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Baker Steel Resources Trust Limited

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FY2022 Annual Report · Baker Steel Resources Trust Limited
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BAKER STEEL RESOURCES TRUST LIMITED 

Annual Report and Audited Financial Statements 

For the year ended 31 December 2022 

Baker Steel Resources Trust Limited (the "Company") is a closed-ended investment company with limited liability incorporated 
on 9 March 2010 in Guernsey under The Companies (Guernsey) Law, 2008 with registration number 51576. 

BAKER STEEL RESOURCES TRUST LIMITED

CONTENTS 

Management and Administration 

Chairman’s Statement 

Investment Manager’s Report 

Portfolio Statement 

Strategic Report 

Board of Directors 

Directors’ Report 

Report of the Audit Committee  

Independent Auditor’s Report 

Statement of Financial Position 

Statement of Comprehensive Income 

Statement of Changes in Equity 

Statement of Cash Flows 

Notes to the Financial Statements

Appendix - Additional Information (Unaudited) 

Glossary of Terms 

PAGE

1-2

3-4

5-9

10-11

12-17

18

19-26

27-29

30-36

37

38-39

40

41

42-63

64

65-66

BAKER STEEL RESOURCES TRUST LIMITED

MANAGEMENT AND ADMINISTRATION 

DIRECTORS: 

REGISTERED OFFICE:

MANAGER: 

INVESTMENT MANAGER:

STOCKBROKERS:

SOLICITORS TO THE COMPANY:
(as to English law) 

ADVOCATES TO THE COMPANY:
(as to Guernsey law)  

Howard Myles (Chairman) 
Charles Hansard 
Fiona Perrott-Humphrey  
David Staples (retired 31 December 2022) 
John Falla (appointed 13 October 2022) 
(all of whom are non-executive and independent)

Arnold House 
St. Julian’s Avenue 
St. Peter Port 
Guernsey, GY1 3NF 
Channel Islands 

Baker Steel Capital Managers (Cayman) Limited 
PO Box 309 
George Town 
Grand Cayman KY1-1104 
Cayman Islands 

Baker Steel Capital Managers LLP* 
34 Dover Street 
London W1S 4NG 
United Kingdom 

Numis Securities Limited 
10 Paternoster Square 
London EC4M 7LT 
United Kingdom 

Norton Rose Fulbright LLP
3 More London Riverside 
London SE1 2AQ 
United Kingdom 

Mourant Ozanne 
Royal Chambers 
St Julian’s Avenue 
St Peter Port 
Guernsey GY1 4HP 
Channel Islands 

ADMINISTRATOR & COMPANY SECRETARY:

HSBC Securities Services (Guernsey) Limited 
Arnold House 
St. Julian’s Avenue 
St. Peter Port 
Guernsey GY1 3NF 
Channel Islands 

*  The  Investment  Manager  was  authorised  as  an  Alternative  Investment  Fund  Manager  (“AIFM”)  for  the  purpose  of  the 
Alternative Investment Fund Managers Directive (“AIFMD”) on 22 July 2014.   

1

BAKER STEEL RESOURCES TRUST LIMITED

MANAGEMENT AND ADMINISTRATION (CONTINUED) 

SUB-ADMINISTRATOR TO THE COMPANY:

HSBC Securities Services (Ireland) DAC  
1 Grand Canal Square 
Grand Canal Harbour 
Dublin 2 
Ireland 

CUSTODIAN TO THE COMPANY:

SAFEKEEPING AND MONITORING AGENT: 

AUDITOR: 

REGISTRAR: 

UK PAYING AGENT AND TRANSFER AGENT:  

RECEIVING AGENT:

PRINCIPAL BANKER:

HSBC Continental Europe 
1 Grand Canal Square 
Grand Canal Harbour 
Dublin 2 
Ireland 

HSBC Continental Europe 
1 Grand Canal Square 
Grand Canal Harbour 
Dublin 2 
Ireland 

BDO Limited 
P O Box 180  
Place du Pre 
Rue du Pre 
St. Peter Port 
Guernsey GY1 3LL 
Channel Islands

Computershare Investor Services (Jersey) Limited 
Queensway House 
Hilgrove Street 
St Helier 
JE11ES 
Jersey  

Computershare Investor Services (Jersey) Limited 
Queensway House 
Hilgrove Street 
St Helier 
JE11ES 
Jersey  

Computershare Investor Services (Jersey) Limited 
Queensway House 
Hilgrove Street 
St Helier 
JE11ES 
Jersey  

HSBC Bank plc 
8 Canada Square 
London E14 5HQ 
United Kingdom 

2

BAKER STEEL RESOURCES TRUST LIMITED

CHAIRMAN’S STATEMENT 
For the year ended 31 December 2022 

2022 was a difficult year for your Company with the NAV per share falling by 19.3% to 79.4 pence, versus a 10.2% rise in the 
EMIX  Global  Mining  Index  in  Sterling  terms.  This  divergence  in  performance  can  be  explained  mainly  by  the  difficulty 
experienced in financing new projects for junior mining development companies and the consequent effect on their valuations, 
as opposed to the EMIX Index which is dominated by much larger producers.  Following the invasion of Ukraine by Russia in 
February 2022, potential investors in mining companies became increasingly risk averse with regard to committing capital to the 
construction of new projects whilst existing producers benefitted from strong commodity prices largely as a result of supply 
chain-related disruption to supply.  

One bright point during 2022 was the sale of Bilboes Gold to AIM listed gold producer Caledonia Mining. The consideration 
comprised a  combination of equity and a  royalty stream,  which  was signed in July 2022 and completed on 6 January 2023. 
Caledonia’s  technical  team  has  demonstrated  its  ability  to  operate  successfully  in  Zimbabwe  having  recently  increased  the 
production capacity  at its Blanket  mine from 50,000 ounces to 80,000 ounces  gold per annum. The two teams have  already 
shown their ability to work together with the restart of oxide heap leach operations at Bilboes whilst Caledonia implements its 
plan to bring the larger sulphide ore reserve into production. Caledonia’s recent acquisition of the much earlier stage Motapa 
exploration project, which is contiguous to Bilboes, has the potential to double the resources of a combined project and to create 
a 300,000 ounce per annum gold operation in due course.  The financial structure of the acquisition by Caledonia has allowed 
your  Company  to  maintain  its  exposure  to  the  Bilboes  project  through  its  shareholding  in  Caledonia  and  the  royalty,  which 
together with the other royalties in the portfolio should form the basis of regular income stream in the future. 

Futura Resources received its Mining Licences from the Queensland Government in November 2022 but the financing of the 
development has taken longer than anticipated which is particularly frustrating at a time of high steel-making coal prices. When 
operating at full capacity, Futura’s two mines are projected to produce around 2 million tonnes of saleable product after washing 
and processing. Given a margin of some US$150 per tonne at current prices, this would mean the start-up capex of around US$35 
million could be repaid in under a year.  

CEMOS achieved its third year of profitable cement making operations in Morocco since commencing production. It has now 
acquired a second grinding line which will enable it to double production with ramp up expected in 2025. Technical and financial 
studies  were  also  undertaken  with  a  view  to  constructing  a  clinker  making  facility  sufficient  to  meet  CEMOS’s  internal 
requirements, which it is anticipated could significantly reduce current clinker costs from third party suppliers and thus enhance 
margins. A decision is likely in 2023. 

Tungsten West Plc successfully raised £35 million at its IPO in October 2021. Having signed a term sheet for a royalty sale, 
which together with the funds raised from the IPO should have provided it with sufficient capital to redevelop the Hemerdon 
tungsten mine in Devon, it nevertheless had to pause the redevelopment in the face of soaring energy prices. In the circumstances 
it therefore reconfigured its ore processing design to consume significantly less energy and lower both operating and capital 
requirements.  This  has  culminated  in  a  revised  Feasibility  Study  the  results  of  which  were  released  in  January  2023.  The 
economics of the new study demonstrated an acceptable post-tax Net Present Value (NPV5%) of £297 million with an Internal 
Rate of Return (IRR) of 25%. However, during the delay, the share price of Tungsten West fell substantially such that raising 
finance for the redevelopment of Hemerdon has become increasingly difficult. The Company is therefore planning to support an 
interim financing announced in early April 2023 to provide time to put together the full financing package 

In April 2022, First Tin PLC completed a successful IPO, raising the £20 million needed to undertake feasibility studies on both 
its two key tin projects Tellerhäuser in Germany and Taronga in Australia. These studies are expected to be completed in late 
2023/early 2024 at which point we will have a much better indication of which of the two projects should be prioritised. Although 
world tin prices and the performance of First Tin shares have been disappointing, there is significant optionality built into these 
projects to capitalise on an improvement in market sentiment should it occur. We recognise the commodity’s attractions given 
its critical requirement as solder in the structural electrification trend. 

During 2022, Nussir also sought to raise the finance to develop its fully electrified copper project in northern Norway. Although 
good  interest  was  generated,  Nussir  ran  into  the  same  difficulty  in  completing  the  financing  that  other  single  project  junior 
companies have experienced as discussed above. It has therefore engaged an investment bank to investigate a sale or merger of 
the company with an existing producer. We would hope that any transaction would be similar to that of Bilboes and that we can 
therefore retain some exposure to the project. 

Although the current risk aversion of banks and other financiers to providing capital for the development of mining assets is 
proving challenging in terms of value realisation for the Company, experience suggests that these periods are usually transitory. 
We believe that in due course the global economy will need these minerals in large quantities and in order to satisfy this demand 
new mines will have to be discovered, developed and brought into production. It is therefore important to adopt a careful and 
measured approach during these periods in order to seek to ensure that the latent value in the projects in which we are invested 
is maintained.

3

BAKER STEEL RESOURCES TRUST LIMITED

CHAIRMAN’S STATEMENT (CONTINUED) 
For the year ended 31 December 2022 

Outlook 
The  outlook  for  2023  for  mining  is  expected  to  remain  challenging  with  uncertainty  about  the  macro-economic  and  global 
geopolitical situation continuing to encourage investors to remain risk averse and thus creating a difficult environment for raising 
development capital. However, we are beginning to see major mining companies building up mergers and acquisition teams 
which may lead to increased activity in the junior space. The structural case for those metals and commodities essential for the 
electrification and decarbonisation trends continues to strengthen and was considerably boosted by the Inflation Reduction Act 
under the Biden Administration. The longer-term and geopolitical consequences of the war in Ukraine as yet remain unclear; 
however, deglobalisation and security of-supply themes are likely to gain traction and underpin commodity prices in the longer 
term. 

At the year end, your Company’s portfolio consisted of 19.2% (31 December 2021: 18.0%) listed equity, 63.1% (31 December 
2021:  65.2%)  unlisted  equity  and  convertible  loans  and  17.5%  (31  December  2021:  15.7%)  royalty  interests  with  0.2%(31 
December 2021: 1.1%) net cash and receivables with no gearing. The listed equity and royalty interests have since been increased 
by the conversion of Bilboes Gold into listed Caledonia Mining and the royalty. On 31st December 2022, the share price traded 
at a 44% discount to the NAV at that date and continues to be monitored by the Board. It is hoped that dividends generated from 
the regular income to be provided by the royalties will help to reduce this discount in the future.  

On 31st December 2022, David Staples retired as a director and I would like to reiterate my thanks for his invaluable contribution 
to the Board. We welcomed John Falla to the Board as a non-executive director in October 2022. John qualified as a chartered 
accountant with Ernst and Young in London, before transferring to its Corporate Finance Department. His specialist knowledge 
in the valuation of unquoted securities will be of particular value as Chairman of the Audit Committee. 

Howard Myles 
Chairman 
21 April 2023 

4

BAKER STEEL RESOURCES TRUST LIMITED

INVESTMENT MANAGER’S REPORT 
For the year ended 31 December 2022 

Financial Performance 

The audited Net Asset Value per Ordinary Share (“NAV”) as at 31 December 2022 was 79.4 pence, a decrease of 19.3% in the 
year compared with the increase in the EMIX Global Mining Index of 10.2% in Sterling terms. 

For the purpose of calculating the NAV per share, unquoted investments were carried at fair value as at 31 December 2022 as 
determined by the Directors and quoted investments were carried at their quoted prices as that date. 

Net assets at 31 December 2022 comprised the following: 

Unquoted Investments 
Quoted Investments 
Cash and other net assets 

Investment Update 

Largest 10 Holdings – 31 December 2022 
Futura Resources Limited 
Cemos Group Plc 
Bilboes Gold Limited 
Kanga Investments Limited 
Tungsten West Plc 
Silver X Mining Corporation 
First Tin Plc 
Nussir ASA
Metals Exploration plc 
PRISM Diversified Limited 

Other Investments  
Cash and other net assets 

Largest 10 Holdings – 31 December 2021 
Cemos Group Plc
Futura Resources Limited 
Tungsten West Plc 
Bilboes Gold Limited 
First Tin Limited (previously Anglo Saxony Mining Limited) 
Polar Acquisition Limited 
Kanga Potash (previously Sarmin Minerals Exploration) 
Nussir ASA
Silver X Mining Corporation (previously Mines & Metals Trading (Peru) Plc 
Azarga Metals Corporation 

Other Investments  
Cash and other net assets 

5

 £m 
68.1 
16.2 
0.2 
84.5 

  % net assets
80.6 
19.2 
0.2 
100.0 

% of NAV 
27.7 
22.8 
16.2 
5.7 
5.4 
5.4 
4.8 
4.1 
1.7 
1.5 
95.3 
4.5 
0.2 
100.0 

% of NAV 
 18.6 
 18.1 
 14.7 
 13.0 
 7.7 
 7.5 
 4.1 
 3.6 
2.8 
 2.4 
92.5 
 6.4 
 1.1 
100.0 

 
 
 
 
BAKER STEEL RESOURCES TRUST LIMITED

INVESTMENT MANAGER’S REPORT (CONTINUED) 
For the year ended 31 December 2022 

Review 

At the year end, the Company was fully invested, holding 20 investments of which the top 10 holdings comprised 95% of the 
portfolio by value. The portfolio is well diversified both in terms of commodity and the geographical location of the projects. In 
terms of commodity the portfolio has exposure to cement, copper, gold, iron, lead, lithium, potash, silver, steel making coal, tin, 
tungsten, vanadium, and zinc. Its projects are located in Australia, Canada, Germany, Indonesia, Madagascar, Morocco, Norway, 
Peru, the Philippines, Republic of Congo, Russia, South Africa, the UK and Zimbabwe.  

During the year, mining market performance showed significant diversity by commodity with overall the EMIX Global Mining 
Index ending the year up 10.2% in Sterling terms. Precious metals were volatile but were flat over the year with gold down 0.3% 
and silver up 2.8% in US Dollars. After a strong 2021, metals required for the electrification of the world’s infrastructure fell 
back on global recessionary concerns with copper falling 14.1% during the year and tin falling 37.1% having almost doubled in 
2020 (all in US dollars). Steel making coal gave back some of its 252% gain in 2021, falling 17.6% with iron ore also falling 
some 7.4% during 2022. Likewise, potash fell back 39.8% but still remained almost double the price at the end of 2020.  

The Company’s NAV fell 19.3% during the year primarily due to the reduction in carrying value of Polar Acquisition Limited 
following the invasion of Ukraine and falls in the quoted prices of Tungsten West, First Tin and Azarga Metals Corporation. 

The Company’s main investments at the year-end: 

Futura Resources Ltd (“Futura”)
Futura  owns  the  Wilton  and  Fairhill  steel  making  coal  projects  in  the  Bowen  Basin  in  Queensland,  Australia  which  hold 
Measured and Indicated resources of 843 million tonnes of coal.  

Investment:  

11,309,005 ordinary shares (26.9%) valued at £9.6 million 
1.5% Gross Revenue Royalty valued at £13.7 million 
A$300,000 million bridging loan valued at £0.14 million 

During the year Futura sought to finance the start-up of its two steel making coal mines Wilton and Fairhill to take advantage of 
historically high coal prices. This was not assisted by the Queensland government unexpectedly introducing higher royalties at 
high coal prices. The effect of these additional royalties is not material to asset valuation at the long-term consensus pricing used 
in  Futura’s  economic  model  but  it  was  a  sufficient  shock  to  the  market  for  potential  investors  to  pause  the  process.  A  pre-
condition of all the financing proposals being discussed was receipt of the mining licences for both projects which were awarded 
on  23  November  2022.  Financing  discussions  are  continuing,  with  mining  able  to  commence  approximately  three  months 
following closing given the existing agreement in place for the coal to be processed at the nearby Gregory Crinum wash plant. 
Once in full production the mines are scheduled to produce around 2 million tonnes of coal per year at a cost of around US$70 
per tonne. During the year the Company converted a bridging loan it had extended to Futura, thereby increasing its gross revenue 
royalties over both mines from 1% to 1.5% in addition to its ownership of approximately 27% of Futura. 

Cemos Group plc (‘‘Cemos’’) 
Cemos is a private cement producer at Tarfaya in Morocco.  

Investment:  

24,004,167 ordinary shares (24.6%) valued at £9.2 million 
1,045 Convertible Loan Units valued at £10.1 million 
Percentage of Company owned at full conversion 31.6% 

During 2022, Cemos Group  PLC continued profitable operations  selling  202,000 tonnes of cement  from  its cement  plant in 
Morocco. This was approximately 14% lower than the previous year due to difficulty in sourcing local clinker earlier in the year 
together with lower demand in the local market later in the year. Unaudited EBITDA for 2022 was still estimated at a healthy 
€8 million albeit around 14% lower than 2021. After successful establishment of its first cement plant Cemos is planning an 
expansion and has acquired a second grinding plant identical to the existing operation which will allow it to double its production. 
It is also undertaking a feasibility study into the production of its own clinker, the main raw material in cement production, which 
will not only provide security of supply but has the potential to further increase  margins. Cemos is also testing potential for 
manufacture of ‘green cement’ products by replacing some clinker in the production process with more environmentally friendly 
supplementary cementitious materials such as pozzolan which would not only reduce the CO2 footprint of the operation but may 
also have a positive impact on costs. 

6

BAKER STEEL RESOURCES TRUST LIMITED

INVESTMENT MANAGER’S REPORT (CONTINUED) 
For the year ended 31 December 2022 

Bilboes Gold Limited ("Bilboes")  
The Bilboes’ gold project in Zimbabwe has a JORC compliant Proved and Probable Reserve containing 1.8 million ounces of 
gold  out  of  a  total  Mineral  Resource  of  3.8  million  ounces  of  gold.  Following  its  acquisition  in  January  2023,  Bilboes  is  a 
subsidiary of Caledonia Mining Corporation Plc. 

Investment:  

535,943 ordinary shares (24.2%) valued at £13.7 million  

In July 2022, the Company announced the sale of Bilboes Gold to Caledonia Mining Corporation Plc which is a NYSE, AIM 
and Victoria Falls Exchange listed gold producer whose primary asset is the Blanket Mine in Zimbabwe currently producing at 
the rate of 80,000 ounces of gold per annum. The transaction closed on 6 January 2023 so the investment is still shown as Bilboes 
Gold at the year-end though the Company now holds a 1% Net Smelter Royalty over the Bilboes properties together with shares 
in  Caledonia.  Caledonia  has  indicated  that  it  will  re-engineer  the  Bilboes  feasibility  study  which  outlined  production  of  an 
average of 168,000 ounces per annum over 10 years, to a phased development approach which would lower up-front capital. It 
has already moved forward with recommencing gold production at Bilboes from near surface oxide ores which should not only 
generate  additional  cash  but  will  have  the  benefit  of  pre-stripping  for  the  underlying  sulphide  project,  thus  accelerating  its 
development. The recent acquisition by Caledonia of the Motapa exploration ground, contiguous to Bilboes’s properties, is an 
important  strategic  addition  to  the  project.  It  had  been  tracked  by  the  Bilboes  management  team  for  some  time  as  initial 
exploration on Motapa was undertaken by Anglo American when it owned Bilboes and additional resources at Motapa could 
both expand and extend the life of the Bilboes project. 

Kanga Investments Ltd (“Kanga”) 
Kanga is a private company which holds the Kanga potash project, in the Republic of the Congo. 

Investment:  

56,042 ordinary shares (6.6%) valued at £4.8 million 

Kanga Investments Ltd (“Kanga”) completed a positive Definitive Feasibility Study (“DFS”) in 2020 on its Kanga Potash project 
in the Republic of Congo for a mine producing 600,000 tonnes per annum of Muriate of Phosphate (“MOP”). The DFS economic 
model gave a Net Present Value at a 10% discount rate (NPV10) of US$511 million with an IRR of 22% based on an MOP price 
of US$282 per tonne compared to the current price of around US$500 per tonne. In addition, there is potential for the mine to be 
expanded on a modular basis up to 2.4m tonnes per annum over 30 years as set out in the DFS. Kanga continues to have advanced 
discussions regarding the financing or sale of the project. In the second half of 2022 the government published a decree awarding 
the Kanga Exploitation/Mining Licence to Kanga, a key condition of the potential acquirors. 

Silver X Mining Corporation (“Silver X”)   
Silver X is a TSX-V listed company whose Recuperada project in Peru comprises 11,261 Ha of mining concessions centred 
around a 600 tonne per day processing plant.  

Investment:  

19,502,695 ordinary shares (12.5%) valued at £4.5 million 

During 2022, the Company’s convertible loan to Mines and Metals Trading Peru PLC was converted into equity of Silver X 
Mining Corporation, listed on the TSX-V exchange, and as a result became its largest shareholder. In the second half of the year 
Silver X successfully ramped up production to 673,458 ounces of silver equivalent at its Nueva Recuperada Silver mine in Peru, 
with  the  operation  turning  cashflow  positive.    In  February  2023  Silver  X  released  the  results  of  a  Preliminary  Economic 
Assessment (“PEA”) under Canadian National Instrument 43-101 Standards for the expansion of the Tangana Mining Unit at 
Nueva  Recuperada.  The  PEA  outlined  the  potential  to  treble  annual  production  to  4.2  million  ounces  silver  equivalent  by 
constructing an additional recovery plant at a capital cost of US$61 million to give a post-tax NPV10 of US$175 million. 

.  

7

BAKER STEEL RESOURCES TRUST LIMITED

INVESTMENT MANAGER’S REPORT (CONTINUED) 
For the year ended 31 December 2022 

Tungsten West Plc (‘‘Tungsten West’’) 
Tungsten West owns the Hemerdon Mine in Devon, United Kingdom and is quoted on the AIM market of the London Stock 
Exchange.  

Investment:  

28,846,515 ordinary shares (16.1%) valued at £4.3 million 
1,657,195 second options valued at £0.1 million 
1,657,195 third options valued at £0.1 million 

On 16 January 2023 Tungsten West announced the results of its updated feasibility study on the Hemerdon tungsten and tin mine 
in  Devon.  The  feasibility  study  detailed  a  mine  with  average  annual  production  of  2,900  tonnes  of  tungsten  (WO3) and  310 
tonnes of tin in concentrate over 27 years. The economics showed a post-tax NPV5 of £297 million with an Internal Rate of 
Return  (IRR)  of  25%.  It  also  highlighted  an  Upside  Case  post-tax  NPV5 of  £416  million with  an  IRR  of  32%.  Total  pre-
production capex, corporate commitments and working capital was estimated at £54.9 million. Key to the improved economics, 
following a reworking of the development plan due to higher energy costs, has been a complete redesign of the front-end crushing 
circuit which has considerably reduced capex.  Optimisation of ore-sorting parameters has significantly reduced opex by allowing 
the  re-purposing of the dense  media separation circuits and the  removal  of the refinery kiln from  the  circuit reducing diesel 
consumption by 1.3 million litres per annum.  Tungsten West is in the process of raising up to £8.95 million in convertible debt 
and equity whilst it finalises the finance for the redevelopment of Hemerdon. 

First Tin PLC (“First Tin”)  
First Tin is a company listed on the London Stock Exchange which owns the Tellerhäuser and Gottesburg tin projects in Germany 
and the Taronga tin project in Australia. Combined contained tin for the three projects totals 143,000 tonnes.  

Investment:  

37,128,014 ordinary shares (14.0%) valued at £4.1 million 

In April 2022 First Tin PLC completed a successful IPO, raising the £20 million required to undertake feasibility studies on both 
its two key tin projects, Tellerhäuser in Germany and Taronga in Australia.  Progress at Taronga is particularly promising with 
drilling outlining a 350 metre extension to the current resource area. This will be followed up by First Tin and has the potential 
to increase the previously suggested production rate at Taronga once incorporated in the Feasibility Study on the project. The 
price of tin has been extremely volatile over the past 12 months though consensus analysis suggests strong future demand given 
that tin will be an important component of the global trend towards electrification. At the time of listing the economic models in 
the pre-feasibility studies, using a US$30,000 per tonne price assumption for tin on the two projects, together totalled a pre-tax 
NPV8 of US$433 million. The price of tin during 2022 was volatile, ranging between US$18,000/tonne and US$46,000/tonne. 
The Feasibility Study on Taronga due to be completed before the end of 2023 and that on Tellerhäuser in 2024 will provide a 
more accurate and up to date reflection of value. 

Nussir ASA ("Nussir") 
Nussir is a Norwegian private company whose key asset is the Nussir copper project in Northern Norway.  

Investment:  

12,785,361 ordinary shares (12.1%) valued at £3.5 million 

In  early  2022  Nussir  reconfigured  its  2021  DFS  on  its  Nussir  copper  project  in  northern  Norway  to  a  fully  electrified  mine 
producing around 14,000 tonnes of copper per year over a 14-year mine life. This has since been reoptimized and updated and 
is expected to be completed in the second quarter of 2023. Following this Nussir will seek to attract an industry partner to assist 
with financing the development of the mine. 

Metals Exploration plc (“Metals Exploration”) 
Metals Exploration is an AIM listed company which owns the Runruno gold mine in the Philippines.  

Investment:  

112,510,000 ordinary shares (5.4%) valued at £1.4 million 

Metals Exploration plc produced 72,537 ounces of gold in 2022 from its Runruno gold mine in the Philippines and paid off its 
senior debt which allowed for conversion of its remaining high interest mezzanine debt into new lower interest senior debt.  

8

BAKER STEEL RESOURCES TRUST LIMITED

INVESTMENT MANAGER’S REPORT (CONTINUED) 
For the year ended 31 December 2022 

Polar Acquisition Limited ("PAL") 
PAL is a private company  which holds a 1.8% to 0.9% (reducing over 10 years) net  smelter royalty over the Prognoz silver 
project ("Prognoz"), 444km north of Yakutsk in Russia, owned by Polymetal. Prognoz has a 267-million-ounce silver equivalent 
Indicated and Inferred Mineral Resource at a grade of 755 g/t silver equivalent.  

Investment:  

16,352 ordinary shares (49.99%) valued at £1.1 million 

Polymetal International PLC, the owner of the Prognoz silver project net smelter royalty, advised in January 2023 that the mine 
development was progressing on schedule  with  mining due to commence in late 2023 with ore to be shipped to Polymetal’s 
Nezhda mine concentrator on the winter road during the first half of 2024. As a result of the invasion of Ukraine by Russia in 
February 2022 the carrying value of PAL has been reduced by 86.2%.  Although none of the parties are presently sanctioned 
and legal advice is that PAL is currently able to receive the royalty, the Company is cognisant of the issues surrounding political 
sanctions affecting Russian investments and appreciates that the situation is continually changing. Despite the underlying Russian 
operating company acknowledging that it has a contractual obligation to pay the royalty, the sanctions regime may also change 
and there is a risk that financial institutions may not be willing to process bank transfers with contractual parties.  It is therefore 
possible that the royalty stream might be delayed, frozen, or never received.  

Outlook 

The invasion of Ukraine by Russia during 2022 led to higher energy prices, inflation and the advent of rising interest rates, which 
have impacted the  mining industry during 2022. The consequent disruption in availability of financing particularly impacted 
junior companies with development projects. Inflationary increases in key energy price costs have also meant companies have 
had to refresh their feasibility studies as they have quickly become outdated. Higher interest rates have increased the discount 
rates that investors apply when evaluating new mining projects thereby reducing valuations. Although we expect inflation and 
interest rates are  likely to peak in 2023, economic  and geopolitical  uncertainties  may  well persist and continue to  weigh on 
investor confidence during the year and possibly beyond. More optimistically, the hiatus in new mine developments is likely to 
lead to sustained higher commodity prices as the world will require the metals to meet the considerable demands of the global 
energy transition and potential rebuilding of Ukraine. This will be against the possible backdrop of some government stockpiling 
of strategic metals in a deglobalising world where security of supply chains has become of national interest.  

Baker Steel Capital Managers LLP 
Investment Manager
April 2023

9

BAKER STEEL RESOURCES TRUST LIMITED

PORTFOLIO STATEMENT 
AT 31 DECEMBER 2022 

Investments 

Shares 
/Warrants/ 
Nominal 

Listed equity shares

Australian Dollars 

4,091,910  Akora Resources Limited 
4,170,600  Resolute Mining Limited 

409,000  St Barbara Limited 

Australian Dollars Total 

Canadian Dollars 

65,193,952  Azarga Metals Corporation 
19,502,695  Silver X Mining Corporation 

Canadian Dollars Total 

Great Britain Pounds 

37,128,014  First Tin Plc 

112,510,000  Metals Exploration plc 

17,000  Polymetal International Plc 

28,846,515  Tungsten West Plc 

Great Britain Pounds Total 

Total investment in listed equity shares 

Debt instruments

Australian Dollars

300,000  Futura Resources Limited – Bridging Loan 

Australian Dollars Total 

Canadian Dollars 

305,000  PRISM Diversified Limited Loan Note 1 
250,500  PRISM Diversified Limited Loan Note 2 

Canadian Dollars Total 

Euro 

1,045  Cemos Group Plc 

Euros Total 

United States Dollars 
26,301  Bilboes Gold Limited 

7,028,352  Black Pearl Limited Partnership 

United States Dollars Total 

Fair value 
£ equivalent 

% of Net 
assets 

380,826 
470,484 
178,789 

1,030,099 

749,655 
4,544,972 

5,294,627 

4,054,778 
1,434,503 
41,735 
4,326,977 

9,857,993 

16,182,719 

137,764 

137,764 

92,457 
294,592 

387,049 

10,088,046 

10,088,046 

25,090 
726,171 

751,261 

0.45 
0.56 
0.21 

1.22 

0.89 
5.38 

6.27 

4.80 
1.70 
0.05 
5.12 

11.67 

19.16 

0.16 

0.16 

0.11 
0.35 

0.46 

11.94 

11.94 

0.03 
0.86 

0.89 

Total investments in debt instruments 

 11,364,120 

 13.45 

10

 
Fair value 
£ equivalent 

% of Net 
assets 

BAKER STEEL RESOURCES TRUST LIMITED

PORTFOLIO STATEMENT (CONTINUED) 
AT 31 DECEMBER 2022 

Investments

Shares 
/Warrants/ 
Nominal 

  Unlisted equity shares, warrants and royalties

Australian Dollars 

 10,100,000  Futura Gross Revenue Royalty 
 11,309,005  Futura Resources Limited 

Australian Dollars Total 

Canadian Dollars 

6,666,666  Azarga Metals Warrants 09/05/2025 

13,083,936  PRISM Diversified Limited 

40,000  PRISM Diversified Limited – Royalty 

1,000,000  PRISM Diversified Limited Warrants 31/12/2023 

324,000  Unkur Option Warrants 12/31/2023 

Canadian Dollars Total 

Great Britain Pounds 

 1,594,646  Celadon Mining Limited 

 24,004,167  Cemos Group Plc 

 1,657,195  Tungsten West Plc Second Option Share Warrants 18/10/2026 
 1,657,195  Tungsten West Plc Third Option Share Warrants 18/10/2026 

Great Britain Pounds Total 

Norwegian Krone 

 12,785,361  Nussir ASA 

Norwegian Krone Total 

United States Dollars 
535,943  Bilboes Gold Limited 

56,042  Kanga Investments Limited
16,352  Polar Acquisition Limited

United States Dollars Total 

 13,700,733 
 9,568,238 

 23,268,971 

12,692
802,401
24,531 
23,261 
198,700 

1,061,585 

 15,945
 9,201,855 
 129,261 
 77,557 

 9,424,618 

 3,499,979 

 3,499,979 

13,650,910 
4,775,628
1,083,425 

19,509,963 

Total Unlisted equity shares, warrants and royalties 

 56,765,116 

Financial assets held at fair value through profit or loss 

 84,311,955 

Other Assets & Liabilities 

 170,893 

Total Equity 

 84,482,848 

 100.00 

11

 16.22 
 11.33 

 27.55 

0.02
0.95
0.03 
0.03 
0.24 

1.27 

 0.02 
 10.89 
 0.15 
 0.09 

 11.15 

 4.14 

 4.14 

16.16 
5.65
1.28 

 23.09 

 67.20 

 99.81 

 0.19 

BAKER STEEL RESOURCES TRUST LIMITED

STRATEGIC REPORT 

Company Structure 
The Company is a registered closed-ended investment scheme registered pursuant to the Protection of Investors (Bailiwick of 
Guernsey) Law, 2020 (“POI Law”) and the Registered Collective Investment Scheme Rules and Guidance, 2021 issued by the 
Guernsey Financial Services Commission (“GFSC”). The Company is not authorised or regulated as a collective investment 
scheme by the Financial Conduct Authority. The Company is subject to the Listing Rules and the Disclosure and Transparency 
Rules of the UK Listing Authority.  

The Articles of the Company contain provisions as to the life of the Company. At the Annual General Meeting (“AGM”) falling 
in 2018 and at each third AGM convened by the Board thereafter, the Board will propose a special resolution to discontinue (the 
Company) which if passed will require the Directors, within 6 months of the passing of the special resolution, to submit proposals 
to shareholders that will provide shareholders with an opportunity to realise the value of their Ordinary Shares. Shareholders 
voted against discontinuing the Company at the 2021 AGM and the next discontinuation vote will be held at the AGM in 2024 
which is expected to be held in the third quarter of that year. 

Company Purpose and Values 
The purpose of the Company is to carry out business as an investment company and to provide returns to shareholders through 
achieving its investment objective as described on page 13.  

The values of the Company are discussed and agreed upon by the Board. The Board seeks to run the Company with a culture of 
openness, high integrity and accountability. It aims to demonstrate these values through its behaviour both within itself and its 
dealings with its stakeholders. It seeks to act in the spirit of mutual respect, trust and fairness. The Board is robust in its challenge 
of the Investment Manager and other service providers but tries always to be constructive and collegiate. The Board expects its 
members  to  exhibit  an  independence  of  mind  and  not  to  be  wary  of  asking  difficult  questions.  Moreover,  it  expects  and 
encourages its key service providers to exhibit similar values. 

Role and Composition of the Board 
The Board is the Company’s governing body; it sets the Company’s strategy and is collectively responsible for its long-term 
performance. The Board, which is comprised entirely of independent Non-Executive Directors, is responsible for appointing and 
subsequently monitoring the activities of the Manager and other service providers to ensure that the investment objectives of the 
Company continue to be met. The Board also ensures that the Manager adheres to the investment restrictions described in the 
Company’s Prospectus and acts within the parameters set by it in any other respect. It also identifies and monitors the key risks 
facing the Company. 

Investment activities are predominantly monitored through quarterly Board meetings at which the Board receives detailed reports 
and  updates  from  the  Investment  Manager,  who  attends  each  Board  meeting.  Services  from  other  key  service  providers  are 
reviewed as appropriate.  

Subject to meeting solvency requirements, if the Ordinary Shares trade at a discount in excess of 15 per cent to their NAV, the 
Board will consider whether the Company should buy back its own Ordinary Shares, taking into account the Company’s liquidity, 
conditions in the stock market and mining markets. At the year-end the Company’s Ordinary shares traded at a discount to NAV 
of 44%, however the Directors consider that the Company does not currently have sufficient surplus funds to buy back shares, 
irrespective of other considerations such as long term market liquidity and the effect on its Ongoing Charges Ratio. 

The Board continues to review the Company’s expenditure to ensure that the total costs incurred in the running of the Company 
remain  competitive.  An  analysis  of  the  Company’s  costs,  including  management  fees  (which  are  based  on  the  market 
capitalisation of the Company), Directors’ fees and general expenses, is submitted to each Board meeting. 

As at 31 December 2022, the Board comprised four Directors (2021: four), excluding David Staples who retired from the Board 
on 31 December 2022. 

Investment Management 
The Manager was appointed pursuant to a management agreement with the Company dated 31 March 2010 (the Management 
Agreement). Under the Management Agreement, the Manager acts as manager of the Company, subject to the overall control 
and supervision of the Directors and was authorised to appoint the Investment Manager to manage and invest the assets of the 
Company.  The  Manager  is  responsible  for  the  payment  of  the  fees  of  the  Investment  Manager.  The  Manager  is  a  company 
incorporated in the  Cayman  Islands on 10  April 2002 with registration number 117030 and is an  affiliate  of the  Investment 
Manager. 

Baker Steel Capital Managers LLP acts as Investment Manager of the Company and was constituted in England and Wales on 
19 December 2001. It is authorised and regulated by the Financial Conduct Authority in the United Kingdom. The Investment 
Manager is a limited liability partnership with registration number OC301191 and is an affiliate of the Manager. The Investment 
Manager has been appointed by the Company to act as its Alternative Investment Fund Manager (“AIFM”) and is responsible 
for the portfolio management and investment risk management of the Company. The Investment Manager manages the Company 
in accordance with the Alternative Investment Fund Managers Directives (“AIFMD”). The Investment Manager is a specialist 
natural resources asset management and advisory firm operating from its head office in London and its branch office in Sydney.  
12

BAKER STEEL RESOURCES TRUST LIMITED

STRATEGIC REPORT (CONTINUED) 

Investment Management (continued) 
It has an experienced team of fund managers covering the precious metals, base metals and minerals sectors worldwide, both in 
relation to commodity equities and the commodities themselves. 

The  Directors  formally  review  the  performance  of  the  Investment  Manager  on  an  annual  basis  and  remain  satisfied  that  the 
Investment Manager has the appropriate resources and expertise to manage the portfolio of the Company in the best interests of 
the Company and its shareholders. 

Investment Objective  
The Company’s investment objective is to seek capital growth over the long-term through a focused, global portfolio consisting 
principally of the equities, loans or related instruments of natural resources companies. The Company invests predominantly in 
unlisted companies (i.e. those companies that have not yet made an initial public offering (“IPO”) but also in listed securities 
(including special situations opportunities and less liquid securities) with a view to making attractive investment returns through 
the uplift in value resulting from the development progression of the investee companies’ projects and through exploiting value 
inherent in market inefficiencies and pricing anomalies.  

Investment Policy  
The  core  of the  Company’s  strategy is to invest in natural  resources companies,  predominantly  unlisted, that  the  Investment 
Manager  considers  to  be  undervalued  and  that  have  strong  fundamentals  and  attractive  growth  prospects.  Natural  resources 
companies, for the purposes of the investment policy, are those involved in the exploration for and production of base metals, 
precious metals, bulk commodities, thermal and metallurgical coals, industrial minerals and energy, and include single-asset as 
well as diversified natural resources companies. 

It is intended that unlisted investments be realised through an IPO, trade sale, management repurchase or other methods. 

The Company focuses primarily on making investments in companies with producing and/or tangible assets such as resources 
and reserves that have been verified under internationally recognised standards for reporting, such as those of the Australasian 
Joint Ore Reserves Committee (“JORC”). The Company may also invest from time to time in exploration companies whose 
activities are speculative by nature.  

The Company has flexibility to invest in a wide range of investments in addition to unlisted and listed equities and equity-related 
securities, including but not limited to commodities, convertible bonds, debt securities, royalties, options, warrants and futures. 
Derivatives may be used for efficient portfolio management, hedging and for the purposes of obtaining investment exposure. 
The Company may also have exposure from time to time to other companies within the wider resources and materials sector, 
including services companies, transport and infrastructure companies, utilities and downstream processing companies. 

The  Company  may  take  legal  or  management  control  of  a  company  from  time  to  time.  The  Company  may  invest  in  other 
investment funds or vehicles, including any managed by the Manager or Investment Manager, where such investment would be 
complementary to the Company’s investment objective and policy. 

Borrowing and Leverage 
The Company may, at the discretion of the Investment Manager and within limits set by the Board, incur leverage for liquidity 
purposes  by  borrowing  funds  from  banks,  broker-dealers  or  other  financial  institutions  or  entities.  The  costs  and  impact  of 
leverage, positive and negative, will affect the operating results of the Company. 

During the current and prior year, no leverage was used by the Company. 

Investment Restrictions  
There are no fixed limits on the allocation between unlisted and listed equities or equity-related securities and cash although, as 
a guideline, typically the Investment Manager will aim for the Company to be invested over the long-term as follows: 

• 
• 
• 
• 

between 40 and 100 per cent of the value of its gross assets in unlisted equities or equity-related securities; 
up to 50 per cent of the value of its gross assets in listed equities or equity-related securities; 
up to 10 per cent of the value of its gross assets in cash or cash-like holdings; and 
in 10 to 20 core positions to provide adequate diversification whilst retaining a focused core approach. Core positions will 
be between 5 per cent and 15 per cent of NAV as at the date of acquisition. 

The actual percentage of the Company’s gross assets invested in listed and unlisted equities and equity-related securities and 
cash and cash-like holdings and the number of positions held may fall outside these ranges from time to time. The portfolio may 
become focussed on fewer holdings as certain investments mature and increase in value. Once such investments are realised it 
is intended that the consideration will be reinvested in several new investments thereby diversifying the portfolio. 

13

BAKER STEEL RESOURCES TRUST LIMITED

STRATEGIC REPORT (CONTINUED) 

Investment Restrictions (continued)
Listed securities might exceed the above guideline following a significant number of IPOs or in certain market conditions and 
likewise cash balances may exceed the above guideline following the realisation of one or more investments or following the 
issue of new equity in the Company, pending investment or distribution of the proceeds. 

The investment policy has the following limits: 

• 

•

Save in respect of cash and cash-like holdings awaiting investment, and except as set out below, the Company will invest 
or lend no more than 20 per cent in aggregate of the value of its gross assets in or to any one particular company or group 
of companies, as at the date of the relevant transaction.  

The Company's investment in Futura Resources Limited (“Futura”) may exceed the limit set out above provided that the 
Company will not invest or lend more than 35 per cent in aggregate of the value of its gross assets in Futura as at the date 
of the relevant transaction. 

•  No more than 10 per cent in aggregate of the value of the gross assets of the Company may be invested in other listed 
closed-ended investment funds, except for those which themselves have stated investment strategies to invest no more 
than 15 per cent of their gross assets in other listed closed-ended investment funds. 

Where  derivatives  are  used  for  investment  exposure,  these  limits  will  be  applied  in  respect  of  the  investment  exposures  so 
obtained.  

The Company will avoid (a) cross-financing between the businesses forming part of its investment portfolio and (b) the operation 
of common treasury functions between it and the investee companies. When deemed appropriate, the Company may borrow up 
to 10 per cent of NAV for temporary purposes such as settlement of mis-matches. Borrowings will not however be incurred for 
the purposes of any Share repurchases. Any material change in the investment objective, investment policy or borrowing policy 
will only be made with the prior approval of holders of Ordinary Shares by Ordinary Resolution. In the event of any breach of 
the investment restrictions the Investment Manager would report the breach to the Board and shareholders would be informed 
of any corrective action required.  

No breaches of investment restrictions occurred during the year ended 31 December 2022. 

Hedging 
The Investment Manager will not normally hedge the exposure of the Company to currency fluctuations. 

Performance 
The Company monitors NAV against the EMIX Global Mining Index as a key performance indicator. An outline of performance, 
market background, investment activity and portfolio strategy during the year under review, as well as outlook, is provided in the 
Chairman’s Statement on page 3 to 4 and the Investment Manager’s Report on pages 5 to 9. 

Principal risk and uncertainties
The Board is responsible for the Company’s system of risk management and internal control and for reviewing its effectiveness. 
The Board has adopted a detailed matrix of principal risks affecting the Company’s business as an investment company and has 
established associated policies and processes designed to manage and, where possible, mitigate those risks, which are monitored 
by the Audit Committee on an ongoing basis. This system assists the board in determining the nature and extent of the risks it is 
willing to take in achieving the Company’s strategic objectives.  

Although the Board believes that it has a robust framework of internal controls in place this can provide only reasonable, and 
not absolute, assurance against material financial misstatement or loss and is designed to manage, not eliminate, risk. Actions 
taken  by  the  Board  and,  where  appropriate,  its  committees,  to  manage  and  mitigate  the  Company’s  principal  risks  and 
uncertainties are discussed in more detail below.  

Emerging Risks and Uncertainties 
During the year, the Board also discussed and monitored a number of risks that could potentially impact the Company’s ability 
to meet its strategic objectives. The principal emerging risk continues to be climate change. Climate change risk includes how 
climate change could affect the Company’s investments, and potentially shareholder returns.  The Board has implemented an 
ESG policy which has been developed from the Manager’s own ESG policy. The Company’s ESG policy is available on its 
website.  

The Board will continue to monitor the growing risks identified by ESG and the resulting pressures on its investments. 

14

BAKER STEEL RESOURCES TRUST LIMITED

STRATEGIC REPORT (CONTINUED) 

Principal risk and uncertainties (continued) 
Emerging Risks and Uncertainties (continued) 
The invasion of Ukraine and resulting sanctions on Russia, has increased the risk of investing in companies with interests in 
Russia.  It  has  also  increased  the  uncertainty  around  previous  projections  made  by  those  companies,  in  the  face  of  growing 
financial  and  operational  constraints.  As  a  result,  the  Company  reduced  its  carrying  values  of  PAL  to  reflect  the  risk  that 
Polymetal may not be able to pay the royalty when due and the question of whether PAL is able to receive payments owing due 
to  potential  sanctions.  There  is  also  a  growing  risk  that  rising  energy  prices  and  disrupted  supply  chains  could  further  fuel 
inflationary  pressures.  This,  plus  more  aggressive  monetary  tightening  that  might  be  undertaken  by  central  banks  to  curb 
inflation, raises the risk of a global recession.    

There  is  a  growing  risk  that  measures  imposed  by  Governments  in  response  to  cost  of  living  challenges  will  impact  on  the 
Company’s investments, specifically price caps imposed by Governments may have implications on sales prices that the investee 
companies can achieve. 

Market and financial risks  
Market  risk  arises  from  volatility  in  the  prices  of  the  Company’s  underlying  investments  which,  in  view  of  the  Company’s 
investment policy, are in turn particularly sensitive to commodity prices. Market risk represents the potential loss the Company 
might suffer through holding investments in the face of negative market movements. The Board has set investment restrictions 
and guidelines to help mitigate this risk. These are monitored and reported on by the Investment Manager on a regular basis. 
Further details are disclosed in note 4 on pages 54 to 59. 

The Company’s investment activities also expose it to a variety of financial risks including in particular foreign currency risk. 
An analysis of sensitivity to foreign exchange is presented on pages 54-55. 

Portfolio management and Performance risks  
The  Board  is  responsible  for  determining  the  investment  strategy  to  allow  the  Company  to  fulfil  its  objectives  and  also  for 
monitoring the performance of the Investment Manager to which has been delegated day to day discretionary management of 
the Company’s portfolio. An inappropriate strategy may lead to poor performance. The investment policy of the Company allows 
for a highly focused portfolio which can lead to a concentration of risk. To manage this risk, the Investment Manager provides 
to the Board, on an ongoing basis, an explanation of the significant stock selection recommendations and the rationale for the 
composition of  the  investment portfolio. The Board mandates and  monitors an adequate diversification of  investments, both 
geographically and by commodity, in order to reduce the risks associated with particular sectors, based on the diversification 
requirements  inherent  in  the  Company’s  investment  policy.  The  nature  of  the  investment  strategy  means  that  portfolio 
diversification cannot be rebalanced on a short term basis.

The Company invests in certain companies whose projects are located in emerging markets. In such countries governments can 
exercise substantial influence over the private sector and political risk can be a significant factor. In adverse social and political 
circumstances, governments have been involved in policies of expropriation, confiscatory taxation, nationalisation, intervention 
in the securities markets and imposition of foreign exchange controls and investment restrictions. The Investment Manager and 
the  Board  take  into  account  specific  political  and  other  such  risks  through  its  approach  to  pricing  when  entering  into  an 
investment, and seek to mitigate them by diversifying geographically. 

The Company’s ability to implement its investment policy depends on the Investment Manager’s ability to identify, analyse and 
invest  in  investments  that  meet  the  Company’s  investment  criteria.  Failure  by  the  Investment  Manager  to  find  additional 
investment opportunities  meeting the  Company’s  investment objectives and to  manage  investments effectively could  have a 
material  adverse  effect  on  the  Company’s  business,  financial  condition,  and  results  of  operations.  The  Company  has  no 
employees and, subject to oversight by the Board, is reliant on the Investment Manager, which has significant discretion as to 
the implementation of the Company’s operating policies and strategies. The Company is subject to the risk that the Investment 
Manager or its key investment professionals will cease to be involved in the management of any part of the Company’s assets 
and that no suitable replacement will be found. The Board regularly monitors the performance and capabilities of the Investment 
Manager and its key man risk plans. 

There is the risk that the market capitalisation of the Company (on which the Investment Manager’s fee is calculated) falls to 
such an extent that it will no longer be viable for the Investment Manager to provide the services that it currently provides. The 
Board monitors this possibility and, should it start to become an issue, would review it with the Investment Manager. 

Risk of a vote to wind-up the Company 
The Articles contain provisions for a special resolution of shareholders at the AGM in 2018 and every three years thereafter 
on whether to discontinue the Company. Should there be a catastrophic loss of value in the Company’s assets, possibly as a 
result  of  the  risks  above,  or merely  a  change  in  sentiment  towards  the  mining  sector  generally  by  a  sufficient  proportion  of 
investors, there is the risk of shareholders voting to wind-up the Company at that time. Because the Company’s investments are 
largely unlisted it could then take a protracted amount of time to realise them or they may need to be sold at a discount to Fair 
Value if an accelerated timetable is required.  

15

BAKER STEEL RESOURCES TRUST LIMITED

STRATEGIC REPORT (CONTINUED) 

Risk of a vote to wind-up the Company (continued) 
To  be  passed  the  discontinuation  vote  would  require  a  majority  of  75%  of  those  shareholders  voting.  To  understand  the 
requirements of the Company’s major shareholders, the Investment Manager regularly liaises with the Company’s broker and 
meets major shareholders. The Chairman is also available to meet with shareholders as required.   

In the event of a winding up of the Company, Shareholders will rank behind any creditors of the Company. 

Viability Statement 
In accordance with provision 31 of the UK Corporate Governance Code, published by the Financial Reporting Council (“FRC”) 
in July 2018 (the “UK Code”), the Directors, as advised by the Audit Committee, have assessed the prospects of the Company 
over 3 years. The Board considers that this is an appropriate timeframe to assess the viability of the Company as, in relation to 
the types of investments the Company makes, three years generally provides sufficient time for major milestones to be reached 
on mining projects together with some realisations and new investments to be made by the Company. Beyond three years, the 
Board considers the mining and minerals markets to be too difficult to predict to be sufficiently helpful.   

The Company has previously seen pressures from falls in commodity prices and a move by its share price to an increased discount 
to its NAV. The mining market is inherently cyclical and dependent on world economic  output. Notwithstanding this, it is a 
feature of closed-ended investment companies such as BSRT that the greatest risk to viability is that the investments lose value 
to an extent where the expense ratio becomes excessive such that the Company becomes an unattractive investment proposition. 
In such conditions, it may also be a risk that liquidity (i.e. the ability to sell or realise cash from the portfolio, or raise borrowings 
should that be necessary) is insufficiently available to meet liabilities. 

In the case of the Company, which has no gearing, the Investment Manager has conducted stress and sensitivity tests of future 
income  and  expenditure  and  the  ability  to  realise  assets,  and  it  and  the  Board  have  concluded  that,  even  in  circumstances 
representing a deterioration in value of 50% of net assets and a complete inability to sell any of the unlisted assets in the portfolio, 
the Company should remain viable over a three-year period. The key factor in this assessment is that currently the Company’s 
greatest expense is the management fee which is calculated on the market capitalisation of the Company. Should net assets fall, 
market capitalisation would be expected to fall in line or at a higher rate, such that the costs of the Company would also fall. It 
is also assumed that the liquidity required over the three-year period and under the highly stressed conditions modelled, is largely 
provided by  regular  realisations  of  the  Company’s  listed  equities.  The  Directors believe  this  to  be  reasonable  given  that  the 
majority of these equities are traded at sufficient volumes in the context of the positions the Company’s holdings represent. 

As a result, the Board has 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. 

Environmental, Social and Governance 
The Company believes that monitoring environmental, social and governance (“ESG”) factors is important not only to support 
sustainable and ethical investment but because ESG considerations are key for creating and maintaining shareholder value. The 
Company has developed an ESG Investment Policy which draws from international best practice and builds upon the principles 
and  processes  outlined  in  the  United  Nations  Principles  for  Responsible  Investment,  of  which  the  Investment  Manager  is  a 
signatory. A copy of the Company’s ESG policy is available on the Company’s website. 

ESG considerations are considered as an enhanced risk  management tool and, as  such, are incorporated into the Investment 
Manager’s investment decision process at multiple levels during stock screening and company analysis, as well as being directly 
addressed with company management during meetings and on-site visits. The Company is an active investor and will use its 
voting rights to influence company direction in a sustainable way where deemed appropriate. The Company considers that social 
and environmental responsibility, along with good governance, are an integral element of running a successful mining company. 
For example, the Nussir copper project in Norway aims to become the first zero carbon mine globally through being fully electric 
with the electricity generated from entirely renewable sources. The Company has used its representation on the Board of Nussir 
to actively promote this evolution to electrification.    

Non-Mainstream Pooled Investment 
The Directors intend to operate the Company in such a  manner that its shares are not categorised as non-mainstream pooled 
investments. 

16

BAKER STEEL RESOURCES TRUST LIMITED

STRATEGIC REPORT (CONTINUED) 

Stakeholder Engagement 
During the year-ending 31 December 2022, the Board sought to voluntarily comply with the requirements of Section 172 of the 
Companies Act 2006 to promote the success of the Company for the benefit of its members as a whole, having regard to the 
interests of all stakeholders.  

Identification of key stakeholders 
As  an  externally  managed  investment  company,  the  Company  has  no  employees,  operations  or  premises.  The  Board  has 
identified its key stakeholders as the Company’s shareholders, the Investment Manager, other service providers and the Investee 
Companies, 

Engagement with stakeholders 
The table below explains how the Board have engaged with all stakeholders. 

Stakeholder 

Engagement 

Shareholders 

The Board seeks an open and constructive engagement with shareholders who have the opportunity 
to vote at and to attend the Company’s AGM. 

The  annual  and  half  year  results  are  available  on  the  Company’s  website  with  the  results  and 
monthly updates also announced via a regulatory news service. 

Investment Manager 

The  Board  receives  regular  updates  on  the  shareholder  register  and  any  trading  activity  and 
feedback received from investor meetings and briefings conducted by the Investment Manager, the 
Broker and research analysts. 
Open and collaborative dialogue is maintained between the Board and the Investment Manager. 

The  Investment  Manager  is  invited  to  all  Board  and  Audit  Committee  meetings  and  provides 
regular reports on the performance of the investments and any potential issues the Board needs to 
be aware of. 

Other Service Providers  The Board receive reports from all service providers at each meeting 

Investee Companies 

The Administrator attends all Board and Committee meetings 

During 2022 the Administrator provided the Board a presentation on the Cyber controls in place. 

The Board conducted a market review of the Depositary during 2022. 
The  Board  receives  detailed  updates  on  operating  performance  of  material  investee  companies 
provided at each meeting. Additionally, the Board receives details of projects being undertaken by 
the  investee  companies,  including  where  these  may  require  the  Company  to  consider  providing 
financial support. Though its investments and board positions on investee companies, the Company 
seeks to promote good ESG practise, with particular attention to Health and Safety of employees 
at investee companies.  

Key Decisions 
Key decisions are those that are material or of strategic importance to any of the Company’s key stakeholders as described above. 
An example of a key decisions made during the year was the sale of Bilboes as described in more detail in the Chairman’s Report,  

Future Developments 
The future performance of the Company depends upon the success of the Company’s investment strategy and, as to its share 
price and  market rating, partly on investors’  view of  mining related investments as an  asset class. Further comments  on the 
outlook for the Company can be found in the Chairman’s Statement on pages 3 and 4 and the Investment Manager’s Report on 
pages 5 to 9. 

Signed on behalf of the Board of Directors by: 

John Falla 
21 April 2023 

17

BAKER STEEL RESOURCES TRUST LIMITED

BOARD OF DIRECTORS 
The  Board  of  Directors  is  listed  below.  In  2018  the  Board  put  in  place  a  succession  plan  to  refresh  its  membership  while 
maintaining a degree of continuity. No limit on the overall length of service of any of the Company’s Directors, including the 
Chairman, has been imposed, as the Board believes that any decisions regarding tenure should consider the balance between the 
need for continuity of knowledge and experience, and the need periodically to refresh the Board’s composition in terms of skills, 
diversity and length of service.  

Howard Myles: Howard Myles currently acts as a non-executive director of a number of investment companies. Howard was a 
partner in Ernst & Young from 2001 until 2007 and was responsible for the Investment Funds Corporate Advisory team. He was 
previously with UBS Warburg from 1987 to 2001. Howard began his career in stockbroking in 1971 as an equity salesman and 
joined Touche Ross in 1975 where he qualified as a chartered accountant. In 1978 he joined W. Greenwell & Co. in the corporate 
broking team and in 1987 moved to SG Warburg Securities where he was involved in a wide range of commercial and industrial 
transactions in addition to leading UBS Warburg’s corporate finance function for investment funds. He is a Fellow of the Institute 
of Chartered Accountants and of The Chartered Institute for Securities and Investments. Howard is a director of abrdn Latin 
American Income Fund Limited, and Chelverton UK Dividend Trust plc both of which are listed on the London Stock Exchange. 

Howard is a member of the Company’s Audit Committee. Notwithstanding that Howard’s tenure extends beyond eleven years, 
the Board is satisfied that he continues to demonstrate independence of the Investment Manager. 

Charles Hansard: Charles Hansard has over 40 years’ experience in the investment industry as a professional and in a non-
executive capacity. He currently serves as a non-executive director on a number of boards which include JJJ Moore part of the 
Moore Capital group of funds of which he was a director for 25 years. He is a director of NYSE listed Los Gatos Silver Inc and 
Electrum Ltd., a privately owned US gold exploration company. He formerly served as a director of Apex Silver Mines Ltd., 
where he chaired the finance committee during its capital raising phase and as chairman of the board of African Platinum Plc, 
which he led through reorganisation and feasibility prior to its sale to Impala Platinum. He commenced his career in South Africa 
with  Anglo  American  Corporation  and  Fleming  Martin  as  a  mining  analyst.  He  subsequently  worked  in  New  York  as  an 
investment  banker  for  Hambros  before  returning  to  the  UK  to  co-found  IFM  Ltd.,  one  of  the  earliest  European  hedge  fund 
managers. Charles holds a B.B.S. from Trinity College Dublin.

Notwithstanding  that  Charles’s  tenure  extends  beyond  eleven  years,  the  Board  is  satisfied  that  he  continues  to  demonstrate 
independence of the Investment Manager. 

Fiona Perrott-Humphrey: Fiona Perrott-Humphrey has over 30 years’ experience in the mining finance industry in London. 
She moved to the UK in 1987 after a period in academia in South Africa, and over the next 15 years, was a rated mining analyst 
for a number of stockbroking  firms including James Capel,  Cazenove  and Citigroup (the  latter as head of European  Mining 
Research).  After leaving full time broking, Fiona has had a portfolio of roles drawing on her experience of covering the global 
mining sector. She is a founder of a mining strategic consulting business, and director of AIM Mining Research and in 2007 
published a book entitled Understanding Junior Miners. In 2004, she was appointed Adviser to the Mining team at Rothschild 
and Co. Fiona was a non-executive director of Dominion Diamonds, located in northern Canada, for two years from 2014. She 
is invited to present regularly at global mining conferences. 

Fiona is a member of the Company's audit committee. 

David Staples: David Staples  worked for PWC in  London for 25  years, including 13 years as Partner. He  has  many  years’ 
experience  serving  on  boards  of  listed  and  private  companies  as  a  non-executive  director,  including  as  chairman  of  listed 
investment  companies.  David  has  a  BSc  in  Economics  and  Accounting,  is  a  Fellow  Chartered  Accountant,  a  Chartered Tax 
Adviser and a holder of the Institute of Directors’ Certificate in Company Direction. He is a Director of NB Global Monthly 
Income Fund, which is listed on the London Stock Exchange. He is also chairman of the general partner companies of private 
equity funds advised by Apax Partners. 

David was the Chairman of the Audit Committee until his retirement from the Board on 31 December 2022 

John  Falla:  John  qualified  as  a  chartered  accountant  with  Ernst  and  Young  in  London,  before  transferring  to  its  Corporate 
Finance Department, specialising in the valuation of unquoted shares and securities. On his return to Guernsey in 1996 he worked 
for an international bank before joining The International Stock Exchange (formerly the Channel Islands Stock Exchange) on its 
launch in 1998 as  a member of the Market  Authority.  In 2000 Mr Falla joined the Edmond de Rothschild Group,  where he 
provided corporate finance advice to international clients including open and closed-ended funds, and institutions with significant 
property interests. He was a director of a number of Edmond de Rothschild operating and investment entities, retiring in 2015.
Mr Falla has been a non-executive director of London listed companies for over 10 years and is an experienced audit committee 
chair. He is currently a director and audit committee chair of NB Private Equity Partners Limited and of Marble Point Loan 
Financing Limited. 

John has been appointed as Chairman of the Audit Committee  following the  retirement of David Staples

18

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT  
For the year ended 31 December 2022 

The Directors of the Company present their eleventh annual report and the audited financial statements (the “Annual Report”) 
for the year ended 31 December 2022. 

The Directors’ Report contains information that covers this period and the period up to the date of publication of this Report. 
Please note that more up to date information is available on the Company’s website www.bakersteelresourcestrust.com. 

Status  

Baker Steel Resources Trust Limited (the “Company”) is a closed-ended investment company with limited liability incorporated 
on 9 March 2010 in Guernsey under the Companies (Guernsey) Law, 2008 with registration number 51576. The Company is a 
registered closed-ended investment scheme registered pursuant to  the Protection of  Investors (Bailiwick of Guernsey) Law, 
2020,  (“POI  Law”)  and  the  Registered  Collective  Investment  Scheme  Rules  and  Guidance,  2021  issued  by  the  Guernsey 
Financial Services Commission (“GFSC”). On 28 April 2010 the Ordinary Shares and Subscription Shares of the Company 
were admitted to the Official List of the UK Listing Authority and to trading on the Main Market of the London Stock Exchange, 
Premium Segment.

Investment Objective  

Details of the Company’s investment objectives and policies are described in the Strategic Report on page 13.  

Performance 

In the year to 31 December 2022, the Company’s NAV per Ordinary Share decreased by 19.3% (2021: 1.2%). This compares 
with  a  rise  in  the  EMIX  Global  Mining  Index  (capital  return  in  Sterling  terms)  of  10.2%  (2021:  5.0%).  A  more  detailed 
explanation of the performance of the Company is provided within the Investment Manager’s Report on pages 5 to 9. 

The results for the year are shown in the Statement of Comprehensive Income on pages 38 and 39 and the Company’s financial 
position at the end of the year is shown in the Statement of Financial Position on page 37.  

Dividends and distribution policy 

During the year ended 31 December 2015 the Board introduced a capital returns policy whereby, subject to applicable laws and 
regulations,  it  will  allocate  cash  for  distributions  to  shareholders.  The  amount  to  be  distributed  will  be  calculated  and  paid 
following publication of the Company’s audited financial statements for each year and will be no less than 15% of the aggregate 
net realised cash gains (after deducting losses) in that financial year. The Board will retain discretion for determining the most 
appropriate manner to make such distribution which may include share buybacks, tender offers and dividend payments. In the 
longer term the Board intends to formulate a more regular dividend policy once it starts to receive significant income from its 
royalty interests. As there was no net realised cash gain during the year, the Board has determined that there will not be any 
distribution in respect of the year ended 31 December 2022. 

Directors and their interests 

The Directors of the Company who served during the year and up until the date of signing of the financial statements are: 

Howard Myles (Chairman) 
Charles Hansard 
Fiona Perrott-Humphrey 
David Staples (retired 31 December 2022) 
John Falla (appointed 13 October 2022) 

Biographical details of each of the Directors who were on the Board of the Company at the time of signing The Annual Report 
are presented on page 18 of the Annual Report. 

19

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT (CONTINUED) 
For the year ended 31 December 2022 

Directors and their interests (continued) 

Each of the Directors is considered to be independent in character and judgement. 

Each Director is asked to declare his interests at each Board Meeting. No Director has any material interest in any other contract 
which is significant to the Company’s business. 

On 10 November 2022, John Falla purchased 60,000 shares in the Company. No other Director has a beneficial interest in the 
Company or any of its investee companies. 

Authorised Share Capital 

The share capital of the Company on incorporation was represented by an unlimited number of Ordinary Shares of no par value. 
The Company may issue an unlimited number of shares of a nominal or par value and/or of no par value or a combination of 
both. 

Shares in issue 

The share capital of the Company on incorporation was represented by an unlimited number of Ordinary Shares of no par value. 
The Company may issue an unlimited number of shares of a nominal or par value and/or of no par value or a combination of 
both.  

The Company has a total of 106,453,335 (2021: 106,453,335) Ordinary Shares outstanding with an additional 700,000 (2021: 
700,000) held in treasury. The Company has 9,167 (2021: 9,167) Management Ordinary Shares in issue, which are held by the 
Investment Manager. 

The Ordinary Shares are admitted to the Premium Listing segment of the Official List of the London Stock Exchange.  

Significant Shareholdings 

As at 31 December 2022, the Company had received notifications in accordance with the FCA’s Disclosure and Transparency 
Rule 5.1.2 R of the following interests in 3% or more of the voting rights attaching to the Company’s issued share capital. 

Ordinary Shareholder
The Sonya Trust 
Northcliffe Holdings Pty Limited 
Overseas Asset Management 
Premier Miton Investors 
RIT Capital Partners 
Armstrong Investments 
Baker Steel Capital Managers 
Interactive Investor 
Hargreaves Lansdown Asset Management 
Jarvis Investment Manager 

Number of 
Ordinary Shares
12,637,350
12,452,177
12,435,915
9,250,000
7,766,803
7,600,000
4,922,877
4,138,994
4,010,686
3,208,131

% of Total 
Shares in issue
11.87
11.70
11.68
8.69
7.30
7.14
4.62
3.89
3.77
3.01

The  Investment  Manager,  Baker  Steel  Capital  Managers  LLP  had  an  interest  in  9,167  Management  Ordinary  Shares  at  31 
December 2022 (31 December 2021: 9,167).  

Baker Steel Global Funds SICAV – Precious Metals Fund (“Precious  Metals Fund”) had an interest in 4,922,877 Ordinary 
Shares in the Company at 31 December 2022 (2021: 4,922,877). Precious Metals Fund has the same Investment Manager as 
the Company. 

David Baker and Trevor Steel, Directors of the Manager, are interested in the shares held by Northcliffe Holdings Pty Limited 
and The Sonya Trust respectively. 

20

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT (CONTINUED) 
For the year ended 31 December 2022 

Statement of Directors’ Responsibilities
The Directors are responsible for preparing the annual report and financial statements in accordance with applicable Guernsey 
law, Listing Rules, Disclosures and Transparency Rules, UK Corporate Governance Code and generally accepted accounting 
principles. 

Guernsey company law requires the Directors to prepare financial statements for each financial year which give a true and fair 
view of the state of affairs of the Company and of the profit or loss of the Company for that year. In preparing these financial 
statements the Directors should: 

-
-
-

-

select suitable accounting policies and then apply them consistently; 
make judgements and estimates that are reasonable; 
state  whether  applicable  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 proper accounting records which disclose with reasonable accuracy at any time the 
financial  position  of  the  Company  and  which  enable  the  Directors  to  ensure  that  the  financial  statements  comply  with  the 
Companies (Guernsey) Law, 2008. The Directors are also responsible for safeguarding the assets of the Company and hence 
for taking reasonable steps for the prevention and detection of fraud and other irregularities.

The Directors confirm that to the best of their knowledge:

-

-

-

-

the financial statements have been prepared in accordance with International Financial Reporting Standards (“IFRS”) as 
adopted by the European Union (“EU”) and give a true and fair view of the assets, liabilities and financial position and 
profit or loss of the Company; 
the Annual Report includes a fair review of the position and performance of the business of the Company together with 
the  description  of  the  principal  risks  and  uncertainties  that  the  Company  faces,  as  required  by  the  Disclosure  and 
Transparency Rules of the UK Listing Authority;  
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; and 
they have carried out a robust assessment of the emerging and principal risks facing the Company, including those that 
would threaten its business model, future performance, solvency or liquidity. 

Auditor Information 
The Directors at the date of approval of this Report confirm that, so far as each of the Directors is aware, there is no relevant 
audit information of which the Company’s auditor is unaware and each Director has taken all the reasonable steps he ought to 
have taken as a director to make himself aware of any relevant audit information and to establish that the Company’s auditor is 
aware of that information. 

Going Concern 
The Directors, as advised by the Audit Committee, have made an assessment of the Company’s ability to continue as a going 
concern and consider it appropriate to adopt the going concern basis of accounting. The discontinuation vote in 2021 was not 
passed and the next vote is in 2024. To be passed, the discontinuation vote requires 75% of shareholders to vote to discontinue. 
The Directors have received no indication that the resolution will be passed.  The Board are satisfied that the Company has the 
resources to continue in business for at least 12 months following the signing of these financial statements. As at 31 December 
2022, approximately 13.8% of the Company’s assets were represented by cash and unrestricted listed and quoted investments 
which are readily realisable. Although the continuing Russian invasion of Ukraine has resulted in a reduction in the carrying 
value of investments with a Russian nexus it is not expected that it will affect the Company’s ability to operate on a normal 
basis. Neither of the two affected investments PAL and Azarga were expected to be a material source of revenue in the next 
two years. The Directors are not aware of any material uncertainties that may cast significant doubt upon the Company’s ability 
to continue as a going concern.

Related party transactions 
Transactions  with  related  parties  are  based  on  terms  equivalent  to  those  that  prevail  in  an  arm’s  length  transaction  and  are 
disclosed in Note 11. 

Corporate Governance Compliance 
The Company is a member of the Association of Investment Companies.  

The Board has therefore considered the Principles and Provisions of the AIC Code of Corporate Governance (AIC Code). The 
AIC Code addresses the Principles and Provisions set out in the UK Corporate Governance Code (the UK Code), as well as 
setting out additional Provisions on issues that are of specific relevance to the Company. 

21

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT (CONTINUED) 
For the year ended 31 December 2022 

Corporate Governance Compliance (continued) 

The Board considers that reporting against the Principles and Provisions of the AIC Code, which  has been endorsed by the 
Financial  Reporting  Council  and  the  Guernsey  Financial  Services  Commission,  provides  more  relevant  information  to 
shareholders. 

The Company has complied with the Principles and Provisions of the AIC Code and therefore the UK Code except as where 
explained in the Annual Report on pages 22 to 24. 

The AIC Code is available on the AIC website (www.theaic.co.uk). It includes an explanation of how the AIC Code adapts the 
Principles and Provisions set out in the UK Code to make them relevant for investment companies. 

The Code includes provisions relating to: 

The role of the Chief Executive  
Executive Directors’ remuneration 
The requirement for a senior Independent Director 




 Nomination and Remuneration Committees  


The requirement for an internal audit function 

The Board considers these provisions are not relevant for the Company as it is an externally managed investment entity. The 
Company has therefore not reported further in respect of these provisions. The Directors are all independent and non-executive 
and the Company does not have employees, hence no Chief Executive is required for the Company. The Board is satisfied that 
any relevant issues can be properly considered by the Board as explained further on the following pages. 

There have been no other instances of non-compliance, other than those noted above. 

Operation and composition of the Board 

 Composition and Independence 

The Board has no executive directors and has contractually delegated responsibility to service providers for the management 
of the Company’s investment portfolio, the arrangement of custodial and cash flow monitoring and oversight services and 
the provision of accounting and company secretarial services. The Company has no employees. 

The Board consists entirely of independent non-executive Directors, of whom Howard Myles is the Chairman. Each of the 
Directors  confirms  that  they  have  no  other  significant  commitments  that  adversely  impact  on  their  ability  to  act  for  the 
Company and its shareholders, and that they have sufficient time to fulfil their obligations to the Company. 

There is no  formal policy in respect of  the tenure  of the  Chairman. The  Board have  initiated a process of refreshing its 
membership and in recent years thee directors have retired with new appointments made. It is envisaged the Chairman will 
retire as part of this succession programme within the next two years. 

 Senior Independent Director

In view of its non-executive nature and small size, the Board considers that it is not necessary for a Senior Independent 
Director to be appointed. 

 Appointment and re-election 

The Company has a transparent procedure for the appointment and re-election of the Directors and independent recruitment 
consultants may be used where appropriate as was the case in 2022 when OSA assisted in the recruitment of Mr Falla. There 
are no service contracts in place for the Directors.  The Directors are not required to retire by rotation. Instead each director 
puts  himself  forward  for  re-election  on  an  annual  basis  at  the  AGM.  The  AGM  also  includes  a  resolution  whereby 
shareholders are able to approve the maximum cumulative remuneration for the Board. 

All  the  Directors  are  responsible  for  reviewing  the  size,  structure  and  skills  of  the  Board  and  considering  whether  any 
changes are required or new appointments are necessary to meet the requirements of the Company’s business or to maintain 
a balanced Board. The Board will seek the assistance of recruitment specialists to identify suitable candidates for the Board 
to consider.  

22

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT (CONTINUED) 
For the year ended 31 December 2022 

Corporate Governance Compliance (continued) 

Operation and composition of the Board (continued) 

Howard Myles and Charles Hansard have served as Directors for more than 9 years. The Board believes that both these 
directors continue to demonstrate independence of the Manager and to make a valuable contribution to the Company, and 
therefore recommends that shareholders vote in favour of their reappointment. The Board has a succession plan under which 
its membership will be refreshed over time. Specialists will be engaged as the Board consider necessary to assist with future 
appointments. 



Information 
The Board receives full details of the Company’s performance, assets, liabilities and other relevant information in advance 
of Board meetings, including information on regulatory and accounting developments.  

 Performance appraisal 

The performance of the Board and the Audit Committee is evaluated through a formal and rigorous assessment process led 
by the Chairman and facilitated by the Company Secretary. The performance of the  Chairman is evaluated by the other 
Directors. 



Investment Manager assessment 
The Investment Manager was appointed pursuant to an investment management agreement with the Manager dated 31 March 
2010 and which was amended and restated, with the Company joining as a party, on 14 November 2014 (the Investment 
Management  Agreement).  The  Investment  Manager  is  paid  by  the  Manager  and  is  not  separately  remunerated  by  the 
Company. The Investment Management Agreement pursuant to which the Company and the Manager have appointed the 
Investment Manager is terminable by any party giving the other parties not less than 12 months’ written notice.

The Investment Manager prepares regular reports to the Board to allow it to review and assess the Company’s activities and 
performance on an ongoing basis. The Board and the Investment Manager have agreed clearly defined investment criteria, 
exposure limits and specified levels of authority. The Board completes a formal assessment of the Investment Manager on 
an annual basis. The assessment covers such matters as the performance of the Company relative to its peers and sector, the 
management of investor relations and the reasonableness of fee arrangements. Based on its assessment it is the opinion of 
the Board that the continuation of the appointment of the Investment Manager is in the best interests of shareholders of the 
Company.

 Board meetings 

The Board generally meets at least four times a year, at which time the Directors review the management and performance 
of the  Company's assets  and  all other significant  matters  so as to ensure  that  the Directors  maintain overall control and 
supervision of the Company’s affairs. The Board is responsible for the appointment and monitoring of all service providers 
to the  Company. Between these  quarterly  meetings there  is regular contact  with  the Investment Manager and  Company 
Secretary. The Directors are kept fully informed of investment and financial controls and other matters which are relevant 
to the business of the Company and which should be brought to the attention of the Directors. The Directors also have direct 
access  to  the  Company  Secretary  (through  its  appointed  representatives  who  are  responsible  for  ensuring  that  Board 
procedures are followed and that applicable rules and regulations are complied with) and, where necessary in the furtherance 
of their duties, to independent professional advice at the expense of the Company. 

Attendance at the quarterly Board and Audit Committee meetings during the year was as follows: 

Howard Myles 
Charles Hansard 
Fiona Perrott-Humphrey 
David Staples (retired 31 December 2022) 
John Falla (appointed 13 October 2022) 
*Held since appointment 

Board Meetings 

Audit Committee 
Meetings 

Held 
4 
4 
4 
4 
1* 

Attended 
4 
4 
4 
4 
1 

Held 
4 
n/a 
4 
4 
1* 

Attended 
4 
n/a 
4 
4 
1 

In  addition  to  the  quarterly  meetings,  adhoc  Board  and  committee  meetings  are  convened  as  required.  All  Directors 
contribute to a significant exchange of views with the Investment Manager on specific matters, in particular in relation to 
developments in the portfolio. 

23

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT (CONTINUED) 
For the year ended 31 December 2022 

Corporate Governance Compliance (continued) 

Operation and composition of the Board (continued) 

 Relations with Shareholders 

The  Board  believes  that  the  maintenance  of  good  relations  with  shareholders  is  vital  for  the  long-term  prospects  of  the 
Company.  The  Company’s  stockbrokers,  Numis  Securities  Limited,  and  the  Investment  Manager  are  responsible  for 
managing  relationships  with  shareholders  and  each  provides  the  Board  with  feedback  on  a  regular  basis  that  includes  a 
shareholder contact report and any concerns the shareholder has raised. The Chairman and the Board are also available to 
meet with shareholders at the Company’s Annual General Meeting or otherwise. 

 Engagement with key Stakeholders

The  Board  considers  its  key  stakeholders,  along  with  its  shareholders,  to  be  the  Company’s  Investment  Manager, 
Administrator, Company Secretary and Stockbroker. Engagement with each Stakeholder is formalised by quarterly reporting 
at the Board Meetings but outside of the formal meetings, is continuous as required by the operations of the Company. The 
Board is very aware of the importance to the success of the Company of these key stakeholders and encourages open and 
frequent dialogue to facilitate improvements to the way that the Company functions. The engagement with stakeholders is 
covered in more detail in the Strategic Report on page 17. 

 Principal and Emerging Risks 

The Board has delegated responsibility for the assessment of its key risks to the Audit Committee. The Audit Committee 
has documented the key risks and controls in a detailed risk matrix and meets on a quarterly basis to update it and to assesses 
the adequacy and completeness of the controls. As the Audit Committee identifies changes that affect the risk profile of the 
Company it will recommend to the Board any actions required to effectively manage risk. More details on the Principal and 
Emerging Risks are presented in the Strategic Report. 

 Diversity 

The Board has no formal policy on diversity but is cognizant of the need to maintain a Board with a spectrum of backgrounds 
and skills appropriate for the specifics of the Company. Due to the small size of the Board, there are no plans to implement 
targets for diversity metrics however recruitment agencies who assist with identifying candidates for Board appointments 
are instructed to do so with diversity in mind. 

Committees 
The Audit Committee is the sole committee of the Board. Terms of Reference for the Audit Committee are available on the 
Company’s webpage http://bakersteelresourcestrust.com/corporate-governance/.

 Audit Committee 

The Board has established an Audit Committee. The Audit Committee meets at least three times a year and is responsible 
for ensuring that the financial performance of the Company is properly reported on and monitored and provides a forum 
through which the Company’s external auditor may report to the Board. The Audit Committee operates within established 
terms of reference. The Directors consider there is no need for an internal audit function because the Company operates 
through service providers and the Directors receive control reports on its key service providers. 

David Staples was Chairman of the Audit Committee until 31 December 2022, with Fiona Perrott-Humphrey, Howard Myles 
and (effective 13 October 2022) John Falla as the other members. As Chairman of the Board, Howard Myles will not Chair 
the Audit Committee but is considered independent and therefore sits as a committee  member. Following David Staples 
retirement from the Board on 31 December 2022 John Falla assumed the role of Chairman of the Audit Committee. 

 Nomination, Remuneration and Management Engagement Committees 

Given the size and nature of the Company and the fact that all the Directors are independent and non-executive it is not 
deemed necessary to form separate Nomination, Remuneration, and Management Engagement Committees. The Board itself 
considers new Board appointments, remuneration and the engagement of service providers.  

Internal Controls 
The Board has delegated to service providers the day to day responsibilities for the management of the Company’s investment 
portfolio, the provision of  depositary  services and administration, registrar and corporate secretarial functions including the 
independent calculation of the Company’s NAV and the production of the Annual Report and Financial Statements which are 
independently audited.  

Formal contractual agreements have been put in place between the Company and providers of these services. 

24

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT (CONTINUED) 
For the year ended 31 December 2022 

Corporate Governance Compliance (continued) 

Operation and composition of the Board (continued) 

Internal Controls (continued) 
Even though the Board has delegated responsibility for these functions, it retains accountability for them and is responsible for 
the systems of internal control. However, it has delegated the regular review and oversight of the systems of internal control to 
the  Audit  Committee  which  reports  back  to  the  Board  following  each  Audit  Committee  meeting.  At  each  quarterly  Board 
meeting, compliance reports are provided by the Administrator and Investment Manager. 

The Company’s risk matrix continues to be the core element of the Company’s risk management process in establishing the 
Company’s system of internal financial and reporting control. The risk matrix is prepared and maintained by the Investment 
Manager  and  reviewed  regularly  by  the  Audit  Committee  which  initially  identifies  the  risks  facing  the  Company  and  then 
collectively assesses the likelihood of each risk, the impact of those risks and the strength of the controls mitigating each risk. 
The system of internal financial and operating control is designed to manage rather than to eliminate the risk of failure to achieve 
business objectives and by its nature can only provide reasonable and not absolute assurance against misstatement and loss. 
These controls aim to ensure that assets of the Company are safeguarded, proper accounting records are maintained and the 
financial information for publication is reliable. The Audit Committee confirms to the Board that there is an ongoing process 
for identifying, evaluating and managing the significant risks faced by the Company.  

This process has been in place for the year under review and up to the date of approval of this Annual Report and Audited 
Financial Statements and is reviewed by the Board by way of reporting from the Audit Committee.  

The Board therefore believes that the Company has adequate and effective systems in place to identify, mitigate and manage 
the risks to which it is exposed.

Director’s Remuneration Policy 

All Directors are non-executive and in view of the relatively small size of the Board a Remuneration Committee has not been 
established. The Board as a whole considers matters relating to the Directors' remuneration. No advice or services were provided 
by any external person in respect of its consideration of the Directors' remuneration. 

The Company's policy is that the fees payable to the Directors should reflect the time spent by the Directors on the Company's 
affairs and the responsibilities borne by the Directors and be sufficient to attract, retain and motivate directors who have the 
experience and qualities required to run the Company successfully. The Chairs of the Board and the Audit Committee are paid 
a higher fee in recognition of their additional responsibilities. The fee levels are reviewed annually.  Effective 1 October 2022 
the Board, recognising the Board remuneration was below market rates having not changed since the Company’s flotation in 
2010, resolved to increase their remuneration to £32,500 per annum for each Director. The Chairman will receive a supplement 
of £10,000 per annum and the Chairman of the Audit Committee a supplement of £5,000 per annum. 

There are no long term incentive schemes provided by the Company and no performance fees are paid to Directors. No Director 
has a service contract with the Company but each of the Directors is appointed by a letter of appointment which sets out the 
main terms of their appointment. Directors hold office until they retire or cease to be a director in accordance with the Articles 
of Incorporation or by operation of law. 

The  Directors  recognise  the  benefits  of  diversity  in  terms  of  gender  and  ethnicity  and  will  take  these  into  account  when 
considering future appointments to the Board. However, their principal criteria will remain the skills and experience of new 
directors and the Board will select the candidates whom it believes will add most value. 

The Directors are remunerated for their services at such rate as the Directors determine provided that the aggregate amount of 
such  fees  may  not  exceed  £200,000  per  annum  (or  such  sum  as  the  Company  in  general  meeting  shall  from  time  to  time 
determine).

For the year ended 31 December 2022, the total remuneration of the Directors was £129,489 (2021: £115,000). There were no 
director fees payable at the year-end (2021: £28,750). 

25

BAKER STEEL RESOURCES TRUST LIMITED

DIRECTORS’ REPORT (CONTINUED) 
For the year ended 31 December 2022 

Corporate Governance Compliance (continued) 

Operation and composition of the Board (continued) 

Director’s Remuneration Policy (continued) 

Directors are remunerated in the form of fees, payable quarterly in arrears, to the Director personally. The fees paid to each 
Director in respect of the years ended 31 December 2022 and 31 December 2021 are shown below. 

Howard Myles 
David Staples 
Charles Hansard 
Fiona Perrott-Humphrey  
John Falla 

Independent Auditors

2022 
£ 
36,875 
31,875 
26,875 
26,875 
6,989 

2021 
£ 
35,000 
30,000 
25,000 
25,000 
- 

The auditors, BDO Limited, have indicated their willingness to continue in office and a resolution for their re-appointment will 
be proposed at the Annual General Meeting. 

Subsequent Events 

Please refer to Note 14 of the financial statements on page 63. 

Signed on behalf of the Board of Directors by: 

John Falla 
21 April 2023 

26

 
BAKER STEEL RESOURCES TRUST LIMITED

REPORT OF THE AUDIT COMMITTEE 
For the year ended 31 December 2022 

The  function  of  the  Audit  Committee  as  described  in  its  Terms  of  Reference  is  to  ensure  that  the  Company  maintains  high 
standards of integrity in its financial reporting and internal controls. David Staples was Chairman of the Audit Committee until 
31 December 2022 when he was replaced by John Falla.  Fiona Perrott-Humphrey and Howard Myles are the other members of 
the  Audit  Committee.  As  Chairman  of  the  Board,  Howard  Myles  will  not  Chair  the  Audit  Committee  but  is  considered 
independent and therefore sits as a committee member. 

The  Audit  Committee  is  appointed  by  the  Board  and  all  members  are  considered  to  be  independent  both  of  the  Investment 
Manager and the external auditor. The Audit Committee typically meets four times a year, aligned to Board Meeting dates, to 
discuss  the  Interim  and  Annual  Report  and  Audited  Financial  Statements,  the  audit  plan  and  engagement  letter,  and  the 
Company’s risks and controls, via discussion of its risk  matrix. The  Board is satisfied that the  Audit Committee  is properly 
constituted  with  members  having  recent  and  relevant  financial  experience,  including  two  members  who  are  chartered 
accountants. 

The Board, advised by the Audit Committee considers the nature and extent of the Company’s risk management framework and 
the risk profile that is acceptable in order to achieve the Company’s strategic objectives. As a result, it is considered that the 
Board has fulfilled its obligations under the AIC Code and the UK Code. 

The Audit Committee continues to be responsible for reviewing the adequacy and effectiveness of the Company’s on-going risk 
management  systems  and  processes.  The  Company’s  system  of  internal  controls,  along  with  its  design  and  operating 
effectiveness, is subject to review by the Audit Committee through reports received from all key service providers. 

In the event of any deficiencies or breaches being reported, the Board would consider the actions required to remedy and prevent 
significant  failings  or  weaknesses.  During  the  year  ended  31  December  2022,  no  significant  weaknesses  or  failings  were 
identified. 

Fraud, Bribery and Corruption 

The Audit Committee continues to monitor the fraud, bribery and corruption policies of the Company. The Board receives a 
confirmation from all service providers that they are not aware of any instances of fraud or bribery. 

The Audit Committee considers the adequacy and security of the arrangements for the employees of its service providers to raise 
concerns, in confidence, about possible wrongdoing in financial reporting or other matters. The Audit Committee is satisfied it 
has the ability and resources to investigate any matters that are brought to its attention and to follow up on any conclusion reached 
by such investigation. 

Primary Areas of Judgement 

As part of its review of the Company’s financial statements, the Audit Committee takes account of the most significant issues 
and risks, both operational and financial, likely to impact on the financial statements and the mitigating controls to address these 
risks. The Audit Committee has determined that the key risk of misstatement is the valuation of investments for which there is 
no readily observable market price. Such investments are recorded at fair value which is the price that would be expected to be 
received to sell an asset in an orderly transaction between market participants at the measurement date. Significant judgements 
are required in respect of the valuation of the Company’s investments for which there is no observable market price. Further 
information on the Company’s methodologies is provided in Note 3 to the financial statements.  

The  risk  is  mitigated  through  the  review  by  the  Audit  Committee  and  Board  of  detailed  reports  prepared  by  the  Investment 
Manager on portfolio valuation including valuation methodology, the underlying assumptions and the valuation process. 

The  Investment  Manager  also  provides  information  to  the  Audit  Committee  and  Board  on  relevant  market  indices,  recent 
transactions in similar assets and other relevant information to allow an assessment of appropriate carrying value having regard 
to the relevant factors.  

The ultimate responsibility for ensuring that investments are carried at fair value lies with the Board. 

27

BAKER STEEL RESOURCES TRUST LIMITED

REPORT OF THE AUDIT COMMITTEE (CONTINUED) 
For the year ended 31 December 2022 

Through its meetings during the year ended 31 December 2022 and its review of the Company’s Annual Report and Audited 
Financial  Statements,  the  Audit  Committee  considered  the  following  significant  risks  as  well  as  the  principal  risks  and 
uncertainties described on pages 14-15. 

Risk Considered 

How addressed 

The accuracy of the Company’s Annual Report and Financial 
Statements 

Adequacy of the Company’s accounting and internal controls 
systems 

Valuation  of  the  Company’s  investments,  in  particular  the 
valuation of unquoted investments 

The  effectiveness  and  independence  of  the  external  audit 
process 

Emerging risks 

Review  of  the  Annual  Report  and  Audited  Financial 
Statements,  discussions  with  the  external  auditor  and 
meetings  with  the  auditor  to  understand  the  audit  approach 
and findings having regard to the level of materiality agreed 
with it. 

Consideration of the Company’s risk matrix, taking account 
of the relevant risks, the potential impact to the Company and 
the mitigating controls in place. The Committee also reviews 
control  and  compliance  reports  in  this  respect  and  receives 
explanations  of  any  breaches  and  how  any  control 
weaknesses have been addressed. 

Reports  received  from  and  discussed  in  depth  with  the 
Investment  Manager  providing  support  for  the  investment 
valuations.  The  Investment  Manager  reporting  is  then 
challenged and reconciled to the independent auditor’s review 
of the investment valuations. 

The Audit Committee has regular dialogue with the external 
auditor both before and during the audit process. The auditor 
presents  to  the  Audit  Committee  at  both  the  planning  and 
audit  review  stage,  and  confirms  its  independence  at  each 
stage.  The  Audit  Committee  receives  feedback  from  the 
Investment Manager on the audit process and any concerns or 
challenges faced. 

The  Audit  Committee  discusses  the  Company’s  risk  matrix 
each time it meets. Through these discussions emerging risks 
such as those caused by the Russian invasion of Ukraine are 
assessed. The matrix also documents long term implications 
for the sector from secular trends such as climate change.  

The Audit Committee also provides a forum through which the Company’s auditor reports to the Board. The Board, advised by 
the Audit Committee, approves all non-audit work carried out by the auditor in advance and the fees paid to the auditor in this 
respect. 

External Audit 

The Company’s external auditor is BDO Limited (“BDO”). 

The fees due to the auditor during the year were as follows: 

Audit fees 

Audit Fees 

Non-audit fees

Total Fees 

Agreed Upon Procedures relating to the 
review of the Company’s half year report 

2022 
£ 
70,000 

9,625 

79,625 

2021 
£ 
58,500 

8,750 

67,250 

28

BAKER STEEL RESOURCES TRUST LIMITED

REPORT OF THE AUDIT COMMITTEE (CONTINUED) 
For the year ended 31 December 2022 

External Audit (Continued) 
The external auditor provides an audit planning report in advance of the annual audit. The Audit Committee has the opportunity 
to question and challenge the auditor in respect of their work. Based on levels of interaction with the auditor, and the assessment 
of  auditor  reporting,  the  audit  planning,  adherence  to  audit  standards,  competence  of  the  audit  team  and  feedback  from  the 
Investment Manager, the Audit Committee and the Board are satisfied that the reappointment of the external auditor should be 
proposed at the Annual General Meeting of the Company. 

The Audit Committee has reviewed the effectiveness of the auditor including: 



Independence: The auditor discusses with the Audit Committee, at least annually, the steps it takes to ensure independence 
and confirms the same to the Audit Committee. The audit fees paid to BDO are presented on Page 28 of the Annual Report. 
The only non-audit fees paid to BDO are in relation to the Agreed Upon Procedures work completed on the Interim Report 
and Accounts. The audit director will rotate after 5 years; this is the third year of the current audit director. 

 Quality of Audit Work: The Audit Committee assess the completion of the audit versus the plan and will seek feedback 
from the Investment Manager and the Administrator on any issues experienced through the Audit. The Chairman of the 
Audit Committee will separately engage with the audit director to discuss progress and issues with the audit. 

Internal Audit 
The Audit Committee believes that the Company does not require an internal audit function because it delegates its day to day 
functions to market leading third party service providers, although the Audit Committee oversees these operations and receives 
regular control reports in this respect. 

Risk Management and Internal Controls 
The Board is responsible for the Company’s system of internal controls and risk management. The Audit Committee has been 
delegated the responsibility  for  reviewing the ongoing  effectiveness of the  Company’s internal controls and it discharges its 
duties in this area by assessing the nature and extent of the significant risks the Company is willing to accept in achieving the 
Company’s  objectives,  and  ensuring  that  effective  systems  of  risk  identification,  assessment  and  mitigation  have  been 
implemented. The Strategic Report on pages 12 to 17 outlines the principal risks and uncertainties affecting the Company and 
the section on Internal Controls in the Directors Report on pages 19 to 26 gives details of the work performed by the  Audit 
Committee in this area.  

By their nature, the control mechanisms can only provide reasonable rather than absolute assurance against misstatement or loss. 
The Audit Committee seeks continual improvement in the Company’s internal control mechanisms. The Audit Committee is not 
aware of any significant failings or weaknesses in the Company’s internal controls in the year under review nor up to the date of 
this report.   

Financial Reporting 

The  primary  role  of  the  Audit  Committee  in  relation  to  financial  reporting  is  to  review  the  Annual  Report  and  Financial 
Statements and the Half Year Report with the Administrator and the Investment Manager and assess their appropriateness. It 
focuses in this respect, amongst other matters, on: 



the clarity of the disclosures in the financial reporting and compliance with statutory, regulatory and other financial 
reporting requirements; 
the quality and acceptability of accounting policies and practices;  


 material areas where significant judgements and estimates have been applied or where there has been discussion with 



the auditor; and  
taken as a whole, whether the financial statements are fair, balanced and understandable and provide shareholders with 
the necessary information to assess the Company’s performance and strategy, reporting to the Board in this respect.  

Going Concern and Viability 

The Audit Committee has made an assessment of the Company’s ability to continue as a going concern and of its viability, see 
pages 16 and 21 and has advised the Board accordingly.  

John Falla 
Audit Committee Chairman 
21 April 2023 

29

BAKER STEEL RESOURCES TRUST LIMITED

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF BAKER STEEL RESOURCES TRUST LIMITED  

Opinion on the financial statements
In our opinion, the financial statements of Baker Steel Resources Trust Limited (“the Company”): 






give a true and fair view of the state of the Company’s affairs as at 31 December 2022 and of its loss for the year then ended; 
have been properly prepared in accordance with International Financial Reporting Standards as adopted by the European 
Union; and 
have been properly prepared in accordance with the requirements of the Companies (Guernsey) Law, 2008. 

We have audited the financial statements of the Company for the year ended 31 December 2022 which comprise the Statement 
of Financial Position, the Statement of Comprehensive Income, the Statement of Changes in Equity, the Statement of Cash Flows
and notes to the financial statements, including a summary of significant accounting policies.  

The  financial  reporting  framework  that  has  been  applied  in  their  preparation  is  applicable  law  and  International  Financial 
Reporting Standards as adopted by the European Union. 

Basis for opinion
We  conducted our  audit in accordance  with International  Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our 
responsibilities  under  those  standards  are  further  described  in  the  Auditor’s  responsibilities  for  the  audit  of  the  financial 
statements section of our report. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a 
basis for our opinion. Our audit opinion is consistent with the additional report to the audit committee.  

Independence 

We remain 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.  

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

Our evaluation of the Directors’ assessment of Company’s ability to continue to adopt the going concern basis of accounting 
included: 

 Obtaining the paper prepared by those charged with governance and management in respect of going concern and discussing 









this with both the Directors and management;  
Challenging the Directors’ cash flow forecasts for the twelve months from the approval of these  financial statements by 
stress testing future income and expenditure, the ability to realise the Company’s assets and the impact on the going concern 
assessment; 
Challenging the key inputs into the cash flow forecasts by comparing these to historic results of the Company and whether 
they were consistent with our understanding of the company;  
Challenging the Directors around the 2024 discontinuation vote and its possible impact on the going concern status of the 
company by considering the related party shareholders; and 
Reviewing the minutes of the Directors, the RNS announcements and the compliance reports for any indicators of concerns 
in respect of going concern.  

Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, 
individually or collectively, may cast significant doubt on the Company’s ability to continue as a going concern for a period of 
at least twelve months from when the financial statements are authorised for issue.  

In relation to the Company’s reporting on how it has applied the UK Corporate Governance Code, we have nothing material to 
add or draw attention to in relation to the Directors’ statement in the financial statements about whether the 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. 

30

BAKER STEEL RESOURCES TRUST LIMITED

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF BAKER STEEL RESOURCES TRUST LIMITED (continued) 

Overview 

Key 
matters 

audit 

Materiality 

Valuation of unlisted investments and  
listed  investments  subject  to  a  lock  up 
period  

Financial statements as a whole 

2022 

2021 

Yes 

Yes 

£1.54m (2021: £1.84m) based on 1.75% (2021: 1.75%) of total assets. 

An overview of the scope of our audit 

Our audit was scoped by obtaining an understanding of the Company and its environment, including the Company’s system of 
internal  control,  and  assessing  the  risks  of  material  misstatement  in  the  financial  statements.    We  also  addressed  the risk  of 
management override of internal controls, including assessing whether there was evidence of bias by the Directors that may have 
represented a risk of material misstatement. 

We tailored the scope of our audit taking into account the nature of the Company's investment, involvement of the Manager and 
the Company’s Administrator, the accounting and reporting environment and the industry in which the Company operates.  

This  assessment  took  into  account  the  likelihood,  nature  and  potential  magnitude  of  any  misstatement.  As  part  of  this  risk 
assessment, we considered the Company's interaction with the Manager and the Company’s Administrator. We considered the 
control environment in place at the Manager and the Company’s Administrator to the extent that it was relevant to our audit. 
Following this assessment, we applied professional judgement to determine the extent of testing required over each balance in 
the financial statement.

Key audit matters 

Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial 
statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to 
fraud) that we identified, 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. 

31

BAKER STEEL RESOURCES TRUST LIMITED

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF BAKER STEEL RESOURCES TRUST LIMITED (continued) 

Key audit matter  
Valuation of unlisted investments and listed investments 
subject to a lock up period.  

Refer to the accounting policies set out in Note 2 and Note 
3 to the Financial Statements.  

The  valuations  are  subjective,  with  a  high  level  of 
judgment  and  estimation  linked  to  the  determination  of 
fair  value  with  limited  third-party  pricing  information 
available.  

As  a  result  of  the  subjectivity,  there  is  a  risk  of  an 
inappropriate  valuation  model  being  applied,  together 
with  the risk of inappropriate inputs  to the  model being 
used  which  could  significantly  impact  the  valuation 
output.  

The valuation of these investments is a key driver of the 
Company's net asset value and total return. Accordingly, 
incorrect  valuations  of  these  investments  could  have  a 
significant impact on the net asset value of the Company 
and  therefore  the  return  generated  for  shareholders.  We 
therefore consider this to be a key audit matter. 

How the scope of our audit addressed the key audit matter 
Our procedures included the following:  

For all unlisted investments:  

 We considered the processes, policies and methodologies 
used  by  management  for  determining  the  fair  value  of 
unlisted investments held by the Company;  

 Agreed 

the  Manager’s  application  of  valuation 
techniques  as  appropriate  to  the  circumstances  of  the 
investment and the accounting policies applied; and  

 Agreed  the  valuation  per  the  models  to  the  financial 

statements.  

In respect of the investments using a valuation model, we: -  

 Obtained  and  challenged,  through  discussion  and 
corroboration  to  external  sources,  the  inputs  and 
assumptions used in management’s model based on our 
understanding of the investment.  

 Agreed  the  inputs,  for  example  volatility,  resource 
prices,  and  tax  rates,  into  the  models  to  independent 
sources;  





Evaluated  whether  all  key  terms  of  the  underlying 
agreements had been considered within the models;  

Performed  an  independent  sensitivity  analysis  of 
certain  inputs  to  identify  and  challenge,  through 
discussion and corroboration to third party sources, in 
more detail, those which have the largest impact on the 
valuation; and  



Tested the mathematical accuracy of the models.  

investments  valued  on  an 

For 
recalculated, using independently obtained information,  
management’s applied basket of indices for each investment. 

index  valuation,  we 

For  those  investments  which  used  recent  Investment  as  a 
basis, we considered if there were any material changes in  
the  market  or  changes  in  the  performance  of  the  investee 
company  affecting  the  fair  value  of  the  investment  at  year 
end.  

For listed investments subject to a lock up period we: -  

 Obtained management’s calculation of the appropriate 
discount to apply to the market price and the underlying 
model prepared to support this;  

Challenged the appropriateness of the model, based on 
standard  practice  valuation  methods  for  investments 
subject to a lockup;  

Calculated  our  own  discount,  utilising  an  appropriate 
valuation  model  and  external  data  sources  obtained 





32

BAKER STEEL RESOURCES TRUST LIMITED

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF BAKER STEEL RESOURCES TRUST LIMITED (continued) 

independently and compared with that of management; 
and  

 Agreed the listed price to a third-party data source and 

reperformed the discount adjustment.  

Key observation:  
Based  on  the  procedures  performed,  we  are  satisfied  that 
judgements  applied  in  valuing  the  unlisted  investments  and 
listed investments subject to a lock up period are appropriate. 

Our application of materiality

We apply the concept of materiality both in planning and performing our audit, and in evaluating the effect of misstatements.  
We  consider  materiality  to  be  the  magnitude  by  which  misstatements,  including  omissions,  could  influence  the  economic 
decisions of reasonable users that are taken on the basis of the financial statements.  

In  order  to  reduce  to  an  appropriately  low  level  the  probability  that  any  misstatements  exceed  materiality,  we  use  a  lower 
materiality level, performance materiality, to determine the extent of testing needed. Importantly, misstatements below these 
levels will not necessarily be evaluated as immaterial as we also take account of the nature of identified misstatements, and the 
particular circumstances of their occurrence, when evaluating their effect on the financial statements as a whole.  

Based  on  our  professional  judgement,  we  determined  materiality  for  the  financial  statements  as  a  whole  and  performance 
materiality as follows: 

Materiality 

Company financial statements 

2022 

£1.48m 

2021 

£1.84m 

Basis for determining materiality 

1.75% of total assets 

Rationale for the benchmark applied 

Due to it being an investment fund with the objective of long-
term capital growth, with investment values being a key focus 
of users of the financial statements. 

Performance materiality 

£0.97m 

£1.19m 

Basis for determining performance materiality 

65% of materiality  

This  was  determined  using  our  professional  judgement  and 
the 
considered 
engagement, together with history of minimal historical errors 
and adjustments. 

the  complexity  and  our  knowledge  of 

Reporting threshold   

We agreed with the Audit Committee that we would report to them all individual audit differences in excess of £44,000 (2021: 
£55,140).  We also agreed to report differences below this threshold that, in our view, warranted reporting on qualitative grounds. 

33

BAKER STEEL RESOURCES TRUST LIMITED

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF BAKER STEEL RESOURCES TRUST LIMITED (continued) 

Other information
The Directors are responsible for the other information. The other information comprises the information included in the Annual 
Report and Audited Financial Statements, 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. Our responsibility is to read the other information and, in doing so, 
consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the 
course of the audit, or otherwise appears to be materially  misstated. If  we  identify  such material inconsistencies or apparent 
material misstatements, we are required to determine whether this gives rise to a material misstatement in the financial statements 
themselves. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, 
we are required to report that fact. 

We have nothing to report in this regard. 

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.  

Going  concern  and 
term viability 

longer-





The Directors' statement with regards the appropriateness of adopting the going 
concern basis of accounting and any material uncertainties identified set out on 
page 21 and 

The  Directors’  explanation  as  to  its  assessment  of  the  entity’s  prospects,  the 
period this assessment covers and why the period is appropriate set out on page 
16. 

Other Code provisions  

 Directors' statement on fair, balanced and understandable set out on page 21;  







Board’s confirmation that it has carried out a robust assessment of the emerging 
and principal risks set out on pages 14-15 and 24;  

The section of the annual report that describes the review of effectiveness of 
risk management and internal control systems set out on page 29; and 

The section describing the work of the Audit Committee set out on page 24 and 
pages 27 to 29. 

Other Companies (Guernsey) Law, 2008 reporting 

We have nothing to report in respect of the following matters where the Companies (Guernsey) Law, 2008 requires us to report 
to you if, in our opinion: 





proper accounting records have not been kept by the Company; or 

the financial statements are not in agreement with the accounting records; or  

 we have failed to obtain all the information and explanations which, to the best of our knowledge and belief, are necessary 

for the purposes of our audit. 

34

BAKER STEEL RESOURCES TRUST LIMITED

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF BAKER STEEL RESOURCES TRUST LIMITED (continued) 

Responsibilities of Directors 

As explained more fully in the Statement of Directors’ Responsibilities within the Directors’ Report 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 have 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. 

Extent to which the audit was capable of detecting irregularities, including fraud

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

We  obtained an understanding of the  legal  and regulatory frameworks  that are applicable to the Company and have a  direct 
impact on the preparation of the financial statements. We determined that the most significant frameworks which are directly 
relevant to specific assertions in the financial statements are those that relate to the reporting framework such as IFRSs and the 
Companies (Guernsey) Law, 2008. We evaluated management’s incentives and opportunities for fraudulent manipulation of the 
financial statements (including the risk of management override of controls) and determined that the principal risks were related 
to revenue recognition on the Company’s investments and the management bias and judgement involved in accounting estimates, 
specifically in relation to the valuation of investments (the response to which is detailed in our key audit matter above).   

We communicated relevant identified laws and regulations and potential fraud risks to all engagement team members who were 
all deemed to have appropriate competence and capabilities and remained alert to any indications of fraud or non-compliance 
with laws and regulations throughout the audit.  

Audit procedures performed by the engagement team to respond to the risks identified included:  

 Discussion with and enquiry of management and those charged with governance concerning known or suspected instances 

of non-compliance with laws and regulations or fraud;  





Reading  minutes  of  meetings  of  those  charged  with  governance,  correspondence  with  the  Guernsey  Financial  Services 
Commission, internal compliance reports, complaint registers and breach registers to identify and consider any known or 
suspected instances of non-compliance with laws and regulations or fraud;  

Performing analytical procedures of the mid-year net asset valuations, with a focus on reviewing and corroborating 
movements over a set threshold. 

Our audit procedures were designed to respond to risks of material misstatement in the financial statements, recognising that the 
risk of not detecting a material misstatement due to fraud is higher than the risk of not detecting one resulting from error, as fraud 
may  involve  deliberate  concealment  by,  for  example,  forgery,  misrepresentations  or  through  collusion.  There  are  inherent 
limitations in the audit procedures performed and the further removed non-compliance with laws and regulations is from the 
events and transactions reflected in the financial statements, the less likely we are to become aware of it. 

further  description  of  our 

A 
https://www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor’s report.  

is  available  on 

responsibilities 

the  Financial  Reporting  Council’s  website  at: 

The engagement director on the audit resulting in this independent auditor’s opinion is Justin Hallett. 

35

BAKER STEEL RESOURCES TRUST LIMITED

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF BAKER STEEL RESOURCES TRUST LIMITED (continued) 

 Use of our report 

This report is made solely to the Company’s members, as a body, in accordance with Section 262 of the Companies (Guernsey) 
Law, 2008. Our audit work has been undertaken so that we might state to the Company’s members those matters we are required 
to state to them in an auditor’s report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume 
responsibility to anyone other than the Company and the Company’s members, as a body, for our audit work, for this report, or 
for the opinions we have formed. 

For and on behalf of BDO Limited 
Chartered Accountants and Recognised Auditor 
Place du Pré 
Rue du Pré 
St Peter Port 
Guernsey 

21 April 2023  

36

BAKER STEEL RESOURCES TRUST LIMITED

STATEMENT OF FINANCIAL POSITION 
AS AT 31 DECEMBER 2022 

Assets
Cash and cash equivalents 
Interest receivable 
Other receivables 
Financial assets held at fair value through profit or loss 
Total assets 

Equity and Liabilities 

Liabilities  
Directors’ fees payable 
Management fees payable 
Administration fees payable 
Audit fees payable 
Custodian fees payable 
Other payables 
Total liabilities 

Equity 
Management Ordinary Shares 
Ordinary Shares 
Revenue Reserves 
Capital Reserves 
Total equity 

Total equity and liabilities 

Notes 

9 
2(c)(i)

3 

11 
7,11 
6 

10 
10 

2022 
£ 

2021
£

254,140 
57,917 
17,899 
84,311,955 
84,641,911 

1,077,482 
 249,445 
 22,132 
 103,685,593 
 105,034,652 

- 
69,854 
9,659 
70,000 
7,158 
2,392 
159,063 

 28,750 
 122,894 
 10,638 
 58,500 
 8,443 
 6,471 
 235,696 

 9,167 
 75,972,688 
8,771,186 
(270,193) 
84,482,848 

 9,167 
 75,972,688 
 10,047,160 
 18,769,941 
 104,798,956 

84,641,911 

105,034,652 

Net Asset Value per Ordinary Share (in Pence) – Basic and Diluted 

12 

79.4 

98.4 

The financial statements on pages 37 to 63 were approved and authorised for issue by the Board of Directors on  
21 April 2023 and signed on its behalf by: 

John Falla 

The accompanying notes form an integral part of these audited financial statements 

37

BAKER STEEL RESOURCES TRUST LIMITED

STATEMENT OF COMPREHENSIVE INCOME  
FOR THE YEAR ENDED 31 DECEMBER 2022 

Income
Interest income 
Dividend income 
Net loss on financial assets at fair value through profit or loss 
Net foreign exchange loss 
Net income / (loss) 

Expenses 
Management fees 
Directors’ fees  
Administration fees 
Other expenses 
Depositary fees 
Custody fees 
Broker fees 
Audit fees 
Directors’ insurance 
Directors’ expenses 
Legal fees 
Total expenses 

Net loss for the year 

Notes 

2(i) 
2(j) 
3 

7,11 
11 
6 
8 

Year ended 
2022
Revenue
£

Year ended 
2022
Capital
£

Year ended 
2022
Total
£

549,607 
9,356 
- 
- 
558,963 

- 
- 
(19,038,918) 
(1,216) 
(19,040,134) 

549,607 
9,356 
(19,038,918) 
(1,216) 
(18,481,171) 

 1,160,507 
 129,489 
 118,002 
 130,321 
 36,942 
 58,918 
 35,000 
 79,625 
 6,000 
 3,344 
 76,789 
1,834,937 

- 
- 
- 
- 
- 
- 
- 
- 
- 
- 
- 

 1,160,507 
 129,489 
 118,002 
 130,321 
 36,942 
 58,918 
 35,000 
 79,625 
 6,000 
 3,344 
 76,789 
1,834,937 

(1,275,974) 

(19,040,134) 

(20,316,108) 

Net loss for the year per Ordinary Share:
Basic and Diluted (in pence) 

12 

(1.20) 

(17.88) 

(19.08) 

In the year ended 31 December 2022 there were no gains or losses other than those recognised above. 

The Directors consider all results to derive from continuing activities. 

The format of the Statement of Comprehensive Income follows the recommendations of the AIC Statement of Recommended 
Practice and is provided for information purposes. 

The accompanying notes form an integral part of these audited financial statements 

38

BAKER STEEL RESOURCES TRUST LIMITED

STATEMENT OF COMPREHENSIVE INCOME  
FOR THE YEAR ENDED 31 DECEMBER 2021 

Income
Interest income 
Dividend income 
Net gain on financial assets at fair value through profit or loss
Net foreign exchange loss
Net income 

Expenses 
Management fees 
Directors’ fees  
Administration fees 
Other expenses 
Depositary fees 
Custody fees 
Broker fees 
Audit fees 
Directors’ Insurance 
Directors’ expenses 
Legal fees 
Total expenses 

Notes 

2(i) 
2(j) 
3 

7,11 
11 
6 
8 

Year ended 
2021
Revenue
£

Year ended 
2021
Capital
£

Year ended 
2021
Total
£

 1,228,691 
 45,880 
 -
 -
 1,274,571 

 1,587,121 
 115,000 
 126,876 
 103,389 
 41,336 
 62,628 
 35,000 
 67,250 
15,750 
515 
 44,515 
2,199,380 

 -
 -
 2,254,094 
 (21,728) 
 2,232,366 

 1,228,691 
 45,880 
 2,254,094 
 (21,728) 
 3,506,937 

 - 
 - 
 - 
 - 
- 
 - 
 - 
 - 
 - 
- 
 - 
-

 1,587,121 
 115,000 
 126,876 
 103,389 
 41,336 
 62,628 
35,000 
 67,250 
15,750 
515 
 44,515 
2,199,380 

Net (loss)/gain for the year 

 (924,809) 

 2,232,366 

 1,307,557 

Net (loss)/gain for the year per Ordinary Share:
Basic and Diluted (in pence) 

12 

 (0.87) 

 2.10 

 1.23 

In the year ended 31 December 2021 there were no gains or losses other than those recognised above. 

The Directors consider all results to derive from continuing activities. 

The format of the Statement of Comprehensive Income follows the recommendations of the AIC Statement of Recommended 
Practice and is provided for information purposes. 

The accompanying notes form an integral part of these audited financial statements 

39 

BAKER STEEL RESOURCES TRUST LIMITED

STATEMENT OF CHANGES IN EQUITY 
FOR THE YEAR ENDED 31 DECEMBER 2022 

Management
Ordinary
Shares
£ 

Ordinary 
Shares
£ 

Treasury 
Shares
£ 

Revenue 
reserves 
£

Capital
 reserves
£ 

Total
equity
£ 

Balance as at 1 January 2021 
Net (loss)/gain for the year 
Balance as at 31 December 2021 

9,167
-
9,167 

76,113,180
-
76,113,180 

(140,492)
-
(140,492) 

10,971,969
(924,809)
10,047,160 

16,537,575
2,232,366
18,769,941 

103,491,399
1,307,557
104,798,956 

Net loss for the year
Balance as at 31 December 2022
Note

-
9,167 
                 10 

-
-
76,113,180 
(140,492) 
                 10               10 

(1,275,974)
8,771,186 

(19,040,134)
(270,193) 

(20,316,108)
84,482,848 

The accompanying notes form an integral part of these audited financial statements 

40 

BAKER STEEL RESOURCES TRUST LIMITED

STATEMENT OF CASH FLOWS 
FOR THE YEAR ENDED 31 DECEMBER 2022 

Cash flows from operating activities 
Net (loss)/gain for the year 
Adjustments to reconcile net (loss) /gain for the year to net cash used in operating 
activities: 
Interest income 
Dividend income 
Net loss/(gain) on financial assets at fair value through profit or loss 
Net decrease/(increase) in receivables 
Net decrease in payables 

Interest received 
Dividend received 

Net cash used in operating activities

Cash flows from investing activities 
Purchase of financial assets at fair value through profit or loss 
Sale of financial assets at fair value through profit or loss
Net cash provided by investing activities 

Year ended 
2022
£

Year ended 
2021
£

Notes

(20,316,108)

1,307,557

3 

(549,607)
(9,356)
19,038,918
4,233
(76,633)
(1,908,553)
741,135
9,356

(1,158,062)

(1,228,691)
(45,880)
(2,254,094)
 (2,504)
 (8,804)
(2,232,416)
 903,607 
 45,880 

(1,282,929) 

(1,882,060)
2,216,780
334,720

 (1,776,426)
 3,712,697 
1,936,271

Net (decrease)/increase in cash and cash equivalents 

(823,342)

653,342

Cash and cash equivalents at the beginning of the year 

1,077,482

424,140

Cash and cash equivalents at the end of the year 

9 

254,140

1,077,482

The accompanying notes form an integral part of these audited financial statements 

41 

 
BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR ENDED 31 DECEMBER 2022 

1. GENERAL INFORMATION 

Baker  Steel  Resources  Trust  Limited  (the  “Company”)  is  a  closed-ended  investment  company  with  limited  liability 
incorporated and domiciled on 9 March 2010 in Guernsey under the Companies (Guernsey) Law, 2008 with registration 
number  51576.  The  Company  is  a  registered  closed-ended  investment  scheme  registered  pursuant  to  the  Protection  of 
Investors (Bailiwick of Guernsey) Law, 2020 and the Registered Collective Investment Scheme Rules and Guidance, 2021 
issued by the Guernsey Financial Services Commission (“GFSC”). On 28 April 2010 the Ordinary Shares and Subscription 
Shares of the Company were admitted to the Official List of the UK Listing Authority and to trading on the Main Market of 
the  London  Stock  Exchange.  The  Company’s  Ordinary  and  Subscription  Shares  were  admitted  to  the  Premium  Listing 
Segment of the Official List on 28 April 2010.  

The final exercise date for the Subscription Shares was 2 April 2013. No Subscription Shares were exercised at this time 
and all residual/unexercised Subscription Shares were subsequently cancelled. 

The Company’s portfolio is managed by Baker Steel Capital Managers (Cayman) Limited (the “Manager”). The Manager 
has appointed Baker Steel Capital Managers LLP (the “Investment Manager”) as the Investment Manager to carry out certain 
duties. The Company’s investment objective is to seek capital growth over the long-term through a focused, global portfolio 
consisting  principally  of  the  equities,  or  related  instruments,  of  natural  resources  companies.  The  Company  invests 
predominantly in unlisted companies (i.e. those companies which have not yet made an Initial Public Offering (“IPO”)) and 
also in listed securities (including special situations opportunities and less liquid securities) with a view to exploiting value 
inherent in market inefficiencies and pricing anomalies.  

Baker  Steel  Capital  Managers  LLP  was  authorised  to  act  as  an  Alternative  Investment  Fund  Manager  (“AIFM”)  of 
Alternative Investment Funds (“AIFs”) on 22 July 2014. On 14 November 2014, the Investment Manager signed an amended 
Investment  Management  Agreement  with  the  Company,  to  take  into  account  AIFM  regulations.  AIFMD  focuses  on 
regulating the AIFM rather than the AIFs themselves, so the impact on the Company is limited. 

2. SIGNIFICANT ACCOUNTING POLICIES 

a) Basis of preparation

The financial statements have been prepared on a historical cost basis except for Financial Instruments at Fair Value Through 
Profit  or  Loss  (“FVTPL”)  in  accordance  with  International  Financial  Reporting  Standards  (“IFRS”)  as  adopted  by  the 
European Union. The financial statements have been prepared on a going concern basis. 

The  Company's  functional  currency  is  the  Great  Britain  pound  Sterling  (“£”),  being  the  currency  in  which  its  Ordinary 
Shares are issued and in which returns are made to shareholders. The presentation currency is the same as the functional 
currency. The financial statements have been rounded to the nearest £. The Company invests in companies around the world 
whose shares are denominated in various currencies.  

Income encompasses both revenue and capital gains/losses. For a listed investment company, it is best practice to distinguish 
revenue from capital. Revenue includes items such as dividends, interest, fees and other equivalent items. Capital is the 
return, positive or negative, from holding investments other than that part of the return that is revenue. The format of the 
Statement of Comprehensive Income follows the recommendations of the AIC Statement of Recommended Practice. 

Assets and liabilities are presented in order of liquidity. Their maturities are disclosed in Note 4(b). 

42 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

2. SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

a)   Basis of preparation (continued) 

New standards, amendments and interpretations to existing standards which are not yet effective for the current 
year 

A  number  of  new  standards  are  effective  for  annual  periods  beginning  after  1  January  2023  and  earlier  application  is 
permitted,  however  the  Company  has  not  early  adopted  the  new  or  amended  standards  in  preparing  these  financial 
statements. 

The following amended standards and interpretations are not expected to have a material impact on the Company’s financial 
statements: 

- Disclosure of Accounting Policies - Amendments to IAS 1 and IFRS Practice Statement 2 (effective for periods starting 
on or after 1 January 2023). 
- Definition of Accounting Estimates - Amendments to IAS 8 (effective for periods starting on or after 1 January 2023). 
- Deferred Tax related to Assets and Liabilities arising from a Single Transaction - Amendments to IAS 12 (effective for 
periods starting on or after 1 January 2023). 
- IFRS 17 Insurance Contracts (effective for periods starting on or after 1 January 2023). 
- Classification of Liabilities as Current or Non-current - Amendments to IAS 1 (effective for periods starting on or after 1 
January 2023). 

New standards, amendments and interpretations to existing standards which are effective for the current year 

There are a  number of new  standards, amendments  to standards and interpretations that are effective  for  annual  periods 
beginning  after  1  January  2022  and  were  adopted  from  their  effective  date.  These  amendments  did  not  have  a  material 
impact on the Company’s financial statements. 

- Property, Plant and Equipment: Proceeds before Intended Use – Amendments to IAS 16 (effective for periods starting on 
or after 1 January 2022). 
- Reference to the Conceptual Framework – Amendments to IFRS 3 (effective for periods starting on or after 1 January 
2022). 
- Onerous Contracts - Cost of Fulfilling a Contract (Amendments to IAS 37) (effective for periods starting on or after 1 
January 2022). 
- IFRS 9 Financial Instruments – Fees in the ‘10 per cent’ test for derecognition of financial liabilities (effective for periods 
starting on or after 1 January 2022). 

43 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

2. SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

b)

IFRS 9 Financial Instruments 
IFRS 9 sets out the requirements for recognising and measuring financial assets, financial liabilities and some contracts to 
buy or sell non-financial items.  

Classification and measurement of financial assets and financial liabilities 

A financial asset or liability is measured at amortised cost if it meets both of the following conditions and are not designated 
as at FVTPL: 
 it is held within a business model whose objective is to hold assets to collect contractual cash flows; and 
 its contractual terms give rise on specified dates to cash flows that are solely payments of principal and interest on the 

principal amount outstanding. 

All financial assets of the Company are measured at FVTPL, except for cash and cash equivalents which are measured at 
amortised cost. 

All financial liabilities of the Company are measured at amortised cost. 

Impairment of financial assets 
Under  IFRS  9  for  trade  receivables  the  Company  has  applied  the  simplified  model.  Under  the  simplified  approach  the 
requirement is to always recognise lifetime expected credit loss (“ECL”). Under the simplified approach there is no need to 
monitor significant increases in credit risk and measure lifetime ECLs at all times. The interest receivable is in respect of 
the Convertible loan notes, a list of which is presented in Note 4(c) on Page 58 of the Annual Report, and no provision has 
been made for credit losses. This is on the basis that the fair value of the underlying asset supports the convertible receivable. 

For other receivables, the Directors have concluded that any ECL on these receivables would be highly immaterial.   

c) Significant accounting judgements and estimates 

The  preparation  of  the  Company’s  financial  statements  requires  the  Directors  to  make  judgements,  estimates  and 
assumptions that affect the reported amounts recognised in the financial statements and disclosure of contingent liabilities. 
However,  uncertainty  about  these  assumptions  and  estimates  could  result  in  outcomes  that  could  require  a  material 
adjustment to the carrying amount of the asset or liability in future periods. 

(i) Judgements 

In the process of applying the Company’s accounting policies, the Directors have made the following judgements, which 
have had the most significant effect on the amounts recognised in the financial statements: 

Going Concern 
The Directors, as advised by the Audit Committee, have made an assessment of the Company’s ability to continue as a going 
concern and consider it appropriate to adopt the going concern basis of accounting. The discontinuation vote in 2021 was 
not passed and the next vote  is in 2024. To be passed, the discontinuation vote requires 75% of shareholders to vote  to 
discontinue. The Directors have received no indication that the resolution will be passed.  The Board are satisfied that the 
Company has the resources to continue in business for at least 12 months following the signing of these financial statements. 
As at 31 December 2022, approximately 13.8% of the Company’s assets were represented by cash and unrestricted listed 
and quoted investments which are readily realisable. Although the continuing Russian invasion of Ukraine has resulted in a 
reduction in the carrying value of investments with a Russian nexus it is not expected that it will affect the Company’s ability 
to operate on a normal basis. Neither of the two affected investments PAL and Azarga were expected to be a material source 
of revenue in the next two years. The Directors are not aware of any material uncertainties that may cast significant doubt 
upon the Company’s ability to continue as a going concern. 

(ii) Estimates and assumptions 

The key assumptions concerning the future and other key sources of uncertainty at the reporting date, that have a significant 
risk of causing a  material adjustment  to the  carrying amounts of assets  and liabilities  within the next financial  year, are 
discussed below. The Company based its assumptions and estimates on parameters available when the financial statements 
were prepared. However, existing circumstances and assumptions about future developments may change due to market 
changes or circumstances arising beyond the control of the Company. Such changes are reflected in the assumptions when 
they occur. Please refer to Note 3 for further information.

44 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

2. SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) 

c)   Significant accounting judgements and estimates (continued) 

(iii) Fair value of financial instruments 

When the fair values of financial assets and financial liabilities recorded in the Statement of Financial Position cannot be 
derived from active markets, their fair value is determined using a variety of valuation techniques that include the use of 
valuation  models.  The  inputs  to  these  models  are  taken  from  observable  markets  where  possible,  but  where  this  is  not 
feasible, estimation is required in establishing fair values. The estimates include considerations of liquidity and model inputs 
related to items such as credit risk, correlation and volatility. Changes in assumptions about these factors could affect the 
reported fair value of financial instruments in the Statement of Financial Position and the level where the instruments are 
disclosed in the fair value hierarchy. To assess the significance of a particular input to the entire measurement, the Company 
performs  sensitivity  analysis  or  stress  testing  techniques.  Please  refer  to  Note  3  for  further  information.  Investments  in 
associates are carried at fair value as they are held as part of the investment portfolio which is valued on a fair value basis. 

d)  Interest income and expense  

Bank interest income and interest expense are recognised on an accruals basis using the effective interest method. 

e)  Expenses  

All expenses are recognised on an accruals basis.

f)  Translation of foreign currencies 

Foreign currency transactions during the year are translated into Sterling at the rate of exchange ruling at the date of the 
transaction. Assets and liabilities denominated in foreign currencies are translated into Sterling at the rate of exchange ruling 
at the Statement of Financial Position date. Exchange differences including those arising from adjustment to fair value of 
financial  instruments  during  the  year,  are  included  in  the  Statement  of  Comprehensive  Income.  The  foreign  exchange 
movements relating to financial assets form part of the fair value movement in the Statement of Comprehensive Income. 

g)  Segment information 

The Directors are of the opinion that the Company is engaged in a single segment of business: investing in natural resources 
companies. 

h)  Net asset value per share 

Net Asset Value per Ordinary Share disclosed on the face of the Statement of Financial Position is calculated in accordance 
with the Company’s Prospectus by dividing the net assets of the Company on the Statement of Financial Position date by 
the number of Ordinary Shares (including the Management Ordinary Shares) outstanding at that date. Treasury Shares are 
excluded from the Net Asset Value per Ordinary Share calculation. 

i)

Interest on investments 
These comprise of interest accrued and interest received from convertible loans where interest is payable throughout the life 
of the instrument which are accounted for on an accruals basis and recognised in the Statement of Comprehensive Income. 

j)    Dividend income 

Dividend  income  is  accrued  on  an  ex-dividend  basis  and  recognised  in  the  Statement  of  Comprehensive  Income  and  is 
presented net of withholding tax. No withholding taxes were suffered during the year (2021: £Nil).

45 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3. FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS 

Investment Summary: 

Opening book cost 
Purchases at cost 
Proceeds on sale of investments 
Net realised (losses)/gains 
Closing cost 
Net unrealised gains
Financial assets held at fair value through profit or loss 

Year ended 
2022 
£ 
82,910,887 
1,882,060 
(2,216,780) 
(6,866,885) 
75,709,282 
8,602,673 
84,311,955 

Year ended 
2021 
£ 
81,003,041 
2,536,249 
(3,712,697) 
3,084,294 
82,910,887 
20,774,706 
103,685,593 

The  following  table  analyses  net  gains  on  financial  assets  at  fair  value  through  profit  or  loss  for  the  years  ended  
31 December 2022 and 31 December 2021. 

Financial assets at fair value through profit or loss
Realised (losses)/gains on: 
- Listed equity shares 
- Unlisted equity shares 
- Debt instruments 
- Warrants 

Movement in unrealised (losses)/gains on: 
 - Listed equity shares 
 - Unlisted equity shares 
 - Royalties 
 - Debt instruments 
 - Warrants 

Net (loss)/gain on financial assets at fair value through profit or loss 

Year ended 
2022 
£ 

Year ended 
2021 
£ 

(1,438,318) 
(5,118,472) 
(296,970) 
(13,125) 
(6,866,885) 

(792,604) 
- 
3,893,470 
(16,572) 
3,084,294 

(13,716,492) 
7,893,046 
(2,763,850) 
(2,675,240) 
(909,497) 
(12,172,033) 
(19,038,918) 

4,589,432 
1,571,711 
1,943,286 
(10,157,233) 
1,222,604 
(830,200) 
2,254,094 

The following table analyses investments by type and by level within the fair valuation hierarchy at 31 December 2022. 

Financial assets at fair value through 
profit or loss
Listed equity shares
Unlisted equity shares 
Royalties 
Warrants 
Debt instruments 

Quoted prices in 
active markets
Level 1
£

Quoted market 
based observables
Level 2
£

Unobservable 
inputs
Level 3
£

11,378,285
-
-
-
-
11,378,285

4,804,434
-
-
-
-
4,804,434

-
41,514,956
14,808.689
441,471
11,364,120
68,129,236

Total
£

16,182,719
41,514,956
14,808,689
441,471
11,364,120
84,311,955

46 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3.   FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS (CONTINUED)

The following table analyses investments by type and by level within the fair valuation hierarchy at 31 December 2021. 

Financial assets at fair value through 
profit or loss 
Listed equity shares 
Unlisted equity shares 
Royalties 
Warrants 
Debt instruments 

Quoted prices in 
active markets
Level 1
£

Quoted market 
based observables
Level 2
£

Unobservable 
inputs 
Level 3
£

Total
£

4,879,486
-
-
-
-
4,879,486

14,064,224
-
-
-
-
14,064,224

-
46,971,239 
16,479,049
1,364,093 
19,927,502
 84,741,883

18,943,710
46,971,239 
16,479,049
1,364,093 
19,927,502
103,685,593 

The table below shows a reconciliation of beginning to ending fair value balances for Level 3 investments and the amount 
of total gains or losses for the year included in net gain on financial assets and liabilities at fair value through profit or loss 
held at 31 December 2022. 

31 December 2022 

Opening balance 1 January 2022 
Purchases of investments 
Conversion 
Sales of investments 
Transfer out of Level 3 
Change in net unrealised gains/(losses) 
Realised losses 
Closing balance 31 December 2022 

Unrealised gains on investments still 
held at 31 December 2022 

Unlisted 
Equities 
£ 

46,971,239 
- 
- 
(178,554) 
(8,052,304) 
7,893,046 
(5,118,471) 
41,514,956 

Debt 

Royalties 
£ 

instruments  Warrants 
£ 
£ 

Total 
£ 

16,479,048 
- 
1,093,491 
- 
- 
(2,763,850) 
- 
14,808,689 

19,927,503 
189,649 
(1,093,491) 
- 
(4,687,331) 
(2,675,240) 
(296,970) 
11,364,120 

1,364,093 
- 
- 
- 
- 
(909,497) 
(13,125) 
441,471 

84,741,883 
189,649 
- 
(178,554) 
(12,739,635) 
1,544,459 
(5,428,566) 
68,129,236 

10,549,611 

1,905,220 

1,675,718 

441,471 

14,592,020 

The table below shows a reconciliation of beginning to ending fair value balances for Level 3 investments and the amount 
of total gains or losses for the year included in net gain on financial assets and liabilities at fair value through profit or loss 
held at 31 December 2021.

31 December 2021 

Opening balance 1 January 2021 
Purchases of investments 
Sales of investments 
Conversion* 
Transfer out of Level 3 
Change in net unrealised gains/losses 
Realised gains 
Closing balance 31 December 2021 

Unrealised gains on investments still 
held at 31 December 2021 

Unlisted 
Equities 
£ 
36,987,733 
 300,143 
 - 
11,987,827 
 (3,876,175) 
1,571,711 
 - 
46,971,239 

Royalties 
£ 
14,512,762 
23,000 
 - 
- 
 - 
  1,943,286 
 - 
16,479,048 

Debt 

instruments  Warrants 
£ 
141,489 
 - 
16,572 
- 
 - 
 1,222,604 
(16,572) 
1,364,093 

£ 
43,780,112 
541,140 
(399,576) 
(12,730,410) 
(5,000,000) 
(10,157,233) 
3,893,470 
19,927,503 

Total 
£ 
95,422,096 
864,283 
(383,004) 
(742,583) 
(8,876,175) 
(5,419,632) 
3,876,898 
84,741,883 

 7,686,978 

  4,689,071 

 2,948,246 

 1,350,968 

16,675,263 

*Conversion of Futura and Anglo Saxony debt into Level 3 equity positions and Mines & Metal Trading into Silver X and 
therefore a Level 1 investment 

47 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3.   FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS (CONTINUED)

It is the Company’s policy to recognise a change in hierarchy level when there is a change in the status of the investment, 
for  example  when  a  listed  company  delists  or  vice  versa,  or  when  shares  previously  subject  to  a  restriction  have  that 
restriction released. The transfers between levels are recorded either on the value of the investment immediately after the 
event or the carrying value of the investment at the beginning of the financial year.  

The following transfers from Level 3 have taken place during the year ended 31 December 2022: 

On 8 April 2022 First Tin listed on the London Stock Exchange. The shares held by the Company are locked up until 8 April 
2023 and are therefore held at a discount to the market price and accordingly the investment has been transferred from Level 
3 to Level 2 in these financial statements.  

On  15  June  2022  the  Company  converted  its  convertible  loan  to  Azarga  into  Equity.  The  Company  holds  over  30%  of 
Azarga and the investment is therefore carried at a discount to the market prices as it is considered unlikely the quoted price 
could be achieved if the Company decided to sell its investment. Accordingly, the investment has been transferred from 
Level 3 to Level 2 in these financial statements. 

On 8 June 2022 the Company converted its US$4m convertible debenture into Silver X shares. This resulted in a transfer 
from level 3 to level 1 of the investment. 

The following transfer from Level 2 has taken place during the year ended 31 December 2022: 

On 21 October 2022, the lock-up relating to the shares held in Tungsten West Plc expired and accordingly the investment 
has been transferred from Level 2 to Level 1. 

In determining an investment’s position within the fair value hierarchy, the Directors take into consideration the following 
factors:

Investments whose values are based on quoted market prices in active markets are classified within Level 1. These include 
listed equities  with observable market prices. The Directors do not adjust the quoted price for such instruments, even in 
situations where the Company holds a large position and a sale could reasonably impact the quoted price. The Company 
does not and neither did it during the year hold a sufficiently large position in any listed company classified as Level 1 that 
it could impact the quoted price via a sale of its investment. 

Investments that trade in markets that are not considered to be active but are valued based on quoted market prices, dealer 
quotations or alternative pricing sources supported by observable inputs, are classified within Level 2. These include certain 
less-liquid listed equities. Level 2 investments are valued with reference to the listed price of the shares should they be freely 
tradable after applying a discount for liquidity if relevant. As Level 2 investments include positions that are not traded in 
active  markets  and/or  are  subject  to  transfer  restrictions,  valuations  may  be  adjusted  to  reflect  illiquidity  and/or  non-
transferability, which are generally based on available market information. The Company had two Level 2 investments at 
31 December 2022 (31 December 2021: one). 

Investments classified within Level 3 have significant unobservable inputs. They include unlisted debt instruments, unlisted 
equity shares and warrants. Level 3 investments are valued using valuation techniques explained below. The inputs used by 
the Directors in estimating the value of Level 3 investments include the original transaction price, recent transactions in the 
same or similar instruments if representative in volume and nature, completed or pending third-party transactions in the 
underlying investment of comparable issuers, subsequent rounds of financing, recapitalisations and other transactions across 
the capital structure, offerings in the equity or debt capital markets, and changes in financial ratios or cash flows. Level 3 
investments may also be adjusted with a discount to reflect illiquidity and/or non-transferability in the absence of market 
information. 

48 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3.   FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS (CONTINUED)

Valuation methodology of Level 3 investments 

The primary valuation technique is of “Latest Recent Transaction” being either recent external fund raises or transactions. 
In all cases the valuation considers whether there has been any change since the transaction that would indicate the price is 
no longer fair value. Where an unquoted investment  has been acquired or  where  there  has been a material arm’s length 
transaction during the past six months it will be carried at transaction value, having taken into account any change in market 
conditions and the performance of the investee company between the transaction date and the valuation date. If it is assessed 
that a recent transaction is not at an arm’s length or there are other indicators that it has not been executed at a price that is 
representative of fair value then the transaction value will not be used as the carrying value of the investment. Where there 
has been no  Latest  Recent Transaction the primary  valuation driver is  IndexVal. For each core  unlisted investment, the 
Company  maintains a  weighted  average basket of listed companies  which are comparable  to the investment in terms of 
commodity, stage of development and location (“IndexVal”). IndexVal is used as an indication of how an investment’s share 
price might have moved had it been listed. Movements in commodity prices are deemed to have been taken into account by 
the movement of IndexVal.  

A  secondary  tool  used  by  Management  to  evaluate  potential  investments  as  well  as  to  provide  underlying  valuation 
references for the Fair Value already established is Development Risk Adjusted Value (“DRAV”). DRAVs are not a primary 
determinant  of  Fair  Value.  The  Investment  Manager  prepares  discounted  cash  flow  models  for  the  Company’s  core 
investments annually taking into account significant new information, and for decision making purposes  when required. 
From these, DRAVs are derived. The computations are based on consensus forecasts for long term commodity prices and 
investee company management estimates of operating and capital costs. The Investment Manager takes account of market, 
country and development risks in its discount factors. Some market analysts incorporate development risk into the discount 
rate in arriving at a net present value (“NPV”) rather than establishing an NPV discounted purely for cost of capital and 
country risk and then applying a further overall discount to the project economics dependent on where such project sits on 
the development curve per the DRAV calculations.  

The valuation techniques for Level 3 investments can be divided into six groups: 

i. Transactions & Offers  
Where there have been transactions within the past 6 months either through a capital raising by the investee company or 
known secondary market transactions, representative in volume and nature and conducted on an arm’s length basis, this is 
taken as the primary driver for valuing Level 3 investments, having taken into account of any change in market conditions 
and the performance of  the  investee company between the transaction date  and the  valuation date. This includes offers, 
binding or otherwise from third parties around the year end which may not have completed prior to the year-end but have a 
high chance of success and are considered to represent the situation at year end. 

ii. IndexVal 
Where  there  have  been  no  known  transactions  for  6  months,  at  the  Company’s  half  year  and  year  end,  movements  in 
IndexVal will generally be taken into account in assessing Fair Value where there has been at least a 10% movement in 
IndexVal over at least a six-month period. The IndexVal results are used as an indication of trend and are viewed in the 
context of investee company progress and any requirement for finance in the short term for further progression. 

iii. Royalty Valuation Model 
The  rights  to  receive  royalties  are  valued  on  projected  cashflows  taking  into  account  expected  time  to  production  and 
development risk and adjusted for movement in commodity prices. 

iv. EBITDA Multiple 
In the case of Cemos Group plc, which moved to full production during 2020 and so could reflect maintainable earnings, its 
main asset is a cement plant with no defined life like a mining project and therefore has been valued on the basis of a multiple 
of a blend of historical and forecast earnings before interest, tax, depreciation and amortisation (“EBITDA”) when compared 
to listed comparable cement producers. 

49 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3.  FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS (CONTINUED) 

Valuation methodology of Level 3 investments (continued) 

v. Warrants 
Warrants are valued using a simplified Black Scholes model taking into account time to expiry, exercise price and volatility. 
Where there is no established market for the underlying shares the average volatility of the companies in that investment’s 
basket of IndexVal comparables is utilised in the Black Scholes model.  

vi. Convertible loans 
Convertible loans are valued at fair value through profit or loss, taking into account credit risk and the value of the conversion 
aspect.

Quantitative information of significant unobservable inputs – Level 3 

2022
£

Valuation technique 

Unobservable input 

Range of 
unobservable input 
(weighted average)

Description 

Unlisted Equity  
Unlisted Equity
Unlisted Equity 
Royalties 

28,797,176 Transactions 
3,499,979 IndexVal 
9,201,855 EBITDA Multiple 

14,808,689 Royalty Valuation model 

Unlisted Equity

15,946 Other 

Private transactions 
Change in index 
EBITDA Multiple 
Commodity price and 
discount rate risk 
Exploration results, 
study results, 
financing 

n/a 
n/a 
n/a 
n/a 

n/a 

Debt Instruments 
Black Pearl Limited 
Partnership
Other Convertible 
Debentures/Loans 

Warrants 

Warrants 

726,171 Valued at mean estimated 

recovery 
10,637,949 Valued at fair value with 

Estimated recovery 
range 
Rate of Credit Risk 

+/-50% 

20%-40% 

reference to credit risk  

242,771 Simplified Black Scholes 

Volatilities 

50% 

Model 
198,700 External valuation 

50 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3.  FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS (CONTINUED) 

Quantitative information of significant unobservable inputs – Level 3 (continued) 

2021
£

Valuation technique 

Unobservable input 

Range of 
unobservable input 
(weighted average)

Description 

Unlisted Equity  
Unlisted Equity
Unlisted Equity 
Royalties 

 20,914,006  Transactions 
 16,587,037 

IndexVal 

 9,306,914  EBITDA Multiple 
 16,479,048 Royalty Valuation model 

Unlisted Equity

163,284 Other 

Private transactions 
Change in index 
EBITDA Multiple 
Commodity price and 
discount rate risk 
Exploration results, 
study results, 
financing 

n/a 
n/a 
n/a 
n/a 

n/a 

Debt Instruments 
Black Pearl Limited 
Partnership
Other Convertible 
Debentures/Loans 
Other Convertible 
Debentures/Loans 

 1,292,467  Valued at mean estimated 

 2,157,657 

recovery 
IndexVal 

Estimated recovery 
range 
Change in Index 

+/-50% 

n/a 

16,477,378 Valued at fair value with 

Rate of Credit Risk 

20%-40% 

reference to credit risk  

Warrants 

1,364,093 Simplified Black Scholes 

Volatilities 

50% 

Model 

Information on third party transactions in unlisted equities is derived from the Investment Manager’s market contacts. The 
change in IndexVal for each particular unlisted equity is derived from the weighted average movements of the individual 
baskets for that equity so it is not possible to quantify the range of such inputs.  

51 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3.  FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS (CONTINUED) 

Sensitivity analysis to significant changes in unobservable inputs within Level 3 investments 

The significant unobservable inputs used in the fair value measurement categorised within Level 3 of the fair value hierarchy 
together with a quantitative sensitivity analysis as at 31 December 2022 are as shown below:

Description 

Input

Sensitivity used

Effect on Fair Value (£) 

Unlisted Equity 

Transactions & Expected Transactions 

+/- 20% 

+/-5,759,434 

Unlisted Equity  

Change in IndexVal 

+44%/-79%* 

+1,539,991/-2,764,984 

Unlisted Equity 

EBITDA Multiple 

Royalties 

Royalties 

Debt Instruments 

Black Pearl Limited 
Partnership 

Commodity Price 

Discount Rate 

Probability weighting 

Others/Loans 

Risk discount rate 

Convertibles /Loans 

Volatility of Index Basket 

Warrants

Volatility of Index Basket 

+/- 20% 

+/-20% 

+/-1,840,371 

+/-2,956,853 

+/-20% 

-1,597,086/+1,939,463 

+/-33% 

+/-20% 

+/-40% 

+/-40% 

+/- 239,627 

-1,160,677/+227,963 

+206,177/-1,656 

+21,662/-18,733 

* The sensitivity analysis refers to a percentage amount added or deducted from the input and the effect this has on the fair 
value. The +44%/-79% sensitivity was used as this was the range of movements of the constituents in the IndexVal baskets 
for Nussir 

52 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

3. FINANCIAL ASSETS AT FAIR VALUE THROUGH PROFIT OR LOSS (CONTINUED) 

Sensitivity analysis to significant changes in unobservable inputs within Level 3 investments 

The significant unobservable inputs used in the fair value measurement categorised within Level 3 of the fair value hierarchy 
together with a quantitative sensitivity analysis as at 31 December 2021 are as shown below:

Description 

Input

Sensitivity used

Effect on Fair Value (£)

Unlisted Equity 

Transactions & Expected Transactions 

+/- 10% 

+/- 2,091,401 

Unlisted Equity  

Change in IndexVal 

+101%/-57%* 

+ 16,752,907/-9,454,611 

Unlisted Equity 

EBITDA Multiple 

Royalties 

Royalties 

Debt Instruments 

Commodity Price 

Discount Rate 

Black Pearl Limited 
Partnership 

Probability weighting 

Others/Loans 

Risk discount rate 

Convertibles /Loans 

Volatility 

Warrants

Volatility 

+/- 20% 

+/-20% 

+/-20% 

+/-33% 

+/-20% 

+/-40% 

+/-40% 

+/-1,861,383 

+/- 3,291,141 

+/- 4,788,365 

+/- 426,514 

-2,417,009/+1,292,006 

+704,696/-262,075 

-36,769,+56,488 

* The sensitivity analysis refers to a percentage amount added or deducted from the input and the effect this has on the fair 
value. The +101%/-57% sensitivity was used as this was the range of movements of the constituents in the IndexVal baskets 
for Bilboes Gold, Kanga Potash and Prism 

The  Company  has  not  disclosed  the  fair  value  for  financial  assets  such  as  cash  and  cash  equivalents  and  short-term 
receivables and payables, because their carrying amounts are a reasonable approximation of fair values. 

53 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

4. RISK MANAGEMENT POLICIES AND DISCLOSURES  

The Company’s principal financial instruments comprise financial assets, primarily unlisted equity investments and loans 
in  natural  resources  companies.  The  portfolio  is  concentrated  on  projects  on  the  large  liquid  commodity  markets  and 
diversified in terms of geography. These investments reflect the core of the Company’s investment strategy. 

The Company manages its exposure to key financial risks primarily through diversification of geography and commodity, 
and through technical and legal due diligence. The objective of the policy is to support the delivery of the Company’s core 
investment objective whilst maintaining future financial security. The main risks that could adversely affect the Company’s 
financial  assets or  future  cash flows are  market  risk (comprising  market price risk, currency risk and interest  rate risk), 
commodity price risk, liquidity risk, concentration risk and credit risk. 

The Company’s financial liabilities principally comprise fees payable to various parties and arise directly from its operations. 

Risk exposures and responses 

The Company’s Board of Directors oversees the management of financial risks, each of which is summarised below. 

a) Market risk 

Market risk is the risk that the fair value of a financial instrument will fluctuate because of changes in market prices. Market 
risk comprises three types of risk: market price risk, currency risk and interest rate risk.  

i. Market price risk 

Market price risk is the risk that the fair value of future cash flows will fluctuate because of changes in the market prices of 
the Company’s investment portfolio. 

The sensitivity analysis on the previous page illustrates the sensitivity of the key inputs into the market valuation and the 
resulting impact of the  fair values. The level of change is considered to be reasonably possible. The sensitivity analysis 
assumes all other variables are held constant. 

ii.  Currency risk 

At 31 December 2022, the largest non-Sterling portion of the Company’s financial assets and liabilities was denominated 
in Australian Dollars. The functional currency of the Company is Sterling. Currency risk is the risk that the value of non-
Sterling denominated financial instruments will fluctuate due to changes in foreign exchange rates. The tables below show 
the currencies and amounts the Company was exposed to at 31 December 2022 and 31 December 2021. 

31 December 2022
Currency

AUD 
CAD 
EUR 
GBP 
NOK
USD 

31 December 2021
Currency

AUD 
CAD 
EUR 
GBP 
NOK
USD 

Amount in 
local currency
 43,324,009 
 10,995,550 
 11,430,526 
 19,408,238 
 41,552,423 
 24,410,380 

Amount in 
local currency
 38,079,806 
 3,850,097 
 12,176,338 
 35,626,057 
 44,748,764 
 43,995,802 

54 

Conversion rate 
 (based on £)
 0.5640 
 0.6133 
 0.8868 
 1.0000 
 0.0842 
 0.8299 

Conversion rate 
 (based on £)
 0.5371 
 0.5837 
 0.8401 
 1.0000 
 0.0838 
 0.7386 

Value  % of net assets 

£ 
 24,436,834 
 6,743,260 
 10,136,120
 19,408,238 
 3,499,979 
20,258,417
 84,482,848 

28.93%
7.98%
12.00%
22.97%
4.14%
23.98%
100.00%

Value  % of net assets 

£ 
 20,451,724 
 2,247,114 
 10,229,833 
 35,626,057 
 3,751,021 
 32,493,207 
 104,798,956 

19.52%
2.14%
9.76%
33.99%
3.58%
31.01%
100.00%

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

4. RISK MANAGEMENT POLICIES AND DISCLOSURES (CONTINUED) 

a) Market risk (continued) 

ii.  Currency risk (continued) 

Analysis  has  been  completed  to  assess  what  movements  in  currency  rates  are  reasonably  possible.  This  analysis  has 
considered the variance between the highest and lowest conversion rates in 2022 and 2021 for each of the currencies in the 
table below. The table shows the potential movements in the Company’s net assets as a result of such foreign exchange 
movements. 

Currency

AUD 
CAD 
EUR 
NOK
USD 

Reasonably 
possible 
move 
10% 
11% 
13% 
20% 
16% 

2022
Value
£
2,443,683 
741,759 
 1,317,696
699,996 
 3,241,347
8,444,481

2021
Value
£
2,045,172 
247,183 
1,329,878 
750,204 
5,198,913 
9,571,350

The  estimated  movement is  based on management’s determination of a  reasonably possible change in foreign exchange 
rates. In practice, the actual results may differ from the sensitivity analysis above and the difference could be material. 

iii.  Interest rate risk 

Although the Company’s financial assets and liabilities expose it indirectly to risks associated with the effects of fluctuations 
in the prevailing levels of market interest rates on its financial position and fair value, it is subject to little direct exposure to 
interest rate fluctuations as the majority of the financial assets are equity investments or similar investments which do not 
pay interest. For valuation purposes convertible loans all have fixed interest rates and are treated more like quasi equity 
albeit with higher ranking than equity. As such they are not directly exposed to interest rates from a cash flow perspective. 
Any  excess  cash  and  cash  equivalents  are  invested  at  short-term  market  interest  rates  which  expose  the  Company,  to  a 
limited  extent,  to  interest  rate  risk  and  corresponding  gains/losses  from  a  change  in  the  fair  value  of  these  financial 
instruments. 

The table below summarises the Company’s exposure to interest rate risk. It includes the Company’s assets and liabilities 
at fair values, categorised by the earlier of contractual re-pricing or maturity dates. 

At 31 December 2022 

Assets 
Cash and cash equivalents 
Financial assets held at fair value through profit or loss* 
Other receivables 
Interest receivable* 
Total Assets

Liabilities
Other liabilities 
Total Liabilities
Interest rate sensitivity gap

Less than 
6 months
£
254,140
524,813
-
57,917
836,870

More than  Non-interest 
bearing
£
-
72,947,836
17,899
-
72,965,735

6 months 
£
-
10,839,306
-
-
10,839,306

Total
£
254,140
84,311,955
17,899
57,917
84,641,911

-
-
836,870

-
-
10,839,306

159,063
159,063

159,063
159,063

      *The interest rate risks on these items are considered as part of overall price risk in valuing the convertibles.

55 

 
 
 
 
 
BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

4. RISK MANAGEMENT POLICIES AND DISCLOSURES (CONTINUED) 

a) Market Risk (continued) 

iii.  Interest rate risk (continued) 

At 31 December 2021 

Assets 
Cash and cash equivalents 
Financial assets held at fair value through profit or loss* 
Other receivables 
Interest receivable* 
Total Assets

Liabilities
Other liabilities 
Total Liabilities
Interest rate sensitivity gap

Less than 
6 months
£
 1,077,482 
1,235,273
 - 
 249,445 
 2,562,200 

More than  Non-interest 
bearing
£
 - 
 86,212,477 
 22,132 
 - 
86,234,609 

6 months 
£
 - 
 16,237,843 
 - 
 - 
 16,237,843 

Total
£
 1,077,482 
 103,685,593 
 22,132 
 249,445 
 105,034,652 

 - 
 - 
2,562,200 

 - 
 - 
 16,237,843 

 235,696 
 235,696 

 235,696 
 235,696 

*The interest rate risks on these items are considered as part of overall price risk in valuing the convertibles. 

Interest rate sensitivity 
It is the opinion of the Directors that the Company is not materially exposed to interest rate risk and accordingly no interest 
rate sensitivity calculation has been provided in these financial statements. 

b)  Liquidity risk 

Liquidity risk is defined as the risk that the Company may not be able to settle or meet its obligations as they fall due. The 
Company invests in unlisted equities for which there may not be an immediate market. The Company seeks to mitigate this 
risk by maintaining cash and readily realisable listed equity positions which will cover its ongoing operational expenses. 

The Company has the ability to incur borrowings of up to 10% of its NAV but the Company's policy is to restrict any such 
borrowings to temporary purposes only, such as settlement mis-matches. 

The  table  below  analyses  the  Company’s  financial  assets  and  liabilities  into  relevant  maturity  groupings  based  on  the 
remaining period at the Statement of Financial Position date to the contractual maturity date. The amounts in the table are 
the contractual cash flows. 

At 31 December 2022

Assets
Cash and cash equivalents 
Financial assets held at fair 
value through profit 
or loss 
Receivables 
Total Assets 

Less than
1 month
£ 
254,140

1-3 months
£ 
-

3-12 months
£ 
-

More than
12 months
£ 
-

No 
contractual
maturity
£ 
-

Total
£ 
254,140

-
64,364
318,504

524,813
11,452
536,265

10,088,045
-
10,088,045

491,092

73,208,005

491,092

73,208,005

84,311,955
75,816
84,641,911

Liabilities
Other payables 
and accrued expenses 
Total Liabilities

Less than
1 month
£ 

84,896
84,896

Net assets attributable to shareholders

1-3 months
£ 

3-12 months
£ 

More than
12 months
£ 

No 
contractual
maturity
£ 

Total
£ 

-
-

74,167
74,167

-
-

-
-

159,063
159,063

84,482,848

56 

 
 
 
 
 
 
BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

4. RISK MANAGEMENT POLICIES AND DISCLOSURES (CONTINUED) 

b)   Liquidity risk (continued)

The  table  below  analyses  the  Company’s  financial  assets  and  liabilities  into  relevant  maturity  groupings  based  on  the 
remaining period at the Statement of Financial Position date to the contractual maturity date. The amounts in the table are 
the contractual cash flows. 

At 31 December 2021

Assets
Cash and cash equivalents 
Financial assets held at fair 
value through profit 
or loss 
Receivables 
Total Assets 

Liabilities
Other payables 
and accrued expenses 
Total Liabilities

Less than
1 month
£ 
 1,077,482 

1-3 months
£ 
 - 

3-12 months
£ 
 - 

More than
12 months
£ 
 - 

No 
contractual
maturity
£ 
 - 

Total
£ 
 1,077,482 

 - 
 249,445 
 1,326,927 

1,235,273 
 16,132 
1,251,405

4,721,075 
 6,000 
4,727,075

11,516,768
 - 
 11,516,768 

86,212,477  103,685,593 
 271,577 
86,212,477  105,034,652 

 - 

Less than
1 month
£ 

1-3 months
£ 

3-12 months
£ 

More than
12 months
£ 

No 
contractual
maturity
£ 

Total
£ 

 28,750 
 28,750 

 144,279 
 144,279 

 62,667 
 62,667 

 - 
 - 

 - 
 - 

 235,696 
 235,696 

Net assets attributable to shareholders

104,798,956

The  value  of  the  cash  and  level  1  listed  equity  positions  held  by  the  Company  at  the  year-end  was  £11,632,425  (2021: 
£5,956,968 ) with the total liabilities at the year-end at £159,063 (2021: £235,696). 

c)  Credit risk 

Credit risk is the risk that a counterparty will be unable to pay amounts in full as they fall due. The Company has exposure 
to credit risk in relation to its cash balances, debt instruments, loan and loan notes as stated in the Statement of Financial 
Position.  

The Company seeks to mitigate this risk by lending to companies with projects which have significant value over and above 
the  value  of  the  debt  in  such  company  so  that  there  is  a  significant  equity  “buffer”.  The  maximum  credit  risk  on  debt 
instruments for the Company is £11,364,120 (2021: £19,950,848). 

The Company’s financial assets are exposed to credit risk, which amounted to the following at the Statement of Financial 
Position date: 

Assets 
Cash and cash equivalents 
Interest receivable 
Other receivables 
Financial assets held at fair value through profit or loss 
Total assets 

2022 

£ 

254,140 
57,917 
17,899 
84,311,955 
84,641,911 

2021
£

1,077,482 
 249,445 
 22,132 
 103,685,593 
105,034,652

57 

 
BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

4. RISK MANAGEMENT POLICIES AND DISCLOSURES (CONTINUED) 

c)  Credit risk (continued)

As at 31 December 2022, the Company's non-equity financial assets exposed to credit risk were held with the following 
ratings: 

Financial Assets 

Counterparty

-Convertible Loan Note 
-Convertible Loan Note 
-Convertible Loan Note 
-Loan Note 
-Loan Note 
-Loan Note 
Cash and cash equivalents 
Total 

Bilboes Gold Limited 
Black Pearl Limited Partnership  
Futura Resources Limited 
Cemos Group Plc  
PRISM Diversified Limited Loan Note 1 
PRISM Diversified Limited Loan Note 2 
HSBC  Bank plc 

**Credit
Rating
NR*
NR*
NR*
NR*
NR*
NR*
A+

2022
% of net assets
 0.03 
 0.86 
 0.16 
 11.94 
 0.11 
 0.35 
 0.30 
13.75

As at 31 December 2021, the Company's non-equity financial assets exposed to credit risk were held with the following 
ratings: 

Financial Assets 

Counterparty

Azarga Metals 
Bilboes Holdings Loan Note 1 
Bilboes Holdings Loan Note 2 
Silver X Mining Corporation (Previously 
known as Mines & Metals Trading (Peru) 
Plc) 
Black Pearl Limited Partnership  
Futura Resources Limited 

Cemos Group Plc  
PRISM Diversified Limited Loan Note 1 
PRISM Diversified Limited Loan Note 2 
HSBC  Bank plc 

-Convertible Loan & Loan Note 
-Convertible Loan & Loan Note 
-Convertible Loan & Loan Note 
-Convertible Loan & Loan Note 

-Convertible Loan Note 
-Convertible Unsecured Loan 
Security 
-Loan Note 
-Loan Note 
-Loan Note 
Cash and cash equivalents 
Total 

* No rating available 
**As per S&P 

**Credit
Rating
NR*
NR*
NR*
NR*

NR*
NR*

NR*
NR*
NR*
AA-

2021
% of net assets
 2.11 
 1.72 
 0.33 

 2.37 
 1.23 

 1.18 
 9.72 
 0.08 
 0.27 
 1.03 
20.04

58 

 
 
 
 
 
 
BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

4. RISK MANAGEMENT POLICIES AND DISCLOSURES (CONTINUED) 

d)  Concentration risk  

The Company’s investment policy is to invest in natural resources companies, both listed and unlisted, that the Investment 
Manager considers to be undervalued and that have strong fundamentals and attractive growth prospects which means that 
the Company has significant concentration risk relating to natural resources companies.  

Concentration  risks  include,  but  are  not  limited  to  natural  resources  asset  category  (such  as  gold)  and  geography.  The 
Company may at certain times hold relatively few investments. The Company could be subject to significant losses if it 
holds a large position in a particular investment that declines in value or is otherwise adversely affected, including by the 
default of the issuer. Such risks potentially could have a material adverse effect on the Company’s financial position, results 
of operations, business prospects and returns to investors. The Company’s investments are geographically diverse reducing 
this aspect of concentration risk. In terms of commodity, the portfolio is likewise diversified in the large liquid markets of 
silver, gold, iron ore, coal and copper to mitigate this aspect of concentration risk. 

5. TAXATION 

The Company is a Guernsey Exempt Company and is therefore not subject to taxation in Guernsey on its income under the 
Income Tax (Exempt Bodies) (Guernsey) Ordinance, 1989. An annual exemption fee of £1,200 (2021: £1,200) has been 
paid. The Company may, however, be exposed to taxes in certain other territories in which it invests such as withholding 
taxes on interest payments and dividends and on realisations of investments. 

6. ADMINISTRATION FEES 

The Administrator, HSBC Securities Services (Guernsey) Limited, is paid fees for acting as administrator of the Company 
at the rate of 7 basis points of gross asset value up to US$250 million; the rate reduces to 5 basis points of gross asset value 
above US$250 million. The Administrator is also reimbursed by the Company for reasonable out-of-pocket expenses. These 
fees are calculated and accrued as at the last business day of each month and paid monthly in arrears. 

The Administrator is also entitled to a fee for its provision of corporate secretarial services provided to the Company on a 
time  spent  basis  and  subject  to  a  minimum  annual  fee  of  £40,000.  The  Company  is  also  responsible  for  any  sub-
administration fees as agreed in writing from time to time, and reasonable out-of-pocket expenses. The Administrator is also 
entitled to fees of €5,000 for preparation of the financial statements of the Company. 

The administration fees payable for the year ended 31 December 2022 were £118,002 (2021: £126,876) of which £9,659 
(2021: £10,638) was payable at 31 December 2022. HSBC Securities Services (Ireland) DAC, the sub-Administrator, is 
paid a portion of these fees by the Administrator. 

7. MANAGEMENT AND PERFORMANCE FEES 

The  Manager  was  appointed  pursuant  to  a  management  agreement  with  the  Company  dated  31  March  2010  (the 
“Management Agreement”). The Company pays to the Manager a management fee which is equal to 1/12th of 1.75 per cent 
of the total average market capitalisation of the Company during each month. The management fee is calculated and accrued 
as at the last business day of each month and is paid monthly in arrears. The Investment Manager’s fees are paid by the 
Manager. 

The management fee for the year ended 31 December 2022 was £1,160,507 (2021: £1,587,121) of which £69,854 (2021: 
£122,894) was outstanding at the year end. 

The Manager is also entitled to a performance fee.  The Performance Period is each 12-month period ending on 31 December 
(the “Performance Period”). The amount of the performance fee is 15 per cent of the total increase in the NAV, if the Hurdle 
has been met, at the end of the relevant Performance Period, over the highest previously recorded NAV as at the end of a 
Performance  Period  in  respect  of  which  a  performance  fee  was  last  accrued,  having  made  adjustments  for  numbers  of 
Ordinary Shares issued and/or repurchased (“Highwater Mark”). The Hurdle is the Issue Price multiplied by the shares in 
issue, increased at a rate of 8% per annum compounded to the end  of the relevant Performance  Period.  In addition, the 
performance  fee  will only become  payable  if  there  has been sufficient  net realised gains.  As at 31 December 2022, the 
Highwater Mark was the equivalent of approximately 94 pence per share with the relevant Hurdle being the equivalent of 
approximately 163 pence per share. 

There were no earned performance fees payable for the current or prior year. 

59 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

7. MANAGEMENT AND PERFORMANCE FEES (CONTINUED) 

If the Company wishes to terminate the Management Agreement without cause it is required to give the Manager 12 months 
prior notice or pay to the Manager an amount equal to: (a) the aggregate investment management fee which would otherwise 
have been payable during the 12 months following the date of such notice (such amount to be calculated for the whole of 
such period by reference to the Market Capitalisation prevailing on the Valuation Day on or immediately prior to the date 
of such  notice);  and (b) any  performance  fee accrued  at  the  end of any Performance Period which ended on or prior to 
termination and which remains unpaid at the date of termination which shall be payable as soon as, and to the extent that, 
sufficient cash or other liquid assets are available to the Company (as determined in good faith by the Directors), provided 
that such accrued performance fee shall be paid prior to the Company making any new investment or settling any other 
liabilities; and (c) where termination does not occur at 31 December in any year, any performance fee accrued at the date of 
termination  shall  be  payable  as  soon  as  and  to  the  extent  that  sufficient  cash  or  other  liquid  assets  are  available  to  the 
Company (as determined in good faith by the Directors), provided that such accrued performance fee shall be paid prior to 
the Company making any new investment or settling any other liabilities.  

8.  OTHER EXPENSES 

Research fees
Regulatory fees
Investor services fees
Public relation fees
Miscellaneous expenses

9.  CASH AND CASH EQUIVALENTS 

Cash at HSBC Bank plc

10.  SHARE CAPITAL 

2022 
£ 
35,356 
31,286 
30,781 
11,520 
21,378 
130,321 

2021 
£ 
33,910 
30,970 
24,031 
10,080 
4,398 
103,389 

2022 
£ 
254,140 

2021 
£ 
1,077,482 

The share capital of the Company on incorporation was represented by an unlimited number of Ordinary Shares of no par 
value.  The  Company  may  issue  an  unlimited  number  of  shares  of  a  nominal  or  par  value  and/or  of  no  par  value  or  a 
combination of both.  

The  Company  has  a  total  of  106,453,335  (2021:  106,453,335)  Ordinary  Shares  outstanding  with  an  additional  700,000 
(2021: 700,000) held in treasury. The Company has 9,167 (2021: 9,167) Management Ordinary Shares in issue, which are 
held by the Investment Manager. 

The  Ordinary  Shares  are  admitted  to  the  Premium  Listing  segment  of  the  Official  List  of  the  London  Stock  Exchange. 
Holders of Ordinary Shares have the right to receive notice of and to attend and vote at general meetings of the Company.  

Each holder of Ordinary Shares being present in person or by proxy at a meeting will, upon a show of hands, have one vote 
and upon a poll each such holder of Ordinary Shares present in person or by proxy will have one vote for each Ordinary 
Share held.  

60 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

10.  SHARE CAPITAL (CONTINUED)

Holders of Management Ordinary Shares have the right to receive notice of and to attend and vote at general meetings of 
the Company, except that the holders of Management Ordinary Shares are not entitled to vote on any resolution relating to 
certain specific matters, including a material change to the Company’s investment objective, investment policy or borrowing 
policy. Each holder of Management Ordinary Shares being present in person or by proxy at a meeting will, upon a show of 
hands, have one vote and upon a poll each such holder of Management Ordinary Shares present in person or by proxy will 
have one vote for each Management Ordinary Share held. Holders of Ordinary Shares and Management Ordinary Shares 
are entitled to receive, and participate in, any dividends or other distributions out of the profits of the Company available for 
dividend and resolved to be distributed in respect of any accounting period or other income or right to participate therein. 

The details of issued share capital of the Company are as follows: 

Issued and fully paid share capital 
Ordinary Shares of no par value** 
(including Management Ordinary Shares) 
Treasury Shares 
Total Share Capital 

2022 

Amount  No. of shares*

£

2021 

Amount
£

No. of shares*

76,122,347

107,162,502

76,122,347

107,162,502

(140,492)
75,981,855

(700,000)
106,462,502

(140,492)
75,981,855

(700,000)
106,462,502

The outstanding Ordinary Shares as at the year ended 31 December 2022 are as follows: 

Balance at 1 January 2022 & 31 December 2022 

Ordinary Shares 

Amount
£ 
76,122,347 

No. of shares*

106,462,502 

Treasury Shares 
Amount No. of shares

£
140,492 

700,000 

The outstanding Ordinary Shares as at the year ended 31 December 2021 were as follows: 

Balance at 31 December 2021 
* Includes 9,167 (2021: 9,167) Management Ordinary Shares. 

Ordinary Shares 

Treasury Shares 

Amount
£ 
76,122,347 

No. of shares*

Amount No. of shares

106,462,502 

£
140,492 

700,000 

         ** The value reported for the ordinary shares represents the net of subscriptions and redemptions (including any associated expenses)

Capital Management 

The Company regards capital as comprising its issued Ordinary Shares. The Company does not have any debt that might be 
regarded as capital. The Company’s objectives in managing capital are: 

 To safeguard its ability to continue as a going concern and provide returns to shareholders in the form of capital growth 
over the long-term through a focused, global portfolio consisting principally of the equities or related instruments of 
natural resources companies; 

 To allocate capital to those assets that the Directors consider are most likely to provide the above returns;  
 To manage, so far as is reasonably possible and when desirable, any discount or premium between the Company’s share 

price and its NAV per Ordinary Share; and 

 To make distributions to shareholders when circumstances permit in accordance with the Company’s distribution policy. 

The Company has continued to hold sufficient cash and liquid listed assets to enable it to meet its obligations as they arise 
and the Investment Manager provides the Directors with reporting on the activities of the investments of the Company such 
that they can be satisfied with the allocation of capital. 

61 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

10.  SHARE CAPITAL (CONTINUED) 

Capital Management (continued) 

As  discussed  in  the  Strategic  Report,  in  August  2015,  the  Company  introduced  a  share  buyback  programme  with  the 
objective of managing the discount the Company’s shares trade at compared with its NAV. The Company has repurchased 
700,000 shares at an average price of 20 pence per share through this programme and the repurchased shares are held in 
Treasury.  

The Company has authority to make market purchases of up to 14.99 Per Cent of its own Ordinary Shares in issue. A renewal 
of such authority is sought from Shareholders at each Annual General Meeting of the Company or at a General Meeting of 
the Company, if required. Any purchases of Ordinary Shares will be made within internal guidelines established from time 
to time by the Board and within applicable regulations.  

As described in the Directors’ Report on page 19, the Company has a policy to distribute at least 15 per cent of net realised 
cash gains after deducting losses during the financial year through dividends, tender offers or otherwise. 

The Company is not subject to any externally imposed capital requirements. 

Reserves 

As  at  the  year-end  the  Company  had  Revenue  Reserves  of  £8,771,186  (2021:  £10,047,160)  and  Capital  Reserves  of  
£(270,193) (2021: £18,769,941). 

Under  the  Companies  (Guernsey)  Law  2008,  the  Company  may  buy  back  its  own  shares,  or  pay  dividends,  out  of  any 
reserves, subject to  passing a solvency test.  This test considers whether,  immediately after the  payment, the Company’s 
assets exceed its liabilities and whether it will be able to pay its debts when they fall due. 

11. RELATED PARTY TRANSACTIONS 

The Investment Manager, Baker Steel Capital Managers LLP, had an interest in 9,167 Management Ordinary Shares at 31 
December 2022 (31 December 2021: 9,167). 

Baker Steel Global Funds SICAV – Precious Metals Fund (“Precious Metals Fund”) had an interest in 4,922,877 Ordinary 
Shares in the Company at 31 December 2022 (2021: 4,922,877).  These shares are held in a custodian account with Citibank 
N.A. London. Precious Metals Fund shares a common Investment Manager with the Company. 

David Baker and Trevor Steel, Directors of the Manager, are interested in the shares held by Northcliffe Holdings Limited 
and The Sonya Trust respectively, which are therefore considered to be Related Parties. Northcliffe Holdings Pty Limited 
holds 12,452,177 shares (2021: 12,452,177) and The Sonya Trust holds 12,637,350 shares (2021: 12,722,129).    

John Falla purchased 60,000 shares in the Company on 10 November 2022. 

The Company’s associates are described in Note 13 to these financial statements.  

The Management fees and Directors’ fees paid and accrued for the year were: 

Management fees 
Directors’ fees 

The Management fees and Directors’ fees outstanding at the year-end were: 

Management fees 
Directors’ fees 

62 

2022 
£ 
1,160,507 
129,489 

2022 
£ 
69,854 
- 

2021
£ 
1,587,121 
115,000 

2021 
£ 
122,894 
28,750 

BAKER STEEL RESOURCES TRUST LIMITED

NOTES TO THE FINANCIAL STATEMENTS (CONTINUED) 
FOR THE YEAR ENDED 31 DECEMBER 2022 

12. NET ASSET VALUE PER SHARE AND GAIN PER SHARE 

Net asset value per share is based on the net assets of £84,482,848 (31 December 2021: £104,798,956) and 106,462,502 (31 
December  2021: 106,462,502)  Ordinary  Shares,  being  the  number  of  shares  in  issue  at  the  year-end  excluding  700,000 
shares which are held in treasury. The calculation for basic and diluted NAV per share is as below: 

Net assets at the year-end (£) 
Number of shares
Net asset value per share (in pence) basic and diluted
Weighted average number of shares 

31 December 2022 
Ordinary Shares 

31 December 2021 
Ordinary Shares 

84,482,848 
106,462,502 
79.4 
106,462,502 

104,798,956 
106,462,502 
98.4 
106,462,502 

The basic and diluted loss per share for 2022 is based on the net loss for the year of the Company of £20,316,108 and on 
106,462,502 Ordinary Shares, being the weighted average number of Ordinary Shares in issue during the year.  

The basic and diluted gain per share for 2021 is based on the net gain for the year of the Company of £1,307,557 and on 
106,462,502 Ordinary Shares, being the weighted average number of Ordinary Shares in issue during the year.  

There are no outstanding instruments which could result in the issue of new shares or dilute the issued share capital. 

13. INVESTMENT IN ASSOCIATES 

The interests in the below companies are for investment purposes and they are deemed associates by virtue of the Company 
having appointed a non-executive director (“NED”) and/or holding in excess of 20% of the voting rights of the relevant 
company. Investments in associates are carried at fair value as they are held as part of the investment portfolio which is 
valued on a fair value basis. 

Investment 
Cemos Group Limited 
Bilboes Gold Limited 
Nussir ASA
Futura Resources 
Tungsten West Plc 
Silver X Mining Corporation 
Polar Acquisition Limited 
Azarga 

Country of Incorporation 
Jersey 
Mauritius 
Norway 
Australia 
England and Wales 
Canada 
British Virgin Islands 
Canada 

Voting Rights held 
24.59% 
24.16% 
12.12% 
26.94% 
16.10% 
12.46% 
49.99% 
31.33% 

NED Appointed 
Yes 
No* 
Yes 
Yes 
No** 
Yes 
Yes 
No 

Various  Baker  Steel  representatives  and  their  associates  received  fees  and  incentives  for  their  role  as  directors  to  these 
companies. These fees are received in addition to the management fees charged. 

*Retired from the board on 6 January 2023 
**Retired from the board on 13 March 2023 

14. SUBSEQUENT EVENTS 

On 6th January 2023, Caledonia Mining Corporation Plc acquired all the shares of Bilboes Gold Limited. The Company 
received a 1% net smelter royalty over future production from Bilboes’ project area and shares in Caledonia. The expected 
transaction was taken into account in the valuation of Bilboes at 31 December 2022. 

There were no further events subsequent to the period end, not already disclosed in the Annual Report and Accounts, that 
materially impacted on the Company that require disclosure or adjustment to these financial statements. 

15. APPROVAL OF ANNUAL REPORT AND AUDITED FINANCIAL STATEMENTS 

The Annual Report and Audited Financial Statements for the year-ended 31 December 2022 were approved by the Board of 
Directors on 21 April 2023. 

63 

BAKER STEEL RESOURCES TRUST LIMITED

APPENDIX - ADDITIONAL INFORMATION (UNAUDITED) 

REMUNERATION DETAILS FOR INVESTMENT MANAGER’S STAFF 

As noted earlier, under AIFMD, the Investment Manager received approval to act as a full scope UK AIFM to the Company as 
of 22 July 2014. Pursuant to Article 22(2)9e) and (f) of AIFMD, an AIFM must, where appropriate for each AIF it manages, 
make an annual report available to the AIF investors. The annual report must contain, amongst other items, the total amount of 
remuneration paid by the AIFM to its staff for the financial year, split into fixed and variable remuneration including, where 
relevant,  any  carried  interest  paid  by  the  AIF,  along  with  the  aggregate  remuneration  awarded  to  senior  management  and 
members of staff whose actions have a material impact on the risk profile of the AIF.  

For the year ended 31 December 2022 the LLP as Investment Manager paid fixed remuneration to members and those identified 
as AIF code staff of £437,346. Variable remuneration amounted to £2,225,935. No carried interest was paid by the Company. 
These  figures  represent  the  aggregate  remuneration  paid  to  members  and  those  identified  as  AIF  code  staff  of  the  LLP  as 
Investment  Manager for the  year ended 31  December 2022. The total  remuneration of  the individuals  whose  actions  have a 
material impact upon the risk profile of the AIF managed by the AIFM amounted to £2,662,740. 

The total AIFM remuneration attributable to senior management was £2,662,740. No other staff were identified as material risk 
takers in the year. The remuneration figures reflect an approximation of the portion of AIFM remuneration reasonably attributable 
to the AIF.

64 

BAKER STEEL RESOURCES TRUST LIMITED

GLOSSARY OF TERMS 

AIF – Alternative Investment Fund 

AIFM – Alternative Investment Fund Manager 

AIFMD - Alternative Investment Fund Managers Directive

BSRT – Baker Steel Resources Trust Limited

Commission – Guernsey Financial Services Commission 

DRAVs – Development Risk Adjusted Values 

DFS – A Definitive Feasibility Study is an evaluation of a proposed mining project to determine whether the mineral resource 
can be mined economically. A DFS is the basis for detailed design and construction of a project and determines definitively 
whether to proceed with the project. Detailed feasibility studies require a significant amount of formal engineering work, with 
costings accurate to within 10-15%. The definitive feasibility study will be based on indicated and measured mineral resources. 

EU – European Union 

EGM – Extraordinary General Meeting 

FCA – Financial Conduct Authority 

FRC – Financial Reporting Council 

FVO – Fair value option

FVOCI– Fair value through other comprehensive income

FVTPL – Fair value through profit or loss 

GFSC – Guernsey Financial Services Commission 

GFSC Code - Guernsey Financial Services Commission Code of Corporate Governance 

g/t – Grams per tonne 

IAS – International Accounting Standards 

ITG – IFRS Transition Resource Group of Impairment of Financial Instruments 

IFRS – International Financial Reporting Standards as adopted by the European Union

IndexVal – Where there have been no known transactions for 6 months, at the Company’s half year and year-end, movements 
in  IndexVal  will  generally  be  taken  into  account  in  assessing  Fair  Value  where  there  has  been  at  least  a  10%  movement  in 
IndexVal over at least a six month period. The IndexVal results are used as an indication of trend and are viewed in the context 
of investee company progress. 

IPO – Initial Public Offering (stock market launch) 

JORC – AUSTRALASIAN JOINT ORE RESERVES COMMITTEE 
The  Code  for  Reporting  of  Mineral  Resources  and  Ore  Reserves  (the  JORC  Code)  of  the  Australasian  Joint  Ore  Reserves 
Committee (JORC) is widely accepted as a standard for professional reporting of mineral resources and ore reserves. Mineral 
resources are classified as 'Inferred', 'Indicated' or 'Measured', while ore reserves are either 'Probable' or 'Proven'. 

Mt – million tonnes 

NAV – Net Asset Value 

65 

BAKER STEEL RESOURCES TRUST LIMITED

GLOSSARY OF TERMS (CONTINUED) 

NI 43–101 – CANADIAN NATIONAL INSTRUMENT 43-101 
Canadian  National  Instrument  43-101  is  a  mineral  resource  classification  instrument  which  dictates  reporting  and  public 
disclosure of information in Canada relating to mineral properties. 

NAV Discount – NAV  to  market price discount The  Net  Asset  Value  (“NAV”) per share is the value  of all the investment 
company’s assets, less any liabilities it has, divided by the number of shares. However, because the Company’s Ordinary Shares 
are traded on the London Stock Exchange's Main Market, the share price may be higher or lower than the NAV. The difference 
is known as a discount or premium.  

OCI – Other comprehensive income 

PEA – Preliminary Economic Assessment

SORP – Statement of Recommended Practice issued by The Association of Investment Companies dated November 2021 

UK Code – UK Corporate Governance Code published by the Financial Reporting Council in July 2018. 

66