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Athelney Trust Plc

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FY2019 Annual Report · Athelney Trust Plc
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Annual Report 

for the year ended 

 31 December 2019 

COMPANY NUMBER: 02933559 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

CONTENTS 

Directors of the Company 

Strategic Report including: 
Chairman’s Statement and Business Review 
Fund Manager’s Report 
Investment and Portfolio Analysis 
Portfolio Breakdown by Sector and by Index 
Strategic Report 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 

2 

3 - 7 
8 - 11 
12 
13 
14 - 16 

17 - 23 

24 - 27 

28 - 29 

30 - 33 

34 - 38 

39 

40 

41 

42 

43 - 51 

52 

53 - 59 

60 - 61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors of the Company 

Frank Ashton (Non-Executive Chairman) 

Frank Ashton, aged 58, 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. 

Dr Emmanuel Clive Pohl AM (Managing Director) 

Manny Pohl, aged 66, is the Chairman and CEO of investment house EC Pohl & Co which he founded in June 2012 and 
has  led  through  its  evolution  into  today’s  independent,  highly  acclaimed  Australian  fund  manager.  Manny  holds 
engineering  and  MBA  degrees  from  the  University  of  Witwatersand  and  a  doctorate  in  Business  Administration 
(Economics) from Potchefstroom University.  

Manny has over 30 years of investment experience, initially as head of research for leading South African broking firm, 
Davis Borkum Hare, followed by Westpac Investment Management in Australia after he emigrated to Australia in 1994. 
Manny founded Hyperion Asset Management in 1996 and left in 2012. He has served on the Boards of several major 
corporations in his native South Africa, the UK and his adopted home Australia. In 2019 Manny was recognised in the 
Queen’s Birthday honours list for significant service to the finance sector, and to the community. 

Simon Moore (Non-executive Director) 

Simon Moore, aged 58, is a consultant Senior Investment Analyst. He has been an investment trust analyst since 1994 and 
has worked with several stockbrokers in the City of London including Williams de Broe, Teather & Greenwood and 
Collins Stewart.  He was also Senior Investment Manager at  Seven Investment Management and Head of Research at 
Tilney Bestinvest and Senior Investment Analyst at EQ Investors. Simon is a long standing member of two important 
committees at the Association of Investment Companies: the Statistics committee and the Property and Infrastructure 
Forum. In 2013 and 2014 Simon was chosen as one of the Citywire Wealth Manager Top 100 most influential people in 
UK  private  client  fund  selection.  Simon  is  a  scientist  by  training  and  has  worked  at  two  start  up  UK  biotechnology 
companies, before passing on his knowledge and passion as a science tutor for the Open University. He has a Biochemistry 
BSc from Imperial College, and an MSc in Computer Modelling of molecules from Birkbeck College. He is a member of 
the UK Society of Investment Professionals and the CFA institute. 

David Lawman (Non-executive Director) 

David Lawman aged 71 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. 

 2 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 

Chairman’s Statement and Business Review  

Overview 
I am very pleased to be able to report such a substantial change in the fortunes of the Athelney Trust plc (the 
‘Company’ or the ‘Trust’), environmentally, structurally and with respect to performance, over the past 12 
months. Given the uncertainties in all these areas at this time last year, I am delighted to report very good 
results for the Company in the year ended 31 December 2019.  The key points are as follows: 

  At 31 December 2019, audited NAV was 266.9p per share (2018: 225.9p), an increase of 18.2% 
  The  Trust’s  investment  performance  over  12  months  as  measured  by  Net Asset Value (NAV) total 
return, which is the change in NAV plus the dividend paid, was plus 22.2% (2018: minus 17.6%). Long 
term performance represented by the Trust’s average 10 year total shareholder return of 127% beat 
the FTSE 100 (107%) and lagged the FTSE 250 (211%).   

  The 12-month revenue return per ordinary share was 9.1p (2018: 9.9p), a decrease of 8% 
 

Issues leading to Board/major shareholder disruption are now fully resolved. However, the disruption 
led to approximately £88,000 non-recurring costs over the financial years 2018 and 2019.  Conditions 
leading  to  these  non-recurring  costs  ended  when  Robin  Boyle  sold  his  shareholding  in  November 
2019.  In November we welcomed a new major shareholder, BIP Worldwide Flexible Fund to the 
register.  We expect the more normal cost run-rate for the Company, re-established since the AGM 
last April, to continue in future 

  Your Board recommend a final dividend of 9.3p per share (2018: 9.1p) an increase of  2.2%.  UK 

Inflation for the year of 2019 was 1.4% (Office for National Statistics) 

  This is the 18th successive year of progressive dividend and importantly returns the Trust to a Top 5 
position in the dividend yield league table for Investment Companies as well as keeps us in the Next 
Generation of Dividend Heroes list maintained by the AIC (Athelney  was 3rd on the list in March 
2019)  

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 on pages 17 to 23. 

An Independent Board 
There were a number of movements including five directors who came off the Board, another five who came 
on and two reshuffles in the first third of 2019.  Details of the various Board changes are on page 24. The 
directors in place at the time of signing these accounts are: 
  Myself, Frank Ashton – Non-Executive Chairman 
  Simon Moore – Non-Executive Director, Chair of Audit Committee 
  David Lawman – Non-Executive Director 
  Dr Manny Pohl - Managing Director, Fund Manager 

 3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Chairman’s Statement and Business Review  
(continued) 

We  currently  have  four  directors  who  together  make  up  an  independent  Board  under  the  AIC  Code  of 
Governance 2019.   I have no current or prior connection with any major shareholder of the Company and 
maintain I am an independent Chairman.  The Board is also agreed that Simon Moore and David Lawman are 
independent at 31 December 2019.  I returned to a Non-Executive role and fee from Executive Chairman in 
July 2019 when it was clear the conditions requiring this unusual position had ceased, as reported at the time. 

Capital Gains 

During the year the Company realised capital profits before expenses arising on the sale of investments in the 
sum of £262,480 (2018: £98,840). 

Portfolio Review 
Holdings of Abcam, Boohoo, Churchill China, Close Brothers, Fevertree Drinks, Gamma Communications, Homeserve, JD 
Sports, Liontrust Asset Management, LXI REIT, Smart Metering Services and National Grid were all purchased for the 
first time. 

 Additional  holdings  of  AEW  UK,  Custodian  REIT,  Hill  &  Smith,  Lok’n  Store,  Londonmetric,  Paypoint,  Randall  & 
Quillter, Regional REIT, Rightmove, S&U, Treatt, Tritax BigBox and XP Power were also acquired. 

 Air Partner, Braemar Shipping, Capital &  Regional, Charles Taylor Consulting, Chesnara, Cineworld, Crest Nicholson, 
Epwin, F&C UK, Fisher (James), Gattaca, Goodwin, Greene King, Hansard Global, Harworth Group, Heath (Samuel) & 
Sons, Hostelworld, Huntsworth, Ibstock, John Menzies, Jupiter Fund Management, KCOM, Kin & Carta, Latham (James), 
M&C Saatchi, McColls Retail, Ocean Wilsons, Palace Finance, Park Group, Photo-me, PRS REIT, Quarto Group, Reach, 
Real Estate Investors, Record, River & Mercantile, Schroder European, Schroder REIT, Town Centre Securities,  TPICAP, 
Wynnstay Group and XL Media were sold.  

Corporate Activity 
The holding of Greencore was subject to a Tender Offer during the year at a capital profit of 60% whilst 
Dairycrest, Murgitroyd and Safecharge were taken over at a capital profit of 32%, 52% and 74% respectively. 

Dividend 

The Board is very pleased to recommend an increased annual dividend of 9.3p per ordinary share (2018: 9.1p). 
This  represents  an  increase  of  2.2%  over  the  previous  year.  Subject  to  shareholder  approval  at  the  Annual 
General Meeting on 8 April 2020, the dividend will be paid on 16 April 2020 to shareholders on the register 
on 20 March 2020. 

The  Board  is  also  reflecting  the  needs  of  some  shareholders  for  more  frequent  income  contributions  and 
therefore is assessing the net benefits to all shareholders of distributing dividends twice each year. 

 4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Chairman’s Statement and Business Review  
(continued) 

Review 
I am very pleased that we are now free from a number of elements of uncertainty for shareholders and potential 
investors that together delayed the time when fund growth might occur.  We are now in a period of greater 
structural and economic stability, because: 

• 

•  Robin Boyle a major shareholder this time last year, sold all his shares ahead of the planned timetable, 
effectively  removing  the  conditions  that  might  lead  to  substantial  extra  costs  being  incurred  by  the 
Company. Significant efforts were made by myself, other directors and the Company Secretary John 
Girdlestone, to reach this peaceful, natural outcome in the interests of all shareholders 
Total transaction costs for 2019 temporarily increased as Dr Manny Pohl, the incoming fund manager 
rotated  the  portfolio  he  inherited  (as detailed in  the  Fund  Manager’s  report).  The  portfolio  is  now 
correctly positioned and so transaction costs should be back to lower, more normal levels for 2020. 
Parties who bought the Boyle shares are fully supportive of the Board and its plan - allowing full focus 
on portfolio and Company performance in readiness for growth 
There  was  a  very  smooth  transition  to  Debbie  Warburton  as  sole  Company  Secretary,  when  John 
Girdlestone retired - I thank them both and wish John well 
The  sizeable  majority  of  the  new  Johnson  UK  government  removes  much  of  the  very  significant 
uncertainty for UK businesses arising from the Brexit ‘political impasse’. It is hoped this should now 
complete without a hard exit by 31 December 2020, the planned end of the standstill transition period, 
when a new trade deal should come into effect; and 

• 

• 

• 

•  China and US signed a trade deal on 15 January 2020, bringing the tit-for-tat trade war that started in 
2018 to an end described as “win-win” by China.  This reduces uncertainty for the global economy - 
however considerable uncertainty remains on how new UK trade deals will play out in future months 
as Brexit takes effect. 

This greater stability has meant David Lawman who was due to retire from the Board at this AGM, has decided 
not to stand for re-election. I thank David for his help in a four-person board to transition to the current state; 
in future we will revert to the more usual three-person board until fund size or conditions require a change. 

Along with all colleagues on the Board, I am delighted to welcome the BIP Worldwide Flexible Fund to our 
shareholder  register.    This  publicly  offered  collective  investment  scheme  is  managed  by  an  experienced 
independent team of investment and administrative professionals domiciled in South Africa with its units quoted 
on the Johannesburg Stock Exchange.  It is a passive long-term investor and it has informed us that it has every 
intention of remaining on the register for many years to come. 

The Board is very happy with Dr Manny Pohl’s performance as Fund Manager in 2019 which saw greater focus 
on a smaller number of shareholder value-creating holdings. This resulted from portfolio repositioning within 
the UK Smaller Company sector in the first half of the year.  The excellent year-end performance was effectively 
realised within eight months post AGM when the current Board and Fund Manager were confirmed.  We expect 
this strong performance to continue in 2020 probably supported by an influx of investors to UK stocks, making 
Athelney an even more attractive investment opportunity. 

 5 

 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Chairman’s Statement and Business Review  
(continued) 

We  are  also  pleased  to  report  that,  as  planned,  overall  directors’  remuneration  was  1%  less  than  in  2018, 
despite there being one more director in 2019.  The Board continues to be focused on efficient management 
and appropriate levels of cost in line with the size of the fund. 

Outlook 
The world and UK markets had a sparkling year in 2019 (FTSE 100 Index rose 12%) and I am very pleased to 
report that along with this improvement, and with the active work of Dr Manny Pohl the Fund Manager, the 
Company’s NAV improved from 225.9p per share at 31 December 2018 to 266.9p per share (plus 18.1%) at 
31 December 2019.  A further improvement to 270.9p (unaudited) took place to 31 January 2020, an increase 
of 1.5%.   

We  have  realised greater  stability  and  general  performance  for  shareholders  building  from  the  April  AGM, 
achieving good interim results and then hearing of Robin Boyle’s disposal of his holding in November; we are 
much more confident that, free from distractions our future performance will lead to better conditions for us 
to grow the fund by attracting new investors. 

Externally, uncertainties have reduced for a UK small-cap fund, particularly around Brexit.  Much remains to 
play out during the next 12-18 months on new trade deals between UK/Europe and UK/US. These can impact 
sterling, the UK economy, general investor sentiment and so the fortunes of companies in our sector. 

Time will tell, as it will for the overall impact of the coronavirus (COVID-19) which remains hard to assess.  I 
emphasise in the meantime that we invest for the long term and strongly believe our UK Smaller Companies 
focus  allied  to  the  Fund  Manager’s  leading  stock  evaluation  process  will  return  very  good  to  excellent 
performance in the future.  Many have commented that such stocks are underweighted  - we expect we will 
now see further investments in this sector if uncertainty continues to recede. 

Some  developments  in  2019  give  us  an  opportunity  to  remind  current  and  potential  investors  of  some 
advantages of Athelney Trust, a closed-ended fund.  For example, the suspension of the open-ended Woodford-
managed funds illustrates that for their investors there can suddenly be no choice, no liquidity at any price 
simply because the fund manager deems it so.  Illiquid stocks create risk for an open-ended fund investor - the 
Bank of England’s December 2019 Financial Stability Report says so as does the experience of many thousands 
of investors in the two Woodford funds. 

For closed-ended funds like Athelney, there is always an option (albeit sometimes at a loss) for shareholders to exit (because 
the shares are traded every business day on the Stock Exchange) as compared to open ended funds where such an exit may 
cause balance sheet stress arising from the forced sale of illiquid underlying assets to fund the exit.  Therefore, investing in 
such illiquid stocks is at lower, more diversified risk through closed-ended than open-ended funds. 

In addition, investment trusts such as Athelney provide some ability to smooth the highest peaks and lowest 
troughs of the market because we are allowed to hold back up to 15% of investment income in good years to 
offset lower income in leaner years.  

 6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Chairman’s Statement and Business Review  
(continued) 

The net benefit for investment trust investors is a greater probability of more consistent annual income from such closed-ended 
funds’ dividends. 

The dividend cover for last year was 2.24 though current year revenues may not cover this year’s dividend 
payment. Maintaining dividend cover is helped by being a closed-ended fund and therefore able to return a 
proportion of revenues to reserves - a structural advantage compared to unit trust funds. 

We continue to poll and listen to our shareholders.  We understand from our research and conversations with 
leading shareholders that a number of the previous Board’s 2018 AGM resolutions were voted against because 
of dissatisfaction with the continuing proposed involvement of Robin Boyle and possible Fund Management by 
Gresham  House.    Those  possibilities  ended  at  the  AGM  and  the  current  Board  has  a  very  good  working 
relationship with Fund Manager Dr Manny Pohl. 

We  are  also  aware  that  some  shareholders  along  with  the  Board  would  like  to  see  the  fund  grow  and  we 
continually assess both the best timing and route for this to happen.  We believe shareholders will be pleased 
by the greater stability and better performance in the second half of 2019 and we look forward to the benefits 
of the new conditions and environment in 2020, continuing to deliver and cement better performance.  We 
expect the second half of 2020 to be the time at which various economic questions (e.g. UK Trade Deals) allow 
us to be more certain of next steps to growth.   

I believe we are already seeing the fruits of greater focus on value creation within a smaller portfolio reflecting 
the full conviction of Dr Manny Pohl (rather than the transition portfolio from Robin Boyle’s Fund Management 
legacy, of early 2019). The Board will continue to manage and optimise costs as we have now returned to a 
more normal operating environment. Shareholder support for continuation with this period of performance 
improvement will be sought at the AGM. 

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

The 2019 AGM will be held at 3.30pm on Wednesday 8 April, at the offices of Company solicitors Druces 
LLP, Salisbury House, London Wall, London, EC2M 5PS.  I encourage as many shareholders as possible to 
attend and take the opportunity to meet the Board as well as to hear a short presentation from Dr Pohl, the 
Fund Manager. 

Frank Ashton 
Non-Executive Chairman 
2 March 2020 

 7 

 
 
 
 
 
 
 
 
 
 
 
 
  
     
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Fund Manager’s Review of 2019 

As I reflect on what was quite a challenging year, I am very proud of what I have achieved in managing the 
Athelney  investment  portfolio and  in  overseeing  the  ECP  Asset  Management  business  (ECP)  in  what  was a 
particularly turbulent year for geopolitics. This year ECP has increased funds under management to circa £1 
billion and added additional support and back-office staff to ensure that I and ECP can deliver on the promises 
made  to  clients  and  to  the  shareholders  of  the  four  associated  Listed  Investment  Companies  (LICs).  As  a 
custodian of other people’s money, we all owe it to those who have invested alongside us to allocate their capital 
to opportunities that we believe in because of the work that has been. 

Alongside my work in Athelney, I continue to lead the evolution of ECP as a business, firming up its corporate 
values and its vision with a fresh new look that sets the scene for the next phase of its growth in Australia and 
eventually here in the UK. We have set ourselves the goal to ‘Redefine Active Investing’ through ensuring we 
continue  to  take  a  forensic  approach  to  our  analysis,  valuing  investment  potential  not  just  asset  value  and 
historical performance.  

The Global Scene 
Over  the  past  year,  volatility,  uncertainty,  complexity,  and  ambiguity  (VUCA)  were  at  an  all-time  high. 
Geopolitical woes, market volatility, trade complexity, and ambiguity of world leadership has seen the world 
divided across many issues. For some time, confidence and trust in institutions have been a major concern with 
hostility regarding inequalities coming to the fore. However, the Edelman barometer has indicated that over 
the  past  year  there  has  seen  some  improvement  in  societal  trust  with  the  public  focusing  more  time  on 
relationships they can control and finding unity in one core message: an urgent desire for change.  

As the world order continues to be challenged, China comes out from behind its Special Economic Zones to 
establish and challenge the “five eyes” nations of the West (Australia, USA, Britain, Canada, and New Zealand) 
by infiltrating and asserting ownership right across the South Pacific. Chairman Xi is now entrenched as the 
party’s leader for life, with China reverting to the governance structure of the emperors who ruled for so many 
thousands of years and which, until the Industrial Revolution in Britain, gave the Chinese people at large a much 
higher living standard than the West.  

President  Trump  has  continued  his  colourful  presidency,  with  many  of  his  policies  following  economic 
nationalism, having an enormous impact across the world. When we consider the desire for change and an 
economic system that has brought vast inequity in many parts of the world, moderate political leaders we have 
seen through time have not brought the radical change needed. As Michael Moore correctly predicted Trump’s 
win in 2016, he appears to be correct in that Trump has been the “human Molotov cocktail” that has driven 
substantial change (for better or worse).  

Global Economics 
After robust growth over the past few years, the International Monetary Fund (IMF) forecasts global economic 
growth to be 3.5% in 2020. Global central banks, including our own, appear perplexed by stubbornly low 
inflation with many being increasingly frustrated with a lack of political action to stimulate flagging economies.  
Interestingly, as the global scene continues to evolve, we are seeing early signs of a shift toward policymakers 
being more acutely aware of environmental, social, and economic factors. 

 8 

 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Fund Manager’s Review of 2019 
(continued) 

The ‘Wellbeing Economy Alliance’ is seeing some early-adopting countries shifting toward frameworks that 
move beyond GDP as a sole marker for economic success, which can only be a positive political development. 
In much the same way Environmental, Social and Governance (ESG) factors have become integral in investment 
markets, and wellbeing indexes are a shift in the right direction for policymakers to recognise what is important 
to the broader public.  

Paul Schmelzin, a senior executive of the Bank of England, has studied interest rates going back to 1321 from 
which he concluded that current declining world interest rates are consistent with the historic trend and we 
may not see high rates for a while other than for periodic spikes. Furthermore, with world inflation remaining 
very low, rates are unlikely to increase in the foreseeable future. Should this be correct, then the BOE is unlikely 
to raise rates any time soon and P/E ratios will remain higher for longer than we otherwise might expect. 

The Markets, Our Portfolio  
Turning to the stock market, one could be forgiven for thinking that the world was not burning but rather 
booming.  After financial markets slammed on the brakes in 2018, resulting in a decline of 12.5% in the FTSE 
100  Index,  this  index  rebounded  in  2019  to  be  up  by  12.1%  for  the  year  with  most  investment  managers 
producing healthy returns in this positive environment.  I am proud to say that our relative performance was 
exceptional as I managed to produce a total portfolio return of 28.5% over the year. While the majority of the 
stocks in the portfolio contributed to the outperformance of the portfolio over the market, a handful of names 
performed exceptionally well, including Games Workshop (LSE: GAW), Liontrust Asset Management (LSE: 
LIO) and Lok 'n Store (LSE: LOK).  The biggest detractors from returns over the year included Costain (LSE: 
COST), M&C Saatchi (LSE: SAA) and Samuel Heath & Sons (LSE: HSM). At an aggregate level, all of the alpha 
was generated through stock selection, as opposed to sector selection and this is consistent with a bottom-up, 
benchmark unaware, high conviction manager. 

Games Workshop (LSE: GAW) 
Games Workshop Group PLC designs, manufactures, distributes and markets a hobby based upon collecting, 
modelling, painting and tabletop gaming with model soldiers. Its key brands are the high fantasy Warhammer 
and dark future Warhammer 40,000 game systems. Games Workshop has exploited its valuable intellectual 
property across a variety of settings, refreshing its miniature toy lines on a regular basis and expanding the 
Warhammer universe out to encompass video games, books and new campaigns. Its competitive advantage is 
driven by the fact that it is operating in a market of one with the games voraciously supported by a legion of 
fans worldwide, who will go to great lengths (and expense) to produce their own accompaniments to add to 
the series’ lore and backstory. 

Liontrust Asset Management (LSE: LIO) 
Liontrust Asset Management plc provides portfolio management services in UK, European, Asian and Emerging 
Markets  equities.  It  markets  its  long-only,  long/short  and  absolute  return  products  through  unit  trusts, 
individual savings accounts (ISAs), offshore funds, pooled pension funds and segregated institutional accounts 
to professional investors, predominantly in the UK and Continental Europe. Assets under management (AUM) 
jumped to £19.1bn for the period ended 31 December 2019 from £14.6bn at the start of the quarter with the 
asset manager enjoying net inflows of £836m in the quarter. The acquisition of Neptune added £2.7bn to AUM 
and  allows  Liontrust  to  diversify  across  global  equities  and  emerging  markets  and  offers  an  opportunity  to 
expand their client base. 

 9 

 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Fund Manager’s Review of 2019 
(continued) 

Lok'n Store (LSE: LOK) 
Lok'n Store Group plc opened its first self-storage centre in Horsham, Sussex in February 1995 and has grown 
consistently over the last 20 years, currently operating 26 self-storage centres and two serviced document stores 
in  Southern  England  offering  self-storage  and  serviced  document  storage  and  management  services  to  both 
household  and  business  customers.  Each  centre  is  prominently  located  mainly  in  the  affluent  South-East  of 
England in large towns and cities. 

Sleep Well rather than Eat Well 
As the investment process aims to find high-quality businesses that are owned for the very long-term, portfolio 
turnover remains low. Through time the portfolio will comprise investments that have been held for over ten 
years, however, this does not mean that I am not always looking for new investments. As mentioned in our 
monthly  reports,  the  focus  this  year  has  been  to  restructure  the  portfolio  I  inherited  to  align  it  with  the 
investment philosophy and this process is largely complete with the stocks I acquired and those divested listed 
earlier in this report.  In summary, the portfolio I inherited in September 2018 comprised eighty-three (83) 
stocks, to which we added fifteen (15) and sold fifty-one (51) to end up with the current portfolio of forty-
seven (47) stocks.  I have retained and consolidated our holdings into those quality companies in the portfolio 
which  are  unlikely  to  be  disintermediated  by  technological  change  and  able  to  maintain  or  increase  their 
dividend, as well as adding companies which have an acceptable level of predictable growth in medium-term 
economic performance.  To this end I have sold our holdings in companies where there has been a change to 
the industry structure, the business model, the senior management team or the product/service offering, the 
occurrence of which will result in my view in a deterioration in future profitability and hence dividends. 

Investment management is more than merely generating alpha in excess of a benchmark.  While that is a core 
part of our mandate, other very important qualitative issues are central to what I do.  For example, I recognise 
that capital allocation is a vehicle through which to drive change.  We have the opportunity to demand specific 
standards of corporate governance, decide whether specific social and ethical issues are acceptable and, if they 
are not, we can vote with our feet.   

For me, the integrity and credibility of any management team is a founding principle to the investment process. 
I need to trust that management has the best interests for all stakeholders, and have faith that they will make 
sound strategic decisions and have substantial experience and capabilities in their chosen field. As custodians of 
our clients’ capital, I must ensure that I am doing whatever I can to preserve capital and grow it over time.  I 
allocate capital to investments which I believe are sustainable in the long-term, and finding trustworthy, values-
based management that aligns with my core values and beliefs will ensure above-average economic portfolio 
returns.  In cases where I feel I can add something to the conversation, I engage with the company. 

 10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 

Fund Manager’s Review of 2019 
(continued) 

Looking Forward 
We are now in the Year of the Rat.  A quick google tells me that the Year of the Rat is interesting as it marks the 
completion  of  a  previous  long  cycle  and  the  beginning  of  a  new  one. The rat  is  apparently  characterised  as 
being resourceful and diligent and we certainly aspire to apply these characteristics within the work that we do, 
and hope that they will flow through to the results we seek to achieve for our clients. As trust remains a central 
theme  across  the  world,  I  for  one  hope  this  shift  towards  trustworthiness  continues.  Through  time,  I  have 
emphasised the importance of management in the investment process, and I applaud further developments in 
the trustworthiness of our leaders and the management of companies. Sustainability of investment performance 
or the improvement of the wellbeing of broader society hinges upon ethical, transparent, and honest leadership. 

Our investment philosophy is based on the belief that the economics of business drives long-term investment 
returns. The short-term financial metrics of portfolio companies, including organic sales growth, earnings and 
dividend growth, should provide the impetus for improvement in valuations or at  least be supportive of the 
current  valuations  in  the  future.  Our  investee  companies  have  strong  business  models  with  capable  and 
experienced management teams which we expect will continue to deliver above-average returns. While I do 
feel that the overall markets are relatively fully valued and do not see a significant improvement in the P/E 
ratings of the companies from current levels, our earnings, dividend estimates and forecasts for the stocks in 
the portfolio remain promising. 

However, the latest coronavirus (COVID-19) threatens to be a disruptor to companies, supply chains and the 
world economy for at least the first half of 2020. The overall impact of the virus is hard to assess at the moment. 

Update 
The  unaudited  NAV  on  31  January  2020  was  270.9p per  share  –  up  1.59%  from  31  December  2019,  the 
seventh monthly increase in a row and beating the FTSE (-3.40%), Small Cap Index (-0.92%) as well as AIM 
All-share Index (-0.95%). The share price on the same day was 235p (trading at a discount of 13.3%).  Further 
updates can be found at www.athelneytrust.co.uk  

Dr Manny Pohl AM 
Fund Manager 
2 March 2020 

 11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 
Strategic Report (continued) 
Investment and Portfolio Analysis at 31 December 2019 

Stock 

 Holding  

 Value (£) 

Biotechnology 
Chemicals 
Construction & materials 

Abcam 
Treatt 
Costain Group 
Clarke T 
Forterra 

Electronic & electrical equipment  X P Power 
Food & beverages 

General financial  

Household goods & construction 
Industrial engineering 

Leisure goods 
Media 

Mobile communications 
Multiutilities 
Property, commercial & 
residential 

Retailers 

Support services 

Travel and leisure 

Fevertree Drinks 
Greencore Group 
Camellia 
Close Brothers 
Jarvis Securities 
Liontrust Asset Management 
Randall & Quillter Investment Holdings 
S & U 
Churchill China 
Hill & Smith 
Vitec 
Games Workshop 
4Imprint 
Rightmove 
Wilmington 
Gamma Communications 
National Grid 
AEW UK REIT 
Belvoir Lettings 
Custodian REIT 
Hansteen Holdings 
Lok’n Store Group 
Londonmetric Property 
LXI REIT 
Mountview Estates 
Picton Property Income 
Regional REIT 
Target Healthcare REIT 
Tritax Big Box 
JD Sports 
Boohoo 
Andrews Sykes Group 
Begbies Traynor 
Biffa 
Homeserve 
NWF Group 
Paypoint 
Smart Metering Services 
Vianet Group 
VP 
Marstons 

4,100 
21,000 
14,666 
55,000 
40,000 
4,000 
1,000 
12,044 
500 
13,500 
27,000 
33,000 
68,217 
6,000 
3,500 
14,000 
4,000 
4,500 
2,000 
10,000 
32,500 
10,000 
28,000 
130,000 
85,000 
75,000 
50,000 
22,000 
100,000 
60,000 
1,500 
175,000 
123,750 
100,000 
170,000 
5,000 
10,000 
19,500 
80,000 
25,000 
11,000 
35,000 
9,000 
3,000 
50,000 
19,000 
80,000 

55,391 
96,390 
23,348 
74,800 
138,400 
123,600 
20,920 
32,254 
43,500 
215,595 
126,900 
361,350 
117,333 
125,400 
62,650 
206,080 
43,800 
274,500 
69,400 
63,340 
79,950 
132,500 
264,376 
128,960 
118,150 
85,350 
58,200 
158,620 
236,400 
83,880 
175,500 
169,575 
139,838 
115,500 
252,790 
41,860 
29,780 
113,100 
72,800 
68,376 
138,930 
61,250 
90,900 
16,875 
77,500 
178,600 
101,680 

Portfolio Value 
Net Current Assets 

TOTAL VALUE 

Shares in issue 

£5,466,191 
£292,526 

£5,758,717 

2,157,881 

Audited NAV 

266.9p 

 12 

 SECTOR 
 £  
55,391 
96,390 

% 

1.0% 
1.8% 

236,548 
123,600 

4.3% 
2.3% 

53,174 

1.0% 

990,078 
62,650 

249,880 
274,500 

212,690 
132,500 
264,376 

18.1% 
1.1% 

4.6% 
5.0% 

3.9% 
2.4% 
4.8% 

1,722,763 

31.5% 

71,640 

1.3% 

818,331 
101,680 

15.0% 
1.9% 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
  
 
 
  
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 
Portfolio Breakdown by Sector and Index 

Portfolio by Sectors

1.0% Biotechnology

1.9% Travel

1.8% Chemicals

1.3% Retailers

31.5% Property, Comm 
& Residential

4.3% Construction & 
Materials

2.3% Electronic & 
Electrical Equipment

1.0% Food & Beverages

18.1% General Financial

1.1% Home Goods & 
Home Construction

4.6% Insurance

4.8% Multiutilities

5.0% Leisure Goods

2.4% Mobile 
Communications

3.9% Media

15.0% Support Services

Portfolio by listing

4.4% Non Indexed

29.6% FTSE Mid250

6.4% FTSE 100

21% AIM

 13 

32.4% Small Caps

1.3% Fledgling

4.9% Cash

 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 
Other Statutory Information 

As explained within the Report of the Directors on pages 24 to 27, the Company carries on business as an investment 
trust. Investment trusts are collective closed-ended public limited companies. 

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 four male Directors, can be found on page 2. 

S172 Statement 

The directors of the Company act in a way that they consider to be; 

• 
• 
• 

in good faith, 
likely to promote the success of the Company and; 
to the benefit of its members as a whole 

The Board considers that all the Directors  have regard for the  long term objectives  of the company,  meet  at regular 
intervals throughout the year to discuss these objectives, and ensure that they remain on track. The Directors conduct the 
majority of their Board Meetings via conference calls to reduce travelling, and all printed material produced is using FSC 
paper which ultimately reduces the impact on the community and the environment. This year the Board has spent time 
speaking to members of the company and gathering feedback. The Directors aim to maintain a reputation for conducting 
business at a high standard and maintaining that standard for future years. 

One of the directors is the Company's only employee (2018: one employee). 

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 spread of holdings in quality small cap companies that operate in 
various industries and sectors. The Fund Manager 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 NEX. 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.  

 14 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 
Other Statutory Information 

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 2019 can be found on page 12 of 
the annual report. 

Responsible Ownership 

The Fund Manager takes a particular  interest  in  corporate governance and social  responsibility  investment policy. As 
stated within the Corporate Governance Statement on pages 17 to 23, the Fund Manager’s current policy is available on 
the Trust’s 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 7 and the Fund Manager’s review on pages 
8 to 11 which form part of the Strategic Report. 

Principal Risks and Uncertainties and Risk Management 

As stated within the Corporate Governance Statement on pages 17 to 23, 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. 

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 17 to 23. 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. 

  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.  

 15 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Strategic Report 
 (continued) 
Other Statutory Information 

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

  Trading – ATY is a small trust and its shares can be illiquid, which means that investors may have difficulty in 

dealing in larger amounts of shares. 

On the 3 January 2018 MiFID ll 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 Board is not aware of any breaches of laws or regulations during the period under review and up to the date of 
this report. 

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.  

Social, Community and Human Rights Issues 

The Company has one employee (2018: 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 

Waterside Court 
Falmouth Road 
Penryn 
Cornwall 
TR10 8AW 

2 March 2020 

D. Warburton 
Secretary 

 16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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 July 2018 which can be found at 
www.frc.org.uk. The Association of Investment Companies issued its own Code of Corporate Governance in February 
2019 (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 provisions on 
issues which are of specific relevance to investment trusts. The Board considers that reporting against the Principles and 
Provisions of the AIC Code, which has been endorsed by the FRC, provides more relevant information to shareholders. 

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

  Due to the uncertainty facing 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 Frank 
Ashton was appointed as Executive Chairman on 8 February 2019. The situation was reversed when Frank Ashton 
stood down as Executive Chairman on 17th July 2019 at the same time as Manny Pohl became Managing Director. 

  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. 

 

 

 

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. The Directors retire by rotation on a three yearly 
basis in accordance with the Company’s articles of association. 

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 comprised a maximum of four 
Directors  who  liaised  continuously  throughout  and  were  aware  of  their  obligations  to  consider  recruitment  of 
further Directors as and when the occasion occurred.  

Board Membership 
During the year the following Board changes took place: 

On 20 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, which was 
held on the 22 January 2019. 

At the GM on 22 January 2019 Manny Pohl, Simon Moore and Jemma Jackson were voted off the Board by shareholders 
with David Lawman and Paul Coffin being appointed. 

 17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

On 25 January 2019 Mr Paul Coffin resigned as a Director of the Company and Frank Ashton was appointed in his place.  

At  the  AGM  on  3  April  2019  Helen  Sachdev  was  voted  off  the  Board,  and  Simon  Moore  and Manny  Pohl  were re-
appointed to the Board by shareholders. 

At  31  December  2019  the  Board  consisted  of  four  Directors,  of  which  three  were  and  remain  independent.  The 
biographies of all the current Directors are contained on page 2. 

David Lawman is due to retire by rotation at the forthcoming AGM and he will not offer himself for re-election. After 
carefully  considering  his  position  and  discussions  with  the  Board,  David  believes  the  conditions  that  required  his 
involvement in the Company have come to a natural end.  He was originally asked to join the Board by a major shareholder 
who  has  since  sold  his  holding,  over  a  number  of  months  he  helped  to  facilitate  the  smooth  transition  to  this  new 
position.  He believes this is an appropriate point for him to leave the Board. 

The Directors believe that the Board has, and will after David Lawman’s retirement continue to have, 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.  

All Directors receive relevant training, collectively or individually, as necessary.  

The Directors of the Company meet at regular Board Meetings. During the year ended 31 December 2019, the Board 
met a total of 12 times.   

 E C Pohl 
 N F Ashton 
 S Moore  
 D Lawman 
 H Sachdev 
 J Jackson 

Board 

Audit 

Meetings  Committee 

6 
12 
6 
12 
5 
- 

- 
1 
- 
1 
1 
- 

Remuneration 
Committee 
- 
1 
- 
1 
1 
- 

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  four  male  Directors  for  the  last  eight  months  of  the  year  to  31 
December 2019, and also one female and two male directors for much of the first four months. The current composition 
of the Board was voted in by shareholders at the AGM in April. 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 even without David Lawman who will 
not be seeking re-election, the Board has an appropriate breadth of skills and experience. The Board is not currently 
planning to add a fourth Director to the board. 

 18 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

    Corporate Governance Statement  
 (Continued) 

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 16. 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. 

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  
As a result of the GM (as detailed on pages 17-18) 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 N F Ashton was appointed 
Executive  Chairman.  Mr  N  F  Ashton  is  independent  and  considers  himself  to  have  sufficient  time  to  commit  to  the 
Company’s affairs. He remained as Executive Chairman until Dr E C Pohl became Managing Director on 17 July 2019 at 
which point he reverted to the role of Non-executive Director. 

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.  Three of the four 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. 

 19 

 
 
 
 
 
 
 
                        
 
 
 
 
 
 
 
 
Athelney Trust plc 

Corporate Governance Statement  
(Continued) 

Remuneration Committee 
During the year the Remuneration Committee comprised Manny Pohl and Simon Moore (Chairman) until the GM on 22 
January. After the GM the Remuneration Committee comprised Frank Ashton, David Lawman and Helen Sachdev. After 
the  AGM  on  the  3  April  2019  the  Remuneration  Committee  comprised  Simon  Moore  and  David  Lawman.  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 30 to 33 and in note 4 to the 
financial statements. 

Company Secretary 
During the year the Company had two Company Secretaries until John Girdlestone’s retirement on 31 May 2019. The 
Company Secretary, Deborah Warburton FCCA, is responsible for ensuring that Board and Committee procedures are 
followed  and  that  the  Company  complies  with  regulations.    The  Company  Secretary  also  ensures  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 Secretary. 

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  Secretary  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 comprised Manny Pohl and Simon Moore (Chairman) until the GM on 22 January 
2019. After the GM the Audit Committee comprised Frank Ashton, David Lawman and Helen Sachdev. After the AGM 
on the 3 April 2019 the Audit Committee comprised Simon Moore and David Lawman. 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. 

 20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  or  NEX,  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 Secretary 
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 Secretary. 

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 2019. 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 34 to 38. 

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 25 and 26. 

 Details of the substantial shareholders in the Company are listed on page 25. 

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

Association and are discussed on page 24. 

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

Meeting. 

 21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 have spoken to major shareholders during the year regarding events surrounding voting at the 
AGM on 3 April 2019 and to discuss their aspirations for the Company going forward. 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. 

To comply with the AIC Code the Board are required to consult with shareholders when 20 percent or more of votes 
have been cast against board recommendations for a resolution. This was the case in the voting results for the AGM held 
on the 3 April 2019. A summary of the results are shown below and the feedback received from shareholders. 

Resolution 

To re-elect Helen Sachdev as a Director 
To  resolve  that  the  Directors  be  generally 
and  unconditionally  authorised  to  allot 
shares to the extent stated in the resolution

%  Against  Board 
Recommendations 
41.0% 
28.8% 

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

To authorise purchase of own shares 
To elect Mr S Moore as a Director 
To elect Dr E C Pohl as a Director 

28.9% 

33.3% 
36.2% 
40.6% 

Shareholder Comments 

the 

between 

Shareholders  were  concerned  with  the  ongoing 
disagreement 
two  major 
shareholders. They wished to see stability on the 
Board  and  a  clear  direction  for  the  Company’s 
future. 
They  voted  against  the  Board  recommendations 
as  they  felt  that  this  would  bring  about  the 
stability  needed  for  the  Company  to  move 
forward. 

The notice of the Annual General Meeting, to be held in London on 8 April 2020, is set out on pages 52 to 61. 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. 

 22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 Secretary in detail on a regular 

basis. 

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                                                              

         D. Warburton 
               Secretary 
           2 March 2020 

 23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                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 
2019.   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 £195,643 (2018: £213,098) as detailed on page 
38. 

It is recommended that a dividend of 9.3p (2018: 9.1p) 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  2018. The  Directors  are  of  the  opinion  that  the  Company  has  conducted  its affairs for the year ended 31 
December 2019 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. 

Jason Pohl was approved by the Board on 11 October 2019 to act as alternate director for Manny Pohl; he will represent 
Manny when he is unable to attend a Board meeting. 

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. David Lawman will retire at the 2020 AGM and will not offer himself for 
re-election. 

In addition to any power of removal conferred by the Companies Acts, the Company may by special resolution remove 
any Director without notice. 

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. 

 24 

 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Report of the Directors 
(continued) 

Capital Structure  
At  31  December  2019  the  Company’s  capital  structure  consisted  of  2,157,881  Ordinary  Shares  of  25p  each  (2018: 
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  
S. Moore 
J. Jackson 
D. Lawman 
P. Coffin 
F. Ashton 
H. Sachdev 

(Managing Director) terminated 22/1/2019 - appointed 3/4/2019 
(Chairman) terminated 22/1/2019 - appointed 3/4/2019 (Non-executive Director) 
(Non-executive Director) terminated 22/1/2019 
(Non-executive Director) appointed 22/1/2019 
(Non-executive Director) appointed 22/1/2019 - resigned 25/1/2019 
(Non-executive Chairman) appointed 25/1/2019 
(Non-executive Director) appointed 8/2/2019 - terminated 3/4/2019 

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.  

At a Board meeting on 11 October 2019 J Pohl was approved as alternate director for Dr E C Pohl. As Dr E C Pohl was 
able to attend all meetings of the Board during the year, J Pohl was not required to act as his alternate.  

There were a number of Director changes during the year. A detailed disclosure of the events can be found in the 
Corporate Governance Statement on pages 16 to 22. 

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

E C Pohl & Co Pty Ltd 

BIP Worldwide Flexible Fund 

Global Masters Fund 

Mr GW & Mrs DJ Whicheloe 

Mehr Mutual 

Astuce Group 

Mrs E Davison 

Mr C Frostick 

Simon Moore 

P Grodzinski 

Ordinary 
Shares 
339,054 

339,054 

205,951 

104,000 

99,643 

91,000 

75,000 

69,720 

67,500 

65,000 

  % of issue 

15.71% 

15.71% 

9.54% 

4.82% 

4.62% 

4.22% 

3.47% 

3.23% 

3.13% 

3.01% 

Out of the ten major shareholders listed above three were under the direct control of two of the Directors during the 
year. The remaining seven are in regular contact with the Directors (or their respective agent) to ensure that they are 
frequently apprised 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 2020. 

 25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

Engagement with Suppliers and Other Business Relationships 
The Directors have regard for the need to maintain good business relationships with suppliers and other businesses that 
the Company may have contact with throughout the year. Suppliers are paid in a timely manner and well within the credit 
terms afforded to the Company. Other business relationships are maintained on a professional and courteous level with 
regular contact being maintained by the Fund Manager, Company Secretary and Audit Committee Chairman.     

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 
14 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 or ISDX. 

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 page 15), 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. 

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. 

 26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Report of the Directors 
(continued) 

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 53 to 59.  

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. 

BY ORDER OF THE BOARD 

D. Warburton 
Secretary 

Waterside Court 
Falmouth Road 
Penryn 
Cornwall 
TR10 8AW 

2 March 2020 

 27 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

 28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

D. Warburton   
    Secretary 
2 March 2020 

 29 

 
 
 
 
 
 
 
 
 
 
 
                 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 34 to 38. 

Remuneration Committee 
The Company had a Remuneration Committee during the year comprising Manny Pohl and Simon Moore, until the GM 
on 22 January. After the GM the Remuneration Committee comprised Frank Ashton, David Lawman and Helen Sachdev. 
After the AGM on the 3 April 2019 the Remuneration Committee comprised Simon Moore and David Lawman. 

The Committee met during the year to review and implement measures to avoid or manage conflicts of interest where 
applicable and to consider and approve the Directors’ remuneration for the year ending 31 December 2019. 

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 2020 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. Non-executive Director’s fees have been set at £10,500 per annum for a number of years and no 
changes are expected for the foreseeable future. 

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. 

The policy was last approved by Shareholders at the Annual General Meeting on 30 March 2017 and will remain valid 
until the Annual General Meeting in 2020. 

Directors’ Service Contracts 
Each of the Directors has a service contract or letter of engagement with the Company for an initial three year term 
commencing in 2019. There are no provisions in the service agreements for payments to be made for loss of office, the 
service contracts are kept at the Registered Office and are available for inspection by appointment. 

The letters of engagement for all the Directors provide for renewal by the Board on terms to be agreed from time to 
time. 

 30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors’ Remuneration Report 
(continued) 

Company Performance 
The  graph  below  compares  capital  growth,  for  the  ten  financial  years  ended  31  December  2019,  as  a  cumulative 
performance graph over the whole 10 years and a table of discrete calendar year performance figures. The comparison is 
between  AIM  All-Share  and  FTSE  Small  Caps  indices  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. 

Capital Growth
(rebased to 100 at 31/12/2009)

240.0
230.0
220.0
210.0
200.0
190.0
180.0
170.0
160.0
150.0
140.0
130.0
120.0
110.0
100.0
90.0
80.0
70.0

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, no other salary related payments were made to any Director during the year. 

Dr E C Pohl (Chairman, Non-executive) 
Dr E C Pohl (Managing Director) 
Dr E C Pohl (Non-executive) 
R G Boyle (Managing Director) 
S Moore (Non-executive) 
J Jackson (Non-executive) 
F Ashton (Chairman) 
D Lawman (Non-executive) 
H Sachdev (Non-executive) 

2019 
£ 

- 
19,170 
18,952 
- 
8,750 
875 
12,250 
9,625 
1,750 
71,372 

2018 
£ 
8,750 
8,639 
- 
43,399 
10,500 
875 
- 
- 
- 
72,163 

The Directors who were removed from the Board during the year did not receive any payments for loss of office. 

 31 

2010201120122013201420152016201720182019ATY NAV11.9%-13.3%21.1%47.0%4.0%7.5%2.5%13.4%-20.7%18.2%FTSE 1009.0%-5.6%5.8%14.4%-2.7%-4.9%14.4%7.6%-12.5%12.1%FTSE 25024.2%-12.6%22.5%28.8%0.9%8.4%3.7%14.7%-15.6%25.0%FTSE Small Cap16.3%-26.8%46.1%4.2%-24.0%7.8%4.5%3.6%-23.8%31.2%AIM All Share42.7%-48.0%37.4%17.9%-31.4%27.5%8.6%8.8%-34.2%36.4% 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors’ Remuneration Report 
(continued) 

The Directors’ remuneration for the year of £71,372 is before the proposed dividend of 9.3p (2018:9.1p) per ordinary 
share. As stated in the Chairman’s Statement on page 3 this is an increase of 2.2 per cent on last year. 

Chairman basic fee 
Fund Manager 0.75% of net assets 
Non-Executive Director basic fee 

Expected Fees for the Year to 31 
December 2020 
10,500 
44,250 
10,500 

Fees for Year to 31 
December 2019 
12,250 
38,122 
10,500 

Travel expenses amounting to £1,353 were paid to Frank Ashton for his attendance at Board meetings up to the AGM 
on 3 April 2019 (2018:£nil). No further expenses were claimed by him after this date. 

Relative importance of spend on pay 

Total remuneration paid to the Fund Manager 
Total remuneration paid to non-executive Directors 
Total remuneration paid 

2019 

2018 

38,122 
33,250 
71,372 

52,038 
20,125 
72,163 

% 
Change 
(26.7%) 
65.2% 
(1.1)% 

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: 

Dr E.C. Pohl  
S. Moore  
D. Lawman 

Notes: 

31 December 
2019 
(or date of 
resignation if 
earlier) 
1,000¹ 
67,500 
2,500 

31 December 
2018 
(or date of 
appointment 
if later) 
- 
50,000 
2,500 

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. E C Pohl & Co 
Pty Limited holds 339,054 (2018: Nil), Global Masters Fund Limited holds 204,951 (2018: 379,640) shares in the 
Company. 

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. There are no 
requirements for the Director’s to own shares in the Company. 

The Directors are fully aware that the Company is not a close company and of the rules associated with this status. The 
Company Secretary maintains a record of shareholders which is regularly updated. The Company breached the 5/50 rule 
during 2019 because the top 5 shareholders came to own more than 50% of the total shares in the company. The Company 
holds  its  Investment  Trust  status  under  the  S446  Companies  Act  2010  exemption  because  more  than  35%  of  the 
company’s  shares  are  held  by  the  public  and  have  been  actively  traded  in  the  past  12  months  on  the  London  Stock 
Exchange. 

 32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Directors’ Remuneration Report 
(continued) 

The Directors’ Remuneration Report for the year ended 31 December 2018 was approved by shareholders at the Annual 
General Meeting held on 3 April 2019. The votes cast by proxy were as follows: 

For 
Against 
Total votes cast 
Number of votes withheld 

Number of votes  % of votes cast 
73.0 
4.4 
77.4 
0.4 

1,575,211 
95,000 
1,670,211 
9,000 

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 2 March 2020. 

D. Warburton 
Company Secretary 

 33 

 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2019, 
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 2019 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 15 to 168 that describe the principal risks and explain how they 

are being managed or mitigated;  

  the Directors’ confirmation set out on page 16 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  26 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 26 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.  

 34 

 
 
 
  
 
  
 
 
 
  
 
  
  
  
  
  
  
  
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.  

Investment trust status  
In order to remain tax exempt the criteria of an investment trust must be met. This includes a 15% limit on retention of income after 
dividends and revenue expenses and a minimum of 35% of its shares must be owned by the general public and traded on a recognised 
stock exchange. Our audit work included, but was not restricted to: reviewing calculations to ensure that no more than 15% of income 
was retained after dividends and revenue expenditure; reviewing the shareholder' register to ensure that at least 35% of the share were 
not held by a related party; and obtaining an Audit Representation Letter from the Company's directors confirming that they complied 
with the applicable rules. 

 35 

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

            (Continued) 

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.  

We established materiality for the financial statements as a whole to be £101,000, which is 1.75% 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 £49,000, 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:  

 36 

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

            (Continued) 

  Fair,  balanced  and  understandable,  set  out  on  page  16  –  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 20 to 21 – 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 17 to 
18 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.  

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  

 37 

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

            (Continued) 

  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  28-29),  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.  

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.  

2 March 2020 

 38 

 
 
 
 
 
 
 
  
  
 
  
  
  
 
  
  
  
 
 
   
  
 
 
 
 
Athelney Trust plc 

Income Statement 

For the Year Ended 31 December 
2019 

For the Year Ended 31 December 
2018 

Note  Revenue 

Capital  

Total 

  Revenue 

Capital 

Total 

£ 

£ 

£ 

£ 

£ 

£ 

Gains/(losses) om investments 
held at fair value 

Income from investments 

Investment management 
expenses 

Other expenses 

Net return on ordinary 
activities before taxation 

Taxation 

Net return on ordinary 
activities after taxation 

Net return per ordinary 
share 

Dividend per ordinary 
share paid during the year 

8 

2 

3 

3 

5 

6 

6 

7 

- 

1,086,854 

1,086,854 

- 

(1,135,313) 

(1,135,313) 

232,262 

- 

232,262 

251,990 

- 

251,990 

(3,812) 

(34,682) 

(38,494) 

(5,412) 

(51,068) 

(56,480) 

(32,807) 

(166,384) 

(199,191) 

(33,480) 

(106,537) 

(140,017) 

195,643 

885,788 

1,081,431 

213,098 

(1,292,918) 

(1,079,820) 

- 

- 

- 

- 

- 

- 

195,643 

885,788 

1,081,431 

213,098 

(1,292,918) 

(1,079,820) 

9.1p 

41.0p 

50.1p 

9.9p 

(59.9)p 

(50.0)p 

9.1p 

8.9p 

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 43 to 51 form part of these financial statements. 

 39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Statement of Changes in Equity for the Year Ended 
31 December 2019 

Called-up 
Share 
Capital 
£ 

Share 
Premium 
£ 

Capital 
reserve 
realised 
£ 

Capital 
reserve  Revenue 
reserve 
£ 

unrealised 
£ 

Total 
Shareholders’ 
Funds 
£ 

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 

539,470 

881,087 

1,855,088 

1,157,686 

440,322 

4,873,653 

- 

- 

- 
- 
- 

- 

- 

- 
- 
- 

262,480 

- 

- 

824,374 

- 

- 

(201,066) 
- 
- 

- 
- 
- 

- 
195,643 
(196,367) 

262,480 

824,374 

(201,066) 
195,643 
(196,367) 

539,470 

881,087 

1,916,502 

1,982,060 

439,598 

5,758,717 

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 

Balance brought forward at 1 
January 2019 
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 2019 

  The notes on pages 43 to 51 form part of these financial statements. 

 40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Statement of the Financial Position as at 
31 December 2019 

Company Number: 02933559 

2019 

£ 

  2018 

   £ 

5,466,191 

4,648,238 

                                                                       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 

Net assets 

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 

11 

223,733 
90,902 
314,635 

(22,109) 

292,526 

5,758,717 

5,758,717 

539,470 
881,087 

1,916,502 
1,982,060 
439,598 

5,758,717 

Net Asset Value per share 

13 

266.9p 

     Approved and authorised for issue by the Board of Directors on 2 March 2020. 

   Dr Manny Pohl 

Director 

  The notes on pages 43 to 51 form part of these financial statements. 

 41 

213,435 
35,520 
248,955 

(23,540) 

225,415 

4,873,653 

4,873,653 

539,470 
881,087 

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

4,873,653 

225.9p 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
  
 
    
 
 
                                                                                  Athelney Trust plc 

Statement of Cash flows for the Year Ended 
31 December 2019 

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

Cash (used)/from operations 

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

2019 
£ 

2018 
£ 

195,643 

213,098 

(201,066) 
(1,431) 
(10,298) 

(17,152) 

(2,074,201) 
2,343,102 
268,901 

(157,605) 
299 
(56,638) 

(846) 

(581,051) 
764,179 
183,128 

Equity dividends paid 

(196,367) 

(192,051) 

Net increase/(decrease) in cash 

Cash at the beginning of the year 

Cash at the end of the year 

55,382 

35,520 

90,902 

(9,769) 

45,289 

35,520 

As the company do not have any loans, overdrafts or hire purchase arrangements, net debt is equal to cash and therefore 
no reconciliation of net debt has been disclosed. 

   The notes on pages 43 to 51 form part of these financial statements. 

 42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
      
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

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 October 2019, 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 four 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. 

 43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

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 
Bank compensation 

Total income 

UK dividend income 

UK Main Market listed investments 
UK AIM-traded shares 

 44 

2019 
£ 

173,047 
25,542 
33,173 
- 
500 

232,262 

2019 
£ 

124,674 
48,373 

173,047 

2018 
£ 

183,833 
30,496 
37,653 
8 
- 

251,990 

2018 
£ 

145,370 
38,463 

183,833 

 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

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 

2019 
£ 

2018 
£ 

26,250 
45,122 

13,250 

153 
32,472 
12,351 
6,748 
27,633 
73,706 

21,000 
51,163 

10,930 

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

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. 

237,685 

196,497 

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 

2019 
£ 

26,250 
45,122 
153 

71,525 

- 
1 
- 
1 

2018 
£ 

               21,000 
51,163 
2,400 

74,563 

- 
1 
- 
1 

 45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

5. Taxation 

(i)  On the basis of these financial statements no provision has been made for corporation tax (2018: Nil). 
(ii) Factors affecting the tax charge for the year. 

The tax charge for the period is lower than (2018: lower than) the average small company rate of corporation tax in the 
UK of 19 per cent. The differences are explained below: 

    2019 
       £ 

2018 
£ 

Total return on ordinary activities before tax 

1,081,431 

(1,079,820) 

Total return on ordinary activities multiplied by the average small 
company rate of corporation tax 19% (2018: 19%) 

205,472 

(205,166) 

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 

(32,879) 
(156,631) 
(49,871) 
33,909 

-  

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

-  

The Company has unrelieved excess revenue management expenses of £356,765 at 31 December 2019 (2018: £214,415) 
and £102,597 (2018: £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 2018, 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  2018.    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 

2019 
£ 
Capital 

£ 
Total 

£ 

  Revenue 

2018 
£ 
Capital 

£ 
Total 

Attributable return on  
ordinary activities after 
taxation 

Weighted average number of 
shares 

195,643 

885,788 

1,081,431 

213,098 

(1,292,918) 

(1,079,820) 

2,157,881 

2,157,881 

Return per ordinary share 

9.1p 

41.0p 

50.1p 

9.9p 

(59.9)p 

(50.0)p 

 46 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 
Notes to the Financial Statements  
For the Year Ended 31 December 2019 

7. Dividend 

Final dividend in respect of 2018 of 9.1p (2018: a final dividend 
of 8.9p was paid in respect of 2017) per share 

2019 
£ 

2018 
£ 

196,367 

192,051 

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 9.3p (2018: 9.1p) per ordinary share be paid out of revenue profits amounting 
to a total of £196,367.  For the year 2018, a final dividend of  9.1p was  paid on  18  April  2019  amounting to a total of 
£196,367.  

2019 
£ 

195,643 

(200,683) 

(5,040) 

2019 
£ 

4,648,238 
2,074,201 
(2,343,102) 
262,480 
824,374 

5,466,191 

3,484,130 
1,982,061 

5,466,191 

4,258,921 
1,207,270 

5,466,191 

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 

Revenue available for distribution 
Final dividend in respect of financial year ended 
  31 December 2019 

Undistributed Revenue Reserve 

8. Investments 

Movements in year 
Valuation at beginning of year 
Purchases at cost 
Sales - proceeds 
         - realised gains on sales 
Increase/(decrease) 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 

 47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

8. Investments (continued) 

Gains on investments 

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

2019 
£ 
262,480 
       824,374 

2018 
£ 
98,840 
(1,135,313) 

1,086,854 

835,709 

The purchase costs and sales proceeds above include transaction  costs of £15,533  (2018: £4,290) and £8,810  (2018: 
£3,308) 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 

2019 
£ 
213,862 
9,871 

223,733 

2019 
£ 

1,148 
2,956 
18,005 

22,109 

2019 
£ 

2018 
£ 

201,627 
11,808 

213,435 

2018 
£ 

524 
2,961 
20,055 

23,540 

2018 
£ 

Authorised 
10,000,000 Ordinary Shares of 25p 

Allotted, called up and fully paid 
2,157,881 Ordinary Shares of 25p 

2,500,000 

2,500,000  

539,470 

539,470 

 48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

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 2019 would have decreased net assets attributable to 
shareholders by 51 pence per share (2018: 43 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  

2019 
£ 
5,466,191 

2018 
£ 
4,648,238 

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. 

 49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

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 2019 

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

Liabilities as per the balance sheet 
Creditors 
Total 

31 December 2018 

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 
£ 

- 
223,733 
90,902 
314,635 

22,109 
22,109 

5,466,191 
- 
- 
5,466,191 

- 
- 

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 

- 
- 

 50 

Total 
£ 

5,466,191 
223,733 
90,902 
5,780,826 

22,109 
22,109 

Total 
£ 

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

23,540 
23,540 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

Notes to the Financial Statements  
For the Year Ended 31 December 2019 

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 (2018: classification A investments only). 

13. Net Asset Value per Share 

The  net  asset  value  per  share  is  based  on  net  assets  of  £5,758,717  (2018:  £4,873,653)  divided  by  2,157,881  (2018: 
2,157,881) ordinary shares in issue at the year end. 

Net asset value per share 

266.9p 

225.9p  

2019 

2018 

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: 

Manny Pohl 
Simon Moore 
David Lawman 

Notes: 

£45,955¹ 
£6,143 
£227 

1.  Manny Pohl’s relationship with Global Masters Fund Limited is described in Note 1 to the table of Directors’ interests on 
page 31. During the year a dividend of £45,864 was paid to Global Masters Fund Limited and £91 to Manny Pohl for shares 
held in his own name. 

 51 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Athelney Trust plc 

OFFICERS AND FINANCIAL ADVISERS 

Directors:  

Secretary:  

Registered Office: 

Mr N F Ashton (Chairman) 
Dr E C Pohl 
Mr S Moore 
Mr D Lawman 

                 Email: frankashton@athelneytrust.co.uk 
Email: mannypohl@athelneytrust.co.uk 
Email: simonmoore@athelneytrust.co.uk 
Email: davidlawman@athelneytrust.co.uk 

Mrs D Warburton 
Waterside Court  
Falmouth Road 
Penryn 
Cornwall, TR10 8AW 

Waterside Court  
Falmouth Road  
Penryn 
Cornwall, TR10 8AW 

Email: secretary@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 

 52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 8 April 2020 at 3.30pm 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 Debbie 
Warburton, 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 
3.30pm on 6 April 2020. Instructions for the appointment of proxies through CREST are contained in the Notes 
to the Notice of Annual General Meeting. 

 53 

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

Directors 
E Pohl 
F Ashton 
S Moore 
D Lawman 

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”). 

                                                                                                                                                     2 March 2020 

Dear Shareholder, 

2020 ANNUAL GENERAL MEETING 
APPROVAL OF ANNUAL REPORT AND ACCOUNTS AND OTHER RESOLUTIONS 

Introduction 

The 2020 Annual General Meeting (“AGM”) of the Company is to be held on 8 April 2020 at 3.30pm 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. 

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 2019 will be undertaken at this meeting. 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 6 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 6, the Directors will (pursuant to paragraph (i) of Resolution 6) have the necessary authority until 
the date of the next annual general meeting, or 30 April 2021 if earlier, to allot 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 6, (pursuant to paragraph (ii) of Resolution 6) the Directors will have authority, until 
the date of the next annual general meeting of the Company or 30 April 2021 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 expect to 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 6. 

 54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Resolution 7 proposes as follows: 
If the Directors wish to exercise the authority under Resolution  6 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 7 will empower the Directors until the date of the next annual general meeting of the Company, 
or 30 April 2021 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 expect to 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 28 February 2020 (being the last practicable date prior to publication of this document), the Company held no shares in 
treasury. 

Resolution 8 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 2021 or on 30 April 2021 if sooner. 

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 5 relate to the receiving of the report and accounts; the declaration of a dividend; the approval of the report of the 
remuneration committee; the approval of the Company’s remuneration policy 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  Debbie  Warburton,  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 3.30pm on 6 April 
2020.  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 8 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 these Resolutions. 

Yours faithfully, 

Frank Ashton 
Non-Executive Chairman 

 55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 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 8 April 2020 at 3.30pm to consider the following Ordinary 
and Special business, of which Resolutions 1 to 6 will be proposed as Ordinary Resolutions and Resolutions 7 to 8 will be proposed 
as Special Resolutions. 

ORDINARY BUSINESS 

1 

2 

3 

4 

5 

To receive and adopt the Company’s Accounts for the year ended 31 December 2019. 

To declare a final dividend of 9.3p per ordinary share.  It is intended that dividend cheques in respect of the dividend will 
be posted on 16 April 2020 to all shareholders on the register of members at close of business on 20 March 2020.  

To approve the Directors’ Remuneration Report (excluding the Directors’ Remuneration Policy) as set out on pages 30-
32 of the Company’s Accounts for the year ended 31 December 2019. 

To approve the Directors' Remuneration Policy as set out on page 30 of the Company's Accounts for the year ended 31 
December 2019. 

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

SPECIAL BUSINESS 

6 

 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 2021, 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 

(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. 

7 

Limited disapplication of pre-emption rights 

That, subject to the passing of Resolution 6 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 

 56 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6 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) 

(b) 

generally,  up  to  an  aggregate  nominal    amount  of  £53,947  pursuant  to  the  authority  given  by  paragraph  (i)  of 
Resolution 6 above;  and 

in connection with a pre-emptive offer pursuant to the authority given by paragraph (ii) of Resolution 6 above 

such power to expire at the conclusion of the next annual general meeting or on 30 April 2021, 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 6 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. 

8 

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) 

(d) 

(e) 

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 on the trading venues where the purchase is carried out and the highest current independent bid on the 
trading venues where the purchase is carried out; 

this authority shall expire at the conclusion of the next annual general meeting or on 30 April 2021 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. 

Dated 2 March 2020 

By Order of the Board   
Debbie Warburton 
Company Secretary 

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

 57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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: 
in hard copy form by post or by hand to the Company Secretary at the address shown on the form of proxy; or 
3.1 
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 6 April 2020 
(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 
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. 

 58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 28 February 2020 (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 

 59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ATHELNEY TRUST PLC 
Company Number 02933559 
Form of Proxy for use at the Annual General Meeting to be held at 3.30pm on 8 April 2020 
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 8 April 2020 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. 

RESOLUTIONS 

FOR  AGAINST  ABSTAIN  DISCRETIONARY 

1 

2 

3 

4 

5 

6 

7 

To receive and adopt the Company’s Accounts 
for the year ending 31 December 2019. 

To declare a final dividend of 9.3p per ordinary 
share. 

To approve the Directors’ Remuneration 
Report (excluding the Directors’ Remuneration 
Policy) for the year ended 31 December 2019. 

To approve the Directors' Remuneration Policy 
as set out on page 30 of the Company's 
Accounts for the year ended 31 December 
2019. 

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. 

8 

To authorise purchase of own shares. 

Your attention is drawn to the notes overleaf. 

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

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

 60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

 61