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Athelney Trust Plc
Annual Report 2022

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FY2022 Annual Report · Athelney Trust Plc
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Annual Report 2022

DISCOVERING POTENTIAL

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                                        11 

Portfolio Breakdown by Sector and by Index                     12 

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 

13 

14 

16 

20 

22 

23 

26 

30 

31 

32 

33 

34 

39 

Contents 

Annual Report for the year ended  

31 December 2022 

Company number 
02933559 

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

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

The  assets  of  the Trust  are allocated  predominantly  to companies with  either  a  full 
Investment Policy 
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 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Directors of the  Company 

Frank Ashton 
Non-Executive Chairman 

Dr Emmanuel Clive Pohl AM 

Managing Director 

Frank  Ashton,  aged  61,  is  a  highly  experienced  senior 
manager  and  independent  management  consultant.  After 
leaving Cambridge University with a Natural Sciences degree 
(Metallurgy  &  Materials  Science),  he  spent  much  of  his 
career  providing 
independent  management  advice  to 
companies in a wide variety of sectors. With 15 years spent 
at  PricewaterhouseCoopers  and  KPMG  (Operational  Due 
Diligence)  and  5  years  working  in  Strategy  and  M&A  for 
Cummins  Inc,  he  has  a  proven  track  record  in  shareholder 
value  creation  and  governance,  in  providing  strategic  and 
operational advice to both public and private companies in 
Europe  and  USA,  as  well  as  working  at  a  policy  level  for 
Government entities. 

Manny Pohl, aged 69, is the Chairman and CIO 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 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Continued 
Directors of the  Company 

Simon Moore 
Non-executive Director 

Simon  Moore,  aged  62,  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  has been  a  long-standing  member  of  two 
important  committees  at  the  Association  of  Investment 
Companies:  the  Statistics  committee  and  the  Property  and 
Infrastructure Forum. In 2013 and 2014 Simon was chosen as 
one of the Citywire Wealth Manager Top 100 most influential 
people in UK private client fund selection. Simon is a scientist 
by training and has worked at two start up UK biotechnology 
companies, before passing on his knowledge and passion as 
a  science  tutor  for  the  Open  University.  He  has  a 
Biochemistry  BSc  from  Imperial  College,  and  an  MSc  in 
Computer Modelling of molecules from Birkbeck College. He 
is a member of the UK Society of Investment Professionals 
and  the  CFA  institute.  During  2020  he  was  appointed  as  a 
Non-Executive Director of Home REIT Plc. 

3 | Athelney Trust plc | Annual Report 2022 

 
 
 
Strategic Report 
  Dear Shareholder 
Chairman’s Statement and Business   Review 
I am pleased to present the Annual Financial Report for the year to 
31 December 2022. 

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

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

• 

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

Capital Gains 
During  the  year  the  Company  realised  capital  profits  before 
expenses  arising  on  the  sale  of  investments  in  the  sum  of 
£382,704 (2021: £354,843). 

Portfolio Review 
Additional Holdings Purchased 
Additional  holdings  of  AEW  UK,  Cerillion.  Close  Brothers, 
Fevertree,  Gamma,  Impax  Asset  Management,  Paypoint, 
Target Healthcare, Treatt  and Tritax Bigbox  were acquired. 

Holdings Sold or Trimmed 
Abcam,  Clinigen,  Forterra,  Homeserve,  Jarvis  Securities,  JD 
Sports, Lok’n Store  and LXI Reit. 

Dividend 
During  the  year  the  Company  paid  an  interim  dividend  of 
2.1p on 23 September 2022. 

The Board recommends a final dividend of 7.5p per ordinary 
share making an increased dividend this year of 9.6p (2021: 
9.5p).  Subject to shareholder approval at the Annual General 
Meeting  on 16  March  2023,  the  dividend  will  be  paid  on 6 
April 2023 to shareholders on the register on 10 March 2023. 

Period Review 
The  year  of  2022  was,  for  many,  including  the  investment 
community, one to forget.  Shocks and surprises marked the 
year,  which  ended  very  poorly  with  market  uncertainty  and 
loss  of  confidence  created  by  the  short-lived  Liz  Truss 
premiership,  made  worse  by  the  impact  of  double-digit  UK 
inflation.  

In  an  interview  with  the  BBC  in  2014,  Charlie  Munger, 
renowned partner in Berkshire Hathaway said: 

“Without  a  system  of  wise  restraints,  gross  immorality  and 
extreme  craziness  will  happen  in  markets.  They  need  to  be 
dampened.” 

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 
The key performance points are as follows: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

At 31 December 2022, audited Net Asset Value (NAV) was 
219.4  p  per  share  (2021:  310.3p),  a  decrease  of  29.3% 
over  the  year  as  compared  to  a  19.7%  decrease  in  the 
FTSE 250 and a 1% increase in the FTSE 100. 
The share price fell to 210.0p from 225.0p at 31 
December 2021 a negative return of 6.7%. 
The discount to NAV at the end of year had reduced to 
4.3% compared to 27.4% at 31 December 2021.  
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 minus 26.2% (2021:25.2%).  
The Trust’s performance over 12 months as measured by 
share price total return, which is the change in share price 
plus the dividend paid, was minus 3.3% (2021:8.2%)  
The 12-month revenue return per ordinary share was 6.9p 
(2021:7.0p), a decrease of 1%. 
The  interim  dividend  of  2.1p  per  share  was  paid  on  23 
September 2022. 
Your Board recommends a final dividend of 7.5p per share 
increasing  a  total  dividend  payable  for  the  year  to  9.6p 
(2021:  9.5p)  an  increase  of  1%.    UK  inflation  for  the  12 
months to December 2022 slowed for the second month 
in a row to 10.5% 
This  is  the  20th  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 promotes us to the “Dividend Heroes” list maintained 
by  the  AIC,  a  list  of  investment  companies  that  have 
consistently  increased  their  dividends  for  20  or  more 
years in a row. 

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. 

We  note  the  Financial  Conduct  Authority’s  Policy  Statement 
PS22/3  of  April  2022  to  comply  or  explain  in  relation  to  board 
inclusion,  with  changes  to  the  Listing  Rules 
diversity  and 
commencing in 2023 for the Trust.  As a small, low-cost fund, your 
board  continues  to  assess  how best  to  structure  and  plan  for  a 
board  that  meets  shareholder  and  regulatory  needs,  has 
continuity, stability and reflects prudent management of costs. 

4 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Strategic Report 
Chairman’s  Statement  and  Business  Review 
Continued
He was talking about some of the causes of the Crash and Global 
Financial  Crisis  in  2007-08,  but  this  is  also  true  elsewhere.    For 
in  a  powerful  political  and 
example,  a 
governmental  system  with  few  restraints  represents  a  risk:  
Ukraine’s  citizens,  and  to  a  lesser  extent  a  large  proportion  of 
Europe’s  population  are  paying  the  price  for  Putin’s  ‘grossly 
immoral’ and unfettered ambition to control that country. 

leader  operating 

29.45%)  compared  to  the  AIC  UK  Smaller  Companies  weighted 
average of 9.88%. 

This time last year I commented on Apple being the first stock to 
reach  $1  trillion  market  cap  on  4  January  2022,  after  tripling  the 
share price over the prior two years.  Well, in 2022 Apple lost a third 
of that value, beset with problems on iPhone 14 shipments due to 
COVID restrictions at its main Chinese factory, resulting in declining 
earnings and disappointing fourth quarter guidance. 

I mention such a large US stock in a UK small company fund report 
because this poor year, especially for Apple shareholders is a timely 
reminder;  we should be investing in good stocks and management 
teams  for  the  long  term  and  resist  perhaps  emotionally  driven 
reactions  to  news  or  poor  performance  over  a  relatively  short 
period  of  time.      Wars,  times  of  political  incompetence,  market 
corrections and yes, apparent evidence of fraud at ‘star companies’ 
(such as Sam Bankman-Fried’s crypto empire FTX) should really not 
surprise us much.  Human nature and systemic failings are hardly 
news. Temperament is much more important than intelligence for 
investors  (as  Messrs  Buffett  and  Munger  have  told  us  for  a  long 
time). 

While others run for safety, cool-headed investors look widely and 
carefully,  to  find  good  companies  with  shares  at  low  price-book 
ratios to invest in.  In his report below, Manny explains the care he 
takes to deliver income for investors, as well as investing for growth 
(which may take a little longer to realise at the moment, but it will 
come).  The coming year will be a time for patience and resisting 
temptation to run with the herd. 

At the start of the year we had hoped dividend income would return 
to pre-pandemic levels, but that evaporated in the second half as 
inflation and interest rates rocketed, reducing many UK companies’ 
margins and cash generated.  In the end net income was very similar 
to last year at £148,531 (2021: £151,260).  I remind you that as a 
closed-ended fund we can save up to 15% of our portfolio income 
each year, which, unlike open-ended funds, provides a reserve to 
use in those leaner income years. 

I  am  very  pleased  to  tell  you  that  the  Board  recommends  a  final 
dividend  payment  of  7.5p  (total  9.6p)  an  increase  of  0.01p 
(2021:9.5p).  Subject to shareholder approval at the AGM and based 
on our share price at 31 December 2022 of 210p this represents a 
dividend yield of 4.6% (2021: 3.1%) and is better than the AIC UK 
Smaller Companies’ weighted average yield of 2.80%. 

With this further year of progressive dividend payment (if approved 
at the AGM), I am delighted to say your company is promoted to the 
full  list  of  AIC  Dividend  Heroes,  as  this  would  represent  the  20th 
consecutive year of dividend growth.  In 2022 this list comprised just 
seventeen  investment  companies  (out  of  324  AIC  members),  and 
therefore  would  be  a  marvellous  company  milestone  since  its 
inception as a founder member of AIM in 1995, especially because 
this  has  been  delivered  from  the  UK  Smaller  Companies  segment 
only.   

A new prime minister, seemingly believing the only opinions on the 
September  mini-budget  that  mattered  were  her  own  and  her 
Chancellor’s,  was  swiftly  brought  low;  however  the  damage  had 
been done.  The mini-budget resulted in ‘craziness’ for a few weeks 
with  a  dramatic  loss  of  financial  market  confidence  in  the  UK 
resulting in the Bank of England being forced to stabilise the bond 
market by temporarily buying long-dated UK gilts. Enter Hunt and 
Sunak as new Chancellor and PM to try to return the narrative to 
calmer and more acceptable content and tones.  Now homeowners 
who have to start a new mortgage term face a dramatic rise in cost 
and many wish Truss and Kwarteng had used any ‘system of wise 
restraints’ before launching that particular mini-budget against the 
backdrop of a rising cost of living crisis. 

All these events had a heavy impact on the UK Smaller Companies 
segment,  the  focus  of  this  fund;  smaller  companies  can  be 
perceived to be a riskier investment because they tend to be less 
liquid  and  less  resilient  stocks  in  a  challenging  environment, 
compared  even  to  FTSE-250  companies.    Market  sentiment  has 
recently been strongly negative to this segment.  By comparison the 
blue-chip FTSE-100 fared better than most markets because these 
large ‘old-fashioned’, liquid, oil/gas- and commodity-based stocks 
were buoyed by the run from UK bonds, representing a safer haven 
than,  for  example  the  NASDAQ  where  Big  Tech  companies  had  a 
torrid 2022. 

investors 

in  us  by 

I am disappointed to report the poor absolute performance of the 
Company  in  the  past  12  months  and  comparatively  against  FTSE-
250 and especially FTSE-100 indices.  We are very aware of the trust 
in  the  company  and  take  our 
placed 
responsibilities  very  seriously.    However  a  better  comparison  is 
against UK Smaller Company investment fund peers, and our Share 
Price Total Return at minus 2.57% has performed much better over 
the  past  12  months  in  comparative  terms  than  the  segment 
weighted average of minus 23.52%.  Our NAV one year Total Return 
at  minus  23.64%  confirms  we  performed  similarly  to  investment 
funds  in  the  same  sector,  whose  weighted  average  return  was 
minus 22.32%.   

Further information on portfolio activity and the drivers behind the 
performance  is  contained  in  the  Managing  Director,  Dr  Manny 
Pohl’s  Report  below.    Manny  is  highly  experienced  at  managing 
funds in challenging market environments, and your board is very 
pleased  with  the  comparative  outcome  for  the  year,  given  the 
conditions faced.  Our invested companies perhaps have a vote of 
confidence  taken  as  a  portfolio,  given  that  the  share  price  was 
trading at year end at a slightly lower discount of 7.85% (2021:  

5 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
Continued

• How long will UK inflation remain above that of other countries in 
Europe,  and  what  interest  rate  medicine  will  be  needed  to  bring  it 
back in line (after reaching a peak of 11.7% in October, are we over 
the worst). This will affect our income 

• What costs, including those to settle public sector pay negotiations, 
will be incurred by the government, over what period of time, and is 
a  Labour  government  now  inevitable  in  2025;  this  affects  general 
sentiment on the economy, tax burden and confidence for investors, 
including inward investors 

•  What  global  assistance  or  headwind  for  UK  economic  recovery 
might be expected?  Potential global recession, no sight of an end to 
war  in  Ukraine,  the  rate  and  strength  of  recovery  for  China’s 
economy, and the apparent weakening of America’s economy, all play 
into the geo-political environment. 

We cannot know the answers to these questions; however, I do know 
that  Manny  Pohl’s  meticulous  and  repeatable  investment  and 
divestment  approach,  explained  in  his  report,  will  on  average,  find 
and capture value and that being invested for the long term, in those 
shares, is right also. 

I  would  encourage  you  to  actively  take  interest  in  your  company; 
perhaps come to meet the board at the AGM in central London on 
Thursday 16 March 2023 at 12 noon. 

Frank Ashton 
Non-Executive Chairman 
13 February 2023 

Strategic Report 
Chairman’s Statement and Business Review 

This is testament and credit to the current MD, Fund Manager and 
long-standing major shareholder and board member, Manny Pohl, 
and  his  predecessor,  Robin  Boyle  who  managed  the  fund  over 
many years, and also to other board members of Athelney Trust, 
including Simon Moore, well-known in the industry, supported by 
John Girdlestone, the immediate past CoSec, and ably succeeded 
by Debbie Warburton.  Thank you all. 

In terms of controllable costs, I confirm the board has approved a 
continued  freeze  on  the  non-executive  director’s  fee  (£10,500) 
with no premium for Chair positions, which is comparable to NED 
fees  of  other,  similarly-sized  funds.    Our  Ongoing  Charges  Figure 
(OCF,  calculated  using  the  AIC  recommended  Ongoing  Charges 
methodology,  April  2022,  taking  annualised  costs  that  would 
reasonably  be  incurred  if  there  was  no  trading  of  the  investee 
shares, divided by the average of published monthly NAV) is 2.89% 
(2021: 2.38%).  The increase is due to the decrease in NAV through 
2022,  and  also  £1,000  net  increase  in  Ongoing  Charges  in  2022 
compared to 2021.  While we  remain a small fund, reducing the 
OCF will continue to be a challenge, however every effort is made 
to do this, while applying appropriate time and resource to growth 
and good governance. 

Outlook 
Perhaps the main questions that will affect our performance for 
2023 include: 

6 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Strategic Report 
Fund Manager’s Review 
Reflecting on 2022 
By any measure, the past twelve months have delivered a very 
poor result, especially when compared to the remarkable return 
achieved in 2021 when the FTSE 100 was up by 14.6% and our 
portfolio  up  by  29.1%.  Over  the  past  twelve  months  we  have 
under-performed the various benchmarks as shown in Table 1 
Table 1: Performance Metrics 

and as one would expect, while our long-term results are still in 
line  with  the  FTSE  250,  this  recent  underperformance  has 
prompted  us  to  consider 
in  our 
deliberations  or  if  there  was  anything  we  should  have  done 
differently in our analysis?   

if  we  missed  anything 

Compound Growth Rate 

1 Year 

2 Years 

3 Years 

5 Years 

10 Years 

ATY PORTFOLIO 

ATY NAV 

FTSE 250 

FTSE 100 

FTSE Small Cap 

-24.7% 

-29.3% 

-19.7% 

   0.9% 

-16.3% 

-1.5% 

-7.3% 

-4.1% 

 7.4% 

 0.2% 

 0.3% 

-6.3% 

-4.8% 

-0.4% 

 1.6% 

n.a. 

-5.1% 

-1.9% 

-0.6% 

 1.1% 

n.a. 

4.3% 

4.3% 

2.4% 

6.2% 

 Our Investment Philosophy is based on the belief the economics 
of a business drives long-term investment returns and evidenced 
through  our  investment  process  which  delivers  a  portfolio  of 
high-quality  businesses  in  the  growth  stage  of  their  life  cycle.  
However,  investment  returns  over  any  period  comprise  two 
components, namely the dividends received and the movement 
in the value of the investment portfolio.  While the dividends we 
are likely to receive from the companies in our portfolio are fairly 
easy  to  predict  and,  for  the  most  part  increase  over  time,  the 

same cannot be said for the market price for the shares. These 
are  affected  by  investors  responding  to  daily  news  feeds  and 
commentary on local and global economic data as well as macro 
events. 

Chart 1, showing the FTSE 250 Index in 2022 provides some idea 
of events that have impacted the market over the past twelve 
months. 

Chart 1:  FTSE 250 Index 

7 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
Strategic Report 
Fund Manager’s Review 
In  the  first  quarter  of  the  financial  year,  Russia  invaded  the 
Continued 
issue  sanctions  and 
Ukraine.  The  West  was  quick  to 
multinationals  started  closing  down  any  operations  linked  to 
Russia.  However, the war amplified energy and food price issues 
straining an already COVID constrained supply-side environment 
and pushing inflation higher.  Central banks began raising rates 
and forecasting future increases which drove down equity-based 
valuations across the board. 
By the second quarter the high inflation readings were a major 
detractor  for  all  sectors  of  the  financial  markets  other  than 
mining and energy stocks.  The fiscal stimulus plan and series of 
tax cuts and regulatory reforms announced in the mini-budget in 

September sent financial markets into a tailspin with the pound 
reaching  a  record  low  and  short-term  interest  rates  and  bond 
yields  moving  sharply  up.    The  yields  on  five-year  government 
bonds reached levels similar to those of more heavily-indebted 
European economies such as Italy and Greece. Commensurate 
with  this  rise  in  short  and  medium-term  interest  rates,  the 
quoted  prices  for  income  generating  assets  and  REITs  in 
particular,  declined  materially.  The  net  effect  of  this  and  the 
tightening in monetary policy has been to put pressure on the 
high PE valuations of the market and growth stocks in particular, 
as future earnings are discounted at a higher rate.   

Chart 2: Contributions to NAV in the period 1 January 2022 to 31 December 2022 (pence per share) 

In spite of this, recent operating results from companies in our 
portfolio indicate that they have been able to partially withstand 
these inflationary pressures by implementing appropriate short-
term strategies and adapting their business models accordingly.  

While the majority of the stocks in the portfolio have declined in 
value  over  the  past  year,  dividends  for  the  most  part  were 
maintained, with a handful of names producing positive returns 
for the year.  These were Begbies Traynor (LSE: BEG), 4Imprint 
(LSE: FOUR) and NWF (LSE: NWF). 

8 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
Strategic Report 
Fund Manager’s Review 
Continued 
While we do sell some of our investments from time to time, our 
process aims to find high-quality businesses that we own for the 
very  long-term  and  as  a  result  our  portfolio  turnover  remains 
low.  During  the  past  year,  while  we  did  reduce  our  overall 
exposure to the Property Trusts, we still maintained a material 
exposure  in  recognition  of  the  need  to  maintain  the  dividend 
paid to shareholders within a growth style portfolio. However, 
we are always looking for new investments and when we do find 
them,  we  ensure  that  they  have  sustainable  and  resilient 
characteristics.  In the past twelve months we added two new 
names to the portfolio: 

Cerillion: (LSE: CER) 
Cerillion  joined  AIM  in  2016  and  has  since  established  a  very 
strong  record  of  revenue  and  profit  growth  principally  from 
software licences and related support and maintenance sales.  It 
operates 
forty-five  countries  globally, 
providing  customers  with  mission-critical  software  for  billing, 
charging  and  customer  relationship  management  mainly  for 
telecommunications  providers,  but  also  for  other  sectors, 
including energy and utilities.  

in  approximately 

Whilst the coronavirus pandemic is no longer directly affecting 
business operations, the global experience of remote-working – 
still in place in many economies – has continued to emphasise 
the  dependence  of  the  world  economy  on  state-of-the-art 
telecoms infrastructure. Over the year, we continued to see high 
levels  of  investment  in  the  sector,  and  an  acceleration  of 
investment in 5G and fibre rollouts, with spending trickling down 
from core network improvements to ancillary system upgrades 
and  replacements,  particularly  due  to  national  security 
concerns.  We  expect  to  see  these  trends  continue  with 
increasing pressure on telcos to find efficiencies in their digital 
real-estate. This is likely to encourage further market take-up of 
product-based SaaS solutions, which Cerillion offers, rather than 
the  more  bespoke  solutions  available  from  more  traditional 
vendors  which  require  highly  complex  implementations  over 
several years and have a higher total cost of ownership. 

Impax Asset Management (LSE: IPX) 
Impax  Asset  Management  is  a  fund  manager  who  invests 
globally  in  companies  focused  on  the  transition  to  a  more 
sustainable global economy and is well placed to benefit from 
the profound changes to the economic landscape particularly in 
the areas of climate change, pollution and essential investments 
in human capital, infrastructure and resource efficiency. Impax 
has proven expertise in finding and investing in companies and 
assets that are well positioned in this space and should benefit 
from these mega-trends which will drive growth for them and 
create  risks  for  those  unable  or  unwilling  to  adapt  to  the 
changes. They offer a well-rounded suite of investment solutions 
spanning  multiple  asset  classes  and  should  be  able  to  deliver 
superior shareholder returns over the medium to long-term.  

9 | Athelney Trust plc | Annual Report 2022 

Looking ahead 
While  I  was  preparing  to  write  this  year’s  commentary,  the 
following quote came to my attention: 

“Time is the friend of the wonderful business, the enemy of the 
mediocre.” Warren Buffett - Letter to Shareholders 1989 

While  supply  chains  are  stretched  and  input  products  in  short 
supply,  it  can  be  challenging  to  recognise  the  potential  in 
companies,  particularly  those  that  are  in  the  growth  stage  of 
their life cycle. It can also be difficult to evaluate the ‘narratives’ 
that some companies are telling about themselves.  To invest in 
a company in the growth stage of their life cycle it is important 
to balance the company’s narrative alongside its numbers and it 
is vital not to get caught up in the hype and noise of the internet 
and daily market movements.   

A sound investment philosophy sets out a number of ‘rules’ or 
‘procedures’ to fall back on when the market noise gets too loud.  
Companies that have a sustainable competitive advantage will 
always  be  well-placed  to  withstand  short-term  headwinds, 
regardless  of  market  conditions,  maintain  market  share  and 
ultimately find new ways to grow. Their ability to be flexible, to 
move quickly, to take advantage of opportunities as they arise, 
and to capitalise on market trends and demand, will continue to 
support  the  ongoing  success  of  such  businesses,  and  provide 
significant  long-term  opportunities  for  their  investors.    The 
pandemic,  devastating  weather  events,  and  the  invasion  of 
Ukraine are examples of macro-environmental shocks impacting 
companies worldwide and it is also of paramount importance to 
take a holistic approach when analysing the companies and their 
sustainability by considering the business competitiveness and 
ability to dynamically adapt and react to black swan events - to 
be resilient. 

Over the past few years our industry, and society more broadly, 
has continued to evolve with higher expectations being made of 
businesses  and  their  social  licence  to  operate.  Being  a  good 
corporate citizen is only part of it. Being a good corporate citizen 
that is compassionate, committed to its people, planet, and the 
community is mandatory.  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.  

 
 
 
 
 
 
  
 
 
 
 
 
 
Strategic Report 
Fund Manager’s Review 
Continued 
A genuine long-term approach 
Investment management is more than merely generating alpha in 
excess of a benchmark.  While that is a core part of our mandate, 
other very important qualitative issues are central to what we do.  
For  example,  we  recognise  that  capital  allocation  is  a  vehicle 
through which to drive change.  We have the opportunity to demand 
specific standards of corporate governance, decide whether specific 
social and ethical issues are acceptable and, if they are not, we vote 
with our feet.   

For  us,  the  integrity  and  credibility  of  any  management  team  is  a 
founding principle to our investment process. We need to trust that 
management has the best interests for all stakeholders at heart, and 
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 which we believe are sustainable in 
the long-term, and finding trustworthy, values-based management 
that  aligns  with  our  core  values  and  beliefs  will  ensure  above-
average  economic  portfolio  returns.  Sustainability  of  investment 
performance  or  the  improvement  of  the  wellbeing  of  broader 
society hinges upon ethical, transparent, and honest leadership and 
in cases where we feel we can add something to the conversation, 
we engage with the company.   

While current macro events have put pressure on our portfolio in the 
short-term,  our  investment  philosophy  is  based  on  the  belief  the 
long-term  economics  of  a  business  drives  long-term  investment 
returns. Our companies have strong business models with capable 
and experienced management teams and 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 in the good times 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  and 
over  time  we  expect  that  dividends  from  the  high  growth 
quality companies in the portfolio will increase sufficiently so 
that the property trusts can be replaced by other high growth 
quality  companies  without  jeopardising  our  AIC  dividend 
hero status. 

Update 
The unaudited NAV on 31 January 2023 was 229.4p per share 
– up by 4.6% from 31 December 2022. The share price on the 
same day was 205p (trading at a discount of 10.7%). Further 
updates can be found at www.athelneytrust.co.uk 

Dr Manny Pohl AM 
Fund Manager 
13 February 2023 

10 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 SECTOR 
 £  
186,600 
174,000 
80,400 
155,700 

% 

4.5% 
4.2% 
1.9% 
3.7% 

922,780 
300,125 

22.1% 
7.2% 

470,640 
161,700 
140,140 

11.3% 
3.9% 
3.4% 

1,124,330 

26.7% 

345,570 
119,000 

8.3% 
2.8% 

Strategic Report 
Investment and Portfolio Analysis at 31 December 2022 

 Holding  

 Value (£) 

Stock 

Chemicals 
Construction & materials 
Electronic & electrical equipment 
Food & beverages 
General financial  

Leisure goods 
Media 

Mobile communications 
Multiutilities 
Property, commercial & 
residential 

Support services 

Technology  

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

AEW UK REIT 
Londonmetric REIT 
Target Healthcare REIT 
Tritax BigBox REIT 
Begbies Traynor 
NWF Group 
Paypoint 
Smart Metering Systems 
Cerillion 

Portfolio Value 
Net Current Assets 

TOTAL VALUE 

Shares in issue 

Audited NAV 

219.4p 

186,000 
174,000 
80,400 
155,700 
209,600 
287,600 
300,780 
124,800 
300,125 
214,250 
154,380 
102,010 
161,700 
140,140 

475,950 
172,600 
196,980 
278,800 
135,090 
86,800 
60,960 
62,720 
119,000 

30,000 
145,000 
4,000 
15,000 
20,000 
40,000 
27,000 
6,000 
3,500 
5,000 
30,000 
10,100 
15,000 
14,000 

475,000 
100,000 
245,000 
200,000 
95,000 
35,000 
12,000 
8,000 
10,000 

4,180,985 
553,577 

4,734,562 

2,157,881 

11 | Athelney Trust plc | Annual Report 2022 

 
 
 
  
 
 
  
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Strategic Report 
Investment and Portfolio Analysis at 31 December 2022 
Portfolio by Sectors 
Continued 

2.8% Technology 
software services

8.3% Support services

26.7% Property 
commercial & 
residential

4.5 % Chemicals 4.2% Construction & 

materials
1.9% Electronic & 
electrical equipment

3.7% Food & 
beverages 

22.1% General 
financial

3.4% Multiutilities

7.2% Leisure goods

11.3% Media

3.9% Mobile 
communications

Portfolio by Listing 

11.5% Cash

6.2% FTSE 100

19.7% Small Caps

3.7% Fledgling

35.4% FTSE 250

23.5% AIM

12 | Athelney Trust plc | Annual Report 2022 

 
 
 
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: 

• 

• 

• 

• 

• 

• 

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

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

the impact of the Company’s operations on 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, reports to other 
Board  members  and  answers  any  questions  raised.  Compliance  with 
existing regulatory and legal requirements is 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: 

Annual General Meeting 
The  Company,  in  normal  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.  

13 | Athelney Trust plc | Annual Report 2022 

The Board plan to hold the 2023 AGM on 16 March 2023 at 12.00 
noon. Further details regarding the 2023 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. 

Suppliers 
The Company Secretary Deborah Warburton and Administrator 
GW & Co. Limited are often the main contact point for advisors 
and  stakeholders  in  the  Company.  Regular  communication  is 
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 
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. 

impact  on  the  environment 

its 

 
 
 
 
 
 
Strategic Report 
Other Statutory Information 

As explained within the Report of the Directors on pages 20 to 21, the 
Company carries on business as an investment trust. Investment trusts 
are collective closed-ended public limited companies. 

Board 
The Board of Directors is responsible for the overall stewardship of the 
Company, including investment  and dividend policies, corporate  and 
gearing  strategy,  corporate  governance  procedures  and 
risk 
management. Biographical details of the three male Directors, can be 
found on pages 2 and 3. 

One  of  the  Directors  is  the  Company's  only  employee  (2021:  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, 
individual 
financial  strength  and  cash  flows.  The  weighting  of 
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 2022 
can be found on pages 11 and 12 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  16  to  19,  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.  

14 | Athelney Trust plc | Annual Report 2022 

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 10 which 
form part of the Strategic Report. 

Principal  Risks  and  Uncertainties  and  Risk 
Management 
As stated within the Corporate Governance Statement on pages 
16 to 19, the Board applies the principles detailed in the internal 
control guidance issued by the Financial Reporting Council, and 
has  established  a  continuing  process  designed  to  meet  the 
particular  needs  of  the  Company  in  managing  the  risks  and 
uncertainties to which it is exposed. 

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

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

Investment  and  strategic  – 

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

incorrect 

• 
Regulatory – Relevant legislation and regulations which 
apply  to  the  Company  include  the  Companies  Act  2006,  the 
Corporation  Tax  Act  2010  (“CTA”)  and  the  Listing  Rules  of  the 
Financial Conduct Authority (“FCA”). The Company has noted the 
recommendations of the UK Corporate Governance Code and its 
statement of compliance appears on pages 16 to 19. 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 

 
 
 
 
Strategic Report 
Other Statutory Information 
Continued 
• 

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. 

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. 

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

On behalf of the Board 

 Dr Manny Pohl AM 
 Managing Director 

 13 February 2023 

15 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
Manny Pohl and Simon Moore retired by rotation and were re-elected 
at the AGM on 5 April 2022. The Directors believe that the Board has 
the balance of skills, experience 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 2022, the Board met a total of 7 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 
5 
5 
5 

Audit 
Committee 
- 
1 
1 

Remuneration 
Committee 
1 
1 
1 

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

The  Board  of  Directors  of  the  Company  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  15.  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. 

Corporate Governance Statement

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

The  Company  is  required  to  comply  with,  or  to  explain  its  non-
compliance  with,  the  relevant  provisions  of  the  UK  Corporate 
Governance  Code  issued  by  the  Financial  Reporting  Council  (the 
‘FRC’) in 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: 

• 

• 

• 

• 

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 2022 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. 

16 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
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: 

• 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 
comparisons with previous years, cash availability and requirements 
and a breakdown of shareholdings by listing and sector.  The Board 
takes account of Corporate Governance best practice. 

considers 

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 
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. 

17 | Athelney Trust plc | Annual Report 2022 

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  23  to  25  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  
Much  of  the  Board’s  corporate  governance  responsibility  is 
Continued 
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 is still adversely affecting the global 
economy and this, in turn may, still 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. 

Ukraine War 

The war in the Ukraine has adversely affected the global 
economy and this, may impact on the valuation of investee 
companies and their ability to pay dividends. 

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 2022. At the conclusion of the audit Hazlewoods LLP did 
not highlight any issues to the Audit Committee which would cause 
it to qualify its audit report nor  did it  highlight any fundamental 
internal  control  weaknesses.  Hazlewoods  LLP 
issued  an 
unqualified audit report which is included on pages 26 to 29. 

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. 

18 | Athelney Trust plc | Annual Report 2022 

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 Company’s capital structure and voting rights are  

• 
          summarised on pages 20 and 21. 

• 

• 

Details of the substantial shareholders in the Company are 
listed on page 20. 

The rules concerning the appointment and replacement of 
Directors  are  contained 
in  the  Company’s  Articles  of   
Association and are discussed on page 20. 

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. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate Governance Statement  
Relations with Shareholders 
Continued
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. 

•  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: 

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.  All 
resolutions proposed at the AGM were unanimously passed. 

The notice and further details of the Annual General Meeting, to be 
held on 16 March 2023 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 
internal  controls  are 
Risk  assessment  and  the  review  of 
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: 

•  Corporate strategy; 

•  Published 

information,  compliance  with 

laws  and 

regulations; 

•  Relationship with service providers; and 

• 

Investment and business activities. 

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

•  Custody  and  valuation  of  assets  is  undertaken  by  James 

Sharp & Co; 

•  The  duties  of  investment  management,  accounting  and 
the  custody  of  assets  are  segregated.  The  procedures  of 
the  individual  parties  are  designed  to  complement  one 
another; 

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

•  Mandates  for  authorisation  of  investment  transactions 

and expense payments are set by the Board; and 

•  The Board reviews financial information produced by the 
Fund Manager and the Company Secretary in detail on a 
regular basis. 

In  accordance  with  guidance 
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 
13 February 2023 

19 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
Capital Structure  
At 31 December 2022 the Company’s capital structure consisted of 
2,157,881  Ordinary  Shares  of  25p  each  (2021:  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  25  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 

Astuce Group 

IP Worldwide Flexible Fund 

Mehr Mutual 

E C Pohl & Co Pty Ltd  

Mr GW & Mrs DJ Whicheloe 

Mrs E Davison 

Mr C Frostick 

Mr S Moore 

P Grodzinski 

550,000 

339,054 

121,479   

  86,000 

  81,500 

  75,000 

  70,500 

  67,500 

  65,000 

% of 

Issue 

25.5 

15.7 

  5.6 

  4.0 

  3.8 

  3.5 

  3.3 

  3.1 

  3.0 

Out of the nine major shareholders listed above Dr. Manny Pohl has 
control over two substantial shareholdings amounting to 29.5% of 
the  total  shareholding,  he  is  also  in  contact  with  IP  Worldwide 
Flexible Fund and Mr C Frostick on a regular basis. Simon Moore has 
control of 3.1% of the total shareholdings and is in regular contact 
with  two  of  the  remaining  four  substantial  shareholders.  The 
remaining  two  are  in  regular  contact  with  the  Directors  (or  their 
respective  agent)  to  ensure  that  they  are  frequently  apprised  and 
are content with the manner in which the Company is being run. 

There have been no changes to the substantial shareholders up until 
6 February 2023. 

Report of the Directors

The  Directors  present  their  report  and  audited 
financial 
statements of the Company for the year ended 31 December 2022. 
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 £148,531 (2021: £151,260) as detailed on page 30. 

The company paid an interim dividend of 2.1p per ordinary share  
on the 23 September 2022. 

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 9.6p 
(2021: 9.5p) 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 
2021.  The  Directors  are  of  the  opinion  that  the  Company  has 
conducted its affairs for the year ended 31 December 2022 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.  Frank  Ashton  will  retire  at  the 
2023 AGM and will offer himself for re-election. 

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

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

20 | Athelney Trust plc | Annual Report 2022 

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

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

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

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

Going Concern 
In assessing the going concern basis of accounting, the Directors 
have had regard to the guidance issued by the Financial Reporting 
Council.  They  have  considered  the  current  cash  position  of  the 
Company, and forecast revenues for the current financial year. The 
Directors have also taken into account the Company’s investment 
policy,  which  is  described  on  page  14  and  which  is  subject  to 
regular Board monitoring processes, and is designed to ensure that 
the Company is invested in listed securities and those traded on 
AIM or 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. 

21 | Athelney Trust plc | Annual Report 2022 

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  14  and  15),  its  portfolio  of  listed 
equity  investments  and  cash  balances,  and  its  ability  to  achieve  the 
stated dividend policy. The Directors have assessed the ability of the 
Company to continue as a going concern as outlined above. 

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

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

instruments  comprise 

Financial Instruments 
investment 
The  Company’s  financial 
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 
13 February 2023 

 
 
 
 
 
Statement of Directors’ responsibilities in respect of the 
financial statements

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 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. 

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 
13 February 2023 

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. 

22 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 
These were renewed for a further three years before the 2022 AGM. 
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 2022, 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. 

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 26 to 29. 

Remuneration Committee 
The  Company  had  a  Remuneration  Committee  during  the  year 
comprising  Simon  Moore  and  Frank  Ashton,  Manny  Pohl  was 
invited to attend the meeting by the other Board members. 

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 2022. 

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 2023 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. 

23 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
        
 
 
 
 
 
 
 
 
 
 
 
Directors’ Remuneration Report 
Continued

Capital Growth
(re-based to 100 at 31/12/2012)

250

200

150

100

50

0

2012

2013

2014

ATY NAV

2015
FTSE100

2016

2017

FTSE 250

2018
2019
FTSE Small Cap

2020

2021

2022

AIM All Share

ATY NAV

FTSE 100

FTSE 250

FTSE Small Cap

AIM All Share

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

2022
21.5% -29.3%
14.6%
1.0%
14.3% -19.7%
20.0% -16.3%
5.2% -31.7%

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  -  Fund Manager 

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

Director’s expenses 

2022 
£ 
40,077 

10,500 
10,500 

- 

2021 
£ 
44,877 

10,500 
10,500 

- 

61,077 

65,877 

The Directors’ remuneration for the year of £61,077 which is down 
by 7.3% on 2021 and is before the proposed final dividend of 7.5p 
increasing the total dividend for the year to 9.6p  (2021: 9.5p) per 
ordinary share, and as compared to total dividends paid in the year 
at  9.7p  per  share  amounting  to  £207,156    (2021:  £202,840).  The 
remuneration decrease is due to the decrease in the portfolio value 
during the year on which the Fund Manager’s fee is based. 

24 | Athelney Trust plc | Annual Report 2022 

Expected Fees 
for the Year to 
31 December 
2023 
10,500 
42,000 
10,500 

Fees for Year 
to 31 
December 
2022 
10,500 
40,077 
10,500 

Chairman basic 
Fund Manager 
Non-Executive 

No expenses were claimed by any Directors during this year. 

Performance, Service Contracts, Compensation 
and Loss of Office 

• 

The Directors’ remuneration is not subject to any 
performance related fee. 

•  No Director was interested in contracts with the 
Company during the period or subsequently 

• 

• 

The terms of appointment provide that a Director may 
be removed without notice. 

Compensation will not be due upon leaving office. 

 
     
  
 
 
  
 
  
 
 
 
 
 
 
 
 
Directors’ Remuneration Report 
Continued 
• 

No Director is entitled to any other monetary payment or any 

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. 

The Directors’ Remuneration Report for the year ended 31 December 
2021 was approved by shareholders at the Annual General Meeting 
held on 5 April 2022. The votes cast by proxy were as follows: 

For 
Against 
Total votes cast 
Number of votes withheld 

Number of  
Votes 

% of  
votes 

814,560 
Nil 
814,560 
Nil 

38 
- 
38 
-

Approval 
The Directors’ Remuneration Report was approved by the Board 
on 13 February 2023. 

Dr Manny Pohl AM 
Managing Director 

assets of the Company.

•  No incentive or introductory fees will be paid to encourage 

a directorship. 

• 

The Directors are not eligible for bonuses, pension 

benefits, share options, long term incentive schemes or 

other benefits. 

Directors’ & Officers’ liability insurance cover is maintained by the 
Company on behalf of the Directors. 

Relative importance of spend on pay 

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

2022 
40,077 

2021 
44,877 

% Change 
-10.7% 

21,000 

21,000 

0% 

61,077 

65,877 

-7.3% 

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: 

31 
December 
2022 
(or date of 
Resignation 
If earlier) 

    31 
    December 
              2021 
    (or date of 
appointment 
  if later) 

-¹ 
67,500 
2,234 

           -¹ 
  67,500 
    2,234 

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. E C Pohl & Co Pty Limited holds 86,000 shares 
(2021: 496,000). 

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  the  following  three  years  due  to  the  top  5 
shareholders  owning  more  than  50%  of  the  total  shares  in  the 
company. The Company holds its Investment Trust status under the  

25 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF 
ATHELNEY TRUST PLC
Conclusions relating to going concern  
Opinion  
In  auditing  the  financial  statements,  we  have  concluded  that  the 
We have audited the financial statements of Athelney Trust plc (the 
director's  use  of  the  going  concern  basis  of  accounting  in  the 
‘Company’) for the year ended 31 December 2022, which comprise the 
preparation of the financial statements is appropriate.  
Income Statement, Statement of Changes in Equity, Statement of the 
Financial Position, Statement of Cash Flows and notes to the financial 
statements,  including  a  summary  of  significant  accounting  policies. 
The  financial  reporting  framework  that  has  been  applied  in  their 
preparation 
law  and  United  Kingdom  Accounting 
Standards,  including  Financial  Reporting  Standard  102  The  Financial 
Reporting  Standard  applicable  in  the  UK  and  Republic  of  Ireland 
(United Kingdom Generally Accepted Accounting Practice).  

In  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.  

is  applicable 

In our opinion the financial statements:  

• give a true and fair view of the state of the Company’s affairs as at 
31 December 2022 and of its net return for the year then ended;  
•  have  been  properly  prepared  in  accordance  with  United  Kingdom 
Generally Accepted Accounting Practice;  
•  have  been  prepared  in  accordance  with  the  requirements  of  the 
Companies Act 2006. 

Basis for opinion  
We  conducted  our  audit  in  accordance  with  international  Standards 
on  Auditing  (UK)  ((ISAs  UK))  and  applicable  law.  Our  responsibilities 
in  the  Auditor’s 
under  those  standards  are  further  described 
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  and  the  maintenance  of  the 
Company’s  accounting  records  are  managed  internally,  with  the 
custody of its investments outsourced to third-party service providers. 
Accordingly, our audit work is focused on obtaining an understanding 
of,  and  evaluating,  internal  controls  of  the  Company  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. 

The audit team communicated throughout the audit with the directors 
and investment managers in order to ensure we had good knowledge 
of the business of the Company. During the audit, we reassessed and 
re-evaluated audit risks and tailored our approach accordingly.  

We  communicated  with  those  charged  with  governance  regarding, 
among other matters, the planned scope and timing of the audit and 
significant findings, including significant deficiencies in internal control 
that we identified during the audit, if any. 

26 | Athelney Trust plc | Annual Report 2022 

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 entities reporting on how they have 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  directors  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 management override of controls 
are always deemed risks in any audit.  This is not a complete list of 
all risks identified by our audit.  

Valuation, ownership and existence of investments  
The Company’s investment portfolio is one of the key drivers of its 
results, of which 100% is represented by quoted investments. The 
investments  are  not  considered  to  be  at  a  high  risk  of  material 
misstatement, or to be subject to a significant level of judgement, 
because  they  comprise  liquid,  quoted  investments  for  which 
evidence of the market price is readily available.  

 
  
 
  
 
 
 
 
 
 
 
 
 
 
  
 
INDEPENDENT  AUDITOR’S  REPORT  TO  THE  MEMBERS  OF 
ATHELNEY TRUST PLC
However,  due  to  their  materiality  in  the  context  of  the  financial 
Continued
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  third 
party custodian confirmations. 

Key observations 
Our testing did not identify any material misstatements in revenue 
recognition. 

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

Key observations 
Our  testing  did  not  identify  any  breaches  in  the  criteria  stated 
above. 

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  £95,000,  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  £37,000,  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. 

Key observations 
Our  testing  did  not  identify  any  material  misstatements  in  the 
valuation of the Company’s investment portfolio as at the year end. 

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

Key observations 
Our  testing  did  not  identify  any  material  misstatements  in  the 
allocation of costs between capital and revenue as at the year end. 

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

Key observations 
Our  testing  did  not  identify  any  management  override  of  financial 
controls that will materially misstate 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. 

27 | Athelney Trust plc | Annual Report 2022 

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

In  connection  with  our  audit  of  the  financial  statements,  our 
responsibility  is  to  read  the  other  information  and,  in  doing  so, 
consider  whether  the  other  information  is  materially  inconsistent 
with the financial statements or our knowledge obtained in the audit 
or otherwise appears to be materially misstated. If we identify such 
material inconsistencies or apparent material misstatements, we are 
required  to  determine  whether  there  is  a  material  misstatement  in 
the  financial  statements  or  a  material  misstatement  of  the  other 
information. If, based on the work we have performed, we conclude 
that there is a material misstatement of this other information,  we 
are required to report that fact.  

We have nothing to report in this regard. 

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

•  Fair,  balanced  and  understandable,  set  out  on  page  15  –  the 
statement  given  by  the  Directors  that  they  consider  the  annual 
report and financial statements taken as a whole is fair, balanced 
and  understandable  and  provides  the  information  necessary  for 
shareholders  to  assess  the  Company’s  performance,  business 
model and strategy, is materially inconsistent with our knowledge 
obtained in the audit; or   

•  Audit  committee  reporting,  set  out  on  pages  17  to  18  –  the 
section  describing  the  work  of  the  audit  committee  does  not 
appropriately address matters communicated by us to the audit 
committee; or   

•  Directors’  statement  of  compliance  with  the  UK  Corporate 
Governance Code, set out on page 16  - the parts of the Directors’ 
statement  required  under  the  Listing  Rules  relating  to  the 
Company’s compliance with the UK Corporate Governance Code 
containing  provisions  specified  for  review  by  the  auditors  in 
accordance with Listing Rule 9.8.10R (2) do not properly disclose a 
departure  from  a  relevant  provision  of  the  UK  Corporate 
Governance Code.  

• 

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

• 

• 

the part of the Directors’ Remuneration Report to be audited has 
been  properly  prepared  in  accordance  with  the  Companies  Act 
2006;  

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

• 

the information about internal control and risk management  

28 | Athelney Trust plc | Annual Report 2022 

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:   

• 
• 

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

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

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

• 

•  certain disclosures of Directors’ remuneration specified by law 

are not made; or  

•  we have not received all the information and explanations we 

require for our audit; or   

•  a  corporate  governance  statement  has  not  been  prepared  by 

the Company.  

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  Company'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:  

• 

the disclosures in the annual report set out on pages 14 to 15 
that describe the principal risks and explain how they are being 
managed or mitigated;   

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

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 of investments has 
been verified by reference to this information. 

the Directors’ confirmation set out on page 14 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 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 
This 
description forms part of our auditor’s report.  

at  www.frc.org.uk/auditorsresponsibilities. 

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

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

13 February 2023 

• 

the  Directors’  statement  set  out  on  page  21  in  the  financial 
statements about whether the Directors considered it appropriate 
to  adopt  the  going  concern  basis  of  accounting  in  preparing  the 
financial  statements  and  the  Directors’  identification  of  any 
material uncertainties to the Company’s ability to continue to do 
so  over  a  period  of  at  least  twelve  months  from  the  date  of 
approval of the financial statements;    

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

• 

the Directors’ explanation set out on page 21 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 pages 22), 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.  

29 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
  
 
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Income Statement 
For the Year Ended 31 December 2022

Note 

 Revenue 

                    2022 
      Total 

Capital  

 Revenue 

 Capital 

           2021 
   Total 

(Losses)/gains on 
investments held at 
fair value 

Income from 
investments 
Investment 
management 
expenses 

Other expenses 

Net return on 
ordinary activities 
before taxation 

Taxation 
Net return (negative 
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 

 £ 

 £ 

      £ 

- 

(1,787,296) 

(1,787,296) 

£ 

- 

 £ 

     £ 

1,359,219 

1,359,219 

183,273 

- 

183,273 

186,393 

- 

186,393 

(4,008) 

(36,327) 

(40,335) 

(4,488) 

(40,692) 

(45,180) 

(30,734) 

(78,720) 

(109,454) 

(30,645) 

(72,964) 

(103,609) 

148,531 

(1,902,343) 

(1,753,812) 

151,260 

1,245,563 

1,396,823 

- 

- 

- 

- 

- 

- 

148,531 

(1,902,343) 

(1,753,812) 

151,260 

1,245,563 

1,396,823 

6.9p 

(88.2p) 

(81.3p) 

7.0p 

57.7p 

64.7p 

9.6p 

9.7p 

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 34 to 38 form part of these financial statements. 

30 | Athelney Trust plc | Annual Report 2022 

 
 
 
               
                
 
                                                                                             
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Statement of Changes in Equity  
For the Year Ended 31 December 2022

Called-up 
Share 
Capital 
£ 

Share 
Premium 
£ 

Capital 
reserve 
realised 
£ 

Capital 
reserve 
unrealised 
£ 

Revenue 
reserve 
£ 

Total 
Shareholders’ 
Funds 
£ 

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 

539,470 

881,087 

2,271,737 

2,731,784 

271,452 

6,695,530 

- 

- 

- 
- 
- 

- 

- 

- 
- 
- 

382,704 

- 

- 

(2,170,000) 

- 

- 

382,704 

(2,170,000) 

(115,047) 
- 
- 

- 
- 
- 

- 
148,531 
(207,156) 

(115,047) 
148,531 
(207,156) 

539,470 

881,087 

2,539,394 

561,784 

212,827 

4,734,562 

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

Shareholders’ Funds at 31 
December 2021 

Balance brought forward at 
1 January 2022 
Net profits on realisation 
   of investments 
Decrease in unrealised 
   Appreciation 
Expenses allocated to  
   Capital 
Profit for the year 
Dividend paid in year 

Shareholders’ Funds at 31 
December 2022 

  The notes on pages 34 to 38 form part of these financial statements. 

31 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2022 

£ 

2021 

             £ 

4,180,985 

6,436,820 

Statement of Financial  Position 
As at 31 December  2022 
Company Number: 02933559 

                                                                       Note   

Fixed assets 
Investments held at fair value through profit and 
loss 

Current assets 
Debtors 
Cash at bank and in hand 

8 

9 

Creditors: amounts falling due within one year 

10 

Net current assets 

Total assets less current liabilities 

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 

543,301 
27,361 
570,662 

(17,085) 

553,577 

4,734,562 

4,734,562 

539,470 
881,087 

2,539,394 
561,784 
212,827 

4,734,562 

245,163 
30,676 
275,839 

(17,129) 

258,710 

6,695,530 

6,695,530 

539,470 
881,087 

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

6,695,530 

310.3p 

Net Asset Value per share 

13 

219.4p 

These financial statements were approved and authorised for issue by the Board of Directors on 13 February 2023 and signed on their 
behalf by 

Dr Manny Pohl AM 
Managing Director 

The notes on pages 34 to 38 form part of these financial statements. 

32 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Statement of Cash Flows 
For the Year Ended 31 December 2022 

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

Cash used in operations 

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

Equity dividends paid 

Net decrease in cash 

Cash at the beginning of the year 

Cash at the end of the year 

2022 
     £ 

148,531 

(115,047) 
(44) 
(298,138) 

(264,698) 

(1,003,583) 
1,472,122 
468,539 

(207,156) 

(3,315) 

30,676 

27,361 

2021 

      £ 

151,260 

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

(65,671) 

(545,379) 
778,439 
233,060 

(209,314) 

(41,925) 

72,601 

30,676 

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 34 to 38 form part of these financial statements.

33 | Athelney Trust plc | Annual Report 2022 

 
  
 
 
 
 
 
                                 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
      
 
 
Notes to the Financial Statements 
1.  Accounting Policies 
For the Year Ended 31 December 2022
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 and 
Fledgling.  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. 

34 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
Notes to the Financial Statements 
For the Year Ended 31 December 2022 (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 

2022 
£ 
108,179 
3,760 
71,308 
26 
183,273 

2022 
£ 

79,926 
28,253 

108,179 

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

2021 
£ 

74,775 
  42,741 
117,516 

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 

2022 
£ 

2021 
£ 

21,000 
40,077 

21,000 
44,877 

11,984 

11,964 

- 
32,472 
6,687 
10,500 
23,276 

       - 
32,472 
4,101 
10,020 
23.215 

3,793 

1,140 

149,789 

148,789 

4. Employees and Directors’ Remuneration 

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

2022 
£ 

21,000 
40,077 
61,077 

2021 
£ 

21,000 
44,877 
65,877 

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 (2021: Nil). 

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

The tax charge for the period is lower than (2021: 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 

2022 
£ 
(1,753,812) 

2021 
  £ 
1,396,823 

(333,223) 

265,396 

(20,739) 
412,299 
(72,714) 
14,377 

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

Current tax charge for the year 

- 

- 

The  Company  has  unrelieved  excess  revenue  management 
expenses of £671,156 at 31 December 2022 (2021: £595,482) and 
£102,597  (2021:  £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  2021,  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  2021.    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. 

35 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
Notes to the Financial Statements 
For the Year Ended 31 December 2022 (continued)
6. Return per Ordinary Share 
The  calculation  of  earnings  per  share  has  been  performed  in 
accordance with FRS 102. 

£ 
Revenue 

2022 

£ 
Capital 

£ 
Total 

148,531 

(1,902,343) 

(1,753,812) 

2,157,881 

6.9p 

(88.2p) 

(81.3p) 

£ 
Revenue 

2021 

£ 
Capital 

£ 
Total 

151,260 

1,245,563 

1,396,823 

2,157,881 

7.0p 

57.7p 

64.7p 

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 

Final dividend in respect of 2021 of 
7.5p (2021: a final dividend of 7.7p 
was paid in respect of 2020) per 
share 

Interim dividend in respect of 2022 
of  2.1p  (2021:  an  interim  dividend 
of 2.0p was paid in respect of 2021) 
per share 

207,156 

209,314 

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  (2021:  7.50p)  per 
ordinary share be paid out of revenue profits amounting to a total of 
£161,841. An interim dividend of 2.1p per ordinary share was paid on 
23 September 2022 amounting to £45,315 making the total dividend 
payable in the year £207,156. 

  Summary of dividends paid for the last 10 financial years 

Ex-div date 

6/04/2023 
08/09/2022 
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 

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

Amount 

7.5p 
2.1p 
7.5p 
2.0p 
7.7p 
1.7p 
9.3p 
9.1p 
8.9p 
8.6p 
7.9p 
6.7p 
5.5p 
5.0p 

Financial 
Year 
2022 
2022 
2021 
2021 
2020 
2020 
2019 
2018 
2017 
2016 
2015 
2014 
2013 
2012 

for 

available 

Revenue 
distribution 
Interim dividend paid 
Final  dividend  in  respect  of 
financial year end 

2022 
£ 
148,531 

2021 
£ 
151,260 

(45,315) 

(43,157) 

(161,841) 

(161,841) 

Undistributed 
reserves 

revenue 

(58,625) 

(53,738) 

2022 
£ 
6,436,820 

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

1,003,583 
(1,472,122) 
382,704 
(2,170,000) 

4,180,985 

2021 
£ 
5,310,661 

545,379 
(778,493) 
354,843 
1,004,376 

6,436,820 

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

3,619,201 
561,784 

3,705,034 
2,731,786 

4,180,985 

6,436,820 

2022 
£ 

2021 
£ 
161,841                  166,157 

 8. Investments 

45,315 

43,157 

Movements in year 

For the year 2021, a final dividend of 7.5p was paid on 13 April 2022 
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 paid in the year £209,314. 

UK  Main  Market 
investments 
UK AIM-traded shares 

listed 

3,070,365 

5,014,560 

1,110,620 

1,422,260 

4,180,985 

6,436,820 

36 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Financial Statements 
Gains on investments 
For the Year Ended 31 December 2022 (continued)

Realised gains on sales 
Increase/(decrease) 
appreciation 

in 

unrealised 

2022 
£ 
382,704 
(2,170,000) 

2021 
£ 
354,843 
1,004,376 

(1,787,296) 

1,359,219 

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 

2022 
£ 
513,597 
29,704 

543,301 

2021 
£ 
236,912 
8,251 

245,163 

10. Creditors: amounts falling due within one 
year 

Social security and other taxes 
Other creditors 
Accruals and deferred income 

2022 
£ 
700 
2,850 
13,535 

17,085 

2021 
£ 
719 
2,850 
13,560 

17,129 

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 

2022 
£ 

2021 
£ 

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 2022 would have decreased net assets attributable 
shareholders by 39 pence per share (2021: 60 pence per share). 
An increase of the same percentage would have an equal but 
opposite effect on net assets attributable 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. 

37 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
For the Year Ended 31 December 2022 (continued) 
Notes to the Financial Statements 

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 

2022 
£ 
4,180,985 

2021 
£ 
6,436,820 

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

31 December 2022 

At 
Amortised 
Cost 

£ 

Assets at 
fair value 
through 
profit or 
loss 
£ 

Total 

£ 

- 
543,301 
27,361 

4,180,985 
- 
- 

4,180,985 
543,301 
27,361 

Assets  as  per  balance 
sheet 
Investments 
Debtors 
Cash at bank 

Total 

570,662 

4,180,985 

4,751,647 

17,085 

17,085 

- 

- 

At Amortised 
Cost 

£ 

Assets at 
fair value 
through 
profit or 
loss 
£ 

17,085 

17,085 

Total 

£ 

- 
245,163 
30,676 

6,436,820 
- 
- 

6,436,820 
245,163 
30,676 

275,839 

6,436,820 

6,712,659 

Liabilities as per the 
balance sheet 
Creditors 

Total 

31 December 2021 

Assets  as  per 
balance sheet 
Investments 
Debtors 
Cash at bank 

Total 

Liabilities as per 
the balance 
sheet 
Creditors 

Total 

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  (2021: 
classification A investments only). 

13. Net Asset Value per Share 
The net asset value per share is based on net assets of 
£4,734,562 (2021: £6,695,530) divided by 2,157,881 (2021: 
2,157,881) ordinary shares in issue at the year end. 

Net asset value per 
share 

2022 
£ 
219.4p 

2021 
£ 
310.3p 

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: 

£8,256¹ 
£6,480 
£   214 

17,129 

17,129 

- 

- 

17,129 

17,129 

1.  Manny Pohl’s relationship with EC Pohl & Co Pty Ltd 
is  described  in  Note  1  to  the  table  of  Directors’ 
interests  on  page  25.  During  the  year  dividends 
amounting to £8,256 were paid to EC Pohl & Co Pty 
Ltd. 

38 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

39 | Athelney Trust plc | Annual Report 2022 

 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
    
 
 
   
 
   
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
Company number 
02933559 

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

athelneytrust.co.uk 

40 | Athelney Trust plc | Annual Report 2022