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Athelney Trust Plc
Annual Report 2021

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FY2021 Annual Report · Athelney Trust Plc
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Investment Objective and Policy 
Directors of the Company 

Strategic Report including: 

Chairman’s Statement and Business Review 

Fund Manager’s Review 

1 
2 

4 

7 

Investment and Portfolio Analysis                                        10 

Portfolio Breakdown by Sector and by Index                     11 

Section 172(1) Statement 

Other Statutory Information  

Corporate Governance Statement 

Report of the Directors 

Statement of Directors’ Responsibilities 

Directors’ Remuneration Report 

Independent Auditor’s 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 

12 

13 

15 

19 

21 

22 

24 

29 

30 

31 

32 

33 

38 

Contents 

Annual Report for the year ended  

31 December 2021 

Company number 
02933559 

Athelney Trust 
Waterside Court, Falmouth Road 
Penryn, Cornwall TR10 8AW 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
IInvestment Objective  

The  investment  objective  of  the  Trust  is  to  provide  long-term  growth  in  dividends  and 
capital,  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. 

IInvestment 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 AQSE. 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 are undervalued by the market when compared to future 
earnings and dividends; second, those companies whose shares are undervalued by 
the market when compared with the value of land, buildings, other assets or cash on 
their balance sheet. 

1 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DDirectors oof tthe CCompany

Frank Ashton 
Non-Executive Chairman 

Dr Emmanuel Clive Pohl AM 

Managing Director 

independent  management  consultant.  After 

Frank Ashton, aged 60, is a highly experienced senior manager 
leaving 
and 
Cambridge  University  with  a  Natural  Sciences  degree 
(Metallurgy & Materials Science), he spent much of his career 
providing independent management advice to companies in a 
spent  at 
wide  variety  of 
PricewaterhouseCoopers 
(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. 

sectors.  With  15  years 

and  KPMG 

Manny Pohl, aged 68, 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. 

2 | Athelney Trust plc | Annual Report 2021 

  
 
 
 
 
 
DDirectors oof tthe CCompany
Continued 

Simon Moore 
Non-executive Director 

Simon  Moore,  aged  61,  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 
in 
Biochemistry  BSc  from  Imperial  College,  and  an  MSc 
Computer Modelling of molecules from Birkbeck College. He is 
a member of the UK Society of Investment Professionals and the 
CFA institute. During 2020 he was appointed as a Non-Executive 
Director of Home REIT Plc. 

3 | Athelney Trust plc | Annual Report 2021 

 
Strategic Report 
Chairman’s Statement and Business   Review 

Capital Gains 
During  the  year  the  Company  realised  capital  profits  before 
expenses  arising  on  the  sale  of  investments  in  the  sum  of 
£354,843 (2020: £223,957). 

Portfolio Review 

Additional Holdings Purchased 

Additional holdings of Abcam, Clinigen, Fevertree, JD Sports, LXI 
REIT, Rightmove, Target Healthcare and Treatt  were acquired. 

Holdings Sold or Trimmed 

AEW  UK,  Belvoir  Group,  Churchill  China,  Games  Workshop, 
Liontrust Asset Management, Mountview Estates and National 
Grid. 

Dividend 
During the year the Company paid an interim dividend of 2.0p 
on 24 September 2021. 

The  Board  recommends  a  final dividend  of  7.5p  per  ordinary 
share  making  an  increased  dividend  this  year  of  9.5p  (2020: 
9.4p).  Subject to shareholder approval at the Annual General 
Meeting on 5 April 2022, the dividend will be paid on 13 April 
2022 to shareholders on the register on 11 March 2022. 

Review 
Geo-political  uncertainties  grew  during  2021,  from  more 
extremely polarised US politics and questions on that country’s 
future  role  in  conflict  areas,  to  the  end-game  for  Taiwan  and 
Ukraine.  Who can forget the mob scenes at the US Capitol or the 
chaos at Kabul airport as the rapid withdrawal from Afghanistan 
unfolded?    It  seems  in  retrospect  that  2021  will  be  seen  by 
history as a major year of change and development as the usual 
suspects reposition on the world stage. 

Economies recovered, some faster than expected, thanks to the 
remarkably  rapid  vaccination  development  and  deployment.  
Shortages  of  a  wide  variety  of  products  occurred  as  supply 
struggled to keep pace with demand.  We dined out less,  but 
bought  more  goods  leading  to  container  port  blockages  for 
example.  Common items such as microchips were in such short 
supply  that  delivery  on  a  wide  range  of  items  –  from  cars  to 
handheld  tablets  -  were  delayed.    Apple,  which  navigated  the 
shortages better than others, estimated the impact to be a loss 
of $6 billion to 2021 sales.  The IMF estimates that globally 1% of 
2021 GDP was lost as a result, however stock markets reached 
record highs. 

Dear Shareholder 

I am pleased to present the Annual Financial Report for the year to 
31 December 2021. 

The Strategic Report section of this Annual Report has been prepared 
to help all Shareholders understand the drivers of performance in the 
past year, how the Company operates and to assess its performance. 

Overview 
Athelney Trust plc (the ‘Company’ or ‘Trust’) experienced a year of 
different conditions to 2020 as the global pandemic transitions little 
by little to an endemic and economies deal more with the results of 
disruption rather than just the health crisis itself.    

Your company performed extremely well in this context, and the 
key performance points are as follows: 

(cid:120) 

(cid:120) 

(cid:120) 

(cid:120) 

(cid:120) 

(cid:120) 

At 31 December 2021, audited Net Asset Value (NAV) was 
310.3p per share (2020: 255.3p), an increase of 21.5% over 
the year as compared to a 14.6% increase in the FTSE 250 
and a 14.3% increase in the FTSE 100. 
The  Trust’s  investment  performance  over  12  months  as 
measured by NAV total return, which is the change in NAV 
plus the dividend paid, was 25.2% (2020: -0.22%).    
The 12-month revenue return per ordinary share was 7.0p 
(2020: 5.9p), an increase of 18.6%. 
The  interim  dividend  of  2.0p  per  share  was  paid  on  24 
September 2021. 
Your Board recommends a final dividend of 7.5p per share 
increasing  a  total  dividend  payable  for  the  year  to  9.5p 
(2020: 9.4p) an increase of 1.1%.  UK inflation for 2021 was 
4.8% (Office for National Statistics) 
This is the 19th successive year of progressive dividend and 
importantly  returns  the  Trust  to  a  high  position  in  the 
dividend  yield  league  table  for  Investment  Companies.  It 
also keeps us in the Next Generation of Dividend Heroes list 
maintained by the AIC. 

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 15 to 18. 

An Independent Board 
The Directors in place at the time of signing these accounts are: 
(cid:120)  Myself, Frank Ashton – Non-Executive Chairman 
(cid:120) 

Simon  Moore  –  Non-Executive  Director,  Chair  of  Audit 
Committee, Chair of Remuneration Committee 
Dr Manny Pohl - Managing Director, Fund Manager 

(cid:120) 

We  currently  have  three  directors  who  together  make  up  an 
independent Board under the AIC Code of Governance 2021. 

4 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Strategic Report 
Chairman’s  Statement  and  Business  Review 
Continued

Dividend  growth  amongst  smaller  companies  was  faster  still  and 
this is one of the reasons we focus on small companies; resilience 
from the right companies and their management team in times of 
adversity.    However  despite  this  growth,  mid-cap  dividends  only 
ended  the  year  at  the  same  level  as  2007/2008.    The  headlines 
were  taken  in  2021  by  mining  companies  delivering  a  record 
£16.9bn of special dividends, three quarters of this from Rio Tinto 
and BHP alone.   

Your company’s revenue return improved by 19% to 7p per share 
(2020: 5.9p) still below the 9.1p of 2019.  NAV total return was a 
very healthy 25.2% (2020: -0.2%) improving on the pre-Covid figure 
of 22.2%. 

Against  this  backdrop  I  am  pleased  to  tell  you  that  your  Board 
recommends  a  final  dividend  payment  of  7.5p  (total  9.5p).    This 
reflects  the  better  performance  and  total  return  for  the  year, 
subject to approval at the AGM.  At a share  price of 310p on 31 
December, this represents a dividend yield of 3.1%, better than the 
average  2021  yield  from  FTSE  250  companies  of  1.91%  (and 
comparable to the FTSE All-Share yield of 3.07%). 

Non-executive  Director’s  fees  remain  at  £10,500  each  and  your 
board  continues  to  exercise  a  tight  grip  on  costs.  Our  ongoing 
charges figure has fallen again, from 2.45% last year to 2.38%.  Your 
board understands that while we remain a small fund, reducing this 
will continue to be a challenge, however every effort is made to do 
this,  while  maintaining  appropriate  attention  on  controls  and 
governance. 

Outlook 
There  are  a  number  of  ongoing  uncertainties  that  may  slow  the 
return to foreign investment in UK stocks, starting with the obvious 
potential  for  another  Covid  variant  prolonging  the  progress 
towards endemicity.  Being able to ‘live with the virus’ depends on 
social norms for what is ‘acceptable’, the possible occurrence of a 
more severe variant and the effectiveness of global vaccinations. 

Secondly the risk of conflict or at least lower levels of cooperation 
and trade between major nations is higher at the moment, in the 
case  of  Russia,  Ukraine  and  NATO  countries,  and  also  between 
China,  Taiwan  and  America.    Globalisation  and  trade  between 
major countries and regions means that local shocks now have a 
much  larger  impact  on  national  economies  and  in  some  cases 
global outlook than perhaps ever before.   

Covid has not encouraged the wider country-country cooperation 
or action that was hoped; in fact we see more of the opposite as 
politicians act ‘in the national interest’, and countries have to look 
after themselves. 

A year on from Brexit it is hard to quantify and isolate the impact from 
that of COVID, however most agree that so far it has been negative: 
The UK’s GDP continues to under-perform the Euro zone which may 
be partly due to a loss of EU nationals previously employed in the UK, 
increased  controls  at  the  border  reducing  trade,  and  the  long  term 
effects of the uncertainty created by the referendum result in 2016. 
The next few years need to produce clearer benefits to evidence a net 
gain;  in  the  meantime  UK  stocks  continue  to  be  under-valued  as 
investors  prefer  alternatives  and  continue  to  present  us,  your 
company with investment opportunities. 

The  impact  of  the  new  Omicron  variant  added  to  the  list  of 
uncertainties  in  the  last  quarter  of  2021  including  how  much  more 
interventionist European governments will become, for example on 
mandating vaccinations or on when and how quickly the ‘free money’ 
and easy lending from central bank intervention will end, or monetary 
policy tightens to combat rising interest rates. 

I  am  delighted  therefore  to  report  that  your  company’s  NAV 
outperformed both the FTSE 100 and 250 markets over the year by 
7.2 and 6.9 percentage points respectively. We are seeing the benefit 
that  Manny  Pohl  brings  in  the  three  years  since  he  became  fund 
manager with greater conviction, focus and efficiency resulting in a 
smaller  portfolio  that  is  outperforming  comparators.    The  Board  is 
very  grateful  for  his  concentrated  efforts  to  identify  the  right 
investments and timing to invest or divest, and to continue to provide 
returns for shareholders against the backdrop of greater than usual 
uncertainties.  

As 2021 drew to a close, Apple continued its relentless rise, tripling its 
share price since early 2020 when Covid first struck.  On the first day 
of trading in 2022, it became the first company to realise $3 trillion 
market  capitalisation,  reflecting  the  importance  of  technology  for 
work, education, entertainment and staying connected. 

In the wider market a concerted lift to global markets began in April, 
benefiting stocks to cryptocurrencies, with a rush into US equities by 
retail investors at the heart of that lift.  All three major US indices set 
record highs in October.  As the Federal Reserve retreated from its 
stimulus program, however, the bubble burst for Spacs and cryptos, 
the newest, frothiest assets. 

By the end of the year some assets had lost a third to one half of their 
value in just over a month. 

Meanwhile your company continues to invest for the long term in the 
UK market which has de-rated strongly since 2016 and is now trading 
at the lowest price to earnings level against global peers for 30 years: 
Its value is attractive on a relative and absolute basis.  The UK market 
continues to offer the highest dividend yield globally, with high levels 
of dividend cover. 

In  the  UK,  expectations  were  that  dividends  would  grow  just  8%  in 
2021,  best  case  (Link  Group),  however  actual  underlying  growth 
(excluding special dividends) was much better at nearly 22% with most 
sectors  contributing,  especially  banking  (restoring  distributions)  and 
industrials.   Mid-caps (+40.1%) rebounded and grew faster than  the 
top 100 on an underlying basis.  

5 | Athelney Trust plc | Annual Report 2021 

Strategic Report 
Chairman’s Statement and 
Business Review Continued 

Thirdly there will be unrest as we experience an uncomfortable financial 
squeeze.  Interest rates will rise to combat inflation. In the case of the 
Fed, which many commentators feel has lost its direction in this matter 
and  dithered  too  long,  it  appears  likely  there  will  be  an  abrupt 
tightening in response to 7% inflation and a 5% increase in wages and 
salaries in America over 2021.  Globally, inflation is running at 6% and 
here in Europe, central banks are preparing the markets for two or more 
interest rate rises in 2022.  In the short term, the UK is going to see a 
rapid rise in household bills, mostly driven by huge energy price rises; 
this  has  already  resulted  in  calls  from  the  Governor  of  the  Bank  of 
England  for  wage  restraint  to  avoid  entrenchment  of  inflation  longer 
term.  To make the challenge bigger, the jobs market is “extraordinarily 
tight” according to Governor Andrew Bailey.  

At the same time, uncertainty grows for Boris Johnson’s premiership, as 
‘Partygate’  gains  momentum  with  a  possible  fixed  penalty  notice  for 
him and senior No 10 staff a possible result.  This would certainly trigger 
a  no-confidence  vote  by  his  Tory  MPs  and  a  damaging  pause  to  any 
possible progress after Brexit while a new leader is selected.  All await 
the outcome of the Metropolitan Police investigations and the Sue Grey 
report. 

Together these elements raise concern:  History tells us the fight against 
inflation normally results in a recession and short term, the UK  
is apparently short of governmental leadership that inspires trust and 
confidence through challenging times. 

In the UK, record mining special dividends of 2021 are likely to not be 
repeated  in  2022.  However  B&M  and  Next  already  have  distributed 
such dividends to provide a catch-up and to reflect extra revenue from 
lockdown, online pent-up demand and little competition for the wallet 
from international travel.  There is also some optimism that underlying 
dividends for the top 100 will grow by about 5% overall this year (Link 
Group):  This  is  likely  to  be  a  stronger  number  for  smaller  companies 
than for the Top 100. 

Good  companies  at  fair  prices  are  still  overlooked  by  house 
analysts. Those with commitment to a proven system, prepared to 
analyse fully and act on conviction, will come out on top in the long 
run.  Our  Managing  Director  and  Fund  Manager  has  many  years’ 
experience relevant to operating successfully in the conditions of 
2021 – this continues to bode well for your Trust as we recently 
passed his 3 year anniversary in taking on the Fund Management 
role. 

Our AGM in 2021 was again  held virtually, with no shareholders 
present, as movement restrictions and the safety of our investors 
and colleagues were uppermost in our minds. We plan to hold a 
meeting in person for the AGM this year on 5 April 2022 at 12.00 
noon. Shareholder engagement and opinion is very important to 
us,  so  there  are  plans  in  place  to  give  you  the  opportunity  to 
engage with the Board. Details of the proposed AGM can be found 
in the separate Notice to the AGM publication. 

   Manny Pohl, as Fund Manager, will provide a short presentation on 

his investment approach for all attendees of the AGM. 

I and my colleagues on the board look forward to the chance of 
meeting  you  in  person  once  more.    We  wish  you  well  in  the 
meantime. 

Frank Ashton 
Non-Executive Chairman 
23 February 2022 

6 | Athelney Trust plc | Annual Report 2021 

Strategic Report
Fund Manager’s Review 

The Global Scene 
The  past  year  has  been  very  unusual  characterised  by  isolation, 
distance,  and  virtuality  and  one  which  most  of  us  will  be  keen  to 
forget.  While  2020  imposed  a  strange  new  world  upon  us,  2021 
became the year of the ‘new-normal’. For most of us, this past year 
has  seen  our  social  circles  dwindle  dramatically  and  our  online, 
virtual  lives  came  to  fruition.  For  me,  this  year  has  been  most 
challenging due to the restrictions on travelling and not seeing loved 
ones  and  long-standing  friends.  As  for  everyone,  we  have  had  to 
adjust,  be  resilient  and  find  new  and  alternative  ways  to  move 
forward and improve.  

Over  the  past  year,  we  have  been  teased  with  our  freedoms, 
gradually  emerging  from  blanket  lockdowns  and  then  focusing  on 
implementing ongoing regional lockdowns. Many of the rescheduled 
2020  sporting  events  were  hosted  in  2021,  albeit  in  most  cases 
without the public in attendance.  

For the world community, being resilient in these testing times is the 
only attribute that has kept us all going. Sadly, as the world gradually 
opened,  the  reported  deaths  continued  to  climb,  reaching  five 
million  in  November  2021.  On  a  positive  note,  the  vaccines 
administered  worldwide  exceeded  1  billion  in  June  2021.  While 
world health officials were focused on combatting different variants 
of the virus, businesses were struggling to survive, and consumers 
were fearful of disrupted supply chains, low inventories, and rising 
inflation.  

The Markets and Our Portfolio 
Despite this frantic and dramatic backdrop, equity markets and our 
portfolio have delivered a remarkable return with the FTSE 100 up 
by 7.5% in the final quarter of the year and our portfolio up by 29.1%. 
This compared favourably with other major stock markets and better 
than the NASDAQ’s 4.1% rise. The NASDAQ, which is home to many 
technology companies, has outperformed strongly over the last two 
years, but more recently, the share prices of older, more traditional 
companies have started to increase. The FTSE 100 is home to many 
such  companies,  including  BP,  Royal  Dutch  Shell  as  well  as  Utility 
companies.  It  hit  a  record  high  of  7457.1  on  29  December  2021 
before  declining  to  close  at  7384.5  at  year-end.  I  have  been 
managing  the  portfolio  for  the  past  three  years,  and  I  am  very 
pleased with the performance as shown in Table 1. 

 Table 1: Performance Metrics 

Compound 
Growth Rate 

1 Yr 

2 Yr 

3 Yr 

5 Yr 

10 Yr 

ATY PORTFOLIO * 

29.1%  15.7%  19.9%  n.a

n.a.

ATY NAV 

FTSE 250 

FTSE 100 

21.5%  7.8% 

11.2%  4.4% 

9.7% 

14.6%  3.6% 

10.3%  5.4% 

8.8% 

14.3% 

-1.1% 3.2% 

0.7% 

2.9% 

FTSE Small Cap 

20.0%  12.0%  12.9%  7.7% 

10.5% 

*  Portfolio  performance  is  time  weighted,  before  management  fees,
expenses and dividends and is only available from when Dr Manny Pohl AM
commenced managing the portfolio. 

7 | Athelney Trust plc | Annual Report 2021 

Despite  this  excellent  stock  market  performance,  the  Begbies 
Traynor’s “Red Flag Alert”, which has monitored the financial health 
of British companies for the past 15 years, now paints a particularly 
worrying picture for UK businesses with increasing numbers falling 
victim  to  pressures  that  have  been  building  up  over  the  past  two 
years as a result of the COVID-19 pandemic. Therefore, it is essential 
in this environment that the portfolio comprises quality businesses 
with demonstrated resilience against such a headwind, enabling the 
portfolio to outperform. 

Any successful business owner makes decisions for the betterment 
of their long-term business. Having sustainable practices and a long-
term  mindset  is  vital  for  any  operator  in  this  modern,  rapidly 
changing world. Sustainability has long been part of our investment 
process,  and  since  we  see  ourselves  as  business  owners  (and  not 
share traders), we invest along similar principles where sustainability 
and competitiveness are central to any investment analysis.  

While  most  of  the  stocks  in  the  portfolio  contributed  to  the 
outperformance  of  the  portfolio  versus  the  market,  a  handful  of 
names performed exceptionally well, which included Liontrust Asset 
Management (LSE: LIO), Tritax Big Box (LSE: BBOX) and AEW UK Reit 
(LSE:  AEWU).  After  an  impressive  performance  in  2020,  Games 
Workshop (LSE: GAW) detracted from the portfolio return over the 
year, as did HomeServe (LSE: HSV). At an aggregate level, all of our 
alpha was generated through stock selection, as opposed to sector 
selection  and  this  is  consistent  with  our  style  as  a  bottom-up, 
benchmark unaware, high conviction manager. 

Liontrust Asset Management (LSE: LIO) 
The company was launched in 1995 and listed on the London Stock 
Exchange in 1999. LIO currently  has approximately £37.2 billion  in 
assets under management and advice as at the 31 December 2021, 
which increased 20% over the financial year. It is a well-run, fairly 
vanilla active investment manager which offers traditional products 
such  as  Unit  Trusts,  Offshore  funds,  Segregated  Mandates,  and 
fund 
Discretionary  Portfolio  Management 
investment 
management  team  applies  distinct  and  rigorous 
processes  to  manage  funds  and  portfolios  that  ensure  portfolio 
management  is  predictable  and  repeatable.  It  markets  its  fund 
internationally to institutional investors, wealth managers, financial 
advisers,  private  investors,  and  wholesale  markets  such  as  family 
offices,  private  banks,  wealth  managers,  and  multi-managers.  The 
company’s geographical segments are the United Kingdom, Europe 
(excluding the UK), Canada, and Australia. 

Services.  Each 

Tritax Big Box (LSE: BBOX) 
Tritax Big Box owns and operates big box stores which serve as the 
breakdown  point  for  bulk  palleted  deliveries  and  are  often  port-
centric in their location focus. It is a UK-based real estate investment 
trust  with  the  focus  on  the  acquisition  and  management  of  large-
scale logistics real estate let to institutional-grade tenants on long-
term  leases.  The  company  has  benefited  from  implementing  a 
strategy that anticipated long-term, structural changes, particularly 
the  growth  in  e-commerce.  The  company  has  witnessed  the  most 
robust  first  half  performance  to  date  with  a  12.5%  total  return  to 
June  2021  reflecting  an  increasingly  acute  imbalance  between 
increasing demand and highly constrained supply, in a market with 
clear barriers to entry.  

Strategic Report 
Fund Manager’s Review 
Continued 

AEW UK REIT (LSE: AEWU) 
AEW UK is a conservatively geared REIT with a current loan to NAV 
ratio  of  29.84%.  The  company’s  investment  objective  is  the 
attractive total return to shareholders from primarily investing in a 

portfolio of smaller commercial properties in the UK. Geographically, 
it  operates  only  in  the  United  Kingdom  and  the  company  derives 
revenue from rental income and other property income which has 
been retained in the portfolio because of its attractive yield.  

Chart 1: Contributions to NAV in the period 1 January 2021 to 31 December 2021 (pence per share) 

+7(cid:1005)(cid:856)(cid:1010)

-9.7

-2.1

0.0

-4.8

31(cid:1004)(cid:856)(cid:1007)

340.0

320.0

300.0

280.0

260.0

240.0

220.0

200.0

255.3

N(cid:4)(cid:115) 2020

Portfolio
Performance

Dividend Paid Management

Tax

Fee

Operating
Expenses

N(cid:4)(cid:115) 2021

For  us,  the  integrity  and  credibility  of  any  management  team  is  a 
founding principle in our investment process. We need to trust that 
management has the best interests for all stakeholders at heart. We 
have  faith  that  they  will  make  sound  strategic  decisions  and  have 
substantial  experience  and  capabilities  in  their  chosen  field.  As 
custodians  of  our  capital,  we  must  ensure  that  we  are  doing 
whatever  we  can  to  preserve  capital  and  grow  it  over  time.  We 
allocate capital to investments that we believe are sustainable in the 
long  term.  Finding  trustworthy,  values-based  management  teams 
that align with our core values and beliefs will ensure above-average 
investment 
economic  portfolio 
performance  and  the  improvement  of  societal  wellbeing  hinges 
upon ethical, transparent, and honest leadership. In cases where we 
feel we can add something to the conversation, we engage with the 
company.   

Sustainability  of 

returns. 

A genuine long-term approach 
Our process aims to find high-quality businesses that we own for the 
very long-term, our portfolio turnover remains low. We continue to 
have investments that we have held for over ten years; however, this 
doesn’t  mean  we  aren’t  always  looking  for  new  investments.  The 
focus  this  year  has  been  to  monitor  the  individual  business 
performance  in  a  highly  stressful  environment  of  our  existing 
holdings as opposed to the share price performance to ensure that 
they  have  the  sustainable  and  resilient  characteristics  mentioned 
previously. Few changes have been made to the portfolio with our 
exposure  to  property  trusts  retained  to  recognise  the  need  to 
maintain  the  dividend  paid  to  shareholders  within  a  growth  style 
portfolio. 

Investment  management  is  more  than  merely  generating  alpha  in 
excess  of  a  benchmark.  While  that  is  a  core  part  of  our  mandate, 
other fundamental qualitative issues are central to what we do. For 
example,  we  recognise  that  capital  allocation  is  a  vehicle  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 vote with our feet.   

8 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
Strategic Report 
Fund Manager’s Review 
Continued 

Investment Philosophy 
As  far  as  portfolio  investments  are  concerned,  our  investment 
philosophy is clear: 
I. The  economics  of  a  business  drives  long-term  investment
returns; and
II.
Investing in high quality, growth businesses that have the ability
to  generate  predictable,  above-average  economic  returns  will
produce superior investment performance over the long-term.

In essence, this means that in assessing potential investments we: 
1. Value long-term potential, not just performance
2. Choose high-quality, growing businesses; and
3.

Ignore temporary market turbulence.

The key attributes that will define our investments are: 

Organic  Sales  Growth:  Quality  franchises  organically  growing
(cid:120)
sales above GDP growth that can do so (sustainably) because they
have  a 
large,  growing  market  opportunity  and  compelling
competitive advantage which will drive ongoing market share gains
are attractive.

the
A  Proven  Track  Record:  This  encompasses  both 
(cid:120)
management’s capability and the strength of the  business’ model.
Generally,  a  firm  that  consistently  delivers  a  Return  on  Equity  of
greater  than  15% 
indicates  a  Quality  Franchise  for  us.  Our
investment philosophy is built on the belief that a stock’s long-term
return  to  shareholders  is  driven  by  the  return  on  capital  of  the
underlying business.

Company's Future Profits: In essence we are backing a proven
(cid:120)
management team and a successful business model. Management
are the key decision makers regarding the company’s strategy and
its competitive position in the marketplace. It is critical that we have 
confidence  in  the  company’s  ability  to  sustainably  execute  its
strategy  and  grow  earnings,  even  in  a  tough  environment  like  the
current and Brexit conundrum.

Low  Leverage:  We  require  investments  to  operate  with  low
(cid:120)
levels of debt, which ensures that they have sufficient resources to
execute on their strategy. An Interest Coverage above 4x provides
sufficient bandwidth in  times of  economic trouble. As a long-term
investor, capital preservation is the highest priority. There is nothing
that  changes  a  management  team’s  focus  toward  the  short  term
quicker  than  impending  debt  refinancing  when  market  conditions
suddenly change for the worse. We need to be comfortable that this 
will not happen and that the company has a strong enough balance
sheet so that it will retain optionality and can quickly and efficiently
execute its strategy over the long-term.

9 | Athelney Trust plc | Annual Report 2021 

Looking Forward 
The portfolio outperformance over the past twelve months was 
due  to  a  considerable  increase  in  both  the  earnings  and  the 
dividends declared by our companies and a substantial re-rating 
of these businesses by the market. The world economy had the 
wind  at  its  back  in  2021  with  generous  fiscal  policy  and 
accommodative  central  bankers.  However,  inflation  and  supply 
chains  have  been  identified  as  the  key  obstacles  to  earnings 
growth,  with  central  banks  now  focusing  on  dealing  with  the 
former. In the US, the Fed is expected to increase interest rates 
four times during 2022, and with inflation rising in the UK to 5.4% 
in December,  the BoE hiked its policy rate by 25 bps to 0.5% at its 
February  meeting.  In  Europe,  recent  data  has  confirmed  an 
economic soft patch with the Eurozone January services PMI index 
declining by more than expected and the corresponding index in 
the UK also declining in January. 

long-term  economics  of  a  business  drives 

The net effect of the expected tightening in monetary policy has 
placed  pressure  on  the  high  PE  valuations  of  the  market,  in 
particular  growth  stocks  as  future  earnings  are  discounted  at  a 
higher  rate.  While  this  will  put  pressure  on  our  portfolio  in  the 
short term, our investment philosophy is based on the belief that 
the 
long-term 
investment returns. Our companies have strong business models 
with capable and experienced management teams. The long-term 
financial  metrics  of  our  portfolio  companies,  including  organic 
sales growth, earnings, and dividend growth, should provide the 
impetus  for  an  improvement  in  valuations  or  at  least  be 
supportive of the current valuations in the future.   

The  Athelney  dividend  is  supported  in  the  short-term  by  the 
reserves we have built up through our investment performance as 
well as by the ongoing distributions from the high yielding property 
trusts. For many of the companies in the portfolio, our estimates 
and forecasts for earnings and dividends remain promising. Over 
time  we  expect  that  dividends  from  the  high  growth  quality 
companies in the portfolio will increase sufficiently so that other 
high  growth  quality  companies  can  replace  the  property  trusts 
without jeopardising our AIC dividend hero status. 

Update 
The unaudited NAV on 31 January 2022 was 282p per share – down 
by 9.1% from 31 December 2021, The share price on the same day 
was 235p (trading at a discount of 16.5%).  Further updates can be 
found at www.athelneytrust.co.uk  

Dr Manny Pohl AM 
Fund Manager 
23 February 2022 

Strategic Report 
Investment and Portfolio Analysis at 31 December 2021 

Stock 

 Holding 

 Value (£) 

Biotechnology 
Chemicals 
Construction & materials 

Electronic & electrical equipment 
Food & beverages 
General financial 

Healthcare 
Leisure goods 
Media 

Mobile communications 
Multiutilities 
Property, commercial & 
residential 

Retailers 
Support services 

Abcam 
Treatt 
Clarke T 
Forterra 
XP Power 
Fevertree 
Close Brothers 
Jarvis Securities 
Liontrust Asset Management 
S & U 
Clinigen 
Games Workshop 
4Imprint 
Rightmove 
Yougov 
Gamma Communications 
National Grid 

AEW UK REIT 
Lok’n Store 
Londonmetric 
LXI REIT 
Target Healthcare REIT 
Tritax BigBox REIT 
JD Sports 
Begbies Traynor 
Homeserve 
NWF Group 
Paypoint 
Smart Metering Systems 

13,000 
26,000 
145,000 
40,000 
4,000 
7,000 
13,500 
116,000 
27,000 
6,000 
30,000 
3,500 
5,000 
30,000 
10,100 
10,000 
14,000 

350,000 
33,000 
100,000 
106,923 
200,000 
170,000 
55,000 
95,000 
16,000 
35,000 
9,000 
8,000 

226,460 
336,700 
232,000 
109,000 
204,400 
189,980 
189,135 
319,000 
592,650 
162,600 
274,500 
349,650 
139,500 
239,460 
157,560 
164,800 
149,213 

392,700 
326,700 
283,600 
154,612 
235,600 
422,960 
119,460 
125,780 
140,240 
71,400 
60,120 
67,040 

 SECTOR 
 £ 
226,460 
336,700 

341,000 
204,400 
189,980 

1,263,385 
274,500 
349,650 

536,520 
164,800 
149,213 

% 

3.5 
5.2 

5.3 
3.2 
3.0 

19.6 
4.3 
5.4 

8.3 
2.6 
2.3 

1,816,172 
119,460 

28.2 
1.9 

464,580 

7.2 

Portfolio Value 
Net Current Assets 

TOTAL VALUE 

Shares in issue 

Audited NAV 

310.3p 

£6,436,820 
£258,710 

     £6,695,530 

2,157,881 

10 | Athelney Trust plc | Annual Report 2021 

Strategic Report 
Investment and Portfolio Analysis at 31 December 2021 
Continued 

Portfolio by Sectors 

Portfolio by Listing 

11 | Athelney Trust plc | Annual Report 2021 

Strategic Report 
Section 172(1) Statement

The Directors of the Company are required to promote the success 
of the Company for the benefit of the Members and Shareholders 
as  a  whole.  Section  172(1)  of  the  Companies  Act  (2006)  expands 
this duty and requires the Directors to consider a broader range of 
interested  parties  when  considering  the  promotion  of  the 
Company. This wider group of stakeholders will include employees, 
if any, suppliers, customers and others, and the Board will look to 
understand and take into account the needs of each stakeholder, 
although  recognising  that  different  stakeholders  may  have 
conflicting  priorities  and  not  all  decisions  made  will  be  to  the 
benefit of all stakeholder groups. 

When making decisions the Board should consider the following: 

(cid:120)

(cid:120)

(cid:120)

(cid:120)

(cid:120)

(cid:120)

the likely consequences of any decisions in the long-term;

the interests of the Company’s employees (if applicable);

impact  of  the  Company’s  operations  on  the

the 
environment and the community;

the need to foster the Company’s business relationships
with suppliers, customers and others;

the  need  to  act  fairly  for  all  members  of  the  Company,
and

the desirability of the Company maintaining a reputation
for high standards of business conduct.

In  line  with  similar  small  Investment  Trusts  and  Investment 
Companies, Athelney Trust  plc does not have any customers and 
relies  on  a  number  of  third-party  providers  of  services  such  as 
Company  Administrator,  the  Custodian  and  the  Registrar  to 
maintain  its  operations.  The  Company  takes  into  account  the 
regulations of the market in which it operates and has regard to the 
environment and the wider community in which it operates. 

At every Board meeting the Directors review the performance of 
the  Company  towards  meeting  the  Company’s 
Investment 
Objective through its strategy. Manny Pohl is the fund manager and 
reports to other Board members and answers any questions raised. 
The compliance with existing regulatory and legal requirements are 
reviewed,  together  with  any  new  regulations  that  are  due  to  be 
introduced or are being proposed that may affect the Company. 

The  Board  recognises  the  importance  of,  and  is  committed  to, 
understanding  the  views  of  Shareholders  and  maintaining 
communication  with  its  Shareholders  in  the  most  appropriate 
manner. 

This is undertaken through: 

in  normal 

Annual General Meeting 
The  Company, 
circumstances  encourages  all 
Shareholders  to  attend  and  participate  at  its  Annual  General 
Meeting (“AGM”). Whilst the formal business of the meeting is the 
primary  purpose  of  the  meeting,  members  of  the  Board  are 
available  to  answer  questions  directly  from  Shareholders,  to 
provide  an  update  to  the  meeting  and  to  offer  Shareholders  an 
insight into the business.  

12 | Athelney Trust plc | Annual Report 2021 

The AGM held in March 2021 was subject to government COVID-19 
restrictions  and  the  Board  reluctantly  held  the  meeting  behind 
closed  doors  and  Shareholders  were  requested  not  to  attend. 
Voting was poll  based and Shareholders were requested to email 
any  questions  to  the  Directors.  The  Board  plan  to  hold  the  2022 
AGM  in  person  on  5  April  2022  at  12.00  noon.  Further  details 
regarding the 2022 AGM are contained in the Notice of the Annual 
General Meeting published in a separate notification. 

Published Reports 
The Company produces Annual and Half Yearly Reports and monthly 
fact sheets are all available from the Company’s website and paper 
copies  are  available  on  request  from  the  registered  office.  The 
publication of these reports is considered to be the primary method 
of communication to Shareholders and other readers of the reports 
and  provides  detailed  information  on  the  portfolio,  performance 
over the period and an assessment of the outlook for the Company. 

The  Annual  Report  also  contains  details  regarding  the  Company’s 
corporate governance and the Board seek to ensure that the Report 
is  readable  and  is  mindful  that  it  should  be  fair,  balanced  and 
understandable. 

Shareholder enquiries 
Shareholders  can  contact  the  Company  or  any  of  its  Directors 
through  the  Company  Secretary  or  through  their  company  email 
address.  Alternatively, letters can be sent to the registered office 
address. Although the Directors are not available full time, with the 
assistance  of  the  Company  Secretary  they  seek  to  maintain  open 
communication to all Shareholders. 

in 

the  Company.  Regular  communication 

Suppliers 
The Company Secretary Deborah Warburton and Administrator GW 
&  Co.  Limited  are  often  the  main  contact  point  for  advisors  and 
is 
stakeholders 
maintained  between  the  Company  Secretary  and  the  Directors 
advising them of all matters concerning the Company. The Company 
also  relies  on  the  provision  of  services  from  outside  parties  to 
operate  and  gives  consideration  to  the  needs  and  objectives  of 
those providers and recognises that their success will often assist 
the Company in achieving its objectives. 

Regulators 
The Company operates in an environment that is governed by legal 
and  regulatory  requirements.  The  Board  recognises  that  these 
requirements  are  there  to  protect  stakeholders,  including  the 
government. 

Environment and Community 
As  the  Company  does  not  have  any  direct  employees  nor  any 
physical office environment of its own it has little direct impact on 
the community or the environment. The Company seeks to reduce 
its  impact  on  the  environment  in  encouraging  Shareholders  to 
receive  Reports  electronically  rather  than  through  printed  hard 
copies.  When  paper  copies  are  requested  FSC  paper  is  used.  The 
Board also engage through electronic means where possible rather 
than hold excessive face to face meetings. 

Strategic Report 
Other Statutory Information 

As explained within the Report of the Directors on pages 19 to 20, 
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, 
investment  and  dividend  policies, 
corporate and gearing strategy, corporate governance procedures 
and  risk  management.  Biographical  details  of  the  three  male 
Directors, can be found on pages 2 and 3. 

including 

One of the Directors is the Company's only employee (2020: 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  AQSE.  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 revenue and 
profits but, despite this progress are undervalued by the market 
when compared to future earnings and dividends; second, those 
companies  whose  shares  are  undervalued  by  the  market  when 
compared with the value of land, buildings, other assets or cash on 
their 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, future growth, financial strength and cash flows. The 
weighting  of  individual  investments  reflects  the  Fund  Manager’s 
conviction in the expected future returns from those holdings. 

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 2021 can be found on pages 10 and 11 of this 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  15  to  18, 
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.  

13 | Athelney Trust plc | Annual Report 2021 

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 4 
to 6 and the Fund Manager’s review on pages 7 to 9 which form part 
of the Strategic Report. 

Principal  Risks  and  Uncertainties  and  Risk 
Management 
As stated within the Corporate Governance Statement on pages 15 
to 18, 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. 

(cid:120) 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.

(cid:120)

(cid:120)

(cid:120)

(cid:120)

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

the 

recommendations  of 

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
the  UK  Corporate
noted 
Governance Code and its statement of compliance appears
on pages 15 to 18. 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.

third-party 

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

service  providers  could 

lead 

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 and, as far as the Board is aware, 
no  issues  exist  in  respect  of  social,  community  or  human  rights 
issues. 

Investment 

Fund  Manager’s 

Alternative 
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. 

On behalf of the Board 

 Dr Manny Pohl AM 
 Managing Director 

 23 February 2022 

Strategic Report 
Other Statutory Information 
Continued 

(cid:120)

(cid:120)

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.

The Company has complied with the MiFID ll and KID 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 
http://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. 

14 | Athelney Trust plc | Annual Report 2021 

Corporate Governance Statement

Frank Ashton retired by rotation and was re-elected at the AGM on 
31 March 2021. The Directors believe that the Board has the balance 
of skills, experience, ages and length of service to enable it to provide 
effective leadership and  proper  governance of the Company.  The 
Directors possess a range of business and financial expertise relevant 
to  the  direction  of  the  Company  and  consider  that  they  commit 
sufficient time to the Company’s affairs.  

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 2021, the Board met a total of 
9 times, via conferencing facilities due to face to face meetings being 
impossible due to COVID-19 restrictions. 

 E C Pohl 
 N F Ashton 
 S Moore  

Board 
Meetings 
9 
9 
9 

Audit 
Committee 
- 
1 
1 

Remuneration 
Committee 
- 
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  comprises  three  male 
Directors.  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 it has 
an  appropriate  breadth  of  skills  and  experience.  The  Board  is  not 
currently planning to add a fourth Director to the Board. 

The basis on which the Company aims to  generate value over the 
longer term is set out in the Strategic Report on pages 4 to 14. 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. 

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 January 2021 which can be found at www.frc.org.uk. The 
Association  of  Investment  Companies  issued  its  own  Code  of 
Corporate Governance in April 2021 (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: 

(cid:120)

(cid:120)

(cid:120)

(cid:120)

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. One third of the Directors retires by
rotation  annually  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  three  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 
At 31 December 2021 the Board consisted of three Directors, of 
which two were and remain independent. The biographies of all 
the current Directors are contained on pages 2 and 3. 

15 | Athelney Trust plc | Annual Report 2021 

Corporate Governance Statement 
Continued 

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: 

(cid:120)

•

The  maintenance  of  clear  investment  objective  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 
cash  availability  and 
comparisons  with  previous 
requirements  and  a  breakdown  of  shareholdings  by  listing  and 
sector.    The  Board  takes  account  of  Corporate  Governance  best 
practice. 

years, 

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 
Mr.  N  F  Ashton  is  independent  and  considers  himself  to  have 
sufficient time to commit to the Company’s affairs.  

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

16 | Athelney Trust plc | Annual Report 2021 

Remuneration Committee 
During the year the Remuneration Committee comprised Simon 
Moore and Frank Ashton.  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. 
the 
remuneration  arrangements  can  be  found  in  the  Directors’ 
remuneration  report  on  pages  22  to  24  and  in  note  4  to  the 
financial statements. 

information  on 

  Detailed 

Company Secretary 
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. 

Professional 

Independent 
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.  

Advice 

and 

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 Simon Moore 
and Frank Ashton. 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.  

Corporate Governance Statement 
Continued 

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. 

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

Matter 

Action 

COVID-19 pandemic 
The COVID-19 pandemic has adversely affected the global 
economy and this, in turn still, may impact on the valuation of 
investee companies and their ability to pay dividends. 
Key service providers could experience high levels of staff 
illness which may interrupt services. 

The Fund manager and the Administrator monitor the dividend 
situation monthly and make the Board aware of cancelled, 
postponed dividends as soon as they become aware. 

The Board have checked with key service providers the steps they 
have taken to protect their employees and procedures they have 
in place for a continuity of service. 

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 AQSE, 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 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 rules concerning the appointment and replacement of
in  the  Company’s  Articles  of
Directors  are  contained 
Association and are discussed on page 19.

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

• 

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. 

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 2021. 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 
issued  an 
internal  control  weaknesses.  Hazlewoods  LLP 
unqualified audit report which is included on pages 25 to 28. 

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 19 and 20.

Details of the substantial shareholders in the Company are
listed on page 19.

17 | Athelney Trust plc | Annual Report 2021 

Corporate Governance Statement 
Continued

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 
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.  Due  to 
COVID-19 the AGM on the 31 March 2021 was held behind closed 
doors with no shareholders in physical attendance. All resolutions 
proposed at the AGM were unanimously passed. 

The notice and further details of the Annual General Meeting, to be 
held  on  5  April  2022  at  12.00  noon,  is  published  in  a  separate 
notification.  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. 

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 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  authorization  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 
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. 

issued  to  Directors  of 

On behalf of the Board 

•  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;

Dr Manny Pohl AM 
Managing Director 
23 February 2022 

18 | Athelney Trust plc | Annual Report 2021 

Report of the Directors

The  Directors  present  their  report  and  audited 
financial 
statements of the Company for the year ended 31 December 2021. 
This  report  also  contains  certain 
in 
accordance with S992 of the Companies Act 2006. 

information  required 

Results and Dividends 
The return on ordinary revenue activities before dividends for the 
year is £151,260 (2020: £127,275) as detailed on page 29. 

The company paid an interim dividend of 2.0p per ordinary share 
on the 24 September 2021. 

It is recommended that a final dividend of 7.5p per ordinary share 
be paid. This will increase the total dividend paid this year to 9.5p 
(2020: 9.4p) per ordinary share. 

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 
2020.  The  Directors  are  of  the  opinion  that  the  Company  has 
conducted its affairs for the year ended 31 December 2021 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 pages 2 and 
3. 

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. Simon Moore and Manny Pohl will 
retire at the 2022 AGM and will offer themselves 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. 

19 | Athelney Trust plc | Annual Report 2021 

Capital Structure 
At 31 December 2021 the Company’s capital structure consisted of 
2,157,881  Ordinary  Shares  of  25p  each  (2020:  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  is  stated  on  page  24  in  the  Directors’  Remuneration 
Report. 

Dr E. C. Pohl AM 

(Managing Director)  

N. Ashton

S. Moore 

(Chairman) 

(Non-Executive Director) 

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.  

J C Pohl 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 C Pohl was not 
required to act as his alternate. 

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

Ordinary Shares 

E C Pohl & Co Pty Ltd  

IP Worldwide Flexible Fund 

Astuce Group 

Mehr Mutual 

Mr GW & Mrs DJ Whicheloe 

Mrs E Davison 

Mr C Frostick 

Mr S Moore 

P Grodzinski 

496,000 

339,054 

140,000 

105,818 

  81,500 

  75,000 

  70,500 

  67,500 

  65,000 

% of 

Issue 

22.9 

15.7 

  6.5 

  4.9 

  3.8 

  3.5 

  3.3 

  3.1 

  3.0 

Out of the nine major shareholders listed above three were under 
the  direct  control  of  two  of  the  Directors  during  the  year.  The 
remaining  six  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. 

On  12  January  2022  E  C  Pohl  & Co  Pty Ltd  sold  410,000  shares  to 
Astuce Group. Manny Pohl is a Director of E C Pohl & Co Pty Ltd and 
Astuce Group. No other major sharehold(cid:286)(cid:396)(cid:3)(cid:410)(cid:396)(cid:258)(cid:374)(cid:400)(cid:258)(cid:272)(cid:410)(cid:349)(cid:381)(cid:374)(cid:400) took place 
up until 14 February 2022. 

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  13  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 AQSE. 

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. 

20 | Athelney Trust plc | Annual Report 2021 

Viability Statement 
The Directors have assessed the prospects of the Company for a period 
of  three  years.  The  Board  believes  this  time  period  is  appropriate 
having  consideration 
for  the  Company’s  principal  risks  and 
uncertainties  (outlined  on  pages  13  and  14),  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. 

instruments  comprise 

Financial Instruments 
The  Company’s  financial 
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. 

its 

Annual General Meeting 
The  Notice  of  Annual  General  Meeting  is  published  in  a  separate 
notification. 

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. 

On behalf of the Board 

Dr Manny Pohl AM 
Managing Director 
23 February 2022 

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 
(United  Kingdom  Generally 
Kingdom  Accounting  Standards 
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: 

• 

• 

• 

in  accordance  with  UK 
the  Financial  Statements,  prepared 
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 http://www.athelneytrust.co.uk 

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

On behalf of the Board 

Dr Manny Pohl AM 
Managing Director 
23 February 2022 

21 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  Auditor’s  opinion  is  included  in  their 
report on pages 25 to 28. 

Remuneration Committee 
The  Company  had  a  Remuneration  Committee  during  the  year 
comprising Simon Moore and Frank Ashton. 

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 2021. 

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 2022 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 of 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  has  been 
fixed at 0.75% of the portfolio value. 

The policy was last approved by Shareholders at the Annual General 
Meeting  on  30  March  2021  and  will  remain  valid  until  the  Annual 
General Meeting in 2023. 

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. 

Company Performance 
The graph below compares capital growth, for the ten financial years 
ended 31 December 2021, 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. 

22 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
        
 
 
 
 
 
 
 
 
 
 
 
 
Directors’ Remuneration Report 
Continued

Capital Growth
(re-based to 100 at 31/12/2011)

300

250

200

150

100

50

0

2011

2012

2013

ATY NAV

2014
FTSE100

2015

2016

FTSE 250

2017
FTSE Small Cap

2018

2019
AIM All Share

2020

2021

ATY NAV

FTSE 100

FTSE 250

FTSE Small Cap

AIM All Share

2012
21.1%
5.8%
22.5%
46.1%
37.4%

2014
2013
4.0%
47.0%
-2.7%
14.4%
0.9%
28.8%
4.2% -24.0%
17.9% -31.4%

2015
7.5%
-4.9%
8.4%
7.8%
27.5%

2016
2.5%
14.4%
3.7%
4.5%
8.6%

2017

2018
13.4% -20.7%
7.6% -12.5%
14.7% -15.6%
3.6% -23.8%
8.8% -34.2%

2020
2019
18.2%
-4.4%
12.1% -14.3%
-6.4%
25.0%
4.4%
31.2%
20.7%
36.4%

2021
21.5%
14.6%
14.3%
20.0%
5.2%

Expected 
Fees for the 
Year to 31 
December 
2022 

10,500 
46,000 
10,500 

Fees for 
Year to 31 
December 
2021 

10,500 
44,877 
10,500 

Chairman basic 
Fund Manager 
Non-Executive 

No expenses were claimed by any Directors during this year. 

Past performance is no guarantee of future performance.

Directors’ Remuneration for the Year (audited) 
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  -  Managing Director 

                      -  Fund Manager 
S Moore (Non-executive) 
F Ashton (Chairman) 

D Lawman (Non-executive) 
Directors expenses 

2021 
£ 
- 

44,877 
10,500 
10,500 

- 
- 

2020 
£ 
- 

37,807 
10,500 
10,500 

2,625 
- 

65,877 

61,432 

The Directors’ remuneration for the year of £65,877 which is up 
by 7.2% on 2020 and is before the proposed final dividend of 7.5p 
increasing the total dividend for the year to 9.5p  (2020: 9.4p) per 
ordinary  share,  and  as  compared  to  total  dividends  paid  in  the 
year  at  9.7p  per  share  amounting  to  £202,840  (£200,683).  The 
remuneration  increase  is  due  to  the  increase  in  the  portfolio 
value during the year on which the Fund Manager’s fee is based. 

23 | Athelney Trust plc | Annual Report 2021 

 
      
 
 
 
  
 
  
 
 
 
 
 
 
 
 
Directors’ Remuneration Report
Continued 

Relative importance of spend on pay 

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

2021 
44,877 

2020 
37,807 

% Change 
19% 

21,000 

23,625 

-11% 

65,877 

61,432 

8% 

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: 

The Directors’ Remuneration Report for the year ended 31 December 
2020 was approved by shareholders at the Annual General Meeting 
held on 30 March 2021. The votes cast by proxy were as follows: 
% of  
votes 

Number of  
Votes 

For 
Against 
Total votes cast 
Number of votes withheld 

776,234 
Nil 
776,234 
Nil 

36 
- 
36 
-

Approval 
The Directors’ Remuneration Report was approved by the Board 
on 23 February 2022. 

31 
December 
2021 
(or date of 
Resignation 
If earlier) 

    31 
    December 
              2020 
    (or date of 
appointment 
  if later) 

-¹ 
67,500 
2,234 

           -¹ 
  67,500 
    2,234 

Dr Manny Pohl AM 
Managing Director 

Dr E. C. Pohl 
S. Moore 
F. Ashton 

Notes: 

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  496,000  (2020:  394,000),  Global  Masters 
Fund  Limited  holds  nil  (2020:  102,000)  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 and this 
has remained during 2020 and 2021 due to the top 5 shareholders 
owning  more  than  50%  of  the  total  shares  in  the  company.  The 
Company  holds 
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. 

its 

. 

24 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021, 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 
law  and  United  Kingdom  Accounting 
preparation 
Standards,  including  Financial  Reporting  Standard  102  The  Financial 
Reporting  Standard  applicable  in  the  UK  and  Republic  of  Ireland 
(United Kingdom Generally Accepted Accounting Practice).  

is  applicable 

 In our opinion the financial statements:  

(cid:120)  give a true and fair view of the state of the Company’s affairs as 
at  31  December  2021  and  of  its  net  return  for  the  year  then 
ended;  

(cid:120)  have  been  properly  prepared 

in  accordance  with  United 

Kingdom Generally Accepted Accounting Practice;  

(cid:120)  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. 

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. 

Conclusions relating to going concern  
In  auditing  the  financial  statements,  we  have  concluded  that  the 
director's  use  of  the  going  concern  basis  of  accounting  in  the 
preparation of the financial statements is appropriate.  

25 | Athelney Trust plc | Annual Report 2021 

In  making  this  assessment  we  have  considered  the  directors’ 
procedures  for  overseeing  the  activities  of  the  company  and 
reviewing  its  results  and  forecasts.    The  application  of  those 
procedures has been supported by us reviewing Board minutes and 
other  accessible  documentation  which  confirm  that  the  directors 
regularly benchmark key performance indicators which include but 
is not restricted to, comparing performance against the FTSE Small 
Cap,  FTSE  250  and  FTSE  100  markets,  frequent  monitoring  of 
available funds, anticipated cash outflows and financial headroom.  

In conjunction with the evaluation of management’s assessment of 
going  concern,  we  have  observed  that  resources  are  carefully 
planned  and  managed  with  the  intention  of  ensuring  that  the 
company has sufficient resources available and accessible to ensure 
that  the  company’  commitments  and  obligations  are  capable  of 
being met as they fall due.   

In  relation  to  the  entity’s  reporting  on  how  it  has  applied  the  UK 
Corporate  Governance  Code,  we  have  nothing  material  to  add  or 
draw  attention  to  in  relation  to  the  directors’  statement  in  the 
financial  statements  about  whether  the  director’s  considered  it 
appropriate to adopt the going concern basis of accounting. 

Our  responsibilities  and  the  responsibilities  of  the  directors  with 
respect  to  going  concern  are  described  in  the  relevant  sections  of 
this report.  

Our approach to the audit 
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 the risk of management override of 
controls are always deemed risks in any audit.  This is not a complete 
list of all risks identified by our audit.  

VValuation, 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.  

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

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  custodian  confirmations,  we  have  only  checked  to 
custodian confirmations.  

AAllocation 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  nine 
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  preparation  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  
There is always a presumed risk that revenue may be misstated due to 
the improper and/or incomplete 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;  checking  on  a  sample  basis 
income 
transactions by comparing dividends during the year obtained from an 
independent source with those recognised by the Company; checking 
on  a  sample  basis  gains  and  losses  on  investments  to  third  party 
contracts;  and  checking  transactions  close  to  the  financial  year  end 
date on a sample basis, to ensure that they have been allocated to the 
correct accounting period. 

Investment trust status  
In order to maintain its status as a tax exempt investment trust certain 
criteria must be fulfilled. These requirements include a 15% limit on 
retention  of  income  after  dividends  and  revenue  expenses  and  a 
minimum  of  35%  of  the  Company’s  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 shares were not held by related parties; 
and  obtaining  an  Audit  Representation  Letter  from  the  Company's 
Directors confirming that they complied with the applicable rules. 

26 | Athelney Trust plc | Annual Report 2021 

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  £134,000,  which  is  2%  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  £38,000,  which  is  25%  of  the 
Company’s  net  revenue  return  on  ordinary  activities  before 
taxation.  

Other information  
The Directors are responsible for the other information contained 
within  the  annual  report.  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:  

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

(cid:120) Fair,  balanced  and  understandable,  set  out  on  page  12  –  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   

(cid:120) Audit  committee  reporting,  set  out  on  pages  16  to  17  –  the 
section  describing  the  work  of  the  audit  committee  does  not 
appropriately  address  matters  communicated  by  us  to  the  audit 
committee; or   

(cid:120) Directors’  statement  of  compliance  with  the  UK  Corporate 
Governance Code, set out on page 15 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:  

(cid:120) 

(cid:120) 

(cid:120) 

(cid:120) 

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 in:   

27 | Athelney Trust plc | Annual Report 2021 

(cid:120) 

(cid:120) 

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:  

(cid:120)  adequate accounting records have not been kept, or returns 
adequate for our audit have not been received from branches 
not visited by us; or  
the  financial  statements  and  the  part  of  the  Directors’ 
Remuneration Report to be audited are not in agreement with 
the accounting records and returns; or  

(cid:120) 

(cid:120)  certain disclosures of Directors’ remuneration specified by law 

are not made; or  

(cid:120)  we have not received all the information and explanations we 

require for our audit; or   

(cid:120)  a corporate governance statement has not been prepared by 

the Company.  

Corporate governance statement 
The Listing Rules require us to review the directors' statement in 
relation to going concern, longer-term viability and that part of the 
Corporate  Governance  Statement  relating  to  the  entity's 
compliance with the provisions of the UK Corporate Governance 
Statement specified for our review.  

Based  on  the  work  undertaken  as  part  of  our  audit,  we  have 
concluded  that  each  of  the  following  elements  of  the  Corporate 
Governance Statement is materially consistent with the financial 
statements or our knowledge obtained during the audit:  

(cid:120) 

(cid:120) 

(cid:120) 

the disclosures in the annual report set out on pages 13 to 14 
that describe the principal risks and explain how they are being 
managed or mitigated;   
the Directors’ confirmation set out on page 13 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  20  in  the  financial 
statements  about  whether  the  Directors  considered 
it 
appropriate to adopt the going concern basis of accounting in 
financial  statements  and  the  Directors’ 
preparing  the 
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;    

(cid:120)  whether  the  Directors’  statement  relating  to  going  concern 
required under the Listing Rules in accordance with Listing Rule 
9.8.6R(3) 
inconsistent  with  our  knowledge 
obtained in the audit; or    

is  materially 

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

(cid:120)

the Directors’ explanation set out on page 20 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.

Responsibilities of Directors 
As explained more fully in the Statement of Directors' responsibilities 
(set out on page 20), 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.  

Irregularities,  including  fraud,  are  instances  of  non-compliance  with 
laws  and  regulations.  We  design  procedures  in  line  with  our 
responsibilities, outlined above,  to detect material misstatements in 
respect of irregularities, including fraud.  

The audit evidence available in relation to the investment portfolio 
and associated returns are publicly available and considered to be 
strong  sources  of  audit  evidence.    Ownership  has  been  verified 
against custodian documentation and confirmations. 

The nature of the company’s activities means that overheads are 
generally  consistent  and  predictable  and  where  unexpected 
variances occur, adequate evidence is available. 

Our audit work, which utilises the above audit evidence along with 
the audit procedures outlined in our description of our approach 
to the audit above, provides us with a reasonable assurance that 
our audit procedures will detect irregularities, including fraud. 

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/auditorsresposibilities. 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 auditor’s report and for no other purpose. To the fullest 
extent  permitted  by 
law.  We  do  not  accept  or  assume 
responsibility  to  anyone  other  than  the  Company  and  the 
Company’s members as a body, for our audit work, for this report, 
or for the opinions we have formed.  

Ryan Hancock FCCA (Senior Statutory Auditor) 
for and on behalf of Hazlewoods LLP  
Statutory Auditor, Cheltenham.  

23 February 2022 

28 | Athelney Trust plc | Annual Report 2021 

Income Statement 
For the Year Ended 31 December 2021 

Note 

 Revenue 

                    2021 
      Total 

Capital  

 Revenue 

 Capital 

           2020 
   Total 

Gains/(losses) on 
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 

 £ 

 £ 

      £ 

- 

1,359,219 

1,359,219 

£ 

- 

 £ 

     £ 

(30,695) 

(30,695) 

186,393 

- 

186,393 

160,876 

- 

160,876 

(4,488) 

(40,692) 

(45,180) 

(3,781) 

(34,221) 

(38,002) 

(30,645) 

(72,964) 

(103,609) 

(29,820) 

(75,688) 

(105,508) 

151,260 

1,245,563 

1,396,823 

127,275 

(140,604) 

(13,329) 

- 

- 

- 

- 

- 

- 

151,260 

1,245,563 

1,396,823 

127,275 

(140,604) 

(13,329) 

7.0p 

57.7p 

64.7p 

5.9p 

(6.5p) 

(0.6p) 

9.7p 

11p 

All revenue and capital items in the above statement derive from continuing operations. 

No operations were acquired or discontinued during the year. 

The total column of this statement is the Statement of Total Comprehensive Income of the Company prepared in accordance with 
applicable  Financial  Reporting  Standards  (“FRS”).  The  supplementary  revenue  return  and  capital  return  columns  are  prepared  in 
accordance  with  the  Statement  of  Recommended  Practice  (“AIC  SORP”)  issued  in  April  2021  by  the  Association  of  Investment 
Companies. 

The notes on pages 33 to 37 form part of these financial statements. 

29 | Athelney Trust plc | Annual Report 2021 

 
 
               
                
 
                                       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Statement of Changes in Equity  
For the Year Ended 31 December 2021 

Called-up 
Share 
Capital 
£ 

Share 
Premium 
£ 

Capital 
reserve 
realised 
£ 

Capital 
reserve 
unrealised 
£ 

Revenue 
reserve 
£ 

Total 
Shareholders’ 
Funds 
£ 

539,470 

881,087 

1,916,502 

1,982,060 

439,598 

5,758,717 

- 

- 

- 
- 
- 

- 

- 

- 
- 
- 

223,957 

- 

- 

(254,652) 

- 

- 

(109,909) 
- 
- 

- 
- 
- 

- 
127,275 
(237,367) 

223,957 

(254,652) 

(109,909) 
127,275 
(237,367) 

539,470 

881,087 

2,030,550 

1,727,408 

329,506 

5,508,021 

539,470 

881,087 

2,030,550 

1,727,408 

329,506 

5,508,021 

- 

- 

- 
- 
- 

- 

- 

- 
- 
- 

354,843 

- 

- 

1,004,376 

- 

- 

(113,656) 
- 
- 

- 
- 
- 

- 
151,260 
(209,314) 

354,843 

1,004,376 

(113,656) 
151,260 
(209,314) 

539,470 

881,087 

2,271,737 

2,731,784 

271,452 

6,695,530 

Balance brought forward at 
1 January 2020 
Net profits on realization 
   of investments 
Decrease in unrealized 
   Appreciation 
Expenses allocated to  
   Capital 
Profit for the year 
Dividend paid in year 

Shareholders’ Funds at 31 
December 2020 

Balance brought forward at 
1 January 2021 
Net profits on realization 
   of investments 
Increase in unrealized 
   Appreciation 
Expenses allocated to  
   Capital 
Profit for the year 
Dividend paid in year 

Shareholders’ Funds at 31 
December 2021 

  The notes on pages 33 to 37 form part of these financial statements. 

30 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Statement of Financial  Position 
As at 31 December  2021 

Company Number: 02933559 

                                                                       Note   

Fixed assets 
Investments held at fair value through profit and 
loss 

Current assets 
Debtors
Cash at bank and in hand 

8 

9 

2021 

£ 

2020 

             £ 

6,436,820 

5,310,661 

245,163 
30,676 
275,839 

Creditors: amounts falling due within one year 

10 

(17,129) 

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 

258,710 

6,695,530 

6,695,530 

539,470 
881,087 

2,271,737 
2,731,784 
271,452 

6,695,530 

Net Asset Value per share 

13 

310.3p 

142,136 
72,601 
214,737 

(17,377) 

197,360 

5,508,021 

5,508,021 

539,470 
881,087 

2,030,550 
1,727,408 
329,506 

5,508,021 

255.3p 

These financial statements were approved and authorised for issue by the Board of Directors on 23 February 2022 and signed on their 
behalf by 

Dr Manny Pohl AM 
Managing Director 

The notes on pages 33 to 37 form part of these financial statements. 

31 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
  
 
  
 
 
 
 
 
 
Statement of Cash Flows 
For the Year Ended 31 December 2021 

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

Cash (used)/generated from operations 

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

Equity dividends paid 

Net decrease in cash 

Cash at the beginning of the year 

Cash at the end of the year 

2021 
     £ 

151,260 

(113,656) 
(248) 
(103,027) 

(65,671) 

(545,379) 
778,439 
233,060 

(209,314) 

(41,925) 

72,601 

30,676 

2020 

      £ 

127,275 

(109,909) 
(4,732) 
81,597 

94,231 

(1,137,856) 
1,262,691 
124,835 

(237,367) 

(18,301) 

90,902 

72,601 

As the company does 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 33 to 37 form part of these financial statements.

32 | Athelney Trust plc | Annual Report 2021 

 
  
 
 
 
 
 
            
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
      
 
 
Notes to the Financial Statements 
For the Year Ended 31 December 2021

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 April 2021, 
regarding the Financial Statements of Investment Trust Companies 
and  Venture  Capital  Trusts.  All  the  Company’s  activities  are 
continuing. 

The  presentation  currency  of  the  financial  statements  is  pounds 
sterling,  being  the  functional  currency  of  the  primary  economic 
environment in which the company operates. Monetary amounts in 
these financial statements are rounded to the nearest pound. 

1.2 Income 

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

1.3 Investment Management Expenses 

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

1.4 Other Expenses 

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

1.5 Investments 

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

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. 

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.        

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

1.11   Share Issue Expenses  

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  

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. 

33 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
Notes to the Financial Statements 
For the Year Ended 31 December 2021 (continued)

2. Income 
Income from investments 

UK dividend income 
Foreign dividend income 
UK Property REITs 
Bank interest 
Total income 

UK dividend income 

UK Main Market listed investments 
UK AIM-traded shares 

2021 
£ 
117,516 
11,752 
57,078 
47 
186,393 

2020 
£ 
95,482 
17,834 
47,480 
        80 
160,876 

2021 
£ 

2020 
£ 

74,755 
42,741 

65,476 
  30,006 

117,496 

95,482 

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 
Auditor’s 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 

2021 
£ 

2020 
£ 

21,000 
44,877 

23,625 
37,807 

11,964 

9,250 

- 
32,472 
4,101 
10,020 
23.215 

       - 
32,472 
2,310 
11,540 
24,044 

1,140 
148,789 

2,460 
143,508 

4. Employees and Directors’ Remuneration 

Costs in respect of Directors: 
Non-executive Directors’ fees 
Wages and salaries 

2021 
£ 

21,000 
44,877 
65,877 

2020 
£ 

23,625 
37,807 
61,432 

Average number of employees: 

Chairman 
Investment 
Administration 

- 
1 
- 
1 

- 
1 
- 
1 

5. Taxation 
(i)  On the basis of these financial statements no provision has been 
made for corporation tax (2020: Nil). 

(ii) Factors affecting the tax charge for the year. 

The tax charge for the period is lower than (2020: higher than) the 
average small company rate of corporation tax in the UK of 19 per 
cent.   The differences are explained below: 

Total  return  on  ordinary  activities 
before tax 

Total  return  on  ordinary  activities 
multiplied  by  the  average  small 
company rate of corporation tax 19% 
(2020: 19%) 
Effects of: 
UK dividend income not taxable 
Revaluation of shares not taxable 
Capital gains not taxable 
Unrelieved management expenses 

2021 
£ 
1,396,823 

2020 
  £ 
(13,329) 

265,396 

(2,532) 

(22,328) 
(190,831) 
(67,420) 
15,183 

(18,142) 
48,384 
(42,552) 
14,842 

Current tax charge for the year 

- 

- 

The  Company  has  unrelieved  excess  revenue  management 
expenses of £595,482 at 31 December 2021 (2020: £401,358) and 
£102,597  (2020:  £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  2020,  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  2020.    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. 

34 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Financial Statements 
For the Year Ended 31 December 2021 (continued)

6. Return per Ordinary Share 
The  calculation  of  earnings  per  share  has  been  performed  in 
accordance with FRS 102. 

£ 
Revenue 
151,260 

2021 

£ 
Capital 
1,245,563 

2,157,881 

£ 
Total 
1,396,823 

7.0p 

57.7p 

64.7p 

£ 
Revenue 
127,275 

2020 

£ 
Capital 
(140,604) 

2,157,881 

£ 
Total 
(13,329) 

5.9p 

(6.5p) 

(0.6p) 

Attributable return on 
ordinary activities after 
taxation 
Weighted average 
number of shares 
Return per ordinary 
share 

Attributable return on 
ordinary activities after 
taxation 
Weighted average 
number of shares 
Return per ordinary 
share 

7. Dividend 

2021 
£ 
166,157   

2020 
£ 
200,683 

Final dividend in respect of 2020 of 
7.7p (2020: a final dividend of 9.3p 
was paid in respect of 2019) per 
share 

Interim dividend in respect of 2021 
of  2.0p  (2020:  an  interim  dividend 
of 1.7p was paid in respect of 2020) 
per share 

209,314 

196,367 

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  7.5p  (2020:  7.7p)  per 
ordinary share be paid out of revenue profits amounting to a total of 
£161,841. An interim dividend of 2p per ordinary share was paid on 24 
September  2021  amounting  to  £43,157  making  the  total  dividend 
payable in the year £204,998. 

  Summary of dividends paid for the last 10 financial years 

Ex-div date 

10/3/2022 
09/9/2021 
11/3/2021 
10/9/2020 
19/3/2020 
20/3/2019 
01/3/2018 
09/3/2017 
17/3/2016 
19/3/2015 
19/3/2014 
20/3/2013 
21/3/2012 

Dividend 
Type 
Proposed 
Interim 
Final 
Interim 
Final 
Final 
Final 
Final 
Final 
Final 
Final 
Final 
Final 

Amount 

7.5p 
2.0p 
7.7p 
1.7p 
9.3p 
9.1p 
8.9p 
8.6p 
7.9p 
6.7p 
5.5p 
5.0p 
4.95p 

Financial 
Year 
2021 
2021 
2020 
2020 
2019 
2018 
2017 
2016 
2015 
2014 
2013 
2012 
2011 

for 

available 

Revenue 
distribution 
Interim dividend paid 
Final  dividend  in  respect  of 
financial  year  ended  31 
December 2021 

2021 
£ 
151,260 

2020 
£ 
127,275 

(43,157) 

(36,684) 

(161,841) 

(166,157) 

Undistributed 
reserves 

revenue 

(53,738) 

(75,566) 

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 

2021 
£ 
5,310,661 

545,379 
(778,439) 
354,843 
1,004,376 

2020 
£ 
5,466,191 

1,137,856 
(1,262,691) 
223,957 
(254,652) 

6,436,820 

5,310,661 

3,705,034 
2,731,786 

3,583,255 
1,727,406 

6,436,820 

5,310,661 

 8. Investments 

43,157 

36,684 

Movements in year 

For the year 2020, a final dividend of 7.7p was paid on 6 April 2021 
amounting  to  a  total  of  £166,157.  An  interim  dividend  of  1.7p  per 
ordinary share was paid on 24 September 2020 amounting to £36,684 
making the total dividend paid in the year £202,841. 

UK  Main  Market 
investments 
UK AIM-traded shares 

listed 

5,014,560 

3,791,591 

1,422,260 

1,519,070 

6,436,820 

5,310,661 

35 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Financial Statements 
For the Year Ended 31 December 2021 (continued)

Gains on investments 

Realised gains on sales 
Increase/(decrease) 
appreciation 

in 

unrealised 

2021 
£ 
354,843 
1,004,376 

2020 
£ 
223,957 
(254,652) 

1,359,219 

(30,695) 

The purchase costs and sales proceeds above include transaction costs 
of £3,515 (2020: £7,910) and £3,302 (2020: £5,056) respectively. 

9. Debtors 

Investment transaction debtors 
Other debtors 

2021 
£ 
236,912 
8,251 

245,163 

2020 
£ 
133,210 
8,926 

142,136 

10. Creditors: amounts falling due within one 
year 

Social security and other taxes 
Other creditors 
Accruals and deferred income 

2021 
£ 
719 
2,850 
13,560 
17,129 

2020 
£ 
- 
2,850 
14,527 
17,377 

11. Called Up Share Capital 

Authorised  
10,000,000 Ordinary Shares of 25p 

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

2021
£

2020
£

2,500,0000

2,500,000 

539,470

539,470

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. 

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 2021 would have decreased net assets attributable 
shareholders by 60 pence per share (2020: 49 pence per share). 
An increase of the same percentage would have an equal but 
opposite effect on net assets available to shareholders. 

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. 

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

• to ensure the Company’s ability to continue as a going 

concern;  

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.  

• to provide an adequate return to shareholders;  

• to support the Company’s stability and growth;  

• to  provide  capital 

for  the  purpose  of 

further 

investments.  

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. 

36 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Financial Statements 
For the Year Ended 31 December 2021 (continued) 

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. 

Fair value through profit or loss 
investments 

2021 
£ 
6,436,820 

2020 
£ 
5,310,661 

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

31 December 2021 

At 
Amortised 
Cost 

£ 

Assets at 
fair value 
through 
profit or 
loss 
£ 

Total 

£ 

- 
245,163 
30,676 

6,436,820 
- 
- 

6,436,820 
245,163 
30,676 

Assets  as  per  balance 
sheet 
Investments 
Debtors 
Cash at bank 

Total 

275,839 

6,436,820 

6,712,659 

Liabilities as per the 
balance sheet 
Creditors 

Total 

31 December 2020 

Assets  as  per 
balance sheet 
Investments 
Debtors 
Cash at bank 

17,129 

17,129 

- 

- 

At Amortised 
Cost 

£ 

Assets at 
fair value 
through 
profit or 
loss 
£ 

17,129 

17,129 

Total 

£ 

- 
142,136 
72,601 

5,310,661 
- 
- 

5,310,661 
142,136 
72,601 

Total 

214,737 

5,310,661 

5,525,398 

Liabilities as per 
the balance 
sheet 
Creditors 

Total 

17,377 

17,377 

- 

- 

17,377 

17,377 

37 | Athelney Trust plc | Annual Report 2021 

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  (2020: 
classification A investments only). 

13. Net Asset Value per Share 
The net asset value per share is based on net assets of 
£6,695,530 (2020: £5,508,021) divided by 2,157,881 (2020: 
2,157,881) ordinary shares in issue at the year end. 

Net asset value per 
share 

2021 
£ 
310.3p 

2020 
£ 
255.3p 

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: 

Dr Manny Pohl AM 
Simon Moore 
Frank Ashton 

Notes: 

£48,112¹ 
£  6,548 
£     217 

1.  Manny Pohl’s relationship with Global Masters Fund 
Limited  is  described  in  Note  1  to  the  table  of 
Directors’  interests  on  page  25.  During  the  year 
dividends amounting to £48,112 were paid to Global 
Masters Fund Limited and EC Pohl & Co Pty Ltd. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Officers and Financial Advisors 

Directors: 

Secretary:  

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

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

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

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

Registered Office:  Waterside Court  

Falmouth Road  
Penryn  
Cornwall, TR10 8AW 

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

Company Number:  02933559  

(Incorporated and registered in England) 

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

Email: mail@jamessharp.co.uk 
Tel: 0161 764 4043 

Email: ryan.hancock@hazlewoods.co.uk 
Tel: 01242 680 000 

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

Solicitor: 

Druces LLP 
Salisbury House 
London Wall 
London 
EC2M 5PS 

James Sharp & Co  

Stockbroker: 
                                       5 Bank Street 
                                       Bury 
                                       Lancashire, BL9 0DN 

Auditors: 

Banker: 

Registrar: 

Hazlewoods  LLP 
Staverton Court  
Staverton 
GL51 0UX 

HSBC Bank Plc 
Market Street 
Falmouth 
Cornwall, TR11 3AA 

Share Registrars Limited  
3 Millennium Centre 
Crosby Way 
Farnham 
Surrey, GU9 7XX

38 | Athelney Trust plc | Annual Report 2021 

 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
    
 
 
   
 
   
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
Company number 
02933559 

Athelney Trust 
Waterside Court, Falmouth Road 
Penryn, Cornwall TR10 8AW 

athelneytrust.co.uk 

39 | Athelney Trust plc | Annual Report 2021