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Athelney Trust Plc

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FY2018 Annual Report · Athelney Trust Plc
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fLders  

Annual Report 

for the year ended 31 December 2018 

COMPANY NUMBER: 02933559 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Athelney Trust plc 

CONTENTS 

Directors of the Company 

Strategic Report including: 
Chairman’s Statement and Business Review 
Fund Managers Report 
Investment and Portfolio Analysis 
Portfolio Breakdown by Sector and by Index 
Business Model and Other Statutory Information 

Corporate Governance Statement 

Report of the Directors 

Statement of Directors’ Responsibilities 

Directors’ Remuneration Report 

Independent Auditors’ Report 

Income Statement 

Statement of Changes in Equity 

Statement of Financial Position 

Statement of Cash Flows 

Notes to the Financial Statements 

Officers and Financial Advisers 

Notice of Annual General Meeting 

Form of Proxy and Notes 

 1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors of the Company 

Frank Ashton (Executive Chairman) 

Frank Ashton, aged 57, is a highly experienced senior manager and independent management consultant. After leaving 
Cambridge University with a Natural Sciences  degree  (Metallurgy & Materials  Science), he  spent much  of his  career 
providing  independent  management  advice  to  companies  in  a  wide  variety  of  sectors.  With  15  years  spent  at 
PricewaterhouseCoopers  and  KPMG  (Operational  Due  Diligence)  and  5  years  working  in  Strategy  and  M&A  for 
Cummins Inc,  he  has a proven track  record  in shareholder  value creation and governance,  in providing strategic and 
operational advice to both  public  and  private companies  in  Europe and USA, as  well as working at a policy level for 
Government entities. 

David Lawman (Non-executive Director) 

David Lawman aged 70 years has been associated with the London Stock Market since 1969. During that period, he has 
been actively involved in analytical research and marketing of smaller companies at medium sized agency brokers such as 
Sheppards  and  Chase,  Seymour  Pierce,  Williams  de  Broe  and  latterly  at  Daniel  Stewart.  He  has  helped  to  establish 
successful corporate broking businesses which has involved him in both floating smaller companies on AIM and raising 
equity finance for corporate clients thereby establishing a contact list of most small cap fund managers. He is a Liveryman 
with the Worshipful Company of Coach Makers and Coach Harness Makers and a Fellow of the Chartered Institute for 
Securities and Investment. 

Helen Sachdev (Non-executive Director) 

Helen Sachdev, aged 53, is currently Non-Executive Director and Audit Chair of Loughborough Building Society, and 
was Non-Executive Director of Communisis plc, the leading provider of personalised customer communication services, 
until its acquisition in December 2018. Helen is also currently a Director with the coaching consultancy, WOMBA. 

Helen is a Fellow of the Chartered Institute of Management Accountants and has a BA (Hons) in Retail Marketing from 
Manchester Metropolitan University. Helen brings a wealth of experience as a non-executive director, underpinned by 
extensive blue chip executive experience having worked in senior positions at Barclays plc, Tesco and Sainsbury’s, and 
she has a proven track record of operational expertise, corporate development and strategy implementation. 

 2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 

Chairman’s Statement  
Stabilise the Company in readiness for Growth 

Overview 

Given the challenging markets and various Board developments within Athelney Trust plc (the ‘Company’ or 
the ‘Trust’) over the past months, it is perhaps not surprising to have to report mixed results for the Company 
in the year ended 31 December 2018.  The key points are as follows: 

 

Investment performance as measured by Net Asset Value (NAV) total return, which is the change in 
NAV plus the dividend paid, was minus 17.6% (2017: plus 16.8%) 

  Audited NAV was 225.9p per share (2017: 284.8p) - a decline of 20.7% 
  Revenue return per ordinary share was 9.9p (2017: 9.6p), an increase of 3.1% 
  Board/major shareholder disagreements led to approximately £90,000 extra cost (£40,000 pre year 
end and £50,000 post year end), ongoing distraction for the Board and general shareholder uncertainty 
– more of this would be unsustainable, especially for a fund of this size 

  Recommended final dividend of 9.1p per share (2017: 8.9p) an increase of 2.2% 
  The Fund Manager (and then Managing Director), Dr Manny Pohl volunteered in December 2018 to 

reduce his salary by 0.25% to 0.75% starting from January 2019 

  Long term performance represented by the 10 year Total Shareholder Return lags both FTSE SmallCap Index 

and AIM All-Share Index (see graph on page 37) 

Board and Governance 
The  Board  places  significant  importance  on  corporate  governance  and  compliance  with  the  AIC  and  UK 
Corporate Governance Codes.  Full details are set out in the Corporate Governance section of our Annual 
Report and Accounts on pages 20 to 29. 

An Independent Board - Update 
There were a lot of movements including five directors who came off the Board, another five who came on and 
two reshuffles over the last six months.  Details of the various Board changes are on page 31. The directors in 
place at the time of signing these accounts are: 

  Myself, Frank Ashton – Executive Chairman 
  Helen Sachdev – Non-Executive Director, Chair of Audit Committee 
  David Lawman – Non-Executive Director  

We now have three directors who together make up an independent Board.  On 8 February 2019 I took over 
the role of Chairman from David Lawman.  To the best of my knowledge, like Helen Sachdev, I have no current 
or prior connection with any major shareholder of the Company and maintain I am an independent Chairman.   

I  am  also  Executive  Chairman.    Both  roles  being  undertaken  by  one  person  is  not  compliant  with  the  UK 
Corporate Governance Code. However after full consideration by the Board it is deemed appropriate at this 
critical time for the Company. A detailed explanation of the non-compliant position is available in the Corporate 
Governance section. 

I believe the Board has created and is now implementing a plan that reflects Robin Boyle’s long-held vision and 
ambition for the Company, which he founded 24 years ago.  Further details can be found on pages 6 to 8. 

 3 

 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 

Chairman’s Statement  
Stabilise the Company in readiness for Growth 

Capital Gains 
During the year the Company realised capital profits before expenses arising on the sale of investments in the 
sum of £98,840 (31 December 2017: £296,629). 

Portfolio Review 
Holdings of Belvoir Lettings, Clarke T, Dairy Crest, Hansteen Holdings, Paypoint, Real Estate Investors and Rightmove 
were all purchased for the first time.  Additional holdings of Braemar Shipping, Cineworld, Epwin, Ibstock, Jarvis 
Securities, Marstons, VP and XP Power were also acquired. Connect Group, Debenhams, DX Group, Countrywide, GVC, 
Juridica, Low & Bonar, Safestyle, Slingsby, Sprue Aegis, Standard Life and UK Commercial were sold. Nine holdings 
were top-sliced to provide capital for the new purchases. 

Corporate Activity 
The holding of Communisis was taken over at a capital profit of 152.8%.  

Dividend 
The Board is pleased to recommend an increased annual dividend of 9.1p per ordinary share (2017: 8.9p). This 
represents an increase of 2.2% over the previous year. Subject to shareholder approval at the Annual General 
Meeting on 3 April 2019, the dividend will be paid on 18 April 2019 to shareholders on the register on 22 
March 2019. 

Summary 

  As Chairman, I am pleased that we now have an independent board in place to set up and oversee the 
transition to growth – creating shareholder value for all, managing costs and risk.  We are now in a 
period of stability, which is essential as a precursor to growth 

  We believe the optimum size for the fund will be between £50m and £150m.  At this size we will 

have: 
- 
Sufficient fund management capacity and skills to uncover and maximise potential opportunities  
-  The ability to consistently deliver superior performance, driven by the right targets and measures 
-  Reduced risk of breaching the Chapter 3 regulation (five shareholders owning more than 50% of 
the Company) that would result in temporarily losing Investment Trust and tax exempt status 
-  An opportunity to reduce the Ongoing Charge percentage to match or better our peer group 
  We are in the process of confirming a Fund Management team that in our judgement, will have the 
necessary  skills  and  processes  in  place  to  identify  and  realise  value-enhancing  investment 
opportunities, at lower relative risk 

  We will continue to balance the need to manage costs and also ensure  the Company and fund are 

supported with appropriate resources now and in the longer term  

 4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 

Chairman’s Statement  
Stabilise the Company in readiness for Growth 

Outlook 
The world and UK markets have recovered since the start of 2019 (FTSE 100 Index rose over 6% from 31 
December 2018 to 1 March 2019).  I am very pleased to report that along with this improvement, and with the 
active support of Dr Manny Pohl the Fund Manager, the Company’s NAV has also recovered from 225.9p per 
share at 31 December 2018 to 235.9p per share (unaudited) at 28 February 2019, an increase of 4.4%.  

The February change in NAV was 1.07%, the second monthly increase in a row, outperforming the SmallCap 
Index (0.90%) as well as the AIM All-share Index (-0.88%). The share price on 28 February 2019 was 225p, 
trading  at  a  discount  of  4.84%,  a  substantial  improvement  on  the  position  just  after  the  shareholder 
requisitioned General Meeting (GM) when the discount briefly increased to more than 20%.  This is the point 
I joined the board.  Ever since the GM, we appear and are more stable; this report will address a number of 
basic shareholder questions about the near and medium-term future stability, including recommended dividend 
and management plan, that should reduce uncertainty. 

Externally, uncertainties continue for a UK small-cap fund.   

Brexit rumbles on, struggling between the need for a political outcome that reflects the balanced voting 52:48 
in  the  referendum,  and  the  realities  of  negotiation  between  two  sides  with  a  lot  to  lose,  economically  and 
politically – the UK government and remaining 27 member states of the EU.  How or even when this will end 
is still uncertain.  The manner of Brexit, whatever it is, and also developments on the global stage will impact 
the economy and sterling in the short term; we invest for the longer term in quality stocks and are mindful of 
opportunities that arise as a result in the shorter term. 

The US economy is unlikely to repeat its 2018 outperformance and  Washington’s more hostile approach to 
trade  is  a  driver  of  convergence  of  larger  developed  economies’  growth  and  a  thorn  for  the  UK’s  trade 
negotiators post Brexit.  More protectionism and continued uncertainty has already translated to companies 
deferring investment or freezing recruitment, and there are signs global companies will  move capacity away 
from the UK over time. 

We are watching these market trends closely to see which Company plans, if any, need to change as the market 
cycle continues – there will be turbulence, but we are here for the long term. 

We are excited to see the prospect of a new-look Athelney Trust on the horizon.  We must continue to deliver 
to all shareholders a period of stability and solid performance as well as listen to their feedback and needs, then 
using that information, build an even stronger future. 

So far our listening and analysis has produced the following common ground:  The Trust has a history of good 
results, but recent events also show it is vulnerable, because of its size and pattern of shareholding.  Many would 
like to see it grow, and at least some see the advantage of external Fund Management in that regard.  Dividends 
are progressive but some criticise total shareholder returns over the long term and also the fund’s size. 

 5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 

Chairman’s Statement  

Stabilise the Company in readiness for Growth 

The conditions need to be right – right to convince existing shareholders that growth is possible (because the 
Company is once again stable over a period of months at least) and then right to attract new shareholders over 
time.  The benefits from our plan to Stabilise and Grow are set out in Figure 1 below. 

 Figure 1 - The Board's Plan to Stabilise and Grow the Company and Fund 

I believe we now have the right elements in place, and a process and plan to unite them, so that the foundations 
for ‘Readiness to Grow’ are in place.  Shareholder support for continuation with this plan will be sought at the 
AGM. 

The plan’s foundations are: 

1.  A carefully reviewed and confirmed mandate, with continued focus in the small/mid-cap territory 
2.  A  Fund  Management  team  capable  of  delivering  significant  benefits  realised  from  an  optimal  size 

(around £100m total assets) 

3.  A fund which is large enough to attract  further investors and reduce the risks of accidentally losing 

investment trust status 

4.  Realising a larger fund allows us to reduce the Ongoing Charge percentage as well as attract, retain the 

best resources 

 6 

 
 
 
 
 
 
  
 
 
Athelney Trust plc 

Strategic Report 

Chairman’s Statement  

Stabilise the Company in readiness for Growth 

We appreciate the hard-working contribution of Dr Manny Pohl, the current Fund Manager and second largest 
shareholder (17.6%) and continue to discuss his role. 

We are grateful for the support and interest shown by Gresham House Asset Management (Gresham House).  
Since December 2018 Gresham House has worked hard with Robin Boyle, the largest shareholder (20.8%) to 
set up an ‘externally-managed Fund’ option for the Company.  Robin founded the Company 24 years ago and 
until last September was Managing Director and Fund Manager.  Now, as he considers the future, he wants to 
help realise the most attractive, sustainable future possible for Athelney Trust.  Those of Robin’s friends and 
family who are also shareholders and have been contacted, agree with our initial assessment that Gresham House 
appears to be a very attractive route to preserve and grow shareholder value. 

I believe, along with my colleagues, that although Dr Manny Pohl has investment success through ECP Asset 
Management, when it comes to maximising shareholder value, the Gresham House option represents a strong 
alternative as it has the following features; 

  More investment management capacity from existing, proven skills and experience in UK small- and 
mid-cap companies – not just from Robin Boyle who would be a consultant to Gresham House but also 
Investment Manager Laurence Hulse, his manager Ken Wotton and the wider team of Gresham House.  
These UK-based segments are where the undervalued companies are and this team has the capacity to 
find and realise value for shareholders, now and in the future when the fund has grown 

  More due diligence face-face with the management team – which often produces invaluable insights 
otherwise  not  available  at  any  price.    In  my  own  experience  of  due  diligence  and  work  with 
management  teams  of  all  sizes,  personal  visits  always  give  a  clearer  view  of  management,  their 
processes, culture and aspirations that aids making better investment management decisions.  ‘In person 
due diligence’ has always been central to Robin Boyle’s process and this is also true of Gresham House 
  A route for Robin Boyle’s knowledge, insights and investment process to be teamed with Gresham 
House’s compatible value-based structure and conviction scoring.  This teamwork and parallel working 
can  be  co-located  in  Gresham  House’s  London  office,  allowing  the  most  effective  transition  and 
succession plan for Robin Boyle’s knowledge over time.  Robin would work closely with Laurence 
Hulse, Investment Manager at Gresham House, from the start; they already speak highly of each other 
from their work to date 

  A great opportunity to use Gresham House’s proven ability to grow in the UK market, as well as select 
from  a  choice  of  mandates,  used  successfully  by  them  –  the  existing  Gresham  House  culture, 
management style and portfolio structure fits well with our Company 

Finally we believe a move to a ‘Gresham House with Robin Boyle’ Fund Management option, could happen 
quickly after the AGM, with low risk and limited cost to Athelney and its shareholders, so that free cash flows 
over time can be quickly optimised.  At the moment, given Dr Manny Pohl’s resolutions that, if carried, would 
re-shuffle  the  Board  once  again,  we  are  blocked  from  committing  the  Company  to  further  contracts,  and 
therefore unable to proceed more quickly. 

 7 

 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 

Chairman’s Statement  

Stabilise the Company in readiness for Growth 

We will use the time up to the AGM to complete our review of the options available to the Company, and to 
determine the best option for shareholders. 

We have a particularly important AGM this year.  Given the resolutions presented, shareholders have a clear 
choice to determine the future direction and prospects for the Company. 

Some resolutions are the usual and expected ones, including those to re-elect myself and Helen Sachdev (new 
directors appointed since the last AGM, not voted on to the Board by shareholders).   

Others, requisitioned by Dr Manny Pohl, if carried, return himself and Simon Moore to the Board and vote 
David Lawman off, almost perfectly reversing the result of the GM held a month ago.  We believe this returns 
shareholders to the conditions of late 2018, and will introduce further uncertainty and delay.  

We, the current Board of Directors, have quickly created an effective and proactive working relationship.  We 
are  in  the  process  of  stabilising  the  Company  by  doing  what  all  directors  must:  Listen  to  the  needs  of  all 
shareholders, explore all options to create shareholder value and carry out our fiduciary duties in a collaborative 
way that embodies the AIC Code of Governance.   

Compared to our plan we believe the implied direction from the Dr Manny Pohl resolutions represents less 
shareholder value, and carry the prospect of continued instability and we therefore recommend you vote against 
his resolutions. 

We believe the current Board has understood the current position quickly and selected the plan that we are 
confident is best for shareholders and the future of the Company.  

We look forward to a good relationship with existing and future shareholders, and with the right management 
team in place, are confident in the prospects for Athelney Trust PLC. 

Frank Ashes

Frank Ashton 
Executive Chairman 
4 March 2019 

 8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Fund Manager’s Review of 2018 
Delivering Steady Performance in a Difficult Market 

2018 in Review 
The 2018 calendar year began with strong growth across many global economies, however, the wheels began 
to fall off quickly, with growth trajectories diverging. After two years of steady growth in asset prices, the 
13.7% fall in the MSCI World Index in the last three months of 2018 means global stocks produced their worst 
quarterly performance in seven years leading to a decline of 10.4% for the full year. In comparison, the FTSE 
performed slightly better during the quarter, declining by only 10.4% to close 12.5% down for the full financial 
year.  

Since the Global Financial Crisis (GFC), equities have been  a major beneficiary of the low-interest rate and 
loose monetary policy environment. Companies have been able to borrow money cheaply to strengthen their 
balance sheets while also benefiting from a pick-up in demand as the global economy recovered. Low-interest 
rates have driven down the yield on other asset classes such as bonds, with UK government bonds yielding 
around 1.3% compared with the FTSE All Share Index which yields approximately 4.0%.  Now that UK and 
US interest rates have each risen by 0.25% in late 2018, markets have recovered well. 

The year of 2018 saw disappointing market returns and higher correlation between asset classes. For many, the 
geopolitical  risks  around  the  global  have  presented  investors  with  an  uncertain  future  with  a  poor  growth 
outlook. 

Investment Philosophy 
As a survivor of the stock market crash in 1987 and the GFC in 2008, I have learned the importance of having 
the courage to stand true to core values when approaching investments and be willing to source conviction from 
within.  When  times  get  tough,  the  delineation  between  facts  and  feelings  is  blurred  and  having  a  high 
conviction, based on a core philosophy, helps us move through these turbulent and traumatic snapshots in time. 
I have found that when the dust settles, and we look back on these events, there is quite a thrilling tale; but only 
for those who stood by their convictions.  

At the core of my values is the belief that the underlying economics of a business drives its long-term returns. 
Companies who are growing their economic footprint (profitably) are generally better investment opportunities 
than those that aren't.  I would rather invest in a smaller number of companies which I understand well than a 
large number of companies of which I have only a cursory understanding. As a custodian of other people’s 
money, I owe it to those who have invested alongside us to allocate their capital to opportunities that I believe 
will produce the best return for shareholders.   

As a high-conviction, quality-growth manager that invests for the long-term, my promise ensures that: 1 - I will 
never speculate to generate returns; 2- I buy for the long-term and do not see myself as a trader; and, 3 - I do 
not diversify to cover up for poor due diligence.   

 9 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Fund Manager’s Review of 2018 

Delivering Steady Performance in a Difficult Market 

Our Task 
My  task  begins  with  the  mandate  of  Athelney  Trust  –  to  provide  shareholders  with  prospects  of  long-term 
capital growth in quality small-cap companies, while maintaining a progressive dividend record. With this in 
mind, the first task when taking over the portfolio was to consolidate the holdings and divest of poor-quality 
companies,  without  jeopardising  the  progressive  annual  dividend.  My  portfolio  review  identified  several 
investments with lacklustre long-term growth prospects, with some investments where the business model is 
under serious threat.  

The  request  for  a  GM  presented  some  uncertainty  for  our  Company  and  meant  I  ceased  making  further 
wholesale changes to the portfolio in the event that fund management would revert back to Robin Boyle.  

With the GM behind us, I will continue to deliver superior returns for shareholders. Note, I will remain mindful 
that  our  investment  turnover  should  remain  low  while aiming  to  have  no  more than  fifty  companies  in  the 
portfolio. Further, I am pleased to report that the Company realised capital profits before expenses arising from 
the sale of investments in the sum of £98,840 (31 December 2017: £296,629). 

Redefining Active Investing 
While the active versus passive debate continues, and while the focus of the industry has been on the fees paid 
rather than on the returns generated, the more compelling issue which needs to be addressed is, in fact, manager 
skill in picking quality investments rather than having a broad portfolio and replicating an index.  In all of this, 
the acid test is longer-term investment performance and the only way to grow sustainable wealth that is resilient 
through time is to invest money in a careful, considered and committed way.  I adhere to an Active Investing 
approach and believe that it requires: 

I.  Forensic Research: Considerable factors need to line up before I invest in a business.  For example, a 
sound business strategy that is contextually relevant to the markets they operate.  A durable business 
model with a Sustainable Competitive Advantage (SCA) that management has previously demonstrated 
a strong competency of execution.  

II.  Understanding Potential, not just Performance: I believe it’s important to understand both the narrative of 
an investment and the numbers that support it. Investing on the narrative alone ignores reality; and 
investing in numbers alone, ignores potential.  I marry the two together so that we can best capture the 
long-term potential while ensuring that we pay a fair price. 

III.  Being Highly Engaged with Portfolio Companies: To make high conviction investment decisions and to maintain these 
over the long-term requires deep understanding and a lot of time and attention.  It means I need to think about 
investing as an owner, and not a share trader.  As a result, I only have time for our best ideas, and we continue 
to monitor and assess these through collaborative and discursive practices 

. 

 10 

 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Fund Manager’s Review of 2018 

Delivering Steady Performance in a Difficult Market 

Environmental, Social and Governance Considerations 
In  more  recent  times,  investment  management  is  more  than  merely  generating  performance  in  excess  of  a 
benchmark.  While that is a core part of a mandate, there are other very important qualitative issues that are 
central to what should be done.  For example, one should recognise that capital allocation is a vehicle through 
which to drive change.  I have the opportunity to demand specific standards of corporate governance, decide 
whether specific social and ethical issues are acceptable and, if they are not, I vote with my feet.   

For me, the integrity and credibility of any management team is a founding principle to our investment process.  
I need to trust that management have the best interests for all stakeholders, and I have faith that they will make 
sound strategic decisions and have strong experience and capabilities in their chosen field.  As custodians of 
shareholders’ capital, we have an obligation to ensure that we are doing whatever we can to preserve capital 
and grow it over time.  I allocate capital to investments which are sustainable in the long-term, and finding 
trustworthy, values-based management that align with my core values and beliefs that will ensure above-average 
economic portfolio returns. 

Recent Additions 
Since taking over the management of the  portfolio I added only one position: Rightmove Plc (LSE: RMV). 
Rightmove has been able to ride the paradigm shift from papers to online. Its principal business is their website 
(www.rightmove.co.uk) where its customers - estate agents, rental agents and new home developers - pay fees 
to have their properties displayed on the website, which provides home hunters with property details to search. 
The business competes for classified property advertising and has seen impressive growth. Rightmove’s success 
means it is now a household name; and its opportunity ahead remains large, particularly compared to the other 
online pure-plays.  

Update 
The unaudited NAV on 28 February 2019 was 235.9p per share – up 1.07%, the second monthly increase in a 
row and beating the SmallCap Index (0.90%) as well as AIM All-share Index (-0.88%). The share price on the 
same day was 225p (trading at a discount of 4.84%).  Further updates can be found at www.athelneytrust.co.uk  

 11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Fund Manager’s Review of 2018 
Delivering Steady Performance in a Difficult Market 

Prospects 
To  this end,  I  will  continue  to  consolidate  the  REIT and  property  exposure  into  names  that  have a  limited 
exposure to retail and display the ability to grow their dividend over time. For any new additions, I will ensure 
that the investments fit within our investment philosophy, while adhering to the Company Mandate. The key 
attributes that will define my investments are: 

I.  Organic Sales Growth: Quality franchises organically growing sales above GDP and can do so (sustainably) 
because they have a large, growing market opportunity and compelling competitive advantage which 
will drive ongoing market share gains. 

II.  A  Proven  Track  Record:  This  encompasses  both  the  management’s  capability  and  the  strength  of  the 
business’  model.  Generally,  a  firm  that  delivers  a  ROE  >  15%  (consistently)  indicates  a  Quality 
Franchise.  Our  investment  philosophy  is  built  on  the  belief  that  a  stock’s  long-term  return  to 
shareholders is driven by the return on capital of the underlying business. Our view is that long-term 
investors are backing a management team and a business model. Management are the key decision-
makers regarding the company’s strategy and its competitive position in the marketplace. 

III.  Company's future profits: It is critical that I have confidence in their ability to execute even in a tough 

environment like the current Brexit conundrum.  

IV. Low Leverage: I require investments to operate with low levels of debt, which ensure that they have 
sufficient  resources  to  execute  on  its  strategy.  For  me,  an  Interest  Coverage  above  4x  provides 
sufficient bandwidth in times of economic trouble. As a long-term investor, capital preservation is my 
highest  priority.  There  is  nothing  that  changes  a  management  team’s  focus  toward  the  short  term 
quicker than an upcoming debt refinance when market conditions suddenly change. We need to be 
comfortable that this will not happen and that the company has a strong enough balance sheet so that it 
will retain optionality and can easily execute its strategy over the long-term.  

For me, investment discipline is a prerequisite for success, and I am going to ensure a consistent approach to 
investments during this uncertain time.  

Dr Manny Pohl 
Fund Manager 
4 March 2019 

 12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 SECTOR 
 £  
46,970 

% 

1.0% 

333,368 
62,850 

7.2% 
1.4% 

108,049 

2.3% 

693,324 
39,360 

14.9% 
0.8% 

181,430 

3.9% 

187,810 

4.0% 

68,985 
136,575 

1.5% 
2.9% 

290,398 

6.2% 

Athelney Trust plc 

Investment and Portfolio Analysis at 31 December 2018 

Stock 

 Holding  

 Value (£) 

Chemicals 
Construction & materials 

Electronic & electrical equipment 
Food & beverages 

General financial  

Home construction 
Industrial engineering 

Industrial transportation 

Insurance 

Leisure goods 
Media 

Property, commercial & 
residential 

11,000 
14,666 
55,000 
50,000 
40,000 
15,500 
30,000 
3,000 
10,000 
19,000 
8,000 
500 
35,714 
27,000 
15,000 
140,000 
40,000 
150,000 
22,500 
4,000 
15,000 
12,000 
2,000 
7,000 
4,000 
30,000 
3,000 
6,500 
16,000 
30,000 
4,500 
2,000 
40,000 
16,000 
50,000 
42,500 
2,000 
32,500 
45,000 
65,000 
85,000 
135,000 
40,000 
45,000 
50,000 
52,500 
11,000 
32,500 
1,500 
13,000 
175,000 
90,000 
50,000 
89,000 
50,000 

46,970 
46,198 
47,740 
36,200 
89,400 
54,250 
59,580 
62,850 
42,200 
33,849 
32,000 
52,750 
77,499 
124,200 
44,265 
101,500 
65,600 
46,950 
50,625 
84,800 
45,135 
39,360 
50,000 
83,930 
47,500 
60,450 
51,960 
75,400 
55,200 
13,785 
136,575 
36,800 
43,000 
46,080 
36,500 
28,008 
8,644 
57,931 
33,435 
57,850 
73,950 
37,125 
46,480 
41,400 
46,300 
59,588 
44,000 
56,518 
138,000 
40,820 
148,925 
44,280 
46,200 
50,819 
52,750 

Treatt 
Costain Group 
Clarke T 
Epwin Group 
Forterra 
Heath (Samuel) & Sons 
Ibstock 
XP Power  
Dairy Crest 
Greencore Group 
Wynnstay Group 
Camellia 
Charles Taylor 
Jarvis Securities 
Jupiter Fund Management 
Park Group 
Randall & Quilter Investment Holdings 
Record 
River & Mercantile Group 
S & U 
TP ICAP 
Crest Nicholson 
Goodwin 
Hill & Smith 
Vitec 
Braemar Shipping Services 
Fisher (James) 
Ocean Wilsons 
Chesnara 
Hansard Global 
Games Workshop 
4Imprint 
Huntsworth 
M&C Saatchi  
Quarto Group Inc Com 
Reach 
Rightmove 
Wilmington 
XLmedia 
AEW UK REIT 
Belvoir Lettings 
Capital & Regional 
Custodian REIT 
F & C UK Real Estate Investments 
Hansteen Holdings 
Harworth Group 
Lok’n Store Group 
London Metric Property 
Mountview Estates 
Palace Capital 
Picton Property Income 
Real Estate Investments 
Regional REIT Ltd 
Schroder Real Estate Investment Trust 
Schroder European Real Estate 

 13 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Investment and Portfolio Analysis at 31 December 2018 

Stock 

 Holding  

 Value (£) 

 SECTOR  
 £  

% 

Property, commercial & 
residential (continued) 

Retailers 

Support services 

Target Healthcare 
The PRS REIT 
Town Centre Securities 
Tritax Big Box 

McColls Retail Group 

Andrew Sykes Group 
Begbies Traynor 
Biffa 
Gattaca  
Kin & Carta 
Latham (James) 
Menzies (John) 
Murgitroyd 
NWF Group 
Paypoint 
Safecharge International 
Vianet Group 
VP 

Telecommunications 

KCOM Group 

Travel & leisure 

Air Partner 
Cineworld 
Greene King 
Hostelworld 
Marstons 
Photo-Me 

100,000 
50,000 
27,500 
60,000 

35,000 

19,500 
80,000 
25,000 
21,500 
37,500 
5,500 
9,500 
12,500 
35,000 
5,000 
20,000 
50,000 
19,000 

56,000 

112,500 
37,500 
10,000 
22,500 
80,000 
32,500 

107,500 
47,100 
56,650 
78,720 

19,355 

92,040 
52,640 
48,900 
22,253 
36,225 
34,375 
48,545 
56,250 
54,950 
40,400 
46,000 
50,500 
186,580 

40,824 

93,374 
98,625 
52,780 
45,338 
75,200 
28,990 

1,274,975 

19,355 

27.5% 

0.4% 

769,658 

40,824 

16.6% 

0.9% 

394,307 

8.5% 

Portfolio Value 

Net Current Assets 

TOTAL VALUE 

Shares in issue 

£4,648,238 

£225,415 

£4,873,653 

2,157,881 

Audited NAV 

225.9p 

 14 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Portfolio Breakdown by Sector and Index 

Portfolio by Sectors

1.0% Chemicals

7.2% Construction 
materials

8.5% Travel & leisure

0.9% 
Telecommunications

1.4% Electronic & 
electrical equipment

2.3% Food & beverages

16.6% Support services

0.4% Retailers

14.9% General financial

0.8% Home 
construction
3.9% Industrial 
engineering

4.0% Industrial 
transportation

1.5% Insurance

27.5% Property, 
commercial & 
residential

2.9% Leisure goods

6.2% Media

Portfolio by listing

17.7% FTSE Mid 250

7.6% Non Indexed

0.2% FTSE 100

24.0% AIM

42.8% Small Caps

7.7% Fledgling

 15 

 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Business Model and Other Statutory Information 

Business Model 
The Business Model and principal activity of the Company remained unchanged throughout the year ended 31 
December 2018.   

Strategy 
The long term strategy of Athelney Trust PLC is to pursue its investment objective and deliver shareholder 
value  by  operating  as  an  investment  trust  company  (as  explained  on  pages  30  to  33  –  Directors’  Report).  
Investment  trusts  are  collective  closed-ended  public  limited  companies.  The  investment  trust  company 
structure allows the shareholders, whether institutions or private investors, to access a diversified portfolio of 
investments that is professionally managed, and so reduce risk over time compared to investing themselves. 

Stabilising the Company and Growing the Fund 
What is clear, however, is that there is a growing imperative to grow the fund.  Our fund must be larger to 
deliver better long term performance in all measures.  The Board will continue in the early part of 2019 to 
stabilise  the  Governance  and  running  of  the  fund.    The  Board  will  also  in  parallel  carry  out  the  necessary 
preparation to grow the fund.  This in turn will allow the fund over time to move to a proportionally lower 
Ongoing  Charge  and  in  the  short  term,  reduce  the  risk  of  losing  its  tax  status,  as  well  as  better  overall 
performance.   

The  Mandate  will  evolve,  but  will  focus  on  similar  opportunities  -  small-/mid-cap  development  from  the 
existing portfolio, allowing value-/conviction-based process to uncover under-researched opportunities and so 
deliver superior performance. 

Stabilising the 
Company  
Growing the Fund  

New Board appointed, process in place to appoint long term Fund Manager  

We believe the optimum size for the fund will be between £50m and £150m.  At this size 
we will have: 

- 

Sufficient investment management capacity to maximise potential 
opportunities  

-  The ability to consistently deliver superior performance  
- 

Significantly reduce the risk of losing the Trust’s tax status by an inadvertent 
breach of the 5/50 rule 

Reduce Cost 

Growing whilst keeping a tight control of costs will allow us to reduce the Ongoing Charge 
percentage to be in line with or better than the peer group 

Investment Approach – the Board 
The Board of Directors is responsible for the overall stewardship of the Company, including investment and dividend 
policies, corporate and gearing strategy, corporate governance procedures and risk management. Biographical details of 
the three Directors, can be found on page 2 and details of other Directors during the year can be found on page 31. 

The Company had one male employee during the year (2017: one male employee).  

 16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Business Model and Other Statutory Information 
(continued) 

Investment Objective 
The investment objective of the Trust is to provide shareholders with prospects of long-term capital growth with the risks 
inherent in small cap. investment minimised through a wide spread of holdings over various industries and sectors. The 
Board also considers that it is important to maintain a progressive dividend record. 

Investment Policy 
The assets of the Trust are allocated predominantly to companies with either a full listing on the London Stock Exchange 
or a trading facility on AIM or ISDX. The assets of the Trust have been allocated in two main ways: first, to the shares of 
those companies which have grown steadily over the years in terms of profits and dividends but, despite this progress, the 
market rating is favourable when compared to future earnings and dividends; second, to those companies whose shares 
are standing at a favourable level compared with the value of land, buildings or cash in the balance sheet. 

Investment Strategy 
The investment strategy  employed by  the  Fund Manager  in  meeting the investment objective focuses  on active stock 
selection.  The  selection  of  individual  holdings  is  based  on  analysis  of,  amongst  other  things,  market  positioning, 
competitive  advantage,  financial  strength  and  cash  flows.  The  weighting  of  individual  investments  reflects  the  Fund 
Manager’s conviction in those holdings and his views on asset allocation, including between UK and overseas equities, 
corporate bonds, cash and gearing.  

Investment of Assets 
At each Board meeting, the Board considers compliance with the Company’s investment policy and other investment 
restrictions during the reporting period. An analysis of the portfolio on 31 December 2018 can be found on pages 13 to 
14 of the annual report. 

Responsible Ownership 
The Fund Manager takes a particular interest in corporate governance and social responsible investment policy. As stated 
within the Corporate Governance Statement on pages 20 to 29, the Fund Manager’s current policy is available on its 
website www.athelneytrust.co.uk. The Board supports the Fund Manager on his voting policy and his stance towards 
environmental, social and governance issues.  

Review of Performance and Outlook 
Reviews of the Company’s returns during the financial year, the position of the Company at the year end, and the outlook 
for the coming year are contained in the Chairman’s Statement on pages 3 to 8 which forms part of the Strategic Report. 

Principal Risks and Uncertainties and Risk Management 
As stated within the Corporate Governance Statement on pages 20 to 29, the Board applies the principles detailed in the 
internal control guidance issued by the Financial Reporting Council, and has established a continuing process designed to 
meet the particular needs of the Company in managing the risks and uncertainties to which it is exposed. 

 17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Business Model and Other Statutory Information 
(continued) 

The principal risks and uncertainties faced by the Company are described below and in note 12 which provides detailed 
explanations of the risks associated with the Company’s financial instruments. 

• Market – the Company’s fixed assets consist almost entirely of listed securities and it is therefore exposed to movements 
in the prices of individual securities and the market generally. 

• Investment and strategic – incorrect investment strategy, asset allocation, stock selection and the use of gearing could 
all lead to poor returns for shareholders. 

• Regulatory – relevant legislation and regulations which apply to the Company include the Companies Act 2006, the 
Corporation Tax Act 2010 (“CTA”) and the Listing Rules of the Financial Conduct Authority (“FCA”). The Company has 
noted the recommendations  of  the  UK  Corporate  Governance  Code  and  its  statement  of  compliance  appears  on 
pages 20 to 29.  A breach  of  the  CTA could  result  in  the  Company  losing  its  status  as  an  investment  company  and 
becoming subject to capital gains tax, whilst a breach of the Listing Rules might result in censure by the FCA. At each 
Board meeting the status  of  the  Company  is  considered  and  discussed,  so  as  to  ensure  that  all  regulations  are  being 
adhered to by the Company and its service providers. 

On the 3 January 2018 MiFIDll and KID came into force with the introduction of the Key Information Document (KID). 
The Company has complied with the legislation and the deadlines to ensure that shares in the Company were still able to 
be traded. A copy of the Company’s KID can be found on the website www.athelneytrust.co.uk. The reports are updated 
on a yearly basis. 

The Board is not aware of any breaches of laws or regulations during the period under review and up to the date of 
this report. 

•  Operational  –  failure  of  the  accounting  systems  or  disruption  to  its  business,  or  that  of  other  third  party  service 
providers,  could lead to an inability to provide accurate reporting and monitoring,  leading to a loss  of shareholders’ 
confidence. 

•  Financial  –  inadequate  controls  by  the  Fund  Manager  or  other  third  party  service  providers  could  lead  to 
misappropriation of assets. Inappropriate accounting policies or failure to comply with accounting standards could lead 
to misreporting or breaches of regulations.  

• Liquidity – the Company may have difficulty in meeting obligations associated with financial liabilities.   

 The  Board  seeks  to  mitigate  and  manage  these  risks  through  continual  review,  policy  setting  and  enforcement  of 
contractual obligations. It also regularly monitors the investment environment and the management of the Company’s 
investment portfolio. Investment risk is spread through holding a wide range of securities in different industrial sectors. 

Statement Regarding Annual Report and Financial Statements 
Following  a  detailed  review  of  the  Annual  Report  and  Financial  Statements  by  the  Audit  Committee,  the  Directors 
consider  that  taken  as  a  whole  it  is  fair,  balanced  and  understandable  and  provides  the  information  necessary  for 
shareholders to assess the Company’s performance, business model and strategy. 

Environment Emissions 
The Company does not have any physical assets, property, or operations of its own and as such does not generate any 
greenhouse gas or other emissions. 

 18 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Business Model and Other Statutory Information 
(continued) 

Social, Community and Human Rights Issues 
The Company has one employee (2017: one employee) and, as far as the Board is aware, no issues exist in respect of 
social, community or human rights issues. 

Alternative Investment Fund Manager’s Directive (“AIFMD”) 
The Company is registered as its own AIFM with the FCA under the AIFMD and confirms that all required returns have 
been completed and filed. 

                                                                    BY ORDER OF THE BOARD 

J. Girdlestone 
Secretary 

Waterside Court 
Falmouth Road 
Penryn 
Cornwall 
TR10 8AW 

4 March 2019 

 19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement 

Shareholders  hold  the  Directors  of  a  company  responsible  for  the  stewardship  of  that  company’s  affairs.  Corporate 
governance is the process by which a board of Directors discharges this responsibility. The Company’s arrangements in 
respect of corporate governance are explained in this report. 

Statement of Compliance with the UK Corporate Governance Code 
The Company  is required to comply  with, or  to  explain its  non-compliance with, the  relevant provisions of the UK 
Corporate Governance Code issued by the Financial Reporting Council (the ‘FRC’) in April 2016 which can be found at 
www.frc.org.uk. The Association of Investment Companies issued its own Code of Corporate Governance in July 2016 
(the ‘AIC Code’), which can be found at www.theaic.co.uk and which has been approved by the FRC as it addresses all 
the principles of the UK Corporate Governance Code as well as setting out additional principles and recommendations 
on issues which are of specific relevance to investment trusts. The Board considers that reporting against the principles 
and recommendations of the AIC Code provides better information to shareholders than the UK Corporate Governance 
Code on its own. 

The Company has not complied with the provisions of the Corporate Governance Code in respect of the following: 

 

Frank Ashton holds the role of Executive Chairman. The background is the uncertainty faced by the Company and 
its shareholders, following the changes to the composition of the board at, and immediately after, the shareholder-
requisitioned General Meeting (GM) on 22 January 2019.  The board believes there is considerable support from 
shareholders to resolve the shareholder dispute over time, and in the meantime stabilise and grow the Fund.  In the 
short term, a lot of work is required to set this up.  Much of this work has and is being performed by Frank Ashton. 
As  a result  of  this  work,  the  board  now  believes  it  has  the  resources  and  skills,  in  the  absence  of  a  permanent 
executive director, to bring all parties towards a common ground that allows a more viable and attractive future for 
all shareholders, including the two major shareholders.  

At the same time, the Company has been on a critical path to Annual Reporting and the AGM. The Company is on 
schedule to comply as planned, but has needed executive input from Frank Ashton to meet this timetable.  

As a result the board resolved to appoint Frank Ashton as Executive Chairman of the Company until the end of May 
2019,  in the expectation that by that time  we  will  have reached resolutions of the various  challenges  facing the 
Company.  Mr Ashton’s role as Executive Chairman will be reviewed by the board following the AGM on 3 April 
2019, allowing changes or any recruitment to take place as the workload reduces, which we believe should happen 
by the end of May 2019.  

The Board notes that the appointment of an Executive Chairman, whilst not in compliance with the UK Corporate 
Governance Code, does not offend against the Compliance Code recommended for investment companies such as 
the Company by the Association of Investment Companies, and is approved by the Financial Reporting Council as 
an acceptable corporate governance code for such companies.  

In  mitigation  of  risk  all  three  directors  will  sit  on  the  Audit  Committee  (chaired  by  Helen  Sachdev)  and 
Remuneration Committee.  

  Due  to the  size  of  the  Board,  formal  performance  evaluations  of  the  Chairman, the  Board,  its  Committees  and 
individual Directors are not undertaken.  Instead it is felt more appropriate to address matters as and when they 
arise.   

  Due to the size of the Board, it is felt inappropriate to appoint a senior independent non-executive Director. 

 20 

 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

 

 

 

All the Directors have agreements for provision of their services but no limit has been imposed on the overall length 
of service.  The recommendation of the Code is for fixed term renewable contracts. In recent years each of the 
Directors has retired and, where appropriate, sought re-election each year. The Directors retire by rotation on a 
three yearly basis in accordance with the Company’s articles of association with effect from the 2017 AGM. 

The Company has one employee. The Company Secretary’s line of communication in relation to whistle-blowing is 
to the Chairman of the Company. 

The Company does not have a Nominations Committee. During the year the Board consisted of only three Directors 
who liaised continuously throughout the year and were aware of their obligations to consider recruitment of further 
Directors as and when the occasion occurred. The Board are in the process of setting up a Nominations Committee 
for 2019. 

Board Membership 
During the year and post year end the following Board changes took place: 

On  26th  September  2018  Mr  Robin  Boyle,  the  Managing  Director  and  Fund  Manager,  resigned  as  a  Director  of  the 
Company with immediate effect. Subsequently an emergency Board meeting was held on 1st October 2018, Dr Manny 
Pohl was appointed Managing Director and Fund Manager and Mr Simon Moore was appointed Chairman. The Board 
decided to actively seek to appoint a new non-executive Director as a matter of urgency. 

Mrs Jemma Jackson was appointed as a non-executive Director on 1st December 2018 to be effective until the next AGM 
when she would retire and seek re-election. 

On 20th December 2018 the Board received a letter from the Director of Trehellas House Limited, a major shareholder 
in Athelney Trust. The Director of Trehellas House, Mr Robin Boyle, called for the Company to hold a GM within the 
timescales detailed in the Companies Act 2006.  

The following ordinary resolutions were requisitioned by Mr Robin Boyle, circulated to Shareholders in a GM notice on 
28 December 2018, and voted on at the GM on 22 January 2019, where the Shareholders voted as follows: 

Ordinary Resolution 1  

AGAINST 

The proposed re-appointment of Robin Boyle as a Director of the Company 

Ordinary Resolution 2 

The proposed appointment of David Lawman as a Director of the Company 

Ordinary Resolution 3 

The proposed appointment of Paul Coffin as a Director of the Company 

Ordinary Resolution 4 

The proposed termination of Dr Emmanuel Pohl as a Director of the Company 

Ordinary Resolution 5 

The proposed termination of Simon Moore as a Director of the Company 

Ordinary Resolution 6 

The proposed termination of Jemma Jackson as a Director of the Company 

FOR 

FOR 

FOR 

FOR 

FOR 

 21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

                        Corporate Governance Statement  
                                             (Continued) 

Ordinary Resolution 7 

FOR 

The proposed termination of Jason Pohl as alternate Director of the Company 

Ordinary Resolution 8 

The termination of the appointment of any Director appointed on or after the date of this 

notice,  and  prior  to  the  consideration  of  this  resolution  at  a  general  meeting  of  the 

NOT VOTED UPON 
* 

Company. 

*Resolution 8 was not voted on due to the fact that no further Directors had been appointed to the Board since the notice 
of the GM was published. 

As a result of the GM on 22nd January 2019 the three Directors who were on the Board at the year end were terminated 
and two new Directors were appointed, Mr David Lawman and Mr Paul Coffin. 

On the 25th January 2019 Mr Paul Coffin resigned as a Director of the Company and Mr Frank Ashton was appointed in 
his place. The biographies of all the current Directors are contained on page 2. 

At 31 December 2018 the Board consisted of three Directors, of which two were independent.  

The Board has agreed that Frank Ashton and Helen Sachdev will retire at the forthcoming AGM and each of them has 
indicated that they will seek re-election. Re-election is subject to a continuing satisfactory performance by the director 
seeking re-election; the Board confirm that they are happy for Frank Ashton and Helen Sachdev to seek re-election at the 
forthcoming AGM.  

The Board believes that Frank Ashton and Helen Sachdev are Directors independent in character and that there are no 
relationships  or  circumstances  which  are  likely  to  affect  their  judgement.  All  Directors  receive  relevant  training, 
collectively or individually, as necessary.  

The Directors believe that the Board has the balance of skills, experience, ages and length of service to enable it to provide 
effective  leadership and proper governance of the  Company.   The Directors possess a range of business and financial 
expertise relevant to the direction of the Company and consider that they commit sufficient time to the Company’s affairs.  

The Directors of the Company meet at regular Board Meetings. During the year ended 31 December 2018, the Board 
met a total of 15 times.  Mr Robin Boyle attended all meetings until his resignation on 26th September 2018. 

 Dr. E C Pohl 
 R G Boyle 
 S Moore 
 J Jackson 

Board 

Audit 

Meetings  Committee 

15 
9 
15 
- 

1 
- 
1 
- 

Remuneration 
Committee 
1 
- 
1 
- 

 22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

    Corporate Governance Statement  
 (Continued) 

The Board subscribes to the view expressed in the AIC Code that long-serving Directors should not be prevented from 
forming part of an independent majority. It does not consider that the length of a Director’s tenure reduces their ability 
to act independently. The Board’s policy on tenure is that continuity and experience are considered to add significantly 
to the strength of the Board and, as such, no limit on the overall length of services of any of the Company’s Directors, 
including  the  Chairman,  has  been  imposed,  although  the  Board  believes  in  the  merits  of  periodic  and  progressive 
refreshment of its composition. 

The Board of Directors of the Company comprised three male and one female Director in the year to 31 December 2018. 
Whilst the Board recognises the benefits of diversity in appointments to the Board, the key criteria for the appointment 
of new Directors will be the appropriate skills and experience in the interest of shareholder value. The Directors are 
satisfied that the Board currently contains members with an appropriate breadth of skills and experience. 

The basis on which the Company aims to generate value over the longer term is set out in the Strategic Report on pages 
3 to 8. All matters, including corporate and gearing strategy, investment and dividend policies, corporate governance 
procedures  and  risk  management  are  reserved  for  the  approval  of  the  Board  of  Directors.  The  Board  receives  full 
information on the Company’s investment performance, assets, liabilities and other relevant information in advance of 
Board meetings. 

Board Responsibilities and Relationship with the Fund Manager 
The Board is responsible for the investment policy (the Mandate) and strategic and operational decisions of the Company 
and for ensuring that the Company is run in accordance with all regulatory and statutory requirements.   These matters 
include: 

 

 

 

The  maintenance  of  clear  investment  objectives  and  risk  management  policies,  changes  to  which  require  Board       
approval; 
The monitoring of the business activities of the Company, including investment performance and annual budgeting; 
and 
Review of matters delegated to the Fund Manager and Company Secretary. 

The Fund Manager ensures that Directors have timely access to all relevant management and financial information to 
enable informed decisions to be made and contacts the Board as required for specific guidance.  The Company Secretary 
and  Fund  Manager  prepare  monthly  reports  for  Board  consideration  on  matters  of  relevance,  for  example  current 
valuation  and  portfolio  changes,  dividend  comparisons  with  previous  years,  cash  availability  and  requirements  and  a 
breakdown of shareholdings by listing and sector.  The Board takes account of Corporate Governance best practice. 

 23 

 
 
 
 
 
 
 
 
 
                        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

Corporate Governance and Social Responsible Investment Policy 
The  Board  is  aware  of  its  duty  to  act  in  the  interests  of  the  Company.  The  Board  acknowledges  that  there  are  risks 
associated  with  investment  in  companies  which  fail  to  conduct  business  in  a  socially  responsible  manner.  The  Fund 
Manager considers social, environmental and ethical factors which may affect the performance or value of the Company's 
investments. The Directors, through the Fund Manager, encourage companies in which investments are held to adhere 
to best practice in the area of  Corporate Governance. They  believe that this can best be achieved by entering into a 
dialogue with company management to encourage them, where necessary, to improve their policies in this area. The 
Company's ultimate objective is to deliver superior long term returns for Shareholders which the Board believe will be 
produced  on  a  sustainable  basis  by  investing  in  companies  which  adhere  to  best  practice  in  the  area  of  Corporate 
Governance. Accordingly the Fund Manager will seek to favour companies which pursue best practice in this area. 

Chairman  
The Chairman,  during the  year was  Dr.  E C  Pohl from 1 January  2018 till  1 October 2018  when he  was appointed 
Managing Director and Fund Manager and Mr S Moore was appointed Chairman.  

As a result of the GM (as detailed on pages 21-22) Mr S Moore’s tenure as Chairman was terminated on 22 January 2019 
and Mr D Lawman was appointed. 

Mr D Lawman stepped down as Chairman in a board meeting on 8 February 2019, and Mr F Ashton was appointed 
Executive  Chairman.    Mr  F  Ashton  is  independent  and  considers  himself  to  have  sufficient  time  to  commit  to  the 
Company’s affairs. 

Directors’ Independence 
In accordance with the Listing Rules for investment entities, the Board has reviewed the status of its individual Directors 
and the Board as a whole.  Two of the three current Directors including the Chairman are considered by the Board to be 
independent in character and judgement and there are no relationships or circumstances which are likely to affect or could 
appear to affect the Directors’ judgement. 

Remuneration Committee 
During the year the Remuneration Committee comprised of Dr Emmanuel Pohl and Mr Simon Moore (Chairman). Post 
year  end  the  Remuneration  Committee  comprises  the  current  Directors.  The  Committee  will  meet  as  necessary  to 
determine  and  approve  Director’s  fees,  following  proper  consideration  of  the  role  that  individual  Directors  fulfil  in 
respect of Board and Committee responsibilities, the time committed to the Company’s affairs and remuneration levels 
generally within the Investment Trust Sector. 

Under Listing Rule 15.6.6, the Code principles relating to Directors’ remuneration do not apply to an investment trust 
company other than to the extent that they relate specifically to non-executive Directors.  Detailed information on the 
remuneration arrangements can be found in the Directors’ remuneration report on pages 36 to 39 and in note 4 to the 
financial statements. 

 24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

Company Secretaries 
The Company Secretaries, Mr John Girdlestone FCA and Mrs Deborah Warburton FCCA, are responsible for ensuring 
that Board and Committee procedures are followed and that applicable regulations are complied with.  The Company 
Secretaries also ensure timely delivery of information and reports and that the statutory obligations of the Company are 
met.  

All the Directors have access to the advice and services of the Company Secretaries. 

Independent Professional Advice and Directors’ Training 
Individual  Directors  may,  at  the  expense  of  the  Company,  seek  independent  professional  advice  on  any  matter  that 
concerns them in the furtherance of their duties.  

The Chairman liaises on a regular basis with the other Directors and the Company Secretaries to ensure that they are 
maintaining adequate training and continuing professional development. 

Institutional Investors – Use of Voting Rights and Voting Policy 
The Fund Manager, in the absence of explicit instruction from the Board, is empowered to exercise discretion in the use 
of the Company’s voting rights. The Fund Manager votes against resolutions he believes may damage shareholders’ rights 
or economic interests.   

Audit Committee 
During the year the Audit Committee was chaired by Mr Simon Moore and attended by Dr Emmanuel Pohl. Post year 
end the Audit Committee comprises the current Directors. The Committee met once during the year. The duties of the 
committee  include  reviewing  the  Annual  and  Interim  Accounts,  the  system  of  internal  controls,  and  the  terms  of 
appointment and remuneration of the auditor, Hazlewoods LLP, including its independence and objectivity. It is also the 
forum through which Hazlewoods LLP reports to the Board of Directors.  

Much of the Board’s corporate governance responsibility is discharged through the Audit Committee. This Committee 
operates within clearly defined written terms of reference which are available upon request at the Company’s registered 
office. 

 25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

Significant Issues Considered by the Audit Committee in Relation to the Financial Statements 

Matter 

Action 

Investment Portfolio Valuation 
The  Company’s  portfolio  is  invested  predominantly  in 
listed securities. Although all the securities are fully listed 
or traded on AIM, errors in the portfolio valuation could 
have a material impact on the Company’s net asset value 
per share. 
Misappropriation of Assets 
Misappropriation of the Company’s investments or 
cash balances could have a material impact on its net 
asset value per share. 

The  portfolio  is  valued  at  bid  price  at  the  end  of  each 
month by the custodians James Sharp & Co. 

The  portfolio  is  valued  at  bid  price  at  the  end  of  each 
month by the custodians James Sharp & Co. The portfolio 
is agreed on a monthly basis by the Company Secretaries 
during the completion of the monthly accounts. 

Income Recognition 
Incomplete or inaccurate income recognition could have 
an  adverse  effect  on  the  Company’s  net  asset  value  and 
earnings per share and its level of dividend cover. 

The level of income received for the year and the dividend 
forecast for the year are agreed on a monthly basis with 
the Fund Manager and the Company Secretaries. 

The  Audit  Committee  reviews  the  scope  and  results  of  the  audit  and,  during  the  year,  considered  and  approved 
Hazlewoods LLP’s plan for the audit of the financial statements for the year ended 31 December 2018. At the conclusion 
of the audit Hazlewoods LLP did not highlight any issues to the Audit Committee which would cause it to qualify its audit 
report nor did it highlight any fundamental internal control weaknesses.  Hazlewoods LLP issued an unqualified audit 
report which is included on pages 40 to 44. 

The Audit Committee also reviews any potential provision of non-audit services by the auditor. It has been agreed that 
all non-audit work to be carried out by the auditor must be approved in advance by the Audit Committee. No non-audit 
services have been provided in the year. 

As part of the review of auditor independence and effectiveness, Hazlewoods LLP has confirmed that it is independent of 
the Company and has complied with relevant auditing standards. In evaluating Hazlewoods LLP, the Audit Committee 
has taken into consideration the standing, skills and experience of the firm and the audit team. Following professional 
guidelines, the audit partner rotates after five years. 

Company Information 
The  following  information  is  disclosed  in  accordance  with  The  Large  and  Medium-Sized  Companies  and  Groups 
(Accounts and Reports) Regulations 2008 and DTR 7.2.6. 

 The Company’s capital structure and voting rights are summarised on pages 31 and 32. 

 Details of the substantial shareholders in the Company are listed on page 31. 

 The  rules  concerning  the  appointment  and  replacement  of  Directors  are  contained  in  the  Company’s Articles  of   

Association and are discussed on page 30. 

 The Board is seeking to renew its current powers to issue and re-purchase shares at the forthcoming Annual General 

Meeting. 

 26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

 There are: no restrictions concerning the transfer of securities in the Company; no special rights with regard to the 
control attached to securities; no restrictions on voting rights; no agreements which the Company is party to that might 
affect its control following a successful takeover. 

 There are no agreements between the Company and its Directors concerning compensation for loss of office. 

Relations with Shareholders 
The Company places great importance on communication with shareholders and welcomes their views. The Chairman 
and the other Directors are available to meet shareholders. The Annual General Meeting of the Company provides a 
forum, both formal and informal, for shareholders to meet and discuss issues with the Directors of the Company. 

The notice of the Annual General Meeting, to be held in London on 3 April 2019, is set out on pages 59 to 67. The Annual 
Report and Notice of Annual General Meeting are sent to shareholders at least 20 working days before the Meeting. 

Internal Control 
The Board is responsible for the Company’s system of internal control and for reviewing its effectiveness. It has therefore 
established an ongoing process designed to meet the particular needs of the Company in managing the risks to which it is 
exposed, consistent with the internal control guidance issued by the Financial Reporting Council. 

Adequate internal controls are in place for identifying, evaluating and managing risks faced by the Company.  This process, 
together with key procedures established with a view to providing effective financial control, has been in place for the full 
financial year and up to the date the financial statements were approved and is consistent with the internal control guidance 
issued by the Financial Reporting Council. 

The Board has reviewed the need for an internal audit function. It has decided that the systems and procedures employed 
by the Directors, provide sufficient assurance that a sound system of internal control, which safeguards the Company’s 
assets, is maintained. An internal audit function specific to the Company is therefore considered unnecessary. 

 27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

Internal Control Assessment Process 
Risk  assessment  and  the  review  of  internal  controls  are  undertaken  by  the  Board  in  the  context  of  the  Company’s 
overall investment objective. The review covers the key business, operational, compliance and financial risks facing the 
Company.  In  arriving  at  its  judgement  of  what  risks  the  Company  faces,  the  Board  has  considered  the  Company’s 
operations in the light of the following factors: 

  The nature and extent of risks which it regards as acceptable for the Company to bear within its overall business 

objective; 

  The threat of such risks becoming a reality; 

  The Company’s ability to reduce the incidence and impact of risk on its performance; and 

  The cost and benefits to the Company of third parties operating the relevant controls. 

Against this background, the Board has split the review of risk and associated controls into four sections reflecting the 
nature of the risks being addressed. These sections are as follows: 

  Corporate strategy; 

  Published information, compliance with laws and regulations; 

  Relationship with service providers; and 

 

Investment and business activities. 

The key procedures which have been established to provide internal controls are as follows: 

  Custody and valuation of assets is undertaken by James Sharp & Co; 

  The  duties  of  investment  management,  accounting  and  the  custody  of  assets  are  segregated.  The  procedures  of  the 

individual parties are designed to complement one another; 

  The Directors of the Company clearly define the duties and responsibilities of their agents and advisers. The appointment 
of agents and advisers is conducted by the Board after consideration of the quality of the parties involved; the Board 
monitors their ongoing performance and contractual arrangements; 

  Mandates for authorisation of investment transactions and expense payments are set by the Board; and 

  The Board reviews financial information produced by the Fund Manager and the Company Secretaries in detail on a 

regular basis. 

 28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

In  accordance  with  guidance  issued  to  Directors  of  listed  companies,  the  Directors  have  carried  out  a  review  of  the 
effectiveness of the system of internal control as it has operated over the year. 

BY ORDER OF THE BOARD 

Waterside Court 
Falmouth Road 
Penryn 
Cornwall  
TR10 8AW                                                             4 March 2019 

      J. Girdlestone 
           Secretary  

 29 

 
 
 
 
 
 
 
 
 
 
  
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
        
                                                                                     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Report of the Directors 

The Directors present their report and audited financial statements of the Company for the year ended 31 December 
2018.   This report also contains certain information required in accordance with S992 of the Companies Act 2006. 

Results and Dividends 
The return on ordinary revenue activities before dividends for the year is £213,098 (2017: £206,177) as detailed on page 
45. 

It is recommended that a dividend of 9.1p (2017: 8.9p) per ordinary share be paid.  

Principal Activity and Status 
The Company (company number: 02933559) is a public limited company, limited by shares and incorporated in England 
and Wales. It is an investment company as defined in Section 833 of the Companies Act 2006. The registered office is 
Waterside Court, Falmouth Road, Penryn, TR10 8AW. 

The Company carries on business as an investment trust. The Company has been granted approval from HM Revenue & 
Customs ('HMRC') as an authorised investment trust under Section 1158 of the Corporation Tax Act 2010 for the year ended 
31 December  2017. The  Directors  are  of  the  opinion  that  the  Company  has  conducted  its affairs for the year ended 31 
December 2018 so as to be able to continue to obtain approval as an authorised investment trust, under Section 1158 of the 
Corporation Tax Act 2010.  

Directors 
Biographical details of the Directors, can be found on page 2. 

In accordance with the arrangements for retirement contained in the Company’s Articles of Association, the Directors 
will retire by rotation on a three yearly cycle. Having been appointed by the Board since the last AGM Mr Frank Ashton 
and Mrs Helen Sachdev will retire at the 2019 AGM and will offer themselves for re-election. 

The Board confirms that, following the evaluation process set out in the Corporate Governance Statement on pages 20 to 
29,  Mr  Ashtons’s  and  Mrs  Sachdev’s  performances  as  Directors  continues  to  be  effective  and  they  demonstrate 
commitment to the role. The Board therefore believes that it is in the interests of shareholders that Mr Ashton and Mrs 
Sachdev are re-elected. In addition to any power of removal conferred by the Companies Acts, the Company may by 
special resolution remove any Director without notice. 

Directors’ Indemnity 
Each Director of the Company is entitled to be indemnified to the extent permitted by the Companies Act 2006 against 
liabilities incurred by any of them in the execution of their duties and exercise of their powers. 

Conflicts of Interest 
Each Director has a statutory duty to avoid a situation where they have, or could have, a direct or indirect interest which 
conflicts, or may conflict, with the interests of the Company. A Director will not be in breach of that duty if the relevant 
matter  has  been  authorised  by  the  Board  in  accordance  with  the  Company’s  Articles  of  Association.  The  Board  has 
approved a protocol for identifying and dealing with conflicts and conducts a review of actual or possible conflicts at least 
annually. No conflicts or potential conflicts were identified during the year. It is not considered that an interest in the 
Company’s shares held by a Director will of itself give rise to a situation where that Director’s interests or duties conflict 
with the interests of the Company. 

 30 

 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Report of the Directors 
(continued) 

Capital Structure  
At  31  December  2018  the  Company’s  capital  structure  consisted  of  2,157,881  Ordinary  Shares  of  25p  each  (2017: 
2,157,881 Ordinary Shares of 25p each). 

Directors and Their Interests 
The Directors who held office during the year and at the date of this report are shown below; their interest in the ordinary 
shares of the Company are stated on page 38 in the Directors’ Remuneration Report. 

Dr. E. C. Pohl  
R. G. Boyle 
S. Moore 
J. Jackson 
D. Lawman 
P. Coffin 
F. Ashton 

(Non-executive Chairman)(Managing Director) terminated 22/1/2019 
(Managing Director) resigned 26/9/2018 
(Non-executive Director)(Chairman) terminated 22/1/2019 
(Non-executive Director) appointed 1/12/2018 – terminated 22/1/2019 
(Non-executive Director) appointed 22/1/2019 
(Non-executive Director) appointed 22/1/2019 – resigned 25/1/2019 
(Executive Chairman) appointed 25/1/2019 

The Company does not have any contract of significance subsisting during the year, with any other company in which a 
Director is or was materially interested.  

Mr J Pohl was appointed as alternate director for Dr EC Pohl but as Dr EC Pohl was able to attend all meetings of the 
Board and its committees during the year, Mr J Pohl was not required to act as his alternate. Following the EGM, Mr J 
Pohl’s position as alternate director has been terminated. 

There were a number of Director changes during the year and more changes as a result of the GM on the 22 January 
2019 a detailed disclosure of the events can be found in the Corporate Governance Statement on pages 20 to 29. 

Substantial Shareholders 
The Directors have been notified of the following major shareholdings in the Company that represent greater than 3% 
of the voting rights: 

Mr RG Boyle 

Global Masters Fund 

Mr GW & Mrs DJ Whicheloe 

Mrs E Davison 
Mr C Frostick 

Ordinary 
Shares 
449,055 

379,640 

104,000 

75,000 
69,720 

  % of issue 

20.81 

17.59 

4.82 

3.48 
3.23 

Out of the six major shareholders listed above two were under the direct control of two of the Directors during the year. 
The remaining four are in regular contact with the Directors (or their respective agent) to ensure that they are frequently 
appraised and are content with the manner in which the Company is being run. 

There have been no other changes in the above major shareholdings in the Company up to 20 February 2019. 

 31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Report of the Directors 
(continued) 

Dividends 
The Ordinary Shares carry a right to receive dividends which are declared from time to time by an Ordinary Resolution 
of  the  Company  (up  to  the amount recommended  by  the  Directors)  and to receive  any  interim  dividends  which  the 
Directors may resolve to pay. 

Capital Entitlement 
On a winding up, after meeting the liabilities of the Company, the surplus assets will be paid to ordinary shareholders in 
proportion to their shareholdings. 

Voting 
On a show of hands, every ordinary shareholder present in person or by proxy has one vote and on a poll every ordinary 
shareholder present in person has one vote for every share he/she holds and a proxy has one vote for every share in respect 
of which he/she is appointed. 

Payment of Suppliers 
It is the Company’s policy to obtain the best possible terms for all business and, therefore, there is no consistent policy as 
to the terms used.  The Company contracts the terms on which business will take place throughout the year with its 
suppliers.  There are accrued expenses outstanding at the end of the year, all of which appear as creditors in the balance 
sheet. 

Going Concern 
In assessing the going concern basis of accounting, the Directors have had regard to the guidance issued by the Financial 
Reporting Council. They have considered the current cash position of the Company, and forecast revenues for the current 
financial year. The Directors have also taken into account the Company’s investment policy, which is described on page 
17 and which is subject to regular Board monitoring processes, and is designed to ensure that the Company is invested in  
listed securities  and those traded on AIM. 

The Company retains title to all assets held by its custodian. Note 12 to the financial statements sets out the financial risk 
profile of the Company and indicates the effect on its assets and liabilities of falls and rises in the value of securities, market 
rates of interest and changes in exchange rates. 

The Directors believe, in the light of the controls and review processes noted above and bearing in mind the nature of the 
Company’s business and assets, that the Company has adequate resources to continue in operational existence for the 
foreseeable future. Accordingly, they continue to adopt the going concern basis in preparing the financial statements. 

Viability Statement 
The Directors have assessed the prospects of the Company for a period of three years. The Board believes this time period 
is appropriate having consideration for the Company’s principal risks and uncertainties (outlined on pages 17 and 18), its 
portfolio of listed equity investments and cash balances, and its ability to achieve the stated dividend policy. The Directors 
have assessed the ability of the Company to continue as a going concern as outlined above. 

 32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Report of the Directors 
(continued) 

In making this assessment, the Directors have considered detailed information provided at board meetings which includes 
the Company’s balance sheet, investment portfolio and income and operating expenses.  

Based on the above, the Board confirms that the Company fully expects it will be able to continue in operation and meet 
its liabilities as they fall due over the three-year period of this assessment. 

Financial Instruments 

The Company’s financial instruments comprise its investment portfolio, cash balances and debtors and creditors that arise 
directly  from  its  operations  such  as  sales  and  purchases  awaiting  settlement  and  accrued  income.  The  financial  risk 
management objectives and policies arising from its financial instruments and the exposure of the Company to risk are 
disclosed in note 12 to the financial statements. 

Annual General Meeting 
The Notice of Annual General Meeting is set out on pages 59 to 67.  

Disclosure of Information to Auditors 
The Directors confirm that, so far as each of them is aware, there is no relevant audit information of which the Company’s 
auditor is unaware and the Directors have taken all the steps that they ought to have taken as Directors in order to make 
themselves  aware  of  any  relevant  audit  information  and  to  establish  that  the  Company’s  auditor  is  aware  of  that 
information. 

Re-appointment of Auditor 
A resolution will be put to the shareholders at the Annual General Meeting proposing the re-appointment of Hazlewoods 
LLP as Auditor to the Company. Hazlewoods LLP has indicated its willingness to continue in office. 

Waterside Court 
Falmouth Road 
Penryn 
Cornwall 
TR10 8AW 

4 March 2019 

BY ORDER OF THE BOARD 

J. Girdlestone 
Secretary 

 33 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Statement of Directors’ responsibilities in respect of the financial 
statements 

The Directors are responsible for preparing the Annual Report and the financial statements and have elected to prepare 
them in accordance with applicable United Kingdom law and United Kingdom  Accounting Standards (United Kingdom 
Generally Accepted Accounting Practice). 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 its profit or loss 
for that period. 

In preparing the financial statements, the Directors are required to: 

•  select suitable accounting policies and then apply them consistently; 

•  make judgements and estimates that are reasonable and prudent; 

•  present  information,  including  accounting  policies,  in  a  manner  that  provides  relevant,  reliable,  comparable  and 

understandable information; 

•  state whether applicable UK Accounting Standards have been followed, subject to any material departures disclosed 

and explained in the financial statements; and 

•  prepare  the  financial  statements  on  the  going  concern  basis  unless  it  is  inappropriate  to  presume  that  the 

Company will continue in business. 

The  Directors  are  responsible  for  keeping  adequate  accounting  records  that  are  sufficient  to  show  and  explain  the 
Company’s transactions and disclose with reasonable accuracy, at any time, the financial position of the Company and to 
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. 

Under  applicable  law  and  regulations,  the  Directors  are  also  responsible  for  preparing  a  Report  of  the  Directors,  a 
Strategic Report, Directors’ Remuneration Report and Statement on Corporate Governance. 

The Directors state that to the best of their knowledge: 

•  the Financial Statements, prepared in accordance with UK Generally Accepted Accounting Practice, give a true and 

fair view of the assets, liabilities, financial position and net return of the Company;  

•  consider  the  annual report  and  accounts,  taken  as  a  whole,  are  fair,  balanced  and  understandable and  provide  the 
necessary information for shareholders to assess the Company’s position and performance, business model and strategy; 
and 

•  the Chairman’s Statement and Report of the Directors include a fair review of the development and performance of 
the business and the position of the Company together with a description of the principal risks and uncertainties that 
it faces. 

The Directors are responsible for the maintenance and integrity of the corporate and financial information related to 
the Company including on the Company’s website www.athelneytrust.co.uk 

 34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Statement of Directors’ responsibilities in respect of the financial 
statements  
(Continued) 

Legislation  in  the  United  Kingdom  governing  the  preparation  and  dissemination  of  financial  statements  may  differ 
from legislation in other jurisdictions. 

BY ORDER OF THE BOARD 

Waterside Court                                    
Falmouth Road 
Penryn    
Cornwall 
TR10 8AW 

J.Girdlestone 
    Secretary 
4 March 2019 

 35 

 
 
 
 
 
 
 
 
 
 
 
 
                 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors’ Remuneration Report 

The Board has prepared this Report in accordance with the requirements of Section 421 of the Companies Act 2006.  An 
Ordinary Resolution will be put to the members to approve the Report at the forthcoming Annual General Meeting. 

The law requires the Company’s Auditors to audit certain disclosures provided.  Where disclosures have been audited, 
they are indicated as such.  The Auditors’ opinion is included in their report on pages 40 to 44. 

Remuneration Committee 
The Company had a Remuneration Committee during the year comprising of Dr Emmanuel Pohl and Mr Simon Moore, 
with Simon Moore chairing the meetings.  The Committee considered and approved the Directors’ remuneration for the 
year ending 31 December 2018. The changes to the Directors after the  GM on 22 January 2019 has led to the three 
current Directors being appointed to the Remuneration Committee. 

Policy on Directors’ Remuneration 
The Board’s policy is that the remuneration of non-executive Directors should be sufficient to attract and retain Directors 
with suitable skills and experience, and is determined in such a way as to reflect the experience of the Board as a whole, 
in order to be comparable with other organisations and appointments. It is intended that this policy will continue for the 
year ending 31 December 2019 and thereafter. 

The fees for non-executive Directors are determined within the limits set out in the Company’s Articles of Association. 
The approval of shareholders would be required to increase the limits set out in the Articles of Association. Directors are 
not eligible for bonuses, pension benefits, share options, long-term incentive schemes or other benefits, as the Board does 
not consider such arrangements or benefits necessary or appropriate. Fees for any new Director appointed will be made 
on the same basis. 

The salary for the Managing Director and Fund Manager was fixed on 1 April 2015 at 1% of portfolio value calculated on 
a monthly basis. At a Board meeting held in December 2018 it was agreed that with effect from 1 January 2019 this would 
be reduced to 0.75% of the portfolio value. 

Directors’ Service Contracts 
Each of the Directors has a service contract or letter of engagement with the Company. There are no provisions in the 
service agreements for payments to be made for loss of office. 

The letters of engagement for two of the three non-executive Directors, Mr F Ashton and Mrs H Sachdev, provide for 
their appointment to continue until the Annual General Meeting following the appointment and, following re-election at 
that meeting, for renewal by the Board on terms to be agreed from time to time.    Mr D Lawman was appointed by 
shareholders at the GM held on 22 January 2019 and accordingly his agreement provides for renewal by the Board on 
terms to be agreed from time to time. 

 36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors’ Remuneration Report 
(continued) 

Company Performance 
The graph below compares, for the ten financial years ended 31 December 2018, the total return (assuming all dividends 
are reinvested) to ordinary shareholders compared to the total shareholder return on a notional investment made up of 
shares in the component parts of the AIM All-Share Index and Small Caps Index.  The comparison is made between AIM 
All-Share and Small Caps as the majority of investment holdings by the Company are a constituent of one or the other of 
these two indices. The comparison is required by Statutory Instrument to enable the readers of the accounts to compare 
the performance of the Company and Directors remuneration. 

*Assuming all dividends are reinvested 
Past performance is no guarantee of future performance. 

Directors’ Remuneration for the Year (audited information) 
The Directors who served in the year received the following remuneration in the form of salaries or non-executive 
Directors’ fees:  

Dr E. C. Pohl (Chairman, Non-executive) 
Dr E. C. Pohl (Managing Director) 
R. G. Boyle (Managing Director) 
S. Moore (Non-executive) 
J. Jackson 

2018 
£ 

8,750 
8,639 
43,399 
10,500 
875 
72,163 

2017 
£ 

10,500 
- 
57,474 
10,500 
- 
78,474 

The Director’s remuneration for the year of £72,163 is before the proposed dividend of 9.1p (2017:8.9p) per ordinary 
share. As stated in the Chairman’s Statement on page 3 this is an increase of 2 per cent on last year. 

 37 

 
 
 
 
 
 
 
 
 
 
  
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors’ Remuneration Report 
(continued) 

Chairman basic fee 
Fund Manager 0.75% (2018: 1%) of net assets 
Non-Executive Director basic fee 

Expected Fees for the Year to 31 
December 2019 
16,800 
40,000 
10,500 

Fees for Year to 31 
December 2018 
10,500 
51,163 
10,500 

Directors’ beneficial and family interests (audited) 
The interests of the Directors and their families in the Ordinary shares of the Company are set out below: 

R.G. Boyle  
Dr E.C. Pohl  
S. Moore  

Notes: 

31 December 
2018 
(or date of 
resignation if 
earlier) 
449,055² 
-¹ 
50,000 

31 December 
2017 
(or date of 
appointment 
if later) 
449,055 
- 
32,000 

1.  Dr. E. C. Pohl is the sole beneficial owner of E C Pohl & Co Pty Limited, which owns 54.1% of the issued share 
capital of Global Masters Fund Limited on behalf of itself and clients whose portfolios it manages. Global Masters 
Fund Limited holds 379,640 (2017: 349,640) shares in the Company. 

2. 

Included within R.G. Boyle’s holding is an interest in Trehellas House Limited, a company which holds 391,600 
(2017:  391,600)  ordinary  shares  representing  18.1  per  cent  of  the  Company’s  share  capital.  R.G.  Boyle  has 
separately entered into an agreement with E C Pohl & Co giving E C Pohl & Co on behalf of its client Global Masters 
Fund a right of first refusal to such number of shares owned by Trehellas House Limited as shall when taken with 
their existing holding not exceed 29.9% of the issued equity share capital of the Company. The price for any such 
sale and purchase has been agreed at the net asset value of each share as determined by the most recent published 
statement. This agreement amounts to a right of first refusal only and there is no obligation on Trehellas House 
Limited to sell its shares at any particular time nor, Trehellas House Limited having determined to sell those shares, 
any obligation on E C Pohl & Co to buy. 

Mr D Lawman has an indirect interest in the form of 2,500 shares held in his SIPP.  Apart from this none of the current 
Directors has any beneficial or non-beneficial interests to disclose. 

None  of  the  Directors  nor  any  persons  connected  with  them  had  a  material  interest  in  the  Company’s  transactions, 
arrangements or agreements during the year other than through their holdings in the Company’s shares. 

The Directors are fully aware that the Company is not a close company and of the rules associated with this status. The 
Company  Secretaries  maintain  a  record  of  shareholders  that  is  regularly  updated and  used  to  publish,  with the  Fund 
Manager’s report, the latest total holding of the top 5 shareholders.  Shareholders and potential investors are able to see 
the risk and understand how their proposed transaction might affect the Investment Trust status of the Company, possibly 
breaching the Chapter 3 “5/50 rule”. 

 38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors’ Remuneration Report 
(continued) 

The Directors’ Remuneration Report for the year ended 31 December 2017 was approved by shareholders at the Annual 
General Meeting held on 22 March 2018. The votes cast by proxy were as follows: 

For 
Against 
Total votes cast 
Number of votes withheld 

Number of votes  % of votes cast 
60.3 
- 
60.3 
- 

1,302,011 
Nil 
1,302,011 
Nil 

The Directors’ Remuneration Policy was approved by shareholders at the Annual General  Meeting held on 30 March 
2017. The votes cast by proxy were as follows: 

For 
Against 
Total votes cast 
Number of votes withheld 

Approval 

Number of votes  % of votes cast 
57.5 
- 
57.5 
- 

1,241,619 
Nil 
1,241,619 
Nil 

The Directors’ Remuneration Report was approved by the Board on 3 March 2019. 

J. Girdlestone 
Company Secretary 

 39 

 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF 
ATHELNEY TRUST PLC  

Opinion 
We have audited the financial statements of Athelney Trust plc (the ‘Company’) for the year ended 31 December 2018, 
which comprise the Income Statement, Statement of Changes in Equity, Statement of the Financial Position, Statement 
of Cash Flows and notes to the financial statements, including a summary of significant accounting policies. The financial 
reporting  framework  that  has  been  applied  in  their  preparation  is  applicable  law  and  United  Kingdom  Accounting 
Standards,  including  Financial  Reporting  Standard  102  The  Financial  Reporting  Standard  applicable  in  the  UK  and 
Republic of Ireland (United Kingdom Generally Accepted Accounting Practice). 

In our opinion the financial statements: 

 

 
 

give a true and fair view of the state of the Company’s affairs as at 31 December 2018 and of its net return for 
the year then ended; 
have been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice; 
have been prepared in accordance with the requirements of the Companies Act 2006. 

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  Company  in  accordance  with  the  ethical 
requirements that are relevant to our audit of the financial statements in the UK, including the FRC’s Ethical Standard as 
applied to listed entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements. 
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. 

Conclusions relating to principal risks, going concern and viability statement 
We have nothing to report in respect of the following information in the annual report, in relation to which the ISAs (UK) 
require us to report to you whether we have anything material to add or draw attention to: 

the disclosures in the annual report set out on pages 17 to 18 that describe the principal risks and explain how 

 
they are being managed or mitigated; 

the Directors’ confirmation set out on page 17 in the annual report that they have carried out a robust assessment 
 
of the principal risks facing the Company, including those that would threaten its business model, future performance, 
solvency or liquidity;  

the Directors’ statement set out on page 32 in the financial statements about whether the Directors considered 
 
it appropriate to adopt the going concern basis of accounting in preparing the financial statements and the Directors’ 
identification of any material uncertainties to the Company’s ability to continue to do so over a period of at least twelve 
months from the date of approval of the financial statements;  

whether the Directors’ statement relating to going concern required under the Listing Rules in accordance with 

 
Listing Rule 9.8.6R(3) is materially inconsistent with our knowledge obtained in the audit; or  

the Directors’ explanation set out on page 32 in the annual report as to how they have assessed the prospects of 
 
the  Company,  over  what  period  they  have  done  so  and  why  they  consider  that  period  to  be  appropriate,  and  their 
statement as to whether they have a reasonable expectation that the Company will be able to continue in operation and 
meet its liabilities as they fall due over the period of their assessment, including any related disclosures drawing attention 
to any necessary qualifications or assumptions. 

. 

 40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF 
ATHELNEY TRUST PLC  

            (Continued) 

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)  we  identified,  including  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. 

Key audit matters identified were valuation, ownership and existence of investments and the allocation of capital and 
revenue items.  Revenue recognition and management override of controls are always deemed risks in any audit.  This is 
not a complete list of all risks identified by our audit. 

Valuation, ownership and existence of investments 
The company’s investment portfolio is one of the key drivers of its results, of which 100% is represented by quoted investments. The 
investments are not considered to be at a high risk of material misstatement, or to be subject to a significant level of judgement, because 
they comprise liquid, quoted investments for which evidence of the market price is readily available. However, due to their materiality in 
the context of the financial statements as a whole, they are considered to be a significant risk area. Our audit work included, but was not 
restricted to, consideration of the design and implementation of controls over the pricing of quoted investments and agreeing 100% of 
investment prices to independent sources. We considered the appropriateness of the use of the quoted bid price by reviewing the liquidity 
of the market of the quoted investments held. We also confirmed investment holdings to either third party confirmations, direct investee 
confirmations or share certificates. 

Allocation of costs between capital and revenue 
The company allocates expenditure between revenue and capital on the basis of the Board’s expected long-term capital and revenue 
returns. The allocation is important as it affects distributable reserves. Our audit work included, but was not restricted to, a detailed 
review of the actual dividend and capital income received in the past seven years compared to the Board’s expected long-term capital and 
revenue returns. The company’s accounting policy on this allocation is included in note 1 to the financial statements. 

Management override of financial controls 
The risk of management override is always considered a significant audit risk but is particularly relevant for the company due to the size 
of the organisation structure. Our audit work included, but was not restricted to a review of all significant management estimates and 
judgements applied during the completion of the financial statements. We also reviewed material journal entries processed by management 
during the period. The company’s principal accounting policies are included in note 1 to the financial statements. 

Revenue recognition 
Under ISA 240 there is always a presumed risk that revenue may be misstated due to the improper recognition of revenue.  In particular 
we identified completeness and occurrence of investment income as a risk that requires particular audit attention. Our audit work included, 
but  was  not  restricted  to:  Obtaining  an  understanding  of  management’s  process  to  recognise  revenue  in  accordance  with  the  stated 
accounting policy; testing income transactions by comparing dividends during the year obtained from an independent source with those 
recognised by the Company; testing gains and losses on investments to third party contracts; and performing cut-off testing of dividend 
income around the year end. 

Our application of materiality 
We  apply  the  concept  of  materiality  in  planning  and  performing  our  audit,  in  evaluating  the  effect  of  any  identified 
misstatements and in forming our opinion. For the purpose of determining whether the financial statements are free from 
material  misstatement,  we  define  materiality  as  the  magnitude  of  a  misstatement  or  an  omission  from  the  financial 
statements or related disclosures that would make it probable that the judgement of a reasonable person, relying on the 
information  would  have  been  changed  or  influenced  by  the  misstatement  or  omission. We  also  determine  a  level  of 
performance materiality, which we use to determine the extent of testing needed, to reduce to an appropriately low-
level the probability that the aggregate of uncorrected and undetected misstatements exceeds materiality for the financial 
statements as a whole. 

 41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF 
ATHELNEY TRUST PLC  

            (Continued) 

We  established  materiality  for  the  financial statements  as  a  whole  to  be  £73,000,  which  is  1.5%  of  the  value  of the 
Company’s  net  assets.  For  income  and  expenditure  items  we  determined  that  misstatements  of  lesser  amounts  than 
materiality for the financial statements as a whole would make it probable that the judgement of a reasonable person, 
relying on the information would have been changed or influenced by the misstatement or omission. Accordingly, we 
established materiality for revenue items within the income statement to be £53,000, which is 25% of the Company’s net 
return on ordinary activities before taxation, excluding gains on investments at fair value. 

An overview of the scope of our audit 
Our audit approach was based on a thorough understanding of the Company’s business and is risk-based. The day-to-day 
management  of  the  Company’s  investment  portfolio,  the  custody  of  its  investments  and  the  maintenance  of  the 
Company’s accounting records is outsourced to third-party service providers. Accordingly, our audit work is focused on 
obtaining an understanding of, and evaluating, internal controls at the Company and the third-party service providers and 
inspecting  records  and  documents  held  by  the  third-party  service  providers.  We  undertook  substantive  testing  on 
significant transactions, balances and disclosures, the extent of which was based on various factors such as our overall 
assessment  of  the  control  environment,  the  effectiveness  of  controls  over  individual  systems  and the  management  of 
specific risks. 

Other information 
The Directors are responsible for the other information. The other information comprises the information included in 
the annual report, other than the financial statements and our auditor’s report thereon. 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. 

In connection with our audit of the financial statements, 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 audit  or  otherwise  appears  to  be  materially  misstated.  If  we  identify  such  material  inconsistencies  or 
apparent material misstatements, we are required to determine whether there is a material misstatement in the financial 
statements or a material misstatement of the other information. 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. 

In this context, we also have nothing to report in regard to our responsibility to specifically address the following items 
in the other information and to report as uncorrected material misstatements of the other information where we conclude 
that those items meet the following conditions: 

• Fair, balanced and understandable, set out on page 18 – the statement given by the Directors that they consider 
the  annual  report  and  financial  statements  taken  as  a  whole  is  fair,  balanced  and  understandable  and  provides  the 
information necessary for shareholders to assess the Company’s performance, business model and strategy, is materially 
inconsistent with our knowledge obtained in the audit; or 

• Audit committee reporting, set out on pages 25 to 26 – the section describing the work of the audit committee 
does not appropriately address matters communicated by us to the audit committee; or 

• Directors’ statement of compliance with the UK Corporate Governance Code, set out on pages 20 to 
21 the parts of the Directors’ statement required under the Listing Rules relating to the Company’s compliance with the 
UK Corporate Governance Code containing provisions specified for review by the auditors in accordance with Listing 
Rule 9.8.10R (2) do not properly disclose a departure from a relevant provision of the UK Corporate Governance Code. 

 42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF 
ATHELNEY TRUST PLC  

            (Continued) 

Opinion on other matters prescribed by the Companies Act 2006 
In our opinion, based on the work undertaken in the course of the audit: 

the part of the Directors’ Remuneration Report to be audited has been properly prepared in accordance with 

 
the Companies Act 2006; 

the information given in the Strategic Report and the Report of the Directors for the financial year for which the 
 
financial  statements  are  prepared  is  consistent  with  the  financial  statements  and  those reports  have  been  prepared  in 
accordance with applicable legal requirements  

the information about internal control and risk management systems in relation to financial reporting processes 
 
and  about  share  capital  structures,  given  in  compliance  with  rules  7.2.5  and  7.2.6  in  the  Disclosure  Rules  and 
Transparency Rules sourcebook made by the Financial Conduct Authority (the FCA Rules), is consistent with the financial 
statements and has been prepared in accordance with applicable legal requirements; and 

 

information  about  the  Company’s  corporate  governance  code  and  practices  and  about  its  administrative, 
management and supervisory bodies and their committees complies with rules 7.2.2, 7.2.3 and 7.2.7 of the FCA 
Rules. 

Matters on which we are required to report by exception 
In the light of the knowledge and understanding of the Company and its environment obtained in the course of the audit, 
we have not identified material misstatements:  

 

 

 

 

 

 

 

 

       the strategic report or the Directors’ Report; or 

the information about internal control and risk management systems in relation to financial reporting processes    
and about share capital structures, given in compliance with rules 7.2.5 and 7.2.6 of the FCA Rules. 

We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 
requires   us to report to you if, in our opinion: 

adequate accounting records have not been kept, or returns adequate for our audit have not been received from  
branches not visited by us; or 

the financial statements and the part of the Directors’ Remuneration Report to be audited are not in agreement 
with the accounting records and returns; or 

certain disclosures of Directors’ remuneration specified by law are not made; or 

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

       a corporate governance statement has not been prepared by the Company. 

Responsibilities of Directors 
As  explained  more  fully  in  the  Statement  of  Directors'  responsibilities  (set  out  on  pages  34-35),  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 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 Company or to cease operations, or has no realistic alternative but to 
do so. 

 43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF 
ATHELNEY TRUST PLC  

            (Continued) 

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 Financial Reporting 
Council’s website at www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor’s report. 

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 auditors’ 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. 

Scott Lawrence FCA (Senior Statutory Auditor ) 
for and on behalf of Hazlewoods LLP 
Statutory Auditor, Cheltenham. 

4 March 2019 

 44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Income Statement 

For the Year Ended 31 December 
 2018 

For the Year Ended 31 December 
 2017 

Note  Revenue 

Capital 

Total 

Revenue 

Capital 

Total 

£ 

£ 

£ 

£ 

£ 

£ 

(Losses)/gains on 
investments held at fair 
value 

Income from investments 

Investment Management 
expenses 

Other expenses 

Net return on ordinary 
activities before taxation 

Taxation 

8 

2 

3 

3 

5 

Net return on ordinary 
activities after taxation         6 

- 

(1,135,313)) 

(1,135,313) 

- 

835,709 

835,709 

251,990 

- 

  251,990 

238,832 

- 

238,832 

(5,412) 

(51,068) 

(56,480) 

(6,128) 

(56,042) 

(62,170) 

(33,480) 

(106,537) 

(140,017) 

(26,527) 

(73,817) 

(100,344) 

213,098 

(1,292,918)  (1,079,820) 

206,177 

705,850 

912,027 

- 

- 

- 

- 

- 

                   - 

213,098 

(1,292,918)  (1,079,820) 

206,177 

705,850 

912,027 

Net return per 
ordinary share 

6 

9.9p 

(59.9)p 

(50.0)p 

9.6p 

32.7p 

42.3p 

Dividend per ordinary share 
paid during the year              7 

8.9p 

8.6p 

The total column of this statement is the profit and loss account for the Company. 
All revenue and capital items in the above statement derive from continuing operations. 
No operations were acquired or discontinued during the above financial years. 
A statement of movements of reserves is given overleaf. 
A Statement of Comprehensive Income is not required as all gains and losses of the Company have been reflected in the above Statement. 

The notes on pages 49 to 57 form part of these financial statements. 

 45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Statement of Changes in Equity for the Year Ended 
31 December 2018 

Called-up 
Share 
Capital 
£ 

Share 
Premium 
£ 

Capital 
reserve 
realised 
£ 

Capital 
reserve  Revenue 
reserve 
£ 

unrealised 
£ 

Total 
Shareholders’ 
Funds 
£ 

539,470 

881,087 

1747,083 

1852,759 

398,134 

5,418,533 

- 

- 

- 
- 
- 

- 

- 

- 
- 
- 

296,629 

- 

- 

539,080 

- 

- 

(129,859) 
- 
- 

- 
- 
- 

- 
206,177 
(185,036) 

296,629 

539,080 

(129,859) 
206,177 
(185,036) 

539,470 

881,087 

1,913,853 

2,391,839 

419,275 

6,145,524 

539,470 

881,087 

1,913,853 

2,391,839 

419,275 

6,145,524 

- 

- 

- 
- 
- 

- 

- 

- 
- 
- 

98,840 

- 

- 

(1,234,153) 

- 

- 

98,840 

(1,234,153) 

(157,605) 
- 
- 

- 
- 
- 

- 
213,098 
(192,051) 

(157,605) 
213,098 
(192,051) 

539,470 

881,087 

1,855,088 

1,157,686 

440,322 

4,873,653 

Balance brought forward at 1 
January 2017 
Net profits on realisation 
   of investments 
Increase in unrealised 
   appreciation 
Expenses allocated to  
   Capital 
Profit for the year 
Dividend paid in year 

Shareholders’ Funds at 
31 December 2017 

Balance brought forward at 1 
January 2018 
Net profits on realisation 
   of investments 
Decrease in unrealised 
   appreciation 
Expenses allocated to  
   Capital 
Profit for the year 
Dividend paid in year 

Shareholders’ Funds at 
31 December 2018 

  The notes on pages 49 to 57 form part of these financial statements. 

 46 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Statement of the Financial Position as at 
31 December 2018 

Company Number: 02933559 

                                                                       Note   

Fixed assets 
Investments held at fair value through profit and 
loss 

Current assets 
Debtors 
Cash at bank and in hand 

8 

9 

Creditors: amounts falling due within one 
year 

10 

Net current assets 

Total assets less current liabilities 

2018 

£ 

2017 

£ 

4,648,238 

5,966,679 

213,435 
35,520 
248,955 

(23,540) 

225,415 

4,873,653 

156,798 
45,289 
202,087 

(23,242) 

178,845 

6,145,524 

- 

Provisions for liabilities and charges 

-       

Net assets 

4,873,653 

6,145,524 

11 

Capital and reserves 
Called up share capital 
Share premium account 
Other reserves (non distributable) 
            Capital reserve - realised 
            Capital reserve - unrealised 
Revenue reserve (distributable) 

Shareholders' funds - all equity 

Net Asset Value per share 

13 

     Approved and authorised for issue by the Board of Directors on 4 March 2019. 

539,470 
881,087 

1,855,088 
1,157,686 
440,322 

4,873,653 

225.9p 

539,470 
881,087 

1,913,853 
2,391,839 
419,275 

6,145,524 

284.8p 

     ………………………………….. 

Ante

Frank
Frank Ashton 
Director 

The notes on pages 49 to 57 form part of these financial statements. 

 47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
                                                                                  Athelney Trust plc 

Statement of Cash flows for the Year Ended 
31 December 2018 

Cash flows from operating activities 
Net revenue return 
Adjustment for: 
Expenses charged to capital 
Increase in creditors 
(Increase)/decrease in debtors 

2018 
£ 

2017 
£ 

213,098 

 206,177 

      (157,605) 
299 
(56,638) 

(129,859) 
8,410 
100,166 

Cash (used)/from operations 

(846) 

184,894 

Cash flows from investing activities 
Purchase of investments 
Proceeds from sales of investments 
Net cash used in investing activities 

Equity dividends paid 

Net decrease in cash 

Cash at the beginning of the year 

Cash at the end of the year 

     The notes on pages 49 to 57 form part of these financial statements. 

(581,051) 
764,179 
183,128 

(674,520) 
660,818 
(13,702) 

(192,051) 

(185,036) 

(9,769) 

45,289 

35,520 

(13,844) 

59,133 

45,289 

 48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

1.  Accounting Policies 

1.1  Statement of Compliance and Basis of Preparation of Financial Statements 

The financial statements are prepared in accordance with applicable United Kingdom accounting standards, including 
Financial  Reporting  Standard  102  (“FRS  102”),  the  Companies  Act  2006  and  with  the  AIC  Statement  of 
Recommended  Practice  (“SORP”)  issued  in  November  2014  (amended  January  2017),  regarding  the  Financial 
Statements of Investment Trust Companies and Venture Capital Trusts. All the Company’s activities are continuing. 

1.2  Income 

Income from investments including taxes deducted at source is recognised when the right to the return is established 
(normally the ex-dividend date).  UK dividend income is reported net of tax credits  in  accordance with FRS  102 
“Income Tax”.  Interest is dealt with on an accruals basis. 

1.3  Investment Management Expenses 

All three Directors are involved in investment management, 10% of their salaries or fees have been charged to revenue 
and the other 90% to capital.  All other investment management expenses have been charged to capital.  The Board 
propose continuing this basis for future years. 

1.4  Other Expenses 

Expenses (including VAT) and interest payable are dealt with on an accruals basis and charged through the Revenue 
and Capital Accounts in an allocation that the Board consider to be a fair distribution of the costs incurred.  

1.5  Investments 

Listed investments comprise those listed on the Official List of the London Stock Exchange. Unlisted investments are 
traded  on  AIM.  Profits  or  losses  on  sales  of  investments  are  taken  to  realised  capital  reserve.  Any  unrealised 
appreciation or depreciation is taken to unrealised capital reserve. 

Investments have been classified as “fair value through profit and loss” upon initial recognition. 

Subsequent to initial recognition, investments are measured at fair value with changes in fair value recognised in the 
Income Statement. 

Securities of companies quoted on a recognised stock exchange are valued by reference to their quoted bid prices at 
the close of the year, similarly, AIM-traded investments are valued using the closing bid price on 31 December. 

1.6  Taxation 

The tax effect of different items of income and expenses is allocated between capital and revenue on the same basis as 
the particular item to which it relates, using the Company’s effective rate of tax for the year. 

1.7  Judgements and estimates 

The  Directors  confirm  that  no  judgements  or  significant  estimates  have  been  made  in  the  process  of  applying  the 
Company’s accounting policies. 

 49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

1. Accounting Policies (continued) 

1.8  Deferred Taxation 

Deferred tax is recognised in respect of all timing differences that have originated but not reversed by the balance sheet 
date. Deferred tax liabilities are recognised for all taxable timing differences but deferred tax assets are only recognised 
if it is considered more likely than not that there will be suitable profits from which the future reversal of the underlying 
timing differences can be deducted. Deferred tax assets and liabilities are calculated at the tax rates expected to be 
effective  at  the  time  the  timing  differences  are  expected  to  reverse.  Deferred  tax  assets  and  liabilities  are  not 
discounted. 

1.9  Capital Reserves 

Capital Reserve – Realised 
Gains and losses on realisation of fixed asset investments are dealt with in this reserve. 

Capital Reserve – Unrealised 
Increases and decreases in the valuations of fixed asset investments are dealt with in this reserve. Unrealised capital 
reserves cannot be distributed by way of dividends or similar. 

1.10 Dividends 

In accordance with FRS 102 “Events after the end of the Reporting Period”, dividends are included in the financial 
statements in the year in which they go ex-div.        

1.11 Share Issue Expenses  

The costs associated with issuing shares are written off against any premium arising on the issue of Share Capital. 

1.12 Financial Instruments 

Short term debtors and creditors are held at cost. 

2. Income 

Income from investments 

UK dividend income 
Foreign dividend income 
UK Property REITs 
Bank interest 

Total income 

UK dividend income 

UK Main Market listed investments 
UK AIM-traded shares 

 50 

2018 
£ 

183,833 
30,496 
37,653 
8 

251,990 

2018 
£ 

145,370 
38,463 

183,833 

2017 
£ 

154,547 
43,876 
40,334 
75 

238,832 

2017 
£ 

101,879 
52,668 

154,547 

 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

3. Return on Ordinary Activities before Taxation 

The following amounts (inclusive of VAT) are included 
within investment management and other expenses: 

Directors’ remuneration: 
  -  Services as a director 
  -  Otherwise in connection with management 
Auditors’ remuneration: 
  -  Audit Services - Statutory audit 
Miscellaneous expenses: 
 -   Other wages and salaries 
 -   Management services 
 -   PR and communications 
 -   Stock exchange subscription 
 -   Sundry investment management and other expenses 
-  Legal fees 

2018 
£ 

2017 
£ 

21,000 
51,163 

10,930 

2,400 
32,472 
2,958 
8,760 
24,255 
42,559 

21,000 
57,474 

10,500 

4,134 
30,996 
3,891 
7,920 
26,599 
- 

On 1 April 2016 the Company entered into a contract with GW & Co to provide management services at an annual cost 
of £24,600 plus VAT. An increase of 10% was agreed in July 2017 making the annual fee £27,060 plus VAT. 

196,497 

162,514 

4. Employees and Directors’ Remuneration 

Costs in respect of Directors: 

Non-executive directors’ fees 

     Wages and salaries 
     Social security costs 

Average number of employees: 
     Chairman 
     Investment 
    Administration 

2018 
£ 

21,000 
51,163 
2,400 

74,563 

- 
1 
- 
1 

2017 
£ 

               21,000 
57,474 
4,134 

82,608 

- 
1 
- 
1 

 51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

5. Taxation 

(i)  On the basis of these financial statements no provision has been made for corporation tax (2017: Nil). 
(ii) Factors affecting the tax charge for the year. 

The tax charge for the period is lower than (2017: lower than) the average small company rate of corporation tax in the 
UK of 19 per cent. The differences are explained below: 

Total return on ordinary activities before tax 

(1,079,820) 

    2018 
       £ 

2017 
£ 

912,027 

Total return on ordinary activities multiplied by the average small 
company rate of corporation tax 19% (2017: 19.25%) 

(205,166) 

175,565 

Effects of: 
UK dividend income not taxable 
Revaluation of shares not taxable 
Capital gains not taxable 
Unrelieved management expenses 

Current tax charge for the year 

(34,945) 
233,746 
(18,037) 
24,402 

-  

(29,750) 
(103,773) 
(57,101) 
15,059 

-  

The Company has unrelieved excess revenue management expenses of £214,415 at 31 December 2018 (2017: £127,914) 
and £102,597 (2017: £102,597) of capital losses for Corporation Tax purposes and which are available to be carried forward 
to future years. It is unlikely that the Company will generate sufficient taxable profits in the future to utilise these expenses 
and therefore no deferred tax asset has been recognised.  

For the year ended 31 December 2017, the Company received approval from HM Revenue and Customs under Section 
1158  of  the  Corporation  Tax  Act  2010,  therefore  the  Company  was  not  liable  to  Corporation  Tax  on  any  realised 
investment  gains  for  2017.    The  Directors  intend  to  continue  to  meet  the  conditions  required  to  obtain  approval  and 
therefore  no  deferred  tax  has  been  provided  on  any  capital  gains  or  losses  arising  on  the  revaluation  or  disposal  of 
investments. 

6. Return per Ordinary Share 

The calculation of earnings per share has been performed in accordance with FRS 102. 

£ 
Revenue 

2018 
£ 
Capital 

£ 
Total 

£ 

  Revenue 

2017 
£ 
Capital 

£ 
Total 

Attributable return on  
ordinary activities after 
taxation 

Weighted average number of 
shares 

213,098 

(1,292,918) 

(1,079,820) 

206,177 

705,850 

912,027 

2,157,881 

2,157,881 

Return per ordinary share 

9.9p 

(59.9)p 

(50.0)p 

9.6p 

32.7p 

42.3p 

 52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 
Notes to the Financial Statements  
For the Year Ended 31 December 2018 

7. Dividend 

Final dividend in respect of 2017 of 8.9p (2017: a final dividend 
of 8.6p was paid in respect of 2016) per share 

2018 
£ 

2017 
£ 

192,051 

185,036 

Set out below is the total dividend payable in respect of the financial year, which is the basis on which the requirements of 
Section 1158 of the Corporation Tax Act 2010 are considered.    

It is recommended that a final dividend of 9.1p (2017: 8.9p) per ordinary share be paid out of revenue profits amounting 
to a total of £196,367 For the year 2017, a final dividend of 8.9p was paid on 6 April 2018 amounting to a total of £192,051.  

2018 
£ 

213,098 

(196,367) 

16,731 

2018 
£ 

5,966,679 
581,051 
(764,179) 
98,840 
(1,234,153) 

4,648,238 

3,490,551 
1,157,687 

4,648,238 

3,530,985 
1,117,253 

4,648,238 

2017 
£ 

206,177 

(192,051) 

14,126 

2017 
£ 

5,117,268 
674,520 
(660,818) 
296,629 
539,080 

5,966,679 

3,574,834 
2,391,845 

5,966,679 

4,618,263 
1,348,416 

5,966,679 

Revenue available for distribution 
Final dividend in respect of financial year ended 
  31 December 2018 

Undistributed Revenue Reserve 

8. Investments 

Movements in year 
Valuation at beginning of year 
Purchases at cost 
Sales - proceeds 
         - realised gains on sales 
(Decrease)/increase in unrealised appreciation 

Valuation at end of year 

Book cost at end of year 
Unrealised appreciation at the end of the year 

UK Main Market listed investments 
UK AIM-traded shares 

 53 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

8. Investments (continued) 

Gains on investments 

Realised gains on sales 
(Decrease)/Increase in unrealised appreciation 

2018 
£ 

    98,840 
   (1,234,153) 

    (1,135,313) 

2017 
£ 

296,629 
539,080 

835,709 

The  purchase  costs  and  sales  proceeds  above  include  transaction  costs  of  £4,290  (2017:  £5,711)  and  £3,308  (2017: 
£2,401) respectively. 

9. Debtors 

Investment transaction debtors 
Other debtors 

10. Creditors: amounts falling due within one year 

Social security and other taxes 
Other creditors 
Accruals and deferred income 

11. Called Up Share Capital 

Authorised 
10,000,000 Ordinary Shares of 25p 

Allotted, called up and fully paid 
2,157,881 Ordinary Shares of 25p 
(2016: 2,157,881 Ordinary Shares of 25p) 

2018 
£ 
201,627 
11,808 

213,435 

2018 
£ 

524 
2,961 
20,055 

23,540 

2018 
£ 

2017 
£ 

148,483 
8,315 

156,798 

2017 
£ 
2,959 
8,628 
11,655 

23,242 

2017 
£ 

2,500,000 

2,500,000  

539,470 

539,470 

 54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

12. Financial Instruments 

The Company’s financial instruments  comprise equity investments, cash balances  and debtors and creditors that arise 
directly from its operations, for example, in respect of sales and purchases awaiting settlement. 

The  major  risks  associated  with  the  Company  are  market,  credit  and  liquidity  risk.  The  Company  has  established  a 
framework  for  managing  these  risks.  The  Directors  have  guidelines  for  the  management  of  investments  and  financial 
instruments.  

Market Risk  

Market  price  risk  arises  mainly  from  uncertainty  about  future  prices  of  financial  investments  used  in  the  Company’s 
business. It represents the potential loss  the Company might suffer through holding market positions by way of price 
movements other than movements in exchange rates and interest rates.  

The Company’s investment portfolio is exposed to market price fluctuations which are monitored by the Fund Manager 
who gives timely reports of relevant information to the Directors. 

Adherence to the investment objectives and the internal controls on investments set by the Company mitigates the risk of 
excessive exposure to any one particular type of security or issuer. 

The Company’s exposure to other changes in market prices at 31 December on its investments is as follows:  

A 20% decrease in the market value of investments at 31 December 2018 would have decreased net assets attributable to 
shareholders by 43 pence per share (2017: 55.3 pence per share). An increase of the same percentage would have an equal 
but opposite effect on net assets available to shareholders. 

Fair value through profit or loss investments  

2018 
£ 
4,648,238 

2017 
£ 
5,966,679 

Market risk also arises from changes in interest rates and exchange risk.  All of the Company’s assets are in sterling and 
accordingly the Company has limited currency exposure.  The majority of the Company’s financial assets are non-interest 
bearing, as a result the Company’s financial assets are not subject to significant risk due to fluctuations in the prevailing 
levels of market interest rates. 

The  carrying  amounts  of  financial  assets  best  represent  the  maximum  credit  risk  exposure  at  the  balance  sheet  date. 
Bankruptcy  or  insolvency  of  the  custodian  may  cause  the  Company’s  rights  with  respect  to  securities  held  with  the 
custodian to be delayed. 

Liquidity Risk  
Liquidity Risk is the risk that the Company may have difficulty in meeting obligations associated with financial liabilities.  
The Company is able to reposition its investment portfolio when required so as to accommodate liquidity needs.  However 
it may be difficult to realise its investment portfolio in adverse market conditions. 

Maturity Analysis of Financial Liabilities 
The Company’s financial liabilities consist of creditors as disclosed in note 10. All items are due within one year. 

 55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

12. Financial Instruments (continued) 

Capital management policies and procedures  
The Company’s capital management objectives are:  

 

 

 

 

to ensure the Company’s ability to continue as a going concern;  

to provide an adequate return to shareholders;  

to support the Company’s stability and growth;  

to provide capital for the purpose of further investments.  

The Company actively and regularly reviews  and manages  its capital  structure to ensure an optimal capital structure, 
taking into consideration the future capital requirements of the Company and capital efficiency, projected operating cash 
flows and projected strategic investment opportunities. The management regards capital as total equity and reserves, for 
capital management purposes. 

Fair values of financial assets and financial liabilities 
Fixed asset investments (see note 8) are valued at market bid price where available which equates to their fair values. The 
fair values of all other assets and liabilities are represented by their carrying values in the balance sheet.  

Financial instruments by category 
The financial instruments of the Company fall into the following categories 

31 December 2018 

Assets as per the balance sheet 
Investments 
Debtors 
Cash at bank 
Total 

Liabilities as per the balance sheet 
Creditors 
Total 

31 December 2017 

Assets as per the balance sheet 
Investments 
Debtors 
Cash at bank 
Total 

Liabilities as per the balance sheet 
Creditors 

                Total 

At 
Amortised 
Cost 
£ 

Assets at fair 
value through 
profit or loss 
£ 

- 
213,435 
35,520 
248,955 

23,540 
23,540 

4,648,238 
- 
- 
4,648,238 

- 
- 

At Amortised 
Cost 
£ 

Assets at fair 
value through 
profit or loss 
£ 

- 
156,798 
45,289 
202,087 

23,242 
23,242 

5,966,679 
- 
- 
5,966,679 

- 
- 

 56 

Total 
£ 

4,648,238 
213,435 
35,520 
4,897,193 

23,540 
23,540 

Total 
£ 

5,966,679 
156,798 
45,289 
6,168,766 

23,242 
23,242 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2018 

12. Financial Instruments (continued) 

Fair value hierarchy  
In accordance with FRS 102, the Company must disclose the fair value hierarchy of financial instruments. 

The fair value hierarchy consists of the following three classifications:  

Classification A – Quoted prices in active markets for identical assets or liabilities.  
Quoted  in  an  active  market  in  this  context  means  quoted  prices  are  readily  and  regularly  available  and  those  prices 
represent actual and regularly occurring market transactions on an arm’s length basis. 

Classification B – The price of a recent transaction for an identical asset, where quoted prices are unavailable.  

The price of a recent transaction for an identical  asset provides evidence of fair value as long as there has not been a 
significant change in economic circumstances or a significant lapse of time since the transaction took place. If it can be 
demonstrated that the last transaction price is not a good estimate of fair value (e.g. because it reflects the amount that an 
entity would receive or pay in a forced transaction, involuntary liquidation or distress sale), that price is adjusted. 

Classification C – Inputs for the asset or liability that are based on observable market data and unobservable market 
data,  to  estimate  what  the  transaction  price  would  have  been  on  the  measurement  data  in  an  arm’s  length  exchange 
motivated by normal business considerations. 

The Company only holds classification A investments (2017: classification A investments only). 

13. Net Asset Value per Share 

The  net  asset  value  per  share  is  based  on  net  assets  of  £4,873,653  (2017:  £6,145,524)  divided  by  2,157,881  (2017: 
2,157,881) ordinary shares in issue at the year end. 

Net asset value per share 

225.9p 

284.8p  

2018 

2017 

14. Dividends paid to Directors 

During the year the following dividends were paid to the Directors of the Company as a result of their total shareholding: 

Mr Robin Boyle 
Dr. Manny Pohl 
Mr Simon Moore 

Notes: 

£39,966² 
£31,118¹ 
£2,848 

1.  Dr Manny Pohl’s relationship with Global Masters Fund Limited is described in Note 1 to the table of Directors’ interests 

on page 38. During the year a dividend of £31,118 was paid to Global Masters Fund Limited.  

2.  This figure includes £34,852 paid to Trehellas House Limited. Mr Robin Boyle’s interest in Trehellas House Limited is 

described in Note 2 to the table of Directors’ interests on page 38. 

 57 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

OFFICERS AND FINANCIAL ADVISERS 

Directors:  

Secretaries:  

Registered Office: 

Mr N F Ashton (Chairman) 
Mr D Lawman 
Mrs H Sachdev 

                 Email: frankashton@athelneytrust.co.uk 

Email: davidlawman@athelneytrust.co.uk 
Email: helensachdev@athelneytrust.co.uk 

J. Girdlestone and D.Warburton 
Waterside Court  
Falmouth Road 
Penryn 
Cornwall, TR10 8AW 

Waterside Court  
Falmouth Road  
Penryn 
Cornwall, TR10 8AW 

Email: john@athelneytrust.co.uk 
Tel: 01326 378 288   

Website: www.athelneytrust.co.uk  
Email: info@athelneytrust.co.uk 
Tel: 01326 378 288 

Company Number:   

02933559  
(Incorporated and registered in England) 

Solicitor:   

Druces LLP 
Salisbury House 
London Wall 
London 
EC2M 5PS 

Email: d.smith@druces.com 
Tel: 020 7638 9271 

Stockbroker: 

James Sharp & Co  
                                                                   5 Bank Street                                             Tel: 0161 764 4043 
                                                                   Bury 
                                                                   Lancashire, BL9 0DN 

                Email: mail@jamessharp.co.uk 

Auditors:   

Banker: 

Registrar:  

Hazlewoods  LLP 
Windsor House  
Bayshill Road 
Cheltenham 
GL50 3AT 

HSBC Bank Plc 
Market Street 
Falmouth 
Cornwall, TR11 3AA 

Share Registrars Limited  
Suite E First Floor 
9 Lion & Lamb Yard 
Farnham 
Surrey, GU9 7LL 

Email: scott.lawrence@hazlewoods.co.uk 
Tel: 01242 237 661 

Email: peter@shareregistrars.uk.com 
Tel: 01252 821 390 

 58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
THIS DOCUMENT IS IMPORTANT AND REQUIRES YOUR IMMEDIATE ATTENTION. 

If  you  are  in  any  doubt  as  to  the  content  or  action  you  should  take,  you  should  immediately  consult  your 
stockbroker, bank manager, solicitor, accountant or other independent financial adviser authorised under the 
Financial Services and Markets Act 2000.  
If  you  have  sold  or  otherwise  transferred  all  your  shares  in  Athelney  Trust  plc  please  send  this  document, 
together with the accompanying Form of Proxy to the purchaser or transferee or to the stockbroker, bank or 
other agent through whom the sale or transfer was effected for transmission to the purchaser or transferee. 
____________________________________________________________________________________ 

ATHELNEY TRUST PLC 

NOTICE OF ANNUAL GENERAL MEETING 

Notice of the Annual General Meeting to be held at the offices of Druces LLP, Salisbury House, London Wall, 
London EC2M 5PS on 3 April 2019 at 2.00pm is set out at the end of this document.  The accompanying Form of 
Proxy for use at the Annual General Meeting should be completed and returned and to be valid to reach John 
Girdlestone, C/O Athelney Trust plc, Waterside Court, Falmouth Road, Penryn, Cornwall TR10 8AW as soon as 
possible but, in any event so as to arrive not later than 48 hours prior to the meeting time being not later than 
2.00pm on 1 April 2019. Instructions for the appointment of proxies through CREST are contained in the Notes 
to the Notice of Annual General Meeting. 

 59 

 
 
 
 
 
 
 
 
 
 
 
  
Letter from the Chairman 
Athelney Trust PLC 
(Incorporated and registered in England and Wales with No. 02933559) 

Directors 
D Lawman 
F Ashton 
H Sachdev 

Registered office: 
Waterside Court 
Falmouth Road 
Penryn 
Cornwall TR10 8AW 

To the holders of ordinary shares of 25p each (“Shares”) in the capital of Athelney Trust plc 
(“Company”).  

                                                                                                                                                     4 March 2019 

Dear Shareholder, 

2019 ANNUAL GENERAL MEETING 
APPROVAL OF ANNUAL REPORT AND ACCOUNTS AND OTHER RESOLUTIONS 

Introduction 

The 2019 Annual General Meeting (“AGM”) of the Company is to be held on 3 April 2019 at 2.00pm at the 
offices of Druces LLP, Salisbury House, London Wall, London EC2M 5PS.  A copy of the notice convening 
the AGM (the “Notice”) is set out at the end of this letter. 

Your full attention is directed to the full terms of the Notice. 

As you will see from the Notice, there are additional items of special business to be considered at Resolutions 
10, 11 and 12. 

I am writing to you to explain its purpose. 

In addition, the normal business of the Annual General Meeting including appointment of Directors and the 
approval of the Annual Report and Accounts for the year ended 31 December 2018 will be undertaken at this 
meeting.   Reference is made to those resolutions at the end of this letter.  A copy of the Annual Report and 
Accounts is enclosed. 

Proposal 

It is the belief of the Directors of the Company (the “Directors” or the “Board”) that the Company would 
benefit from the Directors being authorised to allot further shares in the Company so that the Company may 
make offers and enter into agreements during the relevant period which would, or might, require shares to 
be allotted or rights to subscribe for, or convert other securities into, shares to be granted after the authority 
ends. The Directors further believe that the statutory pre-emption rights on the issue of new shares for cash 
which are contained in the Companies Act should be disapplied and that the Company should be allowed to 
purchase its own shares. 

Resolution 7 proposes as follows: 
The authority given to the Directors to allot further shares or to grant rights to subscribe for, or to convert 
securities  into  ordinary  shares  in  the  capital  of  the  Company  requires  the  prior  authorisation  of  the 
shareholders in general meeting under section 551 Companies Act 2006. 

Upon the passing of Resolution 7, the Directors will (pursuant to paragraph (i) of Resolution 7) have the 
necessary authority until the date of the next annual general meeting, or 30 April 2019 if earlier, to allot 

 60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and/or grant equity securities (as defined in section 560(1) of the Act), up to an aggregate nominal amount 
of £53,947, which is equivalent to 10 per cent of the current issued share capital. 

In addition, upon the passing of Resolution 7, (pursuant to paragraph (ii) of Resolution 7) the Directors will 
have authority, until the date of the next annual general meeting of the Company or 30 April 2020 if earlier, 
to allot and/or grant equity securities (as defined in section 560(1) of the Act) in connection with a rights 
issue or other pre-emptive offer in favour of Shareholders (subject to certain exclusions) up to an aggregate 
nominal amount equal to £53,947. 

The Directors will continue to seek to renew this authority at each annual general meeting. 

This limited authority will enable the Directors to issue shares when they believe it is in the interests of the 
Company  to  do  so.    While  the  Company  would  always  consider  from  time  to  time  the  best  manner  of 
financing  its  activities,  there  is  no  present  intention  of  issuing  ordinary  shares  pursuant  to  the  authority 
proposed in Resolution 7. 

Resolution 8 proposes as follows: 
If the Directors wish to exercise the authority under Resolution 7 and issue Shares (or sell any shares which 
the Company may purchase and elect to hold as treasury shares) for cash, the Companies Act 2006 requires 
that unless shareholders have given specific authority for the waiver of their statutory pre-emption rights, the 
new shares must be offered first to existing shareholders in proportion to their existing shareholdings. This 
can be a cumbersome and particularly expensive exercise for a company of this size. 

Accordingly  if  passed  Resolution  8  will empower  the Directors  until  the  date  of the  next annual  general 
meeting of the Company, or 30 April 2020 if earlier, to allot and/grant equity securities for cash (or transfer 
shares which are from time to time held by the Company in treasury) (i)  by way of a pre-emptive offer(a) by 
way of a rights issue (subject to certain exclusions), or (b) by way of an open offer or other offer of securities 
(not being a rights issue) in favour of existing shareholders in proportion to their shareholdings (subject to 
certain exclusions) or (ii) otherwise than pursuant to (i) up to an aggregate nominal value of £53,947. The 
Directors will seek to renew such authority and power at successive annual general meetings. 

This limited authority will enable the Directors to issue shares for cash when they believe it is in the interests 
of the Company to do so.   

As at 1 March 2019 (being the last practicable date prior to publication of this document), the Company held 
no shares in treasury. 

Resolution 9 proposes as follows: 
That authority be granted to the Directors to make market purchases (as defined in section 693 Companies 
Act 2006) of ordinary shares of 25p in the capital of the Company. In this case the authority contained in the 
resolution will be limited to a maximum number of ordinary shares of 25p each equivalent to 10 per cent of 
the issued ordinary shares of the Company at a minimum price of 25 pence per share and a maximum price 
(exclusive of expenses) being an amount equal to 105 per cent of the average of the middle market quotations 
for an ordinary share of the Company (as derived from the Daily Official List of London Stock Exchange plc) 
for the five trading days immediately preceding the day on which the share is contracted to be purchased. 
This authority will expire at the Annual General Meeting for 2020 or on 30 April 2020 if sooner. 

Other resolutions 
On 18 February 2019 the directors received a requisition letter from Global Masters Fund Limited in which 
Dr EC Pohl has a 54.1% interest.  Global Masters Fund Limited, a substantial shareholder in the Company, 

 61 

 
 
 
 
 
 
 
 
 
 
 
 
 
through this letter is requiring the following resolutions, included in the Notice as resolutions 10, 11 and 12, 
to be proposed at the AGM: 

  That Simon Moore be appointed as a Director of the Company 
  That Emmanuel Clive Pohl be appointed as a Director of the Company 
  That David Lawman be removed as a Director of the Company 

The other resolutions proposed to be taken at the AGM are set out below and constitute the normal annual 
business of the meeting. 

Resolutions  1  to  6  relate  to  the  receiving  of  the  report  and  accounts;  the  declaration  of  a  dividend;  the 
approval of the report of the remuneration committee; the re-election of Mr F Ashton and Mrs H Sachdev 
who retire and offer themselves for re-election under the articles of association; and the re-appointment of 
the auditors and approval of authority to set their remuneration. 

Form of proxy and meeting arrangements 

A form of proxy is enclosed for you to complete according to the instructions given in the Notice and on the 
proxy form.  The completed form should be sent to John Girdlestone, C/O Athelney Trust plc, Waterside 
Court, Falmouth Road, Penryn, Cornwall TR10 8AW to be received not later than 48 hours before the start 
of the meeting being not later than 2.00pm on 1 April 2019.  Appointment of a proxy will not prevent you 
from attending and voting at the meeting if you subsequently find that you are able to do so. 

Instructions for appointing a proxy through CREST are given in the notes to the Notice. 

We would very much welcome you to the meeting, if you can attend, where there will be an opportunity for 
you to ask questions relating to the business of the meeting. 

Recommendations 

I consider that resolutions 1 to 9 in the Notice are in the best interests of the Company and shareholders as a 
whole and I and my fellow Directors unanimously recommend that you vote in favour of Resolutions 1-
9. 

I consider that resolutions 10 to 12 in the Notice are not in the best interests of the Company and shareholders 
as a whole.  The full reasoning is set out in the Outlook sub-section, under Chairman’s Statement of the Annual 
Report.  In summary we believe it is a retrograde step, returning the Company to the uncertain and ultimately 
costly management conditions of the last quarter of 2018 and therefore producing less shareholder value over 
time than our plan.  I and my fellow Directors unanimously recommend that you vote against Resolutions 
10, 11 and 12. 

Yours faithfully, 

Mr Frank Ashton 
Executive Chairman 

 62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 NOTICE OF ANNUAL GENERAL MEETING 

NOTICE IS HEREBY GIVEN that the Annual General Meeting of Athelney Trust plc ( “the Company”) will be held at 
the offices of Druces LLP, Salisbury House, London Wall, London EC2M 5PS on 3 April 2019 at 2.00pm to consider 
the following Ordinary and Special business, of which Resolutions 1 to 6 will be proposed as Ordinary Resolutions, 
Resolutions 7 to 9 will be proposed as Special Resolutions and Resolutions 10 to 12 will be proposed as Ordinary 
Resolutions: 

ORDINARY BUSINESS 

1 

2 

3 

4 

5 

6 

To receive and adopt the Company’s Accounts for the year ended 31 December 2018. 

To declare a final dividend of 9.1p per ordinary share.  It is intended that dividend cheques in respect of the 
dividend will be posted on 18 April 2019 to all shareholders on the register of members at close of business 
on 22 March 2019.  

To approve the Directors’ Remuneration Report (excluding the Directors’ Remuneration Policy) as set out 
on pages 36-39 of the Company’s Accounts for the year ended 31 December 2018. 

To re-elect Mr F Ashton as a Director of the Company retiring pursuant to the Articles of Association. 

To re-elect Mrs H Sachdev as a Director of the Company retiring pursuant to the Articles of Association. 

To  appoint  Hazlewoods  LLP  as  auditors  to  the  Company  and  to  authorise  the  Directors  to  fix  their 
remuneration. 

SPECIAL BUSINESS 

7 

 Directors’ authority to allot shares 

To resolve that the Directors be generally and unconditionally authorised pursuant to and in accordance with 
section 551 of the Companies Act 2006 to exercise all the powers of the Company to allot shares or grant 
rights to subscribe for or to convert any security into shares: 

(i)  up to an aggregate nominal amount of £53,947; and 

(ii)  comprising equity securities (as defined in section 560(1) of the Companies Act 2006) up to a 

further nominal amount of £53,947 in connection with a pre-emptive offer 

such authorities to apply in substitution for all previous authorities pursuant to section 551 of the Companies 
Act 2006 and to expire at the conclusion of the next annual general meeting or on 30 April 2020, whichever 
is the earlier but, in each case, so that the Company may make offers and enter into agreements during the 
relevant period which would, or might, require shares to be allotted or rights to subscribe for, or convert 
other securities into, shares to be granted after the authority ends. 

For the purposes of this resolution: 

(a)  “pre-emptive offer” means a rights issue or an offer of equity securities open for acceptance for a period 
fixed by the Directors to (i) holders (other than the Company) on the register on a record date fixed by the 
Directors of ordinary shares in proportion to their respective holdings and (ii) other persons so entitled by 
virtue of the rights attaching to any other equity securities held by them, but subject in all such cases to such 
exclusions or other arrangements as the Directors may deem necessary or expedient in relation to treasury 
shares, fractional entitlements, record dates, legal, regulatory or practical problems in, or under the laws of, 
any territory; and 

 63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(b)  “rights issue” means an offer to (i) ordinary shareholders in proportion (or as near as may be practicable) 
to their existing holdings; (ii) to people who are holders of other equity securities if this is required by the 
rights of those securities or, if the Directors consider it necessary, as permitted by the rights of those securities; 
in  either  case  to  subscribe  for  further  securities  by  means  of  the  issue  of  a  renounceable  letter  (or  other 
negotiable document) which may be traded for a period before payment for the securities is due, but subject 
in both cases to such exclusions or other arrangements as the Directors may deem necessary or expedient in 
relation to treasury shares, fractional entitlements, record dates, legal, regulatory or practical problems in, or 
under the laws of, any territory. 

8 

Limited disapplication of pre-emption rights 

That, subject to the passing of Resolution 7 above, the Directors be empowered to allot equity securities (as 
defined in section 560(1)  of  the  Companies Act 2006) wholly for  cash pursuant  to the authority given by 
paragraph (i) of Resolution 7 above or where the allotment constitutes an allotment of equity securities by 
virtue of section 560(3) of the Companies Act 2006 in each case: 

(a)  generally, up to an aggregate nominal  amount of £53,947 pursuant to the authority given by paragraph 

(i) of Resolution 7 above;  and 

(b) 

in connection with a pre-emptive offer pursuant to the authority given by paragraph (ii) of Resolution 7 
above 

such power to expire at the conclusion of the next annual general meeting or on 30 April 2020, whichever is 
the earlier, but so that the Company may make offers and enter into agreements during this period which 
would, or might, require equity securities to be allotted after the power ends and the  Directors may allot 
equity securities under any such offer or agreement as if the power had not ended. 

For the purposes of this resolution: 

(a)  pre-emptive offer has the same meaning as in Resolution 7 above;  

(b)  references to an allotment of equity securities shall include a sale of treasury shares; and 

(c)   the nominal amount of any securities shall be taken to be, in the case of rights to subscribe for or convert 
any securities into shares of the Company, the nominal amount of such shares which may be allotted 
pursuant to such rights. 

9 

Authority to purchase ordinary shares  

That the Company be and is hereby generally and unconditionally authorised for the purposes of section 701 
of the Companies Act 2006 to make market purchases (within the meaning of section 693 of the Companies 
Act 2006) of ordinary shares of 25p each in the capital of the Company and where such shares are held in 
treasury, the Company may use them for the purposes of its employees’ share plans, provided that: 

(a) 

(b)   

(c) 

the  maximum  aggregate  number  of  ordinary  shares  authorised  to  be  purchased  shall  be  such  an 
amount as represents 10 per cent of the Company’s issued share capital from time to time; 

the minimum price which may be paid for each ordinary share shall be 25p; 

the maximum price, exclusive of expenses, which may be paid for each ordinary share shall be an 
amount equal to the higher of (a) 105 per cent of the average closing price of the Company’s ordinary 
shares as derived from the London Stock Exchange Daily Official List  for the five London business 
days immediately preceding the day on which such share is contracted to be purchased or (b) the 
higher of the price of the last independent trade and the highest current bid as stipulated by Article 
5(1)  of  the  Commission  Regulation  (EC)  22  December  2003  implementing  the  Market  Abuse 
Directive as regards exemptions for buy-back programmes and stabilisation of financial instruments 
(No 2273/2003); 

 64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(d)   

(e) 

this authority shall expire at the conclusion of the next annual general meeting or on 30 April 2020 
whichever is the earlier, unless such authority is renewed before then; and 

the Company may make a contract to purchase its ordinary shares under this authority before its 
expiry which would or might be executed wholly or partly after the expiry, and may make a purchase 
of its ordinary shares under that contract 

SPECIAL BUSINESS PURSUANT TO A SHAREHOLDER REQUISITION 

10 

11 

12 

That Simon Moore be appointed as a Director of the Company 

That Emmanuel Clive Pohl be appointed as a Director of the Company 

That David Lawman be removed as a Director of the Company 

Dated 4 March 2019 

By Order of the Board   
John Girdlestone  
Company Secretary 

Registered office: 
Waterside Court 
Falmouth Road 
Penryn 
Cornwall TR10 8AW 

 65 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes 

Appointment of Proxies 

1.  A member entitled to attend and vote at the meeting is entitled to appoint another person(s) (who need 
not be a member of the Company) to exercise all or any of his rights to attend, speak and vote at the meeting. 
A member can appoint more than one proxy in relation to the meeting, provided that each proxy is appointed 
to exercise the rights attaching to different shares held by him. 

2.  Your proxy could be the Chairman, another director of the Company or another person who has agreed 
to attend to represent you.  Your proxy will vote as you instruct and must attend the meeting for your vote 
to be counted. Details of how to appoint the Chairman or another person as your proxy using the proxy form 
are set out in the notes to the proxy form. Appointing a proxy does not preclude you from attending the 
meeting and voting in person. If you attend the meeting in person, your proxy appointment will automatically 
be terminated. 

3.  An appointment of proxy is provided with this notice and instructions for use are shown on the form. In 
order to be valid, a completed appointment of proxy must be returned to the Company by one of the following 
methods: 
3.1  in hard copy form by post or by hand to the Company Secretary at the address shown on the form of 
proxy; or 
3.2  in  the  case  of  CREST  members,  by  utilising  the  CREST  electronic  proxy  appointment  service  in 
accordance with the procedures set out below, 
 and in each case must be received by the Company Secretary or as the case may be the Company's Registrars 
not less than 48 hours before the time fixed for the meeting. Please note that any electronic communication 
sent to us/our registrars in respect of the appointment of a proxy that is found to contain a computer virus 
will not be accepted. 

4.  To change your proxy instructions you may return a new proxy appointment using the methods set out 
above.  Where you have appointed a proxy  using  the hard copy proxy form and would like to change the 
instructions using another hard copy proxy form, please contact the Company Secretary at Waterside Court, 
Falmouth Road, Penryn, Cornwall TR10 8AW. The deadline for receipt of proxy appointments (see above) 
also applies in relation to amended instructions. Any attempt to terminate or amend a proxy appointment 
received after the relevant deadline will be disregarded. Where two or more valid separate appointments of 
proxy are received in respect of the same share in respect of the same meeting, the one which is last sent shall 
be treated as replacing and revoking the other or others. 

5.  Crest Members 

5.1  CREST  members  who  wish  to  appoint  a  proxy  or  proxies  by  utilising  the  CREST  electronic  proxy 
appointment service may do so by utilising the procedures described in the CREST Manual. CREST Personal 
Members  or other CREST sponsored members,  and those CREST  members  who have appointed a voting 
service provider(s), should refer to their CREST sponsor or voting service provider(s), who will be able to 
take the appropriate action on their behalf. 

5.2  In order for a proxy appointment made by means of CREST to be valid, the appropriate CREST message 
(a "CREST Proxy Instruction") must be properly authenticated in accordance with Euroclear UK & Ireland's 
specifications and must  contain the information required  for such instructions, as described in the CREST 
Manual. The message, regardless of whether it constitutes the appointment of a proxy or an amendment to 
the instruction given to a previously appointed proxy, must, in order to be valid, be transmitted so as to be 
received by the issuer's agent (ID 7RA36) by the latest time(s) for receipt of proxy appointments specified in 
the notice of meeting. For this purpose, the time of receipt will be taken to be the time (as determined by the 
timestamp applied to the message by the CREST Applications Host) from which the issuer's agent is able to 
retrieve the message by enquiry to CREST in the manner prescribed by CREST. 

5.3  The Company may treat as invalid a CREST Proxy Instruction in the circumstances set out in Regulation 
35(5)(a) of the Uncertificated Securities Regulations 2001. 

6.  Only those shareholders registered in the Register of Members of the Company as at 6.00p.m. on 22 March 2019 
(or, if the meeting is adjourned, on the date which is two days before the time of the adjourned meeting) shall be entitled 
to attend and vote at the meeting or adjourned meeting in respect of the number of shares registered in their respective 

 66 

 
 
 
 
 
 
 
 
 
 
 
 
names at that time. Changes to the Register of Members after that time will be disregarded in determining the rights of 
any person to attend or vote at the meeting or adjourned meeting. 

7.  Any corporation which is a member can appoint one or more corporate representatives who may exercise on its 
behalf all of its powers as a member provided that they do not do so in relation to the same shares. 

Nominated Persons 

8.  A copy of this notice has been sent for information only to persons who have been nominated by a member to enjoy 
information rights under section 146 of the Companies Act 2006 (a "Nominated Person"). The rights to appoint a proxy 
cannot be exercised by a Nominated Person they can only be exercised by the member. However, a Nominated Person 
may have a right under an agreement between him and the member who has nominated him to be appointed as a proxy 
for the meeting or to have someone else so appointed. If a Nominated Person does not have such a right or does not wish 
to exercise it, he may have a right under such an agreement to give instructions to the member as to the exercise of voting 
rights. 

lssued Shares and Total Voting Rights 

9.  As at 1 March 2019 (being the last business day before the publication of this Notice), the Company's issued share 
capital consisted of 2,157,881 ordinary shares carrying one vote each. Therefore the total voting rights in the Company 
are currently 2,157,881. 

Website Publication of Audit Concerns 

10.  Members satisfying the thresholds in section 527 of the Companies Act 2006 can require the Company to publish 
a statement on its website setting out any matter relating to the audit of the Company's accounts (including the auditor's 
report and  the conduct of the audit) that are to be laid before the meeting. 
The Company cannot require the members requesting the publication to pay its expenses. Any statement placed on the 
website must also be sent to the Company's auditor no later than the time it makes its statement available on the website. 
The business which may be dealt with at the meeting includes any statement that the Company has been required to 
publish on its website. 

Members' Right to ask Questions 

11.  Any member attending the meeting has the right to ask questions. The Company must cause to be answered any 
such question relating to the business being dealt with at the meeting but no such answer need be given if: 

11.1  to  do  so  would  interfere  unduly  with  the  preparation  for  the  meeting  or  involve  the  disclosure  of  confidential 
information; 

11.2  the answer has already been given on a website in the form of an answer to a question; or 

11.3  it is undesirable in the interests of the Company or the good order of the meeting that the question be answered. 

Documents on Display 

12.  The  following  documents  are  available  for  inspection  at  the  Company's  registered  office  at  Waterside  Court, 
Falmouth Road, Penryn, Cornwall TR10 8AW during normal business hours on each weekday (public holidays excluded) 
from the date of this Notice of Annual General Meeting until the date of the Annual General Meeting and will be available 
for inspection at the place of the Annual General Meeting for at least 15 minutes prior to and during the meeting: 

12.1  copy of the Managing Director’s service contract with the Company; 

12.2  copies of Letters of Appointment of the Non-Executive Directors; and 

12.3  a copy of the Articles of Association of the Company. 

A copy of this notice, and other information required by section 311A of the Companies Act 2006, can be found at 
www.athelneytrust.co.uk 

 67 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ATHELNEY TRUST PLC 
Company Number 02933559 
Form of Proxy for use at the Annual General Meeting to be held at 2.00pm on 3 April 2019 
at the offices of Druces LLP. Salisbury House, London Wall, London EC2M 5PS 

in 

full) 

(name 

.................................................................(IN  BLOCK  CAPITALS)  of 
I/We 
......................................................................................................hereby appoint the Chairman of the 
Meeting 
..........................................of 
................................................................................... to act as my/our proxy to attend, speak and vote 
at the Annual General Meeting of the Company to be held on 3 April 2019 and at any adjournment thereof. 

failing 

him 

or 

I/We direct my/our proxy to vote on the following resolutions as I/we have indicated by marking the appropriate box 
with an “X”.  If no indication is given below, my/our proxy will vote or abstain from voting at his or her discretion. 
FOR  AGAINST  ABSTAIN  DISCRETIONARY 

RESOLUTIONS 

1 

2 

3 

4 

5 

6 

7 

8 

To receive and adopt the Company’s Accounts 
for the year ending 31 December 2018. 

To declare a final dividend of 9.1p per ordinary 
share. 

To approve the Directors’ Remuneration 
Report (excluding the Directors’ Remuneration 
Policy) for the year ended 31 December 2018. 

To re-elect Mr F Ashton as a Director retiring 
pursuant to the Articles of Association. 

To re-elect Mrs H Sachdev as a Director 
retiring pursuant to the Articles of Association. 

To appoint Hazlewoods as the Auditors and 
authorise the Directors to fix their 
remuneration. 

To resolve that the Directors be generally and 
unconditionally authorised to allot shares to the 
extent stated in the resolution. 

To resolve to dis-apply the statutory pre-
emption rights to the extent stated in this 
resolution. 

9 

To Authorise purchase of own shares. 

10  To elect Mr S Moore as a Director 

11  To elect Dr E C Pohl as a Director 

12  To remove Mr D Lawman as a Director 

Your attention is drawn to the notes overleaf. 

Signature(s)...................................................... 

Dated............................................  

 68 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTES 

1.  To be valid, completed forms must be returned to the Company by one of the following methods: 

in hard copy form by post, by courier or by hand to the Company’s Registered Office Waterside Court, Falmouth  

1.1 
Road, Penryn, Cornwall TR10 8AW; or 

1.2 in the case of CREST members, by utilising the CREST electronic proxy appointment service in accordance with the 
procedures set out below, 

and in each case must be received by the Company Secretary or (as the case may be) the Company’s Registrars not less than 
48 hours before the time fixed for the meeting. If someone else signed the form on your behalf, you or that person must 
send the power of attorney or other written authority under which it is signed to the Company’s registrars so that it is 
received not less than 48 hours before the time fixed for the meeting. 

2.  A  corporation  must  execute  this  form  either  under  its  common  seal  or  under  the  hand  of  an  officer  or  attorney  duly 

authorised in writing. 

3.  This form enables you to instruct your proxy how to vote, whether on a show of hands or on a poll, on the resolutions to 
be proposed at the meeting. If you want your proxy to vote in a certain way on the resolutions specified please place an ‘X’ 
in the relevant boxes. If you fail to select any of the given options your proxy can vote as he or she chooses or can decide 
not to vote at all. The proxy can also do this on any other resolution that is put to the meeting. The ‘Vote Withheld’ option 
is provided to enable you to abstain on any particular resolution; however it should be noted that a ‘vote withheld’ is not a 
vote in law and will not be counted in the calculation of the proportion of the votes ‘For’ and ‘Against’ a resolution. 

4.  Every holder has the right to appoint some other person(s) of their choice, who need not be a shareholder, as their proxy 
to exercise all or any of their rights to attend, speak and vote on their behalf at the meeting, provided each proxy is appointed 
to  exercise  rights  in  respect  of  different  shares.  The  appointment  of  the  chairman  as  proxy  has  been  included  for 
convenience. If you wish to appoint any other person or persons as proxy or proxies delete the words “the chairman of the 
meeting” and add the name and address of the proxy or proxies appointed in the space provided. If you do not delete such 
words and you appoint  a proxy  or proxies, the chairman shall  not be  entitled  to vote as proxy.  If your proxy is being 
appointed in relation to less than your full voting entitlement, the number of shares in respect of which each such proxy is 
to vote must be specified in the space provided. In the absence of any specific direction, a proxy shall be deemed to be 
entitled to vote in respect of all the shares in the relevant holding. 

5.  CREST members who wish to appoint a proxy or proxies by utilising the CREST electronic proxy appointment service may 
do so by utilising the procedures described in the CREST Manual. To be valid, the appropriate CREST message, regardless 
of whether it constitutes the appointment of a proxy or an amendment to the instruction given to a previously appointed 
proxy, must be transmitted so as to be received by the Company’s agent (ID 7RA36) by the latest time(s) for receipt of 
proxy appointments specified in the notice of meeting. See the notes to the notice of the Annual General Meeting for further 
information on proxy appointment through CREST. 

6.  To appoint more than one proxy, please photocopy this form indicating on each copy the name of the proxy you wish to 

appoint and the number of shares in respect of which the proxy is appointed. 

7. 

8. 

In the case of joint holders, the signature of any one holder will be sufficient but the names of all the joint holders should be 
stated and the vote of the senior who tenders a vote, whether in person or by proxy, will be accepted to the exclusion of 
the votes of the other joint holders. For this purpose, seniority will be determined by the order in which the names stand 
in the register of members in respect of the shares. 

If you submit more than one valid proxy appointment, the appointment received last before the latest time for the receipt 
of proxies will take precedence. 

9.  Returning the form of proxy will not prevent you from attending the meeting and voting in person. 

10.  You may not use any electronic address provided either in this form of proxy or any related documents (including the notice 

of meeting) to communicate with the Company for any purposes other than those expressly stated. 

11.  Any questions regarding the proxy form are to be addressed to the Company Secretary, whose contact details are shown in 

paragraph 1 above. 

 69