Quarterlytics / Financial Services / Insurance - Life / Ecclesiastical Insurance Office plc

Ecclesiastical Insurance Office plc

ella.l · LSE Financial Services
Claim this profile
Ticker ella.l
Exchange LSE
Sector Financial Services
Industry Insurance - Life
Employees 1353
← All annual reports
FY2021 Annual Report · Ecclesiastical Insurance Office plc
Sign in to download
Loading PDF…
Building a 
Movement  
for Good

Ecclesiastical Insurance Office plc 
Annual Report & Accounts 2021

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

An-nual Report and Ac-count concept amends 
 
 
 
 
 
 
 
 
Trusted to protect

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Proud to preserve

 
 
 
 
 
 
 
 
 
Committed to change

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
Building a Movement  
for Good

It’s amazing to think that we’ve now given 
£100m to charities throughout the UK, Ireland, 
Canada and Australia. What’s more amazing  
is the incredible collective effort involved.

This great act of giving has only been possible with the 
help of our customers, brokers, colleagues, partners and 
people who take part in our Movement for Good awards. 
And for that, I want to say a heartfelt thank you. 

Thanks to you, we’ve been able to make such a difference 
to the lives of so many. And this strong charitable purpose 
– this desire to help others – is what unites our family  
of global, trusted businesses and drives us forward. 

Proudly part of Benefact Group, by giving our profits  
to charity, we can support the causes you care about. 
And we’re ambitious to give more. It’s why we’re 
determined to keep growing – because the more  
we grow, the more we can give back.

So again, thank you for helping us build a special  
kind of business. Thank you for helping us build  
a Movement for Good.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

Mark Hews, 
Group Chief Executive, 
Ecclesiastical Insurance Office plc

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
Contents

Section One About Us 

Building a Movement for Good 

Ecclesiastical at a glance 

Our businesses 

Section Two Strategic Report 

Chair’s Statement 

Chief Executive’s Report 

Beneficiary stories 

Global trends in financial services 

Our business model and strategy 

Strategy in action 

Key Performance Indicators  

Financial Performance Report  

Risk Management Report  

Principal risks 

Responsible Business Report 

Non-Financial Information Statement 

Section 172 Statement 

Strategic Report approval 

Section Three Governance 

Board of Directors 

Directors’ Report 

Corporate Governance 

Section Four Financial Statements 

Independent auditors’ report to the members of Ecclesiastical Insurance Office plc 

Consolidated statement of profit or loss 

Consolidated and parent statement of comprehensive income 

Consolidated and parent statement of changes in equity 

Consolidated and parent statement of financial position 

Consolidated and parent statement of cash flows 

Notes to the financial statements 

Section Five Other Information 

Directors, executive management and company information 

United Kingdom regional centres 

United Kingdom business division and international branches 

Insurance subsidiaries and agencies 

Notice of meeting 

Notes 

3

4

6

8

11

12

16

22

34

40

44

50

54

62

68

80

94

96 

96

99

100

104

110

181

182

192

193

194

195

196

197

263

264

266

267

268

269

270

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
Section One

About Us

Building a Movement for Good 

Ecclesiastical at a glance 

Our businesses 

4

6

8

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
At Ecclesiastical our way of doing business 
is a little different to most. That’s because, 
proudly part of Benefact Group, we give all 
available profits to charities and good causes. 
So, the more our business grows, the more  
we can give back. The knowledge that  
the more successful we become – the more  
we can help improve lives and communities  
– is what spurs us on each day. 

And wanting to help others applies equally 
to our customers. It’s why we’re always 
looking for ways to offer them more, 
building on our trusted specialist expertise 
and unrivalled world-respected knowledge. 

Together, building a Movement for Good.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
Section One

About Us – Ecclesiastical at a glance

6

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

7

Ecclesiastical at a glance

Best Ethical 
Investment 
Provider 

Voted by the Financial 
Adviser community  
at the Moneyfacts Life  
& Pensions Awards for 
13 consecutive years 
(2009-2021) – EdenTree 
Investment Management

Leading  
insurer for 
the Anglican 
church 

in all our territories

Proudly part  
of Benefact Group,  
a specialist financial 
services group that  
gives all its available 
profits to charity  
and good causes

Since the 1880s

Ecclesiastical has been 
providing specialist insurance 
and risk management support 
to its customers

Our specialist brokers 
provide tailored 
insurance products
particularly for customers in the 
high net worth, farming and rural 
estates, equine, animal trades, and 
specialist motor insurance sectors

A leading  
multi-faith insurer

Protecting 
churches, 
synagogues, 
mosques and 
Hindu, Sikh and 
Buddhist temples 
across our 
territories

£150m+
One of the UK’s 
largest charitable 
donors. We are 
proud of our 
ambition to give 
more than £250m 
to good causes.

Since 2014 we have given over  
£150m in grants and donations*

*Cumulative total 2014-2021

98% +

UK overall customer satisfaction  
across all the sectors we measure*

*Based on FY 2021 results for Home New Business and Renewals – Ecclesiastical UK; Church Renewals; 
Ecclesiastical claims; Risk Management; Charity; EFAS and Funeral Directors results

4th largest 
corporate donor 
to charity

£77.0m

profit before tax
(£15.7m loss before  
tax in previous year)

Our parent, Benefact Group, is already 
the UK’s 4th largest corporate donor* 
and we aim to be the largest

*DSC – The guide to UK Company Giving 2021-22

Movement  
for Good
Through our Movement 
for Good Awards  
– our biggest ever giving 
campaign – we gave  
£1m to help a wide range  
of charitable causes

Rated best 
insurer by 
UK brokers 
in the charity, 
commercial 
heritage, 
education and 
faith sectors*

*Ecclesiastical UK Broker survey FY2021

In Canada our 
Community 
Impact Grants 
supported 
projects that 
make a positive 
impact on the 
community

£486.2m

gross written premium
(£437.3m in previous year)

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Section One

About Us – Our businesses

8
8

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

9
9

Our businesses

This Annual Report & Accounts is for Ecclesiastical Insurance Office plc.  
The following terms are used throughout this report and are defined as follows: 

Terms

Definition

The ‘Company’  
or ‘Parent’

The ‘Group’

‘Benefact Group’  
or ‘wider group’

Benefact Trust

Ecclesiastical Insurance Office plc (EIO)

Ecclesiastical Insurance Office plc together  
with its subsidiaries

Benefact Group plc (formerly Ecclesiastical 
Insurance Group plc), the parent company  
of Ecclesiastical Insurance Office plc, together 
with its subsidiaries. This includes Ecclesiastical 
Planning Services Ltd (EPSL), Lycetts Insurance 
Brokers (Lycetts) and Lycetts Financial Services.

Benefact Trust Limited, the ultimate parent 
undertaking of Ecclesiastical Insurance Office plc

We are organised into three divisions: 
Specialist Insurance; Investment 
Management; and Broking and Advisory.  
All are underpinned by our specialist 
knowledge and a reputation for delivering  
an outstanding service to our customers.

We provide products and services
to businesses, organisations and retail 
customers, both directly and through 
intermediaries. Operating primarily  
from the UK, our divisions and their  
associated companies are:

Specialist Insurance
Ecclesiastical UK / Ansvar UK / Ansvar Australia / Ecclesiastical Canada / 
Ecclesiastical Ireland

Our award-winning insurance businesses offer insurance products and risk 
management services to customers in the faith, heritage, charity, education  
and real estate markets.

We have particular expertise in valuing and protecting distinctive properties  
both old and new – from cathedrals to concert halls, schools to stately homes  
and iconic modern buildings to youth hostels.

We also provide a discrete range of specialist products including household 
insurance for churches and congregations and fine art insurance to the high net 
worth market. Committed to being the most trusted and ethical specialist financial 
services group, we are proud that our UK home insurance has again been awarded 
the First Place Gold Ribbon in this year’s independent Fairer Finance Customer 
Experience ratings.

Investment Management
EdenTree Investment Management (EdenTree)

With over 30 years of experience in responsible and sustainable investing,  
our investment management team manages and sells Environmental, Social  
and Governance investment products to institutional customers, including the charity 
and faith markets, and to retail customers through the advisory market. EdenTree 
also manages the majority of the Group’s financial investments. This year, for the 13th 
consecutive year, EdenTree celebrated winning ‘Best Ethical Investment Provider’  
at the Moneyfacts Investment Life & Pensions Awards.

Broking and Advisory

SEIB Insurance Brokers (SEIB) / Ecclesiastical Financial Advisory Services (EFAS) / 
Ecclesiastical Planning Services Ltd1 (EPSL) / Lycetts Insurance Brokers1 (Lycetts) / 
Lycetts Financial Services1

Our specialist brokers, SEIB and Lycetts, provide tailored insurance products  
for customers, particularly those in the high net worth, farming and rural estates, 
equine, animal trades, and specialist motor insurance sectors.

EFAS and Lycetts Financial Services offer financial advice to businesses  
and individual customers including Church of England clergy. EPSL markets  
and administers prepayment funeral plans under the Perfect Choice brand.

1 These businesses are owned by Benefact Group plc

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance  
 
 
 
 
 
 
 
 
10

11

Section Two

Strategic Report

Chair’s Statement 

Chief Executive’s Report 

Beneficiary stories 

Global trends in financial services 

Our business model and strategy 

Strategy in action 

Key Performance Indicators  

Financial Performance Report  

Risk Management Report  

Principal risks 

Responsible Business Report 

Non-Financial Information Statement 

Section 172 Statement 

Strategic Report approval 

12

16

22

34

40

44

50

54

62

68

80

94

96 

96

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section Two 
 
 
 
 
 
 
 
 
Chair’s Statement

It is with great 
pleasure and pride 
that I reflect on a 
hugely successful 
year for Ecclesiastical 
in 2021. 

The Group exceeded its ambitious target  
of donating £100m, an extraordinary 
achievement that has helped thousands  
of good causes and communities to transform 
lives for the better in the UK and abroad. 

12

13

This was made possible thanks to our direct 
giving and the annual grants given to our 
charitable owner, Benefact Trust, over the past 
five years. I would like to thank our customers, 
brokers, partners, and colleagues for helping 
us achieve this milestone. Alongside this,  
we made significant progress on a number 
of strategic initiatives including the launch  
of the new Ecclesiastical brand and the 
opening of our new headquarters  
in Gloucestershire. 

After a long period of restrictions, the latter 
half of 2021 started to feel like a return  
to normality. The official opening of our head 
office in June was a welcome opportunity  
to meet many of our talented colleagues,  
who have worked tirelessly through  
the challenges of the past two years  
to deliver outstanding service to our 
customers. Their resilience, positivity  
and commitment to doing the right thing  
is what sets Ecclesiastical apart. 

At the time of writing, the war in Ukraine casts 
a dark cloud over the world. Many Ukrainians 
continue to be caught in conflict and are 
suffering due to the unjust actions of the 
Russian government. Our charitable purpose 
allows us to help those most in need,  
and I’m pleased that our charitable owner 
Benefact Trust is contributing £1m of grant 
funding to charities supporting those affected 
by the war. Alongside this, the Group has also 
pledged to triple-match employee giving  
to any Ukraine appeals. We send our thoughts 
and prayers to those affected by the conflict.

A strong set of results 
Thanks to our charitable ownership, we are 
able to take a long-term, sustainable approach 
to growth. Our 2021 results demonstrate our 
continuing financial strength as we recovered 
from the challenges posed by Covid-19  
the previous year. Strong investment returns 
and a solid underwriting result helped us  
report a profit before tax of £77.0m, which  
is a fantastic achievement. This enabled us  
to contribute £26.0m to our owner  

Benefact Trust in respect of 2021 performance ,  
which includes £5m paid in 2022. We also gave 
£2.5m to good causes through our direct giving.

Since 2014, the Group has given over £150m 
to good causes. Already the fourth-biggest 
corporate donor in the UK, we now want  
to become the biggest and to donate  
a cumulative £250m to good causes  
by the end of 2025.

Achievements and reflections 
During my three years as Chair, the Group has 
evolved into a modern and confident business, 
driven by an ambition to create a Movement 
for Good in society. The core insurance, broker 
and advisory, and investment management 
businesses have all demonstrated impressive 
growth. Alongside the launch of the new 
Ecclesiastical insurance brand and the 
opening of our head office, we continued  
to invest in systems and technology to 
improve the broker and customer experience, 
with a new general insurance system for the 
UK and Ireland launching soon. 

Our commitment to innovation remains strong 
with the launch of the Smart Properties 
proposition, which provides an early-warning 
system for heritage properties to prevent fire 
and flood. This clever technology won Digital 
Insurance Innovation of the Year Award at the 
British Insurance Awards. 

Underpinning all of these achievements  
is our commitment to first-class customer 
service. Our customer satisfaction and  
Net Promoter Scores remain high alongside  
a record number of external awards,  
and the Group achieved Best Companies 
two-star status, demonstrating outstanding 
employee engagement. 

Looking ahead 
While pleased with the progress made  
in 2021 in such challenging circumstances,  
we undoubtedly have the potential to develop 
the business even further following the launch 
of our next chapter strategy. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoStrategic Report – Chair’s StatementSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Section Two

Strategic Report – Chair’s Statement

14

15

This year will see us start to realise the 
benefits of our long-term investments  
in systems and processes. Alongside this, 
we will continue to invest in technology and 
our people to drive innovation and growth 
to enable yet more giving to charities and 
communities. I’m confident this roadmap  
will see us become an even more successful 
organisation over the next five years.

We enter the next chapter with a new name 
for our wider group – Benefact Group.  
The new name better reflects our purpose  
to do good in society – it derives from Latin 
and means to do well by supporting a person 
or good cause. All of the trading brands in the 
Benefact family will continue to operate under 
their own names, united in a belief that better 
business can better lives.

As the Board looks towards the next chapter 
for the Group, it must respond to broader 
issues of sustainability and climate change. 
As a responsible business, we are committed 
to making a positive environmental impact 
in the world. The Group recently unveiled 
its plan to reach net zero carbon emissions 
by 2040. Over the past year, much work has 
gone into understanding and measuring our 
climate impact, in order to make meaningful 
commitments for the future. 

Our ambition to wipe out our historic direct 
carbon impact by 2030 is, I believe, unique 
in the insurance industry, and is the right 
thing to do for a company with our purpose 
and values. The good news is we’re building 
on strong foundations – our award-winning 
investment management company, EdenTree, 
is a pioneer in the field of ethical investing, 
and the Group has introduced a responsible 
and sustainable investment strategy that 
seeks to invest in markets that have positive 
impacts. We’re also a long-term member 
of ClimateWise, a group of organisations 
ambitious about climate action. Reducing  

our climate impact is a key priority for 
the Board and we look forward to making 
progress on our commitments. 

Board activity 
It was a pleasure to be able to return  
to face-to-face Board meetings in 2021.  
While virtual meetings have provided 
increased flexibility, our Board members 
welcomed the opportunity to interact and 
engage in person after a long period apart.

We said goodbye to Caroline Taylor,  
who retired from the Board in September. 
I would like to thank Caroline for her 
contribution over the past seven years. 

In July, Rita Bajaj joined us as Non-Executive 
Director, bringing with her over 30 years  
of financial markets experience. She has  
held senior portfolio management positions  
at both UK and US investment institutions  
as well as experience working in UK 
regulation. 

A key priority for the Board this year  
will be spending more time in the business  
and continuing to develop relationships  
with senior executives and managers. 

The future
It is a privilege to be a part of a business  
with such a special purpose of contributing 
to the greater good of society. With the 
new strategy in place, I believe we are well 
positioned to take the business forward,  
and in doing so give even more to charities  
and communities to help transform lives  
for the better.

David Henderson 
Chair

‘All of the trading 
brands in the 
Benefact family will 
continue to operate 
under their own 
names, united in  
a belief that better 
business can  
better lives.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Two

Strategic Report – Chief Executive’s Report

16

17

Chief Executive’s Report

Over 135 years ago, 
our founders created  
a different kind of 
business committed  
to the greater good  
of society. 

Times may have changed, but our drive and 
purpose remain the same. Today we are one  
of the biggest corporate donors in the UK, 
helping to transform thousands of lives  
for the better. 

Like many businesses, we are ambitious.  
But our ambition is not driven by the short-term 
pursuit of profits at any cost. Our ambition  
is fuelled by a desire to support and care  
for our customers, their communities and 
society as a whole. 

As a specialist insurer, we not only protect 
much of the nation’s irreplaceable heritage, 
we are trusted to insure the buildings and 
organisations that bind our communities 
together – schools, charities, churches, 
community centres, and historic buildings.  
As custodians of these special places,  
we take great care to support our customers. 

As a charity-owned business, we believe 
commercial success and social good can  
sit side by side to generate incredible social 
impact. By growing our business, we can give 
even more to charities and communities,  
and help even more people. By doing business 
with Ecclesiastical, every one of our customers, 
brokers, and partners is helping to support 
good causes and create a powerful Movement 
for Good in society. 

It’s impossible to write this report without 
mentioning the harrowing situation in Ukraine. 
The conflict is having a devastating effect 
on innocent civilians and, like the rest of the 
world, I’ve been shocked by the stories and 
pictures emerging from the war. As a business 
committed to the greater good of society, 
both in the UK and abroad, I am pleased that 
our charitable owner, Benefact Trust, has 
committed £1m of grant funding to support 
charities helping those affected by the conflict. 
The Group has also pledged to triple-match 
employee giving to any Ukraine appeals  
up to £50,000.

Continuing to build a Movement  
for Good 
Despite the ongoing challenges of the 
pandemic, 2021 was a year of great 
achievement for our Group. We reported  
strong financial performance, a record number 
of external awards, excellent customer  
and employee survey feedback, and continued 
progress on our strategy. 

Most importantly, we were able to give  
a total of £28.5m to charity in respect of 2021 
performance. This meant we achieved our goal 
of giving more than £100m to good causes  
– meeting and exceeding the stretching goal  
that we set ourselves a few short years ago. 
This is a remarkable feat and I want to say  
a heartfelt thank you to all of our customers, 
brokers, business partners, employees and 
supporters who have made this happen.  
Thanks to you, we have made thousands  
of charitable donations over the past five years, 
making a difference to countless lives. 

As a result of our performance in 2021,  
we were able to further the aims of our 
charitable owner, Benefact Trust, with  
a donation of £26m. This was split between  
£21m in cash paid in 2021, with the remainder 
paid in 2022. The balance of our giving was 
distributed via giving programmes in the UK, 
Australia, Canada and Ireland, such as the 
Movement for Good awards, which allows 
customers, business partners and others  
to help steer funds to the causes they wish.

Alongside Benefact Trust, we are very  
proud to have supported charities tackling  
so many different and important issues.  
Their work includes lifting people out of 
poverty, making society more inclusive,  
helping to support bereaved families and  
so much more. When one hears stories  
of how our support is making a difference,  
it is difficult not to feel humbled, moved  
and inspired. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Two

Strategic Report – Chief Executive’s Report

18

19

Indeed, seeing the inspiring work of charities 
around us makes us determined to give even 
more and set our sights even higher. Already 
the fourth biggest corporate donor, we now 
have an ambition to be the largest corporate 
donor in the UK – not because of the position 
in the league table, but because of the 
transformative impact that such an ambition 
would have on lives and communities.

We step into this challenge with a new identity 
for our wider Group – Benefact Group. The new 
name for our immediate parent better reflects 
our diversity, breadth and charitable purpose 
– it originates from the verb ‘benefact’ which 
means ‘to do well’ which is for us the basis for 
our commitment to give money or help to good 
causes. All of the trading brands in the Benefact 
Group family will continue to operate under 
their own names, united in a belief that better 
business can mean better lives. All the available 
profits from Benefact Group will continue to 
benefit charity. 

Delivering for our customers 
2021 was another difficult year for many  
of us, but our colleagues rose to the challenge 
admirably. They embraced new ways  
of working while continuing to serve our 
customers brilliantly, whether that was  
from our offices or from home. I would like  
to thank all of our colleagues for their 
dedication and resilience. 

I continue to be genuinely impressed  
at the level of service my colleagues offer. 
The independent research consultancy, 
Gracechurch, put Ecclesiastical ahead of all 
other insurers for claims service. In addition, 
an incredible 98% of customers and brokers 
are satisfied with the service they receive from 
Ecclesiastical, whether that is making a claim 
or experiencing our risk management service. 
The Net Promoter Score, which measures how 
likely a customer is to recommend a company’s 
products and services, for Ecclesiastical 
Insurance put us ahead of well-known  
and respected brands such as John Lewis  
and Marks & Spencer. 

With such a brilliant team of people, it was 
heartening to receive external recognition 
for our levels of engagement. In our first 
year of participation in the Best Companies 
assessment, the Group was awarded a two-star 
accreditation demonstrating ‘outstanding’ levels 
of employee engagement. 

Alongside this, we won a record number  
of external awards. This included being named 
as the UK’s most trusted home insurer for the 
14th consecutive time by independent ratings 
agency Fairer Finance, and our Canadian 
team was named one of the Top Employers 
for Young People for the ninth consecutive 
year. Ecclesiastical UK won Digital Insurance 
Innovation of the Year Award at the British 
Insurance Awards for Smart Properties, while 
EdenTree was named Best Ethical Investment 
Provider at the 2021 Investment Life and 
Pensions Moneyfacts Awards for the 13th  
time in a row. 

I was particularly pleased our UK General 
Insurance team received accolades for our 
Smart Properties proposition, which uses 
cutting-edge technology to protect some  
of the UK’s most iconic properties. This clever 
early warning system uses wireless sensors  
to learn what’s ‘normal’ for a property. An alert 
is then sent by email, text or phone to highlight 
a change in conditions, so early preventative 
action can be taken. This is a wonderful 
example of how we’re using innovation 
to protect our customers and our nation’s 
irreplaceable heritage. 

Despite these achievements, we are  
not complacent and we recognise there  
is always more to do. Our culture means  
that we continually strive to do better for  
our customers. 

I have previously highlighted the importance  
of managing claims for physical and sexual 
abuse (PSA) and we remain committed  
to improving the claims handling experience  
in these sensitive cases. The final report  
of the Independent Inquiry into Child Sexual 

Abuse (IICSA) will be published later this year 
and we await its recommendations on ways 
to better safeguard children and improve 
the treatment of victims and survivors when 
disclosing abuse.

The experience of bringing an insurance claim 
can be traumatic for victims and survivors 
within the adversarial civil justice system  
in which we have to operate. We always aim  
to handle claims with empathy and sensitivity, 
as embodied in our Guiding Principles.  
We thank the Inquiry for its work, and we will 
continue to review our processes as part  
of our commitment to continual improvement.

Financial performance
After a challenging year in 2020 due to the 
impact of the Covid-19 pandemic, I’m delighted 
that the Group reported a profit before tax  
of £77.0m in 2021 (2020: loss before tax  
of £15.7m). Our positive financial performance 
was driven by impressive investment returns, 
as markets bounced back, alongside a strong 
underlying underwriting result. I’m pleased  
our investment approach saw us outperform 
the indices for most asset classes.

Our overall underwriting result included  
a strengthening of reserves in our Australian 
business, due to an increase in PSA cases, 
and the impacts of adverse weather events, 
including Storm Arwen and the July floods  
in the UK, and severe flooding in Canada  
and Australia. 

We delivered Gross Written Premium (GWP) 
growth of 11% to £486m (2020: £437m) 
supported by strong retention and new 
business in the UK and Canada. Our broking 
businesses also performed above expectation 
with SEIB reporting a profit before tax of £3.2m 
(2020: £2.4m). Our award-winning investment 
management firm EdenTree had another 
excellent year, achieving record inflows and 
exceeding fund benchmarks. It reported a loss 
before tax of £2.5m (2020: loss before tax  
of £1.0m) as it continued to invest in growing  
the business.

Strategic progress
2021 was a truly transformational year for 
Ecclesiastical as we made significant progress 
on our strategic initiatives, despite the ongoing 
uncertainty in the external environment. 
We successfully launched the new 
Ecclesiastical brand to positive feedback.  
We opened our new head office  
in Gloucestershire. We continued to make 
substantial investments in new insurance 
systems and technology to improve the broker 
and customer experience. We reinvigorated  
our EdenTree business, strengthening the team 
and introducing new funds. We continued  
to grow the Broking and Advisory division  
and transformed its financial contribution. 

Many of these initiatives will have a positive 
impact on our carbon footprint. Our new 
head office was built to ‘very good’ BREEAM 
standards, a leading sustainability assessment 
method, and our new EdenTree funds are aimed 
at investors looking to contribute to a more 
sustainable economy. 

As a socially responsible business, we are 
committed to making a positive environmental 
impact in the world and supporting customers 
and communities to tackle their climate 
challenges too.

We pioneered ethical investment over  
30 years ago and our responsible and 
sustainable investment strategy remains 
amongst the most stretching in the industry. 
As an example, unlike many others, we do not 
invest in companies undertaking fossil fuel 
exploration or production. More generally,  
we look to avoid investment in businesses that 
cause social harm whilst proactively seeking 
to invest in companies that have positive 
impact. We consider environmental, social and 
governance factors in every investment case 
using our specialists at our award-winning 
subsidiary EdenTree.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Two

Strategic Report – Chief Executive’s Report

20

21

Join our Movement for Good
After a successful 2021, we step into 2022  
with more ambition and confidence than ever  
to build a Movement for Good. None of this 
would be possible, of course, without the 
energy and endeavour of our specialist teams 
worldwide. Our dedicated and talented people 
are at the heart of our business, driven  
by a desire to support our customers and 
united by a common purpose to contribute  
to the greater good of society. The Board  
and I would like to thank all of our colleagues 
for their exceptional efforts. I very much hope 
that they are inspired when they look back  
at what they have achieved. I certainly am. 

As we build momentum for our movement  
for good, I invite anyone reading this, whether 
as a potential colleague, customer or business 
partner, to come and join us and experience  
a different way of doing business. Together,  
with your support, we can grow our giving  
and transform lives for the better. 

By order of the Board

Mark Hews
Group Chief Executive

We’ve been members of the voluntary initiative, 
ClimateWise, for a number of years and 
continue to build our response to the climate 
crisis using ClimateWise’s framework, which  
is in line with the recommendations of the Task 
Force on Climate-related Financial Disclosures 
(TFCD). We are in the process of developing 
an ambitious roadmap to net zero and are 
supporting our customers and communities  
to do the same.

Looking ahead 
As we look to the future, we expect the needs 
of our beneficiaries and charities to grow 
substantially. And rather than look the other 
way, we want to play our part in rising to help 
meet those needs. To this end we have recently 
launched a new ambitious Group strategy that 
will see us transform our Group over the next 
five years. In short, we want to innovate and 
accelerate our growth so that we can give  
even more money to good causes. 

Our ‘next chapter’ will see us invest even more 
in new systems and technology, helping our 
businesses to innovate with purpose. Over  
the next few months, we’ll start to roll out  
a new strategic General Insurance system for 
the UK and Ireland which, once live, will help 
us to provide our customers and brokers with 
an enhanced experience and more efficient 
processes and capacity.

We will invest in our dedicated and brilliant 
people to maximise their potential, creating  
a world-class and energised team. 

We will seek out new opportunities and new 
paths to growth, with an ambition to double  
the size / contribution of our businesses. 

…And we will give even more. Since 2014,  
the Group has given over £150m to good 
causes. Our parent, Benefact Group, is now 
aiming to donate a cumulative £250m1  
to good causes by the end of 2025.

1  Cumulative giving since 2014

‘As a charity-owned 
business, we believe 
commercial success 
and social good can 
sit side by side to 
generate incredible 
social impact.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Two

Strategic Report – Beneficiary stories

22
22

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

23
23

A belief that better business 
can better lives

Ecclesiastical Insurance Office plc is proudly part of Benefact Group 
and a shared desire to help others is the common thread that binds 
the family of businesses together. Each business is a specialist  
in its field, leading in everything from ethical investment and broking 
and advisory to specialist protection for iconic buildings and world 
heritage sites. Each one exists for the same purpose: to give all  
its available profits to good causes. 

This charitable giving is at our very core and has been for over  
135 years. We’re even owned by a charity, Benefact Trust.  
So our way of doing business is different. The better we serve  
our customers, the more our business grows. And the more  
we grow, the more we can give back. It’s how we’re making  
a difference  – to people’s lives and to communities. 
And it’s how, together, we’re building a Movement for Good.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information24

25

“ The young people 
whom we work with 
have suffered due  
to the current Covid-19 
crisis, our inspiring 
sailing voyages will 
help them to overcome 
their problems.” 

Emma Pate, Fundraising Manager, The Island Trust

The Island Trust Ltd

The Island Trust, based in Devon,  
is a youth sail training charity that enables 
disadvantaged and disabled young people 
to experience the benefits and challenges 
of sailing a traditional wooden sailing boat. 
As a winner of the 2021 Movement  
for Good awards, the charity can continue 
enhancing young lives – building resilience, 
independence and self-confidence.

A
b
o
u
t

A
b
o
u
t

U
s

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
 
 
 
26

27

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

“ It’s a privilege  
to welcome these 
children into An Garda 
Síochána as Honorary 
Garda. They love 
getting to wear the 
uniform and being 
involved on an  
ongoing basis.” 

Alan Keane, Secretary, Little Blue Heroes Foundation

Little Blue Heroes Foundation

Little Blue Heroes Foundation’s mission  
is to provide practical and financial 
support to families of children who have 
serious illnesses in Ireland, while granting 
the wish of the children it supports  
to become Honorary Gardaí to empower 
the child and foster positive engagement 
with An Garda Síochána, Ireland’s National 
Police Service. The Movement for Good 
awards money means they can keep 
making a positive difference to the lives  
of seriously ill children and their families.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glanceThe Island Trust Ltd 
 
 
 
 
 
 
 
 
 
28

29

“ Watching malnourished 
babies growing stronger 
with our milk – and 
knowing their carers 
have the means to 
support them – makes 
everything worthwhile.”

Forever Angels UK Ltd

Forever Angels provides life-saving 
nutrition to orphaned, abandoned and 
vulnerable babies in Tanzania, while 
empowering their caregivers through 
business creation. The Movement for 
Good money will provide milk for two 
babies, plus pay for 12 months’ training 
for two caregivers in malaria prevention, 
health, hygiene, nutrition and child 
development. It will also pay to establish 
them in a sustainable business, so they 
can provide for their families. 

Amy Hathaway, Founder and Director,  
Forever Angels UK

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
 
30

31

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

“ However different  
you think someone  
is from you, when you 
get talking to them,  
the similarities  
and the shared  
day-to-day concerns 
are often striking.” 

Rose Drew, CEO, Interfaith Glasgow

Interfaith Glasgow

Building bridges of trust and friendship 
between people of different beliefs  
is the aim of Interfaith Glasgow.  
By creating a welcoming space where 
people can meet and talk, the charity 
is helping to overcome prejudice and 
promote understanding and respect.  
With the Movement for Good money, 
Interfaith Glasgow can keep working 
to tackle prejudice through friendship-
building initiatives and projects which 
bring people together to work for  
the common good.

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
 
32

33

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

“ Helping to bring joy 
and laughter to the 
lives of our residents  
– people who have 
given so much – is 
incredibly rewarding.” 

Sophie Fanning-Tichborne, Partnerships Manager, 
Royal Star & Garter

Royal Star & Garter

Royal Star & Garter provides loving, 
compassionate, residential care to 
veterans and their partners living with 
disability or dementia. The Movement  
for Good award will fund their Wellbeing 
Programme which offers meaningful 
activities and exercise ranging from 
arts and crafts to gardening and tai chi, 
supporting individuals in feeling engaged, 
valued and loved.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
 
Section Two

Strategic Report – Global trends in financial services

34

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

35

Global trends in 
financial services

As part of our everyday business management, we monitor  
a number of global trends that we believe have the potential  
to impact our business in the future.

Trend

Our perspective

Trend

Our perspective

The conflict in Ukraine

Global economics  
and trade

First and foremost the unfolding conflict in Ukraine is a humanitarian catastrophe, with the UN 
reporting that over 2.5 million people have been displaced by the conflict at the time of writing.  
As an organisation with a strong caring ethos, we empathise with those facing extreme hardship  
and are working together with our charitable parent, Benefact Trust, to identify the best ways  
that we can provide financial support to them in their hour of need.

The invasion of Ukraine in late February 2022 is a cause for concern around the world. Large oil  
and natural gas stocks are found in the region, leading to fears of supply shortages due to the 
imposition of sanctions and surging energy prices. Countries across Europe (including the UK)  
are seeking to lessen their reliance on Ukraine and Russia for oil and natural gas supplies.

Disruption fears now encompass a wide range of other products that will affect both businesses  
and consumers. Uncertainty has spread, with volatility seen in global financial markets and adverse 
impacts beginning to flow through for economic growth and inflation. The most severe economic 
impacts are expected to be felt in Europe, which is already facing inflation in energy prices resulting  
in financial pressure on its businesses and households.

The outlook for the global economic landscape is cautious in 2022. Despite advances in the fight 
against Covid-19, countries continue to feel impacts from the pandemic, and the unfolding conflict  
in Ukraine continues to affect the outlook. The burden of the pandemic has been significant across  
all economies, particularly with national debts rising to potentially unsustainable levels. Gross 
Domestic Product (GDP) in advanced economies is expected to rebound to pre-pandemic levels,  
with the recovery expected to be fuelled by vaccination programmes and the emergence  
of antiviral treatments. 

Markets remain nervous with expectations that central banks will raise interest rates at a time  
when economies are emerging from the pandemic. Inflation is expected to be above targets  
stemming from global supply chain issues, high energy prices and skills shortages.

Pressures on businesses are increasing from supply disruptions and shortages of manufacturing 
inputs, together with continued virus containment methods. A huge surge in demand has led  
to significant price rises and shortages, particularly in global consumer goods and semi-conductors. 
There is increasing discontent with rising energy prices, particularly in Europe, which is likely  
to be exacerbated by increased focus on addressing climate risks which will have associated  
transition costs. 

Low trust in financial 
services

Trust is at the heart of all business relationships and is a result of a combination of ethics and 
competence. Ethical behaviour is driven by being purpose-led, honest and fair. Competent services 
businesses create value, act as a force for innovation and drive economic prosperity.

Climate change 
response

Financial services has been the least trusted business sector and in 2021, trust fell in all subsectors  
of the financial services sector but particularly in property and casualty insurance, financial advisory 
and asset management.

Benefact Group, Ecclesiastical Insurance Office plc’s parent company, aims to be a beacon  
of responsible and sustainable business practice. This distinct positioning is supported by a business 
model and values. Together these target outcomes have resulted in high levels of trust placed  
in the Group and its businesses that are rare amongst financial services businesses. These include:
•  Ecclesiastical UK being recognised once again as the most trusted home insurer, retaining  

its accolade at the top of the Fairer Finance league table for the 14th time and; 

•  EdenTree, our investment management business, has been recognised for its market-leading 
reputation and ethical approach with its 13th consecutive annual award from Moneyfacts.

The climate emergency continues to dominate the World Economic Forum’s Global Risks Report with 
environmental risks dominating the global landscape over the next ten years. Average temperatures 
continue to rise alongside increased frequency of extreme weather events. Natural defences are 
coming under pressure with urbanisation and deforestation increasing global vulnerability to climate 
change. These pressures are likely to lead to greater concentrations of insurance losses. Society  
and businesses have begun to recognise that urgent action is needed.

Global sentiment is showing that governments need to do more to manage their climate risks.  
Many countries are considering how to manage their climate risk and establishing appropriate steps  
to move towards a low carbon economy. Opportunities include redirecting investment away from fossil 
fuels and subsidising low carbon technologies, supported by building regulations that expect the use 
of low-carbon materials. The costs of moving to a lower carbon economy are expected to be very 
significant and are likely to lead to further economic and political pressures.

Investors are increasingly demanding Environmental, Social and Governance (ESG) criteria. Companies 
are expected to have ESG as a priority (particularly given that the green recovery is playing a part 
in the post Covid-19 economy) and this investor demand is likely to be the key driver of increased 
environmental responsibility in financial services. EdenTree, our responsible investment business,  
has continued to be a champion for sustainability engaging with companies on the opportunities arising 
from ESG focused investing. This is underpinned by the intentions of our parent company, Benefact 
Group, which has made commitments to be a net zero group by 2040 and support our customers  
and partners to tackle their own impacts too.

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Two

Strategic Report – Global trends in financial services

36

37

Trend

Our perspective

Regulation

Regulatory scrutiny continues with common themes across governance, culture/accountability,  
and technology/data management. The world continues to face challenges from Covid-19 with  
a variety of economic and regulatory responses across the world.

Despite some regulatory divergence, regulators are imploring financial services organisations  
to prioritise their financial and operational resilience to ensure that the financial system can continue 
to support businesses and households. As part of the continued response to the pandemic, financial 
services organisations are being urged to target credit and investment to where they are most critical 
and can have the greatest impact.

Sustainability and responding to climate change is one of the key topics under consideration  
by regulators. Our membership of ClimateWise, the insurance industry initiative, helps us to shape  
our response to climate change, working within the regulatory frameworks across our geographies, 
while supporting our customers and business partners with their own sustainability ambitions.

Other key challenges at the forefront of regulators’ minds for financial services businesses  
are evolving their cultures to create positive outcomes for customers and society, and progressing 
diversity and inclusion.

Data, technology 
and analytics

Data continues to be seen as one of the world’s most valuable assets. The pandemic accelerated  
the digitalisation of the majority of economic activities. The online economy has become more 
significant, with a continued shift towards trusted brands and dominant platforms. More customer-led 
propositions and tailored products are being shaped with the power of data.

Socioeconomic trends

The increased threat and potential for harm from cyber-attacks continues to increase with expectations 
of further attacks fuelled by the crisis in Ukraine. The private sector and governments need to work 
more closely together on cyber security. Cyber security failure continues to be seen as one of the 
top global risks, with the threat of adverse technology advances over the next five to ten years. Our 
businesses continue to respond to the opportunities arising from this evolving landscape to work with 
current and emerging technologies through a data strategy that is overseen by senior management.

Global interconnectivity and digitalisation has increased over the past few years, accelerating the 
‘fourth industrial revolution’. Against the continued backdrop of the Covid-19 pandemic, there has been  
a significant shift to a more digital-enabled society underpinned by a deep shift towards remote 
working, particularly in the developed economies. The pace of technological change has accelerated 
and amplifies the increased expectations from customers and business partners seeking enhanced 
tailored propositions.

Labour shortages have been a feature during the pandemic. This talent shortage is being seen in many 
countries and business sectors, making recruitment and retention challenging and creating inflationary 
pressures on people costs.

There is growing appetite for ethical employers and businesses, particularly from young people. 
A rising focus on the climate emergency is beginning to influence buyers and partners with a more 
proactive requirement for proven ethical and trusted companies. As award-winning, purpose-driven 
and trusted providers, our businesses continue to attract and retain prestigious customers across  
our geographies and markets. We are building a Movement for Good, with our charitable giving helping 
to support our communities to support those who are vulnerable in our societies.

‘Benefact Group, 
Ecclesiastical 
Insurance Office’s 
parent company, 
aims to be a beacon 
of responsible 
and sustainable 
business practice.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationAbout Us – Ecclesiastical at a glance

38

39

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

Born to give 

Charitable giving is at the very heart of our business. 
It’s what defines us and what drives us forward.  
For us, giving isn’t something new, it’s what we set 
out to do when we first started over 135 years ago.

Back in 1887, our founders created  
a different kind of business based on 
a powerful vision: to contribute to the 
greater good of society. We do this by 
giving all our available profits to charity. 
Since 2016, we’ve donated over £100m 
– a target we set ourselves and which 
we’re delighted to have reached.

We’re delighted too that Benefact Group 
(formerly the Ecclesiastical Insurance 
Group) has again been named the fourth 
biggest corporate giver to charity1  
in The Guide to UK Company Giving.  
Far from making us feel satisfied it’s 
made us hungry to give more, to be the 
largest corporate donor, making the 
greatest difference to more. That’s why 
we’ve set ourselves a new, ambitious 

giving target of £250m by 2025. And 
given the energy and enthusiasm of  
our people, we’re confident we’ll hit it. 

Every Ecclesiastical colleague has the 
opportunity to give to good causes 
through personal grants and matched 
donations for fundraising and payroll 
giving as part of our ‘My Giving’ scheme. 
And so far, we’ve donated to over 10,000 
charities throughout the UK, Ireland, 
Canada and Australia – charities that 
are tackling the big issues, like poverty, 
disability, education, health and heritage. 
We also give our time, sharing our 
knowledge and expertise, as well  
as offering voluntary hands-on help.  
In short, we don’t give up giving.

1 Directory for Social Change – The Guide to UK Company Giving 2021-2022

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section One 
 
 
 
 
 
 
 
 
Section Two

Strategic Report – Our business model and strategy

40
40

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

41
41

Our business model and strategy

Benefact Group, our wider group, is a diverse family  
of specialist financial services businesses, driven  
by our shared ambition to do right by our customers  
and clients, and united by a common purpose to give  
all available profits to charity and good causes.

Being owned by a charity – Benefact Trust – places  
good intentions at the foundations of our businesses. 
Whether in specialist insurance, investment management, 
broking or advisory, every business that makes  
up Benefact Group is a specialist in their respective 
field. Together we provide responsible and sustainable 
investment, protection of iconic buildings and world 
heritage sites, and trusted advice to people  
and businesses.

The most trusted specialist insurer
Our aim is to be the most trusted specialist insurer, offering unrivalled 
expertise and knowledge in our core markets, with appealing customer 
propositions and an excellent claims service that meet the concerns  
and needs of our customers and business partners.

The most trusted specialist adviser
We aim to be the most trusted specialist adviser in our chosen  
markets, providing our customers with the best independent and  
impartial insurance or financial advice in order to meet their needs.

The best ethical investment provider
We aim to be the best ethical investment provider and thought leader 
on socially responsible investment. Building on an impressive track 
record, we will continue to enhance our proposition and our ethical 
credentials, leading the debate on the ethical investment issues that  
matter to our customers.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Our business model and strategy

42

43

Section Two

Strategic Report

Strategy in action 

44 

Our charitable purpose drives our strategic goal of being 
the most trusted and ethical business in our chosen 
markets. It shapes the way we do business, particularly 
our focus on doing the right thing for our customers 
and business partners. It creates an environment where 
sustainable, long-term value generation is prized over 
short-term results. 

Thanks to our long-term approach, we have built  
long-standing relationships with our customers  
and brokers, as demonstrated by their high levels  
of trust, loyalty and engagement with our business.  
These enduring relationships have helped us build  
deep understanding and expertise within our sectors,  
allowing us to provide highly valued products  
and services. 

These factors combine to support our drive to deliver 
sustainable and growing returns over the long term, 
creating long-term value for our charitable owner and 
demonstrating that a distinctly ethical, specialist financial 
services group can succeed in competitive markets.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section Two 
 
 
 
 
 
 
 
 
Strategic Report – Strategy in action

44

45

Strategy in action

Ecclesiastical Insurance Office plc is a member of Benefact Group,  
a diverse family of specialist financial services businesses.  
Benefact Group is driven by a shared ambition to do right by our 
customers and clients, and united by a common purpose to give  
all available profits to charity and good causes.

The Group is delighted to continue to make significant contributions  
to good causes with a further £21m grant to its charitable owner,  
Benefact Trust, in the year. This accomplishment has been made  
possible through the significant efforts of all the businesses across  
Benefact Group, which have focused on meeting the needs  
of their customers, clients and business partners.

Our refreshed strategy demonstrates our ambitions for the future, 
responding to global trends and the external market context, building  
on our distinctive position in our chosen markets and our intent to have  
a positive impact on all communities that are important to us. 

Throughout 2021, we continued to deliver the key elements of our 
ambitious strategy enabling further investment in our businesses and the 
delivery of value to our customers. At a wider group level, our strategic 
actions include reflecting our purpose and distinctive positioning with the 
renaming to Benefact Group, and making commitments to being a net zero 
group by 2040 and supporting our customers and partners to tackle their 
carbon emissions. Highlights of this strategy are shown here:

Most trusted specialist insurer

We achieve 
this by being

Strategy in action

Trusted – Operating with the highest ethical 
standards and living our customer and 
intermediary promise

Specialist – Focusing on customer  
segments where we have sustainable 
competitive advantage

Customer led – Delivering a value  
proposition focused on outstanding customer 
experience built on insight, innovation, 
personalised engagement, ethics and  
true product differentiation

Expert – Possessing outstanding expertise  
in core risk and insurance disciplines 

Efficient – Leveraging innovation and 
technology to keep costs as low as possible 

Agile – Leveraging data and our smaller  
size as an advantage to drive pace  
of decision making

•  Strong business growth, attracting and retaining 
prestigious customers across all our segments 
in all our geographies with ongoing recognition 
of our valued and trusted approach

•  Continued to invest in innovation including  

the launch of the Ecclesiastical Smart 
Properties sensor system to provide early 
warning to help prevent fire and water risks 

•  Launched a new visual identity in our 

Ecclesiastical brand across UK, Ireland  
and Canada geographies

•  Continued our targeted support for broker 
partners including wellbeing and mental  
health guidance

•  Won 17 awards in general insurance  

for various categories including innovation, 
service quality, products, claims, people  
and corporate social responsibility

•  Helped customers to manage their strategic 

risks, providing an expert and specialist voice, 
publishing insights such as the Education Risk 
Barometer and strengthened our enterprise  
risk management offering across the UK  
and Australia

•  Reflected the local needs of our customers 

sharing operational risk management advice 
including the use of electric vehicles, protecting 
buildings against arson, storm and flood 
readiness, safeguarding and business resilience

•  Established the Ecclesiastical Specialist School 
in Canada to offer specialised training modules, 
webinars and workshops to customers  
and brokers across underwriting, claims  
and risk disciplines

•  Offered a local point of contact for UK church 

customers through our team of Church 
Insurance Consultants (CICs) who have  
an in-depth toolkit to address key insurance,  
risk management and fundraising concerns

•  Helped customer communities with tailored 
fundraising advice including digital content, 
interactive webinars and a church-focused 
Fundraising in a Box toolkit

Customer satisfaction

•  98% overall satisfaction for the  
Ecclesiastical UK claims service  
(of which 93% are extremely or very satisfied) 
with an 84% Net Promoter Score 

•  98% of church customers are satisfied  
with our service, with 86% extremely  
or very satisfied

•  99% of customers are satisfied with the 

knowledge, efficiency and friendliness of our 
customer service team

•  100% of customers are satisfied with the service 

provided by our team of risk surveyors

•  97% of brokers that place business with 

Ecclesiastical UK are satisfied with our service

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Strategy in action

46

47

Most trusted specialist insurer

Best ethical investment provider

Awards and 
accreditations

Ecclesiastical UK 

Ecclesiastical Canada

We achieve this by

•  #1 for Home Insurance for 13th and 14th 

•  Canada’s Top 100 Employer for Young 

consecutive times, Fairer Finance

People for 9th consecutive year

•  Top for Trust, Happiness, Transparency  
and Complaint Handling, Fairer Finance

•  Greater Toronto Top Employer  

for 3rd consecutive year

•  Digital Insurance Innovation of the Year, 

•  Five Star Carrier Award for 2nd consecutive 

British Insurance Awards

year, Insurance Business Canada

•  Insurance Claims Team of the Year, 

•  Excellence in Corporate Social 

Insurance Post Claims and Fraud Awards

Responsibility, Insurance Business Canada

•  Service Quality Marque for mid-market 

•  Caring Company, Imagine Canada

claims, Gracechurch

Strategy in action

•  Best Overall Completion of the Advanced 

Diploma, Cheltenham and Gloucester 
Chartered Institute of Insurance

•  Best Paper in Advanced Claims,  

Cheltenham and Gloucester Chartered 
Institute of Insurance

•  Customer Service Champion Award  
(Kay Short), Plymouth and Cornwall 
Chartered Institute of Insurance

•  Fellow Chartered Insurance Professional 

(FCIP) Top Graduate Award, Insurance 
Institute of Canada

•  Norman Bortnick Memorial Gold Medal 

Award for FCIP top marks in British 
Columbia, Insurance Institute of Canada

Ecclesiastical Ireland 

•  Specialist Lines Best Product Producer, 

Brokers Ireland Excellence Awards

Ansvar UK

•  Corporate Community Local Involvement 

Award with The Hygiene Bank, The Charity 
Times Awards

Listening to our clients – we have implemented 
a client feedback programme to create greater 
proximity to our clients and their evolving needs 

Enhancing our infrastructure – we are building 
a platform for growth and increased efficiency

Promoting socially responsible investment  
– we have an industry-leading reputation  
for our socially responsible investment funds 
and investment thought leadership 

Delivering long-term performance  
– we use a consistent, proven approach  
to deliver long-term investment success 

Developing our products – we are developing 
and deepening our fund offering with particular 
focus on meeting the demands of our investors 
and providing innovative solutions

•  Recognised for responsible and sustainable 

•  Continued to engage across the responsible 

investment with a strong long-term 
performance record while seeking to have  
a positive impact on society

•  Acknowledged as a pioneer and thought 

leader in our markets with a strengthened 
team with even more expertise 

•  Launched three new multi-asset funds  

with different risk objectives and investment 
goals to complement our responsible  
and sustainable portfolio of funds

•  Sixth year of carbon footprinting of 

investment landscape with membership 
of IIGCC (Institutional Investors Group 
on Climate Change), BBFAW (Business 
Benchmark on Farm Animal Welfare) and 
The 30% Club (to increase gender diversity 
at Board and senior management levels) 

•  Reinforced our thought leadership position 
with acclaimed responsible investment 
research and briefings on topics such as 
Climate change and net zero, Oppressive 
regimes, Antimicrobial resistance, and 
Conflict minerals

EdenTree’s funds portfolio, with an overall 
reduction in the amount of CO2 in the 
investments portfolio since our footprinting 
began. Funds are aligned to the targeted 
outcomes from the Paris Agreement (COP26)

•  Established partnership with British 

swimmer Alice Dearing, the first Black 
woman to represent Team GB in open 
water swimming who embodies EdenTree’s 
approach to Performance with Principles

Awards and 
accreditations

•  Best Ethical Investment Provider for 13th 

•  Sustained A+ rating for Strategy and 

consecutive year, Investment Life & Pensions 
Moneyfacts Awards

Governance in the PRI Transparency Report

•  Boutique Investment Management Award, 

the European SRI Transparency Code

•  Gained ninth accreditation under  

The Charity Times Awards

•  Retained Tier I Status under  

the Stewardship Code

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
 
 
 
 
 
 
Strategic Report – Strategy in action

48

49

Section Two

Strategic Report

Key Performance Indicators 

Financial 

Non-Financial 

50

52 

Most trusted specialist adviser

We achieve this by

Strategy in action

Providing excellent service – building  
long-term sustainable relationships  
with our clients and insurer partners

Strengthening our proposition – deepening 
our expertise further in our chosen markets, 
cementing our position as market leaders  
in these areas 

Building our business – delivering growth  
by developing new offerings and schemes  
which complement our existing niche markets 

Working more closely together – developing 
closer operational links across the Group to offer 
solutions that meet our customers’ needs

•  Continued to grow the Broking and Advisory 
division, sharing expertise and capabilities, 
working together to develop even stronger 
relationships with suppliers and carriers

•  Continued to offer supportive and responsive 
service that meets customer needs including 
insurance broking, risk management and claims 
solutions, and financial advice

•  Leveraged deep understanding of client and 

customer needs and monitored trends to evolve 
product offerings and innovative solutions, for 
example reflecting medical advances in veterinary 
diagnostics and new schemes such as a forestry 
and estates scheme that included carbon credits 
in sums insured

•  Offered knowledge and insights on specialist 

areas such as an interactive guide for professional 
drivers, equine topics including field safety 
and preventing heat stress, risk advice for 
funeral directors, fortifying against flooding, 
underinsurance in farming, and the impact  
of climate uncertainty on crop yield

•  Ecclesiastical Planning Services1 (EPSL) launched 
a new distribution channel, enabling our funeral 
director customers to buy plans online 

•  Ecclesiastical Financial Advisory Services (EFAS) 
continued to meet the key financial concerns  
of clergy and church-related people, offering 
online and face-to-face financial support 
seminars in a number of dioceses  
as the pandemic restrictions eased

•  Supported our specialist communities including:

– Rewarding excellence in horse care for the third 
consecutive year with the SEIB Yard Awards 
and for racehorse training with the Lycetts 
Leadership & Team Champion Awards 

– Recognising long-standing relationship with 
first ever joint SEIB and National Association  
of Funeral Directors Lifetime Achievement 
Award and launched a thank you campaign  
to appreciate the efforts of funeral directors  
on the frontline of the Covid-19 pandemic 

•  Expanded our specialist broking footprint with  

the acquisition of six specialist businesses through 
our investment in Lloyd & Whyte2

•  Celebrated 60 years of broking with our  

Lycetts1 business

Customer satisfaction

Strong customer satisfaction scores and excellent 
Net Promoter Scores across the division:

•  96% EPSL1 funeral director customers are 

•  96% EFAS customers are extremely or very 
satisfied, with 100% satisfied. EFAS achieved  
a Net Promoter Score of 89

extremely or very satisfied, with 100% satisfied 
for the second year running. EPSL achieved  
a Net Promoter Score of 96

•  92% Lycetts1 customers are extremely or very 
satisfied with 98% satisfied. Lycetts achieved  
a Net Promoter Score of 76 

Awards and 
accreditations

•  EPSL1: Funeral Plan Experts of the Year  

– South West, Southern Enterprise Awards

•  Lloyd & Whyte2: Growth Company of the Year, 

National Insurance Awards 

•  Lloyd & Whyte2: Commercial Lines Broker  
of the Year (for Business Choice Direct),  
National Insurance Awards 

1  part of Benefact Group

2   part-owned by Benefact Group

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section Two 
 
 
 
 
 
 
 
 
Strategic Report – Key Performance Indicators

50

51

Key Performance Indicators
Financial

Measure

Performance

Measure

Performance

Donations
The amount donated  
by Ecclesiastical to charities, 
including our charitable 
owner, each year. This is 
the main measure of our 
ambition, which was  
to exceed £100m  
in charitable giving  
by September 2021.

Strong investment returns and a robust 
underwriting performance1 enabled  
us to increase our charitable giving  
to £23.5m. This includes grants of £21.0m  
to our charitable owner, Benefact Trust,  
and a further £2.5m to good causes.

We achieved our £100m target, set in 2016, 
and have set a new target of reaching 
£250m1 by the end of 2025.

Regulatory capital2
The Group’s regulatory 
capital requirements are 
defined under the Solvency II  
directive as issued by the 
European Union and adopted 
by the Prudential Regulation 
Authority (PRA). 

As the Group assessment  
is conducted at the level  
of Benefact Group plc,  
the following refers  
to the regulatory capital 
of Ecclesiastical Insurance 
Office plc (Ecclesiastical 
Insurance Office Group’s 
parent company).

The Solvency Capital 
Requirement (SCR) is a risk-
based statistical calculation 
that quantifies risks specific 
to our business. The Group 
sets a target level of capital 
that is in excess of the SCR  
to ensure ongoing compliance.

Ecclesiastical’s capital cover under 
Solvency II has improved.

During 2021, own funds have increased  
with the favourable performance  
of financial investment assets, pension 
surplus and the issuance of €30m 
subordinated debt in February 2021.  
The €30m subordinated debt is classed  
as tier 2 capital. Our Solvency II regulatory 
capital position remains above regulatory 
requirements and risk appetite.  
The solvency coverage has decreased 
due to an increase in the Loss Absorbing 
Capacity of Deferred Taxes. 

The figures for 2021 are based on the 
information provided to the Board as part 
of its ongoing management of the business 
and are unaudited. 

We continue to balance the need to retain 
profit within the business, to support our 
strategy for future growth and investment 
in technology and innovation, with our 
aspiration to meet charitable giving targets.

£m

40 -

30 -

27.5

32.5

18.8

23.5

20 -

10 -

0 -

£m

700 -

600 -

500 -

400 -

300 -

200 -

100 -

0 -

2.7

2017 2018 2019 2020

2021

Solvency II capital cover 
(unaudited)

269
292

295
257

306 256
264 263

381
236

%

- 300%

- 250%

- 200%

- 150%

- 100%

- 50%

- 0 %

2017
(i)

2018
(ii)

2019 
(ii)

2020 
(ii)

2021

SCR (£m)
Excess own funds (£m)
Capital cover (%)

(i) the 2017 figures are audited and reflect figures 
from the Company’s published Solvency and 
Financial Condition Report which is available  
via the Company’s website

(ii) the 2018, 2019 and 2020 own funds  
are audited and reflect figures from the 
Company’s published Solvency and Financial 
Condition Report which is available  
via the Company’s website

Profit or loss  
before tax
The Group’s profit before 
deduction of tax.

Each year, refreshed targets 
are set in relation to the 
Group’s business plans for 
profit before tax. Details  
of the target that was set 
for 2021 can be found in the 
Group Remuneration Report. 
Our short-term target  
is to generate sufficient  
profit to enable us to meet 
our targets for charitable 
donations.

Combined operating 
ratio1 (COR)
The sum of Ecclesiastical’s 
general insurance incurred 
losses and expenses divided 
by earned premiums for each 
financial year.

Each year, refreshed targets 
are set in relation to the 
Group’s business plans for 
the Group COR. Details of the 
target that was set for 2021 
can be found in the Group 
Remuneration Report.  
Our target over the longer 
term is to achieve a 95% COR.

The Group reported a profit before tax  
in 2021 of £77.0m (2020: loss before tax £15.7m)  
driven by strong investment returns and a solid 
insurance result.

Increased profits from our Broking and  
Advisory business contributed to the Group 
result, while our Investment Management 
business reported a loss as it continued  
to invest in growing the business.

More information on underwriting performance1 
is given below.

See the Financial Performance Report within  
the Strategic Report for more details.

Our COR increased in 2021. This reflects liability 
reserve strengthening in Australia, adverse 
weather events in the UK and more modest prior 
year claim releases compared with previous 
financial years.

The Group continues to keep underwriting  
and pricing discipline at the centre of its 
strategy, prioritising profit over growth  
in the competitive business environment. 

For a breakdown of how COR is calculated,  
see note 37 to the financial statements.

See the Financial Performance Report within  
the Strategic Report for more details.

£m

80 -

60 -

40 -

20 -

0 -

(20) -

%

105 -

100 -

95 -

90 -

85 -

80 -

82.2

73.3

77.0

15.4

(15.7)

2017 2018 2019 2020

2021

Profit/(loss) before tax
Underwriting profit1

96.8

95.1

91.1

86.9

86.4

2017 2018 2019 2020

2021

Longer-term target

1  Cumulative giving since 2014.

2  Alternative performance measure, refer to note 37 to the financial statements for further explanation.

1  Alternative performance measure, refer to note 37 to the financial statements for further explanation.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Key Performance Indicators

52

53

Section Two

Strategic Report

Financial Performance Report 

54 

Measure

Performance

Our NER increased in 2021 to 53.5% reflecting 
a 10.2% increase in net earned premium and 
12.6% increase in net expenses.

Expenses include our continuing programme  
of strategic investment in technology to support 
business growth and customers’ needs. 

For a breakdown of how NER is calculated, 
see note 37 to the financial statements.

Investment markets were more optimistic  
in 2021 as the world learned to live with 
Covid-19. Economies reopened and stimulus 
packages bolstered growth.

The Group’s investment management
business, EdenTree, increased its distribution 
capacity and widened its product range. 

Against this backdrop, record net new inflows  
of £415m were reported, with the previous  
high being £204m in 2019.

Net expense ratio1 
(NER)
Total expenses as  
a proportion of the net 
premium earned in the 
year. These expenses 
include acquisition costs, 
administration costs,  
the movement in deferred 
acquisition costs and 
commission paid less 
commission received. 

Our aim is to make year-on-
year improvements in the 
NER. However, in the short 
term, we expect the NER  
to reflect a planned increase 
in strategic investment.

Net inflows1 
(Investment 
Management)
Net inflows are the difference 
between the funds invested 
and the funds withdrawn 
during the period by third 
parties in the range of funds 
our Investment Management 
division offers.

Net inflows contribute  
to funds under management 
which is a key driver  
of the division’s revenue.

Each year, refreshed targets 
are set which take into 
account current market 
conditions and potential 
new initiatives.

1  Alternative performance measure, refer to note 37 to the financial statements for further explanation.

Key Performance Indicators
Non-Financial

We place equal importance on financial and non-financial key performance 
indicators. Details of the non-financial performance indicators can be found  
within our Strategy in action section and our Responsible Business Report.

(%)

100 -

80 -

60 -

53.6

54.5 53.0 52.4

53.5

40 -

20 -

0 -

£m

450 -

400 -

350 -

300 -

250 -

200 -

150 -

100 -

50 -

0 -

2017 2018 2019 2020

2021

415

204

173

173

61

44

2017 2018 2019 2020

2021

(i)

(i) 2020 figures have been updated to exclude certain  
net flows managed at Benefact Group level

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section Two 
 
 
 
 
 
 
 
 
Financial Performance Report

Profit before tax of £77.0m1 (2020: loss before 
tax £15.7m) has been driven in particular 
by strong investment returns, as markets 
rebounded strongly from 2020.

54

55

The Group’s general insurance businesses 
reported profit before tax of £8.8m  
(2020: £12.1m) representing another robust 
performance. This result includes areas  
where we have strengthened reserves and  
the impacts of some adverse weather events. 
Our underwriting result is also reflective  
of our continued strategic investment across 
our insurance technology platforms to ensure 
that our businesses are well positioned  
to deliver sustainable and profitable growth. 
We continue to be a trusted partner to our 
customers and brokers, and this is reflected 
in our strong retention and satisfaction levels, 
which have supported the 11% growth in gross 
written premiums (GWP). 

Our business is managed with a long-term 
view of risk and, as a result, we have  
a strong capital position that can withstand 
short-term volatility and our strong credit 
ratings with S&P and AM Best were both 
reaffirmed during the year. Our Solvency II 
regulatory capital position remains above 
regulatory requirements and risk appetite  
and was supported with the issuance of €30m 
subordinated debt in February 2021, as the 
Group seeks to take advantage of profitable 
growth opportunities.

General insurance
The Group’s underwriting businesses have 
performed in line with expectations in most 
territories, resulting in a Group Combined 
Operating Ratio2 (COR) of 96.8% (2020: 95.1%). 
We have delivered steady underwriting profits 
despite liability reserves strengthening  
in Australia and adverse weather events in the 
UK. Our strategy to focus on profitable growth 
opportunities has continued to deliver, with 
new business of £42.2m contributing to our 
overall GWP growth of 11% to £486m (2020: 
£437m) which also reflects targeted rate 
increases as well as strong retention.

Our programme of investment has continued, 
particularly across our technology platforms. 
The customisation and development of the 
software that underpins these platforms made 
up 2.8 points of our Group COR for the year. 
Our investment in these platforms are  
an important part in supporting the growth  
of our business and our customers’ needs  
for the long term.

United Kingdom and Ireland
In the UK and Ireland, underwriting profits 
increased to £25.0m (2020: £12.3m) giving 
a COR of 85.3% (2020: 92.5%). GWP grew  
by 7.5% to £297.2m (2020: £276.6m).  
The current year underwriting performance 
was strong with prior year claim releases 
contributing to a more modest proportion  
of the result compared with previous financial 
years. Despite a series of weather events and 
large claims, current year loss ratios were 
slightly ahead of expectations as a result  
of rate changes and portfolio management.  
Both property and casualty accounts 
generated underwriting profits.

Heritage, Education and Real Estate were 
particularly strong growth areas in 2021 
despite the competitive trading conditions. 
We expect trading conditions to remain 
competitive but the outlook is becoming 
increasingly unpredictable. Inflationary 
pressures in the economy, Covid-19 
uncertainty, and the potential for more 
frequent and intense weather events due 
to climate change all contribute to this 
uncertainty. However, our Net Promoter 
Scores across brokers and customers are 
robust, have improved and provide resilience, 
enabling us to carry positive rate change 
where needed and contribute to the high 
levels of retention experienced. Market 
hardening in certain areas of our property  
and casualty portfolios enabled us to write 

 1  Further details can be found in note 5 to the financial statements.

 2  Alternative performance measure, refer to note 37 to the financial statements for further information.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoStrategic Report – Chair’s StatementSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Strategic Report – Financial Performance Report

56

57

new business at profitable levels.  
GWP in respect of our Faith business  
remained in line with prior year reflecting  
a good result in challenging conditions.

Our strategy over the medium term  
is to deliver GWP growth, while maintaining 
our strong underwriting discipline, as our 
philosophy is to seek only profitable growth. 
We will continue to deepen our specialist 
capabilities through investment in technology 
and innovation together with the propositions, 
specialism, and excellent service that  
our customers value.

Ansvar Australia
Our Australian business reported an 
underwriting loss of AUD$24.4m resulting 
in a COR of 156.9% (2020: AUD$1.2m loss, 
COR of 102.2%). GWP grew by 14.2% in local 
currency to AUD$171.2m (2020: AUD$149.9m) 
with strong new business growth, retention 
and rate increases. The performance of the 
business written in the current year has 
been good and continues to improve in light 
of positive underwriting actions. However, 
the overall underwriting result includes the 
adverse impact of reserves strengthening in 
the liability account for historic physical and 
sexual abuse (PSA) claims. The underwriting 
loss also reflects our significant investment  
in a new underwriting system which will 
benefit the business over the longer term.

The Group made a further underwriting loss 
of £10.0m (2020: £4.7m) within its internal 
reinsurance portfolio as a result of reserves 
strengthening in respect of historic PSA  
claims in Ansvar Australia. 

Canada 
Our Canadian business continued its track 
record of delivering premium growth, 
reporting GWP of CAD$158.0m (2020: 
CAD$131.5m), a 20.1% increase, which  
was supported by strong retention and  
rate increases as well as new business. 

Canada reported an underwriting profit  
of CAD$12.2m resulting in a COR of 88.6% 
(2020: CAD$7.8m profit, COR of 91.2%). 
Despite an increase in the number of large 
losses, the property book performed well 
due to benign weather, lighter than expected 
attritional losses, and favourable development 
on prior year net losses. The performance 
of the liability book was impacted by some 
adverse development on prior year claims and 
the strengthening of the reserves provision.

Investments 
2021 saw optimism return as Covid-19 
vaccines allowed economies to reopen,  
with unprecedented stimulus packages from 
governments and central banks bolstering 
growth, but also stoking inflation. The Group’s 
net investment return of £101.1m (2020: loss 
of £4.3m) can be largely attributed to the 
continued recovery in equities, both within 
our directly-held portfolio, and via holdings 
in EdenTree’s Responsible and Sustainable 
OEIC funds, whilst our investment property 
portfolio also experienced strong gains.

Investment income of £30.9m reflects a more 
optimistic market as the world learns to live 
with Covid-19 (2020: £30.2m). A recovery 
from the initial impact of the pandemic was 
also reflected in fair value gains on financial 
instruments of £38.1m, reversing the impact 
of fair value losses of £13.6m seen in 2020. 
The past two years highlight the impact 
economic and political uncertainty can have 
on the performance of our investments, 
with the recent conflict in Ukraine leading 
to an increased level of market volatility. 
Notwithstanding this, we remain confident  
in our long-term investment philosophy,  
and are well-diversified and relatively 
defensively positioned. 

Within our UK equity portfolio, small-cap 
exposure proved beneficial as the FTSE  
Small-Cap outperformed the FTSE All-Share 
by a significant margin over the course  
of the year. 

Our directly-held sterling bond portfolio 
outperformed the FTSE Gilts benchmark  
by 5.3% in 2021, as the longer duration index 
was impacted by rising yields to a greater 
extent than our shorter-dated bond portfolio.

Our investment properties delivered fair value 
gains of £20.2m (2020: losses of £5.0m) 
driven by increased market demand for 
commercial property where the portfolio  
is well-represented.

The upward movement in bond yields led  
to an increase in the discount rate applied 
to long-tail insurance liabilities. The change 
in discount rate on those liabilities resulted 
in a profit of £11.9m recognised within net 
investment return (2020: £15.9m loss).

Investment Management 
The Group’s investment management 
business, EdenTree, was pleased to report 
record net inflows of £415m, excluding Group 
flows. The previous high was £204m in 2019 
(2020: £44m). EdenTree incurred a loss  
before tax for the year of £2.5m (2020: loss 
before tax £1.0m) as it invested in growing  
the business through its distribution capacity 
and with a widening of its product range.

Assets under management (AUM) increased 
by 25% in the year. Half of this asset growth 
was attributable to new money into the 
business, and half to markets as funds 
performed well across the fund range.  
AUM were £3.7bn (2020: £3.1bn) and £2.8bn 
(2020: £2.3bn) excluding assets managed  
for the Group. 

Net income at £14.9m was up by 20% year  
on year (2020: £12.4m). This is due to both 
client inflows in the year and increasing 
market value of assets, however maintaining 
margins on fees earned continues to be 
challenging, a trend which is seen across  
the industry.

Long-term business 
Our life business, Ecclesiastical Life Limited, 
reopened to business during the year, 
launching a new product providing guaranteed 
returns for funeral planning products sold  
by Ecclesiastical Planning Services, a business 
within the wider Benefact group. The legacy 
book within our life insurance business 
remains closed to new business. Profit before 
tax grew to £1.1m for the year (2020: £0.5m). 
Assets and liabilities in relation to the life 
insurance business remain well matched. 

Broking and Advisory 
Overall, Broking and Advisory performance 
has been strong, reporting a profit before 
tax of £3.0m (2020: £2.4m). This area of our 
business includes our insurance broker,  
SEIB Insurance Brokers (SEIB) and our 
financial advisory business, Ecclesiastical 
Financial Advisory Services (EFAS).  
SEIB reported an increase in profit before  
tax to £3.2m (2020: £2.8m), whilst EFAS 
reported a small loss of £0.2m in the year 
(2020: £0.3m loss). 

In addition to these Broking and Advisory 
businesses our immediate parent company, 
Benefact Group plc holds interests in the 
specialist broker groups Lycetts and Lloyd  
& Whyte and a prepaid funeral plan business, 
Ecclesiastical Planning Services. Whilst the 
results of these are not included within the 
Ecclesiastical Insurance Office Group, they are 
managed together as part of the Group’s wider 
Broking and Advisory group of businesses.  
The broker businesses were profitable in 2021 
but the prepaid funeral plan business made  
a small loss in the year. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Financial Performance Report

58

59

Outlook 
Although the easing of most pandemic-related 
restrictions means we entered 2022 in a very 
different place to the start of last year, we are 
still living with Covid-19, and some remaining 
level of uncertainty from the pandemic will 
likely persist. The recent devastating events  
in Ukraine, and the consequences  
of previously unthinkable international 
economic sanctions, has led to heightened 
market volatility, an increased risk of inflation 
and risks to the supply chain. We will continue 
to manage these risks and remain alert to 
changes in them across all of our businesses. 
Despite the increased level of uncertainty, 
we remain optimistic about the future and are 
fully committed to our ethical and long-term 
investment strategy. The Group continues  
to take a long-term view of risk, remains well 
capitalised and is capable of withstanding 
potential future volatility.

As part of Benefact Group, we have many 
exciting opportunities ahead. We’ll continue 
to grow, innovate and build a sustainable 
business that can continue to generate 
profitable growth and help achieve our 
ambition of giving £250m to charity and  
good causes by the end of 2025.

Denise Cockrem
Group Chief Financial Officer

‘As part of  
 Benefact Group, we 
have many exciting 
opportunities ahead. 
We’ll continue to 
grow, innovate and 
build a sustainable 
business.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information60

61

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Benefact. One family. One vision. 

We’re proud to be part of Benefact Group,  
a global family of specialist financial services 
businesses. Like us, each business in the Group 
is a trusted expert in its market and has a strong 
charitable purpose. And it’s this powerful desire to 
help others that binds us together.

These fundraising activities 
complement our online church and 
charity fundraising hubs, which we 
launched in 2020. Featuring a range 
of resources, developed in conjunction 
with fundraising specialists, they offer 
easy-to-use support, tools and guidance, 
including advice on researching and 
applying to possible donors and grant 
funders. Practical help that goes  
hand-in-hand with our financial support.

Our desire to help others – to support 
the causes you care about – is why  
we give all available profits to charities 
and good causes. It’s also why we’re  
so ambitious to keep on growing – 
because quite simply, the more we grow, 
the more we can give back. Besides our 
charitable donations, one of the other 
key ways in which we support charities 
is through fundraising. 

In 2021, we continued to build on our 
fundraising support. We ran a series  
of successful webinars, following which 
95% of charity attendees said they would 
recommend the sessions. And with church, 
as well as charity, incomes being hit hard 
by the pandemic, we also produced  
a tailored toolkit ‘Fundraising in a Box’, 
which was sent to all Anglican church 
customers in January.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
Strategic Report – Risk Management Report

62

63

Risk Management Report

Introduction
Strong governance is fundamental to what we do and drives the ongoing 
embedding of our Enterprise-Wide Risk Management Framework. 
This provides the tools, guidance, policies, standards and defined 
responsibilities that enable us to achieve our strategy and objectives, 
whilst ensuring that individual and aggregated risks to our objectives  
are identified and managed on a consistent basis.

Risk 
strategy

Risk appetite

Risk policies and standards

Internal model

Stress and 
scenario 
testing

ORSA

d three lines of defence
ntrol framework an
Internal co

Risk 
management 
process

R

i

s

k

r

e

p

o

r

t
i

n

g

a

n

d

m

o

n

i
t

o

r

i

n

g

Business performance 
and capital 
management

Values and culture

People, systems and processes

Governance

The Risk Management Framework  
is integrated into the culture of the Group 
and is owned by the Board. Responsibility 
for facilitation of the implementation and 
oversight is delegated via the Group Chief 
Executive to the Group Risk Function, led by 
the Group Chief Risk and Compliance Officer.

The Risk Management process  
demands accountability and is embedded  
in performance measurement and reward, 
thus promoting clear ownership for risk  
and operational efficiency at all levels.  
On an annual basis, the Group Risk Committee 
(GRC), on behalf of the Board, carries out  
a formal review of the key strategic risks 
for the Group with input from the Group 
Management Board (GMB) and the Strategic 
Business Units (SBUs). The GRC allocates 
responsibility for each of the risks  
to individual members of the Group’s executive 
management team. Formal monitoring of the 
key strategic risks is undertaken quarterly, 
which includes progress of Risk Management 
actions and is overseen by Executive  
Risk Committees.

Ecclesiastical has clearly defined the 
accountabilities, roles and responsibilities  
of all key stakeholders in implementing  
and maintaining its Risk Management 
Framework. These are defined, documented 
and implemented through the Terms  
of Reference of Board Sub Committees, 
Management and Executive Forums, 
Statement of Responsibilities and  
Functional Charters.

The Group’s Risk Management Framework  
is part of a wider Internal Control Framework. 
Systems of internal control are designed 
to manage rather than eliminate the risk 
of failure to achieve business objectives, 
and provide reasonable, but not absolute, 
assurance as to the prevention and detection 
of financial misstatements, errors, fraud  
or violation of law or regulations.

Key to the successful operation of the 
internal control framework is the deployment 
of a strong Three Lines of Defence Model 
whereby:
• 1st Line (Business Management)  

is responsible for strategy execution, 
performance and identification and 
management of risks and application  
of appropriate controls;

• 2nd Line (Reporting, Oversight and Guidance) 

is responsible for assisting the Board  
in formulating risk appetite, establishing 
minimum standards, developing appropriate 
risk management tools, providing oversight 
and challenge of risk profiles and risk 
management activities within each of the 
business units and providing risk reporting  
to executive management and the Board. 
• 3rd Line (Assurance) provides independent 

and objective assurance of the effectiveness 
of the Group’s systems of internal control. 
This activity principally comprises the 
Internal Audit function, which is subject  
to oversight and challenge by the Group 
Audit Committee.

We seek to develop and improve our Risk 
Management Framework and strategy on an 
ongoing basis to ensure it continues to support 
the delivery of our strategy and objectives.

The Group Risk Appetite defines the level  
of risk-taking that the Board considers  
to be appropriate for the Group as we pursue 
our business objectives. It is defined in line 
with the different categories of risk that the 
Group faces, and provides the backdrop 
against which the business plan is developed 
and validated. This ensures that the risk profile 
resulting from the business plan is in line  
with the risk-taking expectations of the Board. 
Compliance with the risk appetite is formally 
monitored every quarter and reported  
to the GRC at each meeting.

The risk appetite is formally reviewed 
annually with approval and sign-off by the 
Board and there are ongoing assessments  
to ensure its continued appropriateness  
for the business.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
 
Section Two

Strategic Report – Risk Management Report

64

65

The Own Risk and Solvency Assessment 
(ORSA) process is carried out at least once 
a year and is a key part of the business 
management and governance structure.  
This integrates the risk management,  
business planning and capital management 
activities and ensures that risk, capital and 
solvency considerations are built into the 
development and monitoring of the Group’s 
business strategy and plans and all key 
decision making. 

The Group has Regulatory approval for  
the use of an Internal Model to determine  
our Regulatory Capital requirement.  
In addition, the Internal Model’s capability  
to quantify material risks and assess  
the impacts on Capital requirements across  
a range of scenarios allows us to gain  
a deeper insight into the relationship  
between Risk and Capital Management. 

The Internal Model is used extensively  
to inform key business decisions across  
the Group, including setting business 
strategies and objectives, producing risk 
profiles and capital requirements for different 
scenarios, informing risk-taking guidelines, 
informing and defining the Group Risk Appetite 
and Investment Strategy, determining risk 
mitigation mechanisms and responses  
to regulatory capital requirements. 

Risk environment
The Risk environment is monitored  
on an ongoing basis and key areas of concern 
are escalated to the GRC. 

The impacts of the conflict in Ukraine are 
being closely monitored as the range of 
measures being taken in response by the 
UK government and other countries grow. 
We remain alert to the changing external 
environment and the impact it could have  
on our business and risk profile.

The Covid-19 pandemic continues to have  
a wide-ranging impact on the Group and  
the environment in which we operate.  
The management of various risks arising from 
the evolving position has been co-ordinated 
by the GMB. As well as continuing operational 

implications, there were impacts on the 
insurance policies written by Group companies 
and on the Group’s investment assets. 

A Crisis Management Team (CMT) continued  
to operate for the first part of 2021, using  
the Group’s Business Continuity Plans,  
and to oversee the ongoing management  
of operational elements. The primary focus 
of the CMT was oversight of the continued 
effectiveness of remote working,  
with particular emphasis on people  
and technology. 

Responses to other specific risk-types were 
delegated to existing bodies within the risk 
framework, with focused management groups 
set up where considered appropriate. 

Investment markets recovered well during 
2021, as economies recovered from the  
effects of the global pandemic leading  
to growth in the value of our investment 
assets throughout the year. We maintained 
our existing investment approach and made 
no material changes to our asset mix, holding 
a diversified portfolio of assets including 
equities and property held for prospects  
of long-term returns. Consequently,  
we continue to choose to take a relatively  
high level of market risk, which is well 
understood and closely monitored and 
managed. We have seen market volatility  
in 2022 that has persisted with the unfolding 
conflict in Ukraine and this continues  
to be monitored.

The profitable management of our insurance 
businesses on a portfolio basis in hardening 
markets continues to be a key area of focus for 
the Group; ensuring that the business written 
and retained is profitable and sustainable. 
Competitor activity is an ever-present risk 
across all our business operations and 
chosen niches and 2021 was no exception. 
Our strategy remains to achieve controlled 
and profitable growth within our defined 
specialist markets. During 2021 we obtained 
improvements in rate strength across all 
territories in which we operate and we have 
maintained our strong underwriting discipline 
and risk appetite. 

is therefore highly important at this time, 
and the Group operates an ongoing 
programme of training and awareness 
exercises for its staff.

The Group aims to be the most trusted, 
specialist insurer and therefore maintaining  
a positive reputation is critical. Our reputation 
could potentially be damaged as a result  
of a range of factors including poor business 
practices and behaviours. High standards  
of conduct are a core part of the Group’s 
brand, values and culture and there is an 
ongoing focus on ensuring this is maintained. 

Climate change presents increasing levels 
of risk to our businesses and our customers. 
Whilst the greatest impacts of these risks  
are expected to materialise in the medium  
to long term, it is important that we take 
actions to mitigate and manage these risks 
now. Our exposures to climate change risk 
include transition risk, primarily related  
to our investment portfolio, and physical  
risk that additionally affects the insurance 
risks that we cover.

The potential for adverse development  
of long-tail liability claims, particularly  
in respect of PSA claims, remains a key risk 
that we continue to actively manage.  
The Independent Inquiry into Child Sexual 
Abuse in the UK is progressing and we 
participated in one of the investigations 
that delivered its report in 2020. Further 
investigations as part of the Inquiry are 
underway. New claims volumes emerging 
during 2021 in Australia and Canada had  
led to increases in levels of reserves held.  
We continue to monitor the experience and 
claims environment in all of the territories  
in which we operate.

The Covid-19 pandemic was the trigger  
for a high volume of regulatory guidance 
issued in all territories during the prior 
year. Consequently, some other elements  
of regulatory change have been delayed, 
though we expect the pace of change  
to increase again as we move forward 
into 2022. Management of change in the 
regulatory environment continues to be 
a focus to ensure that we operate within 
relevant legal, regulatory and consumer 
protection requirements and guidelines  
and that our people maintain the highest 
standards of conduct with continued 
commitment to placing customers at the 
centre of everything we do.

Cyber risk remains a constantly evolving 
threat due to the threat of zero day attack  
and with the unfolding conflict in Ukraine.  
We hold customer data, and therefore any event  
involving a significant loss of such data could 
result in harm to the data subjects, significant 
operational disruption and an impact on our 
service to customers, as well as sizeable 
regulatory fines and reputational damage. 
The increased societal focus on data security 
and appropriateness of use, together with 
regulations such as GDPR, results in increased 
scrutiny and prominence. External attackers 
view the disruption arising from a more 
hybrid working environment as an exploitable 
opportunity, and there continues to be a 
general increase in social engineering and 
phishing attacks across the financial sector. 
Employee awareness and vigilance  

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information66

67

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

Committed to tackling climate change

As a company dedicated to making a positive  
impact on society – and therefore our environment 
– we’re committed to making big changes to protect 
our planet.

We support our customers and 
communities to reduce their carbon 
emissions through our innovation  
and advice, and we support climate 
change reduction through our giving.  
So, when we talk about being committed 
to tackling climate change we’re talking 
about effecting real change through 
carefully-thought-out strategies backed 
up by a 135 year commitment to the 
world around us.

By 2030, instead of just aiming for net 
zero emissions, we’ve set ourselves  
a target to wipe out our historic carbon 
impact. And we’re working with 
independent bodies to help us achieve 
this across all our businesses.

Through our investment management 
business, EdenTree – a pioneer in 
Environmental, Social and Governance, 
and a signatory to the Montréal Carbon 
Pledge in June 2016 – our responsible 
and sustainable investment strategy  
is a bold step forward. It not only avoids 
investment in businesses that cause 
social harm but actively seeks to invest 
in markets that have positive impacts. 
We’ve already disposed of the most 
carbon-intensive holdings by excluding 
fossil fuels, mining and high emitting 
polluters such as automotive, aviation, 
and heavy industry – directing capital  
to sustainable solutions.

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
Strategic Report – Principal risks

68

69

Principal risks

There is an ongoing risk assessment process which has identified the current principal risks for the Group as follows:

Insurance risk
The risk that arises from the fluctuation in the timing, frequency and severity of insured events 
relative to the expectations of the firm at the time of underwriting.

Risk detail

Key mitigants

Change from last year

Risk detail

Key mitigants

Change from last year

Underwriting risk1
The risk of failure  
to price insurance products 
adequately and failure 
to establish appropriate 
underwriting disciplines.  
The premium charged must 
be appropriate for the nature 
of the cover provided and the 
risk presented to the Group. 
Disciplined underwriting 
is vital to ensure that 
only business within the 
Company’s risk appetite and 
desired niches is written. 

Reserving risk1
Reserving risk is the risk 
of actual claims payments 
exceeding the amounts  
we are holding in reserves. 
This arises primarily 
from our long-tail liability 
business. Failure to interpret 
emerging experience or fully 
understand the risks written 
could result in the Group 
holding insufficient reserves 
to meet our obligations.

There have been no material 
changes to this risk during 
the year and minimal impacts 
as a result of the conflict in 
Ukraine. 

• A robust pricing process is in place
• The Underwriting Licencing process has been refreshed
• A documented underwriting strategy and risk appetite  
is in place together with standards and guidance and 
monitored by SBUs

• This is supported by formally documented authority levels  

for all underwriters which must be adhered to. Local checking 
procedures ensure compliance

• Monitoring of rate strength compared with technical rate  

is undertaken on a regular basis within SBUs

• There are ongoing targeted underwriting training 

programmes in place

• A portfolio management framework is in place to ensure clear 

understanding and allow targeted actions to be taken 

• Claims development and reserving levels are closely 

monitored by the Group Reserving team

• For statutory and financial reporting purposes, prudential 
margins are added to a best estimate outcome to allow  
for uncertainties

• Claims reserves are reviewed and signed-off by the Board 

acting on the advice and recommendations of the Group Chief 
Actuary following review by the Reserving Committee 
• An independent review is also conducted by the Actuarial 

Function Director with reporting to the Board

This risk is not considered 
to have changed materially 
during the year. A rise  
in numbers of Physical and 
Sexual Abuse claims in the 
Australian and Canadian 
businesses over the past 
year has led to an increase  
in reserves.

• Modelling is undertaken to understand the risk profile  

and inform the purchase of reinsurance

• There is a comprehensive reinsurance programme in place  

to protect against extreme events. All placements are 
reviewed and approved by the Group Reinsurance Board

• Exposure monitoring is undertaken on a regular basis
• A Catastrophe Risk Management Group provides oversight 

and sign off of reinsurance modelling

• The Group Risk Appetite specifies the reinsurance purchase 

levels and retention levels for such events

• Local risk appetite limits have been established to manage 
concentrations of risk and these are monitored by SBUs

• We take a long-term view of reinsurance relationships  

to deliver sustainable capacity 

• A well-diversified panel of reinsurers is maintained for each 

element of the programme

• A Group Reinsurance Board approves all strategic 

reinsurance decisions

Catastrophe risk1
The risk of large scale 
extreme events giving 
rise to significant insured 
losses. Through our general 
insurance business  
we are exposed to significant 
natural catastrophes  
in the territories in which  
we do business.

Reinsurance risk
The risk of failing to access 
and manage reinsurance 
capacity at a reasonable 
price. Reinsurance is a 
central component of our 
business model, enabling  
us to insure a portfolio  
of large risks in proportion 
to our capital base.

There have been no material 
changes to this risk.  
We continue to monitor our 
aggregations and exposures 
to such events and ensure 
careful management utilising 
appropriate protections.

The level of this risk has 
remained broadly similar 
since last year. Reinsurance 
markets have experienced 
challenges in recent  
years due to the impact  
of Covid-19 claims and global 
catastrophe events.  
This has resulted in 
tightening of criteria and 
capacity in certain areas.  
We continue to take  
a long-term approach to our  
reinsurance relationships. 

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

1  Link to viability statement – risk included in stress and scenario analysis

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection FourFinancial StatementsSection FiveOther Information 
 
Strategic Report – Principal risks

70

71

Other financial risks
The risk that proceeds from financial assets are not sufficient to fund the obligations arising from 
insurance contracts.

Risk detail

Key mitigants

Change from last year

Risk detail

Key mitigants

Change from last year

Market and 
investment risk1
The risk of adverse 
movements in net asset 
values arising from a 
change in interest rates, 
equity and property 
prices, credit spreads and 
foreign exchange rates. 
This principally arises 
from investments held by 
the Group. We actively 
take such risks to seek 
enhanced returns on these 
investments.

• An investment strategy is in place which is reviewed at least 

annually and signed off by the Finance and Investment 
Committee (F&I). This includes consideration of the Group’s 
liabilities and capital requirements

• A Market and Investment Risk Committee is in place and 
provides oversight and challenge of these risks and the 
agreed actions. There is a formalised escalation process to 
GMB and F&I in place

• There are risk appetite metrics in place which are agreed by 

the Board and include limits on Asset / Liability Matching and 
the management of investment assets

• Derivative instruments are used to hedge elements of market 
risk, notably equity and currency. Their use is monitored to 
ensure effective management of risk

• There is tracking of risk metrics to provide early warning 

indicators of changes in the market environment 

Overall the market risk 
profile has not materially 
changed and we remain 
invested for the long term. 
We continue to monitor 
market conditions and the 
socio-political environment. 
We have seen increased 
stock market volatility in 
2022 in response to the 
conflict in Ukraine and 
continue to monitor this. 
However, the impact has 
been minimal to date given 
the assets we hold and our 
investment strategy.

The Group’s balance sheet is 
also exposed to market risk 
within the defined benefit 
pension fund.

The Pension Scheme Trustee Board has an Investment 
Committee that oversees the market risks in the pension fund. 
The Company, as employer sponsor of the fund maintains 
regular communication with this Committee. 

Further information on this risk is given in note 4 to the financial 
statements.

•  Strict ratings criteria are in place for the reinsurers that 
we contract with and a Reinsurance Security Committee 
approves all of our reinsurance partners

•  Group Reinsurance monitors the market to identify changes in 

the credit standing of reinsurers

•  There are risk appetite limits in place in respect of reinsurance 

counterparties which are agreed by the Board

•  Strong credit control processes are in place to manage broker 

and policyholder exposures

Further information on this risk is given in note 4 to the financial 
statements.

The level of this risk has 
remained broadly similar  
to the previous year.

Credit risk1
The risk that a counterparty, 
for example a reinsurer, 
fails to perform its financial 
obligations to the Company 
or does not perform them in 
a timely manner resulting 
in a loss for the Group. 
The principal exposure 
to credit risk arises from 
reinsurance, which is central 
to our business model. Other 
elements are our investment 
in debt securities, cash 
deposits and amounts owed 
to us by intermediaries and 
policyholders.

1  Link to viability statement – risk included in stress and scenario analysis

Liquidity risk
The risk that the Group, 
although solvent, either does 
not have sufficient financial 
resources available to enable 
it to meet its obligations as 
they fall due, or can secure 
them only at excessive 
cost. We may need to pay 
significant amounts of claims 
at short notice if there is 
a natural catastrophe or 
other large event in order to 
deliver on our promise to our 
customers.

Climate change
The financial risks arising 
through climate change. 
The key impacts for the 
Company are physical  
risks (event driven  
or longer-term shifts),  
the transition risks of moving 
towards a lower carbon 
economy and liability risks 
associated with the potential 
for litigation arising from  
an inadequate response.

•  We hold a high proportion of our assets in readily realisable 
investments to ensure we could respond to such a scenario 

• We maintain cash balances that are spread over several 

There have been no material 
changes to this risk since  
last year.

banks

• We have arrangements within our reinsurance contracts for 
reinsurers to pay recoverables on claims in advance of the 
claim settlement

•  Catastrophe risk is managed through reinsurance models
•  We consider flood risk and other weather-related risk factors 

in insurance risk selection

•  There is an ESG overlay on the Investment Strategy

The Group has effected 
changes to its investment 
policy to:
•  Exclude investment in 

companies that are wholly 
or mainly involved in 
fossil fuel exploration and 
production and thermal 
coal

•  Monitor the overall carbon 

profile and intensity of 
companies and, through its 
Fund Manager, engage with 
the highest emitters, and 
urge the setting of science-
based targets aligned with 
the Paris Agreement

•  Seek opportunities to invest 
in areas that are leading the 
transition to a low carbon 
economy, where these also 
meet robust investment 
criteria

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Principal risks

72

73

Operational risk
The risk of loss arising from inadequate or failed internal processes, people and systems,  
or from external events.

Risk detail

Key mitigants

Change from last year

Risk detail

Key mitigants

•  A defined IT Strategy is in place
•  Systems monitoring is in place together  
with regular systems and data backups

•  A strategic systems programme is underway  

to deliver improved systems, processes and data

•  Business recovery plans are in place for all critical systems 

and are tested according to risk appetite

This level of risk remains 
stable, as the Group 
continues to invest in IT 
infrastructure to maintain 
and improve future stability.

•  A number of security measures are deployed  

to ensure protected system access

•  Security reviews and assessments are performed  

on an ongoing basis

•  There is ongoing maintenance and monitoring of our systems 

and infrastructure in order to prevent and detect cyber 
security attacks

•  There is an ongoing Information Security training  

and awareness programme

•  We have a clearly articulated Group Strategic  

Programme, identifying areas of priority across the Group

•  We ensure that there is adequate resourcing for change 

projects using internal and external skills where appropriate

•  A Change Board and change governance processes  

are in place and operate on an ongoing basis

•  The GMB undertakes close monitoring and oversight  

of the delivery of the strategic initiatives and key  
Group change programmes

Cyber risk remains a constantly 
evolving threat, with malicious 
threat attackers continuing  
to seek to exploit Covid-19 
related business disruption 
including a more hybrid 
approach to working.  
Employee awareness and 
vigilance is therefore highly 
important at this time, especially 
with the unfolding conflict  
in Ukraine, which is continuing 
to be proactively managed. 

The level of this risk has not 
materially changed. There 
continues to be a significant 
volume of change within the 
business, which is monitored 
closely, relating to both IT 
systems and to meet the ever 
changing regulatory landscape. 

Appropriate strengthening of 
expertise has continued in the 
year to reflect and meet this 
volume of change.

Systems risk
The risk of inadequate, 
ageing or unsupported 
systems and infrastructure 
and system failure 
preventing processing 
efficiency. Systems  
are critical to enable  
us to provide excellent 
service to our customers.

Cyber risk
The risk of criminal or 
unauthorised use of electronic 
information, either belonging  
to the Group or its 
stakeholders, for example 
customers, employees etc. 
Cyber security threats from 
malicious parties continue  
to increase in both number  
and sophistication across  
all industries.

Change risk
The risk of failing to manage  
the change needed to 
transform the business.  
A number of strategic initiatives 
are underway under three 
themes, Support and protect, 
Innovate and grow and 
Transform and thrive. These 
include a transformation  
of our core system and key 
processes, which will deliver 
significant change for the 
Company over the next few 
years. There are a number 
of material risks associated 
with major transformation, 
not only on the risks to project 
delivery itself, but the potential 
disruption to business as usual, 
or delays to planned benefits.

Operational resilience
The risk that the Group 
does not prevent, respond 
to, recover and learn from 
operational disruptions. 
The Group provides a wide 
range of services to a diverse 
customer base and has  
a reputation for delivering 
excellent service. Therefore, 
we seek to minimise the 
potential for any such 
disruption that would impact 
on the service provided  
to our customers.

Data management and 
governance
The risk that the 
confidentiality, integrity  
and/or availability of data 
held across the Group  
is compromised, or data 
is misused. The Group 
holds significant amounts 
of customer and financial 
data and there could be 
significant implications if this 
is compromised or is found  
to be inaccurate. 

• A recovery and resilience framework is in place aligned  

to the delivery of customer services

• Recovery exercises including IT systems are regularly 
performed across the Company with actions identified 
addressed within an agreed timescale

• All suppliers are subject to ongoing due diligence
• There is ongoing maintenance and monitoring of our systems 

and infrastructure in order to prevent and detect issues

Change from last year

Operational Resilience 
continues to have been 
successfully tested during 
the year, with the continued 
need to meet the needs of 
our customers, alongside 
working in a new hybrid 
environment. Focus in 2021, 
and into 2022, remains 
on meeting the enhanced 
Regulatory requirements 
around Resilience.

• A Group Data Governance and Management Committee  

is in place

• Group Data Governance and Group Data Management  

and Information Security Policies are in place

• A Group Data Optimisation Programme is in place which  

is responsible for ensuring the delivery of the data strategy 
and all aspects relating to the governance, management, 
use and control of the Group’s data in line with regulatory 
requirements

Enhancements continue  
to be made to the governance, 
management, use and control 
of data, in order to meet the 
evolving requirements.  
It continues to be monitored  
and managed within the context 
of major change programmes. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Strategic Report – Principal risks

74

75

Regulatory and conduct risk
The risk of regulatory sanction, operational disruption or reputational damage  
from non-compliance with legal and regulatory requirements or the risk that  
Ecclesiastical’s behaviour may result in poor outcomes for the customer.

Reputation risk
The risk that our actions lead to reputational damage in the eyes of customers,  
brokers or other key stakeholders 

Risk detail

Key mitigants

Change from last year

Risk detail

Key mitigants

Regulatory risk
The risk of regulatory 
sanction, operational 
disruption or reputational 
damage from non-compliance 
with legal and regulatory 
requirements. We operate  
in a highly regulated 
environment which  
is experiencing a period  
of significant change.

Conduct risk
The risk of unfair outcomes 
arising from the Group’s 
conduct in the relationship 
with customers, or in 
performing our duties and 
obligations to our customers.
We place customers  
at the centre of the business, 
aiming to treat them 
fairly and ethically, while 
safeguarding the interests  
of all other key stakeholders.

• We undertake close monitoring of regulatory developments 
and use dedicated project teams, supported by in-house  
and external legal experts, to ensure appropriate actions are 
taken to achieve compliance

• An ongoing compliance monitoring programme is in place 

across all our SBUs

• Regular reporting to the Board of regulatory compliance 

issues and key developments is undertaken

There continues to be a significant 
volume of regulatory change. 
We remain focused on the 
management of regulatory change 
and therefore the overall risk level 
is unchanged. We also remain 
vigilant with our financial crime/
sanction controls in response  
to the unfolding conflict in Ukraine.

• There is ongoing staff training to ensure that customer 
outcomes are fully considered in all business decisions
• Customer charters have been implemented in all SBUs
• Conduct Risk Reporting to relevant governing bodies  

is undertaken on a regular basis

• Customer and conduct measures are used to assess 

remuneration

The probability of such risks 
crystallising have increased 
due to the on-going Covid-19 
pandemic. However, we 
remain committed to placing 
customers at the centre of 
our practices and decision 
making, demonstrated by 
our wide-ranging industry 
awards and customer 
satisfaction scores. Overall 
the level of this risk is 
unchanged from last year.

Brand and reputation 
risk
The Group aims to be the most 
trusted specialist insurer and, 
as a consequence, this brings 
with it high expectations  
from all of our stakeholders, 
be they consumers, regulators 
or the wider industry. 

Whilst we aim to consistently 
meet and, where possible, 
exceed these expectations, 
increasing consumer 
awareness and increased 
regulatory scrutiny across  
the sector exposes the Group 
to an increased risk  
of reputational damage should 
we fail to meet them, for 
example as a consequence  
of poor business practices  
and behaviours. 

•  There is ongoing training of core customer-facing staff  
to ensure high skill levels in handling sensitive claims

•  We adopt a values led approach to ensure  

customer-centric outcomes

•  There is a dedicated Marketing and PR function  

responsible for the implementation of the marketing  
and communication strategy

•  Ongoing monitoring of various media is in place to ensure 

appropriate responses

Change from last year

Maintaining a positive 
reputation is critical  
to the Group’s vision  
of being the most trusted  
and ethical specialist 
financial services group. 

Risks to our brand and 
reputation are inherently 
high in an increasingly 
interconnected environment, 
with the risks of external 
threats such as cyber 
security attacks, and viral 
campaigns through social 
media always present. 

The external environment 
continues to drive a high 
inherent probability of 
reputational issues across  
all financial services 
companies. We continue 
to focus on serving our 
customers and ensuring 
fair treatment and clear 
communication, and are 
proud of the volume  
of Industry Awards  
we continue to win. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Principal risks

76

77

Section Two

Strategic Report

Responsible Business Report highlights 

Overview 

Socially-positive 

Environmentally-positive 

80

82

83

85

Longer-term viability statement
It is fundamental to the Group’s longer-
term strategy that the Directors manage 
and monitor risk taking into account all key 
risks the Group faces, including longer-term 
insurance risks, so that it can continue to meet 
its obligations to policyholders. The Group 
is also subject to extensive regulation and 
supervision, including Solvency II. Against 
this background, the Directors have assessed 
the prospects of the Group in accordance 
with Provision 31 of the 2018 UK Corporate 
Governance Code. The assessment of the 
Group’s prospects by the Directors covers 
the three years to 2024 and is underpinned 
by management’s 2022-24 business plans. 
In making its assessment the Directors 
considered:

- The Group’s current position and prospects, 
risk appetite, and the potential impact of the 
principal risks and how these are managed;
- The Group’s long-term business plans and 
strategy, and the costs associated with  
its delivery;

- The Group’s current capital, liquidity and 
solvency position and projections; and
- The political, economic and regulatory 
environment, including uncertainties  
on the geopolitical outlook, which have been 
heightened following the recent conflict 
in Ukraine, market volatility, inflation, the 
Covid-19 pandemic and the impact on supply 
chain of the UK’s exit from the EU.

While the Directors have no reason to 
believe the Group will not be viable over a 
longer period, a three-year outlook period 
has been selected. Given the rate of change 
in the markets in which the Group operates, 
three years provides an appropriate balance 
between the period of outlook and degree of 
clarity over specific, foreseeable risk events 
that could impact on the viability of the Group. 
The Directors will continue to monitor and 
consider the suitability of this period.

The Group uses varying stress scenarios 
with reference to the principal risks, with the 
principal risks documented on pages 68  
to 75. Scenarios are designed to be severe, 
but plausible, and assess the impact of certain 
events on the Group’s profitability and capital 
strength. Reverse stress testing is also used  
to assess what could make the Group’s 
business model unviable. The outcome of 
testing was discussed by the Board during the 

year and consideration was given  
to the current environment and the impact  
of Covid-19 on the Group’s viability.

Risks arising from the Ukraine conflict,  
in particular investment market volatility and 
supply chain/inflationary pressures, have  
been considered. Scenario testing showed that, 
at this stage, there is no perceived material  
risk to the Group’s viability resulting from  
the conflict.

The solvency position of the Group has been 
projected as part of the Own Risk and Solvency 
Assessment (ORSA), which is a private, 
internal, forward-looking assessment of own 
risk, required as part of the Solvency II regime. 
The forward-looking emphasis of the ORSA 
ensures that business strategy and plans  
are formulated with full recognition of the risk 
profile and future capital needs. 

Analysis confirms that the Group has 
sufficient capital resources to cover its capital 
requirements and is operationally resilient. 
The impact of Covid-19 on the Group has been 
subject to continual monitoring with additional 
focus across Committees and at Board level.

The Directors have also considered the 
Group’s ability to service its preference share 
and subordinated debt borrowing and the 
expectations of its ultimate charitable owner, 
Benefact Trust Limited. The Group has fixed 
annual dividend payments of £9.2m in respect 
of its non-cumulative irredeemable preference 
shares and quarterly interest payments  
in respect of its 6.3144% €30m subordinated 
debt. The Group makes regular grants to its 
ultimate charitable owner, Benefact Trust 
Limited. There is a regular cycle of discussion 
with Benefact Trust Limited to determine 
the appropriate level of grants, in which the 
Group’s capital position and future business 
needs are taken into account. 

Confirmation of viability
Based on the Group’s strong capital position, 
the strong risk management framework in 
place and the Group’s resilience to the variety 
of adverse circumstances as demonstrated in 
the results of the stress testing and potential 
mitigating actions, the Directors confirm that 
they have a reasonable expectation that the 
Group will continue in operation and be able  
to meet its liabilities over the three year period 
of the viability assessment.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section Two 
 
 
 
 
 
 
 
 
78

79

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Trusted for our  
specialist protection 

For more than 135 years, we’ve been trusted  
to protect some of the country’s most iconic buildings 
and places. We’ve worked hard to earn that trust and 
work even harder to keep it. That means constantly 
honing our specialist knowledge and coming up with 
innovative new ways to protect our customers’ assets.

Two of the most serious and common 
risks to properties are fire and escape  
of water. In 2020, 25% of all the property 
claims we handled were for water 
damage. And according to Home Office 
figures for 2019/20, nearly 11,900 
property fires were caused by electrical 
systems or specific appliance failures.

Soon after launching the new solution  
at Kenwood House in London a flood 
was averted. Sensors identified water 
ingress in the staff room, an instant alert 
meant that the leak could be located  
and rectified before it could cause 
damage to the building or the priceless 
artworks in the room below.

To help combat this, we’ve joined forces 
with property performance specialists 
Shepherd to create an innovative, 
technology-based solution called 
Ecclesiastical Smart Properties.  
This software-based, wireless sensor 
system works by detecting abnormal 
changes in the property – sudden spikes 
in temperature or moisture levels  
– and sends a real-time alert via email, 
SMS or phone, so early preventative 
action can be taken. 

One of the first insurers to offer this new 
way of managing risk, Ecclesiastical 
Smart Properties was awarded Digital 
Insurance Innovation of the Year 2021  
at the British Insurance Awards.  
We were also delighted to have picked 
up many other awards last year 
including Commercial Lines Broker  
of the Year at the National Insurance 
Awards and Best Ethical Investment 
Provider at the 2021 Investment Life  
& Pensions Moneyfacts Awards. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
Strategic Report – Responsible Business Report

80

81

Responsible Business Report 
highlights

Socially-positive

74% 

suppliers paid  
within 30 days

£2.5m 

to charity direct; 
£23.5m from the 
Group overall

Award-winning 
across the Group including  
Best Ethical Investment 
Provider for thirteen 
consecutive years

Signatory to the 
ABI’s Making 
Flexible Work 
Charter

Top 4

Corporate Giver – 
according to the DSC’s 
2021/22 Guide to UK 
Company Giving

2 Star Company

demonstrating outstanding 
levels of employee 
engagement – judged  
by Best Companies

100%

sign-up to employee 
Code of Conduct

>150

virtual development 
sessions organised 
to keep connected 
despite Covid-19

Environmentally-positive

£250,000

Nearly £250,000 of 
charitable funding for 
climate-related projects

‘Very good’ BREEAM 
sustainability standard 
achieved for new build 
head office

1.5˚ potential 
temperature 
– Group business 
fund alignment with 
the Sustainable 
Development 
Scenario compared 
to 3.6 degree 
benchmark

> 1,600

desktop surveys 
completed in the 
UK which reduced 
environmental impact

ClimateWise

member  
of voluntary  
industry  
initiative 

Net 
Zero 

0.23 tonnes
carbon footprint;  
or 0.23 tonnes  
– carbon intensity  
per employee

commitment by 
2023 for direct 
impact, 2040  
for the Group

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Responsible Business Report

82

83

Overview

Socially-positive 

Our charitable ownership and commitment 
to our customers and communities means 
we have a unique opportunity to create a 
positive social and environmental impact  
in the world.

This means using our unique business 
model to give to charities and communities 
everywhere, reaching out to help our 
customers tackle their climate challenges 
and being a beacon of best practice  
for responsible business. 

An expectation to uphold responsible 
business standards is engrained in what  
we do but it also has formal governance  
in place which includes Board visibility  
and responsibility for overarching strategy; 
a senior-level steering group providing 
leadership; and local business ownership 
of activity.

Independent assessment and accreditation 
continues to be important – it ensures  
we challenge ourselves and live  
up to the highest standards. We continue  
to hold standards including Living Wage, 
Women in Finance and the Fairer Finance 
Gold Ribbon and we are a voluntary 
member of ClimateWise and the ABI’s 
Making Flexible Work Charter. Our ethical 
investment business EdenTree maintains 
a number of memberships including the 
UK Sustainable Investment and Finance 
Association, UN Principles for Responsible 
Investment and the Institutional Investors 
Group on Climate Change. 

In particular, in 2021, we continued  
to support our colleagues, customers  
and communities through difficult times  
and developed our climate strategy.  
Read on to find out more. 

Charitable giving
Social impact is central to the purpose  
of the Group. Its unique business model enables  
it to give millions of pounds to hundreds  
of charities every year. 2021 was another year 
of sustained giving affirmed by a fourth-place 
ranking in the Directory of Social Change’s  
Guide to UK Company Giving. 

The Group distributed £2.5m in its own right, 
primarily through its Movement for Good awards 
which give £1m to charities in a combination  
of small donations to a huge diversity  
of causes and more targeted large grants.  
In 2021 the campaign was developed to directly 
involve employees from all over the Group  
in ‘giving panels’ to find the charities closest  
to communities the Group supports. 

Around the Group business giving programmes 
continued to make a significant impact. In Canada 
the now well-established Community Impact 
Grants gave CAN$250,000 to 12 charitable 
organisations across Canada and in December  
it released a further CAN$250,000 to support 
89 charities continuing to help their communities 
during the pandemic. In Australia the Community 
Education Programme continues to equip 
Australians under the age of 25 with the tools 
to achieve a higher quality of life. Ansvar UK 
launched funds to promote healthy lifestyles  
to children and young adults. EdenTree’s 
community fund supports small, innovative 
organisations that are having a remarkable 
impact working with marginalised people.  
Our Irish business provides a wide range  
of support to Jigsaw, the national centre  
for youth mental health. 

Employee engagement  
and wellbeing
Support for employees was paramount 
throughout 2021 as we all battled the ongoing 
challenging circumstances. The Group continued 
to take a supportive and pragmatic approach, 
using flexibility and technology to enable our 
people to work at their best, ensuring  
we continued to deliver for customers  
and partners. 

We improved our wellbeing offer even further 
with the launch of an app which 25%  
of employees signed-up to and we made the 
process for counselling referral much easier. 
Despite the challenging working restrictions  
we grasped the opportunity to launch Group-
wide future flexible working principles and 
became a signatory to the ABI’s Making Flexible 
Work Charter. As we were able to move back  
to an effective balance of office working  
we invested in fantastic office spaces to support 
flexible working in the short and long term.  
2021 marked the opening of the Group’s new 
head office in Gloucester. The building is built 
to high sustainability standard BREEAM and 
designed with flexibility and wellbeing in mind 
with FitWel. 

It was particularly heartening to receive external 
recognition of the Group’s levels of engagement 
– in the first year of participation in the Best 
Companies assessment the Group was awarded 
a 2 star accreditation demonstrating ‘outstanding’ 
levels of employee engagement, with many 
teams being recognised at the highest 3 star 
level, or ‘world class.’ Employees feel particularly 
positive, and the results score above benchmark, 
on some key topics including running the 
organisation on strong values and principles  
and making a positive difference in the world.  
In a year that brought personal challenges for all 
of us, and in which we developed our approach 
to flexible working, we also exceeded benchmark 
on feeling supported by our managers and 
finding a positive working balance.

The Group continued to keep focused on its 
approach to diversity and inclusion. During the 
year a campaign to improve the quality and 
quantity of data was launched, policies and tone 
of voice were reviewed resulting in the launch 
of a new campaign ‘we all belong’. The Group 
continued to be a founding and supportive 
signatory to the Women in Finance Charter  
and published gender pay reporting.

Despite the ongoing pandemic we continued 
to invest in our people, ensuring their ongoing 
personal growth and professional development. 
We ensured employees completed regulatory 
training across the Group, renewed our  

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Responsible Business Report

84

85

UK General Insurance Corporate Chartered 
Status with the CII and supported leaders 
through an in-house programme  
and sponsorship of several senior leaders 
through Windsor Leadership Programmes  
and with Cranfield University. 

We also ran over 150 virtual learning sessions  
to colleagues across our UK and Ireland 
businesses, provided tools for managers  
to develop and supported a large number 
of colleagues with professional qualification 
programmes, using our apprenticeship levy 
scheme where appropriate. 

We developed and agreed Group-wide  
values and a refreshed culture model which  
was launched internally alongside our new 
Group Brand.

Customers and partners 
The Group showed the same level of care 
and commitment to supporting customers 
and partners. We launched mental health 
and wellbeing training for our UK brokers and 
continued to develop fundraising tools to help 
charities sustain their activities. Our dedicated 
fundraising site was visited by over 12,000 users 
and over 750 charities attended a webinar jointly 
organised with the Directory of Social Change  
to network, ask questions and hear the latest 
from a range of fundraising experts. 

Key employee statistics 

Gender by level

Group Management Board 
Senior Leader 
Manager 
Team Member 
Grand Total 

Gender pay gap

Male 

5 
67 
255 
452 
779 

2021 

Fixed pay gap mean/median 
Bonus pay gap mean/median 

27.7%/20.4% 
51.2%/32.9%  

We believe we’re doing the right things, but 
it’s particularly encouraging when the Group 
receives external awards and recognition.  
The list of awards for 2021 includes Top 
Employer for Young People for the 9th time 
(Canada); top ranking for the 13th time for trust, 
happiness, transparency and complaint handling 
in the Fairer Finance ratings (UK direct insurance); 
digital innovation at the British Insurance Awards 
(UK general insurance); growth company of the 
year at the National Insurance Awards (broking); 
best specialist lines producer (Ireland); and Best 
Ethical Investment Provider for 13 consecutive 
years (investment). 

We recognise the social impact and influence  
our business can have on the partners and 
suppliers we work with. To ensure we uphold  
the highest standards regarding human rights, 
anti-corruption and anti-bribery we have  
a range of measures including robust risk 
management, employee Code of Conduct  
and employee regulatory training on topics  
such as data protection and whistleblowing. 
100% of employees attested to our Code  
of Conduct in 2021. 

We continue to submit our Modern Slavery 
Act declaration and we reported a continuing 
improvement in the number of suppliers paid 
within 30 days to 74% under the Payment 
Practices and Performance Reporting  
(2020: 72%).

Female 

3 
28 
182 
643 
856 

2020 

28.0%/21.1% 
49.3%/28.9% 

Total

8
95
437
1068
1635

2019

27.6%/22.4%
50.1%/32.4%

Ethnicity

White 

1250 

Prefer not to say 

312 

BME 

73 

Total

1635

Environmentally-positive 

Climate change is one of the biggest challenges 
facing our colleagues, customers, partners  
and communities. The Group is committed  
to grasping its opportunity to make a positive 
environmental impact and support customers 
and communities to tackle their climate 
challenges too. 

That’s why the Group continues to be  
a voluntary member of ClimateWise,  
a group of organisations ambitious about 
climate action. The Group reports annually 

to ClimateWise’s framework which is in line 
with the recommendations of the Task Force 
on Climate-related Financial Disclosures 
(TCFD). The Group will continue to integrate 
the assessment of climate-related risks and 
opportunities into governance, strategy, risk 
management and reporting to both improve  
its response and enhance its disclosures  
in line with guidance and best practice from 
TCFD. We have made significant progress  
in 2021, which is summarised over the  
following sections. 

7. Enhance  
reporting

!

6. Customer/client 
awareness

1. Be accountable

i n s urer

n

    As a

Our Group
Climate 
Response

A

s

a

n

a

dvisor

r

o

t

s

e
v
n
 i
n

   As a

2. Strategies and 
investments

3. Managing  
climate risk

5. Informing public 
policy

4. Our own impact

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
 
 
 
 
 
 
 
 
 
 
Strategic Report – Responsible Business Report

86

87

1. Be accountable – governance
The Group ensures climate risk has strong 
governance and oversight in a number of ways:

–  Climate risk is a key consideration of the 

Group’s enterprise-wide risk management 
framework overseen by the Group Risk 
Committee (GRC). 

–  Board engagement and oversight was 

strengthened in 2021 – an extraordinary 
climate strategy session was held to discuss 
the Group’s position and future ambitions.  
A Non-Executive Director has been appointed 
to be accountable for climate. Progress  
against our climate strategy and plans will  
be reported to the Board regularly. 

–  The Board has delegated responsibility for 

oversight of risk arising from climate change 
to the GRC. Updates are provided through 
quarterly reports and ad-hoc updates 
provided to GRC meetings.

–  Climate risk is assessed and managed 

through the Group risk function, reinsurance 
management and investment advisory panel. 
–  Under the Senior Managers and Certification 

Regime (SMCR) climate responsibilities 
have been included in Statements 
of Responsibilities for specific senior 
management functions, including all 3 Lines 
of Defence. Leaders of all Strategic Business 

Units in the Group have been assigned 
responsibility for managing the risks arising  
in their businesses. 

–  A requirement for businesses to consider  
the impact of climate change has been 
introduced into key risk policies of the Group 
that are owned by the Board.

–  A climate strategy response group was 

established in 2021 to strengthen existing 
governance. It is senior management-led  
and includes representation from risk, 
investment, strategy, general insurance, 
Broking and Advisory, communications, risk  
and responsible business. This group reports 
to the GMB and co-ordinates communication 
of climate-related issues to management 
across the Group and to the Board.  
This includes external information and sharing 
of specific issues that have been identified 
and are being managed at Group or individual 
business levels. Relevant information is also 
shared through existing governance bodies 
such as Centres of Excellence in the  
insurance businesses.

–  Group level risk management committees, 

the Insurance Risk Committee and the Market 
& Investment Risk Committee have been 
assigned responsibility for oversight of the 
assessment and management of climate 
related risks arising in those areas.

Working Groups

Strategic  
Business Units

Climate Response Strategy Group

General  
Management Board

Main Board

Senior management-led 
representation:

– Risk
– Investment
– Strategy
– General insurance
– Broking and Advisory
– Communications
– Risk
– Responsible business

2. Strategies and investments
Climate risk and opportunity continues  
to be integrated into the Group’s core strategy 
for general insurance, investment and advisory 
business. We recognise our responsibility and 
opportunity as an insurer, investor and advisor. 

–  In 2021 the Group set out a new five-year 

strategy which includes a key focus  
on climate response and action. 

–  A strategic and emerging risk process  
is core to assessing and monitoring  
the impact, probability and exposure  
of the Group to climate risk. 

–  The key risks to the Group’s general 

insurance businesses arise from the physical 
risk of the impact of increased frequency and 
severity of weather-related events, changes 
in precipitation and rises in sea levels and 
temperature variations. These risks primarily 
relate to property insurance based on the 
location of insured risks.  
The Group also recognises the likely  
impacts on its customers and seeks  
to support them to address these through 
underwriting, claims management and  
risk management activities. 

–  The Group uses a range of data and tools  
to assess its insurance risk and is seeking  
to develop external partnerships  
to strengthen its approach. 

–  The Group’s main exposure to transition 

risks is on the value of its investment assets 
through the impact of changes to a low 
carbon economy on investee companies.
–  The Group adopted a new responsible and 
sustainable investment policy in February 
2021 strengthening its climate response.  
The new policy evolves exclusion criteria  
by fully removing fossil fuel exploration  
and production and thermal coal, so widening 
the previous policy of excluding material 
exposure to oil sands and Arctic drilling.  
The policy also features a new ESG portfolio 
risk overlay approach, which will consider 
how companies manage their ESG risks  
as a factor in investment decisions and  
put more pressure on companies the Group 
invests in to improve. The new policy has 
already resulted in divestment in some  
key areas. 

–  The Group has invested in a tool  

to complete carbon footprinting of equity  
and corporate bond assets. 80% of funds 
under management were included in an 
internal footprint review in 2021 and this 
analysis will continue to be developed. 
–  The Group has identified opportunities  

to benefit from the effects of climate change 
including greater resource efficiency, using 
expertise to help customers and directing 
investment assets towards areas that will 
profit from changes made in transition  
to a low carbon economy.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationStrategic Report – Responsible Business Report

88

89

3. Managing climate risk
The Group has continued to embed the 
identification, assessment, management, 
monitoring and reporting of climate-related 
risks within the Risk Management Framework.

–  The Group’s emerging risk process  

continues to place climate risk at the heart  
of our consideration of risk.

–  Scenario analysis is a key tool in this process 
and it is being developed to consider short- 
(up to 5 years), medium- (5 to 20 years) 
and longer-term (20 to 30 years) time 
horizons. Key scenarios used by the Group 
in identifying and assessing climate risks are 
an ‘early action’ scenario, whereby alignment 
with the Paris agreement to limit warming 
to no more than two degrees is successful, 
in which transition risks are most prominent 
and a ‘no further action’ scenario, where 
warming continues to increase and physical 
risks become much greater.

–  The Group held risk identification workshops 
across all of its territories to consider the 
impact of climate change on the operations 
of the local businesses. These have resulted 
in climate change risk registers owned by 
business management. These workshops 
considered weather-related perils relevant 
for each territory in which the Group 
operates, based on scientific projections  
of the impact of the climate change scenarios, 
and identified the main impacts of these  
on the local underwriting portfolios.

–  Local insurance underwriting businesses 
have considered how these impacts can  
be more integrated into underwriting, claims 
and risk management strategies. 

–  The Group’s investment manager EdenTree 
engages at portfolio, issuer and individual 
holding levels with oversight from  
the investment advisory panel. 

–  In 2021 the Group continued to develop 

approaches to help customers strategically 
manage their climate risk. For example:
•  brokers continue to provide advice and 

cover in a range of climate-related areas 
including cover for woodlands and 
renewable energy; and 

•  the UK general insurance business 

launched a partnership with a third party  
to more intelligently manage properties  
to reduce risk and climate impact.  
The Ecclesiastical Smart Properties 
initiative is in its trial phase but we plan  
to roll it out widely.

4. Metrics and targets  
– our own impact
In 2021 the Group set out its net zero ambitions:

–  Achieve net zero for direct impact  

(scopes 1+2) by 2023;

–  Eliminate historic emissions (scopes 1+2)  

by 2030; and

–  Net zero for the Group for all scopes  

by 2040.

The Group recognises that these ambitions 
are long-term, challenging and will stimulate 
accelerated climate action. 

Methodology 

We have reported on all emission sources 
required under the Companies (Directors’ 
Report) and Limited Liability Partnerships 
(Energy and Carbon Report) Regulations 
2018. Our reporting year runs from January 
to December 2021. The emissions reporting 
boundary is defined as all entities and 
facilities either owned or under operational 
control of Ecclesiastical Insurance Office, 
therefore emissions relating to our premises 
and associated travel by staff based at those 
premises. It includes data covering 72%  
of our Group by headcount. We continue  
to improve the coverage and quality of data 
which informs our report.  

We have recalculated 2020 emissions and are 
restating these figures. These include a broader 
scope of operations and improved quantification 
methodology. Scope 1 Emissions from 
fluorinated gas losses and fuel combustion in 
premises / vehicles, Scope 2 Emissions from 
electricity and cooling in premises, and Scope 
3 Emissions associated with business travel, 
waste and water use have been calculated 
using UK government greenhouse gas 
reporting emission factors 2021 (Department 
for Environment, Food and Rural Affairs), and 
independently verified according to ISO – 
14064-3:2019 Specifications with Guidance for 
the Validation and Verification of Greenhouse 
Gas Statements.

In line with the Streamlined Energy and Carbon Reports the Group’s 2021 carbon footprint  
is detailed here including carbon intensity:

Scope 1

Scope 2 – Location 
Based

Scope 2 – Market Based 
(not previously reported 
in 2020)

Scope 3

TOTAL

UK

97 (378)

383 (414)

68

172 (273)

338 (1,093)

1  Assuming Scope 2 Market Based
2  Total using Scope 2 Location Based

2021 (2020)

Non-UK 

6 (40)

97 (106)

97

22 (46)

126 (192)

Total

104 (446)

480 (521)

165

195 (319)

4631 (1,2862) 

Total energy use 59,585,679kwH of which 48,147,143kwH is UK and 11,438,536kwH non-UK.
tCO2e/employee: 0.23 (0.54)

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
 
 
 
 
Strategic Report – Responsible Business Report

90

91

7. Enhance reporting
The Group’s climate-related communication 
and reporting will continue to evolve in line with 
TCFD requirements. References or commentary 
on climate-related issues relevant to TCFD  
are included in a number of different areas  
in this Annual Report & Accounts highlighted  
in each section of the report above. 

Topic

Governance

Strategy

Disclosure area

See also…

Disclose the organisation’s governance 
around climate-related risks  
and opportunities

–  Risk Management Report

•  More in-depth description  

of the Group’s governance of risk

Disclose the actual and potential  
impacts of climate-related risks  
and opportunities on the organisation’s 
businesses, strategy and  
financial planning

–  Global trends in financial services

•  Global context and how this shapes 

our strategy
–  Strategy in Action

•  Consideration of climate risk  

in the Group’s strategy
–  Chief Executive’s Report

•  Statement of commitment to tackling 

climate challenge

Risk Management

Disclose how the organisation identifies, 
assesses and manages climate-related 
risks

-  Risk Management Report

•  More detailed description of the 

Group’s management of climate risk

Metrics and Targets

Disclose the metrics and targets used  
to assess and manage relevant  
climate-related risks and opportunities

-  Group Remuneration Report

•  Commentary on the inclusion  

of Environmental and Social targets 
in bonus schemes

Commentary 

The Group’s carbon footprint continues  
to develop for a number of reasons:

-  It covers the entire Group’s operations,  
either using actual or extrapolated data 
(average data is only used for 28%  
of operations by headcount). 

-  It continues to be impacted by the Covid-19 
period which has influenced reduced office 
attendance and business travel. Some  
of this influence we expect to stay with  
us for the long term – increased use  
of meeting technologies and more flexible 
work – but we also expect office occupancy 
to increase, but not to pre-Covid levels.  
To grasp the learnings from the pandemic 
period the Group launched future flexible 
working principles supported by investment 
in technology and fantastic office 
environments. The environmental benefits 
will be monitored over the long term. 
-  A dedicated desktop surveying service 

has been established by the UK general 
insurance business. Its target is to reduce site 
visits by more than 3,000 by 2022 to both 
improve customer experience and reduce 
environmental impact. In 2021 over 1,600 
desk top surveys were completed.

-  A Scope 3 initial footprint was completed 

and assured by a third party in 2021 for the 
first time. Although this year’s reporting only 
includes business travel, waste and water  
in Scope 3, the initial exercise has given  
a greater understanding of Scope 3 impacts 
and will continue to broaden our reporting  
in the future. 

-  The carbon intensity of the Group’s 

investments continues to be a key part  
of its footprint and opportunity for influence. 
The Group’s investments were 61.3% less 
emission intense than its benchmark  
in 2020 and, based on current targets,  
the fund is expected to align to the 
Sustainable Development Scenario  
of 1.5 degrees by 2050 compared  
to 3.6 degrees for the benchmark. 
-  2021 was a transitional year in terms  
of head office premises. The footprint 
includes occupancy of both an old and  
a new head office which was officially 

opened in late January. The new head office 
has been designed to a ‘very good’ BREEAM 
sustainability standard featuring heat 
recycling, solar panels and electric charging 
points. These enhancements have had  
a significant impact on our footprint  
already and will make further contributions  
to our direct reduction plans in the future. 

5. and 6. Informing public policy 
and customer / client awareness
Improved communication of climate change  
to a wide range of stakeholder groups including 
customers, clients, employees and partners is 
also a key consideration of the Group’s strategy. 

–  Public engagement activity includes 

briefings and publications led by investment 
management business EdenTree which 
continue to have a presence and show 
support for key initiatives such as the 
Global Investor Statement to Governments 
on the Climate Crisis to demonstrate our 
commitment and influence. Topics included 
energy and fossil fuel divestment.
–  Customer and partner engagement  

activities include issuing advice on cold 
weather, storms and floods. The Group  
also researches and promotes climate  
impact for specific customer groups, such  
as the education sector, through webinars 
and guidance. 

–  In 2021 we made significant shifts to direct 
some of our charitable funding towards 
environment and climate-related projects:
•  Our £1m Movement for Good awards 

gave £94,000 to climate-related charities 
including the Transition Network and 
Sheffield Wildlife Trust; and 

•  Our owner Benefact Trust, formerly 

Allchurches Trust, has awarded £150,000 
to Eco Church, a charity which will  
be supporting one of our key customer 
groups, the Church, with advice  
on reducing carbon impact. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationWorkplaces fit for  
a world-class team 

Our stunning new HQ, Benefact House, marks  
an important milestone in our history and 
symbolises our forward-looking approach.  
The office has been designed to support  
a modern, agile and collaborative way of working  
– a way of working we’ve fully embraced.

on wellbeing our office meets FitWel 
standards, a framework which focuses 
on creating a healthy workplace, 
including plants throughout the offices 
to oxygenate the air, natural lighting,  
a variety of work spaces to accommodate 
different needs and healthy options  
at our staff restaurant. The Gloucester 
head office is just the latest example 
of our commitment to invest in great 
workplaces across our Group to enable 
our people to work at their best. 

And our focus on our people is clearly 
paying off. Following our 2021 b-Heard 
survey, we were delighted to be awarded 
Best Companies’ 2 star accreditation 
demonstrating ‘outstanding’ levels 
of employee engagement, with many 
teams recognised at the highest  
3 star or ‘world class’ level.

In October 2018, we signed  
an Agreement for Lease for a new office 
to be built at Gloucester Business Park. 
The new building would be purpose-
built for our needs, providing a flexible 
office space that would accommodate all 
our Gloucester colleagues and provide 
plenty of parking. The offices were 
also designed to BREEAM standards, 
a sustainability assessment which 
looks at the building’s performance and 
environmental factors such as electric 
car charging points and solar panels.

Despite Covid-19 and several lockdowns, 
the development continued with 
only minor disruptions, and the first 
colleagues started working at Benefact 
House in January 2021. Feedback has 
been overwhelmingly positive, with 
praise for the fresh, modern working 
environment and focus on wellbeing. 

The new HQ fits perfectly with our 
Future Working Vision, which recognises 
the importance of flexible working and 
vibrant, social spaces. With an emphasis 

92

93

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout Us – Ecclesiastical at a glance 
 
 
 
 
 
 
 
 
Section Two

Strategic Report – Non-Financial Information Statement

94
94

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

9595

Non-Financial 
Information Statement

Non-financial information 
The Non-Financial Reporting requirements contained in sections 414CA  
and 414CB of the Companies Act 2006 are addressed below:

Non-financial information

Disclosure

Section

Business model

Our business model and information  
on how we do business differently

Key performance indicators 
(KPIs)

Our KPIs set out how we are doing 
against our strategic goal

Principal risks

Our key risks and their management

Our policies

We have a range of policies and guidance 
in place to support the key outcomes 
for our stakeholders. These also 
ensure consistent governance on 
environmental matters, our employees, 
social matters, human rights and  
anti-bribery and corruption

Strategic report  
– Our Business model 
and strategy

Strategic report  
– Key performance 
indicators

Strategic report  
– Principal risks

See below

Pages

40

50

68

Our key policies / statements  
of intent
Environmental matters

•  We are committed to running the business  

in a sustainable way to tackle climate change 
and encourage others to do more. 

•  We assess performance against ClimateWise 

reporting which is aligned to Taskforce  
on Climate-related Financial Disclosures 
(TFCD) reporting.

•  We aim to reduce our direct impact  
on the environment and seek to use 
renewable sources of energy.

•  Other information on environmental  

matters is included within the Responsible 
Business Report. 

Employees

•  Our Code of Conduct policy is centred  

on ‘Doing the right thing’ and sets  
the standards of conduct and behaviour 
expected from employees.

•  The Board aims to ensure it is comprised  

of persons who are fit and proper to direct  
the business. The Board’s diversity policy  
sets out the approach to diversity in the 
leadership population. 

•  Other information on our commitments  

to supporting diversity and development  
is included in the socially-positive section  
of the Responsible Business Report.  
Also included within the Corporate 
Governance report is information about  
the composition and diversity of the Board.

Social matters

•  We were founded over 135 years ago  

with a charitable purpose and this remains 
what motivates us today. We believe business 
has a social responsibility and should give 
more to support charities and communities. 
More information about how we support  
our communities can be found in the 
Responsible Business Report. The Group  
does not make political donations.

•  Our tax strategy supports our Group strategy 
and the ethical way we do business. We are 
committed to managing all aspects of tax 
transparently and in accordance with current 
legislation. We work to achieve the spirit  
of legislation and not just the letter of the law 
in each tax jurisdiction. Our tax strategy  
is available on www.ecclesiastical.com

Human rights, anti-bribery and anti-corruption

•  The Board is committed to operating with 

honesty and integrity in all of our business 
activities and promoting an anti-bribery  
and corruption culture across the Group. 

•  We have established and uphold good 
practices regarding human rights, anti-
corruption and anti-bribery through a range  
of measures including robust risk 
management, employee Code of Conduct  
and employee training on topics such  
as data protection, whistleblowing  
and vulnerable customers.

•  We comply with relevant legislation 

concerning our supply chain – the Modern 
Slavery Act 2015 and the Payment Practices 
and Performance regulations – to drive good 
practice and transparency. 

•  The Responsible Business Report contains 

more information including our commitment 
to putting customers and partners at the 
heart of everything we do, focusing on good 
governance, service and support.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Section Two

Strategic Report – Strategic Report approval

96
96

97

Section 172 Statement 

This section of the Strategic Report provides an overview of how the Directors have fulfilled  
their duties to promote the success of the Company and had regard to the matters set out  
in section 172(1) (a) to (f) Companies Act 2006 as detailed below: 

(1)   A director of a company must act in the way he/she considers, in good faith, would be  
most likely to promote the success of the company for the benefit of its members  
as a whole, and in doing so have regard (amongst other matters) to –

  a)   the likely consequences of any decision in the long term;

  b)   the interests of the company’s employees;

  c)   the need to foster the company’s business relationships with suppliers,  

customers and others;

  d)   the impact of the company’s operations on the community and the environment;

  e)   the desirability of the company maintaining a reputation for high standards  

of business conduct, and;

  f)   the need to act fairly as between members of the company.

This also forms the Directors’ statement required under section 414CZA, of the Companies  
Act 2006.

Our stakeholders are identified in the Group Governance Framework, and are at the core  
of all decision making. Key stakeholders are our customers (and clients), employees, 
shareholders and bondholders, regulators, intermediary partners (including brokers  
and other suppliers), and environment and community groups. 

Examples of the way in which the Board has engaged with some of these stakeholder groups 
throughout the year can be found in the Corporate Governance Section of the Annual Report  
and Accounts. 

Strategic Report Approval

The Strategic Report, outlined on pages 12 to 96, incorporates the Chief Executive’s Review,  
the Business Model and Strategy, the Key Performance Indicators, reviews of Financial 
Performance and Position and Risk Management, the Responsible Business Report and  
the Section 172 Statement and, when taken as a whole, is considered by the Directors  
to be fair, balanced and understandable.

By order of the Board

Mark Hews
Group Chief Executive
17 March 2022

‘Our dedicated and 
talented people are 
at the heart of our 
business, driven by 
a desire to support 
our customers 
and united by a 
common purpose 
to contribute to the 
greater good  
of society.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section TwoSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Section Three

Governance

Board of Directors 

Directors’ Report 

Corporate Governance 

100

104

109

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
Section Three

Governance – Board of Directors

100
100

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

101

Board of Directors

Key to membership 
of Group Board Committees

(a) Group Finance and Investment
(b) Group Nominations
(c ) Group Risk 
(d) Group Audit
(e) Group Remuneration

David Henderson  (a) (b) (e)
Chair, Independent Non-Executive Director
David Henderson was appointed to the Board  
in April 2016. David began his career specialising  
in personal tax and UK trusts. He spent ten years  
as a banker with Morgan Grenfell and, following 
that, 11 years in financial services executive 
recruitment with Russell Reynolds Associates.  
He joined the Board of Kleinwort Benson Group plc 
as Personnel Director in 1995. He was appointed 
Chief Executive of Kleinwort Benson Private  
Bank Ltd (now Kleinwort Benson) in June 1997.  
He was Chairman of Kleinwort Benson from  
2004 to 2008 and a Senior Adviser to the Bank  
until 2019. He holds several external  
Non-Executive Directorships.

Denise Cockrem
Group Chief Financial Officer
Denise Cockrem was appointed Group Chief 
Financial Officer on 10 December 2018 and  
joined the EIO Board on 6 September 2019.  
Denise is a Chartered Accountant with significant 
industry experience, predominantly in financial 
services. She spent her early career in corporate 
finance and banking roles for EY, Barclays, RBS and 
Direct Line. She then joined RSA as Group Financial 
Controller, spending 9 years with them in various 
roles culminating in UK & Western Europe Finance 
Director. Denise most recently held the position  
of Chief Financial Officer at Good Energy Group plc, 
an AIM-listed renewable energy company  
who provide 100% renewable electricity and carbon 
neutral gas. Denise was also a Non-Executive 
Director of the Skipton Building Society from 2015 
to 2021. Denise is a Trustee of MacIntyre Academy 
Trust, which provides special schools and specialist 
alternative provision for children and young people.

Mark Hews 
Group Chief Executive
Mark Hews was appointed Group Chief Executive  
in May 2013 and was previously Group Chief 
Financial Officer. He was appointed to the Board  
in June 2009 and appointed to the Board  
of MAPFRE RE in December 2013 and became  
a Trustee of The Windsor Leadership Trust  
in November 2017. He was formerly a Director  
of HSBC Life and Chief Executive of M&S Life.  
Prior to this he was Finance Director at Norwich 
Union Healthcare. He started his financial career  
at Deloitte (formerly Bacon and Woodrow)  
as a consultant and actuary.

S. Jacinta Whyte
Deputy Group Chief Executive
Jacinta Whyte was appointed Deputy Group Chief 
Executive and joined the Board in July 2013 with 
responsibility for the Group’s General Insurance 
business globally. She was also appointed to the 
Ansvar Australia Board during 2013. Jacinta joined 
Ecclesiastical in 2003 as the General Manager 
and Chief Agent of the Group’s Canadian business. 
Having commenced her career as an underwriter 
for RSA in Dublin in 1974, she moved with them 
to Canada in 1988, holding a number of senior 
executive positions in both Ireland and Canada.

Chris Moulder  (b) (c ) (d) 
Senior Independent Non-Executive Director
Chris Moulder was appointed to the Board  
in September 2017. Chris is also a Director of the 
Company’s ultimate parent, Benefact Trust Limited, 
as well as the Insurance Board of Lloyds Banking 
Group and Tokio Marine Kiln. Chris retired in 2017 
after five years at the Bank of England as Director 
of General Insurance at the Prudential Regulation 
Authority. Prior to this he had spent 26 years with 
KPMG as a partner in its Financial Sector practice.

Francois-Xavier Boisseau  (a) (c ) (d)
Independent Non-Executive Director
Francois-Xavier Boisseau was appointed  
to the Board in March 2019. Francois-Xavier  
has more than 30 years’ experience working  
in the insurance industry, 25 years in the UK.  
He was CEO of Insurance Ageas (UK) until 
December 2018. Prior to that Francois-Xavier  
was CEO of Groupama and CEO of GUK Broking 
Services as well as being Non-Executive  
Chairman of Lark, Bollington and Carole Nash. 
Francois-Xavier is also Chairman of IQUW 
Syndicate Managing Agency Ltd.

Rita Bajaj  (a)
Independent Non-Executive Director
Rita was appointed to the Board in July 2021.  
She is a Non-Executive Director, Board, and IGC 
member with over 30 years’ broad investment 
markets experience. Previously, she held senior 
investment positions at Global and UK Asset 
Managers, heading investment teams at Royal 
London and Invesco Perpetual. She was EMEA  
Chief Administrative Officer at custodian, State Street 
and she is also a former FCA regulator.  Currently, 
Rita is a Board and Investment Panel member  
for the London Pension Fund Authority (LPFA),  
Non-Executive Director on Columbia Threadneedle 
OEIC Boards and an Independent Governance 
Member for Hargreaves Lansdown’s workplace  
SIPP Independent Governance Committee.

Sir Stephen Lamport  (c ) (e)
Independent Non-Executive Director
Sir Stephen was appointed to the Board in March 
2020. He is the Vice Lord-Lieutenant of Surrey  
and a Senior Adviser at Sanctuary Counsel.  
He is a Board member of Benefact Trust Limited; 
Vice-President of the Community Foundation  
for Surrey; Chairman of Painshill Park Trust; 
a member of the Court of the St Katharine 
Foundation; and Chairman of the British Red Cross 
UK Solidarity Fund Committee. He is the Deputy 
High Bailiff of Westminster Abbey. Sir Stephen  
was the Receiver General of Westminster Abbey 
from 2008 to 2018, and previously a Group  
Director of the Royal Bank of Scotland for five 
years. He was Deputy Private Secretary  
to The Prince of Wales from 1993, and Private 
Secretary and Treasurer from 1996 to 2002. 
From 1994 to 2002 he was a member of HM 
Diplomatic Service, with overseas postings 
in New York, Tehran and Rome.

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Three

Governance – Board of Directors

102
102

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

103

Key to membership 
of Group Board Committees

(a) Group Finance and Investment
(b) Group Nominations
(c ) Group Risk 
(d) Group Audit
(e) Group Remuneration

Neil Maidment  (c ) (d) (e)
Independent Non-Executive Director
Neil Maidment was appointed to the Board  
in January 2020. Neil is an Independent  
Non-Executive Director at Lloyd’s of London  
and a member of the Council of Christ’s Hospital. 
He has over 35 years’ experience in the insurance 
market. He was previously a Director of Beazley plc 
and was Chief Underwriting Officer of the company 
and Active Underwriter of its Lloyd’s syndicates 
from 2008 to 2018. He was Chairman of the Lloyd’s 
Market Association from 2016 to 2018 and served 
as an elected working member of the Council  
of Lloyd’s during the same period.

Angus Winther  (a) (b) (e)
Independent Non-Executive Director
Angus Winther was appointed to the Board  
in March 2019. Angus co-founded Lexicon Partners, 
a London-based investment banking advisory 
firm, where he specialised in advising clients in the 
insurance and financial services sectors. He was 
closely involved in Lexicon Partners’ leadership 
until it was acquired by Evercore in 2011 and served 
as a senior Adviser at Evercore until October 2016. 
He is currently a Non-Executive Director and 
Chair of the Audit Committee at Trinity Exploration 
& Production plc and a Non-Executive Director 
of Lloyd’s managing agent, Hiscox Syndicates 
Limited. Angus is also Churchwarden of Holy 
Trinity Brompton, Deputy Chair of the Church 
Revitalisation Trust and a trustee of St Mellitus 
College Trust and St Paul’s Theological Centre. 

Andrew McIntyre  (c ) (d)
Independent Non-Executive Director
Andrew McIntyre was appointed to the Board 
in April 2017. Andrew is the Senior Independent 
Director of C. Hoare & Co where he chairs  
the Audit, Risk and Compliance Committee, and  
an independent Non-Executive Director of Lloyds 
Bank Corporate Markets plc and of Target Group 
Limited, where he also chairs the Audit Committees. 
He is a trustee of the Foundling Museum. 
Previously, Andrew was for 28 years a partner  
in EY, and was for nine years Chairman of the  
Board of Southern Housing Group, one of the 
largest housing associations in the UK.  
He was an Independent Non-Executive Director  
of National Bank of Greece S.A. and chaired  
its Audit Committee.

Caroline Taylor resigned as a Director on 8 September 2021. 

Board diversity

Balance of Non-Executive Directors and Executive Directors 
8:3 
Non-Executive Directors : Executive Directors 

8:3

2021 

2020 

Gender Balance
Male : Female 

Length of Tenure
(Chair and Non-Executive Directors)
0 – 3 years 
3 – 6 years 
6 – 9 years 
 10 years + 

Geographical Mix 
United Kingdom 
Rest of Europe 
North America 
Rest of World 

Age 
35 – 45 
45 – 55 
55 – 65 
65 + 

8:3 

8.3

5 
3 
0 
0 

9 
1 
1 
0 

0 
2 
5 
4 

4
3
1
0

9
1
1
0

0
2
7
2

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Section Three

Governance – Directors’ Report

104

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

105

Directors’
Report

The Directors 
submit their Annual 
Report and Accounts 
for Ecclesiastical 
Insurance Office  
plc, together with  
the consolidated 
financial statements 
for the year ended  
31 December 2021.

The Group Chief Executive’s Review, Strategic 
Report and Corporate Governance section  
(this includes Board Governance, the Group 
Finance and Investment Committee Report,  
the Group Nominations Committee Report,  
the Group Risk Committee Report, the Group 
Audit Committee Report, and the Group 
Remuneration Report) are all incorporated  
by reference into this Directors’ Report.

Principal activities
The Group operates principally as a provider  
of general insurance in addition to offering  
a range of financial services, with offices  
in the UK, Ireland, Canada, and Australia.  
A list of the Company’s subsidiary undertakings 
are given in note 35 to the financial statements 
and details of international branches are shown 
in Section Five, Other Information.

Ownership
At the date of this report, the entire issued 
Ordinary share capital of the Company and 
4.35% of the issued 8.625% Non-Cumulative 
Irredeemable Preference Shares of £1 each 
(‘Preference shares’) were owned by Benefact 
Group plc.

Board of Directors
The Directors of the Company during the year 
and up to the date of this report are stated  
on pages 100 to 102.

Caroline Taylor resigned as a Non-Executive 
Director on 8 September 2021. 

Rita Bajaj was appointed as a Non-Executive 
Director on 15 July 2021.

In line with the Financial Reporting Council’s 
(FRC) 2018 UK Corporate Governance Code  
(the Code), the Board has voluntarily chosen  
to comply with the recommended annual  
re-election of Directors. All Directors who have 
served since the last AGM will be proposed for 
re-election at the forthcoming AGM. Rita Bajaj 
will also be recommended for election at the 
forthcoming AGM following recommendation 
from the Group Nominations Committee. 

The Company has made qualifying third- 
party indemnity provisions for the benefit  
of its Directors and Directors of any associated 
company. These were in place throughout  
the year and remain in force at the date  
of this report.

Neither the Directors nor their connected 
persons held any beneficial interest in any 
Ordinary shares of the Company during  
the year ended 31 December 2021. There has 
been no change in this position since the end  
of the financial year and the date of this report.

The following Directors of the Company, and their connected persons, held Preference shares  
in the capital of the Company at 31 December 2021:

Director 

Nature of interest 

Number of Non-Cumulative 
Irredeemable Preference 
Shares held

Mark Hews 
Denise Cockrem 

Connected person 
Connected Person  

75,342
16,000

There have been no changes to their holdings between the end of the financial year and the date 
of this report.

No contract of significance existed during or at the end of the financial year in which a Director 
was or is materially interested.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
 
 
 
 
Section Three

Governance – Directors’ Report

106
106

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

107
107

Dividends
Dividends paid on the Preference shares were 
£9,181,000 (2020: £9,181,000).

The Directors do not recommend a final dividend 
on the Ordinary shares (2020: £nil), and no 
interim dividends were paid in respect of either 
the current or prior year.

Charitable and political donations
Charitable donations made in the year amounted 
to £23.5m (2020: £2.7m).

It is the Company’s policy not to make political 
donations. No political donations were made  
in the year (2020: £nil).

Financial instruments 
Information about the use of financial 
instruments by the Group is given in note 22  
to the financial statements.

Employees
The Group is committed to nurturing
a culture and work environment in which  
all employees can fulfil their potential  
Our Equality and Diversity Standard and 
Guidance sets our expectations for an open  
and inclusive workplace and we place the care 
and wellbeing of our employees at the heart  
of our employment policies.

Information on engaging and involving 
employees is provided on page 115.

Throughout the employee lifecycle from 
recruitment onwards, we carefully consider 
adjustments to our processes and practices  
and look for solutions to remove barriers  
for those employees with disabilities.

When needed, we engage with third-party and 
Occupational Health specialists who provide  
us with expert advice and ensure we are offering 
the best support we can. Through our adjusted 
work approach, we provide an environment  
in which disabled employees can fully 
participate in all opportunities provided by the 
Group from continued employment to training, 
job moves and promotions.

Climate change and environment

Information about the approach to climate 
change and the environment is provided  
in the Responsible Business Report. 

Principal risks and uncertainties

The Directors have carried out a robust 
assessment of the principal risks facing  
the Group including those that threaten 
its business model, future performance, 
solvency and liquidity. The principal risks and 
uncertainties, together with the financial risk 
management objectives and policies of the 
Group are included in the Risk Management 
section of the Strategic Report.

Events after the balance sheet date 

There were no events after the reporting 
period that require disclosure in the Financial 
Statements.

Going concern

The Financial Performance section and Risk 
Management section of the Strategic Report 
provide a review of the Group’s business 
activities and disclose the Group’s principal  
risks and uncertainties, including exposures  
to insurance financial risk, operational and 
strategic risk, and risks associated with Covid-19.

The Group has considerable financial  
resources: financial investments of £883.8m 
of which 90% are liquid (2020: financial 
investments of £820.8m, 92% liquid) and cash 
and cash equivalents of £114.0m (2020: £104.4m). 
Liquid financial investments consist of listed 
equities and open-ended investment companies, 
government bonds and listed debt. In February 
2021, the Company raised €30m of Tier 2 capital 
with the issue of 20-year subordinated bonds, 
callable after year 10.

The Group has a strong risk management 
framework and solvency position, is well placed 
to withstand significant market disruption  
and has proved resilient to stress testing.

The Group has considered its capital position, 
liquidity and expected performance. The Group 
and its businesses have strong levels of cash 
and other liquid resources and has no concerns 
over the ability to meet its cash commitments 
over the three year planning horizon. The Group 
and its businesses expect to continue to meet 
regulatory requirements.

Primarily during 2020, Covid-19 impacted 
how the businesses operate, with a significant 
proportion of employees working effectively in a 
remote environment. Whilst there was still some 
disruption caused by the pandemic during 2021, 
our businesses and people continued to work 
effectively and support our customers, work with 
our key suppliers and perform other functions of 
the Group.

Given the Group’s operations, robust capital 
strength, liquidity and in conjunction with 
forecast projections and stress testing,  
the Directors have a reasonable expectation  
that the Group has adequate resources and  
is well placed to manage its risks successfully 
and continue in operational existence  
for at least 12 months from the date of this 
report. Accordingly, they continue to adopt  
the going concern basis in preparing  
the Annual Report and Accounts.

Auditor and the disclosure of 
information to the auditor
So far as each person who was a Director
at the date of approving this report is aware, 
there is no relevant audit information that  
the auditor is unaware, that could be needed  
by the auditor in order to prepare their report.

Having made enquiries of fellow Directors  
and the Group’s auditor, each Director has taken 
all the steps that they ought to have taken  
as a Director, in order to make themselves  
aware of any relevant audit information,  
and to establish that the auditor is aware  
of that information.

This confirmation is given and should  
be interpreted in accordance with the provisions 
of Section 418 of the Companies Act 2006.

The Group Audit Committee reviews  
the appointment of the auditor, including  
the auditor’s effectiveness and independence, 
and recommends the auditor’s reappointment 
and remuneration to the Board. Further  
details are disclosed in the Group Audit 
Committee Report. 

In accordance with Section 489 of the 
Companies Act 2006, a resolution proposing  
that PricewaterhouseCoopers LLP  
be reappointed as auditor of the Group  
will be put to the forthcoming AGM.

Directors’ responsibilities
The Directors are responsible for preparing 
the 2021 Annual Report and the financial 
statements in accordance with applicable law 
and regulation.

Company law requires the Directors to prepare 
financial statements for each financial year. 
Under that law the Directors have prepared the 
Group and the Company financial statements 
in accordance with UK-adopted international 
accounting standards.

Under company law, Directors must not approve 
the financial statements unless they are satisfied 
that they give a true and fair view of the state 
of affairs of the Group and Company and of the 
profit or loss of the Group for that period. In 
preparing the financial statements, the Directors 
are required to:

• select suitable accounting policies and then 

apply them consistently;

• state whether applicable UK-adopted 

international accounting standards have been 
followed, subject to any material departures 
disclosed and explained in the financial 
statements;

• make judgements and accounting estimates 

that are reasonable and prudent; and

• prepare the financial statements on the going 

concern basis unless it is inappropriate to 
presume that the Group and Company will 
continue in business.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Three

Governance – Directors’ Report

108108

109

Section Three

Governance

Corporate Governance 

Group Finance and Investment Committee Report 

Group Nominations Committee Report 

Group Risk Committee Report 

Group Audit Committee Report 

Group Remuneration Report 

110

120

124

130 

132

142

Directors’ confirmations
The Directors consider that the 2021 Annual 
Report and accounts, taken as a whole, is fair, 
balanced and understandable and provides  
the information necessary for shareholders  
to assess the Group’s and Company’s position 
and performance, business model and strategy.
Each of the Directors, whose names and 
functions are listed in Section Three  
– Governance confirm that, to the best  
of their knowledge:
• the Group and Company financial statements, 

which have been prepared in accordance 
with UK-adopted international accounting 
standards, give a true and fair view of the 
assets, liabilities and financial position  
of the Group and Company, and of the profit  
of the Group; and

• the Strategic Report includes a fair review  

of the development and performance  
of the business and the position of the Group 
and Company, together with a description 
of the principal risks and uncertainties  
that it faces.

By order of the Board

David Henderson 
Chair 
17 March 2022  

Mark Hews 
Group Chief Executive 
17 March 2022

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section Three 
 
 
 
 
 
 
 
 
Governance – Corporate Governance

110

111

Corporate
Governance

The Board of Directors is committed to applying the highest standards 
of corporate governance and believe that the affairs of the Company 
should be conducted in accordance with best business practice. 

Accordingly, although the Company does  
not have shares with a premium listing  
on the London Stock Exchange and, therefore, 
does not need to adhere to requirements,  
the Company has voluntarily chosen to comply 
with the Principles and Provisions of the 2018 
UK Corporate Governance Code (the Code) 
throughout the year ended 31 December 2021 
where relevant. A copy of the Code can be 
found on the FRC’s website. The Corporate 
Governance Statement also includes the 
reports from Group Audit Committee, the Group 
Finance and Investment Committee, the Group 
Nominations Committee, Group Remuneration 
Committee and the Group Risk Committee1 .

The following aspects of the Code are not 
considered appropriate for the Company  
given its ownership structure:
• provisions relating to outcomes from 
shareholder votes (Provision 4); and 

• shareholding requirements for Executive 

Directors (Provision 36).

During the year, the Company did not comply 
with the following provision of the Code:
• with the exception of the Group Chief 

Executive Officer (GCEO), pension contribution 
rates for Executive Directors are aligned 
to those available to the wider workforce 
(Provision 38). Further information  
is contained in the Directors’ Remuneration 
Report. The Group Remuneration Committee 
has reviewed the pension contribution rate  
of the GCEO and determined that it should  
be aligned to the wider workforce with  
effect from 1 April 2022.

Board leadership and  
Company purpose
Role of the Board
The Board is responsible to the Group’s 
shareholders for the long-term success  
of the Group, its purpose, values, strategy, 
culture and its governance. Great importance  
is placed on a well-informed and decisive 
Board, and Board meetings are scheduled  
and held regularly throughout the year.

The Board sets annual objectives for each 
year in addition to setting the Group’s strategic 
direction. These are implemented through 
approval and regular assessment of the 
business plan and strategy process.

Purpose, value and strategy
The Group’s purpose is to contribute  
to the greater good of society. In particular,  
the Group strives to improve the lives  
of customers, beneficiaries and society  
as a whole. This is achieved by managing  
a portfolio of businesses that operates  
on the highest ethical principles. It seeks  
to diversify and bring an ethical dimension 
to more aspects of society; and all of its 
businesses need to set a high bar, putting  
its customers first and setting an example  
to others.

See our business model and strategy  
for more details.

It is the Board’s policy to record any  
unresolved concerns about the running 
of the Company or any proposed action  
in the Board minutes. During 2021, 
no Director had any such concerns. 

1. Committees of the Company also perform the same Committee functions for Benefact Group plc, the Company’s immediate 

parent undertaking.

Culture
The Board is responsible for setting the right 
values and culture within the Group and 
ensuring the fair treatment of customers. 
During 2021 a refreshed set of values were 
launched which inform the culture across  
the Group, as described below. 

This is embedded across the Group’s 
employee lifecycle, from recruitment 
through performance management and our 
behaviour model, personal development and 
communications. The Board monitors cultural 
alignment through the b-Heard survey results.

Our target culture

We are a group that CARES

Collaborating 
and welcoming

•  We’re a family of diverse businesses united in a common purpose sharing  

our vision, values, culture and behaviours

•  We all belong – welcome and inclusion run through everything we do
•  Our diversity makes us stronger, more connected with each other,  

our customers and communities

•  We’re willing to listen, we trust our colleagues and value their perspectives  

and experience

•  We break down barriers where we spot them to engage with each other  

and work together to get the job done

Ambitious and 
pioneering

•  We’re driven to outperform our ambitious business goals by being bold, brave, 

agile and innovative

•  We’re competitive and commercial with exceptionally high standards  

of customer service

•  We nurture new ideas and innovation – listening, learning, adapting  

and leading the way

•  We have high expectations of each colleague’s performance, supported  

by a clear sense of direction and coaching

•  We take personal responsibility for the way we act and for delivering  

our commitments

•  We celebrate every kind of success and reward people for positive results

•  We’re building a long-term, sustainable legacy
•  We maintain the highest ethical principles that we apply to all aspects  

of our business

•  We actively manage our impacts on the environment, locally and globally
•  We embrace our responsibilities to our colleagues, customers, charities  

and communities

•  We can be trusted to do the right thing

Responsible and 
sustainable

Expert and 
specialist

•  We nurture specialist expertise across the Group
•  We seek to really understand our customers and their needs so we can find  

the right solutions for them

•  We invest in our colleagues’ personal growth to enable them to reach  

their potential

•  We understand and fully utilise our individual strengths, skills and knowledge
•  We get out of each other’s way and trust our specialists to deliver

Supporting  
and Caring

•  We grow our business so we can give our profits to good causes
•  We’re proud to be a commercial company with a charitable purpose
•  We’re caring, kind, empathetic people
•  We all passionately believe in improving the lives of people in our communities
•  Our culture of giving (money, time and kindness) makes a difference, locally  

and globally 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Corporate Governance

112

113

Board activities during 2021 

During the year, the Board made decisions  
on the following business issues, routine  
and Legal and regulatory matters:

Strategic matters

2021 year in review 
• Reviewed delivery of the Group’s commercial 
achievements and delivery of agreed Group 
transitional strategic initiatives and Covid-19 
response throughout the previous year.

EdenTree
• Reviewed and approved the EdenTree  

growth strategy.

Next chapter strategy
• Oversaw the development  

of the Group’s Next Strategic Chapter  
which it ultimately approved.

Benefact House
• Approved the change of registered office.

Benefact Trust Limited
• Received regular reports from  

the Shareholder.

People and culture
• Considered the findings of the 2021  

Employee survey. 

Climate change
• Held a dedicated strategy session  
to discuss the Group’s approach  
to climate change, including reporting  
and regulatory requirements. 

Company and operational performance

The Chief Executive Officer led discussions 
on general business performance and key 
strategic initiatives. Providing the Board  
with the opportunity to review and challenge 
points of interest. 

• Considered feedback and insight on service 
delivered to brokers and customers; and 

• Approved the Group’s approach to Operational 

Resilience.

Charitable purpose
• Considered regular updates on the charitable 
purpose and mission (including consideration 
of the Grant Policy in Canada and Australia); 
and 

• Approved the Sustainable and Responsible 

Investment Policy.

Governance and regulatory matters
• Discussed reports from Board Committees 

and management on legislation and proposed 
consultations that affect or will affect  
the Group’s legal and regulatory obligations; 
• Reviewed and approved the updated Group 

Data Policy; 

• Approved the resolutions to be put  
to the shareholders at the AGM;

• Approved changes to the Board Committee’s 

Terms of Reference; and

• Considered Directors’ Conflicts of Interest 

Register.

Board succession and diversity 
• Assessed the independence of Non-Executive 
Directors upon the recommendation of the 
Group Nominations Committee; 

• Approved the appointment of a new  
Non-Executive Director and changes  
to Committee composition; 

• Approved the refreshed Board Diversity 

Policy; and

• Considered the annual renewal of Directors’ 

and Officers’ Liability Insurance. 

Board effectiveness
• Approved the 2021 Objectives of the Board 
and monitored progression throughout  
the year; 

• In a private session considered the results  
of the annual appraisal of the Chair; and 
• Considered the outcome of an externally 

facilitated Board Paper effectiveness review. 

Business updates
• Received updates on performance from  

each business area (general insurance, broker 
and advisory and investment);

Regulatory disclosures
• Reviewed and approved the Annual Report 
and Accounts, Notice of General Meeting,  
Half Year and Full Year results announcements. 

Financial reporting and controls,  
capital structure and dividend

and reasonable view of the effectiveness  
of the Group’s systems of control; and

• Approved the Group Own Risk and Solvency 

Financial resilience
• Reviewed the going concern assessment  

Assessment and considered the Annual 
Report of the Data Protection Officer 

and viability statement; 

• Considered the General Insurance Claims 

Reserve Adequacy; and

• Provided final approval for the raising  

of €30m of Tier 2 capital with the issue  
of 20-year subordinated bonds, callable  
after year 20. 

Capital, costs and budget
• Considered the Group’s reinsurance 

arrangements; 

• Approved a transfer of shares held in Ansvar 

Risk Management Services Pty Limited  
to Ansvar Insurances Limited; and 

• Agreed the Group Corporate Strategy  
and Business Plans for 2022 to 2024. 

Cashflow and dividends 
• Considered the dividends to be paid  

to the holders of the 8.625% Non-Cumulative 
Shares of £1; and

• Considered making a grant to the Company’s 

ultimate parent Benefact Trust Limited 
(formerly Allchurches Trust Limited).

Regulatory reporting 
• Considered the report of the Actuarial 
Function Holder on the adequacy  
of the year-end technical provisions; and

• Reviewed and approved the Solvency 
and Financial Condition Report (SFCR), 
Regular Supervisory Report (RSR), Annual 
Quantitative Reporting Templates, National 
Specific Templates (NSTs), Internal Model 
Output Templates and the Standard Formula 
Template (SF) prior to submission to the PRA. 

Oversight of Risk and Risk Management
• Received and discussed reports from  
the Group Chief Risk and Compliance  
Officer (via the Group Risk Committee),  
and assessed the Group’s significant risks  
and regulatory issues;

• Reviewed the Group Chief Executive’s Report 
on the outcomes of the Systems of Control 
and Risk Self-Assessment (CRSA) exercise, 
concluding that the report provided a fair  

Our approach to the long-term 
success of the Company 
The Board of Directors recognise that  
the long-term success of the Company  
is dependent upon having regard to the 
interests of its stakeholders. In our ambition 
to be the most trusted and ethical specialist 
financial services group, the Board understands 
how important it is to listen and respond to the 
needs of our stakeholders. 

As an ethical, global financial services  
group we are fundamentally different from  
our competitors because we are driven  
by the power of why and are continually 
striving to do the right thing at all times.  
In doing so there are occasions where 
balancing the needs of different stakeholder 
groups can be challenging. On these occasions, 
the Board attempts to balance the conflicting 
interests and impacts of our stakeholders  
in its decision making. 

Stakeholder engagement in 
decision making
The Board adopts a range of approaches  
to engage with stakeholders and recognises 
that the importance of a stakeholder group may 
differ depending on the matter to be considered. 
Given the nature of the business, the Board 
sometimes engages directly with stakeholders 
and also understands that it may be more 
appropriate for engagement to be undertaken 
at an operational level. 

The Board considers a variety of information 
to understand the impact of the Company’s 
operations and also the interests and views  
of our key stakeholders. A one-year rolling plan 
of business for discussion is agreed annually 
to ensure that the Board is focused on the 
right issues at the right time and sufficient time 
is allowed for appropriate consideration and 
debate. Information is provided to Directors  

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
Governance – Corporate Governance

114

115

in papers in advance of each meeting.  
In addition, people from the business are invited 
to attend meetings to provide insight into key 
matters and developments. At each Board 
meeting, the Directors discuss strategic and 
business matters, financial, operational and 
governance issues and other relevant issues 
that arise. Following Committee meetings,  
the Board receives oral reports from the Chair  
of each Committee at the next Board meeting. 
As a consequence of this, the Board has an 
appreciation of engagement with stakeholders 
and other relevant matters, which enables the 
Directors to comply with their legal duties. 

As a global group, the Board also believes 
governance is best achieved through the use 
of delegation of its authority for the executive 
management to the Group Chief Executive.  
To assist him in delivering his responsibilities  
to the Board, the Group Chief Executive  
has established a corporate structure  
that comprises three business divisions  
(Broker and Advisory, General Insurance 
and Investment Management) with more 
information found in the ’Our businesses’ 
section. A General Management Board (GMB) 
and Relevant Boards and Committees have also 
been established  in each business division.

General Management Board (GMB)
Under the leadership of the Group Chief 
Executive, the GMB leads the Shared Services 
and oversees the business divisions. Working 
closely with the Board, it focuses on Group 
delivery of culture and values; strategy and 
direction; governance and risk management; 
key projects and programmes; budgets; 
reviewing performance; rating agency  
and shareholder matters; and leadership  
and communication. 

Management Committees
A number of Management Committees  
and Boards have been established to ensure 
that each SBU Managing Director has oversight 
of their respective areas, whilst providing 
assurance to the Group Chief Executive  
and other Executive Directors and ultimately 
the Board.

As the Board remains ultimately responsible 
for decision making within the Group, it receives 
regular updates from the Group Chief Executive 
and other Executive Directors

Covid-19 response 
As the world begins to return to some form 
of normality, we understand that the effects 
of Covid-19 remain with us all. We set out our 
initial response to Covid-19 in the 2020 Strategy 
and Company Performance Overview. As such, 
the Board has continued to make decisions this 
year to ensure that the Group remains strong 
and in a position of being able to continue 
our Movement for Good for so many, during 
a time of great need. The ongoing pandemic 
has also encouraged us and our stakeholders 
to consider and embrace new and innovative 
methods of engagement. 

This impact and how we have responded to 
protect our Group and manage the expectations 
of our stakeholders has been included in our 
Stakeholder engagement overview below:

Next strategic chapter 
The Group unveiled its Next Chapter Strategy 
internally in September 2021. A dedicated Board 
Session was held which considered feedback 
from Benefact Trust Limited (the Company’s 
ultimate shareholder) and other stakeholder 
and external perspectives (including customers, 
colleagues, communities and the environment). 
The development of the Strategy was a key 
focus of Board Meetings throughout the year. 
This culminated in the Board’s approval  
of the Corporate Strategic Plan 2022-24.  
For more detail on the Strategy please refer  
to the Strategic Report.

Below is a summary of key decisions and 
actions the Board has taken during the year  
in respect of strategic and Group performance 
and how it has had regard to the interests  
of, and impact on a selection of its stakeholders.

Employee engagement
The Board recognises that employees are  
the Group’s greatest asset given their specialist 
skills and knowledge and propensity  
to go above and beyond. Members of the 
management team and subject matter experts 
are invited to Board and Committee meetings 
to present on items and input into discussion. 
Directors also visit subsidiaries and other SBUs 
and Project teams to gain a good understanding 
of colleagues’ views. In order to engage, involve 
and inform colleagues, a range of methods  
as set out below are used: 
• Given Sir Stephen Lamport’s previous 

experience and responsibilities as Group 
Remuneration Committee Chair, the Board 
agreed that he was the most appropriate  
Non-Executive Director to replace Caroline 
Taylor as the designated Non-Executive 
Director for employee engagement .  
The designated Non-Executive Director  
is briefed on employee engagement survey 
results and relevant findings are reported  
to the Board; 

• A variety of communication channels including 

intranet, all staff emails (including weekly 
news, results, achievements and changes), 
briefings, conferences and publishing of 
financial reports and feedback and discussion 
is adopted (including to make employees 
aware of financial and economic factors 
affecting the performance of the Company);

• During 2020, as a result of the pandemic, 
the Group chose to focus on more tailored 
and regular ‘check-in’ surveys which were 
conducted monthly. This enabled the Group  
to gather real time feedback, to flex each 
survey and to respond as the situation 
evolved during what was a unique year. 
During 2021 the Group transitioned back  
to a full annual colleague engagement survey 
adopting a new b-Heard Survey provided  
by an external partner, Best Companies.  
The full b-Heard survey was undertaken  
in the Spring with 79% of employees taking 
part, and this was supplemented by a further 
pulse survey later in the year. The Group  
was proud to be awarded Best Companies’  
2 star accreditation demonstrating 
‘outstanding’ levels of employee engagement, 
with many of the Group’s teams being 

recognised at the highest 3 star level,  
or ‘world class’;

• During the year the employees undertook 

training to support the accessibility  
and understanding of our whistleblowing 
policy, procedure and approach;

• Direct engagement and consultation through 
employee representative forums including 
the Group’s recognised Union and informal 
Employee Working Groups (such as  
‘The Explainers’ and ‘The Office Life Network’) 
is encouraged; 

• ‘Town Hall’ meetings are hosted virtually  
by senior management where employees  
can ask questions and provide feedback.  
For example during the year the Chief 
Executive and other senior leaders engaged 
directly with colleagues, through a series  
of online roadshows to which employees 
from all territories were invited for the internal 
launch of the Group’s next strategic chapter;

• A performance-related bonus scheme  

is operated, which directly links individual 
objectives and business performance  
to encourage employees to participate  
in the overall financial success of the  
Group; and

• A range of training, development and 
volunteering activities are available  
to employees, including technical  
courses, mentoring, coaching and  
community opportunities.

An example of an opportunity where the Board 
of Directors were able to engage with a range 
of employees from across the Group, at various 
levels of seniority, was at the Official Opening 
ceremony of the Group’s new Head office  
in Gloucester in September. Following which, 
the Directors were invited to attend a two day 
offsite Leadership Conference. The opportunity 
was used to enhance collaboration between 
Board members and employees and therefore 
improving decision making.

Customer engagement
Customers (being the person or entity, 
which ultimately relies upon Ecclesiastical’s 
products, advice or expertise for the protection 
and management of their assets including 
prospective and former customers) are the 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Corporate Governance

116

117

lifeblood of the Group. The Board considers  
that customers should be at the heart of 
everything we do, treating them fairly and 
ethically and ensuring any actions or decisions 
demonstrate our passion for customers and 
make us first choice for customers both today 
and in the future. During the year, the Board 
received updates on customer issues via the 
Group Chief Executive’s Report and reports  
on strategic initiatives. 

The Board also received a report on customer 
feedback. The report provided an overview  
of service delivery as experienced by its various 
customer groups. It also outlined a number  
of the Group’s externally received accolades  
as evidence of the strong service provided 
to our customers. 

In addition, the Board considered customers’ 
needs, knowledge and expectations as part 
of the development of the Next Chapter 
Strategy and Company’s new visual identity. 
Meetings are held between management 
and key customers to understand their needs 
and perspectives. In addition, the Group has 
regular engagement with customers (including 
conducting listening exercises, surveys, holding 
focus or consultative groups, monitoring 
customer complaints and satisfaction data)  
and key outcomes are shared with the Board. 
Our commitment to customers and clients  
is further demonstrated by the tailored 
Customer Promises that have been developed 
for key Strategic Business Units.

Shareholder engagement
Benefact Group plc owns the entire issued 
Ordinary share capital of Ecclesiastical 
Insurance Office plc. The Directors of the  
Boards of both companies are identical. 
Benefact Group plc in turn is wholly owned  
by Benefact Trust Limited (previously 
Allchurches Trust Limited) with whom the Board 
has an open and constructive relationship. 

Protocols for the exchange of information 
between Benefact Trust Limited and Benefact 
Group plc and its subsidiaries (including 
Ecclesiastical Insurance Office plc) are in place 
and cover performance, operations and financial 

position. There is at least one ‘Common Director’ 
(a Director who is a member of the Boards  
of Benefact Trust Limited, Benefact Group plc 
and Ecclesiastical Insurance Office plc) who  
is expected to attend every Board meeting. 

Sir Stephen Lamport and Chris Moulder  
were appointed as ‘Common Directors’. 

The Common Directors present a summary 
of highlights from Benefact Trust Limited 
Board meetings to the Directors. There is 
also engagement between respective Board 
and Committee Chairs and the Group Chief 
Executive Officer. Regular dialogue takes  
place on Benefact Trust Limited’s expectations 
of the Group, strategy for the development  
of the business and the grant from the Group. 
This ensures that the views of Benefact Trust 
Limited are communicated to the Board  
as a whole. In turn, the Common Directors 
are able to support the Directors of Benefact 
Trust Limited to understand the performance 
and strategic issues faced by the Company. 
A conflict of interest policy which sets out 
how actual and perceived conflicts of interest 
between the two companies are managed  
is in place.

When determining if it is appropriate to make 
a grant to the Company’s ultimate parent 
undertaking, Benefact Trust Limited, the Board 
considers advice from the Group Chief Financial 
Officer. A key area for the Board’s deliberation 
is the Company’s capital position and the 
affordability of the grant based on a range  
of stressed circumstances as well as the  
views of the Chair of Benefact Trust Limited.  
Two grants amounting to £21m were paid  
to Benefact Trust Limited during the calendar  
year 2021.

Suppliers (including brokers) 
The importance of the role that suppliers 
play in ensuring a reliable service is delivered 
to customers is recognised by Directors. 
Consequently, the Group Risk Committee 
oversees the Procurement, Purchasing  
and Outsourcing Policy and receives  
regular updates on the Group’s material 
outsourcing contracts. 

During the year, the Board received a report  
on Broker feedback, which presented  
an overview of broker servicing. The report 
also set out the Group’s response to supporting 
Brokers throughout the pandemic and 
subsequent restrictions. 

In addition, Executive Directors hold regular 
meetings with key suppliers to understand  
their perspectives, specifically the impacts that 
the wider economic environment (including 
Brexit and Covid-19) had upon them.

Community and environment 
The Board understands the importance  
and the impact of climate change upon  
the environment, our communities,  
our customers and our wider stakeholders.  
In response, Directors attended a bespoke 
Climate Change Response Strategy workshop 
in order to better understand the potential 
impact (and opportunities) that climate change 
could have on the Group as an Insurer and 
asset owner. This session drove the ongoing 
discussions allowing the Group to formulate 
its Climate Change ambition, which has been 
overseen by the Group Risk Committee. 

Being an asset owner, the Group understands 
its responsibilities as a sustainable investor. 
As such, the Board has overseen the 
implementation of EdenTree’s growth strategy. 

The importance of communities to us is 
demonstrated by our new Group vision  
and in particular our desire to transform lives 
and communities. During 2021 the Group 
achieved its ambition to give more than £100m 
to charity leading to a cumulative £150m  
since 2014. 

We are also committed to creating  
a Movement for Good. In doing so, the Board 
has overseen and had regular updates  
on the Group’s charitable giving. 

Engagement with regulators 
The Board recognises the importance  
of open and honest dialogue with regulators 
(including those in the UK, Australia, Canada 

and the Republic of Ireland) and is committed 
to complying with applicable legislation and 
regulation. The Board (via its Committees) 
receives regular reports detailing the Group’s 
regulatory interactions. The Board (via its 
Committees) also receives regular reports  
on the evolving legal and regulatory landscape 
incorporating a detailed impact and progress 
assessment which undergoes a rigorous cross 
departmental challenge process before being 
presented to the Board. 

In addition, Directors attend regular  
one-to-one meetings with representatives  
from its regulatory bodies. 

Whistleblowing
The Board (via the Group Audit Committee) 
is responsible for reviewing the Group’s 
Whistleblowing Policy and Procedures  
and receives regular updates.

The Group’s approach to whistleblowing is set 
out in a Policy and supported by procedures 
and guidance documents (which is available 
internally on the Group’s intranet). The Chair 
of the Group Audit Committee is designated 
the Group’s ‘Whistleblowing Champion’ having 
responsibility to ensure the independence, 
autonomy and effectiveness of the Group’s 
policies and procedures on whistleblowing 
including the procedures for protection of staff 
that raise concerns from detrimental treatment.
Group HR has responsibility for ensuring 
the effectiveness of internal whistleblowing 
arrangements, including arrangements 
for protecting whistleblowers against 
detrimental treatment (on behalf of the 
Whistleblowing Champion) including ownership 
of the associated policy, procedures  
and guidance documents.

More information about the Group’s 
whistleblowing policy and arrangements  
is included within the Group Audit  
Committee Report.

Conflicts of interest
A Register of Directors’ Conflicts is maintained 
by the Group Company Secretary to monitor 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Governance – Corporate Governance

118

119

and manage any potential conflicts of interest.
Training on the Companies Act 2006  
has been given to all Directors and Directors 
are regularly reminded of their duties.
Any conflicts are declared at the first Board 
meeting at which the Director becomes aware 
of a potential conflict and then recorded  
in the Conflicts Register. The Board considers 
all conflicts in line with the provisions set  
out in the Company’s Articles. The Directors  
are required to review their interests recorded 
in the Conflicts Register on a biannual basis.

In addition, the Board oversees the procedure 
for managing actual and potential conflicts  
of interest in the trading relationship with 
owned brokers (Lycetts and SEIB) and the 
general insurance business. It is underpinned 
by the desire to put the customer interest  
at the forefront of their dealings and seek 
to deliver the best customer outcome.

It is the Board’s policy to record any  
unresolved concerns about the running  
of the Company or any proposed action  
in the Board minutes. During 2021,  
no Director had any such concerns.

Division of responsibilities
The responsibilities of the Board,  
its Committees, Chair, Group Chief Executive  
and Senior Independent Director are set  
out in writing and are available  
on the Company’s website.

The Chair and the Group Chief Executive
The roles of the Chair and the Group Chief 
Executive are undertaken by separate 
individuals. The Chair, David Henderson,  
is responsible for leadership of the Board.
The day-to-day management of the business  
is undertaken by the Group Chief Executive, 
Mark Hews, assisted by the Group 
Management Board.

Senior Independent Director
Chris Moulder was appointed as the Senior 
Independent Director on 14 January 2020.  
The Senior Independent Director supports  
and acts as a sounding board for the Chair  
and is responsible for overseeing  
the governance practices of the Company 
and leading the Directors in their appraisal 
of the Chair. Along with the Chair, the Senior 
Independent Director is the primary contact  
for the shareholder and they meet regularly 
with the shareholder to share and  
understand views.

Non-Executive Directors
Non-Executive Directors have a responsibility 
to uphold high standards of integrity  
and probity including acting as both internal 
and external ambassadors of the Company. 
As part of their role as members of a unitary 
Board, Non-Executive Directors should 
constructively challenge and help develop 
proposals on strategy.

Ecclesiastical Board of Directors

Group Finance and 
Investment Committee

Group 
Nominations 
Committee

Group Risk
Committee

Group Audit
Committee

Group 
Remuneration 
Committee

Board Committees
The Group has five Board Committees which 
are shown above.

Details of all the Board Committees  
are contained within their respective reports 
that follow.

Attendance at meetings
Directors are required to attend all Board 
meetings and strategy days as well  
as Committee meetings where they  
are members. In 2021, the Board held five 
scheduled meetings and a strategy day.  
In addition, the Board participated in regular 
training sessions.

David Henderson met with the Non-Executive 
Directors without the Executive Directors 
present on a number of occasions throughout 
the year.

Below is a record of the Directors’ attendance for the Board meetings during 2021:

Board attendance table
Executive Directors 

Director since 

Meetings eligible 
to attend  

Meetings 
attended

Mark Hews  
S. Jacinta Whyte 
Denise Cockrem 

June 200 9 
July 2013 
September 2019 

6 
6 
6 

6
6
6

Non-Executive Directors 

Director since 

Meetings eligible 
to attend  

Meetings  
attended

David Henderson (Chair) 
Rita Bajaj 
Francois-Xavier Boisseau 
Sir Stephen Lamport 
Neil Maidment 
Andrew McIntyre 
Chris Moulder 
Angus Winther 
Caroline Taylor 

April 2016 
July 2021 
March 2019 
March 2020 
January 2020 
April 2017 
September 2017 
March 2019 
September 2014 

6 
3 
6 
6 
6 
6 
6 
6 
3 

6
3
6
6
6
51
51
6
3

1  Mr McIntyre and Mr Moulder were unable to attend a meeting because of a prior business commitment arranged 

before the meeting was confirmed.

Company Secretary
The Company Secretary is responsible  
for compliance with Board procedures, 
advising the Board on all governance matters, 
supporting the Chair and helping the Board  
and its Committees to function efficiently.  
All Directors have access to the advice  
of the Company Secretary.

Internal controls
The Board is ultimately responsible for the 
systems of risk management and internal 
control maintained by the Group and reviews 
their appropriateness and effectiveness 
annually. The Board views the management 
of risk as a key accountability and is the 
responsibility of all management and believes 
that, for the period in question, the Group  
has maintained an adequate and effective 
system of risk management and internal control 
that complies with the Code. Further details  
are set out in the Risk Management Report. 

The Group embeds risk management  
into its strategic and business planning 
activities whereby major risks that could  
affect the business in the short and long term 
are identified by the relevant management 
together with the assessment of the 
effectiveness of the processes and controls  
in place to manage and mitigate these risks.

The Group’s internal control framework  
is vital in setting the tone for the Group  
and in creating a high degree of control 
consciousness in all employees.

A Code of Conduct and a Code of Ethics  
are embedded into the culture of the Group  
and are accessible to all staff via the intranet.

Assurance on the adequacy and effectiveness 
of internal control systems is obtained through 
management reviews, control self-assessment 
and internal audits.

Systems of internal control are designed  
to manage rather than eliminate the risk  
of failure to achieve business objectives,  
and can provide reasonable, but not absolute, 
assurance as to the prevention and detection 
of financial misstatements, errors, fraud 
or violation of law or regulations. Further 
information on internal controls is set out  
in the Group Audit Committee Report. 

By order of the Board

Mrs. R. J. Hall
Group Company Secretary 
17 March 2022

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
  
 
 
 
  
Governance – Group Finance and Investment Committee Report

120

121

Group Finance and Investment 
Committee Report

Chair’s introduction

I am pleased to present this report, describing  
the work undertaken by the Committee during  
the past year. Caroline Taylor stepped down from  
the Committee during the year and we are grateful  
for her contribution. We also welcomed Rita Bajaj  
and Francois-Xavier Boisseau who joined  
as members of the Committee in July 2021. 

Membership
The members of the Group Finance and Investment Committee and their attendance  
during the year are shown below:

Committee member 

Member since 

Meetings eligible to attend  Meetings attended

Angus Winther1 

Rita Bajaj2 

April 2019 

July 2021 

Francois-Xavier Boisseau3 

July 2021 

David Henderson 

Caroline Taylor4 

June 2016 

March 2016 

4 

2 

2 

4 

2 

4

2

1

4

2

1  Angus Winther was appointed to the Committee on 3 April 2019 and was appointed Chair on 1 January 2020.
2  Rita Bajaj was appointed to the Committee on 15 July 2021.

3  Francois-Xavier Boisseau was appointed to the Committee on 1 July 2021. Mr Boisseau was unable to attend his first 

Committee meeting due to illness. 

4  Caroline Taylor was a member of the Committee until 8 September 2021 when she left the Board. 

Committee meetings
The Committee held four scheduled meetings 
during the year, each of which were attended 
by the Group Chief Executive and Group Chief 
Financial Officer by invitation. Other people 
from the business were invited to attend 
meetings to provide insight into key matters 
and developments.

The Committee’s key responsibility is to ensure 
that, within designated financial limits, the 
management of the Group’s financial assets, 
including its investment portfolio, is properly 
governed, controlled and is performing  
as expected. The Committee also considers  
and approves major financial decisions 
including capital raisings, acquisitions  
and disposals on behalf of the Board.  
The Committee is also constituted  
as a Committee of the Company’s immediate 
parent Benefact Group plc and provides  
the same functions.

A summary of the main activities of the 
Committee during 2021 are set out below:

Finance
During the year, the Committee has monitored 
acquisition and disposal activity, outcomes 
and performance across the Group. The need 

to extend support to some of the businesses 
within the Group to enable them to realise 
local strategic ambitions was also considered. 
In response Benefact Group plc acquired 
2,799,900 £1 ordinary shares in Ecclesiastical 
Planning Services Limited (EPSL) and 
200,000 £1 ordinary shares in EdenTree Asset 
Management Limited (EAM).

Benefact Group plc has a non-controlling 
equity interest in the speciality insurer Lloyd  
& Whyte. The Committee has monitored various 
matters relating to that acquisition, including 
associated structural changes, Lloyd & Whyte’s 
acquisition pipeline, associated loan exposure 
and performance.

Investments
During the year, the Committee reviewed the 
investment mandate with EdenTree Investment 
Management Limited to ensure that it remained 
fit for purpose and remained compliant with 
legal and regulatory requirements. In addition, 
the performance of the Group’s investment 
portfolios and outlook for the financial markets 
were also considered. 

The Group’s business plan investment 
assumptions and the overall investment 
strategy were reviewed. This included 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Finance and Investment Committee Report

122

Ecclesiastical Annual Report & Accounts 2021

123
123

consideration of asset allocation and exposure 
(to equities, bonds, infrastructure, property 
and cash) and associated risk. The Committee 
also considered a framework for determining 
hedging decisions. Areas of focus included the 
reasons and rationale for the framework and 
who was best placed to make such decisions 
and how they should be made.  

Additionally, the Committee reviewed in detail 
investments in property and MAPFRE RE.

Governance
The Committee also reviewed its own 
performance and set objectives. During the 
year, Mr Boisseau was appointed as a member 
of the Committee to further strengthen the 
interaction with the Group Audit and Group  
Risk Committees. 

Together with the Group Risk Committee,  
the Committee oversaw a review of the  
Group’s Authorities Framework, culminating  
in recommendations to the Board which  
were approved.

By order of the Board

Angus Winther
Chair of the Group Finance  
and Investment Committee
17 March 2022

‘The Committee’s 
key responsibility 
is to ensure that, 
within designated 
financial limits, the 
management of the 
Group’s financial 
assets, including 
its investment 
portfolio, is 
properly governed, 
controlled and 
is performing as 
expected.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
Governance – Group Nominations Committee Report

124

125

Group Nominations 
Committee Report

Dear Stakeholder

I am pleased to present the Group Nominations 
Committee’s Report describing the work  
we have carried out during the past year.  
This report gives more detailed information  
on how we performed our duties in 2021.

Committee composition
The members of the Group Nominations Committee and their attendance at meetings during  
the year are shown below:

Committee member 

Member since 

Meetings eligible 
to attend 

Meetings 
attended

Chris Moulder 
David Henderson 
Angus Winther 1 
Caroline Taylor2 

November 2019 
January 2019 
May 2021 
November 2019 

3 
3 
2 
2 

1  Angus Winther was appointed to the Committee on 13 May 2021. 

2  Caroline Taylor was a member of the Committee until 8 September 2021.

3
3
2
2

Meetings of the Committee
The Committee held three scheduled  
meetings in 2021 (February, May and October) 
which were attended by the Group Chief 
Executive and Group Company Secretary 
(2020: three meetings). 

Composition of the Board  
and senior management
The Committee considered the composition  
of the Board and its Committees, subsidiaries  
and senior management (including members  
of the Group Management Board (GMB), heads  
of Strategic Buiness Units and senior functions). 
This included consideration of skills, knowledge, 
and experience, length of tenure, independence 
and diversity in the context of the Group’s  
long-term strategic priorities.

Appointment of a new Group 
Remuneration Chair and  
Workforce Engagement  
Non-Executive Director
The appointment process for a new Group 
Remuneration Chair commenced during 2020. 
This was to ensure that the appointee was able  
to serve on the Group Remuneration Committee 
for at least 12 months. The Board considered  
the Committee’s recommendation that Sir 
Stephen Lamport be Caroline Taylor’s successor 
at its meeting in February 2021. This proposal  
was unanimously supported by Directors subject 
to regulatory approval, which was received  
on 24 June 2021. As part of the appointment 
process, Sir Stephen completed an extensive 
induction to the Group Remuneration Committee. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
 
  
  
 
Governance – Group Nominations Committee Report

126

127

Board diversity
Ecclesiastical recognises the benefits of having 
a diverse Board and is committed to improving 
diversity on the Board in the broadest sense.  
It believes that diversity, including in respect  
of gender, both improves performance  
of the Board and strengthens the business. 

Ecclesiastical will:

•  Seek to achieve a level of at least 33% female 
Directors over the medium term on the Board 
of Ecclesiastical Insurance Office plc;

•  Ensure that the Board composition comprises 

of at least one Director from an ethnic 
minority background;

•  Engage solely with executive search firms 
who have signed up to the voluntary Code  
of Conduct on both gender and ethnic 
diversity and practice;

•  Ensure that the recruitment process and the 
development of ‘long-lists’ reflect the Board’s 
diversity commitments to both gender  
and ethnic diversity and that candidates  
are presented from all backgrounds, and  
with diverse skills and personal qualities;

•  Maintain commitment to the Women  

in Finance Charter, which focuses upon 
building a more balanced and fair industry  
by promoting gender balance at all levels 
across the financial services industry; and 
•  Report annually on its diversity objectives 
and other initiatives undertaken by the 
Company, which promote gender, social  
and ethnic diversity.

As at 17 March 2022 the Board has appointed 
three female Directors (including two Executive 
Directors) in a membership of eleven. The Board 
recognises that the majority of its Committees 
lack female representation and that all of its 
Committees are chaired by male Non-Executive 
Directors. The Board is actively seeking  
to address this issue. Notwithstanding this,  
the Board is proud that most of the Company’s 
Executive Directors are female. 

As at 31 December 2021, female representation 
on the GMB stands at 38%(2020: 38%) and  
in the wider senior management population 

(GMB and BL) at approximately 28%  
(2020: 27%). The Board encourages executive 
management to ensure appropriate diversity  
at senior levels within the organisation.

The Board will take the opportunity, as and 
when appropriate, to further improve diversity 
in its broadest sense (including ethnicity, skills, 
regional and industry experience, background, 
age, gender and other distinctions) as part 
of its Board recruitment practice. The Board, 
via the Group Nominations Committee, will 
consider the progression of women to key roles 
including Chair, Senior Independent Director 
and Executive Directors as part of its regular 
review of succession planning. All Board 
appointments are made on merit, in the context 
of the diversity of skills, experience, background 
and gender required to be effective. 

Directors’ length of service
The Committee monitors the length of tenure  
of all Directors as shown in the table  
on Board diversity.

Independence and time 
commitment
The Board believes that all the Non-Executive 
Directors were independent throughout  
2021. Independence is reviewed as part  
of each Director’s annual appraisal, considered 
by the Committee and agreed by the Board 
annually. The Committee has considered  
the circumstances and relationships of all 
Non-Executive Directors and, following rigorous 
review, the Committee confirmed to the Board 
that all Non-Executive Directors remained 
independent in character and judgement.  
No individual participated in the discussions 
relating to their own independence.

Chris Moulder and Sir Stephen Lamport  
are Directors on the Boards of Benefact Trust 
Limited and the Company (‘common Directors’). 
The common directorship model is regarded  
as good practice with a charity that owns 
a trading subsidiary and these ‘common 
Directors’ enable the Trust to gain a thorough 
understanding of its subsidiary company’s 

Appointments to the Board
Non-Executive Director Appointment  
Rita Bajaj

An Appointments Panel comprising David 
Henderson, Chris Moulder, and Angus Winther 
was formed to commence the recruitment  
of a new Non-Executive Director with extensive 
experience in financial services, preferably 
gained from investment management and 
ideally with some experience of socially 
responsible investments.

Four executive search firms were interviewed 
with Sapphire Partners (which had no other 
connection to the Group and is a signatory 
to the Voluntary Code of Conduct on gender 
diversity and best practice) engaged to support 
the recruitment process. 

The initial candidate long-list was reduced  
to a short-list by the Appointments Panel. 
The short-list was further reduced by the 
Appointment Panel based on the skills and 
knowledge of the candidates and identified 
Board skills gaps. After a series of interviews 
and due diligence, Rita Bajaj emerged as  
the preferred candidate. This was based  
on consideration of personal attributes,  
external commitments and needs of the Board.  
Prior to appointment, all members of the Board  
were given the opportunity to meet with Rita.  
At the end of the process and following 
recommendation of the Group Nominations 
Committee, the appointment was approved  
by the Board and was effective on 15 July 2021. 

performance and the strategic issues it faces,  
and for the subsidiary to understand  
the expectations of its parent company.  
A joint Company and Benefact Trust Limited 
Nominations Committee Meeting is held  
on an annual basis, amongst other things to 
consider the appointment of common Directors.

The Committee evaluates the time  
Non-Executive Directors spend on  
the Company’s business annually and  
is satisfied that, in 2021, the Non-Executive 
Directors continued to be effective and fulfilled 
their time commitment as stated in their  
letters of appointment.

External directorships are considered to be 
valuable in terms of broadening the experience 
and knowledge of Executive Directors, provided 
there is no actual or potential conflict of interest, 
and the commitment required is not excessive. 

All appointments are subject to approval  
by the Board, and the Conflicts Register 
maintained by the Group Company Secretary  
is used to monitor external interests.  
Any monetary payments received by Executive 
Directors from outside directorships are paid 
over to and retained by the Group.

Succession planning
The Committee considered the Group’s Board 
and Leadership Succession Plan to ensure that  
a rigorous and phased approach is adopted, 
taking into account the challenges and 
opportunities facing the Group.

In respect of each leadership role, emergency, 
short-term and long-term succession plans 
are considered and challenged to ensure that 
appropriate skills are in place to support the 
Group’s short- and long-term strategy and 
ensure a diverse pipeline of talent is in place.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Nominations Committee Report

128

Ecclesiastical Annual Report & Accounts 2021

129
129

Induction and training 
All new Directors undertake a formal, 
comprehensive and tailored induction  
to the Group upon joining the Board.  
This includes sessions with the Group Company 
Secretary, Group Chief Risk and Compliance 
Officer, Director of Group Finance, Group Chief 
Actuary, Group Development Director, Group 
HR Director, Group Reinsurance Director, Group 
Chief Internal Auditor and heads of the Group’s 
trading businesses. New Directors also meet 
individually with the Chair of Benefact Trust,  
the Group Chair, the Senior Independent 
Director, and each of the Executive Directors. 
This is to ensure they understand the significant 
risks, strategic and commercial issues affecting 
the Group and the markets in which it operates 
as well as their duties and responsibilities  
as a Director.

The Group Company Secretary maintains 
annual CPD records for all Directors, which  
the Chair reviews as part of their annual 
appraisal. Training and development needs 
of Board members are also reviewed by the 
Committee. In 2021, a number of training 
sessions took place including Catastrophe  
and PSA Exposure, Internal Model, Board  
Paper Review Workshop, Anti-Money 
Laundering, Bribery and Corruption, IFRS17  
and Cyber Training. In 2022 sessions have  
been planned on Technology, IFRS 17, Insure 
Tech and Re-Insurance (Credit Risk). 

Board evaluation
All Directors receive an annual appraisal  
from the Chair. The Chair is appraised  
by the Board, in his absence, led by  
the Senior Independent Director.

It is the Board’s policy for its evaluations  
to be facilitated typically every two to three 
years. The last external Board evaluation 
was carried out in 2019; facilitated by Grant 
Thornton (which acts as our co-source 
provider for internal audit on UK and Canada 
and has no other connection with the Group). 
Given Covid-19, the Board agreed that the 
next external evaluation should take place 
in 2022. During 2021, the Board has focused 
its attention upon a Board and Committee 
Reporting Review, which was an action arising 
from the previous Board evaluation. The Board 
and Committee Reporting Review has been 
externally facilitated by Deloitte and will further 
strengthen the Board’s oversight and decision 
making of the Company and its SBUs. 

In addition, the Company Secretariat facilitated 
an evaluation based on bespoke questionnaires 
with outcomes considered by the Board  
and Committees. 

The next external Board evaluation will  
be undertaken in 2022.

By order of the Board

Chris Moulder
Chair of the Group Nominations Committee
17 March 2022

‘Ecclesiastical 
recognises the 
benefits of having 
a diverse Board 
and is committed to 
improving diversity 
on the Board in the 
broadest sense.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Three

Governance – Group Risk Committee Report

130

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

131
131

Group Risk
Committee Report

Chair’s introduction

I am pleased to present this report describing 
the work undertaken by the Group Risk 
Committee (the Committee) during the past year. 
The Committee’s role is to oversee the Group’s 
risk management framework (including risk 
appetite and tolerance) and the Group’s risk and 
compliance functions; and to monitor prudential 
risk (including overseeing the internal model). 

Membership
The members of the Group Risk Committee and their attendance at meetings during the year  
are shown below:

Committee member 

Member since 

Meetings eligible 
to attend 

Meetings  
attended

Chris Moulder (Chair) 

September 2017 

Andrew McIntyre 

August 2017 

Francois-Xavier Boisseau  

April 2019 

Neil Maidment  

March 2020 

Sir Stephen Lamport  

November 2020 

4 

4 

4 

4 

4 

4

4

4

4

4

The Group has voluntarily chosen to include  
a Group Risk Committee Report in addition  
to the disclosures in the Risk Management 
Report and Principal Risks sections. 

Throughout 2021, the Committee continued  
to monitor the impact of the Covid-19 pandemic 
on the Group’s risk environment, including the 
Group’s financial and operational resilience  
and its capital and solvency position. 

The Committee’s key responsibility is to assist 
the Board in monitoring the appropriateness 
and effectiveness of the Group’s risk strategy, 
appetite and profile; and risk management 
culture and framework. In addition,  
the Committee oversees the material risks  
of the Group. The Committee is also responsible 
for reviewing Group capital management  
and Internal Model scope, use, governance  
and validation. 

The Group’s principal risks and uncertainties  
are set out on pages 68 to 75. The Committee 
has reviewed these in detail and is comfortable 
that the business has addressed them 
appropriately within its ongoing operating 
model and identification of strategic priorities. 
The impact of the recent conflict in Ukraine  
on the principal risks was considered  
by the Committee and these are included within 
the Group’s principal risks and uncertainties.

Committee meetings
The Group Risk Committee comprised  
the Directors shown in the table above  
who were appointed by the Board.

The Committee held four meetings during  
the year, which were attended by the Group 
Chair, Deputy Group Chief Executive, Group 
Chief Risk and Compliance Officer, Group Chief 
Financial Officer, Group Underwriting Director, 
Group Chief Actuary and Group Chief  
Internal Auditor.

A focus of the Committee’s work this year 
has been monitoring the Group’s ongoing 
operational and financial resilience; and  
its capital and solvency position, in light  
of the continuing Covid-19 pandemic, receiving 
reports from management. The Committee also 
continued to monitor the ongoing development, 
governance, methodology and calibration of the 
Internal Model; overseeing validation; reviewing 
Profit and Loss Attribution and recommending 
Model changes and management actions  
to the Board.

During the year, the Committee also received  
a report on the outcome of a risk and 
compliance effectiveness review; oversaw 
projects to develop the Group’s data 
management model and a Group operational 
resilience programme; reviewed the Own 
Risk and Solvency Assessment (ORSA) and 
Control Risk Self-Assessment; and oversaw  
the continuing development of a risk oversight 
and assurance plan and the risk taxonomy.

Additionally, the Committee received regular 
reports on risk and compliance monitoring and 
breaches; underwriting and insurance risk; 
reinsurance; material outsourcing; and business 
continuity. The Committee also received the 
Money Laundering Reporting Officer’s Report 
and reviewed a financial crime continuous 
assurance plan.

The Group Chief Risk and Compliance Officer 
reports to the Committee and has direct access 
to the Committee Chair and the Non-Executive 
Directors. The Committee ensures that it meets 
with the Group Chief Risk and Compliance 
Officer at least annually without  
management present.

By order of the Board

Chris Moulder
Chair of the Group Risk Committee 
17 March 2022

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
 
 
Section Three

Governance – Group Audit Committee Report 

132

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

133
133

Group Audit
Committee Report

Chair’s overview

As Chair of the Group Audit Committee, I am pleased 
to present the Committee’s report for the year  
ended 31 December 2021. This report outlines  
the work undertaken by the Committee to safeguard 
Ecclesiastical for the benefit of its shareholder.  
The Committee plays a crucial role in oversight  
and scrutiny of the Group’s financial and regulatory 
reporting, internal and external audit arrangements, 
internal control environment and the processes  
for compliance with laws, regulation and ethical 
codes of practice.

The Committee’s duties over the last year were 
unchanged, however, there was a particular 
focus on supporting the business as it navigated 
through some of the risks and uncertainties 
arising from Covid-19. While 2021 may have 
presented less of a challenge than 2020,  
for nearly all of the Committee’s work during 
2021, Covid-19 continued to be an important 
consideration. The invasion of Ukraine by Russia 
in March 2022 caused the Committee to consider 
whether there were issues arising which might 
affect its assessment of the Company’s 2021 
Annual Report. Developments related to these 
tragic events will be kept under close scrutiny.

The Committee has reviewed the Group’s 
financial reporting, ensuring that this year’s 
Annual Report and Accounts are prepared using 
appropriate judgements and are a fair reflection 
of the Group’s performance and position.  
The significant accounting and reporting issues 
considered in detail by the Committee are set 
out on pages 136 to 138. The new insurance 
accounting standard IFRS 17 will be effective  
for the Group from January 2023 and will 
continue to be an important part of the 
Committee’s 2022 agenda. The Committee 
has also monitored internal and external audit 

arrangements and the effectiveness of internal 
controls. Additionally, the Committee has 
monitored the external environment to ensure 
that reporting and controls have continued  
to adapt and respond to developments.

The role of the Committee in the Group’s 
governance framework is vital, providing 
independent challenge and oversight across 
financial reporting and internal control 
procedures. The Committee ensures the interests 
of our shareholders are protected by providing 
independent scrutiny and challenge to ensure 
the Group always presents a true and fair view 
of its performance, with a focus on the accuracy, 
integrity and communication of its financial 
reporting. The Committee also examines the 
Group’s control environment and strategies  
for risk management, providing assurance  
these are managed appropriately. We remain 
satisfied that the business has maintained  
a robust risk management and internal controls 
culture, supported by strong overall  
governance processes.

Andrew McIntyre
Chair of the Group Audit Committee

Members of the Committee 
Committee members are independent Non-Executive Directors and have been selected with  
the aim of providing the wide range of financial, risk, control and commercial expertise necessary 
to fulfil the Committee’s duties. The Committee is also then able to challenge and scrutinise 
management’s work. Further information about the experience of each member of the Committee 
can be found on page 100. The Board considers that Andrew McIntyre has recent and relevant 
financial experience and accounting competence and that the Committee as a whole  
is appropriately competent in the sectors within which the Group operates.

The members of the Group Audit Committee who were appointed by the Board and their attendance 
at the six meetings held during the year are shown below.

Committee member

Member since

Meetings eligible  
to attend

Meetings attended

Andrew McIntyre (Chair) April 2017

Francois-Xavier 
Boisseau

Neil Maidment

Chris Moulder

March 2019 

March 2020

September 2017

6

6

6

6

6

6

5

6

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
 
Governance – Group Audit Committee Report 

134

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

135
135

Committee meetings
In addition to the members of the Committee,  
the Chair of the Board, the Group Chief Executive, 
the Group Chief Financial Officer, the Deputy  
Group Chief Executive and the Group Chief  
Internal Auditor attend meetings by invitation. 
Other relevant people from the business are  
invited to attend certain meetings in order to 
provide insight into key issues and developments. 

Auditor appointment, independence 
and non-audit services
The Committee has primary responsibility 
for overseeing the relationship with and 
performance of the external auditor. This includes 
making the recommendation on the appointment, 
reappointment and removal of the external 
auditor, assessing their independence on an 
ongoing basis and for agreeing the audit fee.

The Group’s external auditor is invited 
to attend meetings. During the year, 
PricewaterhouseCoopers (PwC) attended six  
of the Committee’s meetings. During the year,  
the Committee met privately with the Group’s 
external auditors without management present.

The Committee’s key responsibilities include:
• Monitoring the integrity of the financial 

statements;

• Challenging the Group’s financial reporting,  

and reporting upon anything that  
it is not satisfied with;

• Reviewing regulatory reports;
• Reviewing tax strategy and policies;
• Reviewing the Group’s whistleblowing 

arrangements;

• Reviewing the Group’s audit arrangements,  

both externally and internally; and

• Reviewing the effectiveness of the Group’s 

systems of internal controls and the 
management of financial risks.

When the Committee discharges its responsibilities 
these are extended to include Ecclesiastical 
Insurance Office plc’s immediate parent Benefact 
Group plc (formerly Ecclesiastical Insurance Group 
plc) and matters related to its own subsidiary 
undertakings and interests.

A summary of the main activities of the Committee 
during the year is set out below:

PwC has acted as the Group’s external statutory 
auditor following appointment at the Annual 
General Meeting in June 2020. The Group’s 
policy for auditor rotation follows regulatory 
requirements and PwC will be required  
to be rotated after no more than 20 years,  
and an audit tender held after no more than  
10 years.

Sue Morling of PwC became the Group’s Senior 
Statutory Auditor for the financial year 2020 
after PwC’s appointment. Sue Morling’s term 
as Senior Statutory Auditor cannot exceed a 
maximum duration of five years. 

The Company confirms that it complied with 
the provisions of the Competition and Markets 
Authority’s Order for the financial year under 
review. Both the Board and the external  
auditor have safeguards in place to protect  
the independence and objectivity of the  
external auditor.

The Committee is responsible for the 
development, implementation and monitoring  
of the Group’s policy on the provision  
of non-audit services by the external  
auditor. The policy is reviewed annually  
by the Committee. The purpose of the policy  
is to safeguard the independence and objectivity 
of the external auditor and to comply  
with the ethical standards of the Financial 
Reporting Council (FRC).

The Committee oversees the plan for  
the external audit to ensure it is comprehensive, 
risk-based and cost-effective. The plan described 
the proposed scope of the work and the 
approach to be taken, and also proposed  
the materiality levels to be used which are 

described in the Independent auditors’ report.  
In order to focus the audit work on the right 
areas, the auditors identify particular risk 
issues based on various factors, including 
their knowledge of the business and operating 
environment and discussions with management. 

For the year ended 31 December 2021, the Group 
was charged £946,000 (ex VAT) by PwC  
for audit services. Non-audit fees for  
audit-related assurance services required  
by legislation and/or regulation amounted  
to £214,000, making total fees from PwC  
of £1,160,000. There were no other non-audit 
services provided by PwC during the financial 
year. More detail can be found in note 12  
to the financial statements.

External audit effectiveness
The Committee assesses the effectiveness  
of the external auditor annually against  
a number of criteria including, but not  
limited to, accessibility and knowledgeability  
of audit team members, the efficiency of the 
audit process including the effectiveness  
of the audit plan, and the quality  
of improvements recommended.

The Committee reviewed a report based 
on questionnaires completed by senior 
management, business unit leaders  
and those members of staff most involved  
in the external audit process, regarding  
the PwC 2020 statutory audit. The audit 
team had been responsive and demonstrated 
flexibility in working with management  
to overcome the challenges of completing  
the majority of the audit remotely.  
The Committee recognised the strengths  
of the external auditor and that their duties 
were performed independently and effectively.

Appropriateness of the Group’s 
external financial reporting
The primary role of the Committee in relation  
to financial reporting is to review, challenge  
and agree the appropriateness of the  
half-year and annual financial statements and 
annual regulatory reporting under Solvency II, 

concentrating on, amongst other matters:
• The quality and acceptability of the Group’s 

accounting policies and practices;

• The clarity of the disclosures and compliance 

with financial and regulatory reporting 
standards, and relevant financial  
and governance reporting requirements;

• Material areas in which significant judgements 

have been made by the Group or there  
has been discussion with the external auditor;

• Whether the Group’s Annual Report  

and Accounts, taken as a whole, are fair, 
balanced and understandable and provide  
the information necessary for shareholders  
to assess the Group’s position  
and performance, business model  
and strategy; and

• Any correspondence from regulators  

in relation to financial reporting.

In respect of these annual financial statements 
the Committee paid particular attention to the 
significant judgements set out below, including  
a review of the corporate governance 
disclosures, monitoring of the external audit 
process and statements about going concern 
and the viability statement.

The Committee concluded that it remained 
appropriate to prepare the financial statements 
on a going concern basis and recommended  
the viability statement to the Board for approval.

The Committee reviewed and challenged  
the Group’s annual regulatory submissions 
under Solvency II. The Committee focused on the 
reporting requirements of the publicly filed SFCR 
and QRTs and privately filed RSR Annual Update.

The significant areas of focus considered  
by the Committee in relation to the 2021 
accounts, and how these were addressed,  
are outlined below. These were discussed  
and agreed with management during  
the course of the year, and also discussed  
with PwC. The nature of these issues and how 
they are mitigated is explained in more detail  
in the Risk Management Report, and also  
note 2 to the financial statements.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Audit Committee Report 

136
136

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

137
137

Matter considered

Action

Matter considered

Action

General insurance reserves
The estimation of the ultimate liability arising from claims  
under general business insurance contracts is a critical accounting 
estimate. There is uncertainty as to the total number of claims  
on each class of business, the amounts that such claims will  
be settled for and the timings of any payments.

The Committee considered detailed reports provided  
by the Group’s Reserving Actuary on the adequacy of the Group’s 
general insurance reserves at both the half year and the full year 
and discussed and challenged management across a wide range  
of assumptions and key judgements. 

This is a major area of audit focus and PwC also provided detailed 
reporting on these matters to the Committee.

The Committee considered the latest developments of Covid-19 
across the Group for both the business interruption and liability 
claims and acknowledges that although this remains an area  
of uncertainty for the next 12 to 18 months, the level of uncertainty 
has decreased since last year end as the reserves set up in 
2020 are running off as expected. The Committee challenged 
management on whether the current reserves appropriately take 
account of these uncertainties.

The Committee acknowledged the exceptional economic 
circumstances leading to high current and future inflation  
and how these impact both property and liability accounts across 
the group. The Committee was satisfied that management and 
the Group Reserving Actuary have considered inflation in their 
recommendations and that this will be a key area of uncertainty  
for the medium term. 

The Committee continues to maintain a focus on the longer term 
reserves relating to asbestos and PSA claims and reviewed actual 
claims experience against expectations throughout the year.  
The Committee noted and supported management’s decision  
to continue to hold an additional margin in respect of future  
PSA claims as the IICSA investigations develop. 

Following all of our reviews and discussions, the Committee’s 
opinion was that the reserving process and outcomes were  
robust and well managed and that the overall reserves  
set were reasonable as disclosed in notes 9 and 27  
of the financial statements. 

Life insurance reserves 
The calculation of the Group’s life insurance reserves requires 
management to make significant judgements about bond yields, 
discount rates, credit risk, mortality rates and current expectations 
of future expense levels.

Carrying value of goodwill
This is an area of focus for the Committee given the materiality  
of the Group’s goodwill balances (£24m as at 31 December 2021) 
and the inherent subjectivity in impairment testing.

The judgements in relation to goodwill impairment continue  
to relate primarily to the assumptions underlying the calculation  
of the value in use of the business, being the achievability  
of the business plans and the macroeconomic and related 
modelling assumptions underlying the valuation process.

The Committee considered a report from the Chief Actuary  
of Ecclesiastical Life Limited (ELL) (the Group’s life business)  
which sets out recommendations for the basis and methodology  
to apply for:

• Valuation of policy liabilities for inclusion in the report  

and accounts for ELL at 31 December 2021; and

• The calculation of technical provisions in accordance  

with Solvency II regulations at 31 December 2021.

The Committee noted that no material changes in methodology 
were proposed, for either the accounts or Solvency II reporting 
basis, from those used for the valuations at 31 December 2020.

The Committee reviewed the work done by the Chief Actuary  
to assess whether the methodology remained appropriate, with  
a particular focus on mortality assumptions (including any impacts 
from Covid-19), interest and inflation rate assumptions.

Following its review, and after consideration of PwC’s report,  
the Committee was satisfied that the assumptions proposed were 
appropriate and overall the judgements made in respect of the 
reserves were reasonable. The assumptions are disclosed in note 
27(b) of the financial statements.

The Committee received detailed reporting from management  
and challenged the appropriateness of the assumptions  
made, including:

•  The consistent application of management’s methodology;
•  The achievability of the business plans;
•  Assumptions in relation to long-term growth in the businesses  

at the end of the plan period; and
•  The determination of a discount rate.

The Committee paid particular attention to the business plans  
and management’s proposed cashflows attributable to each  
Cash Generating Unit, and the determination of the discount rate 
used in the calculation. Detailed support for these assumptions  
was provided by management.

The Committee considered the proposal and provided robust 
challenge to the assumptions, notably the evidence to support 
the discount rate and the appropriateness of the future cashflow 
assumptions. After its reviews, the Committee concluded that  
the assumptions were reasonable.

Goodwill is disclosed in note 16 of the financial statements.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Audit Committee Report 

138
138

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

139
139

Matter considered

Action

Valuation of defined benefit pension scheme liability
The Group’s liabilities of the scheme are material in comparison  
to the Group’s net asset and the valuation requires many actuarial 
assumptions, including judgements in relation to long-term interest 
rates, inflation, longevity and investment returns. 

Judgement is applied in determining the extent to which a surplus  
in the Group’s defined benefit scheme can be recognised  
as an asset.

Valuation of unlisted equity
This is an area of focus for the Committee given the materiality  
and the subjectivity in deriving fair value.

The judgements and estimates used to determine the value  
of the Group’s interest in unlisted equity follow industry recognised 
fair value model techniques and the principles of IFRS 13 Fair Value 
Measurement. Judgements and estimates include the selection  
of the most appropriate valuation approach, the set of comparable 
companies, choice of valuation multiples and the setting  
of an illiquidity discount.

Significant insurance risk
During 2021, the Group launched a new whole of life policy  
to support pre-paid funeral plan products. The specific features  
of the product and the resulting accounting treatment were an area 
of focus for the Committee.

Judgement was required when determining how the contractual 
terms of the arrangements affected the accounting treatment.

During 2021, the Committee received reports from management 
on the proposed approach to the valuation of the pension scheme. 
As the pension scheme is sensitive to changes in key assumptions, 
management completed an assessment as to the appropriateness 
of the assumptions used, taking advice from independent actuarial 
experts and including, where appropriate, benchmark data,  
and reported its findings to the Committee. Following this review, 
management concluded that a number of assumptions needed 
updating, which included a reduction in the expected long-term 
improvements in future mortality. Management also concluded  
that no weighting would be applied to 2020 mortality data  
as the long-term impacts of Covid-19 on mortality were uncertain. 

Following consideration, the Committee concluded that  
the assumptions proposed were appropriate and in line  
with normal market practice.

The impact of updating assumptions to reflect those in force  
at the balance sheet date on the valuation at 31 December 2021  
are explained in note 18 to the financial statements.

The Committee received information from management  
on the composition of the investment property portfolio  
and the methodology used to determine the fair value.  
The Committee paid particular attention to the application  
of industry recognised valuation techniques and areas  
of the portfolio more susceptible to valuation uncertainty.

When considering management’s assessment of the fair value  
of unlisted equities, the Committee considered the fair value  
model and inputs used. Particular consideration was given  
to management’s recommendations of the valuation multiple,  
the suitability of comparable companies and the discount applied 
for illiquidity.

Following consideration, the Committee concluded that  
the assumptions proposed were appropriate.

The Committee received management’s assessment of the 
arrangement and how the contractual terms of this whole of life 
policy resulted in the conclusion that the product was accounted 
for under IAS 39 Financial Instruments and not IFRS 4 Insurance 
Contracts. Particular attention was paid to whether there was 
significant insurance risk transferred from the policyholder.

When considering management’s assessment of product and  
its accounting treatment, the Committee studied the requirements 
of IAS 39 and IFRS 4 which are currently applied by the Group 
along with IFRS 9 Financial Instruments and IFRS 17 Insurance 
Contracts which are the equivalent standards the Group will  
apply from 1 January 2023. 

Following consideration, the Committee concluded management’s 
assessment that there is no insurance risk resulted in the 
appropriate accounting treatment of financial instruments. 

The Committee is constituted as a Committee 
of the Board of Directors of both Ecclesiastical 
Insurance Office plc and its immediate parent, 
Benefact Group plc (formerly Ecclesiastical 
Insurance Group plc). As a result, the Committee 
will also consider matters that are specific  
to the Group, Benefact Group plc and therefore 
items that are not included within Ecclesiastical 
Insurance Office plc’s financial statements within 
this Annual Report and Accounts. The Committee 
considered a number of accounting judgements 
and reporting matters in the preparation  
of Benefact Group’s financial results in a manner 
consistent with that set out within this report.  
This included the carrying value of goodwill  
and the accounting treatment and control  
of business combinations related to insurance 
broker businesses of that Group.

Implementation of IFRS 17 Insurance 
contracts
IFRS 17 is a new insurance accounting standard, 
issued by the International Accounting 
Standards Board (IASB). IFRS 17 will be effective 
for the Group from 1 January 2023 and will 
impact the Group’s financial reporting.

During the year, the Committee monitored 
preparedness of the implementation of IFRS 17. 
This new accounting standard is expected  
to impact the measurement and disclosure  
of the Group’s insurance business, which  
is predominantly general insurance. 

The Committee continues to assess the impact 
the new standard on the calculation of insurance 
liabilities and financial reporting processes. The 
implementation of this standard is an important 
feature on the Committee’s current agenda as 
management work to complete the changes 
required to adopt the standard and carry out  
‘dry runs’ before the effective date.

and provided feedback on early drafts  
of the Annual Report and Accounts, highlighting 
any areas where further clarity was required  
in the final version.

The Committee was provided with comprehensive 
verification of all the information and facts  
in the Annual Report and Accounts. When  
forming its opinion, the Committee reflected  
on information it had received and discussions 
 throughout the year as well as its knowledge 
of the business and its performance. A suitably 
qualified employee of the Group, who does  
not work in a financial or actuarial area and  
is not involved in the production of the Annual 
Report and Accounts or financial results, reviewed 
a near-final draft and gave their opinion  
on whether they consider it to be fair, balanced 
and understandable. Guidance on what is meant 
by these statements and aspects the employee 
might wish to consider when forming an opinion 
was provided. When forming its opinion,  
in particular, the Committee considered:

Is the report fair?
– Does the financial reporting reflect the key 
messages within narrative statements?

– Is the story complete and is there any sensitive 
material that has been omitted that should have 
been included?

– Does the Group that is portrayed in the 

Annual Report and Accounts reflect the Group 
discussed by the Committee and the Board?

Is the report balanced?
– Are the key areas of judgement included 

within any narrative reporting and significant 
matters discussed within this Committee report 
consistent with the disclosures within  
the financial statements?

– Are the significant and higher risk areas 

identified within the Annual Report and Accounts 
also those risks identified and reported by PwC.

Fair, balanced and understandable 
The Committee considered whether in its opinion, 
the 2021 Annual Report and Accounts were fair, 
balanced and understandable and provided the 
information necessary for shareholders to assess 
the Group’s position and performance, business 
model and strategy. The Committee has reviewed 

Is the report understandable?
– Does the reporting focus on the more  

significant items and not become obscured  
with immaterial detail?

– Are the important messages highlighted  

up front?

– Does the report use clear and concise language 

and provide simple explanations of topics? 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Audit Committee Report 

140
140

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

141
141

The Committee was satisfied that the disclosures 
in the Annual Report and Accounts, taken  
as a whole, are fair, balanced and understandable 
and represented the results and business 
performance for the year ended  
31 December 2021.

• Any unauthorised acquisition, use or disposal 

of the Group’s assets that could have a material 
effect on the financial statements should  
be detected on a timely basis;

• Transactions are recorded as required to permit 

the preparation of financial statements; and

Oversight of the Group’s systems  
of internal control including  
the internal audit function
Assessment of internal controls
The Group’s approach to internal control  
and risk management is set out in the Corporate 
Governance Report.

In reviewing the effectiveness of the system  
of internal control and risk management during 
2021, the Committee has:
• Reviewed the findings and agreed management 
actions arising from both external and internal 
audit reports issued during the year;

• Monitored management’s responsiveness  

to the findings and recommendations  
of the Group Chief Internal Auditor;

• Met with the Group Chief Internal Auditor once 
during the year without management being 
present to discuss any issues arising from 
internal audits carried out; and

• Considered a report prepared by the Group 
Chief Internal Auditor giving his assessment  
of the strength of the Group’s internal controls 
based on internal audit activity during the year.

Internal control over financial reporting
Internal control over financial reporting  
is a process designed to provide reasonable,  
but not absolute, assurance regarding  
the reliability of management and financial 
reporting in accordance with generally accepted 
accounting principles. Controls over financial 
reporting policies and procedures include  
controls to ensure that:
• Through clearly defined role profiles  

and financial mandates, there is effective 
delegation of authority;

• There is adequate segregation of duties  
in respect of all financial transactions;

• Commitments and expenditure are appropriately 

authorised by management;

• Records are maintained which accurately  

and fairly reflect transactions;

• The Group is able to report its financial 
statements in compliance with IFRS.

Due to inherent limitations, internal control  
over financial reporting may not prevent  
or detect misstatements. Risk management  
and control systems provide reasonable 
assurance that the financial reporting does 
not contain any material inaccuracies.  
Through its review of reports received from 
management, along with those from internal  
and external auditors, the Committee did not 
identify any material weaknesses in internal 
controls over financial reporting during the 
year. The financial systems are deemed to have 
functioned properly during the year under review, 
and there are no current indications they will  
not continue to do so in the forthcoming period.

Group Internal Audit (GIA)
GIA is monitored by the Committee and provides 
independent, objective assurance to the Board 
that the governance processes, management  
of risk and systems of internal control  
are adequate and effective to mitigate  
the most significant risks to the Group.  
GIA operate a co-sourcing arrangement in the UK  
and Ireland where specialist resource is required 
to supplement existing resources. In addition,  
GIA oversees and monitors the outsourced internal 
audit arrangements in Australia and Canada.

The Committee has oversight responsibility for 
GIA and is satisfied that GIA has the appropriate 
resources. The Group Chief Internal Auditor  
is accountable to the Committee Chair, reports 
administratively to the Group Chief Financial 
Officer and has access to the Group Chief 
Executive and the Chair of the Board. The function 
also has an extensive stakeholder management 
programme across the whole of the Group.

GIA’s annual programme of work is risk based  
and designed to cover areas of higher risk  
or specific focus across the Group. The plan  

is approved annually in advance by the 
Committee and is regularly reviewed throughout 
the year to ensure that it continues to reflect 
areas of higher priority. Where necessary, 
changes to the agreed plan are identified  
as a consequence of the Group’s changing 
risk profile. GIA continued to focus on the 
highest areas of risk within the Group such 
as Cyber Security, Operational Resilience, 
Disaster Recovery and the firm’s major change 
programmes .

Throughout the year, GIA submitted quarterly 
reports to the Committee summarising findings 
from audit activity undertaken and the responses 
and action plans agreed with management. 
During the year, the Committee monitored 
progress of the most significant management 
action plans to ensure that these were completed 
in a timely manner and to a satisfactory standard.

Whistleblowing
During the year, the Committee continued 
to perform regular oversight of the Group’s 
whistleblowing arrangements, which are the 
responsibility of the Board and overseen by 
Group HR. Actions during 2020 had focused  
on ensuring an environment in which 
whistleblowing is well understood, openly 
communicated and that a positive culture  
for raising concerns was promoted. 

During 2021 and following the roll out  
of a targeted set of actions designed to improve 
both accessibility and understanding across 
the Group, an independent assessment was 
undertaken and overseen by the Committee 
to establish whether these actions had raised 
awareness and understanding. The assessment 
found that engagement, understanding 
and governance had significantly improved, 
supporting a culture of openness where 
colleagues feel confident and safe to speak  
up and challenge when and if they need to.

The Group now has an established annual 
whistleblowing activity cycle encompassing 
training, communication and monitoring. Online 
training modules for all colleagues and managers 
in both Whistleblowing and Code of Conduct 
increase and maintain awareness and emphasise 

an open and positive culture. Individual attestation 
and quarterly reporting ensure the continued 
close monitoring of whistleblowing activity and 
understanding across the Group. These annual 
actions are reinforced by regular colleague 
communications and awareness raising activities. 

Our whistleblowing procedures, polices  
and guides are also reviewed and updated 
annually to ensure that, in line with best practice, 
they are accessible, easily understood and  
are aimed to encourage and give confidence  
to potential whistleblowers. 

More information about the Group’s 
whistleblowing policy and arrangements  
is included within the Corporate  
Governance Report.

Legal and regulatory developments
The Committee receives regular reports  
and considers the impact of legal and regulatory 
developments on the UK Group to control legal 
and regulatory risk. It monitors the application  
and impact of any actions required by the 
business or organisation through to completion. 
Reports are shared with relevant business  
areas, and with relevant subsidiary Boards  
and Board Committees.

The year ahead
In 2022, the Committee will continue to provide 
oversight of financial reporting and internal 
controls of the Group. Key areas of focus for  
the Committee will be the Group’s implementation 
of IFRS 17, effective from 1 January 2023,  
and the increasing maturity of the control 
environment, the resourcing and scope of work  
of GIA as the Group continues to expand,  
and continued close attention to geo-political 
events which might impact on the Group’s 
operations and stakeholder reporting.

The Committee remains committed to its role  
in overseeing the integrity of financial reporting 
and effectiveness of controls.

Andrew McIntyre
Chair of the Group Audit Committee 
17 March 2022

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

142

143

Group Remuneration Report

Group Remuneration 
Committee Chair’s 
statement

As Chair of the Group Remuneration Committee 
(the Committee), I am pleased to introduce  
the Group Remuneration Report for 2021  
and to highlight some of the key aspects  
of the Committee’s work during the year.  
I was appointed as Chair of the Committee  
on 8 September 2021, having been a member  
of the Committee since 2020. I would like  
to take this opportunity to thank Caroline Taylor 
for her leadership of the Committee over  
the last two years and her ongoing support  
of the Committee’s work. 

2021 performance and incentive outcomes 
2021 saw the Group recover strongly from  
the challenges caused by Covid-19 over  
the previous year. The Group reported a profit 
before tax of £77.0m in 2021. This positive 
financial performance was driven by strong 
investment returns, as markets bounced back, 
and a solid underlying underwriting result  
of £8.8m (2020: £12.1m). The Group delivered 
Gross Written Premium (GWP) growth of 11% 
to £486m (2020: £437m) supported by strong 
retention and new business in the UK and 
Canada. Our broking business performed above 
expectation, with SEIB reporting a profit before 
tax of £3.2m. Lycetts, owned by Benefact Group, 
reported a profit before tax of £3.2m, well ahead 
of the £1.1m in the previous year. Our award 
winning investment management business, 
EdenTree, had another excellent year, achieving 
record inflows and exceeding fund benchmarks. 
These excellent results enabled the Group  
to award a grant of £21m to our owner Benefact 
Trust, together with a further grant of £5m  
in 2022 in respect of its 2021 performance.

2021 continued, however, to be a challenging 
year for customers, brokers, business partners 
and colleagues alike. The Committee note with 
pride and thanks the outstanding efforts of all 
our colleagues across the Group in continuing 
to deliver what matters most to the business, 
supporting our customers and delivering  
on the Group’s purpose, strategy and ambition 
for the future. Our colleagues’ dedication  
to providing excellent customer service is borne 
out by an outstanding 98% of customers and 
brokers who report they are satisfied with  
the service they receive from Ecclesiastical. 
This level of delivery is reflected in the Group’s 
performance against its customer and conduct 
targets for the year.

2021 was a transformational year for the Group, 
with significant progress on the Group’s strategic 
initiatives and the launch of a new and ambitious 
Group strategy which aims to raise £250m  
for good causes by the end of 2025. Alongside 
the launch of the new Ecclesiastical brand  
and the opening of our head office, 2021 saw  
us continue to invest in systems and technology 
to improve the broker and customer experience; 
to grow our Broking and Advisory business;  

and to strengthen the team and fund portfolio  
of our EdenTree business. During 2021,  
as part of our commitment to making a properly 
responsible environmental, as well as social, 
impact, we built on our existing membership 
of ClimateWise and the pioneering work of 
EdenTree in the field of ESG investments 
through the adoption of a new responsible and 
sustainable investment strategy; improvements 
to the way we measure our climate impact; 
and the integration of our environmental 
commitments into our remuneration schemes  
for 2022 and beyond.

In considering the annual bonus outcomes  
for Executive Directors, the Committee reflected 
on the financial, underwriting, strategic, customer 
and conduct performance of the Group including 
the reported profit before tax of £77.0m, solid 
performance against Group COR targets,  
and the continuing strong delivery against  
the Group’s strategic change programme  
and customer and conduct targets. In its 
assessment of individual performance during 
the year, the Committee recognised the excellent 
performance against Executive Directors’ 
personal financial, strategic and wider objectives. 
The Committee considered that the annual 
bonus outcomes were a fair reflection  
of the overall performance achieved and,  
having considered all the relevant factors, 
determined that no discretionary adjustment  
of awards was necessary.

The annual bonus awards for 2021 of 87.5% 
of maximum (which is 100% of salary) for the 
Group Chief Executive; 84.4% for the Deputy 
Group Chief Executive; and 71.9% for the Group 
Chief Financial Officer reflected the strong 
performance of the Group during the year. 
Further details of performance against the 
targets set for 2021 are disclosed on page 166  
of this report. 

In view of the Group’s reported results for 2020, 
35% of the awards for Executive Directors under 
the 2020 plan were deferred for one year, 
subject to the Group returning to profit in 2021.  
In light of the Group’s welcome return to profit  
in 2021, the Committee has approved payment  
of the 2020 deferred awards.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section Three 
 
 
 
 
 
 
 
 
Governance – Group Remuneration Report

144

145

The long-term incentive plan (LTIP) granted 
in 2019 vested at 47.0%, reflecting the Group’s 
performance against the financial, strategic, 
customer and conduct targets over the  
2019-2021 period. The Committee considered 
that the LTIP awards were a fair reflection  
of the overall performance achieved and,  
having considered all the relevant factors, 
determined that no discretionary adjustment  
of awards was necessary.

In line with the Committee’s established practice, 
the Committee, supported by the Group Chief 
Risk and Compliance Officer, considered risk 
management outcomes across the Group  
as part of its deliberations, including how  
these had impacted individual performance 
assessments where relevant. Following this 
review, the Committee did not consider further 
risk adjustment of the awards to be necessary. 

Base salary
The level of salary increases for UK 
Ecclesiastical employees is a key consideration 
in setting the level of any salary increase  
for Executive Directors. After careful 
consideration the Committee determined that 
the base salaries of Executive Directors would 
be increased by 5.0% (effective 1 April 2022)  
in line with the wider workforce.

Key Committee activities during the year
During 2021 the Committee undertook  
a strategic review of the Group’s remuneration 
policy and incentive design, including  
the applicable performance measures  
and targets, in order to ensure these continue 
to drive the Group’s strategy and long-term 
performance, including in respect of ESG  
and climate change considerations. The review 
was underpinned by the following principles: 
fair reward; simplification of the Group’s 
incentive arrangements; compliance with 
evolving regulatory and corporate governance 
requirements; linking pay and performance; 
alignment of incentive designs with the Group’s 
strategy and with shareholder expectations;  

and consideration of the reputational impact  
of any changes. As part of this strategic review 
the Committee consulted with the Group’s 
charitable owner and ultimate shareholder 
Benefact Trust Limited (previously Allchurches 
Trust Limited) and the Committee are grateful  
for their support and counsel. 

The 2022 Group Management Board (GMB) 
annual bonus applicable to Executive Directors 
and members of the Group’s leadership team 
includes stretching targets in relation  
to the delivery of profit; the Group’s growth 
strategy; and its strategic change programme. 
The new Greater Good measure supports  
the Group’s ambition to build a Movement  
for Good, incentivising delivery of its charitable 
giving programme; exceptional customer 
service; and the highest standards of conduct 
and governance. In line with evolving market 
practice, deferral of bonuses is increased  
to one third of the total annual bonus awarded, 
with deferral continuing to be over a period  
of three years.

The award level applicable to Executive 
Directors under the 2022–2024 Group LTIP  
is increased to 180% for the Group Chief 
Executive; and 120% for the Deputy Group  
Chief Executive and Group Chief Financial 
Officer. The 2022–2024 Group LTIP is subject  
to performance measures which incentivise  
the delivery of the Group’s return on capital 
targets; the growth strategy applicable to each 
of the Group’s divisions; the delivery of grants  
to Benefact Trust Limited to support  
its charitable work; and the Group’s climate 
change targets for the period ahead.

Full details of the revised incentive 
arrangements applicable to Executive Directors 
and the Group’s senior leaders are set out  
on page 156.

The Committee determined that the 
remuneration packages of Executive Directors 
remain appropriately aligned with the Group’s 

strategic objectives and reflect both the 
experience and track record of the Executive 
Directors and comparative benchmarking.  
The pension contribution rate for the Group 
Chief Executive was reviewed during the year 
and will be aligned with the wider workforce 
rate of 12% of salary with effect from April 2022.

During 2021 the Committee also considered  
the remuneration packages for a number  
of its Material Risk Takers, ensuring that these 
remained in line with evolving responsibilities 
and market benchmarks. 

The Group’s gender pay report for 2021 showed 
a continuing improvement in the Group’s gender 
pay gap. The actions the Group has taken have 
resulted in a higher proportion of women filling 
senior roles over time and this has contributed 
to our median gender pay gap reducing for  
a fifth consecutive year to 20.4%, from 21.1%  
in 2020. The Group continues to be committed 
to promoting inclusion and diversity through 
our business and to ensuring that all employees 
have a fair and equal pay opportunity 
appropriate to their role. 

The regulatory and corporate governance 
environment in which the Group operates 
continues to evolve. During 2021, the Committee 
considered the implications of the Investment 
Firms Prudential Regime on remuneration 
policy; the BEIS white paper on ‘Restoring trust 
in audit and corporate governance’; and the 
Regulators’ proposals on improving diversity 
and inclusion in financial services. 

Conclusion
Finally, I value the continued support and 
counsel of our charitable owner and ultimate 
shareholder Benefact Trust Limited, and remain 
mindful of our responsibilities to drive sustained 
and improved performance over the long term 
through our remuneration strategy, policy  
and principles.

Sir Stephen Lamport
Chair of the Group Remuneration Committee
17 March 2022

Committee member 

Member since 

Meetings eligible  Meetings 
attended
to attend 

Sir Stephen Lamport (Chair)1 
David Henderson 
Neil Maidment2 
Angus Winther 
Caroline Taylor3 

June 2020 
September 2016 
March 2020 
April 2019 
November 2014 

7 
7 
7 
7 
5 

7
7
6
7
5

1  Sir Stephen Lamport was appointed the Chair of the Committee on 8 September 2021.

2  Neil Maidment was unable to attend a meeting due to a prior commitment.

3  Caroline Taylor stepped down as Chair and member of the Committee on 8 September 2021.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
 
Governance – Group Remuneration Report

146

147

Group Remuneration Committee
Purpose and membership 
The Committee is responsible for recommending 
to the Board the Remuneration Policy  
for Executive Directors and for setting  
the remuneration packages for each Executive 
Director, members of the Group Management 
Board (GMB), Material Risk Takers and heads  
of strategic business units. None of the Executive 
Directors were involved in discussions relating  
to their own remuneration. The Committee  
also has overarching responsibility for  
the Group-wide Remuneration Policy.

During 2021, the Committee held seven 
meetings in total. The Group Remuneration 
Committee members and their attendance  
at meetings during the year are set out  
in the table above. All members are independent  
Non-Executive Directors (NED) and have the 
necessary experience and expertise to meet 
the Committee’s responsibilities. There was 
cross membership of the Group Risk Committee 
and the Committee to promote alignment of 
the Group’s Risks and Remuneration Policies 
and consideration of Risk management and 
outcomes in setting reward.

Remuneration Committee timetable
The table below sets out some of the key agenda items discussed at each Committee meeting 
during 2021.

Meeting

Key discussion points

February 2021

•  2021 annual bonus and 2021-2023 LTIP design and targets
•  2021 Lycetts annual bonus design
•  2020 Directors’ Remuneration Report
•  Material Risk Taker list
•  Evaluation of Committee performance

February 2021

•  2021 annual bonus and 2021-2023 LTIP design and targets
•  2020 annual bonus and 2018-2020 LTIP outcomes

March 2021

April 2021

July 2021

October 2021

November 2021

•  2020 annual bonus and 2018-2020 LTIP outcomes
•  Review of 2021 salary proposals
•  2020 Directors’ Remuneration Report
•  Material Risk Taker list
•  2021 Committee objectives

•  Strategic review of remuneration

•  Strategic review of remuneration
•  Review of executive remuneration trends and market practice
•  Wider employee trends and policies
•  Remuneration Policy review and Remuneration Policy Statement
•  Review of remuneration packages for Material Risk Takers
•  Material Risk Taker list

•  Strategic review of remuneration
•  Performance management policy
•  Deferral policy

•  Strategic review of remuneration
•  Update on 2021 GMB pay outturns
•  Wider employee remuneration trends and pay
•  2021 Directors’ Remuneration Report
•  Material Risk Taker list
•  Gender pay gap reporting
•  Annual audit of EdenTree remuneration policy
•  Review of remuneration packages for Material Risk Takers
•  Annual review of Remuneration Committee Terms of Reference

Advisers to the Committee
Having stepped down as Chair and member 
of the Committee in September 2021, Caroline 
Taylor acted as an advisor to the Committee 
for the period October 2021 to February 2022 
to support the strategic review of the Group’s 
remuneration policy.

During the year, the Committee received 
external advice from Deloitte in relation  
to the strategic review of remuneration;  
the determination of appropriate remuneration 
packages for Executive Directors, members  
of the GMB and heads of strategic business 
units; and remuneration market trends  
and regulation. The Committee also had access 
to benchmarking reports from Willis Towers 
Watson and McLagan, which provide additional 
data to support the determination of pay  
and conditions throughout the Group.

Fees for professional advice to the Committee 
paid to Deloitte were £137,250 (2020: £99,222). 
The Committee is satisfied that the advice 
received during 2021 from Deloitte  
was impartial.

To assist its work, the Committee received input 
from the Group Chief Executive, Group Chief 
Financial Officer, Group HR Director, Group Chief 
Risk and Compliance Officer and Group Reward 
Director. Such input, however, never relates  
to their own remuneration.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

148

149

Remuneration ‘At a Glance’ – Remuneration Policy summary and implementation for 2022
During 2021 the Committee undertook a strategic review of and consulted with the shareholder regarding remuneration  
policy and incentive design to ensure these continue to drive the Group’s strategy and long-term performance. The principles  
which underpin the Group’s reward structures for all Group employees are set out in full on page 150. The table below sets  
out the key features of the revised remuneration policy and how it will be implemented in 2022. 

Element of pay Operation 

Base Salary

Reviewed annually with any increases normally taking effect in April.

Benefits

Pension

Annual Bonus

Long-term 
incentive plan

Benefits normally comprise a car allowance, a private healthcare 
scheme, income protection, life assurance, medical assessments,  
and other benefits cover on the same basis as the wider  
employee population.

For 2021, the employer contribution rate to the UK Defined 
Contribution Scheme for Executive Directors appointed prior to 2019  
is 15% and for Executive Directors appointed from 2019 is 12%  
of salary, in line with the wider employee population. A cash allowance 
can be paid where pension contributions would be in excess  
of the HMRC annual and/or lifetime allowance. 
The employer contribution rate to the Canada Defined Contribution 
Pension plan is 12% of salary subject to the government’s annual 
contribution limits. Amounts in excess are contributed to a SERP.

Maximum opportunity of 100% of salary of which 50% is payable  
for a target level of performance.
Targets are set annually and award levels are determined based  
on one-year performance against these targets. 
For 2021, these were: 
i)  Benefact Group (BG) PBT (including fair value investment  

gains/losses);

ii)  Group Combined Operating Ratio (COR);
iii)  Underwriting balanced scorecard;
iv)  Strategic targets;
v)  Customer and conduct targets; and
vi)  Personal performance targets.
Any bonus earned in excess of 75% of maximum opportunity  
is deferred over three years. Malus and clawback provisions apply.

The awards are granted annually and operate in three-year periods. 
Under the rules of the LTIP applicable in 2021, awards can be made  
of up to 150% of salary in the case of the Group Chief Executive and  
of up to 100% of salary in the case of other Executive Directors.
Targets are set annually for each successive three-year LTIP period. 
For 2021-23, the measures were: 
i)  Group BG PBT (including fair value investment gains/losses); 
ii)  Group BG PBT (excluding fair value investment gains/losses); 
iii)  Group COR; 
iv)  Strategic targets; and
v)  Customer and conduct targets.
Malus and clawback provisions apply.

Implementation 
 for 2022

•  CEO: £498,800
•  Deputy CEO: £407,433
•  Group Chief Financial Officer: £322,900

The Canadian branch car allowance applicable  
to the Deputy CEO increases to £17k.

With effect from April 2022 the employer pension 
contribution rate for Executive Directors appointed 
before 2019, applicable to the Group Chief Executive, 
reduces to 12% of salary, in line with the wider 
employee population.

The maximum and target opportunities are 
unchanged for 2022, with targets for 2022 being:
i)  Group BG PBT (including fair value investment 

gains/losses);

ii)  Group BG PBT (excluding fair value investment 

gains/losses);

iii)  Underwriting balanced scorecard;
iv)  Gross New Money;
v)  Broking and Advisory turnover;
vi)  Strategic targets;
vii)  Greater Good targets; and
viii)  Personal performance targets.
One third of total bonus earned is deferred over three 
years. Malus and clawback provisions apply.

Under the rules of the LTIP applicable in 2022, 
awards can be made of up to 180% of salary in the 
case of the Group Chief Executive and of up to 120% 
of salary in the case of other Executive Directors.
The measures applicable to the 2022-2024 LTIP 
period are:
i)  Group BG PBT (including fair value investment 

gains/losses); 
ii)  Return on Capital; 
iii)  Underwriting profit;
iv)  EdenTree revenue;
v)  Broking and Advisory turnover; 
vi)  Grant to Benefact Trust Limited; and 
vii)  Environmental targets. 
Malus and clawback provisions apply.

Remuneration ‘At a Glance’ – variable pay outturns

Annual bonus outturn for the year ending 31 December 2021
Further details including information on the performance assessment of the strategic  
and customer and conduct metrics are set out on page 166 in this report.

Threshold (0.5x) Target 

Maximum (1.5x) Weighted multiplier

Group BG PBT 
(including fair value investment 
gains/losses)

£7.6m

(1.0x)

£37.4m

£73.8m

0.60

Actual £83.6m

Group COR

97.0%

91.3%

86.3%

Actual 96.8%

Underwriting balanced  
scorecard

Strategic Targets

50%

50%

75%

100%

Actual 90.8%

75%

100%

Actual 90.0%

Customer and Conduct

85%

90%

100%

Actual 99.0%

Total

0.10

0.13

0.20

0.22

1.25

2019-2021 LTIP Outturns
Further details including information on the performance assessment of the strategic  
and customer and conduct metrics are set out on page 169 in this report.

Group BG PBT 
(excluding fair value  
investment gains/losses)

Group BG PBT 
(including fair value  
investment gains/losses)

Threshold 
(20% vesting)

Target 
(50% vesting)

Maximum  
(100% vesting)

Percentage vesting

£82.4m

£114.1m

£156.2m

-

Actual £58.6m

£70.9m

£117.6m

£189.8m

63%

Actual £135.7m

Group COR

96.6%

93.6%

89.3%

41%

Strategic Targets

50%

75%

100%

Actual £94.5%

Customer and Conduct

85%

90%

100%

Actual £97.3%

Actual £91.8%

Total 

84%

87%

47%

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

150

151

6. Reward structures will achieve a balance 

between short- and long-term incentives, 
supporting the overall aim of the Group’s 
Remuneration Policy of promoting the 
long-term success of the Group. The balance 
between short- and long-term incentive pay 
is largely driven by role and seniority, with 
generally a greater contribution to reward 
provided by long-term incentives for  
more senior employees.

7.  Ecclesiastical is committed to ensuring that 
all employees have a fair and equal pay 
opportunity appropriate to their role. 

8. The Group will strive to adhere to the highest 
standards of remuneration-related regulatory 
compliance and best practice guidelines, 
while ensuring that the Group’s remuneration 
policies are appropriately tailored to its 
circumstances, challenges and strategic goals.

9. The Group holds itself to the high standards  

of corporate behaviour as a trusted, 
ethical and socially responsible business 
and is mindful of the need to maintain and 
build on these standards, and to avoid 
risk of reputational damage to the Group 
and Benefact Trust Limited through the 
implementation of its remuneration policy.

Directors’ Remuneration Policy 
The Directors’ Remuneration Policy (the ‘Policy’) 
described in this part of the report is intended  
to apply for up to three years from January 2022. 
The Policy is aligned to delivery of the Group’s 
strategic objectives and establishes a set  
of principles which underpin the Group’s reward 
structures for all Group employees. 

1.  Reward structures will promote the delivery  

of long-term sustainable returns, and 
take into account the expectations of the 
shareholder. As such, the performance 
measures in the annual bonus and LTIP  
will reflect and support the Group’s  
underlying strategic goals and risk appetite 
and are comprised of both financial and  
non-financial targets.

2. Reward payments will be performance-

related, reflecting individual and business 
performance, including both what has  
been delivered and the way in which such 
deliveries have been achieved. However,  
the Group will adopt a prudent and considered 
approach when determining what portion  
of an employee’s package should  
be performance-linked and/or variable  
so as to ensure that irresponsible conduct  
and behaviours are neither encouraged  
nor rewarded and that customer experience  
is not prejudiced in any way by the operation  
of its pay arrangements.

3. Reward structures will be straightforward  
and simple for everyone to understand.

4. Remuneration packages will be set  

by reference to levels for comparable  
roles in comparable organisations.  
However, benchmark data will be only  
one of a number of factors that will  
determine remuneration packages. 

5. Reward structures will deliver an appropriate 

balance of fixed to variable pay in order 
to foster a performance culture, with the 
proportion of ‘at risk’ pay typically increasing 
with seniority. However, high levels of leverage 
are not appropriate for the Group.

Balancing short- and long-term remuneration
The Committee has established the remuneration 
elements set out in this report in line with 
the Group’s Remuneration Policy principles 
described above. Fixed annual elements including 
salary, pension and benefits, are set in order  
to recognise the responsibility and experience 
of the Group’s Executive Directors and to ensure 
current and future market competitiveness.  
The annual and long-term incentives are set 
in order to incentivise and reward the Group’s 
Executive Directors for making the Group 
successful on a sustainable basis. 

When determining remuneration policy  
for Executive Directors, the Committee considers 
the following factors, which are embedded  
in the Group’s principles:

•  Clarity and simplicity – that remuneration 

arrangements are straightforward  
and simple for everyone to understand, 
providing transparency for executives  
and our shareholder regarding the business 
and individual performance sought.

•  Risk – that incentive plans are designed  
to manage and mitigate the reputational  
and other risks that can arise from excessive 
rewards, together with the behavioural risks. 

•  Predictability – that the range of possible 

values of reward for performance outcomes 
together with the limits and discretion 
applicable to the remuneration arrangements 
are identified and clearly explained.

•  Proportionality – that the link between 

individual remuneration outcomes and the 
delivery of the Group’s strategy and long-term 
performance is clear and that remuneration 
outcomes are proportionate and do not reward 
poor performance.

•  Alignment to culture – that remuneration 
arrangements drive behaviours consistent 
with the Group’s purpose, values, culture 
and strategy, with remuneration outcomes 
reflecting both what has been delivered  
and the way in which such deliveries have 
been achieved.

The Committee reviews the Group’s 
Remuneration Policy on a regular basis to ensure 
that it remains aligned with the needs of the 
Group and its longer-term strategy and that  
it remains appropriately aligned with  
the external market. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

152

153

Future policy table (Executive Directors)

How the element supports the 
Group’s strategic objectives

Operation of the element

Maximum potential value and payment at threshold

Performance measures used, weighting 
and time period applicable

Salary
To support the attraction  
and retention of talent  
with the capability to deliver 
the Group’s strategy  
and performance goals.

Benefits
To provide a market-competitive 
and cost-effective benefits 
package and promote the 
wellbeing of employees. 

Pension
To provide market-competitive 
and cost-effective  
post-retirement benefits. 

Salaries are normally reviewed annually with any changes 
normally taking effect from 1 April each year.  

Group and individual performance

When the annual review is conducted various factors  
are taken into account, including Group and individual 
performance, any changes to the scope or responsibilities 
of the role, relevant market information and levels of pay 
increases in the wider UK or relevant territory population.

Salary increases will normally be in line with the increase 
applicable to the wider employee population, but higher salary 
increases can be awarded in certain circumstances such  
as (but not limited to) where there is an increase in scope  
of role or responsibility; due to performance in the role;  
or where there has been an increase in the size and/or 
complexity of the business.

Benefits normally comprise a car allowance, a private healthcare 
scheme, income protection and medical assessments. Executive 
Directors also receive life assurance cover on the same basis  
as the wider employee population and in the case of the Deputy 
Group Chief Executive, health and dental cover and accidental 
death and dismemberment cover on the same basis as the wider 
employee population in the Group’s Canadian branch. 

UK Defined Contribution Scheme: UK-based Executive Directors 
are eligible to participate in the Group Personal Pension plan. 
Contributions are made by the employee and employer.  
A cash allowance can be paid where pension contributions  
would be in excess of the HMRC annual and/or lifetime allowance.  
The cash allowance is equal to the employer contribution rate,  
net of employer’s national insurance contributions.

Canadian EIO plc Defined Contribution Pension plan:  
the Canadian Defined Contribution plan is applicable  
to Ecclesiastical’s Canadian staff. The Deputy Group Chief  
Executive participates under this plan and does not participate  
in the UK Defined Contribution Scheme. Contributions are made  
by the employer. 

Benefits are set at a level taking into account benefit packages 
offered by comparable organisations for comparable roles; 
benefits offered to the wider employee population and with  
the overall objective of promoting the wellbeing of employees. 
The costs are those relating to providing the benefit.

Not applicable

Not applicable

The level of pension contribution is set at a level taking into 
account pension benefits offered by comparable organisations 
for comparable roles and benefits offered to the wider 
employee population.

The employer contribution rate to the UK Defined Contribution 
Scheme for Executive Directors is 12% of salary, in line with  
the wider employee population.

The employer contribution rate to the Canada Defined 
Contribution Pension plan is 12% of salary subject  
to the government’s annual contribution limits.  
Amounts in excess are contributed to a SERP.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

154

155

Future policy table (Executive Directors) continued

How the element supports the 
Group’s strategic objectives

Operation of the element

Maximum potential value and payment at threshold

Performance measures used, weighting 
and time period applicable

GMB annual bonus 
scheme 
To incentivise delivery  
of the Group’s key financial and 
strategic targets over the year.

Deferral provides further 
alignment with shareholder 
interests and promotes 
retention.

Group LTIP
To focus the executives and 
incentivise the achievement 
of the Group’s long-term 
objectives; to align the 
Executive Directors’ 
interests with those of the 
shareholder and to promote 
attraction and retention  
of talented individuals.

This cash bonus is paid annually, normally three months  
after the end of the financial year to which it relates.  
Targets are set annually and award levels are determined  
by the Committee based on performance against these targets.

One third of total bonus earned is deferred over three years. 

Maximum opportunity of 100% of salary of which 50%  
is payable for a target level of performance. 

Cash awards under the Group LTIP vest dependent  
on the Committee’s assessment of performance against the 
performance conditions over the relevant three-year period. 
Targets are set annually for each successive three-year  
LTIP period.

Under the rules of the LTIP, awards can be made  
of up to 180% of salary in the case of the Group Chief 
Executive and of up to 120% of salary in the case  
of other Executive Directors. 

At on-target performance, a target opportunity of 50% 
of the award applies. Threshold business performance 
results in vesting of no more than 20% of the award.

The GMB annual bonus is subject to a range of challenging 
financial and non-financial metrics linked to key strategic priorities.
For 2022, these are:
•  Group BG PBT (including fair value investment gains/losses);
•  Group BG PBT (excluding fair value investment gains/losses);
•  Underwriting balanced scorecard;
•  EdenTree Gross New Money;
•  Broking and Advisory turnover;
•  Strategic targets;
•  Greater Good targets; and
•  Personal performance targets.

The Group LTIP is subject to a range of challenging financial and 
non-financial conditions linked to key strategic priorities.
For 2022 awards relating to the performance period 2022-2024, 
the following performance conditions will apply:
•  Group BG PBT (including fair value investment gains/losses); 
•  Return on capital;
•  Underwriting profit;
•  EdenTree revenue;
•  Broking and Advisory turnover;
•  Grant to Benefact Trust Limited; and 
•  Environmental targets.

Notes to policy table
Performance measures and targets

During 2021 the Committee undertook a strategic 
review of remuneration policy and incentive  
design, including the applicable performance 
measures and targets, in order to ensure these 
continue to drive the Group’s strategy and long-
term performance. The Committee selected  
the performance conditions set out in the table 
above because they are central to the Group’s  
new strategy and are key metrics used  
in measuring the performance of the Group.  
As part of this strategic review the Committee 
consulted with the Group’s charitable owner  
and ultimate shareholder Benefact Trust Limited 
and the Committee are grateful for their support 
and counsel. The Committee additionally sought 
input from the Group Chief Risk and Compliance 
Officer, in particular regarding the extent to which 
the revised schemes operate within the Group’s 
risk appetite.

The Committee is of the opinion that  
the performance targets are commercially 
sensitive to the Group and that disclosure  
at the beginning of the financial year may  
be detrimental to its interests.
The Committee will keep this under review. 
Meanwhile targets will be disclosed  
at the end of the relevant financial year in that 
year’s Remuneration Report provided they  
are not considered commercially sensitive at that 
time. Performance conditions under annual bonus 
and LTIP schemes may be amended or substituted 
by the Committee if an event occurs, or other 
exceptional circumstances arise, which cause  
the Committee to determine an amended  
or substituted performance condition would  
be more appropriate. 

Remuneration Committee discretion, malus  
and clawback provisions 
The Committee has discretion to reduce any 
annual bonus and LTIP prior to award in certain 

circumstances, including (but not limited to) 
where: 

(i)  There are material issues regarding  
the Group’s underlying financial 
strength and position (including  
if the Group has made a loss); 
(ii)  There is actual or potential material 

regulatory censure; 

(iii)  The Group is in material breach  

of its risk policies (including conduct 
risk) and/or its values and ethics; 
(iv)  There is material reputational damage 
or a material diminution in the regard  
by which the Group is held  
by its customer base; or 

Bonus already paid or deferred,  
LTIP already vested and any unvested LTIP  
are subject to malus and clawback  
in certain circumstances, including  
(but not limited to) where: 

(i)  There are issues regarding the material 
accuracy of the calculated award;
(ii)  There is material regulatory censure,  
or material reputational damage  
or a material diminution in the regard  
by which the Group is held by  
its customer base;

(iii)  There is material non-adherence  

to the Group’s risk guidance, limits and 
/or tolerances (including conduct risk);

(v)  There is a material reduction in the 

(iv)  The Group or any company within  

Group’s and/or any regulated entity’s 
Solvency ratio and/or a material 
reduction in EdenTree’s capital base 
and/or a material reduction in the 
Group’s credit rating.

the Group suffers a material failure  
of risk management;

(v)  There is reasonable evidence  

of misbehaviour or material error  
on the part of a scheme participant; 

(vi)  There is a corporate failure of the Group 
and/or any company within the Group 
and/or there has been unreasonable 
failure to protect the interests  
of employees and customers; or
(vii) (In relation to malus only) the Group  
or any company within the Group 
suffers a material downturn  
in its financial performance.

A three-year time limit applies in respect  
of clawback from the date of bonus 
payment and LTIP vesting.

Due to the Group’s ownership structure,  
in particular that its ultimate parent 
company is a charity, it is not possible 
to deliver variable remuneration in the 
form of shares. Cash awards under the 
GMB Annual Bonus and Group LTIP 
arrangements are not subject to a post 
vesting holding period.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Governance – Group Remuneration Report

156

157

Changes to the Policy from that operating in 2021 
The Committee carried out a strategic review of the Group’s remuneration policy and incentive 
design during 2021 in order to ensure these continue to drive the Group’s strategy and long-term 
performance, including in respect of ESG and climate change considerations. 

As a result of the review, the following revised performance conditions will apply to the GMB 
annual bonus for 2022, together with individual performance:

Group performance measures

Percentage 
weighting

Strategic rationale

Group BG PBT (including fair value 
investment gains and losses)

Group BG PBT (excluding fair value 
investment gains and losses)

25%

25%

Underwriting balanced scorecard

10%

Gross New Money

Broking and Advisory Turnover

Delivery of Group strategic initiatives 
in line with the Group’s strategic plan

Greater Good

5%

5%

15%

15%

To incentivise delivery of overall  
profitability targets

To incentivise delivery of profitability targets, 
excluding market movements

To incentivise delivery of the general insurance 
growth strategy through achievement  
of a balanced scorecard of rate adequacy, 
retention and new business targets

To incentivise delivery of the EdenTree 
growth strategy

To incentivise delivery of the Broking  
and Advisory growth strategy

To incentivise delivery of the Group’s strategic 
change programme

Aligned to the Group’s ambition to build  
a Movement for Good, to incentivise delivery  
of the Group’s charitable giving and colleagues’ 
engagement with the Group’s MyGiving 
programme; of exceptional customer service;  
and of the highest standards of conduct  
and governance

In line with evolving market practice, deferral of bonuses is increased in 2022 to one third  
of the total annual bonus awarded, with deferral continuing to be over a period of three years 
(previously bonus earned in excess of 75% of maximum opportunity was deferred over three years). 
Malus and clawback provisions are amended as set out on page 154.

Following the review, the following revised performance conditions will apply to the Group LTIP  
for 2022-2024:

Group performance measures

Percentage 
weighting

Strategic rationale

Group BG PBT (including fair value 
investment gains and losses)

Return on Capital

30%

30%

General Insurance Underwriting Profit

10%

EdenTree Revenue

Broking and Advisory Turnover

Grant to Benefact Trust Limited

Environmental targets

5%

5%

10%

10%

To incentivise delivery of overall  
profitability targets

To incentivise delivery of return on capital targets

To incentivise delivery of the general insurance 
growth strategy

To incentivise delivery of the EdenTree  
growth strategy

To incentivise delivery of the Broking  
and Advisory growth strategy

To incentivise delivery of Grants to Benefact Trust 
Limited to support the Trust’s charitable work

To incentivise delivery of the Group’s climate 
change strategy

Malus and clawback provisions are amended as set out on page 154.

The pension contribution rate for the Group Chief Executive will be aligned with the wider workforce 
rate of 12% of salary with effect from April 2022. 

These changes to the Group’s Remuneration Policy will be made in 2022 and are reflected  
in the Future Policy table above.

Remuneration arrangements elsewhere  
in the Group
The Group’s approach to Executive Director  
and wider employee remuneration is based  
on the common set of principles set out  
in the Group’s Remuneration Policy on page 
150. However, given the size of the Group  
and the range of its operations, the manner  
in which these principles are implemented 
varies with seniority and, where appropriate, 
with the nature of the business transacted  
by a Group entity and the individual regulatory 
requirements which may be applicable.

All employees of the Group are entitled  
to a salary, benefits, pension and an annual 
bonus opportunity. However, remuneration  
for Executive Directors is more heavily  
weighted towards variable rewards, through 
a higher annual bonus opportunity and 
participation in the Group LTIP alongside  
other senior employees. Such variable 
remuneration is conditional on the  
achievement of performance targets that  
are linked to the successful delivery of the 
Group strategy. The greater weighting towards 
variable remuneration thereby aligns the 
interests of Executive Directors with those  
of the shareholder.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

158

159

Remuneration scenario charts

Notes to the charts:

The remuneration scenario charts below 
illustrate what each Executive Director  
could earn in respect of the policy for 2022, 
under different performance scenarios:
•  Minimum: fixed pay only (being salary, 

pension or cash in lieu of pension  
and benefits) with no annual bonus  
and no vesting of the LTIP;

•  Fixed pay is base salary for 2022 plus  

the value of pension and benefits.

•  Salary is the salary applicable  

at 1 April 2022.

•  The value of pension is calculated  

as described in the Future Policy table.
•  The value of benefits in-kind is taken  
from the single figure table for 2021.

•  On target: fixed pay plus annual bonus  

•  The Group operates a cash LTIP  

of 50% of salary and 50% vesting  
of the LTIP; and

•  Maximum: fixed pay plus maximum  
bonus of 100% of salary and 100%  
vesting of the LTIP.

scheme for the reasons set out above.  
No share price appreciation has therefore 
been included in the remuneration 
scenario charts.

Mark Hews: Effect of the application of this policy in financial year 2021

Minimum

100%

Total £563k

On-Target

Maximum

45%

29%

20%

34%

Total £1,240k

26%

45%

Total £1,917k

S. Jacinta Whyte: Effect of the application of this policy in financial year 2021

Minimum

100%

Total £455k

On-Target

Maximum

54%

37%

23%

23%

Total £841k

31%

31%

Total £1,228k

D. Cockrem: Effect of the application of this policy in financial year 2021

Minimum

100%

Total £352k

On-Target

Maximum

53%

36%

23%

23%

Total £660k

32%

32%

Total £967k

Fixed Pay 

Annual Variable 

LTIP

Approach to recruitment remuneration

Ecclesiastical is a specialist financial services 
group competing for talent across a variety  
of markets.

Any new Executive Director’s package would 
include the same elements and generally  
be subject to the same constraints as existing 
Executive Directors.

The Committee’s approach is to pay a fair 
market value to attract appropriate candidates 
to the role, taking into consideration their 
individual skills and experience and the ethos  
of the Group.

Where it is thought necessary to compensate 
for an individual’s awards resulting from 
previous employment, the Group may, as far  
as practicable, seek to match the expected 
value of such awards through the use of the 
Group’s existing incentive arrangements. Where 
this is not possible, it may be necessary to offer 
some form of ‘buy-out’ award, the size of which 
will, in the normal course of events, reflect the 
commercial value of the award foregone (and 
the vesting timetable of the awards foregone) 
and will also (where possible) be subject  
to some form of clawback if the individual 
leaves Ecclesiastical within a set timeframe.

The Group retains discretion to adjust  
the balance of the annual bonus and LTIP  
and the measures used to assess performance. 
Other payments may be made in relation  
to relocation expenses and support  
as appropriate.

In the case of an internal appointment,  
any incentive awards in respect of the prior  
role would be allowed to continue according  
to its original terms, or be adjusted  
if appropriate to take into account  
the appointment.

The Group retains discretion to make 
appropriate remuneration decisions outside  
the Policy to meet the individual circumstances 
of recruitment when:
•  an interim appointment is made to fill  

an Executive Director role on a short-term 
basis; and

•  exceptional circumstances require that  
the Chair or a Non-Executive Director  
takes on an executive function  
on a short-term basis.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Governance – Group Remuneration Report

160

161

Service contracts and policy on payment for loss of office

Service contracts and policy on payment for loss of office continued

Standard provision

Policy

Details

Standard provision

Policy

Details

Notice periods in Executive 
Directors’ service contracts 

Payment in lieu of notice 

Severance payment  
for Deputy Group  
Chief Executive 

Twelve months by the Group 
or Executive Director for  
the Group Chief Executive  
and six months by the Group 
or Executive Director for  
the Deputy Group Chief 
Executive and Group Chief 
Financial Officer. 

The Group may decide  
if it wishes to make a payment 
in lieu of notice of an amount 
prescribed under the contract, 
comprising of salary (and in 
the case of the Group Chief 
Executive, benefits) for the 
balance of the notice period, 
excluding bonus and accrued 
holiday entitlement. 

The Deputy Group Chief 
Executive’s pre-existing 
contract of employment 
before her appointment  
as Deputy Group Chief 
Executive contained 
severance provisions in 
line with Canadian law and 
practice. The policy of the 
Group has been to honour 
these commitments insofar 
as they relate to accrued 
service up to the date of her 
appointment to her new role, 
but not in respect of service 
after that date. 

Executive Directors may  
be required to work through 
their notice period, or may  
be paid in lieu of notice if they 
are not required to work  
the full notice period.

Payable as a lump sum within 
14 days of termination date  
in the case of the Group Chief 
Executive. Payable in monthly 
instalments over the balance 
of the notice period in the case 
of the Deputy Group Chief 
Executive and Group  
Chief Financial Officer. 

The executive’s entitlement 
arises in the case of any 
termination by the Group  
for ‘No Cause’ as defined and 
represents the sum of £504k 
and the provision of dental and 
health insurance cover and life 
assurance cover for a period of 
21 months after the termination 
date of her employment. 

The sums due may be made  
in monthly instalments to allow 
for mitigation. 

In addition, any sums otherwise 
due under the rules of any 
bonus or cash incentive plan  
in respect of the bonus year  
in which the termination date 
falls or in any subsequent year 
are only payable to the extent 
that they would otherwise 
exceed £148k.

Mitigation

Except in the case of the Group 
Chief Executive, Executive 
Directors’ service contracts 
expressly provide for mitigation 
on termination by allowing for 
payment in instalments over 
the balance of the notice period. 

The Committee will take 
account of the circumstances 
of the termination and the 
Director’s performance during 
the period of qualifying service 
to determine whether the 
exercise of any discretion  
is appropriate.

Treatment of annual bonus 
on termination or change  
of control under plan rules 

Treatment of long-term 
incentive awards  
on termination or change  
of control under plan rules  

No payment is to be made 
unless the executive  
is employed on the date  
of bonus payment except  
for ‘good leavers’ as defined 
in the plan rules (for example 
death, ill health, retirement) and 
other circumstances  
at the Committee’s discretion. 
If there is a change of control 
event, then an early payment 
can be calculated and made. 

All awards lapse except  
for ‘good leavers’ as defined 
in the plan rules (for example 
death, ill health, retirement)  
and other reasons at the 
discretion of the Committee.

If there is a change of control 
event, then an early payment 
can be made at the discretion  
of the Committee. 

Good leavers are entitled  
to a bonus payment subject 
to the achievement of bonus 
criteria which is pro-rated 
down to reflect their service 
during the performance 
year unless the Committee 
determines that a higher 
amount is justified. A similar 
provision would apply if there 
were a change of control 
event. Bonus payments  
for good leavers are subject  
to deferral, malus  
and clawback.

For good leavers, vesting 
is determined based on the 
application of the performance 
conditions and any award  
is then pro-rated down based 
on the proportion of the 
36-month performance period 
that the employee has served 
since the grant date unless  
the Committee determines that 
a higher amount is justified.  
A similar provision would 
apply if there were a change of 
control event. For good leavers 
grants vest on the original 
anniversary date.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

162

163

Service contracts and policy on payment for loss of office continued

NED fees policy

Standard provision

Policy

Details

Exercise of discretion 

Discretion is intended  
to be relied upon only  
in certain circumstances  
as set out on page 161. 

The Committee’s 
determination will take  
into account the circumstances 
of the Executive Director’s 
departure and the recent 
performance of the Group 
when using discretion  
in relation to short- or  
long-term bonus payments.

How the element supports 
the Group’s strategic 
objectives

To attract NEDs who have 
a range of experience and 
skills to oversee  
the implementation  
of the Group’s Strategy 

Other matters 

Non-Executive Directors 

The Group’s policy  
is to honour commitments 
made under contractual 
arrangements that may 
have been entered into with 
an employee prior to them 
becoming a Director.

There are no other provisions 
for termination payments  
or payments for loss of office 
in standard Directors’  
service contracts.

Each NED is appointed  
for an initial three-year term 
and is subject to election  
by the shareholder  
at the first AGM following 
their appointment.
In addition, the Board  
has agreed that all Directors 
(including NEDs) will be 
subject to annual re-election 
by the shareholder  
at each AGM. 

NEDs are entitled to receive 
a pro-rata proportion of their 
fees that they have accrued 
up to the date of termination 
of their contract.

.

Operation of the element

Maximum potential value 
and payment at threshold

Performance measures 
used, weighting and time 
period applicable

Current fee levels are shown  
in the section on 
implementation of policy.

NEDs are not eligible  
to participate in any 
performance-related 
arrangements.

NEDs’ fees, including  
the Committee Chair’s fees,  
are approved by the Board and 
at a general meeting, following 
recommendation by the Chair 
and Executive Directors.

NEDs take no part in the 
discussion relating to their 
own fees. The Chair’s and the 
SID’s fees are considered and 
approved by the Board in the 
absence of the Chair and SID.

Fees are typically paid in 12 
equal monthly instalments 
during the year. Fees are 
normally reviewed every two 
years against those for NEDs 
in companies of a similar scale 
and complexity.

NEDs do not participate  
in incentive or pension plans.

NEDs and the Chair shall  
be entitled to have reimbursed 
all expenses (such as their 
travel to Board meetings), 
and any associated tax that 
they reasonably incur in the 
performance of their duties. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
 
Governance – Group Remuneration Report

164

165

Annual Report on Remuneration
This section of the Directors’ Remuneration 
Report sets out how the above Remuneration 
Policy was implemented in 2021 and  
the resulting payments each Executive Director 
received. The financial information contained  
in this report has been audited where indicated.

Single total figure of remuneration for 
Executive Directors (audited)
The table on the following page shows a single 
total figure of remuneration received in respect 
of qualifying services for the 2021 financial  
year for each Executive Director, together  
with comparative figures for 2020.

Consideration of employment 
conditions elsewhere in the Group
The remuneration of employees across  
the Group is a key consideration when setting 
remuneration policy and outcomes for 
Executive Directors. The Committee is mindful 
of the importance of aligning executive and 
wider employee pay and conditions and takes 
internal and external measures, including 
internal pay relativities, into account when 
considering remuneration policy and outcomes 
for Executive Directors. As part of its work, 
the Committee has oversight of pay, incentive 
arrangements and conditions applicable  
to employees and oversees the incentive plans 
and material changes to employee pay and 
conditions across the Group’s businesses.

The Group consults with its recognised Union, 
Unite, regarding remuneration for employees 
within relevant UK businesses. Additionally, 
employees can provide feedback via  
the Group’s employee engagement survey  
and to their managers or HR. The Group  
HR Director attends the Committee meetings 
and advises the Committee on HR strategy, 
including the effectiveness of the Group’s 
remuneration policies and how they  
are viewed by employees.

Consideration of shareholder views
The Committee, through the Board, consults  
with the shareholder on any changes to this 
policy in order to understand expectations  
with regard to Executive Directors’ remuneration 
and any changes in the shareholder’s views.  
The Committee additionally consults with  
the shareholder in respect of the NED’s  
and the Chair’s fees.

During 2021, the Committee consulted  
the shareholder throughout its strategic 
review of remuneration in order to understand 
the shareholder’s expectations with regard 
to Executive Directors and wider employee 
remuneration and the shareholder’s  
views in relation to the evolving  
remuneration proposals.

£000

Fixed pay

Pension

Salary

Benefits1

Pension 
benefit2 

Total fixed 
remuneration

Fixed

Variable pay

Total variable 
remuneration

Total  
remuneration

Annual  
bonus3

LTIP4

Variable

Total

2021

2020 2021

2020 2021

2020 2021

2020 2021

2020 2021

2020 2021

2020 2021

2020

475

388

472

386

14

37

308

306

13

14

22

13

61

69

32

61

57

551

493

547

465

416

327

214

180

319

174

355

193

734

501

569

1,285

1,116

374

994

839

32

353

351

221

133

108

0

329

133

682

484

Executive 
Director

Mark Hews

S. Jacinta 
Whyte5 6

Denise  
Cockrem

 Total

1,171

1,164

64

49

162

150

1,397 1,363

964

527

601

548

1,564 1,076 2,961 2,439

1  Benefits include car allowance and private medical insurance which are valued at their taxable value. Provision of benefits during 2021 was in line  

with the Directors’ Remuneration Policy. The Deputy Group Chief Executive received £15k in 2021 in respect of outstanding annual leave.

2  The Group Chief Executive and Group Chief Financial Officer received a cash allowance in lieu of pension, in line with Company policy that a cash allowance 
of 15% (Group Chief Executive) or 12% (Group Chief Financial Officer) of salary (net of national insurance contributions) can be paid to UK-based Executive 
Directors where pension contributions would be in excess of the HMRC annual and/or lifetime allowance.

3  In line with the deferral policy, annual bonus earned in respect of 2021 which is in excess of 75% of the maximum bonus opportunity is deferred over  

a period of three years. In 2021 the value of Executive Directors’ annual bonuses that are deferred is: £59k (Group Chief Executive) and £36k  
(Deputy Group Chief Executive). 35% of the awards under the 2020 annual bonus plan were deferred for one year and were subject to the Group  
returning to profit in 2021. These amounts became payable in March 2022 on the Group returning to profit in 2021. 

4  LTIP represents the amount payable in respect of the three-year LTIP performance period 2019-2021 for 2021 and 2018-2020 for 2020.  

The Group operates a cash LTIP scheme, therefore no part of the award was attributable to share price appreciation. All Executive Directors  
hold unvested LTIP awards in accordance with the rules of the LTIP plan.

5  An average 2021 exchange rate of 1.7247 Canadian dollars to 1 GBP has been used in respect of both 2021 and 2020.

6  Contributions to the Canadian pension plan that are above the Canadian Revenue Agency’s prescribed limit are paid into a SERP.  
These contributions for the Deputy Group Chief Executive and interest accruing to the SERP are included in the figures shown. 

Mark Hews is a NED for MAPFRE RE and was appointed to their Board in December 2013. The fee of £30k (2020: £34k)  
that Mark Hews earns in respect of this role is paid directly to the Group by MAPFRE RE and is not received by Mark Hews.

Denise Cockrem resigned as a NED of Skipton Building Society in April 2021. The fee that Denise Cockrem earned in respect  
of this role was paid directly to the Group by Skipton Building Society and was not received by Denise Cockrem. The fee 
earned in respect of 2021 was £15.6k (the fee earned in respect of 2020 was £52.1k, of which £49.5k was received  
by the Group and £2.6k was donated to charity).

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

166

167

Additional requirements in respect  
of the single total figure table

Annual bonus outcomes for 2021 (audited) 
The annual bonus awards for 2021 were 87.5% 
of maximum (which is 100% of salary)  
for the Group Chief Executive; 84.4%  
for the Deputy Group Chief Executive; and 
71.9% for the Group Chief Financial Officer.

The annual bonuses outturns were determined 
taking into account both Group and individual 
performance. 

Individual performance is subject to delivery 
of personal performance objectives and 
performance in line with the Group’s 
behavioural competency framework for 
strategic leaders. A personal performance 
percentage of between 0% and 75% may  
be awarded in respect of this element of the 
annual bonus. The personal performance 
percentage is reviewed and agreed  
by the Committee.

these were Group BG PBT (including fair value 
investment gains and losses) (40%); Group COR 
(20%); Underwriting balanced scorecard  
(10%); delivery of Group strategic initiatives  
in line with the Group’s strategic plan (15%);  
and Customer and Conduct performance (15%).

Results in respect of each performance 
condition are assessed against the required 
performance levels set at threshold, target  
and maximum, in order to calculate the 
aggregate Group performance multiplier  
as shown in the table below. Performance 
targets for 2021 were not adjusted as a result 
of the impact of the Covid-19 pandemic  
and remain as originally determined. 

The overall bonus outturn for each Executive 
Director is the product of the personal 
performance percentage and the aggregate 
Group performance multiplier. The maximum 
opportunity under the annual bonus plan  
is 100% of salary.

Group performance is subject to the five 
performance conditions which together form 
the Group performance multiplier. For 2021, 

The targets relating to the GMB annual bonus 
and actual performance against those targets 
for the financial year 2021 were:

Performance 
Condition

Group BG PBT1

Group COR

Underwriting 
balanced scorecard

Strategic Targets

Customer and 
Conduct

Weighting

Threshold 
(0.5x)

40%

20%

10%

15%

15%

£7.6m

97.0%

50%

50%

85%

Target 
(1.0x)

£37.4m

91.3%

75%

75%

90%

Aggregate Group performance multiplier

1  Audited to EIO Group level

Maximum  
(1.5x)

Actual 
performance

Weighted 
multiplier

£73.8m

£83.6m

86.3%

100%

100%

100%

96.8%

90.8%

90.0%

99.0%

0.60

0.10

0.13

0.20

0.22

1.25

satisfaction continued to be high through 2021, 
with 98% of customers and brokers reporting 
that they were satisfied with the service they 
received from Ecclesiastical. This outstanding 
level  
of customer service, together with the Group’s 
strong customer and conduct culture and 
effective systems of control, drove another 
strong performance against the Group’s 
customer and conduct targets, with an outturn 
of 99.0% being achieved in 2021. In just one 
business unit customer satisfaction outturns 
were slightly below target. Targets in respect 
of compliance with the Group’s risk appetite; 
regulatory feedback; the Group’s rolling 
programme of product reviews; complaints 
handling; data security; and timely resolution 
of internal audit and compliance findings  
were met in full. 

The Strategic Targets performance condition 
measures delivery of the Group’s change 
programme. As set out in more detail  
in the Strategic Report, 2021 saw both 
significant progress on the Group’s strategic 
initiatives and the launch of an ambitious 
new strategy for the Group. During the year, 
the Group launched the new Ecclesiastical 
brand; opened its new head office; delivered 
further investment in systems, technology and 
innovation; grew the Broking and Advisory 
business; and invested in the EdenTree 
business, including strengthening the team  
and launching three new funds. The Group’s 
climate change strategy was agreed by the 
Board and a new responsible and sustainable 
investment strategy implemented. Overall  
in 2021, substantial progress was made  
on the Group’s change programme, resulting  
in an outturn of 90.0% being achieved against 
the strategic targets measure for 2021.

In line with the Group’s commitment  
to delivering exceptional customer service  
and the highest standards of conduct,  
the Customer and Conduct performance 
condition measures delivery across a range 
of customer and conduct metrics. Customer 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

168

169

Personal performance
Personal performance was assessed taking into consideration delivery against the Group’s 
business plans for 2021, personal objectives and performance in line with the Group’s behavioural 
competency framework for strategic leaders. The table below provides an overview of the personal 
performance achieved by each Executive Director based on their objectives.

The assessment of personal performance for 2021 takes account of the additional challenges  
that the ongoing Covid-19 pandemic has presented.

Mark Hews

S. Jacinta Whyte

Denise Cockrem

Delivered another year of exceptional leadership across the Group 
throughout what has been a pivotal year in the Group’s history. Under Mark 
Hews’ leadership, 2021 saw the Group recover strongly from the challenges 
caused by Covid-19 in 2020, with the Group reporting a profit before tax  
of £77.0m in 2021 and exceeding its goal of donating more than £100m  
to good causes.

The Group continued to deliver for customers, maintaining outstanding 
levels of customer satisfaction, with 98% of customers and brokers reporting 
that they were satisfied with the service they received from Ecclesiastical. 
Employee engagement levels remained high, with the Group being awarded 
a two-star ‘outstanding’ accreditation by Best Companies.

During 2021, Mark Hews oversaw the development of the new Benefact 
Group identity and name for the Group, the delivery of transformational 
changes including investments in new systems and technology, a new 
head office, the new Ecclesiastical brand for the Group’s General Insurance 
businesses and a new ambitious strategy behind which the whole Group  
can align. 

Continued to provide strong leadership across the Group’s General  
Insurance portfolio of businesses. Playing a central leadership role  
in the Group’s ongoing Covid-19 response, Jacinta Whyte ensured that  
the Group’s General Insurance businesses continued to provide market 
leading products and service as well as overseeing the management  
of business interruption claims. 

Jacinta Whyte additionally managed a programme of work to strengthen  
the Group’s overall management of data, enabling the Group to be increasingly 
strategic in its use of data in support of its long-term business goals.

Further improved the financial strength of the Group during 2021 and made 
a significant contribution across the Group which has been central to the 
delivery of the business plan, including overseeing a return to profitability  
in all of the Group’s businesses at the same time as maintaining control  
over costs. 

Denise Cockrem additionally managed the issuance of €30m subordinated 
debt in February 2021, as the Group seeks to take advantage of profitable 
growth opportunities, and continued to lead and strengthen the Group’s Risk, 
Compliance and Audit functions.

Bonuses are earned in respect of the financial year and are paid in March following the end  
of the financial year. Under the plan rules, any proportion of a bonus outcome above 75%  
of the maximum bonus outcome is deferred over three years, in cash, and all annual bonus 
outcomes are subject to malus and clawback as set out on page 154.

LTIP outcomes in 2021 (audited)
The LTIP amount included in the single total figure of remuneration is the cash award resulting  
from the Group LTIP grant for the period 2019-2021, which vested at 47.0%. Vesting was dependent 
on performance over the three financial years ending on 31 December 2021 and continued service 
until March 2022.

The 2019-2021 Group LTIP is subject to five performance conditions: Group BG PBT (excluding fair 
value investment gains and losses) (25%); Group BG PBT (including fair value investment gains 
and losses) (25%); Group COR (25%); delivery of Group strategic initiatives in line with the Group’s 
strategic plan (15%); and Customer and Conduct performance (10%). Results in respect of each 
performance condition are assessed against the required performance levels set at threshold, 
target and maximum as shown below. Performance targets were not adjusted in light of the impact 
of the Covid-19 pandemic and remain as originally determined.

Performance condition

Threshold – 
20% vesting

Target –
50% vesting

Maximum – 
100% vesting

Actual

Vesting 
(% of maximum 
for performance 
condition)

Group PBT (excluding 
fair value investment 
gains and losses)1

Group PBT 
(including fair value 
investment gains and 
losses)1

Group COR

Strategic Targets

Customer and Conduct

Total

1  Audited to EIO Group level 

£82.4m

£114.1m

£156.2m

£58.6m

-

£70.9m

£117.6m

£189.8m

£135.7m

63%

96.6%

50%

85%

93.6%

75%

90%

89.3%

100%

100%

94.5%

91.8%

97.3%

41%

84%

87%

47.0%

The Strategic Targets performance condition measures delivery of the Group’s change programme 
over the period 2019-2021. During 2021 the Group surpassed its target of delivering £100m to good 
causes. Key achievements over the period include the implementation of enhanced systems  
and technology across the Group’s businesses; welcoming new brokers into the Group’s expanding 
broking business; investment in people and expertise; launching the new Ecclesiastical and 
Benefact Group brands; further strengthening the Group’s award winning EdenTree business; 
adoption of a climate change strategy for the Group; and the launch of an ambitious new strategy 
for the Group. A minority of programmes remain to be fully delivered, including the new strategic 
General Insurance system for UK and Ireland. Overall, substantial progress has been made  
on the Group’s change programme, resulting in an outturn of 91.8% being achieved against  
the strategic targets measure for 2019-2021.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
Governance – Group Remuneration Report

170

171

The Customer and Conduct performance condition measures delivery against the Group’s customer 
and conduct metrics. Targets in respect of compliance with the Group’s risk appetite; regulatory 
feedback; complaints handling; data security; and timely resolution of internal audit and compliance 
findings were met in full throughout the period. Customer satisfaction outturns were slightly below 
target for one business unit in 2021 and for two business units in 2020, with all business units 
meeting targets in 2019. Claims service outturns were slightly below target in 2020, reflecting  
the challenges of Covid-19, having been met in full in 2019 and 2021. Targets relating to the Group’s 
rolling programme of product reviews were met in full in 2021 and 2020, with one business unit 
reporting below target outturns in 2019. An overall outturn of 97.3% was achieved.

Combining the financial and non-financial performance results in an overall vesting level of 47.0%.

The Group LTIP outcome that vests in respect of each Executive Director in respect of 2019-2021  
is shown below.

Mark Hews

S. Jacinta Whyte1

Denise Cockrem2

LTIP grant

% of salary

150%

100%

100%

Total LTIP vesting

£000

319

174

108

% of maximum

47.0%

47.0%

47.0%

1  An average 2020 exchange rate of 1.7247 Canadian dollars to 1 GBP has been used in respect of 2021.

2  Denise Cockrem was appointed to the Board on 6 September 2019.

Scheme interests awarded during 2021 (audited)
During 2021, awards comprising of a cash sum were granted under the 2021-2023 Group
LTIP to each Executive Director as set out below. These awards will vest, and the cash sum  
will be transferred to the award holder, in March 2024, to the extent that the applicable 
performance targets are met. The vesting date for these awards is the date on which  
the Group’s 2023 results are announced, anticipated to be during March 2024.

Executive 
Director

Award 
date

Maximum 
cash sum 
subject to 
the award 
(% base 
salary)

Face value 
of award 
at grant 
£000s

Cash award 
if threshold 
performance 
achieved
(% base 
salary)

End of the 
period over 
which the 
performance 
targets have 
to be fulfilled

Performance 
measures1

2020-2022 Group LTIP

Mark Hews

26 Jul 
2021

150%

713

20%

31 December 
2023

S. Jacinta 
Whyte2

26 Jul 
2021

100%

388

20%

31 December 
2023

Denise 
Cockrem

26 Jul 
2021

100%

308

20%

31 December 
2023

•  Group BG PBT 

(including fair value 
investment gains/
losses) 40%;
•  Group BG PBT 

(excluding fair value 
investment gains/
losses) 20%;
•  Group COR 15%;
•  Strategic targets 

15%; and 
•  Customers  

and conduct  
targets 10%. 

1  Vesting occurs on a straight line basis between pre-determined milestones set in relation to threshold, target  

and maximum performance. These will be disclosed on a retrospective basis in the Directors’ Remuneration Report  
for the year for which the Group LTIP awards vest.

2  An average 2021 exchange rate of 1.7247 Canadian dollars to 1 GBP has been used.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
Governance – Group Remuneration Report

172

173

The information provided in this part of the Annual Report on Remuneration is not subject to audit 

Chief Executive pay ratio
The Group structure means that it does not have to comply with the regulations governing  
the disclosure of executive remuneration to which quoted companies are subject. The Group  
has nonetheless chosen to disclose the ratio of the Group Chief Executive’s pay to that of other  
UK employees1 in the Group in order to provide greater transparency.

Year

Method

2021

2020

2019

Option A 2

Option A 2

Option A 2

25th percentile pay 
ratio

Median pay ratio

75th percentile pay 
ratio

32.1

30:1

40:1

23.1

23:1

29:1

17.1

16:1

21:1

The total remuneration and salary values for the 25th percentile, median and 75th percentile 
employees for 2021 were:

25th percentile 

Total remuneration3

Salary

£40,755

£31,948

Median 

£55,306

£42,506

75th percentile 

£77,786

£57,562

1   The table sets out the ratio between the Group Chief Executive’s total remuneration and that of the 25th percentile, median 
and 75th percentile UK-based employees of Ecclesiastical Insurance Office plc (excluding SEIB), which constitute the large 
majority of the UK employee population. The Committee is satisfied that the individuals identified appropriately reflect the 
employee remuneration profile at the lower, median and upper quartile and that the overall picture presented by the ratios 
is consistent with the Group’s wider policies pay, reward and progression policies for the Group’s UK-based employees.

2  The calculation is based on Option A as set out in the regulations for listed companies, as this is considered to be the most 

accurate way of identifying employees at the 25th percentile, median and 75th percentile.

3  Total remuneration reflects all remuneration received by the individual in the relevant year, including base salary, 

benefits, pension, annual bonus and, where relevant, the long-term incentive that vests, but excludes taxable company car 
benefits and taxable travel and accommodation expenses for administrative reasons. Calculations have been carried out 
on a full-time equivalent basis as at 31 December 2021.

The Group Chief Executive was paid 23 times the median employee in 2021, with the CEO pay  
ratios being broadly consistent with the prior year. 2021 awards under both the Group’s GMB  
and employee annual bonus schemes were materially higher in comparison to the prior year,  
in line with 2021 performance. Vesting of the 2019-2021 Group LTIP was, however, marginally  
lower than the prior year. Whilst salary increases were awarded to employees during 2021,  
those of the Group Chief Executive, Directors or other senior leaders across the Group  
were frozen, in light of the impact of the Covid-19 pandemic.

Percentage change in remuneration of all Directors and UK-based employees
The table below shows the percentage year-on-year change in salary, benefits and annual bonus 
(from 2020 to 2021) for the Board Directors compared with UK-based employees1. The Committee 
has selected this comparator group as being the most appropriate because the composition  
and structure of remuneration for this group most closely reflects that of the Board.

Salary

Taxable benefits2

Annual bonus

Executive Directors

Mark Hews

Jacinta Whyte

Denise Cockrem

UK-based employees

0.6%

0.6%

0.6%

Average UK-based employees1

3.9%

0.1%

67.1%

0.0%

1.1%

94.7%

81.5%

65.6%

132.0%

1  UK-based employees of Ecclesiastical Insurance Office plc; excluding employees in SEIB; matched sample basis.

2  Based on contractual P11D taxable benefits for the tax year ending 5 April in the relevant year. Taxable benefits include car 
allowance and private medical insurance for Executive Directors and private medical insurance for UK-based employees 
(taxable company car benefits and taxable travel and accommodation expenses are excluded for administrative reasons). 
The Deputy Group Chief Executive received £15k in respect of outstanding annual leave in 2021 (2020: £0k).

  The fee paid to the Chair and the basic fee for NEDs were unchanged in 2021 compared to 2020.

Relative importance of spend on pay
The table below sets out for 2021 and 2020, the actual costs of employee remuneration;  
grants paid to Benefact Trust Limited; and dividends paid to Preference shareholders.  
PBT in each year is provided for context. 

(£000)

Remuneration paid to all Group employees

Gross charitable grants to the ultimate 
parent company, Benefact Trust Limited2

2021

102,313

21,000

2020

86,840

Nil

Non-Cumulative Irredeemable Preference 
share dividend

9,181

9,181

Profit/(loss) before tax3

77,037

(15,746)

% change

17.8%1

N/A

Nil

N/A

1.  In light of the Group’s reported results, total variable remuneration is significantly increased compared to 2020  

as set out above. In addition, there has been an increase in the number of employees and salary inflation.  
See note 13 to the financial statements.

2  An additional grant of £5m has been made in 2022 following finalisation of the Group results.

3  Ecclesiastical Insurance Office (EIO) Group.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

174

175

Group Chief Executive pay for performance comparison 
The table below shows the single figure of total remuneration for the incumbent, Mark Hews,  
and prior Group Chief Executive, Michael Tripp, for the ten years to 31 December 2021.

Financial year ending 31 December

Financial 
year

Group Chief 
Executive1

2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Total remuneration 
(single figure) £000

Annual bonus 
received (% of 
maximum)

Long-term incentive 
vesting (% of 
maximum)

Mark Hews

N/A

569

907

1,089 1,370 1,212 1,240 1,489 1,116 1,285

Michael 
Tripp

390

330

162

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Mark Hews

N/A

45% 78% 88% 97% 99% 84% 96% 45% 88%

Michael 
Tripp2

0%

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Mark Hews3 N/A

4%

60% 70% 88% 75% 88% 86% 54% 47%

Michael 
Tripp4

0%

4%

47% N/A

N/A

N/A

N/A

N/A

N/A

N/A

1  Michael Tripp resigned from the Board on 21 May 2013 and Mark Hews was appointed Group Chief Executive on 1 May 
2013, having previously held the position of Group Chief Financial Officer. The total remuneration single figure value  
for both Michael Tripp and Mark Hews is shown for 2013.

2  Michael Tripp received no payment under the annual bonus or the Executive Director’s LTIP for performance in 2013.  
He did, however, receive a payment (£100k) under the terms of a discretionary arrangement put in place to incentivise  
the delivery of a smooth transition of the management to the successor in the role of Group Chief Executive.  
The maximum opportunity was capped at three months’ salary. 

3  The LTIP vesting relevant to Mark Hews represents the amount vesting in respect of the three-year LTIP performance 
period 2012-2014 for 2014; 2013-2015 for 2015 and 2014-2016 for 2016, together with the amounts vesting in respect  
of the Group Chief Executive’s three-year incentive plan in 2014, 2015 and 2016 respectively. The Group Chief Executive’s 
three-year incentive plan concluded at the end of 2016. LTIP vesting in 2017 and subsequent years represent the amounts 
vesting in respect of the relevant three-year LTIP performance period only.

4  Michael Tripp received a 2013 LTIP payment in respect of performance in the years 2011 and 2012 (only) under the  

2011-2013 LTIP. He received a 2014 LTIP payment in respect of performance in 2012 (only) under the 2012-2014 LTIP.

Statement of Directors’ shareholdings and share interests
Directors’ shareholdings and share interests are set out in the Directors’ Report. Due to the Group’s 
ownership structure, in particular that its ultimate parent company is a charity, it is not possible to 
deliver variable remuneration in the form of shares. Directors’ shareholdings are not subject  
to post-employment shareholding requirements.

Directors’ service agreements 
Mark Hews has a service contract which provides for a notice period of 12 months by the Company. 
S. Jacinta Whyte and Denise Cockrem have service contracts which provides for a notice period  
of 6 months by the Company. No NED has a service contract.

Payments for loss of office (audited) 
No termination payments were made to Executive Directors in 2021.

Early vesting of LTIP award
There is no early vesting of the Executive Directors’ LTIP. 

Single total figure of remuneration for NEDs (audited)
NEDs do not participate in any of the Group’s incentive arrangements.

The Board believes that it is appropriate that the level of fees paid to NEDs should reflect  
equivalent fees paid by organisations of similar size and complexity whilst being mindful that  
the Group is owned by a charity. This will enable the Group to attract NEDs of the calibre  
required to help the Group to implement its future strategy.

NED fees were last reviewed by the Board in November 2019 with increased fees becoming 
effective from 1 January 2020. The fees set out below are commensurate with the demands  
and responsibilities of the NED roles.

£

Fees

Taxable Benefits1

Non-Executive Directors

2021

2020

David Henderson2

Chris Moulder3

Andrew McIntyre4

Sir Stephen Lamport5

Angus Winther6

Francois-Xavier Boisseau7

Neil Maidment8

Rita Bajaj9

Caroline Taylor10

The Very Revd Christine Wilson11

Total

145,000

145,000

75,000

68,000

59,087

66,000

61,500

55,000

25,417

46,879

0

601,883

74,772

68,000

42,708

66,000

55,000

54,402

0

68,000

26,485

600,637

2021

182

0

0

385

0

0

0

0

222

0

789

2020

987

5

4

159

144

263

6

0

2,869

1,467

5,904

1  Benefits are travel and accommodation expenses only, valued at their grossed up tax and NI value, in accordance  

with Group’s travel and expenses policy.

2  David Henderson was appointed as Chair on 19 March 2019. 

3  Chris Moulder was appointed as the SID on 14 January 2020 and a NED on 27 September 2017. He became Chair  
of the Group Nominations Committee on 7 January 2020 and Chair of the Group Risk Committee on 1 June 2018.

4  Andrew McIntyre was appointed as a NED and Chair of the Group Audit Committee on 4 April 2017.

5  Sir Stephen Lamport was appointed as a NED on 23 March 2020 and Chair of the Group Remuneration Committee 

on 8 September 2021.

6  Angus Winther was appointed as a NED on 19 March 2019 and Chair of the Group Finance and Investment Committee  

on 1 January 2020.

7  Francois-Xavier Boisseau was appointed as a NED on 19 March 2019 and to undertake a Broker Oversight role  

on 1 July 2021.

8  Neil Maidment was appointed as a NED on 6 January 2020.

9  Rita Bajaj was appointed as a NED on 15 July 2021.

10 Caroline Taylor retired from the Board and as Chair of the Group Remuneration Committee on 8 September 2021.

11  The Very Revd Christine Wilson retired from the Board on 18 June 2020. Christine Wilson chose to donate her fee  

to charity in 2020. 

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

176

177

The information provided in this part of the Annual Report on Remuneration is not subject to audit

EdenTree
EdenTree has been subject to the FCA Remuneration Code since 1 January 2011.  
EdenTree operates a remuneration policy which is compliant with the Remuneration Code, 
details of which can be found in the EdenTree Pillar 3 statement on EdenTree’s website  
(www.edentreeim.com).

Statement of implementation of Remuneration Policy in 2022
The implementation of the remuneration policy will be consistent with that outlined  
in the Directors’ Remuneration Policy above. Details of how this policy will apply in 2022  
are set out below.

Salary (Executive Directors)
Executive Directors’ salaries are reviewed annually in line with the Directors’ Remuneration 
Policy. The level of salary increases for UK Ecclesiastical employees is a key consideration  
in setting the level of any salary increase for Executive Directors. After careful consideration 
the Committee determined that the salaries of Executive Directors would be increased by 
5.0% in line with the wider workforce. The following salaries will apply from 1 April 2022:

(£000)

Salary

Salary

Mark Hews

S. Jacinta Whyte1

Denise Cockrem

1 April 2022

1 April 2021

499

407

323

475

388

308

1  An average 2021 exchange rate of 1.7247 Canadian dollars to 1 GBP has been used.

Percentage
increase

5.0%

5.0%

5.0%

Annual bonus for 2022
The annual bonus performance conditions and targets have been set in accordance with  
the Directors’ Remuneration Policy above. 

As set out above, a strategic review of the Group’s incentive arrangements was carried out in 2021, 
with the resulting revised arrangements below applying from 2022.

The annual bonuses payable to Executive Directors in respect of 2022 will be assessed based  
on both Group and individual performance. Individual performance continues to be subject  
to delivery of personal performance objectives and performance in line with the Group’s culture 
and behaviours framework, expressed as a personal performance multiplier. Group performance 
is subject to seven performance conditions which together form the Group performance multiplier. 
For 2022, these will be as follows:

Group performance measures

Percentage weighting

Group BG PBT (including fair value investment gains and losses)

Group BG PBT (excluding fair value investment gains and losses)

Underwriting balanced scorecard

Gross New Money

Broking and Advisory Turnover

Delivery of Group strategic initiatives in line with the Group’s strategic plan

Greater Good (including charitable giving; employee engagement with 
MyGiving programme; customer and conduct; and governance)

25%

25%

10%

5%

5%

15%

15%

The overall bonus outturn for each Executive Director is the product of their target bonus 
opportunity, personal performance multiplier and the aggregate Group performance multiplier. 
The maximum opportunity under the annual bonus plan in 2022 is 100% of salary. Annual bonuses 
in respect of 2022 will be subject to deferral, over a period of three years, of one third of the total 
annual bonus awarded.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationGovernance – Group Remuneration Report

178

Ecclesiastical Annual Report & Accounts 2021

179
179

LTIP for 2022-2024
The 2022-2024 LTIP performance conditions and targets have been set in accordance  
with the Directors’ Remuneration Policy above. As outlined above, a strategic review  
of the Group’s incentive arrangements was carried out in 2021, with the resulting revised 
performance conditions below applying for the 2022-2024 Group LTIP:

Group performance measures

Percentage weighting

Group BG PBT (including fair value investment gains and losses)

Return on Capital

General Insurance Underwriting Profit

EdenTree Revenue

Broking and Advisory Turnover

Grant to Benefact Trust Limited

Environmental targets

30%

30%

10%

5%

5%

10%

10%

Awards under the 2022-2024 Group LTIP will be up to 180% of salary in the case of the Group
Chief Executive and up to 120% of salary in the case of the Deputy Group Chief Executive  
and Group Chief Financial Officer.

Fees (Non-Executive Directors)
The following fee structure will apply from 1 January 2021.

All-inclusive fee for the Group Chair

All-inclusive fee for the Senior Independent Director

Basic fee for a NED (including Committee Membership)

Fee for chairing the Group Audit Committee

Fee for chairing the Group Remuneration Committee

Fee for chairing the Group Risk Committee

Fee for Broker Oversight Role

Fee for chairing the Group Finance and Investment Committee

Fee for chairing the Group Nominations Committee1

Fees (£000)

145

75

55

13

13

13

13

11

11

1  The fee for chairing the Group Nominations Committee is included within the all-inclusive fee for the Senior Independent 

Director for 2022.

By order of the Board

Sir Stephen Lamport
Chair of the Group Remuneration Committee
17 March 2022

‘A transformational 
year for the Group, 
2021 saw significant 
progress on the 
Group’s strategic 
initiatives and the 
launch of a new and 
ambitious Group 
strategy which aims 
to raise £250m for 
good causes by the 
end of 2025.’

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Section ThreeSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Four

Financial Statements

Independent auditors’ report to the members of Ecclesiastical Insurance Office plc 

Financial Statements 

182

191

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
182

183

Independent auditors’ report to the members  
of Ecclesiastical Insurance Office plc

Basis for opinion
We conducted our audit in accordance with 
International Standards on Auditing (UK)  
(“ISAs (UK)”) and applicable law.  
Our responsibilities under ISAs (UK) are further 
described in the Auditors’ 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.

Independence
We remained independent of the group  
in accordance with the ethical requirements 
that are relevant to our audit of the financial 
statements in the UK, which includes the FRC’s 
Ethical Standard, as applicable to listed public 
interest entities, and we have fulfilled our other 
ethical responsibilities in accordance with  
these requirements.

To the best of our knowledge and belief,  
we declare that non-audit services prohibited  
by the FRC’s Ethical Standard were not provided.

Other than those disclosed in note 12, we have 
provided no non-audit services to the parent 
company or its controlled undertakings  
in the period under audit.

Report on the audit of the  
financial statements
Opinion
In our opinion, Ecclesiastical Insurance Office 
plc’s group financial statements and parent 
company financial statements (the “financial 
statements”):

• give a true and fair view of the state  

of the group’s and of the parent company’s 
affairs as at 31 December 2021 and  
of the group’s profit and the group’s  
and parent company’s cash flows  
for the year then ended;

• have been properly prepared in accordance 
with UK-adopted international accounting 
standards; and

• have been prepared in accordance with  

the requirements of the Companies Act 2006.

We have audited the financial statements, 
included within the Annual Report and 
Accounts (the “Annual Report”), which comprise: 
Consolidated and parent statement of financial 
position as at 31 December 2021; Consolidated 
statement of profit or loss, Consolidated and 
parent statement of comprehensive income, 
Consolidated and parent statement of cash 
flows and Consolidated and parent statement 
of changes in equity for the year then ended; 
and the notes to the financial statements, 
which include a description of the significant 
accounting policies.

Our opinion is consistent with our reporting  
to the Group Audit Committee.

Key audit matters
Key audit matters are those matters that,  
in the auditors’ professional judgement, were 
of most significance in the 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) 
identified by the auditors, 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,  
and any comments we make on the results  
of our procedures thereon, 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.

This is not a complete list of all risks identified 
by our audit.

Completeness of reserves in relation  
to business interruption claims, valuation 
of investment property and unlisted equity 
and impact of Covid-19, which were key audit 
matters last year, are no longer included 
because of the subsequent easing of lockdown 
restrictions and start of the recovery from  
the pandemic has resulted in the reduction 
of the level of uncertainty surrounding these 
areas of the audit. Otherwise, the key audit 
matters below are consistent with last year.

Our audit approach

Context
The company is a UK headquartered general 
insurer. The majority of business is written  
in the UK however it does also have branches  
in Ireland and Canada and subsidiaries  
in Australia. The group of which it is the parent 
also includes subsidiaries that carries out 
insurance broking, life insurance, investment 
management and financial advisory business.

Overview
Audit scope
• We have scoped the audit based  

on the financially significant components  
and material account balances within  
the group, which are described below.

Key audit matters
• Assumptions used in calculating asbestos  

and Physical and Sexual Abuse “PSA” reserves 
(group and parent).

Materiality
• Overall group materiality: £11,382,000  
(2020: £10,000,000) based on 1.8%  
of Net assets.

• Overall parent company materiality: 

£10,813,000 (2020: £9,500,000) based  
on 2.0% of Net assets.

• Performance materiality: £8,536,000  

(2020: £7,500,000) (group) and £8,109,000 
(2020: £7,100,000) (parent company).

The scope of our audit
As part of designing our audit, we determined 
materiality and assessed the risks of material 
misstatement in the financial statements.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Independent auditors’ report to the members of Ecclesiastical Insurance Office plcSection FourSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information184

185

Key audit matter

Assumptions used in calculating asbestos  
and Physical and Sexual Abuse “PSA” reserves 
(group and parent)

As disclosed in the Group Audit Committee 
Report and notes 2, 3 and 27. The valuation  
of the general insurance liabilities is a complex 
process involving inherent uncertainty and  
is one of the most significant areas of 
management judgement within the financial 
statements of the group and company.

The uncertainty around claims frequency, claims 
severity, discount rate, future inflation and 
reserve margin require significant management 
judgement and estimation in setting the reserves.

We consider the area of significant judgement 
to be specific to assumptions used in calculating 
the reserves for asbestos and PSA exposures, 
specifically in relation to the incurred but not 
reported (‘IBNR’) element of these reserves. 
Specifically, the assumptions requiring significant 
judgement and estimation are claims frequency, 
claim severity, the discount rate, future inflation, 
and the reserve margin. 

How our audit addressed the key  
audit matter

With involvement from our Actuarial specialists 
we have performed the following procedures:

– Observed the Reserving Committee control 
which reviews, challenges and approves  
the assumptions used within the calculation 
of the reserves;

– Challenged the assumptions used  

by management and considered reasonable 
alternative assumptions and the impact  
of the level of reserves calculated.

This includes consideration of the historic 
claim numbers, average claims cost, the 
current regulatory environment and IICSA 
review (for PSA) and Asbestos Working Party 
(for asbestos), discount rate, future inflation 
and level of margin.

- We have assessed the appropriateness  
of the resulting reserves based on the 
assumptions selected.

Based on the work performed and evidence 
obtained, we consider the assumptions used 
in the calculation of the asbestos and PSA 
reserves to be appropriate.

How we tailored the audit scope
We tailored the scope of our audit to ensure 
that we performed enough work to be able  
to give an opinion on the financial statements 
as a whole, taking into account the structure  
of the group and the parent company,  
the accounting processes and controls,  
and the industry in which they operate.

The group operates a general insurance 
business in the United Kingdom, Ireland, Canada 
and Australia. It also operates a life insurance 
business, an investment management business 
and an insurance broking business within  
the United Kingdom. The group includes certain 
non-insurance entities within the United 
Kingdom and Australia which are smaller and 
do not form part of our in scope components.

We consider the general insurance business 
in the United Kingdom and the consolidation 
adjustments to be a financially significant 

reporting component. We have performed  
a full scope audit of this component.  
The general insurance business in Canada 
and Australia as well as the life insurance 
business, an investment management business 
and an insurance broking business within 
the United Kingdom were noted to include 
specific large balances. These large balances 
have then been brought into the scope of our 
audit. Consolidation adjustments in the Group 
accounts have also been considered.

Together with additional procedures performed 
at a Group level on the consolidation, the result 
of the above scoping was that we achieved 
greater than 96% coverage of gross written 
premiums and 95% coverage of insurance 
contract liabilities.

Materiality
The scope of our audit was influenced  
by our application of materiality. We set certain 
quantitative thresholds for materiality.  
These, together with qualitative considerations, 
helped us to determine the scope of our audit 
and the nature, timing and extent of our audit 
procedures on the individual financial statement 

line items and disclosures and in evaluating  
the effect of misstatements, both individually 
and in aggregate on the financial statements  
as a whole.

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

Financial statements – group

Financial statements 
– parent company

Overall materiality £11,382,000 (2020: £10,000,000).

£10,813,000 (2020: £9,500,000).

How we 
determined it

Rationale  
for benchmark 
applied

1.8% of Net assets

2.0% of Net assets

The engagement team concluded 
that a net assets benchmark  
is the most appropriate when setting 
an overall materiality on the 2021 
audit engagement. We consider 
net assets to be the appropriate 
benchmark as it best aligns  
with the underlying interest  
of the stakeholders. 

The engagement team concluded 
that a net assets benchmark  
is the most appropriate when setting 
an overall materiality on the 2021 
audit engagement. We consider 
net assets to be the appropriate 
benchmark as it best aligns  
with the underlying interest  
of the stakeholders. 

The percentage of net assets  
of 1.8% is consistent with the prior 
period. The quantum of materiality 
was determined by considering  
the various benchmarks available  
to us as auditors, our experience  
of auditing other insurance groups 
and the business performance 
during 2021.

The percentage of net assets  
of 2.0% is consistent with the prior 
period. The quantum of materiality 
was determined by considering  
the various benchmarks available  
to us as auditors, our experience  
of auditing other insurance groups 
and the business performance 
during 2021.

For each component in the scope of our group 
audit, we allocated a materiality that is less 
than our overall group materiality. The range  
of materiality allocated across components  
was between £2.0 million and £10.0 million. 
Certain components were audited to a local 
statutory audit materiality that was also less 
than our overall group materiality.

of account balances, classes of transactions 
and disclosures, for example in determining 
sample sizes. Our performance materiality 
was 75% (2020: 75%) of overall materiality, 
amounting to £8,536,000 (2020: £7,500,000) 
for the group financial statements and 
£8,109,000 (2020: £7,100,000) for the parent 
company financial statements.

We use performance materiality to reduce  
to an appropriately low level the probability 
that the aggregate of uncorrected and 
undetected misstatements exceeds overall 
materiality. Specifically, we use performance 
materiality in determining the scope of our audit 
and the nature and extent of our testing  

In determining the performance materiality,  
we considered a number of factors  
– the history of misstatements, risk assessment 
and aggregation risk and the effectiveness  
of controls – and concluded that an amount  
at the upper end of our normal range  
was appropriate.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Independent auditors’ report to the members of Ecclesiastical Insurance Office plcSection FourSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
186

187

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.

However, because not all future events  
or conditions can be predicted, this conclusion 
is not a guarantee as to the group’s and  
the parent company’s ability to continue  
as a going concern.

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

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

We agreed with the Group Audit Committee 
that we would report to them misstatements 
identified during our audit above £560,000 
(group audit) (2020: £500,000) and £540,000 
(parent company audit) (2020: £475,000)  
as well as misstatements below those amounts 
that, in our view, warranted reporting  
for qualitative reasons.

Conclusions relating to going concern
Our evaluation of the directors’ assessment  
of the group’s and the parent company’s ability 
to continue to adopt the going concern basis  
of accounting included:

• Obtained and reviewed management’s 
updated going concern assessment  
which included the board approved income 
statement, balance sheet, cash flow  
and solvency forecasts;

• Considered the forward looking assumptions 

and assessed the reasonableness of this 
based on recent historic performance;
• Considered information obtained during  

the course of the audit and publicly available 
market information to identify any evidence 
that would contradict management’s 
assessment; and

• Considered our own independent alternative 
downside scenarios and whether these could 
impact the going concern assessment.

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 group’s and  
the parent 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.

Strategic Report and Directors’ Report
In our opinion, based on the work undertaken  
in the course of the audit, the information given 
in the Strategic report and Directors’ Report  
for the year ended 31 December 2021  
is consistent with the financial statements 
and has been prepared in accordance with 
applicable legal requirements.

In light of the knowledge and understanding 
of the group and parent company and their 
environment obtained in the course of the audit, 
we did not identify any material misstatements 
in the Strategic report and Directors’ Report.

Corporate governance statement
ISAs (UK) require us to review the directors’ 
statements in relation to going concern,  
longer-term viability and that part of the 
corporate governance statement relating  
to the parent company’s compliance with  
the provisions of the UK Corporate Governance 
Code, which the Listing Rules of the Financial 
Conduct Authority specify for review  
by auditors of premium listed companies.  
Our additional responsibilities with respect  
to the corporate governance statement  
as other information are described in the 
Reporting on other information section  
of this report.

Reporting on other information
The other information comprises all  
of the information in the Annual Report other 
than the financial statements and our auditors’ 
report thereon. The directors are responsible  
for the other information. Our opinion  
on the financial statements does not cover  
the other information and, accordingly,  
we do not express an audit opinion or, except  
to the extent otherwise explicitly stated  
in this report, any form of assurance thereon.

In connection with our audit of the financial 
statements, our responsibility is to read  
the other information and, in doing so, consider 
whether the other information is materially 
inconsistent with the financial statements  
or our knowledge obtained in the audit,  
or otherwise appears to be materially misstated. 
If we identify an apparent material inconsistency 
or material misstatement, we are required  
to perform procedures to conclude whether 
there is a material misstatement of the financial 
statements or a material misstatement of the 
other information. If, based on the work we have 
performed, we conclude that there is a material 
misstatement of this other information, we are 
required to report that fact. We have nothing  
to report based on these responsibilities.

With respect to the Strategic report and 
Directors’ Report, we also considered whether 
the disclosures required by the UK Companies 
Act 2006 have been included.

Based on our work undertaken in the course  
of the audit, the Companies Act 2006 requires 
us also to report certain opinions and matters  
as described below.

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Independent auditors’ report to the members of Ecclesiastical Insurance Office plcSection FourSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information188

189

Based on the work undertaken as part  
of our audit, we have concluded that each 
of the following elements of the corporate 
governance statement, included within  
the Governance and Strategic Report sections 
is materially consistent with the financial 
statements and our knowledge obtained during 
the audit, and we have nothing material  
to add or draw attention to in relation to:

• The directors’ confirmation that they have 

carried out a robust assessment  
of the emerging and principal risks;
• The disclosures in the Annual Report  
that describe those principal risks,  
what procedures are in place to identify 
emerging risks and an explanation of how 
these are being managed or mitigated;
• The directors’ statement in the financial 

statements about whether they considered  
it appropriate to adopt the going concern basis 
of accounting in preparing them, and their 
identification of any material uncertainties 
to the group’s and parent company’s ability 
to continue to do so over a period of at least 
twelve months from the date of approval  
of the financial statements;

• The directors’ explanation as to their 

assessment of the group’s and parent 
company’s prospects, the period this 
assessment covers and why the period  
is appropriate; and

• The directors’ statement as to whether they 

have a reasonable expectation that the parent 
company will be able to continue in operation 
and meet its liabilities as they fall due over 
the period of its assessment, including any 
related disclosures drawing attention to any 
necessary qualifications or assumptions.

Our review of the directors’ statement regarding 
the longer-term viability of the group was 
substantially less in scope than an audit 
and only consisted of making inquiries and 
considering the directors’ process supporting 
their statement; checking that the statement is 
in alignment with the relevant provisions of the 
UK Corporate Governance Code;  
and considering whether the statement  
is consistent with the financial statements  
and our knowledge and understanding  
of the group and parent company and their 
environment obtained in the course of the audit.

In addition, 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  
and our knowledge obtained during the audit:

• The directors’ statement that they consider 
the Annual Report, taken as a whole, is fair, 
balanced and understandable, and provides 
the information necessary for the members 
to assess the group’s and parent company’s 
position, performance, business model  
and strategy;

• The section of the Annual Report that 

describes the review of effectiveness of risk 
management and internal control systems; 
and

• The section of the Annual Report describing 

the work of the Group Audit Committee.

We have nothing to report in respect of our 
responsibility to report when the directors’ 
statement relating to the parent company’s 
compliance with the Code does not properly 
disclose a departure from a relevant provision 
of the Code specified under the Listing Rules  
for review by the auditors.

Responsibilities for the financial 
statements and the audit
Responsibilities of the directors  
for the financial statements
As explained more fully in the Directors’ 
responsibilities, the directors are responsible  
for the preparation of the financial statements 
in accordance with the applicable framework 
and for being satisfied that they give a true  
and fair view. The directors are also responsible 
for such internal control as they 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 group’s and the parent 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 group or the parent company 
or to cease operations, or have no realistic 
alternative but to do so.

Auditors’ 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 auditors’ report that includes 
our opinion. Reasonable assurance is a high 
level of assurance, but is not a guarantee that 
an audit conducted in accordance with ISAs 
(UK) will always detect a material misstatement 
when it exists. Misstatements can arise from 
fraud or error and are considered material if, 
individually or in the aggregate, they could 
reasonably be expected to influence  
the economic decisions of users taken  
on the basis of these financial statements.

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

Based on our understanding of the group and 
industry, we identified that the principal risks 
of non-compliance with laws and regulations 
related to breaches of UK regulation, such  
as those governed by the Prudential Regulation 
Authority and the Financial Conduct Authority, 
and we considered the extent to which 
non-compliance might have a material effect 
on the financial statements. We evaluated 
management’s incentives and opportunities 
for fraudulent manipulation of the financial 
statements (including the risk of override  
of controls), and determined that the principal 
risks were related to posting inappropriate 
journal entries to revenue or expenditure and 
management bias in accounting estimates 
specifically the valuation of specific general 
insurance reserves including asbestos and 

Physical and Sexual Abuse (“PSA”) reserves 
(see Key Audit Matters section). The group 
engagement team shared this risk assessment 
with the component auditors so that they 
could include appropriate audit procedures 
in response to such risks in their work. 
Audit procedures performed by the group 
engagement team and/or component  
auditors included:

• Enquiries of compliance, risk, internal audit, 
and the Group’s legal function, including 
consideration of known or suspected 
instances of non-compliance with laws  
and regulation and fraud;

• Reading key correspondence with  

the Prudential Regulation Authority  
and the Financial Conduct Authority in relation 
to compliance with laws and regulations;

• Reviewing relevant meeting minutes including 

those of the Group Board, Group Audit 
Committee and Group Risk Committee;

• Procedures relating to the valuation of specific 
general insurance reserves such as asbestos 
and PSA reserves described in the related key 
audit matters;

• Identifying and testing journal entries,  
in particular any journal entries posted  
with unusual account combinations in revenue 
or expenditure; and

• Designing audit procedures to incorporate 
unpredictability around the nature, timing  
or extent of our testing.

There are inherent limitations in the audit 
procedures described above. We are less  
likely to become aware of instances  
of non-compliance with laws and regulations 
that are not closely related to events  
and transactions reflected in the financial 
statements. Also, 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  
or intentional misrepresentations,  
or through collusion.

Our audit testing might include testing complete 
populations of certain transactions and  
balances, possibly using data auditing techniques.  

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021Independent auditors’ report to the members of Ecclesiastical Insurance Office plcSection FourSection OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Four

Independent auditors’ report to the members of Ecclesiastical Insurance Office plc

190

Appointment
Following the recommendation of the Group 
Audit Committee, we were appointed by the 
directors on 18 June 2020 to audit the financial 
statements for the year ended 31 December 
2020 and subsequent financial periods.  
The period of total uninterrupted engagement  
is 2 years, covering the years ended  
31 December 2020 to 31 December 2021.

Other matter
In due course, as required by the Financial 
Conduct Authority Disclosure Guidance and 
Transparency Rule 4.1.14R, these financial 
statements will form part of the ESEF-prepared 
annual financial report filed on the National 
Storage Mechanism of the Financial Conduct 
Authority in accordance with the ESEF 
Regulatory Technical Standard (‘ESEF RTS’). 
This auditors’ report provides no assurance 
over whether the annual financial report will  
be prepared using the single electronic  
format specified in the ESEF RTS.

Sue Morling (Senior Statutory Auditor)
for and on behalf of  
PricewaterhouseCoopers LLP
Chartered Accountants and Statutory Auditors
Bristol
17 March 2022

However, it typically involves selecting a limited 
number of items for testing, rather than testing 
complete populations. We will often seek to 
target particular items for testing based on their 
size or risk characteristics. In other cases,  
we will use audit sampling to enable us to draw 
a conclusion about the population from which 
the sample is selected.

A further description of our responsibilities  
for the audit of the financial statements  
is located on the FRC’s website at:  
www.frc.org.uk/auditorsresponsibilities.  
This description forms part of our  
auditors’ report.

Use of this report
This report, including the opinions, has been 
prepared for and only for the parent company’s 
members as a body in accordance with Chapter 
3 of Part 16 of the Companies Act 2006 and  
for no other purpose. We do not, in giving these 
opinions, accept or assume responsibility  
for any other purpose or to any other person  
to whom this report is shown or into whose 
hands it may come save where expressly 
agreed by our prior consent in writing.

Other required reporting
Companies Act 2006 exception reporting
Under the Companies Act 2006 we are 
required to report to you if, in our opinion:

• we have not obtained all the information  

and explanations we require for our audit; or
• adequate accounting records have not been 

kept by the parent company, or returns 
adequate for our audit have not been received 
from branches not visited by us; or

• certain disclosures of directors’ remuneration 

specified by law are not made; or

• the parent company financial statements  
are not in agreement with the accounting 
records and returns.

We have no exceptions to report arising from 
this responsibility.

Section Four

Financial Statements

Consolidated statement of profit or loss 

Consolidated and parent statement of comprehensive income 

Consolidated and parent statement of changes in equity 

Consolidated and parent statement of financial position 

Consolidated and parent statement of cash flows 

Notes to the financial statements 

192

193

194

195

196

197

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

 
 
 
 
 
 
 
 
 
 
Consolidated statement of profit or loss
for the year ended 31 December 2021
Consolidated statement of profit or loss  
for the year ended 31 December 2021

Revenue
Gross written premiums
Outward reinsurance premiums
Net change in provision for unearned premiums
Net earned premiums

Fee and commission income 
Other operating income
Net investment return
Total revenue

Expenses
Claims and change in insurance liabilities
Reinsurance recoveries
Fees, commissions and other acquisition costs
Other operating and administrative expenses
Total operating expenses

Operating profit/(loss)
Finance costs
Profit/(loss) before tax
Tax (expense)/credit
Profit/(loss) for the year (attributable to equity holders of the Parent)

Notes

5, 6
6
6

7

8

9
9
10

5
14
11

2021
£000

486,211
(198,601)
(14,620)
272,990

81,547
1,136
101,067
456,740

(269,633)
123,822
(95,896)
(135,632)
(377,339)

79,401
(2,364)
77,037
(17,648)
59,389

2020
£000

437,299
(173,074)
(16,562)
247,663

69,582
2,126
(4,298)
315,073

(222,794)
94,581
(85,444)
(116,393)
(330,050)

(14,977)
(769)
(15,746)
526
(15,220)

192

193

Consolidated and parent statements of comprehensive income
Consolidated and parent statements of comprehensive income  
for the year ended 31 December 2021
for the year ended 31 December 2021

Profit/(loss) for the year

Other comprehensive income
Items that will not be reclassified to profit or loss:
Fair value losses on property
Actuarial gains/(losses) on retirement benefit plans
Attributable tax

Items that may be reclassified subsequently to profit or loss:
(Losses)/gains on currency translation differences
Gains/(losses) on net investment hedges
Attributable tax

Net other comprehensive income/(expense)

Notes

2021

Group
£000

59,389

 -
38,660
(8,098)
30,562

(2,356)
1,912
(183)
(627)

29,935

18

26
26
26

Total comprehensive income/(loss) attributable to equity holders of the Parent 

89,324

Parent
£000

64,229

 -
38,660
(8,098)
30,562

551
(713)
131
(31)

30,531

94,760

2020

Group
£000

(15,220)

Parent
£000

(19,376)

(15)
(17,318)
3,521
(13,812)

1,980
(2,339)
265
(94)

(15)
(17,318)
3,521
(13,812)

(711)
279
(64)
(496)

(13,906)

(14,308)

(29,126)

(33,684)

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationConsolidated and parent statements of changes in equity
Consolidated and parent statements of changes in equity 
for the year ended 31 December 2021
for the year ended 31 December 2021

Group

Notes

15
15
15

15

At 1 January 2021
Profit for the year
Other net (expense)/income
Total comprehensive (expense)/income
Dividends
Gross charitable grant 
Tax relief on charitable grant
Reserve transfers
At 31 December 2021

At 1 January 2020
Loss for the year
Other net income/(expense)
Total comprehensive income/(expense)
Dividends
At 31 December 2020

Parent

At 1 January 2021
Profit for the year
Other net (expense)/income
Total comprehensive (expense)/income
Dividends
Gross charitable grant 
Tax relief on charitable grant
Group tax relief in excess 

of standard rate 
Reserve transfers
At 31 December 2021

At 1 January 2020
Loss for the year
Other net income/(expense)
Total comprehensive income/(expense)
Dividends
Group tax relief in excess 

of standard rate 
At 31 December 2020

Share
capital
£000

120,477
 -
 -
 -
 -
 -
 -
 -
120,477

120,477
 -
 -
 -
 -
120,477

120,477
 -
 -
 -
 -
 -
 -

 -
 -
120,477

120,477
 -
 -
 -
 -

 -
120,477

Share
premium
£000

Revaluation
reserve
£000

Translation
and hedging
reserve
£000

4,632
 -
 -
 -
 -
 -
 -
 -
4,632

4,632
 -
 -
 -
 -
4,632

4,632
 -
 -
 -
 -
 -
 -

 -
 -
4,632

4,632
 -
 -
 -
 -

 -
4,632

599
 -
(18)
(18)
 -
 -
 -
(313)
268

565
 -
34
34
 -
599

600
 -
(18)
(18)
 -
 -
 -

 -
(313)
269

565
 -
35
35
 -

 -
600

18,230
 -
(627)
(627)
 -
 -
 -
 -
17,603

18,324
 -
(94)
(94)
 -
18,230

7,067
 -
(31)
(31)
 -
 -
 -

 -
 -
7,036

7,564
 -
(497)
(497)
 -

 -
7,067

Retained
earnings
£000

425,290
59,389
30,580
89,969
(9,181)
(21,000)
3,990
313
489,381

463,537
(15,220)
(13,846)
(29,066)
(9,181)
425,290

348,644
64,229
30,580
94,809
(9,181)
(21,000)
3,990

Total
£000

569,228
59,389
29,935
89,324
(9,181)
(21,000)
3,990
 -
632,361

607,535
(15,220)
(13,906)
(29,126)
(9,181)
569,228

481,420
64,229
30,531
94,760
(9,181)
(21,000)
3,990

(87)
313
417,488

(87)
 -
549,902

391,519
(19,376)
(13,846)
(33,222)
(9,181)

524,757
(19,376)
(14,308)
(33,684)
(9,181)

(472)
348,644

(472)
481,420

The revaluation reserve represents cumulative net fair value gains on owner-occupied property. Further details of the translation and hedging 

reserve are included in note 26.

194

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

195
195

Consolidated and parent statements of financial position
Consolidated and parent statements of financial position
at 31 December 2021
at 31 December 2021

Notes

2021

Assets
Goodwill and other intangible assets
Deferred acquisition costs
Deferred tax assets
Pension surplus
Property, plant and equipment
Investment property
Financial investments
Reinsurers' share of contract liabilities
Current tax recoverable
Other assets
Cash and cash equivalents
Total assets

Equity
Share capital
Share premium account
Retained earnings and other reserves
Total shareholders' equity

Liabilities
Insurance contract liabilities
Investment contract liabilities
Lease obligations
Provisions for other liabilities
Pension deficit
Retirement benefit obligations
Deferred tax liabilities
Current tax liabilities
Deferred income
Subordinated liabilities
Other liabilities
Total liabilities

Group
£000

52,512
46,027
8,480
28,304
35,245
163,355
883,770
254,449
5
240,910
114,036
1,827,093

120,477
4,632
507,252
632,361

943,292
15,519
22,738
6,373
 -
7,058
48,355
1,232
28,385
24,433
97,347
1,194,732

16
17
29
18
19
20
21
27

23
24

25

27
32
33
28
18
18
29

30
31
30

Parent
£000

27,501
36,740
 -
28,304
32,771
162,822
707,106
171,922
5
194,808
48,437
1,410,416

120,477
4,632
424,793
549,902

673,598
 -
20,806
6,068
 -
7,058
46,123
819
21,951
24,433
59,658
860,514

A
A
b
b
o
o
u
u
t
t

A
b
o
u
t

U
U
s
s

U
s

S
S
e
e
c
c
t
t
i
i
o
o
n
n
O
O
n
n
e
e

S
e
c
t
i
o
n
O
n
e

2020

Group
£000

54,353
41,989
1,078
1,053
38,316
142,142
820,777
208,677
7,986
216,570
104,429
1,637,370

120,477
4,632
444,119
569,228

868,649
 -
25,450
6,499
10,406
6,530
29,846
1,293
25,908
 -
93,561
1,068,142

Parent
£000

24,265
33,472
 -
1,053
34,726
142,142
650,787
134,516
5,497
161,114
59,466
1,247,038

120,477
4,632
356,311
481,420

616,202
 -
22,838
5,842
10,406
6,530
28,562
1,293
18,858
 -
55,087
765,618

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

Total shareholders' equity and liabilities

1,827,093

1,410,416

1,637,370

1,247,038

The financial statements of Ecclesiastical Insurance Office plc, registered number 24869, on pages 192 to 261 were approved and authorised for 

issue by the Board of Directors on 17 March 2022 and signed on its behalf by:

i

F
n
a
n
c
a
l

i

David Henderson
Chair

Mark Hews
Group Chief Executive          

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
o
u
r

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated and parent statements of cash flows
Consolidated and parent statements of cash flows 
for the year ended 31 December 2021
for the year ended 31 December 2021

Notes

2021

Profit/(loss) before tax
Adjustments for:
Depreciation of property, plant and equipment
Revaluation of property, plant and equipment
Loss on disposal of property, plant and equipment
Amortisation and impairment of intangible assets
Loss on disposal of intangible assets
Impairment of shares in subsidiary undertakings
Profit on disposal of subsidiary
Net fair value (gains)/losses on financial instruments and investment 

property
Dividend and interest income
Finance costs
Adjustment for pension funding

Changes in operating assets and liabilities:
Net increase in insurance contract liabilities
Net increase in investment contract liabilities
Net increase in reinsurers' share of contract liabilities
Net increase in deferred acquisition costs
Net increase in other assets
Net increase in operating liabilities
Net (decrease)/increase in other liabilities
Cash generated by operations

Purchases of financial instruments and investment property
Sale of financial instruments and investment property
Dividends received
Interest received
Tax paid
Net cash from operating activities

Cash flows from investing activities
Purchases of property, plant and equipment
Proceeds from the sale of property, plant and equipment
Purchases of intangible assets
Acquisition of business, net of cash acquired
Disposal of subsidiary
Net cash used by investing activities

Cash flows from financing activities
Interest paid
Payment of lease liabilities
Change in interest in subsidiary
Proceeds from issue of subordinate debt, net of expenses
Dividends paid to Company's shareholders
Charitable grant paid to ultimate parent undertaking
Net cash used by financing activities

Net increase/(decrease) in cash and cash equivalents
Cash and cash equivalents at beginning of year
Exchange (losses)/gains on cash and cash equivalents
Cash and cash equivalents at end of year

Group
£000

77,037

6,155
 -
24
856
4,765
 -
 -

(58,340)
(21,802)
2,364
1,646

83,952
15,519
(49,513)
(4,376)
(25,891)
8,472
(234)
40,634

(186,514)
157,614
7,427
14,068
(3,142)
30,087

(3,634)
48
(3,914)
 -
 -
(7,500)

(2,364)
(3,209)
 -
25,014
(9,181)
(21,000)
(10,740)

11,847
104,429
(2,240)
114,036

Parent
£000

87,719

5,285
 -
11
622
87
 -
(5)

(58,384)
(18,822)
2,276
1,646

57,439
 -
(37,260)
(3,169)
(33,049)
8,544
114
13,054

(117,611)
103,706
9,547
8,830
(4,912)
12,614

(3,451)
19
(3,914)
 -
5
(7,341)

(2,276)
(2,512)
(5,406)
25,014
(9,181)
(21,000)
(15,361)

(10,088)
59,466
(941)
48,437

21

24

2020

Group
£000

Parent
£000

(15,746)

(20,398)

5,486
(10)
172
1,468
 -
 -
 -

18,602
(21,814)
769
1,003

94,180
 -
(45,101)
(3,352)
(35,369)
16,642
1,298
18,228

(121,754)
151,531
6,255
14,519
(2,756)
66,023

(6,028)
1
(15,602)
(822)
 -
(22,451)

(769)
(5,090)
 -
 -
(9,181)
 -
(15,040)

28,532
74,775
1,122
104,429

4,620
(10)
172
593
 -
58
 -

24,390
(17,185)
667
1,003

59,703
 -
(27,858)
(2,405)
(27,384)
10,148
1,212
7,326

(89,260)
129,725
6,812
9,332
(2,844)
61,091

(5,881)
1
(12,978)
 -
 -
(18,858)

(667)
(4,432)
(11,086)
 -
(9,181)
 -
(25,366)

16,867
42,248
351
59,466

196

197

Notes to the financial statements
Notes to the financial statements

1 Accounting policies
1 Accounting policies
Ecclesiastical Insurance Office plc (hereafter referred to as the ‘Company’, or ‘Parent’), a public limited company incorporated and domiciled in 

England, together with its subsidiaries (collectively, the ‘Group’) operates principally as a provider of general insurance and in addition offers a range 

of financial services, with offices in the UK & Ireland, Australia and Canada. The principal accounting policies adopted in preparing the International 

Financial Reporting Standards (IFRS) financial statements of the Group and Parent are set out below.

Basis of preparation
The Group’s consolidated and Parent's financial statements have been prepared using the following accounting policies, which are in accordance 

with UK adopted IFRS applicable at 31 December 2021 issued by the International Accounting Standards Board (IASB). The financial statements have 

been prepared on the historical cost basis, except for certain financial assets and derivatives measured at fair value through profit and loss (FVTPL), 

and the revaluation of properties and certain derivatives measured at fair value through other comprehensive income (FVOCI).

As stated in the Directors' Report, the directors consider that it is appropriate to continue to adopt the going concern basis in preparing the accounts.

In accordance with IFRS 4, Insurance Contracts,  on adoption of IFRS the Group applied existing accounting practices for insurance and participating 

investment contracts, modified as appropriate to comply with the IFRS framework and applicable standards, introducing changes only where they 

provide more reliable and relevant information.

Items included in the financial statements of each of the Group’s entities are measured in the currency of the primary economic environment in 

which that entity operates (the 'functional currency'). The consolidated financial statements are stated in sterling, which is the Company's functional 

currency and the Group’s presentational currency.

As permitted by Section 408 of the Companies Act 2006, a separate profit and loss account for the Company is not presented.

New and revised standards
A number of amendments and improvements to accounting standards have been issued by the International Accounting Standards Board (IASB), 

and endorsed by the UK, with an effective date of on or after 1 January 2021, and are therefore applicable for the 31 December 2021 financial 

statements. None had a significant impact on the Group.

IFRS 9, Financial Instruments , is effective for periods beginning on or after 1 January 2018. However the Group has taken the option available to 

insurers to defer the application of IFRS 9 as permitted by IFRS 4, Insurance Contracts . The Group qualifies for the temporary exemption, which is 

available until annual periods beginning on or after 1 January 2023, since at 31 December 2015 greater than 90% of its liabilities were within the 

scope of IFRS 4. The Parent qualifies for the temporary exemption since at 31 December 2015 greater than 80% of its liabilities were within the 

scope of IFRS 4 and it does not engage in significant activities unconnected with insurance. Other liabilities of the Parent include employment benefit 

and tax liabilities which arise solely because the Parent insures, or fulfils obligations arising from insurance contracts.  There has been no significant 

change to the Group or Parent's operations since 31 December 2015 and as a result, the Group and Parent continue to apply IAS 39, Financial 

Instruments .

Within the Group, Ecclesiastical Insurance Office plc and Ansvar Insurance Limited qualify for the temporary exemption from the requirements of 

IFRS 9. Within the Group, Ecclesiastical Life Limited previously qualified for the temporary exemption, however policies issued by Ecclesiastical Life 

Limited from 1 August 2021 do not give rise to liabilities within the scope of IFRS 4. Following this change in operations, Ecclesiastical Life Limited is 

still able to defer application of IFRS 9 for a further year, until 1 January 2023.

The following standards were in issue but were either not yet effective or have been deferred and therefore have not been applied in these financial 

statements.

IFRS 9, Financial Instruments
Key requirements
Provides a new model for the classification and measurement of financial instruments, a single, forward-looking ‘expected loss’ impairment model 

and a reformed approach to hedge accounting.

Effective date
Annual periods beginning on or after 1 January 2018. Although can be deferred until 2023 for insurers in line with the effective date of IFRS 17.

Expected impact on financial statements
It is expected that equity instruments will continue to be measured at fair value through profit or loss. The measurement of certain debt instruments 

may change to amortised cost or fair value through other comprehensive income. No changes are expected from the more principles-based hedge 

accounting requirements.  The Group is eligible for, and has applied, the deferral approach, which gives a temporary exemption from applying IFRS 

9 until the effective date of IFRS 17, Insurance contracts .

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
198

199

Notes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

Notes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

IFRS 17, Insurance Contracts
Key requirements
Requires insurance liabilities to be measured at a current fulfilment value and provides a more uniform measurement and presentation approach for 

all insurance contracts. These requirements are designed to achieve the goal of a consistent, principle-based accounting for insurance contracts.

Use of estimates
The preparation of financial statements requires the use of estimates and assumptions that affect the reported amounts of assets and liabilities, 

and the disclosure of contingent assets and liabilities at the date of the financial statements. Although these estimates are based on 

management’s best knowledge of current events and actions, actual results ultimately may differ from those estimates. Those estimates which 

have the most material impact on the financial statements are disclosed in note 2.

Effective date
Applicable to annual reporting periods beginning on or after 1 January 2023. The final standard remains subject to endorsement in the UK by the UK 

Endorsement Board which is expected to be complete in time for the 1 January 2023 effective date.

Operating profit or loss
Operating profit or loss is stated before finance costs.

Expected impact on financial statements
IFRS 17 is a comprehensive new accounting standard for insurance contracts covering recognition and measurement, presentation and disclosure. 

The accounting principles for the Group’s life insurance business (Whole-of-Life policies supporting pre-paid funeral plans, which ceased to be 

Basis of consolidation
Subsidiaries
Subsidiaries are those entities over which the Company, directly or indirectly, has control, with control being achieved when the Company has 

power over the investee, is exposed to variable return from its involvement with the investee and has the ability to use its power to affect its 

returns. The results and cash flows relating to subsidiaries acquired or disposed of in the year are included in the consolidated statement of 

written from 2013) are expected to be revised. These contracts are serviced over a long coverage period and applying IFRS 17 is expected to result in 

profit or loss, and the consolidated statement of cash flows, from the date of acquisition or up to the date of disposal. All inter-company 

expected profits attributable to future services (the contractual services margin concept within IFRS 17) being spread over the lifetime of the contract. 

transactions, balances and cash flows are eliminated.

Margins for prudence within the reserving basis will be replaced with an explicit risk adjustment defined as the compensation required by the entity 

for non-financial risks. A key judgement being assessed is whether sufficient information exists to apply the full retrospective approach to transition, 

otherwise a fair value approach is expected to be adopted.

The Group expects to use the premium allocation approach for the majority of its general business insurance contracts, and for which the deferral 

of expected future profits and initial recognition of losses are not expected to represent a significant change. The Group has developed draft 

accounting policies for the key accounting judgements. The key new items expected to impact net assets relate to:

Key item 

Impact

Level of aggregation for 

portfolios and groups of 

For the majority of  product lines, the Group issues packaged policies incorporating a range of lines of business within 

a single contract. Accounting policy development has focussed on applying the IASB’s Transition Resource Group’s 

insurance and reinsurance 

guidance to identify when it is appropriate to unbundle individual components and treat as separate contracts. In the 

In the Parent statement of financial position, subsidiaries are accounted for within financial investments at cost less impairment, in accordance 

with International Accounting Standard (IAS) 27, Separate Financial Statements.

The Group uses the acquisition method of accounting to account for business combinations. The cost of an acquisition is measured as the fair 

value of the assets given, equity instruments issued and liabilities incurred or assumed at the acquisition date. Identifiable assets acquired and 

liabilities and contingent liabilities assumed in a business combination are measured initially at their fair values at the acquisition date. Non-

controlling interests are measured either at fair value or at a proportionate share of the identifiable net assets of the acquiree. Goodwill is 

measured as the excess of the aggregate of the consideration transferred, the fair value of contingent consideration, the amount of non-

controlling interests and, for an acquisition achieved in stages, the fair value of previously held equity interest over the fair value of the 

identifiable net assets acquired. If the cost of acquisition is less than the fair value of the net assets acquired, the difference is recognised directly 

through profit or loss.

contracts 

majority of cases, the Group expects that its contracts should not be unbundled below the legal contract level. The 

For business combinations involving entities or businesses under common control, the cost of the acquisition equals the value of net assets 

most material determinant of portfolios of significant risks that are managed together is expected to be the 

transferred, as recognised by the transferor at the date of the transaction. No goodwill arises on such transactions.

geographic territories in which the Group underwrites its core general insurance products. An outcome of the draft 

policy is instances of up front recognition of losses on groups of onerous contracts within a portfolio will be triggered 

at a more granular level, although the transitional impact is not expected to be significantly different from applying 

the current Liability Adequacy Test under IFRS 4.

Eligibility for applying the 

premium allocation 

approach 

Draft definitions of what constitutes reasonably expected assumption changes on future profitability, and measuring 

the materiality of differences between the general measurement model and the premium allocation approach as a 

proportion of exposure, indicates that the majority of the Group’s general insurance products and associated 

reinsurance are expected to be eligible.

Foreign currency translation
The assets and liabilities of foreign operations are translated from their functional currencies into the Group's presentation currency using year-

end exchange rates, and their income and expenses using average exchange rates for the year. Exchange differences arising from the 

translation of the net investment in foreign operations are taken to the currency translation reserve within equity. On disposal of a foreign 

operation, such exchange differences are transferred out of this reserve, along with the corresponding movement on net investment hedges, 

and are recognised in the statement of profit or loss as part of the gain or loss on sale.

Foreign currency transactions are translated into the functional currency using exchange rates prevailing at the date of the transactions. 

Exchange gains and losses resulting from the settlement of such transactions, and from the translation of monetary assets and liabilities 

Discounting of the claims 

The Group already incorporates illiquidity into a discount rate, but this will be extended to all components of the 

denominated in foreign currencies, are recognised through profit or loss.

reserves 

reserve and not only the longer term liabilities. Aligning the illiquidity measurement to the characteristics of the 

liabilities is expected to increase the discount because general insurance liabilities in the incurred claims phase are 

highly illiquid and cannot be extinguished on demand by the Group or readily converted into cash by the policyholder.

Risk adjustment

For products applying the premium allocation approach, the Group’s reserves for incurred claims are currently 

measured using best estimate plus an explicit risk margin quantified using confidence level techniques. This is 

expected to remain the case, with policy development focussing on the level of diversification of risk informing each 

entity’s compensation required, to quantify the risk adjustment as aligned to risk appetite.

Expenses allocation

A new policy has been developed defining directly attributable expenses as those which are required in order to 

obtain and fulfil contracts, with other expenses being reported outside of insurance services. Under the premium 

allocation approach, the Group does not expect to choose to recognise insurance acquisition cash flows when they 

are incurred, with measurement therefore remaining similar to the current policy of deferring acquisition costs. The 

recurring nature of the Group’s acquisition cost expense base on renewing business means that all such incurred 

costs are expected to be attributable to groups of insurance contracts that have been recognised (impacting the 

liability for remaining coverage), with the presentation not expected to give rise to separate assets for insurance 
acquisition cash flows.

The Group is developing and testing the changes to existing processes required to apply new policies. It is not yet practicable to quantify the impact 

on the Group’s financial statements

Amendments to other standards in issue but not yet effective are not expected to materially impact the Group.

Product classification
Contracts under which the Group accepts significant insurance risk from another party (the policyholder) by agreeing to compensate the 

policyholder or other beneficiary if a specified uncertain future event (the insured event) adversely affects the policyholder are classified as 

insurance contracts. Contracts that do not transfer significant insurance risk are classified as investment or service contracts. All of the Group's 

life business contracts written up to April 2013 are classified as insurance contracts and those written from August 2021 are classified as 

investment contracts. 

Contracts may contain a discretionary participating feature, which is defined as a contractual right to receive additional benefits as a supplement 

to guaranteed benefits. The Group does not have any such participating contracts (referred to as with-profit contracts). The Group's long-term 

business contracts are referred to as non-profit contracts in the financial statements.

Premium income
General insurance business
Premiums are shown gross of commission paid to intermediaries and accounted for in the period in which the risk commences. Estimates are 

included for premiums not notified by the year end ('pipeline premiums') and provision is made for the anticipated lapse of renewals not yet 

confirmed. Those proportions of premiums written in a year which relate to periods of risk extending beyond the end of the year are carried 

forward as unearned premiums.

Premiums written include adjustments to premiums written in prior periods and estimates for pipeline premiums and are shown net of insurance 

premium taxes.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
200

201

Notes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

Notes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

Life insurance business
Insurance contract premiums are recognised as income when receivable, at which date the liabilities arising from them are also recognised.

(iii) Liability adequacy
At each reporting date, the Group reviews its unexpired risks and carries out a liability adequacy test for any overall excess of expected claims 

and deferred acquisition costs over unearned premiums, using the current estimates of future cash flows under its contracts. Unexpired risks are 

Fee and commission income
Fee and commission income consists primarily of reinsurance commissions and reinsurance profit commissions which are accounted for in 

assessed separately for each class of business.

accordance with IFRS 4, Insurance contracts . It also includes income from the Group's insurance broking activities, investment fund management 

Surpluses and deficits are offset where business classes are considered to be managed together and a provision is held for any net deficit.

fees, distribution fees from mutual funds and commission revenue from the sale of mutual fund shares which are accounted for in accordance with 

IFRS 15, Revenue from contracts with customers . 

As with general insurance premiums, reinsurance commissions are accounted for in the period in which the risk commences. Those proportions of 

reinsurance commissions written in a year which relate to periods of risk extending beyond the end of the year, are carried forward as deferred 

income. Reinsurance profit commissions are recognised at the point in time when the amount of commission can be accurately estimated. 

Life insurance provisions
Under current IFRS requirements, insurance contract liabilities are measured using accounting policies consistent with those adopted previously. 

The life insurance provision is held in respect of funeral plans and determined using methods and assumptions approved by the directors based 

on advice from the Chief Actuary. 

The life insurance provision is held in respect of certain funeral plans and is based on an estimate of the discounted future cash flows expected 

to arise from contracts in-force at the year-end date. The methods and assumptions used in calculating the provision are approved by the 

Income generated from the Group's insurance broking activities is recognised at the point at which the performance obligation is satisfied, being the 

directors based on advice from the Chief Actuary, including assumptions relating to future interest rates, inflation, mortality, expenses and 

inception date of the insurance cover, or, where this income is variable, the point at which it is reasonably certain that no significant reversal of the 

investment return. Changes in the life business provision are recognised in the statement of profit or loss.

amount recognised would occur. An estimate is made for the amount of fees and commission that may be clawed back as a result of policy 

cancellations or amendments in relation to performance obligations satisfied in the year. This is deducted from fee and commission income and 

recognised in provisions. Where commission or fees are received in advance of the inception date of cover, deferred income is recognised. 

Receivables are recognised in other debtors on inception date of cover in respect of fees or commissions that the Group has an unconditional right 

to receive.

Reinsurance
The Group assumes and cedes reinsurance in the normal course of business, with retention limits varying by line of business. Premiums on 

reinsurance assumed are recognised as revenue in the same manner as direct business. Outwards reinsurance premiums are accounted for in 

the same accounting period as the related premiums for the direct or inwards reinsurance business being reinsured. Estimates are included for 

premiums not notified by the year end and provision is made for the anticipated lapse of renewals not yet confirmed. The proportion of 

Fees charged for investment management services are variable based on funds under management and are recognised over time as the services 

premiums ceded in a year which relates to periods of risk extending beyond the current year is carried forward as unearned. The Group does 

are provided, once it is reasonably certain that no significant reversal of the amount recognised would occur. Fees charged for investment 

not reinsure its life business.

management services for institutional and retail fund management are also recognised on this basis.

Other operating income
Other operating income consists of the return of surplus reserves from a government-backed reinsurance scheme. It is recognised when the 

distribution is declared.

Net investment return
Net investment return consists of dividends, interest and rents receivable for the year, realised gains and losses, unrealised gains and losses on 

financial investments and investment properties. Dividends on equity securities are recorded as revenue on the ex-dividend date. Interest and rental 

income is recognised as it accrues.

Unrealised gains and losses are calculated as the difference between carrying value and original cost, and the movement during the year is 

recognised through profit or loss. The value of realised gains and losses includes an adjustment for previously recognised unrealised gains or 

losses on investments disposed of in the accounting period.

The impact of discount rate changes on insurance contract liabilities is also presented within net investment return in order to match with the 

corresponding movements of assets backing the liabilities.

Claims
General insurance claims incurred include all losses occurring during the year, whether reported or not, related handling costs, a reduction for the 

value of salvage and other recoveries, and any adjustments to claims outstanding from previous years.

Claims handling costs include all internal and external costs incurred in connection with the negotiation and settlement of claims.

Life business claims and death claims are accounted for when notified. 

Insurance contract liabilities 
General insurance provisions
(i) Outstanding claims provisions
General insurance outstanding claims provisions are based on the estimated ultimate cost of all claims incurred but not settled at the year-end date, 

Reinsurance assets primarily include balances due from both insurance and reinsurance companies for ceded insurance liabilities. Amounts 

recoverable from reinsurers are estimated in a manner consistent with the outstanding claims provisions or the settled claims associated with 

the reinsured policies and in accordance with the relevant reinsurance contract.

Further details on insurance contract liabilities are included in note 27.

Investment contract liabilities
For products that have no significant insurance risk and therefore classified as a investment contracts, the Group recognises a liability measured 

at fair value. The fair value of these liabilities is estimated based on an arms-length transaction between willing market participants with 

consideration given to the cost of the minimum repayment guarantee to the policyholders. The cost of the guarantee is determined using risk 

free rates of return, with the associated volatility assumption and allowing for the costs of administration associated with this low risk investment 

Intangible assets
Goodwill
Goodwill represents the excess of the cost of an acquisition over the fair value of the identifiable assets and liabilities acquired at the date of 

acquisition. Goodwill on acquisitions prior to 1 January 2004 (the date of transition to IFRS) is carried at book value (original cost less 

amortisation) on that date, less any subsequent impairment. Where it is considered more relevant, the Group uses the option to measure 

goodwill initially at fair value, less any subsequent impairment.

Goodwill is tested annually for impairment and carried at cost less accumulated impairment losses. Goodwill is allocated to cash-generating 

units for the purpose of impairment testing. Gains and losses on the disposal of an entity include the carrying amount of goodwill relating to the 

entity sold.

Computer software
Computer software is carried at historical cost less accumulated amortisation and impairment, and amortised over a useful life of between three 

and ten years, using the straight-line method. Amortisation and impairment charges incurred for the period are included in the statements of 

profit or loss within other operating and administrative expenses.

whether reported or not, together with related claims handling costs. Significant delays are experienced in the notification and settlement of certain 

Software costs that cannot be classified as intangible assets are charged to profit or loss during the period in which they are incurred.

types of general insurance claims, particularly in respect of liability business, the ultimate cost of which cannot be known with certainty at the year-

end date. An estimate is made representing the best estimate plus a uncertainty margin within a range of possible outcomes. Designated insurance 

liabilities are remeasured to reflect current market interest rates.

(ii) Provision for unearned premiums
The proportion of written premiums, gross of commission payable to intermediaries, attributable to subsequent periods is deferred as a provision for 

unearned premiums. The change in this provision is taken to profit or loss in order that revenue is recognised over the period of risk.

Other intangible assets
Other intangible assets consist of acquired brand, customer and distribution relationships, and are carried at cost at acquisition less accumulated 

amortisation and impairment after acquisition. Amortisation is on a straight-line basis over the weighted average estimated useful life of 

intangible assets acquired. Amortisation and impairment charges incurred for the period are included in the statement of profit or loss within 

other operating and administrative expenses.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
Notes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

Notes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

Property, plant and equipment
Owner-occupied properties are stated at fair value and movements are taken to the revaluation reserve within equity, net of deferred tax. When such 

Derivative financial instruments and hedging
Derivative financial instruments include foreign exchange contracts and other financial instruments that derive their value from underlying equity 

properties are sold, the accumulated revaluation surpluses are transferred from this reserve to retained earnings. 

instruments. 

202

203

Where the fair value of an individual property is below original cost, any revaluation movement arising during the year is recognised within net 

investment return in the statement of profit or loss. Valuations are carried out at least every three years by external qualified surveyors. All other 

items classed as property, plant and equipment within the statement of financial position are carried at historical cost less accumulated depreciation 

and impairment.

Land is not depreciated. No depreciation is provided on owner-occupied properties since such depreciation would be immaterial. Depreciation is 

calculated to write down the cost of other assets to their residual values over their estimated useful lives as follows:

Computer equipment
Motor vehicles
Fixtures, fittings and office equipment
Right-of-use assets

3 - 5 years straight line
4 years straight line or 27% reducing balance
3 - 10 years or length of lease straight line
Over the term of the lease

Where the carrying amount of an item carried at historical cost less accumulated depreciation is greater than its estimated recoverable amount, it is 

written down to its recoverable amount by way of an impairment charge to profit or loss.

Repairs and maintenance are charged to profit or loss during the financial period in which they are incurred.

Investment property
Investment property comprises land and buildings which are held for long-term rental yields. It is carried at fair value with changes in fair value 

recognised in the statement of profit or loss within net investment return. Investment property is valued annually by external qualified surveyors at 

open market value. Investment properties are derecognised when they have been disposed of. Where the Group disposes of a property, the carrying 

value immediately prior to the sale is adjusted to the transaction price, and the adjustment is recorded in profit or loss within net investment return.

Financial instruments 
IAS 39, Financial Instruments: Recognition and Measurement  requires the classification of certain financial assets and liabilities into separate 

categories for which the accounting requirements differ. 

All derivatives are initially recognised in the statement of financial position at their fair value, which usually represents their cost, including any 

premium paid. They are subsequently remeasured at their fair value, with the method for recognising changes in the fair value depending on 

whether they are designated as hedges of net investments in foreign operations. All derivatives are carried as assets when the fair values are 

positive and as liabilities when the fair values are negative.

The notional or contractual amounts associated with derivative financial instruments are not recorded as assets or liabilities in the statement of 

financial position as they do not represent the fair value of these transactions. Collateral pledged by way of cash margins on futures contracts is 

recognised as an asset in the statement of financial position within cash and cash equivalents.

Certain Group derivative transactions, while providing effective economic hedges under the Group’s risk management positions, do not qualify for 

hedge accounting under the specific IFRS rules and are therefore treated as derivatives held for trading. Their fair value gains and losses are 

recognised immediately in net investment return. The fair value gains and losses for derivatives which are hedge accounted in line with IFRIC 16 are 

recognised in other comprehensive income.

(b) Financial assets at fair value through other comprehensive income
Derivative instruments for hedging of net investments in foreign operations
On the date a foreign exchange contract is entered into, the Group designates certain contracts as a hedge of a net investment in a foreign operation 

(net investment hedge) and hedges the forward foreign currency rate.

Hedge accounting is used for derivatives designated in this way, provided certain criteria are met. At the inception of the transaction, the Group 

documents the relationship between the hedging instrument and the hedged item, as well as the risk management objective and the strategy for 

undertaking the hedge transaction. The Group also documents its assessment of whether the hedge is expected to be, and has been, highly effective 

in offsetting the risk in the hedged item, both at inception and on an ongoing basis.

Gains and losses on the hedging instrument, relating to the effective portion of the net investment hedge, are recognised in other comprehensive 

income and accumulated in the hedging reserve. The gain or loss relating to the ineffective portion is recognised immediately in profit or loss, and is 

included in net investment return.

Gains and losses on the hedging instrument relating to the effective portion of the hedge accumulated in the foreign currency translation reserve 

The classification depends on the nature and purpose of the financial assets and liabilities, and is determined at the time of initial recognition. Assets 

are reclassified to profit or loss on disposal of the related investment.

and liabilities held at fair value are disclosed according to a hierarchy that reflects the significance of observable market inputs in calculating those 

fair values. The three levels of the fair value hierarchy are included within note 4. Financial instruments are initially measured at fair value. Their 

subsequent measurement depends on their classification:

-

Financial instruments designated as fair value through profit or loss, those held for trading, and hedge accounted derivatives under IFRIC 16, 

Hedges of a Net Investment in a Foreign Operation , are subsequently carried at fair value. To the extent to which they are effective, changes to the 

fair value of hedging instruments are recognised in other comprehensive income, with all other fair value changes recognised through profit or 

loss in the period in which they arise.

(c) Loans and receivables
Loans and receivables, comprising loans and cash held on deposit for more than three months, are carried at amortised cost using the effective 

interest method. Loans are recognised when cash is advanced to borrowers. To the extent that a loan or receivable is uncollectable, it is written off 

as impaired. Subsequent recoveries are credited to profit or loss.

Subordinated liabilities
Subordinated liabilities are recognised initially at fair value, being the issue proceeds net of premiums, discounts and transaction costs incurred. All 

borrowings are subsequently measured at amortised cost using the effective interest rate method. The amortisation is recognised as an interest 

-

All other financial assets and liabilities are measured at amortised cost, using the effective interest method (except for short-term receivables and 

expense using the effective interest rate method.

payables when the recognition of interest would be immaterial).

Offset of financial assets and financial liabilities
Financial assets and liabilities are offset, and the net amount reported in the statement of financial position, when there is a legally enforceable right 

to offset the recognised amounts and there is an intention to settle on a net basis, or realise the asset and settle the liability simultaneously.

Financial investments
The Group accounts for financial assets under IAS 39 and classifies its financial investments as either financial assets at fair value through profit or 

loss (designated as such or held for trading), as financial assets at fair value through other comprehensive income or as loans and receivables. 

(a) Financial assets at fair value through profit or loss
Financial investments are classified into this category if they are managed, and their performance evaluated, on a fair value basis. Purchases and 

sales of these investments are recognised on the trade date, which is the date that the Group commits to purchase or sell the assets, at their fair 

Deferred acquisition costs
General insurance business
For general insurance business, a proportion of commission and other acquisition costs relating to unearned premiums is carried forward as 

deferred acquisition costs or, with regard to reinsurance outwards, as deferred income. Deferred acquisition costs are amortised over the period in 

which the related revenues are earned. The reinsurers’ share of deferred acquisition costs is amortised in the same manner as the underlying asset.

Life insurance business
For life insurance contracts, acquisition costs comprise direct costs such as initial commission and the indirect costs of obtaining and processing new 

business. Acquisition costs which are incurred during a financial year can be deferred and amortised over the period during which the costs are 

expected to be recoverable. No acquisition costs have been deferred on the Group's existing long-term business.

Cash and cash equivalents
Cash and cash equivalents include cash in hand, deposits held at call with banks, other short-term highly liquid investments with original maturities 

value adjusted for transaction costs. Financial investments within this category are classified as held for trading if they are derivatives that are not 

of three months or less and bank overdrafts.

accounted for as a net investment hedge or are acquired principally for the purpose of selling in the near term.

The fair values of investments are based on quoted bid prices. Where there is no active market, fair value is established using a valuation technique 

based on observable market data where available.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

Notes to the financial statements
Notes to the financial statements
1 Accounting policies (continued)
1 Accounting policies (continued)

204

205

Insurance broking debtors and creditors
Where the Group acts as an agent in placing the insurable risks of clients with insurers, debtors arising from such transactions are not included in 

the Group's assets. When the Group receives cash in respect of resultant premiums or claims, a corresponding liability is established in other 

creditors in favour of the insurer or client. Where the Group provides premium finance facilities to clients, amounts due are included in other debtors, 

with the amount owing for onward transmission included in other creditors.

Leases
Group as a lessee
Leases are recognised as a right-of-use asset and a corresponding lease liability at the date at which the lease asset is available for use by the 

Group. Each lease payment is deducted from the lease liability. Finance costs are charged to the profit and loss over the lease period so as to 

produce a constant periodic rate of interest on the remaining balance of the liability for each period. The right-of-use asset is depreciated over the 

shorter of the asset’s useful life and the lease term on a straight-line basis.

Lease liabilities are determined using the net present value of the payments over the lease term with the rate used to discount payments reflecting 

the rate implicit in the lease or, if it not readily determinable, the Group's incremental borrowing rate, and include:

Variable lease payments that are based on an index or rate;

-  Fixed payments less any lease incentives receivable;
- 
-  Amounts expected to be payable by the lessee under residual value guarantees;
- 
-  Payments and penalties from terminating the lease, if the lease term reflects the lessee exercising that option.

The exercise price of an option if the lessee is reasonably certain to exercise that option; and

Employee benefits
Pension obligations
The Group operates defined benefit and defined contribution pension plans, the assets of which are held in separate trustee-administered funds.

For defined benefit plans, the pension costs are assessed using the projected unit credit method. Under this method, the cost of providing pensions 

is charged to profit or loss so as to spread the regular cost over the service lives of employees. The pension obligation is measured as the present 

value of the estimated future cash outflows using a discount rate based on market yields for high-quality corporate bonds. The resulting pension 

plan surplus or deficit appears as an asset or obligation in the statement of financial position. Any asset resulting from this calculation is limited to 

the present value of economic benefits available in the form of refunds from the plan or reductions in future employer contributions to the plan. 

Independent actuarial valuations are carried out at the end of each reporting period.

In accordance with IAS 19, Employee Benefits,  current and past service costs, gains and losses on curtailments and settlements and net interest 

expense or income (calculated by applying a discount rate to the net defined benefit liability or asset) are recognised through profit or loss. Actuarial 

gains or losses are recognised in full in the period in which they occur in other comprehensive income. 

Contributions in respect of defined contribution plans are recognised as a charge to profit or loss as incurred.

Other post-employment obligations
Some Group companies provide post-employment medical benefits to their retirees. The expected costs of these benefits are accrued over the 

period of employment using an accounting methodology similar to that for defined benefit pension plans. Interest expense (calculated by applying a 

discount rate to the net obligations) is recognised through profit or loss. Actuarial gains and losses are recognised immediately in other 

Right-of-use assets are initially measured at cost and subsequently measured as cost less accumulated depreciation and comprises:

comprehensive income. Independent actuarial valuations are carried out at the end of each reporting period.

-  The amount of the initial measurement of lease liability;
-  Any lease payment made at or before the commencement date, less any lease incentives received;
-  Any initial direct costs; and
-  Restoration costs.

Right-of-use assets are presented within property, plant and equipment in the statement of financial position.

Payments associated with short-term leases are recognised on a straight-line basis as an expense in profit or loss. Short-term leases are leases 

with a lease term of 12 months or less.

Group as a lessor
The Group enters into lease agreements as a lessor with respect to some of its investment properties. The Group also sublets property no longer 

occupied by the Group.

Other benefits
Employee entitlements to annual leave and long service leave are recognised when they accrue to employees. A provision is made for the estimated 

liability for annual leave and long service leave as a result of services rendered by employees up to the year-end date.

Taxation
Income tax comprises current and deferred tax. Income tax is recognised in the statement of profit or loss except to the extent that it relates to items 

recognised in other comprehensive income, in which case it is recognised in the statement of comprehensive income.

Current tax is the expected tax payable on the taxable result for the period, after any adjustment in respect of prior periods. 

Deferred tax is provided in full on temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and 

the amounts used for tax purposes. Deferred tax is measured using tax rates expected to apply when the related deferred tax asset is realised, or 

the deferred tax liability is settled, based on tax rates and laws which have been enacted or substantively enacted at the year-end date.

Leases for which the Group is a lessor are classified as finance or operating leases. Whenever the terms of the lease transfer substantially all the 

risks and rewards of ownership to the lessee, the contract is classified as a finance lease. All other leases are classified as operating leases.

Deferred tax assets are recognised to the extent that it is probable that future taxable profit will be available against which the temporary 

differences can be utilised.

When the Group is an intermediate lessor, it accounts for the head lease and the sublease as two separate contracts. The sublease is classified as a 

finance or operating lease by reference to the right-of-use asset arising from the head lease.

Rental income from operating leases is recognised on a straight-line basis over the term of the relevant lease.

Amounts due from lessees under finance leases are recognised as receivables at the amount of the Group’s net investment in the leases. Finance 

lease income is allocated to accounting periods so as to reflect a constant periodic rate of return on the Group’s net investment outstanding in 

respect of the leases.

Provisions and contingent liabilities
Provisions are recognised when the Group has a present legal or constructive obligation, as a result of past events, and it is probable that an 

outflow of resources, embodying economic benefits, will be required to settle the obligation, and a reliable estimate of the amount of the obligation 

can be made. Where the Group expects a provision to be reimbursed, the reimbursement is recognised as a separate asset, but only when it is 

virtually certain that the reimbursement will be received.

The Group recognises a provision for onerous contracts when the expected benefits to be derived from a contract are less than the unavoidable 

costs of meeting the obligations under the contract.

Contingent liabilities are disclosed if there is a possible future obligation as a result of a past event, or if there is a present obligation but either an 

outflow of resources is not probable or the amount cannot be reliably estimated. 

Appropriations
Dividends
Dividends on Ordinary shares are recognised in equity in the period in which they are declared and, for the final dividend, approved by shareholders. 

Dividends on Non-Cumulative Irredeemable Preference shares are recognised in the period in which they are declared and appropriately approved.

Charitable grant to ultimate parent undertaking
Payments are made via Gift Aid to the ultimate parent company, Benefact Trust Limited, a registered charity. The Group does not regard these 

payments as being expenses of the business and, as such, recognises these net of tax in equity in the period in which they are approved.

Use of Alternative Performance Measures (APM)
As detailed in the Strategic Report, the Group uses certain key performance indicators which, although not defined under IFRS, provide useful 

information and aim to enhance understanding of the Group's performance. The key performance indicators should be considered complementary 

to, rather than a substitute for, financial measures defined under IFRS. Note 37 provides details of how these key performance indicators reconcile 

to the results reported under IFRS.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information206

207

Notes to the financial statements

Notes to the financial statements

2 Critical accounting estimates and judgements in applying accounting policies
2 Critical accounting estimates and judgements in applying accounting policies

The Group makes estimates and judgements that affect the reported amounts of assets and liabilities. Estimates and judgements are regularly 

reviewed and based on historical experience and other factors, including expectations of future events that are believed to be reasonable under the 

circumstances. Management have considered the current economic environment in their estimates and judgements.

(a) Critical judgements in applying the Group’s accounting policies
The following are the critical judgements, apart from those involving estimations which are dealt with separately below, that the directors have 

made in the process of applying the Group’s accounting policies and that have the most significant effect on the amounts recognised in the financial 

statements:

Pension and other post-employment benefits
The Group's pension and other post-employment benefit obligations are discounted at a rate set by reference to market yields at the end of the 

reporting period on high-quality corporate bonds that are denominated in the currency in which the benefits will be paid, and that have terms to 

maturity approximating the terms of the related pension liability. Judgement is required when setting the criteria for bonds to be included in the 

population from which the yield curve is derived. The most significant criteria considered for the selection of bonds includes the nature and quality of 

the corporate bonds and the identification of outliers which are excluded.

The Group also applies judgement in determining the extent to which a surplus in the defined benefit plan can be recognised in the statement of 

financial position. In accordance with IAS 19, Employee benefits, the recognisable surplus is limited to the lower of the surplus in the plan and the 

asset ceiling. The asset ceiling is the present value of future economic benefits available in the form of a refund or as a reduction in future 

contributions. The Group applies judgement in determining the asset ceiling in accordance with IFRS Interpretations Committee Interpretation 14 

(IFRIC 14).

Unlisted equity securities
The value of unlisted equity securities, where there is no active market and therefore no observable market price, are classified as level 3 financial 

assets. This requires the Group to make judgements in respect of the most appropriate valuation technique to apply. Further details, including the 

amounts recognised within the financial statements which are impacted by these judgements are shown in note 4(b).

Significant insurance risk

Whole-of-life policies issued by the Group where significant insurance risk has been accepted from a policyholder are accounted for as insurance 

contracts. Whole-of-life policies where the Groups has not accepted significant insurance risk from a policyholder are accounted for as financial 

instruments. Contracts can have features of, or appear to have features of, an insurance contract and therefore judgement is required on whether 

there is insurance risk and then whether that insurance risk is significant. Policies are considered to be insurance contracts where future benefits are 

linked to inflation as there is uncertainty over the timing and amount of a resulting claim. Policies that provide a policyholder with a guarantee to 

return the original premium have not transferred insurance risk and are considered financial instruments.

Leases
In determining the lease term, consideration is given to all facts and circumstances that create an economic incentive to exercise an extension option 

or not exercise a termination option. Extension options are only included in the lease term if the lease is reasonably certain to be extended. Most 

extension options have not been included in the lease liability because the Group could replace the assets without significant cost or business 

disruption.

The lease term is reassessed if an option is exercised (or not exercised) or the Group becomes obliged to exercise (or not exercise) it. The 

assessment of reasonable certainty is only revised if a significant event or change in circumstances occurs, which affects this assessment and is 

within the control of the Group. 

(b) Key sources of estimation uncertainty
In applying the Group’s accounting policies various transactions and balances are valued using estimates or assumptions. All estimates are based on 

Notes to the financial statements
Notes to the financial statements
2 Critical accounting estimates and judgements in applying accounting policies (continued)
2 Critical accounting estimates and judgements in applying accounting policies (continued)

The following items are considered key estimates and assumptions which, if actual results differ from those predicted, may have significant impact 

on the following year’s financial statements:

The ultimate liability arising from claims made under general business insurance contracts
The estimation of the ultimate liability arising from claims made under general business insurance contracts is a critical accounting estimate. There is 

uncertainty as to the total number of claims made on each business class, the amounts that such claims will be settled for and the timing of any 

such payments. There are various sources of estimation uncertainty as to how much the Group will ultimately pay with respect to such contracts. 

Such uncertainty includes:

- 
- 

- 

- 
- 

- 

- 

whether a claim event has occurred or not and how much it will ultimately settle for; 

variability in the speed with which claims are notified and in the time taken to settle them, especially complex cases resolved through the courts;

changes in the business portfolio affecting factors such as the number of claims and their typical settlement costs, which may differ significantly 

from past patterns;
new types of claim, including latent claims, which arise from time to time; 
changes in legislation and court attitudes to compensation, including the discount rate applied in assessing lump sums, which may apply 

retrospectively;
the way in which certain reinsurance contracts (principally liability) will be interpreted in relation to unusual/latent claims where aggregation of 

claimants and exposure over time are issues; and
whether all such reinsurances will remain in force over the long term.

The uncertainties surrounding the estimates of claims payments for the various classes of business are discussed further in note 3, and where 

discount rates have been applied these are disclosed in note 27(a). General business insurance liabilities include a margin for risk and uncertainty in 

addition to the best estimates for future claims. The sensitivity of profit or loss to changes in the ultimate settlement cost of claims reserves is 

presented in note 27(a).

Future benefit payments arising from life insurance contracts
The determination of the liabilities under life insurance contracts is dependent on estimates made by the Group.

Estimates are made as to the expected number of deaths for each of the years in which the Group is exposed to risk. The Group bases these 

estimates on standard industry and national mortality tables, adjusted to reflect recent historical mortality experience of the Group's portfolio, with 

allowance also being made for expected future mortality improvements where prudent. The estimated mortality rates are used to determine 

forecast benefit payments net of forecast premium receipts.

Estimates are also made as to future investment returns arising from the assets backing life insurance contracts. These estimates are based on 

current market returns as well as expectations about future economic and financial developments.

In addition to the best estimates of future deaths, inflation, investment returns and administration expenses, margins for risk and uncertainty are 

added to these assumptions in calculating the liabilities of life insurance contracts. The sensitivity of profit or loss to changes in the assumptions is 

presented in note 27(b)(iii).

Pension and other post-employment benefits
The cost of these benefits and the present value of the pension and other post-employment benefit liabilities depend on factors that are determined 

on an actuarial basis using a number of assumptions. Any change in these assumptions may affect planned funding of the pension plans. 

The discount rate assumption is a component in determining the charge to profit or loss. The effect of movements in the actuarial assumptions 

during the year, including discount rate, mortality, inflation, salary and medical expense inflation assumptions, on the pension and other post-

employment liabilities are recognised in other comprehensive income An explanation of the actuarial gains recognised in the current year is included 

in note 18.

The Group determines an appropriate discount rate at the end of each year, to be used to determine the present value of estimated future cash 

management’s knowledge of current facts and circumstances, assumptions based on that knowledge and their predictions of future events and 

outflows expected to be required to settle the pension and other post-employment benefit obligations.

actions.

The expected rate of medical expense inflation is determined by comparing the historical relationship of medical expense increases over a portfolio 

There is still some uncertainty as to the economic effect that both Covid-19 and higher inflation will have in both the short and long term. The key 

of UK-based post-retirement medical plans with the rate of inflation, making an allowance for the size of the plan and actual medical expense 

estimates and assumptions set out below include variables which may be impacted (either positively or negatively). These include but are not limited 

experience. 

to inflation, discount rate, long-term economic growth rate and investment market returns.

Other key assumptions for the pension and post-employment benefit costs and credits are based in part on current market conditions. Additional 

information including the sensitivity of pension and post-employment medical benefit scheme liabilities to changes in the key assumptions is 

disclosed in note 18.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements
2 Critical accounting estimates and judgements in applying accounting policies (continued)
2 Critical accounting estimates and judgements in applying accounting policies (continued)

Unlisted equity securities
The valuation of unlisted equity securities requires estimates to be made for the illiquidity discount and credit rating discount. Further details, 

including the sensitivity of the valuation to these inputs, are shown in note 4(b).

208

209

Notes to the financial statements
Notes to the financial statements

3 Insurance risk
3 Insurance risk
Through its general and life insurance operations, the Group is exposed to a number of risks, as summarised in the Risk Management section of the 

Strategic Report. The risk under any one insurance contract is the possibility that the insured event occurs and the uncertainty of the amount and 

timing of the resulting claim. Factors such as the business and product mix, the external environment including market competition and reinsurance 

capacity all may vary from year to year, along with the actual frequency, severity and ultimate cost of claims and benefits. This subjects the Group 

to underwriting and pricing risk (the risk of failing to ensure disciplined risk selection and to obtain the appropriate premium), claims reserving risk 

(the risk of  actual  claims  payments  exceeding the  amount  we are holding in reserves) and reinsurance risk (the risk of failing to access and 

manage reinsurance capacity at a reasonable price).

(a) Risk mitigation
Statistics demonstrate that the larger and more diversified the portfolio of insurance contracts, the smaller the relative variability in the expected 

outcome will be. The Group’s underwriting strategy is designed to ensure that the underwritten risks are well diversified in terms of type and amount 

of risk and geographical spread. In all operations pricing controls are in place, underpinned by sound statistical analysis, market expertise and 

appropriate external consultant advice. Gross and net underwriting exposure is protected through the use of a comprehensive programme of 

reinsurance using both proportional and non-proportional reinsurance, supported by proactive claims handling. The overall reinsurance structure is 

regularly reviewed and modelled to ensure that it remains optimum to the Group's needs. The optimal reinsurance structure provides the Group with 

sustainable, long-term capacity to support its specialist business strategy, with effective balance sheet and profit and loss protection at a reasonable 

cost.

Catastrophe protection is purchased following an extensive annual modelling exercise of gross and net (of proportional reinsurance) exposures. In 

conjunction with reinsurance brokers the Group utilises the full range of proprietary catastrophe models and continues to develop bespoke 

modelling options that better reflect the specialist nature of the portfolio. Reinsurance is purchased in line with the Group's risk appetite.

(b) Concentrations of risk
The core business of the Group is general insurance, with the principal classes of business written being property and liability. The miscellaneous 

financial loss class of business covers personal accident, fidelity guarantee and loss of money, income and licence. The other class of business 

includes cover of legal expenses and also a small portfolio of motor policies, but this has been in run-off in the United Kingdom since November 

2012. The Group's whole-of-life insurance policies support funeral planning products.

The table below summarises written premiums for the financial year, before and after reinsurance, by territory and by class of business:

2021

Group

Territory
United Kingdom and Ireland

Australia

Canada

Total

Parent

Territory
United Kingdom and Ireland

Canada

Total

General insurance

Life insurance

Property
£000

Liability
£000

Miscellaneous
financial
loss
£000

Other Whole of Life
£000
£000

Total
£000

Gross
Net
Gross
Net
Gross
Net
Gross
Net

Gross
Net
Gross
Net
Gross
Net

217,961
109,242
54,229
5,891
64,086
44,750
336,276
159,883

217,961
109,242
64,086
44,750
282,047
153,992

62,949
60,060
37,106
31,733
27,524
25,306
127,579
117,099

62,949
60,060
27,524
25,306
90,473
85,366

16,941
8,883
1,290
1,238
 -
 -
18,231
10,121

16,941
8,883
 -
 -
16,941
8,883

3,394
376
740
140
 -
 -
4,134
516

16,425
13,407
 -
 -
16,425
13,407

(9)
(9)
 -
 -
 -
 -
(9)
(9)

 -
 -
 -
 -
 -
 -

301,236
178,552
93,365
39,002
91,610
70,056
486,211
287,610

314,276
191,592
91,610
70,056
405,886
261,648

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements
3 Insurance risk (continued)
3 Insurance risk (continued)

Notes to the financial statements
Notes to the financial statements
3 Insurance risk (continued)
3 Insurance risk (continued)

210

211

2020

Group

Territory
United Kingdom and Ireland

Australia

Canada

Total

Parent

Territory
United Kingdom and Ireland

Canada

Total

General insurance

Life insurance

Property
£000

Liability
£000

Miscellaneous
financial
loss
£000

Other
£000

Whole of Life
£000

Total
£000

Gross
Net
Gross
Net
Gross
Net
Gross
Net

Gross
Net
Gross
Net
Gross
Net

203,921
107,458
48,665
7,299
51,920
35,846
304,506
150,603

203,922
107,458
51,920
35,846
255,842
143,304

57,634
55,095
29,279
24,840
24,033
22,425
110,946
102,360

57,634
55,095
24,033
22,425
81,667
77,520

16,273
9,080
1,332
1,283
 -
 -
17,605
10,363

16,273
9,080
 -
 -
16,273
9,080

3,328
716
902
171
 -
 -
4,230
887

4,005
752
 -
 -
4,005
752

12
12
 -
 -
 -
 -
12
12

 -
 -
 -
 -
 -
 -

281,168
172,361
80,178
33,593
75,953
58,271
437,299
264,225

281,834
172,385
75,953
58,271
357,787
230,656

(c) General insurance risks
Property classes
Property cover mainly compensates the policyholder for damage suffered to their property or for the value of property lost. Property insurance 

may also include cover for pecuniary loss through the inability to use damaged insured commercial properties.

For property insurance contracts, there can be variability in the nature, number and size of claims made in each period.

The nature of claims may include fire, business interruption, weather damage, escape of water, explosion (after fire), riot and malicious damage, 

subsidence, accidental damage, theft and earthquake. Subsidence claims are particularly difficult to predict because the damage is often not 

apparent for some time. The ultimate settlements can be small or large with a risk of a settled claim being reopened at a later date.

The number of claims made can be affected in particular by weather events, changes in climate, economic environment, and crime rates. Climate 

change may give rise to more frequent and extreme weather events, such as river flooding, hurricanes and drought, and their consequences, for 

example, subsidence claims. If a weather event happens near the end of the financial year, the uncertainty about ultimate claims cost in the financial 

statements is much higher because there is insufficient time for adequate data to be received to assess the final cost of claims.

Individual claims can vary in amount since the risks insured are diverse in both size and nature. The cost of repairing property varies according to the 

extent of damage, cost of materials and labour charges. 

Contracts are underwritten on a reinstatement basis or repair and restoration basis as appropriate. Costs of rebuilding properties, of replacement or 

indemnity for contents and time taken to bring business operations back to pre-loss levels for business interruption are the key factors that 

influence the cost of claims. Individual large claims are more likely to arise from fire, storm or flood damage. The greatest likelihood of an 

aggregation of claims arises from earthquake, weather or major spreading fire events.

Claims payment, on average, occurs within a year of the event that gives rise to the claim. However, there is variability around this average with 

Liability classes
The main exposures are in respect of liability insurance contracts which protect policyholders from the liability to compensate injured employees 

(employers' liability) and third parties (public liability).

Claims that may arise from the liability portfolios include damage to property, physical injury, disease and psychological trauma. The Group has a 

different exposure profile to most other commercial lines insurance companies as it has lower exposure to industrial risks. Therefore, claims for 

industrial diseases are less common for the Group than injury claims such as slips, trips and back injuries.

The frequency and severity of claims arising on liability insurance contracts can be affected by several factors. Most significant are the increasing 

level of awards for damages suffered, legal costs and the potential for periodic payment awards.

The severity of bodily injury claims can be influenced particularly by the value of loss of earnings and the future cost of care. The settlement value 

of claims arising under public and employers' liability is particularly difficult to predict. There is often uncertainty as to the extent and type of injury, 

whether any payments will be made and, if they are, the amount and timing of the payments, including the discount rate applied for assessing lump 

sums. Key factors driving the high levels of uncertainty include the late notification of possible claim events and the legal process.

Late notification of possible claims necessitates the holding of provisions for incurred claims that may only emerge some years into the future. In 

particular, the effect of inflation over such a long period can be considerable and is uncertain. A lack of comparable past experience may make it 

difficult to quantify the number of claims and, for certain types of claims, the amounts for which they will ultimately settle. The legal and legislative 

framework continues to evolve, which has a consequent impact on the uncertainty as to the length of the claims settlement process and the 

ultimate settlement amounts.

Claims payment, on average, occurs about three to four years after the event that gives rise to the claim. However, there is significant variability 

around this average.

Provisions for latent claims
The public and employers’ liability classes can give rise to very late reported claims, which are often referred to as latent claims. These can vary in 

nature and are difficult to predict. They typically emerge slowly over many years, during which time there can be particular uncertainty as to the 

number of future potential claims and their cost. The Group has reflected this uncertainty and believes that it holds adequate reserves for latent 

claims that may result from exposure periods up to the reporting date.

Note 27 presents the development of the estimate of ultimate claim cost for public and employers' liability claims occurring in a given year. This 

gives an indication of the accuracy of the estimation technique for incurred claims.

(d) Life insurance risks
The Group provides whole-of-life insurance policies to support funeral planning products, for most of which the future benefits are linked to 

inflation and backed by index-linked assets. None of the risks arising from this business are amongst the Group's principal risks and no new policies 

with insurance risk have been written in the life fund since 2013.

The primary risk on these contracts is the level of future investment returns on the assets backing the liabilities over the life of the policyholders is 

insufficient to meet future claims payments, particularly if the timing of claims is different from that assumed. The interest rate and inflation risk 

within this has been largely mitigated by holding index-linked assets of a similar term to the expected liabilities profile. The main residual risk is the 

spread risk attached to corporate bonds held to match the liabilities.

Uncertainty in the estimation of the timing of future claims arises from the unpredictability of long-term changes in overall levels of mortality. The 

Group bases these estimates on standard industry and national mortality tables and its own experience. The most significant factors that could alter 

the expected mortality rates profile are epidemics, widespread changes in lifestyle and continued improvement in medical science and social 

conditions. This small mortality risk is retained by the Group. The Group holds a reserve to meet the costs of future expenses in running the life 

larger claims typically taking longer to settle and business interruption claims taking much longer depending on the length of the indemnity period 

business and administration of the policies. There is a risk that this is insufficient to meet the expenses incurred in future periods. 

involved.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements

4 Financial risk and capital management
4 Financial risk and capital management
The Group is exposed to financial risk through its financial assets, financial liabilities, reinsurance assets and insurance liabilities. In particular, the key financial risk 

is that the proceeds from its financial assets are not sufficient to fund the obligations arising from its insurance contracts. The most important components of 

financial risk are interest rate risk, credit risk, equity price and currency risk.

There has been no change from the prior period in the nature of the financial risks to which the Group is exposed. Despite the rollout of the Covid-19 vaccine 

programmes in 2021, the subsequent conflict in Ukraine and recent international economic sanctions means there is continued uncertainty in relation to the 

economic risks to which the Group is exposed. This includes equity price volatility, movements in exchange rates and long-term UK growth prospects. The 

Group's management and measurement of financial risks is informed by either stochastic modelling or stress testing techniques.

(a) Categories of financial instruments
(i) Categories applying IAS 39

Group

Designated
at fair
value
£000

Financial assets

Held for
trading
£000

Loans and
receivables
£000

Hedge
accounted
derivatives
£000

Designated
at fair
value
£000

Financial liabilities 

Held for
trading
£000

Financial
liabilities¹
£000

Hedge
accounted
derivatives
£000

Other assets
and liabilities
£000

Total
£000

883,770
240,910
114,036
(22,738)
(24,433)
(81,828)
(15,519)
(461,837)
632,361

820,777
216,570
104,429
(25,450)
(93,561)
(453,537)
569,228

 -
8,357
 -
 -
 -
(13,394)
 -
(461,837)
(466,874)

 -
5,095
 -
 -
(12,093)
(453,537)
(460,535)

At 31 December 2021
Financial investments
Other assets
Cash and cash equivalents
Lease obligations
Subordinated liabilities
Other liabilities
Inv't contract liabilities
Net other
Total

At 31 December 2020
Financial investments
Other assets
Cash and cash equivalents
Lease obligations
Other liabilities
Net other
Total

Parent

At 31 December 2021
Financial investments
Other assets
Cash and cash equivalents
Lease obligations
Subordinated liabilities
Other liabilities
Net other

At 31 December 2020
Financial investments
Other assets
Cash and cash equivalents
Lease obligations
Other liabilities
Net other
Total

882,350
 -
 -
 -
 -
 -
 -
 -
882,350

817,551
 -
 -
 -
 -
 -
817,551

639,523
 -
 -
 -
 -
 -
 -
639,523

586,804
 -
 -
 -
 -
 -
586,804

¹ Financial liabilities are held at amortised cost.

336
 -
 -
 -
 -
 -
 -
 -
336

2,079
 -
 -
 -
 -
 -
2,079

481
 -
 -
 -
 -
 -
 -
481

2,079
 -
 -
 -
 -
 -
2,079

670
232,553
114,036
 -
 -
 -
 -
 -
347,259

746
211,475
104,429
 -
 -
 -
316,650

670
190,478
48,437
 -
 -
 -
 -
239,585

746
157,239
59,466
 -
 -
 -
217,451

414
 -
 -
 -
 -
 -
 -
 -
414

401
 -
 -
 -
 -
 -
401

269
 -
 -
 -
 -
 -
 -
269

401
 -
 -
 -
 -
 -
401

 -
 -
 -
 -
 -
 -
(15,519)
 -
(15,519)

 -
 -
 -
 -
 -
 -
 -

 -
 -
 -
 -
 -
 -
 -
 -

 -
 -
 -
 -
 -
 -
 -

 -
 -
 -
 -
 -
(331)
 -
 -
(331)

 -
 -
 -
 -
 -
 -
 -

 -
 -
 -
 -
 -
(331)
 -
(331)

 -
 -
 -
 -
(1,244)
 -
(1,244)

 -
 -
 -
(22,738)
(24,433)
(68,103)
 -
 -
(115,274)

 -
 -
 -
(25,450)
(80,224)
 -
(105,674)

 -
 -
 -
(20,806)
(24,433)
(48,571)
 -
(93,810)

 -
 -
 -
(22,838)
(44,008)
 -
(66,846)

 -
 -
 -
 -
 -
 -
 -
 -
 -

 -
 -
 -
 -
(1,244)
 -
(1,244)

 -
 -
 -
 -
 -
 -
 -
 -

 -
 -
 -
 -
 -
 -
 -

The carrying value of those financial assets and liabilities not carried at fair value in the financial statements is considered to approximate to their fair value.

212

213

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

(ii) Categories of financial assets applying IFRS 9

As disclosed in note 1, the Group has chosen to defer application of IFRS 9 and classifies and measures financial instruments using IAS 39. To 

facilitate comparison with entities applying IFRS 9, the table below sets out the Group's financial assets at the balance sheet date, split between 

those which have contractual cash flows that are solely payments of principal and interest on the principal outstanding (SPPI), other than those 

which are held for trading or whose performance is evaluated on a fair value basis, and all other financial assets.

Group

2021

2020

SPPI financial 

Other financial 

Total financial 

SPPI financial 

Other financial 

Total financial 

assets

£000

assets

£000

assets

£000

assets

£000

assets

£000

assets

£000

Financial investments
Cash and cash equivalents
Other financial assets
Total fair value

                      670 
              114,036 
            232,553 
            347,259 

            883,100 
                          -  
                          -  
            883,100 

            883,770 
              114,036 
            232,553 
         1,230,359 

                   746 
            104,429 
              211,475 
            316,650 

            820,031 
                      -   
                      -   
            820,031 

            820,777 
            104,429 
              211,475 
           1,136,681 

Parent

2021

2020

SPPI financial 

Other financial 

Total financial 

SPPI financial 

Other financial 

Total financial 

assets

£000

assets

£000

assets

£000

assets

£000

assets

£000

assets

£000

Financial investments
Cash and cash equivalents
Other financial assets
Total fair value

                      670 
               48,437 

190,478
239,585

            640,273 
                          -  
                          -  

640,273

            640,943 
               48,437 

190,478
879,858

                   746 
             59,466 
157,239
217,451

           589,284 
                      -   
 -
589,284

          590,030 
             59,466 
157,239
806,735

There has been a £30,609,000 increase (2020: £62,109,000 increase) in the fair value of SPPI financial assets of the Group, and a £63,069,000 

increase (2020: £32,112,000 decrease) in the fair value of other financial assets of the Group during the reporting period. There has been a 

£22,134,000 increase (2020: £39,217,000 increase) in the fair value of SPPI financial assets of the Parent, and a £50,989,000 increase (2020: 

£52,374,000 decrease) in the fair value of other financial assets of the Parent during the reporting period.

66,163
4,330
 -
 -
 -
(10,756)
(295,552)
(235,815)

707,106
194,808
48,437
(20,806)
(24,433)
(59,658)
(295,552)
549,902

60,757
3,875
 -
 -
(9,835)
(312,022)
(257,225)

650,787
161,114
59,466
(22,838)
(55,087)
(312,022)
481,420

S
t
a
t
e
m
e
n
t
s

i

F
n
a
n
c
a
l

i

S
e
c
t
i
o
n
F
o
u
r

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FiveOther Information 
 
Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

214

215

(b) Fair value hierarchy
The fair value measurement basis used to value those financial assets and financial liabilities held at fair value is categorised into a fair value 

hierarchy as follows:

Level 1: fair values measured using quoted bid prices (unadjusted) in active markets for identical assets or liabilities. This category includes listed 

equities in active markets, listed debt securities in active markets and exchange-traded derivatives.

Level 2: fair values measured using inputs other than quoted prices included within level 1 that are observable for the asset or liability, either 

directly (as prices) or indirectly (derived from prices). This category includes listed debt or equity securities in a market that is not active and 

derivatives that are not exchange-traded.

Level 3: fair values measured using inputs for the asset or liability that are not based on observable market data (unobservable inputs). This 

category includes unlisted debt and equities, including investments in venture capital, and suspended securities. Where a look-through valuation 

approach is applied, underlying net asset values are sourced from the investee, translated into the Group's functional currency and adjusted to 

reflect illiquidity where appropriate, with the fair values disclosed being directly sensitive to this input.

There have been no transfers between investment categories in the current year.

Analysis of fair value measurement bases

Group

At 31 December 2021
Financial assets at fair value through profit or loss
Financial investments
   Equity securities
   Debt securities
   Structured notes
   Derivatives
   Hedged accounted derivatives
Total financial assets at fair value

At 31 December 2020
Financial assets at fair value through profit or loss
Financial investments
   Equity securities
   Debt securities
   Derivatives
   Hedged accounted derivatives
Total financial assets at fair value

Fair value measurement at the
end of the reporting period based on
Level 1
£000

Level 2
£000

Level 3
£000

281,169
515,953
 -
 -
 -
797,122

262,014
493,601
 -
 -
755,615

186
1,412
14,649
336
414
16,997

185
1,512
2,079
401
4,177

68,947
34
 -
 -
 -
68,981

59,687
552
 -
 -
60,239

Total
£000

350,302
517,399
14,649
336
414
883,100

321,886
495,665
2,079
401
820,031

Parent

At 31 December 2021
Financial assets at fair value through profit or loss
Financial investments
   Equity securities
   Debt securities
   Derivatives
Hedged accounted derivatives
Total financial assets at fair value

At 31 December 2020
Financial assets at fair value through profit or loss
Financial investments
   Equity securities
   Debt securities
   Derivatives
Hedged accounted derivatives
Total financial assets at fair value

Fair value measurement at the
end of the reporting period based on
Level 1
£000

Level 2
£000

Level 3
£000

254,377
315,033
 -
 -
569,410

238,150
287,252
 -
 -
525,402

186
1,094
481
269
2,030

185
1,158
2,079
401
3,823

68,799
34
 -
 -
68,833

59,507
552
 -
 -
60,059

Total
£000

323,362
316,161
481
269
640,273

297,842
288,962
2,079
401
589,284

In the current year the derivative liabilities of the Group and Parent were measured at fair value through profit or loss. In the prior year the 

derivative liabilities of the Group were measured at fair value through other comprehensive income and the derivative liabilities of the Parent 

were measured at fair value through profit or loss. Derivative liabilities are categorised as level 2 (see note 22).

Fair value measurements based on level 3
Fair value measurements in level 3 for both the Group and Parent consist of financial assets, analysed as follows:

Group

At 31 December 2021
Opening balance
Total gains/(losses) recognised in profit or loss
Closing balance
Total gains/(losses) for the period included in profit or loss for assets
held at the end of the reporting period

At 31 December 2020
Opening balance
Total (losses)/gains recognised in profit or loss
Closing balance
Total (losses)/gains for the period included in profit or loss for assets
held at the end of the reporting period

Financial assets at fair value
through profit and loss

Equity
securities
£000

Debt
securities
£000

59,688
9,259
68,947

551
(517)
34

Total
£000

60,239
8,742
68,981

9,259

(517)

8,742

66,703
(7,015)
59,688

(7,015)

404
147
551

147

67,107
(6,868)
60,239

(6,868)

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information216

217

Notes to the financial statements
4 Financial risk and capital management (continued)
Notes to the financial statements
4 Financial risk and capital management (continued)

Parent

At 31 December 2021
Opening balance
Total gains/(losses) recognised in profit or loss
Closing balance
Total gains/(losses) for the period included in profit or loss for assets
held at the end of the reporting period

At 31 December 2020
Opening balance
Total (losses)/gains recognised in profit or loss
Closing balance
Total (losses)/gains for the period included in profit or loss for assets
held at the end of the reporting period

Financial assets at fair value
through profit and loss

Equity
securities
£000

Debt
securities
£000

59,508
9,292
68,800

551
(518)
33

Total
£000

60,059
8,774
68,833

9,292

(518)

8,774

66,523
(7,015)
59,508

(7,015)

404
147
551

147

66,927
(6,868)
60,059

(6,868)

All the above gains or losses included in profit or loss for the period (for both the Group and Parent) are presented in net investment return within

the statement of profit or loss. 

The valuation techniques used for instruments categorised in levels 2 and 3 are described below.

Listed debt and equity securities not in active market (level 2)
These financial assets are valued using third-party pricing information that is regularly reviewed and internally calibrated based on management's 

knowledge of the markets.

Non-exchange-traded derivative contracts (level 2)
The Group's derivative contracts are not traded in active markets. Foreign currency forward contracts are valued using observable forward exchange 

rates corresponding to the maturity of the contract and the contract forward rate. Over-the-counter equity or index options and futures are valued by 

reference to observable index prices. 

Structured notes (level 2)
These financial assets are not traded on active markets.  Their fair value is linked to an index that reflects the performance of an underlying basket of 

observable securities, including derivatives, provided by an independent calculation agent.

Unlisted equity securities (level 3)
These financial assets are valued using observable net asset data, adjusted for unobservable inputs including comparable price-to-book ratios based 

on similar listed companies, and management's consideration of constituents as to what exit price might be obtainable.

The valuation is sensitive to the level of underlying net assets, the Euro exchange rate, the price-to-tangible book ratio, an illiquidity discount and a 

credit rating discount applied to the valuation to account for the risks associated with holding the asset. If the illiquidity discount or credit rating 

discount applied changes by +/-10%, the value of unlisted equity securities could move by +/-£8m (2020: +/-£7m).

Unlisted debt (level 3)
Unlisted debt is valued using an adjusted net asset method whereby management uses a look-through approach to the underlying assets supporting 

the loan, discounted using observable market interest rates of similar loans with similar risk, and allowing for unobservable future transaction costs.

The valuation is most sensitive to the level of underlying net assets, but it is also sensitive to the interest rate used for discounting and the projected 

date of disposal of the asset, with the exit costs sensitive to an expected return on capital of any purchaser and estimated transaction costs. 

Reasonably likely changes in unobservable inputs used in the valuation would not have a significant impact on shareholders' equity or the net result. 

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

(c) Interest rate risk
The Group’s exposure to interest rate risk arises primarily from movements on financial investments that are measured at fair value and have fixed 

interest rates, which represent a significant proportion of the Group’s assets, subordinated debt which has a fixed interest rate until 2030, and from 

those insurance liabilities for which discounting is applied at a market interest rate. The Group's investment strategy is set in order to control the 

impact of interest rate risk on anticipated cash flows and asset and liability values. The fair value of the Group's investment portfolio of fixed income 

securities reduces as market interest rates rise as does the present value of discounted insurance liabilities, and vice versa.

Interest rate risk concentration is reduced by adopting asset-liability duration matching principles where appropriate. Excluding assets held to back 

the life business, the average duration of the Group’s fixed income portfolio is three years (2020: three years), reflecting the relatively short-term 

average duration of its general insurance liabilities. The mean term of discounted general insurance liabilities is disclosed in note 27(a)(iv).

For the Group’s life insurance business, consisting of policies to support funeral planning products, benefits payable to policyholders are 

independent of the returns generated by interest-bearing assets. Therefore, the interest rate risk on the invested assets supporting these liabilities is 

borne by the Group. This risk is mitigated by purchasing fixed interest investments with durations that match the profile of the liabilities. For funeral 

plan insurance policies, benefits are linked to the Retail Prices Index (RPI). Assets backing these liabilities are also linked to the RPI, and include index-

linked gilts and corporate bonds. For practical purposes it is not possible to exactly match the durations due to the uncertain profile of liabilities (for 

example mortality risk) and the availability of suitable assets, therefore some interest rate risk will persist. The Group monitors its exposure by 

comparing projected cash flows for these assets and liabilities and making appropriate adjustments to its investment portfolio.

The table below summarises the maturities of life insurance business assets and liabilities that are exposed to interest rate risk.

Group life business

At 31 December 2021
Assets
Debt securities
Cash and cash equivalents

Liabilities (discounted)
Life insurance business provision

At 31 December 2020
Assets
Debt securities
Cash and cash equivalents

Liabilities (discounted)
Life insurance business provision

Within
1 year
£000

Maturity
Between
1 and 5 years
£000

After
5 years
£000

Total
£000

6,120
5,269
11,389

26,768
 -
26,768

63,819
 -
63,819

96,707
5,269
101,976

4,787

16,686

52,436

73,909

6,083
4,692
10,775

30,161
 -
30,161

61,665
 -
61,665

97,909
4,692
102,601

5,103

18,045

53,709

76,857

Group financial investments with variable interest rates, including cash and cash equivalents, and insurance instalment receivables are subject to 

cash flow interest rate risk. This risk is not significant to the Group.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information218

219

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

(d) Credit risk
The Group has exposure to credit risk, which is the risk of non-payment of their obligations by counterparties and financial markets borrowers. 

Areas where the Group is exposed to credit risk are:

- 

- 

- 

- 

Counterparty default on loans and debt securities;

Deposits held with banks;

Reinsurers’ share of insurance liabilities (excluding provision for unearned premiums) and amounts due from reinsurers in respect 

of claims already paid; and

Amounts due from insurance intermediaries and policyholders.

The Group is exposed to minimal credit risk in relation to all other financial assets.

The carrying amount of financial and reinsurance assets represents the Group's maximum exposure to credit risk. The Group structures the levels 

of credit risk it accepts by placing limits on its exposure to a single counterparty. Limits on the level of credit risk are regularly reviewed. Where 

available the Group also manages its exposure to credit risk in relation to credit risk ratings. Investment grade financial assets are classified within 

the range of AAA to BBB ratings, where AAA is the highest possible rating. Financial assets which fall outside this range are classified as sub-

investment grade. ‘Not rated’ assets capture assets not rated by external ratings agencies.

Parent

At 31 December 2021
AAA
AA
A
BBB
Below BBB
Not rated

AAA
AA
A
BBB
Below BBB
Not rated

SPPI

Non-SPPI

Cash and cash 

Reinsurance 

Other financial 

equivalents¹ 

debtors 

assets 

Total SPPI 

Debt securities 

£000
 -
7,018
10,896
30,518
 -
5
48,437

 -
15,726
12,151
31,584
 -
5
59,466

£000
 -
1,828
5,585
3
 -
585
8,001

 -
1,592
3,008
3
 -
338
4,941

£000
 -
 -
 -
 -
 -
183,147
183,147

 -
 -
 -
 -
 -
153,044
153,044

£000
 -
8,846
16,481
30,521
 -
183,737
239,585

 -
17,318
15,159
31,587
 -
153,387
217,451

£000
89,099
61,199
108,443
44,598
4,379
8,443
316,161

72,697
51,769
96,351
55,456
5,539
7,150
288,962

The following table provides information regarding the credit risk exposure of financial assets with external credit ratings from Standard & Poors 

hand.

¹ Cash includes amounts held on deposit classified within financial investments and disclosed in note 21. Cash balances which are not rated relate to cash amounts in 

or an equivalent rating from a similar agency. This includes financial assets that meet the definition of 'solely payments of principal and interest' 

equivalents¹ 

debtors 

assets 

Total SPPI 

Debt securities 

The debt securities portfolio consists of a range of mainly fixed interest instruments including government securities, local authority issues, 

(SPPI), as detailed in note 4(a)(ii).

Group

At 31 December 2021
AAA
AA
A
BBB
Below BBB
Not rated

At 31 December 2020
AAA
AA
A
BBB
Below BBB
Not rated

Cash and cash 

Reinsurance 

Other financial 

SPPI

Non-SPPI

£000
 -
42,719
19,946
51,365
 -
6
114,036

 -
36,319
16,753
51,351
 -
6
104,429

£000
 -
2,651
9,424
3
 -
505
12,583

 -
1,986
8,564
3
 -
452
11,005

£000
 -
 -
 -
 -
 -
220,640
220,640

 -
 -
 -
 -
 -
201,216
201,216

£000
 -
45,370
29,370
51,368
 -
221,151
347,259

 -
38,305
25,317
51,354
 -
201,674
316,650

£000
171,502
122,895
129,795
72,653
7,895
12,659
517,399

128,037
130,285
125,745
94,101
8,997
8,500
495,665

¹ Cash includes amounts held on deposit classified within financial investments and disclosed in note 21. Cash balances which are not rated relate to cash amounts in 

hand.

For financial assets meeting the SPPI test that do not have low credit risk, the carrying amount disclosed above is an approximation of their fair 

value.

Group cash balances are regularly reviewed to identify the quality of the counterparty bank and to monitor and limit concentrations of risk.

corporate loans and bonds, overseas bonds, preference shares and other interest-bearing securities. Limits are imposed on the credit ratings of the 

corporate bond portfolio and exposures regularly monitored. Group investments in unlisted securities represent less than 1% of this category in the 

current and prior year.

The Group’s exposure to counterparty default on debt securities is spread across a variety of geographical and economic territories, as follows:

2021

Group
£000

265,506
104,530
119,622
27,741
517,399

Parent
£000

168,798
 -
119,622
27,741
316,161

2020

Group
£000

276,914
108,792
89,661
20,298
495,665

Parent
£000

179,003
 -
89,661
20,298
288,962

UK
Australia
Canada
Europe
Total

Reinsurance is used to manage insurance risk. This does not, however, discharge the Group's liability as primary insurer. If a reinsurer fails to pay a 

claim for any reason, the Group remains liable for the payment to the policyholder. The creditworthiness of reinsurers is considered on a regular 

basis through the year by reviewing their financial strength. The Group Reinsurance Security Committee assesses, monitors and approves the 

creditworthiness of all reinsurers, reviewing relevant credit ratings provided by the recognised credit rating agencies, as well as other publicly 

available data and market information. The Group Reinsurance Security Committee also monitors the balances outstanding from reinsurers and 

maintains an approved list of reinsurers. 

The Group's credit risk policy details prescriptive methods for the collection of premiums and control of intermediary and policyholder debtor 

balances. The level and age of debtor balances are regularly assessed via monthly credit management reports. These reports are scrutinised to 

assess exposure by geographical region and counterparty of aged or outstanding balances. Any such balances are likely to be major international 

brokers that are in turn monitored via credit reference agencies and considered to pose minimal risk of default. The Group has no material 

concentration of credit risk in respect of amounts due from insurance intermediaries and policyholders.

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
220

221

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

(e) Equity price risk
The Group is exposed to equity price risk because of financial investments held by the Group which are stated at fair value through profit or loss. 

The Group mitigates this risk by holding a diversified portfolio across geographical regions and market sectors, and through the use of derivative 

contracts from time to time which would limit losses in the event of a fall in equity markets.

The concentration of equity price risk by geographical listing, before the mitigating effect of derivatives, to which the Group and Parent are exposed 

is as follows:

2021

Group
£000

281,497
68,619
186
350,302

Parent
£000

254,557
68,619
186
323,362

UK
Europe
Hong Kong
Total

2020

Group
£000

262,414
59,287
185
321,886

Parent
£000

238,370
59,287
185
297,842

UK
Europe
Hong Kong
Total

(f) Currency risk

The Group operates internationally and its main exposures to foreign exchange risk are noted below. The Group's foreign operations generally 

invest in assets and purchase reinsurance denominated in the same currencies as their insurance liabilities, which mitigates the foreign currency 

exchange rate risk for these operations. As a result, foreign exchange risk arises from recognised assets and liabilities denominated in other 

currencies and net investments in foreign operations. The Group mitigates this risk through the use of derivatives when considered necessary.

The Group exposure to foreign currency risk within the investment portfolios arises from purchased investments that are denominated in currencies 

other than sterling.

The Group's foreign operations create two sources of foreign currency risk:

- 

The operating results of the Group's foreign branches and subsidiaries in the Group financial statements are translated at the average exchange

rates prevailing during the period; and

- 

The equity investment in foreign branches and subsidiaries is translated into sterling using the exchange rate at the year-end date.

The forward foreign currency risk arising on translation of these foreign operations is hedged by the derivatives which are detailed in note 22. The 

Group has designated certain derivatives as a hedge of its net investments in Canada and Australia, which have Canadian and Australian dollars 

respectively as their functional currency. 

(g) Liquidity risk
Liquidity risk is the risk that funds may not be available to pay obligations when due. The Group is exposed to daily calls on its available cash 

resources mainly from claims arising from insurance contracts. An estimate of the timing of the net cash outflows resulting from insurance contracts 

is provided in note 27. The Group has robust processes in place to manage liquidity risk and has available cash balances, other readily marketable 

assets and access to funding in case of exceptional need. This is not considered to be a significant risk to the Group.

Non-derivative financial liabilities consist of lease liabilities, for which a maturity analysis is included in note 33, and other liabilities for which a 

maturity analysis is included in note 30, and subordinated debt for which a maturity analysis is included in note 31.

(h) Market risk sensitivity analysis
The sensitivity of profit and other equity reserves to movements on market risk variables (comprising interest rate, currency and equity price risk), 

each considered in isolation and before the mitigating effect of derivatives, is shown in the table below. This table does not include the impact of 

variables on retirement benefit schemes. Financial risk sensitivities for retirement benefit schemes are disclosed separately in note 18.

Group

Variable

Interest rate risk

Currency risk

Equity price risk

Parent

Variable

Interest rate risk

Currency risk

Equity price risk

Change in
variable

-100 basis points
+100 basis points
-10%
+10%
+/-10%

Change in
variable

-100 basis points
+100 basis points
-10%
+10%
+/-10%

Potential increase/
(decrease) in profit

2021
£000

(6,797)
5,088
4,118
(3,369)
28,375

2020
£000

(11,896)
6,153
2,833
(2,318)
26,073

Potential increase/
(decrease) in profit

2020
£000

(9,642)
4,909
2,833
(2,318)
24,125

(4,999)
2,733
4,118
(3,369)
26,192

Potential increase/
(decrease) in
other equity reserves

2021
£000

54
(48)
10,845
(8,873)
 -

2020
£000

(70)
44
9,715
(7,948)
 -

Potential increase/
(decrease) in
other equity reserves

2021
£000

(19)
29
5,303
(4,339)
 -

2020
£000

(19)
29
3,692
(3,021)
 -

The largest currency exposures, before the mitigating effect of derivatives, with reference to net assets/liabilities are shown below, representing 

effective diversification of resources.

The following assumptions have been made in preparing the above sensitivity analysis:

2021

Group
£000

64,005
46,087
11,054
2,345
172

Parent
£000

14,131
46,087
11,054
2,345
172

Aus $
Can $
Euro
USD $
HKD $

2020

Group
£000

57,291
39,621
23,932
2,045
171

Parent
£000

3,089
39,621
23,932
2,045
171

Aus $
Can $
Euro
USD $
HKD $

The figures in the table above, for the current and prior years, do not include currency risk that the Group and Parent are exposed to on a ‘look 

through’ basis in respect of collective investment schemes denominated in sterling. The Group and Parent enter into derivatives to hedge currency 

exposure, including exposures on a ‘look through’ basis. The open derivatives held by the Group and Parent at the year end to hedge currency 

exposure are detailed in note 22.

-

-

-

-

The value of fixed income investments will vary inversely with changes in interest rates, and all territories experience the same interest 

rate movement;

Currency gains and losses will arise from a change in the value of sterling against all other currencies moving in parallel;

Equity prices will move by the same percentage across all territories; and

Change in profit is stated net of tax at the standard rate applicable in each of the Group's territories.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information222

223

Notes to the financial statements
Notes to the financial statements
4 Financial risk and capital management (continued)
4 Financial risk and capital management (continued)

(i) Capital management
The Group's primary objectives when managing capital are to:

-

-

Comply with the regulators' capital requirements of the markets in which the Group operates; and

Safeguard the Group's ability to continue to meet stakeholders' expectations in accordance with its corporate mission, vision and values.

The Group is subject to insurance solvency regulations in all the territories in which it issues insurance and investment contracts, and capital is 

managed and evaluated on the basis of both regulatory and economic capital, at a group and parent entity level.

In the UK, the Group and its UK regulated entities are required to comply with rules issued by the Financial Conduct Authority (FCA) and the 

Prudential Regulation Authority (PRA). 

Capital is assessed at both individual regulated entity and group level.  The PRA expects a firm, at all times, to hold Solvency II Own Funds in excess 

of its calculated Solvency Capital Requirement (SCR). Group solvency is assessed at the level of Ecclesiastical Insurance Office plc (EIO)’s parent, 

Benefact Group plc. Consequently, there is no directly comparable solvency measure for EIO group. Quantitative returns are submitted to the PRA, 

in addition to an annual narrative report, the Solvency and Financial Condition Report (SFCR) which is also published on the company's website. A 

further report, the Regular Supervisory Report (RSR) is periodically submitted to the PRA.

Notes to the financial statements
Notes to the financial statements

5 Segment information
5 Segment information
(a) Operating segments
The Group segments its business activities on the basis of differences in the products and services offered and, for general insurance, the 

underwriting territory. Expenses relating to Group management activities are included within 'Corporate costs'. This reflects the management and 

internal Group reporting structure. 

The activities of each operating segment are described below.

- General business

United Kingdom and Ireland
The Group's principal general insurance business operation is in the UK, where it operates under the Ecclesiastical and Ansvar brands. 

The Group also operates an Ecclesiastical branch in the Republic of Ireland underwriting general business across the whole of Ireland.

Australia
The Group has a wholly-owned subsidiary in Australia underwriting general insurance business under the Ansvar brand.

Canada
The Group operates a general insurance Ecclesiastical branch in Canada.

EIO’s Solvency II Own Funds will be subject to a separate independent audit, as part of the Group's process for Solvency II reporting to the PRA. The 

Other insurance operations
This includes the Group's internal reinsurance function, adverse development cover and operations that are in run-off or not reportable 

Group's regulated entities, EIO and ELL, expect to meet the deadline for submission to the PRA of 8 April 2022 and their respective SFCRs will be 

due to their immateriality.

made available on the Group's website shortly thereafter. Benefact Group is also expected to meet its deadline for submission to the PRA of 20 May 

2022, with its SFCR also being made available on the Group’s website shortly after.

-  Investment management

2021

2020

Ecclesiastical
Insurance
Office plc
Parent
£000

Ecclesiastical
Life Limited
£000

Ecclesiastical
Insurance
Office plc
Parent
£000

Ecclesiastical
Life Limited
£000

The Group provides investment management services both internally and to third parties through EdenTree Investment Management 

Limited.

-  Broking and advisory

The Group provides insurance broking through SEIB Insurance Brokers Limited and financial advisory services through Ecclesiastical 

Financial Advisory Services Limited.

-  Life business

Solvency II Own Funds

616,905

55,235

518,562

49,259

Ecclesiastical Life Limited provides long-term policies to support funeral planning products. The business reopened in the year but 

Economic capital is the Group’s own internal view of the level of capital required, and this measure is an integral part of the Own Risk and Solvency 

Assessment Report (ORSA) which is a private, internal forward-looking assessment of own risk, as required as part of the Solvency II regime. Risk 

appetite is set such that the target level of economic capital is always higher than the regulatory SCR.

remains closed to new insurance business.

-  Corporate costs

This includes costs associated with Group management activities.

Inter-segment and inter-territory transfers or transactions are entered into under normal commercial terms and conditions that would also be 

available to unrelated third parties.

The accounting policies of the operating segments are the same as the Group's accounting policies described in note 1, with the exception of the 

investment management and broking and advisory segments. These segments do not qualify for the temporary exemption from IFRS 9 available to 

insurers and as a result have adopted IFRS 9. Consequently, their accounting policies for financial instruments may differ, but all other accounting 

policies are the same as the Group.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements
5 Segment information (continued)
5 Segment information (continued)

Notes to the financial statements
Notes to the financial statements
Notes to the financial statements
5 Segment information (continued)
5 Segment information (continued)
5 Segment information (continued)

224

225

Segment revenue
The Group uses gross written premiums as the measure for turnover of the general and life insurance business segments. Turnover of the non-

insurance segments comprises fees and commissions earned in relation to services provided by the Group to third parties. Segment revenues do not 

include net investment return or general business fee and commission income, which are reported within revenue in the consolidated statement of 

profit or loss. 

Revenue is attributed to the geographical region in which the customer is based.

General business
   United Kingdom and Ireland
   Australia
   Canada
   Other insurance operations
Total
Life business
Investment management
Broking and advisory
Group revenue 

Gross
written
premiums
£000

297,235
93,365
91,610
4,010
486,220
(9)
 -
 -
486,211

2021

Non-
insurance
services
£000

 -
 -
 -
 -
 -
 -
14,908
11,346
26,254

Gross
written
premiums
£000

276,618
80,178
75,953
4,538
437,287
12
 -
 -
437,299

2020

Non-
insurance
services
£000

 -
 -
 -
 -
 -
 -
12,382
9,458
21,840

Total
£000

297,235
93,365
91,610
4,010
486,220
(9)
14,908
11,346
512,465

Total
£000

276,618
80,178
75,953
4,538
437,287
12
12,382
9,458
459,139

Group revenues are not materially concentrated on any single external customer.

Segment result

General business segment results comprise the insurance underwriting profit or loss, investment activities and other expenses of each underwriting 

territory. The Group uses the industry standard net combined operating ratio (COR) as a measure of underwriting efficiency. The COR expresses the 

total of net claims costs, commission and underwriting expenses as a percentage of net earned premiums. Further details on the underwriting profit 

or loss and COR, which are alternative performance measures that are not defined under IFRS, are detailed in note 37.

The life business segment result comprises the profit or loss on insurance contracts (including return on assets backing insurance liabilities in the 

long-term fund), shareholder investment return and other expenses. 

All other segment results consist of the profit or loss before tax measured in accordance with IFRS.

2021

General business
   United Kingdom and Ireland
   Australia
   Canada
   Other insurance operations

Life business
Investment management
Broking and advisory
Corporate costs
Profit/(loss) before tax

Combined
operating
ratio

85.3%
156.9%
88.6%

96.8%

Insurance
£000

Investments
£000

24,952
(13,306)
7,065
(9,952)
8,759
1,117
 -
 -
 -
9,876

87,106
1,924
246
(133)
89,143
3,981
 -
 -
 -
93,124

Other
£000

(2,098)
(34)
(156)
 -
(2,288)
 -
(2,525)
2,984
(24,134)
(25,963)

Total
£000

109,960
(11,416)
7,155
(10,085)
95,614
5,098
(2,525)
2,984
(24,134)
77,037

2020

2020

General business
   United Kingdom and Ireland
General business
   Australia
   United Kingdom and Ireland
   Canada
   Australia
   Other insurance operations
   Canada
   Other insurance operations
Life business
Investment management
Life business
Broking and advisory
Investment management
Corporate costs
Broking and advisory
Profit/(loss) before tax
Corporate costs
Profit/(loss) before tax

Combined
operating
Combined
ratio
operating
ratio
92.5%
102.2%
92.5%
91.2%
102.2%
91.2%
95.1%

95.1%

Insurance
£000
Insurance
£000
12,254
(620)
12,254
4,521
(620)
(4,103)
4,521
12,052
(4,103)
468
12,052
 -
468
 -
 -
 -
 -
12,520
 -
12,520

Investments
£000
Investments
£000
(12,123)
1,678
(12,123)
3,003
1,678
 -
3,003
(7,442)
 -
29
(7,442)
 -
29
 -
 -
 -
 -
(7,413)
 -
(7,413)

Other
£000
Other
£000
(479)
(31)
(479)
(176)
(31)
 -
(176)
(686)
 -
 -
(686)
(1,031)
 -
2,397
(1,031)
(21,533)
2,397
(20,853)
(21,533)
(20,853)

Total
£000
Total
£000
(348)
1,027
(348)
7,348
1,027
(4,103)
7,348
3,924
(4,103)
497
3,924
(1,031)
497
2,397
(1,031)
(21,533)
2,397
(15,746)
(21,533)
(15,746)

(b) Geographical information
Gross written premiums from external customers and non-current assets, as attributed to individual countries in which the Group operates, are as 
(b) Geographical information
Gross written premiums from external customers and non-current assets, as attributed to individual countries in which the Group operates, are as 
follows:

follows:

2021

2020

Non-current
assets
Non-current
£000
assets
£000
276,236
6,114
276,236
6,946
6,114
289,296
6,946
289,296
Gross written premiums are allocated based on the country in which the insurance contracts are issued. Non-current assets exclude rights arising 

United Kingdom and Ireland
Australia
United Kingdom and Ireland
Canada
Australia
Canada

Non-current
assets
Non-current
£000
assets
£000
301,523
2,925
301,523
6,227
2,925
310,675
6,227
310,675

Gross
written
Gross
premiums
written
£000
premiums
£000
301,236
93,365
301,236
91,610
93,365
486,211
91,610
486,211

Gross
written
Gross
premiums
written
£000
premiums
£000
281,168
80,178
281,168
75,953
80,178
437,299
75,953
437,299

2021

2020

Gross written premiums are allocated based on the country in which the insurance contracts are issued. Non-current assets exclude rights arising 
under insurance contracts, deferred tax assets, pension assets and financial instruments and are allocated based on where the assets are located.

under insurance contracts, deferred tax assets, pension assets and financial instruments and are allocated based on where the assets are located.

6 Net insurance premium revenue
6 Net insurance premium revenue
6 Net insurance premium revenue

For the year ended 31 December 2021
Gross written premiums
For the year ended 31 December 2021
Outward reinsurance premiums
Gross written premiums
Net written premiums
Outward reinsurance premiums
Net written premiums
Change in the gross provision for unearned premiums
Change in the provision for unearned premiums, reinsurers' share
Change in the gross provision for unearned premiums
Change in the net provision for unearned premiums
Change in the provision for unearned premiums, reinsurers' share
Earned premiums, net of reinsurance
Change in the net provision for unearned premiums
Earned premiums, net of reinsurance
For the year ended 31 December 2020
Gross written premiums
For the year ended 31 December 2020
Outward reinsurance premiums
Gross written premiums
Net written premiums
Outward reinsurance premiums
Net written premiums
Change in the gross provision for unearned premiums
Change in the provision for unearned premiums, reinsurers' share
Change in the gross provision for unearned premiums
Change in the net provision for unearned premiums
Change in the provision for unearned premiums, reinsurers' share
Earned premiums, net of reinsurance
Change in the net provision for unearned premiums
Earned premiums, net of reinsurance

General
business
General
£000
business
£000

486,220
(198,601)
486,220
287,619
(198,601)
287,619
(24,504)
9,884
(24,504)
(14,620)
9,884
272,999
(14,620)
272,999

437,287
(173,074)
437,287
264,213
(173,074)
264,213
(24,984)
8,422
(24,984)
(16,562)
8,422
247,651
(16,562)
247,651

Life
business
Life
£000
business
£000

(9)
 -
(9)
(9)
 -
(9)
 -
 -
 -
 -
 -
(9)
 -
(9)

12
 -
12
12
 -
12
 -
 -
 -
 -
 -
12
 -
12

Total
£000
Total
£000

486,211
(198,601)
486,211
287,610
(198,601)
287,610
(24,504)
9,884
(24,504)
(14,620)
9,884
272,990
(14,620)
272,990

437,299
(173,074)
437,299
264,225
(173,074)
264,225
(24,984)
8,422
(24,984)
(16,562)
8,422
247,663
(16,562)
247,663

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements
Notes to the financial statements

Notes to the financial statements
Notes to the financial statements
Notes to the financial statements

226

227

7 Fee and commission income
7 Fee and commission income
During the year, the Group recognised £55,019,000 (2020: £47,541,000) fee and commission income in accordance with IFRS 4, Insurance Contracts 
7 Fee and commission income
and £26,528,000 (2020: £22,041,000) in accordance with IFRS 15, Revenue from contracts with customers . Fee and commission income from
During the year, the Group recognised £55,019,000 (2020: £47,541,000) fee and commission income in accordance with IFRS 4, Insurance Contracts 
contracts with customers was recognised as follows:

and £26,528,000 (2020: £22,041,000) in accordance with IFRS 15, Revenue from contracts with customers . Fee and commission income from

Recognised at a 

Recognised 

contracts with customers was recognised as follows:

point in time 

Recognised at a 

£000

over time 
£000

Recognised 

Total 

£000

Total 

point in time 

£000
398
14,908
11,222
398
26,528
14,908
11,222
26,528
201
12,382
9,458
201
22,041
12,382
9,458
22,041

£000
398
7
11,222
398
11,627
7
11,222
11,627
201
66
9,458
201
9,725
66
9,458
9,725

over time 
£000
 -
14,901
 -
 -
14,901
14,901
 -
14,901
 -
12,316
 -
 -
12,316
12,316
 -
12,316

For the year ended 31 December 2021
General business
Investment management
For the year ended 31 December 2021
Broking and advisory
General business
Investment management
Broking and advisory
For the year ended 31 December 2020
General business
Investment management
For the year ended 31 December 2020
Broking and advisory
General business
Investment management
Broking and advisory
8 Net investment return
8 Net investment return
8 Net investment return
Income from financial assets at fair value through profit or loss
- equity income
- debt income
Income from financial assets at fair value through profit or loss
- structured note income
- equity income
Income from financial assets calculated using the effective interest rate method
- debt income
- cash and cash equivalents income
- structured note income
- other income received
Income from financial assets calculated using the effective interest rate method
Other income
- cash and cash equivalents income
- rental income
- other income received
- exchange movements
Other income
Investment income
- rental income
Fair value movements on financial instruments at fair value through profit or loss
- exchange movements
Fair value movements on investment property
Investment income
Fair value movements on property, plant and equipment
Fair value movements on financial instruments at fair value through profit or loss
Impact of discount rate change on insurance contract liabilities
Fair value movements on investment property
Net investment return/(loss)
Fair value movements on property, plant and equipment
Impact of discount rate change on insurance contract liabilities
Net investment return/(loss)
Included within fair value movements on financial instruments at fair value through profit or loss are gains of £6,434,000 (2020: £2,396,000) in 

(24)
8,648
1,999
605
30,863
8,648
38,102
605
20,238
30,863
 -
38,102
11,864
20,238
101,067
 -
11,864
101,067

2021
7,482
£000
12,123
30
7,482
12,123
(24)
30
1,999

141
8,786
1,887
492
30,192
8,786
(13,618)
492
(4,984)
30,192
10
(13,618)
(15,898)
(4,984)
(4,298)
10
(15,898)
(4,298)

2020
6,255
£000
12,631
 -
6,255
12,631
141
 -
1,887

2021
£000

2020
£000

respect of derivative instruments. 

Included within fair value movements on financial instruments at fair value through profit or loss are gains of £6,434,000 (2020: £2,396,000) in 

respect of derivative instruments. 

9 Claims and change in insurance liabilities and reinsurance recoveries
9 Claims and change in insurance liabilities and reinsurance recoveries
9 Claims and change in insurance liabilities and reinsurance recoveries

For the year ended 31 December 2021
Gross claims paid
For the year ended 31 December 2021
Gross change in the provision for claims
Gross claims paid
Gross change in life business provision
Gross change in the provision for claims
Claims and change in insurance liabilities
Gross change in life business provision
Reinsurers' share of claims paid
Claims and change in insurance liabilities
Reinsurers' share of change in the provision for claims
Reinsurers' share of claims paid
Reinsurance recoveries
Reinsurers' share of change in the provision for claims
Claims and change in insurance liabilities, net of reinsurance
Reinsurance recoveries
For the year ended 31 December 2020
Claims and change in insurance liabilities, net of reinsurance
Gross claims paid
For the year ended 31 December 2020
Gross change in the provision for claims
Gross claims paid
Gross change in life business provision
Gross change in the provision for claims
Claims and change in insurance liabilities
Gross change in life business provision
Reinsurers' share of claims paid
Claims and change in insurance liabilities
Reinsurers' share of change in the provision for claims
Reinsurers' share of claims paid
Reinsurance recoveries
Reinsurers' share of change in the provision for claims
Claims and change in insurance liabilities, net of reinsurance
Reinsurance recoveries
Claims and change in insurance liabilities, net of reinsurance
10 Fees, commissions and other acquisition costs
10 Fees, commissions and other acquisition costs
10 Fees, commissions and other acquisition costs

Fees paid
Commission paid
Fees paid
Change in deferred acquisition costs
Commission paid
Other acquisition costs
Change in deferred acquisition costs
Fees, commissions and other acquisition costs
Other acquisition costs
Fees, commissions and other acquisition costs

General
business
General
£000
business
£000
191,685
75,605
191,685
 -
75,605
267,290
 -
(83,235)
267,290
(40,587)
(83,235)
(123,822)
(40,587)
143,468
(123,822)
143,468
164,510
59,617
164,510
 -
59,617
224,127
 -
(59,024)
224,127
(35,557)
(59,024)
(94,581)
(35,557)
129,546
(94,581)
129,546

Life
business
Life
£000
business
£000
5,438
 -
5,438
(3,095)
 -
2,343
(3,095)
 -
2,343
 -
 -
 -
 -
2,343
 -
2,343
6,008
 -
6,008
(7,341)
 -
(1,333)
(7,341)
 -
(1,333)
 -
 -
 -
 -
(1,333)
 -
(1,333)

2021
£000
2021
21
£000
73,446
21
(4,376)
73,446
26,805
(4,376)
95,896
26,805
95,896

Total
£000
Total
£000
197,123
75,605
197,123
(3,095)
75,605
269,633
(3,095)
(83,235)
269,633
(40,587)
(83,235)
(123,822)
(40,587)
145,811
(123,822)
145,811
170,518
59,617
170,518
(7,341)
59,617
222,794
(7,341)
(59,024)
222,794
(35,557)
(59,024)
(94,581)
(35,557)
128,213
(94,581)
128,213

2020
£000
2020
13
£000
68,717
13
(3,352)
68,717
20,066
(3,352)
85,444
20,066
85,444

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information228

229

Notes to the financial statements
Notes to the financial statements
Notes to the financial statements

11 Profit/(loss) for the year
11 Profit/(loss) for the year
11 Profit/(loss) for the year

Profit/(loss) for the year has been arrived at after (crediting)/charging
Profit/(loss) for the year has been arrived at after (crediting)/charging
Net foreign exchange gains
Net foreign exchange gains
Depreciation of property, plant and equipment
Depreciation of property, plant and equipment
Loss on disposal of property, plant and equipment
Loss on disposal of property, plant and equipment
Amortisation of intangible assets
Amortisation of intangible assets
(Increase)/decrease in fair value of investment property
(Increase)/decrease in fair value of investment property
Employee benefits expense including termination benefits, net of recharges
Employee benefits expense including termination benefits, net of recharges

12 Auditor’s remuneration
12 Auditor's remuneration
12 Auditor's remuneration

Fees payable to the Company's auditor and its associates for the audit of the Company's 
Fees payable to the Company's auditor and its associates for the audit of the Company's 
annual accounts 
annual accounts 
Fees payable to the Company’s auditor and its associates for other services:
Fees payable to the Company’s auditor and its associates for other services:
- The audit of the Company's subsidiaries
- The audit of the Company's subsidiaries
Total audit fees
Total audit fees
- Audit-related assurance services
- Audit-related assurance services
Total non-audit fees
Total non-audit fees

Total auditor's remuneration
Total auditor's remuneration

2021
2021
£000
£000

(605)
(605)
6,155
6,155
24
24
829
829
(20,238)
(20,238)
98,838
98,838

2021
2021
£000
£000

599
599

347
347
946
946
214
214
214
214

1,160
1,160

2020
2020
£000
£000

(493)
(493)
5,486
5,486
172
172
1,433
1,433
4,984
4,984
83,865
83,865

2020
2020
£000
£000

476
476

238
238
714
714
178
178
178
178

892
892

Amounts disclosed are net of services taxes, where applicable. Audit-related assurance services include Prudential Regulatory Authority (PRA) and 
Amounts disclosed are net of services taxes, where applicable. Audit-related assurance services include Prudential Regulatory Authority (PRA) and 
other regulatory audit work.
other regulatory audit work.

Notes to the financial statements
Notes to the financial statements

13 Employee information
13 Employee information
The average monthly number of full-time equivalent employees of the Group and Parent, including executive directors, during the year by 

geographical location was:

Group

United Kingdom and Ireland
Australia
Canada

Parent

United Kingdom and Ireland
Canada

General
business
No.

860
110
78
1,048

General
business
No.

860
78
938

2021

Life
business
No.

1
 -
 -
1

2021

Life
business
No.

1
 -
1

General
business
No.

827
102
81
1,010

General
business
No.

827
81
908

2020

Life
business
No.

1
 -
 -
1

2020

Life
business
No.

1
 -
1

Other
No.

227
 -
 -
227

Other
No.

107
 -
107

Other
No.

194
 -
 -
194

Other
No.

92
 -
92

Average numbers of full-time equivalent employees have been quoted rather than average numbers of employees to give a better reflection of the 

split between business areas, as some employees' work is divided between more than one business area.  

Wages and salaries
Social security costs
Pension costs - defined contribution plans
Pension costs - defined benefit plans
Other post-employment benefits
Total staff costs

Staff costs recharged to related undertakings of the Group
Capitalised staff costs

2021

2020

Group
£000

86,072
8,101
6,411
1,646
83
102,313

(2,303)
(1,446)
98,564

Parent
£000

72,207
7,592
5,516
1,646
83
87,044

(12,260)
(1,446)
73,338

Group
£000

73,057
6,815
5,853
1,003
112
86,840

(1,743)
(1,652)
83,445

Parent
£000

61,194
6,347
5,101
1,003
112
73,757

(9,010)
(1,652)
63,095

The above Group figures do not include termination benefits of £274,000 (2020: £476,000) of which £nil (2020: £56,000) was recharged to related 

undertakings of the group. The above Parent figures do not include termination benefits of £274,000 (2020: £476,000), of which £10,000 (2020: 

£74,000) was recharged to related undertakings of the Parent.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements

14 Tax expense
14 Tax expense

(a) Tax charged/(credited) to the statement of profit or loss

Current tax

Deferred tax

Total tax expense/(credit)

- current year
- prior year adjustments
- temporary differences
- prior year adjustments
- Impact of change in deferred tax rate

230

231

Notes to the financial statements
Notes to the financial statements

15 Appropriations

2021
£000

13,178
1,468
(5,140)
(887)
9,029
17,648

2020
£000

1,027
(414)
(5,395)
 -
4,256
(526)

Amounts paid directly from equity in the period:

Dividends
Non-Cumulative Irredeemable Preference share dividend (8.625 pence per share)

Charitable grants
Gross charitable grants to the ultimate parent company, Benefact Trust Limited
Tax relief
Net appropriation for the year

2021
£000

2020
£000

9,181

9,181

21,000
(3,990)
17,010

 -
 -
 -

Tax on the Group’s result before tax differs from the United Kingdom standard rate of corporation tax for the reasons set out in the following 

reconciliation: 

Profit/(loss) before tax

Tax calculated at the UK standard rate of tax of 19% (2020: 19%)

Factors affecting charge/(credit) for the year:
Expenses not deductible for tax purposes
Non-taxable income
Life insurance and other tax paid at non-UK rates
Impact of differential between current and deferred tax rate
Tax losses utilised for which no deferred tax asset was recognised          
Deferred tax asset for tax losses not previously recognised
Impact of change in deferred tax rate
Adjustments to tax charge in respect of prior periods
Total tax expense/(credit)

2021
£000

77,037

14,637

(1,265)
(1,862)
(1,234)
707
(379)
(2,565)
9,029
580
17,648

2020
£000

(15,746)

(2,992)

84
(1,391)
90
 -
(159)
 -
4,256
(414)
(526)

A change in the UK standard rate of corporation tax from 19% to 25% will become effective from 1 April 2023. Deferred tax has been provided at 

an average rate of 24% (2020: 19%).

(b) Tax charged/(credited) to other comprehensive income

Current tax charged/(credited) on:

Fair value movements on hedge derivatives

Deferred tax charged/(credited) on:

Fair value movements on property
Actuarial movements on retirement benefit plans
Fair value movements on hedge derivatives
Impact of change in deferred tax rate

Total tax charged/(credited) to other comprehensive income

Tax relief on charitable grants of £3,990,000 (2020: £nil) has been taken directly to equity.

2021
£000

2020
£000

313

(328)

 -
9,665
(178)
(1,519)

(62)
(3,291)
53
(158)

8,281

(3,786)

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information232

233

Notes to the financial statements
Notes to the financial statements
Notes to the financial statements
16 Goodwill and other intangible assets (continued)
16 Goodwill and other intangible assets (continued)
16 Goodwill and other intangible assets (continued)

Other intangible assets consist of acquired brand, customer and distribution relationships, which have an overall remaining useful life of three years 

on a weighted average basis (2020: one year). 
Other intangible assets consist of acquired brand, customer and distribution relationships, which have an overall remaining useful life of three years 

on a weighted average basis (2020: one year). 
Parent

Parent

Computer
software
£000
Computer
software
£000
41,330
3,914
41,330
(1,964)
3,914
92
(1,964)
43,372
92
43,372
17,222
574
17,222
(1,876)
574
52
(1,876)
15,972
52
27,400
15,972
27,400

Cost
At 1 January 
Cost
Additions
At 1 January 
Disposals
Additions
Exchange differences
Disposals
At 31 December 
Exchange differences
Amortisation
At 31 December 
At 1 January 
Amortisation
Charge for the year
At 1 January 
Disposals
Charge for the year
Exchange differences 
Disposals
At 31 December 
Exchange differences 
Net book value at 31 December 
At 31 December 
Net book value at 31 December 
17 Deferred acquisition costs
17 Deferred acquisition costs
17 Deferred acquisition costs

At 1 January
Increase in the period
At 1 January
Release in the period
Increase in the period
Exchange differences 
Release in the period
At 31 December
Exchange differences 
All balances are current.
At 31 December

All balances are current.

2021

2021

Other
intangible
assets
Other
£000
intangible
assets
£000
198
 -
198
 -
 -
(13)
 -
185
(13)
185
41
48
41
 -
48
(5)
 -
84
(5)
101
84
101

Total
£000
Total
£000
41,528
3,914
41,528
(1,964)
3,914
79
(1,964)
43,557
79
43,557
17,263
622
17,263
(1,876)
622
47
(1,876)
16,056
47
27,501
16,056
27,501

Computer
software
£000
Computer
software
£000
29,163
12,780
29,163
(542)
12,780
(71)
(542)
41,330
(71)
41,330
17,249
552
17,249
(542)
552
(37)
(542)
17,222
(37)
24,108
17,222
24,108

2020

Other
2020
intangible
assets
Other
£000
intangible
assets
£000
 -
198
 -
 -
198
 -
 -
198
 -
198
 -
41
 -
 -
41
 -
 -
41
 -
157
41
157

2021

2020

2021

Group
£000
Group
41,989
£000
46,122
41,989
(41,746)
46,122
(338)
(41,746)
46,027
(338)
46,027

Parent
£000
Parent
33,472
£000
36,689
33,472
(33,520)
36,689
99
(33,520)
36,740
99
36,740

2020

Group
£000
Group
38,199
£000
41,582
38,199
(38,230)
41,582
438
(38,230)
41,989
438
41,989

Total
£000
Total
£000
29,163
12,978
29,163
(542)
12,978
(71)
(542)
41,528
(71)
41,528
17,249
593
17,249
(542)
593
(37)
(542)
17,263
(37)
24,265
17,263
24,265

Parent
£000
Parent
31,133
£000
33,515
31,133
(31,110)
33,515
(66)
(31,110)
33,472
(66)
33,472

Notes to the financial statements
Notes to the financial statements

16 Goodwill and other intangible assets
16 Goodwill and other intangible assets

Group

Cost
At 1 January 2021
Additions
Disposals
Exchange differences
At 31 December 2021
Accumulated impairment losses and amortisation
At 1 January 2021
Amortisation charge for the year
Impairment losses for the year
Disposals
Exchange differences 
At 31 December 2021
Net book value at 31 December 2021

Cost
At 1 January 2020
Additions
Disposals
Exchange differences
At 31 December 2020
Accumulated impairment losses and amortisation
At 1 January 2020
Amortisation charge for the year
Impairment losses for the year
Disposals
Exchange differences 
At 31 December 2020
Net book value at 31 December 2020

Goodwill
£000

Computer
software
£000

Other
intangible
assets
£000

24,697
 -
 -
 -
24,697

379
 -
27
 -
 -
406
24,291

23,779
918
 -
 -
24,697

344
 -
35
 -
 -
379
24,318

48,135
3,914
(6,641)
(73)
45,335

19,179
575
 -
(1,876)
53
17,931
27,404

33,069
15,407
(542)
201
48,135

18,537
1,219
 -
(542)
(35)
19,179
28,956

5,987
 -
 -
(12)
5,975

4,908
254
 -
 -
(4)
5,158
817

5,376
611
 -
 -
5,987

4,692
214
 -
 -
2
4,908
1,079

Total
£000

78,819
3,914
(6,641)
(85)
76,007

24,466
829
27
(1,876)
49
23,495
52,512

62,224
16,936
(542)
201
78,819

23,573
1,433
35
(542)
(33)
24,466
54,353

£16,885,000 of the goodwill balance in the current and prior year relates to the 2008 acquisition of South Essex Insurance Holdings Limited. 

£4,392,000 of the current and prior period balance relates to the acquisition of Lansdown Insurance Brokers Limited during 2014. £918,000 of the 

current and prior period balance relates to the acquisition of WRS Insurance Brokers Limited (WRS) during 2020.

Goodwill is tested annually for impairment and carried at cost less accumulated impairment losses. The calculations for all recoverable amounts 

use cash flow projections based on management-approved business plans, covering a three-year period, with forecast annual cash flows at the end 

of the planning period continuing thereafter in perpetuity at the UK long-term average growth rate, usually sourced from the Office for Budget 

Responsibility (OBR). The Group selected a rate of 1.7% (2020: 1.8%) as being appropriate, based on medium-term rates published in the OBR's 

November report. The pre-tax discount rate of 10.8% (2020: 9.8%) reflects the way that the market would assess the specific risks associated with 

the estimated cash flows.

The recoverable amount of the investment in South Essex Insurance Holdings Limited exceeds its carrying amount by £5.8m (2020: £4.4m). If the 

cumulative growth rate between 2022 and 2024 was 2.8% lower than assumed in management-approved business plans, or the discount rate 

increased by 1.9%, then the recoverable amount would equal the carrying amount. For the investment in Lansdown Insurance Brokers Limited, the 

headroom above the carrying value is significant and reasonably possible changes to the key assumptions do not result in impairment.

Assumptions used are consistent with historical experience within the business acquired and external sources of information.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information234

235

Notes to the financial statements
Notes to the financial statements

18 Retirement benefit schemes
18 Retirement benefit schemes
Defined contribution pension plans
The Group operates a number of defined contribution pension plans, for which contributions by the Group are disclosed in note 13.

Defined benefit pension plans
The Group's defined benefit plan is operated by the Parent in the UK. The plan closed to new entrants on 5 April 2006. The terms of the plan for 

future service changed in August 2011 from a non-contributory final salary scheme to a contributory scheme in which benefits are based on career 

average revalued earnings. The scheme closed to future accrual on 30 June 2019. Active members in employment at this date retained certain 

enhanced benefits after the plan closed to future accrual, including benefits in relation to death in service and ill health retirement. They also retain 

the link to final salary whilst they remain employed by the Parent. From 1 July 2019, active members in employment joined one of the Group’s 

defined contribution plans. The scheme previously had two discrete sections; the EIO Section and the Ansvar Section. With effect from 1 January 

2021, the two discrete sections of the scheme have been combined.

The assets of the defined benefit plan are held separately from those of the Group by the Trustee of the Ecclesiastical Insurance Office plc Staff 

Retirement Benefit Fund (the 'Fund'). The Fund is subject to the Statutory Funding Objective under the Pensions Act 2004. An independent qualified 

actuary appointed by the Trustee is responsible for undertaking triennial valuations to determine whether the Statutory Funding Objective is met. 

Pension costs for the plan are determined by the Trustee, having considered the advice of the actuary and having consulted with the employer. The 

most recent triennial valuation was at 31 December 2019. No contribution is expected to be paid by the Group in 2022.

Actuarial valuations were reviewed and updated by an actuary at 31 December 2021 for IAS 19 purposes. The surplus in the scheme attributable to 

the former EIO Section has been assessed against the economic benefit available to the Parent as a reduction in future contributions in accordance 

with IFRIC 14. This has resulted in the recognisable surplus being restricted by £17.5m. The Parent has an unconditional right to a refund of the 

surplus attributable to the former Ansvar Section of the Fund, which has been recognised in full in accordance with IFRIC 14. 

In the current year, actuarial gains arising from changes in financial assumptions of £19.4m (2020: actuarial losses of £53.6m) have been recognised 

in the statement of other comprehensive income. These gains resulted from a 0.6% increase in the discount rate partially offset by inflation-linked 

pension increases. In the prior year, actuarial losses were recognised as a result of a 0.6% fall in the discount rate combined with inflationary 

increases arising from a reduction in the gap between the RPI and CPI assumptions following the conclusion of the government's consultation on 

the future measure of RPI.

Certain mortality assumptions used in the IAS 19 valuation were reviewed and updated resulting in an actuarial gain of £4.2m (2020: £6.0m actuarial 

gain) being recognised in the current year. In the prior year, updating for actual member experience since the previous triennial valuation and for 

other financial assumption experience resulted in an actuarial gain of £14.5m.

A past service cost of £32,000 was recognised in the prior year following the High Court ruling relating to Guaranteed Minimum Pensions (GMP) 

equalisation for historic transfers values.

The defined benefit plan typically exposes the Group to risks such as:

-

Investment risk: The Fund holds some of its investments in asset classes, such as equities, which have volatile market values and, while these 

assets are expected to provide the best returns over the long term, any short-term volatility could cause funding to be required if a deficit 

emerges. Derivative contracts are used from time to time, which would limit losses in the event of a fall in equity markets;

- Interest rate risk: Scheme liabilities are assessed using market rates of interest to discount the liabilities and are therefore subject to any volatility 
in the movement of the market rate of interest. The net interest income or expense recognised in profit or loss is also calculated using the market 

rate of interest. The Group's defined benefit plan holds Liability Driven Investments (LDIs) to hedge part of the exposure of the scheme's liabilities 

to movements in interest rates;

- Inflation risk: A significant proportion of scheme benefits are linked to inflation. Although scheme assets are expected to provide a good hedge 

against inflation over the long term, movements over the short term could lead to a deficit emerging. The Group's defined benefit plan holds LDIs 

to hedge part of the exposure of the scheme's liabilities to movements in inflation expectations;

- Mortality risk: In the event that members live longer than assumed the liabilities may be understated originally, and a deficit may emerge if 

funding has not adequately provided for the increased life expectancy; and

- Currency risk: The Fund holds some of its investments in foreign denominated assets. As scheme liabilities are denominated in sterling, short-

term fluctuations in exchange rates could cause funding to be required if a deficit emerges. Currency derivative contracts are used from time to 

time, which would limit losses in the event of adverse movements in exchange rates.

Notes to the financial statements
Notes to the financial statements
18 Retirement benefit schemes (continued)
18 Retirement benefit schemes (continued)

The Trustees set the investment objectives and strategy for the Fund based on independent advice and in consultation with the employer. Key 

factors addressed in setting strategy include the Fund’s liability profile, funding level and strength of employer covenant. Their key objectives are to 

ensure the Fund can meet members’ guaranteed benefits as they fall due, reduce the risk of assets failing to meet its liabilities over the long term 

and manage the volatility of returns and overall funding level.

A blend of diversified growth assets (equities and property) and protection assets (bonds, gilts and cash) are deployed to balance the level of risk to 

that required to provide, with confidence, a sufficient return and liquidity to continue to meet members' obligations as they fall due. The Trustees 

have identified the key risks faced by the Fund in meeting this objective to be equity price risk, falls in bond yields and rising inflation.

Assets include an LDI portfolio, structured to increase in value with decreases in interest rates and grow in line with inflation expectations. This is 

estimated currently to hedge 65% of the interest rate and 75% of the inflation rate risk of the guaranteed benefits of the Fund. Exposure of the 

Fund's assets to interest rates and inflation counter-balances exposure of the Fund's liabilities to these factors and has reduced, but not eliminated, 

volatility in the funding position.

The Trustees monitor investment performance and strategy over time to ensure the structure adopted continues to meet their objectives and to 

highlight opportunities to reduce investment risk and volatility where practical and affordable, including the use of an equity protection strategy to 

reduce the impact of a material fall in equity markets. Their aim is to establish a Long Term Funding Target in line with guidance from the Pensions 

Regulator. The Trustees intend that this long term target will be reached through investment performance only and without requiring further 

contributions from the Parent.

The Trustees have recently adopted a Responsible and Sustainable Investment Policy with regards to the Fund’s equities. This includes an 'absence 

of harm' exclusion policy, as well as an aspiration to reduce the portfolio’s carbon intensity over time.

Group and Parent

The amounts recognised in the statement of financial position are determined as follows:
Present value of funded obligations 
Fair value of plan assets 

Restrictions on asset recognised
Net defined benefit pension scheme surplus/(deficit) in the statement of financial position

Movements in the net defined benefit pension scheme asset recognised in the statement of financial position 

are as follows: 
At 1 January
Expense charged to profit or loss
Amounts recognised in other comprehensive income
Contributions paid 
At 31 December

The amounts recognised through profit or loss are as follows:
Current service cost
Administration cost
Interest expense on liabilities
Interest income on plan assets 
Past service cost
Total, included in employee benefits expense

The amounts recognised in the statement of other comprehensive income are as follows:
Return on plan assets, excluding interest income
Experience (losses)/gains on liabilities
Gains from changes in demographic assumptions
Gains/(losses) from changes in financial assumptions
Change in asset ceiling
Total included in other comprehensive income

2021
£000

2020
£000

(377,113)
422,885
45,772
(17,468)
28,304

(403,709)
394,356
(9,353)
 -
(9,353)

(9,353)
(1,646)
39,303
 -
28,304

683
828
5,193
(5,058)
 -
1,646

34,200
(944)
4,155
19,360
(17,468)
39,303

8,505
(1,003)
(16,855)
 -
(9,353)

575
557
6,971
(7,132)
32
1,003

16,150
14,543
6,017
(53,565)
 -
(16,855)

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements
18 Retirement benefit schemes (continued)
18 Retirement benefit schemes (continued)

Notes to the financial statements
Notes to the financial statements
18 Retirement benefit schemes (continued)
18 Retirement benefit schemes (continued)

The following is the analysis of the defined benefit pension balances:

The movements in the fair value of plan assets and the present value of the defined benefit obligation over the year are as follows:

236

Ecclesiastical Insurance Office plc Annual Report & Accounts 2021

237
237

Group and Parent

Pension surplus
Pension deficit

The principal actuarial assumptions (expressed as weighted averages) were as follows:

Discount rate 
Inflation (RPI)
Inflation (CPI)
Future salary increases 
Future increase in pensions in deferment
Future average pension increases (linked to RPI)
Future average pension increases (linked to CPI)

Mortality rate

The average life expectancy in years of a pensioner retiring at age 65, at the year-end date, is as follows: 

Male
Female

The average life expectancy in years of a pensioner retiring at age 65, 20 years after the year-end date, is as 

follows: 
Male
Female

Plan assets are weighted as follows:

Cash and other1

Equity instruments
   UK quoted
   UK unquoted
   Overseas quoted

Liability driven investments - unquoted

Debt instruments
   UK public sector quoted - fixed interest
   UK non-public sector quoted - fixed interest
   UK quoted - index-linked

Derivative financial instruments - unquoted

Property

2021
£000

28,304
 -
28,304

2020
£000

1,053
(10,406)
(9,353)

%

1.90
3.40
3.00
4.50
3.60
3.20
2.20

22.7
24.0

23.5
25.2

£000

38,856

81,330
34
90,751
172,115

60,482

227
77,883
24,806
102,916

851

47,665

%

1.30
2.90
2.50
4.50
3.40
2.80
1.70

22.9
24.1

24.0
25.6

£000

36,657

83,040
552
80,704
164,296

57,519

243
68,500
24,383
93,126

885

41,873

1 Includes accrued income, prepayments and other debtors and creditors.

The actual return on plan assets was a gain of £39,258,000 (2020: a gain of £23,282,000).

The underlying assets of the LDIs are primarily UK government bonds and interest rate repurchase agreements at various rates and terms.

The fair value of unquoted securities is measured using inputs for the asset that are not based on observable market data. The fair value is estimated 

and approved by the Trustee based on the advice of investment managers. Property is valued annually by independent qualified surveyors using 

standard industry methodology to determine a fair market value. All other investments either have a quoted price in active markets or are valued 

based on observable market data.

422,885

394,356

Plan assets
At 1 January
Interest income
Actual return on plan assets, excluding interest income
Pension benefits paid and payable
At 31 December

Defined benefit obligation
At 1 January
Current service cost
Administration cost
Past service cost
Interest cost
Pension benefits paid and payable
Experience losses/(gains) on liabilities
Gains from changes in demographic assumptions
(Gains)/losses from changes in financial assumptions
At 31 December

Asset ceiling
At 1 January
Change in asset ceiling
At 31 December

History of plan assets and liabilities

Present value of defined benefit obligations
Fair value of plan assets

Restrictions on asset recognised
Surplus/(deficit)

2021
£000

394,356
5,058
34,200
(10,729)
422,885

403,709
683
828
 -
5,193
(10,729)
944
(4,155)
(19,360)
377,113

 -
17,468
17,468

2018
£000

(325,738)
341,869
16,131
 -
16,131

2020
£000

379,684
7,132
16,150
(8,610)
394,356

371,179
575
557
32
6,971
(8,610)
(14,543)
(6,017)
53,565
403,709

 -
 -
 -

2017
£000

(343,143)
363,179
20,036
 -
20,036

2021
£000

(377,113)
422,885
45,772
(17,468)
28,304

2020
£000

(403,709)
394,356
(9,353)
 -
(9,353)

2019
£000

(371,179)
379,684
8,505
 -
8,505

The weighted average duration of the defined benefit obligation at the end of the reporting period is 21 years (2020: 21 years).

Significant actuarial assumptions for the determination of the defined benefit obligation are discount rate, inflation, expected salary increases 

and mortality. The sensitivity analysis below has been determined based on reasonably possible changes in the assumptions occurring at the 

end of the reporting period assuming that all other assumptions are held constant.  

Assumption

Change in assumption

Discount rate

Inflation

Salary increase

Life expectancy

Increase by 0.5%
Decrease by 0.5%
Increase by 0.5%
Decrease by 0.5%
Increase by 0.5%
Decrease by 0.5%
Increase by 1 year
Decrease by 1 year

Increase/(decrease)
in plan liabilities
2021
£000

2020
£000

(35,010)
40,505
29,134
(26,435)
5,540
(5,128)
16,402
(16,021)

(39,500)
46,000
33,600
(29,100)
6,800
(6,300)
20,100
(20,000)

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
G
o
o
v
v
e
e
r
r
n
n
a
a
n
n
c
c
e
e

S
S
e
e
c
c
t
t
i
i
o
o
n
n
T
T
h
h
r
r
e
e
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021 
 
 
 
 
 
 
 
 
 
Notes to the financial statements
Notes to the financial statements
18 Retirement benefit schemes (continued)
18 Retirement benefit schemes (continued)

Notes to the financial statements
Notes to the financial statements

Post-employment medical benefits
The Parent operates a post-employment medical benefit plan, for which it chooses to self-insure. The method of accounting, assumptions and the 

19 Property, plant and equipment
19 Property, plant and equipment

238

239

Group

Cost or valuation
At 1 January 2021
Additions
Disposals
Transfers to investment property
Exchange differences
At 31 December 2021
Depreciation
At 1 January 2021
Charge for the year
Disposals
Exchange differences 
At 31 December 2021
Net book value at 31 December 2021

Cost or valuation
At 1 January 2020
Additions
Disposals
Revaluation
Exchange differences
At 31 December 2020
Depreciation
At 1 January 2020
Charge for the year
Disposals
Exchange differences 
At 31 December 2020
Net book value at 31 December 2020

Land and
buildings
£000

Motor
vehicles
£000

Furniture,
fittings and
equipment
£000

Computer
equipment
£000

Right-of-
use asset
£000

2,440
 -
 -
(975)
 -
1,465

 -
 -
 -
 -
 -
1,465

2,445
 -
 -
(5)
 -
2,440

 -
 -
 -
 -
 -
2,440

146
34
(68)
 -
 -
112

107
17
(50)
 -
74
38

146
 -
 -
 -
 -
146

87
20
 -
 -
107
39

14,971
2,444
(2,087)
 -
8
15,336

7,247
1,377
(2,087)
(5)
6,532
8,804

9,841
5,142
(10)
 -
(2)
14,971

6,536
712
(6)
5
7,247
7,724

11,363
1,155
(3,880)
 -
(16)
8,622

8,738
1,599
(3,880)
(13)
6,444
2,178

10,748
892
(300)
 -
23
11,363

7,539
1,481
(300)
18
8,738
2,625

31,766
746
(2,241)
 -
(77)
30,194

6,278
3,162
(1,952)
(54)
7,434
22,760

14,595
17,599
(535)
 -
107
31,766

3,291
3,273
(342)
56
6,278
25,488

Total
£000

60,686
4,379
(8,276)
(975)
(85)
55,729

22,370
6,155
(7,969)
(72)
20,484
35,245

37,775
23,633
(845)
(5)
128
60,686
 -
17,453
5,486
(648)
79
22,370
38,316

frequency of valuation are similar to those used for the defined benefit pension plans. 

The provision of the plan leads to a number of risks as follows:

-

-

-

-

-

Interest rate risk: The reserves are assessed using market rates of interest to discount the liabilities and are therefore subject to volatility in the 

movement of the market rates of interest. A reduction in the market rate of interest would lead to an increase in the reserves required to be 

held;

Medical expense inflation risk: Future medical costs are influenced by a number of factors including economic trends and advances in medical 

technology and sciences. An increase in medical expense inflation would lead to an increase in the reserves required to be held;

Medical claims experience: Claims experience can be volatile, exposing the Company to the risk of being required to pay over and above the 

assumed reserve. If future claims experience differs significantly from that experienced in previous years, this will increase the risk to the 

Company;

Spouse and widows' contributions: The self-insured benefit includes a potential liability for members who pay contributions in respect of their 

spouse and for widows who pay contributions. There is the possibility that the contributions charged may not be sufficient to cover the medical 

costs that fall due; and

Mortality risk: If members live longer than expected, the Company is exposed to the expense of medical claims for a longer period, with 

increased likelihood of needing to pay claims.

The amounts recognised in the statement of financial position are determined as follows:

Group and Parent

Present value of unfunded obligations and net obligations in the statement of financial position

Movements in the net obligations recognised in the statement of financial position are as follows: 

At 1 January
Total expense charged to profit or loss
Net actuarial losses during the year, recognised in other comprehensive income
Benefits paid 
At 31 December

The amounts recognised through profit or loss are as follows:
Interest cost 
Total, included in employee benefits expense

2021
£000

7,058

6,530
83
643
(198)
7,058

83
83

2020
£000

6,530

5,998
112
463
(43)
6,530

112
112

The weighted average duration of the net obligations at the end of the reporting period is 12.8 years (2020: 13.1 years).

The main actuarial assumptions for the plan are a long-term increase in medical costs of 7.4% (2020: 6.9%) and a discount rate of 1.9% (2020: 1.3%). 

An actuarial loss from experience of £814,000 has been recognised in the current year following a review of the medical cost scale. This has been 

partially offset by an actuarial gain of £130,000 arising from changes in financial assumptions. A small actuarial gain has been recognised due to 

changes in mortality assumptions. The sensitivity analysis below has been determined based on reasonably possible changes in the assumptions 

occurring at the end of the accounting period assuming that all other assumptions are held constant.

Assumption

Change in assumption

Discount rate

Medical expense inflation

Life expectancy

Increase by 0.5%
Decrease by 0.5%
Increase by 1.0%
Decrease by 1.0%
Increase by 1 year
Decrease by 1 year

Increase/(decrease)
in plan liabilities

2021
£000

(421)
464
875
(743)
513
(480)

2020
£000

(404)
445
851
(721)
576
(527)

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information240

241

Notes to the financial statements
Notes to the financial statements
19 Property, plant and equipment (continued)
19 Property, plant and equipment (continued)

Parent

Cost or valuation
At 1 January 2021
Additions
Disposals
Transfers to investment property
Exchange differences
At 31 December 2021
Depreciation
At 1 January 2021
Charge for the year
Disposals
Exchange differences 
At 31 December 2021
Net book value at 31 December 2021

Cost or valuation
At 1 January 2020
Additions
Disposals
Revaluation
Exchange differences
At 31 December 2020
Depreciation
At 1 January 2020
Charge for the year
Disposals
Exchange differences 
At 31 December 2020
Net book value at 31 December 2020

Land and
buildings
£000

Motor
vehicles
£000

Furniture,
fittings and
equipment
£000

Computer
equipment
£000

Right of
use asset
£000

2,040
 -
 -
(575)
 -
1,465

 -
 -
 -
 -
 -
1,465

2,045
 -
 -
(5)
 -
2,040

 -
 -
 -
 -
 -
2,040

53
 -
(39)
 -
 -
14

40
2
(28)
 -
14
 -

53
 -
 -
 -
 -
53

29
11
 -
 -
40
13

14,439
2,438
(2,045)
 -
9
14,841

6,922
1,321
(2,045)
(6)
6,192
8,649

9,315
5,138
(10)
 -
(4)
14,439

6,270
654
(6)
4
6,922
7,517

10,283
1,013
(3,795)
 -
10
7,511

7,989
1,432
(3,793)
7
5,635
1,876

9,846
742
(298)
 -
(7)
10,283

6,964
1,329
(300)
(4)
7,989
2,294

27,802
678
(2,195)
 -
29
26,314

4,940
2,530
(1,940)
3
5,533
20,781

11,362
16,994
(535)
 -
(19)
27,802

2,658
2,626
(342)
(2)
4,940
22,862

Total
£000

54,617
4,129
(8,074)
(575)
48
50,145

19,891
5,285
(7,806)
4
17,374
32,771

32,621
22,874
(843)
(5)
(30)
54,617

15,921
4,620
(648)
(2)
19,891
34,726

All properties of the Group and Parent were last revalued at 31 December 2020. Valuations were carried out by Cluttons LLP, an independent 

professional firm of chartered surveyors who have recent experience in the location and type of properties. Valuations were carried out using 

standard industry methodology to determine a fair value. All properties are classified as level 3 assets.

Movements in fair values are taken to the revaluation reserve within equity, net of deferred tax. When such properties are sold, the accumulated 

revaluation surpluses are transferred from this reserve to retained earnings. Where the fair value of an individual property is below original cost, 

any revaluation movement arising during the year is recognised within net investment return in the statement of profit or loss. There have been no 

transfers between investment categories in the current year.

The value of land and buildings of the Group on a historical cost basis is £1,464,000 (2020: £2,444,000). The value of land and buildings of the 

Parent on a historical cost basis is £1,464,000 (2020: £2,044,000).

Depreciation expense has been charged in other operating and administrative expenses.

Notes to the financial statements
Notes to the financial statements
Notes to the financial statements

20 Investment property
20 Investment property
20 Investment property

Fair value at 1 January
Fair value at 1 January
Transfers from property, plant and equipment
Transfers from property, plant and equipment
Disposals
Disposals
Fair value gains/(losses) recognised in profit or loss
Fair value gains/(losses) recognised in profit or loss
Fair value at 31 December
Fair value at 31 December

2021
2021

Group
Group
£000
£000
142,142
142,142
975
975
 -
 -
20,238
20,238
163,355
163,355

Parent
Parent

142,142
142,142
575
575
 -
 -
20,105
20,105
162,822
162,822

2020
2020

Group
Group
£000
£000
148,146
148,146
 -
 -
(1,020)
(1,020)
(4,984)
(4,984)
142,142
142,142

Parent
Parent
£000
£000
148,146
148,146
 -
 -
(1,020)
(1,020)
(4,984)
(4,984)
142,142
142,142

The Group’s investment properties were last revalued at 31 December 2021 by Cluttons LLP, an independent professional firm of chartered 
The Group’s investment properties were last revalued at 31 December 2021 by Cluttons LLP, an independent professional firm of chartered 
surveyors who have recent experience in the location and type of properties. Valuations were carried out using standard industry methodology to 
surveyors who have recent experience in the location and type of properties. Valuations were carried out using standard industry methodology to 
determine a fair value. There has been no change in the valuation technique during the year. All properties are classified as level 3 assets. There 
determine a fair value. There has been no change in the valuation technique during the year. All properties are classified as level 3 assets. There 
have been no transfers between investment categories in the current year.
have been no transfers between investment categories in the current year.

Investment properties are held for long-term capital appreciation rather than short-term sale. Rental income arising from the investment properties 
Investment properties are held for long-term capital appreciation rather than short-term sale. Rental income arising from the investment properties 
owned by both the Group and Parent amounted to £8,648,000 (2020: £8,786,000) and is included in net investment return. 
owned by both the Group and Parent amounted to £8,648,000 (2020: £8,786,000) and is included in net investment return. 
21 Financial investments
21 Financial investments
21 Financial investments
Financial investments summarised by measurement category are as follows:
Financial investments summarised by measurement category are as follows:

Financial investments at fair value through profit or loss
Financial investments at fair value through profit or loss
Equity securities
Equity securities
- listed
- listed
- unlisted
- unlisted
Debt securities
Debt securities
- government bonds
- government bonds
- listed
- listed
- unlisted
- unlisted
Structured notes
Structured notes
Derivative financial instruments
Derivative financial instruments
- options
- options
- forwards
- forwards

Financial investments at fair value through other comprehensive income 
Financial investments at fair value through other comprehensive income 
Derivative financial instruments
Derivative financial instruments
- forwards
- forwards
Total financial investments at fair value
Total financial investments at fair value

Loans and receivables
Loans and receivables
Other loans
Other loans

Parent investments in subsidiary undertakings
Parent investments in subsidiary undertakings
Shares in subsidiary undertakings
Shares in subsidiary undertakings

Total financial investments
Total financial investments
Current
Current
Non-current
Non-current

All investments in subsidiary undertakings are unlisted.
All investments in subsidiary undertakings are unlisted.

2021
2021

Group
Group
£000
£000

281,682
281,682
68,620
68,620

204,071
204,071
313,294
313,294
34
34
14,649
14,649

334
334
2
2
882,686
882,686

Parent
Parent
£000
£000

254,743
254,743
68,619
68,619

100,631
100,631
215,496
215,496
34
34
 -
 -

334
334
147
147
640,004
640,004

2020
2020

Group
Group
£000
£000

262,598
262,598
59,288
59,288

160,381
160,381
334,732
334,732
552
552
 -
 -

1,407
1,407
672
672
819,630
819,630

Parent
Parent
£000
£000

238,555
238,555
59,287
59,287

71,199
71,199
217,211
217,211
552
552
 -
 -

1,407
1,407
672
672
588,883
588,883

414
414
883,100
883,100

269
269
640,273
640,273

401
401
820,031
820,031

401
401
589,284
589,284

670
670

 -
 -

883,770
883,770
447,418
447,418
436,352
436,352

670
670

66,163
66,163

707,106
707,106
392,530
392,530
314,576
314,576

746
746

 -
 -

820,777
820,777
335,916
335,916
484,861
484,861

746
746

60,757
60,757

650,787
650,787
298,036
298,036
352,751
352,751

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information242

243

Notes to the financial statements
Notes to the financial statements

22 Derivative financial instruments
22 Derivative financial instruments
The Group utilises derivatives to mitigate equity price risk arising from investments held at fair value, foreign exchange risk arising from investments 

denominated in foreign currencies, and foreign exchange risk arising from investments denominated in Sterling that contain underlying foreign 

currency exposure. These 'non-hedge' derivatives either do not qualify for hedge accounting or the option to hedge account has not been taken.

The Group has also formally designated certain derivatives as a hedge of its net investments in Australia and Canada. A gain of £1,912,000 (2020: 

loss of £2,339,000) in respect of these 'hedge' derivatives has been recognised in the hedging reserve within shareholders' equity, as disclosed in 

note 26. The Group has formally assessed and documented the effectiveness of derivatives that qualify for hedge accounting in accordance with 

IAS 39, Financial Instruments: Recognition and Measurement .

Group

Non-hedge derivatives
Equity/Index contracts
Options

Foreign exchange contracts
Forwards (Euro)

Hedge derivatives
Foreign exchange contracts
Forwards (Australian dollar)
Forwards (Canadian dollar)

Contract/
notional
amount
£000

2021

Fair value
asset
£000

Fair value
liability
£000

Contract/
notional
amount¹
£000

2020

Fair value
asset
£000

Fair value
liability
£000

34,695

99,369

40,512
37,609
212,185

334

2

145
269
750

296

35

 -
 -
331

40,597

1,407

86,980

672

41,231
30,269
199,077

 -
401
2,480

 -

 -

1,244
 -
1,244

¹ The contract/notional amount in the prior year has been restated to reflect sterling values 

All derivatives in the current and prior period expire within one year.

The derivative financial instruments of the Parent are the same as the Group, with the exception of the Australian dollar foreign exchange contract 

which is classified as a non-hedge derivative. 

All contracts designated as hedging instruments were fully effective in the current and prior year.

The notional amounts above reflect the aggregate of individual derivative positions on a gross basis and so give an indication of the overall scale of 

the derivative transactions. They do not reflect current market values of the open positions. 

Derivative fair value assets are recognised within financial investments (note 21) and derivative fair value liabilities are recognised within other 

liabilities (note 30). 

Notes to the financial statements
Notes to the financial statements
Notes to the financial statements

23 Other assets
23 Other assets
23 Other assets

2021

2020

Group
£000

2021

Parent
£000

Group
£000

2020

Parent
£000

Group
50,285
£000
66,232
11,005
50,285
66,232
11,005
4,329
5,259
52,683
4,329
6,685
5,259
236
52,683
19,856
6,685
216,570
236
19,856
162,085
216,570
54,485
162,085
54,485

Group
52,706
£000
67,333
12,583
52,706
67,333
12,583
3,927
8,606
68,900
3,927
7,008
8,606
111
68,900
19,736
7,008
240,910
111
19,736
181,346
240,910
59,564
181,346
59,564

Parent
52,629
£000
43,712
8,001
52,629
43,712
8,001
3,096
4,425
80,688
3,096
 -
4,425
111
80,688
2,146
 -
194,808
111
2,146
134,574
194,808
60,234
134,574
60,234

Receivables arising from insurance and reinsurance contracts
- due from contract holders
- due from agents, brokers and intermediaries 
Receivables arising from insurance and reinsurance contracts
- due from reinsurers
- due from contract holders
- due from agents, brokers and intermediaries 
Other receivables
- due from reinsurers
- accrued interest and rent
- other prepayments and accrued income
Other receivables
- amounts owed by related parties 
- accrued interest and rent
- debtors arising from broking activities
- other prepayments and accrued income
- net investment in finance leases
- amounts owed by related parties 
- other debtors
- debtors arising from broking activities
- net investment in finance leases
- other debtors
Current
Non-current
Current
The Group has recognised a net charge of £554,000 (2020: net charge of £759,000) in other operating and administrative expenses in the 
Non-current
statement of profit or loss for the impairment and reversal of impairment of its trade and other receivables during the year. The Parent has 
The Group has recognised a net charge of £554,000 (2020: net charge of £759,000) in other operating and administrative expenses in the 
recognised a net charge of £578,000 (2020: £693,000).
statement of profit or loss for the impairment and reversal of impairment of its trade and other receivables during the year. The Parent has 
There has been no significant change in the recoverability of the Group's or Parent's other assets, for which no collateral is held. The directors 
recognised a net charge of £578,000 (2020: £693,000).
consider that the amounts are recoverable at their carrying values, which are stated net of an allowance for doubtful debts for those debtors that 
There has been no significant change in the recoverability of the Group's or Parent's other assets, for which no collateral is held. The directors 
are individually determined to be impaired.
consider that the amounts are recoverable at their carrying values, which are stated net of an allowance for doubtful debts for those debtors that 
Included within amounts due from agents, brokers and intermediaries of the Group and Parent is a letter of credit for £2,000,000 (2020: 
are individually determined to be impaired.
£2,000,000) and included within amounts owed by related parties of the Parent is £12,152,000 (2020: £2,920,000) pledged as collateral in respect 
Included within amounts due from agents, brokers and intermediaries of the Group and Parent is a letter of credit for £2,000,000 (2020: 
of an insurance liability.
£2,000,000) and included within amounts owed by related parties of the Parent is £12,152,000 (2020: £2,920,000) pledged as collateral in respect 
Included within other receivables of the Group is £1,584,000 (2020: £1,201,000) classified as contract assets, and £1,618,000 (2020: £1,410,000) 
of an insurance liability.
classified as receivables in accordance with IFRS 15. 
Included within other receivables of the Group is £1,584,000 (2020: £1,201,000) classified as contract assets, and £1,618,000 (2020: £1,410,000) 

Parent
49,981
£000
39,796
4,941
49,981
39,796
4,941
3,253
3,966
56,513
3,253
 -
3,966
236
56,513
2,428
 -
161,114
236
2,428
105,075
161,114
56,039
105,075
56,039

classified as receivables in accordance with IFRS 15. 
Movement in the allowance for doubtful debts

2021

Group
£000

2021

Parent
£000

2020

Group
£000

2020

Parent
£000

Movement in the allowance for doubtful debts
Balance at 1 January
Movement in the year
Balance at 31 December
Balance at 1 January
Movement in the year
Included within other assets of the Group is £13,702,000 (2020: £13,767,000) overdue but not impaired, of which £11,754,000 (2020: £11,588,000) is 
Balance at 31 December
not more than three months overdue at the reporting date. Included within trade receivables of the Parent is £2,012,000 (2020: £5,238,000) 
Included within other assets of the Group is £13,702,000 (2020: £13,767,000) overdue but not impaired, of which £11,754,000 (2020: £11,588,000) is 
overdue but not impaired, of which £1,884,000 (2020: £4,245,000) is not more than three months overdue at the reporting date.
not more than three months overdue at the reporting date. Included within trade receivables of the Parent is £2,012,000 (2020: £5,238,000) 
24 Cash and cash equivalents
overdue but not impaired, of which £1,884,000 (2020: £4,245,000) is not more than three months overdue at the reporting date.
24 Cash and cash equivalents
24 Cash and cash equivalents

Parent
574
£000
307
881
574
307
881

Parent
69
£000
505
574
69
505
574

Group
723
£000
262
985
723
262
985

Group
145
£000
578
723
145
578
723

2020

2021

Cash at bank and in hand 
Short-term bank deposits 
Cash at bank and in hand 
Short-term bank deposits 
Included within short-term bank deposits of the Group and Parent are cash deposits of £2,830,000 (2020: £1,960,000) pledged as collateral by 

Group
£000

Group
75,982
£000
38,054
114,036
75,982
38,054
114,036

Parent
£000

Parent
30,038
£000
18,399
48,437
30,038
18,399
48,437

Group
£000

Group
78,643
£000
25,786
104,429
78,643
25,786
104,429

Parent
£000

Parent
43,713
£000
15,753
59,466
43,713
15,753
59,466

2021

2020

way of cash margins on open derivative contracts to cover derivative liabilities. Included within cash at bank and in hand of the Group and Parent are 
Included within short-term bank deposits of the Group and Parent are cash deposits of £2,830,000 (2020: £1,960,000) pledged as collateral by 
amounts of £820,000 (2020: £874,000) held in accordance with the third country branch requirements of the European Union.
way of cash margins on open derivative contracts to cover derivative liabilities. Included within cash at bank and in hand of the Group and Parent are 
Included within Group cash at bank and in hand are amounts of £23,072,000 (2020: £4,131,000) pledged as collateral by way of cash calls from 
amounts of £820,000 (2020: £874,000) held in accordance with the third country branch requirements of the European Union.
reinsurers, and £4,604,000 (2020: £3,765,000) of restricted cash held on an agency basis.
Included within Group cash at bank and in hand are amounts of £23,072,000 (2020: £4,131,000) pledged as collateral by way of cash calls from 

reinsurers, and £4,604,000 (2020: £3,765,000) of restricted cash held on an agency basis.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
Notes to the financial statements
Notes to the financial statements
Notes to the financial statements

25 Called up share capital
25 Called up share capital

25 Called up share capital

Ordinary shares of 4p each
8.625% Non-Cumulative Irredeemable Preference shares of £1 each

Ordinary shares of 4p each
8.625% Non-Cumulative Irredeemable Preference shares of £1 each
The number of shares in issue are as follows:

Ordinary shares of 4p each
The number of shares in issue are as follows:
At 1 January and 31 December

Ordinary shares of 4p each
8.625% Non-Cumulative Irredeemable Preference shares of £1 each
At 1 January and 31 December
At 1 January and 31 December

Issued, allotted and 
fully paid 

Issued, allotted and 
fully paid 

2021
£000

2020
£000

14,027
2021
106,450
£000
120,477
14,027
106,450
120,477

14,027
2020
106,450
£000
120,477
14,027
106,450
120,477

350,678

350,678

350,678
106,450

350,678
106,450

8.625% Non-Cumulative Irredeemable Preference shares of £1 each
On winding up, the assets of the Company remaining after payment of its liabilities are to be applied to holders of the Non-Cumulative 
106,450
At 1 January and 31 December
Irredeemable Preference shares in repaying the nominal capital sum paid up on the shares and an amount equal to all arrears of accrued and 

106,450

unpaid dividends up to the date of the commencement of the winding up. The residual interest in the assets of the Company after deducting all 
On winding up, the assets of the Company remaining after payment of its liabilities are to be applied to holders of the Non-Cumulative 
liabilities belongs to the Ordinary shareholders.
Irredeemable Preference shares in repaying the nominal capital sum paid up on the shares and an amount equal to all arrears of accrued and 

unpaid dividends up to the date of the commencement of the winding up. The residual interest in the assets of the Company after deducting all 
Holders of the Non-Cumulative Irredeemable Preference shares are not entitled to receive notice of, or to attend, or vote at any general meeting 
liabilities belongs to the Ordinary shareholders.
of the Company unless at the time of the notice convening such meeting, the dividend on such shares which is most recently payable on such 

shares shall not have been paid in full, or where a resolution is proposed varying any of the rights of such shares, or for the winding up of the 
Holders of the Non-Cumulative Irredeemable Preference shares are not entitled to receive notice of, or to attend, or vote at any general meeting 
Company.
of the Company unless at the time of the notice convening such meeting, the dividend on such shares which is most recently payable on such 

shares shall not have been paid in full, or where a resolution is proposed varying any of the rights of such shares, or for the winding up of the 
26 Translation and hedging reserve
Company.
26 Translation and hedging reserve
26 Translation and hedging reserve
Group

Total
£000

Total
18,230
At 1 January 2021
£000
Group
(2,356)
Losses on currency translation differences 
Gains on net investment hedges
1,912
18,230
At 1 January 2021
Attributable tax
(183)
(2,356)
Losses on currency translation differences 
17,603
At 31 December 2021
Gains on net investment hedges
1,912
Attributable tax
(183)
18,324
At 1 January 2020
17,603
At 31 December 2021
1,980
Gains on currency translation differences 
(2,339)
Losses on net investment hedges 
18,324
At 1 January 2020
265
Attributable tax 
1,980
Gains on currency translation differences 
18,230
At 31 December 2020
(2,339)
Losses on net investment hedges 
Parent
265
Attributable tax 
18,230
At 31 December 2020
7,067
At 1 January 2021
Parent
Gains on currency translation differences 
551
Losses on net investment hedges
(713)
7,067
At 1 January 2021
Attributable tax
131
551
Gains on currency translation differences 
7,036
At 31 December 2021
Losses on net investment hedges
(713)
Attributable tax
131
7,564
At 1 January 2020
7,036
At 31 December 2021
(712)
Losses on currency translation differences 
279
Gains on net investment hedges 
7,564
At 1 January 2020
(64)
Attributable tax 
(712)
Losses on currency translation differences 
7,067
At 31 December 2020
279
Gains on net investment hedges 
(64)
Attributable tax 
The translation reserve arises on consolidation of the Group's and Parent's foreign operations. The hedging reserve represents the cumulative 
7,067
At 31 December 2020
amount of gains and losses on hedging instruments in respect of net investments in foreign operations. 

The translation reserve arises on consolidation of the Group's and Parent's foreign operations. The hedging reserve represents the cumulative 

amount of gains and losses on hedging instruments in respect of net investments in foreign operations. 

Translation
reserve
£000
Translation
reserve
15,552
£000
(2,356)
 -
15,552
 -
(2,356)
13,196
 -
 -
13,572
13,196
1,980
 -
13,572
 -
1,980
15,552
 -
 -
15,552
6,418
551
 -
6,418
 -
551
6,969
 -
 -
7,130
6,969
(712)
 -
7,130
 -
(712)
6,418
 -
 -
6,418

Hedging
reserve
£000
Hedging
reserve
2,678
£000
 -
1,912
2,678
(183)
 -
4,407
1,912
(183)
4,752
4,407
 -
(2,339)
4,752
265
 -
2,678
(2,339)
265
2,678
649
 -
(713)
649
131
 -
67
(713)
131
434
67
 -
279
434
(64)
 -
649
279
(64)
649

244

245

Notes to the financial statements
Notes to the financial statements

27 Insurance liabilities and reinsurance assets
27 Insurance liabilities and reinsurance assets

Gross
Claims outstanding
Unearned premiums 
Life business provision
Total gross insurance liabilities

Recoverable from reinsurers
Claims outstanding
Unearned premiums 
Total reinsurers’ share of insurance liabilities

Net
Claims outstanding
Unearned premiums 
Life business provision
Total net insurance liabilities

Gross insurance liabilities
Current
Non-current

Reinsurance assets
Current
Non-current

2021

Group
£000

616,225
253,158
73,909
943,292

166,360
88,089
254,449

449,865
165,069
73,909
688,843

Parent
£000

471,209
202,389
 -
673,598

107,491
64,431
171,922

363,718
137,958
 -
501,676

2020

Group
£000

560,992
230,800
76,857
868,649

129,284
79,393
208,677

431,708
151,407
76,857
659,972

Parent
£000

434,583
181,619
 -
616,202

78,450
56,066
134,516

356,133
125,553
 -
481,686

449,342
493,950

347,937
325,661

412,200
456,449

315,863
300,339

172,844
81,605

117,315
54,607

142,466
66,211

94,662
39,854

(a) General business insurance contracts
(i) Reserving methodology
Reserving for non-life insurance claims is a complex process and the Group adopts recognised actuarial methods and, where appropriate, other 

calculations and statistical analysis. Actuarial methods used include the chain ladder, Bornhuetter-Ferguson and average cost methods.

Chain ladder methods extrapolate paid amounts, incurred amounts (paid claims plus case estimates) and the number of claims or average cost of 

claims, to ultimate claims based on the development of previous years. This method assumes that previous patterns are a reasonable guide to 

future developments. Where this assumption is felt to be unreasonable, adjustments are made or other methods such as Bornhuetter-Ferguson or 

average cost are used. The Bornhuetter-Ferguson method places more credibility on expected loss ratios for the most recent loss years. For 

smaller portfolios the materiality of the business and data available may also shape the methods used in reviewing reserve adequacy.

The selection of results for each accident year and for each portfolio depends on an assessment of the most appropriate method. Sometimes a 

combination of techniques is used. The average weighted term to payment is calculated separately by class of business and is based on historical 

settlement patterns.

(ii) Calculation of uncertainty margins
To reflect the uncertain nature of the outcome of the ultimate settlement cost of claims, an uncertainty margin is added to the best estimate. The 

addition for uncertainty is assessed using actuarial methods including the Mack method and Bootstrapping techniques, based on at least the 75th 

percentile confidence level for each portfolio. For smaller portfolios, where these methods cannot be applied, provisions are calculated at a level 

intended to provide an equivalent probability of sufficiency. Where the standard methods cannot allow for changing circumstances, additional 

uncertainty margins are added and are typically expressed as a percentage of outstanding claims. From time to time, management may elect to 

select an additional margin to reflect short-term uncertainty driven by specific events that are not in data. This approach generally results in a 

favourable release of provisions in the current financial year, arising from the settlement of claims relating to previous financial years, as shown in 

part (c) of the note.

(iii) Calculation of provisions for latent claims
The Group adopts commonly used industry methods including those based on claims frequency and severity and benchmarking.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information           
          
         
           
       
        
        
        
246

247

Notes to the financial statements
Notes to the financial statements
27 Insurance liabilities and reinsurance assets (continued)
27 Insurance liabilities and reinsurance assets (continued)

(iv) Discounting
General insurance outstanding claims provisions are undiscounted, except for certain designated long-tail classes of business for which discounted 

provisions are held in the following territories: 

Geographical territory

UK and Ireland
Canada
Australia

Parent consists of UK, Ireland and Canada. Group also includes Australia.

Discount rate

Mean term of discounted
liabilities (years)

2021

2020

2021

2020

1.3% to 2.1%
1.2% to 2.1%
1.5%

0.5% to 1.5%
0.4% to 1.7%
0.70%

17
12
5

17
12
4

The above rates of interest are based on government bond yields of the relevant currency and term at the reporting date. Adjustments are made, 

where appropriate, to reflect portfolio assets held and to allow for future investment expenses. At the year end the undiscounted gross 

outstanding claims liability was £640,528,000 for the Group (2020: £585,635,000), and £493,198,000 for the Parent (2020: £456,912,000).

The impact of discount rate changes on the outstanding claims liability is presented within net investment return (note 8).

At 31 December 2021, it is estimated that a fall of 1% in the discount rates used would increase the Group's net outstanding claims liabilities by 

£18,922,000 (2020: £20,715,000). Financial investments backing these liabilities are not hypothecated across general insurance classes of 

business. The sensitivity of Group profit or loss and other equity reserves to interest rate risk, taking into account the mitigating effect on asset 

values is provided in note 4(h).

(v) Assumptions
The Group follows a process of reviewing its reserves for outstanding claims on a regular basis. This involves an appraisal of each portfolio with 

respect to ultimate claims liability for the recent exposure period as well as for earlier periods, together with a review of the factors that have the 

most significant impact on the assumptions used to determine the reserving methodology. The work conducted on each portfolio is subject to an 

internal peer review and management sign-off process.

The most significant assumptions in determining the undiscounted general insurance reserves are the anticipated number and ultimate settlement 

cost of claims, and the extent to which reinsurers will share in the cost. Factors which influence decisions on assumptions include legal and judicial 

changes, significant weather events, other catastrophes, subsidence events, exceptional claims or substantial changes in claims experience and 

developments in older or latent claims. Significant factors influencing assumptions about reinsurance are the terms of the reinsurance treaties, the 

anticipated time taken to settle a claim and the incidence of large individual and aggregated claims.

(vi) Changes in assumptions
There are no significant changes in approach but we continue to evolve estimates in light of underlying experience.

(vii) Sensitivity of results
The ultimate amount of claims settlement is uncertain and the Group's aim is to reserve to at least the 75th percentile confidence level.

If final settlement of insurance claims reserved for at the year end turns out to be 10% higher or lower than the undiscounted reserves included in 

these financial statements, the following pre-tax Group loss or profit will be realised: 

Liability

Property

Motor

- UK
- Overseas
- UK
- Overseas
- UK

2021

2020

Gross
£000

18,900
18,000
12,200
9,000
100

Net
£000

17,200
13,700
6,200
3,100
100

Gross
£000

20,200
14,900
10,300
7,200
200

Net
£000

19,000
12,200
5,600
2,600
200

Notes to the financial statements
Notes to the financial statements
27 Insurance liabilities and reinsurance assets (continued)
27 Insurance liabilities and reinsurance assets (continued)

(viii) Claims development tables

The nature of liability classes of business is that claims may take a number of years to settle and before the final liability is known. The tables below 

show the development of the undiscounted estimate of ultimate gross and net claims cost for these classes across all territories. 

Estimate of ultimate gross claims

Group

At end of year
One year later
Two years later
Three years later
Four years later
Five years later
Six years later
Seven years later
Eight years later
Nine years later

Current estimate of ultimate 

claims 
Cumulative payments to 

2012
£000

100,612
88,046
78,196
72,516
67,980
62,712
61,213
60,560
62,025
61,615

2013
£000

81,725
80,027
69,860
66,192
60,174
56,912
54,901
55,516
55,252

2014
£000

61,901
50,571
48,327
45,495
37,064
34,606
34,962
36,195

2015
£000

46,464
43,582
40,337
33,804
29,436
28,211
31,738

2016
£000

51,738
46,073
41,041
38,468
37,044
34,649

2017
£000

50,736
46,885
41,883
38,648
40,177

2018
£000

2019
£000

2020
£000

2021
£000

Total
£000

48,759
40,461
34,680
33,362

47,945
42,467
39,859

60,267

50,134
42,044

61,615

55,252

36,195

31,738

34,649

40,177

33,362

39,859 42,044

60,267

435,158

(54,400)
7,215

date 
Outstanding liability 
Effect of discounting
Present value
Discounted liability in respect of earlier years
Total discounted gross liability (for liability classes) included in insurance liabilities in the statement of financial position

(21,087)
10,651

(21,853)
12,796

(17,642)
22,535

(47,153)
8,099

(12,013)
21,349

(28,117)
8,078

(8,852)
31,007

(5,571)
(1,471)
36,473 58,796

(218,159)
216,999
(10,619)
206,380
162,780
369,160

Total
£000

2012
£000

84,511
77,629
69,580
63,068
56,225
51,872
50,791
50,092
50,367
49,929

2013
£000

71,798
60,950
54,792
50,492
43,910
42,289
40,698
40,041
40,161

2014
£000

52,350
40,153
39,015
37,158
31,530
30,024
30,063
30,505

2015
£000

34,769
31,941
30,129
27,287
23,620
23,068
25,631

2016
£000

37,981
32,541
29,538
28,622
27,899
25,084

2017
£000

34,210
33,353
31,463
29,557
30,012

2018
£000

32,992
28,181
24,212
23,116

2019
£000

2020
£000

33,719 35,690
30,285
28,874
28,618

2021
£000

43,976

Parent

At end of year
One year later
Two years later
Three years later
Four years later
Five years later
Six years later
Seven years later
Eight years later
Nine years later

Current estimate of ultimate 

claims 
Cumulative payments to 

49,929

40,161

30,505

25,631

25,084

30,012

23,116

28,618 28,874

43,976

325,906

(45,540)
4,389

date 
Outstanding liability 
Effect of discounting
Present value
Discounted liability in respect of earlier years
Total discounted gross liability (for liability classes) included in insurance liabilities in the statement of financial position

(5,622)
(8,158)
14,958 22,996

(24,976)
5,529

(34,792)
5,369

(16,580)
8,504

(17,859)
7,772

(13,548)
16,464

(3,744)
25,130

(809)
43,167

(171,628)
154,278
(6,677)
147,601
126,428
274,029

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information248

249

Notes to the financial statements
Notes to the financial statements
27 Insurance liabilities and reinsurance assets (continued)
27 Insurance liabilities and reinsurance assets (continued)

Estimate of ultimate net claims

Group

At end of year
One year later
Two years later
Three years later
Four years later
Five years later
Six years later
Seven years later
Eight years later
Nine years later

Current estimate of ultimate 

claims 
Cumulative payments to 

2012
£000

88,247
79,272
73,735
69,837
65,872
60,800
59,338
59,061
60,056
59,783

2013
£000

76,729
66,475
60,075
55,710
51,482
49,196
47,518
47,443
47,338

2014
£000

59,633
47,690
47,428
41,494
35,164
33,233
33,309
34,245

2015
£000

42,739
40,397
37,740
32,297
28,506
27,418
30,544

2016
£000

47,402
41,631
37,740
36,337
35,217
32,993

2017
£000

45,920
41,706
37,797
34,818
36,431

2018
£000

2019
£000

2020
£000

45,459
37,509

44,230
39,842
37,243

44,053
37,456
32,867
31,647

2021
£000

47,289

Total
£000

59,783

47,338

34,245

30,544

32,993

36,431

31,647

37,243 37,509 47,289

395,022

(53,066)
6,717

date 
Outstanding liability 
Effect of discounting
Present value
Discounted liability in respect of earlier years
Total discounted net liability (for liability classes) included in insurance liabilities in the statement of financial position

(20,558)
9,986

(39,851)
7,487

(17,570)
18,861

(26,771)
7,474

(21,651)
11,342

(1,463)
(12,011)
19,636 28,405 32,025 45,826

(8,838)

(5,484)

(207,263)
187,759
(10,619)
177,140
146,274
323,414

Total
£000

2012
£000

74,361
69,805
65,297
61,795
55,686
51,766
50,762
50,079
50,356
49,918

2013
£000

67,690
57,538
51,828
47,942
43,568
42,126
40,587
39,930
40,051

2014
£000

50,025
38,944
38,215
34,393
30,252
28,825
28,865
29,268

2015
£000

33,122
31,041
29,494
26,981
23,229
22,806
25,061

2016
£000

35,882
30,906
28,199
27,493
26,894
24,782

2017
£000

33,134
30,965
28,854
26,774
27,279

2018
£000

31,981
27,208
23,787
22,651

2019
£000

2020
£000

32,688 33,502
29,509 26,536
27,615

2021
£000

33,792

Parent

At end of year
One year later
Two years later
Three years later
Four years later
Five years later
Six years later
Seven years later
Eight years later
Nine years later

Current estimate of ultimate 

claims 
Cumulative payments to 

49,918

40,051

29,268

25,061

24,782

27,279

22,651

27,615 26,536

33,792

306,953

(45,537)
4,381

date 
Outstanding liability 
Effect of discounting
Present value
Discounted liability in respect of earlier years
Total discounted net liability (for liability classes) included in insurance liabilities in the statement of financial position

(8,156)
(5,613)
14,495 22,002

(34,688)
5,363

(23,752)
5,516

(16,395)
8,387

(13,548)
13,731

(17,330)
7,731

(3,657)
22,879

(800)
32,992

(169,476)
137,477
(6,677)
130,800
119,609
250,409

Notes to the financial statements
Notes to the financial statements
27 Insurance liabilities and reinsurance assets (continued)
27 Insurance liabilities and reinsurance assets (continued)

(b) Life insurance contracts
(i) Assumptions
The most significant assumptions in determining life reserves are as follows:

Mortality
An appropriate base table of standard mortality is chosen depending on the type of contract. Where prudent, an allowance is made for future 

mortality improvements based on trends identified in population data. For both 2021 and 2020 the base tables used were ELF16F and ELT16M with 

a 1% improvement applied each year.

Investment returns
Projected investment returns for index-linked business are based on actual yields for each asset class less an allowance for credit risk, where 

appropriate. The risk adjusted yields after allowance for investment expenses for the current valuation are as follows:

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

UK and overseas government bonds: non-linked
UK and overseas government bonds: index-linked
Corporate debt instruments: index-linked

2021

-
-2.71%
-2.28%

2020

-0.28%
-2.72%
-2.23%

The investment return assumption is determined by calculating an overall yield on all cash flows projected to occur from the portfolio of financial 

assets which are assumed to back the relevant class of liabilities. For index-linked assets, the real yield is shown gross of tax. 

The investment return assumption for non-linked business is based on government bond returns at an average duration of cash flows for this 

business. The return after allowance for investment expenses is 1.02%.

Funeral plans renewal expense level and inflation
Numbers of policies in force and both projected and actual expenses have been considered when setting the base renewal expense level. The unit 

renewal expense assumption for in-force business is £2.60 per annum (2020: £2.50 per annum). Additionally, now the in-force policy volumes are 

expected to fall,  much of the expenses of the company have been reserved for in a separate exercise. A reserve for these expenses is held at £5.7m 

(2020: £5.8m).

Expense inflation is set with reference to the nominal and index-linked UK government bond rates of return and is assumed to be 4.69% per annum 

(2020: 4.07%).

Tax
It has been assumed that current tax legislation and rates applicable at 1 January 2022 will continue to apply. All in-force business is classed as 

protection business and is expected to be taxed on a profits basis.

(ii) Changes in assumptions
Projected investment returns have been revised in line with the changes in the actual yields of the underlying assets. As a result, liabilities have 

increased by £0.1m (2020: £5.0m increase).

The assumed future expenses of running the business have been revised based on expenses that are expected to be incurred by the company. The 

effect on insurance liabilities of the changes to renewal expense assumptions (described above) was a £0.2m increase (2020: £0.7m increase).

There has been a small change in the mortality assumptions that has reduced liabilities by £0.1m (2020: no material change).

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
Notes to the financial statements
Notes to the financial statements
27 Insurance liabilities and reinsurance assets (continued)
27 Insurance liabilities and reinsurance assets (continued)

Notes to the financial statements
Notes to the financial statements
27 Insurance liabilities and reinsurance assets (continued)
27 Insurance liabilities and reinsurance assets (continued)

(iii) Sensitivity analysis
The sensitivity of profit before tax to changes in the key assumptions used to calculate the life insurance liabilities is shown in the following table. No 

Group

250

251

account has been taken of any correlation between the assumptions.

Variable

Deterioration in mortality
Improvement in mortality
Increase in fixed interest/cash yields
Decrease in fixed interest/cash yields
Worsening of base renewal expense level
Improvement in base renewal expense level
Increase in expense inflation
Decrease in expense inflation

(c) Movements in insurance liabilities and reinsurance assets

Group

Claims outstanding
At 1 January 2021
Cash (paid)/received for claims settled in the year 
Change in liabilities/reinsurance assets
- arising from current year claims
- arising from prior year claims
- change in discount rate 
Exchange differences  
At 31 December 2021
Provision for unearned premiums
At 1 January 2021
Increase in the period 
Release in the period
Exchange differences  
At 31 December 2021
Life business provision
At 1 January 2021
Effect of claims during the year
Changes in assumptions 
Change in discount rate
Other movements 
At 31 December 2021

Change in
variable

Potential increase/
(decrease) in the result

2021
£000

1,300
(1,500)
 -
(400)
(200)
200
(600)
500

2020
£000

1,300
(1,600)
200
(700)
(200)
300
(600)
500

+10%
-10%
+1% pa
-1% pa
+10%
-10%
+1% pa
-1% pa

Gross
£000

Reinsurance
£000

Net
£000

560,992
(191,685)

252,310
14,980
(13,034)
(7,338)
616,225

230,800
253,759
(229,255)
(2,146)
253,158

76,857
(5,577)
2,493
147
(11)
73,909

(129,284)
83,235

(114,378)
(9,444)
1,023
2,488
(166,360)

(79,393)
(88,464)
78,580
1,188
(88,089)

 -
 -
 -
 -
 -
 -

431,708
(108,450)

137,932
5,536
(12,011)
(4,850)
449,865

151,407
165,295
(150,675)
(958)
165,069

76,857
(5,577)
2,493
147
(11)
73,909

Total insurance contract liabilities and reinsurance assets

943,292

(254,449)

688,843

Claims outstanding
At 1 January 2020
Cash (paid)/received for claims settled in the year 
Change in liabilities/reinsurance assets
- arising from current year claims
- arising from prior year claims
- change in discount rate 
Exchange differences  
At 31 December 2020
Provision for unearned premiums
At 1 January 2020
Increase in the period 
Release in the period
Exchange differences  
At 31 December 2020
Life business provision
At 1 January 2020
Effect of claims during the year 
Changes in assumptions
Changes in methodolgy
Change in discount rate 
Other movements 
At 31 December 2020

Gross
£000

Reinsurance
£000

Net
£000

481,669
(164,510)

240,868
(16,741)
11,810
7,896
560,992

203,096
228,361
(203,377)
2,720
230,800

79,212
(5,549)
(1,077)
(708)
4,986
(7)
76,857

(89,982)
59,024

(97,272)
2,691
(898)
(2,847)
(129,284)

(69,574)
(78,170)
69,748
(1,397)
(79,393)

 -
 -
 -
 -
 -
 -
 -

391,687
(105,486)

143,596
(14,050)
10,912
5,049
431,708

133,522
150,191
(133,629)
1,323
151,407

79,212
(5,549)
(1,077)
(708)
4,986
(7)
76,857

Total insurance contract liabilities and reinsurance assets

868,649

(208,677)

659,972

Parent

Claims outstanding
At 1 January 2021
Cash (paid)/received for claims settled in the year 
Change in liabilities/reinsurance assets
- arising from current year claims
- arising from prior year claims
- change in discount rate 
Exchange differences  
At 31 December 2021
Provision for unearned premiums
At 1 January 2021
Increase in the period 
Release in the period
Exchange differences  
At 31 December 2021

Claims outstanding
At 1 January 2020
Cash (paid)/received for claims settled in the year 
Change in liabilities/reinsurance assets
- arising from current year claims
- arising from prior year claims
- change in discount rate 
Exchange differences  
At 31 December 2020
Provision for unearned premiums
At 1 January 2020
Increase in the period 
Release in the period
Exchange differences  
At 31 December 2020

434,583
(165,227)

(78,450)
57,340

356,133
(107,887)

221,277
(9,317)
(9,367)
(740)
471,209

181,619
202,191
(181,753)
332
202,389

391,268
(136,184)

191,326
(21,916)
9,567
522
434,583

165,004
181,778
(164,992)
(171)
181,619

(102,576)
16,370
 -
(175)
(107,491)

(56,066)
(64,432)
56,049
18
(64,431)

(56,174)
34,368

(66,322)
9,579
 -
99
(78,450)

(50,527)
(56,074)
50,555
(20)
(56,066)

118,701
7,053
(9,367)
(915)
363,718

125,553
137,759
(125,704)
350
137,958

335,094
(101,816)

125,004
(12,337)
9,567
621
356,133

114,477
125,704
(114,437)
(191)
125,553

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements

Notes to the financial statements
Notes to the financial statements

252

253

28 Provisions for other liabilities and contingent liabilities
28 Provisions for other liabilities and contingent liabilities

Group

At 31 December 2020
Additional provisions 
Used during year
Not utilised
Exchange differences 
At 31 December 2021

Current
Non-current

Parent

At 31 December 2020
Additional provisions 
Used during year
Not utilised
Exchange differences 
At 31 December 2021

Current
Non-current

Regulatory
and legal
provisions
£000

Contingent
consideration
£000

Other
provisions
£000

2,329
2,142
(1,789)
(63)
 -
2,619

2,619
 -

2,329
2,142
(1,789)
(63)
 -
2,619

2,619
 -

419
22
(441)
 -
 -
 -

 -
 -

 -
 -
 -
 -
 -
 -

 -
 -

3,751
70
(60)
 -
(7)
3,754

1,609
2,145

3,513
 -
(60)
 -
(4)
3,449

1,609
1,840

Total
£000

6,499
2,234
(2,290)
(63)
(7)
6,373

4,228
2,145

5,842
2,142
(1,849)
(63)
(4)
6,068

4,228
1,840

Regulatory and legal provisions
The Group operates in the financial services industry and is subject to regulatory requirements in the normal course of business, including 

contributing towards any levies raised on UK general and life business. The provisions reflect an assessment by the Group of its share of the total 

potential levies.

In addition, from time to time the Group receives complaints from customers and, while the majority relate to cases where there has been no 

customer detriment, we recognise that we have provided, and continue to provide, advice and services across a wide spectrum of regulated activities. 

We therefore believe that it is prudent to hold a provision for the estimated costs of customer complaints relating to services provided. The Group 

continues to reassess the ultimate level of complaints expected and the appropriateness of the provision, which reflects the expected redress and 

associated administration costs that would be payable in relation to any complaints we may uphold.

Contingent consideration
The provision for contingent consideration relates to the acquisition of WRS Insurance Brokers Limited that completed in 2020.

Other provisions
The provision for other costs relates to costs in respect of dilapidations.

29 Deferred tax
29 Deferred tax
An analysis and reconciliation of the movement of the key components of the net deferred tax liability during the current and prior reporting period is as 

follows:

Group

At 1 January 2020
(Credited)/charged to profit or loss
- Impact of change in deferred tax rate
(Credited)/charged to other comprehensive income
- Impact of change in deferred tax rate
Exchange differences
At 31 December 2020

Charged/(credited) to profit or loss
- Impact of change in deferred tax rate
Charged/(credited) to other comprehensive income
- Impact of change in deferred tax rate
Exchange differences
At 31 December 2021

Parent

At 1 January 2020
(Credited)/charged to profit or loss
- Impact of change in deferred tax rate
(Credited)/charged to other comprehensive income
- Impact of change in deferred tax rate
Exchange differences
At 31 December 2020

Charged/(credited) to profit or loss
- Impact of change in deferred tax rate
Charged/(credited) to other comprehensive income
- Impact of change in deferred tax rate
Exchange differences
At 31 December 2021

Unrealised
gains on
investments
£000

Net
retirement
benefit
assets
£000

Equalisation
reserve
£000

Other
differences
£000

34,081
(6,569)
4,050
 -
 -
(4)
31,558

4,022
8,584
 -
 -
5
44,169

33,149
(6,489)
3,900
 -
 -
 -
30,560

3,538
8,202
 -
 -

425
(204)
232
(3,291)
(182)
 -
(3,020)

(383)
632
9,665
(1,585)
 -
5,309

427
(204)
232
(3,290)
(182)
 -
(3,017)

(383)
632
9,665
(1,585)

42,300

5,312

1,434
(790)
145
 -
 -
 -
789

(789)
 -
 -
 -
 -
 -

1,434
(790)
145
 -
 -
 -
789

(789)
 -
 -
 -

 -

(2,494)
2,168
(171)
(9)
24
(77)
(559)

(8,877)
(187)
(179)
66
133
(9,603)

(582)
971
(165)
(9)
24
(9)
230

(1,442)
(170)
(179)
66
6
(1,489)

Total
£000

33,446
(5,395)
4,256
(3,300)
(158)
(81)
28,768

(6,027)
9,029
9,486
(1,519)
138
39,875

34,428
(6,512)
4,112
(3,299)
(158)
(9)
28,562

924
8,664
9,486
(1,519)
6
46,123

The equalisation reserve was previously required by law and maintained in compliance with insurance companies' regulations.  Transfers to this 

reserve were deemed to be tax deductible under legislation that applied prior to 1 January 2016 and gave rise to deferred tax.  With effect from the 

implementation date of Solvency II, 1 January 2016, these reserves become taxable over 6 years under the transition rules set out by HM Treasury.

Certain deferred tax assets and liabilities have been offset where the Group has a legally enforceable right to do so. The following is the analysis of 

the deferred tax balances (after offset) for financial reporting purposes: 

Deferred tax liabilities
Deferred tax assets

2021

2020

Group
£000

48,355
(8,480)
39,875

Parent
£000

46,123
 -
46,123

Group
£000

29,846
(1,078)
28,768

Parent
£000

28,562
 -
28,562

The Group has unused tax losses of £10,565,000 (2020: £12,954,000) arising from life business, which are available for offset against future profits 

and can be carried forward indefinitely. In the prior year no deferred tax asset was recognised due to the unpredictability of future profit streams. In 

the current year a deferred tax asset has been recognised based on the expectation that these losses can be utilised.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationNotes to the financial statements
Notes to the financial statements
Notes to the financial statements

Notes to the financial statements
30 Other liabilities and deferred income
30 Other liabilities and deferred income
30 Other liabilities and deferred income

2021

2020

2021

2021

30 Other liabilities and deferred income
Creditors arising out of direct insurance operations
Creditors arising out of reinsurance operations
Creditors arising out of direct insurance operations
Derivative liabilities
Creditors arising out of reinsurance operations
Creditors arising from broking activities
Derivative liabilities
Creditors arising out of direct insurance operations
Other creditors
Creditors arising from broking activities
Creditors arising out of reinsurance operations
Amounts owed to related parties
Other creditors
Derivative liabilities
Accruals
Amounts owed to related parties
Creditors arising from broking activities
Accruals
Other creditors
Current
Amounts owed to related parties
Non-current
Accruals
Current
Non-current
Derivative liabilities are in respect of equity futures contracts and are detailed in note 22.
Current
96,791
Non-current
556
Derivative liabilities are in respect of equity futures contracts and are detailed in note 22.
Deferred income of the Group and Parent is a current liability in both the current and prior year.

Group
£000
Group
3,238
£000
34,865
Group
3,238
331
£000
34,865
5,370
331
3,238
23,843
5,370
34,865
22
23,843
331
29,678
22
5,370
97,347
29,678
23,843
96,791
97,347
22
556
29,678
96,791
97,347
556

Parent
£000
Parent
1,579
£000
23,714
Parent
1,579
331
£000
23,714
 -
331
1,579
12,114
 -
23,714
369
12,114
331
21,551
369
 -
59,658
21,551
12,114
59,658
59,658
369
 -
21,551
59,658
59,658
 -

59,658
 -

2020

2020

Group
£000
Group
3,055
£000
39,190
Group
3,055
1,244
£000
39,190
4,343
1,244
3,055
24,020
4,343
39,190
3
24,020
1,244
21,706
3
4,343
93,561
21,706
24,020
93,011
93,561
3
550
21,706
93,011
93,561
550

93,011
550

Parent
£000
Parent
1,556
£000
24,539
Parent
1,556
1,244
£000
24,539
 -
1,244
1,556
12,304
 -
24,539
45
12,304
1,244
15,399
45
 -
55,087
15,399
12,304
55,087
55,087
45
 -
15,399
55,087
55,087
 -

55,087
 -

Deferred income of the Group and Parent is a current liability in both the current and prior year.
Derivative liabilities are in respect of equity futures contracts and are detailed in note 22.
Included within deferred income of the Group is £407,000 (2020: £308,000) classified as contract liabilities in accordance with IFRS 15. Included 

within deferred income of the Parent is £nil (2020: £nil) classified as contract liabilities in accordance with IFRS 15.
Included within deferred income of the Group is £407,000 (2020: £308,000) classified as contract liabilities in accordance with IFRS 15. Included 
Deferred income of the Group and Parent is a current liability in both the current and prior year.
within deferred income of the Parent is £nil (2020: £nil) classified as contract liabilities in accordance with IFRS 15.

Included within deferred income of the Group is £407,000 (2020: £308,000) classified as contract liabilities in accordance with IFRS 15. Included 
31 Subordinated debt
31 Subordinated debt
within deferred income of the Parent is £nil (2020: £nil) classified as contract liabilities in accordance with IFRS 15.
31 Subordinated debt
Group and Parent
31 Subordinated debt
6.3144% EUR 30m subordinated debt
Group and Parent
6.3144% EUR 30m subordinated debt
Group and Parent
Subordinated debt consists of a privately-placed issue of 20-year subordinated bonds, maturing in February 2041 and callable after February 2031. 
6.3144% EUR 30m subordinated debt
The Group's subordinated debt ranks below its senior debt and ahead of its preference shares and ordinary share capital.
Subordinated debt consists of a privately-placed issue of 20-year subordinated bonds, maturing in February 2041 and callable after February 2031. 

2021
£000
2021
24,433
£000
24,433
24,433
2021
24,433
£000

2020
£000
2020
 -
£000
 -
 -
2020
 -
£000

24,433
24,433

 -
 -

The Group's subordinated debt ranks below its senior debt and ahead of its preference shares and ordinary share capital.
Subordinated debt is stated at amortised cost.

Subordinated debt consists of a privately-placed issue of 20-year subordinated bonds, maturing in February 2041 and callable after February 2031. 
Subordinated debt is stated at amortised cost.
32 Investment contract liabilities
The Group's subordinated debt ranks below its senior debt and ahead of its preference shares and ordinary share capital.
32 Investment contract liabilities
Subordinated debt is stated at amortised cost.
Group
32 Investment contract liabilities
32 Investment contract liabilities
Investment contract liabilities
Group
Investment contract liabilities
Group
Investment contract liabilities represents amounts due to policyholders and, if applicable, the cost of the minimum repayment guarantee. Investment 

2021
£000
2021
15,519
£000
15,519
15,519
2021
15,519
£000

2020
£000
2020
 -
£000
 -
 -
2020
 -
£000

contract liabilities are repayable on demand or at short notice and therefore classified as current. These liabilities are matched with highly liquid 
Investment contract liabilities
Investment contract liabilities represents amounts due to policyholders and, if applicable, the cost of the minimum repayment guarantee. Investment 
investments.
contract liabilities are repayable on demand or at short notice and therefore classified as current. These liabilities are matched with highly liquid 

15,519
15,519

 -
 -

254

255

Notes to the financial statements
Notes to the financial statements

33 Leases
33 Leases
Group as a lessee
The Group has lease contracts for various items of property, motor vehicles and other equipment used in its operations. Leases of property 

generally have terms of up to 15 years, while motor vehicles and other equipment generally have lease terms between 2 and 6 years. Lease terms 

are negotiated on an individual basis and contain different terms and conditions, but do not impose any covenants other than security interests. The 

Group's obligations under its leases are secured by the lessor's title to the leased assets, and leased assets may not be used as security for 

borrowing purposes.

Set out below are the carrying amounts of right-of-use assets recognised and the movements during the period. 

Group

At 1 January 2021
Additions
Disposals
Depreciation expense
Exchange differences 
At 31 December 2021

At 1 January 2020
Additions
Disposals
Depreciation expense
Exchange differences 
At 31 December 2020

Parent

At 1 January 2021
Additions
Disposals
Depreciation expense
Exchange differences 
At 31 December 2021

At 1 January 2020
Additions
Disposals
Depreciation expense
Exchange differences 
At 31 December 2020

Set out below are the carrying amounts of lease obligations:

Land and 
buildings
£000

Motor
vehicles
£000

Other
equipment
£000

24,231
189
 -
(2,812)
(20)
21,588

9,961
17,125
 -
(2,901)
46
24,231

1,068
448
(268)
(236)
(2)
1,010

1,038
474
(193)
(254)
3
1,068

189
109
(21)
(114)
(1)
162

305
 -
 -
(118)
2
189

Land and 
buildings
£000

Motor
vehicles
£000

Other
equipment
£000

21,738
121
 -
(2,217)
27
19,669

7,449
16,617
 -
(2,310)
(18)
21,738

993
448
(235)
(219)
 -
987

1,028
377
(193)
(219)
 -
993

131
109
(20)
(94)
(1)
125

227
 -
 -
(97)
1
131

2021

2020

Group
£000

3,402
19,336
22,738

Parent
£000

2,691
18,115
20,806

Group
£000

3,502
21,948
25,450

Total
£000

25,488
746
(289)
(3,162)
(23)
22,760

11,304
17,599
(193)
(3,273)
51
25,488

Total
£000

22,862
678
(255)
(2,530)
26
20,781

8,704
16,994
(193)
(2,626)
(17)
22,862

Parent
£000

2,725
20,113
22,838

investments.
Investment contract liabilities represents amounts due to policyholders and, if applicable, the cost of the minimum repayment guarantee. Investment 

contract liabilities are repayable on demand or at short notice and therefore classified as current. These liabilities are matched with highly liquid 

investments.

Current
Non-current

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information256

257

Notes to the financial statements
Notes to the financial statements

Notes to the financial statements

34 Commitments
34 Commitments
At the year end, the Group and Parent had no capital commitments relating to furniture, fittings and equipment (2020: £2,506,000).
34 Commitments
The Group has lease contracts for right-of-use assets that had not commenced at 31 December 2021. These leases will commence in 2022. Leases 
At the year end, the Group and Parent had no capital commitments relating to furniture, fittings and equipment (2020: £2,506,000).
for other equipment have a term of 2 years with expected cash outflow of £47,000 per annum. Leases for motor vehicles have a term of 4 years 

with an expected cash outflow of £73,000 per annum.
The Group has lease contracts for right-of-use assets that had not commenced at 31 December 2021. These leases will commence in 2022. Leases 

for other equipment have a term of 2 years with expected cash outflow of £47,000 per annum. Leases for motor vehicles have a term of 4 years 
35 Related undertakings
with an expected cash outflow of £73,000 per annum.
35 Related undertakings
Ultimate parent company and controlling party
The Company is a wholly-owned subsidiary of Benefact Group plc. Its ultimate parent and controlling company is Benefact Trust Limited. Both 
35 Related undertakings
companies are incorporated and operate in the United Kingdom and copies of their financial statements are available from the registered office as 
Ultimate parent company and controlling party
shown on page 264. The parent companies of the smallest and largest groups for which group financial statements are drawn up are 
The Company is a wholly-owned subsidiary of Benefact Group plc. Its ultimate parent and controlling company is Benefact Trust Limited. Both 
Ecclesiastical Insurance Office plc and Benefact Trust Limited, respectively. 
companies are incorporated and operate in the United Kingdom and copies of their financial statements are available from the registered office as 

shown on page 264. The parent companies of the smallest and largest groups for which group financial statements are drawn up are 
Related undertakings
Ecclesiastical Insurance Office plc and Benefact Trust Limited, respectively. 
The Company's interest in related undertakings at 31 December 2021 is as follows:

Company
Registration Share
Number
Capital
Company
Registration Share
Number
Capital

2046087
Ordinary
0243111
Ordinary
2519319
Ordinary
Ordinary
2046087
Ordinary
0941199
Ordinary
0243111
Ordinary
10988127
Ordinary
2519319
Ordinary
6317314
Ordinary
0941199
Ordinary
6317313
Ordinary
10988127
Ordinary
6317314
Ordinary
6317313
Ordinary
007216506
623695054 Ordinary
162612286
Ordinary
Ordinary
007216506
623695054 Ordinary
162612286
Ordinary

Holding of shares by
Company

Group

Activity

Holding of shares by
Company

Group

Activity

100%
100%
100%
100%
100%
100%
100%
100%
 -
100%
100%
100%
 -
100%
100%
 -
 -
100%
 -
 -

 -
 -
 -
 -
 -
 -
 -
 -
100%
 -
 -
 -
100%
 -
 -
100%
100%
 -
100%
100%

Independent financial advisory
Life insurance
Investment management
Independent financial advisory
Trustee company
Life insurance
Trustee company
Investment management
Insurance agents and brokers
Trustee company
Investment holding company
Trustee company
Insurance agents and brokers
Investment holding company
Insurance
Risk management services
Dormant company
Insurance
Risk management services
Dormant company

 1

 1

 1

 1

 1

 1 3

 1 3

Subsidiary undertakings
Ecclesiastical Financial Advisory Services Limited
 1
Ecclesiastical Life Limited
Incorporated in the United Kingdom
EdenTree Investment Management Limited
Ecclesiastical Financial Advisory Services Limited
E.I.O. Trustees Limited
 1
 1
Ecclesiastical Life Limited
Ecclesiastical Group Healthcare Trustees Limited
EdenTree Investment Management Limited
SEIB Insurance Brokers Limited
E.I.O. Trustees Limited
South Essex Insurance Holdings Limited
Ecclesiastical Group Healthcare Trustees Limited
Incorporated in Australia
SEIB Insurance Brokers Limited
South Essex Insurance Holdings Limited
Ansvar Insurance Limited
Ansvar Risk Management Services Pty Limited
Incorporated in Australia
Ansvar Insurance Services Pty Limited
Ansvar Insurance Limited
Ansvar Risk Management Services Pty Limited
1
Ansvar Insurance Services Pty Limited
2

 2 4

 2 4

 2

 2

 2

 2

 1

 1

 1

 1

Registered office: Benefact House, 2000 Pioneer Avenue, Gloucester Business Park, Brockworth, Gloucester, GL3 4AW, United Kingdom

Registered office: Level 5, 1 Southbank Boulevard, Melbourne, VIC 3006, Australia

3

1
4

2

3

4

Exempt from audit under s480 of the Companies Act 2006
Registered office: Benefact House, 2000 Pioneer Avenue, Gloucester Business Park, Brockworth, Gloucester, GL3 4AW, United Kingdom
Exempt from audit
Registered office: Level 5, 1 Southbank Boulevard, Melbourne, VIC 3006, Australia

Exempt from audit under s480 of the Companies Act 2006

Exempt from audit

2021

Group
£000

Parent
£000

2020

Group
£000

Parent
£000

Subsidiary undertakings

Company
Incorporated in the United Kingdom

Related undertakings
The Company's interest in related undertakings at 31 December 2021 is as follows:
Company

Notes to the financial statements
Notes to the financial statements
33 Leases (continued)
33 Leases (continued)

Group profit for the year has been arrived at after charging the following amounts in respect of lease contracts:

Depreciation expense of right-of-use assets 
Interest expense on lease liabilities
Expenses relating to short-term leases 

2021
£000

3,162
974
23
4,159

2020
£000

3,273
773
9
4,055

The Group had total cash outflows for leases, including interest paid, of £4,206,000 (2020: £5,872,000). The Parent had total cash outflows for 

leases, including interest paid, of £3,406,000 (2020: £5,103,000). The future cash outflows relating to leases that have not yet commenced are 

disclosed in note 34.

The Group has several lease contracts that include extension and termination options. These options are negotiated by management to provide 

flexibility in managing the leased-asset portfolio and align with the Group's business needs. Management exercises significant judgement in 

determining whether these extension and termination options are reasonably certain to be exercised, as disclosed in note 2.

Group as a lessor
Finance leases
The Group has a finance leasing arrangement as a lessor to sublease a commercial office space no longer occupied by the Group. The remaining 

term of the finance lease is less than 1 year. The contract does not include an extension or early termination option.

Year 1
Year 2
Undiscounted lease payments
Less: unearned finance income
Net investment in the lease

111
 -
111
 -
111

111
 -
111
 -
111

Net investment in the lease is recognised in other assets as shown in note 23.

Group profit for the year has been arrived at after crediting the following amounts in respect of finance lease contracts:

Finance income on the net investment in finance leases

131
110
241
(5)
236

2021
£000

4
4

131
110
241
(5)
236

2020
£000

7
7

Operating leases
The Group has entered into operating leases on its investment property portfolio. These leases have terms of up to 50 years. All leases include a 

clause to enable upward revision of the rental charge on an annual basis according to prevailing market conditions. The lessee is also required to 

provide a residual value guarantee on the properties. Rental income on these properties recognised by the Group during the year is disclosed in 

note 20.

Future minimum rentals receivable under non-cancellable operating leases as at 31 December are as follows:

Year 1
Year 2
Year 3
Year 4
Year 5
After 5 years

2021

2020

Group
£000

7,866
7,604
7,165
6,014
4,883
20,217
53,749

Parent
£000

7,866
7,604
7,165
6,014
4,883
20,217
53,749

Group
£000

8,150
7,290
6,773
6,390
5,441
22,163
56,207

Parent
£000

8,150
7,290
6,773
6,390
5,441
22,163
56,207

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information258

259

Notes to the financial statements
Notes to the financial statements
36 Related party transactions (continued)
36 Related party transactions (continued)

The total aggregate remuneration of the directors in respect of qualifying services during 2021 was £2,801,000 (2020: £2,344,000). After inclusion 

of amounts receivable under long-term incentive schemes and pension benefits, the total aggregate emoluments of the directors was £3,564,000 

(2020: £3,043,000). The key management personnel is defined as the Group Management Board (Ecclesiastical's leadership team), Executive and 

Non-executive directors. The remuneration is shown below.

Key management personnel
Wages and salaries
Social security costs
Pension costs - defined contribution plans
Fees and benefits for non-executive directors

2021

2020

Group
£000

6,221
566
303
602
7,692

Parent
£000

6,221
566
303
602
7,692

Group
£000

3,645
558
241
606
5,050

Parent
£000

3,645
558
241
606
5,050

Charitable grants paid to the Group's ultimate Parent undertaking are disclosed in note 15. Contributions paid to and amounts received from the 

Group's defined benefits schemes are disclosed in note 18.

Notes to the financial statements
Notes to the financial statements

36 Related party transactions
36 Related party transactions
Transactions between the Company and its subsidiaries, which are related parties, have been eliminated on consolidation and are not included in 

the Group analysis, but are included within the Parent analysis below. 

Benefact Group plc is the Group and Parent's immediate parent company. Other related parties, of both Group and Parent, include subsidiary

undertakings of Benefact Group plc, the ultimate parent undertaking and the Group's pension plans.

2021
Group
Trading, investment and other income, including recharges, and amounts received 
Trading, investment and other expenditure, including recharges, and amounts paid
Amounts owed by related parties
Amounts owed to related parties

Parent
Trading, investment and other income, including recharges, and amounts received 
Trading, investment and other expenditure, including recharges, and amounts paid
Amounts owed by related parties
Amounts owed to related parties

2020
Group (restated)
Trading, investment and other income, including recharges, and amounts received 
Trading, investment and other expenditure, including recharges, and amounts paid
Amounts owed by related parties
Amounts owed to related parties*

Parent
Trading, investment and other income, including recharges, and amounts received 
Trading, investment and other expenditure, including recharges, and amounts paid
Amounts owed by related parties
Amounts owed to related parties

Benefact
Group plc
£000

Subsidiaries
£000

531
15,625
66,254
 -

531
15,625
66,254
 -

480
13,525
50,991
 -

480
13,525
50,991
 -

 -
 -
 -
 -

17,700
25,971
12,278
9,458

 -
 -
 -
 -

3,238
20,980
3,873
2,265

Other
related
parties
£000

14,188
5,706
2,646
53,924

960
1,438
2,156
10

1,880
4,534
1,692
43,833

535
1,467
1,649
 -

*Amounts owed to related parties of the Group in the prior year have been restated from £57,427,000, to better reflect the fair value of funeral plan liabilities.

During the year, the Company received premiums, commission and reinsurance recoveries via a related party insurance agency amounting to 

£147,000 (2020: £38,000) and paid reinsurance protection, commission and claims amounting to £136,000 (2020: £34,000).

Trading, investment and other expenditure, including recharges, and amounts paid in the current year includes loans totalling £24.9m (2020: 

£13.1m), general business claims of £11.2m (2020: £5.7m) and acquisition of shares totalling £nil (2020: £11.1m). 

Trading, investment and other income, including recharges, and amounts received in the current year includes general business premiums 

totalling £13.0m (2020: £0.6m) and deposits received for life business totalling £11.8m (2020: £nil).

Amounts owed to related parties by the Group and by the Parent include insurance liabilities which are included in note 27. Amounts owed to 

related parties by the Group also includes investment contract liabilities which are included in note 32.

Transactions and services within the Group are made on commercial terms. With the exception of some insurance liabilities, amounts 

outstanding between Group companies are unsecured, are not subject to guarantees, and will be settled in cash. No provisions have been made 

in respect of these balances.

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther Information 
 
260

261

Notes to the financial statements
Notes to the financial statements
37 Reconciliation of Alternative Performance Measures (continued)
37 Reconciliation of Alternative Performance Measures (continued)

Group

Revenue
Gross written premiums
Outward reinsurance premiums
Net change in provision for unearned premiums
Net earned premiums

Fee and commission income
Other operating income
Net investment return
Total revenue

Expenses
Claims and change in insurance liabilities
Reinsurance recoveries
Fees, commissions and other acquisition costs
Other operating and administrative expenses
Total operating expenses

Operating profit
Finance costs
Profit/(loss) before tax

Underwriting profit

Combined operating ratio

2020

Inv'mnt

Broking
and
mngt Advisory

Inv'mnt
return

Corporate
costs

Total

£000

£000

£000

£000

£000

Insurance

General
£000

Life
£000

12
 -
 -
12

 -
 -
 -
 -

 -
 -
 -
 -

 -
 -
 -
 -

 -
 -
(484)
(472)

 -
 -
(4,600)
(4,600)

12,382
 -
(25)
12,357

9,458
 -
811
10,269

 -
 -
 -
 -

 -
 -
 -
 -

437,299
(173,074)
(16,562)
247,663

69,582
2,126
(4,298)
315,073

1,333
 -
(13)
(380)
940

468
 -
468

 -
 -
 -
(2,813)
(2,813)

(7,413)
 -
(7,413)

 -
 -
(939)
(12,449)
(13,388)

(1,031)
 -
(1,031)

 -
 -
360
(8,149)
(7,789)

2,480
(83)
2,397

[5]

 -
 -
 -
(21,533)
(21,533)

(21,533)
 -
(21,533)

(222,794)
94,581
(85,444)
(116,393)
(330,050)

(14,977)
(769)
(15,746)

437,287
(173,074)
(16,562)
247,651

47,742
2,126
 -
297,519

(224,127)
94,581
(84,852)
(71,069)
(285,467)

12,052
(686)
11,366

[1]

[2]

[3]
[4]

[6]

[6]

12,052

95.1%

Net expenses ( = [2] + [3] + [4] + [5] ) 

[7]

(129,712)

Net expense ratio

52%

Notes to the financial statements
Notes to the financial statements

37 Reconciliation of Alternative Performance Measures
37 Reconciliation of Alternative Performance Measures
The Group uses alternative performance measures (APM) in addition to the figures which are prepared in accordance with IFRS. The financial

measures included in our key performance indicators are set out on page 50: regulatory capital, combined operating ratio (COR), net expense ratio

(NER) and net inflows are APM. These measures are commonly used in the industries the Group operates in and are considered to provide useful

information and enhance the understanding of the results. 

Users of the accounts should be aware that similarly titled APM reported by other companies may be calculated differently. For that reason, the 

comparability of APM across companies might be limited.

The table below provides a reconciliation of the COR and NER to its most directly reconcilable line item in the financial statements. Regulatory 

capital and net inflows to funds managed by Ecclesiastical Insurance Office plc's subsidiary, EdenTree Investment Management Limited, do not have 

an IFRS equivalent. Net inflows are the difference between the funds invested (gross inflows) less funds withdrawn (redemptions) during the year 

by third parties in a range of funds EdenTree Investment Management Limited offers. Regulatory capital is covered in more detail in note 4(i).

Group

Revenue
Gross written premiums
Outward reinsurance premiums
Net change in provision for unearned premiums
Net earned premiums

Fee and commission income
Other operating income
Net investment return
Total revenue

Expenses
Claims and change in insurance liabilities
Reinsurance recoveries
Fees, commissions and other acquisition costs
Other operating and administrative expenses
Total operating expenses

Operating profit
Finance costs
Profit/(loss) before tax

Underwriting profit

Combined operating ratio

Net expenses ( = [2] + [3] + [4] + [5] ) 

Net expense ratio

2021

Inv'mnt
return

Inv'mnt
mngt

Broking
and
Advisory

Corporate
costs

Total

£000

£000

£000

£000

£000

Insurance

General
£000

Life
£000

486,220
(198,601)
(14,620)
272,999

(9)
 -
 -
(9)

 -
 -
 -
 -

 -
 -
 -
 -

 -
 -
 -
 -

55,417
1,136
 -
329,552

 -
 -
3,939
3,930

 -
 -
96,358
96,358

14,908
 -
6
14,914

11,222
 -
764
11,986

 -
 -
 -
 -

 -
 -
 -
 -

486,211
(198,601)
(14,620)
272,990

81,547
1,136
101,067
456,740

(267,291)
123,822
(95,628)
(81,696)
(320,793)

(2,342)
 -
(21)
(450)
(2,813)

 -
 -
 -
(3,234)
(3,234)

 -
 -
(979)
(16,460)
(17,439)

 -
 -
732
(9,658)
(8,926)

[5]

 -
 -
 -
(24,134)
(24,134)

(269,633)
123,822
(95,896)
(135,632)
(377,339)

8,759
(2,288)
6,471

1,117
 -
1,117

93,124
 -
93,124

(2,525)
 -
(2,525)

3,060
(76)
2,984

(24,134)
 -
(24,134)

79,401
(2,364)
77,037

[1]

[2]

[3]
[4]

[6]

[6]

8,759

96.8%

[7]

(146,041)

53%

The underwriting profit of the Group is defined as the operating profit of the general insurance business.

The Group uses the industry standard net COR as a measure of underwriting efficiency. The COR expresses the total of net claims costs, commission 

and underwriting expenses as a percentage of net earned premiums. It is calculated as ( [1] - [6] ) / [1] ).

The NER expresses total underwriting and corporate expenses as a proportion of net earned premiums. It is calculated as
 - [7] / [1].

Section FourFinancial PagesEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationSection Five

Other Information

Directors, executive management and company information 

United Kingdom regional centres 

United Kingdom business division and international branches 

Insurance subsidiaries and agencies 

Notice of meeting 

Notes 

264

266

267

268

269

270

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationDirectors, executive management and Company information (unaudited)

Directors, executive management and Company information (unaudited)
Directors, executive management and company information (unaudited)

Directors, executive management and Company information (unaudited)

Directors, executive management and Company information (unaudited)
Directors, executive management and company information (unaudited)

264

265

Auditor

Auditor

Registrar

Registrar

PricewaterhouseCoopers LLP
PricewaterhouseCoopers LLP
Bristol
Bristol

Computershare Investor Services plc
Computershare Investor Services plc
The Pavilions
The Pavilions
Bridgwater Road
Bridgwater Road
Bristol BS13 8AE
Bristol BS13 8AE

Directors

Directors

1

1

1

1

1

1

1

1

1

R. D. C. Henderson FCA Chair
R. D. C. Henderson FCA Chair
1
R. Bajaj MA
R. Bajaj MA
1
F. X. Boisseau MSc
F. X. Boisseau MSc
D. P. Cockrem, MA, FCA Group Chief Financial Officer
D. P. Cockrem, MA, FCA Group Chief Financial Officer
M. C. J. Hews BSc (Hons), FIA Group Chief Executive
M. C. J. Hews BSc (Hons), FIA Group Chief Executive
Sir S. M. J. Lamport GCVO, DL
Sir S. M. J. Lamport GCVO, DL
N. P. Maidment MA, FCII
N. P. Maidment MA, FCII
A. J. McIntyre MA, ACA, FRCO
A. J. McIntyre MA, ACA, FRCO
C. J. G. Moulder MA, FCA Senior Independent Director
C. J. G. Moulder MA, FCA Senior Independent Director
S. J. Whyte MC Inst. M, ACII Deputy Group Chief Executive
S. J. Whyte MC Inst. M, ACII Deputy Group Chief Executive
A. Winther BA
A. Winther BA

1

1

1

1

1

Company Secretary

Company Secretary

Mrs R. J. Hall FCG

Mrs R. J. Hall FCG

Registered and Head Office

Registered and Head Office

Benefact House,
Benefact House,
2000 Pioneer Avenue,
2000 Pioneer Avenue,
Gloucester Business Park,
Gloucester Business Park,
Brockworth,
Brockworth,
Gloucester, GL3 4AW
Gloucester, GL3 4AW
Tel: 0345 777 3322
Tel: 0345 777 3322

Company Registration Number

Company Registration Number

00024869

00024869

Investment Management Office

Investment Management Office

Legal advisers

Legal advisers

24 Monument Street
London EC3R 8AJ
Tel: 0800 358 3010

24 Monument Street
London EC3R 8AJ
Tel: 0800 358 3010

Charles Russell Speechlys LLP
Cheltenham and London

Charles Russell Speechlys LLP
Cheltenham and London

DAC Beachcroft LLP
Bristol and London

DAC Beachcroft LLP
Bristol and London

Eversheds Sutherland LLP
Cardiff, Birmingham and London

Eversheds Sutherland LLP
Cardiff, Birmingham and London

Burges Salmon LLP
Bristol and London

Burges Salmon LLP
Bristol and London

Harrison Clark Rickerbys LLP
Harrison Clark Rickerbys LLP
Cheltenham
Cheltenham

Matheson
Dublin

Matheson
Dublin

William Fry LLP
William Fry LLP
Dublin
Dublin

Pinsent Masons LLP
Birmingham and London

Pinsent Masons LLP
Birmingham and London

CMS Cameron McKenna Nabarro Olswang LLP
London, Leeds and Bristol

CMS Cameron McKenna Nabarro Olswang LLP
London, Leeds and Bristol

Fieldfisher Capital LLP
Fieldfisher Capital LLP
Dublin
Dublin

Wynne-Jones IP Limited
Cheltenham

Wynne-Jones IP Limited
Cheltenham

1 Non-Executive Directors

1 Non-Executive Directors

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section FiveOther informationUnited Kingdom regional centres (unaudited)

United Kingdom regional centres (unaudited)
United Kingdom regional centres (unaudited)

United Kingdom business division and international branches (unaudited)
United Kingdom business division and international branches (unaudited)

266

267

Central and South West

Central and South West

Office:

Office:

London and South East

London and South East

Office:

Office:

Tel:

Tel:

North

North

Tel:

Tel:

Office:

Office:

Tel:

Tel:

12th Floor
12th Floor
Alpha Tower
Alpha Tower
Suffolk Street
Suffolk Street
Queensway
Queensway
Birmingham B1 1TT
Birmingham B1 1TT
0345 605 0209
0345 605 0209

24 Monument Street
London EC3R 8AJ
0345 608 0069

24 Monument Street
London EC3R 8AJ
0345 608 0069

3rd Floor
3rd Floor
St Ann's House
St Ann's House
St Ann's Place
St Ann's Place
Manchester M2 7LP
Manchester M2 7LP
0345 603 7554
0345 603 7554

Ansvar Insurance
Business Division

Managing Director:
Office:

Canada Branch

Tel:

Deputy Group Chief Executive,
Ecclesiastical Insurance and
General Manager and Chief Agent:
Chief Office:

-

-

-

-

Eastern Region:

Regional Vice President:

Western Region:

Regional Vice President:

Pacific Region:

Regional Vice President:

Central Region and
National Accounts:

Regional Vice President:

Ireland Branch

Managing Director:
Office:

S. Cox ACII Chartered Insurer
Ansvar House
31 St. Leonards Road
Eastbourne, East Sussex BN21 3UR
0345 60 20 999

S. J. Whyte MC Inst M, ACII
2200-100 Wellington St W, TD West Tower
P.O. Box 307
Toronto, Ontario M5K 1K2

K. Biermann BBA, CIP
100 Eileen Stubbs Avenue
Suite 201
Dartmouth, Nova Scotia  B3B 1Y6

K. Webster CRM, FCIP
Suite 521, 10333 Southport Road S.W.
Calgary, Alberta T2W 3X6

N. de Souza Jensen BA, CIP
Suite 1713, Three Bentall Centre
595 Burrard Street, Box 49096
Vancouver, British Columbia V7X 1G4

R. Jordan BBA, CRM, FCIP
2200-100 Wellington St W, TD West Tower
P.O. Box 307
Toronto, Ontario M5K 1K2

D. G. Lane B.Comm (Hons), Certified Insurance Director
2nd Floor, Block F2
Eastpoint
Dublin 3, DO3 T6P8

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section FiveOther informationInsurance subsidiaries and agencies (unaudited)

Insurance subsidiaries and agencies (unaudited)
Insurance subsidiaries and agencies (unaudited)

Notice of meeting (unaudited)
Notice of meeting (unaudited)
Notice of meeting (unaudited)

268

269

Ansvar Insurance Limited

Ansvar Insurance Limited

Chief Executive Officer:
Head Office:

Chief Executive Officer:
Head Office:

W. R. Hutcheon MBA, GAICD, Fellow ANZIIF (CIP)
W. R. Hutcheon MBA, GAICD, Fellow ANZIIF (CIP)
Level 5
Level 5
1 Southbank Boulevard
1 Southbank Boulevard
Southbank
Southbank
Melbourne VIC 3006
Melbourne VIC 3006

Ecclesiastical Life Limited

Ecclesiastical Life Limited

Chief Executive Officer:
Head Office:

Chief Executive Officer:
Head Office:

Ecclesiastical Underwriting
Ecclesiastical Underwriting
Management Limited
Management Limited

Office: 

Office: 

SEIB Insurance
Brokers Limited

SEIB Insurance
Brokers Limited

Chief Executive Officer:
Chief Executive Officer:
Office:
Office:

Tel:

Tel:

P. S. Pickernell, FIA
P. S. Pickernell, FIA
Benefact House,
Benefact House,
2000 Pioneer Avenue,
2000 Pioneer Avenue,
Gloucester Business Park,
Gloucester Business Park,
Brockworth,
Brockworth,
Gloucester,
Gloucester,
GL3 4AW
GL3 4AW

Benefact House,
Benefact House,
2000 Pioneer Avenue,
2000 Pioneer Avenue,
Gloucester Business Park,
Gloucester Business Park,
Brockworth,
Brockworth,
Gloucester,
Gloucester,
GL3 4AW
GL3 4AW

S. Middleton FCII
S. Middleton FCII
South Essex House, North Road
South Essex House, North Road
South Ockendon
South Ockendon
Essex RM15 5BE
Essex RM15 5BE
01708 850000
01708 850000

NOTICE is hereby given that the Annual General Meeting of Ecclesiastical Insurance Office plc will be held at 24 Monument Street, London EC3R 

8AJ on Thursday, 23rd June 2022 at 12.35pm for the following purposes:
NOTICE is hereby given that the Annual General Meeting of Ecclesiastical Insurance Office plc will be held at 24 Monument Street, London EC3R 
8AJ on Thursday, 23rd June 2022 at 12.35pm for the following purposes:
Ordinary business (unaudited)
Ordinary business (unaudited)
Ordinary business (unaudited)
1.

To receive the Report of the Directors and Accounts for the year ended 31st December 2021 and the report of the auditors 

1.

2.

2.
3.

3.
4.

4.
5.

5.
6.

6.
7.

7.
8.

8.
9.

9.
10.

10.
11.

11.
12.

12.
13.

13.
14.

thereon.
To receive the Report of the Directors and Accounts for the year ended 31st December 2021 and the report of the auditors 

1
thereon.
To re-elect Mr F. X. Boisseau as a Director.

1
1
To re-elect Mr F. X. Boisseau as a Director.
To re-elect Mrs D. Cockrem as a Director.

1
1
To re-elect Mrs D. Cockrem as a Director.
To re-elect Mr R. D. C. Henderson as a Director.

1
1
To re-elect Mr R. D. C. Henderson as a Director.
To re-elect Mr M. C. J. Hews as a Director.

1
1
To re-elect Mr M. C. J. Hews as a Director.
To re-elect Sir S. Lamport as a Director.

1
1
To re-elect Sir S. Lamport as a Director.
To re-elect Mr N. Maidment as a Director.

1
1
To re-elect Mr N. Maidment as a Director.
To re-elect Mr A. J. McIntyre as a Director.

1
1
To re-elect Mr A. J. McIntyre as a Director.
To re-elect Mr C. J. G. Moulder as a Director.

1
1
To re-elect Mr C. J. G. Moulder as a Director.
To re-elect Mrs S. J. Whyte as a Director.

1
1
To re-elect Mrs S. J. Whyte as a Director.
To re-elect Mr A. Winther as a Director.

1
1
To re-elect Mr A. Winther as a Director.
To elect Mrs R. Bajaj as a Director.

1
To consider the declaration of a dividend. 
To elect Mrs R. Bajaj as a Director.

To consider the declaration of a dividend. 
To re-appoint PricewaterhouseCoopers LLP as auditors and authorise the Directors to fix their remuneration.

14.
By order of the Board

To re-appoint PricewaterhouseCoopers LLP as auditors and authorise the Directors to fix their remuneration.

By order of the Board
Mrs R. J. Hall, Secretary
17 March 2022
Mrs R. J. Hall, Secretary
1 Brief biographies of the Directors seeking election or re-election are shown on pages 100 to 102 of the 2021 Annual Report. All Non-Executive
17 March 2022
Directors seeking re-election have been subject to formal performance evaluation by the Chair who is satisfied that the performance of each Non-
1 Brief biographies of the Directors seeking election or re-election are shown on pages 100 to 102 of the 2021 Annual Report. All Non-Executive
Executive Director is effective and sufficient time has been spent on the Company’s affairs.
Directors seeking re-election have been subject to formal performance evaluation by the Chair who is satisfied that the performance of each Non-
Only a member holding ordinary shares, or their duly appointed representative(s), is entitled to attend, vote and speak at the annual general 
Executive Director is effective and sufficient time has been spent on the Company’s affairs.
meeting.
Only a member holding ordinary shares, or their duly appointed representative(s), is entitled to attend, vote and speak at the annual general 
A member holding ordinary shares is entitled to appoint a proxy or proxies (who need not be a member of the Company) to exercise all or any of
meeting.
their rights to attend, speak and vote on their behalf at the annual general meeting. Such a member may appoint more than one proxy in relation
A member holding ordinary shares is entitled to appoint a proxy or proxies (who need not be a member of the Company) to exercise all or any of
to the annual general meeting provided that each proxy is appointed to exercise the rights attached to a different share or shares held by that
their rights to attend, speak and vote on their behalf at the annual general meeting. Such a member may appoint more than one proxy in relation
member. 
to the annual general meeting provided that each proxy is appointed to exercise the rights attached to a different share or shares held by that
Any corporation which is a member holding ordinary shares can appoint one or more corporate representatives who may exercise, on its behalf,
member. 
all of the same powers as that corporation could exercise if it were an individual member, provided that they do not do so in relation to the same
Any corporation which is a member holding ordinary shares can appoint one or more corporate representatives who may exercise, on its behalf,
share or shares and that they act within the powers of their appointment.
all of the same powers as that corporation could exercise if it were an individual member, provided that they do not do so in relation to the same
This notice is sent purely for information to the holders of 8.625% Non-Cumulative Irredeemable Preference shares who are not entitled to attend
share or shares and that they act within the powers of their appointment.
and vote at the annual general meeting.
This notice is sent purely for information to the holders of 8.625% Non-Cumulative Irredeemable Preference shares who are not entitled to attend

and vote at the annual general meeting.

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section FiveOther informationOther information

270

271

Notes

Notes

Section OneAbout UsSection TwoStrategic ReportSection ThreeGovernanceSection FourFinancial StatementsSection FiveOther InformationEcclesiastical Insurance Office plc Annual Report & Accounts 2021Section FiveOther informationOther information

272

Notes

A
b
o
u
t

U
s

S
e
c
t
i
o
n
O
n
e

S
e
c
t
i
o
n
T
w
o

i

S
t
r
a
t
e
g
c
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

S
e
c
t
i
o
n
T
h
r
e
e

S
e
c
t
i
o
n
F
o
u
r

i

F
n
a
n
c
a
l

i

S
t
a
t
e
m
e
n
t
s

Fable
Design. Art Direction. Production.
fablecreative.co.uk

S
e
c
t
i
o
n
F
v
e

i

O

t
h
e
r

I

n
f
o
r

m
a
t
i
o
n

Section FiveOther information 
 
 
 
 
 
 
 
 
274

Annual Report & Accounts 2021
Ecclesiastical Insurance Office plc (EIO) 
Benefact House
2000 Pioneer Avenue
Gloucester Business Park
Brockworth
Gloucester
GL3 4AW

Ecclesiastical Insurance Office plc (EIO) Reg. No. 24869. Registered in England at Benefact House, 2000 Pioneer Avenue, Gloucester Business Park, Brockworth, Gloucester, GL3 4AW, United Kingdom. 
EIO is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Firm Reference Number 113848

Section OneAbout Us – Ecclesiastical at a glance