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FY2021 Annual Report · Ampol
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Aldermore Group PLC  
Report and Accounts for the  
year ended 30 June 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company Information                                      

Strategic Report 
Strategic overview                                                      
Business Model                                                           
Market Overview 
Financial Highlights                          

Business Review 
Business Finance                                                         
Retail Finance                                                              
MotoNovo Finance                                                             
Central Functions                                                        
Corporate Responsibility 
Section 172 statement                                            
Energy and Carbon Reporting 

Corporate Governance 
Corporate Governance Structure 
Wates principles 
Audit Committee Report                                         
Risk Committee Report                                              
Remuneration Committee Report                        
Directors’ Report          

Risk Management 
The Group’s Approach to Risk                                
Risk Principles                                                               
Risk Management and Internal Control                   
Risk Management Framework                                  
Risk Governance and Oversight                                
Stress Testing                                                               
Principal Risks                                                               
Emerging Risks 
Credit Risk 

Financial Statements 
Statement of Directors’ responsibilities                   
Independent auditor’s report                                    
Consolidated financial statements                            
Notes to the consolidated financial statements     
The Company financial statements                           
Notes to the Company financial statements 

3 

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6 
10 

16 
18 
20 
22 
24 
28 
32 

35 
36 
39 
42 
47 
52 

57  
57 
57 
58 
58 
60 
62 
65 
69 

88 
90 
100 
105 
171 
174 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Company Information 

Non-Executive Directors 

Pat Butler  
Richard Banks – Appointed 1 September 2020 
Desmond Crowley 
Danuta Gray – Resigned on 31 March 2021 
John Hitchins 
Harry Kellan 
Romy Murray – Appointed 1 August 2021 
Alan Pullinger 
Peter Shaw – Resigned on 30 September 2020 
Cathy Turner  

Executive Directors 

Steven Cooper – Appointed 10 May 2021 
Claire Cordell  
Phillip Monks – Resigned on 7 May 2021 
Christine Palmer – Resigned on 31 July 2020 

Secretary and Registered Office 

Kerryn Bodell 
Aldermore Bank PLC  
4th Floor, Block D  
Apex Plaza, Forbury Road  
Reading  
Berkshire 
RG1 1AX 

Independent Auditor 

Deloitte LLP 
Hill House 
1 Little New Street 
London 
EC4A 3TR  

Company number: 06764335 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                
  
 
 
 
 
 
 
 
 
  
 
 
 
 
 
                              
 
 
 
 
 
 
 
 
 
 
 
Strategic Report 

Strategic Overview 

Aldermore backs  people to fulfil  life’s  hopes and dreams. We  champion equality by  supporting the  exceptions  to the  rule and 

getting  finance  to  where  needed  by  lending  the  money  people  save  with  us,  to  people  who  want  to  get  on  in  life;  building 

businesses, buying property and purchasing vehicles.  The Aldermore Group (“the Group”) consists of two operating companies, 

Aldermore Bank PLC  and MotoNovo  Finance  Limited.   Aldermore  Bank provides  finance to  business owners, homeowners and 

landlords,  and  supports  savers.  MotoNovo  Finance  helps  people  buy  their  next  car,  van  or  motorcycle.  The  Group  operates 

exclusively online, by phone and through networks. 

Aldermore Group is part of FirstRand Group, the largest financial services group in Africa by market capitalisation.  

Continued progress and milestones  

Aldermore Group’s results reflect a resilient performance despite the continued uncertain economic environment with a profit 

before tax of £157.8m (30 June 2020: £48.8m) and a CET1 ratio of 13.9% (30 June 2020: 13.3%). Net lending to customers grew by 

8% to £13.4bn (30 June 2020: £12.4bn) with total customer deposits increasing by 14% to £12.4bn (30 June 2020: £10.9bn). See 

page 11 for further details. We are now backing even more customers than ever before with an increase in customer numbers to 

over 650,000 (30 June 2020: 490,000); delivering strong average customer performance ratings of 4.6 on Trustpilot for Aldermore 
Bank and a Net Promoter Score (“NPS”) score of +70 for MotoNovo Finance.  

Strong leadership  

On 10 May 2021, Steven Cooper replaced Aldermore’s founding CEO, Phillip Monks, following his decision to retire. Steven was 
previously CEO at C. Hoare & Co for two years having spent 30 years at Barclays. Steven is Chairman of Experian UK and a Non-
Executive Director of the global recruitment company Robert Walters PLC. He is also the outgoing Joint Chair of the Social Mobility 
Commission  (a  non-departmental  public  body  sponsored  by  the  Cabinet  Office),  promoting  and  monitoring  progress  towards 
improving social mobility in the UK. 

The Group Board currently comprises of ten Directors, of which two are Executive Directors and eight are Non-Executive Directors. 
During the year, Peter Shaw and Danuta Grey retired from the Board and Richard Banks joined the Board as an independent Non-
Executive Director and became the Chair of the Board Risk Committee. Richard has 40 years of experience in banking and financial 
services including as former Chief Executive of UK Asset Resolution Ltd. On Danuta’s retirement, Desmond Crowley was appointed 
the Senior Independent Non-Executive Director. 

More recently in August 2021, Romy Murray joined the Board as an independent Non-Executive Director. Romy is currently a Non-
Executive Director at Nomura Bank International. In addition, the Group has also created a new Board Apprentice role as a means 
of strengthening the pipeline of diverse non-executive talent for UK PLC. Nicolina Andall joined as a Board Apprentice on the 1 
August  2021  and  will  attend  as  an  observer.  She  is  currently  Senior  Corporate  Counsel  for  Atlas  Copco,  a  global  engineering 
company.  

A number of changes were also made to the leadership team during the period. Andrew Lewis joined as the Chief Risk Officer in 
November 2020. Karl Werner, previously the Deputy CEO of MotoNovo Finance stepped up to become Managing Director of the 
business following Mark Standish’s decision to leave the Group.  In addition, Louise Rogerson, previously Director of HR has become 
Interim Chief People Officer, following Rob Divall’s announcement that he will leave the business after five years. Finally, Zish Khan, 
our Chief Operating Officer is going to focus on the Group’s future strategic development, and lead specifically on technology, 
change and data.  We have therefore welcomed Will Swain to the Executive Committee as our Interim Operations Director. 

4 

 
 
Business Model  

Aldermore Group operates across three customer facing divisions: Business Finance, Retail Finance, and Motor Finance, lending in 
areas of the UK financial market which are chosen specifically to align to the business strategy and for their size, attractive returns 
and strong collateral characteristics. Business Finance consists of Asset Finance, Invoice Finance and SME Commercial Mortgages. 
Retail Finance offers Residential Owner Occupied Mortgages that support borrowers with non-traditional income flows and those 
with complicated credit histories, and Buy to Let mortgages that support all landlords from a first time investor to large portfolio 
landlords, alongside providing options for the growing Ltd Company segment. Our savings proposition often features in best buy 
tables and has received a Which? Recommended Savings Accounts Provider accolade for the last two years. Motor Finance trades 
as MotoNovo Finance and works with nearly 2,500 dealerships across the UK as well as operating a vehicle buying and financing 
website, findandfundmycar.com, that has 2,200 dealerships and over 116,000 cars registered. Lending is primarily funded by retail 
and business customer savings, with the balance coming principally from wholesale markets. 

The Group’s success  is spearheaded by operating  continually high levels of  customer  service to our intermediary partners and 
direct customers. This is demonstrated by Aldermore’s and MotoNovo Finance’s consistently high NPS. Supporting this excellent 
customer service are back-office systems that allow our specialist mortgage and business finance underwriters to make informed 
lending decisions, as well as an efficient system within MotoNovo Finance for automatically processing vehicle finance applications. 
The Group’s combined expertise manages risk across our diversified portfolio with this robust approach to risk extending to our 
prudent management of capital and liquidity. 

5 

 
Market Overview  

Macroeconomy  

There has been continued significant macroeconomic uncertainty over the last year, driven primarily by the impact of the Covid-
19 pandemic. Periods of lockdown restrictions imposed at the end of 2020 and beginning of 2021 caused significant disruption to 
the  economy.  During  the  period,  the  Government  has  continued  to  extend  a  range  of  measures  to  support  businesses  and 
individuals, including the Bounce Back Loan Scheme (“BBLS”), Coronavirus Business Interruption Loan Scheme (“CBILS”) and Job 
Retention  Scheme.  It  has  also  introduced  new  initiatives  including  the  Recovery  Loan  Scheme  and  has  supported  the  housing 
market through the extension of the Stamp Duty Relief Scheme. The Bank of England has kept the UK base rate at 10bps since the 
last adjustment in March 2020. Recent inflation figures have shown uncertainty in the economy with June 2021 recording 2.5%, 
exceeding the Bank of England’s 2% inflation target, that raised the prospect of what the Monetary Policy Committee describe as 
‘modest tightening’ of monetary policy being needed in due course to cool inflation, such as halting quantitative easing earlier than 
forecast. Whilst inflation is expected to rise further, there was a fall in July 2021 to 2% meaning pressure on the Bank of England 
to calm the economy with higher borrowing costs, has eased somewhat for the time being.  

As  restrictions  have  been  lifted  over  July  and  August,  business  confidence  has  begun  to  return,  and  consumer  spending  has 
increased. However, there are ongoing issues impacting businesses from Covid-19 with many employees having to self-isolate, as 
well as impacts of Brexit with seasonal and other European workers retreating from the UK job market. This has impacted supply 
chains and in particular in the retail and agriculture sectors who traditionally rely on this employee pool.  

The short-term outlook for the economy though is favourable, due to the success of the vaccination programme and the near 
ending of restrictions on 19 July in England, with the rest of the UK easing restrictions in August. A combination of excess savings, 
pent-up demand and a range of Government incentives should assist the UK’s economic recovery. However, there is still a fair 
amount of uncertainty in the economy as Government support schemes come to an end whilst there are likely to be continuing 
Covid-19 impacts such as potential further variants that will impact individuals, families and businesses. Whilst the full impact of 
Brexit on the UK is yet to become clear, the direct impact on the Group is likely to be minimal with the effects being felt more in 
the wider economy.  

A range of data published by the Federation of Small Businesses and BDO1 suggests that business confidence has risen, as firms 
make the most of the easing of lockdown restrictions and high levels of consumer spending. Aldermore Group, with its legacy of 
successfully supporting a range of businesses, is well placed to back SMEs as they recover from the wide-ranging impacts of the 
pandemic.  

Covid-19 

Covid-19  has  had  a  significant  financial  impact  on  the  Group,  predominantly  on  impairments  with  historically  high  levels  of 
provisions held on the balance sheet reflecting the rapidly changing macroeconomic outlook, with increased defaults compared to 
historic levels and the impact of payment breaks. However, despite these challenges Aldermore has delivered a robust performance 
in the financial year with a profit before tax (“PBT”) of £157.8 million (30 June 2020: £48.8 million). The increase in PBT is primarily 
driven  by  an  £80  million  reduction  in  the  annual  impairments  charge  as  the  macroeconomic  outlook  in  the  UK  has  improved 
significantly over the course of the year. This improved outlook has been partly offset by increased non-performing loans (“NPLs”) 
reflecting the Group’s conservative policy of classifying all customers who sought more than six months of payment breaks as stage 
3  within  the expected  credit  losses  (“ECL”).  The majority  of customers  who  have  been  supported  with  a  payment  break  have 
resumed full repayments, but will continue to remain in stage 3 until the end of a probationary period.  

1  BDO - https://www.bdo.co.uk/en-gb/insights/business-trends/business-trends  & FSB - https://www.fsb.org.uk/resources-page/fsb-voice-of-
small-business-index--quarter-1--2021.html 

6 

 
 
 
The Group’s capital and liquidity position has remained robust, with a CET1 ratio at the end of June 2021 of 13.9% (30 June 2020: 
13.3%) reflecting increased profit and the continued utilisation of the capital previously injected to pre-fund MotoNovo Finance 
lending growth, and a liquidity coverage ratio of 453% (30 June 2020 397%). No colleagues were furloughed or made redundant 
as  a  result  of  the  pandemic.  The  Group  continues  to  be  focused  on  supporting  its  customers  and  protecting  its  employees’ 
wellbeing. 

The Group  also  performs  a series of  formal  risk management processes as set out in  the Risk Management Framework, which 
includes assessing Emerging Risks. Unlike our Principal Risks, the suite of Emerging Risks is designed to change on a regular basis 
to reflect the Group’s operating environment. Given Covid-19 is unprecedented, and still evolving, it remains one of the Group’s 
key  emerging risks as  we continue to  monitor  future impacts, including  impacts  on customers, credit risk, operational risk and 
people considerations. More information can be found in the Emerging Risks section on page 65.  

The Group’s response to the Covid-19 pandemic 

Our priorities have been to support our customers and safeguard our colleagues’ wellbeing throughout the Covid-19 pandemic. 
There was very little precedence to the  situation experienced  over the past 18  months and  the  Group  has been  guided  by its 
purpose of backing customers. Almost 57,000 customers have been supported with payment breaks through the pandemic and 
within Business Finance we also provided guidance to SME customers to help them understand the various Government support 
schemes available. 

  Supporting our colleagues 
No colleagues were furloughed and a number of colleagues were retrained to temporarily support customer facing teams as they 
helped our customers with the issues they were facing. As we come out of the pandemic, similar to many other firms, we have also 
made some changes to our ways of working and our office footprint. 

  Blended working 
We  have used  the  experiences  gained  during  Covid-19 to  review  the  future of  how  we work  across  the  organisation.  Blended 
working will therefore become our core way of working across the Group. This will allow us to balance flexibility with security, 
productivity and quality. It will also ensure that we can serve our customers in the way they need, protect our business effectively 
and engage with colleagues on how they want to work in the future. It will empower managers and colleagues to discuss where 
the best location is to perform their role and consider what is best suited to individual work styles, whilst balancing the needs of 
the business. We expect that a good blend on average, will look like 2-3 days in the office each week.  

  Office footprint changes 
As a result of our new ways of working, we took the opportunity to look at our office footprint. We have moved to a smaller serviced 
office with better facilities in Peterborough and we closed our Birmingham office in October 2020. 

We have also moved our London office to be co-located with our parent’s FirstRand London Branch (“FRLB”), to support and align 
with the wider group’s objectives and to provide additional collaboration and flexible space for our colleagues. 

  Backing our SME customers 

In the last year, Aldermore was accredited with the Government-funded CBILS for both asset finance and invoice finance, so we 
could continue to help SMEs during the Covid-19 pandemic. As the CBILS closed, we became accredited for the RLS for both asset 
finance and invoice finance, allowing us to continue to support SMEs with their recovery. As of 30 June 2021, we had provided 
£136m of Government-backed funding to over 800 SME customers. 

In  addition  to  the  financial  support  available,  we  produced  several  guides  for  SME  customers  and  brokers:  our  Covid-19 
Government Support guide, summarising the various funds available to SMEs, was updated on a weekly basis; whilst our People 
and HR guide navigated the breadth of advice on how SMEs and brokers could safeguard and protect their employees through the 
immediate crisis and its recovery phase. 

7 

 
 
 
 
 
Throughout the pandemic, we stayed in touch with our customers and brokers, offering live webinars on financial products and 
also  taking  the  opportunity  to  support   them  on  key  topics  such  as  financial  and  cyber-crime,  HR  guidance  and  support,  and 
vulnerable  customer  training.  Overall,  we  engaged  with  over  1,100  customers  and  brokers  through  over  40  roundtables  and 
webinar sessions across our various product lines. 

We celebrated the resilience of SMEs by producing a dedicated campaign, highlighting their challenges but also their passion and 
adaptability. In September 2020, we launched our ‘Small But Mighty’ campaign, putting a spotlight on people going above and 
beyond to support the businesses they love during the Covid-19 pandemic.  The campaign was a huge success which made national 
headlines and featured on ITV news. The campaign, reaching an audience of 2.6m, generated over 8,000 clicks to our website. 

In addition, to support SMEs with the Brexit transition, we created a dedicated hub highlighting the key steps SMEs had to take to 
prepare themselves for new ways of dealing with the EU, from new trade and customs regulations to employment rules.  

To support businesses and customers during the Covid-19 crisis, the Group offered payment breaks, the outcome of which for 
Aldermore’s Business Finance division is summarised in the data below and a more detailed breakdown can be seen on page 16: 

- 
- 
- 
- 

Total forbearance cases in Business Finance were over 21,000 
Asset Finance: 20,529 agreed forbearance cases with 99.5% resuming full repayment 
Invoice Finance: 83 agreed forbearance cases, of which 98.9% have now resumed full repayment 
SME Commercial Mortgages: 776 agreed forbearance cases, and only 1.9% remaining on some form of payment break 

  Helping our mortgage customers 

The pandemic affected a number of our retail mortgage customers and payment breaks were offered to existing homeowners and 
landlords. Our customer propositions were streamlined, as a number of higher risk products were temporarily withdrawn, as our 
focus was on supporting existing customers. However, we are in the process of widening our customer propositions with a greatly 
increased residential mortgage product range being introduced in the second half of 2021 for greater customer choice. 

In aligning with  the UK  Government’s  Covid-19  response  measures for the finance  sector to  support  mortgage customers,  the 
Group offered forbearance measures, titled “payment breaks”, for mortgages. Below is a summary of Aldermore’s Retail Mortgages 
payment break data. As of June 2021:  

- 

In  total  13,064  Mortgage  customers  have  been  supported  with  a  payment  break.  The  majority  of  customers  have 
resumed full repayment with 96.2% and 97.7% in Owner Occupied and Buy to Let respectively 

  Keeping our motor finance customers and dealers moving 

The Covid-19 pandemic created challenges for consumers and businesses over the last year. MotoNovo Finance reacted quickly to 
support its motor retailers and consumer customers by embracing home-working and new technologies. 

- 
- 

- 

Over 22,300 agreed forbearance cases, and 96.6% of those customers having now resumed full repayment 
Over 2,000 MotoNovo customers have  been supported with  financial assistance  with their stock funding plans  and a 
waiving of fees for online marketing tools 
An automated payment deferral application process was used by 17,877 customers, equating to a total balance of £178 
million 

8 

 
 
 
 
 
 
 
 
 
 
 
 Savings proposition during the crisis 

We took steps to help customers by amending key processes that were affected by Covid-19 related disruption, such as swifter 
early  access  to  fixed  rate  accounts  and  digitalising  our  account  opening  process  when  possible.  As  the  pandemic  progressed, 
pressure on the savings market increased including NS&I’s actions in Autumn 2020 when it introduced market leading rates and 
then reduced them in quick succession, which led to a lot of activity in the market as savers looked at alternative savings platforms. 
In line with the changing economic conditions and to align with business needs for liquidity, Aldermore temporarily removed all 
new  non-Easy Access  accounts  from  sale  to  new  customers.  Rates  on  Easy  Access  Accounts  were reduced  in line  with  market 
conditions but have remained open throughout the crisis to new customers.  As of June 2021, we re-introduced our full fixed rate 
bond and ISA product offerings, giving customers more choice in how they save. 

Outlook  

While  there  has  been  optimistic  progress  in  the  UK’s  vaccination  programme  rollout  and  the  softening  of  social  distancing 
restrictions over the past few months, there remain many unknowns, such as the speed of the global vaccination programme, the 
possibility  of  future  virus  variants  and  the  full  impact  of  Brexit  on  the  UK  economy,  all  leading  to  a  fair  amount  of  current 
uncertainty.  

The Bank of England’s August Monetary Policy Report said that vaccines are helping spending, jobs and incomes recover from the 
Covid-19  impact,  and  the  size  of  the  UK  economy  is  getting  close  to  where  it  was  before  the  pandemic.  However,  while 
unemployment is falling, there are a lower number of people in work than before the pandemic and there remains a fair amount 
of ambiguity on the impact of Government support schemes coming to an end. This continues to suggest we need to be cautious 
in our outlook going forward, as the situation remains volatile and open to change.  

Aldermore’s current assumption is that the UK will have a long U-shaped recovery following the Covid-19 pandemic, this recovery 
has already begun but will gather pace in the next two quarters. It is expected that a full recovery will be slow, with lending activity 
remaining lower than previously observed for the remainder of 2021 and into 2022 as consumers and businesses await a more 
settled economic environment and the return to a degree of employment security. While excess savings, pent-up demand and a 
range of Government incentives will provide a boost in assisting the UK’s economic recovery, we expect confidence to take time 
to return as people remain worried about employment and income security. As Aldermore supports its customers through the 
uncertainty, we are also taking the opportunity to invest in infrastructure and further increase digitisation across the Group.  

Aldermore was born in response to a lack of lending support for SMEs as a result of the 2008 financial crisis. Today, Aldermore has 
an expanded lending range, remains operationally resilient and financially robust and will continue to be there for its customers as 
we progress towards a post-Covid-19 world, as we were before and during the pandemic.  

9 

 
 
 
Financial Highlights 
Financial performance benefits from the improved macroeconomic outlook  

The KPIs presented on this page represent those by which the Group monitors and assesses its performance.  
  Net loans to customers up by 8% to £13.4 billion (2020: £12.4 billion) 
 

Statutory  profit  before  tax  of  £157.8  million  (2020:  £48.8  million)  as  the  annual  impairment  charge  reduced  reflecting  the 
improved outlook 
Underlying Cost/income ratio1 of 56% (2020: 57%) has improved as income growth has offset continued investment and the 
reintroduction of staff bonuses which were not paid in 2020 due to the pandemic. Statutory Cost/income ratio has remained 
stable at 56% (2020: 56%)  
Cost of risk reduced to 40bps (2020: 114bps) despite loan book growth, as a result of a more favourable macroeconomic outlook 
CET1 ratio has increased to 13.9% (2020: 13.3%) due to higher profits and the continued utilisation of the capital injected to 
support MotoNovo Finance growth  
Return on equity improved to 10.9% (2020: 3.1%) as profits recovered 

 

 
 

 

Net Loans (£bn) 

Net Interest Margin (%) 

10.6

12.4

13.4

3.3

3.2

3.4

2019

2020

2021

2019

2020

2021

Statutory profit before tax (£m)1 

Underlying profit before tax (£m)1 

129.6 

48.8 

157.8 

134.3

155.8

45.6

2019

2020

2021

2019

2020

2021

Cost/income ratio (%)1 

Cost of risk (bps) 

52

55

57

56

56

56

2019

2020
Underlying cost/income % Cost/income %

2021

Return on equity1 (RoE) (%) 

CET1 ratio (%)

11.4

10.9

10.8

10.9

2.8

3.1

2019

2020

2021

Underlying RoE %

RoE %

1 Underlying in 2021, 2020 (restated) and 2019 excludes the mark-up on the MotoNovo Finance back book recharge. Underlying in 2019 also excludes integration costs of £5.4 million. See page 
15 for a reconciliation from the alternative profit measure to statutory profit.  

10 

 
 
 
 
 
 
 
 
 
 
 
 
Business Overview  

Aldermore Group operates across three customer facing divisions: Business Finance, Retail Finance, and Motor Finance. Business 
Finance  consists  of  Asset  Finance,  Invoice  Finance  and  SME  Commercial  Mortgages.  Retail  Finance  offers  Residential  Owner 
Occupied mortgages and Buy to Let mortgages, and includes our savings proposition, although from a financial perspective this is 
reported with the rest of the funding base in Central Functions. Motor Finance trades as MotoNovo Finance. 

Summary balance sheet 

Net loans 

Cash and investments 

Intangible assets 

Fixed and other assets 

Total assets 

Customer deposits 

Wholesale funding 

Other liabilities 

Total liabilities 

Ordinary shareholders' equity 

AT1 

Equity 

Total liabilities and equity 

Net loans of £13.4 billion 

30 June 2021 

30 June 2020 

Change 

£m 

£m 

13,420.4 

2,911.0 

15.0 

142.7 

16,489.1 

12,427.4 

2,625.9 

204.6 

12,425.7 

2,712.1 

13.7 

172.1 

15,323.6 

10,886.4 

3,099.3 

229.4 

15,257.9 

14,215.1 

1,123.2 

108.0 

1,231.2 

1,000.5 

108.0 

1,108.5 

16,489.1 

15,323.6 

% 

8 

7 

9 

(17) 

8 

14 

(15) 

(11) 

7 

12 

- 

11 

8 

Net loans have grown by £1.0 billion, or 8% in the year with the growth largely attributable to MotoNovo Finance. 2021 was the second 
full year of MotoNovo trading as part of the Aldermore Group and the book is still growing to maturity, with growth of £1.2 billion in 
the year (2020: £1.4 billion). Retail Mortgages net loans remained flat year on year at £7.3 billion, partly due to management action to 
temporarily withdraw a number of higher LTV products to manage risk appetite and operational resilience throughout the pandemic. 
Business Finance net loans reduced 5% to £3.1 billion (2020: £3.3 billion) as customer activity was subdued for the majority of the year 
as a result of the Covid-19 pandemic. Net loans to customers reached £13.4 billion (2020: £12.4 billion) as the number of customers 
grew 46% mainly due to MotoNovo Finance; excluding MotoNovo Finance, customer lending numbers fell 9%. 

Total assets reached £16.5 billion, an increase of 8% on 2020 (2020: £15.3 billion), including increased cash and investments reflecting 
the prudent liquidity position held at the year end. 

Funding strategy continues to be deposit-led 

Aldermore Group continues to be primarily funded by deposits complemented with wholesale funding carefully managed to meet the 
Group’s cashflow requirements. To support asset growth throughout the year, the customer deposit franchise was actively managed 
and 81% of funding is now in customer deposits (2020: 71%). As such, our loan to deposit ratio has reduced to 108% (2020: 114%). 

Total deposits grew 14% to £12.4 billion (2020: £10.9 billion) with growth in all three deposit franchises. Personal savings increased 
17% to £9.0 billion (2020: £7.7 billion) as the Group launched new products and made tactical price changes to meet market demand 
whilst supporting Group funding and liquidity requirements. Growth in Business savings continued to be more subdued than Personal, 
up 2% in the year to £2.3 billion (2020: £2.2 billion) reflective of market conditions, whilst Corporate Treasury increased 19% to £1.2 
billion as the Group actively grew this book to support funding requirements. 

11 

 
 
 
 
  
 
The Retail Savings franchise has continued to prove resilient throughout the Covid-19 pandemic as highlighted by Personal Savings 
growth and many of our savings products winning industry awards in the year. The Group’s Fixed Rate Business Savings won both 
MoneyComms  and  Moneynet.co.uk  awards,  and  personal  ISAs  were  recognised  as  winners  in  the  respective  MoneyComms  and 
Moneynet.co.uk awards. The Group’s Personal savings franchise became “Which Recommended” in the year and the TrustPilot score 
has increased to 4.6/5 from 4.5/5 last year, reflecting continued high Voice of the Customer (VOC) scores and low levels of complaints. 
A further increase in NPS to +55 (2020: +53) further evidences the strength of brand and customer service in the Savings franchise. 

The  Group’s  wholesale  funding  portfolio  has  been  actively  managed  throughout  the  year  to  support  a  diversified  funding  base. 
Wholesale funding has reduced 15% to £2.6 billion (2020: £3.1 billion) driven primarily by Term Funding Scheme (“TFS”) maturities  
that have partly replaced with TFSME funding in line with expectations, resulting in total Group Term Funding Scheme holdings of £1.3 
billion (2020: £1.7 billion) as at 30 June 2021. During the year securitisation funding increased by 52%, in October 2020 the Group 
issued  its  first  auto  loan  securitisation,  Turbo  9,  totaling  £520  million,  adding  to  the  securitisation  portfolio  which  also  includes 
Residential Mortgage Backed Securities (“RMBS”) and an auto-loan backed Warehouse facility (MotoMore). The Group holds £213.6 
million of Tier 2 debt securities.  

There has been no change to the Group’s Additional Tier 1 (AT1) notes held in the year. Total liabilities and equity have increased 8% 
to £16.5 billion (2020: £15.3 billion), primarily driven by increased deposits. 

Summary income statement 

Interest income 

Interest expense 

Net interest income 

Net fee and other operating income 

Net derivatives expense and gains on disposal of debt securities 

Operating income 

Expenses, depreciation and amortisation 

Share of Profit of Associate 

Impairment losses on loans and advances to customers 

Impairment losses on lease modifications  

Profit before tax 

Tax 

Profit after tax 

Key performance indicators 
Net interest margin % 

Cost/income ratio1 % 

Cost of risk (bps) 

Return on equity1 % 

Year Ended 30 
June 2021 

Year Ended 30 
June 2020 

Change  

£m 

592.5 

(156.1) 

436.4 

34.3 

0.2 

470.9 

(261.7) 

0.7 

(51.3) 

(0.8) 

157.8 

(33.4) 

124.4 

2021 

3.4 

56 

40 

10.9 

£m 

563.8 

(193.3) 

370.5 

49.8 

(8.2) 

412.1 

(232.1) 

0.5 

(120.5) 

(11.2) 

48.8 

(10.2) 

38.6 

% 

5 

19 

18 

(31) 

(102) 

14 

(13) 

(40) 

57 

93 

223 

227 

222 

2020 

Change % 

3.2 

57 

114 

3.1 

0.2 

1 

74 

7.9 

1 Underlying in 2020 (restated) and 2021 excludes the mark-up on the MotoNovo Finance back book recharge. See page 15 for a reconciliation from the alternative 
profit measure to statutory profit. 

12 

 
 
 
 
 
 
Net Interest Income reflects improved funding costs and a change in business mix 

Interest income increased by 5% to £592.5 million (2020: £563.8 million) reflecting loan growth in both the current year and prior year, 
including £1.2 billion of growth in MotoNovo Finance in FY2021. Retail Mortgages and Business Finance interest income was impacted 
by the run-off of existing business being replaced with new business at lower margins due to the current low interest rate environment 
and the temporary withdrawal of higher margin products in Retail Mortgages to manage risk appetite and operational capacity for the 
majority of the year. As such, the gross interest margin has dropped to 4.6% (2020: 4.9%).  

Interest expense fell 19% to £156.1 million (2020: £193.3 million) despite 14% growth in customer deposits as the Group actively 
responded to market demand with a new product launch and carefully managed price changes, in addition to benefitting from the 
impact of lower interest rates. Further benefit was realised through the partial replacement of redeemed TFS with TFSME and the 
Group’s cost of funds reduced 47bps to 1.25% (2020: 1.68%). 

As a result, net interest income grew by 18% to £436.4 million (2020: £370.5 million) and the net interest margin has improved to 3.4% 
(2020: 3.2%). 

Other operating income remains stable 

Net  fee  and  other  operating  income  of  £34.3  million  (2020:  £49.8  million)  includes  £27.1  million (2020:  £42.6  million)  of  income 
received from FRLB in relation to the cost incurred to support the MotoNovo back book operations plus an arm’s length fee for this 
service. For further details see the alternative profit measures section on page 15. Excluding this, net fee and other operating income 
was broadly in line with the prior year at £7.2 million (2020: £7.1 million).  

Net derivatives expense and gains on disposal of debt securities was £0.2 million compared with an £8.1 million fair value loss as a 
result of mark to market movements on our loan portfolio hedging in the prior year. 

Operating Expenses highlight increased investment and staff costs 

Operating expenses of £261.7 million (2020: £232.1 million) include £25.1 million (2020: £39.5 million) of costs in MotoNovo incurred 
in servicing the back book that are recharged to FRLB. The value of the recharge to FRLB will continue to reduce over the coming years 
as  the  back  book  gradually  runs  off.  Excluding  this,  Group  operating  expenses  increased  23%  reflecting  continued  investment  in 
automation and operational resilience which includes the recruitment of 139 colleagues in the year to support increased levels of 
collections  activity.  Additionally,  2021  includes  the  reintroduction  of  staff  bonuses  which  were  not  awarded  in  2020  due  to  the 
pandemic. Excluding bonuses, operating expenses increased 9%. 

As a result, the underlying cost to income ratio, which excludes £25.1 million cost and £2.0 million fee income related to MotoNovo 
back book operations, was 53% (2020: 51%). 

Cost of risk reflects improving macroeconomic outlook whilst maintaining prudent provisions  

Impairment  charges  were  60%  lower  than  the  prior  year  at  £52.1  million  (2020:  £131.7  million).  Throughout  the  year  the 
macroeconomic outlook in the UK has significantly improved and provisions were adjusted to reflect this, particularly in the second 
half of the year as the vaccination programme progressed well and lockdown restrictions eased. Accordingly, the Group recorded a 
£2.8 million impairment charge for the second half of the year, compared to £49.3 million in the first half. Although 98% of customers 
who were granted payment breaks have resumed full repayments, arrears and NPLs remain higher than the historic average. 

13 

 
 
 
 
A  significant  proportion  of  the  increase  in  NPLs  reflects  a  conservative  policy  of  classifying  all  customers  surpassing  6  months  of 
payment breaks as stage 3 within the ECL. As a result, the Group’s NPL coverage ratio 2remains prudent at 22.6% (2020: 20.1%) whilst 
total coverage3 ratio remains broadly flat year on year at 1.4% (2020: 1.3%). Cost of risk reflects the reduced impairment charge at 
40bps (2020: 114bps). Further detail on the Group’s credit risk position can be found on page 69.   

Statutory profit of £157.8 million 

The increase in profit before tax of £109.0 million to £157.8 million is predominantly due to the reduced impairment charge, growth 
in MotoNovo Finance and an improved cost of funds. Consequently, return on equity has risen to 10.9% (2020: 3.1%). 

2 NPL coverage ratio calculated as total stage 3 provisions divided by stage 3 advances. 

3 Total coverage ratio calculated as total provisions divided by total advances 

14 

 
 
Alternative profit measure reconciliation to Statutory Profit 

Alternative profit measure reconciliation to Statutory profit 
Underlying profit before tax 
MotoNovo Finance net back book recharges 

Statutory profit before tax 

Year ended 
30 June 2021 
£m 
155.8 
2.0 

157.8 

Year ended  
30 June 2020 
£m 
45.6 
3.2 

48.8 

These financial statements have been prepared in accordance with International Financial Reporting Standards (“IFRS”). Aspects of the 
results  are  adjusted  for  certain  items,  which  are  described  below,  to  reflect  how  management  assesses  the  Group’s  underlying 
performance without distortions caused by items that are not reflective of the Group’s ongoing business activities. The following items 
have been excluded from underlying profits for the years ended 30 June 2021 and 30 June 2020: 

  MotoNovo Finance back book recharges 

These are the net impact of the recharges (being the arm’s length mark-up on costs incurred) to the FirstRand London 
Branch (“FRLB”) in relation to MotoNovo Finance servicing the MotoNovo Finance backbook business.  

On 5 May 2019, MotoNovo Finance began trading as part of the Aldermore Group with all new MotoNovo Finance lending 
from this date funded via a liquidity facility with Aldermore Bank and reported as part of the Aldermore Group financial 
results. MotoNovo Finance is also responsible for servicing, on behalf of the FRLB, the existing back book of loans which are 
expected  to  run  off  over  the  next  three  to  four  years.  These  outstanding  back  book  loans  are  not  included  within  the 
Aldermore results but remain on the balance sheet of FRLB., reported above as the MotoNovo Finance back book recharges. 
Please see the MotoNovo Finance section of the Business Review for more details on the backbook. 

15 

 
 
 
 
Business Review 

Business Finance 

Highlights 

  Organic origination of £1.3 billion (2020: £1.4 billion) 
  Net lending to customers down 5% to £3.1 billion (2020: £3.3 billion) 
 
 
 
 
  Over 21,000 SME customers supported with payment breaks since the start of the pandemic, with only c.1% remaining 

Segmental profit of £109.1 million (2020: £63.5 million) 
Cost of Risk reduced 154bps to 33bps (2020: 187bps) as the macroeconomic outlook improved 
Provided £136 million of CBILS and RLS lending to over 800 SME customers through Asset Finance and Invoice Finance 
SME Commercial Mortgages broker NPS improved 18 points to +16 in the year (2020: -2) 

on some form of support 

Net loans to customers 

Organic origination 

Operating income 

Administrative expenses 

Impairment losses 

Segmental result 

Net interest margin (%) 

Cost of risk (bps) 

Performance 

Year ended 
30 June 2021 

Year ended 
30 June 2020 

Change 

£m 

3,097.9 

1,256.6 

151.8 

(32.0) 

(10.6) 

109.2 

4.5 

33 

£m 

3,275.7 

1,432.3 

155.7 

(29.4) 

(62.8) 

63.5 

4.5 

187 

% 
(5) 

(12) 

(3) 

(9) 

83 

72 

- 

154 

Business Finance net loans fell 5% to £3.1 billion (2020: £3.3 billion). Originations of £1.3 billion (2020: £1.4 billion) largely reflect 
reduced levels of new lending in Asset Finance. Subdued originations in Asset Finance as a result of lower customer appetite for 
traditional financing products and tightening of credit criteria resulted in net loans reducing 15% in the year to £1.6 billion (2020: 
£1.9  billion),  despite  £102  million  of  CBILS  lent  in  the  year.  Aldermore  opted  to  only  participate  in  CBILS  from  the  range  of 
Government backed lending schemes originally available, and since the closure of these schemes also began offering Recovery 
Loan Scheme lending (RLS). CBILS and RLS were offered through Asset Finance and Invoice Finance. SME Commercial Mortgages 
remained broadly flat on prior year at £1.1 billion (2020: £1.1 billion) as a reduction in Property Development due to Covid-19, was 
partly offset by improved origination levels in Commercial Mortgages which saw continued growth in larger size deals, with the 
average  deal  size  13%  higher  than  the  prior  year.  Invoice  Finance  net  lending  increased  to  £0.4  billion  (2020:  £0.3  billion)  as 
originations grew 24% to £221 million (2020: £178 million) driven by strong performance of core products, returning utilisation 
levels and £34 million CBILS lending.  

Net interest margin was maintained at 4.5% (2020: 4.5%) as a fall in volumes leading to reduced interest income was offset by 
lower  funding costs  resulting  from  the  lower interest  rate  environment.  Administrative  expenses  were  up  9%  to  £32.0 million 
(2020: £29.4 million) primarily relating to the reintroduction of staff bonuses that were not awarded in 2020 due to the pandemic. 
Cost of risk reduced significantly in the year to 33bps (2020: 187bps) largely driven by the improvement in macroeconomic outlook.  

16 

 
 
 
 
 
 
 
Market and Strategy 

The total asset finance market grew 7%4 year on year with the broker market showing substantial growth of 39.9%4 over the same 
period, largely driven by returning customer demand particularly in the new car market. Despite this, Aldermore broker originations 
fell by 20%, mainly due to a management decision to withdraw from sectors most affected by Covid-19, resulting in a fall in the 
Group’s  overall  broker  market  share  to  7.5%5  (2020:  10.4%).  Market  share  was  also  impacted  by  the  Group’s  decision  not  to 
participate in all available Government backed lending schemes, opting to offer only CBILS and RLS to Asset Finance and Invoice 
Finance customers.  However, the Group’s market share has been steadily trending upward since March 2021 as SME appetite 
begins to return. Growth in the broker market remains a key strategic focus and the segmentation of existing broker relationships 
has enabled Asset Finance to concentrate on key relationships, allowing for deeper insights and a more tailored approach. Asset 
Finance broker NPS reduced from +32 to +22 due to impacts of Covid-19 on risk appetite as well as product withdrawals and a 
required shift in focus towards existing customers and forbearance cases. Asset Finance supported over 700 customers with CBILS 
loans. 

The invoice finance market fell 34%6 in the 12 months to March 2021 reflecting the impact of the pandemic on both client turnover 
and utilisation. Over the same period Aldermore’s market share grew from 2.0%6 to 2.5% outperforming the market driven by a 
commitment to increasing presence in the specialist lending business. Market share for the core Invoice Finance business also grew 
and outperformed the market, up to 1.5%6 from 1.3%. £34 million of CBILS was loaned to over 70 Invoice Finance customers and 
following the cessation of CBILS, the Group began offering RLS loans to customers. NPS for Invoice Finance was +70 (2020: +46) 
for  satisfaction  and  +68  (2020:  +55)  for  recommendation,  demonstrating  our  commitment  to  providing  a  strong  service  and 
product offering. 

The SME Commercial Mortgages market contracted 30% year on year, with Aldermore market share declining marginally to 0.9%5 
(2020: 1.0%) driven primarily by Covid-19 disruption. Despite this, pipeline business has started to return, average deal sizes have 
increased to £1.8 million (2020: £1.6 million), and focus has shifted towards new asset classes within more resilient sectors, away 
from lower margin retail markets. The division has also shifted towards new product groups which allow greater opportunity for 
cross-sales between Property Development and Commercial Mortgages. Property Development saw increased sales in H2 2021 
primarily driven by the stamp duty relief scheme deadline. Broker NPS improved to +16 (2020: -2) and Broker satisfaction has also 
improved by +4 to -14 (2020: -18) benefitting from transparent commission rates and improved relationships developed with key 
brokers. Similarly, customer NPS for SME Commercial Mortgages improved to +47 (2020: +21) driven by a reduction in application 
process time and improved customer retention following the re-organisation of the division in the prior year. 

4 FLA Statistics, June 2021 
5 CASS year end 2020 CRE Lending Survey 
6 UK Finance data, March 2021 

17 

 
 
 
Retail Finance 

Highlights 

  Organic origination of £0.8 billion (2020: £1.3 billion) 
  Net lending to customers flat at £7.3 billion (2020: £7.3 billion) 
 
Segmental profit of £138.4 million (2020: £147.1 million) 
 
Cost of Risk at 22bps (2020: 19bps)  
 
Strength of customer service continued to be recognised with NPS remaining high at +52 (2020: +55)  
 
Since the outbreak of the pandemic, the Group has supported 13,000 customers with mortgage payment breaks, with 
over 98% of customers now having resumed full payment 

Net loans to customers 

Organic origination 

Operating income 

Administrative expenses 

Impairment losses 

Segmental result 

Net interest margin (%) 

Cost of risk (bps) 

Performance 

Year ended 
30 June 2021 

Year ended 
30 June 2020 

Change 

£m 

7,295.7 

815.7 

173.6 

(19.1) 

(16.2) 

138.3 

2.4 

22 

£m 

7,326.5 

1,293.3 

175.3 

(15.1) 

(13.1) 

147.1 

2.5 

19 

% 
(0.4) 

(37) 

(1) 

(26) 

(24) 

(6) 

(0.1) 

(3) 

Retail Finance loan balances have remained broadly flat at £7.3 billion (2020: £7.3 billion). Residential Owner Occupied lending 
grew by 3% to £2.14 billion (2020: £2.08 billion) despite originations being almost a third lower than the prior year at £0.5billion 
(2020: £0.7 billion). The reduction in new lending is largely due to the temporary withdrawal of a number of products, particularly 
in the higher LTV range, to manage risk appetite and operational capacity. There was a significant uplift in activity in May and June 
ahead of the stamp duty relief scheme deadline on 30 June 2021 with net lending growth two thirds higher than the prior ten 
months combined. The Buy to Let book reduced 2% in the year to £5.2 billion (2020: £5.3 billion) with subdued activity throughout 
the year as the Group withdrew its higher LTV products and tightened lending criteria, driving originations 47% lower than the 
prior year at £0.3 billion (2020: £0.6 billion). This was partly offset by an improvement in retention as the benefit of investment in 
the loyalty proposition has started to be realised. The investment has enabled the creation of a larger team to focus on customer 
loyalty, allowing for enhanced customer engagement processes as well as improved pricing capability. 

Net interest income of £173.2 million (2020: £176.2 million) reflects the withdrawal of higher yielding products for large parts of 
the year as the gross interest margin reduced 26bps to 3.8% (2020: 4.1%). Gross interest was also affected by maturing loans at 
higher rates being replaced with new lending at lower rates in line with market trends and the underlying interest rate environment. 
This was partly offset by an improved cost of funds which benefitted from the low rate environment resulting in a net interest 
margin  of  2.4%  (2020:  2.5%).  The  increase  in  administrative  expenses  to  £19.1  million  (2020:  £15.1  million)  is  largely  due  to 
increased people costs following the reintroduction of bonus payments in 2021 which were not made in 2020 due to the pandemic. 
Cost of risk increased to 22bps (2020: 19bps) as impairments increased £3 million largely due to an increase in NPLs driven by the 
Group policy to classify all customers exceeding 6 months of payment breaks as stage 3. 

18 

 
 
 
 
 
 
 
 
Market and Strategy  

Both the Residential Owner Occupied and Buy to Let markets have been positively impacted, particularly in the first half of calendar 
year 2021, by the stamp duty relief scheme. Activity in the 6 months to June 2021 is widely reported as exceeding historic records 
for a number of market indicators.  

Within the Residential Owner Occupied market annual originations for 2020 were below 2019 at £197 billion7 (2019: £218 billion), 
and in the five months to May 2021 £103 billion had been originated indicating that 2021 lending could be above 2019. Aldermore 
made a decision to temporarily withdraw a number of products from the market to manage risk appetite and operational capacity 
which has resulted in market share reducing 6bps to 0.19%7 as at May 2021 (May 2020: 0.25%). 

Aldermore’s Buy to Let market share has been affected by similar management actions. Total market originations for 2020 totalled 
£39 billion (2019: £42 billion) and lending in the five months to May 2021 stood at £20 billion, as activity was buoyed by the stamp 
duty relief scheme. Aldermore’s market share stood at 0.63% at May 2021, almost half the level reported for May 2020 (1.3%). 

It is expected that the remainder of the withdrawn products will be relaunched in the coming months, subject to risk appetite and 
operational  capacity.  As  reported  last  year,  the  growth  strategy  of  the  Retail  Finance  business  is  increasingly  focused  on  the 
Residential Owner Occupied market. 

Improving the loyalty proposition remains a key driver of future growth for the Group and investment has continued in this area. 
In the second half of the year an online portal was launched to make it easier for brokers to switch existing Aldermore customers 
to new products and automated valuation models were introduced to value existing customer properties and inform retention 
pricing.  From  an  origination  perspective,  the  focus  is  now  on  increasing  the  speed  and  consistency  of  customer  and  broker 
experience, particularly as part of the application process. This will be achieved via automation of key touchpoints whilst retaining 
our human touch. 

7 UK Finance, May 2021  

19 

 
 
MotoNovo Finance  

Highlights 

  Organic originations of £2.0 billion (2020: £1.7 billion) 
  Net lending to customers at £3.0 billion (2020: £1.8 billion)  
 
Segmental profit of £38.5 million (2020: £33.1 million loss) 
 
Impairment charge of £25.3 million (2020: £55.8 million) reflects improved economic outlook 
 
Covid-19 complaints handling recognised by the industry with multiple awards won 
 
“Excellent” TrustPilot rating maintained and NPS remains strong at +71 (2020: +69) 
  Market leading launch of risk-based pricing proposition, MotoRate, supported strong originations activity 
 

In total over 22,000 customers have been supported with a Covid-19 related payment break, and almost all have resumed 
full repayments 

Net loans to customers 

Organic origination 

Operating income 

Administrative expenses 

Impairment losses 

Segmental profit / (loss) 

Net interest margin (%) 

Cost of risk (bps) 

Performance 

Year ended 
30 June 2021 
£m 

Year ended 
30 June 2020 
£m 

Change 
% 

3026.8 

1991.3 

120.2 

(56.3) 

(25.3) 

38.5 

4.9 

105 

1823.5 

1714.5 

60.7 

(38.0) 

(55.8) 

(33.1) 

5.1 

511 

66 

16 

98 

48 

55 

216 

0.2 

406 

MotoNovo Finance started trading as part of the Aldermore Group on 5 May 2019 and all business written by MotoNovo Finance 
from this date is included within the financial statements of Aldermore Group. Additionally, MotoNovo Finance is responsible for 
servicing the existing MotoNovo Finance backbook business on behalf of the Branch, for which the Branch pay a service fee. 

MotoNovo Finance net loans grew 66% to £3.0 billion (2020: £1.8 billion) in its second year of trading as part of the Aldermore 
Group. Originations reached £2.0 billion for the first time in MotoNovo’s history (2020: £1.7 billion) as the launch in June 2020 of 
the Group’s risk base pricing tool, MotoRate, meant MotoNovo was well positioned to support pent-up demand in the car market 
following the first UK lockdown. Operational resilience measures implemented to ensure both collections and sales activity could 
be efficiently deployed also enabled high volumes of new lending to be processed during this time. 

Operating  income  almost  doubled  to  £120.2  million  (2020:  £60.7  million)  reflecting  a  more  mature  loan  book  as  well  as  the 
significant origination activity, particularly in the first half. Net interest margin is slightly below the prior year at 4.9% (2020: 5.1%) 
due to a combination of lower market rates in the current environment and the impact of slightly lower margin but better credit 
quality  business  written  in  the  year  which  was  partly  facilitated  by  the  introduction  of  MotoRate  providing  improved  pricing 
capability. 

Administrative  expenses  of  £56.3  million  (2020:  £38.0  million)  exclude  £25.1  million  (2020:  £39.5  million)  of  cost  incurred  in 
servicing the MotoNovo Finance backbook business which is recharged to FRLB. Operating Income presented above excludes the 
corresponding  income  received  from  FRLB  but  includes  the  8%  arm’s  length  mark-up  of  £2.0  million  (2020:  £3.2 million).  The 
increase in administrative expenses includes investment in digitalisation and automation, as well as increased people costs largely 
driven  by  the  reintroduction  of  staff  bonuses  that were  not  awarded  in  2020  due  to  the  pandemic.    Cost  of  Risk  has  reduced 
materially to 105bps (2020: 511bps) reflecting an impairment charge of £25.3 million (2020: £55.8 million). 

20 

 
 
 
 
 
The  more  favourable  macroeconomic  outlook  in  recent  months  as  well  as  an  improved  outlook  for  the  used  car  market  and 
associated vehicle valuations has driven the reduction. 

Market and Strategy 

New car registrations in the first half of 2021 have seen a significant increase on the prior year with registrations 39.2%8 ahead of 
the same period in 2020. The underlying statistics point to a marked shift in consumer behaviour, with diesel registrations down 
21.7%  and  battery  powered  electric  vehicles  almost  doubling  to  8.6%, albeit  remaining  a  relatively  low  proportion.  There  was 
concern in the market that used car prices would be deflated as a result of Covid-19, however, actual performance has been to the 
contrary as prices have increased 13.9%9 in the year to June 2021 and as of July 2021, prices have exceeded pre-Covid-19 levels. 
The used car market has been boosted by sustained periods of pent-up demand following lockdowns, with demand outstripping 
supply on occasion. MotoNovo Finance achieved record levels of origination in the financial year as a result. 

In June 2020, MotoNovo Finance launched MotoRate, its risk-based pricing proposition, and was the first in the industry to do so. 
MotoRate was gradually rolled out over the course of the first half of the financial year and the success of the roll-out enabled 
MotoNovo Finance to service higher levels of demand in this period and throughout the rest of the year.  

As well as offering payment breaks to customers, MotoNovo Finance also provided specialised forbearance support to dealers. 
Depending  on  the  terms  of  the  relationship  with  each  specific  dealer this  included  mechanisms  such  as  deferring  commission 
recovery and capital repayments, making temporary adjustments to interest rates and extending the tenure of funding for funded 
dealers during periods of closure or low business. 

The Group issued its first auto securitisation in 2021, utilising the MotoNovo Finance loan book to support Group funding needs. 
Turbo 9 was the first UK auto securitisation since the Covid-19 pandemic began and was the largest deal of its kind in 2020. 

MotoNovo Finance holds a 17% share (2020: 18%)  of the used car finance market based on new  business origination with the 
majority gained through its affiliated dealer network and supported by findandfundmycar.com which has 2,200 connected dealers 
and over 116,000 live vehicles as at the end of June 2021. The slight reduction in market share is due to the utilisation of MotoRate 
and increase in PCP volumes being written, both of which allow for improved pricing for better credit quality customers reducing 
the volume of lower credit quality business written. As evidenced by an NPS of +71 and “Excellent” TrustPilot rating, customer 
satisfaction remains high. MotoNovo Finance was also awarded Finance Provider of the Year at the Motor Trader Independent 
Dealer Awards and Best Independent Lender (Bank Owned) at the Car Finance Awards. 

8 SMMT Car Registration 
9 CAP HPI Black book 

21 

 
 
Central Functions  

Savings, Treasury and Support Functions 

Highlights 

Personal deposits up 17% to £9.0 billion (2020: £7.7 billion) 
SME deposits up 2% to £2.3 billion (2020: £2.2 billion) 
Corporate deposits up 19% to £1.2 billion (2020: £1.0 billion) 

 
 
 
  Which Recommended provider of Savings accounts and “Excellent” TrustPilot rating 
  Winner of moneynet.co.uk Best Fixed Rate ISA Provider in 2020 for the 4th year running 

Segmental result 

Operating loss 

Underlying administrative expenses 

Segmental loss 

Retail deposits 

SME deposits  

Corporate deposits  

Year ended 
 30 June 2021 

Year ended 
 30 June 2020 

Change 

£m 

(0.3) 

(127.9) 

(128.2) 

9,009.2 

2,263.0 

1,155.1 

£m 

(19.1) 

(109.6) 

(128.7) 

7,701.1 

2,210.7 

974.6 

% 
98 

(17) 

0.4 

17 

2 

19 

Central  Functions  include  Aldermore Group’s  Treasury  function  and  Savings businesses,  as  well  as  Aldermore’s  common  costs 
which  are  not  directly  attributable  to  the  operating  segments.  Common  costs  include  central  support  function  costs  such  as 
Finance, IT, Legal and Compliance, Risk and Human Resources.  

Performance 

Operating loss includes net interest income and net fees and other income that is not recharged to the business segments. Net 
interest income  predominantly includes  the interest  expense relating  to the  Tier 2 Notes.  Net  fees and other income  includes 
income or expense arising from derivatives held at fair value in hedging relationships, net expense or income from derivatives not 
currently recognised as being in hedging relationships and gains or losses on disposals of debt securities. This year includes a fair 
value loss of £0.5 million as a result of mark to market movements on the Group’s loan portfolio hedging (2020: £8.1 million loss). 

Central  administrative  expenses  increased  18%  to  £128.9  million  (2020:  £109.6  million)  reflecting  continued  investment  in 
digitalisation and operational resilience and the reintroduction of staff bonuses which were not awarded in 2020 due to Covid-19. 

The segmental loss of £128.2 million (2020: £128.7 million loss) also includes £0.7 million share of profit of associate (2020: £0.5 
million). 

Market and Strategy 

The UK savings market  continued to  experience strong growth in  in the 12  months to  June 2021 albeit slightly lower than the 
previous 12 months at 9%10 (2020: 11%). Consumers continued to build cash reserves even as lockdown restrictions were eased 
throughout the year and particularly through the winter lockdown. The UK Household Savings ratio reached historic highs during 
lockdown periods despite the decline in economic activity as consumers had less opportunity to spend and Government support 
measures were enacted. During this period 6 million “accidental savers” were created further boosting the UK savings market.  

10 Bank of England 

22 

 
 
 
 
 
 
A significant amount of this new money was retained in current accounts, whilst the growth in savings account balances weighed 
more  to  Non-Maturing  Deposits,  against  a  decline  in  Fixed  Rate  savings  where  traditionally  challenger  banks  have  competed 
strongly. This has created an active and buoyant market in short term fixed tenors and Non-Maturing Deposits as there is a strong 
customer appetite for access to funds amid the economic uncertainty.  

The  Business  savings  market  has  also  remained  resilient during the pandemic,  in  part  supported  by  Government stimulus  and 
furlough schemes. In a less competitive market dominated by the incumbent high street banks, challenger banks continue to offer 
reasonable rates for business savings accounts, with balances increasing year-on-year and the market remaining stable even as 
Government support schemes are gradually unwound. 

Although the Bank of England base rate remains at a record low of 0.10%, competition in the market has been high, particularly 
towards the end of the financial year with challenger banks leading the way with competitive rate changes. Given the inherent 
uncertainty  in  the  market,  for  the  second  year  running  there  were  relatively  few  new  entrants  to  the  market.  Despite  the 
challenging environment, Aldermore saw a small increase in Personal savings market share to 0.65% (2020: 0.59%), whilst Business 
savings slightly reduced to 0.59% (2020: 0.64%). 

23 

 
 
Corporate Responsibility  

The Aldermore Group’s purpose is to back people to fulfil life’s hopes and dreams. Through our business approach, the Group 
backs customers, local communities and its own people through life’s events. We know it is important to do this responsibly and 
in  collaboration  with  our  stakeholders.  A  business  cannot  deliver  sustainable  long-term  returns  without  considering  its  wider 
impact on society.  

Environmental, Social and Governance  

 Environment and Climate Change 

Aldermore recognises climate change as a defining issue, with potentially far-reaching impacts for our customers, colleagues and 
communities. This is a challenge that requires action in this decade, and we consider this a strategic risk that cuts across other 
risk types – such as credit risk and operational risk. To address this, we are developing a comprehensive action plan. Through 
this, we are progressing a range of activities to better understand the impacts of our business on the climate, the impacts of 
climate  change  on  our  customers,  our  portfolios  and  business  resilience  and  to  build  and  enhance  our  capabilities  for  the 
identification, management, monitoring and disclosure of climate risks and opportunities. Further information on our developing 
approach to climate change is provided alongside our annual operational emissions in our Energy and Carbon Report on page 
32.  

 Levelling Up https://www.levellingupgoals.org/  

Aldermore  is  playing  a  key  role  in  a  parliamentary  cross-party  backed  initiative  that  has  been  supported  by  a  coalition  of 
businesses, NHS Trusts, Councils and Universities committed to driving ‘levelling up’ on the ground in the UK. We are sponsoring 
Goal 7 (out of 14) that aims to ‘Widen access to savings and responsible credit’. Our work involves developing benchmark metrics 
for  Government,  businesses  and  other  organisations  to  strive  to  achieve  making  ‘levelling  up’  a  reality  and  define  what 
improvement looks like in an empirical way. Aldermore will also be involved in shaping the broader framework and agenda that 
will inform a wider reporting standard.  

This  work  builds  on  Aldermore's  best  practice  to  date,  representing  a  powerful  shift  away  from  traditional  corporate  social 
responsibility and towards real purpose-led business, focused on making genuine impact for colleagues and communities. The 
‘Levelling Up’ Goals are setting a new bar for reporting on the 'S' in ESG with a new national standard of reporting, reflecting 
society's wider expectations of organisations post Covid-19. 

 Tax   

Tax is one of the ways in which the Aldermore Group contributes to the societies in which it operates. We seek to pay the right 
amount of tax at the right time and to maintain the Group’s reputation as a fair contributor to the UK economy. Appropriate, 
prudent  and  transparent  tax  behaviour  is  a  key  component  of  corporate  responsibility.  We  comply  with  the  HMRC  Code  of 
Practice on Taxation for Banks and aim to have constructive and professional relationships with the tax authorities. We actively 
support and work with tax authorities to combat tax evasion. We do not interpret tax laws in a way that we believe is contrary 
to the intention of Parliament. We apply tax rules in good faith and in the spirit they are intended. We aim to ensure that our tax 
returns are filed on time. 

Our annual tax strategy aligns with the principles set out in our tax risk management framework implemented through our tax 
risk  management  policy.  The  tax  strategy  and  risk  management  objectives  are  reviewed  and  approved  by  the  Board.  These 
objectives reflect our open and transparent approach to our tax obligations and are also reflected in the products and services 
we offer to our customers. 

24 

 
 
 
 
Our people 

Aldermore’s key strength is its people, and it is through them that we back our customers and continue to succeed. Recognising, 
valuing, and  rewarding  their contribution  is central to our philosophy. Therefore,  Aldermore has  continued to place significant 
focus on building a great place to work, including how we encourage inclusion and belonging in our workplace.  

During the past year, Aldermore has taken a range of steps to ensure that its employees are regularly provided with information 
and guidance on matters of concern to them, which has been even more important during the Covid-19 crisis. Examples include: 

Intranet articles to share best practice, colleague hints and tips, and lockdown experiences 
Established a CEO town hall programme and holding regular CEO all-colleague briefings 

  Weekly and monthly Groupwide colleague newsletters 
 
 
  Weekly well-being and mindfulness sessions 
  Manager Mondays aimed at our people managers and addressing the key challenges they face in the new virtual working 

environment 

Employees are regularly asked for their views on a range of issues, activities include: 

  Quarterly employee ‘pulse surveys’ 
  Well-being surveys 
 

Colleague focus groups  

Aldermore also makes all colleagues aware of the financial performance and economic factors affecting the Group by ensuring 
they are briefed on a half-yearly basis when we publish our results. This is delivered in a multi-channel approach to ensure that the 
information is provided in a format which colleagues value. 

1.  Workplace diversity  

Inclusion and belonging are important to Aldermore and is a standing item on its monthly Executive Committee (“ExCo”) agenda, 
to  give  it  the  importance  and  visibility  it  deserves.  Through  our  colleague  network,  Inclusion@Aldermore  and  our  ‘Value  our 
Differences’ agenda, we discuss and work on plans to ensure our approach is understood and developed.  We cover all aspects 
including  age,  gender, ethnicity, religion  and  belief,  sexual  orientation,  disability,  mental  health  awareness,  social  mobility and 
more. Key workstreams are accountable to an ExCo sponsor, and are committed to the delivery of practical and implementable 
solutions:  

 Inspiring  Future  Female  Leaders  (“IFFL”)  –  focus  on  female  specific  development  to  ensure  we  are  recruiting,  encouraging, 
empowering and elevating female talent. Following the launch of the Aldermore Female Network, founded by members of the 
IFFL  workstream,  the  network  has  now  attracted  over  350  members  from  across  the  Group  and  is  continuing  to  grow.  We 
launched  the  pilot  of  our  new  flagship  development  programme:  ‘Leadership  Summit’  facilitated  by  diversity  and  inclusion 
experts,  The  Pipeline,  with  25  women  within  the  business.  We  also  introduced  our  ‘Leading  Diverse  Teams’  programme  for 
managers to support them in developing more inclusive teams.  

 BAME – building mentoring and networking opportunities to help our BAME colleagues thrive. On 16 February 2021, the Board 
agreed to the adoption of the Parker Review recommendations and our D&I policy has been updated to reflect this. Having signed 
up to the Race at Work Charter, we have achieved some significant milestones, in particular, on the principle of taking action 
that supports ethnic minority career progression. One of the key hurdles for joining the Race at Work Charter is the principle of 
the Group capturing ethnicity data and publicising progress. To improve this, we have undertaken a number of campaigns to 
encourage this data to be completed by colleagues and a wider discussion on how we approach this is key to our success. 

 Mental  Health  –  building  on  the  good  work  to  date  supporting  colleagues  with  ‘Wellbeing  Wednesday’  webinars  and  a 
programme of events for Mental Health Awareness Week. In May 2021, the organisation signed the Mindful Business Charter, 
which promotes better mental health and wellbeing in the workplace via a set of key principles. Going forward the workstream 
will be looking at how we can ensure all the principles from this charter play into our business on a more permanent basis. We 
participated in mental health charity Mind’s Workplace Wellbeing Index to broaden our understanding of mental health matters 
in the workplace.  As a result, we were delighted to be awarded a Mind Silver accreditation in our first year of participation. 

25 

 
 
 
 
 
 LGBTQ+ – we have looked to help better support our LGBTQ+ colleagues through the creation of employee networks, inclusive 
policies  and  events  to  increase  awareness  and  engagement. The  workstream has been  undertaking  a  policy  review  that  has 
included  implementing  measures  such  as  a  ‘Transitioning  at  Work’  policy.  A  number  of  events  have  been  held  to  increase 
awareness and  understanding such as  a conversation with  leading LGBTQ+ campaigner Baroness  Liz Barker in celebration  of 
LGBTQ+ History Month; a series of events to celebrate Pride Month in June 2021, including a panel discussion with colleagues 
from the LGBTQ+ network and their allies as well as a jointly hosted session on LGBTQ+ Allyship with CEO Steven Cooper and 
Susan Allen, CEO of Retail & Business Banking at Santander, who is the lead sponsor of Santander’s Embrace LGBTQ+ network. 

Mentoring 

Again, this year we participated in the world-leading, cross-company, cross-sector mentoring programme led by Moving Ahead.  
The ‘30% Club’ focusses on gender diversity in order to build and strengthen necessary pipelines and achieve parity of women in 
leadership and board roles.  We supported 40 mentoring partnerships, split between two initiatives over a period of nine months. 
The programme is part of our Inspiring Future Female Leaders and BAME workstreams within our overall diversity and inclusion 
approach. 

Aldermore  is  committed  to equal  opportunities  for all  of  its  people,  irrespective  of  gender,  race,  colour,  age, disability,  sexual 
orientation, or marital or civil partner status. 

2. Our Culture 

We are creating a continuous improvement culture where we think differently and put our customers and our colleagues at the 
heart  of  our  decisions.  We  have  made  some  recent  changes  to  our  cultural  approach  including  moving  away  from  an  annual 
engagement survey to more regular, timely pulse surveys (including external surveys by Mind, the mental health charity) and from 
June 2021, we have established a dedicated and focused cultural taskforce (12 culture change agents with sponsorship from ExCo). 
The cultural champions will support our cultural initiatives across the Group including bringing our Colleague Value Proposition to 
life, embedding it and hence helping to shift our culture.  

Impact of Covid-19 

During the past 18 months our colleague engagement and surveys have focused very much on our colleague’s wellbeing, mental 
health and the support they need. After our Wellbeing Pulse Survey in January 2021, we have implemented a number of actions 
as a result:  

  Meeting-free Wednesday afternoons – from a Group-wide perspective, we have implemented a meeting-free afternoon, 

every Wednesday 

In addition, we are continuing to encourage: 

 

‘Walk and talks’ – to reduce screen time to colleagues the time to exercise and get some fresh air during their working 
day 

  Wellbeing Wednesdays – a series of wellbeing events for colleagues to provide a much-needed source of community and 

respite 

3. We support the professional development and recognition of our people 

In 2020, we launched our Colleague Value Proposition (“CVP”).  It is a set of benefits and rewards we offer our colleagues in 
return for the skills, capabilities and performance they bring to Aldermore. It focuses on backing colleagues to bring their best: 

  We value our inclusive culture, where we empower everyone to bring their best and be their true selves.   
  We value our progressive culture, where we empower everyone to make a real contribution to our business. 
  We are driven to put our customers and colleagues’ needs at the heart of everything we do. 
 
A culture where we strive for continuous improvement and doing things differently.  

26 

 
 
 
 
As part of the CVP work to date: 

  We developed our cultural vision and identified the cultural shifts that we need to make. 
 
  We are now looking to embed our CVP in the ‘moments that matter’ across the colleague lifecycle and create a consistent 

All our leaders have been a series of sessions on leading through the CVP. 

colleague experience across the Group. 

  We are currently building a manager development programme to build awareness and capability in embedding the CVP and 

the role they play in its delivery and success. 

Our employee statistics for June 2021 and June 2020: 

Number of Group employees 

Number of Group female employees 

% of Group female employees 

June 2021 

June 2020 

2,029 

944 

46% 

1,966 

865 

44% 

As at 30 June 2021, two out of ten Directors were female (2020: three out of 11 were female), and nine out of 39 Senior Managers 
were female (2020: 9 out of 42 were female).  

Below are also some examples of employee trends the Aldermore Group has recorded during the financial year: 

  Our Group Employee Net Promotor Score (“eNPS”) is currently +39 for recommending Aldermore as place to work 
 

Glass door rating (out of 5) 3.6 Aldermore Bank, 4.2 MotoNovo Finance 

 

Employee turnover was 14.7% 

Our communities  

The SMEs, landlords, homeowners, savers and vehicle owners that work with Aldermore, in turn support the communities in which 
they live and work. We understand that we have a responsibility to be part of these communities.   

Playing our part as a responsible member of the banking community 

 
 
 
 
 

Actively involved with industry bodies including UK Finance, the FLA, and IMLA   
A member of the Banking Standards Board 
A signatory of the Women in Finance Charter 
A signatory of the Race to Work Charter 
A signatory of  the Mindful Business Charter  

We give back to the communities where we operate 

The Group  selects  a  charity  of  the  year  that  are  nominated  and  voted  for  by  employees.  Since  September  2020,  Aldermore’s 
chosen charity has been Macmillan Cancer Support with colleagues raising more than £19,000.  Macmillan Cancer Support is a 
national charity which offers information, advice and resources to people living with cancer.  In addition, following the racist abuse 
suffered by a number of England football players during the Euro Championships, that has wider implications for racism in sport 
and the wider society, Aldermore Group wanted to demonstrate our support for those affected by making a donation of £5,000 to 
each of the following charities:  

 
Show Racism The Red Card 
 
FareShare 
  Making The Leap 

27 

 
 
 
 
 
 
The Group also operates an employee £ for £ charity matching scheme.  Many employees raise funds for their charity of choice 
and the Group supports  them  by matching up to £250 of money raised. This year the  Group has paid  over £22,000 to various 
charities under this scheme through colleague and dealership matched funding. 

Human Rights and Modern Slavery Act 

Aldermore Group PLC, and its principal operating subsidiaries, Aldermore Bank PLC and MotoNovo Finance Limited, take a zero-
tolerance approach to slavery and human trafficking. 

As a UK group with a growing number of international suppliers, the Aldermore Group recognises that there is a risk, however 
small, for slavery or human trafficking to occur in its supply chains. 

The  Group  has  taken  appropriate  steps  to  ensure  that  slavery  or  human  trafficking  is  not  taking  place  in  its  supply  chains  by 
reviewing  its existing business  and supply chains; reviewing  and revising its  procurement processes; changing its  due diligence 
processes; conducting a risk assessment with due regard to the sector and geographical locations in which its suppliers operate 
and disseminating relevant information through its businesses by means of its procurement and due diligence processes to ensure 
Group wide awareness of the risks of slavery and human trafficking in supply chains. 

As part of its supplier on-boarding process, Aldermore engages with its suppliers to seek assurances about their anti-slavery and 
human trafficking policies and whether they are taking steps to prevent slavery and human trafficking in their respective business 
and supply chains. Aldermore will not support or engage suppliers where it is aware of slavery or human trafficking in such suppliers' 
businesses or supply chains. 

In addition, Aldermore uses new supplier due diligence documentation to include confirmations from suppliers on anti-slavery and 
human trafficking compliance. 

Anti-Bribery  

The  Group  has  an  Anti-Bribery  and  Corruption  Policy  which  applies  to  all  Directors,  employees, contractors  and  third  party 
outsource providers, which is reviewed annually  by the Board  to ensure it is fit for purpose. The Group promotes  a culture of 
awareness and understanding at all levels and mandatory training is provided. 

Section 172 Statement 

This section of the Strategic Report describes how our Directors have had regard to the matters set out in section 172 (1) (a) to (f) 
of the Companies Act 2006. 

Directors must act in the way they consider, in good faith, would be most likely to promote the success of the Company for the 
benefit of its members as a whole, and in doing so have regard (amongst other matters) to: 

 
 
 
 
 
 

the likely consequences of any decision in the long term; 
the interests of the Company's employees; 
the need to foster the Company's business relationships with suppliers, customers and others; 
the impact of the Company's operations on the community and the environment; 
the desirability of the Company maintaining a reputation for high standards of business conduct; and 
the need to act fairly as between members of the Company. 

The Directors recognise that having regard for these matters through effective stakeholder engagement is crucial in shaping and 
working towards shared goals which deliver long-term sustainable success. The Board balances the competing priorities of the 
Company’s various stakeholders by considering the long-term implications of its decisions. This includes considering policies and 
decision making made by the shareholder which the Group is required to implement. The Board engages directly with stakeholders 
and also indirectly through reporting from the Executive team. Details of how our Directors have engaged with the Company’s 
stakeholders during the year are set out below. 

Decisions  affecting  stakeholders  of  the  Company’s  subsidiaries  are  made  by  the  Board  where  matters  are  of  Group-wide 
significance, or have the potential to impact the reputation of the Group, with directors of each company in the Group ensuring 
that they meet their duties to their respective companies. 

28 

 
 
 
Covid-19 impact 

The global Covid-19 pandemic continued to present numerous challenges for our customers, colleagues, distribution partners and 
suppliers. As a result, all of the Group’s markets continued to face significant challenges and all areas of our business were impacted 
and had to respond nimbly. Further details of how Covid-19 affected different aspects of our business and our stakeholders and 
our response can be found on page 6 of the Strategic Report. 

Customers  

The Group’s customers are primarily UK consumers and SMEs, seeking specialist mortgages, savings accounts, motor finance and 
business finance solutions.  Our customers sit at the centre of all decisions made and our long-term sustainable success is only 
possible with a customer-centric business model. Customer impact is therefore critical to the Board’s decisions.   

Following the success of the deep dives that took place during 2020, the Chair commissioned a deep dive into MotoNovo Finance’s 
insurance  products  which  took  place  at  Board  Risk  Committee  level.    The  Risk  Committee  agreed  that  the  insurance  offering 
supported  the  fair  treatment  of  its  customers  as  well  as  supporting  MotoNovo  Finance’s  obligation  to  engage  in  responsible 
business, particularly in the case of its highest risk customers. The Risk Committee welcomed the volume and rigour of processes 
and controls that existed for the distribution and governance of MotoNovo’s insurance products and assured the Board that the 
insurance sales team remuneration scheme had been designed to ensure adherence to the principle of treating customers fairly. 

As part of our Covid-19 response the Board and the Risk Committee discussed and reviewed activities to support customers. The 
Board welcomes the FCA’s consultation on a new Consumer Duty and during the year gave its support to management’s plans for 
development of a customer outcomes framework. During the year, the Board spent time at a number of its meetings carefully 
considering the customer impacts of a risk event involving an inadvertent breach of the Consumer Credit Act, further details of 
which are set out on page 154. The Board carefully considered, challenged and ultimately supported management’s proposals for 
remediation. This included consideration of whether management’s proposals produced fair outcomes for customers and were 
compliant with the FCA’s guidance on motor finance agreements and Covid-19. 

In November 2019 the PRA asked the Internal Audit functions of a sample of non-systemic deposit-takers, including the Group, to 
conduct a review of their Collections functions, in order to provide assurance over the effectiveness of controls in this area to the 
Board  and  to  the  PRA  itself.  This  review  reported  during  the  year  and  the  Board  and  its  Committees  digested  the  findings  at 
numerous meetings and are closely tracking progress against the actions identified. The Board and management team had already 
identified a strategic need to enhance Collections capability prior to the impact of Covid-19 and the resultant increase in arrears 
levels. A number of short-term tactical actions to address current arrears levels, as well as longer-term strategic improvements to 
Collections  capability,  were  progressed  during  the  year.  Tactical  actions  included  applying  additional  rigour  to  the  arrears 
forecasting  process  to  determine  future  resourcing  needs  and  plan  for  any  future  spikes  in  arrears  volumes.  Management 
information in this regard is reviewed at each meeting of the Risk Committee. During the year, the Board supported the creation 
of a Collections Centre of Excellence, bringing together Collections activity for all of the Group’s business areas, in order to deliver 
the best possible customer outcomes. 

People 

Our people are the foundation of our business and underpin our business strategy.  

Our people have been one of the Board’s key priorities throughout the pandemic and the welfare, wellbeing and engagement of 
our employees has remained high on the Board’s agenda. At the start of the pandemic colleagues were moved from our offices to 
working from home and many colleagues were redeployed into customer-facing areas of the business in order to manage increased 
work volumes in those areas. A small number of colleagues have now returned to work on-site under Government guidelines. Our 
robust systems and technology have allowed our colleagues to continue to perform their roles with minimal disruption and to 
serve our customers effectively. At the start of the pandemic, the Board supported management’s decision not to furlough any of 
the Group’s workforce. 

During 2020, the Board considered findings from our participation in the Banking Standard Board’s (“BSB’s”) annual survey, which 
measures  the key elements  of the culture of  member firms. The BSB  is  an independent body  that  promotes high standards  of 
behavior and competence across the UK banking industry. In its review of findings, the Board discussed a decrease in scores against 
the previous year’s survey in respect of resilience, which it attributed to the extraordinary events of the year under review. 

29 

 
  
The  Board  also  interrogated  a  theme  that  emerged  from  the  survey  about  colleagues  finding  it  difficult  to  speak  up,  and 
recommended coaching for people managers on the importance of listening, which the Board sees as fundamental to creating a 
safe space in which colleagues feel able to engage in open and honest conversations. In response to this recommendation bespoke 
sessions were held with all people managers within our business with the aim of developing managers as coaches, helping them 
build vulnerability, empathy and better listening skills.  Feedback from the sessions showed an increase from 24% of managers at 
the start of sessions to 85% at the conclusion feeling equipped to lead for the Covid-19 pandemic.  The Board also welcomes the 
launch of a pilot of a newly developed leadership programme in the new financial year, which will help to drive and embed these 
skills across all managers within the organisation.    

The pandemic impacted the ability of the Board to hold its meetings across various regional offices, meaning that engagement with 
colleagues was not possible in person at those offices.  Our new CEO Steven Cooper visited offices where possible as soon as he 
was able and held several “virtual hello” calls for all colleagues during his first month across the business to share a little about 
himself and his first impressions since joining the Aldermore Group.  We saw great engagement from colleagues and a range of 
questions  for  Steven.  The  Board  has  ensured  that  engagement  has  been  maintained  through  other  means,  such  as  intranet 
communications, blog entries, internal networks, virtual town hall meetings and newsletters. The non-executive members of the 
Board also launched a programme of virtual ‘Meet the Board’ sessions alongside the people team to meet with up-and-coming 
talent, following a review by the Board Corporate Governance and Nomination Committee of the succession and talent pipeline 
for  all  our  senior  roles.  The  programme  has  allowed  the  non-executive  members  of  the  Board  to  better  understand  the  skills 
required to manage the business and assess any risks or potential gaps.  

The Board acknowledges its leadership role, beyond Board composition, to promote the Group’s broader societal responsibility to 
embrace  and  encourage  diversity  and  inclusiveness.  The  Board  has  committed  to  encouraging  people  to  uphold  values  and 
behaviours  that  promote  diversity  and  inclusiveness,  that  ensure  fairness  of  opportunities,  and  that  remove  any  barriers  to 
diversity,  inclusivity  and  fairness  where  they  might  exist,  through  its  governance  processes  and  priorities.  In  reviewing  the 
Company’s Gender Pay Gap and Women in Finance data, the Board discussed performance with respect to gender diversity in 
senior management, which at 23%, was below the target as at 30 June 2021 of 30% female representation. The Board discussed 
and  supported  management’s  initiatives  to increase  momentum in  this  area  and  support  the  career  progression  of  women  in 
Financial Services, welcoming the introduction of milestones that will take the Group beyond the initial 30% and commit the Group 
to actions to achieve 50% representation within 5 years. The Board’s wider diversity discussions have focused on the importance 
of  attracting  and  retaining  a  strong  pipeline  of  diverse  talent,  and  the  need  to  attract  diverse  candidates  to  certain  under-
represented  areas,  such  as  sales  and  distribution.  The  Board  has  recommended  that  management  consider  a  socio-economic 
diversity workstream, as well as considering how to prepare for ethnicity and socio-economic pay gap reporting and looks forward 
to receiving progress reports from management against these recommendations.   The Board supports and endorses the initiatives 
and workstreams within the “Value our Differences” agenda, details of which are set out in the Corporate Responsibility Statement 
on page 24. 

Suppliers and Distribution Partners 

The Board receives regular management information on supplier and distribution partners’ performance, as well as updates at 
each Board meeting from the Chief Operating Officer, who has responsibility for third party oversight arrangements. Both of the 
Group’s  operating  subsidiaries  (MotoNovo  Finance  and  Aldermore  Bank)  are  required  to  report,  twice  a  year,  their  payment 
metrics,  including  the  average  time  taken  to  pay  supplier  invoices,  which  provides  insight  into  their  underlying  payment  and 
procurement processes.  

We proactively reached out to suppliers when the Covid-19 crisis struck, highlighting who they should contact if they had an issue 
and encouraging them to go on-line during the period as we would be able to service their needs in a timelier fashion.  Within the 
6-month period to June 2021, we paid 91% of our suppliers within our pre-agreed credit terms (90% in the 6-month period to 
January 2021), and we continue to settle 99% of all invoices within a 60-day period, showing our ongoing commitment to support 
and engage with our suppliers during the period and most notably during Covid-19.  

During the year, the Board considered the Company’s annual statement setting out the steps taken to prevent modern slavery in 
the  business  and  its  supply  chains.  Further  details  on  the  Group’s  Modern  Slavery  Statement  can  be  found  in  the  Corporate 
Responsibility section on page 28 of the Annual Report and on our website. 

30 

 
 
 
Community and Environment 

As part of our purpose, we feel strongly about backing people who have been underserved by the bigger banks and giving back to 
the communities we operate in. Details of how we support the wider communities in which our customers and employees live and 
work are set out in our Corporate Responsibility Statement. 

The Board expects developments on climate change to evolve rapidly, seeing these as being consumer-led as opposed to being led 
by regulation and has urged management to evolve its approach to managing the financial risks from climate change at pace. The 
Board looks forward to further details of management’s roadmap towards disclosures aligned with the recommendations of the 
Task Force on Climate-Related Financial Disclosures. Further climate disclosures can be found in the Energy and Carbon Report on 
page 32.  

Regulators 

The Board  recognises  the  importance  of  regular, open  and  transparent  dialogue  with  our  regulators,  ensuring  that  we  remain 
aligned  with  evolving  regulatory  priorities.    Throughout  the  year,  our  Chair  and  our  Executive  Directors  have  met  with  our 
regulators, the Prudential Regulation Authority (“PRA”) and the Financial Conduct Authority (“FCA”).  The PRA also held routine 
meetings during the year with other Non-Executive Directors and our Executive Directors met representatives of the Prudential 
Authority of FirstRand’s regulator, the South African Reserve Bank. In the year under review, the focus of regulatory engagement 
was on our Covid-19 response, in particular the support offered to customers, colleagues and suppliers. 

In June 2021, representatives from the PRA attended a virtual Board meeting to present and discuss their findings arising from 
their 2021 Periodic Summary Meeting (“PSM”) with the Board. The PRA welcomed the opportunity to fully explain its findings and 
the  actions  it  expected  the Group  to  take.  The  discussion  was open  and  collaborative  and  was  helpful  to  the  Board  in  clearly 
understanding the PRA’s expectations. 

The Board regularly discusses regulatory developments and their potential impact on the Company.  The Board welcomed the Bank 
of England (“BoE”) consultation on its approach to setting a minimum requirement for own funds and eligible liabilities (“MREL”) 
and its implications for proportionate regulation and looks forward to further engagement with the BoE on this matter.  The Board 
and the Remuneration Committee also considered the impacts of the EU Capital Requirements Directive V (“CRD V”) on deferral 
of variable remuneration for material risk takers, further details of which can be found in the Remuneration Committee Report on 
page 47.  

Investors 

The interests  of  our  Shareholder  are represented  on  our  Board  by our  Shareholder  Directors,  Alan  Pullinger  and  Harry Kellan. 
Shareholder representatives are also invited to attend meetings of our Risk Committee and our Audit Committee. 

Our Senior Management team maintain regular dialogue with debt investors. During the year, the Board and Senior Management 
carefully considered the investor impact of an inadvertent breach of the Consumer Credit Act, further details of which are set out 
on page 154 and in July 2021 a full repurchase and substitution exercise was undertaken, the outcome of which ensured that our 
debt investors’ cashflows were not affected. 

31 

 
Energy and Carbon Reporting  

Our developing approach to climate change and key areas of initial focus 

Aldermore Group identifies climate change as a strategic risk and also recognises that this brings opportunities for us to be a part 
of the solution – in supporting the transition to a net zero economy and our customers, colleagues and communities on this journey. 
Our response to this key issue considers both the impact of climate change on the Group and our portfolios, as well as Aldermore 
Group’s impact on the climate and environment – from our operational emissions and those arising indirectly from our lending 
activities. 

The  risks  of  climate  change  to  Aldermore  arise  through  two  primary  channels  –  firstly,  through  physical  risks  associated  with 
changes in climate and weather (such as an increase in storms, floods and sea level rise) and secondly, through society’s response 
to climate change and transition to a low carbon economy. These transition risks may be generated through climate-related policy 
and regulations, technology development and changes in sentiment and behavior. Climate risks, arising through either one or a 
combination of these channels, cut across our existing risk types – such as credit risk, market risk, operational risk and reputational 
risk. We are in the process of developing our understanding of these climate-related risks and updating and enhancing our existing 
frameworks for managing and monitoring these. 

We plan  to enhance  our capability for disclosure, in  closer alignment  with the recommendations  of the Taskforce  for Climate-
related Financial Disclosures (“TCFD”). We have committed to share a more advanced summary in our 2022 annual reporting and 
to enhance this year on year, including key metrics beyond our own operational energy consumption and emissions as presented 
in this report. 

The Board has responsibility for the overall oversight of climate risk and the key activities the Group will be undertaking. Updates 
are being provided on delivery against our plan. A Board knowledge session on climate change was delivered in February 2020 and 
a further session is planned for October 2021 – recognising the evolving landscape of climate science, regulation and the latest 
guidance. 

The Senior Management Function (“SMF”) responsibility for management of climate risk presently rests with the Chief Risk Officer 
(“CRO”). Delivery of the Climate management is coordinated by the Risk function and progressed in collaboration with colleagues 
from across the business. 

To support this oversight and management of climate risk, we are in the process of developing climate management information 
and key metrics which will be regularly reviewed. 

The below provides an indication of the sectors and assets that the Group has assessed as exposed to heightened climate-related 
risks, where we are considering sector contribution to emissions in the UK, the potential vulnerability to physical risks and the 
proportion of lending relative to the Group’s total portfolio to inform prioritisation of further assessment. 

32 

 
 
 
 
 
 
 
 
Energy consumption and GHG emissions  

The Group has seen significant reductions in energy use and associated emissions due to changes in working practices in response 
to Covid-19, which have significantly reduced occupancy within office spaces and business travel.  It is expected that as staff return 
to offices and business travel resumes to pre-Covid-19 levels over the coming months, that there will be an increase in the intensity 
ratio in the next reporting period. 

The below emissions have been re-stated due to a change in the way we collect data related to business travel and heating 
within offices, as well as increasing numerical accuracy by reporting to one decimal place. 

Breakdown of energy consumption used to calculate emissions (kWh): 

Company owned vehicles 

Electricity 

Natural Gas  

Employee owned vehicles where the Group purchases the fuel 

Total gross energy consumed 

Breakdown of emissions associated with the reported energy use (tCO₂e) 

Year ended 
30 June 2021 

Year ended  
30 June 2020 

159,935 

702,041 

160,209 

29,986 

1,052,171 

1,280,093 

1,261,974 

1,396,713 

675,142 

4,613,922 

Year ended 
30 June 2021 

Year ended  
30 June 2020 

Scope 1 

Company owned vehicles 

Natural Gas 

Total Scope 1 

Scope 2 

Electricity 

Total Scope 2 

Scope 3 

Employee owned vehicles where the Group purchases the fuel 

Total Scope 3 

Total gross emissions 

39.8 

29.5 

69.3 

163.7 

163.7 

7.7 

7.7 

240.7 

Tonnes of CO2e per employee1 
1 Average number of employees within the reporting period was 2,029 (2020: 1,966). 

0.1 

0.6 

Year ended 
30 June 2021 

Year ended 
30 June 2020 

317.1 

256.8 

573.9 

322.6 

322.6 

193.1 

193.1 

1,089.6 

Change  
% 

-83% 

The Group reports its annual energy usage and associated annual greenhouse gas (“GHG”) emissions pursuant to the Companies 
(Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (“the 2018 Regulations”) that 
came into force on 1 April 2019.  

In accordance with the 2018 Regulations, the energy use and associated greenhouse gas emissions are for those within the UK only 
that come under the operational control boundary. Therefore, energy use and emissions are aligned with financial reporting for 
the UK subsidiaries, Aldermore Bank PLC and MotoNovo Finance Limited. There are no non-UK based subsidiaries.  

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
We continue to work with energy consultants Briar Associates (Briar Consulting Engineers Limited) to compile this report. The 2019 
UK Government Environmental Reporting Guidelines and the GHG Protocol Corporate Accounting and Reporting Standard (revised 
edition) were followed to ensure the Streamlined Energy and Carbon Reporting (“SECR”) requirements were met and exceeded 
where possible. 

The  energy  data was collated  using existing  reporting  mechanisms  to  provide  figures  back  to  July  2018.  These methodologies 
provided a near continuous record of natural gas, electricity, and transport data (consisting of company cars and employee-owned 
vehicles). 

The emissions are divided into mandatory and voluntary emissions according to the 2018 Regulations, then further divided into 
the direct combustion of fuels and the operation of facilities (scope 1), indirect emissions from purchased electricity (scope 2) and 
further indirect emissions that occur as a consequence of Company activities (scope 3). 

Estimates of energy consumption have been made where data has not been made available from suppliers or landlords.  In some 
cases, data has been pro-rated to match the reporting period.  Where office space is within multi-tenanted buildings with central 
building services, a mixture of benchmark and prorating has been used to estimate the heating and cooling loads.  Due to reduced 
occupancy in office buildings due to staff working from home as a result of our response to Covid-19, we have scaled benchmark 
figures to reflect the reduced energy use. 

Energy efficiency action during current financial year 

The management of resources and sustainability is an important issue for the Group. Energy management issues fall within the 
remit of the Environmental Steering Group made up of members from key departments. Some of the actions implemented follow 
recommendations that were identified in the latest ESOS audits. In the year 1 July 2020 to 30 June 2021, the Group has undertaken 
the following actions to improve energy efficiency: 

 

Reviewed and implemented office-based initiative as highlighted in the Energy Savings Opportunity Scheme (“ESOS”) 
audit, including: 

o 

o 

o 

Implemented energy saving modes in high use peripherals such as coffee machines, boiler taps and AV 
equipment. 
Installed timer plugs for the kitchen coffee machines which could not be placed into energy saving modes so 
they are only on within working hours. 
Reviewed the driving on Company business policy including targeting the Green Fleet provision for Company 
cars.  

 

 

Continued to hold regular reviews with Third Party Suppliers, including Building Management teams and Contractors to 
ensure energy efficiency is highlighted and implemented where possible for new and existing measures.  

Continued to undertake regular reporting to the Climate Change Working Group. 

Savings for these measures have not been quantified. 

This Strategic Report on pages 4 to 15 and the principal risks and uncertainties on pages 62 to 64, were approved by the Board and 
signed on its behalf by: 

Claire Cordell 

Director  

14 September 2021 

34 

 
 
 
 
 
 
 
 
 
 
 
Corporate Governance Structure 

The Board has delegated a number of its responsibilities to Board Committees, which utilise the expertise and experience of their 
members to examine subjects in detail and make recommendations to the Board where required. This delegation allows the Board 
to focus more of its time on strategic and other broader matters. The Chairs of the Board Committees provide the Board with a 
verbal update on matters discussed at each meeting and Board Committee papers and minutes are made available to the whole 
Board through a secure online system.  

The Boards of Aldermore Group and its subsidiary undertakings are committed to implementing a well-defined and well-structured 
corporate governance framework to achieve long-term sustainable success. 

Aldermore Bank and MotoNovo Finance are wholly owned operating subsidiaries of the Aldermore Group. The Boards of the Group, 
the  Bank  and  MotoNovo  Finance  generally  meet  concurrently.  The  Bank  is  authorised  by  the  Prudential  Regulation  Authority 
(“PRA”) and regulated by the Financial Conduct Authority (“FCA”) and the PRA. MotoNovo Finance is authorised and regulated by 
the FCA. 

The Board is committed to the highest standards of corporate governance and best practice. The Board recognises that effective 
governance is key to the implementation of our strategy for our shareholder and wider stakeholders. Aldermore Group has applied 
the Wates Corporate Governance Principles for Large Private Companies for its financial year ending 30 June 2021. 

During  the  summer  of  2020,  the  Group  appointed  external  corporate  governance  consultants  to  undertake  a  Governance 
Transformation project with the aim of streamlining the Group’s executive governance framework to support a commercial and 
nimble approach to decision-making. Our operating rhythm was reviewed to ensure, as we start to come out of the pandemic, that 
we have the right pace and focus to drive us forward. From 1 June 2021, our new executive committee governance structure was 
implemented,  reducing  the  number  of  executive  committees  from  nineteen  to  four.  Our  four  executive  committees  focus  on 
strategy, risk, financial performance and customer and products 

Governance Structure Diagram 

35 

 
 
 
 
The Wates Corporate Governance Principles  

As per the prior year, the Group has applied the Wates Corporate Governance Principles for Large Private Companies (the “Wates 
Principles” or the “Principles”), published by the Financial Reporting Council (“FRC”) in December 2018. 

The Wates Principles provide a framework for the Board to monitor corporate governance standards across the Group, ensuring 
that  the  business  remains  aligned  to  its  purpose,  and  identifying  opportunities  for  further  enhancements  to  our  governance 
framework.  We believe application of the Principles results in better engagement with our stakeholders, including customers and 
distribution partners, employees, and suppliers, and ultimately better outcomes for those groups, and for our wider stakeholders, 
including the communities in which the business operates, and the environment. 

The table below summarises the six Wates Principles and explains how each one has been applied by Board and indicates where 
more information can be found in the strategic and governance reports. Throughout 2021/22, the Board will continue to review 
opportunities to strengthen corporate governance. 

Principle 

Summary 

Purpose and 
leadership 

The Board is responsible for the overall leadership of the Group, and for promoting the 
Group’s culture and values, while at the same time considering how to implement policies 
and decisions made by the shareholder. It is responsible for approval of the Group’s 
strategic plans, which aim to generate long-term sustainable value. 

Page 

4  
24 
28 

Our Purpose – “Backing people to fulfil life’s hopes and dreams” – is why we exist. We turn 
problems into opportunities and help those that others turn their backs on, looking for 
ways to say yes, rather than no, and focusing on people’s future potential. We are 
committed to being fairer, more inclusive and making finance work for good, getting 
money to where it is needed and helping our economy prosper. 

We have supported small and medium sized businesses (“SMEs”) and served society for 
over 12 years. SMEs drive growth and provide employment opportunities and by 
supporting these businesses and helping them get access to finance, we contribute to a 
more prosperous society. 

Board composition 

The Board comprises ten directors – the Chair, two executive directors, five independent 
non-executive directors, and two shareholder non-executive directors. The non-executive 
directors  bring  outside  experience  across  a  range  of  areas,  including  finance,  banking, 
strategy, risk, communications, brand, and technology, and provide constructive challenge 
and influence. The composition of the Board is partly determined by the agreement with 
the shareholder.  

4 
48 
24 

The Board believes that diversity is an important ingredient of board effectiveness, and that 
a  diverse  board  will  bring  richer and  more  broad-based  perspectives  to  governance  and 
decision-making.  The Board adopted the targets of the Hampton-Alexander Review (33% 
female representation on the Board) and the Parker Review (one director of colour on the 
Board)  in  February 2021,  as  part  of  a  longer-term  aspiration  for  the  composition  of  the 
Board to broadly match the gender mix of the UK population. As at the date of this report, 
the representation of women on  our Board  stands  at  30% and  the Board’s  membership 
includes one director of colour. 

The Board also acknowledges its leadership role, beyond Board composition, to promote 
the  Group’s  broader  societal  responsibility  to  embrace  and  encourage  diversity  and 
inclusiveness.  The  Board  has  committed  to  encouraging  people  to  uphold  values  and 
behaviours that promote diversity and inclusiveness, that ensure fairness of opportunities, 
and that remove any barriers to diversity, inclusivity, and fairness where they might exist, 
through its governance processes and priorities. 

All Board appointments are subject to a formal, rigorous and transparent procedure and 
are made on individual merit against a defined job specification and criteria. The Company 

36 

 
 
 
 
 
 
 
 
 
 
 
seeks to ensure that at least half the Board, excluding the Chair, is made up of independent 
non-executive directors. The Company aims to have a Board that brings perspectives, skills 
and experiences from a wide range of backgrounds and disciplines. The Board appointment 
process is overseen by the Board Corporate Governance and Nomination Committee, which 
ensures  candidates  from  a  diverse  range  of  backgrounds  are  considered  on  merit  and 
against  objective  criteria.  The  process  includes  consideration  of  the  impact  individual 
candidates will have on overall Board diversity.  

On 1 August 2021 an apprentice Board member, Nicolina Andall, was appointed. Nicolina 
will  observe  Board  and  Board  Committee  meetings  and  the  Board  has  welcomed  the 
creation of the role as a means of giving aspiring and diverse talent first-hand experience 
of a commercial board, as an observer rather than as a director. 

The effectiveness of the Board and its committees is formally evaluated on an annual basis 
by  means  of  completion  of  a  self-assessment  questionnaire  by  each  Board  member, 
followed  by  review  meetings  between  the  Chair  and  individual  directors.  The  Senior 
Independent Director is responsible for appraising the performance of the Chair. In 2021 
the  review  was  facilitated  by  an  external  party,  Mindcor,  with  the  process  additionally 
involving  qualitative  interviews  with  all  Board  members.  The  review  examined  Board 
composition, dynamics, decision-making, the quality of information received and how the 
Board  spent  its  time.  It  evaluated  the  effectiveness  of  individual  directors,  the  Board 
Committees and the Company Secretary. Progress against recommendations arising from 
the  annual  effectiveness  review  is  monitored  by  the  Board,  and  findings  inform  Board 
succession planning.  

The  2021  assessment  concluded  that  the  Board  and  the  individual  directors  have  been 
effective over the last year and identified future priorities. The Board agreed to strengthen 
its composition by adding more digital expertise and also to prioritise female candidates in 
searches  for  future  Board  vacancies,  in  order  to  increase  female  representation  on  the 
Board. It also identified a need to pivot its focus away from detailed operational matters to 
allow greater focus on commercial and strategic challenges and agreed steps to improve its 
oversight of strategy execution and change. It agreed to streamline attendance at Board 
meetings in order to  support  open, uninhibited  discussions. Finally, the Board  agreed to 
progress plans for alternating between face-to-face meetings and hybrid meetings, where 
some Board members attend in person and some join remotely, and to increase the amount 
of interaction outside of Board meetings with the shareholder non-executive directors. 

37 

 
 
 
 
 
 
 
 
 
Directors’ 
Responsibilities  

The Board has a non-executive Chair to ensure that the balance of responsibilities, 
accountabilities and decision making is effectively maintained. The non-executive 
directors provide constructive challenge in the Board's decision-making processes. 

52 

The Board receives regular reports on business, financial performance, colleague matters 
and engagement, stakeholders and key business risks. 

The Board has established an Audit Committee, a Risk Committee, a Remuneration 
Committee and a Corporate Governance and Nomination Committee. Each of these 
committees has clearly defined Terms of Reference, and the Board receives regular 
updates on the activities and decisions of each committee. The Audit Committee is 
comprised entirely of independent non-executive directors and the Risk, Remuneration 
and Corporate Governance and Nomination Committees are comprised entirely of non-
executive directors, the majority of whom are independent. 

The Board regularly reviews governance processes, the quality and integrity of 
management information and the effectiveness of internal processes and controls. 

Long-term strategic opportunities are evaluated by the Board. The Risk Committee plays a 
key role in providing oversight and advice to the Board on the current risk exposures and 
future risk strategy of the Group, including the development and implementation of the 
Group’s Risk Management Framework. It also oversees performance against the Group’s 
approved risk appetite. The Executive Risk Committee assists the Chief Risk Officer in 
designing and embedding the Group’s Risk Management Framework, monitoring 
adherence to risk appetite statements, and identifying, assessing and controlling the 
principal risks within the Group. 

The Remuneration Committee has clearly defined terms of reference and is responsible for 
setting the Group’s remuneration policy and recommending and monitoring the level and 
structure of remuneration for the Chair of the Board, all executive directors, members of 
the  senior  leadership  team,  and  any  identified  staff,  including  pension  rights  and  any 
compensation  payments.  Pay  is  aligned  with  performance,  considering  fair  pay  and 
conditions across the Group’s workforce. Details of remuneration structures are set out in 
the  Remuneration  Committee  Report  on  page  48.  The  Committee  takes  advice  from 
independent external consultants who provide updates on legislative requirements, market 
best practice and remuneration benchmarking. 

42 

47 

Opportunity and 
Risk 

Remuneration 

Stakeholder 
relationships and 
engagement 

At  the  heart  of  our  business  is  our  Purpose  –  “Backing  people  to  fulfil  life’s  hopes  and 
dreams”.  It  is  a  statement  fundamentally  aimed  at  our  customers  (including  our 
intermediary partners) because they are the reason we exist, and it signifies the role we 
play in their lives. The Section 172(1) Statement on pages 28  sets out the details of some 
of the engagement that takes place at an operational or Group-level with key stakeholders. 

28 
4 

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Audit Committee Report  

I am pleased to present the Audit Committee’s report for the year ended 30 June 2021. It has been a challenging year and, as noted 
in the report below, the Committee has spent much time considering the economic impacts of Covid-19 on our loan loss provisions, 
where the level of uncertainty as to the future outlook has been unprecedentedly high. We have also continued to monitor the 
impact of working from home on our internal control environment. There have been a number of changes to the composition of 
the  Committee  over  the  year  and  I  would  like  to  thank  Peter  Shaw  and  Danuta  Gray  for  their invaluable  contributions  to  the 
Committee and to welcome Richard Banks, Desmond Crowley and Cathy Turner. 

The Committee is comprised of Independent Non-Executive Directors. I was appointed Chair of the Committee in May 2014 and, 
as a qualified Chartered Accountant, act as the Committee member required to have recent and relevant financial experience.  The 
Board  has  confirmed  that  it  remains  satisfied  with  my  experience.  The  other  members  of  the  Committee  are  Richard  Banks 
(appointed 1 September 2020), Desmond Crowley (appointed 1 May 2020) and Cathy Turner (appointed 3 July 2019). Peter Shaw 
and Danuta Gray were members of the Committee until their resignations from the Board on 30 September 2020 and 31 March 
2021, respectively. 

The Committee’s principal responsibilities are: 

  Monitoring  the  integrity  of  the  Group’s  financial  statements,  including  reviewing  whether  appropriate  accounting 

standards have been followed, and reviewing key areas of judgement.  

During 2020/21, the Committee: 
- 
- 

Approved the Pillar 3 disclosures as at 30 June 2020 and the associated Pillar 3 Reporting Policy; 
Reviewed  the  outcome  of  two  deep-dive  workshops  between  Deloitte  and  management  around  the 
performance of the Group’s IFRS 9 credit models, in light of the Covid-19 pandemic and agreed the proposed 
enhancements to the models arising from the workshops; 
Recommended the Annual Report and Accounts of the Company, the Bank and MotoNovo Finance, for the 
year-ended 30 June 2021, to the respective Boards for approval; 
Significant matters and key areas of judgement reviewed by the Committee in respect of the Annual Report 
and Accounts for the year to 30 June 2021 were: 

- 

- 

- 

- 

- 

- 

Loan  impairment  provisions,  reviewing  the  Group’s  approach  to  applying  the  IFRS  9  accounting 
standard,  particularly  in  the  light  of  the  Covid-19  pandemic,  challenging  and  reviewing  the  key 
assumptions  and  judgements  underlying  the  provisions,  including  management  overlays  for 
identified  issues  not  fully  covered  by  the  provisioning  models  and  the  accuracy  and  validity  of 
forward-looking indicators (“FLI”) applied, as well as the adequacy of disclosures shown in the Annual 
Report. In particular this year the Committee reviewed the change in the construction of the Group’s 
macroeconomic  scenarios  from  inputs  supplied  by  Oxford  Economics  to  inputs  supplied  by  the 
Group’s  parent,  FirstRand  as  well  as  monitoring  the  Group’s  policy  for  identifying  the  level  of 
provision needed for those cases among customers requesting forbearance in relation to the Covid-
19  pandemic.  The  Committee  took  particular  account  of  the  circumstances  surrounding  the 
continuing Government support to business and the likely unwinding of that support in 2021/2022. 
The  Committee  also  considered  areas  identified  by  the  External  Auditors  where  the  provisioning 
process could be improved, noting that, while these did not impact the overall provision levels for 
the  current  year,  they  warranted  pursuing  for  the  future.  The  Committee  concluded  that 
management’s approach and assumptions around IFRS 9 impairment provisions were appropriate 
and reflected fairly in the financial statements;  
Assumptions  on  loan  asset  expected  lives  within  the  Effective  Interest  Rate  accounting  models, 
including the transition to new models to calculate Effective Interest Rate and the continuing impact 
of  the  pandemic  on  customer  behaviour.  The  Committee  endorsed  the  judgements  made  by 
management;  
Reviewed the disclosures relating to Internal Benchmark Reform – phase 2 which the Group early 
adopted. The Committee determined that these disclosures were satisfactory; and 
The Committee recommended that the Group’s Annual Report and Accounts should be prepared on 
a Going  Concern  basis and the  statement  should  be  approved  by  the  Board,  following  a  detailed 
review  of  the  underlying  analysis  prepared  by  management  and  the  relevant  disclosures  in  the 
financial statements. 

39 

 
 
 
 
  
  Monitoring the effectiveness of the Group’s internal control systems. 

During 2020/21, the Committee: 
- 

Reviewed the final observations from the external auditor, Deloitte LLP (”Deloitte”) arising from the testing of 
the Group’s internal controls relevant to the audit of the financial statements for the year ended 30 June 2020 
and the interim observations arising from the audit for the year ended 30 June 2021; 
Considered the findings of the Group Internal Audit (“GIA”) function’s programme of audit reviews throughout 
the year; 
Approved the annual Money Laundering Officer’s report; 
Approved the Anti-Bribery and Corruption policy; 
Conducted  an  annual  review  of  the  Group’s  whistleblowing  arrangements,  concluding  that  these  were 
adequate; 
Ratified the findings of an assessment of the Group’s internal financial controls at the half year 2021 and year 
end 2021, following recent changes to listing requirements for FirstRand Limited; 
Assessed the Group’s systems of risk management and internal controls, including a specific assessment that 
the financial statements were free from material error due to fraud.  
The Committee paid particular attention to the degradation of user access review controls for the Group’s key 
mortgages system identified by the External Auditor, noting that management had tightened the control on 
discovery of the lapse, and concluded that sufficient work had been carried out to give reasonable assurance 
that no unauthorised access to the system had occurred;  
The Committee concluded that, overall, the internal control environment was satisfactory; and 
Concluded, following the annual review of the Group’s disclosure controls and procedures, that these remain 
fit for purpose. 

 

Reviewing the effectiveness of the GIA function and reviewing GIA reports and monitoring management’s responsiveness 
to findings and recommendations. 

The GIA effectiveness review was undertaken in the first quarter of 2020/21 and, overall, the Committee concluded 
that the GIA effectiveness review responses had been positive from both Committee members and Management and 
that GIA was well resourced and effective. 
Specifically, during 2020/21, the Committee: 
- 

Approved audit plans for GIA reviews across both Aldermore and the MotoNovo Finance business covering the 
period from July 2021 to June 2022; 
Approved an updated GIA Charter, which sets out the mandate and remit of the function; 
Approved the GIA 2021/22 Skills and Capability Self-Assessment; 
Reviewed the findings of GIA’s thematic reporting on the internal control environment; 
Reviewed quarterly reports from GIA on the output of the function’s work, progress against the plans for 2020 
to 2021 and management’s progress on remediation of issues; and 
The Chair met regularly with the Director of GIA  and also conducted a virtual “Town  Hall” session with the 
members of his team. The Committee also held a private session with the Director of GIA and a number of the 
senior members of the team made presentations to the Committee.   

- 
- 
- 
- 

- 

  Overseeing  the  relationship  with  and  independence  of  the  external  auditor,  Deloitte,  appointed  with  effect  from 

1 January 2017. 

Specifically, during 2020/2021, the Committee: 
- 

Reviewed the external audit plan for 2020/2021, as well as Deloitte’s terms of engagement and approved their 
2020/21 fee proposal for the audit of the Group accounts for the year ended 30 June 2021. This review included 
consideration of the experience of the audit team assigned;  
Approved  the  fees  for  the  work  undertaken  to  perform  a  set  of  specified  procedures  as  requested  by  the 
FirstRand Group auditors; 
Considered the external auditor’s assessment of their own independence; 
Reviewed  the  Group’s  Combined  Policy  on  Non-Audit  Services,  Auditor  Independence  and  employment  of 
former  employees  of  the  Auditor  and  monitored  non-audit  services  provided  by  the  external  auditor.  The 
Committee also monitored adherence to additional governance requirements in relation to the engagement 
for non-audit services of PricewaterhouseCoopers LLP, joint auditor with Deloitte for the FirstRand Group; 
Reviewed control observations made by the external auditor, including management’s responses; 
Reviewed representation letters to the external auditor and recommended these for Board approval; 
Met privately with the senior members of the Deloitte audit team. In addition, the Chair met regularly with 
Deloitte during the period to facilitate effective and timely communication; and 

- 

- 
- 
- 

- 

- 

- 

- 
- 

- 

- 
- 

- 
- 
- 

40 

 
 
 
- 

Assessed  the  effectiveness  of  the  external  auditor  and  recommended  the  re-appointment  of  the  external 
auditor.  In  addition  to  the  matters  above,  this  assessment  considered  the  annual  report  by  the  Financial 
Reporting  Council  (‘FRC’)  on  its  review  of  audits  carried  out  by  Deloitte  and  the  Deloitte  audit  team’s 
contribution to the Audit Committee’s discussions. 

  Other activities 

Additionally, the Committee undertook a review of its own effectiveness as part of the wider Board and Committee evaluation 
exercise. The review was conducted externally, facilitated by Mindcor and was conducted by way of a questionnaire that was issued 
to  all  Committee  members,  as  well  as  qualitative  interviews  with  all  Committee  members.  The  review  covered  various  areas 
including: the role and remit of the Committee; the effectiveness of the Chair; the appropriateness of information provided to the 
Committee and the relationship with management. In June 2021, the Corporate Governance and Nomination Committee and the 
Board  discussed  the  outcome  of  the  review,  concluding  that  the  Audit  Committee  operated  effectively  and  there  were  no 
significant areas for concern. However, a dependency on the Chair of the Committee for technical accounting and reporting issues 
was  noted  and  this  is  being  considered  by  the  Corporate  Governance  and  Nomination  Committee  as  part  of  its  discussions 
regarding Board succession planning. 

Following the issue of a White Paper in March 2021 by the Department for Business, Energy and Industrial Strategy (“BEIS”) entitled 
‘Restoring trust in  audit and corporate governance’,  the external audit Partner  and the  Chair provided the  Committee with an 
overview  of  the  key  proposals  for  Directors  and  Audit  Committees  in  June  2021,  which  included  initial  observations  on  how 
Aldermore  Group  PLC  may  be  impacted  by  those  proposals.  It  was  agreed  that  Aldermore  would  submit  responses  to  the 
consultation, which subsequently occurred. 

The Committee also carried out a review of its own Terms of Reference during 2020/21. A number of minor updates were 
recommended to and approved by the Board.  

John Hitchins  
Audit Committee Chair  

41 

 
 
 
 
  
Risk Committee Report  

I  am  pleased  to  present  to  you  my  inaugural  report  as  Chair  of  the  Risk  Committee  (the  “Committee”)  and  firstly  take  the 
opportunity to thank Peter Shaw for his guidance and support as the previous Committee Chair and to Pat Butler for acting as 
interim Committee Chair from 1 October 2020 until my approval by the PRA. 

The Committee is comprised of Non-Executive Directors. I was appointed as a member on 1 September 2020, and as Chair with 
effect  from  21  December  2020.  The  other  members  of  the  Committee  are  Desmond  Crowley  (appointed  1 May 2020),  John 
Hitchins (appointed 28 May 2014), Harry Kellan (appointed 1 July 2020) and Alan Pullinger (appointed 1 July 2020).  Peter Shaw, 
Danuta Gray and Cathy Turner stepped down as members of the Committee with effect from 30 September 2020, 7 October 2020 
and 7 October 2020 respectively.  

The Group’s  risk  and  compliance  functions  sit  under  the  executive  leadership  of  Andrew  Lewis,  the  Group’s  Chief  Risk  Officer 
(“CRO”), who joined the Group in November 2020.  As part of the transition from Peter Shaw and Pat Butler to myself as Chair of 
the Committee and from the former CRO to Andrew Lewis, all parties worked closely to ensure a smooth transition of both roles.  

The Committee’s key objective is to provide oversight of and advice to the Board on the current risk exposures and future risk 
strategy of the Group, including the development and implementation of the Group’s Risk Management Framework and making 
recommendations to the Board to ensure compliance with the Group’s approved risk appetite. 

The  Committee  continues  to  have  an  open  and  transparent  relationship  with  our  regulators  and  during  the  year  considered 
feedback in respect of the ongoing suite of regulatory reviews and activity, both specific to the Aldermore Group and industry-
wide.  There has been active and healthy dialogue with regulators across a number of topics, including Covid-19 resilience, credit 
quality, thematic reviews and meetings with both myself as the Chair and Andrew Lewis as CRO.  

Areas of focus 

The  rapid  spread  of  Covid-19  continued  during  the  financial  year  and  the  Committee’s  attention  was  firmly  focussed  on  the 
implications of Covid-19 on our risk profile, our business, our customers and our people, during one of the most unprecedented 
economic periods the UK has experienced.  Throughout the pandemic and in preparation for the end of the Government’s Covid-
19 support schemes, the Committee has assessed risks in operational capacity and change management to ensure that the Group 
is able to support customers and to ensure positive outcomes particularly as Government support falls away.   The Group’s credit 
risk profile has been subject to enhanced scrutiny by the Committee as a result of the Group’s increased exposure to forbearance 
during the pandemic.   

Andrew Lewis, as the Group’s new CRO, presented his reflections on risk function priorities to the Committee in March 2021.    He 
identified a series of priorities to recalibrate the focus of the Risk function. Inter alia these include progressing on the journey to 
achieve regulatory permission  for an internal ratings-based approach  to credit risk  ensuring a strong  relationship  between  our 
business strategy, risk appetite, the quality of earnings and the impact on capital and liquidity. There is also a need for increased 
automation in decision making and assessing credit risk and the automation of our key customer identification processes.  Further 
investment in digitisation and automation will improve customer experience and good outcomes whilst strengthening the Group’s 
operating structure to reflect the key risks to the business.  The risks around the ongoing integration of MotoNovo’s operations 
into the Group have and will also be a focus for the Committee with the aim to maximise efficiencies thorough best practice whilst 
minimising risk.   

Other key matters discussed by the Committee during the year are set out below. In addition, pages 62 to 64 provide a summary 
of  the  principal  risks  faced  by  the  Group  and  key  mitigating  actions  and  an  overview  of  emerging  risks, along  with  recent  and 
anticipated  future  developments.  Further  information  on  the  Group’s  approach  to  risk,  including  the  associated  governance 
framework for managing risk, stress testing and a full analysis of the principal risks, are set out in the risk management section on 
pages 57 to 87. 

42 

 
 
Covid-19 impact 

A key area of focus for the Group has been the ongoing impact of Covid-19.  The Committee’s role was to scrutinise the key risks 
emerging  from  the  crisis  and  their  impact  on  the  Group’s  risk  profile.  The  Committee’s  discussions  focused  on  operational 
resilience,  liquidity  and  funding  considerations,  customer  vulnerability  and  the  impact  of  material  increases  in  forbearance 
requests.  These may increase post the end of furlough and Government support and efforts are focused on the impact on the 
Group’s credit portfolios and operational capacity. In considering these matters, the Committee took into account the views of first 
line personnel, Risk and Group Internal Audit. 

Other areas of focus  

In addition to our response to the pandemic, the Committee continued to focus on its core responsibilities.  A series of risk deep 
dives were provided to the Committee on areas such as the financial risks of climate change, the treatment of customers with 
higher  risk  characteristics,  football  finance,  the  Group’s  insurance  products,  non-performing  loans  and  a  growth  analysis  and 
strategic  outlook  for  MotoNovo.    The  Committee  considers  these  deep  dives  to  be  an  important  component  of  proactive  risk 
management and welcomes the high quality, value-add discussions they facilitate. These, and focussed reports from the senior 
executives supported the Committee’s assessment of the Group’s principal risks.   

Overarching risk profile 

The Committee  carried out reviews across  the Group’s principal  risks on a regular basis. In addition, the Committee  approved 
changes to risk metrics, triggers and limits. 

Frameworks 

We  approved  reviews  of the  effectiveness  of  Risk Frameworks  and  further  details  of  frameworks  and  polices  approved  by  the 
Committee during the year are outlined in the following sections below. It also carried out a review of its own Terms of Reference 
during 2020/21. A number of minor updates were recommended to and approved by the Board. 

Risk culture 

The Committee  is  required  to  review  the  Group’s  risk  culture  and  the  effectiveness  of  its  embedding  across  the  Group  on  an 
ongoing basis.  

During the year, the Committee received management’s qualitative assessment of risk culture across the Group and supported the 
development of a framework for assessing risk culture which will be rolled out during 2021/22.  As the Group continues to grow, 
it is recognised that there is a need for its risk management framework to evolve to reflect the maturity of the business. 

Credit risk 

The  Committee  regularly  reviews  the  credit  risk  profile  of  the  Group,  with  a  clear  focus  on  performance  against  risk  appetite 
statements and risk metrics. The Committee considered credit conditions during the year and in particular the impact of the Covid-
19 crisis on performance against both credit risk appetite and a range of key credit risk metrics.  An evaluation of credit risk data 
informed the focus for the second half of 2020/21 on the top-down risk appetite statement, a key building block for managing 
earnings, capital and liquidity.   

The Committee also discussed findings from the annual review of the Credit Risk Management Framework and supported actions 
arising from the review, as well as approving changes to the Credit Risk Management Framework.  

43 

 
 
 
 
Capital and liquidity risk 

The Committee monitors capital and liquidity risk and receives regular reports on actual and forecast levels in relation to key risk 
appetite  framework metrics. During  the  year,  the  Committee scrutinised  and  approved  the  Group’s  Internal  Capital  Adequacy 
Assessment Process (“ICAAP”) and Internal Liquidity Adequacy Assessment Process (“ILAAP”). 

The Committee also approved changes to the Capital Risk Management Framework and the Liquidity Risk Management Framework 
following annual reviews of those documents. 

Market risk 

Although the Group does not seek to take market risk, the Committee reviewed the interest rate risk that the Group carries as part 
of the ICAAP review process and the impact of market risk as it relates to writing MotoNovo Finance business. The Committee 
conducted an annual review of the Group’s Market Risk Management Framework and approved changes to the document. 

Operational risk 

During the year the Committee took a number of steps to increase monitoring and scrutiny of the Group’s operational risk profile 
and operational resilience. Operational resilience and resilience planning have been a major topic of discussion by the Committee 
as  a  consequence  of  Covid-19,  the  uncertainties  of  Brexit,  the  evolving  cyber  security  threat  and  our  portfolio  of  change  and 
transformation. The Committee has overseen the business and risk functions working effectively together on these thematic areas, 
as well as specific areas such as exit plans for payment breaks and collections resourcing and activity. In particular, the Committee 
oversaw progress against actions to address findings following a review of collections by Group Internal Audit (“GIA”). This review 
was carried out by GIA at the request of the PRA which asked the internal audit functions of a sample of non-systemic banks and 
building societies in November 2019 to carry out a review of collections functions. The Committee also reviewed impact tolerances 
for  the  Group’s  critical  business  services  and  recommended  these  for  Board  approval  and  received  a  number  of  updates  on 
operational risk matters, particularly in respect of the impact of Covid-19 on the Group’s operational risk profile. The Committee 
also received updates on key controls testing and the alignment of controls testing across Aldermore and MotoNovo Finance, as 
well as approving an updated approach to risk acceptances. In its annual review of the Group’s Operational Risk Framework the 
Committee noted the impact of Covid-19 and the rapid deployment of working from home. As a consequence, over the year we 
have  identified  a  number  of  process  failures  impacting  a  small  number  of  customers  which  have/will  require  remediation. 
Notwithstanding these issues, the committee confirmed that the Group’s approach was fit for purpose and proportionate.  

In terms of the operational risk profile regular updates on business continuity and disaster recovery, cyber security and cyber risk 
management  were  reviewed. Cyber  security  remains  an  area  of  focus  for  the  Group  and  the  Committee  received  updates  on 
progress against the Group’s cyber strategy, which includes key areas, such as access management and control, data protection, 
security architecture and governance. As the cyber security threat continues to evolve at pace across the financial services industry, 
the Committee has instigated more frequent reporting on cyber security and cyber risk management.   

In addition, the Committee monitored the performance of key systems and significant projects, as well as scrutinising material 
outsourced arrangements. 

Compliance, conduct and financial crime risk 

Conduct  risk  management  continues  to  be  a  key  area  of  focus  and  the  Committee  approved  updates  to  the  Conduct  Risk 
Management Framework following the annual review of its effectiveness. In addition, the Committee received regular reports on 
performance against conduct risk metrics and developments regarding new and existing products. As mentioned above there have 
been a small number of customers impacted by process failures arising from our response to the Covid-19 epidemic. These have 
necessitated remediation activity to ensure good customer outcomes.  

44 

 
There is an increased attention on how we support vulnerable customers and the Group has an appropriate control framework in 
place to manage the associated risks.  This will be a particular focus over the next 12 months.   The effectiveness of the Financial 
Crime Risk Management Framework and Compliance Risk Framework were also reviewed.  

The Committee also received an annual update from the Group’s Data Protection Officer on GDPR compliance.  

Reputational risk 

The Committee received monthly reporting on reputational risk throughout the year.  The Board looks to the Risk Committee to 
monitor these risks and provide an appropriate level of assurance on management and mitigation.  The Covid-19 pandemic saw 
the  crystallisation of  a  number  of  risks, in  particular in  relation  to  operational  resilience  and the  action  taken  to  maintain  this 
resilience is explained elsewhere in the Annual Report. This is another focus area for the CRO, who is establishing a Reputational 
Risk  Forum  to  focus  on  client  and  deal  suitability,  staff  and  supplier  conduct  and  risk  appetite  in  sectors  or  segments  with  a 
heightened risk profile.  

Financial risks from climate change 

We received regular updates on the Group’s approach to addressing the financial risks from climate change but this is an area we 
will devote more time to in the next year given its importance and the increasing attention of governments, regulators, investors 
and our customers. 

Remuneration matters 

The Committee has a duty to advise the Remuneration Committee regarding both the design of senior executive annual and long-
term  incentive  plans,  to  ensure  that  management  are  not  being  incentivised  to  take  undue  risks.    It  also  considers  any  risk 
management  and  control  issues  that  have  arisen  that  it  believes  should  be  taken  into  account  when  determining  executive 
remuneration payments under the aforementioned plans.  In 2020/21 the Committee reviewed regular reports from the Chief Risk 
Officer in relation to such matters. 

Recovery Plan 

During the year, the PRA supported the Committee’s view that the 2019 Recovery Plan was materially more comprehensive than 
the previous year’s plan. The Committee participated in a recovery planning fire drill exercise in September 2020, acting out key 
parts of a response to a designed scenario with facilitation by a third party. The objectives of the exercise were broadly met and 
feedback will be taken into account in developing the 2020 Recovery Plan. 

Risk management function 

The Committee reviewed the remit and performance of Aldermore’s risk management functions to confirm that these functions 
have the requisite skills, experience and resources, along with unrestricted access to information, to discharge their responsibility 
effectively,  in  accordance  with  the  relevant  professional  standards  and  ensuring  also  that  the  functions  have  adequate 
independence. In this context the CRO has implemented an organisational transformation and created a new Target Operating 
Model to drive more effective management of risk.  This included creating a single, future-ready Risk function, moving to a risk 
partnering model and promoted first line empowerment by moving the second line of defence teams undertaking first line risk 
activities for our customer-facing divisions into the business lines. A series of shared services (for example, reporting, assurance 
and governance) and centres of excellence (such as models, credit decisioning and risk automation) have also been established to 
drive the efficiency and effectiveness of the function as capabilities are developed.  As an example, model risk has been promoted 
to a tier 1 principal risk recognising the importance of models in driving our strategy and risk. The business has identified the need 
to enhance our modelling capability, in particular, the ECL models 

45 

 
 
 
Risk Committee effectiveness 

The Committee undertook a review of its own effectiveness as part of the wider Board and Committee external evaluation exercise   
by Mindcor. This was conducted by way of a questionnaire and qualitative interviews with all Committee members. 

The review covered various areas including the role and remit of the Committee, the effectiveness of the Chair, the appropriateness 
of information provided to the Committee and the relationship with management. In June 2021, the Corporate Governance and 
Nomination  Committee  and  the  Board  discussed  the  outcome  of  the  review,  concluding  that  the  Risk  Committee  operated 
effectively  and  there  were  no  significant  areas  for  concern.    A  number  of  topics  were  identified  for  greater  oversight  by  the 
Committee in 2021/22 and will be added to the Committee’s agendas as appropriate. These included the financial risks of climate 
change, cyber security and model risk. 

Horizon Risks 

As discussed above there are a number of challenges both internal and external, such as the post Covid-19 support on customers 
and need for a customer focused approach, climate change and cyber security. There is also the impact of regulation – Capital 
Requirements Directive V, Basel III, the Bank of England’s review of the minimum requirement for own funds and eligible liabilities, 
and various consultations, such as the new Consumer Duty proposed by the FCA. However, the business and the management 
team have the maturity to successfully face these challenges in 2021/22 and beyond. 

Richard Banks 
Risk Committee Chair 

46 

 
 
 
Remuneration Committee Report  

This report presents (i) details of the remuneration of our Executive Directors, Chairman and independent Non-Executive Directors 
and aggregate remuneration for our senior management team, and (ii) a summary of our Directors’ Remuneration Policy. 

In setting the Directors’ Remuneration Policy and individuals’ remuneration, the Committee is mindful of pay and benefits for the 
wider employee population.  The Remuneration Committee and the Board as a whole, takes a keen interest in Aldermore’s Gender 
Pay Gap reporting, our progress against the HM Treasury Women in Finance Charter and our approach to equality and diversity 
more generally. 

As a retail bank, Aldermore is subject to the CRD IV regulations, albeit our size has allowed us to disapply certain aspects of the 
regulations where these are not appropriate for Aldermore (“proportionality”). With CRD V coming into force from 1 July 2021, 
certain changes to the Directors’ Remuneration Policy will apply from next year to ensure that the variable to fixed cap of 2:1 (as 
approved by Aldermore’s shareholder) is applied and new rules on deferral (including the requirement for a holding period on 
payments in instruments) comply with the new requirements.  

Remuneration received by the Directors1 in the year ended 30 June 2021 and 30 June 2020 is shown below: 

£’000 
Pat Butler, 
Chairman 
Phillip Monks, CEO 
Resigned 7 May 
2021 
Steven Cooper2, 
CEO 
Appointed 10 May 
2021 
Claire Cordell, CFO  
James Mack, CFO 
Resigned 31 January 
2020 
Christine Palmer, 
CRO Resigned 31 
July 2020 
Richard Banks, 
Independent Non- 
Executive Director 
Appointed 1 
September 2020 
Desmond Crowley, 
Independent Non- 
Executive Director 

Total fixed 
pay 
2021 

Total fixed 
pay 
2020 

Annual 
Incentive Plan 
2021 

Annual 
Incentive Plan 
2020 

250.0 

247.5 

- 

930.2 

902.8 

512.0 

1,151.8 

390.6 

- 

189.1 

97.5 

290.0 

- 

328.5 

52.0 

630.2 

52.4 

- 

78.5 

13.0 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Long-Term 
Incentive 
Plan 
2021 

Long-Term 
Incentive 
Plan 
2020 

- 

- 

177.3 

678.6 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

47 

 
 
 
 
 
 
 
Total fixed 
pay 
2021 

Total fixed 
pay 
2020 

Annual 
Incentive Plan 
2021 

Annual 
Incentive Plan 
2020 

Long-Term 
Incentive 
Plan 
2021 

Long-Term 
Incentive 
Plan 
2020 

76.7 

108.0 

98.5 

98.0 

25.9 

103.0 

100.0 

103.0 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

£’000 
Danuta Gray, Senior 
Independent Non- 
Executive Director  
Resigned 31 March 
2021 
John Hitchins, 
Independent Non- 
Executive Director  
Peter Shaw, 
Independent Non- 
Executive Director 
Resigned 30 
September 2020  
Cathy Turner, 
Independent Non- 
Executive Director  

1 Two non-executive directors are appointed by the FirstRand Group and receive no remuneration personally although an equivalent sum is paid 
to the FirstRand Group in respect of their services. 

2Steven Cooper was awarded a cash bonus buyout of £1.0 million upon commencement of employment with Aldermore Group. 

The  aggregate  emoluments  (i.e.  salary/fees,  market  adjusted  allowances,  benefits  and  AIP)  for  the  Directors  in  the  year  was                 
£4.4 million. 

Remuneration for other members of the senior management team 

The senior management team consisted of 9 employees in the year. The aggregate total remuneration for the senior management 
team (including the Chief Executive Officer) was £8.6 million. Of this, £6.3 million was fixed pay (salary, market adjusted allowance, 
benefits and pension) and £2.3 million was variable pay.  

The principles and remuneration structures described within the Directors’ Remuneration Policy apply throughout the whole senior 
management team, with slight differences for employees within key control functions (risk, compliance and internal audit).   

Employees  who work within key control functions and  who would otherwise participate in the  AIP and  LTIP  are subject to  the 
following treatments: 

 

 

AIP performance measures will be set on the basis of non-financial measures relating to personal performance and the 
effectiveness of their functions.  Measures will not relate to the financial performance of the unit of which they have 
oversight; and 
Key control functions employees will not participate in the standard LTIP and will instead participate in equivalent value 
awards without financial measures. 

48 

 
 
 
 
 
 
 
 
 
 
Remuneration for wider employees 

Aldermore seeks to pay all of its staff competitively and fairly for the roles they undertake. Aldermore applies similar principles for 
remuneration  across  the  workforce to those  which  apply  to  our Executive  Directors.    All  permanent  employees  are  eligible to 
receive a bonus on a discretionary basis, subject to Company and individual performance. 

We  have  reported  our  Gender  pay  gap  on  four  occasions  (2017-20).   We  are  working  on  our  reporting  for  2021  and  we  are 
committed to continuing the progress we have made to reduce the gender pay gap, which we view as a representation rather than 
a pay differential issue.  

In 2016, we became one of the first signatories to the HM Treasury Women in Finance Charter, and we see gender representation 
as an integral part of our Diversity and Inclusion agenda. By signing up to the Charter, we have committed as a business to its four 
key pillars. 

The commitments we made by signing the charter in are as important as ever because they align so closely with our purpose of 
‘backing people to fulfil life’s hopes and dreams’ and we are preparing milestones that take us beyond the initial 30%, and commit 
us to actions that will take us to 50% representation within 5 years.  

Please see our Women in Finance and Gender Pay Gap disclosure on our website for more information. 

Directors’ Remuneration policy 

The Directors’ remuneration policy is based on the following key principles: 

 
 
 
 

Aligned to the long-term success of the Company; 
Competitive but not excessive; 
Appropriate and balanced proportion of variable pay; and 
Simplicity and transparency in the design. 

Remuneration Committee effectiveness 

The structure of remuneration for our Executive Directors’ is summarised in the table below: 

Element of remuneration 

Policy and operation 

Salary 

To provide a fair level of fixed pay 
which reflects the individual’s 
experience and contribution 

Typically paid monthly in cash and reviewed 
annually. 

The annual review takes into account 
corporate and individual performance, any 
change in role and responsibilities, market 
benchmarking and pay increases awarded 
across the Company as a whole. 

Performance  measures  and  Committee 
flexibility 

No performance measures apply. 

Base salary increases will be awarded at 
the Remuneration Committee’s 
discretion, taking into account the factors 
listed. 

49 

 
 
 
 
 
Element of remuneration 

Policy and operation 

Market Adjusted Allowance 

To ensure appropriate weighting of 
fixed and variable remuneration 
within an overall competitive 
package 

A fixed monthly allowance, typically paid in 
cash. 

Paid on the same basis as salary but is not 
taken account when calculating other 
elements of remuneration. 

Benefits 

To provide competitive benefits 

A range of benefits is provided which 
includes a car allowance, insurance benefits 
and, if appropriate, certain relocation costs. 

Pension 

To enable Executive Directors to 
build long-term savings for 
retirement within an overall 
competitive package 

Contributions may be paid into personal 
pension arrangements or as a cash 
supplement (reduced for the impact of 
employers’ NICs) with the levels aligned to 
those available to staff. 

Annual Incentive Plan (AIP) 

A bonus plan which operates annually. 

To motivate Executive Directors 
and incentivise delivery of 
performance over a one-year 
operating cycle, focusing on the 
short- to medium-term elements of 
our strategy 

The maximum level of AIP outcome is 125% 
of salary p.a. 

Performance measures are set by the 
Remuneration Committee at the start of the 
financial year and targets are assessed 
following the year-end. 

For financial years ending in 2021 and 
before, at least 33% of any annual bonus 
payable will be deferred (where the total 
bonus outcome is at least £50,000), released 
in equal tranches on the first, second and 
third anniversaries of making the deferred 
award.  Deferral will be made in equity-linked 
instruments which mirror the percentage 
change in FirstRand’s share price, albeit not 
subject to changes in the Rand: GBP 
exchange rate. From the 2022 financial year, 
the rules on deferral will be modified to 
ensure compliance with CRD V when AIP and 
LTIP are taken together. 

Malus and clawback provisions apply to both 
the cash bonus and the deferred bonus. 

Performance measures and Committee 
flexibility 

No performance measures apply. 

Market Adjusted Allowance increases will 
be awarded at the Remuneration 
Committee’s discretion, but will only be 
increased if there is a meaningful change 
in the appropriate market benchmarks. 

No performance measures apply. 

The Remuneration Committee may 
introduce new benefits as appropriate. 

No performance measures apply. 

Performance measures will be a balanced 
scorecard based on four quadrants 
comprising financial, assessment of 
customer/strategic performance, risk and 
people objectives. 

For all performance measures, there is a 
robust discretionary override available to 
the Remuneration Committee to ensure 
that outcomes are consistent with 
affordability and overall appropriateness. 

The performance measures for 
employees within key control functions 
will be set only on the basis of measures 
which are predominantly non-financial 
and relate to personal performance.  
Performance is not assessed over the 
financial performance of the unit in 
respect of which they have oversight. 

50 

 
Element of remuneration 

Policy and operation 

Long-Term Incentive Plan (LTIP) 

To motivate Executive Directors 
and incentivise delivery of 
performance over the long-term 

A long-term incentive plan which operates 
annually. 

The maximum award is 135% of salary p.a. 

Awards are settled 50% in equity linked 
instruments (where the headline amount 
vesting will be multiplied by the percentage 
change in FirstRand’s share price) and 50% in 
cash if performance conditions are achieved 
over a 3 year performance measurement 
period. 

Performance measures and Committee 
flexibility 

Performance for the LTIP awards is 
assessed 20% against FirstRand 
performance measures and 80% against a 
balanced scorecard of growth in earnings, 
return on equity and conduct risk. 

In the view of the Remuneration 
Committee, the proposed performance 
measures for LTIP awards are supportive 
of the Company’s risk appetite and do not 
promote undue risk inconsistent with 
that appetite. 

Malus and clawback provisions apply to both 
the cash and equity portions of the LTIP. 

Colleagues in control functions will be 
subject only to conduct risk. 

For grants made on or before October 2021, 
awards may vest at or shortly following the 
end of the performance period. Subsequent 
awards will be subject to additional deferral 
and holding periods to comply with CRD V.  

The structure of remuneration for our Chairman and Non-Executive Directors is summarised in the table below.  Remuneration for 
the Chairman is determined by the Remuneration Committee and remuneration for the independent Non-Executive Directors is 
set by the Board.  No individual is involved in decision making on their own remuneration. 

Element of remuneration 

Policy and operation 

Board flexibility 

Fees are reviewed annually, taking into 
account time commitments and equivalent 
benchmarks to those used for the Executive 
Directors. 

The Company may permit the Chairman or 
Non-Executive  Directors  to  participate  in 
any benefits in kind. 

Fees are structured as a basic fee with 
additional fees for chairmanship or 
membership of Board Committees or 
further responsibilities (such as acting as 
Senior Independent Director). 

The Chairman receives a basic fee only. 

Fees 

To  enable  the  Company  to  recruit 
and  retain,  at  an  appropriate  cost, 
Non-Executive  Directors  with  the 
necessary  skills  and  experience  to 
oversee the  delivery of  the business 
strategy  

Cathy Turner  
Remuneration Committee Chair 

51 

 
 
 
Directors’ Report  

The Directors present their report and the financial statements of the Group for the twelve months ended 30 June 2021. As permitted by 
legislation, some of the matters normally included in the Directors’ Report are included by reference as detailed below. 

Requirement 

Detail 

Where to find further information: 

Section 

Location 

Business review  

Information  regarding  the  business  review  and  future 
developments, key performance indicators and principal risks 
are contained within the Strategic Report. 

Strategic Report 

Pages 4 to 9 
(Business review) 

Page 10 (Key 
performance 
indicators) 

Pages 62 to 64 
(Principal risks) 

Strategic report 

The contents of the Strategic Report fulfil Section 414C of the 
Companies Act 2006.    

Strategic Report 

Pages 4 to 31 

Results 

Dividend 

Financial 
instruments 

The results for the year are set out in the income statement. 
The profit before taxation for the year ended 30 June 2021 was 
£157.8  million  (year  ended  30  June  2020:  £48.8  million).  A 
review of the financial performance of the Group is included 
within the Strategic report. 

Income 
statement 

Strategic Report 

The Directors do not propose to recommend a final dividend in 
respect of the year ended 30 June 2021 (2020: £nil). 

– 

The Group uses financial instruments to manage certain types 
of risk, including liquidity and interest rate risk. Details of the 
objectives  and  risk  management  of  these  instruments  are 
contained in the risk management section. 

Risk 
Management 

Post balance sheet 
events 

On  29  July  2021, the  Group successfully  made  an  additional 
£200 million drawing on the Bank of England’s Term Funding 
Scheme with additional incentives for SMEs.  

Note  41  to  the 
consolidated 
financial               
statements. 

Page 100 

Page 10 

– 

Page 57 

Page 170 

52 

 
 
 
 
 
 
 
Share capital  

At  30  June  2021,  the  Company’s  share  capital  comprised 
2,439,016,380 ordinary shares of £0.10 each. 

The  Company  did  not  issue  or repurchase  any  of the  issued 
ordinary shares during the twelve months ended 30 June 2021 
or up to the date of this report. 

Details of the Company’s share capital are provided in note 33 
to the consolidated financial statements. 

Page 156 

Note  33  to  the 
consolidated 
financial               
statements. 

Rights and 
obligations 
attaching to shares 

There  are  no  restrictions  on  the  transfer  of  the  Company’s 
ordinary shares or on the exercise of the voting rights attached 
to them, except for: 

– 

– 

  where  the  Company  has  exercised  its  right  to 
suspend their voting rights or prohibit their transfer 
following the omission by their holder or any person 
interested  in  them  to  provide  the  Company  with 
information requested by it in accordance with Part 
22 of the Companies Act 2006; or 

  where  their  holder  is  precluded  from  exercising 
voting  rights  by  the  Financial  Conduct  Authority’s 
Listing  Rules  or  the  City  Code  on  Takeovers  and 
Mergers. 

All  the  Company’s  ordinary  shares  are  fully  paid  and  rank 
equally  in  all  respects  and  there  are  no  special  rights  with 
regard to control of the Company. 

Employee share 
scheme rights 

Details of how rights of shares in employee share schemes are 
exercised  when  not  directly  exercisable  by  employees  are 
provided in note 34 to the consolidated financial statements. 

Employees 

The Group is committed to employment policies, which follow 
best practice, based on equal opportunities for all employees, 
irrespective  of  gender,  race,  colour,  age,  disability,  sexual 
orientation  or  marital  or  civil  partner  status.  The  Group  is 
committed  to  ensuring  that  disabled  people  are  afforded 
equality  of  opportunity  with  respect  to  entering  into  and 
continuing employment with the Group. This includes all stages 
from  recruitment  and  selection,  terms  and  conditions  of 
employment, access to training and career development. 

Information on employee involvement and engagement can be 
found in the Strategic report. 

Page 157 

Note 34 to the 
consolidated 
financial 
statements 

Strategic Report 

Page4 

S172(1) 
Statement 

Page 28 

Corporate 
Responsibility  

Page 24 

Suppliers 

Information  on  supplier  engagement  can  be  found  in  the 
Strategic report. 

S172(1) 
Statement 

Page 28 

Corporate 
Governance 
Arrangements 

For  the  year  ended  30  June  2021,  under  the  Companies 
(Miscellaneous  Reporting)  Regulations  2018,  the  Aldermore 
Group PLC applied the Wates Corporate Governance Principles 
for  Large  Private  Companies,  published  by  the  Financial 
Reporting Council (‘FRC’) in December 2018. 

Further information can be found in the Corporate Governance 
report. 

Corporate 
Responsibility 

Corporate 
Governance 

Page 24 

Pages 35 

53 

 
 
 
 
 
 
 
 
 
Directors 

The names of the current Directors who served on the Board 
and  changes  to  the  composition  of  the  Board  that  have 
occurred  during  2021  and  2020  and  up  to  the  date  of  this 
report are provided on page 2 and are incorporated into the 
Directors’ Report by reference. 

Company 
Information 

Page 3 

Appointment and 
retirement of 
Directors 

The appointment and retirement of the Directors is governed 
by the Company’s Articles of  Association and  the  Companies 
Act 2006. The Company’s Articles of Association may only be 
amended by a special resolution passed by shareholders at a 
general meeting. 

Corporate 
–
governance 
Election  and  re-
election 

Page 3 

Directors’ 
indemnities 

Significant 
agreements 

Political donations 

Research and 
development 
activities 

According  to  the  Company’s  Articles  of  Association,  each 
Director shall retire at the Annual General Meeting held in the 
third calendar year following the year in which the Director was 
elected  or last re-elected  by the Company,  or at such earlier 
Annual General Meeting as the Directors may resolve.  

The Directors who served on the Board up to the date of this 
report  have  benefitted  from  qualifying  third-party  indemnity 
provisions by virtue of deeds of indemnity entered into by the 
Directors and the Company. The deeds indemnify the Directors 
to the maximum extent permitted by law and by the Articles of 
Association  of  the  Company,  in  respect  of  liabilities  (and 
associated costs and expenses) incurred in connection with the 
performance of their duties as a Director of the Company and 
any  associated  company,  as  defined  by  section  256  of  the 
Companies Act 2006. 

The  Group  also  maintains  Directors’  and  Officers’  liability 
insurance  which  provides  appropriate  cover  for  legal  actions 
brought against its Directors. 

None for 2021 (2020: None) 

£Nil for 2021 (2020: £Nil) 

The  Group  does  not  undertake  formal  research  and 
development  activities.  However,  new  products  and  services 
are  developed  in  each  of  the  business  lines  in  the  ordinary 
course of business in accordance with the Group’s product and 
pricing governance framework. Under this framework, all new 
products are reviewed and approved by the Group’s Customer 
Committee. 

– 

– 

– 

– 

– 

– 

Pages 151 

Note  24  to  the 
consolidated 
financial 
statements 

54 

 
 
 
– 

– 

Going concern  

The financial statements are prepared on a going concern basis. 
The Directors are satisfied that the Group has the resources to 
continue in business for the foreseeable future (which has been 
taken as 12 months from the date of approval of the financial 
statements)  and  that  there  are  no  material  uncertainties  to 
disclose.  In  making  this  assessment,  the  Directors  have 
considered a wide range of information and the impact of the 
Covid-19 pandemic on the current state of the balance sheet, 
future  projections  of  profitability,  cash  flows  and  capital 
resources, operational resilience and the longer-term strategy 
of the business. In particular, the Directors have considered the 
following: 

 

 

 

 

 

 

The impact on the Group’s profitability from future 
increases in expected  credit  losses.  As part of this, 
the  Directors  considered  revised  macroeconomic 
scenarios which were received from the Group’s in-
house experts. These are discussed and sensitivities 
are disclosed in note 3; 
Sufficiency of headroom  over  minimum regulatory 
requirements for liquidity and capital, including the 
ability of the Group to access sources of additional 
liquidity and / or capital if required;  
Current  and  forecasted  conditions  are  significantly 
less  severe  than  the  reverse  stress  scenario 
considered  in  the  latest  ICAAP  presented  to  the 
Prudential Regulation Authority; 
The  plans  for  further  improving  the  operational 
including  cyber  and 
resilience  of  the  Group 
information 
technology, 
supplier management, people and property. These 
improvements  are  planned  as  part  of  ongoing 
investment activity in the Aldermore Group; 
Any  potential  valuation  concerns  in  respect  of  the 
Group’s  assets  as  set  out  in  the  Company  and 
Consolidated Statements of Financial Position; 
The  validity of the Group’s  current strategy and its 
achievement of its longer-term strategic ambitions.  

information 

security, 

The  Group’s  capital  and  liquidity  plans,  including  stress  tests, 
have  been  reviewed  by  the  Directors  as  noted  above.  The 
Group’s forecasts and projections show that it will be able to 
operate at adequate levels of both liquidity and capital for the 
foreseeable  future,  including  under  a  range  of  stressed 
scenarios.  

After  making  due  enquiries,  the  Directors  believe  that  the 
Group has sufficient resources to continue its activities for the 
foreseeable  future,  and  the  Group  has  sufficient  capital  to 
enable 
its  regulatory  capital 
requirements as set out by the Prudential Regulation Authority. 

it  to  continue  to  meet 

55 

 
 
Disclosure of 
information to 
auditors 

Each person who is a Director at the date of this Directors’ 
Report confirms that: 

– 

– 

 

 

so far as the Director is aware, there is no relevant 
audit information of which the Group’s auditors are 
unaware; and  
he or she has taken all the steps that he or she ought 
to have taken as a Director to make himself or herself 
aware  of  any  relevant  audit  information  and  to 
establish  that  the  Group’s  auditor  is  aware  of 
that information.  This  confirmation  is  given  and 
should  be  interpreted  in  accordance  with  the 
provisions of the Companies Act 2006. 

Auditor 

Deloitte  LLP  was reappointed  as the  Company’s  auditor  with 
effect from the 2020 AGM, at which a resolution authorising 
the Board to set Deloitte’s remuneration was passed. 

- 

Page 41 

This report was approved by the board on 26 August 2021 and signed on its behalf: 

Claire Cordell 

Director 

14 September 2021 

56 

 
 
 
 
 
 
Risk Management  

All areas of the following report are covered by the external auditor’s opinion on pages 90 to 99, except for those areas highlighted 
in grey which are the yield curve on page 84, the leverage ratio and the risk weighted assets and associated capital ratios on page 
87.  

The Group’s approach to risk 

The Board is ultimately responsible for establishing and ensuring maintenance of a sound system of risk management and internal 
controls and approving the Group’s overall risk appetite.  

Effective risk management is a key pillar in the execution of the Group’s strategy. The Board and senior management seek to ensure 
that the risks the Group is taking are clearly identified, managed, monitored and reported and that the Group remains sustainable 
including during a plausible but severely adverse economic downturn and/or idiosyncratic conditions. 

The Risk  Management  Framework (“RMF”)  provides  the overarching  approach  on  how  the  Group  manages risk.  The following 
sections  provide  a  summary  of  the  RMF  within  the  Group.  It  highlights  our  governance  structure,  approach  to  risk,  key  risk 
management processes and the principal and emerging risks we face and the mitigating actions taken to address these.  

The Risk Management approach applies across Aldermore Bank and MotoNovo Finance. 

Risk principles 

 The following principles guide the Group’s overall approach to risk management: 

 

 

 

 

 

All colleagues should adopt the role of “risk manager” and take a prudent approach to risk management in all aspects of 
their role. The Board and senior management “lead from the front” and set the example with regard to risk management; 
Risk management is structured around the Group’s principal risk categories, which are reviewed at least annually as part 
of the RMF; 
The Group maintains a robust Risk Appetite Framework (“RAF”), manages to a consistent appetite using an approved set 
of metrics, and reports to senior management at least monthly; 
The  Group  ensures  that  it  remains  sustainable,  including  during  plausible  but  severely  adverse  economic  and/or 
idiosyncratic conditions; and 
The approach to remuneration ensures that fair customer outcomes and prudent decision-making within risk appetite 
are incentivised. Colleagues are not unduly rewarded for driving sales and/or profits. 

Risk management and internal control 

The Group’s risk management and internal control systems are designed to identify, manage, monitor and report on risks to which 
the  Group  is  exposed.  It  can  therefore,  only  provide  reasonable  but  not  absolute  assurance  against  the  risk  of  material 
misstatement or loss. Further details of the processes and procedures for managing and mitigating these risks are provided in the 
risk management section from page 57. 

The effectiveness of the internal controls was regularly reviewed by the Board, Audit Committee and Risk Committee during the 
period. This involved receiving reports from management including reports from Finance, Risk, Compliance, Internal Audit and the 
business  lines.  The  Audit  Committee  also  receives  reports  on  internal  controls  from  the  Group’s  external  auditor.  Where 
recommendations are identified for improvements to controls, these are monitored by Internal Audit who report the progress 
made in implementing them to the Audit Committee. 

Based on the review performed during the period, and the monitoring and oversight activities performed, the Audit Committee, in 
conjunction with the Risk Committee, concluded that the Group’s risk management and internal control systems were effective. 
The Audit Committee recommended a statement to this effect to the Board. 

Based  on  this  assessment,  the  Board  is  satisfied  with  the  effectiveness  of  the  Group’s  risk  management  and  internal  control 
systems. 

57 

 
 
 
Risk management framework 

The RMF defines Aldermore Group’s overall approach to risk management across all roles and material risk types. The RMF is the 
Group’s foremost  risk  document,  to  which  all  subsidiary risk  policies  and  frameworks  must  align.  The  RMF  is  subject  to  Board 
approval, at least annually. The RMF describes risk management roles and responsibilities, and outlines the Group’s approach to 
each material risk to which it is exposed. The RMF articulates the Group’s principal risks, i.e. the categories of risk that are most 
significant given the Group’s business model and operating environment. 

Risk governance and oversight 

The Group’s risk governance structure ensures the Board and senior management are accountable for overall risk management.  As 
part  of  the  Governance  Transformation  project  set  out  on  page 58,  our  risk  governance  structure  was  streamlined  in  2020  to 
support a  commercial,  nimble  approach  to  decision-making,  The Executive  Risk  Committee is the  formal executive  committee 
responsible for risk and its sub-committees have been reconstituted as fora as part of this transformation project.  The Board is 
responsible  for  approving  the  highest  materiality  risk  frameworks  and  policies,  following  recommendation  by  subsidiary 
committees. A delegated authority approves other frameworks and policies. 

Three lines of defence  

The Group employs a “three lines of defence” model to segregate responsibilities between:  

 
 
 

Risk management as part of business activities;  
Risk oversight; and  
Independent assurance.  

Each of the three lines of defence is responsible for maintaining a prudent and risk-aware culture. 

First line of defence – Business lines and central functions 

The first  line of  defence comprises  all colleagues in business  lines and  central functions that are not  part  of the Risk or Group 
Internal Audit functions. Key responsibilities with regard to risk management are as follows: 

Focus on achieving good customer outcomes while avoiding a dogmatic focus on sales and/or profits; 
Escalate risks via the risk event process; 

  Manage risk within the Group’s stated appetite in day-to-day business activities; 
 
 
  Maintain an up-to-date understanding of risk management responsibilities; and 
 

Proactively identify material risks and design mitigating controls. 

Second line of defence – Risk functions  

The second line of defence comprises all colleagues in the Risk function. Key responsibilities are as follows: 

Develop robust frameworks and policies to manage risk; 
Support the first line with embedding risk frameworks and policies; 

 
 
  Own the Group’s relationship with regulators and validate adherence with applicable regulation and legislation; 
 
  Oversee the delivery of material risk management processes, such as the Internal Capital Adequacy Assessment Process 
(“ICAAP”), Individual Liquidity Adequacy Assessment Process (“ILAAP”) and the Recovery and Resolution Plan (RRP). 

Co-ordinate the Group’s approach to setting and reporting on risk appetite; and 

Third line of defence – Internal Audit 

The third line of defence comprises all colleagues in the Group Internal Audit function. Key responsibilities are as follows: 

 

 
 

Provide  independent  assurance  to  the  Board  that  first  and  second  line  functions  are  properly  discharging  their  risk 
management responsibilities; 
Validate the appropriateness of risk management controls and governance; and 
Track internal and external audit actions to completion.  

58 

 
 
 
Risk appetite framework 

The RAF  defines  the  Group’s  approach  to  setting  risk  appetite  and  underpins  the approach  to  monitoring  Principal  Risks.  This 
Framework applies to  Aldermore Group  and to  all colleagues responsible for defining risk  appetite metrics  and/or statements, 
providing  risk appetite data  or monitoring  risk appetite reports. The Framework  defines the Group’s  approach  to  monthly  risk 
reporting to senior and working level committees and fora and is a core component of the Group’s RMF. The Framework is subject 
to Board approval at least annually. 

The Board provides oversight to ensure the Group adheres to the following principles when setting and monitoring risk appetite: 

 
 
 
 
 

The RAF is aligned with our Strategic Plan; 
Risk reporting is action-oriented; 
The Risk function provides independent challenge; 
The risk profile is monitored on an ongoing basis; and 
The framework is reviewed annually. 

Risk appetite statement 

A core objective of the Group’s Strategic Plan is to “build out the Aldermore Group through controlled, sustainable and customer-
centric growth”. The RAF supports the delivery of this objective, as reflected by the overarching risk appetite statement, as follows: 

“Operate  a  sustainable  and  safe  Group  that  conducts  its  activities  in  a  prudent  manner,  taking  into  account  the  interests  of 
customers and ensuring its obligations to key stakeholders are met.” Key stakeholders are defined as customers, parent company, 
regulators and employees. 

The principal risks identified within the Risk Management Framework have an overarching qualitative risk appetite statement and, 
where appropriate, quantitative metrics to measure the Group’s tolerance and appetite for risk. The suite of risk appetite metrics 
enable systematic monitoring of the risk profile against appetite and is reported to committees and fora on a monthly basis. The 
Group’s risk appetite is set by the Board and embedded down to each business line through the informal risk committees, driving 
a consistent message across the organisation.  

59 

 
 
 
 
 
 
Risk culture 

The Board is accountable for ensuring the Group actively embraces a strong risk culture, in which all staff are accountable for the 
risks that they take. Senior management leads in implementing the risk appetite and ensuring that the RMF is fully embedded, with 
adherence  to  risk  appetite  monitored  by  a  defined  suite  of  metrics.  Risk  management  is  embedded  in  the  design  of  staff 
performance management and reward practices. 
Risk culture is further embedded through: 

 
 
 
 

Framework for risk culture; 
Risk performance considerations; 
Alignment with the Internal Audit assessment methodology; and 
Risk-based remuneration, in part considering the strength and appropriateness of risk culture. 

Stress testing 

Stress testing is an important risk management tool, with specific approaches documented for the Group’s key annual assessments 
including the ICAAP, ILAAP, the RRP and Reverse Stress Testing (RST).  

We maintain a Stress Testing Framework (STF) which is updated on an annual basis, or more frequently if required, to assist the 
Board’s understanding of the key risks, scenarios and sensitivities that may adversely impact our financial or operational position. 
To ensure a coherent approach to stress testing, the Group adheres to the following core principles:  

 

Stress testing is an integral part of risk management. Results inform decision making at the appropriate level, including 
strategic decisions made by the Board and senior management; 
Stress testing draws on the experience and skills of staff across an appropriately wide range of disciplines; 

 
  Written policies and procedures govern the Group’s approach to stress testing, with dedicated policies maintained for 

 

 
 

material asset classes and types of stress test; 
Taken  as  a  whole,  stress  tests  span  a  range  of  analytical  techniques,  risk  types,  scenarios  and  severities  to  ensure  a 
complete  view  of  material  risks.  Stress  testing  systems  and  procedures  must  be  sufficiently  flexible  to  facilitate  this 
approach, while remaining proportionate to the Group’s size and activities; 
Consistent with the RMF, the Group reviews this Framework at least annually; and 
The STF relies upon and supports the Capital Planning and Management policy, the Funding and Liquidity policy and the 
Operational and Credit Risk Frameworks, all of which provide detail of how the STF has been implemented within these 
specific areas. 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Scope of the stress testing framework: 

Stress testing governance 

The Board’s key responsibilities in terms of stress testing are:  

 
 

Review and approve the STF following annual review; and 
Review and approve the ICAAP, ILAAP and Recovery Plan in line with regulatory rules and internal policies. As part of this, 
the Board will assess the approach to scenario design, stress testing methodologies and results. 

The Board Risk Committee key responsibilities in terms of stress testing are:  

 
 

Review the STF following annual review, and make a recommendation to the Board; and 
Review the ICAAP, ILAAP and Recovery Plan, and make recommendation to the Board to approve the documents. As part 
of this, the Board Risk Committee will assess the approach to scenario design, stress testing methodologies and results. 

61 

 
 
Principal risks 

Effective risk management is a core component of the Group, which is embedded throughout the organisation. The Board and 
senior management ensure that a strong risk culture is at the heart of everything we do, with risk appetite clearly defined, managed 
and reported against, and embedded down to business lines.  

The following section summarises the principal risks, which are the categories of risk that are most significant given our business 
model and operating environment, along with our approach to their mitigation. 

Principal risk 
Credit risk 

The risk of financial loss arising 
from a borrower or a counterparty 
failing to meet financial obligations 
to the Group according to agreed 
terms. 

Refer to page 43. 

Capital risk 

The risk that the Group has 
insufficient capital resources, e.g. 
retained profits and qualifying 
financial instruments, to cover 
regulatory requirements and/or 
support growth plans. 

Refer to page 44. 

Liquidity risk 

The risk that we are unable to 
meet our financial obligations as 
they fall due, or can only do so at 
excessive cost.  

Refer to page 44. 

Mitigation 
  Operate  in  selected  sectors  and  products,  where  we 
have expertise to originate and underwrite transactions 
within the agreed risk appetite; 

  Maintain  controlled  levels  of  credit  losses  within  an 
agreed  expected  loss  appetite,  operating  through  the 
economic cycle; 

  Where  appropriate,  obtain  physical  or 

financial 

collateral;  

 

 

  Origination  is  supported  by  robust  post-completion 
credit stewardship and in-life management of the credit 
portfolio; 
Perform  strict  daily  management  of  customer  credit 
risk, including adherence to explicit concentration and 
credit rating limits; 
Credit 
reported 
systematically against  appetite through a  set  of credit 
risk metrics with associated triggers and limits, driving 
management actions where appropriate; and 
Throughout the current Covid-19 crisis there has been 
a specific focus on managing customer forbearance and 
the associated impact on expected credit losses (“ECL”) 
movements. 

is  monitored  and 

risk  profile 

 

  Maintain robust controls for Pillar 1 reporting; 
 

Perform a comprehensive annual ICAAP assessment of 
all material capital risks; 
Plan to meet capital requirements on a forward-looking 
basis,  formally  assessing  confirmed  and  potential 
changes in regulatory rules; and 
To a quantity deemed appropriate, maintain an internal 
capital  buffer  over  and  above  fully  loaded  regulatory 
requirements  to  protect  against  unexpected  losses  or 
risk-weighted asset growth. 

 

 

Commentary 

Although the outlook 
has been improving, the 
pace of recovery has 
been dampened slightly 
by the recent rise in 
Covid-19 infections. We 
continue to remain 
cautious around 
impacted sectors and 
origination levels remain 
constrained to where 
our appetite lies in the 
current environment. 

The Group’s capital 
remains stable despite 
Covid-19. Moreover, the 
Group’s Capital position 
remains well above 
internal targets and 
regulatory minimums. 

  Maintain a sufficient portfolio of cash and high quality 
liquid assets (“HQLA”) to absorb liquidity shocks; 
Perform a comprehensive annual ILAAP assessment of 
all material liquidity risks and meet internal buffers on 
an ongoing basis; and 

 

  Monitor the Group’s liquidity position on a daily basis, 
intra-month  escalation  of  material  risks  as 

with 
appropriate. 

The Group’s liquidity 
position remains stable 
despite Covid-19 and 
has been managed well 
within liquidity buffers. 

62 

 
 
 
 
 
 
 
Market risk 

The risk arising from adverse 
movements in market prices given 
long or short positions in impacted 
assets and / or liabilities.  

Refer to page 44. 

Operational risk 

The risk of loss resulting from 
inadequate or failed internal 
processes, people and systems or 
from external events. 

Compliance, conduct and financial 
crime risk 

The risk of legal or regulatory 
sanctions, material financial loss, 
or loss to reputation as a result of a 
failure to comply with applicable 
laws and regulations, codes of 
conduct and standards of good 
practice or as a result of the 
Group’s activities being used by 
criminals for the purposes of 
money laundering, terrorist 
financing, bribery and corruption 
and fraud 

 

Seek to match the interest rate structure of assets and 
liabilities, creating a natural hedge; 

  Where  a  natural  hedge  is  not  possible  or  desirable, 
hedge  any  material  market  risk  exposure  by  using 
financial  instruments  as  outlined  in  the  Treasury  Risk 
Limits and Standards; 
Perform  a  comprehensive  assessment  of  market  risk 
drivers as part of the ICAAP and assess new/emerging 
risks on an ongoing basis;  

 

  Maintain  a  strong  control  framework  to  ensure 
exposures are managed in line with risk appetite; and    
  Monitor the Group’s Market Risk exposure on a regular 
basis  (including  daily  monitoring),  with  intra-month 
escalations as appropriate. 

  Maintain a comprehensive Risk Control Self-Assessment 
(“RCSA”) process. Assess the efficacy of these controls 
by maintaining a robust approach to business assurance 
testing; 

 
 

  Maintain the risk event reporting process;  
  Mandate  detailed  and  coherent  committee  and  fora 
reporting  that  brings  together  a  diverse  range  of 
supporting risks; 
Ensure a significant emphasis on IT resilience; 
Regularly  review  the  external  threat  posed  by  cyber-
crime  and  ensure  the  adequacy/effectiveness  of  our 
defences; 
Systematically monitor operational losses on both a net 
(overall 
(excluding 
recoveries) basis to understand risk profile and identify 
trends; and 
Proactively  identify  changes  to  our  risk  profile  and 
manage  any  changes 
to  our  control 
environment as Covid-19 pandemic restrictions ease. 

impact)  and  gross 

required 

financial 

 

 

 

  Maintain  a  well-defined  and  embedded  process  for 
legislative  horizon  scanning,  and 

regulatory  and 
preparation for confirmed and potential changes; 
  Maintain  processes  that  focus  on  fair  customer 
outcomes, 
including  the  use  of  metrics  on  staff 
performance, training, customer feedback, complaints 
and product cancellation; 
Ensure that recruitment and training processes have a 
clear  customer  focus,  including  the  use  of  mandatory 
training modules; 
Ensure the approach to remuneration incentivises fair 
customer  outcomes  and  prudent  decision-making 
within risk appetite; 
Perform the requisite checks on all customers, including 
money  laundering,  sanctions  and  fraud  at  origination, 
and  where  appropriate,  on  an  ongoing  basis.  Tightly 
monitor  remedial  actions  relating  to  financial  crime 
breaches; and 
Produce an annual Money Laundering Reporting Officer 
(“MLRO”) Report, which is approved at BRC, and which 
includes  an  opinion  from  the  MLRO  relating  to  the 

 

 

 

The Group’s approach 
remains prudent and 
underlying risks remain 
unchanged. 

The Operational Risk 
profile has reverted to 
stable, with any 
remaining changes to 
the operational control 
environment due to 
Covid-19 incorporated 
into BAU risk 
management.    

The Compliance 
Conduct and Financial 
Crime key risks remain 
unchanged. Our 
collections teams have 
seen a significant uplift 
in activity throughout 
the pandemic and the 
Group continues to 
closely monitor risks 
around unfair outcomes 
to customers, however, 
the outlook has 
stabilised.   

63 

 
 
 
 
 
 
 
Reputational risk 

 

The risk of negative consequences 
arising from a failure to meet the 
expectations and standards of our 
customers, investors, regulators or 
other stakeholders during the 
conduct of any business activities. 

adequacy of the Group’s existing systems and controls 
for  the  prevention  of  money  laundering  and  terrorist 
financing risk. 
Assess  the 
impact  of  reputational  risk  at  the 
‘Reputational Risk Fora’ chaired by the Chief Risk Officer 
and initiate mitigating actions as appropriate 

  Maintain  a  clear  and  explicit  set  of  reputational  risk 
policy  requirements  to  which  all  colleagues  must 
confirm their understanding and adherence; and 
Ensure  that  the  reputational  impact  of  changes  to 
products,  pricing,  systems  and  processes  is  formally 
considered at the relevant committees and fora. 

 

The Group’s risk profile 
remains within appetite. 
We remain mindful of 
our performance against 
the expectations of our 
stakeholders. 

 

 

Model Risk  

The potential for adverse 
consequences from decisions 
based on incorrect or misused 
model outputs and reports. 
Consequences can include poor 
business decisions, financial loss or 
the misstatement of financial 
and/or regulatory reports. 

Skilled  second-line  risk  team  is  in  place  to  drive  and 
oversee model development and ongoing maintenance. 
A robust Model Management Framework which details 
processes  and  controls  for  managing  risk  throughout 
the model lifecycle, which include: 
o  Assigning accountable owners for all models; 
o 

Ensuring  models  are  well-documented,  with  a 
clear  understanding  of  strengths,  limitations  and 
assumptions; 

o  Assigning a model risk rating based on materiality 
to the Group. The rating drives level of validation, 
approval and performance monitoring; 
Ensuring every model is subject to validation and 
formal  approval  prior  to  implementation  and 
thereafter on a regular basis; and 

o 

o  Regular tracking of model performance, including 
a robust process to remediate identified issues. 

In recognition of 
increased sophistication 
and enhancements in 
the Group’s modelling 
approaches, further 
elaboration of Model 
Risk will be carried out 
in Q4 2021. This 
includes the 
development of an 
associated Board 
approved risk appetite 
statement. 

64 

 
 
 
 
Emerging risks 

We  define  emerging  risks  as those  risks  that  are specifically  forward-looking,  the  likelihood  and/or  impact  of  which  cannot  be 

readily quantified and which have not yet crystallised. Emerging risks for the Group include: 

       Risk 

Themes 
Regulatory Change or Intervention 
Government and 
regulatory response to 
Covid-19 

  As a result of the global pandemic, and the 

lockdown of UK PLC, the Government and UK 
regulators intervened with a number of 
measures to support the economy and the 
customers who would be experiencing 
financial difficulties as a result – namely to 
provide customers with payment breaks for a 
range of financial services products, including 
those offered by Aldermore Group. 

  As a result of payment breaks needing to be 

repaid, and the threat of increased 
forbearance through a declining economic 
outlook, there is a risk that an increase in 
service demand is difficult to meet (both from 
a capacity and capability perspective) and that 
this impacts financial performance and 
customer outcomes. 

  The Group remains cognisant that Covid-19 is 
still ongoing, and unprecedented in its nature. 
As restrictions ease the Group continues to 
monitor implications and take a cautious 
approach and in full compliance with 
Government guidelines. 

  Climate change and society’s response to it 

presents a global threat. The risks associated 
with climate change arise via two primary 
transmission channels: the physical effects of 
climate change, and the impact of changes 
associated with the transition to a lower-
carbon economy (i.e. increased energy 
efficient standards on Buy to Let properties). 
These risks manifest themselves across and 
amplify other financial and non-financial risk 
types. 

Risks from Climate 
Change 

What we are currently doing 

 

In response to this risk, the Group has 
focused on increasing capacity and 
capability in the collections space in order 
to support future spikes in service demand 
driven by the aftermath of payment break 
requests and managing these back into 
performance, as well as a potential future 
spike in arrears due to a potential 
downturn. 

  The Group will continue to focus on 

supporting its customers, managing risks 
appropriately and meeting regulatory 
obligations. 

  Our CRO has responsibility for overseeing 
the development of approach and 
ensuring it is grounded in risk 
management, engaging with key 
members of ExCo including the CFO, with 
oversight from the Board Risk Committee. 

 

 

Implementation of a multi-year plan is 
underway - including near-term 
introduction of framework for climate 
risk, development of internal capabilities 
and tools.  

The Group is developing our approach 
and disclosures in line with accepted and 
emerging standards, including the 
Taskforce for Climate-related Financial 
Disclosures. 

65 

 
 
 
 
 
 
Economic and Political Environment 

Declining Retail customer 
income or affordability 

  The key risk to mortgage credit performance 
is loss of income or declining affordability, for 
example customers becoming unemployed, 
increasing their debt burden or facing higher 
interest rates. 

  The Covid-19 pandemic continues to 

challenge affordability as customers lose 
income. Further impacts may be felt if the 
furlough scheme finally terminates at the end 
of September 2021 as planned. 

  We are reviewing our product range, with 
a view to increase our offering at the 
appropriate time but continue to be 
mindful of economic conditions and 
lending capacity.  

  We continue to apply enhanced income 
checks as part of our underwriting. 
Tighter automated credit rules, 
implemented at the start of the 
pandemic, remain in place. 

 

Covid-19 – Operational 
impacts  

  The economic environment created by the 

impacts of Covid-19 has created an increased 
market demand for certain skillsets, 
particularly in the collections space, which 
continues to challenge us from an operational 
capacity perspective.   

  A plan is in place to increase capacity in 
collections including deployment of 
existing resources along with use of third 
parties to allow the Group to continue to 
scale up resources where required.  
The Group continues to proactively 
monitor any changing impacts on our 
operations as the pandemic continues and 
restrictions are eased. 

 

 

 

A new Forward Looking Indicator model 
has been implemented which provides a 
better indication of the forward looking 
macroeconomic adjustments.  Further 
validation of the impact of this will be 
undertaken during 2022. 

Post Model Adjustments continue to be 
assessed on a regular basis for their 
continued appropriateness. 

  2020 saw extreme earnings volatility as a 

result of Covid-19’s impact on forward looking 
macroeconomic scenarios and its impact on 
credit losses.  

  This has continued to result in a higher than 
pre-Covid-19 proportion of Post Model 
Adjustments in the credit provisioning, albeit 
these are slightly reduced from 2020 year 
end.  

  The charge for impairment losses has reduced 
as the forward-looking economic outlook has 
become more stable.  

Covid-19 – ongoing 
impact on credit 
provisioning 

Significant UK downturn 

Auto market uncertainty 
/ change 

  As a UK-only firm, the Group is exposed to a 
deteriorating UK economy, including adverse 
impacts on economic growth, unemployment, 
consumer credit, inflation, property prices and 
interest rates, including potential for 
additional impacts should further Covid-19 
lockdowns be required. 

  A wide range of mitigating actions are 
taken as part of “business as usual”, 
including the use of robust stress tests 
(both for individual loan applicants and the 
entire balance sheet), the purchase of 
Mortgage Indemnity Guarantees and the 
hedging of interest rate risk. 

  Driven by a shift in social conscience, 

exacerbated by a number of high-profile 
scandals, and enabled by technological 
development, the auto industry is amidst a 
period of uncertainty and is starting to 
embark on a period of significant change that 
will impact a number of key areas including:  
Alternative Fuel Vehicles, Autonomous 
Vehicles, Access v Ownership, and Vehicle 
Values. 

  With the largest exposure from a Group 
perspective, the MotoNovo Finance 
strategy remains well placed to further 
support the market post crisis recovery and 
reinvention with a digital offering and focus 
on future trends that could accelerate as a 
consequence of the Covid-19. 
  As to the Asset Finance business, its 

proposition is more focused in specific 
niches. Whilst the overall market dynamics 
will impact, we will adapt origination and 

66 

 
 
 
 
 
 
 
Exposure to geopolitical 
risk 

Competitive Environment 
Competitive dynamics in 
Retail Finance 

Heightened competition 
in motor finance market  

  The risks are that a shift in these scenarios 

could result in high levels of exposure on the 
current book of Aldermore vehicle assets, 
however, currently consumer demand 
remains strong in the used market, but we 
continue to monitor closely. 

risk management to reflect the changes 
and outlook.  

  Continue to monitor the threats and 

opportunities. 

  Watching brief to be maintained on these 

risks, which are tracked in the 
macroeconomic forecasts reporting 
produced. 

 

 

 

There is a potential rebalancing of global 
power post Covid-19 towards China / Asia. 
This could threaten the ability of NATO / EU 
to shape and defend rules-based 
international order.  

Covid-19 highlighted supply chain 
vulnerabilities. Economic nationalism and 
export restrictions could lead to a longer-
term protectionism trend and a resurgence 
of nation state power. This could be 
particularly pronounced between the UK-EU 
given recent tensions emanating from Brexit. 

There is the potential for increased inter-
state conflict and separation, particularly as 
the US continues to decouple China from its 
supply chain.   

  Competition in the Group’s selected markets 
arises from a range of sources, including 
challengers and non-bank lenders. Heightened 
competition may lead to margin compression 
and lower growth, both key drivers of 
profitability. 

  We have developed specialist market-

leading analytics to improve insight into 
the market and our own performance and 
risk profile.  

  We also regularly review competitor 
performance and propositions. 

  MotoNovo Finance has begun to adjust 
and segment its approach to strategy in 
light of the market dynamics and 
competitor threat. A strategic review is 
nearing completion. 

  Traditionally, new entrants into the Motor 

Finance space will have been from the asset 
finance or general banking/finance space. 
However, not only are returns in the market 
currently healthy, giving rise to increase in 
traditional new entrants, but with the 
development of technology, and the level of 
change on the horizon for the auto industry in 
general, the barriers to entry have reduced 
and therefore the risk of new players from a 
variety of different sources entering the 
market is increasing.  

67 

 
 
 
 
 
 
 
 Technology Risk 
Cyber-crime incidents 

Failure of an outsource 
provider or supplier 

  Cyber threat remains significant and high 
profile across all industries.  Cyber threats 
continue to evolve, with increased 
monetisation of cyber to substitute more 
traditional crime. 

  The industry continues to see increased 

Phishing/Smishing attempts with attackers 
capitalising on the Covid-19 situation. 

  The Group has a number of material and 

critical outsource or third-party arrangements 
that are core elements of the supply chain. The 
failure of one of these key partners could 
significantly affect the Group’s customers, 
operations and reputation. 

Detrimental impact on 
customers from an IT 
failure 

  The Group deploys services through a mix of 
hosted systems, both externally hosted or 
hosted on behalf of the Group.  

  The risk is the potential detrimental impact to 

the Group from an IT failure. 

Negative Interest Rates  

  Risk that the Aldermore Group is exposed to a 
UK negative or zero interest rate policy.  
  The BoE on 4th February 2021 set a six-month 
notice period to 5th August 2021 for the 
financial services industry to be tactically ready 
to administer negative rates. 

  The Group continues to focus on the cyber 

threat and continues to invest in 
enhancements to the systems and controls 
to prevent, identify and respond to cyber 
threats. 

 

 

 

The Group continues to maintain controls 
and governance in relation to the 
operating framework for suppliers.  

The Supplier Relationship Model is being 
refined and updated in line with EBA/PRA 
third party guidance. 

Effective third-party supplier management 
is a critical pillar of Operational Resilience 
and the Group has further initiatives 
planned as part of broader enhancement 
activities in this area.  

  Good progress continues on plans to 

migrate the Motor and Bank tenancies, 
enabling a number of collaboration 
features across the Group. 

  The Group continues to perform robust risk 
assessments and mitigation of the risks 
from an IT failure.  

  Scenarios and simulated exercises are run, 
as part of incident management testing, to 
mitigate this risk. 

  Whilst the probability of negative interest 
rates has decreased, the Group has put in 
place manual workarounds to satisfy the 
readiness requirement until permanent 
system solutions can be implemented.  

68 

 
 
Credit Risk 

Credit risk is the risk of financial loss arising from the borrower or a counterparty failing to meet their financial obligations to the 
Group in accordance with agreed terms. The risk primarily crystallises by customers defaulting on lending facilities. Credit risk also 
arises from treasury investments and off-balance sheet activities and any other receivables, which are typically sub-categorised as 
counterparty credit risk. 

The credit risk section of this report includes information on the following: 

1.  The Group’s maximum exposure to credit risk; 
2.  Credit quality and performance of loans; 
3.  Forbearance granted through the flexing of contractual agreements; 
4.  Diversity and concentration within our loan portfolio; 
5.  Details of provisioning coverage and the value of assets against which loans are secured; and 
6. 

Information on credit risk within our treasury operations. 

Due to the more bespoke nature of the Property Development business, the portfolio is excluded from a number of the following 
tables, as indicated by the footnotes. Gross Property Development exposure at 30 June 2021 was £134 million (30 June 2020: £244 
million), and net exposure was £131 million (30 June 2020: £242 million). 

1. The Group’s maximum exposure to credit risk 

The following table presents our maximum exposure to credit risk of financial instruments on the balance sheet and commitments 
to lend before taking into account any collateral held or other credit enhancements. The maximum exposure to credit risk for loans, 
debt securities, derivatives and other on-balance sheet financial instruments is the carrying amount and for loan commitments, 
the full amount of any commitment to lend that is either irrevocable or revocable only in response to material adverse change. 

Our net credit risk exposure as at 30 June 2021 was £16,792.9 million (30 June 2020: £15,510.3 million), an increase of 8.3%. The 
main factors contributing to the increase were: 

i) 
ii) 
iii) 

the growth in gross loans and advances to customers (our largest credit risk exposure), by £1,026.1 million; 
the growth in cash and balances at central banks by £146.1 million; and  
an increase in commitments to lend by £69.9 million. 

Included in the statement of financial position: 
Cash and balances at central banks 
Loans and advances to banks 
Debt securities 
Derivatives held for risk management 
Loans and advances to customers 
Other financial assets 

Irrevocable Commitments to lend  
Gross credit risk exposure 
Less: allowance for impairment losses 
Net credit risk exposure 

Note 

19 
39 

37 

19 

30 June 
2021 
 £m 
688.5 
223.0 
1,999.5 
19.6 
13,612.6 
29.5 
16,572.7 
412.4 
16,985.1 
(192.2) 
16,792.9 

30 June 
2020 
 £m 
542.4 
228.6 
1,941.1 
9.3 
12,586.5 
20.7 
15,328.6 
342.5 
15,671.1 
(160.8) 
15,510.3 

69 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2. Credit quality and performance of loans  

The credit quality of loans and advances to customers are analysed internally in the following tables, which also include the fair 

value of collateral held capped at the gross exposure amount. In the past 12 months, the Group has implemented a new 

macroeconomic model to increase sensitivity to forward-looking macro scenarios and undertaken an upward recalibration of a 

number of the Probability of Default (PD) models. These modelling changes have resulted in some general upward migration of 

PDs across the portfolio in the current year. 

Stage 1 per IFRS 9 – no significant increase in credit risk since initial recognition: 

30 June 2021 
Low risk 
Medium risk 
High risk 
Total 
Fair value of collateral held 

Asset 
Finance 
£m 
52.9 
1,005.5 
311.7 
1,370.1 
877.1 

Invoice 
Finance 
£m 
3.2 
238.6 
157.1 
398.9 
413.9 

SME 
Commercial 
Mortgages1 
£m 
144.7 
755.5 
26.5 
926.7 
926.7 

Buy to Let 
£m 
722.1 
3,848.1 
112.7 
4,682.9 
4,682.9 

Residential 
Mortgages 
£m 
314.5 
1406.0 
109.9 
1,830.4 
1,830.4 

MotoNovo 
Finance 
£m 
1,888.5 
990.5 
46.1 
2,925.1 
2,925.1 

Total 
£m 
3,125.9 
8,244.2 
764.0 
12,134.1 
11,656.1 

Stage 2 per IFRS 9 – a significant increase in credit risk since initial recognition: 

30 June 2021 
Low risk 
Medium risk 
High risk 
Total 
Fair value of collateral held 

Asset 
Finance 
 £m 
0.5 
75.8 
118.7 
195.0 
117.0 

Invoice 
Finance 
 £m 
- 
1.1 
2.8 
3.9 
3.9 

SME 
Commercial 
Mortgages1 
 £m 
9.9 
110.9 
43.8 
164.6 
164.6 

Buy to Let 
 £m 
22.6 
213.6 
148.0 
384.2 
384.2 

Residential 
Mortgages 
 £m 
15.9 
110.6 
82.5 
209.0 
209.0 

MotoNovo 
Finance 
 £m 
31.4 
90.2 
7.8 
129.4 
129.4 

Total 
£m 
80.3 
602.2 
403.6 
1,086.1 
1,008.1 

Stage 3 per IFRS 9 – credit impaired assets: 

Asset 
Finance 
 £m 
30 June 2021 
46.7 
High risk 
46.7 
Total 
28.7 
Fair value of collateral held 
¹ The above analysis includes Property Development. 

Invoice 
Finance 
 £m 
3.6 
3.6 
1.7 

SME 
Commercial 
Mortgages1 
 £m 
56.1 
56.1 
56.1 

Buy to Let 
 £m 
127.5 
127.5 
127.5 

Residential 
Mortgages 
 £m 
110.1 
110.1 
110.1 

MotoNovo 
Finance 
 £m 
48.4 
48.4 
48.4 

Total 
£m 
392.4 
392.4 
372.5 

Stage 1 per IFRS 9 – no significant increase in credit risk since initial recognition: 

30 June 2020 
Low risk 
Medium risk 
High risk 
Total 
Fair value of collateral held 

Asset 
Finance 
£m 
49.9 
1,153.8 
345.9 
1,549.6 
1,027.0 

Invoice 
Finance 
£m 
- 
148.7 
97.1 
245.8 
245.8 

SME 
Commercial 
Mortgages1 
£m 
535.1 
359.4 
25.0 
919.5 
876.5 

Buy to Let 
£m 
3,505.7 
924.3 
24.5 
4,654.5 
4,654.5 

Residential 
Mortgages 
£m 
1315.5 
539.1 
25.0 
1,879.6 
1,879.6 

MotoNovo 
Finance 
£m 
1,047.6 
641.7 
54.1 
1,743.4 
1,743.4 

Total 
£m 
6,653.8 
3,767.0 
571.6 
10,992.4 
10,426.8 

70 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Stage 2 per IFRS 9 – a significant increase in credit risk since initial recognition: 

30 June 2020 
Low risk 
Medium risk 
High risk 
Total 
Fair value of collateral held 

Asset 
Finance 
 £m 
5.5 
185.9 
128.2 
319.6 
182.9 

Stage 3 per IFRS 9 – credit impaired assets: 

Asset 
Finance 
 £m 
30 June 2020 
38.2 
High risk 
38.2 
Total 
Fair value of collateral held 
19.9 
¹ The above analysis includes Property Development. 

Invoice 
Finance 
 £m 
- 
16.5 
15.7 
32.2 
33.3 

SME 
Commercial 
Mortgages1 
 £m 
68.6 
116.4 
22.8 
207.8 
193.5 

Invoice 
Finance 
 £m 
6.3 
6.3 
2.1 

SME 
Commercial 
Mortgages1 
 £m 
28.3 
28.3 
28.3 

Buy to Let 
 £m 
196.2 
249.8 
89.4 
535.4 
535.4 

Residential 
Mortgages 
 £m 
23.5 
54.5 
61.1 
139.1 
139.1 

MotoNovo 
Finance 
 £m 
25.9 
84.6 
11.6 
122.1 
122.1 

Total 

£m 
319.7 
707.8 
328.8 
1,356.3 
1,206.3 

Buy to Let 
 £m 
79.2 
79.2 
79.2 

Residential 
Mortgages 
 £m 
72.0 
72.0 
72.0 

MotoNovo 
Finance 
 £m 
13.8 
13.8 
13.8 

Total 

£m 
237.8 
237.8 
215.3 

The credit quality in respect of irrevocable commitments to lend, which, as at 30 June 2021 and 30 June 2020, were all stage 1 

exposures was as per the following table, which also includes the fair value of collateral to be provided capped at the gross 
exposure amount. 

Asset Finance 

Invoice 
Finance 

SME Commercial 
Mortgages1 

Buy to Let 

Residential 
Mortgages 

MotoNovo 
Finance 

30 June 2021 

Low risk 

Medium risk 

High risk 

Total 

Assessed fair value of collateral to be 
provided 

¹ The above analysis excludes Property Development. 

£m 
- 

- 

- 

- 

- 

£m 
- 

- 

- 

- 

- 

£m 
11.6 

60.9 

2.2 

74.7 

74.7 

£m 
9.1 

48.0 

1.4 

58.5 

58.5 

£m 
17.5 

78.4 

6.1 

102.0 

102.0 

£m 
- 

33.9 

3.6 

37.5 

37.5 

Asset Finance 

Invoice 
Finance 

SME Commercial 
Mortgages1 

Buy to Let 

Residential 
Mortgages 

MotoNovo 
Finance 

30 June 2020 

Low risk 

Medium risk 

High risk 

Total 

Assessed fair value of collateral to be 
provided 

¹ The above analysis excludes Property Development. 

£m 
- 

- 

- 

- 

- 

£m 
- 

- 

- 

- 

- 

£m 
26.4 

17.7 

1.2 

45.3 

45.3 

£m 
50.0 

12.4 

0.3 

62.7 

62.7 

£m 
34.2 

14.0 

0.7 

48.9 

48.9 

£m 
- 

23.4 

17.4 

40.8 

40.8 

Total 

£m 
38.2 

221.2 

13.3 

272.7 

272.7 

Total 

£m 
110.6 

67.5 

19.6 

197.7 

197.7 

71 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Not  included  in  the  above  are  £139.7  million  (30  June  2020:  £144.8  million)  of  irrevocable  commitments  to lend  for  Property 
Development. We use “loan-to-gross-development-value” as an indicator of the quality of credit security of performing loans for 
the Property Development portfolio. Loan-to-gross-development-value is a measure used to monitor the loan balance compared 
with the expected gross development value once the development is complete. The anticipated gross development value of the 
committed lending for Property Development is £380.3 million (30 June 2020: £674.5 million).  

The categorisation of high, medium and low risk is based on internal IFRS 9 Probability of Default (“PD”) and Loss Given Default 
“LGD” models. Drivers for the PDs and LGDs include external credit reference agency risk scores, property valuations and qualitative 
factors.  The  relative  measure  of  risk  reflects  a  combined  assessment  of  the  probability  of  default  by  the  customer  and  an 
assessment of the expected loss in the event of default.  

The resulting classification of balances between low, medium and high is consequently driven by a combination of the PD and LGD 
grades. A matrix of eighteen PD (fifteen of which apply to up-to-date accounts) and ten LGD grades determine the category within 
which each loan is categorised, i.e. those accounts that have a low PD and/or low LGD are graded as ‘low’. Those graded ‘high’ will 
be accounts that have either a high PD and/or high LGD.   

3. Forbearance granted through the flexing of contractual agreements 

Forbearance  is  defined  as  any  concessionary  arrangement  that  is made  for  a period  of  three  months or more where  financial 
difficulty is present or imminent. It is inevitable that some borrowers experience financial difficulties which impact their ability to 
meet their obligations as per the contractual terms. We seek to identify borrowers who are experiencing financial difficulties, as 
well as contacting borrowers whose loans have gone into arrears, consulting with them in order to ascertain the reason for the 
difficulties and to establish the best course of action to bring the account up-to-date. In certain circumstances, where the borrower 
is experiencing financial distress, we may use forbearance measures to assist the borrower. These are considered on a case-by-
case basis and must result in a fair outcome. The forbearance measures are undertaken in order to achieve the best outcome for 
both the customer and the Group by dealing with financial difficulties and arrears at an early stage.  

The  most  widely  used  methods  of  forbearance  are  temporarily  reduced  monthly  payments,  loan  term  extension,  deferral  of 
payment and a temporary or permanent transfer to interest only payments to reduce the borrower’s financial pressures. Where 
the  arrangement  is  temporary,  borrowers  are  expected  to  resume  normal  payments  within  six  months.  Both  temporary  and 
permanent concessions are reported as forborne for twenty-four months following the end of the concession. Forborne amounts 
disclosed as stage 1 in the below table relate to such accounts which are now performing but still reported as forborne following 
the end of concessionary arrangements. In all cases, the above definitions are subject to no further concessions being made and 
the customers’ compliance with the new terms. 

Forbearance levels increased significantly in the prior year due to Covid-19 payment breaks, although they have reduced materially 
in the current year as customers started to repay. The Group still has a proportion of accounts that were subject to a deferred 
payment as at 30 June 2021 with the balance of forborne accounts by payment status shown in the tables below. Forbearance is 
usually a trigger for accounts to be moved into stage 2 or stage 3. Where payment breaks have been provided in relation to Covid-
19 the accounts have been retained in stage 1 but an additional Post Model Adjustment (“PMA”) has been applied to reflect the 
increased risk in this population (see note 3(a) for further detail on PMAs which the Group applies to the modelled IFRS 9 ECL 
provisions). The Group’s policy is to classify all customers exceeding 6 months of payment breaks as stage 3. 

30 June 2021 

Asset Finance 
 £m 
0.3 
0.3 
4.3 
4.9 

Stage 1 
Stage 2 
Stage 3 
Total 
¹ The above analysis includes Property Development. 

Invoice 
Finance 
 £m 
- 
0.3 
- 
0.3 

SME 
Commercial 
Mortgages1 
 £m 
- 
6.3 
10.5 
16.8 

Buy to Let 
 £m 
23.9 
3.9 
19.3 
47.1 

Residential 
Mortgages 
 £m 
5.9 
4.3 
26.2 
36.4 

MotoNovo 
Finance 
£m 
2.7 
7.7 
10.9 
21.3 

Total 
 £m  

32.8 
22.8 
71.2 
126.8 

72 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
30 June 2020 

Stage 1 
Stage 2 
Stage 3 
Total 

Asset Finance 
 £m 
333.9 
100.3 
6.1 
440.3 

Invoice 
Finance 
 £m 
0.4 
20.3 
1.2 
21.9 

SME 
Commercial 
Mortgages1 
 £m 
49.6 
25.6 
8.5 
83.7 

Buy to Let 
 £m 
683.4 
103.7 
11.0 
798.1 

Residential 
Mortgages 
 £m 
404.0 
33.8 
21.8 
459.6 

MotoNovo 
Finance 
£m 
165.3 
26.8 
5.1 
197.2 

Total 
 £m  

1,636.6 
310.5 
53.7 
2,000.8 

¹ The above analysis includes Property Development. 

As at 30 June 2021, we had undertaken forbearance measures as follows in the following segments: 

30 June 2021 
 £m 

30 June 2020 
 £m  

Asset Finance 
Reduced monthly payments 
Loan-term extension 
Deferred payment 
Total Asset Finance 
Forborne as a percentage of the total divisional gross lending book (%) 

Invoice Finance 
Agreement to advance funds in excess of normal contractual terms 
Total Invoice Finance 
Forborne as a percentage of the total divisional gross lending book (%) 

SME Commercial Mortgages1 
Temporary or permanent switch to interest only  
Deferred payment 
Total SME Commercial Mortgages 
Forborne as a percentage of the total divisional gross lending book (%) 

Buy to Let  
Temporary or permanent switch to interest only  
Reduced monthly payments 
Payment, waiver or lower rate product switch 
Deferred payment 
Total Buy to Let 
Forborne as a percentage of the total divisional gross lending book (%) 

Residential Mortgages 
Temporary or permanent switch to interest only 
Reduced monthly payments 
Payment, waiver or lower rate product switch 
Deferred payment 
Total Residential Mortgages 
Forborne as a percentage of the total divisional gross lending book (%) 

MotoNovo Finance 
Reduced monthly payments 
Deferred payment 
Total MotoNovo Finance 
Forborne as a percentage of the total divisional gross lending book (%) 

0.1 
- 
4.8 
4.9 
0.30% 

0.3 
0.3 
0.10% 

0.3 
16.5 
16.8 
1.65% 

0.1 
- 
- 
47.0 
47.1 
0.90% 

- 
2.2 
- 
34.2 
36.4 
1.70% 

15.5 
5.8 
21.3 
0.72% 

0.3 
0.7 
439.3 
440.3 
23.20% 

21.9 
21.9 
7.40% 

2.4 
81.5 
83.9 
7.20% 

- 
0.8 
0.5 
796.7 
798.0 
15.10% 

1.4 
6.7 
0.4 
451.2 
459.7 
22.10% 

3.4 
193.8 
197.2 
11.20% 

73 

 
 
 
Total forborne 
Total temporary or permanent switch to interest only 
Total reduced monthly payments 
Total loan-term extension 
Total Payment, waiver or lower rate product switch 
Total deferred payment 
Total agreement to advance funds in excess of normal contractual terms 
Total forborne 
Total forborne as a percentage of the total gross lending book (%) 
¹ The above analysis includes Property Development. 

30 June 2021
 £m 

30 June 2020
 £m 

0.4 
17.8 
- 
- 
108.3 
0.3 
126.8 
0.93% 

3.8 
11.2 
0.7 
0.9 
1,962.5 
21.9 
2,001.0 
16.80% 

When forbearance is granted to a borrower on a specific exposure, all exposures which are connected with that borrower, e.g. by 
reason of common ownership are deemed as forborne for reporting purposes.  

4. Diversity and concentration within our loan portfolio 
As shown below, we monitor concentration of credit risk by segment, geography, sector and size of loan: 

Credit concentration by segment 

Details of our net lending by segment are as follows: 

Asset Finance 
Invoice Finance 
SME Commercial Mortgages1 
Buy to Let  
Residential Mortgages 
MotoNovo Finance 

¹ The above analysis includes Property Development. 

Credit concentration by geography¹ 

        30 June 2021 

      30 June 2020 

 £m  
1,570.3 
401.6 
1,126.0 
5,159.5 
2,136.2 
3,026.8 
13,420.4 

 % 
12 
3 
8 
38 
16 
23 
100 

 £m  
1,857.9 
278.7 
1,139.1 
5,246.9 
2,079.6 
1,823.5 
12,425.7 

 % 
15 
2 
9 
42 
17 
15 
100 

An analysis of our loans and advances to customers by geography is shown in the table below: 

East Anglia 
East Midlands 
Greater London 
North East 
North West 
Northern Ireland 
Scotland 
South East 
South West 
Wales 
West Midlands 
Yorkshire and Humberside 

¹ The above analysis includes Property Development. 

30 June 2021 
% 
10.8 
6.6 
17.3 
3.1 
10.3 
1.2 
6.5 
18.2 
8.9 
3.3 
6.5 
7.3 
100.0 

30 June 2020 
% 
10.6 
6.3 
17.0 
3.0 
10.4 
1.4 
6.7 
18.1 
8.9 
3.8 
6.8 
7.0 
100.0 

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Credit concentration by sector¹ 

An analysis of our loans and advances to customers by sector is shown in the table below: 

Agriculture, hunting and forestry 
Construction 
Education 
Electricity, gas and water supply 
Financial intermediation 
Health and social work 
Hotels and restaurants 
Manufacturing 
Mining and quarrying 
Private households with employed persons 
Real estate, renting and business activities 
Residential 
Transport, storage and communication 
Wholesale & retail trade repair of motor vehicles & household goods 

¹ The above analysis includes Property Development. 

Credit concentration by quantum of exposure 

30 June 
2021 
% 
0.2 
3.2 
0.1 
0.1 
1.7 
0.2 
0.3 
1.4 
0.1 
4.3 
15.2 
68.6 
1.7 
2.9 
100.0 

30 June 
2020 
% 
0.3 
4.2 
0.2 
0.3 
0.2 
0.2 
0.4 
2.7 
0.1 
3.0 
17.9 
66.4 
2.4 
1.7 
100.0 

An analysis of loans and advances to customers by quantum of exposure is shown in the table below: 

30 June 2021 
£0 - £50k 
£50 - £100k 
£100 - £150k 
£150 - £200k 
£200 - £300k 
£300 - £400k 
£400 - £500k 
£500k - £1m 
£1m - £2m 
£2m+ 
Total 

Asset Finance 
£m 
582.4 
304.9 
161.0 
100.8 
104.0 
58.7 
45.2 
90.0 
51.4 
71.9 
1,570.3 

Invoice 
Finance 
£m 
2.5 
5.9 
7.7 
7.2 
16.2 
14.3 
14.8 
53.4 
40.9 
238.7 
401.6 

SME 
Commercial 
Mortgages1 
£m 
5.0 
26.1 
30.9 
28.5 
40.0 
41.9 
38.7 
143.7 
169.2 
470.8 
994.8 

Buy to Let 
£m 
68.6 
670.7 
658.8 
633.2 
1,174.4 
822.5 
379.1 
484.9 
171.2 
96.1 
5,159.5 

Residential 
Mortgages 
£m 
38.7 
341.2 
490.8 
383.6 
500.6 
206.1 
82.3 
87.9 
3.0 
2.0 
2,136.2 

MotoNovo 
Finance 
£m 
2,939.8 
18.9 
5.4 
6.4 
9.5 
9.1 
4.2 
12.7 
15.4 
5.4 
3,026.8 

¹ The above analysis excludes Property Development. 

75 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
30 June 2020 
£0 - £50k 
£50 - £100k 
£100 - £150k 
£150 - £200k 
£200 - £300k 
£300 - £400k 
£400 - £500k 
£500k - £1m 
£1m - £2m 
£2m+ 
Total 

Asset Finance 
£m 
737.7 
370.6 
193.7 
109.9 
128.9 
71.3 
44.2 
105.1 
36.0 
60.5 
1,857.9 

Invoice 
Finance 
£m 
4.5 
8.5 
8.5 
8.4 
15.5 
10.3 
9.4 
30.3 
17.7 
165.6 
278.7 

SME 
Commercial 
Mortgages1 
£m 
1.4 
24.8 
30.8 
33.9 
47.7 
42.8 
46.0 
157.1 
164.0 
348.2 
896.7 

Buy to Let 
£m 
47.9 
672.6 
675.9 
646.1 
1,222.1 
848.3 
375.6 
475.3 
178.0 
105.1 
5,246.9 

Residential 
Mortgages 
£m 
19.2 
306.1 
497.7 
394.2 
510.0 
200.8 
61.6 
87.0 
1.0 
2.0 
2,079.6 

MotoNovo 
Finance 
£m 
1,749.1 
15.7 
6.2 
5.2 
10.4 
4.7 
6.7 
16.7 
5.9 
2.9 
1,823.5 

¹ The above analysis excludes Property Development.  

5. Details of provisioning coverage and the value of assets against which loans are secured 

The principal indicators used to assess the credit security of performing loans are loan-to-value (“LTV”) ratios for SME Commercial, 
Buy to Let and Residential Mortgages.  

SME Commercial Mortgages1 

Loan-to-value on indexed origination information on our SME Commercial Mortgage portfolio is set out below: 

100%+ 
95-100% 
90-95% 
85-90% 
80-85% 
75-80% 
70-75% 
60-70% 
50-60% 
0-50% 

Capital repayment 
Interest only 

Average loan-to-value percentage  

¹ The above analysis excludes Property Development. 

Property Development 

30 June 
2021 
 £m 
36.0 
21.6 
34.9 
41.0 
47.9 
71.5 
128.2 
215.2 
176.8 
221.7 
994.8 
480.6 
514.2 
994.8 
64.23% 

30 June 
2020 
 £m  
4.0 
5.3 
18.2 
18.9 
29.3 
79.2 
116.3 
190.8 
205.6 
229.1 
896.7 
494.0 
402.7 
896.7 
60.17% 

We use “loan-to-gross-development-value” as an indicator of the quality of credit security of performing loans for the Property 
Development portfolio. Loan-to-gross-development-value is a measure used to monitor the loan balance compared with the 
expected gross development value once the development is complete. Average loan-to-gross-development-value at origination 
for Property Development loans at 30 June 2021 was 61.8% (30 June 2020: 66.1%). 

76 

 
 
 
 
 
 
Buy to Let 
Loan-to-value on indexed origination information on our Buy to Let Mortgage portfolio is set out below: 
30 June 

100%+ 
95-100% 
90-95% 
85-90% 
80-85% 
75-80% 
70-75% 
60-70% 
50-60% 
0-50% 

Capital repayment 
Interest only 

Average loan-to-value percentage  

2021 

 £m  

11.4 
7.2 
16.0 
47.7 
132.5 
409.7 
943.0 
2,003.3 
932.5 
656.2 
5,159.5 
289.5 
4,870.0 
5,159.5 
63.62% 

100%+ 
95-100% 
90-95% 
85-90% 
80-85% 
75-80% 
70-75% 
60-70% 
50-60% 
0-50% 

Residential Mortgages 
Loan-to-value on indexed origination information on our Residential Mortgage portfolio is set out below: 
30 June 
2021 
 £m 
5.3 
10.6 
54.9 
145.4 
242.3 
257.1 
256.4 
443.8 
303.4 
417.0 
2,136.2 
1,961.0 
175.2 
2,136.2 
65.00% 

Capital repayment 
Interest only 

Average loan-to-value percentage  

30 June 

2020 

 £m  

17.7 
9.9 
17.1 
54.6 
213.3 
722.3 
1,274.9 
1,594.6 
753.1 
589.4 
5,246.9 
310.7 
4,936.2 
5,246.9 
65.82% 

30 June 
2020 
 £m  

13.4 
38.6 
178.9 
207.9 
165.4 
207.0 
253.0 
372.9 
267.1 
375.4 
2,079.6 
1,885.0 
194.6 
2,079.6 
67.70% 

Lending at higher LTV bandings continues to be largely as a result of the Group’s participation in mortgage guarantee schemes. We 
participated  in  the  Help  to  Buy  (“HTB”)  mortgage  guarantee  scheme,  which  covered  lending  with  an  LTV  over  85%,  until  the 
retirement  of this  scheme  at  the  end  of  2016.  Following  the  cessation  of  the  HTB  scheme,  we  have  introduced  the  Mortgage 
Indemnity Guarantee (“MIG”) product to cover all new lending over 80% LTV (excluding fees).  

As at 30 June 2021, 96% of the exposures with a current LTV in excess of 85% relate to either HTB or MIG (30 June 2020: 97%). The 
average  LTV  for  mortgages  with  a  guarantee  was  80%  (30  June  2020:  85%).  As  at  30  June  2021,  the  average LTV  of  the  non-
mortgage guarantee owner occupied book is 56% (30 June 2020: 58%).  

The LTV for Commercial Mortgages is elevated due to subdued new business levels over the pandemic period. 

77 

 
 
 
 
 
Invoice Finance  

In respect of Invoice Finance, collateral is provided  by the  underlying  receivables (e.g. trade  invoices). As at  30 June 2021,  the 
average  advance  rate  against  the  fair  value  of  sales  ledger  balances  which  have  been  assigned  to  the  Group,  net  of  amounts 
considered to be irrecoverable, is 68.3% (30 June 2020: 67.5%).  

In  addition  to the  value  of  the underlying  sales  ledger  balances we will,  wherever  possible,  obtain  additional  collateral  before 
offering invoice finance facilities to a client. These may include limited personal guarantees from major shareholders, charges over 
personal and other business property, cross guarantees from associated companies and unlimited warranties in the case of frauds 
or certain other breaches. These additional forms of security are impractical to value given their nature.  

Asset Finance  

In respect of Asset Finance, collateral is provided by our rights and/or title to the underlying assets, which we are able to repossess 
in the event of default. Where appropriate, we will also obtain additional security, such as parent company or personal guarantees. 
Asset  Finance  also  undertakes  unsecured  lending  where  we  have  obtained  an  understanding  of  the  ability  of  the  borrower’s 
business to generate cash flows to service and repay the facilities provided. As at 30 June 2021, the total amount of such unsecured 
lending was £18.9 million (30 June 2020: £37.0 million).  

MotoNovo Finance  

In respect of MotoNovo Finance Limited, collateral is provided by our rights and/or title to the underlying assets, which we are 
able to repossess in the event of default. A proportion of loans are sanctioned at LTVs higher than 100% of the estimated retail 
value and, although the whole agreement is secured on the vehicle, there may be a shortfall in the event of repossession. Loans 
where LTV exceeds 100% are subject to more stringent underwriting criteria. LTV information on MotoNovo Finance’s vehicle 
finance portfolio is set out as follows: 

100%+ 
95-100% 
90-95% 
85-90% 
80-85% 
75-80% 
70-75% 
60-70% 
50-60% 
0-50% 

Group impairment coverage ratio 

Impairment coverage is analysed as follows: 

30 June 2021 
Stage 1 
Stage 2 
Stage 3 
Undrawn loan facilities 
Total 

30 June 
2021 
 £m 
1,000.8 
393.1 
364.0 
293.4 
226.9 
172.1 
128.2 
172.9 
107.9 
93.5 
2,952.8 

30 June 
2020 
 £m 
642.9 
237.6 
214.5 
170.4 
126.8 
97.6 
71.9 
96.5 
57.5 
51.2 
1,766.9 

Gross carrying 
amount 
£m 
12,134.1 
1,086.1 
392.4 
412.4 
14,025.0 

Provisions 
£m 
60.1 
42.5 
89.6 
0.7 
192.9 

Coverage Ratio 
% 
0.50% 
3.91% 
22.83% 
0.17% 
1.38% 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
30 June 2020 
Stage 1 
Stage 2 
Stage 3 
Undrawn loan facilities 
Total 

Gross carrying 
amount 
£m 
10,992.4 
1,356.2 
237.9 
342.5 
12,929.0 

Provisions 
£m 
62.9 
49.9 
48.0 
0.6 
161.4 

Coverage Ratio 
% 
0.57% 
3.69% 
20.13% 
0.18% 
1.25% 

The increase in provisions as at 30 June 2021 is predominantly driven by an increase of stage 3 provisions as a result of a change in 
the definition of default to include accounts that have requested Covid-19 related payment holidays in excess of 6 months. There 
has also been an increase in exposure to the MotoNovo Finance portfolio during the year which generally attracts a higher coverage 
level. 

Offsetting financial assets and liabilities 

It is our policy to enter into master netting and margining agreements with all derivative counterparties.  In general, under master 
netting agreements the amounts owed by each counterparty that are due on a single day in respect of all transactions outstanding 
in the same currency under the agreement are aggregated into a single net amount being payable by one party to the other. In 
certain circumstances, for example when a credit event such as a default occurs, all outstanding transactions under the agreement 
are terminated. 

Under  the  margining  agreements,  where  we  have a  net  asset  position  with  a  counterparty  valued  at  current  market  values  in 
respect of derivatives, then that counterparty will place collateral, usually cash, with us in order to cover the position.  Similarly, 
we will place collateral, usually cash, with the counterparty where we have a net liability position.  

As our derivatives are under master netting and margining agreements as described, which only allows for offsetting in certain 
circumstances such as default, they do not meet the criteria for offsetting in the statement of financial position. 

The following tables detail amounts of financial assets and liabilities subject to offsetting, enforceable master netting agreements 
and similar arrangements including the Term Funding Scheme as detailed in note 19.  

Related amounts not offset in the statement of 
financial position 

Gross amount of 
recognised 
financial 
instruments 
£m 

Net amount of 
financial 
instruments 
presented in the 
statement of 
financial position 
£m 

Financial 
instruments 
£m 

Cash collateral 
paid/ (received) 
£m 

Net amount 
£m 

3,425.1 

19.6 
3,444.7 

(1,326.6) 

(40.9) 
(1,367.5) 

3,425.1 

(1,326.6) 

- 

2,098.5 

19.6 
3,444.7 

(7.2) 
(1,333.8) 

(1,326.6) 

(40.9) 
(1,367.5) 

1,326.6 

7.2 
1,333.8 

(12.4) 
(12.4) 

- 

30.5 
30.5 

- 
2,098.5 

- 

(3.2) 
(3.2) 

79 

30 June 2021 
Type of financial instrument 
Assets 
Loans and advances to customers 
(amounts pre-positioned as 
collateral under the TFS) 
Derivatives held for risk 
management 

Liabilities 
Amounts due to banks (central 
bank under the TFS) 
Derivatives held for risk 
management 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Related amounts not offset in the statement of 
financial position 

Gross amount of 
recognised 
financial 
instruments 

Net amount of 
financial 
instruments 
presented in the 
statement of 
financial position 

Financial 
instruments 

Cash collateral 
paid/ (received) 

Net amount 

£m 

£m 

£m 

£m 

£m 

2,987.0 

2,987.0 

(2,173.5) 

- 

813.5 

9.3 

2,996.3 

(2,173.5) 

(99.8) 
(2,273.3) 

9.3 

(9.2) 

2,996.3 

(2,182.7) 

(2,173.5) 

(99.8) 
(2,273.3) 

2,173.5 

9.2 
2,182.7 

(0.1) 

(0.1) 

- 

88.0 
88.0 

- 

813.5 

- 

(2.6) 
(2.6) 

30 June 2020 

Type of financial instrument 
Assets 
Loans and advances to customers 
(amounts pre-positioned as 
collateral under the TFS) 
Derivatives held for risk 
management 

Liabilities 
Amounts due to banks (central 
bank under the TFS) 
Derivatives held for risk 
management 

6. Information on credit risk within our treasury operations  

Credit risk exists where we have acquired securities or placed cash deposits with other financial institutions as part of our 
treasury portfolio of assets. We consider the credit risk of treasury assets to be relatively low. No assets are held for speculative 
purposes or actively traded. Certain liquid assets are held as part of our liquidity buffer.  

Credit quality of treasury assets  

The table below sets out information about the credit quality of treasury financial assets. As at 30 June 2021 and at 30 June 2020, 
all treasury assets were classified as stage 1 assets per IFRS 9 and no treasury assets were past due or impaired. The Group 
deems the likelihood of default across the respective asset counterparties as immaterial, and hence does not recognise a 
provision against the carrying balances. 

The analysis presented below is derived using ratings provided by Standard and Poor’s (see below disclaimer for further details) 
and Fitch. The worst rating from the credit agencies for each of the counterparties is used as the basis for assessing the credit risk 
of treasury financial assets. 

80 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cash and balances at central banks and loans and advances to banks 
-       Rated AA+ to AA- 
-       Rated A+ to A- 
-       Rated BBB+ 

High quality liquid assets included in the liquidity buffer 
-       Rated AAA 
-       Rated AA+ to AA- 
-       Rated A+ to A- 
-       Rated BBB+ 
Debt securities: Asset backed securities 
-       Rated AAA 

Derivatives held for risk management purposes 
-       Rated A+ to A- 
-       Rated BBB+ 

30 June 

2021 

 £m 

911.5 
- 
- 
911.5 

1,489.0 
510.5 
- 
- 

- 
1,999.5 

19.6 
- 
19.6 
2,930.6 

30 June 

2020 

 £m 

552.6 
15.3 
203.1 
771.0 

1,230.5 
165.4 
5.3 
425.5 

114.4 
1,941.1 

9.1 
0.2 
9.3 
2,721.4 

Standard and Poor’s disclaimer notice in relation to the ratings information set out below: 

“This may contain information obtained from third parties, including ratings from credit ratings agencies such as Standard & Poor’s. Reproduction and distribution of third 
party content in any form is prohibited except with the prior written permission of the related third party. Third party content providers do not guarantee the accuracy, 
completeness, timeliness or availability of any information, including ratings, and are not responsible for any errors or omissions (negligent or otherwise), regardless of 
the cause, or for the results obtained from the use of such content. THIRD PARTY CONTENT PROVIDERS GIVE NO EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT 
LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. THIRD PARTY CONTENT PROVIDERS SHALL NOT BE LIABLE FOR 
ANY  DIRECT,  INDIRECT,  INCIDENTAL,  EXEMPLARY,  COMPENSATORY,  PUNITIVE,  SPECIAL  OR  CONSEQUENTIAL  DAMAGES,  COSTS,  EXPENSES,  LEGAL  FEES,  OR  LOSSES 
(INCLUDING LOST INCOME OR PROFITS AND OPPORTUNITY COSTS OR LOSSES CAUSED BY NEGLIGENCE) IN CONNECTION WITH ANY USE OF THEIR CONTENT, INCLUDING 
RATINGS. Credit  ratings  are  statements  of opinions  and  are  not  statements  of fact  or recommendations to  purchase hold  or  sell  securities.  They do not  address the 
suitability of securities or the suitability of securities for investment purposes, and should not be relied on as investment advice.” 

Funding and liquidity risk 

Liquidity risk is the risk that we are unable to meet financial obligations, such as repaying depositors and counterparties, as they 
fall due, or can only do so at excessive cost. 

To protect the Group and its depositors against liquidity risk, we maintain a liquidity buffer which is based on our liquidity needs 
under stressed conditions. The liquidity buffer is monitored on a daily basis to ensure there are sufficient liquid assets at all times 
to cover cash flow movements and fluctuations in funding, enabling us to meet all financial obligations and to support anticipated 
asset growth.  

81 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Analysis of the liquidity buffer 

The components of the Group’s liquidity buffer are shown below:  

Level 1 

Bank of England reserve account and unencumbered cash and bank balances 

UK gilts and Treasury bills, other Sovereign, Supranational and Covered bonds 

Level 2 

Covered bonds 

Asset backed securities 

Total liquidity buffer 

As a % of funding liabilities 

30 June 

2021 

£m 

652.3 

1,829.6 

54.5 

115.4 

2,651.8 

17.62% 

30 June 

2020 

£m 

512.6 

1,753.4 

73.4 

114.3 

2,453.7 

17.54% 

Our liquidity buffer ensures the Group holds sufficient liquidity under stressed conditions. We monitor stress and ongoing 
commitments to our statement of financial position on a daily basis. We also have access to liquidity through pre-positioned 
collateral with the Bank of England (until drawn this remains off-balance sheet so is not included within the calculation). 

Customer deposits and wholesale funding  

As at 30 June 2021, deposits have grown by 14.2% to £12.5 billion (30 June 2020: £10.9 billion)  and securitisation funding has 
grown by 52%. We continued to maintain a diversified source of funding, including utilising cost effective sources offered by the 
Bank of England.  

In October 2018, the Group issued a new securitisation (Oak No.2) providing £325 million of funding, with £97.8 million in issue 
as at 30 June 2021. The underlying mortgages within the outstanding Oak No.2 securitisation will continue to be repaid with a 
call option in February 2023.  

The Group issued two further tranches of Tier 2 subordinated debt, to its fellow subsidiary FirstRand Bank during the 2019 
financial year, the first tranche of £100 million was issued in November 2018 and the second tranche of £52 million in May 2019. 

In September 2019, the Group issued a new securitisation (Oak No.3) providing £343.5 million of funding with £219.5 million in 
issue as at 30 June 2021. The underlying mortgages within the outstanding Oak No.3 securitisation will continue to be repaid with 
a call option in July 2024. 

In September 2019 the Group issued a new securitisation (MotoMore) providing £250.2 million of funding with £250.2 million in 
issue as at 30 June 2021. The revolving period end date is anticipated to occur in September 2021 and the final maturity date in 
October 2027. 

In October 2020 the Group issued a new securitisation (Turbo 9) providing £519.5 million of funding with £519.5 million in issue 
as at 30 June 2021. The Turbo 9 securitisation will continue to be repaid with a call option which will become applicable once the 
notes outstanding reach 10% of the original principal balance of the notes. 

82 

 
 
 
 
 
 
 
 
 
 
 
Retail deposits 
SME deposits 
Corporate deposits 
Customer deposits 

Term Funding Scheme (“TFS”) 
Term Funding Scheme for SMEs (“TFSME”) 
Other eligible schemes 
Asset Backed Securities (including RMBS) 
Warehouse backed by auto loans  
Deposits by banks 
Subordinated liabilities 
Wholesale funding 
Total funding 

Interest rate and market risk  

30 June 
2021 
£m 
7,503.8 
3,768.4 
1,155.1 
12,427.3 

726.1 
600.0 
- 
835.5 
250.2 
0.5 
213.6 
2,625.9 
15,053.2 

30 June 
2020 
£m 
6,658.3 
3,253.5 
974.7 
10,886.5 

1,671.4 
- 
500.3 
462.4 
249.9 
1.8 
213.5 
3,099.3 
13,985.8 

Interest rate risk is the risk of loss through mismatched asset and liability positions which are sensitive to changes in interest 
rates. Interest rate risk consists of asset-liability gap risk and basis risk. The Group is not exposed to significant foreign exchange 
or equity price risk.  

Effect of IBOR reform 

The reform and replacement of benchmark interest rates such as interbank offered rates (“IBORs”) with alternative risk-free rates 
(“ARRs”)  has  become  a  priority  for  global  regulators.   These  reforms  are  at  various  stages  globally.   On  5  March  2021,  the  ICE 
Benchmark Administration Limited (“IBA”) confirmed the intention to cease the publication of EUR, CHF, JPY and GBP LIBOR for all 
tenors after 31 December 2021 and USD LIBOR after 30 June 2023. Aldermore Group is exposed to GBP LIBOR Reform only. The 
Group established a steering committee in 2019 to oversee the transition to alternative rates and as at 30 June 2021 the transition 
is materially complete with a small number of transactions due to transition ahead of the 31 December 2021 deadline. 

During the  financial year,  new  products  have been launched  to replace  previous GBP LIBOR offerings in  our Retail Mortgages, 
Business Finance and Motonovo Finance divisions with Bank Base Rate (“BBR”) and internal standard variable rates (“SVR”) utilised 
as alternative rates. The derivative portfolio has been materially transitioned onto SONIA. 

The Group has also materially transitioned legacy GBP LIBOR loan agreements onto comparable rates, which mostly utilise BBR 
plus a credit adjustment spread to ensure economic equivalence. To ensure the best possible outcome for  our customers, the 
effective rate for customers transitioned ahead of 31 December 2021 GBP cessation is the lower of GBP LIBOR and the comparable 
rate. 

The table below shows the financial instruments including derivatives that are subject to GBP LIBOR Reforms which have not yet 
transitioned to replacement rates as at 30 June 2021 and which will not have matured by the 31 December 2021 LIBOR cession 
date: 

83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial assets subject to LIBOR reform that have not transitioned to replacement rates at 31 December 2021 

Assets recognised on the balance sheet 

Derivative Financial Instruments  

Advances 

Total assets recognised on the balance sheet subject to IBOR reform  

Amount £m 

283.8 

70.7 

354.4 

Financial liabilities subject to LIBOR reform that have not transitioned to replacement rates at 31 December 2021 

Deposits 

Total liabilities subject to IBOR reform 

These balances represent the notional amount directly impacted by the IBOR reform. 

Asset-liability gap risk 

Amount £m 

250.2 

250.2 

Where possible, we seek to match the interest rate structure of assets with liabilities, creating a natural hedge. Where this is not 
possible, we will enter into interest rate swap transactions to convert the fixed rate exposures on loans and advances, customer 
deposits and fair value through other comprehensive income (FVOCI) securities into variable three-month SONIA assets and 
liabilities. 

Given timing differences and the price of hedging small gaps, it is not cost effective to have an absolute match of variable rate 
assets and liabilities. The risk exposure of the overall asset-liability interest rate profile is monitored against approved limits using 
changes in the economic value of the balance sheet as a result of a modelled 2 percentage point shift in the interest yield curve. 

The impact on profit/(loss) of a 2 percentage point shift in the interest yield curve is as follows: 

2% shift up of the yield curve: 
As at year end 
Average of month end positions 
2% shift down of the yield curve: 
As at year end 
Average of month end positions 

30 June 
2021 
 £m 

(0.6) 
(4.1) 

0.9 
1.9 

30 June 
2020 
 £m  

(3.1) 
(7.2) 

0.9 
1.7 

84 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Gross undiscounted contractual cash flows 
The following is an analysis of gross undiscounted contractual cash flows payable under financial liabilities. The analysis has been 
prepared on the basis of the earliest date at which contractual repayments may take place. This includes consideration of where 
the Group has the contractual right to call, irrespective of whether any decision to call has been made. 

30 June 2021 
Non-derivative liabilities 
Amounts due to banks 
Customers' accounts 
Other liabilities 
Debt securities in issue 
Subordinated notes 
Unrecognised loan commitments 

Derivative liabilities 
Derivatives held for risk management 
settled net 
Amounts received 
Amount paid 

30 June 2020 
Non-derivative liabilities 
Amounts due to banks 
Customers' accounts 
Other liabilities  
Debt securities in issue 
Subordinated notes 
Unrecognised loan commitments 

Derivative liabilities 
Derivatives held for risk management 
settled net 
Amounts received 
Amount paid 

Payable on  
demand 
 £m 

Up to 3 
months 
 £m 

3 to 12 
months 
 £m 

1 to 5  More than 5 
years 
years 
 £m 
 £m 

Total 
 £m  

0.3 
3,532.4 
41.9 
21.8 
- 
412.4 
4,008.8 

450.2 
4,249.7 
4.6 
19.0 
- 
- 
4,723.5 

275.5 
3,241.8 
4.8 
169.9 
70.0 
- 
3,762.0 

- 

- 
- 
- 

6.2 

4.3 
(4.4) 
6.1 

17.6 

- 
- 
17.6 

601.3 
1,473.4 
18.5 
425.1 
164.5 
- 
2,682.8 

17.3 

- 
- 
17.3 

- 
0.2 
14.9 
93.9 
- 
- 
109.0 

1,327.3 
12,497.5 
84.7 
729.7 
234.5 
412.4 
15,286.1 

(0.1) 

- 
- 
(0.1) 

41.0 

4.3 
(4.4) 
40.9 

Payable on  
demand 
 £m 

Up to 3 
months 
 £m 

3 to 12 
months 
 £m 

1 to 5  More than 5 
years 
years 
 £m 
 £m 

Total 
 £m  

0.7 
3,136.6 
79.5 
21.8 
- 
342.5 
3,581.1 

2.3 

- 
- 
2.3 

570.8 
3,660.6 
0.5 
19.0 
- 
- 
4,250.9 

878.5 
2,593.7 
4.3 
169.9 
6.3 
- 
3,652.7 

4.8 

4.3 
(4.4) 
4.7 

24.8 

- 
- 
24.8 

729.5 
1,652.2 
22.1 
425.1 
49.9 
- 
2,878.8 

65.7 

- 
- 
65.7 

- 
0.1 
8.2 
93.9 
245.4 
- 
347.6 

2.1 

- 
- 
2.1 

2,179.5 
11,043.2 
114.6 
729.7 
301.6 
342.5 
14,711.1 

99.7 

4.3 
(4.4) 
99.6 

85 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Capital risk 

Capital risk is the risk that the Group has insufficient capital to cover regulatory requirements and/or support its growth plans. 

The Group operated in line with its capital risk appetite as set by the Board and above its regulatory capital requirements 
throughout the year ended 30 June 2021 and 30 June 2020. 

Our capital resources as at the year end were as follows: 

Common Equity Tier 1 
Share capital 
Share premium account 
Capital redemption reserve 
FVOCI reserve and PVA 
Retained earnings 
IFRS 9 Transitional adjustment1 
Less: intangible assets 
Total Common Equity Tier 1 capital (CET1) 

Additional Tier 1  
Total Tier 1 capital 

Tier 2 capital 
Subordinated notes 
Total Tier 2 capital 

Total capital resources 

Risk weighted assets – Pillar 12 

Capital ratios – regulatory basis2 
Common Equity Tier 1 ratio 
Tier 1 capital ratio 
Total capital ratio 

Leverage ratio (%) 

30 June 
2021 
£m 

243.9 
74.4 
0.1 
8.3 
796.5 
63.4 
(15.0) 
1,171.6 

30 June 
2020 
£m 

243.9 
74.4 
0.1 
1.5 
680.6 
62.9 
(13.7) 
1,049.7 

108.0 
1,279.6 

108.0 
1,157.7 

212.0 
212.0 

212.0 
212.0 

1,491.6 

1,369.7 

8,434.4 

7,864.0 

13.9% 
15.2% 
17.7% 

7.6 

13.3% 
14.7% 
17.4% 

7.7 

1 Under the regulatory rules, an addback to CET1 for the transitional adjustment arising on the implementation of IFRS 9 on 1 July 2018 is permitted 
in the following five years. The permitted addback is 95% in the year following transition reducing to 85%/70%/50%/25% in the second/third/ 
fourth/fifth years respectively following transition. 
2 Risk weighted assets and the capital ratios are not covered by the external auditor’s opinion. 

86 

 
 
 
 
 
 
 
 
 
 
 
 
 
On a fully loaded basis, with no addback for the IFRS 9 transitional 
adjustments, the Group’s capital ratios would be as follows: 

Capital ratios– fully loaded basis1 
Common Equity Tier 1 ratio 
Tier 1 capital ratio 
Total capital ratio 

1 Capital ratios are not covered by the external auditor’s opinion. 

Reconciliation of equity per statement of financial position to capital resources 

Equity per statement of financial position 
Add: subordinated notes 
Add: IFRS 9 transitional adjustment 
Less: intangible assets 
Total capital resources 

30 June 
 2021 
£m 

13.3% 
14.6% 
17.1% 

30 June 
2021 
£m 
1,231.2 
212.0 
63.4 
(15.0) 
1,491.6 

30 June 
 2020 
£m 

12.7% 
14.0% 
16.8% 

30 June 
2020 
£m 
1,108.5 
212.0 
62.9 
(13.7) 
1,369.7 

87 

 
 
 
 
 
 
 
 
 
 
Financial statements 

Statement of Directors’ responsibilities   

Independent auditor’s report  

Consolidated financial statements 

Notes to the consolidated financial statements 

The Company financial statements 

Notes to the Company financial statements 

88 

89 

100 

105 

170 

173 

88 

 
 
 
 
 
 
 
 
 
 
 
Statement  of  Directors’  responsibilities  in  respect  of  the  Report  and  Accounts  and  the 
financial statements 

The Directors are responsible for preparing the Report and Accounts and the Group and parent company financial statements in 
accordance with applicable law and regulations.  

Company law requires the Directors to prepare financial statements for each financial year. Under that law the Directors have 
elected to prepare the financial statements in accordance with International Financial Reporting Standards (IFRSs) as adopted by 
the United Kingdom. 

Under company law the Directors must not approve the financial statements unless they are satisfied that they give a true and fair 
view of the state of affairs of the company and of the profit or loss of the company for that period. In preparing these financial 
statements, International Accounting Standard 1 requires that directors:  

 
 

 

properly select and apply accounting policies; 
present  information,  including  accounting  policies,  in  a  manner  that  provides  relevant,  reliable,  comparable  and 
understandable information;  
provide additional disclosures when compliance with the specific requirements in IFRSs are insufficient to enable users 
to understand the impact of particular transactions, other events and conditions on the entity's financial position and 
financial performance; and 

  make an assessment of the company's ability to continue as a going concern. 

The  Directors  are  responsible  for  keeping  adequate  accounting  records  that  are  sufficient  to  show  and  explain  the  parent 
company’s transactions and disclose with reasonable accuracy at any time the financial position of the Company and enable them 
to ensure that the financial statements comply with the Companies Act 2006. They are also responsible for safeguarding the assets 
of the Company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.  

The  Directors  are  responsible  for  the  maintenance  and  integrity  of  the  corporate  and  financial  information  included  on  the 
Company’s website. Legislation in the United Kingdom governing the preparation and dissemination of financial statements may 
differ from legislation in other jurisdictions. 

Responsibility statement of the Directors in respect of the Report and Accounts and the financial statements   
We confirm that to the best of our knowledge: 

 

 

the financial statements, prepared in accordance with the applicable set of accounting standards, give a true and fair 
view of the assets, liabilities, financial position and profit or loss of the Company and the undertakings included in the 
consolidation taken as a whole; and 
the Strategic Report on pages 4 to 31 includes a fair review of the development and performance of the business and 
the position of the issuer and the undertakings included in the consolidation taken as a whole, together with a description 
of the principal risks and uncertainties that they face. 

Claire Cordell 
Chief Financial Officer 
14 September 2021 

89 

 
 
 
 
 
 
INDEPENDENT  AUDITOR’S  REPORT  TO  THE  MEMBERS  OF  ALDERMORE 
GROUP PLC 

Report on the audit of the financial statements 

1.  Opinion 

In our opinion the financial statements of Aldermore Group Plc (the ‘Parent Company’) and its subsidiaries (the ‘Group’): 
 

give a true and fair view of the state of the Group’s and of the parent company’s affairs as at 30 June 2021 and of the 
Group’s profit for the year then ended; 

 

 

have been properly prepared in accordance with international accounting standards in conformity with the requirements of 
the Companies Act 2006; and 

have been prepared in accordance with the requirements of the Companies Act 2006. 

We have audited the financial statements which comprise: 
the consolidated income statement; 
the consolidated statement of comprehensive income; 
the consolidated and parent company statements of financial position; 
the consolidated and parent company statements of cash flows; 
the consolidated and parent company statements of changes in equity; 
the risk management and capital disclosures marked as audited on pages 57 to 87; and 
the related notes 1 to 41. 

 
 
 
 
 
 
 

The  financial  reporting  framework  that  has  been  applied  in  their  preparation  is  applicable  law  and  international  accounting 
standards in conformity with the requirements of the Companies Act 2006. 

2.  Basis for opinion 

We  conducted  our  audit  in  accordance  with  International  Standards  on  Auditing  (UK)  (ISAs  (UK))  and  applicable  law.  Our 
responsibilities under those standards are further described in the auditor’s responsibilities for the audit of the financial statements 
section of our report.  
We are independent of the Group and the parent company in accordance with the ethical requirements that are relevant to our 
audit of the financial statements in the UK, including the Financial Reporting Council’s (the ‘FRC’s’) Ethical Standard as applied to 
public interest entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We confirm 
that the non-audit services prohibited by the FRC’s Ethical Standard were not provided to the Group or the Parent Company. 
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. 

90 

 
 
 
3. 

Summary of our audit approach 

Key audit matters 

The key audit matters that we identified in the current year were: 
  expected credit losses on loans and advances to customers; and 
  effective interest rate income recognition. 

Within this report, key audit matters are identified as follows: 

Newly identified 

Increased level of risk 

Similar level of risk 

Decreased level of risk 

Materiality 

Scoping 

The materiality that we used for the Group financial statements was £6.1m which was determined on 
the basis of 0.5% of Net Assets. 

Our group audit focused on Aldermore Group Plc and its significant subsidiaries, Aldermore Bank Plc 
and MotoNovo Finance Limited. 

Significant changes in our 
approach 

Our audit approach is consistent with that of the prior year. We have not identified any additional key 
audit matters and the determination of materiality remains in line with the prior year. 

4.  Conclusions relating to going concern 

In auditing the financial statements, we have concluded that the directors’ use of the going concern basis of accounting in the 
preparation of the financial statements is appropriate. 
Our evaluation of the directors’ assessment of the Group’s and parent company’s ability to continue to adopt the going concern 
basis of accounting included: 
 

Obtaining management’s going concern assessment, which included specific consideration of the impacts of the Covid-19 
pandemic and the Group’s operational resilience, in order to understand and assess the key judgements made by 
management; 
Obtaining management’s capital and liquidity forecasts and assessing the key assumptions and their projected impact on 
capital and liquidity ratios; 
Assessing the consistency of assumptions used in forecasts with the assumptions used in other key estimates; 
Obtaining the most recent ICAAP and ILAAP submissions and involving our in-house prudential risk specialists to assess 
management’s capital and liquidity projections and the results of management’s capital reverse stress testing;  
Assessing key assumptions and methods used in the capital reverse stress testing models and checking the mechanical 
accuracy of the capital reverse stress testing models; 
Reading correspondence with regulators to understand the capital and liquidity requirements imposed by the Group’s 
regulators, and evidence any changes to those requirements; 
Assessing the historical accuracy of forecasts prepared by management; and  
Assessing the appropriateness of the going concern disclosures made in the financial statements in view of the FRC 
guidance. 

 

 
 

 

 

 
 

Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, 
individually or collectively, may cast significant doubt on the Group's and parent company’s ability to continue as a going concern 
for a period of at least twelve months from the when the financial statements are authorised for issue. 
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of 
this report. 

91 

 
 
 
 
 
 
 
 
 
5.  Key audit matters 

Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial 
statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to 
fraud) that we identified. These matters included those which had the greatest effect on: the overall audit strategy, the allocation 
of resources in the audit; and directing the efforts of the engagement team. 
These  matters  were addressed  in  the  context  of  our  audit  of  the  financial  statements  as  a  whole,  and  in  forming  our  opinion 
thereon, and we do not provide a separate opinion on these matters. 

5.1.  Expected credit losses on loans and advances to customers  

Key audit matter description  As disclosed in note 2(g) the Group recognises Expected Credit Losses (“ECL”) on loans and advances to 

customers in line with the requirements of IFRS 9.  
ECL provisions as at 30 June 2021 were £192.2m (2020: £160.8m), which represented 1.4% (2020: 1.3%) 
of  loans  and  advances  to  customers.  The income  statement  charge for the year  was  £51.3m  (2020: 
£120.5m).  
As detailed  in  note 3  on  pages  121  to  126  ‘Use  of  estimates  and  judgements’,  determining  the  ECL 
provision  is  inherently  uncertain  and  requires  management  to  make  significant  judgements  and 
estimates. Covid-19 has increased the complexity in estimating ECLs, in particular with respect to the 
incorporation of forward-looking information and identifying significant increases in credit risk. Due to 
the considerable judgement required to estimate the ECL, which by its nature, gives rise to a higher risk 
of  material  misstatement  due  to  error  or  fraud,  we  have  identified  the  determination  of  the  ECL 
provision as a key audit matter. 
We identified five specific areas in relation to the ECL that require significant management judgement 
or relate to assumptions to which the overall ECL is particularly sensitive: 

 

 

 

 

 

The appropriateness of the Probability of Default (PD) and Loss Given Default (LGD) 
considering the actual performance of the book. There is a risk that models are not 
reflective of the actual performance of the book given the unprecedented economic 
environment. 
The staging and PD for Covid-19 affected borrowers and those with increased risk of 
distress. There is a risk that the models do not capture the increased risk of default in these 
customers/sectors. 
The inclusion of post model adjustments (PMAs). The inherent limitations of credit risk 
models are that not all prevalent credit risks may be appropriately captured and thus are 
mitigated by PMAs which, given their nature, are based on management judgements and 
quantified using a range of assumptions.  
The selection of macroeconomic scenarios and the associated weightings applied. ECL 
provisions are required to be calculated on a forward look basis under IFRS 9. Whilst the 
economic outlook has improved over the year, significant uncertainty still remains. 
Management have had to apply significant judgement to determine the future 
macroeconomic forecasts under the four different scenarios selected and the weighting 
applied to each scenario. 
The ECL on significant exposures in default included in Stage 3 is individually assessed on a 
loan by loan basis considering the individual case workout strategy and valuation of 
collateral. There is a risk that the collateral is not appropriately valued, and all cash flows 
and workout scenarios are not considered. 

92 

 
 
 
 
How  the  scope  of  our  audit 
responded  to  the  key  audit 
matter 

We obtained an understanding of the relevant financial controls over the ECL provision with particular 
focus  on  controls  over  significant  management  assumptions  and  judgements  used  in  the  ECL 
determination. Given the inherent judgemental nature of determining the ECL provision we did not plan 
to rely on internal controls. 

To challenge the modelled PDs (including those of Covid-19 affected borrowers) and LGDs we involved 
our credit modelling specialists and: 

 
 
 
 

 

Tested the key data inputs into the models for accuracy and completeness; 
Performed an assessment of the model methodology; 
Assessed whether the PDs and LGDs were calculated in line with the model methodology; 
Assessed the model performance monitoring and validation work undertaken by 
management; 
Segregated the population into different risk characteristics to assess whether PDs and LGDs 
were appropriate for those segments. 

To challenge the staging of Covid-19 affected borrowers we: 

 

 

 

Performed a loan by loan independent qualitative assessment of a sample of affected 
borrowers and assessed whether these loans were included in the correct stage; 
Assessed the staging thresholds, significant increase in credit risk triggers and default 
definitions applied by management; and 
Identified sectors where we considered there to be a higher risk of default and assessed 
whether borrowers were in the correct stage and had an appropriate ECL. 

To challenge the PMAs implemented by management we involved our credit modelling specialists and: 

 

 

 

Performed an assessment of management’s model methodology to identify where model 
limitations existed and whether these were addressed by a PMA; 
Assessed whether each PMA was implemented appropriately and addressed the model 
limitation; and 
Validated management’s process to identify PMAs and recalculated the quantification. 

To challenge the macroeconomic forecasts and scenarios we involved our credit modelling specialists 
and economic advisory specialists and we: 

 

 

 
 

 

 

Assessed management’s determination of the scenarios and probability weightings applied 
to them as at 30 June 2021; 
Evaluated the economic outlook under each of the scenarios with reference to available 
macroeconomic data; 
Assessed whether the appropriate scenarios and forecasts were implemented in the model; 
Performed a benchmarking exercise to compare the weightings and forecasts implemented 
by management to those used by peer lenders; 
Assessed whether management had implemented an appropriate selection of economic 
variables; and  
Assessed whether the macroeconomic scenarios and forecasts translated into an 
appropriate ECL under each scenario. 

To challenge the provisions that are individually assessed by management we: 

 

 

 
 

Independently assessed the appropriateness of the workout scenarios considered by 
management; 
Involved our property valuation specialists for exposures with complex collaterals to 
independently assess the property values applied in the ECL calculation; 
Evaluated the expected cash flows for the individual cases; and  
Tested the mechanical accuracy of the ECL by recalculating the ECL amount for a sample of 
exposures.  

93 

 
 
Key observations 

Based on our audit procedures above, we concluded that the estimate of ECL is not materially misstated. 

5.2.  Effective interest rate income recognition  

Key audit matter description  The Group’s revenue recognition policy is detailed in note 2(a).  

As  detailed  in  note  3,  ‘Use  of  estimates  and  judgements’  on  pages  121  to  126  a  key  judgement  in 
recognition of revenue on an Effective Interest Rate (“EIR”) basis, is the determination of the expected 
life of the underlying loans and advances.  
The Group’s net interest income was £436.4m (June 2020: £370.5m). 
Management’s  approach  to  determining  the  interest  income  that  should  be  recognised  at  each 
reporting date involves the use of complex models and relies on a number of key judgements about 
which fees and costs should be included in the calculation. 
The determination of expected life ‘curves’ to be used in each EIR model is inherently subjective given 
they are forward-looking, and the level of judgement to be exercised by management is increased given 
the limited availability of historical prepayment information. 
Due to the considerable judgement required to estimate the expected lives for the repayment of loans 
and advances to borrowers for whom revenue is recognised at the EIR, and given the potential for fraud 
through  inappropriate  bias  within  the  estimate,  we  have  identified  the  determination  of  income 
recognition using the EIR as a key audit matter. 

How  the  scope  of  our  audit 
responded  to  the  key  audit 
matter 

We  obtained  an  understanding  of  relevant  controls  over  the  EIR  calculation.  Given  the  inherent 
judgemental nature of determining the EIR calculation we did not plan to rely on internal controls.  
In addition, for all portfolios we: 

 

 

 

Assessed management’s accounting policies and confirmed they are in accordance with 
accounting standards. A particular focus was the fees included / excluded from the EIR 
models;  
Tested the relevant loan data inputs, to check they had been completely and accurately 
included in the EIR models; and 
Tested the mathematical integrity of management’s EIR models by building our own models 
(“challenger models”) and comparing the output from our models to the output from 
management’s models. 

To challenge the modelled curves for loan prepayments we involved our data analytic specialists to: 

 

 
 

Assess the methodology and technical source code applied in the EIR model in determining 
the expected life curves; 
Check the completeness and accuracy of the underlying inputs into the EIR model; and 
Independently recreate the forecast expected life curves and apply them in our challenger 
models to assess against management’s curves. 

Key observations 

Based  on  our  audit  procedures  above,  we  concluded  that  net  interest  income  for  the  period  is  not 
materially misstated. 

94 

 
 
 
 
 
 
6.  OUR APPLICATION OF MATERIALITY 

6.1.  Materiality 

We define materiality as the magnitude of misstatement in the financial statements that makes it probable that the economic 
decisions of a reasonably knowledgeable person would be changed or influenced. We use materiality both in planning the scope 
of our audit work and in evaluating the results of our work. 
Based on our professional judgement, we determined materiality for the financial statements as a whole as follows: 

Group financial statements 

Parent Company financial statements 

£6.1m (2020: £5.5m) 

£3.1m (2020: £2.8m) 

for 

0.5% of Net Assets (2020: 0.5% of Net Assets) 

0.5% of Net Assets (2020: 0.5% of Net Assets) 

Materiality 

Basis 
determining 
materiality 

Rationale 
for  the 
benchmark applied 

In the prior year the impact of Covid-19 led to 
significant volatility in the profit before tax. Given 
the continued uncertainty and volatility in earnings 
we therefore continued to identify net assets as a 
more stable and appropriate benchmark on which 
to base our materiality.  

For the parent company financial statements, we 
have determined our materiality on the basis of 
0.5% of net assets, but this has been capped at 50% 
of group materiality, in accordance with our 
methodology for determining materiality for 
components. In our professional judgement, we 
believe that the use of net assets is appropriate as 
the purpose of the company is as a holding 
company.  

6.2.  Performance materiality 

We set performance materiality at a level lower than  materiality to reduce the probability that, in aggregate, uncorrected and 
undetected misstatements exceed the materiality for the financial statements as a whole.  

Performance 
materiality 

Basis  and  rationale 
for 
determining 
performance 
materiality 

Group financial statements 

Parent Company financial statements 

70% (2020: 40%) of group materiality 

70% (2020: 40%) of parent company materiality  

In determining performance materiality, we considered a number of factors, including: our understanding 
of  the  control  environment;  our  understanding  of  the  business;  and  the  low  number  of  uncorrected 
misstatements identified in the prior year.  
Our performance materiality was reduced to 40% in the prior year in response to the potentially pervasive 
impact  of  Covid-19  on  the  control  environment  and  financial  reporting  as  well  as  to  comply  with  the 
instructions provided to us by the auditor of FirstRand Limited. 

6.3.  Error reporting threshold 

We agreed with the Audit Committee that we would report to the Committee all audit differences in excess of £300k (2020: £140k), 
as well as differences below that threshold that, in our view, warranted reporting on qualitative grounds. We also report to the 
Audit Committee on disclosure matters that we identified when assessing the overall presentation of the financial statements. 

7.  AN OVERVIEW OF THE SCOPE OF OUR AUDIT 

7.1. 

Identification and scoping of components 

Our group audit was scoped by obtaining an understanding of the Group and its environment, including group-wide controls, and 
assessing the risks of material misstatement at the group level. Our group audit focused on Aldermore Group Plc and its significant 
subsidiaries, Aldermore Bank Plc  and MotoNovo  Finance Limited which  were subject  to  a  full  scope audit while the remaining 
subsidiaries were subject to specified audit procedures. The full scope audit of the three entities named above provided us with 
coverage of all material balances. Our audits of each of the subsidiaries were performed using levels of materiality appropriate to 
each entity. At the group level, we also tested the consolidation process. All work was performed by the group engagement team. 

95 

 
 
 
 
 
7.2.  Our consideration of the control environment  

In order to test controls, a combination of re-performance, inquiry, observation and inspection was performed on a sample basis, 
tailored to the nature and timing of each control. The IT systems used for the gross loans and advances to customers were in scope 
for our control testing approach. 
We planned to take a controls reliance strategy over gross loans and advances to customers. We obtained an understanding and 
tested controls within the following lending cycles: mortgages, asset finance, invoice finance, and motor leases. Based on our work 
performed, we identified that the IT user access review controls over the key mortgages system did not operate effectively during 
the financial reporting period. We were therefore not able to take a controls reliance approach for our audit of the mortgages 
cycle. We modified our planned audit approach and, increased the extent of our audit procedures over these balances.  
The Audit Committee has performed their own assessment of the internal control environment as set out on page 41. 

8.  OTHER INFORMATION 

The  other  information  comprises  the  information  included  in  the  annual  report  other  than  the  financial  statements  and  our 
auditor’s report thereon. The directors are responsible for the other information contained within the annual report. 
Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated 
in our report, we do not express any form of assurance conclusion thereon. 
Our  responsibility  is  to  read  the  other  information  and,  in  doing  so,  consider  whether  the  other  information  is  materially 
inconsistent  with  the  financial  statements  or  our  knowledge  obtained  in  the  course  of  the  audit,  or  otherwise  appears  to  be 
materially misstated. 
If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether this gives 
rise to a material misstatement in the financial statements themselves. If, based on the work we have performed, we conclude 
that there is a material misstatement of this other information, we are required to report that fact. 

We have nothing to report in this regard. 

9.  RESPONSIBILITIES OF DIRECTORS 

As explained more fully in the directors’ responsibilities statement, the directors are responsible for the preparation of the financial 
statements and for being satisfied that they give a true and fair view, and for such internal control as the directors determine is 
necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or 
error. 
In preparing the financial statements, the directors are responsible for assessing the Group’s and the parent company’s ability to 
continue  as  a  going  concern,  disclosing  as  applicable,  matters  related  to  going  concern  and  using  the  going  concern  basis  of 
accounting unless the directors either intend to liquidate the Group or the parent company or to cease operations, or have no 
realistic alternative but to do so. 

10.  AUDITOR’S RESPONSIBILITIES FOR THE AUDIT OF THE FINANCIAL STATEMENTS 

Our  objectives  are  to  obtain  reasonable  assurance  about  whether  the  financial  statements  as  a  whole  are  free  from  material 
misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a 
high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material 
misstatement when it exists. Misstatements can  arise from fraud or error  and are considered material if, individually or  in the 
aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial 
statements. 
A  further  description  of  our  responsibilities  for  the  audit  of the  financial  statements  is  located  on  the  FRC’s  website  at: 
www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor’s report. 

11.  EXTENT TO WHICH THE AUDIT WAS CONSIDERED CAPABLE OF DETECTING IRREGULARITIES, INCLUDING FRAUD 

Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our 
responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which 
our procedures are capable of detecting irregularities, including fraud is detailed below.  

96 

 
 
 
11.1. Identifying and assessing potential risks related to irregularities 

In identifying and assessing risks of material misstatement in respect of irregularities, including fraud and non-compliance with 
laws and regulations, we considered the following: 

 

 

 

 

the nature of the industry and sector, control environment and business performance including the design of the 
Group’s remuneration policies, key drivers for directors’ remuneration, bonus levels and performance targets; 
results of our enquiries of management, internal audit and the audit committee about their own identification and 
assessment of the risks of irregularities;  
any matters we identified having obtained and reviewed the Group’s documentation of their policies and procedures 
relating to: 
o 

identifying, evaluating and complying with laws and regulations and whether they were aware of any instances of 
non-compliance; 
detecting and responding to the risks of fraud and whether they have knowledge of any actual, suspected or 
alleged fraud; and 
the internal controls established to mitigate risks of fraud or non-compliance with laws and regulations;  

o 
the matters discussed among the audit engagement team and involving relevant internal specialists, regarding how and 
where fraud might occur in the financial statements and any potential indicators of fraud. 

o 

As a result of these procedures, we considered the opportunities and incentives that may exist within the Group for fraud and 
identified the greatest potential for fraud in the following areas: expected credit losses on loans and advances to customers and 
effective interest rate income recognition. In common with all audits under ISAs (UK), we are also required to perform specific 
procedures to respond to the risk of management override. 
We also obtained an understanding of the legal and regulatory framework that the Group operates in, focusing on provisions of 
those  laws  and  regulations  that  had  a direct  effect  on  the  determination  of  material  amounts  and  disclosures  in  the  financial 
statements. The key laws and regulations we considered in this context included the UK Companies Act and UK tax legislation.  
In addition, we considered provisions of other laws and regulations that do not have a direct effect on the financial statements but 
compliance with which may be fundamental to the Group’s ability to operate or to avoid a material penalty. These included the 
requirements  of  the  United  Kingdom’s  Prudential  Regulation  Authority  (PRA)  and  Financial  Conduct  Authority  (FCA)  and  in 
particular their authorised permissions and regulatory capital, liquidity and solvency requirements. 

11.2.  Audit response to risks identified 

As a result of performing the above, we identified expected credit losses on loans and advances to customers and effective interest 
rate income recognition  were relevant  to  the potential  risk  of  fraud.  The  key  audit  matters  section  of  our  report  explains  the 
matters in more detail and also describes the specific procedures we performed in response to those key audit matters.  
In addition to the above, our procedures to respond to risks identified included the following: 

 

 

 

 

 

reviewing the financial statement disclosures and testing to supporting documentation to assess compliance with 
provisions of relevant laws and regulations described as having a direct effect on the financial statements; 
enquiring of management, the audit committee and external legal counsel concerning actual and potential litigation 
and claims; 
performing analytical procedures to identify any unusual or unexpected relationships that may indicate risks of material 
misstatement due to fraud; 
reading minutes of meetings of those charged with governance, reviewing internal audit reports and  correspondence 
from the Group’s primary regulators the PRA and the FCA; and 
in addressing the risk of fraud through management override of controls, testing the appropriateness of journal entries 
and other adjustments; assessing whether the judgements made in making accounting estimates are indicative of a 
potential bias; and evaluating the business rationale of any significant transactions that are unusual or outside the 
normal course of business. 

We  also  communicated  relevant  identified  laws  and  regulations  and  potential  fraud  risks  to  all  engagement  team  members 
including  internal  specialists  and  remained  alert  to  any  indications  of  fraud  or  non-compliance  with  laws  and  regulations 
throughout the audit. 

Report on other legal and regulatory requirements 

97 

 
 
 
12.  OPINIONS ON OTHER MATTERS PRESCRIBED BY THE COMPANIES ACT 2006 

In our opinion, based on the work undertaken in the course of the audit: 
 

the information given in the strategic report and the directors’ report for the financial year for which the financial 
statements are prepared is consistent with the financial statements; and 
the strategic report and the directors’ report have been prepared in accordance with applicable legal requirements. 

 

In the light of the knowledge and understanding of the Group and the parent company and their environment obtained in the 
course of the audit, we have not identified any material misstatements in the strategic report or the directors’ report. 

13.  OPINION ON OTHER MATTER PRESCRIBED BY THE CAPITAL REQUIREMENTS (COUNTRY-BY-COUNTRY REPORTING) 

REGULATIONS 2013 

In our opinion the information given in note 40 to the financial statements for the financial year ended 30 June 2021 has been 
properly prepared, in all material respects, in accordance with the Capital Requirements Country-by Country Reporting Regulations 
2013. 

14.  MATTERS ON WHICH WE ARE REQUIRED TO REPORT BY EXCEPTION 

14.1.  Adequacy of explanations received and accounting records 

Under the Companies Act 2006 we are required to report to you if, in our opinion: 

  we have not received all the information and explanations we require for our audit; or 
 

adequate accounting records have not been kept by the parent company, or returns adequate for our audit have not 
been received from branches not visited by us; or 
the parent company financial statements are not in agreement with the accounting records and returns. 

 

We have nothing to report in respect of these matters. 

14.2.  Directors’ remuneration 

Under the Companies Act 2006 we are also required to report if in our opinion certain disclosures of directors’ remuneration have 
not been made. 

We have nothing to report in respect of this matter. 

15.  OTHER MATTERS WHICH WE ARE REQUIRED TO ADDRESS 

15.1.  Auditor tenure 

Following the recommendation of the audit committee, we were appointed by the shareholders of the company on 16 May 2017 
to  audit  the  financial  statements  for  the  year  ended  30  June  2018  and  subsequent  financial  periods.  The  period  of  total 
uninterrupted engagement of the firm is 4 years, covering the years ending 30 June 2018 to 30 June 2021. 

15.2.  Consistency of the audit report with the additional report to the Audit Committee 

Our audit opinion is consistent with the additional report to the Audit Committee we are required to provide in accordance with 
ISAs (UK). 

98 

 
 
 
 
 
 
 
 
16.  USE OF OUR REPORT 

This report is made solely to the company’s members, as a body, in accordance with Chapter 3 of Part 16 of the Companies 
Act  2006.  Our  audit  work  has  been  undertaken  so  that  we  might  state  to  the  company’s  members  those  matters  we  are 
required to state to them in an auditor’s report and for no other purpose. To the fullest extent permitted by law, we do not 
accept or assume responsibility to anyone other than the company and the company’s members as a body, for our audit work, 
for this report, or for the opinions we have formed. 

Manbhinder Rana FCA (Senior statutory auditor) 
For and on behalf of Deloitte LLP 
Statutory Auditor 
London, United Kingdom 
14 September 2021 

99 

 
 
 
 
 
 
Consolidated income statement  
For the year ended 30 June 2021 

Interest income 
Interest expense 
Net interest income 
Fee and commission income 
Fee and commission expense 
Net losses from derivatives and other financial instruments at fair  
value through profit or loss 

Net gains/(losses) on disposal of financial assets at fair value through other 
comprehensive income 
Other operating income 
Total operating income 
Provisions 
Other administrative expenses 
Administrative expenses 
Depreciation and amortisation 
Operating profit before impairment losses 
Share of profit of associate 
Impairment losses on loans and advances to customers 
Impairment losses on lease modifications  
Profit before taxation 
Taxation 
Profit after taxation - attributable to equity holders of the Group 

The notes and information on pages 105 to 170 form part of these financial statements. 

Year ended  
30 June 2021 

Year ended  
30 June 2020 

Note 

£m 

£m 

5 
6 

7 
8 

9 

29 
10 
10 
14 

22 
19 
19 

15 

592.5 
(156.1) 
436.4 
6.8 
(10.1) 

(0.5) 

0.7 

37.6 
470.9 
(3.8) 
(245.3) 
(249.1) 
(12.6) 
209.2 
0.7 
(51.3) 
(0.8) 
157.8 
(33.4) 
124.4 

563.8 
(193.3) 
370.5 
5.6 
(10.1) 

(8.1) 

(0.1) 

54.3 
412.1 
(3.2) 
(216.8) 
(220.0) 
(12.1) 
180.0 
0.5 
(120.5) 
(11.2) 
48.8 
(10.2) 
38.6 

100 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of comprehensive income 
For the year ended 30 June 2021 

Profit after taxation  
Other comprehensive income/(expense): 
Items that may subsequently be transferred to the income statement: 
FVOCI debt securities: 
Fair value movements  
Amounts transferred to the income statement 
Taxation 
Total other comprehensive income 
Total comprehensive income attributable to equity holders of the Group 

The notes and information on pages 105 to 170 form part of these financial statements. 

Year ended  
30 June 2021 

£m 

124.4 

Year ended  
30 June 2020 

£m 

38.6 

10.3 
(0.7) 
(2.8) 
6.8 
131.2 

1.8 
(0.5) 
(0.3) 
1.0 
39.6 

101 

 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of financial position  
As at 30 June 2021 

Assets  
Cash and balances at central banks 
Loans and advances to banks 
Debt securities 
Derivatives held for risk management 
Loans and advances to customers 
Fair value adjustment for portfolio hedged risk 
Other assets 
Prepayments and accrued income 
Taxation asset 
Deferred taxation 
Investment in associates 
Plant and equipment 
Intangible assets 
Total assets 

Liabilities 
Amounts due to banks 
Customers' accounts 
Derivatives held for risk management 
Fair value adjustment for portfolio hedged risk 
Other liabilities 
Accruals and deferred income 
Current taxation 
Provisions 
Debt securities in issue 
Subordinated notes 
Total liabilities 

Equity 

Share capital 
Share premium account 
Additional Tier 1 capital 
Capital redemption reserve 
Fair value through other comprehensive income 
Retained earnings 
Total equity 
Total liabilities and equity 

The notes and information on pages 105 to 170 form part of these financial statements.   
These financial statements were approved by the Board and were signed on its behalf by: 

Steven Cooper 

Director 

14 September 2021 

Registered number: 06764335 

Claire Cordell 

Director 

14 September 2021 

30 June 2021 

30 June 2020 

Note 

£m 

£m 

36 
16 
17 
18 
19 

21 
22 
23 
24 

25 
26 
18 
18 
27 
28 

29 
30 
31 

33 

35 

688.5 
223.0 
1,999.5 
19.6 
13,420.4 
14.2 
29.4 
18.4 
0.7 
7.6 
5.7 
47.1 
15.0 
16,489.1 

1,326.6 
12,427.4 
40.9 
- 
84.7 
62.9 
11.0 
5.1 
1,085.7 
213.6 
15,257.9 

243.9 
74.4 
108.0 
0.1 
8.3 
796.5 
1,231.2 
16,489.1 

542.4 
228.6 
1,941.1 
9.3 
12,425.7 
58.1 
20.7 
15.4 
11.8 
4.5 
5.5 
46.8 
13.7 
15,323.6 

2,173.5 
10,886.4 
99.8 
2.1 
90.5 
32.5 
- 
4.5 
712.3 
213.5 
14,215.1 

243.9 
74.4 
108.0 
0.1 
1.5 
680.6 
1,108.5 
15,323.6 

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
  
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of cash flows 
For the year ended 30 June 2021 

Cash flows from operating activities 
Profit before taxation 
Adjustments for non-cash items and other adjustments included within the income 
statement 
Increase in operating assets 
Increase in operating liabilities 
Income tax paid 
Net cash flows (used in)/generated from operating activities 

Cash flows from investing activities 
Purchase of debt securities 
Proceeds from sale and maturity of debt securities 
Capital repayments of debt securities 
Interest received on debt securities 
Purchase of property, plant and equipment and intangible assets 
Net cash used in investing activities 

Cash flows from financing activities 
Proceeds from issue of debt securities 
Capital repayments on debt securities issued 
Coupons paid on Additional Tier 1 capital 
Proceeds from the issue of Additional Tier 1 capital 
Redemption of Additional Tier 1 capital 
Interest paid on debt securities issued 
Repayment of lease liabilities – principal 
Interest paid on lease liabilities 
Net cash generated from financing activities 

Net increase in cash and cash equivalents 

Cash and cash equivalents at start of the period 
Movement during the period 
Cash and cash equivalents at end of the period 

Year ended  
30 June 2021 

Year ended  
30 June 2020 

Note 

£m 

£m 

157.8 

65.8 

(973.3) 
663.8 
(17.1) 
(103.0) 

(444.6) 
333.1 
61.4 
6.8 
(14.1) 
(57.4) 

519.5 
(146.2) 
(8.6) 
- 
- 
(7.1) 
(5.1) 
(0.4) 
352.1 

48.8 

136.2 

(2,106.9) 
2,315.3 
(40.3) 
353.1 

(1,085.3) 
281.3 
89.7 
8.5 
(7.2) 
(713.0) 

592.6 
(144.5) 
(12.4) 
61.0 
(75.0) 
(8.1) 
(3.4) 
(0.4) 
409.8 

191.7 

49.9 

583.6 
191.7 
775.3 

533.7 
49.9 
583.6 

36 

36 
36 

17 
17 
17 
5 

30 
30 
35 

30 

36 

36 

103 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of changes in equity 
For the year ended 30 June 2021 

Share  
premium  
account 
£m 

Additional 
Tier 1 
Capital 
£m 

Share 
capital  
£m 

Capital  
redemptio
n  
reserve 
£m 

Note 

FVOCI 
reserve 
£m 

Retained 
earnings 
£m 

Total 
£m 

Year ended 30 June 2021 
As at 1 July 2020 

Profit after taxation 
Other comprehensive income 
- Coupon paid on Additional Tier 1 capital 
securities 

243.9 
- 
- 

74.4 
- 
- 

108.0 
- 
- 

- 

- 

- 

0.1 
- 
- 

- 

1.5 
- 
6.8 

680.6 
124.4 
- 

1,108.5 
124.4 
6.8 

- 

(8.5) 

(8.5) 

As at 30 June 2021 
Year ended 30 June 2020 
As at 1 July 2019 
Profit after taxation 
Other comprehensive income 
- Issuance of Additional Tier 1 capital 
- Redemption of Additional Tier 1 capital 
- Coupon paid on Additional Tier 1 capital 
securities 
As at 30 June 2020 

35 

243.9 

74.4 

108.0 

0.1 

8.3 

796.5 

1,231.2 

243.9 
- 
- 
- 
- 

74.4 
- 
- 
- 
- 

121.0 
- 
- 
61.0 
(74.0) 

- 
243.9 

- 
74.4 

- 
108.0 

0.1 
- 
- 
- 
- 

- 
0.1 

0.4 
- 
1.1 
- 
- 

- 
1.5 

655.4 
38.6 
- 
- 
(1.0) 

(12.4) 
680.6 

1,095.2 
38.6 
1.1 
61.0 
(75.0) 

(12.4) 
1,108.5 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the consolidated financial statements  
1. Basis of preparation 

a) Accounting basis 
The consolidated financial statements of Aldermore Group PLC (the “Company”) include the assets, liabilities and results of the 
operations  of  the  Company,  its  subsidiary  undertakings  (together,  the  “Group”)  including  Aldermore  Bank  PLC  (the  “Bank”), 
MotoNovo Finance Limited and its share of earnings of its associate AFS Group Holdings Limited.  

Both the Group consolidated financial statements and the Company financial statements have been prepared and approved by the 
Directors  in  accordance  with  International  Financial  Reporting  Standards  (“IFRSs”)  as  issued  by  the  International  Accounting 
Standards Board (“IASB”) and the UK adopted IFRS.  

During the year ended  30 June 2021,  the Group  has adopted the following  new  amendment to existing standards which were 
effective for accounting periods starting on or after 1 July 2020. There were no new standards in the year which effected the Group.  

New Accounting Standards 

Description of change 

Impact on the Group 

IBOR Reform Phase 2 

(Amendments to IFRS 9, 
IAS 39, IFRS 7, IFRS 4 and 
IFRS 16) 

The amendments provide temporary reliefs which 
address the financial reporting effects when an 
IBOR is replaced with an alternative nearly risk-free 
interest rate (RFR). These included: 
  Practical expedient to require contractual 
changes, or changes to cash flows that are 
directly required by the reform, to be treated 
as changes to a floating interest rate, 
equivalent to a movement in a market rate of 
interest. Inherent in allowing the use of this 
practical expedient is the requirement that the 
transition from an IBOR benchmark rate to an 
RFR takes place on an economically equivalent 
basis with no value transfer having occurred. 
Any other changes made at the same time, 
such as a change in the credit spread or 
maturity date, are assessed. If they are 
substantial, the instrument is derecognised. If 
they are not substantial, the updated effective 
interest rate (EIR) is used to recalculate the 
carrying amount of the financial instrument, 
with any modification gain or loss recognised 
in profit or loss. 

  The amendments permit changes required by 
IBOR reform to be made to hedge designations 
and hedge documentation without the 
hedging relationship being discontinued. 
Permitted changes include redefining the 
hedged risk to reference an RFR and redefining 
the description of the hedging instruments 
and/or the hedged items to reflect the RFR. 
Entities are allowed until the end of the 
reporting period, during which a modification 
required by IBOR reform is made, to complete 
the changes. 

The amendments provide temporary relief to 
entities from having to meet the separately 

Although the amendments are effective for 
periods beginning on or after 1 January 
2021, the Group elected to early adopt the 
Phase Two amendments.  
In doing so, the practical expedients were 
applied for advances and lease receivables 
where changes in the movement in a 
market rate of interest impacted by IBOR, 
was treated as a change in a floating 
interest rate and not as a modification in 
terms of IFRS 9. 
Any other changes to the interest rate 
made at the same time were assessed to 
determine if they were substantial enough 
to warrant a derecognition event or if not 
deemed significant, then to update the EIR 
and recognise the resultant modification 
gain or loss. 
The other temporary relief provided under 
Phase Two, relate to hedge accounting 
under IFRS 9. The Group has evaluated the 
relief provided against the current hedges 
in place and noted that no adjustment was 
necessary.  
Furthermore, it was noted that no 
comparative information required 
restatement and as such, there was no 
impact on the current period opening 
reserves balance upon early adoption. 
Early adoption required the Group to 
provide the following disclosure: 

  How the Group is managing the 

transition to RFRs, its progress 
and the risks to which it is 
exposed arising from financial 
instruments due to IBOR reform;   

105 

 
 
 
 
 
New Accounting Standards 

Description of change 

Impact on the Group 

identifiable requirement when an RFR instrument is 
designated as a hedge of a risk component. The 
relief allows entities upon designation of the hedge, 
to assume that the separately identifiable 
requirement is met, provided the entity reasonably 
expects the RFR risk component to become 
separately identifiable within the next 24 months. 

  Disaggregated by each significant 
IBOR benchmark, quantitative 
information about financial 
instruments that have yet to 
transition to RFRs; and 
If IBOR reform has given rise to 
changes in the entity’s risk 
management strategy, a 
description of these changes.  
See page 83 for the Group disclosures.  

 

By including the Company financial statements, here together with the Group consolidated financial statements, the Company is 
taking advantage of the exemption in Section 408 of the Companies Act 2006 not to present its individual income statement and 
related notes that form a part of these approved financial statements, see page 169 for the Company profit disclosure.   

The principal activity of the Company is that of an investment holding company. The Company is public and limited by shares. The 
address of the Company’s registered office is: Aldermore Bank PLC, Apex Plaza, 4th Floor Block D, Forbury Road, Reading, Berkshire, 
RG1 1AX.  

b) Basis of consolidation 
The consolidated financial statements incorporate the financial statements of the Company and its subsidiaries which are entities 
controlled by the Company, (jointly referred to as the Group), for the year ended 30 June 2021.  
Control is achieved when the Group: 

 
 
 

Has power over the investee; 
Is exposed, or has rights, to variable returns from its involvement with the investee; and 
Has the ability to use its power to affect returns. 

If facts and circumstances indicate that there are changes to one or more of the three elements of control listed above, the Group 
reassesses whether or not it controls an investee. 

Subsidiaries are consolidated from the date on which control is transferred to the Group and are deconsolidated from the date 
that  control  ceases.  Uniform  accounting  policies  are  applied  consistently  across  the  Group.  Intercompany  transactions  and 
balances are eliminated upon consolidation. On initial recognition in the consolidated financial statements, subsidiaries acquired 
are accounted for by applying the acquisition method of accounting to business combinations.  

The excess  or shortage of the sum of  the consideration transferred, the value of non-controlling interest,  the fair value of  any 
existing interest, and the fair value of identifiable net assets, is recognised as goodwill, or a gain on bargain purchase, as set out 
further below. Transaction costs are included in operating expenses within profit or loss when incurred. 

Unrealised  losses  on  transactions  between  Group  entities  are  also  eliminated  unless  the  transaction  provides  evidence  of 
impairment of  the transferred  asset, in which  case  the transferred  asset  will be  tested for impairment in  accordance with  the 
Group’s impairment policies. 

Securitisation vehicles 
The  Group  has  securitised  certain  loans  and  advances  to  customers  by  the  transfer  of  the  beneficial  interest  in  such  loans  to 
securitisation vehicles (see note 30). The securitisation enabled the subsequent issue of debt securities by a securitisation vehicle 
to investors who have the security of the underlying assets as collateral. The securitisation vehicles are fully consolidated into the 
Group’s accounts as the Group has control as defined above. 

106 

 
 
 
 
 
 
 
 
 
The transfer of the beneficial interest in these loans to the securitisation vehicle are not treated as sales by the Group. The Group 
continues  to  recognise  these  assets  within  its  own  Statement  of  Financial  Position  after  the  transfer  as  it  continues  to  retain 
substantially all the risks and rewards from the assets. 

c) Going concern  
The financial statements are prepared on a going concern basis. The Directors are satisfied that the Group has the resources to 
continue in business for the foreseeable future (which has been taken as 12 months from the date of approval of the financial 
statements) and that there are no material uncertainties to disclose. In making this assessment, the Directors have considered a 
wide range of information and the impact of the Covid-19 pandemic on the current state of the balance sheet, future projections 
of profitability, cash flows and capital resources, operational resilience and the longer-term strategy of the business. In particular, 
the Directors have considered the following: 

 

 

 

 

 

 

The impact on the Group’s profitability from  future increases in  expected  credit losses. As part of  this,  the Directors 
considered  revised  macroeconomic  scenarios  which  were  received  from  the  Group’s  in-house  experts.  These  are 
discussed and sensitivities are disclosed in note 3; 
Sufficiency  of  headroom  over  minimum  regulatory  requirements  for liquidity and  capital,  including  the  ability  of  the 
Group to access sources of additional liquidity and / or capital if required;  
Current and forecasted conditions are significantly less severe than the reverse stress scenario considered in the latest 
ICAAP presented to the Prudential Regulation Authority; 
The  plans  for  further  improving  the  operational  resilience  of  the  Group  including  cyber  and  information  security, 
information  technology,  supplier  management,  people  and  property.  These  improvements  are  planned  as  part  of 
ongoing investment activity in the Aldermore Group; 
Any potential valuation concerns in respect of the Group’s assets as set out in the Company and Consolidated Statements 
of Financial Position; 
The validity of the Group’s current strategy and its achievement of its longer-term strategic ambitions.  

The Group’s capital and liquidity plans, including stress tests, have been reviewed by the Directors as noted above. The Group’s 
forecasts and projections show that it will be able to operate at adequate levels of both liquidity and capital for the foreseeable 
future, including under a range of stressed scenarios.  
After  making  due  enquiries,  the  Directors  believe  that  the  Group  has  sufficient  resources  to  continue  its  activities  for  the 
foreseeable future, and the Group has sufficient capital to enable it to continue to meet its regulatory capital requirements as set 
out by the Prudential Regulation Authority. 

d) Basis of measurement 
The financial statements have been prepared on the historical cost basis except for the following material items in the financial 
statements: 
 
 

Derivative financial instruments are measured at fair value through profit or loss; 
Fair  value  through  other  comprehensive  income  (FVOCI)  debt  securities  are  valued  at  fair  value  through  other 
comprehensive income; and 
Fair value adjustments for portfolios of financial assets and financial liabilities designated as hedged items in qualifying 
fair value hedge relationships, which reflect changes in fair value attributable to the risk being hedged and are reflected 
through profit or loss in order to match the gains or losses arising on the derivative financial contracts that qualify as 
hedging instruments.  

 

e) Use of estimates and judgements 
The preparation of financial statements requires management to make judgements, estimates and assumptions that affect the 
application of accounting policies and the reported amounts of assets, liabilities, income and expenses. Actual results may differ 
from these estimates. 

Estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognised in the 
period in which the estimates are revised and in any future periods affected. 

Information  about  areas  of estimation, uncertainty  and  critical  judgements  in  applying  accounting  policies that  have the  most 
significant effect on the amounts recognised in the financial statements are included in note 3. 

107 

 
 
 
f) Presentation of risk and capital disclosures 
The disclosures required under IFRS 7: “Financial instruments: disclosures” and IAS 1: "Presentation of financial statements" have 
been  included  within  the  audited  sections  of  the  Risk  Report  on  pages  57  to  87.  Where  information  is  marked  as  audited, 
it is incorporated  into these  financial statements  by this  cross  reference and  it is covered by the Independent Auditor’s report 
on page 90. 

g) Standards and interpretation issued not yet effective 
The following new and revised standards and interpretations, all of which have been endorsed for use within the UK (except where 
stated) are applicable to the business of the Group. The Group will comply with these from the stated effective date. 

New Accounting Standards 

Description of change 

Impact on the Group 

Classification of liabilities as 
current or non-current (IAS 
1) 

The amendments clarify the requirements for 
classifying liabilities as current or non-current. More 
specifically: 

  The amendments specify that the 

conditions which exist at the end of the 
reporting period are those which will be 
used to determine if a right to defer 
settlement of a liability exists. 

  Management expectations about events 
after the balance sheet date, for example 
on whether a covenant will be breached, or 
whether early settlement will take place, 
are not relevant. 

The amendments clarify the situations that are 
considered settlement of a liability. 

The amendment prohibits entities from deducting 
from the cost of an item of property, plant and 
equipment (PP&E), any proceeds of the sale of items 
produced while bringing that asset to the location 
and condition necessary for it to be capable of 
operating in the manner intended by management. 
Instead, an entity recognises the proceeds from 
selling such items, and the costs of producing those 
items, in profit or loss.  

The amendments apply a ‘directly related cost 
approach’. The costs that relate directly to a contract 
to provide goods or services include both 
incremental costs (e.g., the costs of direct labour and 
materials) and an allocation of costs directly related 
to contract activities (e.g., depreciation of equipment 
used to fulfil the contract as well as costs of contract 
management and supervision). General and 
administrative costs do not relate directly to a 
contract and are excluded unless they are explicitly 
chargeable to the counterparty under the contract.  

Property, plant and 
equipment (IAS 16) 

Onerous contracts – cost 
of fulfilling a contract (IAS 
37) 

Effective date: 01 July 2022 – 30 June 2023. 
The Group presents its assets and liabilities in 
order of liquidity in its statement of financial 
position. This amendment will only affect the 
disclosures and the Group does not expect 
this amendment to have a significant impact 
on the annual financial statements. 

Effective date: 01 July 2022 – 30 June 2023. 
The amendment is not expected to have a 
significant impact on the annual financial 
statements. 

Effective date: 01 July 2022 – 30 June 2023. 
The amendment is not expected to have a 
significant impact on the annual financial 
statements. 

Business combinations 
(IFRS 3) 

Reference to the Conceptual Framework – 
Amendment to IFRS 3. 

The amendments add an exception to the 
recognition principle of IFRS 3 to avoid the issue of 
potential ‘day 2’ gains or losses arising for liabilities 
and contingent liabilities that would be within the 

Effective date: 01 July 2022 – 30 June 2023. 

The amendment is not expected to have a 
significant impact on the annual financial 
statements. 

108 

 
 
 
New Accounting Standards 

Description of change 

Impact on the Group 

scope of IAS 37 Provisions, Contingent Liabilities and 
Contingent Assets or IFRIC 21 Levies, if incurred 
separately. The exception requires entities to apply 
the criteria in IAS 37 or IFRIC 21, respectively, instead 
of the Conceptual Framework, to determine whether 
a present obligation exists at the acquisition date. At 
the same time, the amendments add a new 
paragraph to IFRS 3 to clarify that contingent assets 
do not qualify for recognition at the acquisition date. 

Improvements to IFRS 

(Annual improvements  

2016 – 2018) 

Improvements to IFRS 

(Annual improvements  

2018 – 2020) 

Cycle. 

These 

2016-2018 

The  IASB  issued  the  Annual  improvements  to  IFRS
standards 
annual
improvements include  amendments  to the following
standards. 
IFRS 9 – The amendment clarifies that fees that an 
entity includes when assessing whether the terms of 
a new or modified financial liability are substantially 
different from the terms of the original financial 
liability. These fees include only those paid or 
received between the borrower and the lender, 
including fees paid or received by either the 
borrower or lender on the other’s behalf.  

IFRS  1  First-time  Adoption  of  International  Financial
Reporting Standards: 
Subsidiary as a first-time adopter  
  The amendment permits a subsidiary that elects 
to apply paragraph D16(a) of IFRS 1 to measure 
cumulative translation differences using the 
amounts reported by the parent, based on the 
parent’s date of transition to IFRS. This 
amendment is also applied to an associate or 
joint venture that elects to apply paragraph 
D16(a) of IFRS 1.  
IFRS 9 Financial Instruments 
Fees  in  the  ’10  per  cent’  test  for  derecognition  of
financial liabilities 
  The amendment clarifies the fees that an entity 
includes when assessing whether the terms of a 
new or modified financial liability are 
substantially different from the terms of the 
original financial liability. These fees include only 
those paid or received between the borrower 
and the lender, including fees paid or received 
by either the borrower or lender on the other’s 
behalf. There is no similar amendment proposed 
for IAS 39. 

  An entity applies the amendment to financial 

liabilities that are modified or exchanged on or 
after the beginning of the annual reporting 
period in which the entity first applies the 
amendment. 

Effective date: 01 July 2022 – 30 June 2023. 
The amendments are not expected to have a 
significant impact on the annual financial 
statements. 

Effective date: 01 July 2022 – 30 June 2023. 
The amendments are not expected to have a 
significant impact on the annual financial 
statements. 

109 

 
 
2. Significant accounting policies 

(a) Interest income and expense 
Interest income and expense are recognised in the income statement on an effective interest rate “EIR” basis. The EIR is the rate 
that,  at the inception  of  the financial  asset or  liability, exactly  discounts expected future  cash payments  and receipts over  the 
expected  life  of  the  instrument  back  to  the  initial carrying  amount.  When  calculating the  EIR,  the  Group  estimates  cash  flows 
considering all contractual terms of the instrument (for example, prepayment options) but does not consider the assets’ future 
credit losses. 

Interest on impaired financial assets is recognised at the same EIR as applied at the initial recognition of the financial asset but 
applied to the book value of the financial asset net of any impairment allowance.  

At  each reporting date, management makes an  assessment  of the expected remaining life of  its financial  assets,  including any 
acquired loan portfolios, and where there is a change in those assessments, the remaining amount of any unamortised discount or 
premiums is adjusted so that the interest income continues to be recognised prospectively on the amortised cost of the financial 
asset at the original EIR. The adjustment is recognised within interest income in the income statement for the current period.  

The calculation of the EIR includes all transaction costs and fees, paid or received, that are an integral part of the interest rate 
together with the discounts or premium arising on the acquisition of loan portfolios. Transaction costs include incremental costs 
that are directly attributable to the acquisition or issue of a financial asset or liability. 

Interest income and expense presented in the income statement includes: 

 
Interest on financial assets and financial liabilities measured at amortised cost calculated on an EIR basis; 
 
Interest on FVOCI debt securities calculated on an EIR basis; 
 
Interest income recognised on finance leases where the Group acts as the lessor (see note19);  
 
Interest income is net of variations in interest income which reflect any non-compliance of interest charged to customers; 
  Modification gains and losses in Asset Finance calculated on the modified cash flows, discounted at the original interest 

rate and unwound through interest income over the remaining term of the asset; and 
Interest income charged to Invoice Finance clients each day on the balance of their outstanding loans on an EIR basis. 

 

(b) Fee and commissions and other operating income  

i. Fee and commission income 
The  Group  earns  fee  and  commission  income  from  a  diverse  range  of  financial  services  it  provides  to  its  customers.  Fee  and 
commission  income  is  recognised  at  an  amount  that  reflects  the  consideration  to  which  the  Group  expects  to  be  entitled  in 
exchange for providing the services.  

Fees  and  commissions  that  form  an  integral  part  of  the  effective  interest  rate  are  excluded  from  fees  and  commissions  from 
customers. Arrangement fees, factoring fees for managing the customer sales ledgers within Invoice Finance and other fees relating 
to loans and advances which meet the criteria for inclusion within interest income are included as part of the EIR. 

Other fee and commission income includes fees charged for mortgage services, arrears and insurance commission receivable. 

Fee income is recognised as the Group satisfies its performance obligations, which can either be satisfied at a point in time or over 
a period of time. 

The vast majority of fee and commission income is earned on the execution of a single performance obligation and as such, it is 
not necessary to make significant judgements when allocating the transaction price to the performance obligation. As such, fee 
and commission income is recognised at a point in time.  

For fees earned on the execution of a significant act, the performance obligation is satisfied when the significant act or transaction 
takes place. Where the performance obligation is satisfied over a period of time, the fees are recognised as follows: 

 

 

Fees for services rendered are recognised on an accruals basis as the service is rendered and the Group’s performance 
obligation is satisfied; and 
Commission income is credited to profit or loss over the life of the relevant instrument on a time apportionment basis. 

110 

 
 
 
 
 
 
 
 
 
 
 
 
ii. Fee and commission expense 
Fee and commission  expense predominantly consists of  introducer  commissions, legal and valuation fees and company search 
fees. Where these fees and commissions are incremental costs that are directly attributable to the issue of a financial instrument, 
they  are  included  in  interest  income  as  part  of  the  EIR  calculation.  Where  they  are  not  incremental  costs  that  are  directly 
attributable, they are recognised within fee and commission expense as the services are received. 

iii. Other operating income 
Other operating income predominantly arises from the provision of MotoNovo Finance dealer funding fees and Invoice Finance 
services which include disbursements and collect out income. This income is recognised within other operating income when the 
Group satisfies its performance obligations. MotoNovo Finance recognises a reduction of certain income for policies expected to 
be cancelled against this based on the long run average cancellation rate over the life of the agreement. 
Other operating income also includes income derived from the service level agreement (“SLA”) recharge to the FirstRand London 
Branch in relation to MotoNovo Finance servicing the back book.  

(c) Net gains / (losses) from derivatives and other financial instruments at fair value through profit or loss 
Net  gains/(losses)  from  derivatives  and  other  financial  instruments  at  fair  value  through  profit  or  loss  relate  to  non-trading 
derivatives held for risk management purposes that do not form part of a qualifying hedging arrangement. It includes all realised 
and unrealised fair value movements, interest and foreign exchange differences. 

(d) Financial instruments - recognition and derecognition 

i. Recognition 
The Group initially recognises loans and advances, amounts due to banks, customer accounts and subordinated notes issued on 
the date that they are originated. 

Regular purchases and sales of debt securities and derivatives are recognised on the trade date at which the Group commits to 
purchase or sell the asset. All other financial assets and liabilities are initially recognised on the trade date at which the Group 
becomes a party to the contractual provisions of the instrument. 

ii. Derecognition 

Financial assets are derecognised when and only when: 

 
 

The contractual rights to receive the cash flows from the financial asset expire; or 
The Group has transferred substantially all the risks and rewards of ownership of the assets. 

When a financial asset is derecognised in its entirety, the difference between the carrying amount, the sum of the consideration 
received  (including  any  new  asset  obtained  less  any  new  liability  assumed),  and  any  cumulative  gain  or  loss  that  had  been 
recognised in other comprehensive income is recognised in gains on disposal of fair value through other comprehensive income 
(FVOCI) in the income statement. 

A financial liability is derecognised when the obligation is discharged, cancelled or expires. Any difference between the carrying 
amount of a financial liability derecognised and the consideration paid is recognised in the income statement. 

iii. Term Funding Scheme 
Loans and advances over which the Group transfers its rights to the collateral thereon to the Bank of England under the TFS and 
TFSME (Term Funding Scheme with additional incentive for SMEs) are not derecognised from the statement of financial position 
as the Group retains substantially all the risks and rewards of ownership including all cash flows arising from the loans and advances 
and exposure to credit  risk.  The cash received against the transferred assets  is  recognised as an asset  within the  statement  of 
financial position, with the corresponding obligation to return it recognised as a liability at amortised cost within ‘Amounts due to 
banks’. Interest is accrued over the life of the agreement on an EIR basis. 

(e) Financial assets  

i. Classification 

Management determines the classification of its financial assets at initial recognition, based on: 

 
 

The Group’s business model for managing the financial assets; and  
The contractual cash flow characteristics of the financial asset. 

111 

 
 
 
 
 
The Group distinguishes three main business models for managing financial assets: 

  Holding financial assets to collect contractual cash flows; 
  Managing financial assets and liabilities on a fair value basis or selling financial assets; and 
 
A mixed business model of collecting contractual cash flows and selling financial assets. 

The business model assessment is not performed on an instrument by instrument basis, but at a level that reflects how groups of 
financial assets are managed together to achieve a particular business objective. This assessment is done on a portfolio or sub-
portfolio level depending on the manner in which groups of financial assets are managed. 

In  considering  whether  the  business  objective  of  holding  a  group  of  financial  assets  is  achieved  primarily  through  collecting 
contractual cash flows, amongst other considerations, management monitors the frequency and significance of sales of financial 
assets out of these portfolios for purposes other than managing credit risk. For the purposes of performing the business model 
assessment, the Group only considers a transaction a sale if the asset is derecognised for accounting purposes. For example, a repo 
transaction  where  a  financial  asset  is  sold  with  the  commitment to  buy  back  the  asset  at  a  fixed  price  at  a  future  date  is  not 
considered  a  sale  transaction  as  substantially  all  the  risks  and  rewards  relating  to  the  ownership  of  the  asset  have  not  been 
transferred and the asset is not derecognised from an accounting perspective.  

If sales of financial assets are infrequent, the significance of these sales are considered by comparing the carrying amount of assets 
sold  during  the  period  and  cumulatively  to  the  total  carrying  amount  of  assets  held  in  the  business  model.  If  sales  are  either 
infrequent  or insignificant,  these  sales will  not impact the conclusion  that  the business  model for holding financial assets  is  to 
collect contractual cash flows. In addition, where the issuer initiates a repurchase of the financial assets which was not anticipated 
in the terms of the financial asset, the repurchase is not seen as a sale for the purposes of assessing the business model of that 
group of financial assets. 

A change in business model of the Group only occurs on the rare occasion when the Group changes the way in which it manages 
financial assets. Any changes in business models would result in a reclassification of the relevant financial assets from the start of 
the next reporting period. 

In order for a debt security to be measured at amortised cost or fair value through other comprehensive income, the cash flows 
on the asset have to be solely payments of principal and interest (SPPI), i.e. consistent with those of a basic lending agreement.  
The SPPI test is applied to individual securities at initial recognition, based on the cash flow characteristics of the asset. All debt 
securities held as at 30 June 2021 passed the SPPI test. The Group held three portfolios of debt securities, the first as part of a 
mixed business model whose objectives include both the collection of contractual cash flows and the sale of financial assets, the 
second as part of a held to collect model whose objective is to collect contractual cash flows until maturity, and the third as part 
of the Aldermore Group Capital Investment Strategy which seeks to stabilise earnings volatility by extending the investment term 
of equity capital. Debt securities held in the mixed business model have been classified as measured at fair value through other 
comprehensive  income,  and  those  held  in  the  held  to  collect  model  and  Capital  Investment  Strategy  have  been  classified  as 
measured at amortised cost.  

The SPPI test is applied on a portfolio basis for loans and advances to customers, cash and balances at central banks and loans and 
advances to banks, as the cash flow characteristics of these assets are standardised. This included consideration of any prepayment 
charges, which in all cases were reasonable compensation and therefore did not cause these assets to fail the SPPI test.  As all of 
these financial  assets were held as part of  business models  with the objective of collecting  contractual cash  flows  and they all 
passed the SPPI test, they have all been classified as financial assets to be measured at amortised cost. 

ii. Measurement 

Financial assets measured at amortised cost 
These are initially measured at fair value plus transaction costs that are directly attributable to the financial asset. Subsequently, 
these are measured at amortised cost using the EIR method. The amortised cost is the amount advanced less principal repayments, 
plus or minus the cumulative amortisation using the EIR method of any difference between the amount advanced and the maturity 
amount, less impairment provisions for incurred losses.  Financial assets measured at amortised cost mainly comprise loans and 
advances to customers and loans and advances to banks. 

112 

 
 
 
 
 
 
Financial assets measured at fair value through other comprehensive income (FVOCI) 
These are initially measured at fair value plus transaction costs that are directly attributable to the financial asset. Subsequently, 
they are measured at fair value based on current, quoted bid prices in active markets for identical assets that the Group can access 
at the reporting date. Where there is no active market, or the debt securities are unlisted, the fair values are based on valuation 
techniques including discounted cash flow analysis, with reference to relevant market rates and other commonly used valuation 
techniques. Interest income is recognised in the income statement using the EIR method. Impairment provisions for incurred losses 
are recognised in the income statement which does not reduce the carrying amount of the investment security but is transferred 
from the FVOCI reserve in equity. Other fair value movements are recognised in other comprehensive income and presented in 
the FVOCI reserve in equity. On disposal, the gain or loss accumulated in equity is reclassified to the income statement. 

Financial assets at fair value through profit or loss 
These are measured both initially and subsequently at fair value with movements in fair value recorded in the income statement. 
Any costs that are directly attributable to their acquisition are recognised in profit or loss when incurred. The Group only measures 
derivative financial assets under this classification.  

Modification of financial instruments 
The Group derecognises a financial asset, such as a loan to a customer, when the terms and conditions have been renegotiated to 
the extent that, substantially, it becomes a new loan, with the difference recognised as a derecognition gain or loss, to the extent 
that an impairment loss has not already been recorded. The newly recognised loans are classified as stage 1 for ECL measurement 
purposes, unless the new loan is deemed to be POCI (“purchased or originated credit-impaired”). 

If the modification does not result in cash flows that are substantially different the modification does not result in derecognition. 
Based on the change in cash flows discounted at the original EIR, the Group records a modification gain or loss, to the extent that 
an impairment loss has not already been recorded 

Modification gains and losses are calculated on an individual contract basis. This is calculated by discounting the modified cash 
flows at the original interest rate and results in a modification gain/loss in impairments in the financial year. The resultant gain/loss 
is recognised in the consolidated income statement. 

(f) Financial liabilities 

i. Overview  
Financial liabilities are contractual obligations to deliver cash or another financial asset. Financial liabilities are recognised initially 
at fair value, net of directly attributable transaction costs for financial liabilities other than derivatives. Financial liabilities, other 
than derivatives, are subsequently measured at amortised cost.  

ii. Financial liabilities at amortised cost  
Financial liabilities at amortised cost are recognised initially at fair value net of transaction costs incurred. They are subsequently 
measured at amortised cost. Any difference between the fair value and the redemption value is recognised in the income statement 
over the period of the borrowings using the EIR method. 

iii. Subordinated notes 
Subordinated notes issued by the Group are assessed as to whether they should be treated as equity or financial liabilities. Where 
there is a contractual obligation to deliver cash or other financial assets, they are treated as a financial liability and measured at 
amortised cost using the EIR method after taking account of any discount or premium on the issue and directly attributable costs 
that are an integral part of the EIR. The amount of any discount or premium is amortised over the period to the expected call date 
of the instrument.  

All subordinated notes issued by the Group are classified as financial liabilities.  

113 

 
 
 
 
 
 
 
(g) Impairment—financial assets 
This policy applies to: 

Financial assets measured at amortised cost; 

 
  Debt securities measured at fair value through other comprehensive income; 
 
 

Loan commitments; and  
Finance lease receivables where Group is the lessor. 

IFRS 9 establishes a three-stage approach for impairment of financial assets. 

 

 

 

Stage 1 - at initial recognition of a financial asset, or when an irrevocable loan commitment is made if this occurs before 
a financial asset is recognised, the asset or loan commitment is classified as stage 1 and 12 month expected credit losses 
(ECL) are recognised, which are credit losses related to default events expected to occur within the next 12 months; 
Stage 2 - if the asset has experienced a significant increase in credit risk since initial recognition, the asset is classified as 
stage 2 and lifetime expected credit losses are recognised; and 
Stage 3 - credit impaired assets are classified as stage 3, the asset is classified as stage 3 and lifetime expected credit 
losses are recognised. 

Collective and individual assessment 
The Group uses a bespoke credit engine to estimate ECL on a collective basis for all loans to customers and loan commitments. 
The collective assessment groups loans with shared credit risk characteristics through lines of business. The engine captures model 
outputs  from  the  12-month  Probability  of  Default  (PD),  Exposure  at  Default  (EAD),  Loss  Given  Default  (LGD),  Lifetime  PD, 
Macroeconomic models and Staging analysis to derive an ECL estimate for each account.   

Statistical modelling techniques are used to determine which borrower and transaction characteristics are predictive of certain 
behaviours, based on relationships observed in historical data related to the group of accounts to which the model will be applied. 
These  result  in  the  production  of  models  that  are  used  to  predict  impairment  parameters  (PD,  LGD,  and  EAD)  based  on  the 
predictive characteristics identified through the regression process. 

When impairments are calculated, each exposure is assigned unique impairment parameters (a PD, LGD and EAD) based on that 
exposure’s  individual  characteristics.  These  account-level  impairment  parameters  are  then  used  to  calculate  account-level 
expected credit losses. 

Where a loan is in stage 3, then a lifetime ECL is estimated based upon an individual assessment of the borrower and any collateral 
provided. Typically, the assessment will evaluate the emergence period, likelihood of recovery, recovery period and size of haircut 
to be applied to the value of the collateral under the different scenarios to estimate their corresponding specific provision amounts 
on a best estimate basis. A scalar is then applied to the best estimate so as to provide a probability weighted estimate of the lifetime 
ECL.  For  recent  non-performing  assets,  where  individual  assessment  is  still  outstanding,  and  those  stage  3  assets  where  the 
individually  assessed  lifetime  ECLs  are  not  significant,  then  the  provisions  will  be  based  on  the  lifetime  ECLs  determined  on  a 
collective basis as the same models used for stage 1 and stage 2 exposures. 

In respect of debt securities and loans to banks, estimates of expected losses are calculated on the current individual credit grading 
of the exposure and externally sourced expected loss rates. The Group deems the likelihood of default across the respective asset 
counterparties as immaterial, and hence does not recognise a provision against the carrying balances. 

Significant increase in credit risk (movement to stage 2) (“SICR”) 
In assessing whether loans to customers and loan commitments have been subject to a significant increase in credit risk the Group 
applies the following criteria in order: 

 

A presumption that an account which is more than 30 days past due has suffered a significant increase in credit risk.  IFRS 
9 allows this presumption to be rebutted, but the Group believes that more than 30 days past due to be an appropriate 
back stop measure and therefore has not rebutted the presumption;  

  Quantitative criteria based upon a change in the modelled probability of default of individual credit exposures. Staging 
models using statistical techniques have been developed on a portfolio basis to determine the levels of changes in PDs 
since  origination  which  correlate  to  a  significant  increase  in  the  likelihood  of  delinquency  among  historic  loans  with 
similar characteristics; and 

114 

 
 
 
 
 
 
 
 
  Qualitative criteria, where an exposure is subject to temporary forbearance or has been placed on a watch list as a result 
of possessing certain qualitative features based on Basel Committee On Banking Supervision “Guidance on credit risk 
and accounting for expected credit losses”, including such matters as significant change in the operating results of the 
borrower or in the value of the collateral provided. 

Accounts that have requested payment breaks in relation to Covid-19 that were not in arrears at the start of the payment break 
are not considered to be past due for the purpose of IFRS 9 staging. 

In respect of debt securities and loans to banks, use is made of the low credit risk expedient permitted by IFRS 9 whereby the credit 
risk is not considered to have increased significantly where the exposures are assumed to be “low” credit risk at the reporting date 
or/and where they continue to be investment grade, or equivalent. 

Definition of credit impaired (movement to stage 3) 
The Group has identified certain quantitative and qualitative criteria to be considered in determining when an exposure is credit 
impaired and should therefore be moved into stage 3, these include the following: 

• 

The exposure becomes 90 days past due.  IFRS 9 allows this assumption to be rebutted, but at present the Group has not 
done so;  

•  Qualitative  criteria,  which  vary  according  to  the  type  of  lending  being  undertaken,  but  include  indicators  such  as 

bankruptcies, Individual Voluntary Arrangements and permanent forbearance; and 

 

Accounts that have requested Covid-19 related payment breaks in excess of 6 months are considered to be in distress 
and moved to stage 3. 

The Group has used the same definition of default as that for the purpose of calculating PDs used in its credit models. In addition, 
the definition has been aligned with those used for regulatory reporting purposes. 

Movements back to stages 1 and 2 
Exposures will move out of stage 3 to stage 2 when they no longer meet the criteria for inclusion and have completed agreed 
probation periods set according to the type of lending. Movement into stage 1 will only occur when the SICR criteria are no longer 
met. 

Write-Off and Recoveries  
Write-off shall occur when either part, or all, of the outstanding debt is considered irrecoverable and all viable options to recover 
the debt have been exhausted. Any amount received after a provision has been raised or debt has been written-off, will be recorded 
as a recovery and reflected as a reduction in the impairment loss reflected in the income statement. 

Forward-looking macroeconomic scenarios 

ECLs  and  SICR  take  into  account  forecasts  of  future  economic  conditions  in  addition  to  current  conditions.    The  Group  has 
developed  a  macroeconomic  model  which  adjusts  the  ECLs  calculated  by  the  credit  models  to  provide  probability  weighted 
numbers based on a number of forward-looking macroeconomic scenarios. 

During  the  reporting  period  the  Group  has  changed  the  sourcing  of  its  forward-looking  economic  scenarios  and  probability 
weightings from an external supplier to internally produced scenarios. 

(h) Financial instruments—fair value measurement 

Fair value is the price that would be received to sell an asset, or paid to transfer a liability, in an orderly transaction between market 
participants at the measurement date in the principal market, or in its absence, the most advantageous market to which the Group 
has access at that date. The fair value of a liability reflects its non-performance risk. 

Where  applicable,  the  Group  measures  the  fair  value  of  an  instrument  using  the  quoted  price  in  an  active  market  for  that 
instrument. A market is regarded as active if transactions for the asset or liability take place with sufficient frequency and volume 
to provide pricing on an ongoing basis. 

Where  there  is  no  quoted  price  in  an  active  market,  the  Group  uses  valuation  techniques  that  maximise  the  use  of  relevant 
observable inputs and minimises the use of unobservable inputs. The chosen valuation techniques incorporate factors that market 
participants would take into account in pricing a transaction. 

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The best evidence of fair value of a financial instrument at initial recognition is normally the transaction price. If an asset measured 
at fair value has a bid and an offer price, the Group measures assets and long positions at the bid price and liabilities at the offer 
price. 

(i) Derivative financial instruments 
The Group enters into derivative transactions only for the purpose of reducing exposures to fluctuations in interest rates, exchange 
rates and market indices. They are not used for proprietary trading purposes. 

Derivatives  are  carried  at  fair  value,  with  movements  in  fair  values  recorded  in  gains  from  derivatives  and  other  financial 
instruments at fair value through profit or loss in the income statement. Derivative financial instruments are principally valued by 
discounted cash flow models using yield curves that are based on observable market data or are based on valuations obtained 
from counterparties. As the Group’s derivatives are covered by master netting agreements with the Group’s counterparties, with 
any net exposures then being further covered by the payment or receipt of periodic cash margins, the Group has used a risk-free 
discount rate for the determination of their fair values. 

All derivatives are classified as assets where their fair value is positive and liabilities where their fair value is negative. Where there 
is the  current legal ability and  intention to settle net, then the derivative is classified  as a  net asset  or liability, as appropriate. 
Where cash  collateral  is received, to mitigate the risk inherent in amounts due to the  Group, it  is included as a liability within 
‘Amounts due to banks’. Where cash collateral is given, to mitigate the risk inherent in amounts due from the Group, it is included 
as an asset in ‘Loans and advances to banks’. 

(j) Hedge accounting 
The Group exercised the accounting policy choice to continue using IAS 39 hedge accounting for  portfolio assets and liabilities 
being hedged by applying fair value hedge accounting. 

The Group designates certain derivatives held for risk management as hedging instruments in qualifying hedging relationships. On 
initial designation of the hedge, the Group formally documents the relationship between the hedging instruments and hedged 
items, including the risk management objective, the strategy in undertaking the hedge and the method that will be used to assess 
the effectiveness of the hedging relationship.  

The Group makes an assessment, both at the inception of the hedge relationship, as well as on an ongoing basis, as to whether the 
hedging instruments are expected to be highly effective in offsetting the movements in the fair value of the respective hedged 
items during the period for which the hedge is designated. 

Fair value hedge accounting for portfolio hedges of interest rate risk 
The Group applies fair value hedge accounting for portfolio hedges of interest rate risk. As part of its risk management process, 
the  Group  identifies  portfolios  whose  interest  rate  risk  it  wishes  to  hedge.  The  portfolios  comprise  either  only  assets  or  only 
liabilities. The Group analyses each portfolio into repricing time periods based on expected repricing dates, by scheduling cash 
flows into the periods in which they are expected to occur. Using this analysis, the Group designates as the hedged item an amount 
of the assets or liabilities from each portfolio that it wishes to hedge. 

The amount to hedge is determined based on a movement in the present value of a portfolio of assets or liabilities for a 1 basis 
point shift in the yield curve used to value the instruments (“PV01”), to ensure the mismatches in expected repricing buckets are 
within the limits set by the Board on the sensitivity analysis approach using a hypothetical shift in interest rates. 

The Group measures monthly the movements in fair value of the portfolio relating to the interest rate risk that is being hedged. 
Provided that the hedge has been highly effective, the Group recognises the change in fair value of each hedged item in the income 
statement with the cumulative movement in their value being shown on the statement of financial position as a separate item, 
‘Fair value adjustment for portfolio hedged risk’, either within assets or liabilities as appropriate. 

The  Group  measures  the  fair  value  of  each  hedging  instrument  monthly.  The  value  is  included  in  derivatives  held  for  risk 
management in either assets or liabilities as appropriate, with the change in value recorded in net gains from derivatives and other 
financial instruments at fair value through profit or loss in the income statement. Any hedge ineffectiveness is recognised in net 
gains from derivatives and other financial instruments at fair value through profit or loss in the income statement as the difference 
between the change in fair value of the hedged item and the change in fair value of the hedging instrument. 

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(k) Embedded derivatives 
A  derivative  may  be  embedded  in  a  financial  liability  at  amortised  cost,  known  as  the  host  contract.  Where  the  economic 
characteristics and risks of an embedded derivative are not closely related to those of the host contract (and the host contract is 
not carried at fair value through profit or loss), the embedded derivative is separated from the host and held on the statement of 
financial position with ‘Derivatives held for risk management’ at fair value. Movements in fair value are recognised in net gains 
from  derivatives  and  other  financial  instruments  at  fair  value  through  profit  or  loss  in  the  income  statement,  whilst  the  host 
contract is accounted for according to the relevant accounting policy for that particular asset or liability.  

Embedded derivatives contained within equity instruments are considered separately. The embedded derivatives on the Additional 
Tier  1  instruments  are  not  separated  as  the  Group  has  an  accounting  policy  not  to  separate  features  that  have  already  been 
considered in determining that the entire issues are non-derivative equity instruments.  

(l) Property, plant and equipment 

Items of property, plant and equipment are stated at cost, or deemed cost on transition to IFRSs, less accumulated depreciation 
and accumulated impairment. Cost includes expenditure that is directly attributable to the acquisition of the asset or costs incurred 
in bringing the asset in to use. Depreciation is provided on all property, plant and equipment at rates calculated to write-off the 
cost of each asset to realisable values on a straight-line basis over its expected useful life, as follows: 

• 
• 
• 
• 
• 
• 

five years 
Fixtures, fittings and equipment 
one to five years 
Computer hardware 
Leasehold improvements                          one to ten years 
Right of use assets – property  
Right of use assets – motor vehicles       three years 
Assets under operating leases        

length of the lease 

one to seven years 

Purchased software that is integral to the functionality of the related equipment is capitalised as part of that equipment.  

Right-of-use assets (ROUA) are recognised at the commencement date of the lease (i.e. the date the underlying asset is available 
for  use).  ROUA’s  are  measured  at  cost,  less  any  accumulated  depreciation  and  impairment  losses,  and  adjusted  for  any  re-
measurement of lease liabilities. The cost of right-of-use assets includes the amount of lease liabilities recognised, initial direct 
costs incurred, and lease payments made at or before the commencement date less any lease incentives received.  

(m) Intangible assets 

i. Goodwill 
Goodwill on the acquisition of  businesses and  subsidiaries  represents excess  consideration transferred and  is  recognised as an 
intangible asset at cost less accumulated impairment losses. 

ii. Computer systems 
Software acquired by the Group is measured at cost less accumulated amortisation and any accumulated impairment losses. Cloud 
computing software is expensed to the Income Statement unless the recognition criteria in IAS 38 can be met.  

Expenditure on internally developed software is recognised as an asset when the Group is able to demonstrate its intention and 
ability to complete the development and use the software in a manner that will generate future economic benefits and can reliably 
measure the costs to complete the development. The capitalised costs of internally developed software include all costs directly 
attributable to developing the software and are amortised over its useful life. Internally developed software is stated at capitalised 
cost less accumulated amortisation and impairment. 

Acquired and internally developed software is amortised on a straight line basis in the income statement over its expected useful 
life from the date that it is available for use, being 3 years.  

(n) Impairment of non-financial assets 
The carrying amounts of the Group’s non-financial assets, i.e. goodwill and other intangible assets are reviewed for impairment. 
Goodwill is tested annually for impairment or earlier if there are objective indicators of impairment. Other intangible assets are 
reviewed for impairment semi – annually or earlier if there is an indicator of impairment. If any such indication exists, then the 
asset’s recoverable amount is estimated. 

117 

 
 
 
 
 
 
 
i. Goodwill 
Goodwill  is  tested  for  impairment  at  least  annually.  For  the  purpose  of  impairment  testing,  goodwill  is  allocated  to  operating 
segments.  An  impairment  loss  is  recognised  if  the  carrying  amount  of  a  segment  is  higher  than  its  recoverable  amount.  The 
recoverable amount of a segment is the greater of its value in use and its fair value less costs to sell. Value in use is calculated from 
forecasts by management of pre-tax profits for the subsequent five years and a residual value discounted at a risk adjusted interest 
rate appropriate to the cash generating unit. Fair value is determined through review of precedent transactions for comparable 
businesses.  Where  impairment  is  required,  the  amount  is  recognised  in  the  income  statement  and  cannot  be  subsequently 
reversed. 

ii. Other intangible assets 
Other intangible assets are tested for impairment at least semi-annually. If impairment is indicated, the asset’s recoverable amount, 
being the greater of value in use and fair value less costs to sell, is estimated. If the carrying value of the asset is greater than the 
greater of the value in use and the fair value less costs to sell, an impairment loss is recognised in the income statement.  

An impairment loss is reversed only to the extent that the asset’s carrying amount does not exceed the carrying amount that would 
have been determined, net of depreciation or amortisation, if no impairment loss had been recognised. 

(o) Assets leased to customers 
Leases of assets to customers are finance leases as defined by IFRS 16. When assets are leased to customers under finance leases, 
the present value of the lease payments is recognised as a receivable. The difference between the gross receivable and the present 
value of the receivable is recognised as unearned finance income. Lease income is recognised within interest income in the income 
statement over the term of the lease using the net investment method (before tax) which reflects a constant periodic rate of return 
ignoring tax cash flows. 

(p) Assets leased from third parties 
The Group applies a single recognition and measurement approach for all leases, except for short-term leases and leases of low-
value assets. The Group elected to apply the short-term lease exemption to leases with a lease term of less than 12 months. The 
Group recognises lease liabilities at the present value of the lease payments outstanding at commencement date, discounted by 
using the rate implicit in the lease. If this rate cannot be readily determined, the Group uses its incremental borrowing rate.  Each 
lease payment is allocated between lease liability and interest expense. Interest expense is charged to the income statement over 
the lease period so as to produce a constant periodic rate of interest on the remaining balance of the liability for each period. The 
right-of-use assets are recognised at cost, comprising the amount of initial measurement of the lease liability plus initial direct 
costs. The right-of use asset is subsequently depreciated over the lease term on a straight-line basis.  

(q) Provisions 
A provision is recognised if, as a result of a past event, the Group has a present legal or constructive obligation that can be estimated 
reliably and it is probable that an outflow of economic benefits will be required to settle the obligation.  

See note 29 for provisions in respect of customer redress and other provisions in accordance with IAS 37.  
(r) Foreign currencies 

Transactions in foreign currencies are recorded using the rate of exchange ruling at the date of the transaction. Monetary assets 
and liabilities held at the statement of financial position date are translated into sterling using the exchange rates ruling at the 
statement of financial position date. Exchange differences are charged or credited to the income statement. 

(s) Taxation 
The Group follows IAS 12 Income Taxes in accounting for taxes on income. Taxation comprises current and deferred tax.  

Current tax is the expected tax payable or receivable on taxable profits or tax allowable losses for the period, together with any 
adjustment  in  respect  of  previous  years.  Current  income  tax  arising  from  distributions  made  on  other  equity  instruments  is 
recognised in the income statement as the distributions are made from retained earnings arising from profits previously recognised 
in the income statement. 

Deferred tax assets  arise on tax deductible temporary differences and  are recognised to the extent  that  these may be  utilised 
against available taxable profits based on management’s review of the budget and forecast information.  Deferred tax is measured 
using tax rates and tax laws that have been enacted or substantively enacted which are expected to apply when the deferred tax 
asset  is  realised.  Deferred  tax  is  not  discounted.  Deferred  tax  assets  and  liabilities  are  only  offset  where  there  is  both  a  legal 
obligation to set-off and a commitment to settle on a net basis.   

118 

 
 
 
 
 
The Group reviews the carrying amount of deferred income tax assets at each reporting date and reduces the carrying amount to 
the  extent  that  it  is  no  longer  probable  that  sufficient  taxable  profits  will  be  available  to  allow  all  or  part  of  the  assets  to  be 
recovered. 

The  Group  considers  an  uncertain  tax  position  to  exist  where,  upon  a  review  of  that  uncertainty  by  a  tax  authority,  the  tax 
recognised in the financial statements differs from the cash tax expected to be payable or receivable based on the tax returns of 
the Group. In accordance with IFRIC 23, a current tax provision for an uncertain tax position will be based upon interpretation of 
current tax legislation and guidance and the tax provision re-measured at each balance sheet date to reflect the up to date position.  

Deferred tax provision adjustments will be recognised where, in management’s view, the outcome of a review by a tax authority 
of  an  uncertain  tax  position  will  result  in  a  reduction  in  the  carrying  value  of  the  deferred  tax  asset.  The  measurement  of  an 
underlying deferred tax asset will be adjusted according to the expected impact on the loss or temporary difference giving rise to 
the deferred tax asset of resolving the uncertain tax position.  

In assessing provision levels, it will be assumed that a tax authority will review all uncertain tax positions and all facts will be fully 
and transparently disclosed.  

The Group does not consider there to be a significant risk of material adjustment to the current and deferred tax balances, including 
provisions for uncertain tax positions for the next financial year. Tax provisions cover all known issues and reflect external advice 
where applicable.  

(t) Pension costs 
The cost of providing retirement benefits is charged to the income statement at the amount of the defined contributions payable 
for each year. Differences between contributions payable and those actually paid are shown as accruals or prepayments. The Group 
has no defined benefit pension scheme. 

(u) Shareholders’ funds 

i. Capital instruments 
The  Group  classifies  capital  instruments  as  financial  liabilities  or  equity  instruments  in  accordance  with  the  substance  of  the 
contractual  terms  of  the  instruments.  Where  an  instrument  contains  no  obligation  on  the  Company  to  deliver  cash  or  other 
financial  assets,  or  to  exchange  financial  assets  or  financial  liabilities  with  another  party  under  conditions  that  are  potentially 
unfavourable to the Group, or where the instrument will or may be settled in the Company’s own equity instruments but includes 
no obligation to deliver a variable number of the Company’s own equity instruments, then it is treated as an equity instrument. 
Accordingly,  the  Company’s  share  capital  and  Additional  Tier  1  capital  securities  are  presented  as  components  of  equity.  Any 
dividends, interest or other distributions on capital instruments are also recognised in equity. 

ii. Share premium 
Share premium is the amount by which the fair value of the consideration received exceeds the nominal value of the shares issued. 

(v) Capital raising costs 
Costs directly incremental to the raising of share capital are netted against the share premium account. Costs directly incremental 
to the raising of convertible securities included in equity are offset against the proceeds from the issue within equity. 

(w) Cash and cash equivalents 
Cash and cash equivalents comprise of cash balances and balances with a maturity of three months or less from the acquisition 
date which are readily convertible to known amounts of cash and which are subject to an insignificant risk of change in value. 

(x) Investment in group undertakings 
Investments in group undertakings are initially recognised at cost. At each reporting date, an assessment is made as to whether 
there is any indication that the investment may be impaired such that the recoverable amount is lower than the carrying value.  

(y) Share-based payment transactions 
In order to incentivise and reward future strong long-term business performance and growth, senior executives and employees of 
the Group have been granted - as part of their remuneration - awards, which are linked to the quoted share price of FirstRand 
Limited. The awards are recognised in the financial statements as cash-settled share-based payments. Awards granted under cash-
settled plans result in a liability being recognised and measured at fair value until settlement.  An expense is recognised in profit or 
loss for employee services received over the vesting period of the plans.  

119 

 
 
 
 
 
The cost of such awards are settled by payments made by the Company to an associate of the FirstRand Group which assumes the 
liability for the settlement of the awards, and the cost will be recharged to the Aldermore Group companies to which the awardees 
provide their services. This results in the derecognition of the share-based payment obligation and the recognition of a prepaid 
debtor, which the Group releases to the income statement over the vesting period of the original award granted to the employees.  

In respect of the equity-settled schemes entered into before the takeover in March 2018, the grant date fair value is recognised as 
an employee expense with a corresponding increase in equity over the period that the employees become unconditionally entitled 
to the awards. The grant date fair value is determined using valuation models which take into account the terms and conditions 
attached  to  the  awards.  Inputs  into  valuation  models  may  include  the  risk-free  interest  rate  and  other  factors  related  to 
performance conditions attached to the awards. 

The amount recognised as an expense is adjusted to reflect differences between expected and actual outcomes, such that the 
amount ultimately recognised as an expense is based on the number of awards that meet the related service and non-market 
performance conditions at the vesting date. For share-based payment awards with market performance conditions or non-vesting 
conditions, the grant date fair value of the share-based payment is measured to reflect such conditions and there is no true-up for 
differences between expected and actual outcomes. 

Within the parent company standalone financial statements, the equity-settled share-based payment transactions are recognised 
as an investment in Group undertakings with an associated credit to the share-based payment reserve. For cash-settled share-
based payments no cost has been recognised as the costs incurred by the Company are fully rechargeable to the Aldermore Group 
companies for which the awardees provide their services. 

(z) Investment in associates 
An associate is a company over which the Group has significant influence and that is neither a subsidiary undertaking nor an interest 
in a joint venture. Significant influence is the power to participate in the financial and operating policy decisions of the investee, 
but  is  neither  control  nor  joint  control  over  the  investee.  The  results  and  assets  of  associates  are  accounted  for  in  these 
consolidated  financial  statements  using  the  equity  method  of  accounting.  Investments  are  measured  at  cost,  which  includes 
transaction costs. Subsequent to initial recognition, the Group includes its share of profit or loss and other comprehensive income 
of equity-accounted investees, until the date on which significant influence ceases. 

120 

 
 
 
 
 
 
3. Use of estimates and judgements 

The preparation of financial information requires management to make judgements, estimates and assumptions that affect the 
application of accounting policies and the reported amounts of assets, liabilities, income and expenses. Actual results may differ 
from these estimates. 

Estimates and assumptions are reviewed on an ongoing basis. Revisions to accounting estimates are recognised in the period in 
which the estimate is revised and in any future periods affected. This year the continued impact of Covid-19 has been considered 
in relation to all of the Group’s estimates and assumptions. The judgements and assumptions that are considered to be the most 
important  to  the  portrayal  of  the Group’s  financial  condition  and  impact  the results  for  the  current  year  and  future  reporting 
periods are those relating to loan impairment provisions and EIR.  

(a) Loan impairment provisions 
The key judgements made in applying the accounting policies were as follows: 

Definition of default 
IFRS 9 does not define default for the purpose of defining the PD as used when calculating ECLs and impairment provisions for 
stage 1 and stage 2 assets. As detailed in note 2(g), the Group has defined default on a basis that is consistent with the definition 
it uses for determining whether an asset is credit impaired, and is therefore classified as stage 3, and with the definition of default 
that is used for regulatory reporting purposes. 

Significant increase in Credit Risk for classification in stage 2  
As explained in note 2(g), loan impairment provisions are measured as an allowance equal to 12-month ECL for stage 1 assets, or 
lifetime ECL for stage 2 or stage 3 assets. An asset moves to stage 2 when its credit risk has increased significantly since initial 
recognition. IFRS 9 does not define what constitutes a significant increase in credit risk. In assessing whether the credit risk of an 
asset has significantly increased, the Group takes into account qualitative and quantitative reasonable and supportable forward 
looking information. Refer to note 2(g) for more details. 

The probation period for reclassification from stage 3 into stage 2 and 1 
As explained in note 2(g), loans are only considered for reclassification from stage 3 into stage 2 when they no longer meet the 
criteria for inclusion and have completed agreed probation periods. The probation periods are set according to the type of lending 
and are based  upon professional judgement as  to when the risk  of a return to  stage 3 is considered minimal. Stage 3 ECL  has 
increased due to a change in the definition of default to include cases in distress that had taken a Covid-19 related payment break 
during the year. It should be noted that £21.7 million (30 June 2020: £2.3 million) of the stage 3 ECL at 30 June 2021 no longer 
meet the criteria for inclusion but remain in stage 3 pending completion of the agreed probation periods. Reclassifications from 
stage 2 to stage 1 are only possible when the SICR criteria are no longer met. 

The key estimates made in applying the accounting policies were as follows: 

PD models 
The Group has employed a number of PD models, tailored to different types of lending with shared characteristics, to assess the 
likelihood of default within the next 12 months and over the lifetime of each loan. The models calculate estimates of PDs based 
upon current  characteristics of the borrower and observed  historical  default  rates. A  10.0% deterioration  in  the modelled PDs 
would result in an increase in impairment provisions by £7.3 million as at 30 June 2021 (30 June 2020: £10.2 million). 

LGD models 
The Group has developed LGD models for the different types of lending. The models use a number of estimated inputs including 
cure rates (i.e. the proportion of loans that do not go into possession) and the valuation of collateral to be collected reflecting the 
impact of changes in House Price Indices (“HPI”), used car prices and other valuation measures, forced sale discounts (“FSD”) and 
the time to sale.  

121 

 
 
 
 
 
 
The models are most sensitive to changes in cure rates and collateral valuations: 

 

 

 

A 10.0% absolute improvement in the cure rate would reduce total impairment provisions by £16.0 million as at 30 June 
2021 (30 June 2020: £19.7 million). 
A 10.0% relative reduction in the HPI would increase the total impairment provisions for mortgage lending by £8.4 million 
as at 30 June 2021 (30 June 2020: £4.4 million). 
A 5.0% absolute increase in the FSD would increase the total impairment provisions for mortgage lending by £6.3 million 
as at 30 June 2021 (30 June 2020: £2.1 million). 
A 10.0% relative reduction in the overall value of collateral realised in the Asset Finance and Invoice Finance businesses 
would increase the total impairment provisions for such lending by £2.6 million as at 30 June 2021 (30 June 2020: £2.9 
million). 
A 10.0% relative reduction in the overall value of collateral realised in the MotoNovo Finance business would increase 
the total impairment provisions of such lending by £5.9 million as at 30 June 2021 (30 June 2020: £4.5 million). 
  A 20.0% relative reduction in the TTS would reduce the total impairment provisions for mortgage lending and Asset 

 

 

Finance business by £2.2 million as at 30 June 2021 (30 June 2020: £1.7 million)  

Forward looking macroeconomic scenarios  

From 1 July 2019 to 28 February 2021 the probability weighted forward-looking macroeconomic scenarios were obtained through 
the IFRS9 Scenario Service from Oxford Economics. After this period the scenarios have been obtained through an internal function 
of the Group. The move to the internal scenarios reduced the number of scenarios from six to four, assisting the Group in having 
greater control over the shape and severity of the forecasts and also creating an alignment between provisioning and scenario 
information used for budgeting. It is recognised that due to Covid-19, macroeconomic projections for the UK economy are changing 
rapidly. For this reason, the economic scenarios were obtained on a monthly basis throughout the period. 

The probability  weighted scenarios  are used  to  model  impacts  on  ECL  through  an  expert  judgement-based  model.  The  model 
combines a cohort of carefully selected macroeconomic variables with expert judgement assigned weightings to produce an index 
ranging between 0 and 100. An index level of 50 corresponds to a through the cycle level. An index level below 50 indicates worse 
than average economic conditions and an index level above 50 describes better than average economic conditions. 

As the forecast moves further  into the  horizon, mean reversion is introduced to bring  the index level toward  the mean as  the 
forecast date moves over the 5 year forecast period. 

The IFRS9 scenarios used at 30 June 2021 use forecast-error distributions as outlined below: 

- 
- 
- 
- 

Upside scenario; 
Base scenario; 
Downside scenario; and 
Severe Downside scenario.  

The Group, by exception and with sufficient rationale, has the ability to reject scenarios or adjust scenario weightings. Scenarios 
and weightings are approved at the Credit Management Forum prior to deployment for use in the ECL.  

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As at 30 June 2021, the following forward-looking macroeconomic scenarios, together with their probability weighting and key 
economic variables, were used in calculating the ECLs used for determining impairment provisions: 

Scenario 

Severe Downside 
Downside 
Base 
Upside 

Probability 
weighting 
15% 
25% 
50% 
10% 

Economic variables per scenario – average next 5 years 

GDP Growth 

(1.50%) 
1.42% 
2.17% 
4.09% 

Bank of England 
Base Rate 
 (0.43%) 
 (0.14%) 
 0.12% 
 1.04% 

Unemployment 
rate 
8.44% 
 6.46% 
 4.76% 
 3.78% 

Consumer Price 
Index 
0.66% 
1.13% 
1.64% 

2.48% 

As at 30 June 2021, applying a 100% weighting to the severe downside scenario would result in an incremental £25.5 million of 
provisions being required. Applying a 100% weighting to the upside scenario would result in a £27.1 million reduction of provisions 
being required. The macroeconomic impact and post model adjustments are excluded from this weighting. 

As at 30 June 2020, the following forward-looking macroeconomic scenarios, together with their probability weighting and key 
economic variables, were used in calculating the ECLs used for determining impairment provisions: 

Scenario 

Severe Downside 
Downside 
Stagnation 
Base 
Mild Upside 
Upside 

Probability 
weighting 
15% 
10% 
10% 
45% 
10% 
10% 

Economic variables per scenario – average next 5 years 

GDP Growth 

4.75% 
5.47% 
5.91% 
7.02% 
7.69% 
8.25% 

Bank of England 
Base Rate 
 (0.34%) 
 (0.02%) 
0.24% 
 0.23% 
 1.13% 
 1.61% 

Unemployment 
rate 
7.61% 
 6.97% 
 6.60% 
 4.28% 
 4.11% 
 3.07% 

Consumer Price 
Index 
0.684% 
0.960% 
1.126% 
1.639% 
1.898% 

2.170% 

The  external  provider’s  forecasts  only  covered  a  5-year  period,  so  the  Group  made  estimates  in  order  to  extend  the  forecast 
horizon:  

 

 

The House Price Index (“HPI”) has been kept flat at 2.5% per annum; and 

The  other  macroeconomic  indicators  revert  to  the  mean  calculated  over  a  10-year  period  (5  year  actual  and  5  year 

forecast).  

As at 30 June 2020, applying a 100% weighting to the severe downside scenario would result in an incremental £14.4 million of 
provisions being required.  Applying a 100% weighting to the upside scenario would result in a £14.6 million reduction of provisions 
being required. The macroeconomic impact and post model adjustments are excluded from this weighting.  

123 

 
 
 
 
 
 
 
 
 
 
 
 
Post Model Adjustments 
The Group applies Post Model Adjustments (“PMA”) to the modelled IFRS 9 ECL provisions. PMAs are reviewed and approved on a 
periodic basis at the Credit Management Forum and Audit Committee. The PMAs applied at 30 June 2021 are listed below: 

 

Asset Price and Property Price PMA applied to the MotoNovo Finance, Asset Finance, Commercial Mortgages, Buy to Let, 

Property Development and Residential Mortgages portfolios to reflect potential increased volatility in asset and property 

values driven by economic uncertainty due to Covid-19; 

  Non-Performing Loan PMA applied to MotoNovo Finance customers to account for the FCA prohibition on Write-Offs 

and  Recoveries.  During  the  initial  stages  of  the  Covid-19  pandemic,  the  FCA  launched  a  prohibition  on  vehicle 

repossession; this lasted until 31 January 2021. The inability to repossess meant that the business could not write-off 

loans that were beyond the point of repaying as the vehicle could not be recovered. A PMA was introduced to account 

for the higher losses that are likely to accrue due to the vehicle ageing and the balance not being repaid; 

 

Covid-19 Scalar PMA applied to customers that have taken a payment break in relation to Covid-19 to account for the 

additional risk of default once the payment break has expired. The PMA utilises “scalars” that are determined via the use 

of a Covid-19 PD Uplift Model that was approved at the Group’s Model Management Committee in June 2020. The model 

is  a  non-statistical  scorecard  model  which  was  built  solely  using  expert  judgement.  A  series  of  expert  panels  were 

convened to agree which characteristics might be predictive of an increase in the likelihood to default for accounts where 

a payment break was in place. The model assigned a Covid-19 adjusted PD at a contract level for the customers who 

requested a payment break, the Covid-19 adjusted PDs are compared to the macroeconomic adjusted PDs to determine 

a factor between the two PDs used to assign ECL scalars; 

 

High Risk Sector PMA to account for customers in sectors assessed by the Group as being most impacted by Covid-19 to 

account for the additional risk of default. Where customers in these sectors have requested payment breaks, they are 

covered by the Covid-19 Scalar PMA (as above). Where customers in these sectors have not requested payment breaks, 

management believe that these sectors may be subject to additional risks due to Covid-19 which are not reflected in the 

ECL PD models and hence an additional PMA has been put in place to reflect the perceived increased risk;  

End of Term (“EoT”) Risk PMA applied to the Commercial and Residential Mortgages portfolios to account for additional 

risk at EoT on Interest-only products; 

PMA to compensate for a lack of historic impairments causing volatility in the observed defaults and loss given defaults; 

 

 

  Operational controls on payment breaks impacting ECL staging PMA; 

 

Cladding PMA to cover additional risk in relation to properties with cladding that may require removal/refitting; and 

  Management  overlay  PMA  to  reflect  its  view  that  the  forward-looking  scenarios  used  to  build  the  forward-looking 

information (FLI) component of the ECL cannot appropriately incorporate all of the potential short to medium-term risk 

given the uncertainty created by Covid-19. The PMA has been isolated to the SME sector of the Group’s portfolio, as this 

sector is deemed the most sensitive to any likely adverse impacts. 

The total value of ECL PMAs as at 30 June 2021 is £42.8 million (30 June 2020: £38.8 million). 

124 

 
 
 
 
Individually assessed impairment provisions on stage 3 loans 
In order to determine the lifetime ECL to be reflected as an impairment provision, estimates were made based upon individual 
assessments of the borrower and the valuation of collateral provided, net of any costs to sell.  The most significant estimate is in 
respect of the valuation of collateral provided and it is estimated that a 10.0% relative reduction in its valuation would increase the 
total impairment provisions for such lending by £6.9 million as at 30 June 2021 (30 June 2020: £3.2 million). 

(b) Effective interest rate (“EIR”) 

IFRSs require interest earned from loans to be measured under the EIR method. Management must therefore use judgement to 
estimate  the  expected  life  of  each  type  of  instrument  and  hence  the  expected  related  cash  flows.  The  accuracy  of  EIR  would 
therefore be affected by unexpected market movements resulting in altered customer behaviour and inaccuracies in the models 
used compared to actual outcomes. 

A critical estimate in determining EIR is the expected life to maturity of the Group’s SME Commercial, Asset Finance, Buy to Let and 
Residential Mortgage portfolios, as a change in these estimates will impact the period over which the directly attributable costs 
and fees and any discount received on the acquisition of mortgage portfolios are recognised as part of the EIR. 

As at 30 June 2021, included within the overall Residential Mortgages book, are a small number of portfolios which were acquired 
by the Group and represent approximately 1.1% and 0.7% of Buy to Let and Residential Mortgages net loans respectively (30 June 
2020: 1.0% and 1.3% respectively). These portfolios were acquired at a discount which is being recognised under the EIR method. 
As disclosed below, these portfolios, although representing a small proportion of overall lending, are sensitive to a change in the 
expected repayment profiles which would impact the periods over which the discount is to be unwound. 

A reassessment was made of the estimates used in respect of the expected lives of the SME Commercial, Asset Finance, Buy to Let 
and Residential Mortgage portfolios during the year. As a consequence, an overall adjustment of £14.8 million (30 June 2020: £3.1 
million) was recorded to reduce the value of the loan portfolios and the interest income recognised in the current period, so that 
interest  can  continue  to  be  recognised  at  the  original  effective  interest  rate  over  the  remaining  life  of  the  relevant  lending 
portfolios. Buy to Let was impacted most materially from this reassessment during the year, reflecting changed customer behaviour 
in more recent years (principally lower repayment levels). 

The adjustment made at the year end is analysed as follows: 

Asset Finance - organic lending 

SME Commercial - organic lending 

Buy to Let - organic lending 

Residential - acquired portfolios  

Residential - organic lending 

Year ended 
 30 June 2021  
interest income 
£m 

Year ended 
 30 June 2020 
interest income 
£m 

(1.1) 

(1.6) 

(13.3) 

(1.0) 

2.2 

(14.8) 

(0.3) 

(2.3) 

(1.1) 

0.8 

(0.2) 

(3.1) 

125 

 
 
 
 
 
 
 
 
 
 
 
 
 
A change in the estimated expected lives to extend the expected lives of the SME Commercial, Buy to Let and Residential Mortgage 
portfolios by six months would have the effect of reducing the cumulative profit before tax recognised as at 30 June 2021 by £0.7 
million (30 June 2020: cumulative increase in profit of £0.5 million). Included within this sensitivity of £0.7 million, is a £1.2 million 
cumulative reduction in profit relating to acquired portfolios (30 June 2020: £1.4 million) due to a change in the unwind of the 
discount together with a £0.5 million cumulative increase in profit relating to the organic portfolios (30 June 2020: cumulative 
increase in profit of £1.9 million). 

There were not any critical accounting estimates in Asset Finance or MotoNovo Finance. 

4. Segmental information 
The Group has seven reportable operating segments as described below which are based on the Group’s six lending segments plus 
Central Functions.  

The organisation’s operating segments are allocated to three distinct customer facing businesses: Business Finance (made up of 
Asset  Finance,  Invoice  Finance  and  SME  Commercial  Mortgages);  Retail  Finance  (made  up  of  Residential  Owner  Occupied 
Mortgages  and  Buy  to  Let  Mortgages)  and  MotoNovo  Finance.  All  2021  financial  reports  detail  performance  on  an  operating 
segment basis. It is also possible to review performance aggregated by Business Finance and Retail Finance using data from the 
individual  operating  segments.  As  such,  it  is  still  deemed  appropriate  to  split  the  segmental  reporting  by  individual  operating 
segments for the 2021 IFRS 8 disclosure. 

For  each  of  the  reportable  segments,  the  Board,  which  is  the  Group’s  Chief  Operating  Decision  Maker,  reviews  internal 
management  reports  every  two  months.  The  following  summary  describes  the  operations  in  each  of  the  Group’s  reportable 
segments: 
 

Asset Finance - lease and hire purchase financing for SMEs, focusing on sectors with complex and structured deals, which 
play to our specialist underwriting advantage; 
Invoice Finance - provides UK SMEs with working capital solutions through invoice discounting, factoring and asset based 
lending; 
SME  Commercial  Mortgages  -  property  finance  needs  of  professional,  commercial  property  investors,  and  owner-
occupier  SMEs.  Targets  multi-let  commercial  investment  property  loans  and  property  development  to  experienced 
regional developers; 
Buy to Let Mortgages - offers a wide range of standard and specialist Buy to Let mortgages for residential units, multi-
unit freehold or houses with multiple-occupation (“HMO”) to both individuals and companies;  
Residential Owner Occupied Mortgages - prime residential mortgages targeting under-served segments of creditworthy 
borrowers that provide attractive and sustainable margins; and 

 

 

 

 

  MotoNovo Finance - provides individuals and dealers with funding to purchase cars, vans and motorcycles. 

Central Functions include the reconciling items between the total of the Bank’s five reportable operating segments (MotoNovo 
Finance is excluded as it has its own central function costs) and the consolidated income statement. As well as common costs, 
Central Functions include the Group’s Treasury and Savings functions which are responsible for raising finance on behalf of the 
operating  segments. The costs of raising finance  are all recharged by  Central Functions  to the operating  segments, apart from 
those costs relating to the subordinated notes and the net gains / losses from derivatives held at fair value shown in note 19. 

Common  costs  are  incurred  on  behalf  of  the  Business  and  Retail  Finance  operating  segments  and  typically  represent  savings 
administration, back office and support function costs such as Finance, IT, Risk and Human Resources. The costs are not directly 
attributable to the operating segments. This does not include MotoNovo Finance central functions.  

Information regarding the results of each reportable segment and their reconciliation to the total results of the Group is shown 
below. Performance is measured based on the segmental result as included in the internal management reports. 

The Group does not have reliance on any major customers, and all lending is in the UK. 

126 

 
 
 
 
 
 
 
 
 
Segmental information for the year ended 30 June 2021 

Interest income – external customers 

Interest expense – external customers 

Interest (expense)/income – internal  

Net fees and other income – external 
customers 

Total operating income 

Administrative expenses including 
depreciation and amortisation 

Impairment losses  

Share of profit of associate 

Segmental result 

Tax  

Profit after tax 

Assets 

Liabilities 

Net assets/(liabilities) 

Asset 
Finance 
£m 

93.4 

Invoice 
Finance 
£m 

23.2 

SME 
Commercial 
Mortgages 
£m 

Buy to Let 
£m 

62.2 

192.3 

- 

- 

- 

- 

Residential 
Mortgages 
£m 

85.7 

- 

MotoNovo 
Finance 
£m 

148.0 

Central 
Functions 
£m 

Total 
£m 

(12.3) 

592.5 

- 

(156.1) 

(156.1) 

(20.8) 

(2.0) 

(11.0) 

(77.2) 

(27.6) 

(34.7) 

173.3 

- 

2.5 

3.7 

0.6 

0.2 

0.2 

32.5 

(5.2) 

34.5 

75.1 

24.9 

51.8 

115.3 

58.3 

145.8 

(0.3) 

470.9 

(15.5) 

(9.3) 

(7.2) 

(12.5) 

(6.6) 

(82.0) 

(128.6) 

(261.7) 

(4.3) 

(1.0) 

(5.3) 

(13.4) 

(2.8) 

(25.3) 

- 

- 

- 

- 

55.3 

14.6 

39.3 

89.4 

- 

48.9 

- 

0.7 

(52.1) 

0.7 

- 

38.5 

(128.2) 

157.8 

(33.4) 

124.4 

1,570.3 

401.6 

1,126.0 

5,159.5 

2,136.2 

3,026.8 

3,068.2 

16,488.6 

(15,257.4) 

(15,257.4) 

1,570.3 

401.6 

1,126.0 

5,159.5 

2,136.2 

3,026.8 

(12,189.2) 

1,231.2 

Segmental information for the year ended 30 June 2020 

Interest income – external customers 

Interest expense – external customers 

Interest (expense)/income – internal  

Net fees and other income – external 
customers 

Total operating income 

Administrative expenses including 
depreciation and amortisation 

Impairment losses  

Share of profit of associate 

Segmental result 

Tax  

Profit after tax 

Assets 

Liabilities 

Net assets/(liabilities) 

Asset 
Finance 
£m 

107.0 

Invoice 
Finance 
£m 

25.7 

SME 
Commercial 
Mortgages 
£m 

Buy to Let 
£m 

64.5 

208.2 

- 

- 

- 

- 

Residential 
Mortgages 
£m 

78.7 

- 

MotoNovo 
Finance 
£m 

73.9 

Central 
Functions(1) 
£m 

Total  
£m 

5.8 

563.8 

- 

(193.3) 

(193.3) 

(28.8) 

(3.1) 

(15.3) 

(81.0) 

(29.8) 

(19.9) 

177.9 

- 

1.8 

3.4 

0.5 

(0.4) 

(0.4) 

46.2 

(9.5) 

41.6 

80.0 

26.0 

49.7 

126.8 

48.5 

100.2 

(19.1) 

412.1 

(13.8) 

(9.0) 

(6.6) 

(8.9) 

(48.9) 

(1.4) 

(12.5) 

(7.8) 

- 

- 

- 

- 

(6.2) 

(5.3) 

- 

(77.5) 

(110.1) 

(232.1) 

(55.8) 

- 

- 

0.5 

17.3 

15.6 

30.6 

110.1 

37.0 

(33.1) 

(128.7) 

(131.7) 

0.5 

48.8 

(10.2) 

38.6 

1,857.9 

278.7 

1,139.1 

5,246.9 

2,079.6 

1,823.5 

2,897.9 

15,323.6 

(14,215.1) 

(14,215.1) 

1,857.9 

278.7 

1,139.1 

5,246.9 

2,079.6 

1,823.5 

(11,317.2) 

1,108.5 

127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5. Interest income 

On financial assets not at fair value through profit or loss: 

On loans and advances to customers* 

On loans and advances to banks  

On debt securities - measured at FVOCI 

On financial assets at fair value through profit or loss: 

Net interest expense on financial instruments hedging assets 

Year ended  
30 June 2021 
£m 
604.7 

Year ended  
30 June 2020  
£m 
557.7 

0.7 

8.1 

613.5 

(21.0) 

592.5 

3.1 

8.7 

569.5 

(5.7) 

563.8 

* Interest Income on loans and advances to customers includes a £(2.2) million adjustment to reflect the non-compliant nature of interest charged 
to customers during a period of non-compliance. See note 29 for more information.  

6. Interest expense 

On financial liabilities not at fair value through profit or loss: 

On customers’ accounts  

On amounts due to banks 

On debt securities in issue 

On subordinated notes 

On lease liabilities 

Other 

On financial liabilities at fair value through profit or loss: 

Net interest expense on financial instruments hedging liabilities 

7. Fee and commission income 

Invoice Finance fees 

Valuation fees 

HP income, option fees and secondary rental fees 

Annual administration and arrears fees 

Other fees 

Year ended 
30 June 2021 
£m 

Year ended 
30 June 2020 
£m 

118.3 

2.8 

10.0 

12.7 

0.4 

0.5 

144.7 

11.4 

156.1 

146.4 

9.9 

9.4 

12.7 

0.4 

0.3 

179.1 

14.2 

193.3 

Year ended  
30 June 2021 
£m 
0.9 

Year ended  
30 June 2020 
£m 
0.8 

0.9 

2.1 

0.6 

2.3 

6.8 

0.5 

1.7 

0.7 

1.9 

5.6 

128 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8. Fee and commission expense 

Introducer commissions 

Legal and valuation fees 

Company searches and other fees 

Credit protection and insurance charges 

Year ended  
30 June 2021 
£m 
1.0 

Year ended 
30 June 2020 
£m 
0.8 

1.1 

6.4 

1.6 

10.1 

1.9 

5.9 

1.5 

10.1 

9. Net losses from derivatives and other financial instruments at fair value through profit 
or loss 

Net gains/(losses) on derivatives 

Net (losses)/gains on available for sale assets held in fair value hedges 

Year ended 
30 June 2021 
£m 
(0.3) 

(0.2) 

(0.5) 

Year ended 
30 June 2020 
£m 
(8.2) 

0.1 

(8.1) 

Included within net gains / (losses) on derivatives on financial instruments at fair value through profit or loss are gains of 
£44.2million (2020: £47.5 million loss) on derivatives held in qualifying fair value hedging arrangements to hedge interest rate 
risk associated with loans and advances to customers, together with losses of £44.4 million (2020: £40.0 million gain) 
representing changes in the fair value of the hedged interest rate risk. Also included are losses of £3.5 million (2020: £2.3 million 
gain) on derivatives held in qualifying fair value hedging arrangements to hedge interest rate risk associated with customer 
deposits, together with gains of £2.6 million (2020: £1.1 million loss) representing changes in the fair value of the hedged interest 
rate risk. 

10. Administrative expenses 

Staff costs 

Legal and professional and other services 

Information technology costs 

Office costs 

Provisions  

Impairment of leases 

Other 

Note 
11 

29 

Year ended  
30 June 2021 
£m 
138.8 

Year ended  
30 June 2020 
£m 
108.5 

38.4 

44.5 

6.2 

3.8 

0.6 

16.8 

249.1 

42.6 

37.3 

7.1 

3.2 

- 

21.3 

220.0 

Included in legal and professional and other services is remuneration to the Group’s external auditors (Deloitte LLP) for the annual 
audit of £1.3 million, of which £0.1m relates to prior year overruns (2020: £1.0 million) and £0.1 million for other assurance services 
(2020 £0.1 million).   

Included in office costs are operating lease rentals (including service charges) of £0.8 million (2020: £1.5 million).  

Included in other administrative expenses are costs relating to temporary staff of £5.6 million (2020: £11.4 million), travel and 
subsistence of £0.3 million (2020: £2.7 million) and staff recruitment of £2.2 million (2020: £2.2 million). 

129 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
11. Staff costs 

Wages and salaries 

Social security costs 

Other pension costs 

Share based payments 

Year ended 
30 June 2021 
£m 
115.1 

13.8 

5.9 

4.0 

138.8 

Year ended 
30 June 2020 
£m 
89.1 

11.2 

5.5 

2.7 

108.5 

Wages and salaries in 2021 includes the reintroduction of staff bonuses of £21.3m that were not awarded in 2020 due to the 
pandemic. 

The average number of persons employed by the Group during the period, including Non-Executive Directors, is disclosed as 
below. 

Central functions 

Business Finance and Retail Finance 

MotoNovo Finance 

12. Remuneration of directors  

Directors’ emoluments 

Payments in respect of personal pension plans 

Contributions to money purchase pension scheme 

Long term incentive schemes 

Year ended 
30 June 2021 
695 

576 

758 

2,029 

Year ended 
30 June 2021 
£'000 
4,113.8 

60.2 

17.0 

177.3 

Year ended 
30 June 2020 
677 

540 

749 

1,966 

Year ended 
30 June 2020 
£'000 
2,750.8 

98.3 

10.3 

678.6 

4,368.3 

3,538.0 

The above disclosure is prepared in accordance with Schedule 5 of the Large and Medium-sized Companies and Groups (Accounts 
and Reports) Regulations 2008.  

In the year ending 30 June 2021, the Group's securitisation vehicles paid third party fees of £44,500 for corporate director services 
(2020: £29,000). While the share capital of these vehicles is not owned by the Group, the vehicles are included in the consolidated 
financial statements as they are controlled by the Group. 

Long-term incentive schemes  
A  number  of  long-term  incentive  schemes  were  introduced  following  the  acquisition  by  FirstRand  in  March  2018.  These  new 
schemes  are  a  mixture  of  equity-settled,  a  requirement  to  purchase  FirstRand  shares  at  vesting,  and  cash-settled  schemes. 
Amounts are reflected in the above remuneration disclosures when the awards are payable as a result of the Director satisfying 
the scheme conditions. 

Included in the values disclosed in the table above is the deferred portion of the Annual Incentive Plan, paid in cash to align the 
interests of the Executive team with Shareholders. 

130 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Highest Paid Director 

The amounts below include the following in respect of the highest paid director: 

Emoluments 

Payments in respect of personal pension plans 

Long term incentive schemes 

Year ended 
30 June 2021 
£'000 
1,392.7 

49.5 

177.3 

Year ended 
30 June 2020 
£'000 
855.0 

47.8 

678.6 

1,619.5 

1,581.4 

13. Pension and other post-retirement benefit commitments 

The Group operates two defined contribution pension schemes. The assets of the schemes are held separately from those of the 
Group in independently administered funds. Pension contributions of £5.9 million (2020: £5.5 million) were charged to the income 
statement  during  the  year  in  respect  of  these  schemes. The  Group  made  payments  amounting  to  £60,220  (2020:  £86,040)  in 
aggregate in respect of Directors' individual personal pension plans during the year. There were outstanding contributions of £0.7 
million at the year end (2020: £0.5 million). 

14. Depreciation and amortisation 

Depreciation 

Amortisation of intangible assets  

15. Taxation 
a) Tax charge 

Current tax on profits for the year 

Over provision in previous periods 
Total current tax 

Deferred tax 

Over provision in previous periods 
Total deferred tax charge/(credit) 

Total tax charge 

Note 

23 

24 

Year ended  
30 June 2021 
£m 
10.6 

2.0 

12.6 

Year ended  
30 June 2020 
£m 
8.7 

3.4 

12.1 

Year ended  
30 June 2021 
£m 
39.5 

(0.2) 

39.3 

(5.5) 

(0.4) 

(5.9) 

33.4 

Year ended  
30 June 2020 
£m 
11.4 

(1.2) 

10.2 

- 

- 

- 

10.2 

Current tax on profits reflects UK corporation tax levied at a rate of 19% for the year ended 30 June 2021 (30 June 2020: 19%) and 
the banking surcharge levied at a rate of 8% on the profits of banking companies chargeable to corporation tax after an allowance of 
£25.0 million per annum. 

A tax credit of £2.8 million in respect of the fair value movements in FVOCI sale debt securities has been shown in other 
comprehensive income during the year ended 30 June 2021 (30 June 2020: £0.3 million credit).  

The tax relief on the contingent convertible security coupon costs for the consolidated Group for the year is £2.0 million (30 June 
2020: £2.6 million). This comprises £1.6 million at mainstream rate (30 June 2020: £2.3 million) and £0.4 million at surcharge rate 
(30 June 2020: £0.3 million).  

131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The UK corporation tax rate will increase from 19% to 25% from 1 April 2023 as substantively enacted on 24 May 2021. Deferred 
tax amounts are measured taking into account this change. 

b) Factors affecting tax charge / (credit) for the year 

The tax assessed for the year is different to that resulting from applying the standard rate of corporation tax in the UK of 19% (30 
June 2020: 19%). The differences are explained below: 

Profit before tax 

Tax at 19% (2020: 19%) thereon 

Effects of: 

Expenses not deductible for tax purposes 

Over provision in previous periods 

Deferred tax rate adjustment 

Effect of banking tax surcharge 

Other differences 

Tax credit relief for contingent convertible securities coupon 

Year ended 
30 June 2021 
£m 
157.8 

30.0 

Year ended 
30 June 2020  
£m 
48.8 

9.3 

0.3 

(0.6) 

(2.1) 

8.0 

(0.6) 

(1.6) 

33.4 

0.2 

(1.2) 

- 

3.9 

0.3 

(2.3) 

10.2 

The effective tax rate of 21.1% (30 June 2020: 21.0%) is higher than the UK corporation tax rate due to the impact of the banking surcharge. 

16. Loans and advances to banks 

Included in cash and cash equivalents: balances with less than three months to 
maturity at inception 

Cash collateral on derivatives placed with banks 

Other loans and advances to banks 

Year ended 
30 June 2021 
£m 

Year ended 
30 June 2020 
£m 

123.0 

84.8 

15.2 

223.0 

71.1 

147.6 

9.9 

228.6 

£15.2 million is recoverable more than 12 months after the reporting date in respect of cash held by the Group’s securitisation 
vehicles (30 June 2020: £10.0 million).   

All loans and  advances  to banks  were stage 1  assets under  IFRS  9 as  at 30  June 2021  and as  at  30  June 2020. There  were no 
significant impairment provisions in respect of expected losses as at 30 June 2021 or during the year then ended.   

132 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
17. Debt securities 

FVOCI debt securities: 

UK Government gilts  

Supranational bonds 

Treasury bonds 

Asset-backed securities 

Covered bonds 

Debt securities at amortised cost 

UK Government gilts  

Supranational bonds 

30 June 2021 
£m 

30 June 2020 
£m 

133.3 

1,061.2 

- 

115.4 

495.9 

107.3 

86.4 

1,999.5 

189.0 

990.6 

46.1 

114.4 

529.7 

48.4 

22.9 

1,941.1 

At 30 June 2021, £1,659.6 million (30 June 2020: £1,875.5 million) of debt securities are expected to be recovered more than 12 
months after the reporting date.  

All debt securities were stage 1 assets under IFRS 9 as at 30 June 2021 and as at 30 June 2020.  There were no significant impairment 
provisions in respect of expected losses as at 30 June 2021 or as at 30 June 2020.     

As part of the Group’s Capital Investment Strategy, which seeks to stabilise earnings volatility by extending the investment term of 
equity capital, debt securities held in the held to collect model have been classified as measured at amortised cost. 

18. Derivatives held for risk management 
Amounts included in the statement of financial position are analysed as follows: 

2021 

2020 

Instrument type 

Interest rate (not in hedging relationships) 

Interest rate (fair value hedges) 

Equity 

Assets 
£m 

1.8 

17.8 

Liabilities 
£m 

Assets 
£m 

Liabilities 
£m 

1.6 

39.3 

                      -  

                       -  

19.6 

40.9 

3.9 

5.3 

0.1 

9.3 

4.1 

95.6 

0.1 

99.8 

All derivatives are held either as fair value hedges qualifying for hedge accounting (from January 2014) or are held for the purpose of managing 
risk exposures arising on the Group’s other financial instruments (all periods). 

a) 

Fair value hedges of interest rate risk 

In accordance with its risk management strategy as described on page 57, the Group enters into interest rate swap contracts to 
manage the  interest  rate risk arising in respect  of the fixed  rate  interest  exposures on loans and  advances  to customers,  debt 
securities and customer deposits, which are each treated as separate portfolios.  

133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Group hedges the fixed interest rate risk on each portfolio firstly by looking for direct offsets between the asset and liability 
exposures and then by using the interest rate swaps between fixed interest rates and market reference rates such as SONIA in 
order to manage the Group’s overall interest rate risk exposure. The Group applies hedge accounting in respect of the interest rate 
risk arising on these portfolios as described in note 2(j). The Group manages all other risks derived by these exposures, such as 
credit risk, but does not apply hedge accounting for these risks.  

The  Group  assesses  prospective  hedge  effectiveness  by  comparing  the  changes  in  fair  value  of  each  portfolio  resulting  from 
changes in market interest rates with the changes in fair value of allocated interest rate swaps used to hedge the exposure.  
The Group has identified the following possible sources of ineffectiveness:  

 

The use of derivatives as a protection against interest rate risk creates an exposure to the derivative counterparty’s credit 
risk which is not offset by the hedged item. This risk is minimised by entering into derivatives which are subject to daily 
margining through a recognised exchange;  
Different amortisation profiles on hedged item principal amounts and interest rate swap notionals;  

 
  Use of different discounting curves when measuring the fair value of the hedged items and hedging instruments;  
 
For derivatives the discounting curve used depends on collateralisation and the type of collateral used; and 
 
Differences in the timing of settlement of hedging instruments and hedged items. 

No other sources of ineffectiveness were identified in these hedge relationships. 

The tables below summarise the derivatives designated as hedging instruments in qualifying portfolio hedges of interest rate risk: 

Nominal amount of the hedging 
instruments 
Year ended 30 June 2021 

Carrying amount of the hedging 
instruments 
Year ended 30 June 2021 

Line item in the statement 
of financial position where 
the hedging instrument is 
located 

Changes in fair value used 
for calculating hedge 
ineffectiveness Year ended 
30 June 2021 

£m 

10,591.1 

Assets 
£m 

17.8 

Liabilities 
£m 

39.3 

Derivatives held for 
risk management 

£m 

63.6 

Nominal amount of the hedging 
instruments 
Year ended 30 June 2020 

Carrying amount of the hedging 
instruments 
Year ended 30 June 2020 

Line item in the statement 
of financial position where 
the hedging instrument is 
located 

Changes in fair value used 
for calculating hedge 
ineffectiveness Year ended 
30 June 2020 

£m 

8,328.7 

Assets 
£m 

5.0 

Liabilities 
£m 

92.8 

Derivatives held for 
risk management 

£m 

(59.6) 

Fair value hedges 
Interest rate risk 

Interest rate swaps 

Fair value hedges 
Interest rate risk 

Interest rate swaps 

134 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The amounts relating to portfolios designated as hedged items in fair value hedge relationships to manage the Group’s exposure 
to interest rate risk were as follows: 

Fair value hedges 
Interest rate risk 

Loans and advances to 
customers 

Debt securities 

Customer deposits 

Fair value hedges 
Interest rate risk 

Loans and advances to 
customers 

Debt securities 

Customer deposits 

Carrying amount of the hedged items 
Year ended 30 June 2021  

Accumulated amount of fair value hedge 
adjustments on the hedged item included in the 
carrying amount of the hedged items 
Year ended 30 June 2021 

Line item in the statement 
of financial position where 
the hedged items are 
included 

Assets 
£m 

8,168.3 

899.8 

N/A 

Liabilities 
£m 

N/A 

N/A 

2,765.0 

Assets 
£m 

13.7 

(0.9) 

N/A 

Liabilities 
£m 

N/A 

N/A 

Loans and advances 
to customers 

Debt securities 

0.5 

Customer accounts 

Carrying amount of the hedged items 
Year ended 30 June 2020  

Accumulated amount of fair value hedge 
adjustments on the hedged item included in the 
carrying amount of the hedged items 
Year ended 30 June 2020 

Line item in the statement 
of financial position where 
the hedged items are 
included 

Assets 
£m 

6,260.6 

936.25 

N/A 

Liabilities 
£m 

N/A 

N/A 

1,723.0 

Assets 
£m 

58.1 

18.3 

N/A 

Liabilities 
£m 

N/A 

N/A 

Loans and advances 
to customers 

Debt securities 

(2.1)  Customer accounts 

The table below summarises the hedge ineffectiveness recognised in profit or loss during the financial year ended 30 June 2021 
and the comparative period, for the Group’s designated fair value hedge relationships. 

Fair value hedges Interest rate 
risk 

Ineffectiveness recognised in the income statement  
Year ended 30 June 2021  
£m 

5.7 

Line item in the statement of financial position where the hedged 
instrument is located 
Net gains / (losses) from derivatives and other 
financial instruments at fair value through profit or 
loss 

Fair value hedges Interest rate 
risk 

Ineffectiveness recognised in the income statement  
Year ended 30 June 2020  
£m 

(3.3) 

Line item in the statement of financial position where the hedged 
instrument is located 
Net gains / (losses) from derivatives and other 
financial instruments at fair value through profit or 
loss 

135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interest Rate Benchmark Reform (“IBOR”) 
The Group adopted the amendments to IAS 39 and IFRS 9 Interest Rate Benchmark Reform in the current year.  In accordance with 
the transition provisions, the amendments have been adopted retrospectively to hedging relationships that existed at the start of 
the financial period or were designated thereafter. 

The amendments provide temporary relief from specific hedge accounting requirements to hedging relationships directly affected 
by any IBOR reform. The reliefs have the effect that the IBOR reform should not generally cause hedge accounting to terminate.  
However, any hedge ineffectiveness would continue to be recognised in the income statement.  Furthermore, the amendments 
set out triggers for when the reliefs will end, which include the uncertainty arising from IBOR reforms no longer being present. 

The relief provided by the amendments that apply to the Group are as follows: 

 In assessing whether the hedge is expected to be highly effective on a forward-looking basis, the Group assumes that the IBOR 

interest rate in the hedge relationship is not altered by its corresponding IBOR reform; and 

 The Group only assessed whether the hedged IBOR risk component is a separately identified risk at first designation and not   

on an ongoing basis. 

The total notional amount of the derivatives impacted by IBOR are set out below:  

GBP LIBOR 

Notional Amount 
£m 

283.7

These derivatives will be transitioned via ISDA protocols. Refer to page 83 for a detailed explanation of how the Group is managing 
the transition to alternative risk-free rates.  

b) Other derivatives held for risk management  
The Group  uses  other derivatives, not  designated  in  qualifying  hedge  accounting  relationships,  to  manage  its  exposure  to  the 
following: 
 
 
 

Interest rate basis risk on certain mortgage loans; 
Equity market risk on equity-linked products offered to depositors; and 
Foreign exchange risk on currency loans provided to Invoice Finance customers. 

19. Loans and advances to customers 

Gross loans and advances 

less: allowance for impairment losses  

Amounts include: 

30 June 2021 
£m 
13,612.6 

(192.2) 

13,420.4 

30 June 2020 
£m 
12,586.5 

(160.8) 

12,425.7 

Expected to be recovered more than 12 months after the reporting date 

11,627.4 

10,897.5 

At 30 June 2021, loans and advances to customers of £3,425.1 million (30 June 2020: £2,987.0 million) were pre-positioned into a 
Single Funding Pool with the Bank of England and HM Treasury Term Funding Scheme. These loans and advances were available 
for use as collateral with the Scheme. Details of amounts drawn on the facility are shown in note 25. 

At 30 June 2021, loans and advances to customers included £1,146.6 million (30 June 2020: £795.5 million) which have been used 
in  secured  funding  arrangements,  resulting  in the beneficial interest  in  these loans  being transferred to  securitisation vehicles 
consolidated into these financial statements. All the assets pledged are retained within the statement of financial position as the 
Group retains substantially all the risks and rewards relating to the loans. 

136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Analysis of gross loans and advances 

£m 
Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 3 to stage 2 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 1 to stage 3 
Stage 2 to stage 3 
Opening balance after transfers 
Repayments of loans and advances 
Change in exposure due to new business in the current year 
Modifications that did not give rise to derecognition 
Bad debts written off 
Amount as at 30 June 2021 

£m 
Amount as at 1 July 2019 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 3 to stage 2 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 1 to stage 3 
Stage 2 to stage 3 
Opening balance after transfers 
Repayments of loans and advances 
Change in exposure due to new business in the current year 
Modifications that did not give rise to derecognition 
Bad debts written off 
Amount as at 30 June 2020 

30 June 2021 

Gross loans and advances (amortised cost) 

Stage 1 
10,992.4 

Stage 2 

Stage 3 

1,356.3 

237.8 

Total 
12,586.5 

633.9 
9.5 

 -   

(633.9) 
 -   

8.7 

 -   
(9.5) 
(8.7) 

- 
- 
- 

(574.9) 
(149.9) 
- 
10,911.0 
(2,533.6) 
3,757.1 
(0.4) 
 -   

12,134.1 

574.9 

                  -  

 -   
(74.5) 
1,231.5 
(421.1) 
276.0 
(0.2) 
 -   

1,086.2 

149.9 
74.5 
444.0 
(63.7) 
45.2 
(0.1) 
(33.1) 
392.3 

- 
- 
- 
12,586.5 
(3,018.4) 
4,078.3 
(0.7) 
(33.1) 
13,612.6 

Stage 1 

Stage 2 

Stage 3 

9,436.4 

1,083.4 

129.1 

Total 
10,648.9 

368.7 
5.8 
- 

(677.6) 
(75.8) 
- 
9,057.5 
(2,729.5) 
4,673.6 
(9.2) 
- 
10,992.4 

(368.7) 
- 
3.4 

677.6 
- 
(66.1) 
1,329.6 
(371.5) 
400.0 
(1.8) 
- 
1,356.3 

- 
(5.8) 
(3.4) 

- 
75.8 
66.1 
261.8 
(60.4) 
60.1 
(0.2) 
(23.4) 
237.9 

- 
- 
- 

- 
- 
- 
10,648.9 
(3,161.4) 
5,133.7 
(11.2) 
(23.4) 
12,586.6 

137 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Analysis of loss allowances 

£m 
Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 3 to stage 2 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 1 to stage 3 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debts written off 
Amount as at 30 June 2021 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of the total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

£m 
Amount as at 1 July 2019 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 3 to stage 2 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 1 to stage 3 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debts written off 
Amount as at 30 June 2020 

30 June 2021 

Allowance for impairment losses (amortised cost) 

Stage 1 

Stage 2 

Stage 3 

Total 

63.5 

10.8 
1.6 
- 

(4.0) 
(1.7) 
                  -  

70.2 

(27.5) 
- 
(27.5) 

17.4 
- 
60.1 

59.4 
0.7 

11.0 
12.2 
- 

49.9 

48.0 

161.4 

(10.8) 
- 
1.9 

4.0 
- 
(4.3) 
40.7 

(4.7) 
(3.2) 
(1.5) 

6.5 
- 
42.5 

42.5 
- 

5.8 
1.4 
- 

- 
(1.6) 
(1.9) 

- 
1.7 
4.3 
50.5 

61.9 
- 
61.9 

10.3 
(33.1) 
89.6 

89.6 
- 

0.3 
0.5 
7.3 

- 
- 
- 

- 
- 
- 
161.4 

29.7 
(3.2) 
32.9 

34.2 
(33.1) 
192.2 

191.5 
0.7 

17.1 
14.1 
7.3 

30 June 2020 

Allowance for impairment losses (amortised cost) 

Stage 1 

Stage 2 

Stage 3 

Total 

21.5 

2.9 
0.6 
- 

(1.3) 
(0.2) 
- 
23.5 

12.0 
- 
12.0 

28.0 
- 
63.5 

8.9 

(2.9) 
- 
0.2 

1.3 
- 
(0.9) 
6.6 

25.0 
5.5 
19.5 

18.3 
- 
49.9 

24.2 

54.6 

- 
(0.6) 
(0.2) 

- 
0.2 
0.9 
24.5 

30.1 
- 
30.1 

16.8 
(23.4) 
48.0 

- 
- 
- 

- 
- 
- 
54.6 

67.1 
5.5 
61.6 

63.1 
-23.4 
161.4 

138 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of the total loss allowance 
-Forward looking information 
-Changes in models 
-Interest on stage 3 advances** 

Stage 1

Stage 2 

Stage 3

Total 

62.9 
0.6 

15.6 
1.0 
- 

49.9 
- 

12.3 
1.7 
- 

48.0 
- 

1.7 
0.7 
6.0 

160.8 
0.6 

29.6 
3.4 
6.0 

Breakdown of impairment charge recognised during the year 

Included in provisions in respect of loan commitments 
Change in exposure of back book in the current year 
Change in exposure due to new business in the current year 
Interest income suspended 
Increase in loss allowance  
Recoveries of bad debts 
Impairment losses on loans and advances to customers 
Impairment losses on lease modifications 
Impairment of advances recognised during the period 

Year ended 
30 June 2021 
£m 
(0.1) 
29.8 
34.2 
(3.3) 
60.6 
(9.3) 
51.3 
0.8 
52.1 

Year ended 
30 June 2020 
£m 
0.8 
67.1 
63.1 
(4.7) 
126.3 
(5.8) 
120.5 
11.2 
131.7 

*Includes committed undrawn facilities as the credit risk of the undrawn component is managed and monitored with the drawn component as a 
single EAD. The EAD on the entire facility is used to calculate the ECL and is therefore included in the ECL allowance.  

**Cumulative balance as at 30 June 2021. 

Basis of preparation of the gross carrying amount and loss allowance   

The reconciliation  of  the gross carrying amount and  loss allowance is prepared using a year-to-date view. This  means  that  the 
Group reports exposures based on the impairment stage at the end of the reporting period. The Group transfers opening balances 
(back book), at the value as at 1 July 2020, based on the impairment stage at the end of the reporting period. Any additional ECL 
raised or released is included in the impairment stage as at the end of the reporting period. Exposures in the back book, can move 
directly from stage 3 to stage 1, if the curing requirements have been met in a reporting period. All new business (as defined below) 
is included in the change in exposure due to new business in the current year based on the exposures’ impairment stage at the 
end of the reporting period.  Similarly, exposures in the new business lines can be reported in stage 3 at the end of the reporting 
date.  

The impairment charge is split between the back book and new business in the gross carrying amount and ECL reconciliation as 
management believes that that providing this split provides meaningful information to the user in gaining an understanding of the 
performance of advances overall.   

Changes in exposure reflect the net amount of: 

 

Additional amounts advanced on the back book and any settlements. Transfers on the back book are reflected separately; 
and 

  New  business  originated  during  the  financial  year,  the  transfers  between  stages  of  the  new  origination  and  any 

settlements. 

Decreases in the advance as a result of write-off are equal to the decrease in ECL as exposures are 100% provided for before being 
written off. The total contractual amount outstanding on financial assets that were written off during the period and are still subject 
to enforcement activity is £33.1 million. 

139 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of the allowance for impairment losses by class - Asset Finance 

Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 3 to stage 2 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 1 to stage 3 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2021 
Included in the total loss allowance 
Netted against loans and advances to customers 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

Amount as at 1 July 2019 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 3 to stage 2 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 1 to stage 3 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2020 
Included in the total loss allowance 
Netted against loans and advances to customers 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 

Stage 1 
£m 
17.3 

Stage 2 
£m 
17.2 

Stage 3 
£m 
15.0 

Total 
£m 
49.5 

4.8 
0.9 

(4.8) 
                   -  

1.4 

                  -  
(0.9) 
(1.4) 

1.1 

                  -  

-  
(1.1) 
(0.6) 

21.3 

-  

(11.9) 
- 
(11.9) 

2.9 
- 
12.3 

12.3 

                   -  
(1.1) 
13.8 

(5.4) 
(2.0) 
(3.4) 

1.1 
- 
9.5 

9.5 

0.6 
1.1 
14.4 

22.1 
- 
22.1 

0.7 
(17.4) 
19.8 

- 
- 
- 

- 
- 
- 
49.5 

4.8 
(2.0) 
6.8 

4.7 
(17.4) 
41.6 

19.8 

41.6 

1.3 
3.0 

0.2 
0.4 
                   -                       -   

                  -   
0.2 
0.7 

Stage 1 
£m 
7.5 

2.2 
0.4 
- 

(0.7) 
(0.2) 
- 
9.2 

2.2 
- 
2.2 

5.9 
- 
17.3 

Stage 2 
£m 
5.4 

(2.2) 
- 
0.2 

0.7 
- 
(0.4) 
3.7 

11.3 
3.7 
7.6 

2.2 
- 
17.2 

Stage 3 
£m 
11.3 

- 
(0.4) 
(0.2) 

- 
0.2 
0.4 
11.3 

17.9 
- 
17.9 

1.3 
(15.5) 
15.0 

1.5 
3.6 
0.7 

Total 
£m 
24.2 

- 
- 
- 

- 
- 
- 
24.2 

31.4 
3.7 
27.7 

9.4 
(15.5) 
49.5 

17.3 

17.2 

15.0 

49.5 

5.5 
1.9 

4.4 
1.3 

0.1 
1.0 

10.0 
4.2 

140 

 
 
 
 
 
 
 
 
                              
 
                              
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of the allowance for impairment losses by class – Invoice Finance 

Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Deterioration of credit exposure 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2021 
Included in the total loss allowance 
Netted against loans and advances to customers 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 

Amount as at 1 July 2019 
Improvement in credit exposure 
Stage 2 to stage 1 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2020 
Included in the total loss allowance 
Netted against loans and advances to customers 
Other components of total loss allowance 
- Forward looking information 

Stage 1 
£m 
2.6 

Stage 2 
£m 
0.4 

Stage 3 
£m 
2.7 

0.3 
0.1 

(0.3) 
                   -  

                  -  
(0.1) 

3.0 

0.3 
- 
0.3 

0.4 
- 
3.7 

3.7 

0.1 

(0.1) 
(0.1) 
- 

- 
- 
- 

- 

2.6 

0.3 
- 
0.3 

- 
(2.0) 
0.9 

0.9 

(0.1)                     -                      -   
                   -                      -   
0.3 

Stage 1 
£m 
2.4 

0.1 

(0.2) 
- 
2.3 

- 
- 
- 

0.3 
- 
2.6 

2.6 

0.6 

Stage 2 
£m 
0.4 

Stage 3 
£m 
1.9 

(0.1) 

0.2 
(0.1) 
0.4 

(0.2) 
(0.2) 
- 

0.2 
- 
0.4 

0.4 

0.2 

- 

- 
0.1 
2.0 

1.2 
- 
1.2 

(0.1) 
(0.4) 
2.7 

2.7 

- 

Total 
£m 
5.7 

- 
- 

5.7 

0.5 
(0.1) 
0.6 

0.4 
(2.0) 
4.6 

4.6 

-0.1 
0.3 

Total 
£m 
4.7 

- 

- 
- 
4.7 

1.0 
(0.2) 
1.2 

0.4 
(0.4) 
5.7 

5.7 

0.8 

141 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of the allowance for impairment losses by class – SME Commercial Mortgages 

Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2021 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

Amount as at 1 July 2019 
Improvement in credit exposure 
Stage 2 to stage 1 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2020 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

Stage 1 
£m 
6.5 

0.4 
0.1 

                   -  

7.0 

(2.1) 
- 
(2.1) 

0.4 
- 
5.3 

4.9 
0.4 

Stage 2 
£m 
4.2 

Stage 3 
£m 
6.2 

(0.4) 
                   -  
(0.1) 
3.7 

                  -  
(0.1) 
0.1 
6.2 

0.9 
0.3 
0.6 

0.2 
- 
4.8 

4.8 

5.7 
- 
5.7 

0.9 
(1.5) 
11.3 

11.3 

                   -  

                  -  

0.4 
2.0 
- 

                   -                      -   
0.1 
0.9 

0.3 
                   -   

Stage 1 
£m 
2.4 

0.1 

(0.1) 
- 
2.4 

4.6 
- 
4.6 

(0.5) 
- 
6.5 

6.1 
0.4 

- 
0.1 
- 

Stage 2 
£m 
0.3 

(0.1) 

0.1 
(0.1) 
0.2 

3.4 
0.4 
3.0 

0.6 
- 
4.2 

4.2 
- 

- 
(0.3) 
- 

Stage 3 
£m 
1.2 

- 

- 
0.1 
1.3 

4.2 
- 
4.2 

1.0 
(0.3) 
6.2 

6.2 
- 

0.4 
- 
0.8 

Total 
£m 
16.9 

- 
- 
- 
16.9 

4.5 
0.3 
4.2 

1.5 
(1.5) 
21.4 

21.0 
0.4 

0.4 
2.4 
0.9 

Total 
£m 
3.9 

- 

- 
- 
3.9 

12.2 
0.4 
11.8 

1.1 
(0.3) 
16.9 

16.5 
0.4 

0.4 
(0.2) 
0.8 

142 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of the allowance for impairment losses by class – Buy to Let 

Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2021 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

Amount as at 1 July 2019 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Deterioration of credit exposure 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2020 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

Stage 1 
£m 
5.0 

Stage 2 
£m 
6.1 

Stage 3 
£m 
11.2 

1.0 
0.1 

(1.0) 
                   -  

                  -  
(0.1) 

(0.1) 

6.0 

-  

2.6 
- 
2.6 

0.6 
- 
9.2 

9.0 
0.2 

0.1 
(0.6) 
4.6 

2.2 
1.9 
0.3 

0.4 
- 
7.2 

7.2 

                  -  

0.6 
11.7 

7.2 
- 
7.2 

0.5 
(0.6) 
18.8 

18.8 

                   -  

                  -  

2.3 
4.5 

0.2 
0.4 
                   -                       -   

Stage 1 
£m 
4.2 

0.5 
0.1 

- 
4.8 

0.1 
- 
0.1 

0.1 
- 
5.0 

4.9 
0.1 

(0.1) 
(0.9) 
- 

Stage 2 
£m 
2.2 

(0.5) 
- 

(0.2) 
1.5 

4.1 
0.5 
3.6 

0.5 
- 
6.1 

6.1 
- 

- 
0.5 
- 

0.1 
0.1 
2.4 

Stage 3 
£m 
6.3 

- 
(0.1) 

0.2 
6.4 

4.1 
- 
4.1 

0.9 
(0.2) 
11.2 

11.2 
- 

0.9 
(0.3) 
3.0 

Total 
£m 
22.3 

- 
- 

- 
- 
22.3 

12.0 
1.9 
10.1 

1.5 
(0.6) 
35.2 

35.0 
0.2 

2.6 
5.0 
2.4 

Total 
£m 
12.7 

- 
- 

- 
12.7 

8.3 
0.5 
7.8 

1.5 
(0.2) 
22.3 

22.2 
0.1 

0.8 
(0.7) 
3.0 

143 

 
 
 
 
 
 
 
 
 
                              
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of the allowance for impairment losses by class – Residential Mortgages 

Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Deterioration of credit exposure 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2021 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

Amount as at 1 July 2019 
Deterioration of credit exposure 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Amount as at 30 June 2020 
Included in the total loss allowance 
Netted against loans and advances to customers 
Included in respect of loan commitments* 
Other components of total loss allowance 
- Forward looking information 
- Changes in models 
- Interest on stage 3 advances** 

Stage 1 
£m 
2.9 

0.1 

- 
3.0 

(1.0) 
- 
(1.0) 

0.5 
- 
2.5 

2.4 
0.1 

Stage 2 
£m 
1.6 

(0.1) 

(0.1) 
1.4 

0.8 
0.1 
0.7 

0.3 
- 
2.5 

2.5 

Stage 3 
£m 
6.7 

- 

0.1 
6.8 

1.0 
- 
1.0 

0.7 
(0.1) 
8.4 

8.4 

                   -  

                  -  

1.1 
2.4 

0.2 
0.3 
                   -                       -   

Stage 1 
£m 
1.1 

- 
1.1 

1.7 
1.7 

0.1 
2.9 

2.8 
0.1 

- 
(0.1) 
- 

Stage 2 
£m 
0.5 

(0.1) 
0.4 

0.9 
0.9 

0.3 
1.6 

1.6 
- 

- 
0.2 
- 

0.1 
0.1 
2.0 

Stage 3 
£m 
3.1 

0.1 
3.2 

1.5 
1.5 

2.0 
6.7 

6.7 
- 

0.3 
- 
2.2 

Total 
£m 
11.2 

- 

- 
11.2 

0.8 
0.1 
0.7 

1.5 
(0.1) 
13.4 

13.3 
0.1 

1.4 
2.8 
2.0 

Total 
£m 
4.7 

- 
4.7 

4.1 
4.1 

2.4 
11.2 

11.1 
0.1 

0.3 
0.1 
2.2 

144 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of the allowance for impairment losses by class – MotoNovo Finance 

Amount as at 1 July 2020 
Improvement in credit exposure 
Stage 2 to stage 1 
Stage 3 to stage 1 
Stage 3 to stage 2 
Deterioration of credit exposure 
Stage 1 to stage 2 
Stage 1 to stage 3 
Stage 2 to stage 3 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2021 
Included in the total loss allowance 
Netted against loans and advances to customers 
Other components of total loss allowance 
- Forward looking information 
- Interest on stage 3 advances** 

Amount as at 1 July 2019 
Improvement in credit exposure 
Stage 3 to stage 1 
Deterioration of credit exposure 
Stage 1 to stage 2 
Opening balance after transfers 

Change in exposure of back book in the current year 
Attributable to change in measurement basis 
Attributable to change in risk parameters 

Change in exposure due to new business in the current year 
Bad debt written off 
Amount as at 30 June 2020 
Included in the total loss allowance 
Netted against loans and advances to customers 
Other components of total loss allowance 
- Forward looking information 

Stage 1 
£m 
29.2 

Stage 2 
£m 
20.4 

Stage 3 
£m 
6.2 

Total 
£m 
55.8 

4.2 
0.4 
- 

(4.2) 
                   -  

0.5 

                  -  
(0.4) 
(0.5) 

2.8 

                  -  

(2.8) 
(1.1) 
- 
29.9 

(15.4) 
- 
(15.4) 

12.6 
- 
27.1 

27.1 

                   -  
(2.4) 
17.1 

(3.1) 
(3.4) 
0.3 

4.5 
- 
18.5 

18.5 

1.1 
2.4 
8.8 

25.6 
- 
25.6 

7.5 
(11.5) 
30.4 

- 
- 
- 

- 
- 
- 
55.8 

7.1 
(3.4) 
10.5 

24.6 
(11.5) 
76.0 

30.4 

76.0 

6.0 

5.2 
                   -   

0.1 
1.3 

11.3 
1.3 

-   

Stage 1 
£m 
3.9 

0.1 

(0.3) 
3.7 

3.4 
- 
3.4 

22.1 
- 
29.2 

29.2 

9.6 

Stage 2 
£m 
0.1 

- 

0.3 
0.4 

5.5 
1.1 
4.4 

14.5 
- 
20.4 

20.4 

7.7 

Stage 3 
£m 
0.4 

(0.1) 

- 
0.3 

1.2 
- 
1.2 

11.7 
(7.0) 
6.2 

Total 
£m 
4.4 

- 

- 
4.4 

10.1 
1.1 
9.0 

48.3 
(7.0) 
55.8 

6.2 

55.8 

- 

17.3 

*Includes committed undrawn facilities as the credit risk of the undrawn component is managed and monitored with the drawn component as 
a single EAD. The EAD on the entire facility is used to calculate the ECL and is therefore included in the ECL allowance.  

**Cumulative balance as at 30 June 2021. 

145 

 
 
 
 
 
 
 
 
 
                   
 
 
 
 
 
 
 
 
 
Lease Modifications 

The table below includes stage 2 and 3 assets that were modified and, therefore, treated as forborne during the period, with 
the related modification loss charged to the income statement. The table also shows the gross carrying amount of previously 
modified financial assets for which loss allowance has changed to 12 month ECL measurement during the period. 

Modifications losses of assets in stage 2 and 3 

Gross carrying amount of assets before modification 
Loss allowance on asset before modification 
Amortised cost of assets before modification 

Gross carrying amount of assets modified while in stage 2 or 3 and now in 
stage 1 

Year ended 
30 June 2021 
£m 
(0.4) 

120.0 
(21.9) 
98.1 

16.0 

Year ended 
30 June 2020 
£m 
(2.0) 

162.9 
(12.3) 
150.6 

38.3 

Finance lease receivables 
Loans and advances to customers include the following finance leases where the Group is the lessor: 

Gross investment in finance leases, receivable: 

Less than one year 
Between one and five years 
More than five years 

Unearned finance income 
Net investment in finance leases 

Net investment in finance leases, receivable: 

Less than one year 
Between one and five years 
More than five years 

Year ended  
30 June 2021 
£m 

Year Ended 
30 June 2020 
£m (restated) 

1,455.5 
3,613.5 
64.4 

5,133.4 

(738.9) 
4,394.5 

1,235.3 
3,102.7 
56.5 

4,394.5 

1,183.9 
2,814.2 
85.0 

4,083.1 

(573.8) 
3,509.3 

999.5 
2,425.8 
84.0 

3,509.3 

The amounts shown for Gross Investment in Finance Leases; Unearned Finance Income; and Net Investment in Finance Leases as 
at 30 June 2020 have been restated to correct for the amounts for Loans relating to the Asset Finance business which had been 
included in error twice. 

The Group enters into finance lease and hire purchase arrangements with customers in a wide range of sectors including plant and 
machinery, cars  and commercial vehicles. The accumulated allowance for uncollectable minimum lease payments receivable is 
£61.0 million (30 June 2020: £100.7 million).  

Due to the nature of the business undertaken, there are no material unguaranteed residual values for any of the finance leases at 
30 June 2021 (30 June 2020: no material residual values).  

146 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
20. Investment in subsidiaries 

The Company has an interest in the total ordinary share capital of the following subsidiaries (except the securitisation vehicles), all 
of which are registered in England and Wales and operate in the UK. All subsidiary undertakings are included in these consolidated 
financial statements. 

Subsidiary undertakings 
(direct interest) 

Aldermore Bank PLC 

Principal activity 
Banking and related 
services 

MotoNovo Finance Limited 

Motor finance 

Dormant subsidiary 
undertakings (indirect 
interest) 
Aldermore Invoice Finance 
(Holdings) Limited 
(Company number 
06913207) 
Aldermore Invoice Finance 
Limited (Company number 
02483505) 

Aldermore Invoice Finance 
(Oxford) Limited (Company 
number 02129734) 

AR Audit Services Limited 
(Company number 
09495046) 
Securitisation vehicles 
(indirect interest) 
Oak No.2 Mortgage Holdings 
Limited* 

Oak No.2 PLC* 

Dormant 

Dormant 

Dormant 

Dormant 

Holding company for 
securitisation vehicle 

Securitisation vehicle 

Oak No.3 Mortgage Holdings 
Limited* 

Holding company for 
securitisation vehicle 

Oak No.3 PLC* 

Securitisation vehicle 

MotoMore Limited* 

Securitisation vehicle 

Turbo Holdings Limited* 

Holding company for 
securitisation vehicle 

Turbo 9 Finance Limited* 

Securitisation vehicle 

Shareholding % 

Class of shareholding 

Country of 
incorporation 

100 

100 

100 

100 

100 

# 

* 

* 

* 

* 

* 

* 

* 

Ordinary 

Ordinary 

Ordinary 

Ordinary 

Ordinary 

# 

* 

* 

* 

* 

* 

* 

* 

UK1 

UK2 

UK1 

UK1 

UK1 

UK3 

UK4 

UK4 

UK4 

UK4 

UK4 

UK4 

UK4 

# The share capital of this company is not owned by the Group, but is included in the consolidated financial statements as it is controlled by the Group. 

*  The share capital of the securitisation vehicles is not owned by the Group but the vehicles are included in the consolidated financial statements as they are controlled by 

the Group. 

1 Registered address 4th Floor Block D, Apex Plaza, Forbury Road, Reading, England, United Kingdom RG1 1AX 
2 Registered address One, Central Square, Cardiff, Wales, United Kingdom, CF10 1FS  

3 Registered address 6 Coldbath Square, London, England, United Kingdom, EC1R 5HL 

4 Registered address 11th Floor, 200 Aldersgate Street, London, England, United Kingdom, EC1A 4HD 

147 

 
 
 
 
 
 
21. Deferred taxation 

A net deferred tax asset is regarded as recoverable and therefore recognised only when, on the basis of all available evidence, it 
can  be regarded as  probable  that  there  will be suitable future taxable  profits against  which the  unwinding  of  the asset can be 
offset.  

Analysis of recognised deferred tax asset: 

Year ended 30 June 2021 
Capital allowances less than depreciation 
FVOCI debt securities transition adjustment 

Gains on debt securities recognised through other 
comprehensive income 
IFRS 9 transition adjustment 
Other temporary differences  
Share-based payment timing differences 

Year ended 30 June 2020 
Capital allowances less than depreciation 
FVOCI debt securities transition adjustment 

Gains on debt securities recognised through other 
comprehensive income 
IFRS 9 transition adjustment 
Other temporary differences  
Share-based payment timing differences 

Balance as at  
30 June 2020 
£m 

Recognised in 
income statement 
£m 

Recognised in 
other 
comprehensive 
income 
£m 

Balance as at  
30 June 2021 
£m 

2.2 
(0.5) 

(0.3) 

1.7 
0.9 
0.5 

4.5 

3.3 
- 

- 

0.3 
2.4 
(0.1) 

5.9 

- 
- 

(2.8) 

- 
- 
- 

(2.8) 

5.5 
(0.5) 

(3.1) 

2.0 
3.3 
0.4 

7.6 

Balance as at 30 
June 2019 
£m 

Recognised in 
income statement 
£m 

Recognised in 
other 
comprehensive 
income 
£m 

Balance as at 30 
June 2020 
£m 

2.5 
(0.5) 

- 

2.0 
0.6 
0.2 

4.8 

(0.3) 
- 

- 

(0.3) 
0.3 
0.3 

- 

- 
- 

(0.3) 

- 
- 
- 

(0.3) 

2.2 
(0.5) 

(0.3) 

1.7 
0.9 
0.5 

4.5 

The deferred tax asset at 30 June 2021 of £7.6 million (30 June 2020: £4.5 million) has been based on substantively enacted tax 
rates at the balance sheet date. These rates should apply when the temporary differences giving rise to the deferred tax are 
expected to reverse. The deferred tax asset relates mainly to timing differences between capital allowances and depreciation.  

The UK corporation tax rate will increase from 19% to 25% from 1 April 2023 as substantively enacted on 24 May 2021. Deferred 
tax rates have been remeasured to take account of this change. 

There were no unrecognised deferred tax balances at 30 June 2021 (30 June 2020: £nil). 

148 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
22. Investment in associate 

The Group acquired a 48% stake in AFS Group Holdings Limited on 28 September 2017 in exchange for consideration of  
£4.8 million. £3.8 million was paid in September 2017 with two tranches of £0.5 million deferred and held in an escrow account 
until  2018  and  2019,  subject  to  certain  targets  being  met.  Both  tranches  were  paid  in  full  in  August  2018  and  August  2019 
respectively. Details of the Group's material associate at the end of the reporting period are as follows: 

Name of associate 
AFS Group Holdings Limited 
(Company number 
09438039) 

Principal activity 

Financial Services 
Intermediary 

Registered office 
30 June 2021 and 2020 

Proportion of ownership interest/voting rights 
held by the Group 
30 June 2020 and 2019 

UK1 

48%2  

1. Registered address Greenbank Court Challenge Way, Greenbank Business Park, Blackburn, United Kingdom, BB1 5QB1. 
2. Class B ordinary shares. 

The above associate is accounted for using the equity method in these consolidated financial statements. The carrying amount of 
the investment as at 30 June 2021 is £5.7 million (30 June 2020: £5.5 million). This includes a £0.7 million share of profit of associate 
which has been recognised in the Consolidated Income Statement for the period ended 30 June 2021 (30 June 2020: £0.5 million). 

The financial year end date of AFS Group Holdings Limited is 30 April. For the purposes of applying the equity method of accounting, 
the management accounts of AFS Group Holdings Limited for the 12 months ended 30 April 2021 have been used.  

Summarised  financial  information  in  respect  of  the  associate  is  set  out  below.  The  summarised  financial  information  below 
represents amounts shown in the associate’s management accounts for the 12 months ended 30 April 2021 (adjusted by the Group 
for equity accounting purposes). 

Current assets 
Non-current assets 
Current liabilities 
Non-current liabilities 

Revenue 
Profit from continuing operations 
Profit for the period 
Total comprehensive income for the period 
Dividends received from the associate during the period 

30 April 2021 
£m 
7.0 
0.5 
4.7 
0.2 

Year ended  
30 April 2021 
£m 
22.9 
1.7 
1.7 
1.7 
0.5 

30 April 2020 
£m 
4.1 
0.6 
2.2 
0.2 

Year ended  
30 April 2020 
£m 
18.7 
1.5 
1.5 
1.5 
0.4 

A reconciliation of the above summarised financial information to the carrying amount of the interest in AFS Group Holdings 
Limited recognised in the consolidated financial statements is shown below: 

Net assets of the associate 

Proportion of the Group’s ownership Interest in the Associate 

Group share of net assets of the associate 

Goodwill 

Dividend received from associate 

Carrying amount of the Group’s interest in the associate 

AFS Group Holdings Limited 

30 June 2021 

30 June 2020 

£m 

2.6 

48% 

1.2 

4.5 

(0.5) 

5.7 

£m 

2.3 

48% 

1.0 

4.5 

(0.4) 

5.5 

149 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
23. Property, plant and equipment 

Cost 

1 July 2020 

Additions 

Disposal 

30 June 2021 

1 July 2019 

IFRS 16 transition 

Additions 

Disposals 

Retirements 

30 June 2020 

Depreciation  

1 July 2020 

Charge for the year 

Disposals 

30 June 2021 

1 July 2019 

Charge for the year 

Disposals 

Retirements 

30 June 2020 

Net book value 

30 June 2021 

30 June 2020 

Computer 
Systems  
£m 

 Furniture, 
fixtures & 
fittings 
£m  

Right of Use 
Assets -
Property  
£m 

Right of Use 
Assets - Motor 
vehicles 
£m 

Asstes Under 
Operating 
Lease 
£m 

7.9 

1.8 

(0.2) 

9.5 

6.6 

- 

1.7 

(0.1) 

(0.3) 

7.9 

5.0 

1.9 

(0.1) 

6.8 

3.8 

1.5 

- 

(0.3) 

5.0 

2.7 

2.9 

13.0 

0.6 

(1.5) 

12.1 

12.0 

- 

1.6 

- 

(0.6) 

13.0 

4.4 

1.9 

(1.0) 

5.3 

3.2 

1.8 

- 

(0.6) 

4.4 

39.1 

4.6 

(5.7) 

38.0 

- 

38.2 

0.9 

- 

- 

39.1 

4.9 

5.1 

(1.9) 

8.1 

- 

4.9 

- 

- 

4.9 

6.8 

8.6 

29.9 

34.2 

1.5 

0.4 

- 

1.9 

- 

0.7 

0.9 

(0.1) 

- 

1.5 

0.4 

0.6 

(0.1) 

0.9 

- 

0.5 

(0.1) 

- 

0.4 

1.0 

1.1 

- 

7.8 

- 

7.8 

- 

- 

- 

- 

- 

- 

- 

1.1 

- 

1.1 

- 

- 

- 

- 

- 

6.7 

- 

Total 
£m 

61.5 

15.2 

(7.4) 

69.3 

18.6 

38.9 

5.1 

(0.2) 

(0.9) 

61.5 

14.7 

10.6 

(3.1) 

22.2 

7.0 

8.7 

(0.1) 

(0.9) 

14.7 

47.1 

46.8 

150 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
24. Intangible assets 

 Computer Systems  
£m 

Goodwill 
£m 

Cost 

1 July 2020 

Additions 

Retirements 

30 June 2021 

1 July 2019 

Additions 

Retirements 

30 June 2020 

Amortisation  

1 July 2020 

Charge for the year 

Retirements 

30 June 2021 

1 July 2019 

Charge for the year 

Retirements 

30 June 2020 

Net book value 

30 June 2021 

30 June 2020 

20.1 

3.3 

(0.2) 

23.2 

18.8 

2.2 

(0.9) 

20.1 

15.0 

2.0 

(0.2) 

16.8 

12.5 

3.4 

(0.9) 

15.0 

6.4 

5.1 

8.6 

- 

- 

8.6 

8.6 

- 

- 

8.6 

- 

- 

- 

- 

- 

- 

- 

- 

8.6 

8.6 

Total 
£m 

28.7 

3.3 

(0.2) 

31.8 

27.4 

2.2 

(0.9) 

28.7 

15.0 

2.0 

(0.2) 

16.8 

12.5 

3.4 

(0.9) 

15.0 

15.0 

13.7 

The goodwill disclosed above relates to the SME Commercial Mortgages segment. The Value in Use (“VIU”) for SME Commercial 
Mortgages was determined by discounting the future cash flows to be generated from the continuing use of the segment. VIU at 
30 June 2021 has been determined in a similar manner as at 30 June 2020. 

Key assumptions used in the calculation of VIU were the following:  

 

 

Cash flows were projected based on past experience, actual operating results and the six year business plan. Cash flows 
after the planning period were extrapolated using a constant growth rate of 2.0% (30 June 2020: 2.0%) into perpetuity; 
and 
A pre-tax discount rate of 14.4% (30 June 2020: 13.9%) was applied in determining the recoverable amounts for the SME 
Commercial Mortgages operating segment. These discount rates were based on the weighted average cost of funding 
for the segment, taking into account the Group’s regulatory capital requirement and expected market returns for debt 
and equity funding, then adjusted for risk premiums to reflect the systemic risk of the segment. 

IAS 36 requires an assessment of goodwill balances for impairment on an annual basis, or more frequently if there is an indication 
of  impairment. An impairment charge should be recognised where the recoverable amount from the segment  is  less than  the 
carrying value of the goodwill. Under IAS 36, the recoverable amount is the greater of either the VIU of a business or its Fair Value 
less Costs of Disposal (“FVLCD”).  

151 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The VIU of the SME Commercial Mortgages segment is significantly above the carrying value of the attributable goodwill and net 
assets. The Group estimates that reasonably possible changes in the above assumptions are not expected to cause the recoverable 
amount of SME Commercial Mortgages to reduce below the carrying amount. 

25. Amounts due to banks 

Cash collateral received on derivatives 

Due to banks - central banks - Term Funding Scheme interest accrual 

Due to banks - central banks - other eligible schemes 

Amounts repayable within 12 months: 

Due to banks – central banks – Term Funding Scheme interest accrual 

Due to banks – central banks – other eligible schemes interest accrual 

Amounts repayable after 12 months: 

Due to banks – central banks – Term Funding Scheme  

30 June 2021 
£m 

30 June 2020 
£m 

0.5 

1.1 

- 

1.6 

725.0 

- 

725.0 

600.0 

600.0 

1,326.6 

1.8 

0.4 

0.3 

2.5 

946.0 

500.0 

1446.0 

725.0 

725.0 

2,173.5 

Amounts repayable after 12 months 

Loans received from the Bank of England against which the Group provides collateral under the Term Funding Scheme are recorded 
as ‘Amounts due to banks’ and are accounted for as a financial liability at amortised cost. Further details can be found in note 19. 

26. Customers’ accounts 

Retail deposits 

SME deposits 

Corporate deposits 

Amounts repayable within one year 

Amounts repayable after one year 

30 June 2021 
£m 
9,009.3 

2,263.0 

1,155.1 

12,427.4 

10,985.9 

1,441.5 

12,427.4 

30 June 2020 
£m 
7,701.1 

2,210.7 

974.6 

10,886.4 

9,285.0 

1,601.4 

10,886.4 

152 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
27. Other liabilities 

Amounts payable within 12 months: 

Amounts payable to Invoice Finance customers 

Other taxation and social security costs 

Trade creditors 

Lease liabilities 

Other payables 

The maturity of the Group’s lease liabilities was as follows: 

Maturity analysis of finance leases: 

Less than one year 

Between one and five years 

More than five years 

28. Accruals and deferred income 

Amounts payable within 12 months: 

Accruals 

Deferred income 

30 June 2021 
£m 

30 June 2020 
£m 

14.9 

4.2 

8.3 

30.7 

26.6 

84.7 

17.9 

5.7 

6.1 

35.0 

25.8 

90.5 

30 June 2021 
£m 

30 June 2020 
£m 

5.3 

16.2 

9.2 

5.0 

18.1 

11.9 

30 June 2021 

30 June 2020 

62.0 

0.9 

62.9 

32.0 

0.5 

32.5 

The increase in accruals for the year ended 30 June 2021 is largely due to the reintroduction of staff bonuses of £21.6m that were not awarded in 
2020 due to the pandemic. 

29. Provisions 

1 July 2020 

Utilised during the year 

Provided during the year 

30 June 2021 

1 July 2019 

Utilised during the year 

Provided during the year 

30 June 2020 

Customer Redress 
£m 

1.5 

- 

3.3 

4.8 

1.3 

- 

0.2 

1.5 

Other 
£m 

3.0 

(3.2) 

0.5 

0.3 

1.1 

(1.2) 

3.1 

3.0 

Total 
£m 

4.5 

(3.2) 

3.8 

5.1 

2.4 

(1.2) 

3.3 

4.5 

153 

 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Customer Redress 

Motor Finance Remediation 

Due to the Covid-19 pandemic, the Group had to make swift changes to systems and processes to ensure we could provide our 
customers with the Government support measures in place to protect those financially affected by the pandemic. As a result, in 
the Motor Finance business line due to certain variations in procedures followed by the Group during the Covid-19 pandemic, 
management discovered that certain Consumer Credit Act (CCA) related documents that should have been required to have 
been delivered to a sub-section of loan receivable customers were not delivered during part of the financial year.  

Provisions include £2.0m in respect of estimated costs to undertake a remediation programme to correct the impacted 
customers’ loan balances to reflect the period of non-compliance with certain provisions of the CCA. This provision is expected to 
be utilised over the next twelve to eighteen months. Additionally, Interest Income and Loans and Advances to Customers reflect 
a £2.2m adjustment to affect a position of compliance on the customer loan accounts concerned. 

Mortgages Remediation 

Swift changes had to be made in the Mortgages division in response to the Government support measures in place to help those 
financially affected by the pandemic. Although the majority of payment break cases were dealt with seamlessly, a population of 
customers were not moved back onto their normal interest terms upon conclusion of their payment break. As a result, the Group 
has employed external consultants to assess the size and cost of any potential remediation. The cost of this remediation exercise 
which is currently recognised within provisions at 30 June 2021, is expected to be £1.7m, to be utilised over the next twelve to 
eighteen months. 

Debt Consolidation 

Following an internal compliance review, it became evident that a small population of customers that were sold mortgages to 
consolidate debt over a number of years were not given sufficient and appropriate advice. The sale of debt consolidation 
mortgages by the Group ceased from February 2019. Work is ongoing by the Group to evaluate which customers, past and 
present, did not receive sufficient and appropriate advice and calculate the redress due. A provision has been made at 30 June 
2021 for £0.9 million (30 June 2020: £1.0 million) for potential compensation based on an analysis of a sample of cases reviewed 
to that date.  

Other 

Financial Services Compensation Scheme (“FSCS”) 

In common with all regulated UK deposit takers, the Group’s principal subsidiary, Aldermore Bank PLC, pays levies to the FSCS to 
enable the FSCS to meet claims against it. The FSCS provision at 30 June 2021 of £0.2 million (30 June 2020: £0.7 million) 
represents the interest element of the compensation levy for the 2020/2021 scheme year (30 June 2020: interest levy for the 
2019/2020 scheme year). 

Onerous Contracts 

The decision was made in June 2020 to stop using a third-party reward system for dealers, called MotorV8, by the end of 2021 
and as a result has given rise to an onerous contract and therefore a provision of £0.1m (30 June 2020: £0.2m). 

Cancellations 

Payment Protection Insurance ("PPI") income is recognised in full when sold to the customer, however MotoNovo Finance 
recognises a reduction in receivables and income for policies expected to be cancelled against this based on the long run average 
cancellation rate over the life of the agreement. 

A review of this balance was conducted in the current year leading to a change in accounting practice. The PPI cancellation 
provision (30 June 2020: £1.6 million) has been reclassified to now offset against the receivables balance of the customer PPI 
payments, whilst the cost recognised for this has been reclassified to offset against the Operating Income earned from the PPI 
income. 

Expected Losses on Loan Commitments 

In prior years, a provision has been recognised for impairment losses expected in respect of any outstanding irrevocable loan 
commitments (30 June 2020: £0.5 million). A review of this accounting practice was conducted in the year, with this balance 
subsequently reclassified to Loans and Advances to Customers to recognise the expected losses against the loans and receivables 
book. 

154 

 
 
30. Debt securities in issue 

Debt securities in issue - Oak No 2 PLC 

Debt securities in issue - Oak No 3 PLC 

Debt securities in issue - MotoMore Limited 

Debt securities in issue - Turbo Finance 9 PLC  

30 June 2021 
£m 
97.5 

219.2 

250.2 

518.8 

1,085.7 

30 June 2020 
£m 
138.7 

323.7 

249.9 

- 

712.3 

Debt securities in issue with a book value of £1,085.7 million (2020: £712.3 million) are secured on certain portfolios of variable 
and fixed rate mortgages and auto loans through the Group's securitisation vehicles. These notes are redeemable in part from time 
to  time, such redemptions  being  limited to the  net capital received  from mortgage and auto loan customers  in  respect of  the 
underlying assets.  

The final maturity date in respect of the Oak No.2 PLC notes is 26 May 2055 with a call option exercisable on the notes falling due 
on 27 February 2023. The final maturity date in respect of the Oak No.3 PLC notes is 28 July 2061 with a call option exercisable on 
the notes falling due on 29 July 2024. The final maturity date in respect of the MotoMore Limited notes is 19 October 2027 with a 
call option exercisable on the notes falling due on 30 September 2021. The final maturity date in respect of Turbo Finance 9 PLC is 
21 August 2028. A clean up call will occur when the book value of the Turbo 9 Finance PLC notes becomes less than 10% of the 
initial principal balance. 

During the year, Aldermore Bank repurchased £nil (2020: £0.4 million) of Oak 3 notes from the market. There is no obligation for 
the Group to make good any shortfall. Further disclosure relating to the underlying assets is contained in note 19.  

31. Subordinated notes 

Subordinated notes 2026 

Subordinated notes 2028 

Subordinated notes 2029 

30 June 2021 
£m 
60.5 

100.8 

52.3 

213.6 

30 June 2020 
£m 
60.5 

100.7 

52.3 

213.5 

On 28 October 2016, the Group issued £60.0 million subordinated 8.5% loan notes, repayable in 2026, with an option for the Group 
to redeem after five years. The interest rate is fixed until October 2021. The loan is carried in the statement of financial position at 
amortised cost using an EIR of 8.9%.  

On  22  November  2018,  the  Group  issued  to  FirstRand  Bank  Limited,  a  fellow  subsidiary  of  FirstRand  Limited,  £100.0  million 
subordinated 4.9% loan notes, repayable in 2028, with an option for the Group to redeem after five years. The interest rate is fixed 
until November 2023. The loan is carried in the statement of financial position at amortised cost using an EIR of 4.9% which is 
identical to the coupon rate. 

On 22 May 2019, the Group issued to FirstRand Bank Limited, a fellow subsidiary of FirstRand Limited, £52.0 million subordinated 
5.1% loan notes, repayable in 2029, with an option for the Group to redeem after five years. The interest rate is fixed until May 
2024. The loan is carried in the statement of financial position at amortised cost using an EIR of 5.1 %.  

155 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
32. Financing activity 

The table below details changes in the Group's liabilities arising from financing activities, including both cash and non-cash changes. 
Liabilities arising from financing activities are those for which cash flows were, or future cash flows will be, classified in the Group's 
consolidated statement of cash flows as cash flows from financing activities. 

Year ended 30 June 2021 

Debt Securities in Issue -  
note 30 

Subordinated notes -  
note 31 

Year ended 30 June 2020 

Debt Securities in Issue -  
note 30 

Subordinated notes -  
note 31 

As at 1 July 2020 
£m 

Financing cash 
flows-debt issued 
£m 

Financing cash 
flows - repayment 
of debt 
£m 

Financing cash 
flows - interest 
paid on debt 
£m 

Non-cash changes-
Interest expense 
per Income 
Statement 
£m 

As at 30 June 
2021 
£m 

712.3 

518.2 

(146.2) 

(6.8) 

8.2 

1,085.7 

213.5 

- 

- 

(12.6) 

12.7 

213.6 

As at 1 July 2019 
£m 

Financing cash 
flows-debt issued 
£m 

Financing cash 
flows - repayment 
of debt 
£m1 

Financing cash 
flows - interest 
paid on debt 
£m 

Non-cash changes-
Interest expense 
per Income 
Statement 
£m 

As at 30 June 
2020 
£m 

263.2 

592.6 

(144.5) 

(8.1) 

9.1 

712.3 

213.4 

- 

- 

(12.6) 

12.7 

213.5 

1. In May 2020 £0.4 million worth of Oak 3 notes were purchased by Aldermore Bank PLC from the market. 

33. Share capital 

Type 

30 June 2021 
£m 

30 June 2020 
£m 

Ordinary shares authorised and fully paid up of £0.10 each 

243.9 

243.9 

As at 30 June 2021, there were 2,439,016,370 ordinary £0.10 shares in issue resulting in share capital of £243,901,637 (30 June 2020: 
2,439,016,370 and £243,901,637 respectively). 

156 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
34. Share-based payments 

The table below shows the charge to the income statement: 

Share plans issued in period ended 30 June 2018 

Share plans issued in year ended 30 June 2019 

Share plans issued in year ended 30 June 2020 

Share plans issued in year ended 30 June 2021 

Total share-based payment charge 

The table below shows the number of awards outstanding as at 30 June 2021: 

Awards 
outstanding value 
30 June 2021 
£m  

Adjusted for 
movement in 
FirstRand ZAR 
Share Price 

Non Market 
Performance 
Conditions 
Attached 1 

Vesting Dates 

Plan 

Deferred Bonus 
Scheme FY18 

Deferred Bonus 
Scheme FY19 

Deferred Bonus 
Scheme FY21 

LTIP awards  
(risk & 
compliance) 
FY19 

LTIP awards  
(risk & 
compliance) 
FY20 

LTIP awards  
(risk & 
compliance) 
FY21 

LTIP  
awards FY19 

LTIP  
awards FY20 

0.1 

Sep-21 

Yes 

No 

0.5 

1.0 

Sep-21 
Sep-22 

Sep-21 
Sep-22 

Yes 

No 

Yes 

No 

0.1 

Sep-21 

Yes 

No 

0.4 

Sep-22 

Yes 

No 

0.4 

Sep-23 

Yes 

No 

0.3 

Sep-21 

Yes 

Yes 

0.5 

Sep-22 

Yes 

Yes 

Settlement 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Year ended  
30 June 2021 
£m 
- 

Year ended  
30 June 2020 
£m 
(0.4) 

0.5 

0.6 

1.0 

2.1 

0.7 

0.7 

- 

1.0 

Liability transferred 
to RMBMS by 
assumption of 
liability agreement 2 

Aldermore 
Group Residual 
Liability 

Charge for 
current year 
£m 

Yes 

Yes 

- 

Yes 

Yes 

0.1 

Yes 

Yes 

0.3 

Yes 

Yes 

- 

Yes 

Yes 

0.1 

Yes 

Yes 

0.1 

Yes 

No 

0.1 

Yes 

No 

0.1 

157 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
LTIP  
awards FY21 

LTIP awards  
(Exco) FY19 

LTIP awards  
(Exco) FY20 

LTIP awards  
(Exco) FY21 

Conditional  
Share  
Plan (MotoNovo  
Finance) - CP18 

Conditional  
Share  
Plan (MotoNovo  
Finance) - CP19 

Conditional  
Share  
Plan (MotoNovo  
Finance) - CP20 

Covid-19 
Conditional 
Incentive Plan 

Total 

0.5 

Sep-23 

Yes 

Yes 

0.6 

Sep-21 

Yes 

Yes 

0.9 

Sep-22 

Yes 

Yes 

0.9 

Sep-23 

Yes 

Yes 

0.6 

Sep-21 

No 

No 

0.3 

Sep-22 

No 

No 

0.6 

Sep-23 

No 

No 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Yes 

No 

0.1 

Yes 

No 

0.2 

Yes 

No 

0.2 

Yes 

No 

0.2 

No 

Yes 

0.2 

No 

Yes 

0.1 

No 

Yes 

0.1 

0.6 

8.3 

Sep-21 
Sep-22 
Sep 23 

Yes 

No 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Sep-23 vesting 
only  

Yes 

0.2 

2.1 

1. Non Market Performance Conditions - 40.0% of the conditional award will vest if: Increase in FirstRand normalised earnings per share equals or 
exceeds the South Africa CPI plus real GDP growth, on a cumulative basis, over the performance period; FirstRand Limited delivers ROE of at least 
18.0% over the performance period; and 60.0% of the conditional award will be based on the performance conditions linked to Aldermore. 
2. Aldermore entered into an assumption of liability and novation agreement with RMB Morgan Stanley Proprietary Ltd (‘RMBMS’), a 50.0% 
owned JV of the FirstRand Group to hedge the cost of the awards linked to the FirstRand share price.  In return for Aldermore making a payment 
to RMBMS, RMBMS is substituted in the agreement and is obligated to pay the GBP amount due to the Aldermore employees at the vesting date.  

158 

 
 
 
 
 
 
 
 
 
 
The table below shows the number of awards outstanding as at 30 June 2020: 

Awards 
outstanding value 
30 June 2020 
£m  

- 

0.2 

0.8 

Adjusted for 
movement in 
FirstRand ZAR 
Share Price 

Non Market 
Performance 
Conditions 
Attached 2 

No 

Yes 

No 

No 

Yes 

No 

Vesting Dates 
Oct-19 
Mar-20 

Sep-20 
Sep-21 

Sep-20 
Sep-21 
Sep-22 

0.1 

Sep-21 

Yes 

No 

0.4 

Sep-22 

Yes 

No 

0.6 

Sep-21 

Yes 

Yes 

0.8 

Sep-22 

Yes 

Yes 

0.8 

Sep-21 

Yes 

Yes 

0.9 

Sep-22 

Yes 

Yes 

0.2 

Sep-19 (CP16) 
Sep-20 (CP17) 

No 

No 

0.4 

Sep-21 

No 

No 

Sep-22 

No 

No 

0.8 

6.0 

Settlement 

Cash 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Cash or FirstRand 
shares to the value of 
the award at the 
vesting date 

Plan 

Transition 
 Award 1 

Deferred Bonus 
Scheme FY19 

Deferred Bonus 
Scheme FY20 

LTIP awards  
(risk & 
compliance) 
FY19 

LTIP awards  
(risk & 
compliance) 
FY20 

LTIP  
awards FY19 

LTIP  
awards FY20 

LTIP awards  
(Exco) FY19 

LTIP awards  
(Exco) FY20 
Conditional  
Share  
Plan (MotoNovo  
Finance) - CP16 
&  
CP17 

Conditional  
Share  
Plan (MotoNovo  
Finance) - CP18 

Conditional  
Share  
Plan (MotoNovo  
Finance) - CP19 

Total 

Liability transferred 
to RMBMS by 
assumption of 
liability agreement 3 

Aldermore 
Group Residual 
Liability 

Charge for 
current year 
£m 

No 

No 

0.2 

Yes 

Yes 

0.3 

Yes 

Yes 

0.2 

Yes 

Yes 

0.0 

Yes 

Yes 

0.1 

Yes 

No 

(0.1) 

Yes 

No 

0.2 

Yes 

No 

0.3 

Yes 

No 

0.1 

No 

Yes 

(0.9) 

No 

Yes 

0.4 

No 

Yes 

0.2 

1.0 

1. Transition award vested on 28 March 2020.  
2. Non Market Performance Conditions - 40.0% of the conditional award will vest if: Increase in FirstRand normalised earnings per share equals or 
exceeds the South Africa CPI plus real GDP growth, on a cumulative basis, over the performance period; FirstRand Limited delivers ROE of at least 
18.0% over the performance period; and 60.0% of the conditional award will be based on the performance conditions linked to Aldermore. 
3. Aldermore entered into an assumption of liability and novation agreement with RMB Morgan Stanley Proprietary Ltd (‘RMBMS’), a 50.0% owned 
JV of the FirstRand Group to hedge the cost of the awards linked to the FirstRand share price.  In return for Aldermore making a payment to 
RMBMS, RMBMS is substituted in the agreement and is obligated to pay the GBP amount due to the Aldermore employees at the vesting date.  

159 

 
 
 
 
 
 
The terms of the schemes which are all cash-settled are as follows: 

a) Deferred Bonus Scheme 

A deferred  portion of  the annual bonus  (or Bonus deferral scheme (“BDS”)),  which is based on the  Aldermore Group’s  and an 
individual’s performance against specified factors during the period to which the annual bonus relates. The deferred bonus is equity 
linked. The awards vest in three equal annual instalments, on the first, second and third anniversary of the date the annual bonus 
is confirmed. There are no performance conditions in respect of the awards however there are service conditions attached to the 
awards in respect of the employee continuing to be employed by the Aldermore Group at each vesting date.  

b) LTIP (Long Term Incentive Plan) 

A long term incentive plan (“LTIP”) for which vesting occurs three years after the award date. The same service conditions apply as 
for the BDS, i.e. continuing to be employed at each vesting date for all awards. The awards are equity linked without performance 
conditions for a small number of employees engaged in risk and control functions. The awards are equity linked with performance 
conditions for other senior employees linked to FirstRand and Aldermore performance. 

c) Conditional Share Plan (MotoNovo Finance) 

The conditional award comprises a number of full shares with no strike price. These awards vest after three years. The number of 
shares that vest is determined by the extent to which the performance conditions are met. Conditional awards are made annually 
and vesting is subject to specified financial and non-financial performance targets set annually by the Remuneration Committee. 
The conditional share plan (“CSP”) is valued using the Black Scholes option pricing model with a zero strike price. The scheme is 
cash-settled and is therefore repriced at each reporting date. The share based payment liability includes two schemes for share 
awards granted in 2018 and 2019. The liability for the 2017 scheme, which was provisionally due to vest in September 2020, was 
released to the income statement in the year to 30 June 2020 given that the performance conditions were not met.  

d) Covid-19 Conditional Incentive Plan 

An equity linked Covid-19 Conditional Incentive Plan was awarded by FirstRand to Aldermore Group employees in September 
2020. The award was introduced to replace the LTIP awards due to vest in September 2021, 2022 and 2023 and will only pay out 
if these LTIP awards do not meet their vesting conditions. The tranche due to vest in September 2023 will be paid out regardless 
of the LTIP also due to vest on this date’s performance. This award has been granted to a small number of senior employees 
within the Group. 

All the schemes identified above have employee service conditions.  

160 

 
 
 
 
35. Additional Tier 1 capital 

Perpetual subordinated capital notes - issued May 2019 

Perpetual subordinated capital notes - issued April 2020 

30 June 2021 
£m 
47.0 

61.0 

108.0 

30 June 2020 
£m 
47.0 

61.0 

108.0 

Perpetual subordinated capital notes 

On 25 June 2019, the Company issued £47.0 million of Perpetual Subordinated Capital Notes to FirstRand Bank Limited, a fellow 
subsidiary of FirstRand Limited.  

The Securities are perpetual and have no fixed redemption date. Redemption of the Securities is at the option of the Company on 
27 June 2024 and semi-annually thereafter. The Securities bear interest at an initial rate of 7.3% per annum until 27 June 2024 and 
thereafter at the relevant Reset Interest Rate as provided in the Information Memorandum. Interest is payable on the Securities 
semi-annually in arrears on each interest payment date commencing from 27 December 2019 and is non-cumulative. The Borrower 
has the full discretion to cancel any interest scheduled to be paid on the Securities. 

On 29 April 2020, the Company issued £61.0 million of Perpetual Subordinated Capital Notes to FirstRand Bank Limited, a fellow 
subsidiary of FirstRand Limited.  

The Securities are perpetual and have no fixed redemption date. Redemption of the Securities is at the option of the Company on 
29 April 2025 and semi-annually thereafter. The Securities bear interest at an initial rate of 8.5% per annum until 29 April 2025 and 
thereafter at the relevant Benchmark Gilt rates plus a margin of 8.324% per annum from up to four leading gilt dealers. Interest is 
payable on the Securities semi-annually in arrears on each interest payment date commencing from 29 October 2020 and is non-
cumulative. The Borrower has the full discretion to cancel any interest scheduled to be paid on the Securities. 

Contingent convertible securities 

On 9 December 2014, the Company issued £75.0 million Fixed Rate Reset Additional Tier 1 Perpetual Subordinated Contingent 
Convertible Securities (the “Securities”). Net proceeds arising from the issuance, after deducting issuance costs and the associated 
tax credit, totalled £74.0 million. 

The Securities were perpetual and had no fixed redemption date. Redemption of the Securities was at the option of the Company 
on 30 April 2020 and annually thereafter. The securities were redeemed on 30 April 2020 and the Company paid the £75.0 million 
on redemption.  

161 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
36. Statement of cash flows 

a)  Adjustments for non-cash items and other adjustments included within the income statement 

Depreciation and amortisation 

Amortisation of securitisation issuance cost 

Impairment losses on loans and advances 

Lease modifications 

Unwind of discounting 

Interest in suspense 

Gains/(losses) on hedged available for sale debt securities recognised in profit or loss 

Net gains/(losses) on disposal of available for sale debt securities 

Interest expense on subordinated notes 

Interest income on debt securities 

Interest expense on debt securities in issue 

Share of profit of associate 

b) Increase in operating assets 

Loans and advances to customers 

Loans and advances to banks 

Derivative financial instruments  

Fair value adjustments for portfolio hedged risk 

Other operating assets 

Dividend received from associate 

c) Increase in operating liabilities 

Amounts due to banks 

Customers' accounts 

Derivative financial instruments 

Fair value adjustments for portfolio hedged risk 

Increase/(decrease) in operating liabilities 

Increase/(decrease) in provisions 

Year ended 
30 June 2021 
£m 
12.6 

Year ended 
30 June 2020 
£m 
12.1 

0.1 

51.3 

0.8 

- 

- 

0.1 

2.6 

0.1 

(8.1) 

7.0 

(0.7) 

65.8 

1.1 

129.0 

11.2 

(0.7) 

2.1 

(17.0) 

(0.5) 

0.1 

(8.7) 

8.0 

(0.5) 

136.2 

Year ended 
30 June 2021 
£m 
(1,046.8) 

57.6 

(10.3) 

43.9 

(18.2) 

0.5 

Year ended 
30 June 2020 
£m 
(1,972.2) 

(83.6) 

(0.2) 

(40.2) 

(11.1) 

0.4 

(973.3) 

(2,106.9) 

Year ended 
30 June 2021 
£m 
(846.9) 

1,540.9 

(58.8) 

(2.1) 

30.1 

0.6 

663.8 

Year ended 
30 June 2020 
£m 
358.9 

1,914.6 

62.4 

1.1 

(21.7) 

(0.2) 

2,315.1 

162 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
d) Cash and cash equivalents 

For the purpose of the statement of cash flows, cash and cash equivalents comprise cash on demand and overnight deposits 
classified as cash and balances at central banks (unless restricted) and balances within loans and advances to banks. The 
following balances have been identified as being cash and cash equivalents. 

Cash and balances at central banks 

Less restricted balances 

Loans and advances to banks 

Year ended 
30 June 2021 
£m 
688.5 

(36.2) 

123.0 

775.3 

Year ended 
30 June 2020 
£m 
542.5 

(29.9) 

71.0 

583.6 

Restricted balances comprise minimum balances required to be held at the Bank of England as they are not readily convertible to 
cash in hand or demand deposits. Loans and advances to banks as at 30 June 2021 include £15.2 million held by the securitisation 
vehicles, which are not available to the other members of the Aldermore Group (30 June 2020: £10.0 million). 

37. Commitments and contingencies 

At  30 June 2021, the Group had undrawn commitments to lend  of £412.4 million (30 June  2020: £342.5 million). These  relate 
mostly to irrevocable lines of credit granted to customers.  

Legislation 

As a financial services group, Aldermore Group PLC is subject to extensive and comprehensive regulation. The Group must comply 
with numerous laws and regulations, which significantly affect the way it does business. Whilst the Group believes there are no 
unidentified  areas  of  failure  to  comply  with  these  laws  and  regulations  which  would  have  a  material  impact  on  the  financial 
statements, there can be no guarantee that all issues have been identified. 

38. Related parties 

(a) Controlling parties 

FirstRand International Limited acquired 100.0% of the share capital of Aldermore Group PLC in March 2018. It, therefore, became 
the immediate parent of Aldermore Group PLC. FirstRand International Limited is a company incorporated in Guernsey (registered 
number 17166), and is a wholly owned subsidiary of FirstRand Limited, a company incorporated in South Africa (registered number 
1966/010753/06) and the ultimate parent and ultimate controlling party. Consolidated accounts are prepared by FirstRand Limited 
and copies are available to the public from the ultimate parent’s registered office c/o 4 Merchant Place, Corner Fredman Drive and 
Rivonia Road, Sandton, Gauteng, South Africa, 2196. 

During the year ended 30 June 2021, the Group also incurred fees of £68,500 (30 June 2020: £137,000) in relation to the Directors 
who represent the ultimate parent company. 

As at 30  June 2021, the  Group owed FirstRand Bank Limited a balance of  £261.0  million (30 June  2020:  £261.0 million)  which 
includes subordinated securities totalling £260.8 million and were owed a balance of £6.0 million from FirstRand Bank Limited (30 
June 2020: £3.4 million) consisting of recharged administrative and operational costs.  

163 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
During the year ended 30 June 2021, the Group received income from FirstRand Bank Limited totalling £27.1 million (30 June 2020: 
£42.6  million)  relating  to  administrative  costs  recharged  to  FirstRand  Bank  Limited  by  MotoNovo  Finance  Limited  and  were 
recharged expenses totalling £16.5 million (30 June 2020: £12.6 million) which includes a subordinated loan note coupon of £7.5 
million, an AT1 coupon of £8.6 million and the remainder being software license costs and non-executive director fees.  

FirstRand  Limited has  issued a  guarantee to the Bank of England to cover  Aldermore Group’s drawings  on the  TFS and TFSME 
facilities.  See page 82 for the Group’s drawings at 30 June 2021.  

b) Associates 

The Group holds a 48% holding in AFS Group Holdings Limited which was acquired on 28 September 2017. During the year ended 
30 June 2021, the Group paid commission of £1.6 million to the associate (year ended 30 June 2020: £2.0 million). The Group also 
received dividends totalling £0.5 million during the year (30 June 2020: £0.4 million). 

c)  Key management personnel compensation  

Key Management Personnel (“KMP”) comprise Directors of the Group and members of the Executive Committee. Details of the 
compensation paid (in accordance with IAS 24) to KMP are: 

Emoluments 

Payments in respect of personal pension plans 

Contributions to money purchase scheme 

Termination benefits 

Share-based payments 

Year ended 
 30 June 2021 
£'000 
6,968.2 

146.2 

51.6 

- 

1,871.9 

9,037.9 

Year ended 
 30 June 2020 
£'000 
4,081.6 

182.6 

44.8 

130.3 

1,031.7 

5,471.0 

Key persons’ emoluments include £0.5 million of deferred bonus (year ended 30 June 2020: £nil). 

Share-based payments (“SBP”) 

During the year ended 30 June 2021, KMP were granted awards which are linked to the share price of the ultimate parent FirstRand 
Limited. Further details of the schemes are provided in note 34. 

164 

 
 
 
 
  
 
 
 
 
 
 
 
 
39. Financial instruments and fair values 
The following table summarises the classification and carrying amounts of the Group’s financial assets and liabilities: 

Assets at amortised 
cost 
£m 

Debt securities at 
FVOCI 
£m 

Fair value through 
profit or loss 
(required) 
£m 

Fair value hedges 
£m 

Liabilities at 
amortised cost 
£m 

30 June 2021 
Cash and balances at central 
banks 

Loans and advances to banks 

Debt securities 

Derivatives held for risk 
management 
Fair value adjustment for 
portfolio hedged risk 
Loans and advances to 
customers 
Other assets 

Total financial assets 

Non-financial assets 
Total assets 

Amounts due to banks 

Customers’ accounts 

Derivatives held for risk 
management 

Other liabilities 

Debt securities in issue 

Subordinated notes 

Total financial liabilities 

Non-financial liabilities 

Total liabilities 

688.5 

223.0 

193.7 

- 

- 

13,420.4 

29.4 

- 

- 

1,805.8 

- 

- 

- 

- 

14,555.0 

1,805.8 

- 

- 

14,555.0 

1,805.8 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

19.6 

- 

- 

- 

19.6 

- 

19.6 

- 

- 

40.9 

- 

- 

- 

40.9 

- 

40.9 

- 

- 

- 

- 

14.2 

- 

- 

14.2 

- 

14.2 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Total 
£m 

688.5 

223.0 

1,999.5 

19.6 

14.2 

13,420.4 

29.4 

16,394.6 

94.5 

16,489.1 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

1,326.6 

1,326.6 

12,427.4 

12,427.4 

- 

84.7 

1,085.7 

213.6 

40.9 

84.7 

1,085.7 

213.6 

15,138.0 

15,178.9 

- 

79.0 

15,138.0 

15,257.9 

165 

 
 
 
 
Assets at amortised 
cost 
£m 

Debt securities at 
FVOCI 
£m 

Fair value through 
profit or loss 
(required) 
£m 

Fair value hedges 
£m 

Liabilities at 
amortised cost 
£m 

30 June 2020 
Cash and balances at central 
banks 

Loans and advances to banks 

Debt securities 

Derivatives held for risk 
management 
Fair value adjustment for 
portfolio hedged risk 
Loans and advances to 
customers 
Other assets 

Total financial assets 

Non-financial assets 
Total assets 

Amounts due to banks 

Customers’ accounts 

Derivatives held for risk 
management 

Fair value adjustment for 
portfolio hedged risk 

Other liabilities 

Debt securities in issue 

Subordinated notes 

Total financial liabilities 
Non-financial liabilities 

Total liabilities 

542.4 

228.6 

71.3 

- 

- 

12,425.7 

20.7 

- 

- 

1,869.8 

- 

- 

- 

- 

13,288.7 

1,869.8 

- 

- 

13,288.7 

1,869.8 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

9.3 

- 

- 

- 

9.3 

- 

9.3 

- 

- 

99.8 

- 

- 

- 

- 

99.8 

- 

99.8 

- 

- 

- 

- 

58.1 

- 

- 

58.1 

- 

58.1 

- 

- 

- 

2.1 

- 

- 

- 

2.1 

- 

2.1 

Total 
£m 

542.4 

228.6 

1,941.1 

9.3 

58.1 

12,425.7 

20.7 

15,225.9 

97.7 

15,323.6 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

2,173.5 

2,173.5 

10,886.4 

10,886.4 

- 

- 

90.5 

712.3 

213.5 

99.8 

2.1 

90.5 

712.3 

213.5 

14,076.2 

14,178.1 

- 

37.0 

14,076.2 

14,215.1 

The following table summarises the carrying amounts and fair values of those financial assets and liabilities not presented in the 
statement of financial position at fair value. The fair values in this note are stated at a specific date and may be significantly different 
from the amounts which will actually be paid on the maturity or settlement dates of the instruments. As a wide range of valuation 
techniques are available, it may be inappropriate to compare this fair value information to that of independent market or other 
financial institutions valuations.  

Cash and balances at central banks 

Loans and advances to banks 

                30 June 2021 

                  30 June 2020 

Carrying value 
£m 

688.5 

223.0 

Fair value 
£m 

688.5 

223.0 

Carrying value 
£m 

542.4 

228.6 

Fair value 
£m 

542.4 

228.6 

Loans and advances to customers 

13,420.4 

13,387.3 

12,425.7 

12,433.3 

Debt securities 

Other assets 

Total financial assets 

193.7 

29.4 

193.8 

29.5 

71.3 

20.7 

72.2 

20.7 

14,555.1 

14,522.1 

13,288.7 

13,297.2 

166 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Amounts due to banks 

Customers’ accounts 

Other liabilities 

Debt securities in issue 

Subordinated notes 

Total financial liabilities 

30 June 2021 

30 June 2020 

Carrying value
£m
1,326.6 

12,427.4 

84.7 

1,085.7 

213.6 

Fair value
£m
1,326.6 

12,453.5 

84.7 

1,089.4 

227.6 

Carrying value
£m
2,173.5 

10,886.4 

90.5 

712.3 

213.5 

Fair value 
£m 
2,173.5 

10,968.8 

90.5 

714.4 

214.0 

15,138.0 

15,181.8 

14,076.2 

14,161.2 

Key considerations in the calculation of the disclosed fair values for those financial assets and liabilities carried at amortised cost 
include the following: 

(a) Cash and balances at central banks  

These  represent  amounts  with  an  initial  maturity  of  less  than  three  months  and  as  such,  their  carrying  value  is  considered  a 
reasonable approximation of their fair value. 

(b) Loans and advances to banks 

These represent either amounts with an initial maturity of less than three months or longer term variable rate deposits placed with 
banks, where adjustments to fair value in respect of the credit risk of the counterparty are not considered necessary. Accordingly, 
the carrying value of the assets is considered to be not materially different from their fair value. 

(c) Loans and advances to customers 

For fixed rate lending products, the Group has estimated the fair value of the fixed rate interest cash flows by discounting those 
cash flows by the current appropriate market reference rate used for pricing equivalent products plus the credit spread attributable 
to  the  borrower.  The  Group  has  calculated  the  fair  value  of  loans  and  advances  to  customers  based  on  the  present  value  of 
expected future principal and interest cash flows, discounted at appropriate market rates, and then adjusted for lifetime expected 
credit losses. 

 (d) Other assets and liabilities 

These represent short term receivables and payables and as such, their carrying value is not considered to be materially different 
from their fair value. 

(e) Amounts due to banks 

These mainly represent securities sold under agreements to repurchase which were drawn down from the Bank of England under 
the terms of the Funding for Term Funding Schemes (“TFS” and “TFSME”). These transactions are collateralised by the Group’s 
eligible loan pool.  

(f) Customers’ accounts 

The fair value of fixed rate customers’ accounts have been determined by discounting estimated future cash flows based on rates 
currently  offered by  the  Group  for  equivalent  deposits.  Customers’  accounts  at  variable rates  are at  current  market  rates  and 
therefore, the Group regards the fair value to be equal to the carrying value. The estimated fair value of deposits with no stated 
maturity is the amount repayable on demand. 

(g) Debt securities in issue  

As the securities are actively traded in a recognised market, with readily available and quoted prices, these have been used to value 
the securities. These securities are therefore regarded as having Level 1 fair values, see below.  

167 

 
 
 
(h) Subordinated notes 

The estimated fair value of the subordinated notes is based on discounted cash flows using interest rates for similar liabilities with 
the same remaining maturity, credit ranking and rating.  

The following table provides an analysis of financial assets and liabilities held on the consolidated statement of financial position 
at fair value, which are all subject to recurring valuation, grouped into Levels 1 to 3 based on the degree to which the fair value is 
observable: 

(i) Debt securities 

Debt Securities held with Capital Investment Strategy are classified as amortised cost only if they meet both the business model 
assessment and SPPI tests. These debt securities are publicly traded in the market and the quoted prices are used as a fair value 
disclosure. 

30 June 2021 

Financial assets: 

Derivatives held for risk management 

Debt securities: 

Asset-backed securities 

UK Gilts and Supranational bonds 

Covered bonds 

Financial liabilities: 

Derivatives held for risk management 

30 June 2020 

Financial assets: 

Derivatives held for risk management 

Debt securities: 

Asset-backed securities 

UK Gilts and Supranational bonds 

Covered bonds 

Treasury bills 

Financial liabilities: 

Derivatives held for risk management 

Level 1 
£m 

- 

- 

1,194.5 

495.9 

1,690.4 

- 

- 

Level 1 
£m 

- 

- 

1179.6 

529.7 

46.1 

Level 2 
£m 

19.6 

115.4 

- 

- 

135.0 

40.9 

40.9 

Level 2 
£m 

9.3 

114.4 

- 

- 

- 

1,755.4 

123.7 

- 

- 

99.8 

99.8 

Level 3 
£m 

- 

- 

- 

- 

- 

- 

- 

Level 3 
£m 

- 

- 

- 

- 

- 

- 

- 

- 

Total 
£m 

19.6 

115.4 

1,194.5 

495.9 

1,825.4 

40.9 

40.9 

Total 
£m 

9.3 

114.4 

1179.6 

529.7 

46.1 

1,879.1 

99.8 

99.8 

Level 1:  Fair value determined using quoted prices (unadjusted) in active markets for identical assets or liabilities. 
Level 2:  Fair value determined using directly or indirectly observable inputs other than unadjusted quoted prices included within 

Level 1 that are observable. 

Level 3:  Fair value determined using one or more significant inputs that are not based on observable market data. 

The fair values of UK T-bills, Gilts, Supranational bonds, Corporate bonds and Covered bonds are based on quoted bid prices in 
active markets. 

168 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The fair value of asset-backed securities are based on the average price of indicative prices from counterparties and Bloomberg, 
but before relying on these prices, the Group has obtained an understanding of how the prices were derived to ensure that each 
investment is assigned an appropriate classification within the fair value hierarchy. 

The  fair  values  of  derivative  assets  and  liabilities  are  determined  using  widely  recognised  valuation  methods  for  financial 
instruments  such  as  interest  rate  swaps  and  use  only  observable  market  data  that  require  little management  judgement  and 
estimation.  Credit  value  and  debit  value  adjustments  have  not  been  applied  as  the  derivative  assets  and  liabilities  are  largely 
conducted through a recognised exchange and as such are subject to daily margining requirements. 

Fair value measurement – financial assets and liabilities held at amortised cost 

The debt securities falling into the Capital Investment business model are classified at amortised cost. The fair value of the debt 
securities classified at amortised cost is based on quoted bid prices in active markets. 

All the fair values of  financial assets  and liabilities carried at amortised cost are considered to be Level 2 valuations which  are 
determined using directly or indirectly observable inputs other than unadjusted quoted prices, except for debt securities in issue 
which are Level 1 and loans and advances to customers which are Level 3. 

Fair value of transferred assets and associated liabilities 

Securitisation vehicles 
The sale of the beneficial ownership of the loans and advances to customers to the securitisation vehicles by the Bank fail the 
derecognition  criteria,  and  consequently,  these  loans  remain  on  the  statement  of  financial  position  of  the  Group.  The  Bank, 
therefore recognises a deemed loan financial liability on its statement of financial position and an equivalent deemed loan asset is 
held on the securitisation vehicle’s statement of financial position. As the securitisation vehicle is consolidated into the Group with 
the Bank, the deemed loans net out in the consolidated accounts. The deemed loans are repaid as and when principal repayments 
are made by customers against these transferred loans and advances. 

The securitisation vehicles have issued fixed and floating rate notes which are secured on loans and advances to customers. The 
notes are redeemable in part from time to time, such redemptions being limited to the net capital received from mortgagors in 
respect of the underlying assets. 

The Group retains substantially all of the risks and rewards of ownership. The Group benefits to the extent to which surplus income 
generated by the transferred mortgage portfolios exceeds the administration costs of these mortgages. The Group continues to 
bear the credit risk of these mortgage assets. 

The results of the securitisation vehicles listed in note 30 are consolidated into the results of the Group. The table below shows 
the carrying values and fair value of the assets transferred to the securitisation vehicles and its associated liabilities. The carrying 
values presented below are the carrying amounts recorded in the Group accounts. Some of the notes issued by the securitisation 
vehicles are held by the Group and as such are not shown in the consolidated statement of financial position of the Group. 

30 June 2021 

Oak No.2 PLC 

Oak No.3 PLC 

MotoMore Limited 

Turbo Finance 9 PLC 

Carrying amount of 
transferred assets not 
derecognised 
£m 
128.0 

Carrying amount of 
associated 
liabilities 
£m 
97.5 

Fair value of 
transferred assets 
not derecognised 
£m 
130.8 

Fair value of 
associated 
liabilities 
£m 
98.3 

215.7 

286.6 

516.3 

219.2 

250.2 

518.8 

220.3 

269.1 

532.8 

221.5 

250.4 

519.1 

Net position  
£m 
32.4 

(1.2) 

18.7 

13.7 

169 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
30 June 2020 

Oak No.2 PLC 

Oak No.3 PLC 

MotoMore Limited 

40. Country-by-Country 

Carrying amount of 
transferred assets not 
derecognised 
£m  
165.8 

Carrying amount of 
associated 
liabilities 
£m 
138.7 

Fair value of 
transferred assets 
not derecognised 
£m 
162.6 

343.2 

286.4 

323.7 

249.9 

334.1 

283.8 

Fair value of 
associated 
liabilities 
£m 
139.0 

323.8 

251.7 

Net position 
£m 
23.6 

10.4 

32.1 

The Capital Requirements (Country-by-Country reporting) Regulations came into effect on 1 January 2014 and introduce reporting 
obligations for institutions within the scope of the European Union’s Capital Requirements Directive (CRD IV). The requirements 
aim to give increased transparency regarding the activities of institutions.  

All companies consolidated within the Group’s financial statements are registered entities in England and Wales. Note 20 to these 
financial statements include an analysis of subsidiary undertakings and their principal activities. All of the subsidiary undertakings 
were incorporated in the UK. The Group did not receive any public subsidies. 

Total operating income 

Profit before tax 

Corporation tax (paid net of refunds received) 

Employees (average FTE equivalent) 

41. Post balance sheet events 

Jurisdiction 
income/expense 
arose 

Year ended  
30 June 2021  
£m 

Year ended  
30 June 2020  
£m 

UK 

UK 

UK 

UK 

470.9 

157.8 

(11.7) 

2,029 

412.1 

48.8 

(40.3) 

1,966 

On 29 July 2021, the Group successfully made an additional £200 million drawing on the Bank of England’s Term Funding Scheme 
with additional incentives for SMEs.  

170 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Company statement of financial position 
As at 30 June 2021 

30 June 2021 

30 June 2020 

Note 

£m 

£m 

Assets  

Investment in Group undertakings 

Investment in associated companies 

Amounts receivable from Group undertakings 

Total assets 

Liabilities 

Amounts payable to Group undertakings 

Subordinated notes 

Total liabilities 

Equity 

Share capital 

Share premium account 

Additional Tier 1 capital 

Capital redemption reserve 

Retained earnings 

Total equity 

Total liabilities and equity 

3 

5 

6 

7 

8 

9 

10 

515.6 

4.8 

361.7 

882.1 

23.4 

213.7 

237.1 

243.9 

74.4 

108.0 

0.1 

218.6 

645.0 

882.1 

The notes and information on pages 174 to 176 form part of these financial statements. 
Aldermore Group PLC profit for the year ended 30 June 2021 was £6.9 million (30 June 2020: profit of £11.9 million). 

These financial statements were approved by the Board and were signed on its behalf by: 

Steven Cooper 

Director 

14 September 2021 

Registered number: 06764335 

Claire Cordell 

Director 

14 September 2021 

465.6 

4.8 

411.3 

881.7 

21.3 

213.7 

235.0 

243.9 

74.4 

108.0 

0.1 

220.3 

646.7 

881.7 

171 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Company statement of cash flows 
For the year ended 30 June 2021 

Cash flows from operating activities 

Profit before taxation 

Decrease in operating liabilities 

Adjustments for non-cash items within the income statement 

Net cash flows generated from operating  activities 

Cash flows from investing activities 

Investment in Subsidiaries 

Disposal of investment in Subsidiaries 

Dividend income from associate 

Net cash used in investing activities 

Cash flows from financing activities 

Proceeds from deposit with Bank 

Interest received on subordinated loan 

Interest paid on subordinated notes 

Proceeds from issue of AT1 capital 

Redemption of AT1 capital 

Coupon paid on contingent convertible securities, net of tax 

Net cash received from financing activities 

Net increase/(decrease) in cash and cash equivalents 

Cash and cash equivalents at start of the year 

Movement during the year 

30 June 2021 

30 June 2020 

Note 

£m 

£m 

6.9 

- 

2.1 

9.0 

3 

(50.0) 

6 

6 

8 

10 

- 

- 

(50.0) 

49.6 

- 

- 

- 

- 

(8.6) 

41.0 

- 

- 

- 

11.9 

(0.1) 

0.5 

12.3 

(61.0) 

74.3 

0.4 

13.7 

- 

1.1 

(2.6) 

61.0 

(74.0) 

(12.4) 

(26.9) 

(0.9) 

0.9 

(0.9) 

172 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Company statement of changes in equity 
For the year ended June 2021 

Year ended 30 June 2021 

As at 1 July 2020 

Profit for the year 

Transactions with equity holders: 

- Coupon paid on contingent convertible securities  

As at 30 June 2021 

Year ended 30 June 2020 

As at 1 July 2019 

Profit for the year 

Transactions with equity holders: 

- Issuance of Additional Tier 1 capital 

- Redemption of Additional Tier 1 capital 

- Coupon paid on contingent convertible securities  

As at 30 June 2020 

Share 
Capital 

Share 
premium 
account 

Additional 
Tier 1 
Capital 

Capital 
redemption 
reserve 

Retained 
earnings 

£m 

£m 

£m 

£m 

£m 

Total 

£m 

243.9 

74.4 

108.0 

0.1 

220.3 

646.7 

- 

- 

- 

- 

- 

- 

- 

- 

6.9 

6.9 

(8.6) 

(8.6) 

243.9 

74.4 

108.0 

0.1 

218.6 

645.0 

243.9 

74.4 

121.0 

0.1 

221.8 

661.2 

- 

- 

- 

- 

- 

- 

- 

- 

- 

61.0 

(74.0) 

- 

- 

- 

- 

- 

11.9 

11.9 

- 

61.0 

(1.0) 

(75.0) 

(12.4) 

(12.4) 

243.9 

74.4 

108.0 

0.1 

220.3 

646.7 

173 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Company financial statements 

1. Basis of preparation 

a) Accounting basis 

These  standalone  financial  statements  for  Aldermore  Group  PLC  (the  “Company”)  have  been  prepared  and  approved  by  the 
Directors  in  accordance  with  International  Financial  Reporting  Standards  (“IFRSs”)  as  issued  by  the  International  Accounting 
Standards  Board  (“IASB”)  and  the  UK  adopted  IFRS.  The  significant  accounting  policies  adopted  are  set  out  in  note  2  to  the 
consolidated financial statements. 

b) Going concern 

As  detailed  in  note  1(c)  to  the  consolidated  financial  statements,  the  Directors  have  performed  an  assessment  of  the 
appropriateness of the going concern basis. The Directors consider that it is appropriate to continue to adopt the going concern 
basis in preparing the financial statements. 

c) Income statement 

Under Section 408 of the Companies Act 2006 the Company is exempt from the requirement to present its own income statement. 

2. Net profit attributable to equity shareholders of the Company 

Net profit attributable to equity shareholders of the Company 

3. Investment in Group undertakings 

As at 1 July 

Capital injection - Preference share capital (note 6) 

Issuance of Additional Tier 1 Capital 

Redemption of Additional Tier 1 Capital 

As at Year End  

As at 30 June 2021, £nil investments (30 June 2020: £nil) were classified as impaired. 

Year ended  
30 June 2021 
£m 
6.9 

Year ended  
30 June 2020 
£m 
11.9 

30 June 2021 
£m 
465.6 

50.0 

- 

- 

515.6 

30 June 2020 
£m 
478.9 

- 

61.0 

(74.3) 

465.6 

Investment in subsidiaries 

The Company owns 100.0% of the issued share capital of Aldermore Bank PLC, which is a registered bank, and 100.0% of MotoNovo 
Finance  Limited,  a  company  engaged  in  motor  finance.  Details  of  subsidiary  undertakings  are  provided  in  note  20  to  the 
consolidated financial statements. All the companies listed in note 38 to the consolidated financial statements are related parties 
to the Company. 

174 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Additional Tier 1 Perpetual Loan 

On 9 December 2014, the Company issued £75.0 million Fixed Rate Reset Additional Tier 1 Perpetual Subordinated Contingent 
Convertible  Securities  that  is  repayable  at  the  option  of  Aldermore  Bank  PLC.  Net  proceeds  arising  from  the  issuance,  after 
deducting issuance costs and the associated tax credit, totalled £74.0 million. Interest was payable on the Securities annually in 
arrears  on  each  interest  payment  date,  commencing  on  30  April  2015  and  was  non-cumulative.  The  loan  was  classified as  an 
investment in a subsidiary undertaking and was carried at cost in accordance with IAS 27. The Redemption of the Securities took 
place on 30 April 2020 and was at the option of Aldermore Bank PLC, the Company thus received the £75.0 million on redemption.  

Perpetual subordinated capital notes 

On 29 April 2020, the Company issued £61.0 million of Perpetual Subordinated Capital Notes to FirstRand Bank Limited, a fellow 
subsidiary of FirstRand Limited. Simultaneously, the Company made a perpetual loan to Aldermore Bank PLC of £61.0 million. The 
capital loan is non-cumulative and redeemable at the option of Aldermore Bank PLC. The loan was classified as an investment in a 
subsidiary undertaking and is carried at cost in accordance with IAS 27. 

4. Related party transactions 
Details of related party transactions of the Company are provided in note 38 to the consolidated financial statements. 

5. Investment in associated companies 

Investment in AFS Group Holdings Limited 

6. Amounts receivable from Group undertakings 

Subordinated loan to Aldermore Bank PLC 

Deposit with Aldermore Bank PLC 

30 June 2021 
£m 

30 June 2020 
£m 

4.8 

4.8 

4.8 

4.8 

30 June 2021 
£m 
161.4 

200.3 

361.7 

30 June 2020 
£m 
161.4 

249.9 

411.3 

On the 28 October 2016 and 22 November 2018, the Company made a £60.0 million and £100.0 million subordinated 8.5% and 
4.9% loans respectively to Aldermore Bank PLC, repayable in 2026 and 2028, with an option for the Bank to redeem after five years. 
The interest rates are fixed until October 2021 and November 2023 respectively. The loans are carried in the statement of financial 
position at amortised cost.  

A £150.0 million deposit placed with Aldermore Bank PLC from the Group pays interest of 1.6% above SONIA on the outstanding 
balance. The interest is paid semi-annually. 

The Group placed £52.0 million and £47.0 million of deposits with Aldermore Bank PLC with interest of 2.5% and 2.3% fixed rate 
on the outstanding balances. The interest is paid semi-annually. 

On the 8th September 2020 MotoNovo Finance issued unsecured, non-voting, cumulative, redeemable preference shares of £50.0 
million to Group. Group funded the preference shares through the partial withdrawal of the deposit with Bank. 

175 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7. Amounts payable to Group undertakings 

Intercompany loans from Aldermore Bank PLC 

30 June 2021 
£m 
23.4 

23.4 

30 June 2020 
£m 
21.3 

21.3 

Amounts payable to Aldermore Bank PLC carry interest of between 1.0 - 1.3% per annum above LIBOR charged on the outstanding loan balances.   

8. Subordinated notes 

Subordinated notes  

30 June 2021 
£m 

213.7 

30 June 2020 
£m 

213.7 

Details of subordinated notes issued by the Company are provided in note 31 to the consolidated financial statements. 

9. Share capital 

Details of  share capital  and the share premium  account of the Company  are provided  in note 33 to the  consolidated  financial 
statements. 

10. Additional Tier 1 capital 

Details of the Additional Tier 1 capital issued by the Company are provided in note 35 to the consolidated financial statements. 

11. Risk management 

Through its Risk Management Framework, the Group is responsible for determining its principal risks, and the level of acceptable 
risks, as stipulated in the Group’s risk appetite statement, thus ensuring that there is an adequate system of risk management so 
that the levels of capital and liquidity held are consistent with the risk profile of the business. 

The risk management  disclosures  of  the  Group  on  page 57  apply  to  the  Company  where  relevant  and  therefore  no  additional 
disclosures are included in this note. 

12. Fair value of financial assets and liabilities 

The Directors consider that the fair value of its financial assets and liabilities, apart from its investments in Group undertakings and 
associates, are approximately equal to their carrying value. Accordingly no further disclosures in respect of fair values are provided. 
The investments  in  Aldermore Bank  PLC,  MotoNovo  Finance  Limited  and  in  AFS  Group  Holdings  Limited  are  considered  to be 
greater than the carrying value.  

13. Controlling party information 

Details of controlling party information of the Company are provided in note 38 to the consolidated financial statements. 

14. Post balance sheet events 

The directors are not aware of any material events that have occurred between the date of the statement of financial position and 
the date of this report. 

176