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HSBC

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FY2020 Annual Report · HSBC
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HSBC Holdings plc
Annual Report and Accounts 2020

Opening up a world 
of opportunity

Contents

Strategic report

Highlights

Group Chairman’s statement 
Group Chief Executive’s review

2 
4  Who we are
6 
8 
12  Our strategy
16  How we do business
22  Board decision making and  

engagement with stakeholders

25  Remuneration
26 
Financial overview
30  Global businesses
37  Risk overview
41   Long-term viability and going  

concern statement

Environmental, social and 
governance review

43   Our approach to ESG
44  Climate
52  Customers
Employees
62 
70  Governance

Financial review

Financial summary

77 
85  Global businesses and geographical 

regions

103  Reconciliation of alternative 
performance measures

Risk review

107  Our approach to risk
110  Top and emerging risks
116  Areas of special interest
118  Our material banking risks

Corporate governance report

196  Group Chairman’s governance statement
198  Biographies of Directors and senior 

management
213  Board committees
229  Directors’ remuneration report

Financial statements

 Independent auditors’ report

267 
278  Financial statements
288  Notes on the financial statements

Additional information

371  Shareholder information
377  Abbreviations

HSBC Holdings plc Annual Report and Accounts 2020

We have changed how we are reporting 
this year
We have changed our Annual Report and 
Accounts to embed the content previously 
provided in our Environmental, Social and 
Governance Update, demonstrating that how 
we do business is as important as what we do.

This Strategic Report was approved by the 
Board on 23 February 2021. 

Mark E Tucker 
Group Chairman

A reminder 
The currency we report in is US dollars. 

Adjusted measures 
We supplement our IFRS figures with 
non-IFRS measures used by management 
internally that constitute alternative 
performance measures under European 
Securities and Markets Authority guidance 
and non-GAAP financial measures defined  
in and presented in accordance with US 
Securities and Exchange Commission rules 
and regulations. These measures are 
highlighted with the following symbol:

Further explanation may be found on page 28.

None of the websites referred to in this Annual 
Report and Accounts 2020 (including where a 
link is provided), and none of the information 
contained on such websites, are incorporated 
by reference in this report.

HSBC Holdings plc
Annual Report and Accounts 2020

Opening up a world 
of opportunity

Cover image: Opening up  
a world of opportunity
We connect people, ideas and 
capital across the world, 
opening up opportunities for 
our customers and the 
communities we serve. 

 
Opening up a world of opportunity

Our ambition is to be the preferred international financial partner for our clients.

We have refined our purpose, ambition and values to reflect our strategy and to support our 
focus on execution.

Read more on our values, strategy and purpose on pages 4, 12 and 16.

Key themes of 2020

The Group has been – and continues to be – impacted by developments in the external environment, including:

Covid-19

Market factors

Geopolitical risk 

The Covid-19 outbreak has significantly 
affected the global economic environment 
and outlook, resulting in adverse impacts on 
financial performance, downward credit 
migration and muted demand for lending.

Interest rate reductions and market volatility 
impacted financial performance during  
2020. We expect low global interest rates to 
provide a headwind to improved profitability  
and returns. 

Levels of geopolitical risk increased with 
heightened US-China tensions and the UK’s 
trade negotiations with the EU notably 
impacting business and investor sentiment. 
We continue to monitor developments closely.

Read more on page 38. 

Read more on page 26. 

Read more on page 38. 

Progress in key areas

The Group continued to make progress in areas of strategic focus during 2020, including:

Supporting customers

Strategic progress

Climate

We continued to support our customers 
during the Covid-19 outbreak, providing relief 
to wholesale and retail customers through 
both market-wide schemes and HSBC-
specific measures.

We made good progress with our 
transformation programme in 2020.  
We have now set out the next phase  
of our strategic plan. 

In October 2020, we set out an ambitious  
plan to prioritise sustainable finance and 
investment that supports the global transition 
to a net zero carbon economy. 

Read more on page 17.

Read more on page 12.

Read more on page 15.

Financial performance

Non-financial highlights 

Reported profit after tax

$6.1bn

(2019: $8.7bn)

Basic earnings per share

$0.19 

(2019: $0.30)

Common equity tier 1 capital ratio

15.9%

(2019: 14.7%)

Gender diversity

30.3%

Women in senior leadership roles. (2019: 29.4%)

Customer satisfaction

7 out of 8

Sustainable finance and investment

$93.0bn

Cumulative total provided and facilitated  
since 2017. (2019: $52.4bn)

5 out of 8

Wealth and Personal Banking markets  
sustained top-three rank and/or improved  
in customer satisfaction.

Commercial Banking markets sustained 
top-three rank and/or improved in customer 
satisfaction.

Read more on our financial overview on page 26.

Read more on how we set and define our environmental, social and governance (‘ESG’) metrics on page 18.

1

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report

Highlights

Financial performance in 2020 was impacted by the Covid-19  
outbreak, together with the resultant reduction in global interest  
rates. Nevertheless, performance in Asia remained resilient and  
our Global Markets business delivered revenue growth.

Delivery against our 
financial targets

Return on average tangible equity

3.1%

February 2020 target: in the range of 10% to 
12% in 2022.
(2019: 8.4%)

Adjusted operating expenses

$31.5bn

Target: ≤$31bn in 2022.
(2019: $32.5bn)

Gross RWA reduction

$61.1bn

Target: >$100bn by end-2022.

 Further explanation of performance against 
Group financial targets may be found on page 26.

2

Financial performance  
(vs 2019)

Outlook and strategic 
update

 – Reported profit after tax down 30% to 
$6.1bn and reported profit before tax 
down 34% to $8.8bn from higher expected 
credit losses and other credit impairment 
charges (‘ECL’) and lower revenue, partly 
offset by a fall in operating expenses. 
Reported results in 2020 included a $1.3bn 
impairment of software intangibles, while 
reported results in 2019 included a $7.3bn 
impairment of goodwill. Adjusted profit 
before tax down 45% to $12.1bn.

 – Reported revenue down 10% to 

$50.4bn, primarily due to the progressive 
impact of lower interest rates across our 
global businesses, in part offset by higher 
revenue in Global Markets. Adjusted 
revenue down 8% to $50.4bn.

 – Net interest margin of 1.32% in 2020, 

down 26 basis points (‘bps’) from 2019, 
due to the impact of lower global interest rates.

 – Reported ECL up $6.1bn to $8.8bn, 

mainly due to the impact of the Covid-19 
outbreak and the forward economic outlook. 
Allowance for ECL on loans and advances to 
customers up from $8.7bn at 31 December 
2019 to $14.5bn at 31 December 2020.

 – Reported operating expenses down 
19% to $34.4bn, mainly due to the 
non-recurrence of a $7.3bn impairment of 
goodwill. Adjusted operating expenses 
down 3% to $31.5bn, as cost-saving 
initiatives and lower performance-related 
pay and discretionary expenditure more 
than offset the growth in investment spend.

 – During 2020, deposits grew by $204bn 
on a reported basis and $173bn on a 
constant currency basis, with growth in all 
global businesses. 

 – Common equity tier 1 (‘CET1’) ratio of 
15.9%, up 1.2 percentage points from 
14.7% at 31 December 2019, which 
included the impact of the cancellation of the 
fourth interim dividend of 2019 and changes 
to the capital treatment of software assets.  

 – After considering the requirements set out in 

the UK Prudential Regulation Authority’s 
(‘PRA’) temporary approach to shareholder 
distributions for 2020, the Board has 
announced an interim dividend for 2020 of 
$0.15 per ordinary share, to be paid in cash 
with no scrip alternative.

In February 2020, we outlined our plan to 
upgrade the return profile of our risk-weighted 
assets (‘RWAs’), reduce our cost base and 
streamline the organisation. Despite the 
significant headwinds posed by the impact of 
the Covid-19 outbreak, we have made good 
progress in implementing our plan.

However, we recognise a number of 
fundamental changes, including the prospect 
of prolonged low interest rates, the significant 
increase in digital engagement from customers 
and the enhanced focus on the environment. 

We have aligned our strategy accordingly.  
We intend to increase our focus on areas 
where we are strongest. We aim to 
increase and accelerate our investments 
in technology to enhance the capabilities we 
provide to customers and improve efficiency  
to drive down our cost base. We also intend  
to continue the transformation of our 
underperforming businesses. As part of our 
climate ambitions, we have set out our plans to 
capture the opportunities presented by 
the transition to a low-carbon economy.

We will continue to target an adjusted cost 
base of $31bn or less in 2022. This reflects 
a further reduction in our cost base, which has 
been broadly offset by the adverse impact  
of foreign currency translation due to the 
weakening US dollar towards the end of 2020. 
We will also continue to target a gross RWA 
reduction of over $100bn by the end of 
2022. Given the significant changes in our 
operating environment during 2020, we  
no longer expect to reach our return on 
average tangible equity (‘RoTE’) target  
of between 10% and 12% in 2022 as 
originally planned. The Group will now target 
a RoTE of greater than or equal to 10%  
in the medium term. 

We intend to maintain a CET1 ratio above 
14%, managing in the range of 14% to 
14.5% in the medium term and managing 
this range down in the longer term. The Board 
has adopted a policy designed to provide 
sustainable dividends going forward. We 
intend to transition towards a target payout 
ratio of between 40% and 55% of 
reported earnings per ordinary share 
(‘EPS’) from 2022 onwards, with the flexibility 
to adjust EPS for non-cash significant items 
such as goodwill or intangibles impairments. 
We will no longer offer a scrip dividend option, 
and will pay dividends entirely in cash.

HSBC Holdings plc Annual Report and Accounts 2020  
 
Highlights

Key financial metrics

Reported results

Reported revenue ($m)

Reported profit before tax ($m)

Reported profit after tax ($m)

Profit attributable to the ordinary shareholders of the parent company ($m)

Cost efficiency ratio (%)

Basic earnings per share ($)

Diluted earnings per share ($)

Net interest margin (%)

Alternative performance measures

Adjusted revenue ($m)

Adjusted profit before tax ($m)

Adjusted cost efficiency ratio (%)

Expected credit losses and other credit impairment charges (‘ECL’) as % of average 
gross loans and advances to customers (%)

Return on average ordinary shareholders’ equity (%)

Return on average tangible equity (%)1

Balance sheet

Total assets ($m)

Net loans and advances to customers ($m)

Customer accounts ($m)

Average interest-earning assets ($m)

Loans and advances to customers as % of customer accounts (%)

Total shareholders’ equity ($m)

Tangible ordinary shareholders’ equity ($m)

Net asset value per ordinary share at period end ($)

Tangible net asset value per ordinary share at period end ($)2

Capital, leverage and liquidity

Common equity tier 1 capital ratio (%)3

Risk-weighted assets ($m)3

Total capital ratio (%)3

Leverage ratio (%)3

High-quality liquid assets (liquidity value) ($bn)

Liquidity coverage ratio (%)

Share count

Period end basic number of $0.50 ordinary shares outstanding (millions)

Period end basic number of $0.50 ordinary shares outstanding and dilutive potential 
ordinary shares (millions)

Average basic number of $0.50 ordinary shares outstanding (millions)

Dividend per ordinary share (in respect of the period) ($)4

For the year ended

2019

56,098

13,347

8,708

5,969

75.5

0.30

0.30

1.58

54,944

22,149

59.2

0.25

3.6

8.4

At 31 December

2019

2,715,152

1,036,743

1,439,115

1,922,822

72.0

183,955

144,144

8.00

7.13

14.7

843,395

20.4

5.3

601

150

20,206

20,280

20,158

0.30

2020

50,429

8,777

6,099

3,898

68.3

0.19

0.19

1.32

50,366

12,149

62.5

0.81

2.3

3.1

2020

2,984,164

1,037,987

1,642,780

2,092,900

63.2

196,443

156,423

8.62

7.75

15.9

857,520

21.5

5.5

678

139

20,184

20,272

20,169

0.15

2018

53,780

19,890

15,025

12,608

64.4

0.63

0.63

1.66

52,098

21,199

60.9

0.16

7.7

8.6

2018

2,558,124

981,696

1,362,643

1,839,346

72.0

186,253

140,056

8.13

7.01

14.0

865,318

20.0

5.5

567

154

19,981

20,059

19,896

0.51

For reconciliations of our reported results to an adjusted basis, including lists of significant items, see page 85. Definitions and calculations of other alternative 
performance measures are included in our ‘Reconciliation of alternative performance measures’ on page 103.
1  Profit attributable to ordinary shareholders, excluding impairment of goodwill and other intangible assets and changes in present value of in-force insurance 

contracts (‘PVIF’) (net of tax), divided by average ordinary shareholders’ equity excluding goodwill, PVIF and other intangible assets (net of deferred tax).
2  Excludes impact of $0.10 per share dividend in the first quarter of 2019, following a June 2019 change in accounting practice on the recognition of interim 

dividends, from the date of declaration to the date of payment. 

3  Unless otherwise stated, regulatory capital ratios and requirements are based on the transitional arrangements of the Capital Requirements Regulation in force at 
the time. These include the regulatory transitional arrangements for IFRS 9 ‘Financial Instruments’, which are explained further on page 173. Leverage ratios are 
calculated using the end point definition of capital and the IFRS 9 regulatory transitional arrangements. Following the end of the transition period after the UK’s 
withdrawal from the EU, any reference to EU regulations and directives (including technical standards) should be read as a reference to the UK’s version of such 
regulation and/or directive, as onshored into UK law under the European Union (Withdrawal) Act 2018, as amended.

4  The fourth interim dividend of 2019, of $0.21 per ordinary share, was cancelled in response to a written request from the PRA. 2019 has been re-presented accordingly.

3

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report

Who we are

About HSBC 

With assets of $3.0tn and operations in 64 countries and territories at 31 December 2020, HSBC is one of the largest banking and financial services 
organisations in the world. More than 40 million customers bank with us and we employ around 226,000 full-time equivalent staff. We have around 
194,000 shareholders in 130 countries and territories.

Our values 

Our values help define who we are as an organisation, and are key to our long-term success. 

We value difference
Seeking out different  
perspectives

We succeed together
Collaborating across  
boundaries

We take responsibility
Holding ourselves accountable  
and taking the long view

We get it done
Moving at pace and making  
things happen

For further details on our strategy and purpose, see pages 12 and 16.

Our global businesses 

We serve our customers through three global 
businesses. On pages 30 to 36 we provide an 
overview of our performance in 2020 for each 
of our global businesses, as well as our 
Corporate Centre.

During the year, we simplified our 
organisational structure by combining Global 
Private Banking and Retail Banking and 
Wealth Management to form Wealth and 
Personal Banking. We also renamed our 
Balance Sheet Management function as 
Markets Treasury to reflect the activities it 
undertakes more accurately and its 
relationship to our Group Treasury function 
more broadly. These changes followed 
realignments within our internal reporting and 
include the reallocation of Markets Treasury,  

hyperinflation accounting in Argentina and 
HSBC Holdings net interest expense from 
Corporate Centre to the global businesses.

Each of the chief executive officers of our 
global businesses reports to our Group Chief 
Executive, who in turn reports to the Board of 
HSBC Holdings plc. 

 For further information on how we are governed, 
see our corporate governance report on  
page 195.

1  Calculation is based on adjusted revenue of our 
global businesses excluding Corporate Centre, 
which is also excluded from the total adjusted 
revenue number. Corporate Centre had negative 
adjusted revenue of $262m in 2020.

Adjusted revenue by global business1

WPB 44%
CMB 26%
GBM 30%

Wealth and Personal Banking  
(’WPB’) 
We help millions of our customers look 
after their day-to-day finances and 
manage, protect and grow their wealth.

Commercial Banking  
(‘CMB’) 
Our global reach and expertise help 
domestic and international businesses 
around the world unlock their potential. 

Global Banking and Markets  
(’GBM’) 
We provide a comprehensive range of 
financial services and products to 
corporates, governments and institutions. 

Our global functions 
Our business is supported by a number of corporate functions and our Digital Business Services teams, formerly known as HSBC 
Operations, Services and Technology. The global functions include Corporate Governance and Secretariat, Communications, Finance, 
Compliance, Human Resources, Internal Audit, Legal, Marketing, Risk and Strategy. Digital Business Services provides real estate, 
procurement, technology and operational services to the business.

4

HSBC Holdings plc Annual Report and Accounts 2020 
Who we are

Our global reach

Multi-award winning 

We aim to create long-term value for our shareholders and capture opportunity. Our goal is  
to lead in wealth, with a particular focus on Asia and the Middle East. Taking advantage of  
our international network, we aspire to lead in cross-border banking flows, and to serve 
mid-market corporates globally. We continue to maintain a strong capital, funding and  
liquidity position with a diversified business model.

We have won industry awards around the 
world for a variety of reasons – ranging from 
the quality of the service we provide to 
customers, to our efforts to support diversity 
and inclusion in the workplace.

Value of customer accounts by geography

North America

11%

UK
30%

Rest of Europe

Mainland China

8%

3%

A selection of the awards recognising 
our support of customers during the 
Covid-19 outbreak includes: 

Euromoney Awards for Excellence 2020 
Global Excellence in Leadership  
Excellence in Leadership in Asia  
Excellence in Leadership in the Middle 
East 

Greenwich Associates 2020 – Standout 
Bank for Corporates in Asia During Crisis  
Most Distinctive in Helping to Mitigate 
Impact of Covid-19

Latin America

2%

Middle East  and North Africa 

3%

Rest of Asia

Hong Kong

11% 32%

We highlight a selection of our other recent 
wins below.

See page 84 for further information on our customers and approach to geographical information.

Engaging with our stakeholders 

Euromoney Awards for Excellence 2020  
World’s Best Bank for Sustainable Finance  
World’s Best Bank for Transaction Services 
Hong Kong’s Best Bank 

The Banker Innovation in Digital Banking 
Awards 2020 
Best Digital Bank in Asia

Customers

Employees

Investors

Communities

Regulators and 
governments

Suppliers

Asia Insurance Industry Awards 2020 
Life Insurance Company of the Year 

Building strong relationships with our stakeholders helps enable us to deliver our 
strategy in line with our long-term values, and operate the business in a sustainable 
way. Our stakeholders are the people who work for us, bank with us, own us, regulate 
us, and live in the societies we serve and the planet we all inhabit. These human 
connections are complex and overlap. Many of our employees are customers and 
shareholders, while our business customers are often suppliers. We aim to serve, 
creating value for our customers and shareholders. Our size and global reach mean  
our actions can have a significant impact. We are committed to doing business 
responsibly, and thinking for the long term. This is key to delivering our strategy. 

 Our section 172 statement, detailing our Directors’ responsibility to stakeholders, can be found 
on page 22.

PWM Wealth Tech Awards 2020 
Best Global Private Bank for Digital 
Customer Experience

Stonewall 
Stonewall Top Global Employers List – 2020 

5

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020 
 
Strategic report

Group Chairman’s statement

The past year brought unprecedented challenges, but our 
people responded exceptionally well and our performance  
has been resilient.

helped ensure our customers received the 
support they needed – all the while managing 
their own, at times extremely difficult, 
situations at home. On behalf of the Board, I 
would like to express my deepest thanks to 
them all for the exceptional way they are 
responding to these most challenging 
circumstances. 

Against this backdrop, HSBC demonstrated a 
resilient performance. Reported profit before 
tax was $8.8bn, a fall of 34%, and adjusted 
profit before tax was $12.1bn, down 45%. 
Within this, Global Banking and Markets 
performed particularly well, while Asia was 
once again by far the most profitable region. 
Deposits also increased significantly across 
the Group, reinforcing the strength of our 
funding and liquidity positions.

In response to a request from the UK’s 
Prudential Regulation Authority, we cancelled 
the fourth interim dividend for 2019. We also 
announced that, until the end of 2020, we 
would make no quarterly or interim dividend 
payments or accruals in respect of ordinary 
shares. This was a difficult decision and we 
deeply regret the impact it has had on our 
shareholders. We are therefore pleased to 
restart dividend payments at the earliest 
opportunity. The Board has announced an 
interim dividend of $0.15 for 2020, and 
adopted a policy designed to provide 
sustainable dividends in the future.

Board of Directors
The confirmation of Noel Quinn as permanent 
Group Chief Executive underlined the Board’s 
belief that he is the best person to lead  
the delivery of the strategic plan. We look  
forward to working closely with Noel and  
the management team as they focus on 
executing our strategic priorities in 2021.

Jamie Forese, Steve Guggenheimer and  
Eileen Murray joined the Board as independent 
non-executive Directors in 2020. All three  
have already demonstrated the valuable skills, 
expertise and experience they bring across  
a wide range of areas, including technology. 
We have also announced that Dame Carolyn 
Fairbairn will join the Board as an independent 
non-executive Director. Carolyn will bring  
a wealth of relevant experience, and her 
appointment will be effective from  
1 September 2021. 

Mark E Tucker
Group Chairman

6

In 2020, we experienced economic and 
social upheaval on a scale unseen in 
living memory. Even before the year 
began, the external environment was 
being reshaped by a range of factors 
– including the impact of trade tensions 
between the US and China, Brexit, low 
interest rates and rapid technological 
development. The spread of the Covid-19 
virus made that environment all the more 
complex and challenging.

The Covid-19 pandemic has severely impacted 
our customers, our colleagues, our 
shareholders and the communities we serve. 
The first priority was, and remains, dealing 
with the public health crisis, but the economic 
crisis that unfolded simultaneously has also 
been unprecedented in recent times. The 
financial services industry has been at the 
forefront of helping businesses and individuals 
through the difficulties they have faced, 
working with governments and regulators 
towards expected recovery and future growth. 
I am enormously proud of the professionalism, 
dedication and energy that my colleagues 
around the world have demonstrated as they 

HSBC Holdings plc Annual Report and Accounts 2020Group Chairman’s statement

“ There are many 
opportunities ahead  
for a bank with HSBC’s 
competitive strengths.”

As reported in the Annual Report and 
Accounts 2019, Sir Jonathan Symonds and 
Kathleen Casey retired from the Board last 
year. Today we also announced that Laura Cha 
will step down from the Board immediately 
after our 2021 Annual General Meeting 
(‘AGM’) in May. I would like to thank  
Jon, Kathy and Laura for the enormous 
contributions they made to HSBC during their 
years of service. We are now in the advanced 
stages of a search for suitable candidates  
to join and strengthen the Board, and I will 
update further on the outcome of this search 
in due course.

Like the rest of the Group, the Board had to 
adapt its ways of working in 2020. We met 
virtually for much of the year, which brought 
benefits including less travel and more 
frequent, shorter meetings. It will be important 
for us to consider how we retain what has 
worked well over the last year once restrictions 
are lifted and it becomes possible to travel 
once again.

The Board enjoys the constructive discussions 
that we have with shareholders at the AGM in 
the UK and the Informal Shareholders’ 
Meeting in Hong Kong, so it was a matter of 
regret that we did not meet in person in 2020. 
While we did maintain regular contact with 
shareholders throughout the year, we will 
resume our face-to-face engagement with 
shareholders in the UK, Hong Kong and more 
widely, as soon as is practicable.

External environment
After the significant deterioration in global 
economic conditions in the first half of the year 
due to the Covid-19 pandemic, there were 
signs of improvement in the second half, 
especially in Asia. The most impressive 
economic recovery has been in China – still 
the biggest driver of global growth – where 
international trade is rebounding most 
strongly. The signing of the Regional 
Comprehensive Economic Partnership should 
further boost intra-regional activity across 
Asia, while the recent political agreement 
between the EU and China on an investment 
deal should, once ratified, bolster the already 
significant two-way investment flows.

Covid-19 infection levels remain very high in 
Europe, the US and Latin America, and new 
variants of the virus have spread quickly. This 

has necessitated new lockdown measures  
in the UK and other countries. While the 
deployment of multiple vaccines means we 
are more optimistic about the future, there is 
clearly still some way to go before life can 
return to something like normality. Recovery 
will therefore take longer in these economies, 
with growth more likely later in 2021 in  
these economies.

The agreement of a trade deal between the  
UK and EU prior to the end of 2020 provides 
some certainty for cross-border trade. 
However, the reduced access for financial 
services under these new arrangements 
means that further work is needed to maintain 
the level playing field that has existed until 
now. Given the many benefits that the UK 
financial services industry brings to the UK 
and EU economies, equivalence must be a  
key priority for both parties.

The geopolitical environment remains 
challenging – in particular for a global bank  
like HSBC – and we continue to be mindful  
of the potential impact that it could have on 
our strategy. We continue to engage fully  
and frequently with all governments as we 
seek to do everything we possibly can to  
help our customers navigate an increasingly 
complex world.

Capturing future opportunities
Given the external environment, it is vital  
we stay focused on what we can control.  
The Board is confident there are many 
opportunities ahead for a bank with HSBC’s 
competitive strengths. This makes it all the 
more important that we position ourselves  
to capture them.

While we prioritised supporting our customers 
and our people during the pandemic, we 
made good progress against the three 
strategic priorities announced in February 
2020 – reallocating capital from 
underperforming parts of the business, 
reducing costs and simplifying the 
organisation. In particular, the Board worked 
closely with the management team over the 
course of the year on plans to accelerate 
progress and investment in key areas of 
growth, which include our Asian franchise,  
our wealth business and new technology 
across the Group. 

We are today unveiling the outcome of 
extensive consultation with our people and 
customers on the Group’s purpose and values. 
Being clear about who we are, what we stand 
for and how this connects to our strategy is an 
important part of how we align and energise 
the organisation to create long-term value for 
all those we work with and for – our investors, 
customers, employees, suppliers and the 
communities we serve. The Board fully 
endorses the outcome of this work.

Our commitment to create sustainable value is 
demonstrated by the new climate ambitions 
we announced in October 2020. The most 
significant contribution that HSBC can make 
to the fight against climate change is to bring 
our customers with us on the transition to a 
low-carbon future. Our goal of being net zero 
for our financed emissions by 2050 sends an 
important signal to our investors, our 
customers and our people – if our clients are 
prepared to change their business models and 
make that transition, we will help and support 
them to do so. HSBC was also delighted to be 
one of the founding signatories of the Terra 
Carta, which was launched last month by HRH 
The Prince of Wales’ Sustainable Markets 
Initiative. Further details about all of the steps 
we are taking towards a more sustainable 
future are set out in the ESG review, which for 
the first time is included within the Annual 
Report and Accounts 2020.

Finally, 2020 underlined once again that  
our people are the driving force behind  
our business. I would like to reiterate how 
enormously grateful I am to my colleagues for 
the great dedication and care they showed to 
our customers and to each other during such 
testing times. Further empowering and 
enabling them to do their jobs and execute  
our strategic priorities is the key to our  
future success.

Mark E Tucker
Group Chairman

23 February 2021

7

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report 

Group Chief Executive’s review

With a blueprint for the future and a renewed purpose to guide us, 
we are building a dynamic, efficient and agile global bank with a 
digital-first mindset, capable of providing a world-leading service 
to our customers and strong returns for our investors.

digital capabilities – both in 2020 and in 
previous years – enabled our customers to 
access more services remotely, and we 
worked closely with our regulators around the 
world to open new digital channels in a safe 
and secure way. In total, we provided more 
than $26bn of relief to our personal customers 
and more than $52bn to our wholesale 
customers, both through government 
schemes and our own relief initiatives. We also 
played a vital role in keeping capital flowing for 
our clients, arranging more than $1.9tn of loan, 
debt and equity financing for our wholesale 
customers during 2020.

Even in the middle of the pandemic, we 
continued to look to the future. In October, we 
announced our ambition to become a net zero 
bank by 2050, supporting customers through 
the transition to a low-carbon economy and 
helping to unlock next-generation climate 
solutions. If the Covid-19 pandemic provided a 
shock to the system, a climate crisis has the 
potential to be much more drastic in its 
consequences and longevity. We are therefore 
stepping up support for our clients in a material 
way, working together to build a thriving 
low-carbon economy and focusing our 
business on helping achieve that goal.

The actions we outlined in February 2020  
are largely on track or ahead of where  
we intended them to be, despite the 
complications of the pandemic. We renewed 
and re-energised the senior management 
team, with around three-quarters of the Group 
Executive Committee in post for just over a 
year or less. Our business is more streamlined 
than it was a year ago, with three global 
businesses instead of four and increased 
back-office consolidation. Costs are down 
materially, with over $1bn of gross operating 
costs removed during 2020. We are also 
already more than half-way towards our target 
to reduce at least $100bn of gross risk-
weighted assets by 2022. Unfortunately, the 
changed interest-rate environment means  
we are no longer able to achieve a return  
on tangible equity of 10% to 12% by 2022.  
We will now target a return on tangible equity 
of 10% or above over the medium term.

The world around us changed significantly  
in 2020. Central bank interest rates in many 
countries fell to record lows. Pandemic-related 
lockdowns led to a rapid acceleration in the 
shift from physical to digital banking. Like 
many businesses, we learned that our people 
could be just as productive working from 

Noel Quinn
Group Chief Executive 

8

In 2020, HSBC had a very clear mandate 
– to provide stability in a highly unstable 
environment for our customers, 
communities and colleagues. I believe  
we achieved that in spite of the many 
challenges presented by the Covid-19 
pandemic and heightened geopolitical 
uncertainty.

Our people delivered an exceptional level  
of support for our customers in very tough 
circumstances, while our strong balance sheet 
and liquidity gave reassurance to those who 
rely on us. We achieved this while delivering  
a solid financial performance in the context  
of the pandemic – particularly in Asia – and 
laying firm foundations for our future growth.  
I am proud of everything our people achieved 
and grateful for the loyalty of our customers 
during a very turbulent year.

2020
Helping our customers emerge from the 
Covid-19 pandemic in a sustainable position 
was our most pressing priority. We did this by 
equipping our colleagues to work from home 
at the height of the pandemic, and keeping the 
vast majority of our branches and all of our 
contact centres open. Our investment in our 

HSBC Holdings plc Annual Report and Accounts 2020Group Chief Executive’s review

“ Helping our customers 
emerge from the Covid-19 
pandemic in a sustainable 
position was our most 
pressing priority.“

home as in the office. Also, as the world 
resolved to build back responsibly from the 
pandemic, governments, businesses and 
customers united to accelerate a low-carbon 
transition that works for all.

All of these things caused us to adjust and 
reinforce elements of our strategy to fit this 
new environment. The growth plans that we 
have developed are a natural progression of 
our February 2020 plans. They aim to play to 
our strengths, especially in Asia; to accelerate 
our technology investment plans to deliver 
better customer service and increased 
productivity; to energise our business for 
growth; and to invest further in our own 
low-carbon transition and that of our 
customers. They are also designed to  
deliver a 10% return on tangible equity over  
the medium term in the current low interest-
rate environment.

Our purpose
As we charted the next stage of HSBC’s 
journey, we also reflected on our purpose as a 
business. We consulted widely both internally 
and externally, speaking to thousands of 
colleagues and customers, and looked deeply 
into our history. The same themes came up 
again and again.

HSBC has always focused on helping 
customers pursue the opportunities around 
them, whether as individuals or businesses. 
Sometimes those opportunities are clear and 
visible, and sometimes they are far from 
obvious. Sometimes they arise in the next 
street, and sometimes on the next continent. 
Sometimes they exist in the status quo, and 
sometimes they are a product of great social 
or economic change. But always, they 

represent a chance for our customers to grow 
and to help those close to them – protecting, 
nurturing, building.

‘Opening up a world of opportunity’ both 
captures this aim and lays down a challenge 
for the future. Opportunity never stands still. It 
changes and evolves with the world around 
us. It is our job to keep making the most of it, 
and to find and capture it with a spirit of 
entrepreneurialism, innovation and 
internationalism that represents HSBC at its 
very best. This is the essence of what our 
plans intend to deliver, and what we intend to 
keep delivering for our customers, colleagues 
and communities as we navigate change and 
complexity together. 

Financial performance
The pandemic inevitably affected our 2020 
financial performance. The shutdown of much 
of the global economy in the first half of the 
year caused a large rise in expected credit 
losses, and cuts in central bank interest rates 
reduced revenue in rate-sensitive business 
lines. We responded by accelerating the 
transformation of the Group, further reducing 
our operating costs and moving our focus 
from interest-rate sensitive business lines 
towards fee-generating businesses. Our 
expected credit losses stabilised in the second 
half of the year in line with the changed 
economic outlook, but the revenue 
environment remained muted.

As a consequence, the Group delivered 
$8.8bn of reported profit before tax, down 
34% on 2019, and $12.1bn of adjusted profits, 
down 45%. Our Asia business was again the 
major contributor, delivering $13bn of adjusted 
profit before tax in 2020.

Adjusted revenue was 8% lower than in 2019. 
This was due mainly to the impact of interest 
rate cuts at the start of the year on our deposit 
franchises in all three global businesses. By 
contrast, our Global Markets business 
benefited from increased customer activity 
due to market volatility throughout the year, 
growing adjusted revenue by 27%.

We made strong progress in reducing our 
operating expenses. A combination of our 
cost-saving programmes, cuts in 
performance-related pay and lower 
discretionary spending due to the Covid-19 
pandemic helped to reduce our adjusted 
operating expenses by $1.1bn or 3%.

9

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report | Group Chief Executive’s review

Response to Covid-19

Our operations have stayed highly 
resilient and we are participating in 
several Covid-19 relief measures.

Approximately 

85% 

of our employees are now equipped to work 
from home.

We provided over 

$26bn 

of relief to our personal customers.

Our investment plans remain essential to the 
future of the business. We continued to invest 
heavily in technology while managing costs 
down, spending $5.5bn during 2020.

Our funding, liquidity and capital remain 
strong. We grew deposits by $173bn on a 
constant currency basis, with increases across 
all three global businesses. Our common 
equity tier one ratio was 15.9% on 31 
December 2020.

Our shareholders
It was a difficult year for our shareholders.  
The Covid-19 pandemic and the impact of 
geopolitics weighed heavily on our share price 
throughout 2020. In March, we cancelled the 
payment of our fourth interim dividend for 2019 
at the request of our lead regulator, and also 
agreed not to make any quarterly or interim 
dividend payments until the end of 2020. This 
particularly affected shareholders who rely on 
our dividend for income. It was a priority for the 
management team to get back to being able to 
pay dividends by the end of the year, and we 
were pleased to be able to recommend the 
payment of an interim dividend for 2020.

10

Dividends are hugely important, but so is 
capacity for growth. To deliver both, we are 
adopting a new policy designed to provide 
sustainable dividends, offering good income 
while giving management the flexibility to 
reinvest capital to grow the firm over the 
medium term. We will consider share 
buy-backs, over time and not in the near term, 
where no immediate opportunity for capital 
redeployment exists. We will also no longer 
offer a scrip dividend option, and will pay 
dividends entirely in cash. 

The last 12 months were tough, but I am highly 
focused on turning our performance around in 
2021 and beyond. I strongly believe that the 
combination of our growth plans and our new 
dividend policy will unlock greater value for our 
shareholders in the years to come.

Opening up a world of opportunity
‘Opening up a world of opportunity’ is more 
than a purpose – it is a statement of intent. 
Everything that we plan to do over the next 
decade is designed to unlock opportunity  
for our stakeholders, whether customers, 
colleagues, shareholders or communities.  
We intend to do this by building a dynamic, 
efficient and agile global bank with a 
digital-first mindset, capable of providing  
a world-leading service to our customers and 
strong returns for our investors. We will also 
need to focus intently on the areas where  
we excel, and to foster a commercial and 
entrepreneurial culture with a conviction to get 
things done. We believe we can achieve this in 
four ways.

First, we plan to focus on and invest in the 
areas in which we are strongest. In Wealth 
and Personal Banking, we aim to become a 
market-leader for high net worth and ultra high 
net worth clients in Asia and the Asian 
diaspora, and to invest in our biggest retail 
markets where the opportunity is greatest. In 
Commercial Banking, we want to remain a 
global leader in cross-border trade, and to lead 
the world in serving mid-market corporates 
internationally. In Global Banking and Markets, 
we intend to invest to capture trade and capital 
flows into and across Asia, while connecting 
global clients to Asia and the Middle East 
through our international network.

everything that we want to achieve. It is how 
we intend to win new customers and retain 
them, to become more agile and efficient, to 
create richer, seamless customer journeys, 
and to build strong and innovative 
partnerships that deliver excellent benefits  
for our customers. We have an opportunity  
to meet the growing market need for 
sophisticated, robust and rapid payment 
solutions, and to lead our industry in applying 
digital solutions to analogue services, such as 
trade. We therefore intend to protect 
technology investment throughout the cycle, 
even as we reduce spending elsewhere.

Third, we want to energise HSBC for growth 
through a strong culture, simple ways of 
working, and by equipping our colleagues 
with the future skills they need. Giving life to 
our purpose will be critical to building the 
dynamic, entrepreneurial and inclusive culture 
that we want to create, as will removing the 
remaining structural barriers that sometimes 
stop our people from delivering for our 
customers. We need to change the way we 
hire to build skills and capabilities in areas that 
are different to what we have needed 
historically, including data, artificial 
intelligence, and sustainable business models. 
Our expanded HSBC University will also help 
to upskill and reskill our people, while fostering 
more of the softer skills that technology can 
never replace.

Fourth, we will seek to help our customers and 
communities to capture the opportunities 
presented by the transition to a low-carbon 
economy. Accelerating this transition is the 
right thing to do for the environment, but also 
the right thing commercially. We intend to 
build on our market-leading position in 
sustainable finance, supporting our clients 
with $750bn to $1tn of sustainable financing 
and investment over the next 10 years. We 
also intend to unlock new climate solutions by 
building one of the world’s leading climate 
managers – HSBC Pollination Climate Asset 
Management – and helping to transform 
sustainable infrastructure into a global asset 
class. These will help us achieve our ambition 
to align our portfolio of financed emissions to 
the Paris Agreement goal to achieve net zero 
by 2050.

Second, we intend to increase the pace at 
which we digitise HSBC through higher levels 
of technology investment. This underpins 

Championing inclusion
I believe passionately in building an inclusive 
organisation in which everyone has the 

HSBC Holdings plc Annual Report and Accounts 2020Group Chief Executive’s review

” I believe passionately  
in building an inclusive 
organisation in which 
everyone has the 
opportunity to fulfil  
their potential”

opportunity to fulfil their potential. Failing to do 
so isn’t just wrong, it is totally self-defeating. It 
means you don’t get the best out of the talent 
you have, and sends the wrong signals to the 
people you want to recruit. An inclusive 
environment is the foundation of a truly 
diverse organisation, with all of the rewards 
that brings.

There is much still to do, but we are moving in 
the right direction. More than 30% of our 
senior leaders are female, in line with the goal 
we set to achieve by the end of 2020. I want 
that number to increase to at least 35% by 
2025, and we have a number of initiatives in 
place to help achieve it. In May, we launched a 
new global ethnicity inclusion programme to 
better enable careers and career progression 
for colleagues from ethnic minorities, and in 
July, we made a series of commitments to 
address feedback from Black colleagues in 
particular. These included a commitment to 
more than double our number of Black senior 
leaders by 2025.

I am particularly proud that during a difficult 
year, which included a large-scale redundancy 
programme, employee sentiment improved 
within HSBC. Around 71% of my colleagues 
said that they found HSBC to be a great place 
to work, up from 66% in 2019. However, the 
view varies across employees from different 
groups. We know, for example, that 
employees with disabilities or who identify as 
ethnic minorities do not feel as engaged as 

others. I take these gaps very seriously.  
Better demographic data globally will help us 
benchmark and measure our progress more 
effectively, and we are taking concerted steps 
to be able to capture that information  
where possible. 

2021 outlook
We have had a good start to 2021, and I am 
cautiously optimistic for the year ahead. While a 
spike in Covid-19 infection rates led to renewed 
lockdown measures in many places at the start 
of 2021, the development of multiple vaccines 
gives us hope that the world will return to some 
form of normality before long. Nonetheless, we 
remain reactive to the ebb and flow of the 
Covid-19 virus and prepared to take further 
steps to manage the economic impact  
where necessary.

The geopolitical uncertainty that prevailed 
during 2020 remains a prominent feature of 
our operating environment. We are hopeful 
that this will reduce over the course of 2021, 
but mindful of the potential impact on our 
business if levels remain elevated. We remain 
focused on serving the needs of our 
customers, colleagues and communities in all 
our markets.

Our people
I would like to pay tribute to my colleagues 
and all those who supported them throughout 
a difficult year. HSBC is a community of 
around 226,000 colleagues – but it relies just 
as much on the family, friends and support 
networks that help them be the best they can 
be. Our people did extraordinary things in 
2020, but it asked a lot of those around them. I 
am hugely grateful to everyone who helped 
HSBC – whether directly or indirectly – in 
supporting our customers, communities and 
each other over the last 12 months.

Noel Quinn
Group Chief Executive

23 February 2021

11

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020 
Strategic report

Our strategy
Our strategy

With continued delivery against our February 2020 commitments, we 
are now in the next stage of our strategic plan, which responds to the 
significant shifts during the year and aligns to our refreshed purpose, 
values and ambition. 

Progress on our 2020 commitments

In February 2020, we outlined our plan to 
upgrade our returns profile through recycling 
risk-weighted assets (‘RWAs’) out of low-
return franchises into higher-performing ones, 
reducing our cost base and streamlining  
our organisation.

we outlined. We delivered $1bn of cost 
programme saves. We also reduced gross 
RWAs by $52bn, including $24bn from our 
non-ring-fenced bank in Europe and the UK, 
and are currently on track to meet the greater 
than $100bn target outlined by 2022. 

During 2020, in spite of significant headwinds 
posed by the impact of the Covid-19 outbreak 
across our network, we made significant 
progress on delivering against the ambitions 

We took bold steps to simplify our 
organisation, including the merger of Retail 
Banking and Wealth Management and Global 
Private Banking to form Wealth and Personal 

Banking. We also reduced management layers 
in Global Banking and Markets and our 
non-ring-fenced bank in Europe and the UK. 
We have built a strong capital position, ending 
the year with a CET1 ratio of 15.9%. Our return 
on tangible equity (‘RoTE’) of 3.1% was 
negatively impacted by the Covid-19 outbreak 
and the challenging macroeconomic 
environment, including lower interest rates 
and higher expected credit losses. 

Responding to the new environment 

There was a set of fundamental shifts in 2020 that profoundly impacted our organisation as well as the wider financial services sector. We have 
adapted our strategy accordingly.

Low interest-rate environment
Interest rates are expected to remain lower for 
longer, resulting in a more difficult revenue 
environment for the financial services sector.

The new digital experience economy
Remote working and global lockdowns due to 
the Covid-19 outbreak have increased our 
customers’ propensity and preference to 
engage digitally.

Increased focus on sustainability 
The demand for sustainable solutions and 
green finance rose to new highs in 2020.

Evolution of major interbank rates1
Three-month interbank offered rates (%)

3.0

2020
1.5

0.0

2018

2019

2020

2021

US

UK

Hong Kong

Digital banking usage up c.30%2 
in the industry 
% customers increasing digital usage, 
mid-2020 vs pre-Covid-19

80

60

40

20

0

Mobile 
Online

Average

US

UK

China

India

HSBC customer trends

125%
Increase in HSBCnet 
mobile downloads3

253%
Increase in HSBCnet 
mobile payments3

Green, social and sustainability 
(’GSS’) bond market4
$bn

GSS share
of global debt
capital markets

2018

179

2019

2020

261

2.7%

3.6%

5.0%

445

Companies with 
disclosed climate 
action targets 
under the Science 
Based Targets Initiative  

228

1,106

We are responding by targeting fee income 
growth in wealth and wholesale banking 
products and improving cost efficiencies.

We are responding by increasing investments 
in technology across our customer platforms.

We stepped up our climate ambitions – we 
aim to be a net zero bank and support our 
clients in their transition with $750bn to $1tn  
of financing. 

1 Source: Datastream.
2 Source: Bain & Company Covid-19 Pulse Survey, July 2020; Overall sample: 10,000.
3 Fourth quarter of 2020 vs fourth quarter of 2019.
4 Source: Dealogic.

12

(in 2018)(in 2020)HSBC Holdings plc Annual Report and Accounts 2020        
Our strategy

Shifting capital to areas with the highest returns and growth

We are responding to the changes in our 
operating environment, and building on our 
2020 commitments. Our strategy includes 
accelerating the shift of capital to areas, 
principally Asia and wealth, that have 
demonstrated the highest returns and where 

we have sustainable advantage through scale. 
Our international network remains a key 
competitive advantage and we will continue to 
support cross-border banking flows between 
major trade corridors. Supported by these 
shifts, we are aiming to reach mid-single-digit 

revenue growth in the medium to long term1, 
with a higher proportion of our revenue 
coming from fee and insurance income.

Capital allocation
Asia
(as a % of Group tangible equity2)

Wealth and Personal Banking
(as a % of Group tangible equity3)

Fees and insurance
(as a % of total revenue)

2020

c.42%

2020

c.25%

2020

Medium to long term

c.50%

Medium to long term

c.35%

Medium to long term

c.29%

c.35%

2020

2020

2020

1 Medium term is three to four years; long term is five to six years.
2 Based on tangible equity of the major legal entities excluding associates, Holdings companies, consolidation adjustments, and any potential inorganic actions.
3 WPB tangible equity as a share of tangible equity allocated to the global businesses (excluding Corporate Centre). Excludes Holdings companies, 
   consolidation adjustments, and any potential inorganic actions.

Group targets, dividend and capital policy

To support the ambitions of our strategy, we have revised our Group targets, dividend and capital policy.

Adjusted costs in 2022

Gross RWA reduction by end of 20221

CET1 ratio 

≤$31bn

(on December 2020 average exchange rate;  
or ≤$30bn using full year 2020 average 
exchange rate) 

>$100bn

≥14%

(manage in 14% to 14.5% range over  
medium term2, and manage the range  
down further long term2)

Sustainable cash dividends with  
a payout ratio3 of

40% to 55% 

from 2022 onwards 

RoTE over medium term

≥10%

(vs 10% to 12% in 2022 in February 2020 
commitment)

We have increased our 2022 cost reduction target by $1bn and we plan to keep costs stable from 2022. We also plan to reduce tangible equity in the 
US and in our non-ring-fenced-bank in Europe and the UK, and increase tangible equity in Asia and in Wealth and Personal Banking. Dividends could 
be supplemented by buy-backs or special dividends, over time and not in the near term4. We will also no longer offer a scrip dividend option, and will 
pay dividends entirely in cash. Given the significant changes in our operating environment during 2020, we no longer expect to reach our RoTE target 
of between 10% and 12% in 2022 as originally planned.

1 Excludes any inorganic actions. 
2 Medium term is three to four years; long term is five to six years.
3  We intend to transition towards a target payout ratio of between 40% and 55% of reported earnings per ordinary share (‘EPS’) from 2022 onwards, with the 

flexibility to adjust EPS for non-cash significant items, such as goodwill or intangibles impairments.

4 Should the Group find itself in an excess capital position absent compelling investment opportunities to deploy that excess.

13

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020 
Strategic report | Our strategy

Our strategy

We have embedded our purpose, values and ambition into our strategy. Our purpose is ‘Opening up a world of opportunity’. Our values are: 
we value difference; we succeed together; we take responsibility; and we get it done. Our ambition is to be the preferred international financial 
partner for our clients. Our strategy centres around four key areas: focus on our areas of strengths; digitise at scale to adapt our operating 
model for the future; energise our organisation for growth; and support the transition to a net zero global economy.

Focus on our strengths
In our global businesses 
In each of our global businesses, we will focus on areas where we are strongest and have significant opportunities for growth. We aim to invest 
approximately $6bn in Asia1, where we intend to drive double-digit growth in profit before tax in the region in the medium to long term2.

Wealth and Personal Banking
Our goal is to lead in wealth, with a particular 
focus on Asia and the Middle East, while 
investing in our largest retail markets such as 
Hong Kong and the UK. Over the medium to 
long term, we intend to grow wealth revenue 
at more than 10% compound annual growth 
rate, and grow Asia wealth assets under 
management faster than the market. In 
support of these ambitions, we aim to: capture 
opportunities to serve high and ultra high net 
worth segments across Asia, especially in 
China, south-east Asia, Hong Kong and 
Singapore; deploy our manufacturing 
capabilities at scale in insurance and asset 
management; and build propositions that 
facilitate client origination from our wholesale 
businesses. 

Commercial Banking
Taking advantage of our international 
network, we aspire to lead in supporting 
cross-border trade and in serving mid-market 
corporates globally. We plan to accelerate 
international client acquisition and deepen our 
share of wallet in cross-border services. We 
aim to develop front-end ecosystems to drive 
international mid-market client acquisition at 
scale. We plan to improve SME propositions 
in key markets with digital sales and service 
journeys. We will also continue to invest in 
our front-end platforms for Global Liquidity 
and Cash Management, Global Trade and 
Receivables Finance and Foreign Exchange to 
drive more fee income and accelerate our 
asset distribution. 

Global Banking and Markets
We will continue to invest in Global Banking and 
Markets as a leading international bank in Asia 
and the Middle East, with a global network to 
support trade and capital flows. We aim to 
invest in areas such as: enhancing digital 
platforms for our Asia wealth propositions, 
including structured products and foreign 
exchange; market access and execution 
capabilities in Global Markets and Securities 
Services; and expansion of our investment 
banking coverage across Asia. The next five 
years should see Global Banking and Markets 
pivot to a less volatile and higher-returns model, 
relying less on our balance sheet, and focusing 
more on the growing capital markets 
opportunity in Asia and the Middle East.

We aim to invest more than

We aim to invest approximately

We aim to invest approximately

$3.5bn 

$2bn

$0.8bn

in Asia over five years to 20251.

across global platforms3 over five years to 20251.

in Asia over five years to 20251.

Continued execution of our transformation programme
To help create capacity for growth, we are refocusing our US business, our non-ring-fenced bank in Europe and the UK, and our Global 
Banking and Markets business.

A focused international business in the US
We will continue to invest in our substantial 
corporate and institutional franchise in the US 
over the medium to long term, including taking 
actions to further increase international 
connectivity and revenue in other geographies 
where HSBC and our US client base have a 
strong presence around the world including 
Asia, the Middle East, the UK and continental 
Europe. We continue to explore strategic 
options with respect to our US retail franchise, 
looking to focus on our high net worth, Jade 
and Premier client base and wealth 
management products, while reviewing other 
options in respect of our retail banking 
presence. 

Our non-ring-fenced bank in Europe and 
the UK
Our non-ring-fenced bank will focus on a 
wholesale footprint that serves international 
customers both outbound and inbound within 
our network. We intend to continue investing in 
our transaction banking franchise that has 
strong linkage to Asia. We are continuing with 
the strategic review of our retail banking 
operations in France and are in negotiations in 
relation to a potential sale, although no decision 
has yet been taken. If any sale is implemented, 
given the underlying performance of the French 
retail business, a loss on sale is expected. We 
simplified our operating model, with shared 
services between our two hubs in London and 
Paris. We plan to continue reducing complexity 
in our RWA and cost consumption, and we aim 
to reduce costs5 by approximately 20% by 2022. 

Our Global Banking and Markets business
Our Global Banking and Markets business will 
refocus on Asia and the Middle East. We aim 
to be the pre-eminent corporate and 
investment bank in Asia, focusing on 
opportunities such as the regionalisation of 
trade and capital flows and the rise in wealth 
creation. We will focus on serving clients into 
and within Asia and the Middle East, and 
providing global institutions with access to 
developed and emerging markets. We are 
redeploying capital and moving centres of 
excellence in Global Markets and Global 
Banking closer to clients in Asia as we  
allocate investments to the region.

Commercial Banking and Global Banking 
revenue4 ($bn)

RWA5 ($bn)

2020

1.9

Medium-term

mid-single-digit 
compound annual 
growth rate

2019

20206

2022

Shifting allocation of RWAs (%)

173

167

c.(25)%

2019

2020

2022

1  Consists of ‘growth investment’, which refers to investment in strategic business growth  

(including the build-out of front-line staff).

East: Asia-Pacific and the Middle East        
West: Europe and the Americas

2 Medium term is three to four years; long term is five to six years.
3 Commercial Banking platforms will be tested in Asia and rolled out globally thereafter.
4 Including Global Liquidity and Cash Management and Global Trade and Receivables Finance revenue.
5 Excludes any inorganic actions.
6 Gross RWA saves of $24.4bn achieved in 2020, largely offset by changes in asset size and quality, and updates to models, methodology and policy.

2019

2020

2022

14

2019

HSBC Holdings plc Annual Report and Accounts 2020Our strategy

Digitise at scale

We plan to grow investments1 at a compound 
annual growth rate of approximately 7% to 
10% from 2019 to 2022. We will focus our 
investments in areas such as technology to 
improve our customers’ digital experiences 
while ensuring security and resilience. These 
investments will be funded in part by using 
technology to drive down costs, including a 
reduction in manual client processes and a 
reduction in our commercial real estate 
footprint.

Investing in technology
We aim to deliver excellent customer 
experience throughout our network,  
including through the use of straight-through 
processing for payments, and through 
partnerships with big technology firms and 
fintechs for innovation support. We also 
intend to build platforms for higher front-end 
productivity, including arming our front-line 
staff with data analytics and visualisation for 
key insights. We plan to automate our middle 
and back office by, for example, integrating 
machine-learning to improve analytics 
capabilities. We also plan to build solutions to 

Energise for growth 

We are moving to a leaner and simpler 
organisation that is energised and fit for  
the future. 

Inspire a dynamic culture 
We intend to re-energise our culture to 
succeed with purpose and bring our values  
to life. We also aim to adopt future ways of 
working. To support these objectives, we 
secured inputs from approximately 120,000 
colleagues and engaged with over 2,500 
customers to help shape our renewed purpose 
and values, which have been embedded into 
our strategy. Furthermore, we are launching 
new leadership expectations that help to: give 
life to our purpose; unleash our organisation’s 
potential; and see through our actions.  

Transition to net zero 

Our ambition is to support the transition to a 
net zero global economy. 

Becoming a net zero bank
We are making changes both in our own 
operations and for our customers through  
our financing portfolio. We aim to bring our 
operations and supply chain to net zero by 
2030 or sooner. We also plan to align our 
financed emissions – the carbon emissions  
of our portfolio of customers – to the Paris 
Agreement goal to achieve net zero by 2050  
or sooner.

free up office footprint, supported by a shift to 
a more agile way of working and more 
efficiencies through reduced headcount. 

Continuing to invest in technology 
capabilities
Technology spend ($bn)

2018

2019

2020

2022

4.7

5.3

5.5

$1bn 

increase in our 2022 cost reduction target

(≤$30bn based on full year 2020 exchange rate  
vs ≤$31bn in our February 2020 commitments)

We plan to deliver

$5bn to $5.5bn

of cost programme saves from 2020 to 2022.

(vs $4.5bn in February 2020 commitments)

Investments             Business-as-usual activities

We plan to spend approximately

Driving down our cost base 
We plan to deliver $5bn to $5.5bn of  
cost programme saves from 2020 to 2022, 
supporting a decline of our cost base to 
$31bn or less by 2022 (using December 2020 
average exchange rate) or $30bn or less 
(using full year 2020 average exchange rate). 
2019
We plan to keep costs broadly stable from 
2022, while increasing the proportion  
of investment.

$7bn

in costs to achieve to help deliver our cost saves.

(vs $6bn in February 2020 commitments)

1  ‘Investment’ includes strategic business growth 
(including build-out of front-line staff), and other 
strategic, regulatory, and technology investment 
(including amortisation).

Champion inclusion
We aim to increase diverse representation, 
particularly in the senior levels of our 
organisation. In 2020, we achieved more than 
30% of female senior leadership, and we 
intend to increase to more than 35% by 2025. 
We endeavour to close the gaps in employee 
engagement in under-represented groups. We 
are also focusing on the quality and reporting 
of ethnicity data and benchmarking our 
actions. Our progress to date includes race 
commitments to at least double the number of 
Black employees in senior leadership roles 
globally by 2025 and recognition within 
Stonewall’s 2020 Top Global Employers Index 
for LGBT+ staff. 

Develop future skills
To energise our colleagues, we are setting out 
initiatives to help develop their future skills and 
capabilities. We aim to deepen the prevalence 
of digital, professional and enabling skills 
across the organisation. Our accomplishments 
to date include expanding HSBC University 
courses on future skills, digitalisation and 
sustainability. Moreover, we are deploying 
third-party platforms such as Degreed, for 
educational technology, and Gloat, for career 
development.

Supporting our customers
Our aim is to provide between $750bn and 
$1tn of sustainable finance and investment by 
2030 to support our customers in their 
transition to lower carbon emissions.

We address the progress made on our 
commitments in a number of different sections 
of this Annual Report and Accounts 2020 and 
beyond. For more information on our climate 
strategy, please refer to the below.

Unlocking new climate solutions 
We are working with a range of partners to 
increase investment in natural resources, clean 
technology and sustainable infrastructure. We 
also plan to donate $100m to a programme 
that will support climate solutions to scale over 
the next five years. 

Our ESG review can be found on page 42.
 A summary of our fourth Task Force on 
Climate-related Financial Disclosures (‘TCFD’) 
can be found on page 20, and our TCFD Update 
2020 can be found at www.hsbc.com/esg.

15

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report

How we do business

We conduct our business intent on supporting the sustained 
success of our customers, people and other stakeholders.

Our approach

We recognise that it is important to be clear 
about who we are and what we stand for to 
create long-term value for our stakeholders. 
This will help us deliver our strategy and 
operate our business in a way that  
is sustainable.

Following an extensive consultation with  
our people and customers, we refined our 
purpose and values. Our new purpose is 
‘Opening up a world of opportunity’ and we 
aim to be the preferred international financial 
partner for our clients. 

To achieve this in a way that is sustainable, we 
are guided by our values: we value difference; 
we succeed together; we take responsibility; 
and we get it done.

Our Covid-19 actions
Having a clear purpose and strong values has 
never been more important, with the Covid-19 
pandemic testing us all in ways we could 
never have anticipated. As the world changed 
over the course of 2020, we adapted to new 
ways of working and endeavoured to provide 
support to our customers during this 
challenging period. 

We kept the majority of our branches and all 
of our contact centres open. To help achieve 
this, we equipped 85% of our colleagues to be 

able to work from home, and provided extra 
resources and support to help them manage 
the mental and physical health challenges of 
the pandemic.

We did not apply for government support 
packages for our employees across the 
countries and territories in which we operate. 

connected workforce. We achieved our target 
of 30% women holding senior leadership 
roles, which are classified as 0 to 3 in our 
global career band structure, by 2020. We 
want to keep our focus and momentum and 
build more gender-balanced teams, so we 
have set ourselves a target to achieve 35% 
women in senior leadership roles by 2025. 

On the following page, we have set out 
further ways that we supported each of  
our stakeholders.

Fair outcomes
In 2020, we continued to promote and 
encourage good conduct through our people’s 
behaviours and the decisions we take during 
these unprecedented times. We define 
conduct as delivering fair outcomes for our 
customers and not disrupting the orderly and 
transparent operation of financial markets. 
This is central to our long-term success and 
ability to serve customers. We have clear 
policies, frameworks and governance in place 
to protect them. For further information on 
conduct, see page 187. Details on our conduct 
framework are available at www.hsbc.com/
who-we-are/esg-and-responsible-business/
our-conduct. 

We believe diversity makes us stronger, and 
we are dedicated to building a diverse and 

We published ethnicity data in the UK and  
US and recognise we need to take action. We 
aim to at least double the number of Black 
employees in senior leadership roles globally 
by 2025.

Our climate ambition
In 2020, we announced our climate ambition 
to become net zero in our operations and our 
supply chain by 2030, and align our financed 
emissions to the Paris Agreement goal of  
net zero by 2050. We know this is a journey 
and recognise that the current means of 
measuring progress globally need improving 
to track reductions better.

We have changed how we report on ESG 
issues this year by embedding the content 
previously provided in our stand-alone  
ESG Update within this Annual Report  
and Accounts. This can be found in the  
ESG review on page 42. 

Our new purpose and values

HSBC was born across different cultures and has 
a long history of connecting people, ideas and 
capital that make progress happen. That is why 
we have been working hard to sharpen our 
strategic focus, clarify our sense of purpose, and 
re-energise our culture. 

As we set out in this Annual Reports and 
Accounts 2020, we have revised our purpose, 
values and ambition. This has followed an extensive 
listening, talking and reflecting exercise involving 
tens of thousands of colleagues, customers and 
other stakeholders. It was the largest employee 
engagement programme in our history.

We plan to formally launch our purpose and 
values to HSBC colleagues and other 
stakeholders in March 2021.

16

HSBC Holdings plc Annual Report and Accounts 2020How we do business

Supporting our stakeholders through Covid-19 

The Covid-19 outbreak has created a great deal of uncertainty and disruption for the people, businesses and communities we serve around the 
world. It is affecting everyone in different ways, with markets at different stages of the crisis. We are tailoring our response to the different 
circumstances and situations in which our stakeholders find themselves.

Customers 
The Covid-19 outbreak has posed significant 
challenges for our customers. Our immediate 
priority is to do what we can to provide them 
with support and flexibility. 

Employees
The Covid-19 outbreak tested our 
colleagues in many ways and they 
adapted at pace in this fast-changing 
environment. 

This has included offering payment relief and 
restructuring mortgage payments, as well as 
extending relief loans or temporary credit limit 
increases for borrowers. At 31 December 
2020, we had active payment relief measures 
impacting 87,000 accounts and $5.5bn in 
balances as part of market-wide schemes and 
our own payment holidays programmes. 

On the first day of a government cash payout 
scheme in Hong Kong, we received one 
million registrations after we set up a simple 
digital and branch registration process. At the 
end of 2020, the lending support we provided 
to more than 237,000 wholesale customers 
globally was valued at $35.3bn, both through 
government schemes and our own initiatives.

We have taken steps to keep many of our 
branches open while protecting customers 
and our colleagues. However, with customers 
doing more of their banking online, we have 
also deployed new technology to help enable 
them to engage with us in new ways.

 For further details on how we are helping our 
customers, including during the Covid-19 
outbreak, see the Customers section of the  
ESG review on page 52.

In branches, we introduced social 
distancing measures, provided personal 
protective equipment, reduced operating 
hours and offered virtual appointments.  
For office workers, we made sure 
cybersecurity controls and software 
supported home working. 

For some of our colleagues, we changed 
their roles, asking them to undertake 
activities that were outside their normal 
activities. This helped to keep many of our 
colleagues working during these 
extraordinary times.

Our employee networks have held regular 
support calls for those experiencing 
mental health challenges and 92,000 
colleagues participated in our Covid-19 
well-being survey, with 86% telling us 
they were confident in the approach our 
leadership team was taking to managing 
the crisis. 

 For further details on how we are helping our 
colleagues, see the Employees section of the 
ESG review on page 62.

Investors
The Covid-19 outbreak and the impact of 
geopolitics weighed heavily on our share 
price throughout 2020. Central banks and 
governments also implemented several 
measures in their response to the 
pandemic. In line with all other large 
UK-based banks, and in response to a 
request from the UK’s PRA, we cancelled 
the fourth interim dividend for 2019. We 
also announced that, until the end of 
2020, we would make no quarterly or 
interim dividend payments or accruals in 
respect of ordinary shares. 

This was a difficult decision and we  
deeply regret the impact it has had on 
shareholders. We are therefore pleased to 
restart dividend payments at the earliest 
opportunity. The Board has announced an 
interim dividend of $0.15 for 2020. 
Adopting a prudent approach now will 
help ensure the dividend remains 
sustainable in the future.

We continued to engage virtually with 
investors. It was unfortunately not 
possible for shareholders to attend the 
2020 AGM in person due to social 
distancing measures. Shareholders were 
instead encouraged to vote by proxy and 
submit questions in advance with the 
answers published subsequently on our 
website. We also maintained an active 
programme of shareholder meetings and 
presentations.

Communities 
Our $25m Covid-19 donation fund supported 
relief and recovery efforts around the world, 
including immediate medical relief, access to 
food, and care for the most vulnerable people.

Regulators and governments
We have proactively engaged with 
regulators and governments globally 
regarding the policy changes issued  
in response to the Covid-19 outbreak  
to help our customers and to contribute  
to an economic recovery.

Suppliers
We made early payments to thousands  
of our suppliers during the year to support 
them through the pandemic.

17

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020 
Strategic report | How we do business

Our ESG metrics and targets 

We have established targets that guide how we 
do business, including how we operate and 
how we serve our customers. These targets are 
designed to help us to make our business – and 
those of our customers – more environmentally 
sustainable. They also help us to improve 
employee advocacy and diversity at senior 
levels as well as strengthen our market conduct. 

The 2020 annual incentive scorecards of the 
Group Chief Executive, Group Chief Financial 
Officer and Group Managing Directors had 
30% weightings for measures linked to 

outcomes that underpin the ESG metrics 
below. In addition, for executive Directors, a 
25% weighting is given to environment and 
sustainability measures in the 2020 long-term 
incentive (‘LTI’) scorecards, which have a 
three-year performance period ending on 31 
December 2023. The targets for this measure 
are linked to our climate ambition of achieving 
a reduction in our carbon footprint and 
facilitating financing to help our clients in their 
transition to net zero. For a summary of how 
all financial and non-financial metrics link to 

executive remuneration outcomes, see pages 
241 to 245 in the Director’s remuneration 
report.

For a number of the metrics outlined below, 
2020 was a transition year. For further details, 
including the high-level framework for how we 
are looking to measure the progress on our 
new climate ambition, see the ESG review on 
page 42. In 2021, we will introduce new 
metrics and targets aligned to our strategy.

Target

Performance in 2020

Environmental

Sustainable finance and investment

Provide and facilitate1

$100bn

by the end of 2025

Reduce operational CO2 emissions 2.0

Climate-related disclosures

tonnes used per full-time 
equivalent (‘FTE’) by the  
end of 20202

Continued implementation 
of the Financial Stability 
Board’s TCFD

$93.0bn 

cumulative progress since 20171 

1.76

tonnes used per FTE2

We published our

4th 

TCFD, which can be found on page 20  
and in the separate TCFD Update 2020 on  
www.hsbc.com/esg. We recognise there  
is still work to be done on how we report 
climate-related disclosures

Social

Customer satisfaction

Customer satisfaction 
improvements in

7

5

Employee advocacy

Employee gender diversity

Governance

8

scale markets3

69%

of employees recommending 
HSBC as a great place to work 
by the end of 20204

30%

women in senior leadership 
roles by the end of 20205

WPB markets 
sustained top-three 
rank and/or improved 
in customer 
satisfaction3

CMB markets 
sustained top-three 
rank and/or improved 
in customer 
satisfaction3 

71%

of employees would recommend HSBC  
as a great place to work4

30.3%

women in senior leadership roles5

Achieve sustained delivery of global 
conduct outcomes and effective 

financial crime risk management 98%

of staff to complete annual 
conduct training

93.2% 

of staff completed conduct training in 20206

1  The sustainable finance commitment and progress figure includes green, social and sustainability activities. In October 2020, we announced a new target ambition 

to provide between $750bn to $1tn of sustainable finance and investment by 2030. For further details, see page 44 in the ESG review.

2  This carbon figure covers scope 1, scope 2 and scope 3 (travel) emissions. For further details, see www.hsbc.com/our-approach/esg-information/esg-reporting-

and-policies. 

3  Our customer satisfaction performance is based on improving from our 2017 baseline. Our scale markets are Hong Kong, the UK, Mexico, the Pearl River Delta, 

Singapore, Malaysia, the UAE and Saudi Arabia. For further details on how we are transitioning to a new metric, see page 54 in the ESG review.

4  Our target was to improve employee advocacy by three points each year through to 2020. Our employee advocacy score in 2019 was 66%. Performance is based 

on our employee Snapshot results. From 2021, our targets will be based on our employee engagement index.

5  Senior leadership is classified as 0 to 3 in our global career band structure.
6 The launch of conduct global mandatory training in 2020 was delayed due to the Covid-19 outbreak and the completion date was rolled over into 2021.

18

HSBC Holdings plc Annual Report and Accounts 2020 
 
 
  
How we do business

Our climate risk and reporting strategy 

Every organisation has a role to play in limiting 
the impact of climate change. We believe our 
most significant contribution will be to align 
with the Paris Agreement goal of net zero 
global greenhouse emissions by 2050, 
through financing the transformation of 
businesses and infrastructure.

Central to our new climate ambition of 
becoming net zero in our financed emissions 
by 2050 or sooner is the intensification of our 
support for customers transitioning to a 
low-carbon economy. We aim to mobilise 
between $750bn and $1tn of sustainable 
finance and investment by 2030. 

The Financial Stability Board’s Task Force  
on Climate-related Financial Disclosures 
(‘TCFD’) recommendations set an important 
framework for understanding and analysing 
climate-related risks, and we are committed  
to regular, transparent reporting to help 
communicate and track our progress. We  
will advocate the same from our customers, 
suppliers and the industry. However, this is  
a journey and much work lies ahead as we 
develop our climate risk management and 
metrics capabilities, and build on our 2020 
climate scenario analysis. This summary, 
together with our separate TCFD Update 2020, 
forms our fourth TCFD disclosure.

We have made headway assessing climate’s 
impact on our customers and our operations 
– from the physical risk of increased severity 
or shifts in weather events, and the potential 
transition risk from changes to policy, 
technology and consumer behaviour. Working 
to embed climate into our risk management 
framework, we are initially focusing on five 
principal risk types most likely to be influenced 
by climate risk. The table below sets out 
examples of how these risk types might  
be impacted.

  For further details of our climate ambition,  
see pages 45 to 50 in the ESG review.  
Our TCFD Update 2020 can be found at  
www.hsbc.com/esg.

Climate risk impact

Principal risk type impacted Examples of potential impact

Extreme weather events or chronic 
changes in weather patterns impact our 
assets, operations or our customers’ 
assets

Retail credit risk 
Wholesale credit risk 
Resilience risk

 – The cost of flood damage to a customer’s home leaves 

them unable to repay their mortgage

 – Hurricane damage to a customer’s warehouse halts 

manufacturing and leaves them unable to repay their loan

 – One of our data centres is flooded and we are unable to 

service customers

Our business models or our customers’ 
business models fail to align to a 
low-carbon economy

Wholesale credit risk 
Reputational risk 

 – Failure to align to new regulations leads to a loss of business 

and customers are unable to repay their loans

 – Our actions lead to negative external perceptions of  

our organisation

We fail to effectively design and market 
climate-related products across all  
global businesses or respond to 
regulatory change

Reputational risk 
Regulatory compliance risk

 – We fail to respond to a regulatory change, leading to adverse 

stakeholder reaction

We have identified six sectors where we are 
most exposed to transition risk and our level of 
lending activity in those sectors. From our 
corporate questionnaire, we collate 
information about our customers’ climate 
transition strategies to assess their need and 
readiness to adapt, and to identify potential 
business opportunities. This supports our 
decision making and credit risk management 

processes. Across 2019 and 2020, we 
received responses from customers within  
the six high transition risk sectors, which 
represented 41% of our exposure – an 
increase of seven percentage points from 
2019. The table below shows our lending 
activity in the six sectors and insights from  
our questionnaire.

Within the power and utilities, and metals and 
mining sectors shown in the table below, our 
direct exposure to thermal coal is 0.2% of the 
wholesale loans and advances figures.

Wholesale loan exposure to transition risk sectors and customer questionnaire responses

Automotive

Building and 
construction Chemicals

Metals and 
mining

Oil and  
gas

Power and 
utilities

Total

Wholesale loan exposure as % of total 
wholesale loans and advances to customers 
and banks1,2,3

Proportion of sector for which questionnaires 
were completed4

Proportion of questionnaire responses that 
reported having a board policy or a 
management plan4

Sector weight as proportion of high 
transition risk sector4

≤3.1%

≤4.0%

≤3.4%

≤2.5%

≤3.4%

≤3.2%

≤19.6%

42%

68%

44%

81%

32%

77%

45%

42%

40%

41%

54%

84%

93%

77%

16%

20%

18%

13%

17%

16%

100%

1  Amounts shown in the table include green and other sustainable finance loans, which support the transition to the low-carbon economy. The methodology for 

quantifying our exposure to high transition risk sectors and the transition risk metrics will evolve over time as more data becomes available and is incorporated in 
our risk management systems and processes. 

2  Counterparties are allocated to the high transition risk sectors via a two-step approach. Firstly, where the main business of a group of connected counterparties is in a 
high transition risk sector, all lending to the group is included irrespective of the sector of each individual obligor within the group. Secondly, where the main business 
of a group of connected counterparties is not in a high transition risk sector, only lending to individual obligors in the high transition risk sectors is included.

3 Total wholesale loans and advances to customers and banks amount to $673bn (2019: $680bn).
4 All percentages are weighted by exposure.

19

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report | How we do business

Task Force on Climate-related Financial Disclosures (‘TCFD’) 

The table below sets out the 11 TCFD recommendations and summarises the progress we have made in the past 12 months.

TCFD recommendation

Our progress in 2020

Governance

Describe the Board’s oversight of 
climate-related risks and 
opportunities 

Describe management’s role in 
assessing and managing climate-
related risks and opportunities 

Strategy

Describe the climate-related risks and 
opportunities the organisation has 
identified over the short, medium and 
long term 

Describe the impact of climate  
risks and opportunities on the 
organisation’s business, strategy 
and planning 

Describe the resilience of the 
organisation’s strategy taking into 
consideration different climate-
related scenarios, including a 2ºC or 
lower scenario

Risk management

Describe the organisation’s processes 
for identifying and assessing 
climate-related risks

 – The Board is responsible for our climate ambition and strategy and receives climate-focused updates

twice a year.

 – The Group Risk Committee provides oversight of climate risks and opportunities through enterprise

risk reports, deep dives and updates.

 – The Group Executive Committee manages our climate ambition with management responsibilities

integrated into the relevant business and functional areas.

For further details of our governance approach, see page 5 of our TCFD Update 2020.

 – We have identified our key climate risks over the short, medium and long term and identified the
principal risk types as retail credit risk, wholesale credit risk, resilience risk, reputational risk and
regulatory compliance risk1.

 For further details of our climate risks and risk types, see pages 3 and 22 of our TCFD Update 2020.

 – We are prioritising climate-related financing and investment, and in October announced our new
climate ambition to become a net zero bank, support customers to thrive in the transition to a
low-carbon economy, and to unlock next generation climate solutions.

 For further details of our climate ambition, see pages 45 to 50 in the ESG review. 

 – We have carried out various exercises to analyse our resilience, including:

 – using the Paris Agreement Capital Transition Assessment (‘PACTA’) tool to assess our customers’
impact on climate and help develop clear pathways to net zero financed emissions. We have run a
pilot on our automotive loan book; and

 – running a stress testing pilot to assess the impact of different climate scenarios on our customers

and our own infrastructure.

For further details of our scenario analysis and ‘PACTA’ pilots, see pages 13 to 21 of our TCFD Update 2020.

 – In response to identifying our key climate risks, we have reviewed our risk appetite and defined our

approach to managing these risks.

 – We are reviewing our policies for managing a number of principal risk types, initially resilience risk,

sustainability risk and regulatory compliance risk.

 For further details of our climate risk management approach, see page 48 in the ESG review and pages 22 to 24 
of our TCFD Update 2020.

Describe the organisation’s processes 
for managing climate-related risks

 – We manage our asset management customers’ climate risk in line with our fiduciary responsibilities

to protect and grow the assets.

Describe how processes for 
identifying, assessing and managing 
climate-related risks are integrated 
into the organisation’s overall risk 
management

Metrics and targets

Disclose the metrics used by the 
organisation to assess climate-related 
risk and opportunities in line with its 
strategy and risk management process

Describe the targets used by the 
organisation to manage climate-
related risks and opportunities and 
performance against targets

Disclose scope 1, scope 2 and, if 
appropriate, scope 3 greenhouse gas 
emissions and the related risks

 Read more on our asset management approach to climate risk in our policies and procedures on 
www.assetmanagement.hsbc.co.uk/en/institutional-investor/about-us/responsible-investing/policies.

 – The Trustee of our UK Pension Scheme manages climate risk in line with its fiduciary responsibilities

towards members2.

 – We have established a dedicated climate risk programme to accelerate the integration of climate risk
into our Group-wide risk management framework, which includes identification and assessment,
management, and aggregation and reporting.

 – We use several metrics to measure and track our progress against key targets, and we will be refining

our approach to financed emissions (scope 3), including carbon intensity, for specific portfolios.
 – We set a new sustainable finance and investment target of $750bn to $1tn by 2030, after reaching

$93.0bn of our $100bn by 2025 target. The $40.6bn achieved in 2020 counts towards both the existing
2025 target and the new target.

 – We continue to disclose our wholesale loan exposure to the six high transition risk sectors, and use

our corporate customer transition risk questionnaire to help inform our risk management.

 – We include an environment measure in the scorecards of our executive Directors and Group Managing 
Directors. The long-term incentive scorecards of our executive Directors (three-year performance period 
to the end of December 2023) have a 25% weighting for targets aligned to our climate ambitions. 
 – We continue to disclose business travel, energy-related emissions and renewable energy use, and

aim to disclose further details on our own scope 3 emissions in future reporting.

For further details of our climate metrics and targets, see pages 45 to 50 in the ESG review.

1 Short term: less than one year; medium term: period to 2030; long term: period to 2050.
2  For further details of our UK Pension Scheme’s latest TCFD statement, see https://futurefocus.staff.hsbc.co.uk/-/media/project/futurefocus/information-centre/

pensioner/other-information/2020-tcfd-statement.pdf

20

HSBC Holdings plc Annual Report and Accounts 2020How we do business

Responsible business culture

We have the responsibility to protect our 
customers, our communities and the integrity 
of the financial system. In this section, we 
outline our requirements under the Non-
Financial Reporting Directive.

Environmental matters
In October 2020, we announced our ambition 
to achieve net zero in our own operations and 
our supply chain by 2030 or sooner. We also 
plan to align our financed emissions –  
the carbon emissions of our portfolio of 
customers – to the Paris Agreement goal of 
net zero by 2050 or sooner. For further details 
of our climate strategy and carbon emission 
metrics, see the ESG review on page 44.

Employee matters 
We are opening up a world of opportunity for 
our colleagues through building an inclusive 
organisation that prioritises well-being and 
prepares our colleagues for the future of work. 

We expect colleagues to treat each other  
with dignity and respect and take action 
where we find behaviour that falls short of our 
expectations. We monitor how we perform on 
metrics that we value and benchmark against 
our peers. We have a range of tools and 
resources to help colleagues to take 
ownership of their development journey. 

We believe in the importance of listening  
to our people and seek innovative ways to 
encourage employees to speak up. At times, 
individuals may not feel comfortable speaking 
up through the usual channels. Our global 
whistleblowing channel, HSBC Confidential, is 
open to colleagues, past and present, to raise 
concerns either confidentially or anonymously. 

In 2018, we committed to reach 30% women 
in senior leadership roles, which are classified 
as 0 to 3 in our global career band structure, 
by 2020. At the end of 2020, we achieved 
30.3% and have now set ourselves a target to 
achieve 35% by 2025. In July 2020, we set out 
global race commitments, which included a 
goal to at least double the number of Black 

employees in senior roles over the next  
five years. We are focusing on the quality  
and reporting of ethnicity data to be more 
transparent about our representation and 
accountable for the effectiveness of our 
actions. In 2020, we began a three-year 
transformation programme. We work hard  
to ensure colleagues impacted by change  
are supported. 

The table below outlines high-level 
diversity metrics. 

All employees

Male

Female

Senior leadership1

Male

Female

Directors

Male

Female

48%

52%

70%

30%

64%

36%

1  Senior leadership is classified as 0 to 3 in our 

global career band structure. 

  For further details on how we look after  
our people, including our diversity targets, 
transformation employee metrics and how we 
encourage our employees to speak up, see the 
Employees section of the ESG review on page 62.

contribute to disaster relief efforts based on 
need. In 2020, we contributed $112.7m to 
charitable programmes and our employees 
volunteered 82,000 hours to community 
activities during the working day.

Human rights 
Our commitment to respecting human rights, 
principally as they apply to our employees, our 
suppliers and through our financial services 
lending, is set out in our Statement on Human 
Rights. This statement, along with our 
statements under the UK’s Modern Slavery 
Act (‘MSA’) is available on www.hsbc.com/
our-approach/measuring-our-impact.

Anti-corruption and anti-bribery
HSBC requires compliance with all applicable 
anti-bribery and corruption laws in all markets 
and jurisdictions in which we operate. These 
laws include the UK Bribery Act, the US 
Foreign Corrupt Practices Act, and the Hong 
Kong Prevention of Bribery Ordinance, as well 
as other similar laws and regulations in the 
countries where we operate. We have a global 
anti-bribery and corruption policy, which gives 
practical effect to these laws and regulations, 
but also requires compliance with the spirit of 
laws and regulations to demonstrate HSBC’s 
commitment to ethical behaviours  
and conduct.  

Social matters
We have a responsibility to invest in the 
long-term prosperity of the communities 
where we operate. We recognise that 
technology is developing at a rapid pace and 
that a range of new and different skills are 
now needed to succeed in the workplace. For 
this reason, much of our focus is on 
programmes that develop employability and 
financial capability. We also back initiatives 
that support responsible business, and 

Non-financial information statement
This section primarily covers our non-
financial information as required by the 
regulations. Other related information can 
be found as follows:

  For further details on our key performance 
indicators, see page 1. 
  For further details on our business model, 
see page 4.
  For further details on our principal risks and 
how they are managed, see pages 37 to 40.

Investing in the skills of the future

In 2020, we launched the global HSBC Future Skills 
Innovation Challenge in partnership with Ashoka, a global 
network for social entrepreneurs, to support innovations 
that help people become more employable and financially 
capable. We received more than 200 submissions to the 
challenge, with 12 winners selected. Each winner received  
a prize of up to $25,000 and additional support and 
mentoring.

All winning entries provided solutions that address local 
problems, such as digital platform Bamba, which helps 
domestic workers gain access to the financial system  
in Mexico. 

Thanks to our support to the challenge, we won The 
Banker’s global award for Banking in the Community in 
December 2020. The award recognised the most innovative 
initiatives launched by financial institutions that enrich and 
improve the societies in which they operate.

21

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report

Board decision making and 
engagement with stakeholders

Our Board is committed to effective engagement and  
seeks to understand the interests of and impacts on  
relevant stakeholders when making decisions.

Section 172 (1) statement

This section, from pages 22 to 24, forms our 
section 172 statement. It describes how the 
Directors have performed their duty to 

promote the success of the company, 
including how they have considered and 
engaged with stakeholders and, in particular, 

how they have taken account of the matters 
set out in section 172(1)(a) to (f) of the 
Companies Act 2006. 

Stakeholder engagement and Covid-19

There were no changes to the Board’s 
identified key stakeholders during the year, 
namely our customers, employees, investors, 
communities, suppliers, and regulators and 
governments. In overseeing the business, the 
Board sought to understand – and have 
appropriate regard to – the interests and 
priorities of these stakeholders, including in 
relation to material decisions that were taken 
during the course of the year. 

Events during the year called for careful 
consideration of the needs and interests of the 
company’s various stakeholders. A specific 
area of focus arising from the Covid-19 
pandemic included our colleagues’ mental and 
physical health, which the Board monitored by 
way of frequent Snapshot and pulse surveys, 
and discussions with senior management on 
the well-being of their teams. Another area of 
Board focus, supported by guidance from 
subject matter experts, was the evolving views 
and requirements of our customers, investors, 
employees, communities and suppliers. The 
effects of the Covid-19 outbreak on these 

stakeholders contributed to the development 
of our Group strategy and purpose and values. 
For further details of how the Board engaged 
with stakeholders in adapting our Group 
strategy and refreshing our purpose and 
values, see ‘Board engagement with 
shareholders’ on page 204.

The unique nature of the Covid-19 outbreak 
also brought logistical challenges for 
interacting with stakeholders. For instance, to 
protect and keep our shareholders and people 
safe and in line with the advice from the UK 
Government, it was not possible for 
shareholders to attend our AGM. 
Consequently, shareholders did not have the 
opportunity to ask questions of the Board in 
person, although alternative arrangements 
were made to publish responses to written 
questions on our website. Similarly, it was not 
possible to hold the Informal Shareholders’ 
Meeting in Hong Kong nor for the Board to 
undertake site visits due to travel restrictions. 
In addition, the financial impact of the 
pandemic brought into sharp focus the need to 

consider carefully the impact of decisions on a 
range of stakeholders. For example, the 
decision to cancel the fourth interim dividend 
for 2019 and suspend dividends for 2020 
required consideration of the request from the 
Prudential Regulation Authority to cancel the 
dividend, the impact the decision would have 
on our shareholders and the important role 
that HSBC has in helping its customers 
manage through the crisis. Further details on 
the dividend cancellation are provided in 
‘Financial decisions’ on page 209 and 
‘Dividends’ on page 256. 

Despite logistical challenges, the Board 
continued to engage directly with many 
stakeholders, including employees, regulators 
and shareholders, and was kept informed 
indirectly about relevant stakeholder matters 
through management reports. Some of the 
ways in which the Board engaged with – or 
received views – from its key stakeholders 
during the year are provided below. Further 
details on our stakeholders are provided in 
‘How we do business’ on page 17.

Customers

Employees

Investors

We seek to understand investor needs through 
ongoing dialogue. Examples of the Board 
engaging with investors in 2020 included: 

 – virtual and Covid-19 safe regular meetings with 
investors to understand evolving views, trends 
and sentiment;

 – reports from institutional investor meetings 

attended by Directors; and

 – regular updates from Investor Relations, 

including a weekly update on market activity  
and sentiment.

Our business is centred around our customers and 
clients. The greater the understanding we have of 
their needs and the challenges they face, the better 
we can support them to achieve their financial 
aims. Examples of the Board engaging with 
customers in 2020 included:

We want our organisation to continue to be a positive 
place to work and build careers. The success of the 
Group’s strategy is dependent upon having motivated 
people with the expertise and skills required to help 
deliver our strategy. Examples of the Board’s 
engagement with our employees in 2020 included:

 – monthly Group Chief Executive Board reports, 

 – ‘Snapshot’ survey updates on employee 

which included updates on key customer 
sentiment and activities;

sentiment and well-being, which were published 
twice during the year;

 – reports from the Group Chief Executive on 

 – additional employee opinion surveys to assess 

meetings he held with customers across the world, 
including pre-Covid-19 interactions and Covid-19 
safe physical meetings in the UK and Asia;

 – regional and sector-based customer insights 

developed through customer interactions with 
senior management and relationship managers, 
which were incorporated into relevant Board 
reports; and 

 – customer survey feedback, including the  
results of our 2020 Navigator survey and  
net promoter scores. 

employee physical and mental well-being;

 – status surveys to assess how employees might 

be affected by the Covid-19 outbreak so that they 
can be supported appropriately;

 – virtual and Covid-19 safe attendance by our 
Board members at workforce engagement 
events focused on our global businesses, 
functions and employee resource groups; and

 – reports from members of senior management on 
the welfare of their teams and areas of expertise 
and skills that required development to deliver 
the strategy.

22

HSBC Holdings plc Annual Report and Accounts 2020   
   
   
Board decision making and engagement with stakeholders

Regulators and governments

Communities

Suppliers

Constructive dialogue and relations with the 
relevant authorities in the markets we operate are 
critical to support the effective functioning of 
economies globally. Examples of the Board’s 
engagement with regulators and governments in 
2020 included:

We play an important role in supporting the 
communities in which we operate through 
customers we serve and corporate social 
responsibility activities. We are, in turn, dependent 
on those communities. Examples of the Board’s 
engagement with communities in 2020 included: 

 – executive and non-executive Directors ‘continuous 

 – regular climate and ESG-related updates to  

assessment’ meetings with the PRA and other 
individual regulatory meetings;

 – the annual presentation by the PRA to discuss 

the outcome and progress of its Periodic 
Summary Meeting Letter;

 – the presentation by the UK Financial Conduct 

Authority (‘FCA’) of its Firm Evaluation;

 – reports from meetings with the supervisory 

college of regulators; and

 – regular dialogue with governments across the 

world, including representation on government-
led forums. 

the Board; 

 – economist updates to the Board on the varying 

impact of the Covid-19 outbreak on the markets in 
which the Group operates, helping to guide the 
focus of the strategy and connect with stakeholder 
groups; 

 – immunologist updates to the Board on the varying 
impact of the Covid-19 outbreak in the geographies 
in which the Group operates, providing insight into 
what support may be required by governments 
globally in support of the recovery and from HSBC 
to our customers and employees; and

 – a Director-led roundtable in Latin America to  

focus on geopolitical and social matters influencing 
that region.

Our suppliers provide the Group with vital 
resources, expertise and services to help us 
operate our business effectively. We work with 
our suppliers to ensure mutually beneficial 
relationships on a global and local level. In some 
cases our suppliers will also be our customers. 
Examples of the Board’s engagement with 
suppliers in 2020 included: 

 – reports from the Group Chief Operating Officer, 
which included updates on third-party suppliers 
and operational resilience; and

 – Board level engagement at external events  

such as the World Economic Forum with the 
opportunity to engage with suppliers across  
the globe.

Principal decisions

Examples of principal decisions made by the Board during 2020, where the Directors had regard to the relevant matters set out in section 172(1)
(a)-(f) of the Companies Act 2006 when discharging their duties, are set out below:

Appointment of Group Chief Executive 

In early 2020, Noel Quinn was appointed 
as Group Chief Executive to lead the 
Group through the next phase of its 
strategy and transformation.

The appointment followed a thorough and 
robust search process, which considered the 
best internal and external talent with the aim 
of identifying the most suitable and able 
candidate to lead HSBC through its next 
stage. For further details of the appointment 
process, see the Nomination & Corporate 
Governance Report on page 213.

In taking this decision, the Board considered 
among other matters the ability of prospective 
candidates to develop trusted, constructive 
and strong relations with each of the Group’s 
customers, colleagues, regulators and 
members of the investor community. For 
instance, the Board benefited from 
assessment criteria that evaluated the ability 
of each candidate to develop and maintain 
strong relations with the global workforce 
while implementing strategic change.

Given the market sensitive implications of the 
appointment and the requirement for absolute 
discretion and confidentiality in relation to 
prospective candidates, it would not have 
been appropriate to engage with all 
stakeholders while the process was ongoing. 
The Group’s principal regulators were kept 

appraised of the progress with the search. 
Towards the end of the process, the 
appointment was approved by the Group’s UK 
regulators, an important step given that the 
role of Group Chief Executive is a regulated 
position in the UK. 

This detailed engagement, together with  
the various interviews and assessments 
conducted during the process, helped the 
Board determine that the appointment of  
Noel was in the best interests of the Group  
as a whole.

Dividend cancellation

On 31 March 2020, HSBC announced 
that, in response to a written request 
from the Bank of England through the 
PRA, the Board had cancelled the fourth 
interim dividend for 2019. The Board also 
announced that no quarterly or interim 
dividend payments, accruals or share 
buy-backs would be paid in respect of 
ordinary shares until the end of 2020.

Cancelling the dividend was an extremely 
difficult decision for the Board. In reaching its 
decision, the Board took into account a 
number of considerations including the 

request from the PRA, the then current and 
potential material impact on the global 
economy as a result of the Covid-19 outbreak 
and the important role that HSBC has in 
helping its customers manage through the 
crisis and to have the resources to invest 
when recovery occurs.

The Board recognised that while HSBC had a 
strong capital, funding and liquidity position, 
there were significant uncertainties in 
assessing the length and impact of the 
Covid-19 outbreak. The Board also noted 
HSBC’s commitment to supporting 
customers in the economies in which HSBC 
serves, particularly Hong Kong and the UK.

These considerations were carefully balanced 
against the impact the decision would have 
on HSBC’s shareholders, including retail 

shareholders in Hong Kong, the UK  
and elsewhere.

At the time of the announcement in March, 
the Board stated that it would review the 
ordinary share dividend policy and payments 
in respect of 2020 once the full impact of the 
outbreak was better understood and 
economic forecasts for global growth in 
future years were clearer.

We are therefore pleased to restart dividend 
payments at the earliest opportunity and on  
23 February 2021 the Board announced an 
interim dividend for 2020 of $0.15 per ordinary 
share. The Board has adopted a policy 
designed to provide sustainable dividends 
going forward. For more information on 
dividend decisions for 2021 see ‘Highlights’ 
on page 2. 

23

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020   
   
   
Strategic report | Board decision making and engagement with stakeholders

Principal decisions continued

Adapted Group strategy 

When Covid-19 was declared a global 
pandemic, the Board determined that the 
assumptions underpinning its February 
2020 business review were to be 
revisited.

As the extent and implications of the Covid-19 
outbreak began to emerge, the Board 
recognised the need to consider the impact on 
the strategy of a prolonged low interest-rate 
environment, as well as geopolitical, 
technological and environmental challenges. 
These fundamental shifts profoundly impacted 
our organisation as well as the wider financial 
services sector. The Board responded by 
aligning our strategy accordingly.

Customer insights were gathered through 
comprehensive engagement with over 4,000 
customers, led by Global Banking and 
Markets, which helped inform the Board of the 
likely wider medium- to long-term implications 
and consumer and societal shifts arising from 
the pandemic. These insights indicated that 
the Covid-19 outbreak had accelerated 
customers’ behaviours and preferences 
towards an increasingly digital, data-driven 
and real-time service requirement, with 
service standards set by sectors outside of 
financial services. Providing a superior 
digitalised proposition supports our customers 
to help achieve their full potential and create a 
culture of innovation and accountability 
among our colleagues.

The Board actively engaged with senior 
management to consider the likely 
consequences of the strategic actions 
proposed, while providing constructive 
challenge and support in the development of 

its plans. The insights gained reinforced the 
need to shift capital away from 
underperforming businesses while investing 
for growth and reducing our cost base. The 
Board considered the views of the Group’s 
brokers in challenging the current strategy 
from an investment perspective. In addition, 
the Board recognised the need for continued 
and constructive engagement with our 
regulators to address their concerns and 
priorities as the Group transforms its business.

Employees were identified as a key 
stakeholder group given that they needed to 
understand and implement the Group 
strategy. The Board received updates on 
senior talent and areas where skills need to be 
developed further.

For further details of the Group’s adapted 
strategy, see ‘Strategy and business 
performance’ on page 209.

Purpose and values

The strategic review prompted the Board 
to revise the Group’s purpose and values.

To support the Board in its decision making, a 
working group was established to develop 
proposals, including three non-executive 
Directors who supported and challenged 
management’s proposals. 

An extensive programme of stakeholder 
engagement across our main operating 
markets was undertaken during the 
development of the revised purpose and 
values involving interviews, focus groups and 

Climate ambition 

During the year, the Board reviewed  
and approved a new climate ambition  
for the Group.

In reviewing and approving a new climate 
ambition, the Board acknowledged that ESG 
issues have developed significantly over 
recent years, and such issues are now 
recognised by stakeholders as key elements 
and risks for businesses to manage.

In May 2020, the Board conducted a detailed 
review of stakeholder expectations and was 
advised of key stakeholders impacted by the 
proposed climate strategy and the leading role 
HSBC was expected to take. This included a 

large-scale surveys. This engagement sought 
to understand what was important to and 
resonated with our employees and customers 
(including next generation customers), while 
identifying societal trends. The purpose and 
value statements were tested for longevity 
and were required to support a culture that 
could help deliver the Group’s strategy. 

The insights gained from this stakeholder 
engagement were used to shape, refine and 
enhance the proposals presented to the Board 
for approval. In terms of our values, there was 
a consistent message that we should build on 
what was already working and avoid passive 
language. Clear direction was provided that 
the values should be simple, memorable, 
translate and be easily understood in many 

countries, and represent a clear guide to 
action. This feedback encouraged the Board 
to adopt a fourth value focused on delivery 
and decision making. As the stakeholder 
engagement neared completion, an additional 
7,000 colleagues were consulted in the final 
assessment of the proposed values. The 
primary view indicated that the revised values 
represented a ‘positive evolution’ for HSBC. 

The Board selected the purpose and values 
that it considered best aligned to the Group’s 
revised strategy, would drive a culture to 
deliver that strategy, and resonated most with 
stakeholder sentiment.

Our new purpose and values can be found on 
page 16. 

comprehensive market update on current 
positions taken by non-government 
organisations, investors, competitors, 
regulators and increased societal awareness. 

As part of the review, HSBC’s climate advisory 
panel – consisting of representatives from 
non-government organisations, clients and 
academics – was consulted in the 
development and drafting of the new climate 
ambition. Wider stakeholder engagement was 
undertaken to help inform the Group’s position 
from a customer perspective including the 
HSBC Sustainable Financing and Investment 
Survey 2020 and the HSBC Navigator survey. 

In the course of the Board’s discussions, it 
considered stakeholder feedback in the 
context of our business mix and the need to 
work towards an orderly transition, given 
current exposures to fossil fuels assets. The 

Board acknowledged the opportunity to help 
support our customers with their transition to 
lower carbon emissions and to manage other 
expectations and matters impacting our 
shareholders, employees and local 
communities.

In addition, the Board noted that HSBC  
had been recognised as a leading bank  
for sustainable finance and acknowledged 
increased competitive activity. As a result, it 
was conscious of the need to maintain the 
Group’s leadership in this area.

In making its decision, the Board recognised 
investors’ expectations for HSBC to continue 
to make progress on climate change, as it 
provides sustainable finance and investment 
and gradually reduces exposure to high-
carbon assets on a timeline aligned with the 
Paris Agreement.

24

HSBC Holdings plc Annual Report and Accounts 2020 
Remuneration

Remuneration

Our remuneration policy supports the achievement of  
our strategic objectives by aligning reward with our  
long-term sustainable performance.

Our remuneration principles

Variable pay

Our performance and pay strategy aims to reward competitively the 
achievement of long-term sustainable performance by attracting, 
motivating and retaining the very best people, regardless of gender, 
ethnicity, age, disability or any other factor unrelated to performance  
or experience. 

 For further details of our principles and what we did during 2020 to ensure 
remuneration outcomes were consistent with those principles, see page 233. 

Our variable pay pool was $2,659m, a 20.4% decrease from 2019. 

 For details of how the Group Remuneration Committee sets the pool,  
see page 229.

($m)

2020

2019

2,659

3,341

Remuneration for our executive Directors

Our remuneration policy for executive Directors was approved at our 
AGM in 2019 and is intended to apply for three performance years until 
the AGM in 2022. Details of the policy can be found in the Directors’ 
remuneration report on page 235.

Variable pay for our executive Directors is driven by scorecard 
achievement. Targets in the scorecard are set according to our key 
performance indicators to ensure linkages between our strategy and 
remuneration policies and outcomes.

2019
Executive Directors’ annual incentive scorecard outcome
(% of maximum opportunity) 

Group Chief Executive

Group Chief Financial Officer

64.50%

63.75%

The table below shows the amount our executive Directors earned in 2020. For details of Directors’ pay and performance for 2020, see the 
Directors’ remuneration report on page 229.

Single figure of remuneration

(£000)

Base 
salary2

Fixed pay 
allowance

Cash in 
lieu of 
pension

Taxable 
benefits3

Noel Quinn1 2020

1,266

1,700

Ewen 
Stevenson

2019

2020

2019

503

738

719

695

950

950

127

50

74

107

186

41

12

16

Non-taxable 

benefits3 Total fixed

Annual 
incentive4

Notional 
returns5

Replacement 
award6

Total 
variable

Total fixed 
and  

variable

59

23

32

28

3,338

1,312

1,806

1,820

799

665

450

1,082

17

—

—

—

—

—

816

665

1,431

1,881

1,974

3,056

4,154

1,977

3,687

4,876

1  Noel Quinn succeeded John Flint as interim Group Chief Executive with effect from 5 August 2019 and was appointed permanently into the role on 17 March 2020. 

The remuneration included in the single figure table above for 2019 is in respect of his services provided as an executive Director for that year.

2  As outlined on page 230, the executive Directors each donated a quarter of their base salary for six months in 2020. The base salary shown in the single figure of 

remuneration is the gross salary before charitable donations.

3  Taxable benefits include the provision of medical insurance, accommodation, car and tax return assistance (including any associated tax due, where applicable). 

Non-taxable benefits include the provision of life assurance and other insurance cover. 

4  Under the policy approved by shareholders, executive Directors can receive 50% of their annual incentive award in cash and the remaining 50% in immediately 
vested shares subject to a one-year retention period. As the executive Directors each decided not to take an annual cash bonus, the 2020 annual incentive is the 
amount after this waiver and will be delivered in immediately vested shares subject to a one-year retention period. The total annual incentives waived by the Group 
Chief Executive and Group Chief Financial Officer were £799,000 and £450,000, respectively.

5  ‘Notional returns’ refers to the notional return on deferred cash for awards made in prior years. The deferred cash portion of the annual incentive granted in prior 

years includes a right to receive notional returns for the period between the grant date and vesting date, which is determined by reference to a rate of return 
specified at the time of grant. A payment of notional return is made annually and the amount is disclosed on a paid basis in the year in which the payment is made. 
6  As set out in the 2018 Directors’ remuneration report, in 2019 Ewen Stevenson was granted replacement awards to replace unvested awards, which were forfeited 
as a result of him joining HSBC. The awards, in general, match the performance, vesting and retention periods attached to the awards forfeited, and will be subject 
to any performance adjustments that would otherwise have been applied. The values included in the table for 2019 relate to Ewen Stevenson’s 2015 and 2016 LTI 
awards granted by The Royal Bank of Scotland Group plc (‘RBS’) for performance years 2014 and 2015, respectively, and replaced with HSBC shares when Ewen 
Stevenson joined HSBC. These awards are not subject to further performance conditions and commenced vesting in March 2019. The total value is an aggregate of 
£1,121,308 for the 2015 LTI and £852,652 for the 2016 LTI. The 2016 LTI award value has been determined by applying the performance assessment outcome of 
27.5% as disclosed in RBS’s Annual Report and Accounts 2018 (page 70) to the maximum number of shares subject to performance conditions. Values in the table 
for 2020 relate to his 2017 LTI award granted by RBS for performance year 2016, which was determined by applying the performance assessment outcome of 
56.25% as disclosed in RBS’s Annual Report and Accounts 2019 (page 91) to the maximum number of shares subject to performance conditions. This resulted in a 
payout equivalent to 78.09% of the RBS award shares that were forfeited and replaced with HSBC shares. A total of 313,608 shares were granted in respect of his 
2017 LTI replacement award at a share price of £6.643. The HSBC share price was £5.845 when the awards ceased to be subject to performance conditions, with 
no value attributable to share price appreciation.

25

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report

Financial overview

In assessing the Group’s financial performance, management 
uses a range of financial measures that focus on the delivery 
of sustainable returns for our shareholders and maintaining our 
financial strength.

Executive summary

Financial performance in 2020 was impacted 
by the Covid-19 outbreak, together with the 
resultant reduction in global interest rates. 
Reported profit before tax of $8.8bn 
decreased by 34%, while adjusted profit 
before tax of $12.1bn decreased by 45%. The 
fall in reported profit was due to an increase in 
our expected credit losses and other credit 
impairment charges (‘ECL’) and a reduction in 
reported revenue. These factors were partly 
mitigated by lower reported operating 
expenses. Our return on average tangible 
equity (‘RoTE’) for 2020 was 3.1%. Given  
the significant changes in our operating 
environment during 2020, we no longer expect 
to reach our RoTE target of between 10%  
and 12% in 2022, as originally planned. 

Group financial targets

During 2020, our operations in Asia continued 
to perform resiliently, generating a reported 
profit before tax of $12.8bn, representing 
146% of Group reported profits. In addition, 
our Global Markets business delivered revenue 
growth of 27% compared with 2019.

Reported results in 2020 included a $1.3bn 
impairment of capitalised software, primarily 
relating to businesses within HSBC Bank plc, 
our non-ring-fenced bank in Europe, reflecting 
underperformance and a deterioration in the 
future forecasts, substantially relating to prior 
periods. During 2020, we also incurred 
restructuring and other related costs of $2.1bn, 
in part related to our strategic actions taken to 
address underperformance in our US business 
and our non-ring-fenced bank in Europe and 

the UK. Reported results in 2019 included a 
$7.3bn impairment of goodwill, primarily in 
GBM and CMB, and customer redress 
programme costs of $1.3bn.

We have made good progress in 
implementing the transformation programme 
we announced in February 2020, despite the 
significant headwinds posed by the Covid-19 
outbreak. However, we recognise the 
fundamental changes in our operating 
environment, including the prospect of 
prolonged low interest rates, the significant 
increase in digital engagement from 
customers and the enhanced focus on the 
environment, and have aligned our strategy 
accordingly. The implications for our Group 
financial targets are set out below.

Return on average tangible equity (%)

Adjusted operating expenses

Gross RWA reductions

3.1%

(2019: 8.4%)

In our business update set out in February 
2020, the Group targeted a reported RoTE  
in the range of 10% to 12% in 2022.

Our RoTE for 2020 was 3.1%, a reduction  
of 530 basis points from 2019, primarily 
reflecting higher ECL and a reduction in 
revenue. Given the significant changes in our 
operating environment during 2020, we no 
longer expect to reach our RoTE target of 
between 10% and 12% in 2022, as originally 
planned.

We have adapted our strategy with an 
intention to increase investment in our areas of 
strength to generate mid-single-digit revenue 
growth, mainly from fees and volumes. We 
intend to drive further reductions in our cost 
base by 2022 and aim for broadly stable  
costs thereafter. As we progress with our 
transformation of our underperforming 
businesses, we also expect to optimise the 
capital allocation across the Group. 
Collectively through these actions, together 
with a normalisation in our ECL charge closer 
to levels seen prior to the Covid-19 pandemic, 
we will now target a RoTE of greater than or 
equal to 10% in the medium term.

26

$31.5bn

$61.1bn

In February 2020, we announced a plan  
to substantially reduce the cost base and 
accelerate the pace of change, with the  
aim of becoming leaner, simpler and more 
competitive. In 2020, our adjusted operating 
expenses were $31.5bn, a reduction of 3% 
compared with 2019.

Our adjusted cost target for 2022 will remain 
$31bn or less. This reflects a further reduction 
in our cost base, which has been broadly offset 
by the adverse impact of foreign currency 
translation due to the weakening US dollar 
towards the end of 2020.

We now plan to deliver $5bn to $5.5bn of cost 
saves for 2020 to 2022, while spending around 
$7bn in costs to achieve.

In the medium to long term, we aim to drive 
positive operating leverage by growing revenue 
while maintaining a broadly stable cost base.

To improve the return profile of the Group, we 
have targeted a gross RWA reduction of more 
than $100bn by 2022, mainly in low-returning 
parts of the Group.

In 2020, we achieved gross RWA reductions of 
$51.5bn, taking our cumulative RWA 
reductions to $61.1bn. We expect to achieve a 
further $30bn of gross RWA reductions in 
2021. In addition, we continue to expect to 
incur total asset disposal costs of around 
$1.2bn during the period 2020 to 2022.

Capital and dividend policy
We intend to maintain a CET1 ratio in excess 
of 14%, managing in the range of 14% to 
14.5% in the medium term. We will seek to 
manage this range down in the longer term. 

The Board has adopted a policy designed to 
provide sustainable dividends going forward. 
We intend to transition towards a target 
payout ratio of between 40% and 55% of 
reported earnings per ordinary share (‘EPS’) 
from 2022 onwards, with the flexibility to 
adjust EPS for non-cash significant items, 
such as goodwill or intangibles impairments. 
The Group has decided to discontinue the 
scrip dividend option as it is dilutive, including 
to dividend per share progression over time.

HSBC Holdings plc Annual Report and Accounts 2020 
 
Financial overview

Reported results

Reported profit 
Reported profit after tax of $6.1bn was $2.6bn 
or 30% lower than in 2019. 

Reported profit before tax of $8.8bn was 
$4.6bn or 34% lower due to a rise in reported 
ECL, primarily reflecting the impact of the 
Covid-19 outbreak on the forward economic 
outlook, and a fall in reported revenue, mainly 
from lower global interest rates. These were 
partly offset by lower reported operating 
expenses, reflecting the non-recurrence of a 
$7.3bn impairment of goodwill in 2019, lower 
customer redress programme costs, a 
reduction of the variable pay accrual and lower 
discretionary expenditure.

Results in 2020 included the impact of certain 
volatile items, notably favourable market 
impacts in life insurance manufacturing in 
WPB of $90m (2019: $129m favourable) and 
favourable movements on our long-term debt 
and associated swaps in Corporate Centre of 
$150m (2019: $147m favourable). These were 
partly offset by adverse credit and funding 
valuation adjustments in GBM of $252m (2019: 
$44m favourable). Additionally in 2019, results 
included disposal gains in WPB and CMB  
of $157m.

Our operations across Asia delivered resilient 
performances in 2020, despite the impact of 
lower interest rates and higher ECL, with 
reported profit before tax representing more 
than 146% of Group profits. Outside of Asia, 
in addition to higher ECL and lower interest 
rates, HSBC Bank plc and our US business 
incurred restructuring costs and charges from 
the impairment of intangibles, in part as a 
result of our strategic actions to address 
underperformance. Reported profit in MENA 
for 2020 included our share of an impairment 
by our associate, The Saudi British Bank 
(‘SABB’), of $462m, while 2019 included a 
$0.8bn dilution gain recognised on the 
completion of the merger of SABB with 
Alawwal bank.

Reported revenue
Reported revenue of $50.4bn was $5.7bn or 
10% lower than in 2019, primarily reflecting the 
progressive impact of lower global interest 
rates on net interest income, notably in Retail 
Banking in WPB and Global Liquidity and Cash 
Management (‘GLCM’) in CMB and GBM.  
In WPB, revenue also reduced from lower 
unsecured lending, a fall in credit card 
spending and lower sales in insurance. In 
GBM, adverse valuation movements relating  

Reported profit after tax

$6.1bn

(2019: $8.7bn)

Basic earnings per share

$0.19

(2019: $0.30)

Reported results

Net operating income before change in 
expected credit losses and other credit 
impairment charges (‘revenue’)

Change in expected credit losses and other 
credit impairment charges

Net operating income

Total operating expenses

Operating profit

Share of profit in associates and joint 
ventures

Profit before tax

Tax expense

Profit after tax

to the widening of credit spreads in the first 
quarter partly reversed as spreads narrowed  
in the subsequent quarters, and in WPB the 
adverse market impacts in life insurance 
manufacturing in the first quarter more than 
reversed over the same period.

These factors were partly offset by higher 
revenue in Global Markets as market volatility 
remained elevated. Revenue relating to 
Markets Treasury, which is allocated to our 
global businesses, also increased, primarily 
due to increased disposal gains.

Reported revenue included net adverse 
movements in significant items of $0.6bn, 
primarily from the non-recurrence of a $0.8bn 
dilution gain in 2019 as discussed above. 
Significant items in 2020 included restructuring 
and other related costs of $0.2bn associated 
with disposal losses related to RWA 
reductions, as well as a property-related  
gain, both of which related to February 2020 
business update commitments. Foreign 
currency translation differences resulted  
in a further adverse movement of $0.5bn 
compared with 2019.

We have observed reductions in the Hong 
Kong interbank offered rate (‘HIBOR’) in the 
early part of 2021. This could put further 
pressure on net interest income, and also 
noting uncertainty around loan growth as 
economies recover from the Covid-19 
pandemic.

Reported ECL
Reported ECL of $8.8bn were $6.1bn higher 
than in 2019, with increases across all global 
businesses.

The ECL charge in 2020 reflected a significant 
increase in stage 1 and stage 2 allowances, 
notably in the first half of the year, to reflect the 
deterioration in the forward economic outlook 
globally as a result of the Covid-19 outbreak. 
The economic outlook stabilised in the second 
half of 2020 and as a result stage 1 and stage 2 
allowances were broadly unchanged at 31 
December 2020, compared with 30 June 2020. 
Stage 3 charges also increased compared with 
2019, largely against wholesale exposures, 
including a significant charge related to a CMB 
client in Singapore in the first quarter of 2020.

2020

$m

50,429

2019

$m

56,098

2018

$m

53,780

(8,817)

(2,756)

(1,767)

41,612

(34,432)

7,180

1,597

8,777

(2,678)

6,099

53,342

(42,349)

10,993

2,354

13,347

(4,639)

8,708

52,013

(34,659)

17,354

2,536

19,890

(4,865)

15,025

While we expect the full year ECL charge for 
2021 to be materially lower than in 2020, the 
outlook is highly uncertain and remains 
dependent on the future path of the Covid-19 
outbreak, including the successful deployment 
of mass vaccination programmes, and the credit 
quality of our loan portfolio as government 
support packages are gradually withdrawn.

Reported operating expenses
Reported operating expenses of $34.4bn were 
$7.9bn or 19% lower than in 2019, primarily 
reflecting a net favourable movement in 
significant items of $6.6bn, driven by the 
non-recurrence of a $7.3bn impairment of 
goodwill in 2019 and lower customer redress 
programme costs. Additionally, the reduction 
reflected lower performance-related pay, 
reduced discretionary expenditure and the 
impact of our cost-saving initiatives, partly 
offset by an increase in investments in 
technology, inflation and impairments of 
certain real estate assets.

The movement in significant items included: 

 – a $1.1bn impairment of goodwill and other 
intangibles in 2020, primarily capitalised 
software related to the businesses within 
HSBC Bank plc and to a lesser extent in the 
US. It reflected underperformance and a 
deterioration in the future forecasts of these 
businesses, in the case of HSBC Bank plc 
substantially relating to prior periods. This 
compared with an impairment of goodwill of 
$7.3bn in 2019, primarily related to lower 
long-term economic growth assumptions in 
CMB and GBM, and the planned reshaping 
of GBM; and

 – a net release in customer redress 

programme costs of $0.1bn in 2020, 
compared with charges of $1.3bn in 2019.

These were partly offset by restructuring and 
other related costs of $1.9bn in 2020, of which 
$0.9bn related to severance, $0.2bn related to 
an impairment of software intangibles and 
$0.2bn related to the impairment of tangible 
assets in France and the US. This compared 
with restructuring and other related costs of 
$0.8bn in 2019. 

The reduction in reported operating expenses 
included favourable foreign currency 
translation differences of $0.2bn. 

27

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Net operating income before change in expected credit losses and other 
credit impairment charges (‘revenue’)

50,366

54,944

52,098

(4,578)

Change in expected credit losses and other credit impairment charges 

(8,817)

(2,627)

(1,620)

(6,190) >(200)

2020

$m

2019

$m

2018

$m

2020 vs 2019

$m

(31,459)

(32,519)

(31,723)

10,090

19,798

18,755

2,059

2,351

2,444

1,060

(9,708)

(292)

12,149

22,149

21,199

(10,000)

3

(49)

(12)

(45)

Strategic report | Financial overview

Reported results continued

Reported share of profit in associates 
and joint ventures
Reported share of profit in associates of 
$1.6bn was $0.8bn or 32% lower than in 2019. 
This included our share of impairment of 
goodwill by SABB of $462m. In addition, our 
share of profit from associates fell due to the 
impact of the Covid-19 outbreak and lower 
global interest rates.

Adjusted performance

Our reported results are prepared in 
accordance with IFRSs, as detailed in the 
financial statements on page 288. 

We also present alternative performance 
measures (non-GAAP financial measures). 
These include adjusted performance, which 
we use to align internal and external reporting, 
identify and quantify items management 
believes to be significant, and provide insight 
into how management assesses period-on-
period performance. Alternative performance 

Adjusted results

Total operating expenses

Operating profit

Share of profit in associates and joint ventures

Profit before tax

Adjusted profit before tax
Adjusted profit before tax of $12.1bn was 
$10.0bn or 45% lower than in 2019, primarily 
from a rise in adjusted ECL and a fall in 
adjusted revenue. Adjusted ECL increased by 
$6.2bn, mainly from charges in the first half of 
2020 relating to the global impact of the 
Covid-19 outbreak on the forward economic 
outlook. Adjusted revenue decreased by 
$4.6bn or 8%, primarily from the progressive 
impact of lower global interest rates in all our 
global businesses, notably in our deposit 
franchises, partly offset by higher revenue 
from Global Markets. Adjusted operating 
expenses decreased by $1.1bn or 3% as we 
lowered performance-related pay and reduced 
discretionary expenditure while continuing to 
invest in our businesses.

28

Tax expense
The tax expense of $2.7bn was $2.0bn lower 
than in 2019, and the effective tax rate for 2020 
of 30.5% was lower than the 34.8% effective 
tax rate for 2019. An impairment of goodwill 
and non-deductible customer redress charges 
increased the 2019 effective tax rate. These 
were not repeated in 2020. Additionally, the 
non-taxable dilution gain arising on the merger 
of SABB with Alawwal bank decreased the 

effective tax rate in 2019. Higher charges in 
respect of the non-recognition of deferred tax 
assets, particularly in the UK ($0.4bn) and 
France ($0.4bn), increased the 2020 effective 
tax rate.

measures are highlighted with the following 
symbol:

To derive adjusted performance, we adjust for:

 – the year-on-year effects of foreign currency 

translation differences; and

 – the effect of significant items that distort 
year-on-year comparisons, which are 
excluded to improve understanding of the 
underlying trends in the business.

The results of our global businesses are 
presented on an adjusted basis, which is 
consistent with how we manage and assess 
global business performance.

 For reconciliations of our reported results to an 
adjusted basis, including lists of significant items, 
see page 85. Definitions and calculations of other 
alternative performance measures are included 
in our ‘Reconciliation of alternative performance 
measures’ on page 103.

%

(8)

(519)

1,828

361

93

165

100

 —

228

66

816

—

(1)

Reconciliation of reported to adjusted profit before tax

Reported profit before tax

Currency translation

Significant items:

 – costs of structural reform

 – customer redress programmes

 – disposals, acquisitions and investment in new 

businesses

 – fair value movements on financial instruments

 – impairment of goodwill and other intangibles

2020

$m

2019

$m

2018

$m

8,777

13,347

19,890

—

(122)

3,372

—

(33)

10

8,924

158

1,444

(768)

(264)

(84)

1,090

7,349

 – past service costs of guaranteed minimum pension 

17

—

benefits equalisation

 – restructuring and other related costs

 – settlements and provisions in connection with legal and 

regulatory matters

 – goodwill impairment (share of profit in associates and 

joint ventures)

 – currency translation on significant items

2,078

12

462

—

827

(61)

—

59

Adjusted profit before tax

12,149

22,149

21,199

HSBC Holdings plc Annual Report and Accounts 2020 
Financial overview

Adjusted performance continued

Adjusted revenue
Adjusted revenue of $50.4bn was $4.6bn or 
8% lower than in 2019, reflecting falls in WPB 
(down $3.6bn) and CMB (down $1.9bn), partly 
offset by higher revenue in GBM (up $0.4bn) 
and Corporate Centre (up $0.4bn).

The reduction in adjusted revenue reflected 
the progressive impact of lower global interest 
rates in many of the key markets in which we 
operate. This had an adverse impact on 
revenue in Retail Banking within WPB, and in 
GLCM within CMB and GBM, although we 
grew deposit balances across these 
businesses compared with 2019. In WPB, 
revenue also reduced as the impact of the 
Covid-19 outbreak resulted in lower customer 
activity in unsecured lending, including a fall in 
credit card spending, and a reduction in sales 
of insurance and certain investment products. 
In GBM, adverse valuation movements, 
primarily in the first quarter, partly reversed in 
the subsequent quarters. This resulted in a net 
adverse movement in credit and funding 
valuation adjustments of $0.3bn and a 
reduction in revenue of $0.1bn in Principal 
Investments compared with 2019. In life 
insurance manufacturing, the adverse market 
impacts in the first quarter following the sharp 
fall in equity markets more than reversed over 
the remainder of the year.

These reductions were partly offset by higher 
revenue in Global Markets, as market volatility 
remained elevated, as well as in Corporate 
Centre. Revenue relating to Markets Treasury, 

which is allocated to our global businesses, also 
increased, primarily due to higher disposal gains.

Adjusted ECL 
Adjusted ECL, which removes the period-on-
period effects of foreign currency translation 
differences, were $8.8bn, an increase of 
$6.2bn from 2019. This increase occurred in all 
global businesses and mainly reflected 
charges related to the global impact of the 
Covid-19 outbreak.

The ECL charge in 2020 reflected a significant 
increase in stage 1 and stage 2 allowances, 
notably in the first half of the year, to reflect 
the deterioration in the forward economic 
outlook globally as a result of the Covid-19 
outbreak. The economic outlook stabilised in 
the second half of 2020 and as a result, stage 
1 and stage 2 allowances were broadly 
unchanged at 31 December 2020, compared 
with 30 June 2020. Stage 3 charges in 2020 
increased compared with 2019, with the rise 
largely related to wholesale exposures, 
including a significant charge related to a CMB 
client in Singapore in the first quarter of 2020. 

Adjusted ECL as a percentage of average 
gross loans and advances to customers was 
0.81%, compared with 0.25% in 2019.

Adjusted operating expenses 
Adjusted operating expenses of $31.5bn were 
$1.1bn or 3% lower than in 2019, as we 
continued to review and reprioritise costs and 
investments to help mitigate revenue 

headwinds. The decrease primarily reflected a 
$0.5bn reduction in performance-related pay 
and lower discretionary expenditure, including 
marketing (down $0.3bn) and travel costs 
(down $0.3bn). In addition, our cost-saving 
initiatives resulted in a reduction of $1.4bn, of 
which $1.0bn related to our costs to achieve 
programme, and the UK bank levy was $0.2bn 
lower than in 2019. These decreases were 
partly offset by an increase in investments in 
technology to enhance our digital and 
automation capabilities to improve how we 
serve our customers, as well as inflation and 
volume-related increases. In addition, the 2020 
period included impairments of certain real 
estate assets. 

We are forecasting broadly stable adjusted 
operating expenses in 2021, relative to 2020.

During 2020, we reduced the number of 
employees expressed in full-time equivalent 
staff (‘FTE’) and contractors by 11,011. This 
included a 9,292 reduction in FTE to 226,059 
at 31 December 2020, while the number of 
contractors reduced by 1,719 to 5,692 at 
31 December 2020.

Adjusted share of profit in associates  
and joint ventures 
Adjusted share of profit from associates of 
$2.1bn was $0.3bn or 12% lower than in 2019, 
primarily reflecting the impact of the Covid-19 
outbreak and lower global interest rates on the 
share of profit we recognised from our 
associates.

Balance sheet and capital

Balance sheet strength
Total assets of $3.0tn were $269bn or 10% 
higher than at 31 December 2019 on a 
reported basis, and 7% higher on a constant 
currency basis. The increase in total assets 
included growth in cash balances and in 
financial investments, as well as from an 
increase in derivative assets, mainly reflecting 
favourable revaluation movements on interest 
rate derivatives. On a constant currency basis, 
loans and advances to customers reduced by 
$25bn during the year, despite mortgage 
growth in WPB.

Customer accounts of $1.6tn increased by 
$204bn, or $173bn on a constant currency 
basis, as corporate customers consolidated 
their funds and redeployed them into cash, 
while our personal customers reduced 

spending, resulting in larger balances held in 
current and savings accounts.

Distributable reserves
The distributable reserves of HSBC Holdings 
at 31 December 2020 were $31.3bn. 
Movements in 2020 included the retained 
earnings of HSBC Holdings plc for the year, 
offset by distributions to and redemptions of 
preference shares and other equity 
instruments. Movements also included a 
$1.7bn return of capital from a subsidiary, 
which had previously been considered as part 
of distributable reserves.

Capital position
We actively manage the Group’s capital 
position to support our business strategy and 
meet our regulatory requirements at all times, 

Total assets
($bn)

$2,984bn

Common equity tier 1 ratio
(%)

15.9%

2020

2019

2018

2019

2,984

2020

2,715

2019

2,558

2018

2019

15.9

14.7

14.0

including under stress, while optimising our 
capital efficiency. To do this, we monitor our 
capital position using a number of measures. 
These include: our capital ratios, the impact 
on our capital ratios as a result of stress, and 
the degree of double leverage being run by 
HSBC Holdings. Double leverage is a 
constraint on managing our capital position, 
given the complexity of the Group’s subsidiary 
structure and the multiple regulatory regimes 
under which we operate. For further details, 
see page 169.

Our CET1 ratio at 31 December 2020 was 
15.9%, up from 14.7% at 31 December 2019. 
This increase included the impact of the 
cancellation of the fourth interim dividend of 
2019 and changes to the capital treatment of 
software assets.

Liquidity position
We actively manage the Group’s liquidity and 
funding to support our business strategy and 
meet regulatory requirements at all times, 
including under stress. To do this, we monitor 
our position using a number of risk appetite 
measures, including the liquidity coverage 
ratio and the net stable funding ratio. At 31 
December 2020, we held high-quality liquid 
assets of $678bn. 

29

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020 
Strategic report | Global businesses

Wealth and  
Personal Banking

Contribution to Group adjusted profit 
before tax   

$4.1bn
(34%)

WPB was formed in the second quarter of 
2020 by combining our Retail Banking 
and Wealth Management and Global 
Private Banking businesses. Throughout 
the pandemic we supported our 
customers with payment holidays and by 
keeping between 70% to 90% of our 
branches open. Performance in 2020 was 
impacted by lower interest rates across 
most markets, reduced customer activity 
and a rise in adjusted ECL charges. 
However, we remain committed to 
serving our customers and increased our  

net promoter scores in most of our 
channels in the UK and Hong Kong.

We serve more than 38 million customers across 
the full spectrum from retail customers to ultra 
high net worth individuals and their families. 

We offer locally-tailored products and services 
across multiple channels for our customers’ 
everyday banking needs, as well as insurance, 
investment management, advisory and wealth 
solutions for those with more sophisticated 
requirements. Our global presence provides 
for customers with international needs.

Adjusted results 

2020

$m

2019

$m

2018

$m

2020 vs 2019

$m

%

Net operating income

22,013

25,565

23,551

(3,552)

(14)

Change in expected credit losses 
and other credit impairment 
charges

(2,855)

(1,348)

(1,072)

(1,507)

(112)

Operating expenses

(15,024)

(15,388)

(14,614)

Share of profit in associates  
and JVs

Profit before tax

RoTE excluding significant items 
and UK bank levy (%)

6

54

32

4,140

9.1

8,883

19.7

7,897

18.8

364

2

(48)

(89)

(4,743)

(53)

Financial planning delivered to 
your door

In 2020, we launched HSBC Pinnacle, a new financial 
planning business in mainland China, which offers 
insurance solutions and wealth services outside of 
branches, bringing them direct to new customers. Our 
wealth planners can advise on life and health protection, 
education savings, retirement and legacy planning – 
supporting multiple needs in one tailored proposition. 

Blending seamless digital experiences with the expertise 
and great service of our people sits at the very heart of 
our approach.

The pioneering business has plans to hire 3,000 wealth 
professionals over a four-year period. By the end of 
2020, almost 200 new colleagues were already helping 
customers in the cities of Shanghai, Guangzhou, 
Hangzhou and Shenzhen. Pinnacle is vital to our 
ambitions for growth and opportunity in one of the 
world’s largest insurance markets, and supports our 
ambition to be the number one wealth manager in Asia 
in the medium to long term.

30

HSBC Holdings plc Annual Report and Accounts 2020 
 
Global businesses | Wealth and Personal Banking

Management view of adjusted revenue

Retail Banking

 – net interest income

 – non-interest income

Wealth Management

 – investment distribution

 – life insurance manufacturing

 – Global Private Banking

net interest income

non-interest income

 – asset management

Other1

Markets Treasury, HSBC Holdings interest expense and 
Argentina hyperinflation

2020

$m

12,938

11,708

1,230

7,818

3,209

1,816

1,746

670

1,076

1,047

429

828

2019

$m

15,655

13,993

1,662

8,633

3,268

2,464

1,878

891

987

1,023

788

489

2018

$m

14,746

13,155

1,591

7,778

3,333

1,621

1,783

884

899

1,041

512

515

2020 vs 2019

$m

(2,717)

(2,285)

(432)

(815)

(59)

(648)

(132)

(221)

89

24

(359)

339

Net operating income2

22,013

25,565

23,551

(3,552)

%

(17)

(16)

(26)

(9)

(2)

(26)

(7)

(25)

9

2

(46)

69

(14)

1  ‘Other’ includes the distribution and manufacturing (where applicable) of retail and credit protection insurance, disposal gains and other non-product specific 

income.

2  ’Net operating income’ means net operating income before change in expected credit losses and other credit impairment charges (also referred to as ‘revenue’).

Divisional highlights

$1.6tn

WPB wealth balances at 31 December 2020, 
up 12% from 31 December 2019. 

$22bn

Growth in mortgage book in the UK (up 9%) 
and Hong Kong (up 5%) since 31 December 
2019.

Adjusted profit before tax
($bn)

$4.1bn

2020

2019

2018

2019

Net operating income
($bn)

$22.0bn

2020

2019

2018

2019

Financial performance
Adjusted profit before tax of $4.1bn was 
$4.7bn or 53% lower than in 2019. Despite 
this, we achieved a RoTE of 9.1%. The 
reduction in adjusted profit before tax 
reflected a fall in adjusted revenue and an 
increase in adjusted ECL from the impact of 
the Covid-19 outbreak. The reduction in 
revenue was mainly as a result of lower global 
interest rates, which particularly affected 
deposit margins, as well as from lower 
spending and reduced customer demand for 
borrowing.

Adjusted revenue of $22.0bn was $3.6bn or 
14% lower, which included the non-recurrence 
of 2019 disposal gains in Argentina and 
Mexico of $133m.

In Retail Banking, revenue of $12.9bn was 
down $2.7bn or 17%.

 – Net interest income was $2.3bn lower due 
to narrower margins from lower global 
interest rates. This reduction was partly 
offset by deposit balance growth of $67bn 
or 9%, particularly in Hong Kong and the 
UK, and higher mortgage lending of $22bn 
or 6%, mainly in the UK and Hong Kong. 

 – Non-interest income fell by $0.4bn, driven 
by lower fee income earned on unsecured 
lending products primarily due to lower 
customer activity as a result of the Covid-19 
outbreak.

In Wealth Management, revenue of $7.8bn 
was down $0.8bn or 9%.

continued actions to support customers  
by improving our digital channels. The 
reduction also included lower favourable 
movement in market impacts of $38m 
(2020: $90m favourable, 2019: $128m 
favourable), as the sharp adverse movement 
we saw in the first quarter reversed over 
subsequent quarters.

 – In Global Private Banking, revenue was 

$0.1bn or 7% lower, as net interest income 
fell as a result of lower global interest rates, 
although investment revenue increased, 
reflecting market volatility and higher fees 
from advisory and discretionary mandates.

 – In investment distribution, revenue was 
$0.1bn or 2% lower, reflecting adverse 
market conditions, which resulted in lower 
mutual fund sales and a reduction in wealth 
insurance distribution. This was partly offset 
by higher brokerage fees from increased 
transaction volumes.

Adjusted ECL of $2.9bn were $1.5bn higher 
than in 2019, reflecting the global impact of 
the Covid-19 outbreak on the forward 
economic outlook across all regions, notably 
in the UK.

Adjusted operating expenses of $15.0bn  
were $0.4bn or 2% lower, as a decrease  
in performance-related pay and reduced 
discretionary expenditure more than offset  
the impact of inflation and our continued 
investment in digital.

4.1

8.9

7.9

22.0

25.6

23.6

 – In life insurance manufacturing, revenue fell 
by $0.6bn or 26%, mainly as the value of 
new business written reduced by $0.4bn or 
37% due to lower volumes following the 
Covid-19 outbreak, in part mitigated by 

31

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report | Global businesses

Commercial Banking

Contribution to Group adjusted 
profit before tax

$1.9bn
(15%)

Throughout 2020, CMB continued to 
support our customers’ liquidity and 
working capital needs, growing deposit 
balances, while our ongoing investment 
in technology enabled us to support 
customers under exceptionally 
challenging conditions. Performance in 
2020 was adversely impacted by an 
increase in adjusted ECL charges and 
lower global interest rates.

We support over 1.3 million business 
customers in 53 countries and territories, 
ranging from small enterprises focused 
primarily on their domestic markets to large 
companies operating globally. 

We help entrepreneurial businesses grow by 
supporting their financial needs, facilitating 
cross-border trade and payment services, and 
providing access to products and services 
offered by other global businesses.

Adjusted results 

2020

$m

2019

$m

2018

$m

2020 vs 2019

$m

%

Net operating income

13,312

15,164

14,374

(1,852)

(12)

Change in expected credit losses 
and other credit impairment 
charges

(4,754)

(1,162)

(683)

(3,592) >(200)

Operating expenses

(6,689)

(6,832)

(6,307)

Share of profit in associates  
and JVs

Profit before tax

RoTE excluding significant items 
and UK bank levy (%)

(1)

—

—

1,868

1.3

7,170

13.0

7,384

13.2 

143

(1)

2

—

(5,302)

(74)

Pioneering ecommerce 
solutions

Hong Kong-based SHOPLINE helps 
companies trade online through its 
ecommerce shopping platform. Founded in 
2013, it has expanded to support over 
250,000 merchants, which serve more than 
80 million customers across 10 regions in 
Asia. We partnered with SHOPLINE to 
integrate advanced digital capabilities, such 
as our Business Collect and PayMe for 
Business services, into their propositions. 
These ‘banking as a service’ capabilities 
enable merchants to access the latest 
collections technology with no additional 
development required. Our collaboration 
with SHOPLINE embodies our passion to 
support small and medium-sized 
enterprises through innovation, enabling 
them to grow their platforms and 
ecosystems across Asia and beyond.

32

HSBC Holdings plc Annual Report and Accounts 2020Global businesses | Commercial Banking

Management view of adjusted revenue 

Global Trade and Receivables Finance 

Credit and Lending 

Global Liquidity and Cash Management

Markets products, Insurance and Investments and Other1

Markets Treasury, HSBC Holdings interest expense and 
Argentina hyperinflation

2020

$m

1,744

5,640

4,178

1,596

154

2019

$m

1,826

5,421

5,932

2,023

2018

$m

1,806

5,162

 5,625

1,836

(38)

(55)

2020 vs 2019

$m

(82)

219

(1,754)

(427)

192

%

(4)

4

(30)

(21)

>200

Net operating income2

13,312

15,164

14,374

(1,852)

(12)

1  Includes revenue from Foreign Exchange, insurance manufacturing and distribution, interest rate management and Global Banking products.
2  ’Net operating income’ means net operating income before change in expected credit losses and other credit impairment charges (also referred to as ‘revenue’).

Divisional highlights

$73.2bn

Growth in adjusted customer deposits  
in 2020.

+8%

Increase in international account openings.

Adjusted profit before tax
($bn)

$1.9bn

2020

2019

2018

2019

Net operating income
($bn)

$13.3bn

2020

2019

2018

2019

1.9

7.2

7.4

13.3

15.2

14.4

Financial performance 
Adjusted profit before tax of $1.9bn was 
$5.3bn or 74% lower than in 2019. Adjusted 
ECL were higher, reflecting the impact of the 
Covid-19 outbreak, and adjusted revenue fell, 
which was primarily due to the impact of 
lower global interest rates.

Adjusted revenue of $13.3bn was $1.9bn or 
12% lower.

 – In GLCM, revenue decreased by $1.8bn or 
30% due to the impact of the lower global 
interest rates, mainly in Hong Kong and the 
UK. This was partly offset by a 16% increase 
in average deposit balances, with growth 
across all regions, particularly in the UK  
and the US.

 – In Global Trade and Receivables Finance 

(‘GTRF’), revenue decreased by $82m or 4% 
from lower lending balances and fees, 
notably in Hong Kong and the UK, reflecting 
a reduction in global trade volumes as a 
result of the Covid-19 outbreak. This was 
partly offset by wider margins in the UK and 
Latin America.

 – In ‘Markets products, Insurance and 

Investments and Other’, revenue was $0.4bn 
lower, reflecting the impact of lower interest 
rates on income earned on capital held in 
the business, a fall in revenue from 
Insurance, Investments and Markets 
products, as well as a reduction in 
revaluation gains on shares. In addition, 
2019 included a disposal gain of $24m in 
Latin America.

This was partly offset by:

 – In Credit and Lending, revenue increased by 
$0.2bn or 4%, reflecting growth in average 
balances driven by the uptake of 
government-backed lending schemes and 
from wider margins.

Adjusted ECL of $4.8bn were $3.6bn higher 
than in 2019. The increase reflected the global 
impact of the Covid-19 outbreak on the 
forward economic outlook, mainly in the UK 
and Asia. There were also higher charges 
against specific customers in 2020, 
particularly in the oil and gas and wholesale 
trade sectors, including a significant charge 
related to a corporate exposure in Singapore in 
the first quarter of 2020. 

Adjusted operating expenses of $6.7bn were 
$0.1bn or 2% lower, reflecting a decrease in 
performance-related pay and reduced 
discretionary expenditure, while we continued 
to invest in our digital and transaction banking 
capabilities to improve customer experience.

In 2020, we delivered around $13bn of RWA 
reductions as part of our transformation 
programme, which mitigated an increase from 
asset quality deterioration.

33

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report | Global businesses

Global Banking  
and Markets

Contribution to Group adjusted profit 
before tax

$4.8bn
(40%)

GBM increased adjusted revenue as 
strong Global Markets performance more 
than offset the impact of lower global 
interest rates and adverse movements in 
credit and funding valuation adjustments. 
In 2020, management actions delivered 
gross RWA reductions of $37bn globally. 
Performance in Global Markets was 
achieved with both a decrease in RWAs 
and no increase in trading value at risk 
(‘VaR’).

We continue to invest in digital capabilities 
to provide value to our clients and support 
them in the current environment.

We support major government, corporate and 
institutional clients worldwide. Our product 
specialists deliver a comprehensive range of 
transaction banking, financing, advisory, 
capital markets and risk management 
services.  

Adjusted results 

2020

$m

2019

$m

2018

$m

Net operating income

15,303

14,869

15,056

2020 vs 2019

$m

434

%

3

Change in expected credit losses 
and other credit impairment 
charges

(1,209)

(153)

34

(1,056) >(200)

Operating expenses

(9,264)

(9,544)

(9,316)

Share of profit in associates  
and JVs

Profit before tax

RoTE excluding significant items 
and UK bank levy (%)

—

 —

—

4,830

6.7

5,172

9.8

5,774

9.5

280

—

3

—

(342)

(7)

Supporting Rolls-Royce with a 
capital markets drive

Rolls-Royce, the blue-chip FTSE 100 engineering 
company, needed to raise additional liquidity in the 
fourth quarter of 2020 as a consequence of the 
Covid-19 outbreak. We acted as joint global 
coordinator on a £2bn fully underwritten rights 
issue, which received strong support from 
Rolls-Royce shareholders with a 94% take-up. The 
rights issue was part of a broader liquidity solution 
that also incorporated raising additional debt, 
including a £2bn unsecured notes offering where 
we acted as joint bookrunner, and a £1bn term loan 
where we acted as lead arranger and bookrunner. 
The rights issue was the largest equity capital 
markets transaction we acted on in the UK in 2020 
and demonstrates our expertise in offering holistic 
solutions to our clients across both equity and debt.

34

HSBC Holdings plc Annual Report and Accounts 2020Global businesses | Global Banking and Markets

Management view of adjusted revenue 

Global Markets

 – FICC

Foreign Exchange

Rates

Credit

 – Equities

Securities Services1

Global Banking1

Global Liquidity and Cash Management

Global Trade and Receivables Finance

Principal Investments

Credit and funding valuation adjustments

Other2

Markets Treasury, HSBC Holdings interest expense and 
Argentina hyperinflation

2020

$m

7,290

6,278

3,373

1,734

1,171

1,012

1,792

3,804

2,021

769

114

(252)

(575)

340

2019

$m

5,728

4,737

2,671

1,451

615

991

2,026

3,875

2,722

802

261

41

(642)

56

2018

$m

6,243

5,062

2,898

1,416

748

1,181

1,925

3,983

2,563

784

219

(183)

(579)

101

Net operating income3

15,303

14,869

15,056

2020 vs 2019

$m

1,562

1,541

702

283

556

21

(234)

(71)

(701)

(33)

(147)

(293)

67

284

434

%

27

33

26

20

90

2

(12)

(2)

(26)

(4)

(56)

>(200)

10

>200

3

1  From 1 June 2020, revenue from Issuer Services, previously reported in Securities Services, was reported within Global Banking. This resulted in $96m additional 

revenue being recorded in Global Banking for 2020. Comparatives have not been restated.

2  ‘Other’ in GBM includes allocated funding costs. In addition, notional tax credits are allocated to the businesses to reflect the economic benefit generated by 

certain activities to reflect the total operating income on an IFRS basis; the offset to these tax credits is included within ‘Other’.

3  ’Net operating income’ means net operating income before change in expected credit losses and other credit impairment charges (also referred to as ‘revenue’).

Divisional highlights

49%

Adjusted revenue generated in Asia in 2020. 

$8bn

Reduction in reported RWAs compared with 
31 December 2019.

Adjusted profit before tax
($bn)

$4.8bn

2020

2019

2018

2019
Net operating income
($bn)

$15.3bn

2020

2019

2018

2019

Financial performance 
Adjusted profit before tax of $4.8bn was 
$0.3bn lower than in 2019, mainly due to 
higher adjusted ECL, which reflected the 
global impact of the Covid-19 outbreak and 
included charges relating to specific 
exposures, partly offset by higher adjusted 
revenue and lower adjusted operating 
expenses.  

Adjusted revenue of $15.3bn increased by 
$0.4bn compared with 2019. We grew 
adjusted revenue, which included adverse 
movements in credit and funding valuation 
adjustments of $0.3bn, while reducing net 
reported RWAs by $8bn, compared with 31 
December 2019.

 – In Global Markets, revenue increased by 

$1.6bn or 27%, as higher volatility levels and 
increased client activity, together with wider 
spreads supported an improved FICC 
performance, particularly in Foreign 
Exchange and Credit. Rates also performed 
strongly due to increased trading activity in 
government bonds.

4.8

5.2

5.8

This was partly offset by:

 – In Securities Services, revenue fell by $0.2bn 
or 12% due to lower global interest rates, 
mainly affecting Asia and Europe, although 
fees increased.

15.3

14.9

15.1

 – In Global Banking, revenue decreased by 
$0.1bn or 2%, reflecting lower real estate 
and structured finance fee income and 
losses on legacy corporate restructuring 
positions. However, we grew capital 
markets revenue and net interest income 
increased from corporate lending.

 – In GLCM, revenue decreased $0.7bn or 26% 
due to the impact of lower global interest 
rates and a fall in transaction volumes that 
reduced fee income, notably in the US and 
the UK, partly offset by a 21% growth in 
average balances, across all regions, 
particularly in the US, Asia and the UK.

 – In GTRF, revenue decreased by $33m or 4%, 

reflecting lower fees in Europe due to 
management actions taken to reduce 
RWAs, partly offset by repricing initiatives in 
Asia and Latin America.

 – In Principal Investments, revenue fell by 

$0.1bn, reflecting revaluation losses incurred 
in the first quarter of 2020, mainly in Europe, 
as a result of the Covid-19 outbreak, which 
partly reversed in the remainder of the period.

Adjusted ECL were $1.2bn, up $1.1bn 
compared with 2019 from charges relating to 
the impact of the Covid-19 outbreak on the 
forward economic outlook, particularly in 
Europe, MENA and North and Latin America.

Adjusted operating expenses of $9.3bn were 
$0.3bn or 3% lower, reflecting management’s 
cost reduction initiatives and from lower 
performance-related pay, which more than 
offset growth in regulatory programme costs 
and investments in technology.

In 2020, net reported RWAs fell by $8bn. We 
delivered around $37bn of RWA reductions in 
2020, taking our cumulative reduction, 
including accelerated saves relating to our 
transformation programme, to $47bn. This 
mitigated RWA growth from asset quality 
deterioration, elevated market volatility and 
from regulatory changes. 

35

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020 
Strategic report | Global businesses

Corporate Centre

During 2020, we began allocating the 
revenue and expenses relating to Markets 
Treasury, the funding costs of HSBC 
Holdings debt and the impacts of 
hyperinflation in Argentina to the global 
businesses. This was to improve how we 
reflect revenue and expense related to 
the global businesses generating or 
utilising these activities. All comparatives 
have been restated accordingly. 

The results of Corporate Centre now primarily 
comprise the share of profit from our interests 
in our associates and joint ventures, together 
with Central Treasury revenue, stewardship 
costs and consolidation adjustments. 

Adjusted results 

Net operating income

Change in expected credit losses 
and other credit impairment 
charges

2020

$m

(262)

1

2019

$m

(654)

36

2018

$m

(883)

101

Operating expenses

(482)

(755)

(1,486)

Share of profit in associates  
and JVs

Profit before tax

RoTE excluding significant items 
and UK bank levy (%)

2,054

2,297

2,412

1,311

3.1

924

0.8

144

1.6

2020 vs 2019

$m

392

%

60

(35)

(97)

273

(243)

36

(11)

387

42

Financial performance
Adjusted profit before tax of $1.3bn was 
$0.4bn higher than in 2019. 

Adjusted revenue increased by $0.4bn, which 
included intersegment eliminations, largely 
related to movements in own shares held by 
the global businesses, which offset an 
equivalent adverse movement in these 
businesses. In addition, certain funding costs 
that were retained in Corporate Centre during 
2019 were allocated to global businesses with 
effect from 1 January 2020. Revenue in our 

legacy portfolios rose by $0.1bn due to the 
non-recurrence of portfolio losses in 2019. 

Adjusted operating expenses, which are 
stated after recovery of costs from our global 
businesses, decreased by $0.3bn due to a 
lower UK bank levy charge and a reduction in 
discretionary expenditure.

Share of profit in associates and joint ventures 
decreased by $0.2bn, primarily due to the 
impact of falling interest rates and the 
Covid-19 outbreak.

Management view of adjusted revenue 

Central Treasury1

Legacy portfolios

Other2

Net operating income3

2020

$m

156

(17)

(401)

(262)

2019

$m

179

(111)

(722)

(654)

2018

$m

(313)

(83)

(487)

(883)

2020 vs 2019

$m

(23)

94

321

392

%

(13)

85

44

60

1  Central Treasury includes favourable valuation differences on issued long-term debt and associated swaps of $150m (2019: gains of $146m; 2018: losses of $313m).
2 I n June 2020, we began allocating the revenue from Markets Treasury, HSBC Holdings net interest expense and Argentina hyperinflation out to the global 

businesses, to align them better with their revenue and expense. The total Markets Treasury revenue component of this allocation for 2020 was $2,809m (2019: 
$2,040m; 2018: $2,213m).

3  ’Net operating income’ means net operating income before change in expected credit losses and other credit impairment charges (also referred to as ‘revenue’).

36

HSBC Holdings plc Annual Report and Accounts 2020Risk overview

Risk overview

Active risk management helps us to achieve our strategy, 
serve our customers and communities and grow our 
business safely.

Managing risk

Unprecedented global economic events meant 
banks played an expanded role in supporting 
society and customers in 2020. Many of our 
customers’ business models and income were 
impacted by the global economic downturn 
caused by the Covid-19 outbreak, requiring 
them to take significant levels of support from 
both governments and banks. 

Throughout the pandemic, we continued to 
support our customers and adapted our 
operational processes. We maintained high 
levels of service as our people, processes and 
systems responded to the required changes.

The financial performance of our operations 
varied in different geographies, but the 
balance sheet and liquidity of the Group 
remained strong. This helped us to support 
our customers both during periods of 
government imposed restrictions and when 
these restrictions were eased.

To meet the additional challenges, we 
supplemented our existing approach to risk 
management with additional tools and 
practices. We increased our focus on the 
quality and timeliness of the data used to 
inform management decisions, through 
measures such as early warning indicators, 
prudent active risk management of our risk 
appetite, and ensuring regular communication 
with our Board and key stakeholders.

Our risk appetite
Our risk appetite defines our desired forward-
looking risk profile, and informs the strategic 
and financial planning process. It provides an 
objective baseline to guide strategic decision 
making, helping to ensure that planned 
business activities provide an appropriate 
balance of return for the risk assumed, while 
remaining within acceptable risk levels.

Our risk appetite also provides an anchor 
between our global businesses and the Global 
Risk and Global Finance functions, helping to 
enable our senior management to allocate 
capital, funding and liquidity optimally to 
finance growth, while monitoring exposure 
and the cost impacts of managing non-
financial risks.

In 2020, we continued to evolve our risk appetite 
by reallocating both financial and non-financial 
resources and adapting aspects of our risk 
appetite statement to ensure we remained able 
to support our customers and strategic goals 

Key risk appetite metrics

Component Measure

Returns

Capital

Return on average tangible equity (‘RoTE’)

CET1 ratio – end point basis1

Change in 
expected  
credit losses 
and other credit 
impairment 
charges

Change in expected credit losses and other credit 
impairment charges as a % of advances: retail

Change in expected credit losses and other credit 
impairment charges as a % of advances: 
wholesale (GBM, CMB, Global Private Banking)

Risk 
appetite

≥6.5%

≥13.1%

≤0.50%

2020

3.1%

15.9%

0.68%

≤0.45%

0.89%

against the backdrop of the Covid-19 outbreak. 
We placed a specific emphasis on capital and 
liquidity to ensure the Group could withstand 
extreme but plausible stress, and had adequate 
capacity to provide increasing levels of financial 
support to customers. Associated non-financial 
risks were reviewed and, where applicable, 
processes and controls were enhanced to 
accommodate material increases in lending 
volumes and help our people manage the 
lending process from a home environment. A 
particular focus was placed on enhancing our 
risk appetite statement to provide early warnings 
of credit deterioration, deliver a more holistic 
view of the Group’s resilience capabilities and 
develop a climate risk appetite focusing on 
transition and physical risk Significant work is 
also underway to further develop our risk 
appetite framework, with forward-looking 
statements informed by stress testing. 

As seen in the key risk appetite metrics table, 
the financial impact of the Covid-19 outbreak 
is apparent with RoTE and ECL outside of 
appetite. These are subject to close monitoring 
and management actions focusing on 
adapting our strategy in the context of the 
pandemic and recovery. We have conducted 
reviews of our portfolios that are highly 
vulnerable to general economic conditions 
and additional review measures have been 
implemented for new credit requests.

Stress tests
We regularly conduct stress tests to assess 
the resilience of our balance sheet and our 
capital adequacy, as well as to provide 
actionable insights into how key elements of 
our portfolios may behave during crises. We 
use the outcomes to calibrate our risk appetite 
and to review the robustness of our strategic 
and financial plans, helping to improve the 
quality of management’s decision making. 
Stress testing analysis assists management in 

understanding the nature and extent of 
vulnerabilities to which the Group is exposed. 
The results from the stress tests also drive 
recovery and resolution planning to enhance 
the Group’s financial stability under various 
macroeconomic scenarios. The selection of 
stress scenarios is based upon the 
identification and assessment of our top and 
emerging risks identified and our risk appetite. 

In 2020, the Bank of England (‘BoE’) and 
European Banking Authority (‘EBA’) cancelled 
the requirement for all participating banks to 
conduct their respective 2020 stress test 
exercises in light of the emerging impacts of 
the Covid-19 outbreak. Notwithstanding this, 
we conducted a range of internal stress tests 
during 2020. These included stress tests 
covering several potential Covid-19-related 
outcomes, incorporating assessments from 
credit experts to assess the resilience of key 
balance sheet metrics including capital 
adequacy and liquidity. We are regularly 
reviewing the economic impacts for key 
economies and markets to understand 
potential vulnerabilities in our balance sheet 
and to identify appropriate mitigating actions. 
We continue to monitor emerging geopolitical, 
economic and environmental risks impacting 
the Group’s capital adequacy and liquidity. Our 
balance sheet and capital adequacy remain 
resilient based on regulatory and internal 
stress test outcomes.

We also developed a framework for our 
climate stress testing and scenario analysis 
capabilities. We conducted a pilot climate 
scenario analysis on some of our portfolios 
exposed to climate risk. The analysis was used 
to identify the most material drivers of climate 
risk within our business, and create informed 
insights of our climate exposures for use in our 
risk management and business decision 
making.

37

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report | Risk overview

Our operations
We remain committed to investing in the 
reliability and resilience of our IT systems and 
critical services that support all parts of our 
business. We do so to protect our customers, 
affiliates and counterparties, and to help 
ensure that we minimise any disruption to 
services that could result in reputational and 
regulatory consequences. We continue to 
operate in a challenging environment in which 
cyber threats are prevalent. To help defend 
against these threats we continue to invest in 

business and technical controls, such as our 
infrastructure, software solutions, and system 
resilience and service continuity. 

We have started to move forward with the 
implementation of our business transformation 
plans. This follows a pause on some elements 
during the first half of 2020 to help ensure our 
continued safe operation and to support our 
people and communities during a period of 
significant change due to the Covid-19 
outbreak. We are aiming to manage the risks 

of the restructuring safely, which include 
execution, operational, governance, 
reputational, conduct and financial risks. We 
put support in place to help our people, 
particularly when we are unable to find 
alternative roles for them as a result of the 
business transformation plans. 

 For further details on our risk management 
framework and risks associated with our banking 
and insurance manufacturing operations, see 
pages 118 and 119 respectively.

Risks related to Covid-19

The Covid-19 outbreak and its effect on the 
global economy have impacted our customers 
and our performance, and the future effects of 
the outbreak remain uncertain. The outbreak 
necessitated governments to respond at 
unprecedented levels to protect public health, 
local economies and livelihoods. It has affected 
regions at different times and to varying degrees 
as it has developed. The varying government 
support measures and restrictions in response 
have added challenges, given the rapid pace of 
change and significant operational demands. 
The speed at which countries and territories will 
be able to unwind the government support 
measures and restrictions and return to 
pre-Covid-19 economic levels will vary based on 
the levels of infection, local governmental 
decisions and access to and ability to roll out 
vaccines. There remains a risk of subsequent 
waves of infection, as evidenced by the recently 
emerged variants of the virus. Renewed 
outbreaks emphasise the ongoing threat of 
Covid-19 even in countries that have recorded 
lower than average cases so far. We continue to 
monitor the situation.

The development of Covid-19 vaccines has 
raised hopes of widespread immunisation being 
achieved by the end of 2021 and government 
restrictions being eased. However, tensions 
could increase as countries compete for access 
to the array of vaccines either under  

development, approved or pending approval, 
while the potential differences in protection 
offered by vaccines and the speed and scale 
with which they can be manufactured and 
distributed may further add to tensions.

The Covid-19 outbreak has led to a significant 
weakening in GDP in many of our markets, 
although regions and sectors have rebounded 
to differing levels from their previous low 
points. Economic consensus forecasts have 
stabilised in recent months and monthly 
changes to the forecasts have become 
smaller, with a partial rebound broadly 
predicted for 2021. However, there is wide 
dispersion in forecasts, and these have yet to 
incorporate fully the adverse effect of the most 
recent stringent government restrictions that 
have been imposed in an increasing number 
of countries. Labour markets in several key 
economies (namely those of the UK and EU) 
may take longer to recover, with 
unemployment rates expected to rise in 2021 
as government support measures are 
discontinued or tapered off.

Notwithstanding the potential for recovery in 
2021, GDP levels are unlikely to return to 
pre-Covid-19 levels until later years in many 
markets. Differing levels of vaccine access 
between markets will also hamper economic 
recovery and could see individual markets 
rebound at different paces. 

While the longer-term effects of the outbreak 
on businesses are uncertain, our financial 
position should allow us to continue to help 
support our customers. The management of 
capital and liquidity remains a key focus area 
and is being continually monitored both at 
Group and entity levels.

The nature and scale of the Covid-19 crisis has 
necessitated strong responses from 
governments, central banks and regulators, and 
the outbreak has also resulted in changes in the 
behaviours of our retail and wholesale 
customers. These factors have impacted the 
performance of our expected credit loss 
models, requiring enhanced monitoring of 
model outputs and use of compensating 
controls, specifically management judgemental 
adjustments based on the expert judgement of 
senior credit risk managers. In addition, we have 
built up our operational capacity rapidly in 
response to government and central bank 
support measures aimed at combating the 
impacts of the Covid-19 outbreak, and have 
been responding to complex conduct 
considerations and heightened risk of fraud 
related to these external programmes.

 For further details on our approach to the risks 
related to Covid-19, see ‘Areas of special interest’ 
on page 116.

Geopolitical and macroeconomic risks

The geopolitical and economic landscape was 
dominated by the Covid-19 outbreak for much 
of 2020 and the virus and its economic impact 
is expected to remain the dominating factor of 
2021. The pandemic contributed to an 
increasingly fragmented trade and regulatory 
environment, and impacted business and 
investor sentiment during a period of 
heightened existing US-China tensions and 
trade negotiations between the UK and the EU.

Central banks reduced interest rates in most 
financial markets due to the adverse impact of 
the pandemic, which has in turn increased the 
likelihood of negative interest rates. Prolonged 
low interest rates and flatter interest rate 
curves in major financial markets continue  
to present risks and concerns, such as our 
readiness to accommodate zero or negative 
rates, the resulting impacts on customers, and 
the financial implications on our net interest 
income.

38

A range of tensions in US-China relations could 
have potential ramifications for the Group and 
its customers. These tensions could include 
divisions over Hong Kong, US funding of and 
trading with strategic Chinese industries, claims 
of human rights violations, and others. Some of 
these tensions have manifested themselves 
through actions taken by the governments of 
the US and China in 2020 and early 2021. These 
tensions may affect the Group as a result of the 
impact of sanctions, including sanctions that 
impact the Group’s customers, as well as 
regulatory, reputational and market risks. The 
US has imposed a range of sanctions and trade 
restrictions on Chinese persons and 
companies, focusing on entities the US believes 
are involved in human rights violations, 
information technology and communications 
equipment and services, and military activities, 
among others. In response, China has 
announced a number of sanctions and trade 
restrictions that target or provide authority to 
target foreign officials and companies, 

including those in the US. Certain measures are 
of particular relevance, including the US Hong 
Kong Autonomy Act. It remains unclear the 
extent to which the new US administration  
will affect the current geopolitical tensions 
following the inauguration of President Biden. 
We continue to monitor the situation.

Investor and business sentiment in some 
sectors in Hong Kong remains dampened, 
although the financial services sector has 
remained strong and has benefited from  
stable liquidity conditions.

The financial impact to the Group of 
geopolitical risks in Asia is heightened due  
to the strategic importance of the region,  
and Hong Kong in particular, in terms of 
profitability and prospects for growth.

 For further details on our approach to geopolitical 
and macroeconomic risks, see ‘Top and 
emerging risks' on page 110.

HSBC Holdings plc Annual Report and Accounts 2020 
Risk overview

UK withdrawal from the European Union

The UK left the EU on 31 January 2020 and 
entered a transition period until 31 December 
2020. A Trade and Cooperation Agreement 
between the EU and the UK was agreed on 24 
December 2020 and ratified by the UK on 30 
December 2020. The deal mainly focused on 
goods and services but also covered a wide 
range of other areas, including competition, 
state aid, tax, fisheries, transport, data and 
security. However, it included limited elements 
on financial services, and, as a result, did not 
change HSBC’s planning in relation to the UK’s 
withdrawal from the EU.

The EU and UK agreed through a joint 
declaration to establish structured regulatory 
cooperation on financial services, with the aim 
of establishing a durable and stable relationship 
between autonomous jurisdictions. Based on a 
shared commitment to preserve financial 
stability, market integrity, and the protection of 
investors and consumers, these arrangements 
are expected to allow for: 

 – bilateral exchanges of views and analysis 
relating to regulatory initiatives and other 
issues of interest; 

 – transparency and appropriate dialogue in 
the process of adoption, suspension and 
withdrawal of equivalence decisions; and 

 – enhanced cooperation and coordination, 

including in international bodies as 
appropriate. 

In the coming months, both parties are 
expected to enter discussions with the aim of 
agreeing a memorandum of understanding 
establishing the framework for this 
cooperation. The parties are expected to 
discuss, inter alia, how to move forward on 
both sides with financial equivalence 
determinations between the EU and UK.

Our global presence and diversified customer 
base should help mitigate the direct impacts 
on our financial position of the absence of a 
comprehensive agreement on financial 

Ibor transition

services between the UK and EU. Our existing 
footprint in the EU, and in particular our 
subsidiary in France, provides a strong 
foundation for us to build upon. As part of our 
stress testing programme, a number of 
internal macroeconomic and event-driven 
scenarios were assessed to support our 
planning for, and evaluation of, the impact of 
the UK’s withdrawal from the EU. The results 
confirmed that we are well positioned to 
withstand potential shocks. However, the UK’s 
withdrawal from the EU is likely to increase 
market volatility and economic risk, 
particularly in the UK, which could adversely 
impact our profitability and prospects for 
growth in this market.

 For further details on our approach to the UK’s 
withdrawal from the EU, see ‘Areas of special 
interest’ on page 116.

Throughout 2020, our interbank offered rate 
(‘Ibor’) transition programme, which is tasked 
with the development of new replacement 
near risk-free rate (‘RFR’) products and 
transition from legacy Ibor products, has 
continued to implement the required IT and 
operational changes necessary to facilitate an 
orderly transition from Ibors to RFRs, or 
alternative benchmarks, such as policy interest 
rates. These changes have enabled HSBC to 
meet regulatory endorsed milestones related 
to product readiness and the clearing 
house-led transition to RFR discounting. 
Additionally, to further support our business 
and our customers, our programme’s scope 
has widened to include additional interest rate 
benchmarks, which now have a plan for 
demise in the near future. The Ibor transition 

programme now covers 12 interest rate 
benchmarks: five London interbank offered 
rate (‘Libor’) currencies; four Asia-Pacific 
benchmarks that reference US dollar Libor; the 
Euro Overnight Index Average (‘Eonia’); the 
Singapore interbank offered rate (‘Sibor’); and 
Turkish Lira interbank offered rate (‘TRLibor’). 

Global business lines, functions and, where 
appropriate, HSBC entities have identified 
financial and non-financial risks related to the 
transition and developed key actions to 
mitigate the identified risks. These risks 
include those associated with the continued 
sale of products referencing Ibor, through 
2020. However, HSBC has actively removed 
certain Ibor referencing products from sale, 
and implemented processes and controls to 

manage the continued sale of Ibor products to 
assist in meeting our clients’ needs. As 
products referencing Ibor continue to be sold, 
and RFR products are developed, 
considerations relating to the enforceability of 
Ibor fallback provisions and the evolution of 
RFR market conventions have increased legal 
and compliance risks. 

Furthermore, the impact of the Covid-19 
outbreak has compressed timelines for client 
engagement and potentially increased the 
resilience risks associated with the rollout of 
new products, transition of legacy contracts, 
and new RFR product sales. 

 For further details on our approach to Ibor 
transition, see ‘Top and emerging risks’ on  
page 110.

Top and emerging risks

Our top and emerging risks report identifies 
forward-looking risks so that they can be 
considered in determining whether any 
incremental action is needed to either prevent 
them from materialising or to limit their effect.

Top risks are those that may have a material 
impact on the financial results, reputation or 
business model of the Group in the year 
ahead. Emerging risks are those that have 
large unknown components and may form 
beyond a one-year horizon. If any of these 
risks were to occur, it could have a material 
adverse effect on HSBC.

Our suite of top and emerging risks is subject 
to review by senior governance forums. In 
January 2020, our top and emerging risk 

themes were streamlined to interconnect 
appropriate thematic risk issues that impact 
our portfolios and business. The themes 
‘geopolitical risk’, ‘the credit cycle’ and 
‘economic outlook and capital flows’ were 
merged into a single theme under ‘geopolitical 
and macroeconomic risks’. We continue to 
monitor closely the identified risks and ensure 
robust management actions are in place, as 
required. In December 2020, change 
execution risk was added as a new thematic 
risk due to the level of change in priorities 
resulting from the Group transformation 
programme and other regulatory or 
remediation programmes.

39

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Strategic report | Risk overview

Risk

Trend Mitigants

Externally driven

Geopolitical and 
macroeconomic risks  

Cyber threat and 
unauthorised access to 
systems

Regulatory compliance 
risk environment, 
including conduct 

Financial crime risk 
environment

Ibor transition

Climate-related risks 

Internally driven

IT systems 
infrastructure and 
resilience

Risks associated with 
workforce capability, 
capacity and 
environmental factors 
with potential impact on 
growth

Risks arising from the 
receipt of services from 
third parties 

Model risk 
management

Data management

Change execution risk

We monitor developments in geopolitical and macroeconomic risk and assess what impacts these may have on 
our portfolios. The Covid-19 outbreak, heightened US-China geopolitical tensions and the UK’s withdrawal from 
the EU have resulted in an unprecedented global economic slowdown, leading to a significant increase in credit 
stress in our portfolio. We have increased the frequency and depth of monitoring activities, and performed 
stress tests and other sectoral reviews to identify portfolios or customers who were experiencing, or were likely 
to experience, financial difficulty as a result.

We help protect HSBC and our customers by continuing to strengthen our cyber defences, helping enable the 
safe execution of our business priorities and the security of our customers’ information. Our data-driven 
approach, grounded in strong controls that help to mitigate advanced cyber threats, enhances our capability 
in threat detection, access controls and resiliency.

We monitor regulatory developments closely and engage with regulators, as appropriate, to help ensure that 
new regulatory requirements are implemented effectively and in a timely way. In addition to developments 
driven by the Covid-19 outbreak, we are keeping abreast of the emerging regulatory agenda, which is 
increasingly focused on diversity, sustainable development, climate change, operational resilience and digital 
services and innovation. 

We continued to support the business and our customers throughout the Covid-19 outbreak, while ensuring that 
our controls remained effective to manage financial crime risk. We progressed with our plans to improve our 
fraud controls and continue to invest in both advanced analytics and artificial intelligence (‘AI’), which remain key 
components of our next generation of tools to fight financial crime. Additionally we continued to update our 
policies and controls in response to new, increasingly complex sanctions and export control regulations, which 
reflected heightened geopolitical tensions.

We remain focused on providing alternative near risk-free rate products, and the supporting processes and 
systems, to replace all outstanding Ibor-linked contracts that are on a demise path. We engage with industry 
participants and regulatory working groups to aid an orderly transition within the required timelines. In light of 
delays in market and client readiness caused by the Covid-19 outbreak, we are engaging and prioritising clients 
for transition of their outstanding contracts linked to Ibors that already have a confirmed demise.

We continue to enhance the identification, oversight and management of climate risk. In 2020, we enhanced  
our climate risk appetite statement with quantitative metrics to articulate the risks from climate change, and 
formalised our overall approach to climate risk management. We also started to integrate climate risk into the 
Group-wide risk management framework (see our TCFD Update 2020 for further information). 

We actively monitor and improve service resilience across our technology infrastructure to minimise service 
disruption to our customers, and enhance our service management disciplines and change execution 
capabilities. We continued to adapt our IT systems during 2020 to support our customers and operations during 
the Covid-19 outbreak.

We monitor workforce capacity and capability requirements in line with our published growth strategy and 
any emerging issues in the markets in which we operate. We have put in place measures to help ensure that 
our people are supported and able to work safely during the Covid-19 outbreak. We are monitoring people 
risks that may arise due to business transformation to help ensure that we sensitively manage any 
redundancies and support impacted employees.

We continue to enhance our third-party risk management programme to help ensure engagements comply with 
our third-party risk policy and required standards. We work closely with providers to monitor performance. In 
2021, we will continue to strengthen our third-party risk framework and improve our technology, process and 
people capabilities.

We continue to strengthen our oversight of models and the second line of defence Model Risk Management 
function. We are embedding a new model risk policy, which includes updated controls around the monitoring 
and use of models. We have developed new model risk appetite measures, which we expect to implement in the 
first quarter of 2021. A redevelopment of our IFRS 9 and capital models is underway to reflect the potential 
effects of the extreme economic shocks and various government support measures as a consequence of the 
Covid-19 outbreak.

We continue to enhance and advance our insights, data aggregation, reporting and decisions through 
ongoing improvement and investments in data governance, data quality, data privacy, data architecture, and 
analytics (including machine learning and AI capabilities). Our work to modernise our data infrastructure also 
continues, building on the Cloud to increase flexibility and scalability and improve our fit-for-purpose data 
while also respecting the evolving regulatory landscape regarding the localisation of data. This is a crucial 
component of effectively managing our risk.

We have established a global transformation programme to oversee all initiatives mobilised to deliver the 
commitments made to restructure the business and reduce costs. The related execution risks are being 
monitored and managed, recognising that many initiatives impact our colleagues and require continued 
investment in technology. We are working to strengthen our change management practices to deliver changes 
efficiently and safely.

Risk heightened during 2020 

 Risk remained at the same level as 2019

40

HSBC Holdings plc Annual Report and Accounts 2020 
Long-term viability and going concern statement

Long-term viability and going 
concern statement

Under the UK Corporate Governance Code, 
the Directors are required to provide a viability 
statement that must state whether the Group 
will be able to continue in operation and meet 
its liabilities, taking into account its current 
position and the principal risks it faces. They 
must also specify the period covered by, and 
the appropriateness of, this statement.

The Directors have specified a period of three 
years to 31 December 2023. They are satisfied 
that a forward-looking assessment of the 
Group for this period is sufficient to enable a 
reasonable statement of viability. In addition, 
this period is covered by the Group’s stress 
testing programmes, and its internal 
projections for profitability, key capital ratios 
and leverage ratios. Notwithstanding this, our 
stress testing programmes also cover 
scenarios out to five years and our assessment 
of risks are beyond three years where 
appropriate:

 – This period is representative of the time 

horizon to consider the impact of ongoing 
regulatory changes in the financial services 
industry.

 – Our updated business plan covers  

2021–2025. 

The Board, having made appropriate enquiries, 
is satisfied that the Group as a whole has 
adequate resources to continue operations for 
a period of at least 12 months from the date of 
this report, and it therefore continues to adopt 
the going concern basis in preparing the 
financial statements. 

Based upon their assessment, the Directors 
have a reasonable expectation that the Group 
will be able to continue in operation and meet 
liabilities as they fall due over the next three 
years.

In making their going concern and viability 
assessments, the Directors have considered a 
wide range of detailed information relating to 
present and potential conditions, including 
projections for profitability, cash flows, capital 
requirements and capital resources.

The Directors carried out a robust assessment 
of the emerging and principal risks facing the 
Group to determine its long-term viability, 
including those that would threaten its 
solvency and liquidity. They determined that 
the principal risks are the Group’s top and 
emerging risks, as set out on page 39. These 
include risks related to geopolitical and 
macroeconomic risks (including in relation to 
Covid-19), which bring a heightened level of 
uncertainty compared with previous years.

The Directors assessed that all of the top and 
emerging risks identified are considered to be 
material and, therefore, appropriate to be 
classified as the principal risks to be 
considered in the assessment of viability. They 
also appraised the impact that these principal 
risks could have on the Group’s risk profile, 
taking account of mitigating actions planned 
or taken for each, and compared this with the 
Group’s risk appetite as approved by the 
Board. At 31 December 2020, there were 
seven heightened top and emerging risks: 
geopolitical and macroeconomic risks; 
financial crime risk environment; Ibor 
transition; climate-related risks; risks 
associated with workforce capability, capacity 
and environmental factors with potential 
impact on growth; model risk management; 
and change executions risks. 

In carrying out their assessment of the 
principal risks, the Directors considered a wide 
range of information including:

 – details of the Group’s business and 
operating models, and strategy;

 – details of the Group’s approach to managing 

risk and allocating capital;

 – a summary of the Group’s financial position 

considering performance, its ability to 
maintain minimum levels of regulatory 
capital, liquidity funding and the minimum 
requirements for own funds and eligible 
liabilities over the period of the assessment. 
Notable are the risks which the Directors 
believe could cause the Group’s future 
results or operations to adversely impact 
any of the above;

 – enterprise risk reports, including the Group’s 

risk appetite profile (see page 107 of the 
Annual Report and Accounts 2020) and top 
and emerging risks (see page 110 of the 
Annual Report and Accounts 2020);

 – the impact on the Group due to the Covid-19 
pandemic, the UK’s departure from the EU, 
tensions between the US and China and the 
situation in Hong Kong;

 – reports and updates regarding regulatory 

and internal stress testing. While the Bank of 
England and European Banking Authority 
cancelled their industry-wide stress test 
exercises in 2020, a number of internal 
stress tests were conducted in 2020, 
including several potential Covid-19 related 
outcomes;

 – reports and updates from management on 
risk-related issues selected for in-depth 
consideration;

 – reports and updates on regulatory 

developments; 

 – legal proceedings and regulatory matters 

set out in Note 34 on the financial 
statements of the Annual Report and 
Accounts 2020; and

 – reports and updates from management on 

the operational resilience of the Group.

Having considered all the factors outlined 
above, the Directors confirm that they have a 
reasonable expectation that the Group will be 
able to continue in operation and meet its 
liabilities as they fall due over the period of the 
assessment up to 31 December 2023.

Aileen Taylor
Group Company Secretary and Chief 
Governance Officer

23 February 2021

41

Strategic reportHSBC Holdings plc Annual Report and Accounts 2020Environmental,  
social and governance  
review

43 

44 

52 

62 

70 

Our approach to ESG

Climate

Customers

Employees

Governance

Our ESG reporting

We have changed how we report this  
year by embedding the content previously 
provided in our stand-alone ESG Update 
within our Annual Report and Accounts.  
This is to further demonstrate that how  
we do business is just as important as what 
we do. In response to the feedback from  
our investors, we are publishing a more 
extensive breakdown of ESG information  
in a supplementary ESG Data Pack for the 
first time alongside the ESG review, which 
can be found at www.hsbc.com/esg.

42

HSBC Holdings plc Annual Report and Accounts 2020ESG review

Our approach to ESG

We have sought to support our stakeholders through an  
unprecedented year, as we set a new climate ambition and  
refined our purpose, ambition and values to reflect our strategy.

About the ESG review 

Our new purpose is: ‘Opening up a world  
of opportunity’. 

To achieve our purpose and deliver our 
strategy in a way that is sustainable, we  
are guided by our values: we value difference; 
we succeed together; we take responsibility; 
and we get it done.

We also need to build strong relationships 
with all of our stakeholders, who are the 
people who work for us, bank with us, own  
us, regulate us, and live in the societies we 
serve and the planet we all inhabit. 

Having a clear purpose and strong values  
have never been more important, with the 
Covid-19 pandemic testing us all in ways  
we could never have anticipated. 

We introduced payment relief measures to  
our customers as part of government-backed 
and our own schemes, which impacted 
87,000 personal accounts and $5.5bn in 
balances, as at the end of 2020. We also 
provided $35.3bn of lending support to  
more than 237,000 wholesale customers.  
For our colleagues, we adapted to new ways 
of working and provided extra support and 
resources to manage their mental and physical 
health. We also announced our climate 
ambition of net zero by 2050, but we know 
this is a journey and that the current means  
of tracking emissions globally need improving.

In this Environmental, Social and Governance 
(‘ESG’) review, we aim to set out our approach 
to our climate, customers, employees and 
governance.

Environmental

 – We announced our net zero climate ambition and increased our climate 

disclosures under TCFD, but we recognise more work is needed as methods  
to measure progress evolve.

 – We surpassed our goal of reducing CO2 per FTE to 2.0 tonnes in 2020, although we 
acknowledge this was mainly due to the consequences of the Covid-19 pandemic.

Read more in the Climate section on page 44.

Social

 – The customer shift to digital accelerated, with 54% of retail customers digitally 
active in 2020. Mobile app downloads of our core business digital platform, 
HSBCnet, rose 146%.

 – An increase in complaints in certain markets reflected a challenging year,  

but we continued to embed new ways of capturing feedback.

Read more in the Customers section on page 52.

 – Employees responded to our Snapshot surveys at a record rate, and our 

employee advocacy rose five points to 71%.

 – We met our target of 30% women in senior leadership roles, and published ethnicity 

data in the UK and US. We recognise we need to take action, and aim to at least 
double the number of Black employees in senior leadership roles by 2025.

Read more in the Employees section on page 62.

Governance

 – Our pioneering scheme to help survivors of human trafficking is used as a model 

for making financial services more accessible.

 – In seeking to safeguard the financial system, we screen over 708 million 

transactions each month for signs of money laundering and financial crime.

Read more in the Governance section on page 70.

How we decide what to measure

We listen to our stakeholders in a number of 
different ways, which we set out in more detail 
within the ESG review. We use the information 
they provide us to identify the issues that are 
most important to them – and consequently 
also matter to our own business.

Social and Governance Reporting Guide 
contained in Appendix 27 to The Rules 
Governing the Listing of Securities on the 
Stock Exchange of Hong Kong Limited)  
to choose what we measure and publicly 
report in this ESG review. 

Our ESG Steering Committee and other 
relevant governance bodies regularly discuss 
the new and existing themes and issues that 
matter to our stakeholders. Our management 
team then uses this insight, alongside the 
framework of the ESG Guide (which refers  
to our obligations under the Environmental, 

Recognising the need for a consistent and 
global set of ESG metrics, we have committed 
to start aligning to World Economic Forum 
core metrics from next year.

Under the ESG Guide, ’materiality’ is 
considered to be the threshold at which  

ESG issues become sufficiently important  
to our investors and other stakeholders that 
they should be publicly reported. We are  
also informed by stock exchange listing and 
disclosure rules globally. We know that what  
is important to our stakeholders evolves over 
time and we will continue to assess our 
approach to ensure we remain relevant in 
what we measure and publicly report. 

 For further information on our approach to 
reporting, see the ‘Additional information’  
section on page 375. 

43

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020 
 
 
ESG review 

Climate

We are powering new solutions to the climate crisis and 
supporting the transition to a low-carbon future, moving to 
carbon net zero ourselves and helping others to do so too.

At a glance

Becoming a net zero bank

Our climate ambition
The transition to net zero carbon emissions 
creates a clear opportunity to set the global 
economy on a more sustainable, resilient  
and inclusive path. We have the ability to 
catalyse a resilient, vibrant future by financing 
the transformation of businesses and 
infrastructure to a low-carbon economy. 

We have a strong track record of leadership  
in the transition to a low-carbon economy.  
In 2017, we committed that we would provide 
and facilitate $100bn of sustainable finance 
and investment by 2025. Since then, we have 
achieved $93.0bn of that goal, launched a 
number of award-winning products and  
been recognised as a leading bank for 
sustainable finance. 

Achieving the scale of change required for the 
world to meet the Paris Agreement goal of net 
zero by 2050 will require us to go further and 
faster. As such, in October 2020, we set out a 
three-part plan to accelerate financing for the 
transition to net zero, underpinned by strong 
governance and risk management. 

 A summary of our fourth TCFD disclosure can  
be found on page 20 in our Strategic Report.  
The full TCFD Update 2020 can be found at 
www.hsbc.com/esg.

To achieve our ambition to be a net zero bank, we can make changes both in  
our own operations and for our customers through our financing portfolio. We 
aim to bring our operations and supply chain to net zero by 2030 or sooner, and 
align our financed emissions to the Paris Agreement goal to achieve net zero by 
2050 or sooner. 

Read more on becoming a net zero bank on page 45.

Supporting our customers through transition

The most significant contribution we can make to solving the climate crisis  
is supporting our customers to decarbonise, while helping to ensure their  
ongoing resilience and prosperity. Our aim is to provide between $750bn and  
$1tn of sustainable finance and investment by 2030 to support our customers  
to transition to lower carbon emissions. 

Read more on supporting our customers through transition on page 48.

Unlocking climate solutions and innovations

We need new ideas to increase the pace of the transition to net zero. We are 
working with a range of partners to increase investment in natural resources, 
technology and sustainable infrastructure. We also plan to donate $100m to a 
programme that will support climate solutions to scale over the next five years.

Read more on unlocking climate solutions and innovations on page 50.

Our approach to sustainability policies

Our sustainability policies help define our appetite for business, and seek to 
encourage customers to meet good international standards of practice. In light  
of our new net zero ambition, we are undertaking a review of our sustainability 
risk policies. We have also removed an exception to our energy policy and are  
a signatory of the Equator Principles.

Read more on our approach to sustainability policies on page 51.

Awards and achievements

Euromoney Awards for Excellence 2020 
World’s Best Bank for Sustainable Finance  
(second consecutive year) 
Asia’s Best Bank for Sustainable Finance 
Middle East’s Best Bank for Sustainable Finance 
Western Europe’s Best Bank for Sustainable 
Finance

The Banker Investment Banking Awards 2020 
Best Investment Bank for Sustainability Finance 
Best Investment Bank for Green/Climate  
Action Bonds 
Best Investment Bank for Sustainable SSA 
Financing

Environmental Finance Bond Awards 2020 
Lead Manager for the Year for Green Bond Bank 
Lead Manager for the Year for Green Bond SSA 
Lead Manager for the Year for Sustainability 
Bond Local Authority/Municipality 
Lead Manager for the Year for Sustainability 
Bond Bank 
Lead Manager for the Year for Social Bond SSA

44

HSBC Holdings plc Annual Report and Accounts 2020 
 
 
 
 
 
Climate

Becoming a net zero bank

Securing the future of our planet – and 
economic resilience and prosperity – depends 
on the transition to a net zero global economy. 
The Intergovernmental Panel on Climate 
Change, a United Nations body, indicated that 
in order to avoid the worst impacts of climate 
change, we need to reduce global greenhouse 
emissions by 45% by 2030, and achieve net 
zero by 2050.

Our net zero ambition
In October 2020, we announced our ambition 
to become net zero in all direct and indirect 
emissions, known as scope 1, 2 and 3 
emissions. We aim to deliver this by achieving 
net zero in our operations and our supply chain 
by 2030 or sooner. We also plan to align our 
financed emissions – the carbon emissions  
of our portfolio of customers – to the Paris 
Agreement goal of net zero by 2050 or sooner. 

We have outlined on the following page a set 
of metrics and indicators against which we 
plan to report progress towards our climate 
ambition. We continue to make regular 
TCFD-aligned disclosures and have published 
our fourth disclosure, a summary of which is 
on page 20. Our stand-alone TCFD Update 
2020 is available at www.hsbc.com/esg. 

We understand that achieving net zero 
requires not just emissions reduction but 
investment in carbon offsets for a balanced 
transition. However, the world currently lacks 
both a globally consistent, future-proofed 
standard to measure financed emissions and  

a fully functional carbon offset market. We are 
working closely with our peers, central banks 
and industry bodies to mobilise the financial 
system around these important goals. 

Reduce, replace and remove
To achieve net zero carbon emissions in our 
operations and our supply chain, we are 
building on the set of reduction targets that 
we set in 2011 to reduce environmental and 
carbon impacts from our operations by 2020. 
Among other achievements, we reduced 
carbon emissions from energy and travel per 
FTE by 49.6% from the 2011 baseline. For 
further details on our progress, see www.
hsbc.com/who-we-are/our-climate-strategy/
becoming-a-net-zero-bank.

For our 2030 ambition, we have three elements 
to our strategy: reduce, replace and remove.  
We plan to first focus on reducing carbon 
emissions from consumption, and then 
replacing remaining emissions with low-carbon 
alternatives in line with the Paris Agreement 
goal of limiting global warming to below 1.5°C. 
We plan to remove the remaining emissions 
that cannot be reduced or replaced by procuring 
high-quality offsets at a later stage. 

We will compare our success against our 
carbon emissions in 2019, including scope  
1, 2 and 3 emissions. We will use 2019 figures 
as a baseline due to the Covid-19 outbreak 
affecting working behaviours, which helped  
to drive further reductions reflected in 2020 
results. For our 2019 baseline, our operational 

emissions were mainly composed of energy 
(approximately 16%), travel (approximately 6%) 
and supply chain emissions (approximately 
78%). We are in the process of reviewing our 
supply chain methodology and we will be 
updating our 2019 baseline, accordingly. We 
will take into consideration cabin class in our 
recording of travel emissions, including the 
baseline, as it represents a more accurate 
representation of our air travel emissions. 

Reducing our operational emissions
In 2017, we committed to achieving 100% 
renewable power across our operations by 
2030, joining other global companies in the 
RE100 initiative. As electricity currently makes 
up 92% of our energy emissions, our aim is to 
reduce electricity consumption by 50% over 
the next 10 years. We plan to then transition 
the remainder to renewable energy. In 2020, 
37.4% of our electricity was renewable, mainly 
due to our power purchase agreements of 
wind and solar energy in the UK, Mexico and 
India. We plan to continue to build our power 
purchase agreements portfolio and expand 
our purchase of green tariffs in markets  
where these are available.

The majority of our travel emissions  
are concentrated in air travel, which fell in  
2020 due to the Covid-19 outbreak. As travel 
restrictions are lifted, we expect our travel 
emissions to rise. However, we will continue to 
encourage the use of technological solutions 
where possible to provide connectivity with 
colleagues and customers. 

Explaining scope 1, 2 and 3 emissions
To measure and manage our carbon emissions, 
we follow the Greenhouse Gas Protocol global 
framework, which identifies three scopes  
of emissions. Scope 1 represents the direct 
emissions we create. Scope 2 represents the 
indirect emissions resulting from the use of 
electricity and energy to run a business. Scope 3 
represents indirect emissions attributed to 
upstream and downstream activities taking 
place to provide services to customers. Our 
upstream activities include business travel and 
emissions from our supply chain including 
transport, distribution and waste. Our 
downstream activities are those related to 
investments and financed emissions.

Scope 2
Indirect

Scope 3
Indirect

Scope 1
Direct

Scope 3
Indirect

Electricity, 
steam 
heating and 
cooling 

Supply 
chain 

Business 
travel

Employee
commuting1

Company
facilities

Company
vehicles

Investments and 
financed emissions

 For further details, see our ESG Data Pack at 
www.hsbc.com/esg.

1 HSBC-sponsored shuttles only

Upstream activities

HSBC Holdings

Downstream activities

45

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Climate

Becoming a net zero bank continued

Working with our supply chain 
As the majority of our emissions are within  
our supply chain, we know we cannot achieve 
our net zero goal without our suppliers joining 
us on our journey. Our supplier emissions are 
currently calculated using a methodology 
based on supplier spend. In 2020, we began 
the three-year process of targeting our largest 
suppliers, representing 60% of our annual 
supplier spend, to encourage them to make 
their own carbon commitments, and to 
disclose their emissions via the CDP supply 
chain programme. This programme will allow 
us to work with our suppliers to understand 
their commitment to carbon emission 
reduction, to educate those that are starting 
their journey, and to collaborate with those 
that are leading in this area. 

Our lending portfolio 
At the heart of our climate plan is a goal  
to align our financed emissions to the Paris 
Agreement goal of net zero by 2050 or sooner. 

Our carbon dioxide emissions in 2020
We report our carbon emissions following 
the Greenhouse Gas Protocol, which 
incorporates the scope 2 market-based 
emission methodology. We report carbon 
dioxide emissions resulting from energy  
use in our buildings and employees’ 
business travel. 

In 2020, we surpassed our carbon emissions 
target of 2.0 tonnes per FTE, achieving 1.76 
tonnes per FTE. This was mainly attributed 
to travel restrictions and the reduction of 
usage of our buildings due to the Covid-19 
outbreak. We also implemented over  
600 energy conservation measures that 
amounted to an estimated energy  
avoidance in excess of 15 million kWh.

In 2020, we collected data on energy  
use and business travel for our operations  
in 28 countries and territories, which 
accounted for approximately 93% of our 
FTEs. To estimate the emissions of our 
operations in countries and territories  

This means making financing decisions  
with a consideration for climate change,  
and intensifying our support for customers  
in their transition to lower carbon emissions.

solutions to help even the most heavy-
emitting sectors to progressively decarbonise, 
while helping to ensure a just and stable 
transition to maintain economic stability. 

In 2017, we pledged to provide and facilitate 
$100bn of sustainable finance and investment 
by 2025 to support our customers as they 
switch to more sustainable ways of doing 
business, and by the end of 2020 we had 
already achieved $93.0bn of that ambition.  
In October 2020, we set ourselves a new 
target of providing between $750bn and  
$1tn in sustainable finance and investment  
by 2030 (for further details, see page 48). 

We will work with our portfolio of customers 
to provide expert advice and support them  
on their transition to lower carbon emissions, 
while taking into account the unique 
conditions for customers across developed 
and developing economies. To do this, we  
will increase our portfolio of transition finance 

where we have operational control and a 
small presence, we scale up the emissions 
data from 93% to 100%.

We then apply emission uplift rates to  
reflect uncertainty concerning the quality 
and coverage of emission measurement and 
estimation. The rates are 4% for electricity, 
10% for other energy and 6% for business 
travel. This is consistent both with the 
Intergovernmental Panel on Climate 
Change’s Good Practice Guidance and 
Uncertainty Management in National 
Greenhouse Gas Inventories and our internal 
analysis of data coverage and quality.

Further details on our methodology,  
our third-party assurance report and 
relevant environment key facts found  
in our ESG Data Pack can each be found  
at www.hsbc.com/esg.

Included within the $100bn facilitation 
total is $2.8bn-worth of advisory services 
on HSBC-issued green/SDG bonds. Our 
green bond report summarises and our 
asset register lists the loans that underpin 
our issuances. The latest report includes 
$1.6bn of balances as at 30 June 2020 
that have been included within the 
financing total. The green report and asset 
register are available at: www.hsbc.com/
our-approach/esg-information/esg-
reporting-and-policies.

Carbon emissions (total and FTE)

1,000,000

)
s
e
n
n
o
t
(

s
n
o
i
s
s
i
m
e

2
O
C

l

a
t
o
T

900,000

800,000

700,000

600,000

500,000

400,000

C
O
2

p
e
r

F
T
E
(
t
o
n
n
e
s
)

4.0

3.5

3.0

2.5

2.0

1.5

1.0

2011 2012 2013 2014 2015 2016 2017

2018

2019 2020

Key:

Total CO

2  emissions (tonnes)

CO per FTE (tonnes)

2 

The 2020 target was set at 2.5 CO2 tonnes/FTE until 2017, 
when the target was stretched to 2.0 CO2 tonnes/FTE

Carbon dioxide emissions in tonnes

Carbon dioxide emissions in tonnes per FTE

Energy consumption in GWh

2020

2019

2020

2019

2020

2019

Total

406,000 530,000

Total

1.76

2.26

Total Group

928

1,050

From energy

363,000 414,000

From energy

1.57

1.76

UK only

247

281

Included energy 
UK

8,000

10,400

From travel

0.19

0.5

From travel

43,000

116,000

46

HSBC Holdings plc Annual Report and Accounts 2020 
 
 
 
 
 
 
 
 
Climate

Becoming a net zero bank continued

Measuring our progress
We are using several metrics to measure our 
progress of our net zero journey, including our 
carbon emissions, renewable energy sourced 
for our operations, balance sheet exposure to 
carbon-intensive sectors and progress made 
against our sustainable finance commitment. 

In 2020, we began to apply PACTA to  
the relevant segments of our loan book, 
starting with the automotive sector, to build 
our knowledge of the tool and improve  
our understanding of its effectiveness and 
limitations (for further details, see page 18 
of our TCFD Update 2020). 

We intend to develop clear, measurable 
pathways to net zero within our financing 
portfolio, using the Paris Agreement Capital 
Transition Assessment (‘PACTA’) tool, which 
measures the alignment of relevant sectors 
with net zero. 

We know this is a journey and recognise  
that the current means of measurement of 
financed emissions globally need improving  
to track reductions better. Over the course  
of 2021, we will be refining our approach  
to financed and supply chain emissions, 

formalising the qualifying criteria for 
sustainable finance, and enhancing  
reporting on investments. 

In the following table, we set out our  
ambition, the metrics and indicators we  
used in 2020 to measure our progress,  
and the metrics and indicators we aim to 
develop in future to measure our progress.

Ambition

Metrics and indicators used in 2020

Becoming a net zero bank1 
Be net zero in our operations 
and supply chain by 2030 or 
sooner

 – CO2 emissions per FTE across scope 1, 2 and 3

 – Absolute CO2 emissions across scope 1, 2 and 3
 – Percentage of renewable electricity sourced

Metrics and indicators to be 
developed in 2021

 – Supply chain emissions

Align our financed emissions 
to achieve net zero by 2050 
or sooner

 – Illustrative PACTA results for our automotive book. (For further

 – Net zero alignment of our

details, see pages 18 and 19 of our TCFD Update 2020.)

financing portfolio

 – Percentage of wholesale loans and advances in high transition

risk sectors. (For a breakdown by sector, see page 9 of our
TCFD Update 2020.)

 – Illustrative impacts of climate scenarios on our transition
risk sectors. (For further details of our scenario analysis,
see pages 14 to 16 of our TCFD Update 2020.)

 – Sustainable finance and investment provided ($bn). (For further

details of our progress, see pages 48 to 50.)

 – Ranking in Dealogic green, social and sustainable bond

league tables2

 – Established HSBC Pollination Climate Asset Management with
the aim to launch the first fund in mid-2021. (For further details,
see page 50.)

Supporting our customers
Support our customers  
in the transition to  
a sustainable future  
with $750bn to $1tn of 
sustainable finance and 
investment by 2030

Unlocking new climate 
solutions
Help transform sustainable 
infrastructure into a global 
asset class, and create a 
pipeline of bankable projects

 – Cleantech investment within our
technology venture debt fund

 – Philanthropic programme
to provide scale to climate
innovation ventures, renewable
energy, and nature-based
solutions

1  Our reported CO2 emissions in 2020 related to energy and business travel. For further details on scopes 1, 2 and 3, and our progress on carbon emissions and 

renewable energy targets, see pages 45 and 46.

2 Dealogic ranking based on apportioned bookrunner value, excluding self-issuances.

47

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Climate

Supporting our customers through transition

Our ability to finance the transformation of 
businesses and infrastructure is key to building 
a sustainable future for our customers and 
society. The most significant contribution we 
can make to this is supporting our portfolio of 
customers to decarbonise within the transition 
to a net zero global economy. 

A leader in sustainable finance
We are a recognised leader in sustainable 
finance, helping to pioneer the market for 
green, social and sustainable bonds and 
attaching ambitious environmental targets  
to business loans. We maintained leadership in 
green, social and sustainable bonds, ranking 
third globally in 2020, according to Dealogic  
on an excluding self-mandated basis. We  
also set up HSBC Pollination Climate Asset 
Management, the first large-scale venture  
to invest in natural capital as an asset class  
(see page 50). We have been recognised  
as the World’s Best Bank for Sustainable 
Finance by Euromoney in 2019 and 2020.

In 2020, we continued to expand the horizons 
of sustainable finance. We helped the Egyptian 
government launch the first sovereign green 
bond in the Middle East and supported Henkel, 
a German household goods company, to issue 
the world’s first plastics reduction bond (see 
page 76). We also issued the first transition 
Islamic bond to enable Etihad, a Middle 
Eastern airline, to become more sustainable 
(see page 266). As we set out below, we are 
intensifying our support to customers as they 
transition to lower carbon emissions. 

Our vision is to help create a vibrant, thriving 
and resilient future that opens up opportunities 
for new skills, ideas and jobs to thrive. Providing 
transition finance solutions, particularly in 
emerging markets where the opportunity  
is greatest, is core to our climate strategy. 

Transition solutions
In 2017, we committed to providing and 
facilitating $100bn of sustainable finance  
and investment by 2025. At the end of 2020, 
we had fulfilled $93.0bn of this commitment, 
comprising $66.9bn through facilitating the 
flow of capital and providing customers 

access to capital markets, and $20.0bn  
in financing and $6.1bn in investments to 
support environmental and social goals. 

Our sustainable finance commitment has 
enabled sustainable infrastructure and energy 
systems, financed the transition towards net 
zero emissions by promoting decarbonisation 
efforts across the real economy, and enhanced 
investor capital through sustainable 
investments. 

We recognise that more and faster action is 
needed to achieve the Paris Agreement goal  
of net zero by 2050 or sooner. That is why in 
October 2020 we announced our ambition  
to provide between $750bn and $1tn of 
sustainable finance and investment over the 
next 10 years. This new commitment builds  
on our 2017 target. Our new commitment 
incorporates sustainable finance and 
investment of $40.6bn in 2020, which also 
contributed to our initial 2017 target, as  
well as additional products of $3.5bn.

Our sustainable finance and investment in 
2020 for our updated target comprises 23% 
green and sustainability-linked lending to 
companies, 9% investments we manage and 
distribute on behalf of investors, and 68% 
facilitating the flow of capital and providing 
access to capital markets.

We have developed and evolved our existing 
data dictionary, taking into consideration  
the principles we developed with UK Finance 
in the white paper ‘Sustainable finance: 
Establishing a principles-based framework for 
the measurement and reporting of multi-year 
commitments’. Our progress will be published 
each year and will seek to continue to be 
independently assured.

 Our revised data dictionary, which includes a 
detailed definition of contributing activities, and 
our ESG Data Pack, which includes our third-party 
assurance letter and the breakdown of our 
sustainable finance and investment, can be found 
at www.hsbc.com/who-we-are/esg-and-
responsible-business/esg-reporting-and-policies.
 For further details of our net zero ambition,  
see www.hsbc.com/who-we-are/our-climate-
strategy/becoming-a-net-zero-bank.

Our approach to climate risk

We continue to improve the identification, 
oversight and management of climate risk. 
In 2020, we enhanced our climate risk 
appetite statement with quantitative 
metrics to articulate the risks from climate 
change, and we plan to develop our risk 
appetite and key indicators iteratively 
through 2021. 

Sustainable finance
We define sustainable finance as:

 – any form of financial service that 

integrates ESG criteria into business  
or investment decisions; and

 – financing, investing and advisory 
activities that support the UN 
Sustainable Development Goals 
(‘SDGs’), in particular taking action to 
combat climate change. The SDGs, 
also known as the Global Goals, were 
adopted by all UN member states in 
2015 as a universal call to action to  
end poverty, protect the planet and 
ensure that all people enjoy peace  
and prosperity by 2030.

We have reviewed and updated these 
definitions to reflect our updated climate 
ambition, which is available at www.hsbc.
com/who-we-are/esg-and-responsible-
business/esg-reporting-and-policies.

$93.0bn 

Cumulative progress since 2017  
on our commitment to provide  
and facilitate sustainable finance  
and investment. 

(Target: $100bn by 2025) 

3rd

Dealogic ranking for green, social and 
sustainability bonds globally in 2020. 

(2019: 2nd)

We also formalised our overall approach  
to climate risk management to integrate 
climate risk into the Group-wide risk 
management framework.

 For further details on climate risk, see our 
TCFD Update 2020 at www.hsbc.com/esg. 

48

HSBC Holdings plc Annual Report and Accounts 2020Climate

Supporting our customers through transition continued

Sustainable infrastructure
Good infrastructure is the backbone of any 
successful society and economy. However, 
addressing climate change requires the world 
– particularly emerging markets – to develop  
a new generation of sustainable infrastructure 
quickly. The OECD estimates that up to  
$6.9tn each year is needed through to 2030  
to achieve this. While many institutions  
have been engaged in mobilising finance  
for this purpose, there remains a significant 
investment gap and lack of adequate, 
bankable projects. Stronger standards are  
also needed to bring investors to the table. 

To help solve for this, we are leading  
the Finance to Accelerate the Sustainable 
Transition-Infrastructure (‘FAST-Infra’) initiative. 
This was established in partnership with the 
International Finance Corporation (‘IFC’), the 
OECD, the World Bank’s Global Infrastructure 
Facility and Climate Policy Initiative under the 
auspices of the One Planet Lab to develop a 
consistent, globally applicable labelling system 
for sustainable infrastructure investment.  
This will aim to ensure that governments and 
project developers embed high ESG standards 
into new infrastructure to access this label. We 
also co-chair the Coalition for Climate Resilient 
Investment, launched at the UN General 
Assembly’s Climate Action Summit in 2019, 
bringing together institutional investors, banks, 
insurers, rating agencies and governments  
to develop risk-informed frameworks and tools 
to integrate and price physical climate risks  
in decision making. 

Responsible and sustainable investment
We offer a broad suite of ESG capabilities 
across asset management, global markets, 
research, wealth, private banking and 
securities services, enabling institutional  
and individual investors to manage risk  
and pursue ESG-related opportunities. 

Our endeavour is to influence the market 
through active engagement on ESG issues. 
We have a dedicated Responsible Investment 
team across developed and emerging 
markets. The team’s activities, along with 
portfolio managers and other investment 

analysts, led to ESG issues being raised in 
engagements with over 2,300 corporate and 
non-corporate issuers in 78 markets in 2020. 
We voted on more than 86,000 resolutions at 
over 8,200 company meetings in 70 markets.

to build our sustainable investment portfolios 
to support the UN SDGs and the Paris 
Agreement. During 2020, we expanded  
the assets in scope of the policy with full 
compliance due in early 2021.

At HSBC Global Asset Management, nearly 
89% of total assets under management were 
invested according to at least one of the seven 
strategies defined by the Global Sustainable 
Investment Alliance, as at December 2020. 

We define sustainable investing as: inclusion, 
which involves strategies that enhance 
portfolio exposure to better ESG performers; 
thematic, where strategies provide exposure 
to transformative environmental or social 
trends; and impact, which are strategies  
linked to tangible societal or environmental 
outcomes/impact.

We launched the Real Economy Green 
Investment Opportunity (‘REGIO’) fund with 
the IFC, and at December 2020 had raised 
$475m to fund green projects in developing 
economies that reduce emissions and meet 
the UN SDG Goals. Through our HGIF Lower 
Carbon Equity and Bond Funds, which are 
available in nine Wealth and Personal Banking 
markets and seven Global Private Banking 
markets, we aim to help investors generate 
long-term total return with a lower carbon 
footprint than reference benchmark indices. 
We expanded our investment offering for 
private banking and wealth clients, including: 
TPG Rise, an impact fund linked to the UN 
SDGs; structured products and certificates of 
deposit where proceeds were used to fund 
green and sustainable development projects; 
and various thematic solutions such as gender 
equality and energy transition.

As a signatory of the United Nations 
Environment Programme Finance Initiative’s 
Principles of Sustainable Insurance, our 
insurance business has continued to 
implement its sustainability policy. The policy 
includes restricting investments that may  
have adverse impacts on people and the 
environment, and incorporating ESG principles 
into our investment governance. We continued 

Embedding ESG into our engagement
Our vision is to support our customers’ 
aspirations to make a positive change in the 
world through wealth value creation. We are 
embedding ESG across client engagement 
and investment solutions in our wealth 
management and private banking businesses. 

We offer a comprehensive range of 
sustainable investment products to help 
clients marry their sustainability and financial 
goals. These include green, social and 
sustainability bonds, investment funds,  
ETFs, discretionary mandates, private market 
investments, structured products and green 
certificates of deposit. Our advisory offering 
also covers securities with substantial 
exposure to environmental themes.

To help customers understand the topic and 
the benefits of investing sustainably, a range 
of educational materials, thought leadership 
publications, and articles on sustainability 
themes are distributed regularly. We partnered 
with the Principles for Responsible Investment 
to develop a training programme for our 
advisers, covering ESG fundamentals, 
investing strategies and client engagement.

We provide our customers with ESG insights 
and foster industry development. HSBC Global 
Research published over 200 climate and  
ESG-related reports in 2020, accompanied  
by approximately 500 client meetings and 15 
client webcasts. Our ESG team works in close 
collaboration with analysts from other asset 
classes and across markets, embedding 
sustainability into research and offering  
a deeper integration approach to a global 
investor client base. The team released  
four episodes of the ESG Brief podcast.  
ESG Insights from HSBC Global Research  
are also repackaged for retail investors as  
a series known as #WhyESGMatters. 

Laying the foundations for a sustainable future

Cement is one of the world’s most socially 
and economically important materials –  
and also among the most highly carbon 
intensive. Long-term change is needed  
to help cement producers reduce their 
environmental impact. Switzerland-based 
LafargeHolcim, one of the largest global 
cement producers, aims to lead its industry 
in becoming greener. 

We helped LafargeHolcim towards its goals 
by playing a major role in the world’s first 
building materials sustainability-linked bond. 
We acted as joint bookrunner on the €850m 
sustainability-linked bond, whose terms 
mean LafargeHolcim must pay a premium  
if it does not meet its target to reduce the 
carbon intensity of the cement it produces 
by 17.5% – from 2018 levels – by 2030. 

49

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Climate

Unlocking climate solutions and innovations  

We understand the need to find new solutions 
to increase the pace of change if the world is 
to achieve the Paris Agreement’s goal of being 
net zero by 2050. We are working closely with 
a range of partners to accelerate investment in 
natural resources, technology and innovations, 
and sustainable infrastructure to reduce 
emissions and address climate change.

Working with our partners 
We know that many investors want to  
invest in companies that can demonstrate 
their ESG credentials. Through philanthropy, 
partnerships and new initiatives our aim is  
to help them invest in protecting the planet,  
with HSBC Global Asset Management  
offering a range of funds for clients to invest  
in businesses and projects that have strong 
ESG track records and ambitions. 

HSBC Global Asset Management also created 
a joint venture in 2020 with Pollination, a 
specialist climate change advisory and 
investment firm. The joint venture, HSBC 
Pollination Climate Asset Management, aims 
to be the world’s largest manager of capital 
invested in natural resources (see box below). 

To encourage more investment in building 
sustainable infrastructure, we are at the 
forefront of an initiative that gives investors 
greater confidence about where their money is 
going. Working with the IFC, OECD, the World 
Bank’s Global Infrastructure Facility and the 
Climate Policy Initiative, under the auspices  
of the One Planet Lab, we helped conceive  
the FAST-Infra initiative. Our collective aim  
is to turn sustainable infrastructure into  
a mainstream asset class. We will aim to 
achieve this by establishing a global labelling 
system that clearly shows investors the 
infrastructure in which they are investing  
is sustainable and contributes to achieving  
the UN’s SDGs.

Backing new technology and innovations
Addressing climate change requires innovative 
ideas. By connecting financing with fresh 
thinking, we can help climate solutions to 
scale to support sustainable growth. Formed 
in 2020, our $100m philanthropic climate 
programme aims to do this and truly transform 
the way we protect our planet, overcoming 
barriers to addressing climate change. We 
provided $7.1m to our non-governmental 
organisation partners during the year to get 
the programme underway.

We intend to expand our technology venture 
debt capabilities to provide $100m of financing 
to companies developing clean technologies 
that can be deployed at scale to support 
businesses and households to transition to a 
low-carbon economy. We will provide further 
updates on cleantech investment and the 
philanthropic programme in 2021.

Skills for a sustainable future
We have a responsibility to invest in the 
long-term prosperity of the communities 
where we operate. We recognise that 
technology is developing at a rapid pace and 
that a range of new and different skills are now 
needed to succeed. For this reason, much of 
our focus is on programmes that develop 
employability and financial capability. We also 
back climate solutions and innovation, and 
contribute to disaster relief efforts based on 
need (see panel on the right).

We also continue to increase knowledge  
on sustainability issues with our people.  
We developed a seven-part online course 
exclusively for our employees in partnership 
with the University of Cambridge Institute  
for Sustainability Leadership. In 2020,  
our colleagues completed more than  
36,700 modules.

Our charitable 
contributions

In 2020, our charitable giving totalled 
$112.7m, including our $25m Covid-19 
donation fund. We also encourage our 
people to volunteer time and share their 
skills, offering paid volunteer days. In 
2020, our colleagues gave over 82,000 
hours to community activities during 
work time.

In 2018, we set out a three-year  
goal to help two million people in our 
communities be more employable and 
financially capable through providing 
more than $100m in charitable 
donations. Current projections from our 
charity partners indicate our support 
reached more than four million people 
through donations of over $115m. This 
funding helped marginalised young 
people prepare for and secure their first 
jobs, supported indigenous people to 
complete their education and gain 
employment, and helped migrant 
workers avoid financial fraud. The 
increased reach from our initial 
projection is due in part to increased 
reach from programmes moving online.

Investing in nature-based projects with Pollination

A key part of our strategy is to unlock new 
climate solutions, helping to transform 
sustainable infrastructure into a global asset 
class. As part of this ambition, we launched 
HSBC Pollination Climate Asset 
Management in August 2020, with the 
vision to create the world’s largest 
dedicated natural capital investment 
manager. The joint venture with Pollination, 
a specialist climate change advisory and 

investment firm, intends to set up funds that 
will invest in a range of nature-based 
projects that protect and enhance nature 
over the long term, and reduce greenhouse 
emissions. The intention is to launch a series 
of natural capital and carbon credit funds for 
institutional investors, with the aim to 
launch the first fund in mid-2021.

50

HSBC Holdings plc Annual Report and Accounts 2020Climate

Our approach to sustainability policies 

We recognise that businesses can have  
an impact on the environment, individuals  
and communities around them. We have 
developed, implemented and refined our 
approach to working with our business 
customers to understand and manage  
these issues.

Our sustainability risk policies seek to ensure 
that the financial services that we provide to 
customers do not contribute to unacceptable 
impacts on people or the environment. We 
seek to analyse the impact of ESG issues  
and follow international good practice in  
these areas. 

We believe that the key to managing 
sustainability risk is creating partnerships  
with our customers, assisting them on their 
transition path to a more sustainable and 
low-carbon economy.

Our policies
Our sustainability risk policies cover 
agricultural commodities, chemicals,  
defence, energy, forestry, mining and  
metals, UNESCO World Heritage Sites  
and Ramsar-designated wetlands. 

These policies define our appetite for business 
in these sectors and seek to encourage 
customers to meet good international 
standards of practice. Where we identify 
activities that could cause material negative 
impacts, we will only provide finance if we can 
confirm customers are managing these risks 
responsibly. Such customers are subject to 
greater due diligence and generally require 
additional approval by sustainability risk 
specialists. We will not provide finance if  
the business activities are not aligned to our 
aims and values. 

Our sustainability policies are being aligned 
with our approach to climate risk as well as 
our net zero commitments, and will be 
enhanced during 2021.

  For further details on how we manage 
sustainability risk as well as our full policies,  
see www.hsbc.com/our-approach/risk-and-
responsibility/sustainability-risk.

Supporting the transition 
At the heart of our net zero plan is an aim  
to align our financed emissions – emissions 
produced by our portfolio of customers – to 
the Paris Agreement goal of net zero by 2050 
or sooner. The most significant contribution 
we can make is to support our customers’ 
transition to lowering carbon through 
transition financing, which is financial support 
that helps heavy-emitting companies take 
action to become more environmentally 
sustainable over time.

To accelerate the global transition to net  
zero, we also want to unlock climate solutions, 
such as cleantech innovation, sustainable 
infrastructure and nature-based solutions. 
These will help smooth a transition and shift to 
a more sustainable economy in the long term. 
As we move closer to 2050, we expect our 
portfolio of financed emissions to reflect this 
and our customers’ business activities to be 
less carbon intensive.

In that light, we are undertaking a review of 
our sustainability risk policies to ensure that 
they will reflect this need to transition and  
the phased reduction of carbon-intensive 
business activities. 

Governance
Within our Global Risk function, we  
have reputational and sustainability risk 
specialists who are responsible for reviewing, 
implementing and managing our sustainability 
risk policies as well as our application of the 
Equator Principles. Our global network of 
more than 75 sustainability risk managers 
supports the implementation of these  
policies. In 2020, these local sustainability risk 
managers were further supported by regional 
reputational risk managers across the Group 
who have taken on additional oversight 
responsibilities for sustainability risk.

We have also established a Sustainability  
Risk Oversight Forum, made up of senior 
members of the Global Risk function and 
global businesses across the Group. 

Equator Principles
The Equator Principles provide a risk 
management framework for determining, 
assessing and managing environmental and 
social risk in projects. We were an early 
adopter of the principles in 2003.

In October 2020, the revised Equator 
Principles framework came into effect, after 
consultation with member banks and external 
stakeholders. In response to the launch of the 
revised framework, we are rolling out updated 
training for staff in 2021 to ensure that Equator 
Principles transactions are properly identified 
and managed. 

We report annually on the transactions 
completed under the principles. Our latest 
Equator Principles report is available at: www.
hsbc.com/who-we-are/our-climate-strategy/
sustainability-risk/equator-principles.

 For further details of our approach to human 
rights, see page 71. 
 For further details of our approach to risk 
management, see page 37.

Our energy policy

When we last updated our energy 
policy in 2018, we stated that we 
would not finance any new coal-fired 
power plants, with the potential 
targeted and time-limited exceptions 
in Bangladesh, Indonesia and 
Vietnam, recognising the need to 
balance local humanitarian needs 
with the need to transition to a 
low-carbon economy.

We therefore agreed that any 
funding of new coal-fired power 
plants in those three countries would 
only be considered subject to certain 
strict criteria. It is important to note 
that we have not provided any 
project finance for any new coal-fired 
power plants anywhere in the world 
since then, including those countries.

In April 2020, we removed these 
exceptions and will not finance  
any new coal-fired power plants 
anywhere globally. We continue  
to support the other needs of our 
customers in these countries and 
continue to support their 
governments.

Within the power and utilities, and 
metals and mining sectors shown  
in our TCFD disclosures on page 19, 
our direct exposure to thermal coal  
is 0.2% of the wholesale loans and 
advances figures.

51

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review 

Customers 

We are bringing the benefits of connectivity and a global 
economy to more people around the world.

At a glance

Digital and technology

Our relationship
We create value by providing the products  
and services our customers need and aim  
to do so in a way that fits seamlessly into  
their lives. This helps us to build long-lasting 
relationships with our customers. We maintain 
trust by striving to protect our customers’ data 
and information, and delivering fair outcomes 
for them. If things do go wrong, we aim to 
take action in a timely manner.

Operating with high standards of conduct  
is central to our long-term success and 
underpins our ability to serve our customers.

In this section, we report on our customers as 
three distinct groups: our wealth and personal 
banking customers; medium and large-sized 
corporate customers; and our global and 
institutional customers. These groups are 
served by our three global businesses 
respectively: Wealth and Personal Banking 
(‘WPB’), Commercial Banking (‘CMB’) and 
Global Banking and Markets (‘GBM’).

Our retail and wholesale customers are using digital services more than  
ever before, with the Covid-19 outbreak accelerating the shift to digital banking. 
We have continued to invest in digital and technology to help make banking 
simpler and safer, and have launched new products and platforms to assist  
and support our customers. 

Read more on digital and technology on page 53.

Customer satisfaction

Through a series of surveys, we aim to listen to our customers to put them at  
the centre of our decision making. We continued to redesign how we receive 
feedback to create a consistent measure of the customer experience and act on 
customers’ feedback. While the roll-out of the full programme was slowed during 
the Covid-19 outbreak, we continue to embed the new ways of working.

Read more on customer satisfaction on page 54.

How we listen

We aim to be open and consistent in how we track, record and manage 
complaints. In 2020, complaints fell across our WPB and GBM businesses  
and were up overall in CMB. Complaint resolution was impacted by staffing 
challenges from the Covid-19 pandemic, while corporate complaints were 
focused on account opening and operations due to increased demand  
for finance.

Read more on how we listen on page 56.

Conduct

We responded to the changing environment and sought to help our customers, 
particularly the most vulnerable, with payment relief measures, lending support 
and improvements to our products and services. The conduct of our people is 
linked to the way we work. We adapted our global training and support for  
our colleagues, updated how we design products and deliver fair value, and 
continued to help customers transition from interbank offered rates.

Read more on conduct on page 58.

52

HSBC Holdings plc Annual Report and Accounts 2020Customers

Digital and technology 

The Covid-19 outbreak meant that many of  
our customers needed to increasingly use our 
services remotely. The significant technology 
investments we made in the years before  
the pandemic to make digital banking easier 
meant we could support the accelerated shift 
to mobile and online channels during 2020. 

For our clients with wealth management 
needs we launched a simplified version of 
Wealth View, an online platform enabling 
easier analysis of their holdings and 
transactions. It is available in Hong Kong, 
Singapore, Luxembourg, the UK, Channel 
Islands and the US.

In 2020, more than nine out of every 10,  
or 92.7%, of our global personal banking 
transactions were done digitally, an increase  
of four points year-on-year. At the same time, 
54% of our retail customers were digitally 
active, an increase of five points from 2019.

Our corporate customers also increased  
their use of our digital services, with mobile 
app downloads of our core business digital 
platform, HSBCnet, growing 146% in 2020.

Throughout the Covid-19 outbreak, we 
continued to invest in technology to help  
our customers to do more of their everyday 
banking online, and we rolled out new 
functionality to support them through the 
pandemic and provide digital solutions for 
their growth ambitions. 

Making banking simpler and faster
During 2020, we completed the initial roll-out 
of new online banking and mobile platforms 
for our retail customers, replacing legacy 
technology across 16 markets, which will  
let us innovate more quickly in the future. 

In 2020, the retail mobile banking app achieved 
an average Apple rating of 4.8 in the UK and 
4.7 in Hong Kong, and an average Android 
rating of 3.8 in the UK and 3.5 in Hong Kong. 

We helped many customers in need of 
support during the economic slowdown.  
On average we deployed digital lending 
portals within six days for business customers 
to be able to apply for government lending 
schemes in the UK, the US and Hong Kong. 

As it has been more difficult to meet in person, 
we introduced customer video meetings for  
all business areas across 47 markets. We also 
continued to expand the use of chatbots to 
support customers with day-to-day queries.  
In WPB, we launched online and in-app chat 
services across eight new markets and there 
were more than 10.5 million chat 
conversations in 2020.

Our improved global online Business Banking 
Experience, used by more than 49,000 
businesses across nine markets, helps 
customers to complete everyday banking 
tasks themselves and run their businesses 
remotely. It has an average customer 
satisfaction score of 9 out of 10.

Helping businesses to grow
We continue to transform our digital platform 
for Global Trade and Receivables Finance, 
HSBC Trade Solutions. We launched trade 
finance and risk mitigation solutions to 2,100 
customers in Hong Kong in November 2020, 
making trade simpler, safer and faster. 

In the UK, HSBC Kinetic, a new mobile 
proposition for SMEs, had 2,899 customers 
onboarded by the end of 2020. Launched  
in June 2020, it enables customers who need 
a business current account or a Business 
Bounceback loan from the UK Government  
to apply online and do their day-to-day 
banking digitally. 

In GBM, we are investing heavily in digital  
and data capabilities to support our clients’ 
growth ambitions and accelerated digital 
needs. In Securities Services, we are 
developing solutions to provide clients with 
fast access to data, and more control of their 
assets and transactions. The monthly usage  
of our API suite, which gives on-demand 
access to data, grew 2,716% in the year to 
December 2020, with a significant increase  
in committed customers.

To help make HSBC even more secure,  
we provide a front-end digital know-your-
customer solution via our SmartServe 
platform, which has been launched in 20 
countries and territories, including the UK, 
UAE, the US, Hong Kong and France.

 For further details of our digital satisfaction 
scores, see page 54.
 For further details of new features we introduced 
to give people more control over their financial 
lives during the Covid-19 outbreak, see page 58. 

Harnessing the 
benefits of blockchain

We are implementing distributed 
ledger technology, including 
blockchain, to improve efficiency, 
transparency and security for clients. 
In global trade, we are using the 
technology to replace the previously 
paper-driven letter of credit process, 
which are the documents 
guaranteeing the seller will be paid.  
It offers a fast and secure alternative, 
which is helping reduce letters of 
credit processing time from between 
five and 10 days to a matter of hours. 

151%

Year-on-year increase in 
wholesale customer mobile 
payments during 2020.

92.7% 

Retail banking transactions 
globally that were digital at 
the end of 2020.

119,782 

Downloads of the HSBCnet 
mobile app in 2020, a 146% 
year-on-year increase. 

53

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Customers

Customer satisfaction

We are continuing to redesign how we receive 
feedback from our customers to put them at 
the centre of decision making.

In 2019, we said we wanted to measure the 
likelihood of customers to recommend HSBC 
across our global businesses, and we now 
have this consistent measure of our customer 
experience to help engage our people and 
improve how we benchmark our performance 
internally and against our competitors. 

Our transition to a new feedback system
What we are trying to achieve goes beyond 
just a measure. It is a way of systematically 
collecting, analysing and acting on our 
customers’ feedback. Across our global 
businesses, it will help us get better  
insight from our customers, build stronger 
relationships with them, and identify and 
prioritise areas where we can improve  
the experience they have with us. 

Through a series of surveys, we ensure we  
are listening to our customers and creating 
insights at all levels of the relationship. We 
create more transparency of the customer 
experience by sharing feedback directly with 
our customer-facing teams and allowing them 
to respond directly to those customers to 
address specific feedback. 

The metric that underpins this new system is 
the net promoter score based on the question: 
‘On a scale on 0 to 10, how likely is it that  
you would recommend HSBC to a friend  
or colleague?’ The score is calculated by 
subtracting the percentage of ‘detractors’, 
who provide a score of 0 to 6, from the 
percentage of ‘promoters’, who provide a 
score of 9 to 10. It can range as low as -100  
to as high as 100.

Although the roll-out of the full programme 
was slowed during the Covid-19 outbreak,  
as we redirected resources to ensure our 
front-line teams could focus on delivering  
for our customers, we continue to embed  
the new ways of working. In 2020, WPB 
launched more than 157 new surveys across 
15 markets. In CMB, we launched elements  
of our programme in the UK, the US, Canada, 
Mexico and India, with more than 30 markets 
planned for 2021. Our GBM business is also 
continually working on ways to collect 
valuable feedback and improve customer 
experience. In 2020, we started conducting 
post-implementation assessments through 
questionnaires, which provide useful insights 
on our performance.

54

How we fared
In 2017, we set ourselves the strategic  
targets to improve customer satisfaction in  
our WPB and CMB global businesses by 2020. 
Both businesses achieved high levels of 
satisfaction in the majority of their respective 
‘scale markets’, although were unable to  
fully achieve their 2020 ambitions to be  
either ranked as top three against relevant 
competitors in these markets, or to have 
improved by at least two ranks compared  
with their 2017 baselines.

Our WPB business, which surveyed more than 
one million customers on their likelihood to 
recommend HSBC and their satisfaction with 
our services, achieved its target in seven of 
our eight scale markets in 2020. Overall, our 
ranking fell below ambition in Malaysia, 
despite our rank position improving during 
2020. Our lower performance than target was 
largely due to ‘the ease of banking with us’ 
compared with our competitors. We are 
carrying out several initiatives to improve its 
performance, including the release of new 
digital features, staff training and a refresh of 
our customer propositions. 

In surveys that we largely conducted of 
customers’ views of our specific services and 
channels, increased market attention, 
geopolitical tensions and market volatility 
impacted scores in mainland China. This trend 
began to reverse due in part to enhanced 
customer communications and a greater 
emphasis on digital assistance. For our 
relationship manager scores, we noted 

7 out of 8

WPB markets sustained top-three rank  
and/or improved in customer satisfaction.

5 out of 8

CMB markets sustained top-three rank  
and/or improved in customer satisfaction.

48

GBM’s overall net promoter score, 
outperforming competitors’ score of 39.

performance below expectations in France, 
where we have ongoing action plans to 
improve communications and drive more 
proactive contact with customers.

In our private bank, our global net promoter 
score fell to nine in 2020, compared with 24 in 
the previous year, largely due to a decline in 
Hong Kong and Switzerland. However, our 
scores improved in Singapore and in France. 
We achieved strong scores for our relationship 
management services, and our approach to 
coping with the Covid-19 outbreak was 
commended in many markets. Key areas 
where our clients would like us to improve 
were our digital and advisory offerings, on 
which we are focusing significant investment.

In CMB, five out of eight tracked markets  
met targets by improving their rank position by 
two places from 2017 or being in the top three 
against competitors, which were Hong Kong, 
the UAE, the Pearl River Delta, Singapore and 
Saudi Arabia in 2020. We declined to fifth 
position in the UK, as we deployed staff to 
Covid-19-related lending schemes impacting 
customer experience in telephony and 
specialist availability in branches. Our rank in 
Mexico remained unchanged at fifth. Similarly, 
in Malaysia, our position remained unchanged 
at sixth, notwithstanding improvement in 
underlying satisfaction scores.

In GBM, our aim is to outperform the average 
competitor score. To measure this, each year 
we partner with Greenwich Associates to 
conduct a relationship level satisfaction 
survey. In 2020, we achieved an overall net 
promoter score of 48, outperforming our 
competitors’ score of 39. We scored 49  
in Asia-Pacific, compared with 32 for our 
competitors, and 44 in the Europe and Middle 
East region, compared with 41 for our 
competitors. However, we scored 54 in North 
America, below our competitors’ score of 73. 

Digital channels
Our customers have increasingly turned to our 
digital services in recent years, a trend which 
was accelerated in 2020 due to the Covid-19 
outbreak. We launched new capabilities and 
digital enhancements in each of our global 
businesses to be closer to our customers and 
support them during the pandemic.

In WPB, we were able to maintain robust 
performance in our digital channels, with an 
improvement in scores in online banking in 
almost all markets compared with 2019. 

This reflects the success of new mobile app 
functionality in the UK, including balance after 
bills forecasting, direct debits and standing 
orders cancellation and in-app overdraft limit 

HSBC Holdings plc Annual Report and Accounts 2020Customers

Customer satisfaction continued

WPB customer satisfaction by channel
(Net promoter score1) 

Branch

Contact centre2

Online banking

Relationship manager

UK

Hong Kong

2020

2019

2020

2019

 62

 62

 57

  42

 39

  36

 57

  57

 48

  41

 4

  2

 58

  45

 49

  25

1  The net promoter score is measured by subtracting the percentage of ‘detractors’ from the percentage of ‘promoters’. ‘Detractors’ are customers who provide a 
score of 0 to 6, and ‘promoters’ are customers who provide a score of 9 to 10 to the question: ‘On a scale on 0 to 10, how likely is it that you would recommend 
HSBC to a friend or colleague’.

2  Hong Kong benchmark data for 2019 is unavailable as the survey methodology changed. The data reported for 2019 is based on January 2020.

management. Customers in the US, Canada 
and the UK gained a view of pending 
transactions, while in Hong Kong and UAE we 
added block and unblock cards capability. We 
introduced digital secure key access and pay 
by instalment in Singapore and Malaysia, and 
launched our HSBC Life Well+ in-app wellness 
and lifestyle programme in Hong Kong.

We faced a temporary technical issue  
related to Bill Pay, a service that allows our  
US customers to pay third-party bills online. 
This affected our digital banking scores, but 
they rebounded once this was resolved. 

In CMB, customer satisfaction with our digital 
services improved in six of the seven markets 
assessed compared with 2019, which were 
Hong Kong, the UAE, Singapore, Malaysia, 
Mexico and the Pearl River Delta. However,  
it fell in the UK, as the significant increase in 
Covid-19-related lending schemes negatively 
impacted turnaround times and our 
customers’ perception of our digital services. 

Despite the difficulties of operating during the 
Covid-19 outbreak, technology enhancements 
introduced during 2020 increased our 
interactions with our customers, helping us  
to provide solutions to their problems, and 
contributed to performing at industry best 
practice levels in our Global Liquidity and 
Capital Management and Global Trade and 
Receivables Finance businesses.

All of our relationship managers were enabled 
to work remotely to support customers from 
home. We introduced digital capabilities that 
were particularly relevant in key markets, 
including remote cheque deposits, a one-hour 
turnaround of shipping guarantees and a 
dedicated trade finance helpline in the UK, and 
electronic signing for key product onboarding 
in Hong Kong. Improvements to our digital 
tools contributed to a 146% year-on-year 
increase in customer downloads of HSBCnet 
mobile in 2020 compared with 2019. Active 
desktop users increased from 400,000 to 
more than 470,000. 

In GBM, the overall satisfaction with our digital 
proposition was strong with 64% satisfaction 
globally, and well ahead of competition in the 
Asia-Pacific, and Europe, Middle East and 
Africa regions, according to our relationship 
level satisfaction survey. Our scores were only 
slightly above our competitors’ score in North 
America. Feedback from clients showed we 
needed to reduce the complexity associated 
with our systems and procedures. To address 
this, we are shifting towards the use of 
technology in our processes, helping to 
remove unnecessary layers while increasing 
efficiency. In 2020, we began the roll-out to a 
small set of customers of HSBC SmartServe, 
an automated centralised service that aims to 
help clients onboard digitally and use services 
with fewer manual transactions.

We also now offer customers the opportunity 
to sign documentation electronically for  
credit and lending, with this service live in  
22 countries at December 2020. We have  
also begun rolling out new soft token  
security solutions. 

Providing support in challenging times

While we have invested in digital and 
technology, it has been important to provide 
effective access to support our vulnerable 
personal customers in our other channels 
during the Covid-19 outbreak. 

Conditions have been challenging for 
in-person interactions at retail branches 
and with relationship managers, which 
hindered performance in some markets, 
such as in Mexico, where a portion of our 
branches remained closed until August 
2020. This affected wait times and staffing 
at open branches. 

Our WPB contact centres recorded strong 
scores during 2020.

In the UK, our WPB business issued new 
telephone security numbers to 1.6 million 
non-digitally active customers. We also 
created a customer line for key workers  
and vulnerable customers, supporting  
more than 1.67 million customers in 2020 
through our contact centres. 

55

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Customers

How we listen 

To improve how we serve our customers, we 
must be open to feedback and acknowledge 
when things go wrong. This was especially 
true during periods of Covid-19-related 
lockdown restrictions when our customers 
encountered new challenges and we needed 
to adapt quickly. 

We aim to be open and consistent in how  
we track, record and manage complaints, 
although as we serve a wide range of 
customers – from personal banking and 
wealth customers to large corporates, 
institutions and governments – we tailor our 
approach in each of our global businesses.

When things go wrong
In 2020, our WPB business received just over 
one million complaints from customers. The 
ratio of complaints per 1,000 customers per 
month in our large markets reduced from  
3.7 to 2.6.

During the year, 73% of complaints were 
resolved on the same or next working day,  
a decline from 77% in 2019, and 80% were 
resolved within five working days, compared 
with 83% in 2019. Complaint resolution was 
impacted predominantly due to staffing 
challenges caused by the Covid-19 outbreak, 
and by our focus on ensuring our customers 
were served safely during this difficult time.

The reduction in complaints in the UK was 
driven in part by the end of the payment 
protection insurance (‘PPI’) complaints 
programme in 2019. Our customers also 
demonstrated a high level of understanding of 
our Covid-19-related challenges. The increase 
in complaints in Hong Kong was related to 
operational stresses due to external events, 
such as the Covid-19 outbreak, economic  
relief measures, social-political sentiments  
and investment market activities. We are 
addressing these by equipping our colleagues 
with home working capabilities, offering 
flexible solutions and enhanced digital 
solutions to improve our customer servicing 
capabilities. In the fourth quarter of 2020, we 
succeeded in bringing down the number of 
complaints by 13% from its peak during June 
to September.

In our private bank in 2020, we received  
572 complaints, an 8% increase on 2019. 
Administration and servicing issues remained 
the largest contributor of complaint categories, 
at 79% in total. Complaints linked to product 
and performance as well as advice and 
suitability were higher than in the previous 
year. This was largely attributable to 
complaints indirectly linked to the  
Covid-19 outbreak.

In 2020, the private bank resolved 557 
complaints, which was a 14% increase from 
2019. We upheld 270 complaints, which  
was a 3% increase on 2019.

Our CMB business resolved 105,215 customer 
complaints in 2020, a 14% increase from 2019. 
Of the overall volumes, 78% came from  
the UK, 16% from Hong Kong and 1%  
from France.

The highest sources of complaints involved 
operations and account opening. This was  
due to the unprecedented demand from 
customers for funding and finance during  
the Covid-19 outbreak through government 
lending schemes and other relief measures, 
which resulted in account opening delays and 
increased call handling times. Recognising  
the impact on our customers, we increased 
automation in our loan application process, 
extended repayment holidays and improved 
processes to escalate and prioritise vulnerable 
customers. We also redeployed resources to 
support increases in call volumes in key 
customer support functions. 

Complaints on operations fell compared  
with the previous year. However, based on 
customer feedback, we are continuing to 
implement changes to reduce payment 
processing errors and delays, most notably  
in the UK and in Hong Kong with several 
digital business banking enhancements, 
including payment notification services. 

An overall increase in the number of 
complaints in Hong Kong was largely 
attributed to the adoption of a more prudent 
complaints definition. This resulted in a 
substantial increase in March 2020, although  
it stabilised from July 2020.

WPB complaint volumes1
(per 1,000 customers per month)

2020

2019

UK

Hong Kong

France

US

Canada

Mexico

Singapore

Malaysia

Mainland China

UAE

2.1

0.6

6.8

2.8

3.8

4.9

1.4

0.5

0.6

4.5

4.5

0.5

7.8

2.9

3.9

5.7

1.3

0.6

0.6

5.1

CMB complaint volumes2 
(000s)

UK2

2020

2019

81.9

78.8

Hong Kong

16.4

5.4

2.7

1.3

1.2

2.4

1

0.9

1.2

1.5

0.9

0.8

Europe

Latin America

US

Middle East, 
North Africa 
and Turkey

Rest of 
Asia-Pacific 
(excluding  
Hong Kong)

Canada

0.5

0.8

1  A complaint is defined as any expression of dissatisfaction, whether upheld or not, from (or on behalf of) a 
former, existing or prospective customer relating to the provision of, or failure to provide, a specific product 
or service activity. 

2  Volumes for the UK are received complaints from eligible complaints aligned to the current FCA reporting 
requirements. Volume of complaints for all other markets, complaint reason breakdown and commentary 
are based on total volumes of resolved complaints.

56

HSBC Holdings plc Annual Report and Accounts 2020Customers

How we listen continued

Our GBM business received 1,432 customer 
complaints, which represented a 14% decline 
compared with 2019, despite the increased 
transaction volumes during the Covid-19 
outbreak in 2020. Our Global Liquidity and 
Cash Management business received the 
most complaints of GBM businesses. This 
corresponds to the nature of the business and 
the high volume of transactions processed 
daily. Despite increased demands as a result  
of the Covid-19 pandemic, Global Liquidity  
and Cash Management demonstrated 
resilience to major shocks and had a reduced 
number of complaints compared with 2019. 

Capturing feedback
We listen to complaints to address customers’ 
concerns and understand where we can 
improve processes, procedures and systems. 

In 2020, we continued to focus on staff 
training in each of our global businesses  
and emphasise the importance of recording 
complaints. This is intended to improve  
our complaint handling expertise and help 
ensure our customers are provided with fair 
outcomes. Complaints are monitored and 
reported to governance forums to ensure  
they are handled quickly and thoroughly. 

In our WPB business, we are using our new 
complaints management platform, which  
we set up in 2018, in seven markets, allowing 
us to deliver a more customer-focused 
experience when managing feedback. We 
have been able to streamline the complaints 
process by simplifying complaints forms and 
procedures, and integrating with our back-end 
systems. We introduced greater automation to 
track complaints from beginning to end and 
provide customers with regular updates. We 
also enhanced our reporting so we can spot 
trends and fix emerging issues more quickly. 

We have also continued our efforts to improve 
the way we capture and report on customer 
complaints in our wholesale businesses. We 
are now piloting a single, overarching tool to 
gather customer feedback for parts of our 
wholesale businesses. The tool enables 
customer complaints to be recorded by 
customer-facing employees across GBM in 
four sites and CMB in one site. This holistic 
approach helps ensure consistent handling  
of complaints and fair outcomes for 
customers. It also makes it easier to identify a 
clear root cause for each complaint, allowing 
detailed thematic analysis, faster resolution 
and more efficient reporting. In 2021, we plan 
to expand the scope of the tool and use it in 
the majority of countries and territories in 
which we operate.

GBM complaint volumes1

2020

2019

Global Banking

309

340

Global Markets 
and Securities 
Services

Global Liquidity 
and Cash 
Management2

363

409

760

919

Total

1,432

1,668

1  A complaint is defined as any expression of 
dissatisfaction, whether upheld/justified or 
not, from (or on behalf of) a client relating  
to the provision of, or failure to provide, a 
specific product or service activity.

2  Global Liquidity and Cash Management 
excludes 1,175 complaints relating to 
payment operations, which is part of  
Digital Business Services.

WPB top complaint categories 
(% of total)

CMB top complaint categories 
(% of total)

GBM top complaint categories 
(% of total)

Process and procedures 43% (2019: 33%)
Service 25% (2019: 24%)
Other1 16% (2019: 29%) 
Fees, rates and charges 9% (2019: 9%) 
Product features and policy 7% (2019: 5%) 

Operations 25% (2019: 26%) 
Account opening 23% (2019: 4%)
Other1 16% (2019: 22%) 
Contact centre 11% (2019: 6%) 
Process and procedures (global standards) 
8% (2019: 27%)
Internet banking 8% (2019: 8%)
Fees, rates and charges 5% (2019: 5%)
Credit risk decisions 4% (2019: 3%)

Process 41% (2019: 34%)
Systems and data 21% (2019: 29%) 
People 20% (2019: 21%)
Other1 18% (2019: 16%) 

1  ‘Other’ in WPB includes issues related to underwriting decisions, claims, personal data privacy, global standards; in CMB, it refers to a wide range of issues, 
including service closures and mobile banking; and in GBM it includes complaints in relation to third parties, as well as legislative and regulatory changes.

57

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Customers

Conduct

We are committed to providing customers 
with products that meet their needs. Good 
conduct at HSBC means that we deliver fair 
outcomes for customers, and maintain  
the orderly and transparent operation of 
financial markets 

Supporting our customers responsibly
We responded rapidly to the changing 
environment caused by the Covid-19  
outbreak and revised our internal policies and 
procedures to help our customers – especially 
the most vulnerable – fairly and safely.

In this section, we address how we 
endeavoured to help our customers in each  
of our global businesses during a difficult year, 
which included the global Covid-19 pandemic. 

17

Number of major markets where we 
introduced payment relief measures for  
our personal and wealth customers.

>237,000

Wholesale customers supported globally  
with $35.3bn of lending through both 
government schemes and our own  
initiatives at the end of 2020.

21,000

GBM colleagues who completed virtual 
conduct training in 2020.

Many of our personal banking and wealth 
customers needed financial relief as a result  
of the economic slowdown caused by the 
Covid-19 outbreak, which we sought to 
address in a responsible way. At 31 December 
2020, we had active payment relief measures 
impacting 87,000 accounts and $5.5bn in 
balances as part of market-wide schemes and 
our own payment holidays programmes. This 
consisted of $4.7bn of mortgage balances and 
$850m of other personal loans in repayment 
relief, compared with $21.1bn of mortgage 
balances and $5.2bn of other personal loans  
at the end of June 2020. To ensure customers 
were financially prepared, we followed local 
government guidelines. In the UK, we 
extended the payment relief scheme into 
March 2021 for customers who have not had  
a payment holiday, in line with local furlough 
timeframes.

In select markets, we used our digital 
messaging capabilities to inform customers 
about available financial help to reach more 
people more quickly. We also made the 
payment relief applications available online 
and offered support to customers through our 
chat functions, to enable a quick turnaround  
of payment relief requests. We responded 
quickly and flexibly to change our products  
for customers, adding insurance coverage  
for people whose health had been affected  
by Covid-19 in Hong Kong, mainland China, 
Singapore and Mexico, and extended the 
grace period for premium payment deferral in 
these countries as well as in France, the UK 
and Argentina. 

While our digital services can support  
many of our customers, we were proactive in 
supporting the most vulnerable. In the UK, we 
identified customers who were at risk of being 
vulnerable during the Covid-19 outbreak, and 
conducted 565,780 outbound care calls  
to update them on safe options to access 
banking services, including access to 
emergency cash and the available payment 
relief options. 

Global and country operational teams 
transitioned resources to homeworking 
throughout the period to ensure customer 
service levels were maintained with minimal 
disruption. Flexible resourcing and training 
was undertaken to allow staff to move from 
branches to call centres to support customers. 

58

Seeking solutions with 
our ‘Covid bundle’

We aimed to reach more of our 
personal and wealth customers in 
innovative ways during the Covid-19 
outbreak, which contributed to 
higher demand for banking services 
due to its economic impact. Our 
‘Covid bundle’ project aimed to 
support our customers in our most 
affected markets through new 
features, capabilities and initiatives. 
In addition to providing customers in 
financial need a variety of payment 
options, we upgraded our telephony 
services and conversational 
capabilities on mobile and web chat 
to improve how we routed queries 
on forbearance and collections to 
our relevant front-line colleagues. 
This helped support our customers 
more quickly and mitigate the 
increased demand on our other 
front-line operational colleagues.

HSBC Holdings plc Annual Report and Accounts 2020Customers

Conduct continued 

Prior to the Covid-19 outbreak, we increased 
our focus on identifying vulnerable customers 
in the UK, but this meant that our teams  
who service vulnerable customers in financial 
difficulty became much busier, resulting in a 
backlog of customer requests. In response,  
we added more staff to these teams, trained 
them and are working to resolve the backlog. 

We also focused on training and coaching our 
customer-facing colleagues to meet the needs 
of customers who were made vulnerable due 
to having difficulties making payments.

Responding to business needs
Our CMB and GBM businesses introduced 
several measures to support our customers, 
many of whom faced pressures in their 
finances as lockdown restrictions impacted 
their businesses. As at the end of 2020, the 
lending support we provided to more than 
237,000 wholesale customers globally was 
valued at $35.3bn, both through government 
schemes and our own initiatives. We offered 
repayment holidays to help businesses 
respond to cash flow pressures and provided 
trade finance solutions to support customers 
with their supply chains. 

We launched online portals for customer 
applications to various government-initiated 
loan schemes, and set up a global team  
to help oversee the provision of the loans, 
expediting the turnaround of loan requests 
and getting funds to our customers quicker.  
In the UK, a dedicated Covid-19-related phone 
line supported our customers by conveying 
what financial guidance and support is 
available to them. In order to help identify  
and mitigate any potential fraud associated 
with the Bounce Bank Loan Scheme, our UK 
Commercial Banking business is also part of 
an industry-wide fraud collaboration working 

group, which has been set up by UK  
Finance and includes other lenders and 
government bodies. 

In our GBM business, we focused on making 
responsible lending decisions and extending 
credit to corporate and institutional customers. 
We also sought to protect the integrity and 
flow of both internal and customer data,  
while maintaining an operationally resilient 
infrastructure. Relationship managers were in 
regular contact with customers, helping to 
ensure they received the most suitable 
support for their business.

Our Global Liquidity and Cash Management 
business, which helps our corporate clients 
access, manage and move their cash, 
provided urgent payment facilities to mobilise 
clients’ cash where it was needed most,  
and helped them move rapidly to digital 
solutions. This included fast-tracking 
payments for urgent medical supplies  
from China to hospitals in Italy and enabling 
cashless, socially distanced payments  
for drive-through testing sites in Malaysia. 
Global Liquidity and Cash Management also 
launched a green deposit proposition during 
2020 in the UK, Singapore and India, which 
involved allowing treasurers to make deposits 
that we use to finance environmentally 
beneficial initiatives, such as renewable  
energy and energy efficient projects. 

Our Markets and Securities Services business 
provided additional guidance around pricing 
decisions in 2020, in light of heightened credit 
risk and remote working arrangements. We 
put in place measures and guidelines to help 
ensure information continues to be monitored 
effectively and controlled in the new working 
environment. 

While working remotely, our Global Research 
team enhanced its review processes to 
provide timely research on economics, 
currencies, fixed income and equities, helping 
our institutional, government, corporate and 
central bank clients, as well as colleagues, 
navigate the extremely complex and fast-
moving situation. We also increased the 
number of research products made freely 
available to help those affected by the crisis  
on a wide variety of platforms.

Digital support
We continued to invest in our digital services 
and tools to support our customers and 
colleagues, delivering initiatives to make 
banking with us simpler and more efficient, 
and we made greater use of online 
appointments and video calls to enable  
our workforce to work from home. 

We launched new features in each of our 
businesses so we could handle crucial 
everyday activities remotely, such as 
onboarding. 

In WPB, new digital features included allowing 
customers to activate cards and cancel regular 
payments through our mobile apps in select 
markets. Our CMB and GBM businesses  
each enabled key documents to be sent and 
received with paperless instructions, enabling 
digital sign-offs and eliminating the need for 
physical signatures. 

We also rolled out globally our digital platform 
‘Vital Insights’ in CMB following a pilot in 
Asia-Pacific, which helped enable us to 
understand the impact of Covid-19 on our 
customers and to take relevant action to  
help them manage uncertainty.

Conduct of our colleagues

The conduct of our people is inextricably 
linked to the way we work.

In WPB, in response to the Covid-19 
outbreak, we adapted and reprioritised 
global training, and rolled out well-being 
programmes and tools, such as coaching 
plans to support virtual working to ensure 
our teams had the resources they needed  
to work safely and productively. 

We also remodelled our incentive 
programme scorecards to allow for 
flexibility, to help our colleagues focus  
on our customer needs, ensuring they  
can provide the appropriate solutions  
as a result of the pandemic.

In our CMB and GBM businesses, we issued 
guidance to our colleagues on remote 
working to help maintain high standards of 
conduct, adhere to competition law, and 
manage potential conflicts of interest.

In GBM, classroom-based conduct training 
was adapted for virtual learning, with more 
than 21,000 colleagues completing the 
curriculum in 2020. Cultivating a positive 
working culture is central to the well-being 
of our colleagues and the performance  
of our business. We introduced culture 
ambassadors, set up new communication 
channels for interactions with senior 
management, and established various 
well-being programmes.

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ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Customers

Conduct continued

Delivering fair outcomes with  
our products
We are committed to providing customers 
with products that meet their needs. We have 
policies and procedures to help deliver fair 
outcomes for our customers, and to maintain 
orderly and transparent financial markets. 
Conduct principles are embedded into the way 
we develop, distribute, structure and execute 
products and services. We are refreshing our 
approach to conduct arrangements across the 
Group with a view to ensuring that the 
arrangements remain appropriate for the 
nature of our business.

Product design and development 
Our approach to product design and 
development entails the following  
overarching principles: 

 – We offer a carefully selected range of 

products that are continually reviewed to 
help ensure they remain relevant in each 
country they are offered and perform in  
line with expectations we have set. Where 
products do not meet our customers’ needs 
or no longer meet our high standards, 
improvements are made or they are 
withdrawn from sale.

 – Wherever possible, we act on feedback 

from our customers to provide better and 
more accessible products and services.

 – We complete regular assessments of our 
products to help ensure we continue to 
deliver fair value.

Oversight of product design and sales 
governance for each of our global businesses 
is provided by governance committees 
chaired and attended by senior executives 
who are accountable for ensuring we manage 
our related non-financial risks appropriately, 
within appetite and in a manner designed to 
ensure fair customer outcomes. 

Our CMB business considers customer 
feedback and user groups in its product 
development and has invested in the 
development of a new global product 
inventory and lifecycle management system  
to help ensure optimal product governance. 
The system uses Cloud technology to provide 
an improved way of managing our products 
from approval through to demise, and has 
been successfully piloted in our Global Trade 
and Receivables Finance and Global Liquidity 
and Cash Management businesses. The 
system, which we plan to deploy to all CMB 
markets within 2021, will help us to bring 
appropriate products to market more quickly, 
as well as helping to ensure we can more 
easily demonstrate fair customer outcomes. 

In our GBM business, we made strides to 
further improve pricing transparency. We 
launched the first phase of our strategic 
foreign exchange margin management tool 
across 1.1 million wholesale customers in 
Singapore, the UAE, Australia and the UK.  
The tool provides customers who make  
or receive payments that require foreign 
exchange conversion with consistent pricing 
and improved transparency of information 
across our various banking channels. 

Transitioning away from Ibors 

As a result of the planned cessation of the 
London interbank offered rates (‘Libor’), Euro 
Overnight Index Average (‘Eonia’) and other 
benchmarks actively known as Ibors, we are 
ensuring that we have the product capability 
in place to support our customers on the 
transition to alternative rates. We aim to 
clearly outline the options available to our 
customers holding existing Libor-based 
products, and our commercial strategy is 
designed to minimise value transfer when 
transitioning their products from Libor  
to alternative rates.

In October 2020, we launched loans using 
the Sterling Overnight Index Average 

(‘Sonia’) benchmark administered by  
the Bank of England, which means that 
customers wanting to borrow on sterling 
Libor now have the option to borrow  
against Sonia instead. 

We began offering Secured Overnight 
Financing Rate (‘SOFR’) loans as an 
alternative to US dollar Libor in the US, 
Hong Kong and the UK in 2020. Further 
products, notably derivatives, and country 
roll-outs are scheduled in 2021. 

 For further details on the transition from  
Ibors, see ‘Ibor transition’ in the Risk section 
on page 112.

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HSBC Holdings plc Annual Report and Accounts 2020Customers

Conduct continued 

Ensuring sales quality
In our WPB business, to help ensure  
the quality of our sales process and our 
colleagues’ behaviour in each of our markets, 
we conduct a mystery shopping programme 
and/or a sales quality programme. Issues 
identified are treated seriously.

We will take action to help achieve a fair 
outcome for our customers. Where concerns 
are found, we will contact the customer to 
apologise, explain and remediate. Depending 
on the severity of the issue, the relevant 
employee will be given enhanced training to 
improve their behaviour and they may become 
ineligible for an incentive reward payment. 
Where a case of misconduct occurs, 
disciplinary action may be taken, which  
can lead to dismissal.

In CMB, for our smaller business clients,  
we operate sales outcomes testing in 12 
markets to ensure we correctly explain 
important product features, pricing, risks  
and benefits. In 2020, we identified 65 issues 
related to documentation, sales process and 
pricing, as well as some wrong customer 
outcomes. We ensured appropriate customer 
remediation took place along with the 
necessary internal action to resolve the 
situation. We plan to expand sales outcome 
testing to a further six sites in 2021.

Meeting our customers’ needs 
We have robust oversight of the sales  
process, which aims to meet our customers’ 
needs effectively. This involves reviewing  
the ongoing suitability of the products and 
services we offer and monitoring sales quality 
as well as examining how we incentivise  
our colleagues (see box below).

Given the varying levels of customer 
sophistication and associated exposure to 
vulnerability in our CMB business, in 2020  
we developed a globally consistent approach 
to ensure we can more effectively identify  
and support customers who are deemed 
potentially vulnerable, with a particular focus 
on sole traders and small and medium-sized 
enterprises. 

In our WPB business, we consider our 
customers’ financial needs and personal 
circumstances to assist us in offering  
suitable product recommendations. This  
is achieved through:

 – a globally consistent methodology to  

rate the riskiness of investment products, 
which is customised for local regulatory 
requirements;

 – a thorough customer risk profiling 

methodology to help assess customers’ 
financial objectives, attitude towards risk, 
financial ability to bear investment risk,  
and their knowledge and experience;

 – robust testing during the design and 

development of a product to help ensure 
there is a clearly identifiable need in  
the market; and

 – consistent standards to follow when we 
provide advice to our customers, while 
taking into account local regulations.

We realise that some circumstances can put 
customers in a vulnerable position, so we are 
training our colleagues to recognise and treat 
these individuals fairly. 

Lessons learned from  
the FX DPA 

In 2018, we entered into a three-year 
deferred prosecution agreement with the 
US Department of Justice arising from its 
investigation into HSBC’s historical foreign 
exchange activities (‘FX DPA’). Since then, 
we have significantly raised our standards 
of conduct and strengthened our controls. 
We have introduced systems and 
enhanced procedures to monitor how we 
execute client transactions, carried out 
extensive conduct-focused training and 
built a conduct-led culture. As a result, the 
FX DPA has now expired, although the 
process to formally dismiss the underlying 
criminal charges will continue for several 
months. Our corresponding 2017 Consent 
Order with the US Federal Reserve Board 
remains in force and going forward we 
seek to continue to implement further 
reforms and we aim to ensure that they are 
effective and sustainable in the long term.

Managing front-line employees and their incentives

In our WPB business, we provide training  
to our employees through our Product 
Management Academy, with more than 
2,000 of our colleagues completing over 
5,200 courses since 2017, including on 
customer insight, customer-focused design, 
communications, product development  
and governance.

We also use a discretionary approach  
to incentivising our front-line colleagues 
instead of a straight formula linked to sales. 
This global improvement has resulted in a 
more balanced performance assessment  
for our people. We have since reviewed  
the incentives approach during 2020 to 

establish opportunities to be even more 
customer-centric, have greater focus on 
employee development and simplify the 
framework. We have also strengthened our 
approach to third-party sales agents that 
distribute our products, such as insurance, 
to ensure that our principles on balanced 
reward are in place. While there is still more 
to do, this change is designed to improve 
oversight and alignment with third-party 
sales agents.

61

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review 

Employees

We are opening up a world of opportunity for our colleagues by building 
an inclusive organisation that prioritises well-being, invests in learning and 
careers and prepares our colleagues for the future of work.

At a glance

The future of work 

Our culture
Our organisation has been shaped by the 
many cultures, communities and continents 
we serve, with over 226,000 full-time 
equivalent employees (‘FTEs’) in 64 countries 
with 168 nationalities. We were founded on 
the strength of different experience and we 
continue to value that difference. We strive  
to champion inclusivity to better reflect the 
worlds of our customers and communities. 
Our culture is underpinned by our values: we 
value difference; we succeed together; we 
take responsibility, and we get it done. 

 For further details on region, age, ethnicity, 
tenure and employment type of our workforce, 
see the ESG Data Pack at www.hsbc.com/esg.

The Covid-19 outbreak taught us many roles can be undertaken effectively 
outside of our branches and offices, accelerating our focus on enabling greater 
flexibility in future working arrangements. Reskilling is also a key priority for us 
and we are investing in a programme to build future skills as we transform the 
structure of our business. 

Read more on the future of work on page 63.

Inclusion 

While there have been many new challenges during the Covid-19 outbreak,  
we continued our emphasis on inclusion. We believe that diversity makes us 
stronger, and we are dedicated to building a diverse and connected workforce. 
We made good progress on gender diversity and increased our focus on ethnicity 
and supporting our Black colleagues. 

Read more on inclusion on page 64.

Well-being 

We provided extra resources to help colleagues manage the mental and physical 
health challenges caused by the Covid-19 outbreak. We carried out two global 
well-being surveys of our colleagues in 2020, helping to shape our response and 
ensure we had the right assistance in place.

Read more on well-being on page 66.

Learning and skills development 

We have continued to find new ways to support colleagues’ learning and growth, 
transitioning to on-demand and digital platforms. We are also using video 
technologies to collaborate across boundaries more than ever before. 

Read more on learning and skills development on page 67.

Listening to our colleagues

We believe in the importance of listening to our colleagues and seeking 
innovative ways to encourage colleagues to speak up. We monitor how  
we perform on selected metrics and benchmark against our peers. 

Read more on listening to our colleagues on page 68.

62

HSBC Holdings plc Annual Report and Accounts 2020Employees

The future of work 

We expect the way our colleagues work to 
change as the workforce of the future meets 
new demands. Colleagues will be using new 
skills we have helped them to develop, and 
working more flexibly to support a better 
work-life balance. 

Adapting how we work 
The Covid-19 outbreak tested our colleagues 
in many ways and they adapted at pace in this 
fast-changing environment. 

In branches, we introduced social distancing 
measures, provided personal protective 
equipment, reduced operating hours and 
offered virtual appointments. For office 
workers, we made sure cybersecurity controls 
and software supported home working.  
In 2020, we delivered laptops, desktops or 
virtual desktop infrastructure to over 78,000 
colleagues and had at points up to 70% of our 
whole workforce working from home at the 
same time. For some of our colleagues, we 
changed their roles, asking them to undertake 
activities that were outside of their normal 
activities (see box). We took an early decision 
not to furlough colleagues in the UK or apply 
for government support packages for our 
employees throughout 2020.

Our businesses are thinking about how we 
adapt to the future of work. As our offices 
reopen we expect to see a much greater 
degree of hybrid working, recognising that 
some roles and groups, such as regulated 
roles and new graduates, will need to spend 
more time in the office than others. We expect 
a change in the way we use our office space, 
recognising the work-life balance and 
environmental benefits of hybrid working 
arrangements.

The Covid-19 outbreak also impacted turnover, 
with 2020 recording the lowest voluntary 
turnover in the last 10 years at 8%, down  
three percentage points on 2019. The rates 
gradually declined month on month from  
April as the pandemic became more of a 
global challenge. Historically, voluntary 
turnover has on average been closer to  
11%, and has remained largely flat at this  
rate over recent years. 

Building the skills of the future 
We have developed a flagship Future Skills 
programme to prepare our colleagues for  
the changing skills required in the future 
workplace. We want our employees to take 

greater ownership of their development and 
invest time in learning new skills. We  
are creating an innovative internal talent 
marketplace through new technology  
that helps improve career development  
by matching the skills and aspirations of  
our colleagues with business needs  
and opportunities. 

Managing change 
Our three-year transformation programme, 
launched in February 2020, is accelerating  
the delivery of our strategy by creating a 
simpler, more customer-centric and future-
focused bank.

We work hard to ensure our colleagues 
understand the reasons for change and how 
they might be affected. We communicate 
through our managers, supported by our 
transformation programme website, which 
explains our plans and rationale in each of our 
global businesses and functions, and we are 
committed to engaging meaningfully with our 
employee representative bodies. We ask our 
businesses to apply global guidance when 
carrying out changes to how we work to 
ensure a fair and consistent experience for our 
colleagues. We also provide mental health 
support guidance to managers to ensure they 
are mindful of the psychological impact of 
change for our colleagues and know how to 
access help. During the height of the Covid-19 
outbreak, we paused the vast majority of 
redundancy activity.

We redeploy our colleagues impacted  
by change where possible. During 2020,  
we restricted external hiring and retained 
employees in preference to contractors so that 
internal talent came first wherever possible. 
We have made it easier for our colleagues 
affected by the transformation programme  
to find alternative roles with us by creating a 
dedicated platform on which their CVs are 
directly visible to internal recruiters. Of those 
whose roles became redundant in 2020, 14% 
were able to find new positions within HSBC. 
We provide skills development, career 
transition support and education for all our 
colleagues, including those who leave as a 
result of the transformation programme. We 
will aim to continue to retain and reskill our 
colleagues as much as possible over the next 
two years of the programme but where we 
cannot we provide severance payments in 
many locations that exceed statutory 
minimum levels. 

Adapting to a 
changing environment

Many of our colleagues have needed 
to adapt to the challenges brought 
about by the Covid-19 outbreak,  
and in some cases took on new 
responsibilities. In the UK, we asked 
colleagues to volunteer to undertake 
activities that were outside of their 
normal roles to meet the changing 
needs of our customers. This helped 
to keep many of our colleagues 
working during these extraordinary 
times. When we reduced branch 
opening times, over 1,000 UK branch 
staff worked in other business areas 
supporting activities such as 
processing Bounce Back loans to 
businesses, helping customers access 
loan repayment holidays and 
supporting with card disputes. 

70%

Workforce working from  
home at the same time  
during the Covid-19 outbreak.

8%

Voluntary employee turnover.

(2019: 11%)

63

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Employees

Inclusion 

Our customers, suppliers and communities 
span many cultures and continents. We 
believe this diversity makes us stronger,  
and we are dedicated to building a diverse  
and connected workforce where everyone 
feels a sense of belonging. 

Women in senior leadership
In 2018, we committed to reach 30% women 
in senior leadership roles by 2020, which are 
classified as 0 to 3 in our global career band 
structure. We achieved 30.3%. Appointments 
of external female candidates into senior 
leadership reduced from 33.0% in 2019 to 
31.6% in 2020. We will continue efforts to build 
more gender-balanced leadership teams and 
have set ourselves a target to achieve 35% 
women in senior leadership roles by 2025.

To diversify the talent pipeline, every member 
of our Group Executive Committee, as well as 
many members of their management teams, 
actively sponsor colleagues from under-
represented groups, including women.  
We paid specific attention to how we select 
and promote candidates for roles and how 
colleagues can readily access opportunities.

In 2020, we expanded the Accelerating into 
Leadership programme to all businesses and 
functions. The programme provides group 
coaching, networking and development for 
high-performing women at manager level, 
which are those at level 4 in our global career 
band structure. Our Accelerating Female 
Leaders programme, which focuses on 
developing high-performing women at level 3 
in the global career band structure, was 
attended by four times as many women  
in 2020 than in the previous year. 

Focus on UK gender and ethnicity  
pay gaps 
In 2020, our median aggregate UK-wide 
gender pay gap, including all reported HSBC 
entities, was 48%, and our median bonus gap 
was 57.9%. Our overall UK gender pay gap  
is driven by the shape of our UK workforce. 
There are more men than women in senior and 
high-paid roles, and more women than men in 
junior roles, many of which are part-time. 

For the first time we also published our UK 
ethnicity pay gap. Our median aggregate 
UK-wide ethnicity pay gap across all reported 
HSBC entities was -5.6%. Our median bonus 
gap was 0.8%. However, the pay gaps differ 
depending on the underlying ethnic minority 
group. The businesses and roles which 
employees from different ethnic groups work 
in impact the gaps, with relatively lower 
representation of ethnic minority employees in 
senior, higher paid roles. While 79% of our UK 
employees have declared their ethnicity, fewer 
senior, higher paid employees have done so  
to date and were therefore not included in our 
ethnicity pay gap analysis.

We intend to publish ethnicity representation 
and pay gap data annually to help ensure we 
continue making progress and help us identify 
further areas for action.

We review our pay practices regularly and  
also work with independent third parties to 
review equal pay. The most recent exercise 
was undertaken in 2020. If pay differences  
are identified that are not due to objective, 
tangible reasons such as performance or skills 
and experience, we make adjustments.

 Our complete Gender and Ethnicity UK Pay Gap 
Report 2020, along with more information about 
our pay gaps and related actions, can be found at 
www.hsbc.com/who-we-are/our-people-and-
communities/diversity-and-inclusion.

Gender balance
All employees

Senior leaders2

Gender diversity statistics1,2 

Holdings 
Board

Group 
Executive 
Committee

9

5

13

3

Combined 
executive 
committee and 
direct reports

141

62

Senior 
2019
leadership

Senior 
leadership 
WPB

Senior 
leadership 
CMB

Senior 
leadership 
GBM

Senior 
2019
leadership 
Digital Business 
Services

6,621

2,875

1,059

545

710

300

2,218

635

732

285

All
employees

111,422

119,618

Male 

Female

64%

36%

81%

19%

69%

31%

70%

30%

66%

34%

70%

30%

78%

22%

72%

28%

48%

52%

1  Combined executive committee and direct reports 

includes HSBC executive Directors, Group 
Managing Directors, Group Company Secretary 
and Chief Governance Officer and their direct 
reports (excluding administrative staff). 

2  Senior leadership refers to employees performing 
roles classified as 0, 1, 2 and 3 in our global career 
band structure.

Percentage of our senior 
leadership who are women

30.3% 

(2019: 29.4%)

Male 48% (2019: 48%)
Female 52% (2019: 52%)

Male 70% (2019: 71%)
Female 30% (2019: 29%)

1 Senior leaders are defined as 0 to 3 in our global career band structure. 

Our approach to ethnicity and Black Lives Matter 

In May 2020, we launched a global ethnicity 
inclusion programme to help us respond to 
challenges that we identified through our 
data. This programme aims to improve the 
diversity of our workforce ethnicity profile 
across the organisation to reflect the 
customers and communities we serve. 

The tragic death of George Floyd in the US 
accelerated conversations around race and 

ethnicity across the Group. Listening to what 
our colleagues have told us in response to 
the Black Lives Matter movement has been 
so important in informing our actions. In July 
2020, we also set out our race commitments 
to improve opportunities for Black and ethnic 
minority colleagues and boost the diversity 
of our senior leadership.

As part of this, we set an aspirational target 

to at least double the number of Black 
employees in senior leadership roles from 
0.7% at 31 December 2020 to 1.3% globally 
by 2025. To achieve our commitments,  
we are also strengthening our recruitment 
processes, partnering with specialist search 
firms, and enhancing talent development 
opportunities. In October 2020, we also 
published country-specific ethnicity data  
and action plans in the UK and US.

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HSBC Holdings plc Annual Report and Accounts 2020Employees

Inclusion continued

Delivering more inclusive outcomes for all
Our diversity and inclusion strategy is designed to deliver more inclusive outcomes for our colleagues, customers and suppliers. Globally we have 
driven improvements in representation and sentiment across multiple diversity strands, grown our commercial focus, strengthened our employee 
networks, and improved our diversity data. Here are some examples of our key achievements in 2020:

Beyond gender
Our global approach to diversity 
goes beyond gender to include 
ethnicity, disability and LGBT+ 
inclusion:

Beyond employees
Across our businesses, we  
are taking opportunities to be 
more inclusive of diverse 
customer groups. 

In our private bank, we want  
to improve how we serve and 
gain insights into our female 
clients, and we are partnering 
with external networks AllBright 
and WealthiHer to address ways 
to improve women’s wealth. 

Our Global Banking and  
Markets business has a team  
that incorporates a gender 
perspective into our mainstream 
products and business lines to 
generate business revenue from 
transactions that drive  
gender equality. 

Our insurance business HSBC 
Life uses a diversity and inclusion 
framework to ensure product 
development and engagement 
opportunities are designed to 
address needs across different 
customer groups.

 – Ethnicity: In 2020, we launched 
our global ethnicity inclusion 
programme, which is 
sponsored by Group Chief Risk 
Officer Pam Kaur and aims  
to diversify our workforce 
ethnicity profile (see box  
on page 64). 

 – Disability: We continue to 

develop our global approach  
to workplace adjustments  
to improve consistency for 
employees with disabilities,  
as part of our global disability 
confidence programme, 
sponsored by Group Chief 
Financial Officer Ewen 
Stevenson. We used our global 
footprint and connectivity to 
raise awareness about disability 
inclusion through our 
sponsorship of #PurpleLightUp.

 – LGBT+: Our work, particularly 

around leadership and engaging 
colleagues, has again been 
recognised by Stonewall, which 
named HSBC as one of only 17 
Top Global Employers for LGBT+ 
inclusion. 

Employee networks 
By appointing global executive 
sponsors from our Group People 
Committee as well as global 
co-chairs across our employee 
networks we are helping them to 
deliver consistent and impactful 
outcomes aligned to our strategy. 

In 2020, we appointed our first 
global executive sponsors for  
our Embrace (ethnicity) and 
Generations (age) networks,  
and our first global co-chairs for 
Embrace, Ability (disability) and 
Nurture (caregivers) networks. 
Global sponsors and co-chairs  
are identifying issues and 
opportunities across their groups 
in different markets, and are 
collaborating with key business 
areas and across networks to 
implement changes that will  
help improve representation  
and engagement with diverse 
groups of colleagues. 

Enhancing data
Collecting better diversity data  
is imperative to measure the 
success of our diversity and 
inclusion strategy, and to inform 
our inclusion priorities going 
forward. It will help us to gain  
a more accurate picture of our 
workforce diversity, pinpoint 
inclusion hotspots and be more 
transparent about our progress. 

We have updated ethnicity 
categories in markets where  
we can currently collect that data 
to better reflect how colleagues 
self-identify. In many locations  
we have also delivered local 
campaigns to promote self-
identification. In 2021, we are 
enabling more colleagues to 
share their ethnicity data with us 
where it is legally permissible and 
culturally acceptable to do so. We 
will run similar self-identification 
campaigns to improve declaration 
rates throughout the year.

Making progress and next steps

There is a clear commitment to achieve 
change from across our leadership. This 
commitment is reinforced by enhanced 
recruitment processes, targets, partnerships 
with like-minded organisations, programmes 
to accelerate diverse leadership and ongoing 
dialogue with employees from under-
represented groups to understand  
what we can do better.

The next phase of our strategy will take a 
broader approach to inclusion across the 
organisation. We will expand our focus to 
recognise the impact of belonging to multiple 
under-represented groups – for example,  
the barriers that might be faced by a Black 
women with disability. 

We will continue to integrate inclusion 
principles into how we do business, and  
will use our employee networks to help us 
address barriers or opportunities together. 
Following colleague feedback, we will also 
seek to improve the HSBC experience for 
those with disability, using the Business 
Disability Forum’s Disability Standard – for 
which we achieved Silver in 2020 – as well  
as for our ethnic minority colleagues.

We are realistic that some progress will take 
time, and we will keep seeking to understand 
different perspectives and experiences to grow, 
learn and improve.

 For further details on how our colleagues 
self-identify, see the ESG Data Pack at  
www.hsbc.com/esg. 

65

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Employees

Well-being

We are deeply committed to supporting the 
well-being of our people. Given the immense 
strain caused by the Covid-19 outbreak, 
including the new realities of working from 
home, home schooling and lack of physical 
contact with family members, friends  
and colleagues – it has never been more 
important. Our well-being priorities, driven by 
feedback from surveys of our people, remain 
mental health, work-life balance and financial 
security. Helping our colleagues be healthy 
and happy is the right thing to do, but by doing 
so, we also enable them to better support our 
customers and communities, which has been 
hugely important this year. 

Adapting to the challenges 
In 2020, we provided extra resources to help 
colleagues manage the mental and physical 
health challenges caused by the Covid-19 
outbreak. We launched a microsite to provide 
them with up-to-date information to support 
well-being, including guidance on how  
to work safely from home. We also made 
medical services available via video-
conferencing to more than 50,000 colleagues. 

At the start of the outbreak, we undertook 
additional surveys and virtual focus groups, 
helping us shape our response to the Covid-19 
outbreak and to ensure we had the right 
assistance in place. From this, 86% told  
us they were confident in the approach our 
leadership team was taking to managing the 
crisis. In December 2020, we ran our annual 
global well-being survey, where 92,000 
colleagues took part, helping us evaluate 
progress since 2019 and to shape future plans.

Mental health
Our global well-being survey revealed 81%  
of colleagues rated their mental health as 
positive, a decrease of two points compared 
with 2019. Given the extraordinary challenges 
caused by the Covid-19 outbreak, we are not 
surprised to see that decrease. However, we 
are very encouraged to see that 70% of 

colleagues feel confident talking to their line 
manager about mental health, an increase  
of 12 points compared with 2019. 

Just over three-quarters (78%) of colleagues 
know how to get support at work about  
their mental health, an increase of 17 points 
compared with 2019, and 63% of colleagues 
feel able to take time off work when they 
experience a mental health concern, an 
increase of 17 points compared with 2019.  
In 2020, we provided specialist support to 
colleagues who were particularly affected  
by the Covid-19 outbreak, including a mental 
health seminar to colleagues in Wuhan, China. 
Human resources advisers and business 
continuity teams were given mental health 
resource packs. Our employee network group, 
Ability, offered weekly mental health calls to 
those in need. 

We conducted an independent review of  
all our employee assistance programmes to 
see if they met best-practice standards, and  
to identify ways to improve our counselling 
services. We continued to promote our global 
mental health education programme that we 
launched in 2019, which has been completed 
by more than 22,000 colleagues. We also 
redesigned our mental health classroom 
course to be delivered virtually. Throughout 
2020, we partnered with mental health 
groups, the City Mental Health Alliance and 
United for Global Mental Health, to share ideas 
with other organisations on ways to raise 
awareness and alleviate stigma surrounding 
mental health. 

Flexible working
Our colleagues have had to adapt how they 
work due to the Covid-19 outbreak, with 80% 
needing to work from home at the height of 
the outbreak. Our global well-being survey 
revealed 74% of colleagues feel they have a 
positive work-life balance, an increase of two 
points compared with 2019. 

We are encouraged to see 76% of colleagues 
feel confident talking to their line manager 
about work-life balance and flexible working, 
an increase of 12 points compared with 2019, 
and 71% of colleagues know how to get 
support at work about work-life balance and 
flexible working, an increase of 14 points since 
2019. In 2020, we promoted new resources, 
videos and education to help colleagues 
working remotely. Topics included stress 
management, coping with isolation, remote 
collaboration, workstation support, and 
balancing care-giving responsibilities. We are 
also thinking about how we will adapt when 
our offices reopen, recognising a greater need 
for hybrid working arrangements and the 
work-life benefits these bring. 

Financial security
Our global well-being survey revealed 68% of 
colleagues rated their financial well-being as 
positive, an increase of 14 points compared 
with 2019. We are encouraged to see that 
50% of colleagues feel confident talking to 
their line manager about their financial 
well-being, an increase of 14 points compared 
with 2019. The survey also showed that 56% 
of colleagues know how to seek support at 
work about their financial well-being, an 
increase of 16 points since 2019, and 42%  
of colleagues feel they could handle an 
unexpected expense without significant 
hardship, an increase of 10 points since 2019. 
While these results are positive, we know 
there is more we can do. 

Conscious that the pandemic may put 
financial pressures on some of our colleagues, 
we worked with experts from our Wealth and 
Personal Banking business to create a financial 
well-being education programme to help 
colleagues develop healthy financial habits. 
The programme was launched globally as part 
of our Future Skills Resilience curriculum. We 
will continue to expand this programme, with 
a follow-up module on the theme of building 
up savings, later in 2021. 

World Mental Health Day

To celebrate World Mental Health Day,  
we ran a global awareness campaign and 
created a film of colleagues sharing personal 
stories. Our human resources teams and 
employee network groups held virtual 
events in all locations across the whole 
month of October 2020. These events 
featured colleagues and external experts 
providing advice on a range of mental 
health-related topics including resilience, 
sleep and management of stress. Following 
this activity, we saw a 29% increase in 
colleagues accessing well-being resources 

compared with the previous month.  
We believe this campaign activity 
contributed to the significant increases  
in levels of awareness, confidence and 
de-stigmatisation of mental health, and why 
75% of colleagues said they believe HSBC 
cares about their well-being in our global 
well-being survey. In 2021, we will continue 
to work with our charity partner, United for 
Global Mental Health, to create campaigns 
that raise awareness and alleviate stigma.

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Learning and skills development 

A workforce capable of meeting the 
challenges of today and tomorrow requires 
significant support to develop the right skills. 
Whatever our colleagues’ career paths,  
we have a range of tools and resources to  
help them. 

A rapid shift to virtual learning 
The Covid-19 outbreak resulted in a halt to 
classroom training and rapid expansion in 
virtual learning. We prioritised the transition  
to remote working and helping colleagues 
manage their well-being. The shift from 
physical classroom training to shorter virtual 
equivalents and online resources resulted in  
a total of 5.2 million hours and 2.9 days per 
FTE training in 2020.

Risk management remains central to 
development and is part of our mandatory 
training. Those at higher risk of exposure  
to financial wrongdoing experience more 
in-depth training on financial risks, such  
as money laundering, sanctions, bribery  
and corruption. Other programmes and 
resources address specific areas of risk,  
like management of third-party suppliers. 

Our Cyber Hub brings together training, 
insights, events and campaigns on how to 
combat cyber-crime. We are also supporting 
those who develop models and senior leaders 
with training to help them understand and 
apply our Principles for the Ethical Use of  
Big Data and AI. 

We converted or rebuilt technical,  
professional and personal classroom 
programmes to deliver online. New joiners  
to HSBC experienced an immersive virtual 
induction programme and virtual internships. 
Our global graduate induction programme 
moved entirely online with more than 100 
leaders and graduate alumni welcoming 
approximately 650 graduates. 

A learning and feedback culture 
We want our colleagues to be well prepared 
for changing workplace requirements and  
so have developed a flagship Future Skills 
programme to support them. We identified 
nine key behaviours we believe are necessary 
future skills for colleagues and built a 
curriculum of resources to support learners  
to develop these.

Supporting self-development
We have a range of tools and resources  
to help colleagues take ownership of their 
development and career. 

 – HSBC University is our one-stop shop  

for learning delivered via an online portal, 
network of global training centres and 
third-party providers.

 – Our My HSBC Career portal offers career 

development resources and information on 
managing change and on giving back to the 
organisation and the communities in which 
we operate. Over 100,000 of our colleagues 
made use of it in 2020. 

 – We launched a global mentoring system in 
2020 to enable colleagues to match with a 
mentor or mentee. At 31 December 2020, 
we had in excess of 6,800 mentors and 
mentees in 58 countries and territories. 

Developing core skills 
Our managers are the critical link in supporting 
our colleagues. In 2020, we redesigned our 
suite of training and resources for managers 
so they can focus on the most important skills 
including leading and supporting teams 
through change. 

More than 1,000 colleagues now act as Future 
Skills Influencers, supporting their businesses 
and teams to invest in learning. In November 
2020, we ran a week-long MySkills festival, 
which helped colleagues explore future skills 
through virtual events, interactive workshops 
and online resources. Demand to join sessions 
surpassed our expectations with more than 
45,000 registrations for the events.

Senior succession planning 
Developing future leaders is critical to our 
long-term success. The Group Executive 
Committee dedicates time to articulate the 
current and future capabilities required to 
deliver the business strategy, and identify 
successors for our most critical roles. 

Successors undergo robust assessment and 
participate in executive development. Potential 
successors for senior roles also benefit from 
coaching and mentoring and are moved into 
roles that build their skills and capabilities.

Inspiring future coders 

We know supporting the next 
generation provides a sense of 
fulfilment to our colleagues. We 
support the Technovation Girls 
programme, which inspires girls 
globally to design and code 
applications that solve problems in 
their community. The long-term goals 
of the programme are to build the 
capacity of girls as technology 
innovators, thereby reducing the 
gender gap in science, technology, 
engineering and mathematics 
(‘STEM’) professions. 

Through our support, over 1,400  
girls across the globe were able to 
participate in the programme in 2020. 
In August 2020, we supported the 
virtual Technovation World Summit 
that had nearly 2,000 participants. 
Winning teams were awarded cash 
prizes to spend on furthering their 
education in STEM subjects or 
turning their ideas into commercial 
projects.

Training at HSBC

5.2 million 

Training hours carried out by our 
colleagues in 2020. 

(2019: 6.5 million) 

2.9 days 

Training days per FTE.

(2019: 3.5 days)

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ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Employees

Listening to our colleagues

We run a Snapshot survey every six months 
and report insights to our Group Executive 
Committee and the Board. Results are shared 
across the Group to provide managers in each 
region with a better understanding to plan and 
make decisions.

As our colleagues faced considerable 
challenges in 2020, Snapshot was a critical 
tool to ensure we were responding to our 
colleagues’ needs. 

Listening to employee sentiment
In our 2020 Snapshot surveys, we had a record 
response rate of 62% in July and 56% in 
December, up from 52% and 50% respectively 
in the same periods of 2019. We undertook 
additional surveys and virtual focus groups, 
focusing on our colleagues’ well-being, the 
changes that the Covid-19 outbreak brought to 
their working lives and their views on returning 
to the workplace. More than 50% of our 
colleagues participated in our Covid-19 
well-being survey, with 86% telling us they 
were confident in the approach our leadership 
team was taking to managing the crisis. 

Finding new ways to listen
We used new and innovative ways to gather 
feedback and ideas from our colleagues in 
2020. In June, we conducted virtual focus 
groups for the first time. Approximately 850 
employees in four markets discussed what it 
was like to work during the Covid-19 outbreak 
and considered how work will evolve in the 
future. In October, we organised our first 
‘employee jam’ – a live online chat between 
employees in 49 countries. This online 
conversation ran over 72 hours and captured 
more than 9,500 online posts on topics 
including the future of work and our values, 
which we have refreshed to remain relevant 
and reflective of our organisation. 

In February 2021, we introduced to our 
colleagues our revised purpose and values, 
which were co-created through an extensive 

listening, talking and reflecting exercise with 
tens of thousands of colleagues, customers 
and other stakeholders. Our new purpose is 
‘Opening up a world of opportunity’. Our new 
values are ‘we value difference’; ‘we succeed 
together’; ‘we take responsibility’; and ‘we get 
it done’.

It was the largest employee engagement 
programme in HSBC’s history – helping to 
ensure our plans were an accurate reflection 
of everything our colleagues told us about 
what is best about HSBC, and everything  
we want to become.

During the consultation on our values, 90%  
of colleagues said they were clear on HSBC’s 
new values and how they could be embedded 
into their day-to-day work.

Encouraging our colleagues to speak up
We believe that change only happens when 
people speak up. If our colleagues have 
concerns, we want them to speak up to help 
us do what’s right. In 2020, acting on findings 
from the November 2019 Snapshot survey, we 
ran a programme to raise awareness of how  
to speak up and what happens when we do. 
Our efforts focused on improving the process, 
demystifying how we investigate concerns and 
improving transparency about what action  
we should take as a result. Following the 2020 
‘Speak Up’ campaign, our speak-up index, 
which is formed by surveying our colleagues’ 
comfort on speaking up, rose six points in 
December 2020, compared with November 
2019. The index outperformed peers by  
10 points. We were pleased to see an 
improvement in employee sentiment, with 
78% of respondents saying they felt able to 
speak up when they saw behaviour they 
considered to be wrong. However, a smaller 
proportion (66%) said they were confident that 
if they speak up, appropriate action will be 
taken. We recognise there is more to do to give 
our colleagues confidence that their concerns 
will be fully addressed. In 2021, we aim  

to continue the speak-up programme  
and will monitor sentiment through our 
Snapshot survey. 

Our whistleblowing channels 
At times individuals may not feel comfortable 
speaking up through the usual channels.  
Our global whistleblowing channel, HSBC 
Confidential, allows our colleagues and other 
stakeholders to raise concerns confidentially, 
and if preferred, anonymously (subject to  
local laws). Enhancements to the channel  
in December 2020 mean the majority  
of concerns are now raised through an 
independent third party offering 24/7 hotlines 
and a web portal in multiple languages. 

We also provide and monitor an external  
email address for concerns about accounting, 
internal financial controls or auditing matters 
(accountingdisclosures@hsbc.com). 

In 2020, while we continued to actively 
promote the channel, the volume of 
whistleblowing concerns fell by 11%, driven in 
part by the change in working environment 
during the Covid-19 outbreak. Of the 
whistleblowing cases closed in 2020, 81% 
related to behaviour and conduct, 15% to 
security and fraud risks, 4% to compliance 
risks and less than 1% to other categories. 

The Group Audit Committee has overall 
oversight of the Group’s whistleblowing 
arrangements. Concerns are investigated 
proportionately and independently, with action 
taken where appropriate. This can include 
disciplinary action, dismissal, and adjustments 
to variable pay and performance ratings. 

Our 2020 Snapshot survey showed increasing 
confidence among our colleagues in raising 
whistleblowing concerns without fear of 
reprisal, reflecting our policy of zero tolerance 
for acts of retaliation. This continues to be an 
area of focus. 

Employee conduct and harassment 

We rely on our people to deliver fair 
outcomes for our customers and to  
make sure we act with integrity in  
financial markets. 

committees. Where we see themes  
or adverse trends we take action,  
including training, communications  
and policy changes.

We foster a healthy working environment 
and expect our people to treat each other 
with dignity and respect, and take action 
where we find behaviour that falls short of 
our expectations. 

The types of cases, thematic links between 
them, and changes in volumes are reported 
on a regular basis to management 

In 2020, to ensure clarity over the standards 
of behaviour expected, we delivered 
mandatory training on bullying and 
workplace harassment. The training 
emphasised our commitment to creating  
an environment where our people feel 
comfortable to speak up and step in  
where they witness poor behaviour. 

We also took disciplinary action against  
2% of our employees for poor conduct, 
examples of which include avoiding 
customer calls and not treating colleagues 
respectfully. Over 800 colleagues were 
dismissed for poor behaviour, including  
41 for workplace harassment. We believe  
in transparency on these matters, and also 
know that we have room to improve. In 2021, 
we will enhance our conduct policies and 
procedures so that they remain current,  
clear and effective.

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HSBC Holdings plc Annual Report and Accounts 2020Employees

Listening to our colleagues continued 

Measuring our progress against peers
In 2020, we introduced six new Snapshot indices to measure key areas of focus and to enable comparison against a peer group of global financial 
institutions. The table sets out how we performed.

Index

Score1

vs 
2019

HSBC vs 

benchmark2 Questions that make up the index

Employee 
engagement

Employee 
focus

72

+5

+2

72

New

+4

Strategy

68

New

Change 
leadership

74

New

-1

0

Speak-up

75

+6

+10

I am proud to say I work for this company. 
I feel valued at this company. 
I would recommend this company as a great place to work.

I generally look forward to going to work. 
My work gives me a feeling of personal accomplishment. 
My work is challenging and interesting.

I have a clear understanding of this company’s strategic objectives. 
I am seeing the positive impact of our strategy. 
I feel confident about this company’s future.

Leaders in my area set a positive example. 
My line manager does a good job of communicating reasons behind important changes that are made. 
Senior leaders in my area communicate openly and honestly about changes to the business.

My company is genuine in its commitment to encourage colleagues to speak up. 
I feel able to speak up when I see behaviour which I consider to be wrong. 
Where I work, people can state their opinion without the fear of negative consequences.

Trust

75

+6

+5

I trust my direct manager. 
I trust senior leadership in my area. 
Where I work, people are treated fairly.

1  Each index comprises three constituent questions, with the average of these questions forming the index score. 
2  We benchmark Snapshot results against a peer group of global financial services institutions, provided by our research partner, Karian and Box. Scores for each 
question are calculated as the percentage of employees who agree to each statement. For further details on the constituent questions and past results, see the  
ESG Data Pack at www.hsbc.com/esg.

Measuring employee engagement 
To understand how our colleagues perceive 
the organisation, we ask if they feel proud, 
valued and willing to recommend HSBC as a 
great place to work. These questions form our 
employee engagement index. Engagement 
rose significantly in 2020 and was two points 
above our peers. More colleagues said  
they ‘feel valued by HSBC’ compared with 
November 2019. Employee advocacy, which  
is defined as those who would recommend 
HSBC, improved five points in 2020 to  
71%. We aim to continue improving our 
understanding and address why 20% of our 
colleagues report neutral levels of advocacy. 
Our research showed that key drivers of 
engagement are career opportunities, trust in 
leadership and our commitment to encourage 
speaking up. We expect our flagship 
programme to help build future skills and  
that this will in turn drive further improvements 
in engagement levels. 

Measuring employee focus 
Our employee focus index tells us about  
our colleagues’ perception of their work. The 
2020 results were four points above our peers. 
This will be a key measure of progress for our 
transformation and our programme to build 
future skills. 

Measuring strategy and change leadership
Our strategy index, which measures how 
employees feel about HSBC’s direction,  
was just below its benchmark. However,  
the index included an improvement in scores 
for questions on whether colleagues see a 
positive impact of our strategy and if they  
have confidence in the future. Our efforts  
to reshape the business and the uncertain 
business environment are affecting these 
results, and we recognise the challenge  
this creates for colleagues. Despite these 
challenges, our change leadership index, 
which measures how employees feel about 
change communication and leadership setting 
a positive example, performed in line with  
the benchmark. This will continue to be vital 
during our ongoing transformation.

Measuring speak-up and trust
Our speak-up index rose six points from 
November 2019, representing the biggest 
improvement in the indices we measure. 
Similarly, trust, particularly in senior 
leadership, improved significantly. These 
results are encouraging but need to be viewed 
in the context of the Covid-19 outbreak  
where research showed our colleagues were 
positive about HSBC’s handling of the crisis. 
Maintaining these gains through a period of 
ongoing change and uncertainty will require 
sustained effort.

Whistleblowing concerns raised 
(subject to investigation) in 2020 

2,510

(2019: 2,808)

Substantiated and partially 
substantiated whistleblowing 
cases in 20201

42%

(2019: 33%)

Employee advocacy 

71%

Would recommend HSBC as a great  
place to work. 
(2019: 66 %)

1  The 2020 substantiation rate excludes 

concerns redirected to other escalation 
routes.

69

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review 

Governance

We remain committed to high standards of governance.  
We work alongside our regulators and recognise our 
contribution to building healthy and sustainable societies. 

At a glance

Our relationship
We act on our responsibility to run our 
business in a way that upholds high  
standards of corporate governance.

We are committed to working with our 
regulators to manage the safety of the 
financial system, adhering to the spirit and the 
letter of the rules and regulations governing 
our industry. In our endeavour to restore trust 
in our industry, we aim to act with courageous 

integrity and learn from past events to help 
prevent their recurrence.

We meet our responsibilities to society, 
including through being transparent in our 
approach to paying taxes. We also seek to 
ensure we respect global standards on human 
rights in our workplace and our supply chains, 
and continually work to improve our 
compliance management capabilities. 

We acknowledge that increasing financial 
inclusion is a continuing effort, and we are 
carrying out a number of initiatives to increase 
access to financial services.

 For further details on our corporate  
governance see our corporate governance  
report on page 195.

Respecting human rights

Our approach with our suppliers

We respect human rights and have signed,  
or expressed support for, a number of 
international codes, as set out in our  
Statement on Human Rights. 

Our ethical code of conduct for suppliers of goods  
and services, which must be complied with by all 
suppliers, sets out minimum standards for economic, 
environmental and social impacts. 

Read more on respecting human rights on page 71.

Read more on our approach with our suppliers on page 73.

Supporting financial inclusion

A responsible approach to tax

We aim to deliver products and services that 
address financial barriers. We invest in financial 
education to help customers, colleagues and 
people in our communities be confident users  
of financial services. 

 Read more on supporting financial inclusion on  
page 71.

We seek to pay our fair share of tax in the jurisdictions  
in which we operate and to minimise the likelihood  
of customers using our products to inappropriately 
avoid tax. 

Read more on a responsible approach to tax on page 74.

Protecting data

Restoring trust

We are committed to protecting the information 
we hold and process in accordance with local 
laws and regulations. We continue to strengthen 
our controls to prevent, detect and react to  
cyber threats.

Read more on protecting data on page 72.

We have sought to learn from past mistakes and  
we are seeking to develop and implement specific 
measures designed to prevent recurrence of similar 
events in the future. 

Read more on restoring trust on page 75.

Safeguarding the financial system

We remain committed in our efforts to combat 
financial crime by continuing to invest in  
new technology to protect our customers  
and organisation, while supporting key  
industry initiatives. 

 Read more on safeguarding the financial system on 
page 73.

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HSBC Holdings plc Annual Report and Accounts 2020Governance

Respecting human rights

We recognise the duty of states to protect 
human rights and the role played by business 
in respecting them, in line with the UN Guiding 
Principles’ Protect, Respect and Remedy 
framework. We have signed, or expressed 
support for, a number of international codes 
as set out in our Statement on Human Rights. 
Our Human Rights Steering Committee, which 
was set up in 2018, continues to develop our 
approach to human rights. Our Statement on 
Human Rights is available at www.hsbc.com/
our-approach/esg-information. 

Pioneering scheme
Our pioneering scheme to help survivors of 
human trafficking is now used as a model for 
making financial services more accessible to 
vulnerable communities through the UN’s  

Finance Against Slavery and Trafficking 
(‘FAST’) Survivor Inclusion Initiative.

Building on the success of our Survivor Bank 
programme in the UK, for which we received  
a Stop Slavery Award from the Thomson 
Reuters Foundation, we became the first bank 
in Hong Kong to offer a Hong Kong Dollar 
Statement Savings account for residents who 
do not have a fixed abode, or who are living  
in subdivided flats without access to postal 
services. Having a bank account can  
improve financial security for members of 
disadvantaged communities – including those 
under potential risk of forced labour or debt 
bondage – and potentially enable them  
to receive welfare allowances or find 
employment.

Identifying suspicious activity

When two large cash deposits were made to 
the same account on two consecutive days,  
it raised suspicion with one of our analysts. 
Further investigation identified a number of 
cautionary flags for potential illegal activity, 
including the apparent findings that 17 people 
– all of whom banked with HSBC – lived in the 
same property. The case was escalated to an 
investigations team, who filed a suspicious 

Spotting the signs of human trafficking
In many cases, transactions related to modern 
slavery and human trafficking will not be 
identified by automated systems alone. As  
a result, our analysts also use a range of 
secondary indicators that may not signify 
suspicious activity on their own, but which 
can be assessed as part of a case review. 
Examples where such transactions have 
successfully been identified and escalated  
are then shared internally, as case studies  
for others to learn from.

 For details of our approach to modern slavery, 
see: www.hsbc.com/our-approach/risk-and-
responsibility/modern-slavery-act.

activity report with the UK regulator. We also 
proceeded to close the account. With these 
actions, we not only disrupted the individual, 
but also alerted the authorities to take the 
case forward through appropriate law 
enforcement channels.

Supporting financial inclusion

We believe that financial services, when 
accessible and fair, can reduce inequality  
and help more people access opportunities. 

Access to products and services
We aim to deliver products and services  
that address the barriers people can face  
in accessing financial services. 

In 2020, we continued to offer innovative 
product offerings. In the UK, we are educating 
people about banking services and reducing 
barriers for those who do not have a fixed 
address as well as for survivors of human 
trafficking. We also introduced new products, 
such as banking services for refugees in  
Hong Kong, allowing individuals to have  
a safe, affordable way to receive support  
from overseas family, friends or local 
non-governmental organisations. 

We embedded diversity and inclusion 
standards into our new product approval 
framework for retail banking, wealth, 
insurance and digital products, such as  
in India, where we added a transgender  
option to the customer application and 
underwriting criteria for health insurance.

Access to financial education
We invest in financial education to help 
customers, colleagues and people in our 
communities be confident users of financial 
services. 

In 2020, we provided more of our own 
financial education content, such as articles 
and features on our digital channels. We had 
over 1.7 million unique visitors to our digital 
content in 2020, making progress towards our  

2019 goal of reaching four million unique 
visitors by the end of 2022. 

We also support charity programmes that 
deliver financial education. In 2020, HSBC UK 
partnered with Young Money, a UK-based 
charity focused on children’s financial 
education, to introduce Money Heroes, an 
innovative education programme that brings 
together teachers and parents or carers to 
develop a child’s financial capability from ages 
three to 11. Combining learning with real life 
activities, Money Heroes aims to reach one 
million children over three years, supporting 
the most vulnerable communities.

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ESG review | Governance

Protecting data

Cybersecurity 
The threat of cyber-attacks remains a concern 
for our organisation, as it does across the 
entire financial sector. Failure to protect  
our operations from internet crime or 
cyber-attacks may result in financial loss, 
disruption for customers or a loss of data.  
This could undermine our reputation and 
ability to attract and retain customers. 

We have invested in business and technical 
controls to help prevent, detect and react to 
these threats. We continually evaluate threat 
levels for the most prevalent attack types  
and their potential outcomes. We have 
strengthened our controls to reduce the 
likelihood and impact of advanced malware, 
data leakage, infiltration of payment systems 
and denial of service attacks. In 2020, we 
continued to strengthen our cyber defences  
to enhance our cybersecurity capabilities, 
including: Cloud security; identity and access 
management; metrics and data analytics; and 
third-party security reviews. These defences 
are grounded in mature controls that mitigate 
the current cyber-attacks and build upon a 
proactive data analytical approach to identify 
and mitigate future advanced targeted threats. 
In addition, an important part of our defence 
strategy is ensuring our people remain aware 
of cybersecurity issues and know how to 
report incidents. We continue to run regular 
cyber awareness campaigns and have 
dedicated training programmes in place.

We operate a three lines of defence model, 
aligned to the operational risk management 
framework, to ensure robust oversight and 
challenge of our cybersecurity capabilities and 
priorities. In the first line of defence, we have 
risk owners within global businesses and 
functions who are accountable for identifying, 
owning and managing the cyber risk. They 
work with control owners to help ensure 
controls are in place to mitigate issues, prevent 
risk events from occurring and resolve them if 
they do. These controls are executed in line 
with policies produced by the information 

security risk teams, the second line of  
defence, which provide independent review 
and challenge. They are overseen by the third 
line of defence, which is the Global Internal 
Audit function.

We regularly report and review cyber risk and 
control effectiveness at relevant governance 
forums and the Board to ensure appropriate 
oversight. We also report across the global 
businesses, functions and regions to help 
ensure appropriate visibility and governance  
of risks and mitigating controls.

Data privacy 
We are committed to protecting and 
respecting the data we hold and process,  
in accordance with the laws and regulations  
of the geographies in which we operate.

Our approach rests on having the right  
talent, technology, systems, controls policies, 
and processes to help ensure appropriate 
management of privacy risk. Our Group-wide 
privacy policy and principles provide a 
consistent global approach to managing data 
privacy risk, and must be applied by all of  
our global businesses and global functions.

We conduct regular training sessions on data 
privacy and security issues throughout the 
year, including global mandatory training for all 
our colleagues, along with additional training 
sessions, where required, to keep abreast of 
new developments in this space.

We provide transparency to our customers 
and stakeholders on how we collect, use  
and manage their personal data, and their 
associated rights. Where relevant, we work 
closely with third parties to help ensure 
adequate protections are provided, in line with 
our data privacy policy and as required under 
data privacy law. We offer a broad range of 
channels in the markets we operate, through 
which customers and stakeholders can raise 
any concerns regarding the privacy of  
their data.

We have established dedicated privacy  
teams reporting to the highest level of 
management on data privacy risks and  
issues, and overseeing our global data privacy 
programmes. We report data privacy regularly 
at multiple governance forums, including at 
Board level, to help ensure there is appropriate 
challenge and visibility among senior 
executives. In addition, we have established 
data privacy governance structures and 
continue to embed accountability across  
all businesses.

We are committed to implementing industry 
practices for data security and our privacy 
teams work closely to drive the necessary 
design, implementation and monitoring of 
privacy solutions, including conducting regular 
reviews and data privacy risk assessments. 
We implemented procedures that articulate 
clearly the action to be taken when dealing 
with a data privacy breach. These include 
notifying regulators, customers or other data 
subjects, as required under applicable privacy 
laws and regulations, in the event of a 
reportable incident occurring.

Data Privacy Day

In January 2020, we hosted a global  
data privacy event for all our colleagues 
to mark International Data Privacy Day. 
The event highlighted the importance  
of taking accountability for data privacy 
across the organisation and the 
continuing need to provide simple and 
clearer mechanisms for our customers  
to have more control and choice in 
managing their data.

We invited internal and external speakers, 
including the UK’s former Deputy 
Information Commissioner, our Group 
Data Protection Officer and Group Chief 
Data Officer, as well as representatives 
from the technology industry. The event 
was broadcast across 62 countries.

Cybersecurity Awareness Month 

Our cybersecurity teams endeavour to 
educate, support and equip every colleague 
with the tools to prevent, mitigate and report 
cyber incidents, and keep our organisation 
and customers’ data safe. Throughout 
October 2020, the cybersecurity team hosted 
a number of virtual awareness events for all 
colleagues as part of a dedicated annual 
Cybersecurity Awareness Month. The global 

and local events were hosted by our 
executive leaders, with the support of a 
number of internal subject matter experts and 
external guest speakers. The Cybersecurity 
Awareness Month established a new level  
of awareness, participation, and commitment 
to cybersecurity inside the Group.

72

HSBC Holdings plc Annual Report and Accounts 2020 
 
Governance

Safeguarding the financial system

We have continued our efforts to combat 
financial crime risks and reduce their impact on 
our organisation and the wider world. These 
financial crime risks include money laundering, 
terrorist and proliferation financing, tax 
evasion, bribery and corruption, sanctions  
and fraud. As part of this work, we have made 
progress on several key initiatives, enabling  
us to manage and mitigate these risks more 
effectively, and further our pioneering work in 
financial crime risk management across the 
financial services industry.

Financial crime risk management
We have embedded a strong financial crime 
risk management framework across all global 
businesses and all countries and territories in 

which we operate. For further details on our 
financial crime risk management framework, 
see page 187.

We continue to invest in new technology  
to enable us to make an impact in the fight 
against financial crime. Our global social 
network analytics platform, which we 
launched in 2018 as an investigative tool, now 
helps us detect high-risk activity across our 
trade finance business. Using a contextual 
monitoring approach, we are able to improve 
the accuracy and efficiency of our operations, 
removing delays in approving genuine 
customer transactions while focusing 
attention on behaviour of concern. 

Building on this approach, we have made 
progress in applying machine learning 
techniques to improve the accuracy and 
timeliness of our financial crime detection 
capabilities. Working with industry leaders,  
we have sought to share what we have 
learned, contributing to the development of 
best practice in this emerging field, in line  
with our Principles for the Ethical Use of  
Big Data and AI.

We are confident our adoption of these new 
technologies will continue to enhance our 
ability to respond quickly to suspicious activity 
and be more granular in our risk assessments, 
helping to protect our customers and the 
integrity of the financial system.

The scale of our work

Each month, we screen over 708 million 
transactions across 275 million accounts for 
signs of money laundering and financial 
crime. In addition, we screen approximately 
114 million customer records and 45 million 
transactions monthly for sanctions 
exposures. During 2020, we filed almost 
50,000 suspicious activity reports to law 
enforcement and regulatory authorities 
where we identified potential financial 
crime.

Our approach with our suppliers

We have globally consistent standards and 
procedures for the onboarding and use of 
external suppliers. We require suppliers to 
meet our compliance and financial stability 
requirements, as well as to comply with  
our supplier ethical code of conduct. We 
consider on time payment to be of paramount 
importance, and our commitment to  
paying our suppliers is in line with all  
local requirements, including the Prompt 
Payment Code in the UK. 

Supplier ethical code of conduct 
We have an ethical code of conduct for 
suppliers of goods and services, which  

must be complied with by all suppliers.  
While our businesses and functions are 
accountable for the suppliers they use, our 
global procurement function owns the code  
of conduct review process for them. Our goal 
is to work collaboratively with our supply  
chain partners on sustainability at all times. 

The ethical code of conduct, which we  
require suppliers to adopt, sets out minimum 
standards for economic, environmental and 
social impacts and outlines the requirement 
for a governance and management structure 
to help ensure compliance. Our supplier 
management conduct principles set out how 

we conduct business with our third-party 
suppliers both in our legal and commercial 
obligations. They also explain how we treat 
suppliers fairly through our behaviour and 
actions and in line with our values. 

 Our supplier management principles and our 
ethical code of conduct are available at: www.
hsbc.com/our-approach/risk-and-responsibility/
working-with-suppliers.

73

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020ESG review | Governance

A responsible approach to tax

We seek to pay our fair share of tax in the 
jurisdictions in which we operate and to 
minimise the likelihood of customers using  
our products and services to evade or 
inappropriately avoid tax. Our approach to  
tax and governance processes is designed  
to achieve these goals. 

Through adoption of the Group’s risk 
management framework, controls are  
in place that are designed to ensure that 
inappropriately tax-motivated transactions or 
products are not adopted by the Group and 
that any tax planning used must be supported 
by genuine commercial activity. HSBC has no 
appetite for using aggressive tax structures. 
Significant investment has been made to 
strengthen our risk processes and train staff to 
identify instances of potential tax evasion and 
we continue to enhance these processes. 

With respect to our own taxes, we are guided 
by the following principles:

 – We are committed to applying both the 

letter and spirit of the law in all jurisdictions 
in which we operate. This includes 
adherence to a variety of measures arising 
from the OECD Base Erosion and Profit 
Shifting initiative. 

 – We seek to have open and transparent 
relationships with all tax authorities. As  
with any group of our size and complexity,  
a number of areas of differing interpretation 
or disputes with tax authorities exist at any 
point in time. We work with the local tax 
authorities to try to agree and resolve these 
in a timely manner.

 – We have applied the OECD/G20 Inclusive 
Framework Pillar 2 guidance to identify 
those jurisdictions in which we operate that 
have nil or low tax rates (12.5% or below). 
We have identified seven such jurisdictions 
in which we had active subsidiaries during 
20201. We continually monitor the number 
of subsidiaries within the Group as part of 
the Group’s ongoing entity rationalisation 
programme. We intend to continue this 
process, with the aim of ensuring that the 
HSBC entities remaining in such jurisdictions 
are regulated entities essential for 
conducting business.

With respect to our customers’ taxes, we  
are guided by the following principles:

 – We have made considerable investment 

implementing processes designed to enable 
us to support external tax transparency 
initiatives and reduce the risk of banking 

services being used to facilitate customer 
tax evasion. These initiatives include the  
US Foreign Account Tax Compliance Act, 
the OECD Standard for Automatic Exchange 
of Financial Account Information (the 
‘Common Reporting Standard’), and the  
UK legislation on the corporate criminal 
offence of failing to prevent the facilitation  
of tax evasion.

 – We have processes in place to help ensure 
that inappropriately tax-motivated products 
and services are not provided to our 
customers.

 For further details of our approach to financial 
crime and action we have taken, see page 73.

Our tax contributions
The effective tax rate for the year was 30.5%. 
Further details are provided on page 308.

As highlighted below, in addition to paying 
$8.1bn of our own tax liabilities during 2020, 
we collected taxes of $9.5bn on behalf of 
governments around the world. A more 
detailed geographical breakdown of the taxes 
paid in 2020 is provided in the ESG Data Pack. 
The tax we paid during 2020 was higher than 
in 2019 due to differences in the timing of 
payments, particularly in Hong Kong.

Taxes paid – by type of tax

Taxes paid – by region

Taxes collected – by region

Tax on profits $3,873m (2019: $1,988m)
Withholding taxes $386m (2019: $282m)
Employer taxes $1,121m (2019: $1,041m)
Bank levy $1,011m (2019: $889m)
Irrecoverable VAT $1,389m (2019: $1,164m)
Other duties and levies $278m (2019: $227m)

Europe $3,022m (2019: $3,077m)
Asia-Pacific $3,911m (2019: $1,487m)
Middle East and North Africa $299m 
(2019: $313m)
North America $382m (2019: $314m)
Latin America $444m (2019: $400m)

Europe $3,462m (2019: $3,636m)
Asia-Pacific $3,595m (2019: $3,288m)
Middle East and North Africa $90m 
(2019: $127m)
North America $1,089m (2019: $876m)
Latin America $1,302m (2019: $1,379m)

1 The Bahamas, Bermuda, the Cayman Islands, Guernsey, Ireland, Jersey and the British Virgin Islands.

74

HSBC Holdings plc Annual Report and Accounts 2020Governance

Restoring trust

Restoration of trust in our industry remains  
a significant challenge as past misdeeds 
continue to remain in the spotlight. But it is  
a challenge we must meet successfully. We 
owe this not just to our customers and to 
society at large, but to our employees to 
ensure they can rightly be proud of the 
organisation where they work. We aim to act 
with courageous integrity in all we do. This 
guiding principle means having the courage  

to make decisions based on doing the right 
thing for customers and never compromising 
our ethical standards.

The chart below sets out fines and penalties 
arising out of major investigations involving 
criminal, regulatory, competition or other law 
enforcement authorities, and costs relating to 
PPI remediation. We have sought to learn from 
these past mistakes and are seeking to 

develop and implement specific measures 
designed to prevent recurrence of similar 
events in the future. Further information 
regarding the measures that we have taken  
to prevent the recurrence of some of these 
matters can be found at www.hsbc.com/
who-we-are/esg-and-responsible-business/
esg-reporting-and-policies.

Major criminal and regulatory fines and penalties and PPI remediation1 

Pre- 
2006

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

AML-related 
investigations

Global Private  
Banking 
tax-related 
investigations

RMBS-related 
investigations

Libor/Euribor

FX-related 
investigations

PPI

Key

1,921

13

43

13

360

521

765

36

2

618

6

175

102

333

870 1,138 700

553

448

502

741

750

572

 Duration of conduct period 

  $m  Fines/penalties/other costs

1   This chart only includes fines and penalties arising out of major investigations involving criminal, regulatory, competition or other law enforcement authorities,  

and costs relating to PPI remediation. The chart reflects the year in which a fine, penalty or remediation cost was paid, which may be different from when a loss  
or provision was recognised under IFRSs. Settlements or other costs arising out of private litigation or arbitration proceedings are not included.

75

ESG reviewHSBC Holdings plc Annual Report and Accounts 2020 
Financial  
review

77  

85  

Financial summary

Global businesses and geographical regions

103   Reconciliation of alternative performance measures

World’s first corporate bonds 
to tackle plastic waste 

Our green expertise and global connectivity helped 
Henkel, a leading consumer goods and industrial 
company, to issue the first ever corporate bonds aimed 
at tackling plastic waste.

The firm behind well-known brands and products such 
as Persil detergent, Schwarzkopf shampoo and Loctite 
adhesives will use the equivalent of $100m raised for 
projects and expenditures related to its activities to 
foster a circular economy, which include the 
development of reusable and recyclable packaging.

We were sole green structuring adviser and sole lead 
manager on the five-year fixed-rate bonds, which were 
issued in two tranches. The bonds generated interest 
from international investors from Japanese insurers to 
German banks.

76

HSBC Holdings plc Annual Report and Accounts 2020Financial summary

Use of alternative performance measures 

Changes from 1 January 2020

Critical accounting estimates and judgements

Consolidated income statement 

Income statement commentary 

Consolidated balance sheet 

Page

77

77

77

78

79

82

Use of alternative performance measures

Our reported results are prepared in accordance with IFRSs 
as detailed in the financial statements starting on page 278.
To measure our performance, we supplement our IFRS figures 
with non-IFRS measures that constitute alternative performance 
measures under European Securities and Markets Authority 
guidance and non-GAAP financial measures defined in and 
presented in accordance with US Securities and Exchange 
Commission rules and regulations. These measures include those 
derived from our reported results that eliminate factors that distort 
year-on-year comparisons. The ‘adjusted performance’ measure 
used throughout this report is described below. Definitions and 
calculations of other alternative performance measures are 
included in our ‘Reconciliation of alternative performance 
measures’ on page 103. All alternative performance measures are 
reconciled to the closest reported performance measure.

A change in reportable segments was made in 2020 by combining 
Global Private Banking and Retail Banking and Wealth 
Management to form Wealth and Personal Banking. We also 
reallocated our reporting of Markets Treasury, hyperinflation 
accounting in Argentina and HSBC Holdings net interest expense 
from Corporate Centre to the global businesses. Comparative data 
have been re-presented on an adjusted basis in accordance with 
IFRS 8 ‘Operating Segments’ with the change in reportable 
segments explained in more detail in Note 10: Segmental analysis 
on page 311.
Adjusted performance

Adjusted performance is computed by adjusting reported results 
for the effects of foreign currency translation differences and 
significant items, which both distort year-on-year comparisons.
We consider adjusted performance provides useful information for 
investors by aligning internal and external reporting, identifying 
and quantifying items management believes to be significant, and 
providing insight into how management assesses year-on-year 
performance.
Significant items

‘Significant items’ refers collectively to the items that 
management and investors would ordinarily identify and consider 
separately to improve the understanding of the underlying trends 
in the business. 
The tables on pages 85 to 88 and pages 94 to 99 detail the effects 
of significant items on each of our global business segments, 
geographical regions and selected countries/territories in 2020, 
2019 and 2018.
Foreign currency translation differences

Foreign currency translation differences reflect the movements of 
the US dollar against most major currencies during 2020. 
We exclude them to derive constant currency data, allowing us to 
assess balance sheet and income statement performance on a 
like-for-like basis and better understand the underlying trends in 
the business.

Foreign currency translation differences
Foreign currency translation differences for 2020 are computed by 
retranslating into US dollars for non-US dollar branches, subsidiaries, joint 
ventures and associates:
•

the income statements for 2019 and 2018 at the average rates of 
exchange for 2020; and
the balance sheets at 31 December 2019 and 31 December 2018 at the 
prevailing rates of exchange on 31 December 2020.

•

No adjustment has been made to the exchange rates used to translate 
foreign currency-denominated assets and liabilities into the functional 
currencies of any HSBC branches, subsidiaries, joint ventures or 
associates. The constant currency data of HSBC’s Argentinian subsidiaries 
have not been adjusted further for the impacts of hyperinflation. When 
reference is made to foreign currency translation differences in tables or 
commentaries, comparative data reported in the functional currencies of 
HSBC’s operations have been translated at the appropriate exchange 
rates applied in the current period on the basis described above.

Changes from 1 January 2020

Interest rate benchmark reform – Phase 2

Interest Rate Benchmark Reform Phase 2: Amendments to IFRS 9, 
IAS 39, IFRS 7, IFRS 4 and IFRS 16 issued in August 2020 
represents the second phase of the IASB’s project on the effects of 
interest rate benchmark reform, addressing issues affecting 
financial statements when changes are made to contractual cash 
flows and hedging relationships as a result of the reform. 

Under these amendments, changes made to a financial instrument 
that are economically equivalent and required by interest rate 
benchmark reform do not result in the derecognition or a change 
in the carrying amount of the financial instrument, but instead 
require the effective interest rate to be updated to reflect the 
change in the interest rate benchmark. In addition, hedge 
accounting will not be discontinued solely because of the 
replacement of the interest rate benchmark if the hedge meets 
other hedge accounting criteria.

These amendments apply from 1 January 2021 with early adoption 
permitted. HSBC has adopted the amendments from 1 January 
2020 and has made the additional disclosures as required by the 
amendments, see pages 112 to 113. 

Critical accounting estimates and judgements

The results of HSBC reflect the choice of accounting policies, 
assumptions and estimates that underlie the preparation of 
HSBC’s consolidated financial statements. The significant 
accounting policies, including the policies which include 
critical accounting estimates and judgements, are described 
in Note 1.2 on the financial statements. The accounting policies 
listed below are highlighted as they involve a high degree of 
uncertainty and have a material impact on the financial 
statements:

• Impairment of amortised cost financial assets and financial 
assets measured at fair value through other comprehensive 
income (‘FVOCI’): The most significant judgements relate to 
defining what is considered to be a significant increase in credit 
risk, determining the lifetime and point of initial recognition of 
revolving facilities, and making assumptions and estimates to 
incorporate relevant information about past events, current 
conditions and forecasts of economic conditions. A high degree 
of uncertainty is involved in making estimations using 
assumptions that are highly subjective and very sensitive to the 
risk factors. See Note 1.2(i) on page 293.

• Deferred tax assets: The most significant judgements relate to 
judgements made in respect of expected future profitability. 
See Note 1.2(l) on page 298.

• Valuation of financial instruments: In determining the fair value 
of financial instruments a variety of valuation techniques are 
used, some of which feature significant unobservable inputs 
and are subject to substantial uncertainty. See Note 1.2(c) on 
page 291.

• Impairment of interests in associates: Impairment testing 

involves significant judgement in determining the value in use, 
and in particular estimating the present values of cash flows 
expected to arise from continuing to hold the investment, 
based on a number of management assumptions. The most 
significant judgements relate to the impairment testing of our 
investment in Bank of Communications Co., Limited (‘BoCom’). 
See Note 1.2(a) on page 290.

HSBC Holdings plc Annual Report and Accounts 2020

77

Financial review 
 
Financial summary

•

Impairment of goodwill and non-financial assets: A high 
degree of uncertainty is involved in estimating the future cash 
flows of the cash-generating units (‘CGUs’) and the rates used 
to discount these cash flows. See Note 1.2(a) on page 290.

• Provisions: Significant judgement may be required due to the 

high degree of uncertainty associated with determining 
whether a present obligation exists, and estimating the 
probability and amount of any outflows that may arise. See 
Note 1.2(m) on page 298.

• Post-employment benefit plans: The calculation of the defined 
benefit pension obligation involves the determination of key 

assumptions including discount rate, inflation rate, pension 
payments and deferred pensions, pay and mortality. See Note 
1.2(k) on page 297.

Given the inherent uncertainties and the high level of subjectivity 
involved in the recognition or measurement of the items above, it 
is possible that the outcomes in the next financial year could differ 
from the expectations on which management’s estimates are 
based, resulting in the recognition and measurement of materially 
different amounts from those estimated by management in these 
financial statements.

Consolidated income statement

Summary consolidated income statement

Net interest income 

Net fee income 

Net income from financial instruments held for trading or managed on a fair value basis

Net income/(expense) from assets and liabilities of insurance businesses, including 
related derivatives, measured at fair value through profit or loss

Footnotes

2020

$m

2019
$m

27,578   

30,462   

11,874   

12,023   

9,582   

10,231   

2018
$m

30,489   

12,620   

9,531   

2017
$m

28,176   

12,811   

8,426   

2016
$m

29,813 

12,777 

7,521 

2,081   

3,478   

(1,488)   

2,836   

1,262 

Change in fair value of designated debt and related derivatives

1

231   

90   

(97)   

155   

(1,997) 

Changes in fair value of other financial instruments mandatorily measured at fair value 
through profit or loss

Gains less losses from financial investments 

Net insurance premium income 

Other operating income/(expense)

Total operating income 

455   

653   

812   

335   

695 

218   

10,093   

10,636   

10,659   

527   

2,957   

960   

N/A

1,150   

9,779   

443   

N/A

1,385 

9,951 

(876) 

63,074   

71,024   

63,587   

63,776   

59,836 

Net insurance claims and benefits paid and movement in liabilities to policyholders 

(12,645)   

(14,926)   

(9,807)   

(12,331)   

(11,870) 

Net operating income before change in expected credit losses and other 
credit impairment charges/Loan impairment charges and other credit risk 
provisions

Change in expected credit losses and other credit impairment charges

Loan impairment charges and other credit risk provisions

Net operating income 

2

50,429   

56,098   

53,780   

51,445   

47,966 

(8,817)   

(2,756)   

(1,767) 

N/A

N/A

N/A

N/A

N/A  

(1,769)   

(3,400) 

41,612   

53,342   

52,013   

49,676   

44,566 

Total operating expenses excluding impairment of goodwill and other intangible assets

(33,044)   

(34,955)   

(34,622)   

(34,849)   

(36,416) 

Impairment of goodwill and other intangible assets

Operating profit

Share of profit in associates and joint ventures 

Profit before tax 

Tax expense 

Profit for the year 

Attributable to:

–  ordinary shareholders of the parent company

–  preference shareholders of the parent company

–  other equity holders

–  non-controlling interests

Profit for the year

Five-year financial information

Basic earnings per share

Diluted earnings per share

Dividends per ordinary share

Dividend payout ratio

Post-tax return on average total assets

Return on average ordinary shareholders’ equity

Return on average tangible equity

Effective tax rate

(1,388)   

(7,394)   

(37)   

(35)   

(3,392) 

7,180   

1,597   

8,777   

10,993   

17,354   

14,792   

2,354   

2,536   

2,375   

13,347   

19,890   

17,167   

4,758 

2,354 

7,112 

(2,678)   

(4,639)   

(4,865)   

(5,288)   

(3,666) 

6,099   

8,708   

15,025   

11,879   

3,446 

3,898   

5,969   

12,608   

9,683   

1,299 

90   

1,241   

870   

6,099   

90   

1,324   

1,325   

8,708   

90   

1,029   

1,298   

90   

1,025   

1,081   

15,025   

11,879   

Footnotes

3

4

2020

$
0.19   
0.19   
—   

%

— 
0.2   
 2.3 

 3.1 
 30.5   

2019

$

0.30   

0.30   
0.51   
%

 172.2 

0.3   

 3.6 

 8.4 

2018

$

0.63   

0.63   

0.51   

%

 81.0 

0.6   

 7.7 

 8.6 

2017

$

0.48   

0.48   

0.51   

%

 106.3 

0.5   

 5.9 

 6.8   

34.8   

24.5   

30.8   

51.5 

90 

1,090 

967 

3,446 

2016

$

0.07 

0.07 

0.51 

%

 728.6 

0.1 

 0.8 

2.6 

1  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch.
2  Net operating income before change in expected credit losses and other credit impairment charges/Loan impairment charges and other credit risk 

provisions, also referred to as revenue. 

3  Dividends recorded in the financial statements are dividends per ordinary share declared and paid in the period and are not dividends in respect 

of, or for, that period. 

4  Dividends per ordinary share expressed as a percentage of basic earnings per share.

Unless stated otherwise, all tables in the Annual Report and Accounts 2020 are presented on a reported basis.

For a summary of our financial performance in 2020, see page 27.

For further financial performance data for each global business and geographical region, see pages 85 to 88 and 92 to 102 respectively. The global business 
segmental results are presented on an adjusted basis in accordance with IFRS 8 ‘Operating Segments’, in Note 10: Segmental analysis on page 311.

78

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Income statement commentary

The following commentary compares Group financial performance for the year ended 2020 with 2019.

Net interest income

Interest income

Interest expense 

Net interest income

Average interest-earning assets 

Gross interest yield

Less: gross interest payable 

Net interest spread

Net interest margin

Year ended

Quarter ended

31 Dec

2020

$m
41,756   
(14,178)   
27,578   
2,092,900   

31 Dec

2019

$m

54,695   

(24,233)   

30,462   

1,922,822   

31 Dec

2018

$m
49,609   
(19,120)   
30,489   
1,839,346   

31 Dec

2020

$m

9,301   

(2,682)   

6,619   

30 Sep

2020

$m

9,455   

(3,005)   

6,450   

31 Dec

2019

$m

13,229 

(5,575) 

7,654 

2,159,003   

2,141,454   

1,945,596 

%

 2.00 

 (0.81) 

 1.19 

 1.32 

%

 2.84 

 (1.48) 

 1.36 

 1.58 

%

 2.70 

 (1.21) 

 1.49 

 1.66 

%

 1.71 

 (0.60) 

 1.11 

 1.22 

%

 1.76 

 (0.68) 

 1.08 

 1.20 

%

 2.70 

 (1.34) 

 1.36 

 1.56 

Footnotes

1

1

2

3

1  Gross interest yield is the average annualised interest rate earned on average interest-earning assets (‘AIEA’). Gross interest payable is the average 

annualised interest cost as a percentage on average interest-bearing liabilities.

2  Net interest spread is the difference between the average annualised interest rate earned on AIEA, net of amortised premiums and loan fees, and 

the average annualised interest rate payable on average interest-bearing funds.

3  Net interest margin is net interest income expressed as an annualised percentage of AIEA.   

Summary of interest income by type of asset

2020

2019

2018

Short-term funds and loans and advances 
to banks

Loans and advances to customers

Reverse repurchase agreements – non-trading

Financial investments 

Other interest-earning assets 

Total interest-earning assets 

298,255    1,264 

  1,046,795    29,391 

221,901    1,819 

463,542    8,143 

62,407    1,139 

  2,092,900    41,756 

 0.42   
 2.81   
 0.82   
 1.76   
 1.83   
 2.00   

Summary of interest expense by type of liability

Average
balance

Interest
income

$m

$m

Yield

%

Average
balance

Interest
income

$m

$m

Yield

%

 1.13   

 3.48   

 2.08   

 2.56   

 2.88   

Average
balance

$m

Interest
income

$m

233,637   

2,475 

972,963    33,285 

205,427   

386,230   

41,089   

3,739 

9,166 

944 

212,920   

2,411 

1,021,554    35,578 

224,942   

4,690 

417,939    10,705 

45,467   

1,311 

1,922,822    54,695 

 2.84   

1,839,346    49,609 

2020

2019

2018

Deposits by banks

Customer accounts

Repurchase agreements – non-trading

Debt securities in issue – non-trading

Other interest-bearing liabilities

Total interest-bearing liabilities

1

2

Footnotes

$m

Average
balance

Interest
expense

65,536   

$m

330 

  1,254,249    6,478 

125,376   

963 

219,610    4,944 

76,395    1,463 

  1,741,166    14,178 

Cost

%

 0.50   
 0.52   
 0.77   
 2.25   
 1.92   
 0.81   

Average
balance

Interest
expense

$m
52,515   

$m

702 

Cost

%

Average
balance

Interest
expense

$m

 1.34   

44,530   

1,149,483    11,238 

 0.98   

1,138,620   

160,850   

211,229   

59,980   

4,023 

6,522 

1,748 

 2.50   

 3.09   

 2.91   

161,204   

183,434   

53,731   

1,634,057    24,233 

 1.48   

1,581,519    19,120 

$m

506 

8,287 

3,409 

5,675 

1,243 

Yield

%

 1.06 

 3.42 

 1.82 

 2.37 

 2.30 

 2.70 

Cost

%

 1.14 

 0.73 

 2.11 

 3.09 

 2.31 

 1.21 

1 
2 

Including interest-bearing bank deposits only. 
Including interest-bearing customer accounts only.

Net interest income (‘NII’) for 2020 was $27.6bn, a decrease of 
$2.9bn or 9.5% compared with 2019. This reflected lower average 
market interest rates across the major currencies compared with 
2019. This was partly offset by interest income associated with the 
increase in average interest-earning assets (‘AIEA’) of $170.1bn or 
8.8%.
Excluding the favourable impact of significant items and the 
adverse effects of foreign currency translation differences, net 
interest income decreased by $2.7bn or 9%.
NII for the fourth quarter of 2020 was $6.6bn, down 13.5% year-
on-year, and up 2.6% compared with the previous quarter. The 
year-on-year decrease was driven by the impact of lower market 
interest rates predominantly in Asia and North America. This was 
partly offset by higher NII from growth in AIEA, notably short-term 
funds and financial investments and predominantly in Asia and 
Europe. The increase compared with the previous quarter was 
mainly driven by lower rates on customer deposits and issued 
debt securities, which were partly offset by lower rates on AIEA.

Net interest margin (‘NIM’) for 2020 of 1.32% was 26 basis 
points (‘bps’) lower compared with 2019 as the reduction in the 
yield on AIEA of 84bps was partly offset by the fall in funding 
costs of average interest-bearing liabilities of 67bps. The decrease 
in NIM in 2020 included the favourable impacts of significant 
items and the adverse effects of foreign currency translation 
differences. Excluding this, NIM fell by 25bps.

NIM for the fourth quarter of 2020 was 1.22%, down 34bps year-
on-year, and up 2bps compared with the previous quarter. The 
year-on-year decrease was mainly driven by Asia and caused by 
the impact of lower market interest rates. The increase compared 
with the previous quarter was driven by a reduction in funding 
costs of average interest-bearing liabilities of 8bps, which was 
partly offset by a reduction in the yield on AIEA of 5bps.
Interest income for 2020 of $41.8bn decreased by $12.9bn or 
24%, primarily due to the lower average interest rates compared 
with 2019 as the yield on AIEA fell by 84bps. This was partly offset 
by income from balance sheet growth, predominantly in Asia and 
Europe. The balance sheet growth was driven by higher balances 
in short-term funds and loans and advances to banks and financial 

HSBC Holdings plc Annual Report and Accounts 2020

79

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial summary

investments, which increased by $85.3bn and $45.6bn, 
respectively. The decrease in interest income included $0.2bn in 
relation to the favourable impact of significant items and $0.8bn 
from the adverse effects of foreign currency translation 
differences. Excluding these, interest income decreased by 
$12.3bn.
Interest income of $9.3bn in the fourth quarter of 2020 was down 
$3.9bn year-on-year, and down $0.2bn compared with the 
previous quarter. The year-on-year decrease was predominantly 
driven by the impact of lower market interest rates, predominantly 
in Asia and in North America, although partly offset by growth in 
AIEA, notably short-term funds and loans and advances to banks 
and financial investments. The small decrease compared with the 
previous quarter was mainly driven by reduced rates on financial 
investments and loans and advances to customers.
Interest expense for 2020 of $14.2bn decreased by $10.1bn or 
41% compared with 2019. This reflected the decrease in funding 
costs of 67bps, mainly arising from lower interest rates paid on 
interest-bearing liabilities. This was partly offset by higher interest 
expense from growth in interest-bearing customer accounts, 
which increased by $104.8bn. The decrease in interest expense 
included the favourable effects of foreign currency translation 
differences of $0.5bn. Excluding this, interest expense decreased 
by $9.6bn.
Interest expense of $2.7bn in the fourth quarter of 2020 was down 
$2.9bn year-on-year, and down $0.3bn compared with the 
previous quarter. The year-on-year decrease was predominantly 
driven by the impact of lower market interest rates, partly offset by 
growth in interest-bearing customer accounts, which increased by 
$142.9bn. The small decrease compared with the previous quarter 
was mainly due to reduced funding costs on customer deposits 
and debt issuances. 
Net fee income of $11.9bn was $0.1bn lower, reflecting 
reductions in WPB and CMB, partly offset by an increase in GBM.
In WPB, lower fee income reflected a reduction in account 
services, notably in the UK, due to lower customer activity. Income 
from credit cards also reduced, as customer spending activity fell 
across most markets, mainly in Hong Kong, the UK, MENA and 
the US. Fee income on unit trusts fell, mainly in Hong Kong. These 
decreases were partly offset by higher income from broking, 
primarily in Hong Kong, as volatility in the equity markets resulted 
in increased customer activity. Fee expenses fell as a result of 
reduced customer activity levels, mainly in cards.
In CMB, trade-related fee income fell, reflecting the reduction in 
global trade activity, notably in Hong Kong and the UK. Income 
also fell in remittances due to lower client activity.
In GBM, net fee income was higher, mainly from growth in 
underwriting fees in the US and the UK. Global custody and 
broking fees also rose as client activity and turnover of securities 
increased due to market volatility. These increases were partly 
offset by a reduction in fee income from credit facilities, notably in 
the UK, Hong Kong and the US.
Net income from financial instruments held for trading or 
managed on a fair value basis of $9.6bn was $0.6bn lower and 
included a loss of $0.3bn from asset disposals relating to our 
restructuring programme. This was partly offset by favourable fair 
value movements on non-qualifying hedges of $0.1bn and 
favourable debit value adjustments of $0.1bn. 
The remaining reduction was primarily due to lower trading 
interest income, reflecting lower market rates. However, other 
trading income increased in GBM as elevated market volatility and 
wider spreads supported a strong performance in FICC.
Net income/(expense) from assets and liabilities of 
insurance businesses, including related derivatives, 
measured at fair value through profit or loss was a net 
income of $2.1bn, compared with a net income of $3.5bn in 2019. 
This decrease primarily reflected less favourable equity market 
performance, compared with 2019 in France and Hong Kong, due 
to the impact of the Covid-19 outbreak on the equity and unit trust 
assets supporting insurance and investment contracts. After large 
losses in the first quarter of 2020, there was a partial recovery in 
the remainder of the year, resulting in higher revenue in these 

80

HSBC Holdings plc Annual Report and Accounts 2020

subsequent quarters during 2020 compared with the equivalent 
quarters in 2019.
This adverse movement resulted in a corresponding movement in 
liabilities to policyholders and the present value of in-force long-
term insurance business (‘PVIF’) (see ‘Other operating income’ 
below). This reflected the extent to which the policyholders and 
shareholders respectively participate in the investment 
performance of the associated assets.
Change in fair value of designated debt and related 
derivatives of $0.2bn was $0.1bn favourable compared with 
2019. The movements were driven by the fall in interest rates 
between the periods, notably in US dollars and pounds sterling.
The majority of our financial liabilities designated at fair value are 
fixed-rate, long-term debt issuances and are managed in 
conjunction with interest rate swaps as part of our interest rate 
management strategy. These liabilities are discussed further on 
page 83.
Changes in fair value of other financial instruments 
mandatorily measured at fair value through profit or loss of 
$0.5bn was $0.4bn lower compared with 2019. This primarily 
reflected adverse movements in equity markets due to the impact 
of the Covid-19 outbreak.
Gains less losses from financial investments of $0.7bn 
increased by $0.3bn, reflecting higher gains from the disposal of 
debt securities in Markets Treasury.
Net insurance premium income of $10.1bn was $0.5bn lower 
than in 2019, reflecting lower new business volumes, particularly 
in France and Hong Kong, partly offset by lower reinsurance 
arrangements in Hong Kong.
Other operating income of $0.5bn decreased by $2.4bn 
compared with 2019, primarily due to lower favourable changes in 
PVIF compared with 2019 (down $1.4bn) and also the non-
recurrence of a $0.8bn dilution gain in 2019 following the merger 
of The Saudi British Bank (‘SABB’) with Alawwal bank in Saudi 
Arabia.
The change in PVIF included a reduction of $0.8bn due to 
assumption changes and experience variances, mainly in Hong 
Kong and France due to the effect of interest rate changes on the 
valuation of liabilities under insurance contracts. In addition, the 
value of new business written fell by $0.4bn, primarily in Hong 
Kong, as sales volumes decreased.
The reduction also reflected the non-recurrence of 2019 gains 
recognised in Argentina and Mexico. 
Net insurance claims and benefits paid and movement in 
liabilities to policyholders was $2.3bn lower, primarily due to 
lower returns on financial assets supporting contracts where the 
policyholder is subject to part or all of the investment risk. New 
business volumes were also lower, particularly in Hong Kong and 
France, partly offset by lower reinsurance arrangements in Hong 
Kong.
Changes in expected credit losses and other credit 
impairment charges (‘ECL’) of $8.8bn were $6.1bn higher 
compared with 2019 with increases in all global businesses.
The ECL charge in 2020 reflected a significant increase in stage 1 
and stage 2 allowances, notably in the first half of the year, to 
reflect the deterioration in the forward economic outlook globally 
as a result of the Covid-19 outbreak. The economic outlook 
stabilised in the second half of 2020 and as a result stage 1 and 
stage 2 allowances were broadly unchanged at 31 December 
2020, compared with 30 June 2020. Stage 3 charges also 
increased compared with 2019, largely against wholesale 
exposures, including a significant charge related to a CMB client in 
Singapore in the first quarter of 2020.
Excluding currency translation differences, ECL as a percentage of 
average gross loans and advances to customers was 0.81%, 
compared with 0.25% in 2019.
The estimated impact of the Covid-19 outbreak was incorporated 
in the ECL through additional scenario analysis, which considered 
differing severity and duration assumptions relating to the global 
pandemic. These included probability-weighted shocks to annual 
GDP and consequential impacts on unemployment and other 
economic variables, with differing economic recovery 

assumptions. Given the severity of the macroeconomic 
projections, and the complexities of the government measures, 
which have never been modelled, additional judgemental 
adjustments have been made to our provisions.
While we expect the full year ECL charge for 2021 to be materially 
lower than in 2020, the outlook is highly uncertain and remains 
dependent on the future path of the Covid-19 outbreak, including 

the successful deployment of mass vaccination programmes, and 
the credit quality of our loan portfolio as government support 
packages are gradually withdrawn.
For further details on the calculation of ECL, including the 
measurement uncertainties and significant judgements applied to 
such calculations, the impact of alternative/additional scenarios 
and management judgemental adjustments, see pages 127 to 135.

Operating expenses – currency translation and significant items

Significant items
–  costs of structural reform1
–  customer redress programmes

–  impairment of goodwill and other intangibles

–  past service costs of guaranteed minimum pension benefits equalisation
–  restructuring and other related costs2
–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items

Currency translation

Year ended 31 Dec

2020

$m 
2,973   
—   
(54)   
1,090   
17   
1,908   
12   

2,973   

2019

$m

9,607 

158 

1,281 

7,349 

— 

827 

(61) 

53 

223 
9,830 

1  Comprises costs associated with preparations for the UK’s exit from the European Union.
2 

Includes impairment of software intangible assets of $189m (of the total software intangible asset impairment of $1,347m) and impairment of 
tangible assets of $197m.

Staff numbers (full-time equivalents)

Global businesses

Wealth and Personal Banking

Commercial Banking

Global Banking and Markets

Corporate Centre

At 31 Dec

2020

20191

20181

135,727   
43,221   
46,729   
382   
226,059   

141,341   

140,666 

44,706   

48,859   

445   

45,046 

48,970 

535 

235,351   

235,217 

1  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly. For further guidance, see Note 10: 

Segmental analysis on page 311.

Operating expenses of $34.4bn were $7.9bn lower than in 2019, 
primarily reflecting the net favourable movements in significant 
items of $6.6bn, which included:
•

the non-recurrence of a $7.3bn impairment of goodwill in 
2019, primarily related to lower long-term economic growth 
assumptions in GBM and CMB, and the planned reshaping of 
GBM. This compared with a $1.1bn impairment of goodwill 
and other intangibles in 2020, primarily capitalised software 
related to the businesses within HSBC Bank plc, and to a lesser 
extent our businesses in the US. These impairments reflected 
underperformance and a deterioration in the future forecasts of 
these businesses, and in the case of HSBC Bank plc 
substantially relating to prior periods; and 
customer redress programme costs, which were a net release 
of $0.1bn in 2020, compared with charges of $1.3bn in 2019.  

•

This was partly offset by:
• restructuring and other related costs of $1.9bn in 2020, of 
which $0.9bn related to severance, $0.2bn related to an 
impairment of software intangibles and $0.2bn related to the 
impairment of tangible assets in France and the US. This 
compared with restructuring and other related costs of $0.8bn 
in 2019. 

The reduction also included favourable currency translation 
differences of $0.2bn. 
The remaining reduction of $1.1bn reflected a $0.5bn decrease in 
performance-related pay and lower discretionary expenditure, 
including marketing (down $0.3bn) and travel costs (down 
$0.3bn). In addition, our cost-saving initiatives resulted in a 
reduction of $1.4bn, of which $1.0bn related to our costs to 
achieve programme, and the UK bank levy was $0.2bn lower than 
in 2019. These decreases were partly offset by an increase in 
investments in technology to enhance our digital and automation 
capabilities to improve how we serve our customers, as well as 
inflation and volume-related increases. In addition, the 2020 period 
included impairments of certain real estate assets.

During 2020, we reduced the number of employees expressed in 
full-time equivalent staff (‘FTE’) and contractors by 11,011. This 
included a 9,292 reduction in FTE to 226,059 at 31 December 
2020, while the number of contractors reduced by 1,719 to 5,692 
at 31 December 2020.
Share of profit in associates and joint ventures of $1.6bn 
was $0.8bn or 32% lower than in 2019, primarily reflecting our 
share of an impairment of goodwill by SABB of $0.5bn. This 
goodwill was recognised by SABB on the completion of its merger 
with Alawwal bank in 2019. The remaining reduction reflected a 
lower share of profit recognised from our associates in Asia and 
MENA due to the impact of the Covid-19 outbreak and the lower 
interest-rate environment.
At 31 December 2020, we performed an impairment review of our 
investment in BoCom and concluded that it was not impaired, 
based on our value-in-use (‘VIU’) calculations. However, the 
excess of the VIU of BoCom and its carrying value has reduced 
over the period, increasing the risk of impairment in the future.
For more information, see Note 18: Interests in associates and 
joint ventures on page 331. 

Tax expense
The effective tax rate for 2020 of 30.5% was lower than the 34.8% 
effective tax rate for 2019. An impairment of goodwill and non-
deductible customer redress charges increased the 2019 effective 
tax rate. These were not repeated in 2020. Additionally, the non-
taxable dilution gain arising on the merger of SABB with Alawwal 
bank decreased the effective tax rate in 2019. Higher charges in 
respect of the non-recognition of deferred tax assets, particularly 
in the UK ($0.4bn) and France ($0.4bn), increased the 2020 
effective tax rate.

HSBC Holdings plc Annual Report and Accounts 2020

81

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial summary

Consolidated balance sheet

Five-year summary consolidated balance sheet

Assets

Cash and balances at central banks

Trading assets

Financial assets designated and otherwise mandatorily measured at fair 
value through profit or loss

Financial assets designated at fair value

Derivatives

Loans and advances to banks

Loans and advances to customers

Reverse repurchase agreements – non-trading

Financial investments

Other assets

Total assets at 31 Dec

Liabilities and equity

Liabilities

Deposits by banks

Customer accounts

Repurchase agreements – non-trading

Trading liabilities

Financial liabilities designated at fair value

Derivatives

Debt securities in issue

Liabilities under insurance contracts

Other liabilities

Total liabilities at 31 Dec

Equity

Total shareholders’ equity

Non-controlling interests

Total equity at 31 Dec

Total liabilities and equity at 31 Dec

1   Net of impairment allowances.

Footnotes

2020

$m

2019

$m

2018

$m

2017

$m

2016

$m

304,481   

231,990   

154,099   

254,271   

162,843   

238,130   

180,624   

287,995   

128,009 

235,125 

45,553   

43,627   

41,111 

N/A

N/A   

N/A

N/A  

29,464   

307,726   

242,995   

207,825   

219,818   

81,616   

69,203   

1

1,037,987   

1,036,743   

230,628   

490,693   

253,490   

240,862   

443,312   

230,040   

72,167   

981,696   

242,804   

407,433   

204,115   

90,393   

962,964   

201,553   

389,076   

159,884   

N/A

24,756 

290,872 

88,126 

861,504 

160,974 

436,797 

148,823 

2,984,164   

2,715,152   

2,558,124   

2,521,771   

2,374,986 

82,080   

59,022   

56,331   

69,922   

59,939 

1,642,780   

1,439,115   

1,362,643   

1,364,462   

1,272,386 

111,901   

140,344   

165,884   

83,170   

164,466   

239,497   

104,555   

97,439   

84,431   

148,505   

205,835   

85,342   

87,330   

130,002   

184,361   

94,429   

216,821   

64,546   

85,667   

88,958 

153,691 

86,832 

279,819 

65,915 

75,273 

75,266   

157,439   

303,001   

95,492   

107,191   

204,019   

194,876   

167,574   

113,690   

109,595 

2,779,169   

2,522,484   

2,363,875   

2,323,900   

2,192,408 

196,443   

183,955   

186,253   

190,250   

175,386 

8,552   

8,713   

7,996   

7,621   

7,192 

204,995   

192,668   

194,249   

197,871   

182,578 

2,984,164   

2,715,152   

2,558,124   

2,521,771   

2,374,986 

A more detailed consolidated balance sheet is contained in the financial statements on page 280.

Five-year selected financial information

Called up share capital 

Capital resources

Undated subordinated loan capital 

Preferred securities and dated subordinated loan capital

Risk-weighted assets

Total shareholders’ equity

Less: preference shares and other equity instruments

Total ordinary shareholders’ equity

Less: goodwill and intangible assets (net of tax)

Tangible ordinary shareholders’ equity

Financial statistics

Loans and advances to customers as a percentage of customer accounts

Average total shareholders’ equity to average total assets

Net asset value per ordinary share at year-end ($) 

Tangible net asset value per ordinary share at year-end ($)

Tangible net asset value per fully diluted share at year-end ($)

Number of $0.50 ordinary shares in issue (millions) 

Basic number of $0.50 ordinary shares outstanding (millions)

Basic number of $0.50 ordinary shares outstanding and dilutive potential 
ordinary shares (millions)

Closing foreign exchange translation rates to $:

$1: £

$1: € 

Footnotes

1

2

3

2020

$m
10,347   
184,423   
1,970   
30,721   
857,520   
196,443   
(22,414)   
174,029   
(17,606)   
156,423   

63.2%

6.46%

8.62   
7.75   
7.72   
20,694   
20,184   

2019

$m

2018

$m

2017

$m

10,319   

10,180   

10,160   

172,150   

173,238   

182,383   

1,968   

33,063   

843,395   

183,955   

(22,276)   

161,679   

(17,535)   

144,144   

72.0%

6.97%

8.00   

7.13   

7.11   

20,639   

20,206   

1,969   

35,014   

865,318   

186,253   

(23,772)   

162,481   

(22,425)   

140,056   

72.0%

7.16%

8.13   

7.01   

6.98   

20,361   

19,981   

1,969   

42,147   

871,337   

190,250   

(23,655)   

166,595   

(21,680)   

144,915   

70.6%

7.33%

8.35   

7.26   

7.22   

20,321   

19,960   

2016

$m

10,096 

172,358 

1,967 

42,600 

857,181 

175,386 

(18,515) 

156,871 

(19,649) 

137,222 

67.7%

7.37%

7.91 

6.92 

6.88 

20,192 

19,838 

20,272   

20,280   

20,059   

20,065   

19,933 

0.732   

0.816   

0.756   

0.890   

0.783   

0.873   

0.740   

0.834   

0.811 

0.949 

1   Capital resources are regulatory capital, the calculation of which is set out on page 173.
2   Including perpetual preferred securities, details of which can be found in Note 28: Subordinated liabilities on page 344.
3   The definition of net asset value per ordinary share is total shareholders’ equity, less non-cumulative preference shares and capital securities, 

divided by the number of ordinary shares in issue, excluding own shares held by the company, including those purchased and held in treasury. 

82

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Balance sheet commentary compared with 
31 December 2019

At 31 December 2020, our total assets were $3.0tn, an increase of 
$269bn or 10% on a reported basis and $200bn or 7% on a 
constant currency basis. 

The increase in total assets primarily reflected growth in cash 
balances, derivative assets and financial investments.

On a reported basis, our ratio of customer advances to customer 
accounts was 63.2%, compared with 72.0% at 31 December 2019, 
mainly due to growth in customer accounts.

Assets

Cash and balances at central banks increased by $150bn or 
98%, mainly in the UK, France, Hong Kong and North America, as 
a result of deposit inflows and an increase in the commercial 
surplus.

Trading assets decreased by $22bn or 9%, notably from a 
reduction in debt securities held, along with a reduction in bond 
positions previously used for hedging purposes.

Derivative assets increased by $65bn or 27%, primarily in the 
UK, France and Hong Kong, reflecting favourable revaluation 
movements on interest rate contracts as interest rates fell in most 
major markets. There was also an increase in foreign exchange 
contracts linked to valuation movements attributable to market 
conditions. The growth in derivative assets was consistent with 
the increase in derivative liabilities, as the underlying risk is 
broadly matched.

Loans and advances to customers of $1.0tn increased by $1bn 
on a reported basis. This included favourable foreign currency 
translation differences of $26bn. Excluding the effects of foreign 
currency translation differences, loans and advances to customers 
decreased by $25bn or 2%. 

Liabilities

Customer accounts of $1.6tn increased by $204bn or 14% on a 
reported basis and included the favourable effect of foreign 
currency translation differences of $31bn. Excluding this, 
customer accounts increased by $173bn or 12%.

The commentary below is on a constant currency basis.

Customer accounts increased in all our global businesses and 
regions. In CMB, balances grew by $73bn, and in GBM, customer 
accounts increased by $33bn. These increases included the impact 
of corporate clients consolidating their funds and depositing these 
into their customer accounts to maintain liquidity, notably in the 
UK, Hong Kong and the US.

In WPB, customer account balances increased by $67bn, notably 
in the UK and Hong Kong, reflecting reduced customer spending 
resulting in larger balances held in current and savings accounts.

Repurchase agreements – non-trading decreased by $28bn or 
20%, primarily in the US, in line with our actions to manage our 
funding requirements across the Group.

Derivative liabilities increased by $64bn or 27%, which is 
consistent with the increase in derivative assets, since the 
underlying risk is broadly matched.

Equity

Total shareholders’ equity, including non-controlling interests, 
increased by $12bn or 6% compared with 31 December 2019, 
reflecting the effects of profits generated of $6.1bn combined with 
other comprehensive income (‘OCI’) of $8bn. OCI included fair 
value gains on debt instruments of $2bn, favourable 
remeasurement of defined benefit pension obligations of $1bn and 
foreign exchange differences of $5bn. These increases were partly 
offset by $2bn of coupon distributions on securities classified as 
equity and dividends paid by non-controlling interests.

The commentary below is on a constant currency basis.

Risk-weighted assets

In GBM, customer lending was down $28bn or 11%, while in CMB 
customer lending was down $11bn or 3%. Despite significant 
growth in these businesses in the first quarter of 2020 from 
customers drawing down on credit facilities, balances 
subsequently reduced as customers made repayments in part due 
to the uncertain economic outlook.

In GBM, lower lending was mainly from decreases in term lending 
in Asia, Europe and the US, and also from a decrease in overdrafts 
in Europe. 

In CMB, the decrease in customer lending reflected a reduction in 
other lending and overdrafts in Asia and North America. In Europe, 
lending remained relatively flat as lower other lending and 
overdrafts were almost entirely offset by a rise in term lending. 

In WPB, lending increased by $14bn or 3%, notably from 
mortgage growth in the UK (up $12bn) and in Hong Kong (up 
$5bn). This was partly offset by a $6bn reduction in credit card 
balances and overdrafts as customer activity fell as a result of 
government measures to contain the outbreak of Covid-19.

Financial investments increased by $47bn or 11%, mainly as we 
redeployed our commercial surplus. We increased our holdings of 
debt securities and treasury bills and benefited from valuation 
gains resulting from interest rate reductions. The increases in 
financial investments were notably observed in Hong Kong, as we 
increased our holdings of government-issued bonds and bills. 
These increases were partly offset by lower holdings of debt 
securities in Canada.

Other assets increased by $23bn due to a $10bn increase in cash 
collateral balances, mainly in France and Hong Kong as underlying 
derivative balances grew. Additionally, there were increases in 
precious metals balances, mainly in the US as we grew our 
depository.

Risk-weighted assets (‘RWAs’) totalled $857.5bn at 31 December 
2020, a $14.1bn increase since 2019. Excluding foreign currency 
translation differences, RWAs increased by $1.0bn in 2020, and 
included the following movements: 

•

a $9.7bn asset size decrease, largely driven by RWA 
reductions in CMB and GBM under our transformation 
programme. This was partly offset by lending growth and 
increases in counterparty credit risk RWAs due to mark-to-
market movements;

• a $24.5bn increase in RWAs due to changes in asset quality, 
mostly in CMB and GBM. This was largely due to credit 
migration in Asia, North America and Europe, partly offset by 
decreases due to portfolio mix changes; and

•

a $14.2bn fall in RWAs due to changes in methodology and 
policy, mostly in GBM and CMB. This included reductions 
under management initiatives involving risk parameter 
refinements, improved collateral linkage, and data 
enhancement, and changes under the CRR ‘Quick Fix’ relief 
package. These reductions were partly offset by changes in 
approach to credit risk exposures.

From a global business perspective, primarily in GBM and CMB, 
increases from credit migration, lending growth, and market risk 
volatility were mitigated by reductions of $51.5bn as a result of 
our transformation programme.

HSBC Holdings plc Annual Report and Accounts 2020

83

Financial reviewFinancial summary

Customer accounts by country/territory

Europe

–  UK

–  France

–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Singapore

–  mainland China

–  Australia

–  India

–  Malaysia

–  Taiwan

–  Indonesia

–  other

Middle East and North Africa (excluding Saudi Arabia)

–  United Arab Emirates

–  Turkey

–  Egypt

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

At 31 Dec

Loans and advances, deposits by currency

2020

$m

629,647   
504,275   
55,111   
21,605   
10,102   
38,554   
762,406   
531,489   
55,140   
56,826   
29,286   
20,199   
15,997   
16,041   
5,198   
32,230   
41,221   
20,974   
3,987   
5,659   
10,601   
182,028   
117,485   
56,520   
8,023   
27,478   
22,220   
5,258   
1,642,780   

2019

$m

528,718 

419,642 

47,699 

19,361 

6,558 

35,458 

697,358 

499,955 

48,569 

48,323 

23,191 

14,935 

14,624 

14,668 

4,732 

28,361 

38,126 

17,949 

3,870 

5,186 

11,121 

146,676 

90,834 

48,425 

7,417 

28,237 

23,051 

5,186 

1,439,115 

$m

Loans and advances to banks

Loans and advances to customers

Total loans and advances

Deposits by banks

Customer accounts

Total deposits

$m

Loans and advances to banks

Loans and advances to customers

Total loans and advances

Deposits by banks

Customer accounts

Total deposits

At

31 Dec 2020

USD

GBP

HKD

17,959   

3,495   

7,155   

173,117   

280,803   

222,138   

191,076   

284,298   

229,293   

EUR

4,601   

89,851   

94,452   

CNY

6,063   

Others1
42,343   

Total

81,616 

37,671   

234,407   

1,037,987 

43,734   

276,750   

1,119,603 

30,239   

7,856   

2,884   

25,291   

4,904   

10,906   

82,080 

433,647   

431,143   

310,197   

135,851   

60,971   

270,971   

1,642,780 

463,886   

438,999   

313,081   

161,142   

65,875   

281,877   

1,724,860 

At

31 Dec 2019

USD

19,386   

177,696   

197,082   

23,508   

360,462   

383,970   

GBP

3,245   

264,029   

267,274   

7,537   

358,764   

366,301   

HKD

6,242   

234,945   

241,187   

1,865   

299,049   

300,914   

EUR

4,266   

84,919   

89,185   

11,154   

122,988   

134,142   

CNY

5,772   

34,338   

40,110   

4,265   

52,216   

56,481   

Others

30,292   

Total

69,203 

240,816   

1,036,743 

271,108   

1,105,946 

10,693   

59,022 

245,636   

1,439,115 

256,329   

1,498,137 

1   ‘Others’ includes items with no currency information available ($8,671m for loans to banks, $56,729m for loans to customers, $4m for deposits by 

banks and $5m for customer accounts).

84

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses and
geographical regions

Summary

Reconciliation of reported and adjusted items – global businesses

Reconciliation of reported and adjusted risk-weighted assets

Supplementary tables for WPB and GBM

Analysis of reported results by geographical regions

Reconciliation of reported and adjusted items – geographical regions

Analysis by country

Summary

.

Page

85

85

88

88

92

94

100

The Group Chief Executive, supported by the rest of the Group 
Executive Committee (‘GEC') (previously the Group Management 

Board), reviews operating activity on a number of bases, including 
by global business and geographical region. Global businesses are 
our reportable segments under IFRS 8 ‘Operating Segments’ and 
are presented in Note 10: Segmental analysis on page 311. 

Geographical information is classified by the location of the 
principal operations of the subsidiary or, for The Hongkong and 
Shanghai Banking Corporation Limited, HSBC Bank plc, HSBC UK 
Bank plc, HSBC Bank Middle East Limited and HSBC Bank USA, 
by the location of the branch responsible for reporting the results 
or providing funding.

The expense of the UK bank levy is included in the Europe 
geographical region as HSBC regards the levy as a cost of being 
headquartered in the UK. For the purposes of the presentation by 
global business, the cost of the levy is included in the Corporate 
Centre. 

The results of geographical regions are presented on a reported 
basis.

Reconciliation of reported and adjusted items – global businesses

Supplementary unaudited analysis of significant items by global business is presented below.

Wealth and 
Personal Banking

Commercial
Banking

2020

Global
Banking and
Markets

Corporate 
Centre

Footnotes

$m

$m

$m

$m

1

2

3

4

5

Revenue

Reported 

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  restructuring and other related costs

Adjusted 

ECL

Reported 

Adjusted

Operating expenses

Reported 

Significant items

–  customer redress programmes

–  impairment of goodwill and other intangibles

–  past service costs of guaranteed minimum pension benefits 

equalisation

–  restructuring and other related costs

–  settlements and provisions in connection with legal and 

regulatory matters

Adjusted 

Share of profit in associates and joint ventures

Reported 

Significant items

–  impairment of goodwill

Adjusted

Profit/(loss) before tax

Reported

Significant items

–  revenue 

–  operating expenses

–  share of profit in associates and joint ventures

Adjusted 

Loans and advances to customers (net)

Reported

Adjusted 

Customer accounts

Reported
Adjusted 

21,999   

13,294   

14   

5   

9   

—   

—   

18   

16   

—   

1   

1   

22,013   

13,312   

(2,855)   

(2,855)   

(4,754)   

(4,754)   

14,994   

309   

—   

—   

2   

307   

15,303   

(1,209)   

(1,209)   

(15,446)   

(6,900)   

(10,169)   

422   

(64)   

294   

—   

211   

1   

45   

—   

905   

—   

577   

—   

142   

(404)   

—   

1   

(267)   

(138)   

(262)   

1   

1   

(1,917)   

1,435   

9   

174   

17   

Total

$m

50,429 

(63) 

21 

10 

(264) 

170 

50,366 

(8,817) 

(8,817) 

(34,432) 

2,973 

(54) 

1,090 

17 

192   

165   

326   

1,225   

1,908 

—   

—   

2   

(15,024)   

(6,689)   

(9,264)   

10   

(482)   

12 

(31,459) 

6   

—   

—   

6   

(1)   

—   

—   

(1)   

3,704   

1,639   

436   

14   

422   

—   

229   

18   

211   

—   

—   

—   

—   

—   

3,616   

1,214   

309   

905   

—   

4,140   

1,868   

4,830   

1,592   

462   

462   

2,054   

(182)   

1,493   

(404)   

1,435   

462   

1,311   

1,597 

462 

462 

2,059 

8,777 

3,372 

(63) 

2,973 

462 

12,149 

469,186   

343,182   

469,186   

343,182   

224,364   

224,364   

1,255   

1,255   

1,037,987 

1,037,987 

834,759   
834,759   

470,428   
470,428   

336,983   
336,983   

610   
610   

1,642,780 
1,642,780 

Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives. 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises losses associated with the RWA reduction commitments and gains relating to the business update in February 2020.
4 

Includes impairment of software intangible assets of $189m (of the total software intangible asset impairment of $1,347m) and impairment of 
tangible assets of $197m.

5  During the year, The Saudi British Bank ('SABB'), an associate of HSBC, impaired the goodwill that arose following the merger with Alawwal bank 

in 2019. HSBC's post-tax share of the goodwill impairment was $462m.

HSBC Holdings plc Annual Report and Accounts 2020

85

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses 

Reconciliation of reported and adjusted items (continued)

Wealth and 
Personal Banking

Commercial
Banking

20194

Global
Banking and
Markets

Footnotes

$m

$m

$m

1

2

3

Revenue

Reported 

Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  currency translation on significant items

Adjusted 

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

Significant items

–  costs of structural reform

–  customer redress programmes

–  goodwill impairment

–  restructuring and other related costs

–  settlements and provisions in connection with legal and 

regulatory matters

–  currency translation on significant items

Adjusted 

Share of profit in associates and joint ventures

Reported 

Currency translation

Adjusted

Profit before tax

Reported

Currency translation

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

25,552   

(208)   

221   

155   

52   

7   

7   

15,256   

(103)   

14,894   

(107)   

11   

7   

—   

4   

—   

82   

—   

—   

84   

(2)   

25,565   

15,164   

14,869   

(1,437)   

89   

(1,348)   

(17,351)   

135   

1,828   

—   

1,264   

431   

180   

(69)   

22   

(1,192)   

30   

(1,162)   

(9,905)   

18   

3,055   

4   

17   

2,956   

51   

—   

27   

(162)   

9   

(153)   

(13,790)   

21   

4,225   

42   

—   

3,962   

217   

2   

2   

Corporate 
Centre

$m

396   

(53)   

(997)   

1   

(820)   

(179)   

1   

(654)   

35   

1   

36   

Total

$m

56,098 

(471) 

(683) 

163 

(768) 

(84) 

6 

54,944 

(2,756) 

129 

(2,627) 

(1,303)   

(42,349) 

49   

499   

112   

—   

—   

379   

6   

2   

223 

9,607 

158 

1,281 

7,349 

827 

(61) 

53 

(15,388)   

(6,832)   

(9,544)   

(755)   

(32,519) 

55   

(1)   

54   

6,819   

15   

2,049   

221   

1,828   

8,883   

443,025   

12,593   

455,618   

753,769   

14,382   

768,151   

—   

—   

—   

4,159   

(55)   

3,066   

11   

3,055   

7,170   

346,105   

7,676   

353,781   

388,723   

8,459   

397,182   

—   

—   

—   

942   

(77)   

4,307   

82   

4,225   

5,172   

246,492   

5,639   

252,131   

295,880   

8,214   

304,094   

2,299   

(2)   

2,297   

2,354 

(3) 

2,351 

1,427   

13,347 

(5)   

(498)   

(997)   

499   

924   

(122) 

8,924 

(683) 

9,607 

22,149 

1,121   

1,036,743 

45   

25,953 

1,166   

1,062,696 

743   

37   

780   

1,439,115 

31,092 

1,470,207 

Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises costs associated with preparations for the UK’s exit from the European Union.
4  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly. For further guidance, see Note 10: 

Segmental analysis on page 311.

86

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Wealth and 
Personal Banking

Commercial
Banking

20184

Global
Banking and
Markets

Footnotes

$m

$m

$m

Corporate 
Centre

$m

1

2

3

Revenue

Reported 

Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  currency translation on significant items

Adjusted 

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

Significant items

–  costs of structural reform

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  past service costs of guaranteed minimum pension benefits 

equalisation

–  restructuring and other related costs

–  settlements and provisions in connection with legal and 

regulatory matters

–  currency translation on significant items

Adjusted 

Share of profit in associates and joint ventures

Reported 

Currency translation

Adjusted

Profit/(loss) before tax

Reported

Currency translation

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

24,232   

(699)   

14,889   

(475)   

18   

—   

2   

16   

—   

(40)   

(53)   

—   

9   

4   

15,754   

(1,095)   

(590)   

(108)   

—   

—   

(112)   

4   

(90)   

302   

—   

111   

187   

4   

23,551   

14,374   

15,056   

(883)   

52,098 

Total

$m

53,780 

(1,854) 

172 

(53) 

113 

100 

12 

(1,163)   

91   

(1,072)   

(15,522)   

625   

283   

2   

172   

52   

—   

7   

58   

(8)   

(737)   

54   

(683)   

(6,563)   

255   

1   

8   

(5)   

—   

—   

—   

—   

(2)   

(14,614)   

(6,307)   

33   

(1)   

32   

7,580   

16   

301   

18   

283   

—   

—   

—   

7,589   

(166)   

(39)   

(40)   

1   

7,897   

7,384   

5,774   

401,268   

17,963   

419,231   

707,773   

22,129   

729,902   

333,400   

11,455   

344,855   

359,957   

12,594   

372,551   

245,525   

7,794   

253,319   

294,130   

12,308   

306,438   

26   

8   

34   

(9,512)   

304   

(108)   

41   

(21)   

—   

—   

—   

(132)   

4   

(9,316)   

—   

—   

—   

107   

(6)   

101   

(3,062)   

96   

1,480   

310   

—   

—   

228   

59   

890   

(7)   

(1,767) 

147 

(1,620) 

(34,659) 

1,280 

1,656 

361 

146 

52 

228 

66 

816 

(13) 

(1,486)   

(31,723) 

2,503   

(91)   

2,412   

2,536 

(92) 

2,444 

6,268   

(1,547)   

19,890 

(278)   

(216)   

(108)   

(108)   

(91)   

1,782   

302   

1,480   

144   

1,503   

96   

(519) 

1,828 

172 

1,656 

21,199 

981,696 

37,308 

1,599   

1,019,004 

783   

48   

831   

1,362,643 

47,079 

1,409,722 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises costs associated with preparations for the UK’s exit from the European Union, costs to establish the UK ring-fenced bank (including the 

Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.

UK ServCo group) and costs associated with establishing an intermediate holding company in Hong Kong.

4  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly. For further guidance, see Note 10: 

Segmental analysis on page 311.

HSBC Holdings plc Annual Report and Accounts 2020

87

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses 

Reconciliation of reported and adjusted risk-weighted assets

Risk-weighted assets

Reported

Adjusted

Risk-weighted assets

Reported

Currency translation

Adjusted

Risk-weighted assets

Reported

Currency translation

Disposals

–  operations in Brazil

Adjusted

Wealth and 
Personal 
Banking

Commercial
Banking

At 31 Dec 2020

Global
Banking and
Markets

Corporate 
Centre

Footnotes

$bn

$bn

$bn

$bn

Total

$bn

1

1

1

172.8   

172.8   

327.7   

327.7   

265.1   

265.1   

91.9   

91.9   

857.5 

857.5 

At 31 Dec 2019

162.6   

2.0   

164.6   

325.9   

6.6   

332.5   

273.4   

3.4   

276.8   

81.5   

0.5   

82.0   

843.4 

12.5 

855.9 

At 31 Dec 2018

161.8   

2.2   

—   

—   

331.8   

10.3   

—   

—   

297.9   

4.4   

—   

—   

164.0   

342.1   

302.3   

73.8   

0.6   

(0.8)   

(0.8)   

73.6   

865.3 

17.5 

(0.8) 

(0.8) 

882.0 

1  Adjusted risk-weighted assets are calculated using reported risk-weighted assets adjusted for the effects of currency translation differences and 

significant items.

Supplementary tables for WPB and GBM

WPB adjusted performance by business unit

A breakdown of WPB by business unit is presented below to reflect the basis of how the revenue performance of the business units is 
assessed and managed.

WPB – summary (adjusted basis)

Footnotes

Total 
WPB

$m

Banking 
operations

Insurance 
manufacturing

Global Private 
Banking

Asset 
management

$m

$m

$m

$m

Consists of1

2020

Net operating income before change in expected credit losses and other 
credit impairment charges

2

–  net interest income

–  net fee income/(expense)

–  other income

ECL

Net operating income

Total operating expenses

Operating profit

Share of profit in associates and joint ventures

Profit before tax

2019

Net operating income before change in expected credit losses and 
other credit impairment charges

2

–  net interest income

–  net fee income/(expense)

–  other income

ECL

Net operating income

Total operating expenses

Operating profit

Share of profit in associates and joint ventures

Profit before tax

22,013   

15,090   

5,408   

1,515   

(2,855)   

19,158   

17,346   

12,181   

4,094   

1,071   

(2,707)   

14,639   

(15,024)   

(12,422)   

4,134   

2,217   

6   

5   

1,874   

2,241   

(518)   

151   

(80)   

1,794   

(479)   

1,315   

1   

4,140   

2,222   

1,316   

1,745   

1,048 

670   

828   

247   

(67)   

1,678   

(1,390)   

288   

—   

288   

(2) 

1,004 

46 

(1) 

1,047 

(733) 

314 

— 

314 

25,565   

17,423   

5,621   

2,521   

(1,348)   

24,217   

(15,388)   

8,829   

54   

8,883   

20,024   

14,371   

4,582   

1,071   

(1,247)   

18,777   

(12,722)   

6,055   

11   

6,066   

2,639   

2,167   

(717)   

1,189   

(80)   

2,559   

(471)   

2,088   

43   

2,131   

1,878   

1,024 

891   

784   

203   

(21)   

1,857   

(1,447)   

410   

—   

410   

(6) 

972 

58 

— 

1,024 

(748) 

276 

— 

276 

88

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
WPB – summary (adjusted basis) (continued)

Footnotes

Total 
WPB

$m

Banking 
operations

Insurance 
manufacturing

Global Private 
Banking

Asset 
management

$m

$m

$m

$m

Consists of1

2018
Net operating income before change in expected credit losses and other 
credit impairment charges

2

–  net interest income

–  net fee income/(expense)

–  other income

ECL

Net operating income

Total operating expenses

Operating profit

Share of profit in associates and joint ventures

Profit before tax

23,551   

16,418   

5,774   

1,359   

(1,072)   

22,479   

(14,614)   

7,865   

32   

7,897   

18,860   

13,477   

4,594   

789   

(1,079)   

17,781   

(12,023)   

5,758   

1   

5,759   

1,868   

2,060   

(593)   

401   

(1)   

1,867   

(437)   

1,430   

31   

1,461   

1,783   

884   

743   

156   

8   

1,791   

(1,449)   

342   

—   

342   

1,040 

(3) 

1,030 

13 

— 

1,040 

(705) 

335 

— 

335 

1  The results presented for insurance manufacturing operations are shown before elimination of inter-company transactions with HSBC non-

insurance operations. These eliminations are presented within Banking operations.

2  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue. WPB insurance 

manufacturing adjusted revenue of $1,874m (2019: $2,639m, 2018: $1,868m) was disclosed within the management view of adjusted revenue on 
page 31, as follows: Wealth Management $1,816m (2019: $2,464m, 2018: $1,621m) and Other $58m (2019: $175m, 2018: $247m). 

WPB insurance manufacturing adjusted results 

The following table shows the results of our insurance 
manufacturing operations by income statement line item. It shows 

the results of insurance manufacturing operations for WPB and for 
all global business segments in aggregate, and separately the 
insurance distribution income earned by HSBC bank channels.

Adjusted results of insurance manufacturing operations and insurance distribution income earned by HSBC bank channels1, 2

Net interest income

Net fee income/(expense)

–  fee income

–  fee expense

Net income from/(expenses) financial instruments held for trading or 
managed on a fair value basis

Net income/(expense) from assets and liabilities of insurance businesses, 
including related derivatives, measured at fair value through profit or loss

Gains less losses from financial investments

Net insurance premium income

Other operating income

Of which: PVIF

Total operating income

Net insurance claims and benefits paid and movement in liabilities to 
policyholders

Net operating income before change in expected credit losses and 
other credit impairment charges

Change in expected credit losses and other credit impairment charges

Net operating income

Total operating expenses

Operating profit

Share of profit in associates and joint ventures

Profit before tax of insurance manufacturing operations

Annualised new business premiums of insurance manufacturing operations

Insurance distribution income earned by HSBC bank channels

2020

2019

2018

WPB

$m  

All global 
businesses

$m

WPB

$m

All global 
businesses

$m

WPB

$m

All global 
businesses

$m

Footnotes

2,241   

2,408   

2,167   

2,308   

2,060   

2,217 

(518)   

110   

(628)   

(556)   

131   

(687)   

(717)   

108   

(825)   

(742)   

130   

(872)   

(593)   

186   

(779)   

(567) 

277 

(844) 

76   

95   

(82)   

(82)   

84   

27 

2,182   

2,137   

3,582   

3,565   

(1,600)   

(1,627) 

13   

13   

5   

5   

54   

56 

9,717   

10,212   

10,398   

10,763   

10,280   

10,824 

336   

370   

351   

382   

1,789   

1,718   

1,805   

1,763   

796   

678   

783 

685 

14,047   

14,660   

17,142   

17,622   

11,081   

11,713 

(12,173)   

(12,683)   

(14,503)   

(14,902)   

(9,213)   

(9,693) 

3

4

1,874   

1,977   

2,639   

2,720   

1,868   

2,020 

(80)   

(92)   

(80)   

(86)   

(1)   

1,794   

1,885   

2,559   

2,634   

1,867   

(479)   

(509)   

(471)   

(497)   

(437)   

1,315   

1,376   

2,088   

2,137   

1,430   

1   

1,316   

2,257   

737   

1   

1,377   

2,307   

801   

43   

2,131   

3,324   

945   

43   

2,180   

3,403   

1,041   

31   

1,461   

3,179   

949   

(1) 

2,019 

(462) 

1,557 

31 

1,588 

3,255 

1,040 

1  Adjusted results are derived by adjusting for year-on-year effects of foreign currency translation differences, and the effect of significant items that 
distort year-on-year comparisons. There are no significant items included within insurance manufacturing, and the impact of foreign currency 
translation on all global businesses’ profit before tax is 2019: $45m favourable (reported: $2,135m), 2018: $15m favourable (reported: $1,573m).

2  The results presented for insurance manufacturing operations are shown before elimination of inter-company transactions with HSBC non-

insurance operations.

3  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
4  The effect on the insurance manufacturing operations of applying hyperinflation accounting in Argentina resulted in an increase in adjusted 

revenue in 2020 of $9m (2019: reduction of $1m, 2018: reduction of $8m) and an increase in profit before tax in 2020 of $12m (2019: increase of 
$1m, 2018: reduction of $3m). These effects are recorded within ‘All global businesses’.

HSBC Holdings plc Annual Report and Accounts 2020

89

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses 

Insurance manufacturing

The following commentary, unless otherwise specified, relates to 
the ‘All global businesses’ results.

HSBC recognises the present value of long-term in-force insurance 
contracts and investment contracts with discretionary 
participation features (‘PVIF’) as an asset on the balance sheet. 
The overall balance sheet equity, including PVIF, is therefore a 
measure of the embedded value in the insurance manufacturing 
entities, and the movement in this embedded value in the period 
drives the overall income statement result.

Adjusted profit before tax of $1.4bn decreased by $0.8bn or 37% 
compared with 2019.

Net operating income before change in expected credit losses and 
other credit impairment changes was $0.7bn or 27% lower than in 
2019. This reflected the following: 

• ‘Net income from assets and liabilities of insurance businesses, 
including related derivatives, measured at fair value through 
profit or loss’ of $2.1bn in 2020 compared with $3.6bn in 2019. 
This decrease primarily reflected less favourable equity market 
performance, compared with 2019 in France and Hong Kong, 
due to the impact of the Covid-19 outbreak on the equity and 
unit trust assets supporting insurance and investment 
contracts. While there was strong investment performance 
within the portfolio in light of volatile markets during the year, 
the overall fair value gains were lower compared with 2019.

This adverse movement resulted in a corresponding movement 
in liabilities to policyholders and PVIF (see ‘Other operating 
income’ below). This reflected the extent to which 
policyholders and shareholders respectively participate in the 
investment performance of the associated assets.

• Net insurance premium income of $10.2bn was $0.6bn lower 
than in 2019, primarily reflecting lower new business volumes 
due to the Covid-19 outbreak, particularly in France and Hong 
Kong, partly offset by lower reinsurance premiums ceded in 
Hong Kong.

• Other operating income of $0.4bn decreased by $1.5bn 

compared with 2019, mainly from adverse movements in PVIF. 
This included a reduction of $0.8bn due to assumption changes 
and experience variances, mainly in Hong Kong and France due 
to the effect of interest rate changes. In addition, the value of 

WPB – reported client assets and funds under management1

Global Private Banking client assets

–  managed by Global Asset Management

–  external managers, direct securities and other

Retail wealth balances

–  managed by Global Asset Management

–  external managers, direct securities and other

Asset Management third-party distribution

Closing balance

new business written fell by $0.4bn, primarily in Hong Kong, as 
sales volumes decreased.

• Net insurance claims and benefits paid and movement in 

liabilities to policyholders was $2.2bn lower, primarily due to 
lower returns on financial assets supporting contracts where 
the policyholder is subject to part or all of the investment risk. 
New business volumes were lower, particularly in Hong Kong 
and France, partly offset by lower reinsurance arrangements in 
Hong Kong.

• Change in expected credit losses and other credit impairment 

charges (‘ECL’) of $92m was $6m higher compared with 2019, 
mainly from charges relating to the global impact of the 
Covid-19 outbreak on the forward economic outlook, partly 
offset by the ECL release on Argentina sovereign exposure due 
to the debt restructure in 2020.

Adjusted operating expenses of $0.5bn increased by 2% 
compared with 2019, reflecting investments in core insurance 
functions and capabilities during the period.

Annualised new business premiums (‘ANP’) is used to assess new 
insurance premium generation by the business. It is calculated as 
100% of annualised first year regular premiums and 10% of single 
premiums, before reinsurance ceded. Lower ANP during the 
period reflected a reduction in new business volumes, mainly in 
Hong Kong and France.

Insurance distribution income from HSBC channels included 
$470m (2019: $658m; 2018: $644m) on HSBC manufactured 
products, for which a corresponding fee expense is recognised 
within insurance manufacturing, and $331m (2019: $382m; 2018: 
$397m) on products manufactured by third-party providers. The 
WPB component of this distribution income was $423m (2019: 
$583m; 2018: $575m) from HSBC manufactured products and 
$314m (2019: $362m; 2018: $374m) from third-party products.

WPB: Client assets and funds under management

The following table shows the client assets and funds under 
management, including self-directed client investments and 
execution-only trades, across our WPB global business. Funds 
under management represents assets managed, either actively or 
passively, on behalf of our customers.

2020

$bn

394   

66   

328   

407   

219   

188   

317   

1,118   

2019

$bn

361 

61 

300 

380 

199 

181 

247 

988 

1  Client assets and funds distributed and under management are not reported on the Group’s balance sheet, except where it is deemed that we are 

acting as principal rather than agent in our role as investment manager. Customer deposits included in client assets are on balance sheet.

WPB wealth balances

The following table shows the consolidated areas of focus across all WPB wealth balances.

WPB wealth balances

Client assets and funds under management
Premier and Jade deposits1
Total

2020

$bn

1,118   

470   

1,588   

2019

$bn

988 

433 

1,421 

1  Premier and Jade deposits, which include Prestige deposits in Hang Seng Bank, form part of the total WPB customer accounts balance of $835bn 

on page 85 (31 December 2019: $754bn).

90

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
Asset Management: Funds under management

The following table shows the funds under management of our 
Asset Management business. Funds under management 
represents assets managed, either actively or passively, on behalf 

of our customers. Funds under management are not reported on 
the Group’s balance sheet, except where it is deemed that we are 
acting as principal rather than agent in our role as investment 
manager.

Asset Management – reported funds under management

Opening balance

Net new money

Value change

Exchange and other

Closing balance

Asset Management – reported funds under management by geography

Europe

Asia

MENA

North America

Latin America

Closing balance

2020

$bn

506   

53   

17   

26   

602   

2020

$bn

346   

176   

6   

65   

9   

602   

2019

$bn

444   

30   

30   

2   

506   

2019

$bn

287   

161   

6   

44   

8   

506   

2018

$bn

462 

8 

(14) 

(12) 

444 

2018

$bn

235 

164 

2 

36 

7 

444 

At 31 December 2020, Asset Management funds under 
management amounted to $602bn, an increase of $96bn or 19%. 
The increase reflected strong net new money, primarily from 
money market funds and passive investment products. In addition, 
the growth reflected positive market performance and favourable 
foreign exchange translation.

Global Private Banking: client assets

The following table shows the client assets of our Global Private 
Banking business which are translated at the rates of exchange 
applicable for their respective year-ends, with the effects of 
currency translation reported separately.

Global Private Banking – reported client assets1

At 1 Jan

Net new money 

Value change

Disposals

Exchange and other

At 31 Dec

Global Private Banking – reported client assets by geography1

Europe 

Asia 

North America

At 31 Dec

2020

$bn

361   

6   

6   

—   

21   

394   

2020

$bn

174   

176   

44   

394   

2019

$bn

309   

23   

23   

—   

6   

361   

2019

$bn

171   

151   

39   

361   

2018

$bn

330 

10 

(17) 

— 

(14) 

309 

2018

$bn

149 

124 

36 

309 

1  Client assets are not reported on the Group’s balance sheet, except where it is deemed that we are acting as principal rather than agent in our role 

as investment manager. Customer deposits included in these client assets are on balance sheet.

GBM: Securities Services and Issuer Services

Assets under administration

Assets held in custody

Custody is the safekeeping and servicing of securities and other 
financial assets on behalf of clients. Assets held in custody are not 
reported on the Group’s balance sheet, except where it is deemed 
that we are acting as principal rather than agent in our role as 
investment manager. At 31 December 2020, we held $10.0tn of 
assets as custodian, 17% higher than at 31 December 2019. This 
increase was driven by favourable market movements and the 
effect of currency translation differences globally. In addition, 
there were increases from new client asset inflows, notably in 
Asia.

Our assets under administration business, which includes the 
provision of bond and loan administration services, transfer 
agency services and the valuation of portfolios of securities and 
other financial assets on behalf of clients, complements the 
custody business. At 31 December 2020, the value of assets held 
under administration by the Group amounted to $4.5tn, which was 
13% higher than at 31 December 2019. This increase was mainly 
driven by the favourable effect of currency translation differences 
in Europe and favourable market movements globally. It also 
included increases from the onboarding of new client assets, 
notably in Europe.

HSBC Holdings plc Annual Report and Accounts 2020

91

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Analysis of reported results by geographical regions

HSBC reported profit/(loss) before tax and balance sheet data

Net interest income

Net fee income

Net income from financial instruments held for 
trading or managed on a fair value basis

Net income from assets and liabilities of insurance 
businesses, including related derivatives, measured 
at fair value through profit and loss

Changes in fair value of other financial instruments 
mandatorily measured at fair value through profit or 
loss

Other income/(expense)

Net operating income before change in
expected credit losses and other credit
impairment charges

Change in expected credit losses and other credit
impairment charges

2020

Footnotes

Europe

$m

5,695   

3,499   

Asia

$m

MENA

$m

14,318   

1,465   

5,418   

695   

North 
America

Latin 
America

Intra-HSBC

$m

2,836   

1,795   

$m

$m

1,960   

1,304   

467   

—   

Total

$m

27,578 

11,874 

3,266   

4,273   

402   

997   

593   

51   

9,582 

327   

1,699   

—   

—   

55   

—   

2,081 

1

2

1,747   

3,885   

17   

1,197   

3   

63   

2   

745   

40   

(95)   

(1,354)   

455 

(6,936)   

(1,141) 

18,419   

26,922   

2,628   

6,375   

3,020   

(6,935)   

50,429 

(3,751)   

(2,284)   

(758)   

(900)   

(1,124)   

—   

(8,817) 

Net operating income 

14,668   

24,638   

1,870   

5,475   

1,896   

(6,935)   

41,612 

Total operating expenses excluding impairment of 
goodwill and other intangible assets

Impairment of goodwill and other intangible assets

Operating profit/(loss)

Share of profit/(loss) in associates and joint ventures

Profit/(loss) before tax

Share of HSBC’s profit before tax

Cost efficiency ratio 

Balance sheet data

(17,860)   

(13,584)   

(1,521)   

(5,081)   

(1,933)   

6,935   

(33,044) 

(1,014)   

(78)   

(4,206)   

10,976   

1   

1,856   

(4,205)   

12,832   

%

(47.9)

102.5

$m

%

146.2

50.7

$m

(65)   

284   

(265)   

19   

%

0.2

60.4

$m

(226)   

168   

—   

168   

%

1.9

83.2

$m

(5)   

(42)   

5   

(37)   

%

(0.4)

64.2

$m

—   

—   

—   

—   

$m

(1,388) 

7,180 

1,597 

8,777 

%

100.0

68.3

$m

Loans and advances to customers (net)

408,495   

473,165   

28,700   

107,969   

19,658   

—    1,037,987 

  1,416,111    1,206,404   

68,860   

373,167   

49,703   

(130,081)    2,984,164 

629,647   

762,406   

41,221   

182,028   

27,478   

3

284,322   

384,228   

60,181   

117,755   

35,240   

—    1,642,780 

—   

857,520 

Total assets 

Customer accounts

Risk-weighted assets

Net interest income

Net fee income

Net income from financial instruments held for 
trading or managed on a fair value basis

Net income from assets and liabilities of insurance 
businesses, including related derivatives, measured 
at fair value through profit and loss

Changes in fair value of other financial instruments 
mandatorily measured at fair value through profit or 
loss

Other income/(expense)

Net operating income before change in
expected credit losses and other credit
impairment charges

1

2

Change in expected credit losses and other credit
impairment charges

Net operating income 

Total operating expenses excluding impairment of 
goodwill and other intangible assets

Impairment of goodwill and other intangible assets

Operating profit/(loss)

Share of profit/(loss) in associates and joint ventures

Profit/(loss) before tax

Share of HSBC’s profit before tax

Cost efficiency ratio 

Balance sheet data

5,601   

3,668   

16,607   

5,325   

1,781   

685   

3,241   

1,804   

2,061   

540   

1,171   

1   

30,462 

12,023 

2019

3,785   

4,735   

327   

873   

883   

(372)   

10,231 

1,656   

1,803   

—   

—   

14   

5   

3,478 

1,516   

1,830   

28   

1,921   

1   

916   

31   

638   

41   

(23)   

(805)   

(6,190)   

812 

(908) 

18,056   

30,419   

3,710   

6,587   

3,516   

(6,190)   

56,098 

(938)   

(724)   

17,118   

29,695   

(117)   

3,593   

(237)   

6,350   

(740)   

—   

(2,756) 

2,776   

(6,190)   

53,342 

(19,209)   

(13,284)   

(1,452)   

(5,150)   

(2,050)   

6,190   

(34,955) 

(2,550)   

(4,641)   

(12)   

(13)   

16,398   

2,070   

(4,653)   

18,468   

%

(34.9)

120.5

$m

%

138.4

43.7

$m

(97)   

2,044   

283   

2,327   

%

17.4

41.8

$m

(433)   

767   

—   

767   

%

5.7

84.8

$m

(339)   

387   

13   

400   

%

3.0

67.9

$m

(3,962)   

(3,962)   

—   

(3,962)   

(29.6)

$m

(7,394) 

10,993 

2,354 

13,347 

%

100.0

75.5

$m

Loans and advances to customers (net)

393,850   

477,727   

28,556   

113,474   

23,136   

—    1,036,743 

Total assets 

Customer accounts

Risk-weighted assets

  1,248,205    1,102,805   

65,369   

377,095   

52,879   

(131,201)    2,715,152 

528,718   

697,358   

38,126   

146,676   

3

280,983   

366,375   

57,492   

121,953   

28,237   

38,460   

—    1,439,115 

—   

843,395 

92

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC reported profit/(loss) before tax and balance sheet data (continued)

Net interest income

Net fee income

Net income from financial instruments held for 
trading or managed on a fair value basis

Net income/(expense) from assets and liabilities of 
insurance businesses, including related derivatives, 
measured at fair value through profit and loss

Changes in fair value of other financial instruments 
mandatorily measured at fair value through profit or 
loss

Other income/(expense)

Net operating income before loan impairment 
(charges)/recoveries and other credit risk provisions

Change in expected credit losses and other credit
impairment (charges)/recoveries

Net operating income 

Total operating expenses excluding impairment of 
goodwill and other intangible assets

Impairment of goodwill and other intangible assets

Operating profit/(loss)

Share of profit  in associates and joint ventures

Profit/(loss) before tax

Share of HSBC’s profit before tax

Cost efficiency ratio 

Balance sheet data

2018

Footnotes

Europe

$m

6,841   

3,996   

Asia

$m

16,108   

5,676   

MENA

$m

1,763   

607   

North 
America

Latin 
America

Intra-HSBC 
items

$m

3,521   

1,854   

$m

2,020   

498   

$m

236   

(11)   

Total

$m

30,489 

12,620 

3,942   

4,134   

285   

728   

736   

(294)   

9,531 

(789)   

(717)   

—   

—   

18   

—   

(1,488) 

1

2

601   

(26)   

3,113   

3,609   

(1)   

33   

36   

586   

27   

58   

(237)   

(5,171)   

695 

1,933 

17,704   

28,784   

2,687   

6,725   

3,062   

(5,182)   

53,780 

(609)   

(602)   

17,095   

28,182   

(209)   

2,478   

223   

(570)   

—   

(1,767) 

6,948   

2,492   

(5,182)   

52,013 

(17,912)   

(12,449)   

(1,357)   

(6,151)   

(1,935)   

5,182   

(34,622) 

(22)   

(839)   

24   

(815)   

%

 (4.1) 

 101.3 

$m

(17)   

15,716   

2,074   

17,790   

%

 89.5 

 43.3 

$m

—   

1,121   

436   

1,557   

%

 7.8 

 50.5 

$m

2   

799   

—   

799   

%

 4.0 

 91.4 

$m

—   

557   

2   

559   

%

 2.8 

 63.2 

$m

—   

—   

—   

—   

$m

(37) 

17,354 

2,536 

19,890 

%

 100.0 

 64.4 

$m

Loans and advances to customers (net)

373,073   

450,545   

28,824   

108,146   

21,108   

—   

981,696 

Total assets 

Customer accounts

Risk-weighted assets

  1,150,235    1,047,636   

57,455   

390,410   

51,923   

(139,535)    2,558,124 

503,154   

664,824   

35,408   

133,291   

3

298,056   

363,894   

56,689   

131,582   

25,966   

38,341   

—    1,362,643 

—   

865,318 

1 

‘Other income/(expense)’ in this context comprises where applicable net income/expense from other financial instruments designated at fair value, 
gains less losses from financial investments, dividend income, net insurance premium income and other operating income less net insurance 
claims and benefits paid and movement in liabilities to policyholders.

2  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
3  Risk-weighted assets are non-additive across geographical regions due to market risk diversification effects within the Group.

HSBC Holdings plc Annual Report and Accounts 2020

93

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items – geographical regions

Reconciliation of reported and adjusted items

Revenue

Reported 

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  restructuring and other related costs

Adjusted 

ECL

Reported 

Adjusted

Operating expenses

Reported 

Significant items

–  customer redress programmes

–  impairment of goodwill and other intangibles

–  past service costs of guaranteed minimum pension benefits equalisation

–  restructuring and other related costs

–  settlements and provisions in connection with legal and regulatory matters

Adjusted

Share of profit/(loss) in associates and joint ventures

Reported 

Significant items

–  impairment of goodwill

Adjusted

Profit/(loss) before tax

Reported

Significant items

–  revenue 

–  operating expenses

–  share of profit in associates and joint ventures

Adjusted 

Loans and advances to customers (net)

Reported

Adjusted 

Customer accounts

Reported

Adjusted 

2,5

2

6

2

2

Footnotes

Europe

$m

Asia

$m

MENA

$m

North
America

Latin
America

$m

$m

Total

$m

2020

1

2

3

2,4

2

18,419   

26,922   

2,628   

6,375   

3,020   

50,429 

(242)   

(37)   

21   

—   

(254)   

(9)   

—   

—   

(5)   

(32)   

—   

—   

—   

—   

—   

43   

—   

10   

(2)   

35   

(3)   

—   

—   

(3)   

—   

(63) 

21 

10 

(264) 

170 

18,177   

26,885   

2,628   

6,418   

3,017   

50,366 

(3,751)   

(2,284)   

(3,751)   

(2,284)   

(758)   

(758)   

(900)   

(1,124)   

(8,817) 

(900)   

(1,124)   

(8,817) 

2

(18,874)   

(13,662)   

(1,586)   

(5,307)   

(1,938)   

(34,432) 

2,203   

171   

(54)   

803   

17   

1,425   

12   

—   

—   

—   

171   

—   

83   

—   

64   

—   

19   

—   

601   

—   

223   

—   

378   

—   

91   

2,973 

—   

—   

—   

91   

—   

(54) 

1,090 

17 

1,908 

12 

(16,671)   

(13,491)   

(1,503)   

(4,706)   

(1,847)   

(31,459) 

1,856   

(265)   

1   

—   

—   

1   

—   

—   

1,856   

(4,205)   

12,832   

1,961   

(242)   

2,203   

—   

134   

(37)   

171   

—   

(2,244)   

12,966   

462   

462   

197   

19   

545   

—   

83   

462   

564   

—   

—   

—   

—   

168   

644   

43   

601   

—   

812   

5   

—   

—   

5   

(37)   

88   

(3)   

91   

—   

51   

1,597 

462 

462 

2,059 

8,777 

3,372 

(63) 

2,973 

462 

12,149 

  408,495    473,165   

28,700    107,969   

19,658   1,037,987 

  408,495    473,165   

28,700    107,969   

19,658   1,037,987 

  629,647    762,406   

41,221    182,028   

27,478   1,642,780 

  629,647    762,406   

41,221    182,028   

27,478   1,642,780 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2  Amounts are non-additive across geographical regions due to inter-company transactions within the Group.
3 
Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.
4   Comprises losses associated with the RWA reduction commitments and gains relating to the business update in February 2020.
5 

Includes impairment of software intangible assets of $189m (of the total software intangible asset impairment of $1,347m) and impairment of 
tangible assets of $197m.

6  During the year, The Saudi British Bank ('SABB'), an associate of HSBC, impaired the goodwill that arose following the merger with Alawwal bank 

in 2019. HSBC's post-tax share of the goodwill impairment was $462m.

94

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Footnotes

UK

$m

2020

Hong 
Kong

$m

Mainland 
China

$m

US

$m

Mexico

$m

Revenue

Reported

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  restructuring and other related costs

1

2

3

Adjusted

ECL

Reported 

Adjusted

Operating expenses

Reported 

Significant items

–  customer redress programmes

–  impairment of goodwill and other intangibles

–  past service costs of guaranteed minimum pension benefits equalisation

–  restructuring and other related costs

–  settlements and provisions in connection with legal and regulatory matters

Adjusted

Share of profit/(loss) in associates and joint ventures

Reported 

Significant items

–  impairment of goodwill

Adjusted

Profit/(loss) before tax

Reported

Significant items

–  revenue 

–  operating expenses

–  share of profit in associates and joint ventures

Adjusted 

Loans and advances to customers (net)

Reported

Adjusted 

Customer accounts

Reported

Adjusted 

13,886   

16,345   

3,088   

4,590   

2,234 

(187)   

21   

—   

(256)   

48   

15   

—   

—   

—   

15   

(5)   

—   

—   

(1)   

(4)   

41   

—   

10   

(2)   

33   

(13) 

— 

— 

(1) 

(12) 

13,699   

16,360   

3,083   

4,631   

2,221 

(3,256)   

(3,256)   

(824)   

(824)   

(114)   

(114)   

(622)   

(622)   

(1,050) 

(1,050) 

(14,855)   

(7,312)   

(2,211)   

(4,194)   

(1,376) 

1,318   

100   

(54)   

650   

17   

693   

12   

—   

—   

—   

100   

—   

19   

—   

—   

—   

19   

—   

556   

—   

223   

—   

333   

—   

42 

— 

— 

— 

42 

— 

(13,537)   

(7,212)   

(2,192)   

(3,638)   

(1,334) 

1   

—   

—   

1   

(2)   

—   

—   

(2)   

1,849   

—   

—   

1,849   

(4,224)   

8,207   

2,612   

1,131   

(187)   

1,318   

—   

115   

15   

100   

—   

14   

(5)   

19   

—   

(3,093)   

8,322   

2,626   

—   

—   

—   

—   

(226)   

597   

41   

556   

—   

371   

5 

— 

— 

5 

(187) 

29 

(13) 

42 

— 

(158) 

  314,530    302,454   

46,113   

58,082   

17,296 

  314,530    302,454   

46,113   

58,082   

17,296 

  504,275    531,489   

56,826    117,485   

22,220 

  504,275    531,489   

56,826    117,485   

22,220 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises losses associated with the RWA reduction commitments and gains relating to the business update in February 2020.

Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.

HSBC Holdings plc Annual Report and Accounts 2020

95

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items (continued)

Revenue
Reported 
Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  currency translation on significant items
Adjusted 
ECL

Reported 

Currency translation

Adjusted

Operating expenses
Reported 
Currency translation

Significant items

–  costs of structural reform

–  customer redress programmes

–  goodwill impairment

–  restructuring and other related costs

–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items
Adjusted 
Share of profit/(loss) in associates and joint ventures

Reported 

Currency translation

Adjusted

Profit/(loss) before tax

Reported

Currency translation

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

Footnotes

Europe

$m

Asia

$m

MENA

$m

North
America

$m

Latin
America

$m

Total

$m

2019

1

2

2

3

2

18,056   

30,419   

3,710   

6,587   

3,516   

56,098 

125   

30   
163   

—   

(137)   

4   

34   

35   
—   

—   

35   

—   

(26)   

(826)   
—   

(828)   

—   

2   

(17)   

(613)   

68   
—   

59   

9   

—   

10   
—   

1   

9   

—   

(471) 

(683) 
163 

(768) 

(84) 

6 

18,211   

30,488   

2,858   

6,638   

2,913   

54,944 

(938)   

(2)   

(940)   

(724)   

—   

(724)   

(117)   

2   

(115)   

(237)   

—   

(237)   

(740)   

129   

(611)   

(2,756) 

129 

(2,627) 

2,5

(21,759)   

(13,297)   

(1,549)   

(5,583)   

(2,389)   

(42,349) 

2

5

4

5

5

5

5

5

(166)   

4,495   
154   

1,281   

2,522   

538   

(60)   

60   

25   

126   
4   

—   

—   

123   

(1)   

—   

28   

112   
—   

—   

97   

15   

—   

—   

11   

543   
—   

—   

431   

113   

—   

(1)   

351   

369   
—   

—   

337   

38   

—   

(6)   

223 

9,607 
158 

1,281 

7,349 

827 

(61) 

53 

(17,430)   

(13,146)   

(1,409)   

(5,029)   

(1,669)   

(32,519) 

(12)   

—   

(12)   

2,070   

(1)   

2,069   

283   

—   

283   

(4,653)   

18,468   

2,327   

(43)   

4,525   

30   

4,495   

58   

161   

35   

126   

4   

(714)   

(826)   

112   

—   

—   

—   

767   

(6)   

611   

68   

543   

(171)   

18,687   

1,617   

1,372   

13   

(2)   

11   

2,354 

(3) 

2,351 

400   

13,347 

(135)   

379   

10   

369   

644   

(122) 

8,924 

(683) 

9,607 

22,149 

393,850   

477,727   

28,556   

113,474   

23,136    1,036,743 

18,021   

9,114   

(537)   

964   

(1,609)   

25,953 

411,871   

486,841   

28,019   

114,438   

21,527    1,062,696 

528,718   

697,358   

38,126   

146,676   

28,237    1,439,115 

22,977   

10,172   

(731)   

979   

(2,305)   

31,092 

551,695   

707,530   

37,395   

147,655   

25,932    1,470,207 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2   Amounts are non-additive across geographical regions due to inter-company transactions within the Group.
Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.
3 
4  Comprises costs associated with preparations for the UK’s exit from the European Union.
5  Amounts are non-additive across geographical regions due to goodwill impairment recognised on the Global Banking and Markets cash-

generating unit, which is monitored on a global basis. 

96

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Revenue

Reported

Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  currency translation on significant items

Adjusted

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

Significant items

–  costs of structural reform

–  customer redress programmes

–  restructuring and other related costs 

–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items

Adjusted 

Share of profit/(loss) in associates and joint ventures

Reported 

Currency translation

Adjusted

Profit/(loss) before tax

Reported

Currency translation

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

UK

$m

Hong
Kong

$m

2019

Mainland 
China

$m

Footnotes

US

$m

Mexico

$m

1

2

3

13,538   

19,412   

3,101   

4,638   

2,555 

65   

29   
162   

—   

(139)   

6   

192   

26   
—   

—   

26   

—   

—   

1   
—   

—   

1   

—   

—   

66   
—   

59   

7   

—   

(256) 

7 
— 

— 

8 

(1) 

13,632   

19,630   

3,102   

4,704   

2,306 

(714)   

(2)   

(716)   

(459)   

(4)   

(463)   

(129)   

—   

(129)   

(170)   

—   

(170)   

(491) 

49 

(442) 

(16,157)   

(6,935)   

(2,111)   

(4,033)   

(1,390) 

(63)   

1,805   
101   

1,281   

405   

8   

10   

(66)   

65   
4   

—   

61   

(1)   

1   

(5)   

6   
—   

—   

6   

—   

—   

—   

93   
—   

—   

93   

—   

—   

141 

18 
— 

— 

20 

— 

(2) 

(14,415)   

(6,936)   

(2,110)   

(3,940)   

(1,231) 

(12)   

—   

(12)   

31   

1   

32   

2,016   

1   

2,017   

(3,345)   

12,049   

2,877   

—   

123   

1,834   

29   

1,805   

91   

26   

65   

(4)   

7   

1   

6   

(1,511)   

12,263   

2,880   

—   

—   

—   

435   

—   

159   

66   

93   

594   

13 

(2) 

11 

687 

(68) 

25 

7 

18 

644 

  303,041    306,964   

42,380   

63,588   

20,426 

9,925   

1,403   

2,802   

—   

(1,033) 

  312,966    308,367   

45,182   

63,588   

19,393 

  419,642    499,955   

48,323   

90,834   

23,051 

13,744   

2,286   

3,194   

—   

(1,166) 

  433,386    502,241   

51,517   

90,834   

21,885 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises costs associated with preparations for the UK’s exit from the European Union.

Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.

HSBC Holdings plc Annual Report and Accounts 2020

97

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items (continued)

Revenue

Reported 

Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial investments

–  currency translation on significant items 

Adjusted 

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

Significant items

–  costs of structural reform

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  past service costs of guaranteed minimum pension benefits equalisation

–  restructuring and other related costs

–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items 

Adjusted 

Share of profit in associates and joint ventures

Reported

Currency translation

Adjusted

Profit/(loss) before tax

Reported

Currency translation

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

Footnotes

Europe

$m

Asia

$m

MENA

$m

North
America

$m

Latin
America

$m

Total

$m

2018

1

2

2

3

2

2

2

4

17,704   

28,784   

2,687   

6,725   

3,062   

53,780 

(760)   

105   

(53)   

(5)   

156   

7   

(263)   

(35)   

—   

—   

(38)   

3   

(37)   

(1)   

—   

—   

(1)   

—   

(57)   

97   

—   

103   

(8)   

2   

(803)   

(1,854) 

6   

—   

15   

(9)   

—   

172 

(53) 

113 

100 

12 

17,049   

28,486   

2,649   

6,765   

2,265   

52,098 

(609)   

(602)   

5   

6   

(604)   

(596)   

(209)   

17   

(192)   

223   

(2)   

221   

(570)   

121   

(449)   

(1,767) 

147 

(1,620) 

(17,934)   

(12,466)   

(1,357)   

(6,149)   

(1,935)   

(34,659) 

530   

664   

352   

146   

52   

228   

46   

(147)   

(13)   

185   

16   

9   

—   

—   

—   

7   

—   

—   

47   

—   

—   

—   

—   

—   

—   

—   

—   

33   

976   

—   

—   

—   

—   

13   

963   

—   

551   

—   

—   

—   

—   

—   

—   

—   

—   

1,280 

1,656 

361 

146 

52 

228 

66 

816 

(13) 

2

(16,740)   

(12,265)   

(1,310)   

(5,140)   

(1,384)   

(31,723) 

24   

(1)   

23   

2,074   

(90)   

1,984   

436   

—   

436   

(815)   

(226)   

769   

105   

664   

17,790   

1,557   

(162)   

(19)   

(35)   

16   

27   

(1)   

(1)   

—   

—   

—   

—   

799   

(26)   

1,073   

97   

976   

2   

(1)   

1   

2,536 

(92) 

2,444 

559   

19,890 

(132)   

(519) 

6   

6   

—   

1,828 

172 

1,656 

(272)   

17,609   

1,583   

1,846   

433   

21,199 

373,073   

450,545   

28,824   

108,146   

21,108   

981,696 

26,141   

10,289   

(521)   

2,957   

(1,558)   

37,308 

399,214   

460,834   

28,303   

111,103   

19,550    1,019,004 

503,154   

664,824   

35,408   

133,291   

25,966    1,362,643 

34,940   

12,491   

(632)   

3,094   

(2,814)   

47,079 

538,094   

677,315   

34,776   

136,385   

23,152    1,409,722 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2   Amounts are non-additive across geographical regions due to inter-company transactions within the Group.
3 
Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.
4  Comprises costs associated with preparations for the UK’s exit from the European Union, costs to establish the UK ring-fenced bank (including the 

UK ServCo group) and costs associated with establishing an intermediate holding company in Hong Kong.

98

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Revenue
Reported

Currency translation

Significant items
–  customer redress programmes

–  disposals, acquisitions and investment in new businesses

–  fair value movements on financial instruments

–  currency translation on significant items

Adjusted

ECL
Reported 

Currency translation

Adjusted

Operating expenses
Reported 

Currency translation

Significant items
–  costs of structural reform

–  customer redress programmes

–  past service costs of guaranteed minimum pension benefits equalisation

–  restructuring and other related costs

–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items 

Adjusted 

Share of profit in associates and joint ventures
Reported

Currency translation

Adjusted

Profit/(loss) before tax
Reported

Currency translation

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)
Reported

Currency translation

Adjusted 

Customer accounts
Reported

Currency translation

Adjusted 

UK

$m

Hong
Kong

$m

2018

Mainland 
China

$m

Footnotes

1

2

3

13,597   

18,231   

(616)   

191   

2,888   

(120)   

115   

(53)   

—   

162   

6   

5   

—   

—   

5   

—   

(1)   

—   

—   

(1)   

—   

US

$m

Mexico

$m

4,741   

—   

97   

—   

103   

(6)   

—   

2,294 

(232) 

(7) 

— 

— 

(7) 

— 

13,096   

18,427   

2,767   

4,838   

2,055 

(516)   

4   

(512)   

(214)   

(3)   

(217)   

(143)   

1   

(142)   

199   

—   

199   

(463) 

45 

(418) 

(14,502)   

(6,539)   

(1,920)   

(4,987)   

(1,303) 

425   

519   

294   

146   

228   

39   

(176)   

(12)   

(69)   

16   

9   

—   

—   

7   

—   

—   

76   

—   

—   

—   

—   

—   

—   

—   

—   

919   

—   

—   

—   

11   

908   

—   

131 

— 

— 

— 

— 

— 

— 

— 

(13,558)   

(6,592)   

(1,844)   

(4,068)   

(1,172) 

25   

(1)   

24   

36   

—   

36   

(1,396)   

11,514   

(188)   

634   

115   

519   

119   

21   

5   

16   

2,033   

(90)   

1,943   

2,858   

(133)   

(1)   

(1)   

—   

(950)   

11,654   

2,724   

—   

—   

—   

(47)   

—   

1,016   

97   

919   

969   

— 

— 

— 

528 

(56) 

(7) 

(7) 

— 

465 

287,144   

290,547   

38,979   

64,011   

17,895 

19,928   

2,945   

2,068   

—   

(180) 

307,072   

293,492   

41,047   

64,011   

17,715 

399,487   

484,897   

45,712   

82,523   

19,936 

27,720   

4,915   

2,426   

—   

(195) 

427,207   

489,812   

48,138   

82,523   

19,741 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises costs associated with preparations for the UK’s exit from the European Union, costs to establish the UK ring-fenced bank (including the 

Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.

UK ServCo group) and costs associated with establishing an intermediate holding company in Hong Kong.

HSBC Holdings plc Annual Report and Accounts 2020

99

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Analysis by country

Profit/(loss) before tax by country/territory within global businesses

Europe

–  UK

–  of which: HSBC UK Bank plc (RFB)

–  of which: HSBC Bank plc (NRFB)

–  of which: Holdings and other

–  France

–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa

–  Egypt

–  UAE

–  Saudi Arabia

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

Footnotes

1

Wealth and
Personal
Banking

Commercial 
Banking

Global Banking 
and Markets

Corporate
Centre

$m

(680)   

(357)   

113   

109   

(579)   

(340)   

17   

(2)   

2   

5,031   

4,927   

108   

16   

(6)   

(34)   

8   

45   

9   

(42)   

(15)   

68   

(21)   

21   

(83)   

(449)   

(547)   

52   

46   

(183)   

(115)   

(68)   

$m

(529)   

(543)   

167   

36   

(746)   

(168)   

16   

(4)   

170   

1,944   

1,787   

76   

187   

(14)   

295   

33   

(644)   

18   

206   

(120)   

46   

(210)   

—   

44   

366   

139   

225   

2   

(22)   

(106)   

84   

$m

(1,809)   

(1,769)   

90   

(1,030)   

(829)   

(347)   

197   

—   

110   

4,002   

1,674   

138   

593   

147   

506   

141   

239   

104   

460   

478   

185   

102   

26   

165   

712   

573   

100   

39   

233   

59   

174   

$m

(1,187)   

(1,555)   

(124)   

(454)   

(977)   

(310)   

(15)   

(10)   

703   

1,855   

(181)   

(7)   

228   

(13)   

1,845   

(55)   

(12)   

(2)   

52   

(324)   

(1)   

(39)   

(264)   

(20)   

(461)   

(391)   

(67)   

(3)   

(65)   

(25)   

(40)   

Total

$m

(4,205) 

(4,224) 

246 

(1,339) 

(3,131) 

(1,165) 

215 

(16) 

985 

12,832 

8,207 

315 

1,024 

114 

2,612 

127 

(372) 

129 

676 

19 

298 

(168) 

(217) 

106 

168 

(226) 

310 

84 

(37) 

(187) 

150 

Year ended 31 Dec 2020

3,704   

1,639   

3,616   

(182)   

8,777 

1   UK includes results from the ultimate holding company, HSBC Holdings plc, and the separately incorporated group of service companies (‘ServCo 

Group’).

100 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Profit/(loss) before tax by country/territory within global businesses (continued)

Wealth and
Personal
Banking3

Commercial
 Banking3

Global
Banking
and Markets3

Corporate
Centre3

Europe

–  UK

–  of which: HSBC UK Bank plc (RFB)

–  of which: HSBC Bank plc (NRFB)

–  of which: Holdings and other

–  France

–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa

–  Egypt

–  UAE

–  Saudi Arabia

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

GBM goodwill impairment

Year ended 31 Dec 2019

Footnotes

1

2

2

2

2

2

$m

(841)   

(1,053)   

(331)   

245   

(967)   

55   

18   

93   

46   

7,715   

7,220   

130   

67   

20   

(73)   

102   

154   

43   

52   

254   

73   

139   

(3)   

45   

(573)   

(277)   

70   

(366)   

264   

311   

(47)   

—   

$m

(1,324)   

904   

1,555   

278   

(929)   

120   

46   

7   

(2,401)   

4,519   

3,242   

127   

201   

55   

317   

73   

105   

25   

374   

212   

81   

94   

—   

37   

855   

386   

427   

42   

(103)   

176   

(279)   

—   

6,819   

4,159   

$m

(997)   

(1,217)   

70   

(186)   

(1,101)   

(65)   

95   

(3)   

193   

4,083   

1,729   

199   

533   

127   

512   

189   

250   

97   

447   

761   

245   

246   

13   

257   

729   

547   

143   

39   

328   

229   

99   

(3,962)   

942   

$m

(1,491)   

(1,979)   

13   

(467)   

(1,525)   

(74)   

2   

(6)   

566   

2,151   

(142)   

(12)   

205   

14   

2,121   

(22)   

(31)   

(4)   

22   

1,100   

11   

(54)   

1,145   

(2)   

(244)   

(221)   

(22)   

(1)   

(89)   

(29)   

(60)   

—   

1,427   

Total

$m

(4,653) 

(3,345) 

1,307 

(130) 

(4,522) 

36 

161 

91 

(1,596) 

18,468 

12,049 

444 

1,006 

216 

2,877 

342 

478 

161 

895 

2,327 

410 

425 

1,155 

337 

767 

435 

618 

(286) 

400 

687 

(287) 

(3,962) 

13,347 

1  UK includes results from the ultimate holding company, HSBC Holdings plc, and the separately incorporated group of service companies (‘ServCo 

2 

Group’).
Includes the impact of goodwill impairment. As per Group accounting policy, HSBC’s cash-generating units are based on geographical regions 
subdivided by global business, except for Global Banking and Markets, for which goodwill is monitored on a global basis.

3  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly. For further guidance, see Note 10: 

Segmental analysis on page 311.

HSBC Holdings plc Annual Report and Accounts 2020 101

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Profit/(loss) before tax by country/territory within global businesses (continued)

Wealth and 
Personal 
Banking2

Commercial
 Banking2

Global
Banking
and Markets2

Corporate
Centre2

Europe

–  UK

–  of which: HSBC UK Bank plc (RFB)

–  of which: HSBC Bank plc (NRFB)

–  of which: Holdings and other

–  France

–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa

–  Egypt

–  UAE

–  Saudi Arabia

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

Footnotes

1

$m
134   

256   

602   

618   

(964)   

(42)   

26   

(76)   

(30)   

7,025   

6,673   

120   

36   

7   

(195)   

145   

125   

60   

54   

251   

51   

142   

—   

58   

37   

(106)   

99   

44   

133   

214   

(81)   

$m
1,798   

1,393   

967   

1,408   

(982)   

163   

92   

5   

145   

4,475   

3,291   

137   

157   

21   

282   

89   

127   

29   

342   

142   

63   

65   

—   

14   

1,036   

498   

489   

49   

138   

119   

19   

$m
147   

(175)   

4   

839   

(1,018)   

7   

116   

(2)   

201   

4,097   

1,768   

212   

433   

97   

592   

137   

266   

138   

454   

769   

215   

307   

—   

247   

901   

734   

187   

(20)   

354   

204   

150   

$m
(2,894)   

(2,870)   

(191)   

(787)   

(1,892)   

(91)   

(33)   

(4)   

104   

2,193   

(218)   

(6)   

199   

(21)   

Total

$m
(815) 

(1,396) 

1,382 

2,078 

(4,856) 

37 

201 

(77) 

420 

17,790 

11,514 

463 

825 

104 

2,179   

2,858 

3   

(27)   

(2)   

86   

395   

4   

(41)   

436   

(4)   

(1,175)   

(1,173)   

(10)   

8   

(66)   

(9)   

(57)   

374 

491 

225 

936 

1,557 

333 

473 

436 

315 

799 

(47) 

765 

81 

559 

528 

31 

Year ended 31 Dec 2018

7,580   

7,589   

6,268   

(1,547)   

19,890 

1  UK includes results from the ultimate holding company, HSBC Holdings plc, and the separately incorporated group of service companies (‘ServCo 

Group’).

2  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly. For further guidance, see Note 10: 

Segmental analysis on page 311.

102 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of alternative 
performance measures

Use of alternative performance measures

Return on average ordinary shareholders’ equity and return on average 
tangible equity

Net asset value and tangible net asset value per ordinary share

Post-tax return and average total shareholders’ equity on average total 
assets

Expected credit losses and other credit impairment charges as % of 
average gross loans and advances to customers

Page

103

103

104

105

105

Use of alternative performance measures

Our reported results are prepared in accordance with IFRSs 
as detailed in our financial statements starting on page 278.

As described on page 77, we use a combination of reported and 
alternative performance measures, including those derived from 
our reported results that eliminate factors that distort year-on-year 
comparisons. These are considered alternative performance 
measures (non-GAAP financial measures). 

The following information details the adjustments made to the 
reported results and the calculation of other alternative 
performance measures. All alternative performance measures are 
reconciled to the closest reported performance measure.

Return on average ordinary shareholders’
equity and return on average tangible equity

Return on average ordinary shareholders’ equity (‘RoE’) is 
computed by taking profit attributable to the ordinary shareholders 
of the parent company (‘reported results’), divided by average 
ordinary shareholders’ equity (‘reported equity’) for the period. The 
adjustment to reported results and reported equity excludes 
amounts attributable to non-controlling interests and holders of 
preference shares and other equity instruments.

Return on average tangible equity (‘RoTE’) is computed by 
adjusting reported results for the movements in the present value 
of in-force long-term insurance business (‘PVIF’) and for 
impairment of goodwill and other intangible assets (net of tax), 
divided by average reported equity adjusted for goodwill, 
intangibles and PVIF for the period. 

Return on average tangible equity excluding significant items and 
UK bank levy is annualised profit attributable to ordinary 
shareholders, excluding changes in PVIF, significant items and 
bank levy (net of tax), divided by average tangible shareholders’ 
equity excluding fair value of own debt, debt valuation adjustment 
(‘DVA’) and other adjustments for the period.

We provide RoTE ratios in addition to RoE as a way of assessing 
our performance, which is closely aligned to our capital position.

Return on average ordinary shareholders’ equity and return on average tangible equity

Profit

Profit attributable to the ordinary shareholders of the parent company

Impairment of goodwill and other intangible assets (net of tax)

Increase/(decrease) in PVIF (net of tax)

Profit attributable to the ordinary shareholders, excluding goodwill impairment and PVIF

Significant items (net of tax) and UK bank levy

Profit attributable to the ordinary shareholders, excluding goodwill impairment, PVIF, significant items and 
UK bank levy

Equity

Average total shareholders’ equity

Effect of average preference shares and other equity instruments

Average ordinary shareholders’ equity

Effect of goodwill, PVIF and other intangibles (net of deferred tax)

Average tangible equity

Fair value of own debt, DVA and other adjustments

Average tangible equity excluding fair value of own debt, DVA and other adjustments

Ratio

Return on average ordinary shareholders’ equity

Return on average tangible equity

Return on average tangible equity excluding significant items and UK bank levy 

2020

$m

2019

$m

3,898   
1,036   
(253)   
4,681   
2,402   

5,969   

7,349   

(1,248)   

12,070   

2,251   

2018

$m

12,608 

— 

(506) 

12,102 

2,590 

7,083   

14,321   

14,692 

189,719   
(22,326)   
167,393   
(17,292)   
150,101   
422   
150,523   

%

2.3

3.1

 4.7 

189,035   

186,979 

(23,614)   

(23,496) 

165,421   

163,483 

(22,574)   

(22,102) 

142,847   

141,381 

1,032   

2,439 

143,879   

143,820 

%

%

 3.6 

 8.4 

 10.0 

 7.7 

 8.6 

 10.2 

HSBC Holdings plc Annual Report and Accounts 2020 103

Financial review  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of alternative performance measures

The following table details the adjustments made to reported results by global business:

Return on average tangible equity by global business

Year ended 31 Dec 2020

Wealth and
Personal
Banking

Commercial
Banking

Global
Banking and
Markets

Corporate
Centre

Profit before tax

Tax expense

Profit after tax

Less attributable to: preference shareholders, other equity holders, non-controlling 
interests

Profit attributable to ordinary shareholders of the parent company

Increase in PVIF (net of tax)

Significant items (net of tax) and UK bank levy

Markets Treasury allocation and other adjustments

$m

3,704   

(509)   

3,195   

(736)   

2,459   

(242)   

190   

20   

$m

1,639   

(661)   

978   

(673)   

305   

(10)   

208   

(14)   

$m

3,616   

(977)   

2,639   

(784)   

1,855   

—   

958   

(25)   

$m

(182)   

(531)   

(713)   

Total

$m

8,777 

(2,678) 

6,099 

(8)   

(2,201) 

(721)   

(1)   

2,041   

60   

3,898 

(253) 

3,397 

41 

Profit attributable to ordinary shareholders, excluding PVIF, significant 
items and UK bank levy

Average tangible shareholders’ equity excluding fair value of own debt, DVA and 
other adjustments

2,427   

489   

2,788   

1,379   

7,083 

26,551   

37,826   

41,566   

44,580   

150,523 

Return on average tangible equity excluding significant items and UK bank levy (%)

 9.1 

 1.3 

 6.7 

 3.1 

 4.7 

Profit before tax

Tax expense

Profit after tax

Less attributable to: preference shareholders, other equity holders, non-controlling 
interests

Profit attributable to ordinary shareholders of the parent company

Increase in PVIF (net of tax)

Significant items (net of tax) and UK bank levy

Markets Treasury allocation and other adjustments

Profit attributable to ordinary shareholders, excluding PVIF, significant items and 
bank levy

Average tangible shareholders’ equity excluding fair value of own debt, DVA and 
other adjustments

Year ended 31 Dec 2019

6,819   

(720)   

6,099   

(1,279)   

4,820   

(1,207)   

1,641   

1   

4,159   

(1,502)   

2,657   

(846)   

1,811   

(40)   

3,036   

—   

942   

(460)   

482   

(784)   

(302)   

—   

4,218   

—   

1,427   

(1,957)   

(530)   

170   

(360)   

(1)   

702   

2   

13,347 

(4,639) 

8,708 

(2,739) 

5,969 

(1,248) 

9,597 

3 

5,255   

4,807   

3,916   

343   

14,321 

26,627   

36,856   

39,999   

40,397   

143,879 

Return on average tangible equity excluding significant items and UK bank levy (%)

 19.7 

 13.0 

 9.8 

 0.8 

 10.0 

Net asset value and tangible net asset value 
per ordinary share

Net asset value per ordinary share is total shareholders' equity less 
non-cumulative preference shares and capital securities (‘total 
ordinary shareholders’ equity’), divided by the number of ordinary 
shares in issue excluding shares that the company has purchased 
and are held in treasury.

Net asset value and tangible net asset value per ordinary share

Tangible net asset value per ordinary share is total ordinary 
shareholders’ equity excluding goodwill, PVIF and other intangible 
assets (net of deferred tax) (‘tangible ordinary shareholders’ 
equity’), divided by the number of basic ordinary shares in issue 
excluding shares that the company has purchased and are held in 
treasury.

Total shareholders’ equity

Preference shares and other equity instruments 

Total ordinary shareholders’ equity

Goodwill, PVIF and intangible assets (net of deferred tax)

Tangible ordinary shareholders’ equity

Basic number of $0.50 ordinary shares outstanding

Value per share

Net asset value per ordinary share

Tangible net asset value per ordinary share

2020

$m

2019

$m

2018

$m

196,443   

183,955   

186,253 

(22,414)   

(22,276)   

(23,772) 

174,029   

161,679   

162,481 

(17,606)   

(17,535)   

(22,425) 

156,423   

144,144   

140,056 

20,184   

20,206   

19,981 

$

$

$

8.62   

7.75   

8.00   

7.13   

8.13 

7.01 

104 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Post-tax return and average total shareholders’
equity on average total assets

Post-tax return on average total assets is profit after tax divided by 
average total assets for the period. 

Average total shareholders’ equity to average total assets is 
average total shareholders' equity divided by average total assets 
for the period.

Post-tax return and average total shareholders’ equity on average total assets

Profit after tax

Average total shareholders’ equity

Average total assets

Ratio

Post-tax return on average total assets

Average total shareholders’ equity to average total assets

Expected credit losses and other credit 
impairment charges as % of average gross 
loans and advances to customers

Expected credit losses and other credit impairment charges (‘ECL’) 
as % of average gross loans and advances to customers is the 
annualised adjusted ECL divided by adjusted average gross loans 
and advances to customers for the period. 

2020

$m

2019

$m

2018

$m

6,099   

8,708   

15,025 

189,719   

189,035   

186,979 

  2,936,939   

2,712,376   

2,611,976 

%

 0.2 

 6.46 

%

 0.3 

 6.97 

%

 0.6 

 7.16 

The adjusted numbers are derived by adjusting reported ECL and 
loans and advances to customers for the effects of foreign 
currency translation differences.

Expected credit losses and other credit impairment charges as % of average gross loans and advances to customers (%)

Expected credit losses and other credit impairment charges (‘ECL’)

Currency translation

Adjusted ECL

Average gross loans and advances to customers

Currency translation

2020

$m

2019

$m

2018

$m

(8,817)   

(2,756)   

(1,767) 

129   

147 

(8,817)   

(2,627)   

(1,620) 

  1,047,114   

1,021,238   

982,409 

36,702   

38,167   

14,911 

Average gross loans and advances to customers – at most recent balance sheet foreign exchange rates

  1,083,816   

1,059,405   

997,320 

Ratio

Expected credit losses and other credit impairment charges as % of average gross loans and advances to customers

%

 0.81 

%

 0.25 

%

 0.16 

HSBC Holdings plc Annual Report and Accounts 2020 105

Financial review 
 
 
 
 
 
 
 
 
 
Risk  
review

107  Our approach to risk

107 

107 

109 

110 

110 

114 

116 

116 

117 

118 

119 

169 

Our risk appetite

Risk management

Key developments in 2020

Top and emerging risks

Externally driven

Internally driven

Areas of special interest

Risks related to Covid-19

UK withdrawal from the European Union

Our material banking risks

Credit risk

Treasury risk

182  Market risk

186 

186 

187 

Resilience risk

Regulatory compliance risk

Financial crime risk

188  Model risk

189 

Insurance manufacturing operations risk

Operational resilience in a pandemic

We upheld our operational resilience during the Covid-19 outbreak 
during a period of increased demand on our teams and systems,  
with approximately 1.6 million of our WPB customers granted  
payment relief options across more than 30 markets. 

We supplemented our existing approach to risk management with 
additional tools and practices helping to mitigate and manage risks. 
Initiatives included mortgage assistance, payment holidays, and  
the waiving of certain fees and charges. 

As we helped our customers during these challenging times, we 
continued to prioritise effective and robust credit risk management.  
We also increased our focus on the quality and timeliness of the data 
used to inform management decisions, so we were able to manage  
the varying level of risk actively throughout the year.

For further details of our customer relief programmes, see page 142.

106

HSBC Holdings plc Annual Report and Accounts 2020 
 
Our approach to risk

Our risk appetite

We recognise the importance of a strong culture, which refers to 
our shared attitudes, values and standards that shape behaviours 
related to risk awareness, risk taking and risk management. All our 
people are responsible for the management of risk, with the 
ultimate accountability residing with the Board.

We seek to build our business for the long term by balancing 
social, environmental and economic considerations in the 
decisions we make. Our strategic priorities are underpinned by our 
endeavour to operate in a sustainable way. This helps us to carry 
out our social responsibility and manage the risk profile of the 
business. We are committed to managing and mitigating climate-
related risks, both physical and transition, and continue to 
incorporate consideration of these into how we manage and 
oversee risks internally and with our customers.

The following principles guide the Group’s overarching appetite for 
risk and determine how our businesses and risks are managed.

Financial position

• We aim to maintain a strong capital position, defined by 

regulatory and internal capital ratios. 

• We carry out liquidity and funding management for each 

operating entity, on a stand-alone basis.

Operating model

• We seek to generate returns in line with a conservative risk 

appetite and strong risk management capability.

• We aim to deliver sustainable earnings and consistent returns 

for shareholders.

Business practice

• We have zero tolerance for any of our people knowingly 
engaging in any business, activity or association where 
foreseeable reputational risk or damage has not been 
considered and/or mitigated.

• We have no appetite for deliberately or knowingly causing 

detriment to consumers, or incurring a breach of the letter or 
spirit of regulatory requirements.

• We have no appetite for inappropriate market conduct by any 

member of staff or by any Group business.

Enterprise-wide application

Our risk appetite encapsulates the consideration of financial and 
non-financial risks. We define financial risk as the risk of a 
financial loss as a result of business activities. We actively take 
these types of risks to maximise shareholder value and profits. 
Non-financial risk is the risk to achieving our strategy or objectives 
as the result of failed internal processes, people and systems, or 
from external events. 

Our risk appetite is expressed in both quantitative and qualitative 
terms and applied at the global business level, at the regional level 
and to material operating entities. Every three years, the Global 
Risk function commissions an external independent firm to review 
the Group’s approach to risk appetite and to help ensure that it 
remains in line with market best practice and regulatory 
expectations. The exercise carried out in 2019 confirmed the 
Group’s risk appetite statement (‘RAS’) remains aligned to best 
practices, regulatory expectations and strategic goals. Our risk 
appetite continues to evolve and expand its scope as part of our 
regular review process.

The Board reviews and approves the Group’s risk appetite twice a 
year to make sure it remains fit for purpose. The Group’s risk 
appetite is considered, developed and enhanced through: 

• an alignment with our strategy, purpose, values and customer 

needs;

• trends highlighted in other Group risk reports;

• communication with risk stewards on the developing risk 

landscape;

• strength of our capital, liquidity and balance sheet;

• compliance with applicable laws and regulations;

• effectiveness of the applicable control environment to mitigate 
risk, informed by risk ratings from risk control assessments;

• functionality, capacity and resilience of available systems to 

manage risk; and

• the level of available staff with the required competencies to 

manage risks. 

We formally articulate our risk appetite through our RAS. Setting 
out our risk appetite ensures that we agree a suitable level of risk 
for our strategy. In this way, risk appetite informs our financial 
planning process and helps senior management to allocate capital 
to business activities, services and products.

The RAS consists of qualitative statements and quantitative 
metrics, covering financial and non-financial risks. It is applied to 
the development of business line strategies, strategic and business 
planning and remuneration. At a Group level, performance against 
the RAS is reported to the Group Risk Management Meeting 
(‘RMM’) alongside key risk indicators to support targeted insight 
and discussion on breaches of risk appetite and associated 
mitigating actions. This reporting allows risks to be promptly 
identified and mitigated, and informs risk-adjusted remuneration 
to drive a strong risk culture.

Each global business, region and strategically important country 
and territory is required to have its own RAS, which is monitored 
to help ensure it remains aligned with the Group’s RAS. Each RAS 
and business activity is guided and underpinned by qualitative 
principles and/or quantitative metrics.

Risk management

We recognise that the primary role of risk management is to 
protect our customers, business, colleagues, shareholders and the 
communities that we serve, while ensuring we are able to support 
our strategy and provide sustainable growth. This is supported 
through our three lines of defence model described on page 109. 

We are focused on the implementation of our business strategy, 
as part of which we are carrying out a major change programme. 
It is critical that we ensure that as we implement changes, we use 
active risk management to manage the execution risks.

We will also perform periodic risk assessments, including against 
strategies, to help ensure retention of key personnel for our 
continued safe operation. 

We use a comprehensive risk management framework across the 
organisation and across all risk types, underpinned by our culture 
and values. This outlines the key principles, policies and practices 
that we employ in managing material risks, both financial and non-
financial.

The framework fosters continual monitoring, promotes risk 
awareness and encourages sound operational and strategic 
decision making. It also ensures a consistent approach to 
identifying, assessing, managing and reporting the risks we accept 
and incur in our activities.

Our risk management framework

The following diagram and descriptions summarise key aspects of 
the risk management framework, including governance and 
structure, our risk management tools and our culture, which 
together help align employee behaviour with our risk appetite.

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Risk reviewRisk

Key components of our risk management framework

HSBC Values and risk culture

Risk governance

Non-executive risk governance

Executive risk governance

Roles and 
responsibilities

Three lines of defence model

Risk appetite

Processes and tools

Enterprise-wide risk management tools

Active risk management: identification/assessment, 
monitoring, management and reporting

The Board approves the Group’s risk appetite, plans and performance 
targets. It sets the ‘tone from the top’ and is advised by the Group Risk 
Committee (see page 209).

Our executive risk governance structure is responsible for the enterprise-
wide management of all risks, including key policies and frameworks for 
the management of risk within the Group (see pages 109 and 118). 

Our ‘three lines of defence’ model defines roles and responsibilities for 
risk management. An independent Global Risk function helps ensure the 
necessary balance in risk/return decisions (see page 109).

The Group has processes in place to identify/assess, monitor, manage 
and report risks to help ensure we remain within our risk appetite.

Policies and procedures

Policies and procedures define the minimum requirements for the 
controls required to manage our risks. 

Internal controls

Control activities

Operational and resilience risk management defines minimum standards 
and processes for managing operational risks and internal controls.

Systems and infrastructure

The Group has systems and/or processes that support the identification, 
capture and exchange of information to support risk management 
activities.

Risk governance 

The Board has ultimate responsibility for the effective 
management of risk and approves our risk appetite. 

The Group Chief Risk Officer, supported by the RMM, holds 
executive accountability for the ongoing monitoring, assessment 
and management of the risk environment and the effectiveness of 
the risk management framework.

The Group Chief Risk Officer is also responsible for the oversight 
of reputational risk, with the support of the Group Reputational 
Risk Committee. The Group Reputational Risk Committee 
considers matters arising from customers, transactions and third 
parties that either present a serious potential reputational risk to 
the Group or merit a Group-led decision to ensure a consistent risk 
management approach across the regions, global businesses and 
global functions. Our reputational risk policy sets out our risk 
appetite and the principles for managing reputational risk. Further 
details can be found under the ‘Reputational risk’ section of 
www.hsbc.com/our-approach/risk-and-responsibility. 

The management of regulatory compliance risk and financial crime 
risk resides with the Group Chief Compliance Officer. Oversight is 
maintained by the Group Chief Risk Officer, in line with their 
enterprise risk oversight responsibilities, through the RMM.

Day-to-day responsibility for risk management is delegated 
to senior managers with individual accountability for decision 
making. All our people have a role to play in risk management. 
These roles are defined using the three lines of defence model, 
which takes into account our business and functional structures as 
described in the following commentary, 'Our responsibilities’.

We use a defined executive risk governance structure to help 
ensure there is appropriate oversight and accountability of risk, 
which facilitates reporting and escalation to the RMM. This 
structure is summarised in the following table.

Governance structure for the management of risk

Authority

Membership

Responsibilities include:

Risk Management Meeting  Group Chief Risk Officer

• Supporting the Group Chief Risk Officer in exercising Board-delegated risk 

Global Risk Executive 
Committee

Global business/regional 
risk management meetings

Group Chief Legal Officer
Group Chief Executive
Group Chief Financial Officer
All other Group Executive Committee 
members

management authority

• Overseeing the implementation of risk appetite and the risk management 

framework

• Forward-looking assessment of the risk environment, analysing possible risk 

impacts and taking appropriate action

• Monitoring all categories of risk and determining appropriate mitigating action 
• Promoting a supportive Group culture in relation to risk management and conduct

Group Chief Risk Officer
Chief risk officers of HSBC’s 
global businesses and regions
Heads of Global Risk sub-functions 

Global business/regional chief 
risk officer
Global business/regional chief 
executive officer
Global business/regional chief financial 
officer
Global business/regional heads 
of global functions

• Supporting the Group Chief Risk Officer in providing strategic direction for the 

Global Risk function, setting priorities and providing oversight

• Overseeing a consistent approach to accountability for, and mitigation of, risk 

across the Group

• Supporting the Group Chief Risk Officer in exercising Board-delegated risk 

management authority

• Forward-looking Group assessment of the risk environment, analysing the 

possible risk impact and taking appropriate action

• Implementation of risk appetite and the risk management framework
• Monitoring all categories of risk and determining appropriate mitigating actions
• Embedding a supportive culture in relation to risk management and controls

The Board committees with responsibility for oversight of risk-related matters are set out on page 213.

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Our responsibilities

All our people are responsible for identifying and managing 
risk within the scope of their roles as part of the three lines of 
defence model.

Three lines of defence

To create a robust control environment to manage risks, we use 
an activity-based three lines of defence model. This model 
delineates management accountabilities and responsibilities 
for risk management and the control environment.

The model underpins our approach to risk management by 
clarifying responsibility and encouraging collaboration, as well as 
enabling efficient coordination of risk and control activities. 
The three lines of defence are summarised below:

• The first line of defence owns the risks and is responsible 

for identifying, recording, reporting and managing them in line 
with risk appetite, and ensuring that the right controls and 
assessments are in place to mitigate them.

• The second line of defence challenges the first line of defence 

on effective risk management, and provides advice and 
guidance in relation to the risk.

• The third line of defence is our Global Internal Audit function, 

which provides independent assurance that our risk 
management approach and processes are designed and 
operating effectively.

Global Risk function

Our Global Risk function, headed by the Group Chief Risk Officer, 
is responsible for the Group’s risk management framework. This 
responsibility includes establishing global policy, monitoring risk 
profiles, and identifying and managing forward-looking risk. Global 
Risk is made up of sub-functions covering all risks to our business. 
Global Risk forms part of the second line of defence. It is 
independent from the global businesses, including sales and 
trading functions, to provide challenge, appropriate oversight and 
balance in risk/return decisions.

Responsibility for minimising both financial and non-financial risk 
lies with our people. They are required to manage the risks of the 
business and operational activities for which they are responsible. 
We maintain adequate oversight of our risks through our various 
specialist risk stewards and the collective accountability held by 
our chief risk officers. 

Non-financial risk is the risk to achieving our strategy or objectives 
as a result of failed internal processes, people and systems, or 
from external events. Sound non-financial risk management is 
central to achieving good outcomes for our customers.  

During 2020, we continued to strengthen the control environment 
and our approach to the management of non-financial risk, as 
broadly set out in our risk management framework. The 
management of non-financial risk focuses on governance and risk 
appetite, and provides a single view of the non-financial risks that 
matter the most and the associated controls. It incorporates a risk 
management system designed to enable the active management 
of non-financial risk. Our ongoing focus is on simplifying our 
approach to non-financial risk management, while driving more 
effective oversight and better end-to-end identification and 
management of non-financial risks. This is overseen by the 
Operational and Resilience Risk function, headed by the Group 
Head of Operational and Resilience Risk.

Stress testing and recovery planning

We operate a wide-ranging stress testing programme that is a key 
part of our risk management and capital and liquidity planning. 
Stress testing provides management with key insights into the 
impact of severely adverse events on the Group, and provides 
confidence to regulators on the Group’s financial stability. 

Our stress testing programme assesses our capital and liquidity 
strength through a rigorous examination of our resilience to 
external shocks. As well as undertaking regulatory-driven stress 
tests, we conduct our own internal stress tests in order to 
understand the nature and level of all material risks, quantify the 

impact of such risks and develop plausible business-as-usual 
mitigating actions. 

The Bank of England (‘BoE’) annual cyclical scenario stress test in 
2020 was cancelled and the publication of the results of the 2019 
biennial exploratory scenario on liquidity was postponed due to 
the Covid-19 outbreak. 

Internal stress tests

Our internal capital assessment uses a range of stress scenarios 
that explore risks identified by management. They include 
potential adverse macroeconomic, geopolitical and operational 
risk events, as well as other potential events that are specific to 
HSBC. 

The selection of stress scenarios is based upon the output of our 
identified top and emerging risks and our risk appetite. Stress 
testing analysis helps management understand the nature and 
extent of vulnerabilities to which the Group is exposed. Using this 
information, management decides whether risks can or should be 
mitigated through management actions or, if they were to 
crystallise, be absorbed through capital and liquidity. This in turn 
informs decisions about preferred capital and liquidity levels and 
allocations.

In addition to the Group-wide stress testing scenarios, each major 
subsidiary conducts regular macroeconomic and event-driven 
scenario analyses specific to its region. They also participate, as 
required, in the regulatory stress testing programmes of the 
jurisdictions in which they operate, such as the Comprehensive 
Capital Analysis and Review and Dodd-Frank Act Stress Testing 
programmes in the US, and the stress tests of the Hong Kong 
Monetary Authority (‘HKMA’). Global functions and businesses 
also perform bespoke stress testing to inform their assessment of 
risks to potential scenarios.

We also conduct reverse stress tests each year at Group level and, 
where required, at subsidiary entity level to understand potential 
extreme conditions that would make our business model non-
viable. Reverse stress testing identifies potential stresses and 
vulnerabilities we might face, and helps inform early warning 
triggers, management actions and contingency plans designed to 
mitigate risks.

Recovery and resolution plans 

Recovery and resolution plans form part of the integral framework 
safeguarding the Group’s financial stability. The Group recovery 
plan together with stress testing help us understand the likely 
outcomes of adverse business or economic conditions and in the 
identification of appropriate risk mitigating actions. The Group is 
committed to further developing its recovery and resolution 
capabilities in line with the BoE resolvability assessment 
framework requirements. 

Key developments in 2020

We actively managed the risks resulting from the Covid-19 
outbreak and its impacts on our customers and operations during 
2020, as well as other key risks described in this section.

In addition, we enhanced our risk management in the following 
areas:

• In January 2020, we simplified our approach and articulation of 
risk management through the combination of our enterprise 
risk management framework and our operational risk 
management framework.

• The global model risk policy and associated standards were 
revised to improve how we manage model risk and meet 
enhanced external expectations. 

• We continued to focus on simplifying our approach to non-
financial risk management. We are implementing more 
effective oversight and better end-to-end identification and 
management of non-financial risks.

• We established the Treasury Risk Management function. This 
function is a dedicated second line of defence, providing 
independent oversight of treasury activities across capital risk, 
liquidity and funding risk, structural foreign exchange risk and 

HSBC Holdings plc Annual Report and Accounts 2020

109

Risk reviewRisk

interest rate risk in the banking book, together with pension 
risk.  

• We continued to support the business and our customers 

throughout the global pandemic, while continuing our focus on 
managing financial crime risk. We continued to invest in both 
advanced analytics and artificial intelligence, which remain key 
components of our next generation of tools to fight financial 
crime.

• We combined our Operational Risk and Resilience Risk teams 
to form a new Operational and Resilience Risk sub-function. 
This sub-function provides robust non-financial risk first line of 
defence oversight and risk steward oversight of the 
management of risk by the Group’s businesses, functions, legal 
entities and critical business services. The sub-function helps to 
ensure that the first line of defence is focused firmly on priority 
tasks. By bringing the two teams together, we expect to benefit 
from improved stewardship, better risk management 
capabilities and better outcomes for our customers.

• We established a dedicated Climate Risk Oversight Forum to 

shape and oversee our approach to climate risk. We have also 
established a climate risk programme to drive the delivery of 
our enhanced climate risk management approach.

Top and emerging risks

We use a top and emerging risks process to provide a forward-
looking view of issues with the potential to threaten the execution 
of our strategy or operations over the medium to long term.

We proactively assess the internal and external risk environment, 
as well as review the themes identified across our regions and 
global businesses, for any risks that may require global escalation, 
updating our top and emerging risks as necessary.

We define a ‘top risk’ as a thematic issue that may form and 
crystallise within one year, and which has the potential to 
materially affect the Group’s financial results, reputation or 
business model. It may arise across any combination of risk types, 
regions or global businesses. The impact may be well understood 
by senior management and some mitigating actions may already 
be in place.

An ‘emerging risk’ is a thematic issue with large unknown 
components that may form and crystallise beyond a one-year time 
horizon. If it were to materialise, it could have a material effect on 
our long-term strategy, profitability and/or reputation. Existing 
mitigation plans are likely to be minimal, reflecting the uncertain 
nature of these risks at this stage. Some high-level analysis and/or 
stress testing may have been carried out to assess the potential 
impact.

Our current top and emerging risks are as follows.

Externally driven

Geopolitical and macroeconomic risks

Our operations and portfolios are exposed to risks associated with 
political instability, civil unrest and military conflict, which could 
lead to disruption of our operations, physical risk to our staff and/
or physical damage to our assets. 

Global tensions over trade, technology and ideology can manifest 
themselves in divergent regulatory standards and compliance 
regimes, presenting long-term strategic challenges for 
multinational businesses.

The Covid-19 outbreak dominated the political and economic 
landscape through much of 2020. The twin shocks of a public 
health emergency and the resultant economic fallout were felt 
around the world, hitting both advanced and emerging markets. 
The closure of borders threatened medical and food supplies for 
many markets, leading to countries and territories focusing efforts 
on building resilient supply chains closer to home. The Covid-19 
outbreak and corresponding vaccine roll-out will likely dominate 
the political and economic agenda for most of 2021. 

Tensions could increase as countries compete for access to the 
array of vaccines either under development, approved or pending 

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HSBC Holdings plc Annual Report and Accounts 2020

approval, while the potential differences of protection offered by 
vaccines, and the speed and scale with which they can be 
manufactured and distributed may further add to tensions.

The Covid-19 outbreak also heightened existing US-China 
tensions. Tensions span a wide range of issues, including trade, 
finance, military, technology and human rights. The Covid-19 
outbreak has accelerated US and Chinese efforts to reduce mutual 
dependence in strategic industries such as sensitive technology, 
pharmaceuticals and precursor chemicals. 

A range of tensions in US-China relations could have potential 
ramifications for the Group and its customers. These tensions 
could include divisions over Hong Kong, US funding of and trading 
with strategic Chinese industries and claims of human rights 
violations. Some of these tensions have manifested themselves 
through actions taken by the governments of the US and China in 
2020 and early 2021. These tensions may affect the Group through 
the impact of sanctions, including the impact of sanctions on 
customers, and could result in regulatory, reputational and market 
risks for the Group.

The US has imposed a range of sanctions and trade restrictions on 
Chinese persons and companies, focusing on entities the US 
believes are involved in human rights violations, information 
technology and communications equipment and services, and 
military activities, among others. In response, China has 
announced a number of sanctions and trade restrictions that 
target or provide authority to target foreign officials and 
companies, including those in the US. Certain measures are of 
particular relevance.

The US Hong Kong Autonomy Act provides 'secondary sanctions’ 
authority that allows for the imposition of US sanctions against 
non-US financial institutions found to be engaged in significant 
transactions with certain Chinese individuals and entities subject 
to US sanctions as a result of a US determination that these 
individuals or entities engaged in activities undermining Hong 
Kong’s autonomy. The US has also imposed restrictions on US 
persons’ ability to engage in transactions in or relating to publicly 
traded securities of a number of prominent Chinese companies. 
China has subsequently adopted regulations providing a 
framework for specific prohibitions against compliance with, and 
private rights of action for damages resulting from, measures that 
the government determines have an unjustified extraterritorial 
application that impairs Chinese sovereignty.  

No penalties have yet been imposed against financial institutions 
under any of these measures, and their scope and application 
remain uncertain. These and any future measures that may be 
taken by the US and China may affect the Group, its customers, 
and the markets in which we operate.

It remains unclear the extent to which the new US administration 
will affect the current geopolitical tensions, following the 
inauguration of President Biden on 20 January 2021. However, 
long-term differences between the two nations will likely remain, 
which could affect sentiment and restrict global economic activity. 
We continue to monitor the situation.

While UK-China relations have historically been shaped by strong 
trade and investment, there are also emerging challenges. 
Following China’s implementation of the Hong Kong national 
security law, the UK offered residency rights and a path to 
citizenship to eligible British National (Overseas) passport holders 
in Hong Kong. In addition, both the UK and Hong Kong 
governments have suspended their extradition treaties with each 
other. 

As geopolitical tensions rise, the compliance by multinational 
corporations with their legal or regulatory obligations in one 
jurisdiction may be seen as supporting the law or policy objectives 
of that jurisdiction over another, creating additional reputational 
and political risks for the Group. We maintain an open dialogue 
with our regulators on the impact of legal and regulatory 
obligations on HSBC's business and customers.

China’s expanding data privacy and cybersecurity laws could pose 
potential challenges to intra-group data sharing, especially within 
the Greater Bay Area. China’s draft Personal Information 

Protection Law and Data Security Law, if passed in their current 
forms, could increase financial institutions’ compliance burdens in 
respect of cross-border transfers of personal information. In Hong 
Kong, there is also an increasing focus by regulators on the use of 
data and artificial intelligence. Use of personal data through digital 
platforms for initiatives in the Greater Bay Area may need to take 
into account these evolving data privacy and cybersecurity 
obligations.

Emerging and frontier markets have suffered particularly heavily 
from the Covid-19 outbreak, in light of healthcare shortcomings, 
widespread labour informality, exposure to commodities 
production and often weak policy frameworks and buffers. 
Multilateral institutions have mobilised support for the weaker 
frontier markets, with the World Bank and G-20 marshalling efforts 
to implement a standstill on debt to public sector institutions. The 
International Monetary Fund has also, to date, made 
approximately $106bn in emergency funds available to over 80 
countries. However, negotiations on debt to the private sector will 
likely prove more difficult, and may result in sovereign debt 
restructuring and defaults for several countries. Most developed 
markets are expected to recover from the crisis, as 
macroeconomic policies remain highly accommodative. However, 
permanent business closures and job losses in some sectors will 
likely prevent several developed markets from achieving pre-crisis 
growth rates or activity levels in the near term. These countries 
and territories should be able to shoulder the higher public deficits 
and debts necessary to offset private sector weaknesses, given 
the continuing low cost of servicing public debt. However, some 
continental European countries entered the Covid-19 crisis on a 
weak economic and fiscal footing and suffered high healthcare 
and economic costs. Although substantial joint EU monetary and 
fiscal measures should help support recoveries and keep debt 
servicing costs down at least through 2021, there are concerns 
that permanently higher debt burdens will eventually lead to 
investors questioning their sustainability. Renewed government 
restrictions in response to new waves of infections will put further 
pressure on these economies.

Central banks have reduced interest rates in most financial 
markets due to the adverse impact on the path for economic 
recovery from the Covid-19 outbreak, which has in turn increased 
the likelihood of negative interest rates. This raises a number of 
risks and concerns, such as the readiness of our systems and 
processes to accommodate zero or negative rates, the resulting 
impacts on customers, and the financial implications given the 
significant impact that prolonged low interest rates have had, and 
may continue to have, on our net interest income. For some 
products, we have floored deposit rates at zero or made decisions 
not to charge negative rates. This, alongside loans repriced at 
lower rates, will result in our commercial margins being 
compressed, which is expected to be reflected in our profitability. 
The pricing of this risk will need to be carefully considered. These 
factors may challenge the long-term profitability of the banking 
sector, including HSBC, and will be considered as part of the 
Group’s transformation programme.

A Trade and Cooperation Agreement between the EU and the UK 
was agreed on 24 December 2020 and ratified by the UK on 30 
December 2020. This avoids the imposition of tariffs and quotas 
on UK-EU goods trade, and thus a more material setback to the 
expected gradual recovery of the UK and EU economies from 
recessions caused by the Covid-19 outbreak. However, the new 
trading relationship features non-tariff barriers, and leaves several 
aspects of the broader relationship, including financial services 
trade, for further negotiation. While it is too early to assess the full 
economic impact, the UK’s exit from the EU may lead to an 
increase in market volatility and economic risk, particularly in the 
UK, which could adversely impact our profitability and prospects 
for growth in this market. For further details on our approach to 
the UK’s withdrawal from the EU, see ‘Areas of special interest’ on 
page 116.

The contraction in the global economy during 2020 has had 
varying effects on our customers, with many of them experiencing 
financial difficulties. This has resulted in an increase in expected 
credit losses (‘ECL’) and risk-weighted assets (‘RWAs’). For further 

details on customer relief programmes, see page 142. For further 
details on RWAs, see page 174.

Mitigating actions 

• We closely monitor economic developments in key markets 

and sectors and undertake scenario analysis. This helps enable 
us to take portfolio actions where necessary, including 
enhanced monitoring, amending our risk appetite and/or 
reducing limits and exposures. 

•   We stress test portfolios of particular concern to identify 

sensitivity to loss under a range of scenarios, with management 
actions being taken to rebalance exposures and manage risk 
appetite where necessary. 

•  We undertake regular reviews of key portfolios to help ensure 
that individual customer or portfolio risks are understood and 
our ability to manage the level of facilities offered through any 
downturn is appropriate.

• We continually monitor the geopolitical outlook, in particular in 

countries where we have material exposures and/or a 
significant physical presence. We have also established 
dedicated forums to monitor geopolitical developments.

• We continue to carry out contingency planning following the 

UK’s withdrawal from the EU and we are assessing the 
potential impact on our portfolios, operations and staff. This 
includes the possibility of disputes arising from differing 
interpretations of the Trade and Cooperation Agreement and 
other aspects of the bilateral relationship.

• We have taken steps to enhance physical security in those 

geographical areas deemed to be at high risk from terrorism 
and military conflicts.

Climate-related risks

Climate change can have an impact across HSBC’s risk taxonomy 
through both transition and physical channels. Transition risk can 
arise from the move to a low-carbon economy, such as through 
policy, regulatory and technological changes. Physical risk can 
arise through increasing severity and/or frequency of severe 
weather or other climatic events, such as rising sea levels and 
flooding.

These have the potential to cause both idiosyncratic and systemic 
risks, resulting in potential financial and non-financial impacts for 
HSBC. Financial impacts could materialise if transition and 
physical risks impact the ability of borrowers to repay their loans. 
Non-financial impacts could materialise if our own assets or 
operations are impacted by extreme weather or chronic changes 
in weather patterns, or as a result of business decisions to achieve 
our climate ambition. 

Climate risks increased over 2020, primarily as a result of the pace 
and volume of policy and regulatory changes. These impacted the 
Group both directly and indirectly through our customers.

Mitigating actions

• A dedicated Climate Risk Oversight Forum is responsible for 

shaping and overseeing our approach to climate risk to provide 
support in managing the Group climate-related risks that are 
outside of our risk appetite. We have also established a climate 
risk programme to drive the delivery of our plans relating to the 
enhancement of our risk management approach.

• The Group’s risk appetite statement has been enhanced with 

quantitative metrics to articulate the risks from climate change 
and embed climate risk into our risk management framework. 
We established a transition risk framework to gain a better 
understanding of our exposure to the highest transition risk 
sectors.

• We implement sustainability risk policies as part of our 

reputational risk framework. We focus our policies on sensitive 
sectors that may have a high adverse impact on people or on 
the environment and in which we have a significant number of 
customers. These include sectors with potentially high-carbon 
impacts. 

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Risk review 
Risk

• We have conducted a climate stress test pilot to inform the 

development of our approach to climate risk management. This 
pilot also aims to help us prepare and build the necessary 
capabilities to execute the Bank of England’s climate biennial 
exploratory scenario in 2021. 

• We continue to engage with our customers, investors and 
regulators proactively when compiling and disclosing the 
information needed to manage climate risk. We also engage 
with initiatives actively, including the Climate Financial Risk 
Forum, Equator Principles, Taskforce on Climate-related 
Financial Disclosures and CDP (formerly the Carbon Disclosure 
Project) to drive best practice for climate risk management.

For further information, see our TCFD report on page 20.

Ibor transition

Interbank offered rates (‘Ibors’) are used to set interest rates on 
hundreds of trillions of US dollars of different types of financial 
transactions and are used extensively for valuation purposes, risk 
measurement and performance benchmarking.

The UK’s Financial Conduct Authority (‘FCA’) announced in July 
2017 that it would no longer continue to persuade or require panel 
banks to submit rates for the London interbank offered rate 
(‘Libor’) after 2021. In addition, the 2016 EU Benchmark 
Regulation, which aims to ensure the accuracy, robustness and 
integrity of interest rate benchmarks, has resulted in other 
regulatory bodies reassessing their national benchmarks. As a 
result, industry-led national working groups are actively discussing 
the mechanisms for an orderly transition of five Libor currencies, 
four Asia-Pacific benchmarks that reference US dollar Libor, the 
Euro Overnight Index Average (‘Eonia’), the Singapore interbank 
offered rate (‘Sibor’), and the Turkish Lira interbank offered rate 
(‘TRLibor’) to their chosen replacement rates. 

The transition process away from Ibors, including the transition of 
legacy contracts that reference Ibors, exposes HSBC to material 
execution risks, and increases some financial and non-financial 
risks. 

As our Ibor transition programme progresses into the execution 
phase, resilience and operational risks are heightened. This is due 
to an expected increase in the number of new near risk-free rate 
('RFR') products being rolled out, compressed timelines for the 
transition of legacy Ibor contracts and the extensive systems and 
process changes required to facilitate both new products and the 
transition. This is being exacerbated by the current interest rate 
environment where low Libor rates, in comparison with 
replacement RFRs, could affect decisions to transition contracts 
early, further compressing transition timelines. Regulatory 
compliance, legal and conduct risks may also increase as a result 
of both the continued sale of products referencing Ibors, and the 
sale of new products referencing RFRs, principally due to the lack 
of established market conventions across the different RFR 
products, and the compressed timelines for transition.  
Financial risks resulting from the discontinuation of Ibors and the 
development of market liquidity in RFRs will also affect HSBC 
throughout transition. The differences in Ibor and RFR interest 
rates will create a basis risk that we need to actively manage 
through appropriate financial hedging. Basis risk in the trading 
book and in the banking book may arise out of the asymmetric 
adoption of RFRs across assets and liabilities and across 
currencies and products. In addition, this may limit the ability to 
hedge effectively.

The continued orderly transition from Ibors continues to be the 
programme’s key objective through 2021 and can be broadly 
grouped into two workstreams: the development of alternative 
rate and RFR product capabilities and the transition of legacy Ibor 
contracts.

Development of alternative rate and RFR product capabilities

All of our global businesses have actively developed and 
implemented system and operational capabilities for alternative 
rates, such as base or prime rates and RFR products during 2020. 
Several key RFR product transactions were undertaken within the 
wholesale, Wealth and Personal Banking and Markets and 

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Securities Services business areas. The offering of RFR products is 
expected to be expanded, with further releases for products 
referencing the Sterling Overnight Index Average (‘Sonia’) and the 
Secured Overnight Financing Rate (‘SOFR’) set for the first half of 
2021, in addition to products linked to other RFRs set to be 
released throughout 2021.

These developments and the reduced suitability of Ibor products 
have enabled HSBC to cease selling certain Ibor-linked products. 
Notably, the origination of US adjustable rate mortgages linked to 
Libor has ceased, and Libor-linked loan products have been 
demised for Business Banking and mid-market enterprise 
segments in certain countries, where suitable alternatives are 
available.

While Ibor sales do continue for a number of product lines, Ibor 
exposures that have post-2021 maturities are reducing, aided by 
market compression of Ibor trades, and undertaking new 
transactions in alternative rate and replacement RFR products, as 
market liquidity builds.

Transition legacy contracts 

In addition to offering alternative rate and replacement RFR 
products, the development of new product capabilities will also 
help facilitate the transition of legacy Ibor and Eonia products. 
HSBC has begun to engage clients to determine their ability to 
transition in line with the readiness of alternative rate and 
replacement RFR products. The Covid-19 outbreak and the 
interest-rate environment may have affected clients’ abilities to 
transition early, and has resulted in compressed timelines for the 
transition of legacy Ibor contracts. However, for some US dollar 
Libor legacy contracts, this timing risk may be mitigated in part by 
the recent announcement by the Libor benchmark administrator, 
ICE Benchmark Administration Limited (‘IBA’), to consult on 
extending the publication of overnight and one, three, six and 12 
month US dollar Libor settings to 30 June 2023. Despite the 
proposed extension, regulatory and industry guidance has been 
clear that market participants should cease writing new US dollar 
Libor contracts as soon as is practicable, and in any event by the 
end of 2021 for the majority of products. While the extended 
deadline will result in additional US dollar Libor transactions 
maturing before cessation, not all of them will, so it is possible 
that other proposed solutions, including legislative relief, will still 
be needed. 

The Group continues to have Ibor and Eonia derivatives, loan and 
bond exposures maturing beyond 2021. 

For the derivatives exposures, HSBC’s main trading entities have 
adhered to the adoption of the International Swaps and 
Derivatives Association (‘ISDA’) protocol as a fallback provision, 
which came into effect in January 2021, and the successful 
changes made by clearing houses to discount derivatives using 
the euro short-term rate (‘€STR’) and SOFR, to reduce the risk of a 
disorderly transition of the derivatives market.

For HSBC’s loan book, our global businesses have developed 
commercial strategies that include active client engagement and 
communication, providing detailed information on RFR products to 
determine our clients’ abilities to transition to a suitable alternative 
rate or replacement RFR product, before Ibor cessation. 

With respect to HSBC’s legacy bond issuances referencing Ibors 
that may be subject to demise, we continue to assess the terms of 
those bond issuances and a variety of transition options, with a 
view to implementing, through 2021 and beyond, transition plans 
that we expect to be value neutral and in line with market practice. 
The timing of that implementation will depend on a variety of 
factors, including the expected timing for the demise of the 
relevant Ibor rate. The success of these transition plans will, to a 
certain extent, also depend on the participation and engagement 
of third-party market participants.  In addition, bond issuances that 
reference Ibors by certain issuing entities in the Group also 
reduced during 2020, with such entities opting to issue bonds that 
reference RFRs such as Sonia and SOFR. For those bonds where 
HSBC is the paying agent, there remains dependence on 
engagement of third-party market participants in the transition 
process of their issued debt.

Mitigating actions 

• Our global Ibor transition programme continues to assist in 
progressing towards an orderly transition to alternative 
benchmarks and replacement RFRs for our business and our 
clients, which is overseen by the Group Chief Risk Officer.

• We have widened the scope of the global Ibor transition 

programme to include additional interest rate benchmarks, 
where plans are in place to demise those benchmarks in the 
near future.

• We assess, monitor and dynamically manage risks, and 
implement specific mitigating controls when required. 

• We continue to engage with regulatory and industry bodies 

actively to mitigate risks relating to hedge accounting changes, 
multiple RFR market conventions, and so-called ‘tough legacy’ 
contracts that have no appropriate replacements or no 
likelihood of renegotiation to transition.  This includes providing 
feedback and responses on recent IBA and FCA consultations.

Financial instruments impacted by Ibor reform

• We have and continue to carry out extensive training, 

(Audited)

communication and client engagement to facilitate appropriate 
selection of products. 

• We have dedicated teams in place to support the development 

of and transition to alternative rate and replacement RFR 
products.

• We are implementing IT and operational changes to enable a 

longer transition window.

• We met the third quarter of 2020 regulatory endorsed 
milestones for implementing changes to contractual 
documentation and the clearing house-led transition to RFR 
discounting for derivatives. 

• We actively compressed derivative contracts and are targeting 
regulatory endorsed and industry-agreed milestones for the 
cessation of new issuance of Libor transactions maturing 
post-2021. These include the first quarter 2021 for sterling Libor 
and the second quarter 2021 for US dollar Libor. This led to a 
reduction in the Group’s Ibor portfolio of financial instruments.

• We are undertaking reviews of existing Ibor hedge accounting 
strategies and have implemented policy and entity tools in 
respect of regulatory reliefs.  

Interest Rate Benchmark Reform Phase 2, the amendments to 
IFRSs issued in August 2020, represents the second phase of the 
IASB’s project on the effects of interest rate benchmark reform. 
The amendments address issues affecting financial statements 
when changes are made to contractual cash flows and hedging 
relationships.

Under these amendments, changes made to a financial instrument 
measured at other than fair value through profit or loss that are 
economically equivalent and required by interest rate benchmark 
reform, do not result in the derecognition or a change in the 
carrying amount of the financial instrument. Instead they require 
the effective interest rate to be updated to reflect the change in 
the interest rate benchmark. In addition, hedge accounting will not 
be discontinued solely because of the replacement of the interest 
rate benchmark if the hedge meets other hedge accounting 
criteria.

These amendments applied from 1 January 2021 with early 
adoption permitted. HSBC adopted the amendments from 
1 January 2020.

At 31 Dec 2020
Non-derivative financial assets2
Non-derivative financial liabilities2
Derivative notional contract amount

Financial instruments yet to transition to alternative 
benchmarks, by main benchmark

USD Libor

GBP Libor

JPY Libor

$m

$m

$m

Others1

$m

94,148   

33,602   

46,587   

7,183   

371   

10,763 

1,548   

549 

  3,045,337    1,196,865   

508,200   

514,959 

1  Comprises financial instruments referencing other significant benchmark rates yet to transition to alternative benchmarks (Euro Libor, Swiss franc 

Libor, Eonia, SOR, MIFOR, THBFIX, PHIREF, TRLibor and Sibor).

2  Gross carrying amount excluding allowances for expected credit losses.

The amounts in the above table relate to HSBC’s main operating 
entities where HSBC has material exposures impacted by Ibor 
reform, including in the UK, Hong Kong, France, the US, Mexico, 
Canada, Singapore, the UAE, Bermuda, Australia, Qatar, Germany, 
Japan and Thailand. The amounts provide an indication of the 
extent of the Group’s exposure to the Ibor benchmarks that are 
due to be replaced. Amounts are in respect of financial 
instruments that:

• contractually reference an interest rate benchmark that is 

planned to transition to an alternative benchmark;

• have a contractual maturity date after 31 December 2021, the 

date by which Libor is expected to cease; and

• are recognised on HSBC’s consolidated balance sheet.

The administrator of Libor, IBA, has announced a proposal to 
extend the publication date of most US dollar Libor tenors until 
30 June 2023. Publication of one-week and two-month tenors will 
cease after 31 December 2021. This proposal, if endorsed, would 
reduce the amounts presented in the above table as some 
financial instruments included will reach their contractual maturity 
date prior to 30 June 2023.

Financial crime risk environment

Financial institutions remain under considerable regulatory 
scrutiny regarding their ability to prevent and detect financial 
crime. Financial crime threats continue to evolve, often in tandem 
with increased geopolitical developments and tensions, posing 
challenges for financial institutions to keep abreast of 
developments and manage conflicting laws. In particular, during 

2020, the escalating US-China tensions had significant impacts on 
sanctions and export control legal and regulatory regimes.
The global economic slowdown as a result of the Covid-19 
outbreak, and the resulting rapid deployment of government relief 
measures to support individuals and businesses, have increased 
the risk of fraud. Developments around virtual currencies, 
stablecoins and central bank digital currencies have continued, 
with the industry’s financial crime risk assessment and 
management frameworks in their early stages. The evolving 
regulatory environment presents an execution challenge. We 
continue to face increasing challenges presented by national data 
privacy requirements in a global organisation, which may affect 
our ability to manage financial crime risks effectively. There has 
also been an increase in media and public scrutiny on how 
financial crime is managed within financial institutions.

Mitigating actions

• We continue to enhance our financial crime risk management 
capabilities. We are investing in next generation capabilities to 
fight financial crime through the application of advanced 
analytics and artificial intelligence. We continue to monitor 
geopolitical developments closely and the impacts on our 
financial crime controls.

• We are strengthening and investing in our fraud controls, to 

introduce next generation anti-fraud capabilities to protect both 
our customers and the Group. 

• We have developed procedures and controls to manage the 
risks associated with direct and indirect exposure to virtual 
currencies. We continue to monitor external developments. We 

HSBC Holdings plc Annual Report and Accounts 2020

113

Risk review 
 
 
Risk

continue to educate our staff on emerging digital products and 
associated risks. 

crime groups and to collaborate in fighting, detecting and 
preventing cyber-attacks on financial organisations.

• We continue to monitor external developments on stablecoins 
and central bank digital currencies, engaging with central 
banks and regulators on financial crime risk management.

Internally driven

Data management

• We continue to work with jurisdictions and relevant 

international bodies to address data privacy challenges through 
international standards, guidance and legislation to help enable 
effective management of financial crime risk.

• We continue to take steps designed to ensure that the reforms 

we have put in place are both effective and sustainable over the 
long term.

• We continue to work closely with our regulators and engage in 
public-private partnerships, playing an active role in shaping 
the industry’s financial crime controls for the future. 

Regulatory compliance risk environment including 
conduct

Financial service providers continue to face numerous regulatory 
and supervisory requirements, particularly in the areas of capital 
and liquidity management, conduct of business, financial crime, 
internal control frameworks, the use of models and the integrity of 
financial services delivery. The competitive landscape in which the 
Group operates may be significantly altered by future regulatory 
changes and government intervention. Regulatory changes, 
including those driven by geopolitical issues, such as US-China 
tensions and those resulting from the UK’s exit from the EU, may 
affect the activities of the Group as a whole, or of some or all of its 
principal subsidiaries. For further details, see page 110.

Mitigating actions

• We engage, wherever possible, with governments and 

regulators in the countries and territories in which we operate, 
to help ensure that new requirements are considered properly 
and can be implemented effectively. In particular, we were 
proactive with the global policy changes issued in response to 
the Covid-19 outbreak to help our customers and contribute to 
an economic recovery. 

• We have had regular meetings with all relevant authorities to 
discuss strategic contingency plans, including those arising 
from geopolitical issues. 

Cyber threat and unauthorised access to systems

Together with other organisations, we continue to operate in an 
increasingly hostile cyber threat environment, which requires 
ongoing investment in business and technical controls to defend 
against these threats.

Key threats include unauthorised access to online customer 
accounts, advanced malware attacks, attacks on our third-party 
suppliers and security vulnerabilities being exploited.

Mitigating actions

• We continually evaluate threat levels for the most prevalent 
attack types and their potential outcomes. To further protect 
HSBC and our customers and help ensure the safe expansion of 
our global business lines, we strengthen our controls to reduce 
the likelihood and impact of advanced malware, data leakage, 
exposure through third parties and security vulnerabilities. 

• We continue to enhance our cybersecurity capabilities, 

including Cloud security, identity and access management, 
metrics and data analytics, and third-party security reviews. An 
important part of our defence strategy is ensuring our 
colleagues remain aware of cybersecurity issues and know how 
to report incidents.

• We report and review cyber risk and control effectiveness 

quarterly at executive and non-executive Board level. We also 
report across our global businesses, functions and regions to 
help ensure appropriate visibility and governance of the risk 
and mitigating actions.

• We participate globally in several industry bodies and working 
groups to share information about tactics employed by cyber-

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HSBC Holdings plc Annual Report and Accounts 2020

We use a large number of systems and applications to support key 
business processes and operations. To manage the risk of error, 
HSBC employs data controls at the point of capture, transfer and 
consumption. Along with other organisations, we also need to 
meet external/regulatory obligations such as the General Data 
Protection Regulation (‘GDPR’) and Basel III.

Mitigating actions 

• We are improving data quality across a large number of 

systems globally. Our data management, aggregation and 
oversight continues to strengthen and enhance the 
effectiveness of internal systems and processes. We are 
implementing data controls for end-to-end critical processes to 
improve our data capture at the point of entry and throughout 
the data lifecycle. 

• Through our global data management framework we are 

expanding and enhancing our data governance processes to 
help monitor the quality of critical customer, product, reference 
and transaction data proactively and resolve associated data 
issues in a timely manner. 

• We continue to modernise our data and analytics infrastructure 

through investments in advanced capabilities in Cloud, 
visualisation, machine learning and artificial intelligence 
platforms.

• We help protect customer data via our global data privacy 
framework programme, which establishes data privacy 
practices, design principles and guidelines that help enable us 
to demonstrate compliance with data privacy laws and 
regulations in the jurisdictions in which we operate.

• To help our employees keep abreast of data privacy laws and 

regulations we hold data privacy awareness training, 
highlighting our commitment to protect personal data for our 
customers, employees and other stakeholders.

Model risk management

Model risk arises whenever business decision making includes 
reliance on models. We use models in both financial and non-
financial contexts, as well as in a range of business applications 
such as customer selection, product pricing, financial crime 
transaction monitoring, creditworthiness evaluation and financial 
reporting. Assessing model performance is a continuous 
undertaking. Models can need redevelopment as market 
conditions change. This was required following the outbreak of 
Covid-19 as some models used for estimating credit losses needed 
to be redeveloped due to the dramatic change to inputs including 
GDP, unemployment rates and housing prices. 

Prior to the Covid-19 outbreak a key area of focus was improving 
and enhancing our model risk governance, and this activity 
continued throughout 2020. We prioritised the redevelopment of 
internal ratings-based (‘IRB’) and internal models methods (‘IMM’) 
models, in relation to counterparty credit, as part of the IRB repair 
and Basel III programmes with a key focus on enhancing the 
quality of data used as model inputs.

Mitigating actions

• We enhanced the monitoring and review of loss model 

performance through our Model Risk Management function as 
part of a broader quarterly process to determine loss levels. The 
Model Risk Management team aims to provide strong and 
effective review and challenge of any future redevelopment of 
these models.

• We appointed model risk stewards for each of the global 

businesses and functions to support, oversee and guide the 
global businesses and functions on model risk management. 
The risk stewards will provide close monitoring of changes in 
model behaviour, working closely with business and function 
model owners and sponsors. 

• We worked with the model owners of IRB models and traded 
risk models to increase our engagement on management of 
model risk with key regulators including the Prudential 
Regulation Authority (‘PRA’).

• We updated the model risk policy and introduced model risk 

standards to enable a more risk-based approach to model risk 
management. 

• We refreshed the model risk controls through the risk control 
assessment process. Employees who work in the first line of 
defence are expected to complete testing using the new 
enhanced controls in order to assess and understand model 
risk across the global businesses and key geographies.

• We upgraded the Group model inventory system to provide 

more granular measurement and management of model risk for 
multiple applications of a single model. 

• We are redeveloping our IRB and IMM models for counterparty 
credit and our internal models approach (‘IMA’) for traded risk 
models. These will be submitted for PRA approval over the next 
two years. 

Risks arising from the receipt of services from 
third parties

We use third parties for the provision of a range of services, in 
common with other financial service providers. Risks arising from 
the use of third-party service providers may be less transparent 
and therefore more challenging to manage or influence. It is 
critical that we ensure we have appropriate risk management 
policies, processes and practices. These should include adequate 
control over the selection, governance and oversight of third 
parties, particularly for key processes and controls that could 
affect operational resilience. Any deficiency in our management of 
risks arising from the use of third parties could affect our ability to 
meet strategic, regulatory or customer expectations.

Mitigating actions

• We continue to embed our delivery model in the first line of 

defence led by a global third-party management team, which 
works closely with our global businesses, global functions and 
regions. We have deployed processes, controls and technology 
to assess third-party service providers against key criteria and 
associated control monitoring, testing and assurance. This 
includes requesting third-party service providers to attest to 
HSBC’s ethical code of conduct during onboarding. 

• A dedicated oversight forum in the second line of defence 

monitors the embedding of policy requirements and 
performance against risk appetite.

• We delivered a major programme involving our global 

businesses, global functions and regions to help ensure that we 
are compliant with our third-party risk policy. 

• We reviewed our external supplier engagements to ensure that 

they meet our third-party risk quality standards including 
remediation where necessary.

• We implemented a new process for risk assessing our internal 
group service providers and ensuring that services we provide 
to other parts of our business also meet defined standards.

Risks associated with workforce capability, capacity 
and environmental factors with potential impact on 
growth

Our success in delivering our strategic priorities and managing the 
regulatory environment proactively depends on the development 
and retention of our leadership and high-performing employees. 
The ability to continue to attract, develop and retain competent 
individuals in an employment market impacted by the Covid-19 
outbreak is challenging particularly due to organisational 
restructuring. Changed working arrangements, local Covid-19 
restrictions and health concerns during the pandemic also impact 
on employee mental health and well-being.

Mitigating actions

• We have put in place measures to help support our people so 
they are able to work safely during the Covid-19 outbreak. 
While our approach to workplace recovery around the world is 
consistent, the measures we take in different locations are 
specific to their environment. 

• We promote a diverse and inclusive workforce and provide 
active support across a wide range of health and well-being 
activities. We continue to build our speak-up culture through 
active campaigns.

• We monitor people risks that could arise due to organisational 
restructuring, helping to ensure we manage redundancies 
sensitively and support impacted employees.

• We launched the Future Skills curriculum through HSBC 
University to help provide critical skills that will enable 
employees and HSBC to be successful in the future.

• We continue to develop succession plans for key management 
roles, with actions agreed and reviewed on a regular basis by 
the Group Executive Committee.

• We have robust plans in place, driven by senior management, 
to mitigate the effects of external factors that may impact our 
employment practices. Political and regulatory challenges are 
closely monitored to minimise the impact on the attraction and 
retention of talent and key performers.  

IT systems infrastructure and resilience

We are committed to investing in the reliability and resilience of 
our IT systems and critical services. We do so to protect our 
customers and ensure they are not impacted by disruption to 
services.

Mitigating actions

• We continue to invest in transforming how software solutions 
are developed, delivered and maintained, with a particular 
focus on providing high-quality, stable and secure services. We 
concentrate on improving system resilience and service 
continuity testing. We have enhanced the security features of 
our software development life cycle and improved our testing 
processes and tools. 

• We upgraded many of our IT systems, simplified our service 

provision and replaced older IT infrastructure and applications. 
These enhancements led to continued global improvements in 
service availability during 2020 for both our customers and 
employees.

Change execution risk

In February 2020, we announced our plans to restructure our 
business, reallocate freed-up capital into higher-growth and 
higher-return businesses and markets, and to simplify our 
organisation and reduce costs. Our success in delivering our 
strategic priorities and continuing to address regulatory change 
and other top and emerging risks is dependent on the effective 
and safe delivery of change across the Group.

Mitigating actions

• We have established a global transformation programme to 

deliver the commitments made in February 2020. The 
programme is overseen by members of the Group Executive 
Committee. Related execution risks across the initiatives, 
including their sequencing and prioritisation, are being 
monitored and managed. Many of the initiatives impact our 
staff and require continued investment in technology.

• We continue to work to strengthen our change management 

practices to deliver sustainable change. These include 
increased adoption across the Group of Agile ways of working 
to deliver change.

HSBC Holdings plc Annual Report and Accounts 2020

115

Risk reviewRisk

Areas of special interest

During 2020, a number of areas were identified and considered as 
part of our top and emerging risks because of the effect they may 
have on the Group. While considered under the themes captured 
under top and emerging risks, in this section we have placed a 
particular focus on the Covid-19 outbreak and the UK withdrawal 
from the EU.

Risks related to Covid-19

The Covid-19 outbreak and its effect on the global economy have 
impacted our customers and our performance, and the future 
effects of the outbreak remain uncertain. The outbreak 
necessitated governments to respond at unprecedented levels to 
protect public health, local economies and livelihoods. It has 
affected regions at different times and to varying degrees as it has 
developed. The varying government support measures and 
restrictions in response have added challenges, given the rapid 
pace of change and significant operational demands. The speed at 
which countries and territories will be able to unwind the 
government support measures and restrictions and return to pre-
Covid-19 economic levels will vary based on the levels of infection, 
local governmental decisions and access to and ability to roll out 
vaccines. There remains a risk of subsequent waves of infection, 
as evidenced by the recently emerged more transmissible variants 
of the virus. Renewed outbreaks emphasise the ongoing threat of 
Covid-19 even in countries that have recorded lower than average 
cases so far.

Government restrictions imposed around the world to limit the 
spread of Covid-19 resulted in a sharp contraction in global 
economic activity during 2020. At the same time governments 
also took steps designed to soften the extent of the damage to 
investment, trade and labour markets. Our Central scenario used 
to calculate impairment assumes that economic activity will 
gradually recover over the course of 2021. In this scenario, 
recovery will be supported by a successful roll-out of vaccination 
programmes across our key markets, which, coupled with 
effective non-pharmacological measures to contain the virus, will 
lead to a decline in infections over the course of the year. 
Governments and central banks are expected to continue to work 
together across many of our key markets to ensure that 
households and firms receive an appropriate level of financial 
support until restrictions on economic activity and mobility can be 
materially eased. Such support is intended to ensure that labour 
and housing markets do not experience abrupt, negative 
corrections. It is also intended to limit the extent of long-term 
structural damage to economies. There is a high degree of 
uncertainty associated with economic forecasts in the current 
environment and there are significant risks to our Central scenario. 
The degree of uncertainty varies by market, driven by country-
specific trends in the evolution of the pandemic and associated 
policy responses. As a result, our Central scenario for impairment 
has not been assigned an equal likelihood of occurrence across 
our key markets. For further details of our Central and other 
scenarios see ‘Measurement uncertainty and sensitivity analysis’ 
on page 127.

There is a material risk of a renewed drop in economic activity. 
The economic fallout from the Covid-19 outbreak risks increasing 
inequality across markets that have already suffered from social 
unrest. This will leave the burden on governments and central 
banks to maintain or increase fiscal and monetary stimulus. After 
financial markets suffered a sharp fall in the early phases of the 
spread of Covid-19, they rebounded but still remain volatile. 
Depending on the long-term impact on global economic growth, 
financial asset prices may suffer a further sharp fall.

Governments and central banks in major economies have 
deployed extensive measures to support their local populations. 
Measures implemented by governments have included income 
support to households and funding support to businesses. Central 
bank measures have included cuts to policy rates, support to 
funding markets and asset purchases. These measures are being 
extended in countries where further waves of the Covid-19 
outbreak are prompting renewed government restrictions. Central 

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HSBC Holdings plc Annual Report and Accounts 2020

banks are expected to maintain record-low interest rates for a 
considerable period of time and the debt burden of governments is 
expected to rise significantly.

We initiated market-specific measures to support our personal and 
business customers through these challenging times. These 
included mortgage assistance, payment holidays, the waiving of 
certain fees and charges, and liquidity relief for businesses facing 
market uncertainty and supply chain disruption. We are also 
working closely with governments, and supporting national 
schemes that focus on the parts of the economy most impacted 
by Covid-19. In the UK, this included providing access to the 
various government support schemes from the beginning. In Hong 
Kong, we provided prompt liquidity relief to businesses facing 
market uncertainty and supply chain pressures. For further details 
of our customer relief programmes, see page 142.

Central bank and government actions and support measures taken 
in response to the Covid-19 outbreak, and our responses to those, 
have created, and may in the future create restrictions in relation 
to capital. This has limited and may in the future limit 
management's flexibility in managing the business and taking 
action in relation to capital distribution and capital allocation. For 
example, in response to a written request from the PRA, we 
cancelled the fourth interim dividend for 2019 of $0.21 per 
ordinary share. We also announced that we would make no 
quarterly or interim dividend payments or accruals in respect of 
ordinary shares until the end of 2020. Following this, in December 
2020 the PRA announced a temporary approach to shareholder 
distributions for 2020 in which it set out a framework for board 
decisions on dividends. After considering the requirements of the 
temporary approach, the Board announced an interim dividend for 
2020 of $0.15 per ordinary share.

The rapid introduction and varying nature of the government 
support schemes, as well as customer expectations, has led to 
risks as the Group implements large-scale changes in a short 
period of time. This has led to increased operational risks, 
including complex conduct considerations, increased reputational 
risk and increased risk of fraud. These risks are likely to be 
heightened further as and when those government support 
schemes are unwound. Central bank and government actions and 
support measures, and our responses to those, have also led to 
increased litigation risk, including lawsuits that have been and 
may continue to be brought in connection with our cancellation of 
the fourth interim dividend for 2019.

At 31 December 2020, our CET1 ratio was 15.9%, compared with 
14.7% at 31 December 2019, and our liquidity coverage ratio 
(‘LCR’) was 139%. Our capital, funding and liquidity position is 
expected to help us to continue supporting our customers 
throughout the Covid-19 outbreak.

In many of our markets the Covid-19 outbreak has led to a 
worsening of economic conditions and increased uncertainty, 
which has been reflected in higher ECL reserves. Furthermore, 
credit losses may increase due to exposure to vulnerable sectors 
of the economy such as retail, hospitality and commercial real 
estate. The impact of the pandemic on the long-term prospects of 
businesses in these sectors is uncertain and may lead to 
significant credit losses on specific exposures, which may not be 
fully captured in ECL estimates. In addition, in times of stress, 
fraudulent activity is often more prevalent, leading to potentially 
significant credit or operational losses. 

The significant changes in economic and market drivers, customer 
behaviours and government actions caused by Covid-19 have 
materially impacted the performance of financial models. ECL 
model performance has been significantly impacted, which has 
increased reliance on management judgement in determining the 
appropriate level of ECL estimates. The reliability of ECL models 
under these circumstances has also been impacted by the 
unprecedented response from governments to provide a variety of 
economic stimulus packages to support livelihoods and 
businesses. Historical observations on which the models were 
built do not reflect these unprecedented support measures. We 
continue to monitor credit performance against the level of 
government support and customer relief programmes.

In order to address some model limitations and performance 
issues, we redeveloped some of the key models used to calculate 
ECL estimates. These models have been independently validated 
by the Model Risk Management team and assessed as having the 
ability to deliver reliable credit loss estimates. While this reduced 
the reliance on management judgement for determining ECL 
estimates, the current uncertain economic outlook, coupled with 
the expected end to government support schemes, resulted in 
judgemental post-model adjustments still being required. The 
Model Risk Management team is reviewing IFRS 9 model 
performance at the country and Group level on a quarterly basis to 
assess whether or not the models in place can deliver reliable 
outputs. 

These assessments provide the credit teams with a view of model 
reliability. The redevelopment of IFRS 9 models will continue as 
the economic consequences of the Covid-19 outbreak become 
clearer over time, economic conditions normalise and actual credit 
losses occur.

As a result of the Covid-19 outbreak, business continuity 
responses were implemented and the majority of service level 
agreements have been maintained. We have not experienced any 
major impacts to the supply chain from our third-party service 
providers due to the pandemic. The risk of damage or theft to our 
physical assets or criminal injury to our employees remains 
unchanged and no significant incidents have impacted our 
buildings or staff.

There remain significant uncertainties in assessing the duration of 
the Covid-19 outbreak and its impact. The actions taken by various 
governments and central banks, in particular in the UK, mainland 
China, Hong Kong and the US, provide an indication of the 
potential severity of the downturn and post-recovery environment, 
which from a commercial, regulatory and risk perspective could be 
significantly different to past crises and persist for a prolonged 
period. A continued prolonged period of significantly reduced 
economic activity as a result of the impact of the outbreak could 
have a materially adverse effect on our financial condition, results 
of operations, prospects, liquidity, capital position and credit 
ratings. We continue to monitor the situation closely, and given 
the novel or prolonged nature of the outbreak, additional 
mitigating actions may be required.

UK withdrawal from the European Union

The UK left the EU on 31 January 2020 and entered a transition 
period until 31 December 2020. A Trade and Cooperation 
Agreement between the EU and the UK was agreed on 
24 December 2020 and ratified by the UK on 30 December 2020. It 
includes a joint declaration of cooperation, and in the coming 
months both parties are expected to enter discussions with the 
aim of agreeing a Memorandum of Understanding establishing the 
framework for this cooperation. As expected, the financial 
passporting arrangement expired at the end of the transition 
period, and therefore financial institutions in the UK including 
HSBC Bank plc and HSBC UK lost their EU regulatory permissions 
to continue servicing clients in the European Economic Area 
(‘EEA’) from 1 January 2021. The Trade and Cooperation 
Agreement mainly focused on goods and services but also 
covered a wide range of other areas, including competition, state 
aid, tax, fisheries, transport, data and security. However, it 
included limited elements on financial services, and, as a result, 
did not change HSBC’s planning in relation to the UK’s withdrawal 
from the EU. 

Our programme to manage the impact of the UK withdrawal from 
the EU has now been largely completed. It was based on the 
assumption of a scenario whereby the UK exits the transition 
period without the financial passporting or regulatory equivalence 
framework that supports cross-border business.

Equivalence decisions are an established feature of EU law, which 
allow the authorities in the UK and EU to rely on the other’s 
regime for specific regulatory purposes only. While the UK and the 
EU have made a number of equivalence decisions, these decisions 
do not give UK firms full access to EU clients and counterparties.

Our programme focused on four main components: legal entity 
restructuring; product offering; customer migrations; and 
employees. However, there remain risks, many of them linked to 
the absence of some equivalence decisions between the EU and 
the UK.

We have carried out detailed reviews of our credit portfolios to 
determine those sectors and customers most vulnerable to the 
UK’s exit from the EU and will continue to monitor any 
implications for our clients in adhering to the new requirements 
under the Trade and Cooperation Agreement. 

Legal entity restructuring

Our branches in seven EEA countries (Belgium, the Netherlands, 
Luxembourg, Spain, Italy, Ireland and Czech Republic) relied on 
financial passporting out of the UK. We had worked on the 
assumption that this passporting would no longer be possible 
following the UK’s withdrawal from the EU and therefore 
transferred our branch business to newly established branches of 
HSBC Continental Europe, our primary banking entity authorised 
in the EU. This was completed in the first quarter of 2019.

Product offering 

To accommodate customer migrations and new business after the 
UK’s departure from the EU, we expanded our product offering in 
a wide range of areas such as in our Markets and Securities 
Services franchise as well as in our Global Trade Business. We 
also enhanced our cash management solutions in France, the 
Netherlands and Ireland. We also opened a new branch in 
Stockholm to service our customers in the Nordic region. 

Customer migrations

The UK’s withdrawal from the EU has had an impact on our 
clients’ operating models, including their working capital 
requirements, investment decisions and financial markets 
infrastructure access. Our priority is to provide continuity of 
service, and while our intention was to minimise the level of 
change for our customers, we were required to migrate some 
EEA-incorporated clients from the UK to HSBC Continental Europe 
or another EEA entity. We have now migrated almost all clients 
who we expect can no longer be serviced out of the UK. The 
majority of remaining customers are covered by national regimes 
that allow continuity of financial services on a temporary or 
permanent basis between the UK and their respective jurisdictions. 
We are working in close collaboration with our customers with the 
aim of managing their transition in 2021, where required.

Employees

The migration of EEA-incorporated clients required us to 
strengthen our local teams in the EU, and France in particular. We 
have now completed the transfer of roles from London to Paris to 
support our post-UK withdrawal from the EU operating model. 

Looking beyond the transfer of roles to the EU, we are also 
providing support to our employees who are UK citizens resident 
in EEA countries, and employees who are citizens of an EU 
member state resident in the UK, for example on settlement 
applications.

HSBC Holdings plc Annual Report and Accounts 2020

117

Risk reviewRisk

Our material banking risks

The material risk types associated with our banking and insurance manufacturing operations are described in the following tables:

Description of risks – banking operations

Risks

Arising from

Measurement, monitoring and management of risk

Credit risk (see page 119)
Credit risk is the risk of financial 
loss if a customer or 
counterparty fails to meet an 
obligation under a contract. 

Treasury risk (see page 169)
Treasury risk is the risk of 
having insufficient capital, 
liquidity or funding resources to 
meet financial obligations and 
satisfy regulatory requirements, 
including the risk of adverse 
impact on earnings or capital 
due to structural foreign 
exchange exposures and 
changes in market interest 
rates, and including the 
financial risks arising from 
historical and current provision 
of pensions and other post-
employment benefits to staff 
and their dependants.

Market risk (see page 182)
Market risk is the risk that 
movements in market factors, 
such as foreign exchange rates, 
interest rates, credit spreads, 
equity prices and commodity 
prices, will reduce our income 
or the value of our portfolios.

Resilience risk (see page 186)
Resilience risk is the risk that 
we are unable to provide critical 
services to our customers, 
affiliates and counterparties as 
a result of sustained and 
significant operational 
disruption.

Credit risk arises principally 
from direct lending, trade 
finance and leasing business, 
but also from other products 
such as guarantees and 
derivatives.

Credit risk is:
• measured as the amount that could be lost if a customer or counterparty fails to 

make repayments; 

• monitored using various internal risk management measures and within limits 

approved by individuals within a framework of delegated authorities; and

• managed through a robust risk control framework, which outlines clear 

and consistent policies, principles and guidance for risk managers.

Treasury risk arises from 
changes to the respective 
resources and risk profiles 
driven by customer behaviour, 
management decisions, or 
pension plan fiduciary decisions. 
It also arises from the external 
environment, including changes 
to market parameters such as 
interest rates or foreign 
exchange rates, together with 
updates to the regulatory 
requirements.

Treasury risk is: 
• measured through risk appetite and more granular limits, set to provide an early 
warning of increasing risk, minimum ratios of relevant regulatory metrics, and 
metrics to monitor the key risk drivers impacting treasury resources;

• monitored and projected against appetites and by using operating plans based on 

strategic objectives together with stress and scenario testing; and 

• managed through control of resources in conjunction with risk profiles, strategic 

objectives and cash flows.

Exposure to market risk is 
separated into two portfolios: 
trading portfolios and non-
trading portfolios. 
Market risk exposures arising 
from our insurance operations 
are discussed on page 185.

Market risk is:
• measured using sensitivities, value at risk and stress testing, giving a detailed 
picture of potential gains and losses for a range of market movements and 
scenarios, as well as tail risks over specified time horizons;

• monitored using value at risk, stress testing and other measures; and
• managed using risk limits approved by the RMM and the risk management meeting 

in various global businesses. 

Resilience risk arises from 
failures or inadequacies in 
processes, people, systems or 
external events.

Resilience risk is: 
• measured using a range of metrics with defined maximum acceptable impact 

tolerances, and against our agreed risk appetite;

• monitored through oversight of enterprise processes, risks, controls and strategic 

change programmes; and

• managed by continual monitoring and thematic reviews.

Regulatory compliance risk (see page 186)
Regulatory compliance risk is 
the risk that we fail to observe 
the letter and spirit of all 
relevant laws, codes, rules, 
regulations and standards of 
good market practice, which as 
a consequence incur fines and 
penalties and suffer damage to 
our business.

Regulatory compliance risk 
arises from the risks associated 
with breaching our duty to our 
customers and inappropriate 
market conduct, as well as 
breaching regulatory licensing, 
permission and rules. 

Financial crime risk (see page 187)
Financial crime risk is the risk of 
knowingly or unknowingly 
helping parties to commit or to 
further illegal activity through 
HSBC, including money 
laundering, fraud, bribery and 
corruption, tax evasion, 
sanctions breaches, and 
terrorist and proliferation 
financing.

Financial crime risk arises from 
day-to-day banking operations 
involving customers, third 
parties and employees. 
Exceptional circumstances that 
impact day-to-day operations 
may additionally increase 
financial crime risk.

Regulatory compliance risk is:
• measured by reference to risk appetite, identified metrics, incident assessments, 

regulatory feedback and the judgement and assessment of our regulatory 
compliance teams;

• monitored against the first line of defence risk and control assessments, the results 
of the monitoring and control assurance activities of the second line of defence 
functions, and the results of internal and external audits and regulatory inspections; 
and

• managed by establishing and communicating appropriate policies and procedures, 
training employees in them and monitoring activity to help ensure their observance. 
Proactive risk control and/or remediation work is undertaken where required.

Financial crime risk is: 
•   measured by reference to risk appetite, identified metrics, incident assessments, 

regulatory feedback and the judgement and assessment of our regulatory 
compliance teams;

•   monitored against the first line of defence risk and control assessments, the results 
of the monitoring and control assurance activities of the second line of defence 
functions, and the results of internal and external audits and regulatory inspections; 
and

•   managed by establishing and communicating appropriate policies and procedures, 
training employees in them and monitoring activity to help ensure their observance. 
Proactive risk control and/or remediation work is undertaken where required.

118

HSBC Holdings plc Annual Report and Accounts 2020

Description of risks – banking operations

Risks

Arising from

Measurement, monitoring and management of risk

Model risk (see page 188)
Model risk is the potential for 
adverse consequences from 
business decisions informed by 
models, which can be 
exacerbated by errors in 
methodology, design or the 
way they are used. 

Model risk arises in both 
financial and non-financial 
contexts whenever business 
decision making includes 
reliance on models. 

Model risk is:
• measured by reference to model performance tracking and the output of detailed 

technical reviews, with key metrics including model review statuses and findings;  

• monitored against model risk appetite statements, insight from the independent 

review function, feedback from internal and external audits, and regulatory reviews; 
and

• managed by creating and communicating appropriate policies, procedures and 

guidance, training colleagues in their application, and supervising their adoption to 
ensure operational effectiveness.

Our insurance manufacturing subsidiaries are regulated separately 
from our banking operations. Risks in our insurance entities are 
managed using methodologies and processes that are subject to 
Group oversight. Our insurance operations are also subject to 

many of the same risks as our banking operations, and these are 
covered by the Group’s risk management processes. However, 
there are specific risks inherent to the insurance operations as 
noted below.

Description of risks – insurance manufacturing operations

Risks

Arising from

Measurement, monitoring and management of risk

Financial risk (see page 192)
For insurance entities, financial risk 
includes the risk of not being able  
to effectively match liabilities 
arising under insurance contracts 
with appropriate investments and 
that the expected sharing of 
financial performance with 
policyholders under certain 
contracts is not possible.

Exposure to financial risk arises 
from: 
• market risk affecting the fair 
values of financial assets or 
their future cash flows;

• credit risk; and
• liquidity risk of entities being 
unable to make payments to 
policyholders as they 
fall due.

Financial risk is:
• measured (i) for credit risk, in terms of economic capital and the amount that 
could be lost if a counterparty fails to make repayments; (ii) for market risk, in 
terms of economic capital, internal metrics and fluctuations in key financial 
variables; and (iii) for liquidity risk, in terms of internal metrics including stressed 
operational cash flow projections;

• monitored through a framework of approved limits and delegated authorities; and
• managed through a robust risk control framework, which outlines clear and 

consistent policies, principles and guidance. This includes using product design, 
asset liability matching and bonus rates. 

Insurance risk (see page 194)
Insurance risk is the risk that, over 
time, the cost of insurance policies 
written, including claims and 
benefits, may exceed the total 
amount of premiums and 
investment income received.

The cost of claims and benefits 
can be influenced by many 
factors, including mortality and 
morbidity experience, as well 
as lapse and surrender rates.

Insurance risk is:
• measured in terms of life insurance liabilities and economic capital allocated to 

insurance underwriting risk;

• monitored through a framework of approved limits and delegated authorities; and
• managed through a robust risk control framework, which outlines clear and 

consistent policies, principles and guidance. This includes using product design, 
underwriting, reinsurance and claims-handling procedures.

Credit risk 

Overview

Credit risk management

Credit risk in 2020

Summary of credit risk

Credit exposure 

Measurement uncertainty and sensitivity analysis of ECL estimates

Reconciliation of changes in gross carrying/nominal amount and 
allowances for loans and advances to banks and customers including 
loan commitments and financial guarantees

Credit quality

Customer relief programmes

Wholesale lending

Personal lending

Supplementary information

HSBC Holdings 

Overview

Page

119

119

122

  123 

126

127

135

138

142

144

158

164

169

Credit risk is the risk of financial loss if a customer or counterparty 
fails to meet an obligation under a contract. Credit risk arises 
principally from direct lending, trade finance and leasing business, 
but also from other products such as guarantees and credit 
derivatives. 

Credit risk management

Key developments in 2020

There were no material changes to the policies and practices 
for the management of credit risk in 2020. We continued to apply 
the requirements of IFRS 9 ‘Financial Instruments’ within the 
Credit Risk sub-function.

Due to the unique market conditions observed during the Covid-19 
outbreak, we expanded operational practices to provide short-term 
support to customers under the current credit policy framework. 

The outbreak necessitated governments to respond at 
unprecedented levels to protect public health, local economies and 
livelihoods. It has affected regions at different times and varying 
degrees as it has developed. The varying government support 
measures in response have added challenges, given the rapid pace 
of change and significant operational demands. The speed at 
which countries and territories will be able to unwind the 
government measures and return to pre-Covid-19 economic levels 
will vary based on the levels of infection, local political decisions 
and access to and ability to roll out vaccine.

As we helped our customers during these challenging times, we 
continued to prioritise effective and robust credit risk 
management. We performed a number of reviews on segments of 
our loan portfolio that were likely to be impacted by the economic 
slowdown. A number of internal stress tests were conducted 
under different scenarios in order to assess the potential impact of 
the Covid-19 outbreak on expected credit losses. We reviewed and 
implemented the guidance provided by regulators on how to 
manage the credit portfolio, how to identify the effects of the 
various payment moratoria, and the appropriate classification of 
forborne/renegotiated loans under the various schemes. We also 
increased our focus on the quality and timeliness of the data used 
to inform management decisions, so we were able to manage the 
varying level of risk actively throughout the year.

The Covid-19 outbreak and its effect on the global economy have 
impacted our customers and our performance during this year, 
and the future effects of the outbreak remain uncertain. 

For further details of market-specific measures to support our 
personal and business customers, see page 142.

HSBC Holdings plc Annual Report and Accounts 2020

119

Risk review 
 
 
Risk

Governance and structure

We have established Group-wide credit risk management and 
related IFRS 9 processes. We continue to assess the impact of 
economic developments in key markets on specific customers, 
customer segments or portfolios. As credit conditions change, we 
take mitigating action, including the revision of risk appetites or 
limits and tenors, as appropriate. In addition, we continue to 
evaluate the terms under which we provide credit facilities within 
the context of individual customer requirements, the quality of the 
relationship, local regulatory requirements, market practices and 
our local market position.

Credit Risk sub-function

(Audited)

Credit approval authorities are delegated by the Board to the 
Group Chief Executive together with the authority to sub-delegate 
them. The Credit Risk sub-function in Global Risk is responsible for 
the key policies and processes for managing credit risk, which 
include formulating Group credit policies and risk rating 
frameworks, guiding the Group’s appetite for credit risk 
exposures, undertaking independent reviews and objective 
assessment of credit risk, and monitoring performance and 
management of portfolios.

The principal objectives of our credit risk management are:

• to maintain across HSBC a strong culture of responsible 
lending, and robust risk policies and control frameworks; 

• to both partner and challenge our businesses in defining, 

implementing and continually re-evaluating our risk appetite 
under actual and scenario conditions; and

• to ensure there is independent, expert scrutiny of credit risks, 

their costs and their mitigation.

Key risk management processes

IFRS 9 ‘Financial Instruments’ process

activities or operate in the same geographical areas or industry 
sectors so that their collective ability to meet contractual 
obligations is uniformly affected by changes in economic, political 
or other conditions. We use a number of controls and measures to 
minimise undue concentration of exposure in our portfolios across 
industries, countries and global businesses. These include portfolio 
and counterparty limits, approval and review controls, and stress 
testing.

Credit quality of financial instruments

(Audited)

Our risk rating system facilitates the internal ratings-based 
approach under the Basel framework adopted by the Group to 
support the calculation of our minimum credit regulatory capital 
requirement. The five credit quality classifications encompass a 
range of granular internal credit rating grades assigned to 
wholesale and retail lending businesses, and the external ratings 
attributed by external agencies to debt securities.

For debt securities and certain other financial instruments, external 
ratings have been aligned to the five quality classifications based 
upon the mapping of related customer risk rating (‘CRR’) to 
external credit rating.

Wholesale lending

The CRR 10-grade scale summarises a more granular underlying 
23-grade scale of obligor probability of default (‘PD’). All corporate 
customers are rated using the 10- or 23-grade scale, depending on 
the degree of sophistication of the Basel approach adopted for the 
exposure.

Each CRR band is associated with an external rating grade by 
reference to long-run default rates for that grade, represented by 
the average of issuer-weighted historical default rates. This 
mapping between internal and external ratings is indicative and 
may vary over time.

Retail lending

The IFRS 9 process comprises three main areas: modelling and 
data; implementation; and governance.

Retail lending credit quality is based on a 12-month point-in-time 
probability-weighted PD.

Modelling and data

We have established IFRS 9 modelling and data processes in 
various geographies, which are subject to internal model risk 
governance including independent review of significant model 
developments.

Implementation

A centralised impairment engine performs the expected credit 
losses calculation using data, which is subject to a number of 
validation checks and enhancements, from a variety of client, 
finance and risk systems. Where possible, these checks and 
processes are performed in a globally consistent and centralised 
manner.

Governance

Regional management review forums are established in key sites 
and regions in order to review and approve the impairment results. 
Regional management review forums have representatives from 
Credit Risk and Finance. The key site and regional approvals are 
reported up to the global business impairment committee for final 
approval of the Group’s ECL for the period. Required members of 
the committee are the global heads of Wholesale Credit, Market 
Risk, and Wealth and Personal Banking Risk, as well as the global 
business chief financial officers and the Group Chief Accounting 
Officer.

Concentration of exposure

(Audited)

Concentrations of credit risk arise when a number of 
counterparties or exposures have comparable economic 
characteristics, or such counterparties are engaged in similar 

120

HSBC Holdings plc Annual Report and Accounts 2020

 
Credit quality classification

Quality classification

Footnotes

1, 2

Strong

Good

Satisfactory

Sub-standard

Credit impaired

Sovereign debt 
securities
and bills

Other debt 
securities
and bills

Wholesale lending
and derivatives

Retail lending

External credit 
rating

External credit 
rating

Internal credit 
rating

12-month Basel 
probability of 
default %

Internal credit 
rating

12 month 
probability- 
weighted PD %

BBB and above

A- and above

CRR 1 to CRR 2

0–0.169

Band 1 and 2

BBB- to BB

BBB+ to BBB-

CRR 3

0.170–0.740

Band 3

0.000–0.500

0.501–1.500

BB- to B and 
unrated

BB+ to B and 
unrated

CRR 4 to CRR 5

0.741–4.914

Band 4 and 5

1.501–20.000

B- to C

Default

B- to C

CRR 6 to CRR 8

4.915–99.999

Default CRR 9 to CRR 10

100

Band 6

Band 7

20.001–99.999

100

1  Customer risk rating (‘CRR’).
2  12-month point-in-time probability-weighted probability of default (‘PD’).

Quality classification definitions

• ‘Strong’ exposures demonstrate a strong capacity to meet financial commitments, with negligible or low probability of default and/or low levels of 

expected loss.

• ‘Good’ exposures require closer monitoring and demonstrate a good capacity to meet financial commitments, with low default risk.
• ‘Satisfactory’ exposures require closer monitoring and demonstrate an average-to-fair capacity to meet financial commitments, with moderate default 

risk.

• ‘Sub-standard’ exposures require varying degrees of special attention and default risk is of greater concern.
• ‘Credit-impaired’ exposures have been assessed as described on Note 1.2(i) on the financial statements.

Renegotiated loans and forbearance

(Audited)

‘Forbearance’ describes concessions made on the contractual 
terms of a loan in response to an obligor’s financial difficulties.

A loan is classed as ‘renegotiated’ when we modify the 
contractual payment terms on concessionary terms because we 
have significant concerns about the borrowers’ ability to meet 
contractual payments when due. Non-payment-related 
concessions (e.g. covenant waivers), while potential indicators of 
impairment, do not trigger identification as renegotiated loans. 

Loans that have been identified as renegotiated retain this 
designation until maturity or derecognition. 

For details of our policy on derecognised renegotiated loans, see Note 1.2(i) 
on the financial statements.

Credit quality of renegotiated loans

such schemes, or an extension thereof, is not automatically 
determined to be evidence of financial difficulty and would 
therefore not automatically trigger identification as renegotiated 
loans. Rather, information provided by payment deferrals is 
considered in the context of other reasonable and supportable 
information. The IFRS 9 treatment of customer relief programmes 
is explained on page 142.

Impairment assessment

(Audited)

For details of our impairment policies on loans and advances and 
financial investments, see Note 1.2(i) on the financial statements.

Write-off of loans and advances

(Audited)

For details of our policy on the write-off of loans and advances, 
see Note 1.2(i) on the financial statements.

On execution of a renegotiation, the loan will also be classified as 
credit impaired if it is not already so classified. In wholesale 
lending, all facilities with a customer, including loans that have not 
been modified, are considered credit impaired following the 
identification of a renegotiated loan. 

Unsecured personal facilities, including credit cards, are generally 
written off at between 150 and 210 days past due. The standard 
period runs until the end of the month in which the account 
becomes 180 days contractually delinquent. However, in 
exceptional circumstances, they may be extended further.

Wholesale renegotiated loans are classified as credit impaired until 
there is sufficient evidence to demonstrate a significant reduction 
in the risk of non-payment of future cash flows, observed over a 
minimum one-year period, and there are no other indicators of 
impairment. Personal renegotiated loans generally remain credit 
impaired until repayment, write-off or derecognition.

Renegotiated loans and recognition of expected credit losses

(Audited)

For retail lending, unsecured renegotiated loans are generally 
segmented from other parts of the loan portfolio. Renegotiated 
expected credit loss assessments reflect the higher rates of losses 
typically encountered with renegotiated loans. For wholesale 
lending, renegotiated loans are typically assessed individually. 
Credit risk ratings are intrinsic to the impairment assessments. The 
individual impairment assessment takes into account the higher 
risk of the future non-payment inherent in renegotiated loans.

Customer relief programmes and renegotiated loans

In response to the Covid-19 outbreak, governments and regulators 
around the world encouraged a range of customer relief 
programmes including payment deferrals. In determining whether 
a customer is experiencing financial difficulty for the purposes of 
identifying renegotiated loans a payment deferral requested under 

For secured facilities, write-off should occur upon repossession of 
collateral, receipt of proceeds via settlement, or determination that 
recovery of the collateral will not be pursued.

Any secured assets maintained on the balance sheet beyond
60 months of consecutive delinquency-driven default require 
additional monitoring and review to assess the prospect of 
recovery.

There are exceptions in a few countries and territories where local 
regulation or legislation constrains earlier write-off, or where the 
realisation of collateral for secured real estate lending takes more 
time. In the event of bankruptcy or analogous proceedings, write-
off may occur earlier than the maximum periods stated above. 
Collection procedures may continue after write-off.

HSBC Holdings plc Annual Report and Accounts 2020

121

Risk reviewWhile credit risk arises across most of our balance sheet, ECL 
have typically been recognised on loans and advances to 
customers and banks, in addition to securitisation exposures and 
other structured products. As a result, our disclosures focus 
primarily on these two areas. For further details of:

• maximum exposure to credit risk, see page 126;
• measurement uncertainty and sensitivity analysis of ECL 

estimates, see page 127;

• reconciliation of changes in gross carrying/ nominal amount 

and allowances for loans and advances to banks and 
customers including loan commitments and financial 
guarantees, see page 135;
• credit quality, see page 138;
• customer relief programmes, see page 142;
• total wholesale lending for loans and advances to banks and 

customers by stage distribution, see page 145;

• wholesale lending collateral, see page 150;
• total personal lending for loans and advances to customers at 

amortised cost by stage distribution, see page 159; and

• personal lending collateral, see page 162.

Risk

Credit risk in 2020

At 31 December 2020, gross loans and advances to customers 
and banks of $1,134bn increased by $19.4bn, compared with
31 December 2019. This included favourable foreign exchange 
movements of $26.4bn. Excluding foreign exchange movements, 
the decline was driven by a $33.2bn decrease in wholesale loans 
and advances to customers. This was partly offset by a $15bn 
increase in personal loans and advances and a $11.2bn increase in 
loans and advances to banks. 

At 31 December 2020, the allowance for ECL of $15.7bn increased 
by $6.3bn compared with 31 December 2019, including adverse 
foreign exchange movements of $0.1bn. It increased by $1.2bn 
compared with 30 June 2020. The $15.7bn allowance comprised 
$14.7bn in respect of assets held at amortised cost, $0.9bn in 
respect of loan commitments and financial guarantees, and 
$0.1bn in respect of debt instruments measured at fair value 
through other comprehensive income (‘FVOCI’).

During the first half of 2020, the Group experienced a significant 
increase in allowances for ECL, which subsequently stabilised 
during the second half of 2020. Excluding foreign exchange 
movements, the allowance for ECL in relation to loans and 
advances to customers increased by $5.7bn from
31 December 2019. This was attributable to:

• a $4.1bn increase in wholesale loans and advances to 

customers, of which $2.0bn was driven by stages 1 and 2; and

• a $1.6bn increase in personal loans and advances to 

customers, of which $1.3bn was driven by stages 1 and 2.

During the first six months of the year, the Group experienced 
significant migrations from stage 1 to stage 2, reflecting a 
worsening of the economic outlook. This trend slowed during the 
second half of 2020 as forward economic guidance remained 
broadly stable in comparison with 30 June 2020, with some 
regions experiencing transfers from stage 2 to stage 1.

At 31 December 2020, stage 3 gross loans and advances to 
customers and banks of $19.1bn increased by $5.7bn compared 
with 31 December 2019. This included favourable foreign 
exchange movements of $0.2bn. Stage 3 gross loans and 
advances to customers and banks at 31 December 2020 increased 
from $17.1bn at 30 June 2020, while benefiting from releases 
from historical default cases. As the Covid-19 pandemic continues, 
there may be volatility in future stage 3 balances, in particular due 
to the expiration of the measures implemented by governments, 
regulators and banks to support customers.

The ECL charge for 2020 was $8.8bn, inclusive of recoveries, 
which comprised $6.0bn in respect of wholesale lending, of which 
stage 3 and purchased or originated credit impaired ('POCI') was 
$3.4bn; $2.7bn in respect of personal lending, of which stage 3 
was $0.8bn; and $0.1bn in respect of other financial assets 
measured at amortised cost and debt instruments measured at 
FVOCI. 

The ECL charge for the six months ended 30 June 2020 was 
$6.9bn, which comprised $4.6bn in respect of wholesale lending, 
of which stage 3 and POCI was $2.2bn; $2.0bn in respect of 
personal lending, of which stage 3 was $0.5bn; and $0.2bn in 
respect of other financial assets measured at amortised cost and 
debt instruments measured at FVOCI.

Income statement movements are analysed further on page 79.

122

HSBC Holdings plc Annual Report and Accounts 2020

Summary of credit risk

The following disclosure presents the gross carrying/nominal amount of financial instruments to which the impairment requirements in 
IFRS 9 are applied and the associated allowance for ECL.

Summary of financial instruments to which the impairment requirements in IFRS 9 are applied

(Audited)

31 Dec 2020

 At 31 Dec 2019

Gross carrying/
nominal amount

Allowance for
ECL1

Gross carrying/
nominal amount

Allowance for 
ECL1

Loans and advances to customers at amortised cost

1,052,477   

(14,490)   

1,045,475   

Footnotes

$m

$m

$m

–  personal

–  corporate and commercial

–  non-bank financial institutions

Loans and advances to banks at amortised cost

Other financial assets measured at amortised cost

–  cash and balances at central banks

–  items in the course of collection from other banks

–  Hong Kong Government certificates of indebtedness

–  reverse repurchase agreements – non-trading

–  financial investments 

–  prepayments, accrued income and other assets

Total gross carrying amount on-balance sheet

Loans and other credit-related commitments

–  personal

–  corporate and commercial

–  non-bank financial institutions

Financial guarantees

–  personal

–  corporate and commercial

–  non-bank financial institutions

Total nominal amount off-balance sheet

2

3

460,809   

527,088   

64,580   

81,658   

772,408   

304,486   

4,094   

40,420   

230,628   

88,719   

104,061   

(4,731)   

(9,494)   

(265)   

(42)   

(175)   

(5)   

—   

—   

—   

(80)   

(90)   

434,271   

540,499   

70,705   

69,219   

615,179   

154,101   

4,956   

38,380   

240,862   

85,788   

91,092   

$m

(8,732) 

(3,134) 

(5,438) 

(160) 

(16) 

(118) 

(2) 

— 

— 

— 

(53) 

(63) 

1,906,543   

(14,707)   

1,729,873   

(8,866) 

659,783   

236,170   

299,802   

123,811   

18,384   

900   

12,946   

4,538   

678,167   

(734)   

(40)   

(650)   

(44)   

(125)   

(1)   

(114)   

(10)   

(859)   

600,029   

223,314   

278,524   

98,191   

20,214   

804   

14,804   

4,606   

620,243   

2,584,710   

(15,566)   

2,350,116   

(329) 

(15) 

(307) 

(7) 

(48) 

(1) 

(44) 

(3) 

(377) 

(9,243) 

Fair value

$m

Memorandum 
allowance for 
ECL4

$m

Memorandum 
allowance for 
ECL4

$m

Fair value

$m

Debt instruments measured at fair value through other comprehensive income 
(‘FVOCI’)

399,717   

(141)   

355,664   

(166) 

1  The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial 

2 

asset, in which case the ECL is recognised as a provision.
Includes only those financial instruments that are subject to the impairment requirements of IFRS 9. ‘Prepayments, accrued income and other 
assets’, as presented within the consolidated balance sheet on page 280, includes both financial and non-financial assets.

3  Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
4  Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is 

recognised in ‘Change in expected credit losses and other credit impairment charges’ in the income statement.

The following table provides an overview of the Group’s credit risk 
by stage and industry, and the associated ECL coverage. The 
financial assets recorded in each stage have the following 
characteristics:

• Stage 3: There is objective evidence of impairment and the 
financial assets are therefore considered to be in default or 
otherwise credit impaired on which a lifetime ECL is 
recognised.

• Stage 1: These financial assets are unimpaired and without 

• POCI: Financial assets that are purchased or originated at a 

significant increase in credit risk on which a 12-month 
allowance for ECL is recognised.

deep discount are seen to reflect the incurred credit losses on 
which a lifetime ECL is recognised.

• Stage 2: A significant increase in credit risk has been 

experienced on these financial assets since initial recognition 
for which a lifetime ECL is recognised.

HSBC Holdings plc Annual Report and Accounts 2020

123

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
–  corporate and 
commercial

–  non-bank 
financial 
institutions

Loans and 
advances to 
banks at 
amortised cost

Other financial 
assets measured 
at amortised 
cost

Loan and other 
credit-related 
commitments

–  corporate and 
commercial

–  financial

Financial 
guarantees

–  personal

–  corporate and 
commercial

–  financial

At 31 Dec 
2020

Risk

Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at
31 December 2020
(Audited)

Gross carrying/nominal amount1

Allowance for ECL

ECL coverage %

Stage 1

Stage 2 Stage 3 POCI2

Total Stage 1 Stage 2 Stage 3 POCI2

Total Stage 1 Stage 2 Stage 3

POCI2 Total

$m

$m

$m

$m

$m

$m

$m

$m

$m

$m

%

%

%

%

%

Loans and 
advances to 
customers at 
amortised cost

  869,920   163,185   19,095    277   1,052,477    (1,974)    (4,965)    (7,439)    (112)   (14,490) 

–  personal

  430,134    25,064    5,611    —    460,809   

(827)    (2,402)    (1,502)    —    (4,731) 

 0.2 

 0.2 

 3.0 

 9.6 

 39.0 

 40.4 

 26.8 

 — 

 1.4 

 1.0 

  387,563   126,287   12,961    277    527,088    (1,101)    (2,444)    (5,837)    (112)    (9,494) 

 0.3 

 1.9 

 45.0 

 40.4 

 1.8 

  52,223    11,834   

523    —   

64,580   

(46)   

(119)   

(100)    —   

(265) 

 0.1 

 1.0 

 19.1 

 — 

 0.4 

  79,654    2,004   

—    —   

81,658   

(33)   

(9)   

—    —   

(42) 

 — 

 0.4 

 — 

 — 

 0.1 

  768,216    3,975   

177    40    772,408   

(80)   

(44)   

(42)   

(9)   

(175) 

 — 

 1.1 

 23.7 

 22.5 

 — 

  604,485    54,217    1,080   

1    659,783   

(290)   

(365)   

(78)   

(1)   

(734) 

–  personal

  234,337    1,681   

152    —    236,170   

(39)   

(1)   

—    —   

(40) 

  253,062    45,851   

888   

1    299,802   

(236)   

(338)   

(75)   

(1)   

(650) 

  117,086    6,685   

40    —    123,811   

(15)   

(26)   

(3)    —   

(44) 

  14,090    4,024   

269   

1   

18,384   

(37)   

(62)   

(26)    —   

(125) 

872   

26   

2    —   

900   

—   

(1)   

—    —   

(1) 

9,536    3,157   

252   

1   

12,946   

(35)   

(54)   

(25)    —   

(114) 

3,682   

841   

15    —   

4,538   

(2)   

(7)   

(1)    —   

(10) 

 — 

 — 

 0.1 

 — 

 0.3 

 — 

 0.4 

 0.1 

 0.7 

 0.1 

 0.7 

 0.4 

 1.5 

 3.8 

 1.7 

 0.8 

 7.2 

 100.0 

 0.1 

 — 

 — 

 — 

 8.4 

 100.0 

 0.2 

 7.5 

 — 

 — 

 9.7 

 — 

 9.9 

 6.7 

 — 

 — 

 — 

 — 

 0.7 

 0.1 

 0.9 

 0.2 

 2,336,365   227,405   20,621    319   2,584,710    (2,414)    (5,445)    (7,585)    (122)   (15,566) 

 0.1 

 2.4 

 36.8 

 38.2 

 0.6 

1  Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
2  Purchased or originated credit-impaired (‘POCI’).

Unless identified at an earlier stage, all financial assets are 
deemed to have suffered a significant increase in credit risk when 
they are 30 days past due (‘DPD’) and are transferred from stage 1 
to stage 2. The following disclosure presents the ageing of stage 2 
financial assets by those less than 30 days and greater than 30 

Stage 2 days past due analysis at 31 December 2020

(Audited)

DPD and therefore presents those financial assets classified as 
stage 2 due to ageing (30 DPD) and those identified at an earlier 
stage (less than 30 DPD).

Gross carrying amount

Allowance for ECL

ECL coverage %

Stage 2

$m

Up-to-
date

$m

1 to 29 
DPD1,2

30 and > 
DPD1,2

Stage 2

$m

$m

$m

Up-to-
date

$m

1 to 29 
DPD1,2

30 and > 
DPD1,2

Stage 2

$m

$m

%

Up-to-
date

%

1 to 29 
DPD1,2

30 and > 
DPD1,2

%

%

Loans and advances to 
customers at amortised 
cost

–  personal

–  corporate and 
commercial

–  non-bank financial 

institutions

Loans and advances to 
banks at amortised cost

Other financial assets 
measured at amortised 
cost

 163,185   159,367    2,052    1,766   

(4,965)   

(4,358)   

(275)   

  25,064    22,250    1,554    1,260   

(2,402)   

(1,895)   

(227)   

(332) 

(280) 

 3.0 

 9.6 

 126,287   125,301   

489   

497   

(2,444)   

(2,344)   

(48)   

(52) 

 1.9 

 2.7 

 8.5 

 1.9 

 13.4 

 14.6 

 18.8 

 22.2 

 9.8 

 10.5 

  11,834    11,816   

9   

9   

(119)   

(119)   

—   

  2,004    2,004   

—   

—   

(9)   

(9)   

—   

— 

— 

 1.0 

 1.0 

 0.4 

 0.4   

  3,975    3,963   

3   

9   

(44)   

(44)   

—   

— 

 1.1 

 1.1 

 — 

— 

 — 

 — 

 — 

 — 

1  Days past due (‘DPD’).
2  The days past due amounts presented above are on a contractual basis and include the benefit of any customer relief payment holidays granted.

124

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
–  corporate and 
commercial

–  non-bank 
financial 
institutions

Loans and 
advances to 
banks at 
amortised cost

Other financial 
assets measured 
at amortised 
cost

Loan and other 
credit-related 
commitments

–  corporate and 
commercial

–  financial

Financial 
guarantees

–  personal

–  corporate and 
commercial

Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at 
31 December 2019 (continued)
(Audited)

Gross carrying/nominal amount1

Allowance for ECL

ECL coverage %

Stage 1

Stage 2

Stage 3 POCI2

Total

Stage 1

Stage 2

Stage 3

$m

$m

$m

$m

$m

$m

$m

$m

POCI2

$m

Total

Stage 1

Stage 2

Stage 3

POCI2

Total

$m

%

%

%

%

%

Loans and 
advances to 
customers at 
amortised cost

951,583    80,182    13,378    332    1,045,475    (1,297)    (2,284)    (5,052)   

(99)    (8,732) 

–  personal

413,669    15,751    4,851    —   

434,271   

(583)    (1,336)    (1,215)   

—    (3,134) 

 0.1 

 0.1 

 2.8 

 8.5 

 37.8 

 25.0 

 29.8 

 — 

 0.8 

 0.7 

472,253    59,599    8,315    332   

540,499   

(672)   

(920)    (3,747)   

(99)    (5,438) 

 0.1 

 1.5 

 45.1 

 29.8 

 1.0 

65,661   

4,832   

212    —   

70,705   

(42)   

(28)   

(90)   

—   

(160) 

 0.1 

 0.6 

 42.5 

 — 

 0.2 

67,769   

1,450   

—    —   

69,219   

(14)   

(2)   

—   

—   

(16) 

 — 

 0.1 

 — 

 — 

 — 

613,200   

1,827   

151   

1   

615,179   

(38)   

(38)   

(42)   

—   

(118) 

 — 

 2.1 

 27.8 

 — 

 — 

–  personal

221,490   

1,630   

194    —   

223,314   

(13)   

(2)   

—   

577,631    21,618   

771   

9   

600,029   

(137)   

(133)   

(59)   

259,138    18,804   

573   

9   

278,524   

(118)   

(130)   

(59)   

97,003   

1,184   

4    —   

98,191   

(6)   

(1)   

—   

17,684   

2,340   

186   

4   

20,214   

(16)   

(22)   

(10)   

802   

1   

1    —   

804   

(1)   

—   

—   

–  financial

4,342   

263   

1    —   

4,606   

(1)   

(1)   

12,540   

2,076   

184   

4   

14,804   

(14)   

(21)   

(9)   

(1)   

At 31 Dec 2019

  2,227,867   107,417    14,486    346    2,350,116    (1,502)    (2,479)    (5,163)   

(99)    (9,243) 

1  Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
2  Purchased or originated credit-impaired (‘POCI’).

Stage 2 days past due analysis at 31 December 2019

(Audited)

—   

—   

(329) 

(15) 

—   

—   

(307) 

(7) 

—   

—   

—   

—   

(48) 

(1) 

(44) 

(3) 

 — 

 — 

 — 

 — 

 0.1 

 0.1 

 0.1 

 — 

 0.1 

 0.6 

 0.1 

 0.7 

 0.1 

 0.9 

 — 

 1.0 

 0.4 

 2.3 

 7.7 

 — 

 10.3 

 — 

 5.4 

 — 

 4.9 

 100.0 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 35.6 

 28.6 

 0.1 

 — 

 0.1 

 — 

 0.2 

 0.1 

 0.3 

 0.1 

 0.4 

Gross carrying amount

Allowance for ECL

ECL coverage %

Stage 2 Up-to-date

1 to 29 
DPD1

30 and > 
DPD1

Stage 2 Up-to-date

1 to 29 
DPD1

30 and > 
DPD1

 Stage 2 Up-to-date

1 to 29 
DPD1

30 and > 
DPD1

$m

$m

$m

$m

$m

$m

$m

$m

%

%

%

%

  80,182    76,035   

2,471   

1,676   

(2,284)   

(1,829)   

  15,751    12,658   

1,804   

1,289   

(1,336)   

(941)   

(208)   

(178)   

(247) 

(217) 

  59,599    58,557   

657   

385   

(920)   

(860)   

(30)   

(30) 

4,832   

4,820   

10   

2   

(28)   

(28)   

—   

1,450   

1,450   

—   

—   

(2)   

(2)   

—   

— 

— 

 2.8 

 8.5 

 1.5 

 0.6 

 0.1 

 2.4 

 7.4 

 1.5 

 0.6 

 0.1 

1,827   

1,783   

14   

30   

(38)   

(38)   

—   

— 

 2.1 

 2.1 

 8.4 

 9.9 

 4.6 

 — 

 — 

 — 

 14.7 

 16.8 

 7.8 

 — 

 — 

 — 

Loans and advances to 
customers at amortised 
cost

–  personal

–  corporate and 
commercial

–  non-bank financial 

institutions

Loans and advances to 
banks at amortised cost

Other financial assets 
measured at amortised 
cost

1  Days past due (‘DPD’).

HSBC Holdings plc Annual Report and Accounts 2020

125

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Other credit risk mitigants

While not disclosed as an offset in the following ‘Maximum 
exposure to credit risk’ table, other arrangements are in place that 
reduce our maximum exposure to credit risk. These include a 
charge over collateral on borrowers’ specific assets, such as 
residential properties, collateral held in the form of financial 
instruments that are not held on the balance sheet and short 
positions in securities. In addition, for financial assets held as part 
of linked insurance/investment contracts the risk is predominantly 
borne by the policyholder. See page 293 and Note 30 on the 
financial statements for further details of collateral in respect of 
certain loans and advances and derivatives.

Collateral available to mitigate credit risk is disclosed in the 
‘Collateral’ section on page 150.

Risk

Credit exposure

Maximum exposure to credit risk

(Audited)

This section provides information on balance sheet items and their 
offsets as well as loan and other credit-related commitments. 
Commentary on consolidated balance sheet movements in 2020 
is provided on page 83.

The offset on derivatives remains in line with the movements 
in maximum exposure amounts.

‘Maximum exposure to credit risk’ table 
The following table presents our maximum exposure before taking 
account of any collateral held or other credit enhancements (unless such 
enhancements meet accounting offsetting requirements). The table 
excludes financial instruments whose carrying amount best represents the 
net exposure to credit risk, and it excludes equity securities as they are not 
subject to credit risk. For the financial assets recognised on the balance 
sheet, the maximum exposure to credit risk equals their carrying amount 
and is net of the allowance for ECL. For financial guarantees and other 
guarantees granted, it is the maximum amount that we would have to pay 
if the guarantees were called upon. For loan commitments and other 
credit-related commitments, it is generally the full amount of the 
committed facilities.
The offset in the table relates to amounts where there is a legally 
enforceable right of offset in the event of counterparty default and where, 
as a result, there is a net exposure for credit risk purposes. However, as 
there is no intention to settle these balances on a net basis under normal 
circumstances, they do not qualify for net presentation for accounting 
purposes. No offset has been applied to off-balance sheet collateral. In the 
case of derivatives, the offset column also includes collateral received in 
cash and other financial assets.

Maximum exposure to credit risk

(Audited)

Maximum
exposure

$m

2020

Offset

$m

Net

$m

Maximum
exposure

$m

2019

Offset

$m

Net

$m

Loans and advances to customers held at amortised cost

  1,037,987   

(27,221)    1,010,766   

1,036,743 

(28,524)  

1,008,219 

–  personal

–  corporate and commercial

–  non-bank financial institutions

Loans and advances to banks at amortised cost

Other financial assets held at amortised cost

–  cash and balances at central banks

–  items in the course of collection from other banks

–  Hong Kong Government certificates of indebtedness

–  reverse repurchase agreements – non-trading

–  financial investments 

–  prepayments, accrued income and other assets

Derivatives 

456,078   

(4,287)   

451,791   

517,594   

(21,102)   

496,492   

64,315   

81,616   

(1,832)   

62,483   

—   

81,616   

774,116   

(14,668)   

759,448   

304,481   

4,094   

40,420   

—   

—   

—   

304,481   

4,094   

40,420   

431,137 

535,061 

70,545 
69,203   

616,648 
154,099   
4,956   
38,380   

230,628   

(14,668)   

215,960   

240,862 

88,639   

105,854   

—   

—   

88,639   

105,854   

85,735   
92,616   

307,726   

(293,240)   

14,486   

242,995 

Total on-balance sheet exposure to credit risk

  2,201,445   

(335,129)    1,866,316   

1,965,589 

Total off-balance sheet

–  financial and other guarantees

–  loan and other credit-related commitments

At 31 Dec 

940,185   

96,147   

844,038   

—   

—   

—   

940,185   

96,147   

844,038   

893,246   
95,967   
797,279   

  3,141,630   

(335,129)    2,806,501   

2,858,835 

(4,640)  

(21,745)  

(2,139)  
—   
(28,826)  
—   
—   
—   
(28,826)  
—   
—   
(232,908)  

(290,258)  
—   
—   
—   
(290,258)  

426,497 

513,316 

68,406 

69,203 

587,822 

154,099 

4,956 

38,380 

212,036 

85,735 

92,616 

10,087 

1,675,331 

893,246 

95,967 

797,279 

2,568,577 

Concentration of exposure

Credit deterioration of financial instruments 

(Audited)

A summary of our current policies and practices regarding the identification, 
treatment and measurement of stage 1, stage 2, stage 3 (credit impaired) and 
POCI financial instruments can be found in Note 1.2 on the financial 
statements.

We have a number of global businesses with a broad range of 
products. We operate in a number of geographical markets with 
the majority of our exposures in Asia and Europe.  
For an analysis of:
• financial investments, see Note 16 on the financial statements;
• trading assets, see Note 11 on the financial statements;
• derivatives, see page 158 and Note 15 on the financial 

statements; and

• loans and advances by industry sector and by the location 

of the principal operations of the lending subsidiary (or, in the 
case of the operations of The Hongkong and Shanghai Banking 
Corporation, HSBC Bank plc, HSBC Bank Middle East Limited 
and HSBC Bank USA, by the location of the lending branch), 
see page 144 for wholesale lending and page 158 for personal 
lending.

126

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measurement uncertainty and sensitivity analysis 
of ECL estimates

(Audited)

The recognition and measurement of ECL involves the use of 
significant judgement and estimation. We form multiple economic 
scenarios based on economic forecasts, apply these assumptions 
to credit risk models to estimate future credit losses, and 
probability-weight the results to determine an unbiased ECL 
estimate. Management judgemental adjustments are used to 
address late-breaking events, data and model limitations, model 
deficiencies and expert credit judgements.  

Methodology

Four economic scenarios have been used to capture the 
exceptional nature of the current economic environment and to 
articulate management’s view of the range of potential outcomes. 
Scenarios produced to calculate ECL are aligned to HSBC’s top 
and emerging risks. Three of these scenarios are drawn from 
consensus forecasts and distributional estimates. The Central 
scenario is deemed the ‘most likely’ scenario, and usually attracts 
the largest probability weighting, while the outer scenarios 
represent the tails of the distribution, which are less likely to 
occur. The Central scenario is created using the average of a panel 
of external forecasters, while consensus Upside and Downside 
scenarios are created with reference to distributions for select 
markets that capture forecasters’ views of the entire range of 
outcomes. Management has chosen to use an additional scenario 
to represent its view of severe downside risks. The use of an 
additional scenario is in line with HSBC’s forward economic 
guidance methodology and has been regularly used over the 
course of 2020. Management may include additional scenarios if it 
feels that the consensus scenarios do not adequately capture the 
top and emerging risks. Unlike the consensus scenarios, these 
additional scenarios are driven by narrative assumptions, could be 
country-specific and may result in shocks that drive economic 
activity permanently away from trend.

Description of economic scenarios

The economic assumptions presented in this section have been 
formed by HSBC with reference to external forecasts specifically 
for the purpose of calculating ECL.

The world economy experienced a deep economic shock in 2020. 
As Covid-19 spread globally, governments in many of our markets 
sought to limit the human impact by imposing significant 
restrictions on mobility, in turn driving the deep falls in activity that 
were observed in the first half of the year. Restrictions were eased 
as cases declined in response to the initial measures, which 
supported an initial rebound in economic activity by the third 
quarter of 2020. This increase in mobility unfortunately led to 
renewed transmission of the virus in several countries, placing 
healthcare systems under significant burden, leading governments 
to reimpose restrictions on mobility and causing economic activity 
to decline once more. 

Economic forecasts are subject to a high degree of uncertainty in 
the current environment. Limitations of forecasts and economic 
models require a greater reliance on management judgement in 
addressing both the error inherent in economic forecasts and in 
assessing associated ECL outcomes. The scenarios used to 
calculate ECL in the Annual Report and Accounts 2020 are 
described below.

The consensus Central scenario

HSBC’s Central scenario features an improvement in economic 
growth in 2021 as activity and employment gradually return to the 
levels experienced prior to the outbreak of Covid-19. 

Despite the sharp contraction in activity, government support in 
advanced economies played a crucial role in averting significant 
financial distress. At the same time, central banks in our key 
markets implemented a variety of measures, which included 
lowering their main policy interest rates, implementing emergency 
support measures for funding markets, and either restarting or 
increasing quantitative easing programmes in order to support 

economies and the financial system. Across our key markets, 
governments and central banks are expected to continue to work 
together to ensure that households and firms receive an 
appropriate level of financial support until restrictions on economic 
activity and mobility can be materially eased. Such support intends 
to ensure that labour and housing markets do not experience 
abrupt, negative corrections and also intends to limit the extent of 
long-term structural damage to economies.

Our Central scenario incorporates expectations that governments 
and public health authorities in our key markets will implement 
large vaccination programmes, first by inoculating critical groups 
and then increasing coverage to include the wider population. The 
deployment of mass vaccination programmes marks a significant 
step forward in combating the virus and will ease the burden on 
healthcare systems. We expect vaccination programmes across 
our key markets to contribute positively to recovery prospects and 
our Central scenario assumes a steady increase in the proportion 
of the population inoculated against Covid-19 over the course of 
2021.

Differences across markets in the speed and scale of economic 
recovery in the Central scenario reflect timing differences in the 
progression of the Covid-19 outbreak, national level differences in 
restrictions imposed, the coverage achieved by vaccination 
programmes and the scale of support measures.

The key features of our Central scenario are:

• Economic activity across our top eight markets will recover in 

2021, supported by a successful roll-out of vaccination 
programmes. We expect vaccination programmes, coupled 
with effective non-pharmacological measures to contain the 
virus including ‘track and trace’ systems and restrictions to 
mobility, to lead to a significant decline in infections across our 
key markets by the end of 2021.

• Where government support programmes are available, they will 
continue to provide support to labour markets and households 
in 2021. We expect a gradual reversion of the unemployment 
rate to pre-crisis levels over the course of the projection period 
as a result of economic recovery and due to the orderly 
withdrawal of government support.

• Inflation will converge towards central bank targets in our key 

markets.

• In advanced economies, government support in 2020 led to 
large deficits and a significant increase in public debt. This 
support is expected to continue as needed and deficits are 
expected to reduce gradually over the projection period. 
Sovereign debt levels will remain high and our Central scenario 
does not assume fiscal austerity. 

• Policy interest rates in key markets will remain at current levels 
for an extended period and will increase very modestly towards 
the end of our projection period. Central banks will continue to 
provide assistance through their asset purchase programmes 
as needed.

• The West Texas Intermediate oil price is forecast to average 

$43 per barrel over the projection period.

HSBC Holdings plc Annual Report and Accounts 2020

127

Risk reviewRisk

The following table describes key macroeconomic variables and the probabilities assigned in the consensus Central scenario.

UK

%

US

Hong Kong

Mainland China

Canada

France

%

%

%

%

UAE

%

Mexico

%

 (6.1) 

 (9.7) 

 (6.3) 

 (9.7) 

Central scenario 2021–2025

GDP growth rate

2020: Annual average growth rate

2021: Annual average growth rate

2022: Annual average growth rate

2023: Annual average growth rate

5-year average

Unemployment rate

2020: Annual average rate

2021: Annual average rate

2022: Annual average rate

2023: Annual average rate

5-year average

House price growth

2020: Annual average growth rate

2021: Annual average growth rate

2022: Annual average growth rate

2023: Annual average growth rate

5-year average 

Short-term interest rate

2020: Annual average rate

2021: Annual average rate

2022: Annual average rate

2023: Annual average rate

5-year average

Probability

 (11.0) 

 (4.1) 

 (6.4) 

 4.9 

 3.1 

 2.4 

 2.8 

 4.6 

 6.9 

 5.8 

 5.4 

 5.6 

 2.3 

 (2.1) 

 0.9 

 3.0 

 1.9 

 0.3 

 0.1 

 0.1 

 0.1 

 0.2 

 40 

 3.8 

 2.9 

 2.4 

 2.7 

 8.3 

 6.7 

 5.8 

 4.9 

 5.3 

 6.0 

 4.0 

 4.3 

 4.0 

 4.0 

 0.7 

 0.3 

 0.3 

 0.4 

 0.5 

 65 

 4.3 

 2.9 

 2.6 

 2.9 

 5.8 

 5.0 

 3.9 

 3.8 

 4.0 

 (0.8) 

 (2.2) 

 2.4 

 5.2 

 2.3 

 1.2 

 1.0 

 1.1 

 1.2 

 1.3 

 70 

The graphs comparing the respective Central scenarios in the 
fourth quarters of 2019 and 2020 reveal the extent of economic 
dislocation that occurred in 2020 and the impact this has had on 
central projections made at the end of 2019.

The emergent nature of the Covid-19 outbreak at the end of 2019 
meant that, consistent with other banks, HSBC’s Central scenario 
did not, on a forward-looking basis, consider the impact of the 
virus. Our Central scenario at the 2019 year-end projected 
moderate growth over a five-year horizon, with strong prospects 
for employment and a gradual increase in policy interest rates by 
central banks in the major economies of Europe and North 
America. The onset of the virus led to a fundamental reassessment 
of our Central forecast and the distribution of risks over the course 
of 2020. Our Central scenario at the end of 2020, as described 
above, is based on assumptions that are considerably different.

GDP growth: Comparison

Hong Kong

8

6

4

2

0

‐2

‐4

‐6

‐8

‐10

2019

%

 2.0 

 7.8 

 5.3 

 5.2 

 5.6 

 3.9 

 4.1 

 4.2 

 4.1 

 4.0 

 2.3 

 4.7 

 5.7 

 5.0 

 4.7 

 3.2 

 2.9 

 3.0 

 3.1 

 3.1 

 80 

 5.0 

 3.1 

 2.4 

 2.9 

 9.6 

 7.9 

 6.8 

 6.5 

 6.8 

 5.7 

 2.1 

 2.0 

 3.1 

 2.7 

 0.8 

 0.5 

 0.6 

 0.8 

 0.8 

 70 

 5.9 

 2.9 

 2.2 

 2.9 

 7.9 

 10.0 

 9.1 

 8.8 

 9.0 

 4.4 

 (0.5) 

 4.1 

 4.1 

 2.8 

 (0.4) 

 (0.5) 

 (0.5) 

 (0.5) 

 (0.5) 

 40 

 3.0 

 3.6 

 3.9 

 3.4 

 3.1 

 2.7 

 2.6 

 2.7 

 2.7 

 (11.6) 

 (9.8) 

 (1.3) 

 2.6 

 — 

 1.0 

 0.8 

 0.8 

 0.9 

 1.0 

 65 

4Q19 Central scenario 5Y Average: 1.9%
4Q20 Central scenario 5Y Average: 2.9%

2021

2023

2025

4Q19 Central

4Q20 Central

UK

20

15

10

5

0

‐5

‐10

‐15

‐20

‐25

100

90

80

70

60

50

40

30

20

10

0

4Q19 Central scenario 5Y Average: 1.6%
4Q20 Central scenario 5Y Average: 2.8%

2019

2021

2023

2025

4Q19 Central

4Q20 Central

Note: Real GDP shown as year-on-year percentage change.

Note: Real GDP shown as year-on-year percentage change.

US

10

8

6

4

2

0

‐2

‐4

‐6

‐8

‐10

2019

4Q19 Central scenario 5Y Average: 1.9%
4Q20 Central scenario 5Y Average: 2.7%

2021

2023

2025

4Q19 Central

4Q20 Central

128

HSBC Holdings plc Annual Report and Accounts 2020

Note: Real GDP shown as year-on-year percentage change.

 3.7 

 2.5 

 2.4 

 2.6 

 5.4 

 5.3 

 4.7 

 4.5 

 4.6 

 5.5 

 3.4 

 5.0 

 4.6 

 4.2 

 5.7 

 4.5 

 4.7 

 5.2 

 5.2 

 65 

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

Mainland China

18

14

10

6

2

‐2

‐6

‐10

2019

4Q19 Central scenario 5Y Average: 5.6%
4Q20 Central scenario 5Y Average: 5.6%

2021

2023

2025

4Q19 Central

4Q20 Central

The consensus Upside scenario

Compared with the consensus Central scenario, the consensus 
Upside scenario features a faster recovery in economic activity 
during the first two years, before converging to long-run trends.

The scenario is consistent with a number of key upside risk 
themes. These include the orderly and rapid global abatement of 
Covid-19 via successful containment and prompt deployment of a 
vaccine; de-escalation of tensions between the US and China; de-
escalation of political tensions in Hong Kong; continued support 
from fiscal and monetary policy and smooth relations between the 
UK and the EU, which enables the two parties to swiftly reach a 
comprehensive agreement on trade and services. 

The following table describes key macroeconomic variables and 
the probabilities assigned in the consensus Upside scenario.

100

90

80

70

60

50

40

30

20

10

0

Note: Real GDP shown as year-on-year percentage change.

Consensus Upside scenario best outcome

UK

%

US

%

Hong
Kong

%

Mainland
China

%

Canada

France

%

%

UAE

%

Mexico

%

GDP growth rate

Unemployment rate

House price growth

19.9 (2Q21) 11.8 (2Q21) 13.8 (4Q21) 20.5 (1Q21) 15.8 (2Q21) 19.5 (2Q21) 13.8 (4Q21) 16.8 (2Q21)

3.7 (4Q22)

3.9 (4Q22)

3.0 (3Q22)

3.9 (4Q21)

5.3 (3Q22)

7.9 (4Q22)

2.2 (4Q21)

3.6 (3Q22)

6.9 (4Q22)

6.4 (1Q22)

4.9 (1Q22) 12.2 (1Q22)

5.2 (1Q21)

5.7 (2Q22) 18.5 (1Q22)

8.2 (3Q22)

Short-term interest rate

0.1 (2Q22)

0.4 (1Q21)

1.1 (1Q21)

3.0 (1Q21)

0.6 (1Q21)

(0.4) (1Q21)

0.9 (1Q21)

5.0 (1Q21)

Probability consensus Upside

 5 

 5 

 5 

 10 

 10 

 5 

 5 

 5 

Note: Extreme point in the consensus Upside is ‘best outcome’ in the scenario, for example the highest GDP growth and the lowest unemployment 
rate, in the first two years of the scenario.

• Continued long-term differences between the US and China,
which could affect sentiment and restrict global economic
activity.

• The Covid-19 outbreak reduced the incidence of protests in

Hong Kong. Despite the passage of the national security law in
2020, such unrest has the potential to return as the virus abates
and restrictions to mobility ease.

• The Trade and Cooperation Agreement between the UK and EU
averted a disorderly UK departure from the EU, but the risk of
future disagreements remains, which may hinder the ability to
reach a more comprehensive agreement on trade and services.

The consensus Downside scenario

In the consensus Downside scenario, economic recovery is 
considerably weaker compared with the Central scenario. GDP 
growth remains weak, unemployment rates stay elevated and 
asset and commodity prices fall before gradually recovering 
towards their long-run trends. 

The scenario is consistent with the key downside risks articulated 
above. Further outbreaks of Covid-19, coupled with delays in 
vaccination programmes, lead to longer-lasting restrictions on 
economic activity in this scenario. Other global risks also increase 
and drive increased risk-aversion in asset markets. 

Downside scenarios

The year 2021 is expected to be a period of economic recovery, 
but the progression and management of the pandemic presents a 
key risk to global growth. A new and more contagious strain of the 
virus increased the transmission rate in the UK and resulted in 
stringent restrictions to mobility towards the end of 2020. This 
viral strain observed in the UK, together with aggressive strains 
observed in other countries including South Africa and Brazil, 
introduce the risk that transmission may increase significantly 
within the national borders of a number of countries in 2021 and 
also raise concerns around the efficacy of vaccines as the virus 
mutates. Some countries may keep significant restrictions to 
mobility in place for an extended period of time and at least until 
critical segments of the population can be inoculated. Further risks 
to international travel also arise.

A number of vaccines have been developed and approved for use 
at a rapid pace and plans to inoculate significant proportions of 
national populations in 2021 across many of our key markets are a 
clear positive for economic recovery. While we expect vaccination 
programmes to be successful, governments and healthcare 
authorities face country-specific challenges that could affect the 
speed and spread of vaccinations. These challenges include the 
logistics of inoculating a significant proportion of national 
populations within a limited timeframe and the public acceptance 
of vaccines. On a global level, supply challenges could affect the 
pace of roll-out and the efficacy of vaccines is yet to be 
determined.

Government support programmes in advanced economies in 2020 
were supported by accommodative actions taken by central 
banks. These measures by governments and central banks have 
provided households and firms with significant support. An 
inability or unwillingness to continue with such support or the 
untimely withdrawal of support present a downside risk to growth.

While Covid-19 and related risks dominate the economic outlook, 
geopolitical risks also present a threat. These risks include: 

HSBC Holdings plc Annual Report and Accounts 2020

129

Risk reviewRisk

The following table describes key macroeconomic variables and the probabilities assigned in the consensus Downside scenario.

Consensus Downside scenario worst outcome

UK

%

US

%

Hong
Kong

%

Mainland
China

%

Canada

France

%

%

UAE

%

Mexico

%

GDP growth rate

Unemployment rate

House price growth

(7.6) (1Q21)

(3.4) (1Q21)

(2.1) (3Q21)

(1.3) (4Q21)

(3.6) (1Q21)

(3.0) (1Q21)

(7.3) (1Q21)

(8.0) (1Q21)

9.4 (4Q21)

8.2 (2Q21)

6.4 (1Q21)

4.3 (3Q22)

9.2 (1Q21)

11.2 (1Q21)

3.0 (1Q21)

6.2 (3Q21)

(10.8) (4Q21)

0.1 (3Q21)

(6.8) (3Q21)

0.3 (4Q21)

(1.3) (1Q22)

(3.3) (2Q21)

(19.2) (2Q21)

1.0 (4Q21)

Short-term interest rate

0.1 (1Q21)

0.3 (1Q22)

1.1 (4Q22)

2.8 (1Q21)

0.5 (1Q21)

(0.5) (1Q21)

0.8 (1Q22)

3.8 (1Q21)

Probability consensus Downside

 40 

 25 

 20 

 8 

 10 

 40 

 25 

 25 

Note: Extreme point in the consensus Downside is 'worst outcome' in the scenario, for example lowest GDP growth and the highest unemployment 
rate, in the first two years of the scenario. 

Additional Downside scenario

An additional Downside scenario that features a global recession 
has been created to reflect management’s view of severe risks. In 
this scenario, infections rise in 2021 and setbacks to vaccine 
programmes imply that successful roll-out of vaccines only occurs 
towards the end of 2021 and it takes until the end of 2022 for the 

pandemic to come to an end. The scenario also assumes 
governments and central banks are unable to significantly increase 
fiscal and monetary programmes, which results in abrupt 
corrections in labour and asset markets. 

The following table describes key macroeconomic variables and 
the probabilities assigned in the additional Downside scenario.

Additional Downside scenario worst outcome

UK

%

US

%

Hong
Kong

%

Mainland
China

%

Canada

France

%

%

UAE

%

Mexico

%

GDP growth rate

Unemployment rate

House price growth

(10.1) (1Q21)

(4.2) (1Q21)

(8.3) (4Q21)

(9.5) (4Q21)

(5.0) (1Q21)

(6.7) (1Q21)

(12.2) (1Q21)

(10.9) (1Q21)

9.8 (3Q21)

11.4 (4Q22)

6.7 (3Q21)

6.1 (3Q22)

11.3 (1Q21)

12.3 (1Q21)

3.9 (1Q21)

6.9 (4Q21)

(14.5) (4Q21)

(9.3) (3Q21)

(21.0) (4Q21)

(19.4) (4Q21)

(10.4) (4Q21)

(7.1) (3Q21)

(22.9) (2Q21)

(2.7) (4Q21)

Short-term interest rate

0.8 (2Q21)

1.1 (1Q21)

1.3 (1Q21)

4.0 (2Q21)

0.4 (1Q21)

0.2 (2Q21)

0.5 (3Q21)

6.7 (2Q21)

Probability additional  Downside

 15 

 5 

 5 

 2 

 10 

 15 

 5 

 5 

Note: Extreme point in the additional Downside is 'worst outcome' in the scenario, for example lowest GDP growth and the highest unemployment 
rate, in the first two years of the scenario. 

Uncertainty related to the continued impact of the pandemic and 
the ability of governments to control its spread via restrictions and 
vaccinations over the course of 2021 also play a prominent role in 
assigning scenario weights to our other markets. In addition, for 
the US, Canada and Mexico, connectivity across the three North 
American economies has been considered. In the UAE, the impact 
of the oil price on the economy and the ability of non-oil sectors to 
contribute to economic recovery have influenced the view of 
uncertainty. The Central scenario has been assigned between 65% 
and 70% weight for these four markets and, with risks perceived 
as being weighted to the downside, the two Downside scenarios 
have been given weights between 20% and 30%.

The following graphs show the historical and forecasted GDP 
growth rate for the various economic scenarios in our four largest 
markets.

US

15.0

10.0

5.0

0.0

‐5.0

‐10.0

2016

2017

2018

2019

Central

2020

Upside

2021

2022

2023

2024

2025

Downside

Additional Downside

100

90

80

70

60

50

40

30

20

10

0

In considering economic uncertainty and assigning probabilities to 
scenarios, management has considered both global and country-
specific factors. This has led management to assigning scenario 
probabilities that are tailored to its view of uncertainty in individual 
markets.

To inform its view, management has considered trends in the 
progression of the virus in individual countries, the expected reach 
and efficacy of vaccine roll-outs over the course of 2021, the size 
and effectiveness of future government support schemes and the 
connectivity with other countries. Management has also been 
guided by the actual response to the Covid-19 outbreak and by the 
economic experience across countries in 2020. China’s visible 
success at containing the virus and its repeated rapid response to 
localised outbreaks, coupled with government support 
programmes and clear signs of economic recovery, have led 
management to conclude that the economic outlook for mainland 
China is the least volatile out of all our top markets. The Central 
scenario for mainland China has an 80% probability while a total 
of 10% has been assigned to the two Downside scenarios. In 
Hong Kong, the combination of recurrent outbreaks, a lack of 
details around the roll-out of a vaccination programme and the 
other risks outlined above, have led management to assign 25% 
weight to the two Downside scenarios.

The UK and France face the greatest economic uncertainty in our 
key markets. In the UK, the discovery of a more infectious strain of 
the virus and subsequent national restrictions on activity imposed 
before the end of 2020 have resulted in considerable uncertainty in 
the economic outlook. In France, the increases in cases and 
hospitalisations towards the end of 2020, the difficulties 
experienced with the launch of a national vaccination programme 
and the wide range of measures taken to restrict activity similarly 
affect the economic outlook. Given these considerations, the 
Central and the consensus Downside scenario for the UK and 
France have each been assigned 40% probability. This reflects 
management’s view that, as a result of elevated uncertainty in 
these two markets, the Central scenario cannot be viewed as the 
single most likely outcome. The additional Downside scenario has 
been assigned 15% probability to reflect the view that the balance 
of risks is weighted to the downside.

130

HSBC Holdings plc Annual Report and Accounts 2020

UK

25.0

20.0

15.0

10.0

5.0

0.0

‐5.0

‐10.0

‐15.0

‐20.0

‐25.0

2016

2017

2018

2019

Central

2020

Upside

2021

2022

2023

2024

2025

Downside

Additional Downside

Hong Kong

15.0

10.0

5.0

0.0

‐5.0

‐10.0

‐15.0

2016

2017

2018

2019

Central

2020

Upside

2021

2022

2023

2024

2025

Downside

Additional Downside

Mainland China

25.0

20.0

15.0

10.0

5.0

0.0

‐5.0

‐10.0

‐15.0

2016

2017

2018

2019

Central

2020

Upside

2021

2022

2023

2024

2025

Downside

Additional Downside

Critical accounting estimates and judgements

The calculation of ECL under IFRS 9 involves significant 
judgements, assumptions and estimates. The level of estimation 
uncertainty and judgement has increased during 2020 as a result 
of the economic effects of the Covid-19 outbreak, including 
significant judgements relating to: 

• the selection and weighting of economic scenarios, given

rapidly changing economic conditions in an unprecedented
manner, uncertainty as to the effect of government and central
bank support measures designed to alleviate adverse economic
impacts, and a wider distribution of economic forecasts than
before the pandemic. The key judgements are the length of
time over which the economic effects of the pandemic will
occur, the speed and shape of recovery. The main factors
include the effectiveness of pandemic containment measures,
the pace of roll-out and effectiveness of vaccines, and the
emergence of new variants of the virus, plus a range of
geopolitical uncertainties, which together represent a very high
degree of estimation uncertainty, particularly in assessing
Downside scenarios;

• estimating the economic effects of those scenarios on ECL,
where there is no observable historical trend that can be
reflected in the models that will accurately represent the effects
of the economic changes of the severity and speed brought
about by the Covid-19 outbreak. Modelled assumptions and

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

linkages between economic factors and credit losses may 
underestimate or overestimate ECL in these conditions, and 
there is significant uncertainty in the estimation of parameters 
such as collateral values and loss severity; and

• the identification of customers experiencing significant

increases in credit risk and credit impairment, particularly
where those customers have accepted payment deferrals and
other reliefs designed to address short-term liquidity issues
given muted default experience to date. The use of
segmentation techniques for indicators of significant increases
in credit risk involves significant estimation uncertainty.

How economic scenarios are reflected in ECL 
calculations

Models are used to reflect economic scenarios on ECL estimates. 
As described above, modelled assumptions and linkages based on 
historical information could not alone produce relevant information 
under the unprecedented conditions experienced in 2020, and it 
was necessary to place greater emphasis on judgemental 
adjustments to modelled outcomes than in previous years.   

We have developed globally consistent methodologies for the 
application of forward economic guidance into the calculation of 
ECL for wholesale and retail credit risk. These standard 
approaches are described below, followed by the management 
judgemental adjustments made, including those to reflect the 
circumstances experienced in 2020.   

For wholesale, a global methodology is used for the estimation of 
the term structure of probability of default (‘PD’) and loss given 
default (‘LGD’). For PDs, we consider the correlation of forward 
economic guidance to default rates for a particular industry in a 
country. For LGD calculations, we consider the correlation of 
forward economic guidance to collateral values and realisation 
rates for a particular country and industry. PDs and LGDs are 
estimated for the entire term structure of each instrument. 

For impaired loans, LGD estimates take into account independent 
recovery valuations provided by external consultants where 
available or internal forecasts corresponding to anticipated 
economic conditions and individual company conditions. In 
estimating the ECL on impaired loans that are individually 
considered not to be significant, we incorporate forward economic 
guidance proportionate to the probability-weighted outcome and 
the Central scenario outcome for non-stage 3 populations.

For retail, the impact of economic scenarios on PD is modelled at 
a portfolio level. Historical relationships between observed default 
rates and macroeconomic variables are integrated into IFRS 9 ECL 
estimates by using economic response models. The impact of 
these scenarios on PD is modelled over a period equal to the 
remaining maturity of the underlying asset or assets. The impact 
on LGD is modelled for mortgage portfolios by forecasting future 
loan-to-value (‘LTV’) profiles for the remaining maturity of the 
asset by using national level forecasts of the house price index and 
applying the corresponding LGD expectation.

These models are based largely on historical observations and 
correlations with default rates. Management judgemental 
adjustments are described below.

Management judgemental adjustments

In the context of IFRS 9, management judgemental adjustments 
are short-term increases or decreases to the ECL at either a 
customer or portfolio level to account for late-breaking events, 
model and data limitations and deficiencies, and expert credit 
judgement applied following management review and challenge. 
In the Annual Report and Accounts 2019, these were ‘Post-model 
adjustments’.

The most severe projections at 31 December 2020 of 
macroeconomic variables are outside the historical observations 
on which IFRS 9 models have been built and calibrated to operate. 
Moreover, the complexities of country-specific governmental 
support programmes, the impacts on customer behaviours and 
the unpredictable pathways of the pandemic have never been 
modelled. Consequently, HSBC’s IFRS 9 models, in some cases, 
generate outputs that appear overly sensitive when compared 

HSBC Holdings plc Annual Report and Accounts 2020

131

Risk reviewRisk

with other economic and credit metrics. Governmental support 
programmes and customer payment reliefs have dislocated the 
correlation between economic conditions and defaults on which 
models are based. Management judgemental adjustments are 
required to help ensure that an appropriate amount of ECL 
impairment is recognised.

We have internal governance in place to regularly monitor 
management judgemental adjustments and, where possible, to 
reduce the reliance on these through model recalibration or 
redevelopment, as appropriate. During 2020 the composition of 
modelled ECL and management judgemental adjustments 
changed significantly, reflecting the path of the pandemic, 
containment efforts and government support measures, and this is 
expected to continue to be the case until economic conditions 
improve. Wider-ranging model changes will take time to develop 
and need observable loss data on which models can be developed. 
Models will be revisited over time once the longer-term impacts of 
Covid-19 are observed. Therefore, we anticipate significant 
management judgemental adjustments for the foreseeable future.

Management judgemental adjustments made in estimating the 
reported ECL at 31 December 2020 are set out in the following 
table. The table includes adjustments in relation to data and model 
limitations resulting from the pandemic, and as a result of the 
regular process of model development and implementation. It 
shows the adjustments applicable to the scenario-weighted ECL 
numbers. Adjustments in relation to Downside scenarios are more 
significant, as results are subject to greater uncertainty. 

Management judgemental adjustments to ECL1

Low-risk counterparties (banks, 
sovereigns and government entities)

Corporate lending adjustments

Retail lending PD adjustments

Retail model default suppression 
adjustment

Other retail lending adjustments

Total

Retail Wholesale

$bn

$bn

—   

—   

(0.8) 

1.9   

0.4   

1.5   

(0.7)   
0.5   

—   
—   
(0.2)   

Total

$bn

(0.7) 

0.5 

(0.8) 

1.9 

0.4 

1.3 

1  Management judgemental adjustments presented in the table reflect 

increases or (decreases) to ECL, respectively.

Management judgemental adjustments at 31 December 2019 
were an increase to ECL of $75m for the wholesale portfolio and 
$131m for the retail portfolio. This excludes adjustments for 
alternative scenarios.

During 2020, management judgemental adjustments reflected the 
volatile economic conditions associated with the Covid-19 
pandemic. The composition of modelled ECL and management 
judgemental adjustments changed significantly over 2020 as 
certain economic measures, such as GDP growth rate, passed the 
expected low point in a number of key markets and returned 
towards those reflected in modelled relationships, subject to 
continued uncertainty in the recovery paths of different 
economies.  

At 31 December 2020, wholesale management judgemental 
adjustments were an ECL reduction of $0.2bn (31 December 2019: 
$0.1bn increase). These wholesale adjustments were lower than 
those made in the second and third quarters of 2020 following an 
improvement in macroeconomic assumptions, with models 
operating closer to their calibration range and following 
recalibration for stressed conditions. 

The adjustments relating to low-credit-risk exposures are mainly to 
highly rated banks, sovereigns and US government-sponsored 
entities, where modelled credit factors did not fully reflect the 
underlying fundamentals of these entities or the effect of 
government support and economic programmes in the Covid-19 
environment. 

Adjustments to corporate exposures principally reflect the 
outcome of management judgements for high-risk and vulnerable 
sectors in some of our key markets, supported by credit experts’ 
input, quantitative analyses and benchmarks. Considerations 

132

HSBC Holdings plc Annual Report and Accounts 2020

include potential default suppression in some sectors due to 
government intervention and late-breaking idiosyncratic 
developments.

In the fourth quarter of 2020, retail management judgemental 
adjustments led to an ECL increase of $1.5bn, primarily from 
additional ECL of $1.9bn to reflect adjustments to the timing of 
default, which has been delayed by government support and 
customer relief measures. This was partly offset by adjustments to 
retail lending PD outputs, to reduce ECL of $0.8bn for unintuitive 
model responses, primarily where economic forecasts were 
beyond the bounds of the model development period. Other retail 
lending adjustments of $0.4bn led to an increase in ECL from 
areas such as customer relief and data limitations. 

The retail model default suppression adjustment was applied as 
defaults remain temporarily suppressed due to government 
support and customer relief programmes, which have supported 
stabilised portfolio performance. Retail models are reliant on the 
assumption that as macroeconomic conditions deteriorate, 
defaults will crystallise. This adjustment aligns the increase in 
default due to changes in economic conditions to the period of 
time when defaults are expected to be observed. The retail model 
default suppression adjustment will be monitored and updated 
prospectively to ensure appropriate alignment with expected 
performance taking into consideration the levels and timing of 
government support and customer relief programmes.

Retail lending PD adjustments are primarily related to an 
adjustment made in relation to the UK. The downside 
unemployment forecasts were outside the historical bounds on 
which the model was developed resulting in unintuitive levels of 
PD. This adjustment reduced the sensitivity of PD to better align 
with the historical correlation between changes in levels of 
unemployment and defaults.

Economic scenarios sensitivity analysis of ECL 
estimates

Management considered the sensitivity of the ECL outcome 
against the economic forecasts as part of the ECL governance 
process by recalculating the ECL under each scenario described 
above for selected portfolios, applying a 100% weighting to each 
scenario in turn. The weighting is reflected in both the 
determination of a significant increase in credit risk and the 
measurement of the resulting ECL.

The ECL calculated for the Upside and Downside scenarios should 
not be taken to represent the upper and lower limits of possible 
ECL outcomes. The impact of defaults that might occur in the 
future under different economic scenarios is captured by 
recalculating ECL for loans in stages 1 and 2 at the balance sheet 
date. The population of stage 3 loans (in default) at the balance 
sheet date is unchanged in these sensitivity calculations. Stage 3 
ECL would only be sensitive to changes in forecasts of future 
economic conditions if the LGD of a particular portfolio was 
sensitive to these changes.

There is a particularly high degree of estimation uncertainty in 
numbers representing tail risk scenarios when assigned a 100% 
weighting. 

For wholesale credit risk exposures, the sensitivity analysis 
excludes ECL and financial instruments related to defaulted 
obligors because the measurement of ECL is relatively more 
sensitive to credit factors specific to the obligor than future 
economic scenarios. Therefore, it is impracticable to separate the 
effect of macroeconomic factors in individual assessments. For 
retail credit risk exposures, the sensitivity analysis includes ECL for 
loans and advances to customers related to defaulted obligors. 
This is because the retail ECL for secured mortgage portfolios 
including loans in all stages is sensitive to macroeconomic 
variables.

Wholesale and retail sensitivity

The wholesale and retail sensitivity analysis is stated inclusive of 
management judgemental adjustments, as appropriate to each 
scenario. The results tables exclude portfolios held by the 
insurance business and small portfolios, and as such cannot be 

 
 
 
 
 
 
 
directly compared to personal and wholesale lending presented in 
other credit risk tables. Additionally in both the wholesale and 
retail analysis, the comparative period results for additional/ 

alternative Downside scenarios are also not directly comparable 
with the current period, because they reflect different risk profiles 
relative to the consensus scenarios for the period end.

Wholesale analysis

IFRS 9 ECL sensitivity to future economic conditions

ECL of loans and advances to 
customers at 31 December 20201

UK

US

Hong Kong

Mainland China

Canada

Mexico

UAE

France

Gross carrying 
amount2

Reported ECL

Central scenario 
ECL

Upside scenario 
ECL

Downside 
scenario ECL

$m

430,555   

201,263   

452,983   

118,163   

85,720   

25,920   

44,777   

164,899   

$m

2,077   

369   

474   

116   

183   

246   

250   

117   

$m

1,514   

314   

388   

93   

140   

222   

241   

109   

$m

1,026   

219   

211   

28   

82   

177   

190   

97   

$m

2,271   

472   

672   

252   

253   

285   

330   

131   

Additional 
Downside 
scenario ECL

$m

3,869 

723 

1,363 

1,158 

528 

437 

536 

238 

IFRS 9 ECL sensitivity to future economic conditions3

ECL of loans and advances to customers 
at 31 December 20191

UK

US

Hong Kong

Mainland China

Canada

Mexico

UAE

France

Gross carrying
 amount2

Reported ECL

Central scenario 
ECL

Upside scenario 
ECL

Downside scenario 
ECL

Alternative 
scenarios ECL4

$m

346,035

203,610

418,102

104,004

74,620

32,632

42,304

124,618

$m

725

148

328

124

80

69

97

55

$m

536

149

243

118

79

68

97

53

$m

480

132

241

95

63

48

89

50

$m

1,050–2,100 

550-700 

150

$m

635

161

244

106

108

99

108

79

1  ECL sensitivity includes off-balance sheet financial instruments that are subject to significant measurement uncertainty.
2 

Includes low credit-risk financial instruments such as debt instruments at FVOCI, which have high carrying amounts but low ECL under all the 
above scenarios. 

3  ECL sensitivities for 2019 exclude portfolios utilising less complex modelling approaches and management judgemental adjustments only included 

in reported ECL.

4  The UK alternative Downside (‘AD’) scenario 1 had an ECL impact of $1bn with AD2 and AD3 scenarios with ECL impacts of $1.9bn and $2.1bn 

respectively. The Hong Kong AD1 and AD2 scenarios had an impact of $0.55bn and $0.7bn respectively.

At 31 December 2020, the most significant level of ECL sensitivity 
was observed in the UK, Hong Kong and mainland China. This 
higher sensitivity is largely driven by significant exposure in these 
regions and more severe impacts of the Downside scenarios 
relative to the Central and probability-weighted scenarios. For 
mainland China, the additional Downside scenario weighting of 

2% reflects a scenario that is considered highly unlikely and is 
significantly more adverse compared with the Central scenario, 
resulting in a higher ECL estimate relative to the reported and 
Central scenarios.

HSBC Holdings plc Annual Report and Accounts 2020

133

Risk review 
 
 
 
 
 
 
 
Risk

Retail analysis

IFRS 9 ECL sensitivity to future economic conditions1

ECL of loans and advances to 
customers at 31 December 20202

$m

$m

$m

$m

$m

$m

Gross carrying 
amount

Reported ECL

Central scenario 
ECL

Upside scenario 
ECL

Downside scenario 
ECL

Additional 
Downside scenario

UK

Mortgages

Credit cards

Other

Mexico

Mortgages

Credit cards

Other

Hong Kong

Mortgages

Credit cards

Other

UAE

Mortgages

Credit cards

Other

France

Mortgages

Other

US

Mortgages

Credit cards

Canada

Mortgages

Credit cards

Other

146,478   

7,869   

9,164   

3,896   

1,113   

2,549   

89,943   

7,422   

6,020   

1,889   

426   

683   

24,565   

1,725   

15,399   

570   

22,454   

260   

1,775   

197   

857   

897   

111   

260   

436   

—   

266   

112   

66   

92   

38   

68   

88   

41   

86   

31   

9   

22   

182   

774   

795   

101   

255   

428   

—   

259   

105   

63   

81   

37   

68   

87   

39   

84   

30   

9   

21   

172   

589   

471   

79   

243   

411   

—   

247   

102   

53   

62   

33   

68   

85   

38   

81   

29   

8   

20   

205   

904   

1,022   

221 

1,084 

1,165 

136   

269   

451   

—   

277   

115   

73   

107   

41   

69   

88   

41   

88   

31   

9   

24   

167 

290 

491 

— 

405 

130 

78 

126 

46 

70 

91 

53 

119 

36 

9 

28 

IFRS 9 ECL sensitivity to future economic conditions1 (continued)

ECL of loans and advances to 
customers at 31 December 20192

$m

$m

$m

$m

$m

$m

Gross carrying 
amount

Reported ECL Central scenario ECL Upside scenario ECL

Downside scenario 
ECL

Alternative scenarios 
ECL

UK

Mortgages

Credit cards

Other

Mexico

Mortgages

Credit cards

Other

Hong Kong

Mortgages

Credit cards

Other

UAE

Mortgages

Credit cards

Other

France

Mortgages

Other

US

Mortgages

Credit cards

Canada

Mortgages

Credit cards

Other

50-80

670-930

490-700

0

400

130

130,079 

9,359 

10,137 

3,385 

1,295 

3,001 

86,448 

7,795 

7,446 

1,983 

513 

895 

21,374 

1,643 

14,732 

738 

19,843 

270 

2,231 

123

431

382

32

211

341

0

243

105

92

54

28

60

73

22

68

15

7

17

33

421

318

31

211

340

0

201

95

92

54

28

60

73

22

68

14

7

17

28

376

282

24

190

312

0

191

90

83

49

26

59

73

21

62

13

7

16

38

506

374

41

231

380

0

201

104

91

72

31

60

74

24

74

16

7

18

1  ECL sensitivities exclude portfolios utilising less complex modelling approaches.
2  ECL sensitivity includes only on-balance sheet financial instruments to which IFRS 9 impairment requirements are applied.

134

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of changes in gross carrying/
nominal amount and allowances for loans and 
advances to banks and customers including loan 
commitments and financial guarantees

The following disclosure provides a reconciliation by stage of the 
Group’s gross carrying/nominal amount and allowances for loans 
and advances to banks and customers, including loan 
commitments and financial guarantees. Movements are calculated 
on a quarterly basis and therefore fully capture stage movements 
between quarters. If movements were calculated on a year-to-date 
basis they would only reflect the opening and closing position of 
the financial instrument.

The transfers of financial instruments represents the impact of 
stage transfers upon the gross carrying/nominal amount and 
associated allowance for ECL. 

The net remeasurement of ECL arising from stage transfers 
represents the increase or decrease due to these transfers, for 
example, moving from a 12-month (stage 1) to a lifetime (stage 2) 
ECL measurement basis. Net remeasurement excludes the 
underlying customer risk rating (‘CRR’)/probability of default (‘PD’) 
movements of the financial instruments transferring stage. This is 
captured, along with other credit quality movements in the 
‘changes in risk parameters – credit quality’ line item. 

Changes in ‘New financial assets originated or purchased’, ‘assets 
derecognised (including final repayments)’ and ‘changes to risk 
parameters – further lending/repayment’ represent the impact 
from volume movements within the Group’s lending portfolio.

At 31 December 2020, the most significant level of ECL sensitivity 
was observed in the UK, Mexico and Hong Kong.

Mortgages reflected the lowest level of ECL sensitivity across 
most markets as collateral values remain resilient. Hong Kong 
mortgages had low levels of reported ECL due to the credit quality 
of the portfolio, and so presented sensitivity was negligible. Credit 
cards and other unsecured lending are more sensitive to economic 
forecasts, which have deteriorated in 2020 due to the Covid-19 
pandemic.

Group ECL sensitivity results

The ECL impact of the scenarios and management judgemental 
adjustments are highly sensitive to movements in economic 
forecasts, including the efficacy of government support measures. 
Based upon the sensitivity tables presented above, if the Group 
ECL balance (excluding wholesale stage 3, which is assessed 
individually) was estimated solely on the basis of the Central 
scenario, Downside scenario or the additional Downside scenario 
at 31 December 2020, it would increase/(decrease) as presented in 
the below table.

Total Group ECL 2020

Reported ECL

Scenarios

100% consensus Central scenario

100% consensus Downside scenario

100% additional Downside scenario

Total Group ECL 2019

Reported ECL

Scenarios

100% consensus Central scenario

100% consensus Downside scenario

100% alternative Downside scenario

Retail1

Wholesale1

$bn 

4.5   

(0.3)   

0.3   

1.3   

$bn

4.5 

(0.9) 

1.0 

5.9 

Retail1

Wholesale

$bn

2.9   

(0.2)   

0.1   

n/a

$bn

2.0 

(0.3) 

— 

n/a

1  On the same basis as retail and wholesale sensitivity analysis.

There still remains a significant degree of uncertainty in relation to 
the UK economic outlook. If a 100% weight were applied to the 
consensus Downside and additional Downside scenario for the 
UK, respectively, it would result in an increase in ECL of $0.2bn 
and $1.8bn in wholesale and $0.2bn and $0.5bn in retail.

HSBC Holdings plc Annual Report and Accounts 2020

135

Risk review 
 
 
 
 
 
 
Risk

Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including 
loan commitments and financial guarantees
(Audited)

Non-credit impaired

Credit impaired

Stage 1

Stage 2

Stage 3

POCI

Total

Gross 
carrying/ 
nominal 
amount

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Allowance 
for ECL

$m

$m

$m

$m

$m

$m

$m

$m

$m

$m

At 1 Jan 2020

 1,561,613   

(1,464)    105,551   

(2,441)    14,335   

(5,121)   

345   

(99)   1,681,844   

(9,125) 

Transfers of financial instruments:

(129,236)   

(1,122)    116,783   

1,951    12,453   

(829)   

–  transfers from stage 1 to stage 2

(298,725)   

947    298,725   

(947)   

–  transfers from stage 2 to stage 1

  172,894   

(2,073)   (172,894)   

2,073   

—   

—   

—   

—   

–  transfers to stage 3

–  transfers from stage 3

(3,942)   

537   

30    (10,320)   

986    14,262   

(1,016)   

(26)   

1,272   

(161)   

(1,809)   

187   

—   

—   

—   

—   

—   

—   

907   

—   

(1,158)   

—   

(750)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

— 

— 

— 

— 

— 

—   

(1,001) 

Net remeasurement of ECL arising 
from transfer of stage

New financial assets originated or 
purchased

Assets derecognised (including final 
repayments)

Changes to risk parameters – 
further lending/repayment

Changes to risk parameters – credit 
quality

Changes to models used for ECL 
calculation

Assets written off

Credit-related modifications that 
resulted in derecognition

Foreign exchange

Others

At 31 Dec 2020

ECL income statement change for 
the period

Recoveries

Others 

Total ECL income statement 
change for the period

  437,836   

(653)   

—   

—   

—   

—   

25   

(1)    437,861   

(654) 

(313,347)   

160    (37,409)   

464   

(3,430)   

485   

(23)   

2    (354,209)   

1,111 

(83,147)   

157    29,092   

85   

(597)   

248   

(50)   

(2)   

(54,702)   

488 

—   

(408)   

—   

(4,374)   

—   

(4,378)   

—   

(39)   

—   

(9,199) 

—   

—   

—   

134   

—   

—   

—   

294   

—   

5   

—   

(2,946)   

2,944   

—   

—   

—   

32,808   

(47)   

9,123   

(223)   

(76)   

5   

292   

(1)   

(23)   

633   

(1)   

7   

(163)   

8   

—   

(30)   

—   

4   

8   

—   

30   

—   

(3)   

(1)   

—   

433 

(2,976)   

2,974 

(23)   

7 

42,568   

(436) 

223   

11 

 1,506,451   

(2,331)    223,432   

(5,403)    20,424   

(7,544)   

279   

(113)   1,750,586   

(15,391) 

297 

(4,689) 

(4,390) 

(40) 

(8,822) 

326 

(84) 

(8,580) 

As above

Other financial assets measured at amortised cost

Non-trading reverse purchase agreement commitments

Performance and other guarantees not considered for IFRS 9
Summary of financial instruments to which the impairment requirements in 
IFRS 9 are applied/Summary consolidated income statement

Debt instruments measured at FVOCI

Total allowance for ECL/total income statement ECL change for the period

At 31 Dec 2020

12 months ended 
31 Dec 2020

Gross carrying/nominal 
amount

Allowance for ECL

ECL charge

$m

1,750,586   

772,408   

61,716   

—   

2,584,710   

399,717   

n/a  

$m

(15,391)   

(175)   

—   

—   

(15,566)   

(141)   

(15,707)   

$m

(8,580) 

(95) 

— 

(94) 

(8,769) 

(48) 

(8,817) 

As shown in the previous table, the allowance for ECL for loans 
and advances to customers and banks and relevant loan 
commitments and financial guarantees increased $6,266m during 
the period from $9,125m at 31 December 2019 to $15,391m at 31 
December 2020.

This increase was primarily driven by:

• $9,199m relating to underlying credit quality changes, including 
the credit quality impact of financial instruments transferring 
between stages; 

• $1,001m relating to the net remeasurement impact of stage 

transfers; and

• foreign exchange and other movements of $425m.

• $433m of changes to models used for ECL calculation; and

• $7m of credit-related modifications that resulted in 

derecognitions.

The ECL charge for the period of $8,822m presented in the 
previous table consisted of $9,199m relating to underlying credit 
quality changes, including the credit quality impact of financial 
instruments transferring between stage and $1,001m relating to 
the net remeasurement impact of stage transfers. This was partly 
offset by $945m relating to underlying net book volume 
movement and $433m in changes to models used for ECL 
calculation. 

Summary views of the movement in wholesale and personal 
lending are presented on pages 147 and 160.

These were partly offset by:

• $2,974m of assets written off;

• $945m relating to volume movements, which included the ECL 

allowance associated with new originations, assets 
derecognised and further lending/repayment;

136

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including 
loan commitments and financial guarantees

(Audited)

Non-credit impaired

Credit impaired

Stage 1

Stage 2

Stage 3

POCI

Total

Gross 
exposure

Allowance/ 
provision 
for ECL

Gross 
exposure

Allowance/ 
provision 
for ECL

Gross 
exposure

Allowance/ 
provision for 
ECL

Gross 
exposure

Allowance/ 
provision 
for ECL

Gross 
exposure

Allowance/ 
provision for 
ECL

$m

$m

$m

$m

$m

$m

$m

$m

$m

$m

At 1 Jan 2019

  1,502,976   

(1,449)    95,104   

(2,278)   

14,232   

(5,135)   

334   

(194)    1,612,646   

(9,056) 

Transfers of financial instruments:

(36,244)   

(543)    31,063   

1,134   

5,181   

(591)   

–  transfers from stage 1 to stage 2

(108,434)   

487    108,434   

(487)   

–  transfers from stage 2 to stage 1

73,086   

(1,044)   

(73,086)   

1,044   

—   

—   

–  transfers to stage 3

–  transfers from stage 3

(1,284)   

388   

59   

(5,022)   

(45)   

737   

665   

(88)   

6,306   

(1,125)   

—   

—   

(724)   

133   

—   

—   

—   

—   

—   

—   

669   

—   

(676)   

—   

(114)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

— 

— 

— 

— 

— 

—   

(121) 

Net remeasurement of ECL arising 
from transfer of stage

New financial assets originated or 
purchased

Assets derecognised (including final 
repayments)

Changes to risk parameters – 
further lending/repayment

Changes to risk parameters – credit 
quality

Changes to models used for ECL 
calculation

Assets written off
Credit-related modifications that 
resulted in derecognition

Foreign exchange

Others

At 31 Dec 2019
ECL income statement change for 
the period

Recoveries

Others
Total ECL income statement change 
for the period

504,064   

(534)   

—   

—   

—   

—   

135   

(21)   

504,199   

(555) 

(352,961)   

112   

(19,909)   

553   

(2,712)   

656   

(26)   

8   

(375,608)   

1,329 

(72,239)   

291   

(2,560)   

67   

402   

(6)   

28   

12   

(74,369)   

364 

—   

—   

—   

—   

16,838   

(821)   

2   

—   

(1,208)   

—   

(2,704)   

—   

(51)   

—   

(3,961) 

(6)   

—   

—   

(9)   

3   

—   

—   

—   

1,201   

652   

4   

—   

—   

(40)   

3   

—   

14   

—   

—   

—   

12 

(2,657)   

2,657   

(140)   

140   

(2,797)   

2,797 

(268)   

160   

(3)   

125   

(31)   

8   

—   

1   

13   

—   

1   

6   

(268)   

18,200   

(159)   

125 

(79) 

20 

  1,561,613   

(1,464)    105,551   

(2,441)   

14,335   

(5,121)   

345   

(99)    1,681,844   

(9,125) 

534 

(1,260) 

(2,154) 

(52) 

(2,932) 

361 

(20) 

(2,591) 

As above

Other financial assets measured at amortised cost

Non-trading reverse purchase agreement commitments

Performance and other guarantees not considered for IFRS 9

Summary of financial instruments to which the impairment requirements in IFRS 9 are applied/ 
Summary consolidated income statement

Debt instruments measured at FVOCI

Total allowance for ECL/total income statement ECL change for the period

At 31 Dec 2019

12 months ended 31 Dec 2019

Gross carrying/
nominal amount

Allowance for ECL

ECL charge

$m

1,681,844   

615,179   

53,093   

— 

2,350,116   

355,664   

n/a  

$m

(9,125)   

(118)   

—   

—   

(9,243)   

(166)   

(9,409)   

$m

(2,591) 

(26) 

— 

(34) 

(2,651) 

(105) 

(2,756) 

HSBC Holdings plc Annual Report and Accounts 2020

137

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Credit quality

Credit quality of financial instruments

(Audited)

We assess the credit quality of all financial instruments that are 
subject to credit risk. The credit quality of financial instruments is 
a point-in-time assessment of PD, whereas stages 1 and 2 are 
determined based on relative deterioration of credit quality since 
initial recognition. Accordingly, for non-credit-impaired financial 

instruments, there is no direct relationship between the credit 
quality assessment and stages 1 and 2, although typically the 
lower credit quality bands exhibit a higher proportion in stage 2.

The five credit quality classifications each encompass a range of 
granular internal credit rating grades assigned to wholesale and 
personal lending businesses and the external ratings attributed by 
external agencies to debt securities, as shown in the table on 
page 121.

Distribution of financial instruments by credit quality at 31 December 2020

(Audited)

Gross carrying/notional amount

Strong

$m

Good

Satisfactory

Sub-
standard

$m

$m

$m

Credit 
impaired

$m

Allowance for 
ECL/other 
credit 
provisions

$m

Total

$m

Net

$m

In-scope for IFRS 9

Loans and advances to customers 
held at amortised cost

506,231   

233,320   

256,584   

36,970   

19,372   

1,052,477   

(14,490)   

1,037,987 

–  personal

357,821   

53,892   

38,520   

4,965   

5,611   

460,809   

–  corporate and commercial

120,971   

158,601   

203,560   

30,718   

13,238   

527,088   

–  non-bank financial institutions

27,439   

20,827   

14,504   

1,287   

523   

64,580   

(4,731)   

(9,494)   

(265)   

456,078 

517,594 

64,315 

Loans and advances to banks held 
at amortised cost 

Cash and balances at central 
banks 

Items in the course of collection 
from other banks

Hong Kong Government 
certificates of indebtedness 

Reverse repurchase agreements – 
non-trading

Prepayments, accrued income and 
other assets

–  endorsements and acceptances

–  accrued income and other

Debt instruments measured at 
fair value through other 
comprehensive income1

Out-of-scope for IFRS 9

71,318   

5,496   

3,568   

1,276   

—   

81,658   

(42)   

81,616 

302,028   

1,388   

1,070   

4,079   

40,420   

9   

—   

6   

—   

177,457   

40,461   

12,398   

81,886   

10,129   

11,570   

1,458   

80,428   

4,355   

5,774   

4,245   

7,325   

—   

—   

—   

312   

1   

298   

229   

69   

—   

304,486   

(5)   

304,481 

—   

4,094   

—   

4,094 

—   

40,420   

—   

40,420 

—   

39   

230,628   

88,719   

—   

230,628 

(80)   

88,639 

178   

20   

158   

104,061   

10,307   

93,754   

(90)   

(30)   

(60)   

103,971 

10,277 

93,694 

367,685   

12,678   

10,409   

825   

306   

391,903   

(141)   

391,762 

Financial investments

77,361   

9,781   

1,537   

Trading assets

117,972   

14,694   

20,809   

829   

43   

154,347   

—   

154,347 

Other financial assets designated 
and otherwise mandatorily 
measured at fair value through 
profit or loss 

Derivatives

Total gross carrying amount on 
balance sheet

6,440   

2,378   

243,005   

54,581   

1,827   

8,709   

109   

1,359   

—   

72   

10,754   

307,726   

—   

—   

10,754 

307,726 

1,995,882   

384,915   

328,487   

41,979   

20,010   

2,771,273   

(14,848)   

2,756,425 

Percentage of total credit quality

72.0%

13.9%

11.9%

1.5%

0.7%

100%

Loan and other credit-related 
commitments

400,911   

157,339   

90,784   

Financial guarantees

6,356   

5,194   

5,317   

9,668   

1,247   

1,081   

659,783   

270   

18,384   

(734)   

(125)   

659,049 

18,259 

In-scope: Irrevocable loan 
commitments and financial 
guarantees

Loan and other credit-related 
commitments

407,267   

162,533   

96,101   

10,915   

1,351   

678,167   

(859)   

677,308 

Performance and other guarantees

26,082   

27,909   

21,256   

59,392   

62,664   

59,666   

2,837   

2,112   

430   

755   

184,989   

78,114   

—   

184,989 

(226)   

77,888 

Out-of-scope: Revocable loan 
commitments and non-
financial guarantees

85,474   

90,573   

80,922   

4,949   

1,185   

263,103   

(226)   

262,877 

1  For the purposes of this disclosure, gross carrying value is defined as the amortised cost of a financial asset before adjusting for any loss 

allowance. As such, the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it 
excludes fair value gains and losses.

138

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Distribution of financial instruments by credit quality at 31 December 2019 (continued)

(Audited)

Gross carrying/notional amount

Strong

$m

Good

Satisfactory

Sub-
standard

Credit impaired

$m

$m

$m

$m

Allowance for 
ECL/other 
credit 
provisions

$m

Total

$m

Net

$m

In-scope for IFRS 9

Loans and advances to customers 
held at amortised cost

–  personal

–  corporate and commercial

–  non-bank financial institutions

Loans and advances to banks held 
at amortised cost 

Cash and balances at central 
banks 

Items in the course of collection 
from other banks

Hong Kong Government 
certificates of indebtedness 

Reverse repurchase agreements – 
non-trading

Financial investments

Prepayments, accrued income and 
other assets

–  endorsements and acceptances

–  accrued income and other

Debt instruments measured at fair 
value through other 
comprehensive income1

Out-of-scope for IFRS 9

Trading assets

Other financial assets designated 
and otherwise mandatorily 
measured at fair value through 
profit or loss 

Derivatives

Total gross carrying amount on 
balance sheet

524,889   

258,402   

228,485   

354,461   

138,126   

32,302   

45,037   

27,636   

190,470   

186,383   

22,895   

14,466   

20,007   

2,286   

16,891   

830   

13,692   

1,045,475   

(8,732)   

1,036,743 

4,851   

8,629   

212   

434,271   

540,499   

70,705   

(3,134)   

(5,438)   

(160)   

431,137 

535,061 

70,545 

60,636   

5,329   

1,859   

1,395   

—   

69,219   

(16)   

69,203 

151,788   

1,398   

915   

4,935   

38,380   

18   

—   

193,157   

78,318   

37,947   

6,503   

70,675   

1,133   

69,542   

8,638   

4,651   

3,987   

3   

—   

9,621   

906   

11,321   

4,196   

7,125   

—   

—   

—   

137   

61   

306   

230   

76   

—   

154,101   

(2)   

154,099 

—   

4,956   

—   

4,956 

—   

38,380   

—   

38,380 

—   

—   

152   

4   

148   

240,862   

85,788   

91,092   

10,214   

80,878   

—   

(53)   

(63)   

(16)   

(47)   

240,862 

85,735 

91,029 

10,198 

80,831 

333,158   

10,966   

7,222   

544   

1   

351,891   

(166)   

351,725 

135,059   

15,240   

22,964   

2,181   

—   

175,444   

—   

175,444 

4,655   

1,391   

5,584   

187,636   

42,642   

11,894   

139   

821   

—   

2   

11,769   

242,995   

—   

—   

11,769 

242,995 

1,783,286   

388,474   

300,774   

25,591   

13,847   

2,511,972   

(9,032)   

2,502,940 

Percentage of total credit quality

70.9%

15.5%

12.0%

1.0%

0.6%

100%

Loan and other credit-related 
commitments

Financial guarantees

In-scope: Irrevocable loan 
commitments and financial 
guarantees

Loan and other credit-related 
commitments

Performance and other guarantees  

Out-of-scope: Revocable loan 
commitments and non-financial 
guarantees

369,424   

146,988   

77,499   

7,441   

6,033   

5,539   

5,338   

1,011   

780   

190   

600,029   

20,214   

(329)   

(48)   

599,700 

20,166 

376,865   

153,021   

83,038   

6,349   

970   

620,243   

(377)   

619,866 

66,148   

30,099   

69,890   

23,335   

58,754   

20,062   

2,605   

2,057   

182   

380   

197,579   

75,933   

—   

197,579 

(132)   

75,801 

96,247   

93,225   

78,816   

4,662   

562   

273,512   

(132)   

273,380 

1  For the purposes of this disclosure, gross carrying value is defined as the amortised cost of a financial asset before adjusting for any loss 

allowance. As such, the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it 
excludes fair value gains and losses.

HSBC Holdings plc Annual Report and Accounts 2020

139

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage allocation

(Audited)

Loans and advances to customers at 
amortised cost

–  stage 1

–  stage 2

–  stage 3

–  POCI

Loans and advances to banks at 
amortised cost

–  stage 1

–  stage 2

–  stage 3

–  POCI

Other financial assets measured at 
amortised cost

–  stage 1

–  stage 2

–  stage 3

–  POCI

Loan and other credit-related 
commitments 

–  stage 1

–  stage 2

–  stage 3

–  POCI

Financial guarantees

–  stage 1

–  stage 2

–  stage 3

–  POCI

Gross carrying/notional amount

Footnotes

Strong

$m

Good Satisfactory

Sub-
standard

Credit 
impaired

$m

$m

$m

$m

Total

$m

Allowance  

for ECL

$m

Net

$m

506,231   

233,320   

256,584   

36,970   

19,372    1,052,477   

(14,490)    1,037,987 

499,836   

199,138   

165,507   

5,439   

6,395   

34,182   

91,077   

31,531   

—   

—   

869,920   

(1,974)   

867,946 

163,185   

(4,965)   

158,220 

—   

—   

—   

—   

—   

—   

—   

—   

19,095   

19,095   

(7,439)   

11,656 

277   

277   

(112)   

165 

71,318   

71,126   

192   

—   

—   

5,496   

5,098   

398   

—   

—   

3,568   

3,357   

1,276   

73   

211   

1,203   

—   

—   

683,231   

61,768   

26,581   

682,412   

61,218   

24,532   

819   

550   

2,049   

—   

—   

—   

—   

—   

—   

400,911   

157,339   

90,784   

396,028   

143,600   

63,592   

4,883   

13,739   

27,192   

—   

—   

6,356   

6,286   

70   

—   

—   

—   

—   

5,194   

4,431   

763   

—   

—   

—   

—   

5,317   

3,163   

2,154   

—   

—   

—   

—   

—   

—   

—   

81,658   

79,654   

2,004   

—   

—   

(42)   

(33)   

(9)   

—   

—   

81,616 

79,621 

1,995 

— 

— 

217   

772,408   

(175)   

772,233 

—   

—   

177   

40   

768,216   

3,975   

177   

40   

(80)   

(44)   

(42)   

(9)   

768,136 

3,931 

135 

31 

1,081   

659,783   

(734)   

659,049 

—   

—   

604,485   

54,217   

(290)   

604,195 

(365)   

53,852 

1,080   

1,080   

1   

1   

270   

18,384   

—   

—   

269   

1   

14,090   

4,024   

269   

1   

(78)   

(1)   

(125)   

(37)   

(62)   

(26)   

—   

1,002 

— 

18,259 

14,053 

3,962 

243 

1 

—   

—   

611   

54   

557   

—   

—   

9,668   

1,265   

8,403   

—   

—   

1,247   

210   

1,037   

—   

—   

At 31 Dec 2020

  1,668,047   

463,117   

382,834   

49,772   

20,940    2,584,710   

(15,566)    2,569,144 

Debt instruments at FVOCI

1

–  stage 1

–  stage 2

–  stage 3

–  POCI

367,542   

12,585   

10,066   

143   

—   

—   

93   

—   

—   

343   

—   

—   

—   

825   

—   

—   

—   

—   

257   

49   

390,193   

1,404   

257   

49   

(88)   

(20)   

(23)   

(10)   

390,105 

1,384 

234 

39 

At 31 Dec 2020

367,685   

12,678   

10,409   

825   

306   

391,903   

(141)   

391,762 

1  For the purposes of this disclosure, gross carrying value is defined as the amortised cost of a financial asset before adjusting for any loss 

allowance. As such, the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it 
excludes fair value gains and losses.

140

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage allocation 
(continued)
(Audited)

Loans and advances to customers at 
amortised cost

–  stage 1

–  stage 2

–  stage 3

–  POCI

Loans and advances to banks at 
amortised cost

–  stage 1

–  stage 2

–  stage 3

–  POCI

Other financial assets measured at 
amortised cost

–  stage 1

–  stage 2

–  stage 3

–  POCI

Loan and other credit-related 
commitments

–  stage 1

–  stage 2

–  stage 3

–  POCI

Financial guarantees

–  stage 1

–  stage 2

–  stage 3

–  POCI
At 31 Dec 2019

Debt instruments at FVOCI

1

–  stage 1

–  stage 2

–  stage 3

–  POCI

Gross carrying/notional amount

Footnotes

Strong

$m

Good

Satisfactory Sub-standard

$m

$m

$m

Credit 
impaired

$m

Allowance for 
ECL

$m

Total 

$m

 Net

$m

524,889   

258,402   

228,485   

20,007   

13,692   

1,045,475   

(8,732)   

1,036,743 

523,092   

242,631   

181,056   

4,804   

1,797   

15,771   

47,429   

15,185   

—   

—   

—   

18   

13,378   

314   

—   

—   

60,636   

60,548   

88   

—   

—   

—   

—   

5,329   

5,312   

17   

—   

—   

—   

—   

1,859   

1,797   

62   

—   

—   

537,253   

54,505   

22,766   

536,942   

54,058   

21,921   

311   

—   

—   

447   

—   

—   

845   

—   

—   

369,424   

146,988   

77,499   

368,711   

141,322   

713   

5,666   

—   

—   

7,441   

7,400   

41   

—   

—   

—   

6,033   

5,746   

287   

—   

66,283   

11,216   

—   

—   

5,539   

4,200   

1,339   

—   

—   
1,499,643   

—   
471,257   

—   
336,148   

333,072   

10,941   

86   

—   

—   

25   

—   

—   

6,902   

320   

—   

—   

951,583   

80,182   

13,378   

332   

69,219   

67,769   

1,450   

—   

—   

(1,297)   

(2,284)   

(5,052)   

(99)   

950,286 

77,898 

8,326 

233 

(16)   

(14)   

(2)   

—   

—   

69,203 

67,755 

1,448 

— 

— 

—   

—   

—   

—   

—   

152   

615,179   

(118)   

615,061 

—   

—   

151   

1   

613,200   

1,827   

151   

1   

780   

600,029   

—   

—   

771   

9   

190   

—   

—   

186   

577,631   

21,618   

771   

9   

20,214   

17,684   

2,340   

186   

(38)   

(38)   

(42)   

—   

(329)   

(137)   

(133)   

(59)   

—   

(48)   

(16)   

(22)   

(10)   

613,162 

1,789 

109 

1 

599,700 

577,494 

21,485 

712 

9 

20,166 

17,668 

2,318 

176 

4   
14,814   

4   
2,350,116   

—   
(9,243)   

4 
2,340,873 

—   

—   

—   

1   

1   

350,915   

(39)   

350,876 

975   

—   

1   

(127)   

—   

—   

848 

— 

1 

351,891   

(166)   

351,725 

1,395   

112   

1,283   

—   

—   

503   

279   

224   

—   

—   

5,338   

1,315   

4,023   

—   

—   

1,011   

338   

673   

—   

—   
28,254   

—   

544   

—   

—   

544   

At 31 Dec 2019

333,158   

10,966   

7,222   

1  For the purposes of this disclosure, gross carrying value is defined as the amortised cost of a financial asset before adjusting for any loss 

allowance. As such, the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it 
excludes fair value gains and losses.

Renegotiated loans and forbearance

The following table shows the gross carrying amounts of the 
Group’s holdings of renegotiated loans and advances to 
customers by industry sector and by stages. Mandatory and 
general offer loan modifications that are not borrower-specific, for 
example market-wide customer relief programmes, have not been 
classified as renegotiated loans. For details on customer relief 
schemes see page 142. 

A summary of our current policies and practices for renegotiated loans and 
forbearance is set out in ‘Credit risk management’ on page 119.

Credit-impaired loans

(Audited)

We determine that a financial instrument is credit impaired and in 
stage 3 by considering relevant objective evidence, primarily 
whether:

• contractual payments of either principal or interest are past due 

for more than 90 days;

• there are other indications that the borrower is unlikely to pay, 
such as when a concession has been granted to the borrower 
for economic or legal reasons relating to the borrower’s 
financial condition; and

• the loan is otherwise considered to be in default. If such 

unlikeliness to pay is not identified at an earlier stage, it is 
deemed to occur when an exposure is 90 days past due, even 
where regulatory rules permit default to be defined based on 
180 days past due. Therefore, the definitions of credit impaired 
and default are aligned as far as possible so that stage 3 
represents all loans that are considered defaulted or otherwise 
credit impaired.

HSBC Holdings plc Annual Report and Accounts 2020

141

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Renegotiated loans and advances to customers at amortised cost by stage allocation

Stage 1

$m

Stage 2

$m

Stage 3

$m

Gross carrying amount

Personal

–  first lien residential mortgages

–  other personal lending

Wholesale

–  corporate and commercial

–  non-bank financial institutions

At 31 Dec 2020

Allowance for ECL

Personal

–  first lien residential mortgages

–  other personal lending

Wholesale

–  corporate and commercial

–  non-bank financial institutions

At 31 Dec 2020

Gross carrying amount

Personal

–  first lien residential mortgages

–  other personal lending

Wholesale

–  corporate and commercial

–  non-bank financial institutions

At 31 Dec 2019

Allowance for ECL

Personal

–  first lien residential mortgages

–  other personal lending

Wholesale

–  corporate and commercial

–  non-bank financial institutions

At 31 Dec 2019

—   

—   

—   

328   

324   

4   

328   

—   

—   

—   

(10)   

(10)   

—   

(10)   

—   

—   

—   

1,168   

1,168   

—   

1,168   

—   

—   

—   

(13)   

(13)   

—   

(13)   

—   

—   

—   

989   

972   

17   

989   

—   

—   

—   

(36)   

(36)   

—   

(36)   

—   

—   

—   

1,179   

1,179   

—   

1,179   

—   

—   

—   

(55)   

(55)   

—   

(55)   

2,429   

1,692   

737   

3,929   

3,903   

26   

6,358   

(452)   

(152)   

(300)   

(1,276)   

(1,263)   

(13)   

(1,728)   

2,207   

1,558   

649   

3,353   

3,290   

63   

5,560   

(397)   

(181)   

(216)   

(1,349)   

(1,316)   

(33)   

(1,746)   

North 
America

Latin 
America

POCI

$m

—   

—   

—   

239   

239   

—   

239   

—   

—   

—   

(86)   

(86)   

—   

(86)   

—   

—   

—   

310   

310   

—   

310   

—   

—   

—   

(86)   

(86)   

—   

(86)   

Total

$m

2,429 

1,692 

737 

5,485 

5,438 

47 

7,914 

(452) 

(152) 

(300) 

(1,408) 

(1,395) 

(13) 

(1,860) 

2,207 

1,558 

649 

6,010 

5,947 

63 

8,217 

(397) 

(181) 

(216) 

(1,503) 

(1,470) 

(33) 

(1,900) 

Of which:

Total

$m

UK

$m

7,914   

3,483   

8,217   

3,438   

Hong 
Kong

$m

220 

277 

Renegotiated loans and advances to customers by geographical region

At 31 Dec 2020

At 31 Dec 2019

Europe

$m

4,274   

4,182   

Asia

$m

745   

838   

MENA

$m

$m

1,279   

1,349   

1,805   

1,185   

$m

267   

207   

Customer relief programmes

In response to the Covid-19 outbreak, governments and regulators 
around the world have introduced a number of support measures 
for both personal and wholesale customers in market-wide 
schemes. The following table presents the number of personal 
accounts/wholesale customers and the associated drawn loan 
values of customers under these schemes and HSBC-specific 
measures for major markets at 31 December 2020. In relation to 
personal lending, the majority of relief measures, including 
payment holidays, relate to existing lending, while in wholesale 
lending the relief measures comprise payment holidays, 
refinancing of existing facilities and new lending under 
government-backed schemes. 

At 31 December 2020, the gross carrying value of loans to 
personal customers under relief was $5.5bn (30 June 2020: 
$26.3bn). This comprised $4.7bn in relation to mortgages (30 June 
2020: $21.1bn) and $0.9bn in relation to other personal lending (30 
June 2020: $5.2bn). The decrease in personal customer relief 
during the second half of the year was driven by customers exiting 
relief measures. The gross carrying value of loans to wholesale 
customers under relief was $35.3bn (30 June 2020: $51.8bn). We 
continue to monitor the recoverability of loans granted under 
customer relief programmes, including loans to a small number of 
customers that were subsequently found to be ineligible for such 
relief. The ongoing performance of such loans remains an area of 
uncertainty at 31 December 2020.

142

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
Personal lending

Extant at 31 December 2020

Market-wide schemes

Number of accounts in mortgage customer relief

Drawn loan value of accounts in mortgage customer relief
Number of accounts in other personal lending customer relief

Drawn loan value of accounts in other personal lending customer relief

HSBC-specific measures

Number of accounts in mortgage customer relief

Drawn loan value of accounts in mortgage customer relief

Number of accounts in other personal lending customer relief

Drawn loan value of accounts in other personal lending customer relief
Total personal lending to major markets under market-wide schemes and 
HSBC-specific measures

Number of accounts in mortgage customer relief

Drawn loan value of accounts in mortgage customer relief

Number of accounts in other personal lending customer relief

Drawn loan value of accounts in other personal lending customer relief
Market-wide schemes and HSBC-specific measures – mortgage relief as a 
proportion of total mortgages

Market-wide schemes and HSBC-specific measures – other personal lending 
relief as a proportion of total other personal lending loans and advances

Wholesale lending

Extant at 31 December 2020

Market-wide schemes

Number of customers under market-wide measures

Drawn loan value of customers under market-wide schemes

HSBC-specific schemes

Number of customers under HSBC-specific measures

Drawn loan value of customers under HSBC-specific measures
Total wholesale lending to major markets under market-wide schemes and 
HSBC-specific measures

Number of customers

Drawn loan value

000s
$m

000s

$m

000s

$m

000s

$m

000s

$m

000s

$m

%

%

000s

$m

000s

$m

000s

$m

UK

Hong
Kong

6  

1,412  
15  

140  

—   

—   
—   

—   

— 

7 

— 

— 

3

1,124

1

75

6   

3   

1,419   

1,124   

15   

140   

 0.9 

 0.7 

1   

75   

 1.2 

 0.2 

UK

226

Hong
Kong

3

US

— 

— 
— 

— 

2

864

6

67

2   

864   

6   

67   

 4.7 

 3.1 

US

3

Other major 
markets1,2,3

5  

908  
28  

386  

3  

360  

18  

182  

Total

11 

2,320 
43 

526 

8 

2,355 

25 

324 

8   

19 

1,268   

4,675 

46   

568   

 1.6 

 1.1 

68 

850 

 1.4 

 0.8 

Other major 
markets1

Total

5  

237 

13,517

10,622

1,043

6,017  

31,199 

—

349

—  

—

— 

924

—  

— 

2,869  

4,142 

226   

3   

3   

5   

237 

13,866   

10,622   

1,967   

8,886   

35,341 

Market-wide schemes and HSBC-specific measures as a proportion of total 
wholesale lending loans and advances

%

 9.6 

 5.9 

 5.2 

 4.6 

 6.4 

1  Other major markets include Australia, Canada, mainland China, Egypt, France, Germany, India, Indonesia, Malaysia, Mexico, Singapore, 

Switzerland, Taiwan and UAE.
In Malaysia, personal lending customers are granted an automatic moratorium programme for all eligible retail customers. At 31 December 2020, 
the number of accounts under this moratorium was 26,000 with an associated drawn balance of $452m.
In Mexico, there were 16,000 personal lending accounts under customer relief with an associated drawn balance of $233m.

2 

3 

The initial granting of customer relief does not automatically 
trigger a migration to stage 2 or 3. However, information provided 
by payment deferrals is considered in the context of other 
reasonable and supportable information. This forms part of the 
overall assessment for whether there has been a significant 
increase in credit risk and credit impairment to identify loans for 
which lifetime ECL is appropriate. An extension in payment 
deferral does not automatically result in a migration to stage 2 or 
stage 3. The key accounting and credit risk judgement to ascertain 
whether a significant increase in credit risk has occurred is 
whether the economic effects of the Covid-19 outbreak on the 
customer are likely to be temporary over the lifetime of the loan, 
and whether they indicate that a concession is being made in 
respect of financial difficulty that would be consistent with     
stage 3.

Market-wide schemes

The following narrative provides further details on the major 
government and regulatory schemes offered in the UK, Hong Kong 
and the US.

UK personal lending

Mortgages

Customer relief granted on UK mortgages primarily consists of 
payment holidays or partial payment deferrals.

Relief is offered for an initial period of three months and may be 
extended for a further three months in certain circumstances. No 
payment is required from the customer during this period (though 

with a partial payment deferral the customer has expressed a 
desire to make a contribution) and interest continues to be 
charged as usual. The customer’s arrears status is not worsened 
from utilisation of these schemes.

Other personal lending payment holidays

Customer relief is granted for an initial period of three months and 
may be extended for a further three months. The maximum relief 
value is up to the due payment amount during the period.

UK wholesale lending 

The primary relief granted under government schemes consists of 
the Bounce Back Loan Scheme, Coronavirus Business Interruption 
Loan Scheme and Coronavirus Large Business Interruption Loan 
Scheme. Since their initial launch, the application deadline for 
these schemes has been extended until 31 March 2021. The key 
features of these schemes are as follows:

• The Bounce Back Loan Scheme provides small and medium-
sized enterprises (‘SME’) with loans of up to £50,000 for a 
maximum period of six years. Interest is charged at 2.5% and 
the government pays the fees and interest for the first 12 
months. No capital repayment is required by the customer for 
the first 12 months of the scheme. A government guarantee of 
100% is provided under the scheme. Before their first payment 
is due customers can extend the term of the loan to 10 years, 
move to interest-only repayments for a period of six months 
(customers can use this option up to three times) and/or pause 
repayments for a period of six months (customers can use this 
option once).

HSBC Holdings plc Annual Report and Accounts 2020

143

Risk review 
 
 
 
 
 
 
 
 
 
 
Wholesale lending

This section provides further details on the regions, countries, 
territories and products comprising wholesale loans and advances 
to customers and banks. Product granularity is also provided by 
stage with geographical data presented for loans and advances to 
customers, banks, other credit commitments, financial guarantees 
and similar contracts. Additionally, this section provides a 
reconciliation of the opening 1 January 2020 to 31 December 2020 
closing gross carrying/nominal amounts and the associated 
allowance for ECL.

At 31 December 2020, wholesale lending for loans and advances 
to banks and customers of $673bn decreased by $7.1bn since 31 
December 2019. This included favourable foreign exchange 
movements of $14.9bn. Excluding foreign exchange movements, 
the total wholesale lending decrease was driven by a $25.3bn 
decline in corporate and commercial balances and a $8bn decline 
in balances from non-bank financial institutions. This was partly 
offset by a $11.2bn increase in loans and advances to banks. 

The primary driver of the decline in corporate and commercial 
balances was $14.5bn in Asia, notably $7.1 bn in Hong Kong, 
$2.8bn in Australia and $1.5bn in Singapore. Balances in Europe 
declined $4.3bn, notably $2.4bn in Germany and $2bn in the UK, 
partly offset by growth of $1.8bn in France.

In North America and Latin America, balances declined $6.8bn 
and $1.3bn respectively, while they grew in MENA by $1.6bn.

Loan commitments and financial guarantees grew $45bn since 31 
December 2019 to $441bn at 31 December 2020, including a 
$8.6bn increase related to unsettled reverse repurchase 
agreements. This also included favourable foreign exchange 
movements of $15.4bn.

The allowance for ECL attributable to wholesale loans and 
advances to banks and customers increased $4.2bn to $9.8bn at 
31 December 2020 from $5.6bn at 31 December 2019. This 
included adverse foreign exchange movements of $0.1bn. 

Excluding foreign exchange movements, the total increase in the 
wholesale ECL allowance for loans and advances to customers 
and banks was driven by a $4bn rise in corporate and commercial 
balances. The primary driver of this increase in corporate and 
commercial allowance for ECL was $1.5bn in Europe, notably 
$1.3bn in the UK. There was an increase of $1.3bn in Asia, notably 
$0.7bn in Singapore and $0.4bn in Hong Kong. Additionally, there 
were increases of $0.5bn, $0.4bn and $0.4bn in MENA, North 
America and Latin America, respectively.

The allowance for ECL attributable to loan commitments and 
financial guarantees of $0.8bn at 31 December 2020 increased 
from $0.4bn at 31 December 2019.

Risk

• The Coronavirus Business Interruption Loan Scheme provides 
SMEs that have a turnover of less than £45m with loans of up 
to £5m for a maximum period of six years. Interest is charged 
between 3.49% and 3.99% above the UK base rate and no 
capital repayment is required by the customer for the first 12 
months of the scheme. A government guarantee of up to 80% 
is provided under the scheme.

• The Coronavirus Large Business Interruption Loan Scheme 
provides medium and large-sized enterprises that have a 
turnover in excess of £45m with loans of up to £200m. The 
interest rate and tenor of the loan are negotiated on 
commercial terms. A government guarantee of 80% is 
provided under the scheme.

Hong Kong wholesale lending

Pre-approved Principal Payment Holiday Scheme for Corporate 
Customers

The above scheme enables eligible customers to apply for a 
payment holiday of six months (or 90 days for trade finance) with 
no change to the existing interest rate charge. On 2 September 
2020, the Hong Kong Monetary Authority announced that this 
scheme has been extended for a further six months to April 2021.

US wholesale lending 

Paycheck Protection Program

The CARES Act created the Paycheck Protection Program (‘PPP’) 
loan guarantee programme to provide small businesses with 
support to cover payroll and certain other expenses. Loans made 
under the PPP are fully guaranteed by the Small Business 
Administration, whose guarantee is backed by the full faith and 
credit of the US. PPP-covered loans also afford customers 
forgiveness up to the principal amount of the PPP-covered loan, 
plus accrued interest, if the loan proceeds are used to retain 
workers and maintain payroll or to make certain mortgage 
interest, lease and utility payments, and certain other criteria are 
satisfied. The Small Business Administration will reimburse PPP 
lenders for any amount of a PPP-covered loan that is forgiven, and 
PPP lenders will not be liable for any representations made by PPP 
borrowers in connection with their requests for loan forgiveness. 
Lenders receive pre-determined fees for processing and servicing 
PPP loans. 

HSBC-specific measures

UK wholesale lending

HSBC is offering capital repayment holidays to CMB customers. 
Relief is offered on a preferred term of six months. However, some 
are granted for three months with the option of an extension. 
Interest continues to be paid as usual.

Hong Kong personal lending

Mortgages 

Customer relief granted on Hong Kong mortgages consists of 
deferred principal repayment of up to 12 months. This relief 
programme is available to existing HSBC mortgage loan 
customers who have a good repayment record during the past six 
months. 

US total personal lending

Customer relief granted on US mortgages and other personal 
lending consists of deferrals of up to 12 months and up to nine 
months respectively.

144

HSBC Holdings plc Annual Report and Accounts 2020

Total wholesale lending for loans and advances to banks and customers by stage distribution

Gross carrying amount

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

Total

Stage 1

Stage 2

Stage 3

$m

$m

$m

$m

POCI

$m

Total

$m

Corporate and commercial

  387,563    126,287    12,961   

277    527,088   

(1,101)   

(2,444)   

(5,837)   

(112)   

(9,494) 

–  agriculture, forestry and fishing

–  mining and quarrying

–  manufacturing

–  electricity, gas, steam and air-

conditioning supply

–  water supply, sewerage, waste 
management and remediation

–  construction

–  wholesale and retail trade, repair of 
motor vehicles and motorcycles

–  transportation and storage

–  accommodation and food

–  publishing, audiovisual and 

broadcasting

–  real estate

6,087   

1,026   

7,429   

3,705   

331   

797   

1   

7,445   

16    11,947   

(12)   

(33)   

  68,179    23,564   

2,076   

87    93,906   

(201)   

(45)   

(112)   

(442)   

(149)   

(209)   

(905)   

(1)   

(11)   

(40)   

(207) 

(365) 

(1,588) 

  14,240   

1,907   

53   

—    16,200   

(25)   

(40)   

(8)   

—   

(73) 

2,874   

253   

9,368   

4,455   

47   

773   

—   

3,174   

(8)   

(7)   

(22)   

4    14,600   

(42)   

(118)   

(426)   

  65,937    21,518   

3,196   

12    90,663   

(174)   

(326)   

(2,029)   

  19,510   

9,143   

  10,616    14,918   

769   

536   

11    29,433   

1    26,071   

(90)   

(76)   

(163)   

(285)   

(240)   

(129)   

—   

(4)   

(3)   

—   

(1)   

(37) 

(590) 

(2,532) 

(493) 

(491) 

  17,019   

2,796   

131   

33    19,979   

(45)   

(85)   

(39)   

(20)   

(189) 

  102,933    22,186   

1,907   

1    127,027   

(169)   

(260)   

(738)   

—   

(1,167) 

–  professional, scientific and technical 

activities

  17,162   

6,379   

–  administrative and support services

  17,085   

8,361   

–  public administration and defence, 

compulsory social security

–  education

–  health and care

–  arts, entertainment and recreation

–  other services

–  activities of households

–  extra-territorial organisations and 

bodies activities

–  government

–  asset-backed securities

1,530   

1,402   

475   

691   

4,049   

1,192   

1,631   

1,570   

  11,380   

1,320   

660   

142   

10   

7,866   

596   

—   

671   

15   

Non-bank financial institutions

  52,223    11,834   

Loans and advances to banks

  79,654   

2,004   

498   

907   

3   

29   

261   

236   

410   

—   

—   

1   

—   

523   

—   

33    24,072   

70    26,423   

—   

—   

8   

—   

2,008   

2,122   

5,510   

3,437   

—    13,110   

—   

802   

—   

—   

—   

10   

8,538   

611   

—    64,580   

—    81,658   

(56)   

(66)   

(2)   

(12)   

(21)   

(9)   

(54)   

—   

—   

(6)   

—   

(46)   

(33)   

(149)   

(153)   

(11)   

(20)   

(45)   

(62)   

(105)   

(1)   

—   

(2)   

(13)   

(119)   

(9)   

(185)   

(291)   

(1)   

(9)   

(120)   

(87)   

(249)   

—   

—   

(1)   

—   

(100)   

—   

(8)   

(24)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(398) 

(534) 

(14) 

(41) 

(186) 

(158) 

(408) 

(1) 

— 

(9) 

(13) 

(265) 

(42) 

  519,440    140,125    13,484   

277    673,326   

(1,180)   

(2,572)   

(5,937)   

(112)   

(9,801) 

  156,474    51,708   

6,531   

109    214,822   

(589)   

(1,400)   

(2,097)   

  104,534    40,454   

4,712   

53    149,753   

(536)   

(1,234)   

(1,320)   

  279,985    58,159   

3,443   

106    341,693   

–  of which: Hong Kong

  156,817    39,257   

1,637   

45    197,756   

  24,753   

7,893   

1,952   

30    34,628   

  46,852    18,220   

  11,376   

4,145   

913   

645   

—    65,985   

32    16,198   

(337)   

(162)   

(91)   

(77)   

(86)   

(383)   

(2,040)   

(260)   

(751)   

(216)   

(1,205)   

(302)   

(271)   

(281)   

(314)   

  519,440    140,125    13,484   

277    673,326   

(1,180)   

(2,572)   

(5,937)   

(112)   

(9,801) 

Total wholesale lending for loans and other credit-related commitments and financial guarantees by stage distribution1

Nominal amount

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

$m

Total

Stage 1

Stage 2

Stage 3

Corporate and commercial

  262,598    49,008   

1,140   

2    312,748   

  120,768   

7,526   

55   

—    128,349   

  383,366    56,534   

1,195   

2    441,097   

  210,141    28,705   

  81,153    17,048   

  63,586   

6,311   

  26,502   

3,639   

4,975   

1,609   

  102,399    19,360   

2,265   

549   

851   

480   

20   

4   

85   

198   

41   

2    239,699   

1    98,682   

—    69,917   

—    30,145   

—   

6,669   

—    121,957   

—   

2,855   

$m

(271)   

(17)   

(288)   

(152)   

(138)   

(73)   

(24)   

(14)   

(39)   

(10)   

$m

(392)   

(33)   

(425)   

(208)   

(176)   

(43)   

(22)   

(44)   

(124)   

(6)   

$m

(100)   

(4)   

(104)   

(83)   

(72)   

(6)   

(1)   

(2)   

(7)   

(6)   

  383,366    56,534   

1,195   

2    441,097   

(288)   

(425)   

(104)   

1 

Included in loans and other credit-related commitments and financial guarantees is $62bn relating to unsettled reverse repurchase agreements, 
which once drawn are classified as ‘Reverse repurchase agreements – non-trading’.

HSBC Holdings plc Annual Report and Accounts 2020

145

At 31 Dec 2020

By geography

Europe

–  of which: UK

Asia

MENA

North America

Latin America

At 31 Dec 2020

Financial 

At 31 Dec 2020

By geography

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2020

(51)   

(33)   

(43)   

(23)   

(12)   

—   

(6)   

(4,137) 

(3,123) 

(2,803) 

(1,196) 

(1,524) 

(660) 

(677) 

POCI

$m

(1)   

—   

(1)   

(1)   

(1)   

—   

—   

—   

—   

—   

(1)   

Total

$m

(764) 

(54) 

(818) 

(444) 

(387) 

(122) 

(47) 

(60) 

(170) 

(22) 

(818) 

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(18)   

(467)   

(934)   

(158)   

(62)   

(33)   

(475)   

(145)   

(179)   

—   

(6)   

(28)   

(11)   

(133)   

—   

—   

(6)   

—   

(90)   

—   

—   

(32)   

(28) 

(564) 

(2)   

—   

(1)   

(1)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(1,184) 

(237) 

(146) 

(87) 

(680) 

(209) 

(270) 

(8) 

(18) 

(57) 

(25) 

(199) 

— 

— 

(14) 

(14) 

(160) 

(16) 

(42)   

(37)   

(30)   

(108)   

(31)   

(33)   

(1)   

(7)   

(9)   

(6)   

(35)   

—   

—   

(6)   

(2)   

(42)   

(14)   

(37)   

(46)   

(23)   

(97)   

(33)   

(58)   

(7)   

(5)   

(20)   

(8)   

(31)   

—   

—   

(2)   

(12)   

(28)   

(2)   

Risk

Total wholesale lending for loans and advances to banks and customers by stage distribution

Corporate and commercial

  472,253   

59,599   

8,315   

332    540,499   

(672)   

(920)   

(3,747)   

(99)   

(5,438) 

Gross carrying amount

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

Total

$m

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

Total

$m

5,416   

9,923   

1,000   

4,189   

278   

311   

2   

6,696   

12   

14,435   

(13)   

(22)   

(29)   

(70)   

88,138   

14,525   

1,581   

136    104,380   

(143)   

(211)   

(139)   

(122)   

(806)   

(1)   

(12)   

(50)   

(182) 

(226) 

(1,210) 

13,479   

1,386   

175   

—   

15,040   

(14)   

(41)   

(25)   

—   

(80) 

–  agriculture, forestry and fishing

–  mining and quarrying

–  manufacturing

–  electricity, gas, steam and air-

conditioning supply

–  water supply, sewerage, waste 
management and remediation

–  construction

–  wholesale and retail trade, repair of 
motor vehicles and motorcycles

–  transportation and storage

–  accommodation and food 

–  publishing, audiovisual and 

broadcasting

–  real estate

2,963   

508   

10,520   

3,883   

30   

852   

—   

3,501   

32   

15,287   

(6)   

(16)   

(4)   

(49)   

83,151   

9,897   

1,625   

8   

94,681   

(111)   

(137)   

22,604   

20,109   

2,359   

4,284   

588   

262   

29   

25,580   

1   

24,656   

18,103   

1,706   

141   

21   

19,971   

  122,972   

6,450   

1,329   

1    130,752   

–  professional, scientific and technical 

activities

21,085   

2,687   

–  administrative and support services

21,370   

3,817   

–  public administration and defence, 

compulsory social security

–  education

–  health and care

–  arts, entertainment and recreation

–  other services

–  activities of households

–  extra-territorial organisations and 

bodies activities

–  government

–  asset-backed securities

Non-bank financial institutions

Loans and advances to banks

1,889   

1,700   

3,543   

2,537   

13,143   

725   

2   

8,159   

722   

65,661   

67,769   

488   

184   

811   

257   

941   

66   

—   

147   

14   

4,832   

1,450   

350   

438   

—   

16   

111   

30   

191   

—   

—   

7   

—   

212   

—   

—   

24,122   

89   

25,714   

—   

—   

—   

—   

1   

—   

—   

—   

—   

—   

—   

2,377   

1,900   

4,465   

2,824   

14,276   

791   

2   

8,313   

736   

70,705   

69,219   

At 31 Dec 2019

By geography

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2019

  605,683   

65,881   

8,527   

332    680,423   

(728)   

(950)   

(3,837)   

(99)   

(5,614) 

  190,528   

20,276   

  131,007   

16,253   

  308,305   

32,287   

  182,501   

23,735   

25,470   

64,501   

16,879   

3,314   

7,495   

2,509   

4,671   

3,343   

1,419   

673   

1,686   

458   

293   

129    215,604   

79    150,682   

148    342,159   

48    206,957   

18   

—   

37   

30,488   

72,454   

19,718   

(318)   

(252)   

(228)   

(118)   

(55)   

(45)   

(82)   

(458)   

(385)   

(253)   

(172)   

(85)   

(96)   

(58)   

(1,578)   

(989)   

(986)   

(475)   

(946)   

(141)   

(186)   

(45)   

(32)   

(38)   

(28)   

(12)   

—   

(4)   

(2,399) 

(1,658) 

(1,505) 

(793) 

(1,098) 

(282) 

(330) 

  605,683   

65,881   

8,527   

332    680,423   

(728)   

(950)   

(3,837)   

(99)   

(5,614) 

Total wholesale lending for loans and other credit-related commitments and financial guarantees by stage distribution1

Corporate and commercial

Financial 

At 31 Dec 2019

By geography

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2019

Nominal amount

Stage 1

Stage 2

Stage 3

$m

$m

  271,678   

20,880   

  101,345   

1,447   

  373,023   

22,327   

  190,604   

76,013   

60,759   

27,047   

5,690   

7,852   

4,193   

3,762   

2,114   

621   

  112,812   

9,933   

3,158   

159   

$m

757   

5   

762   

645   

494   

8   

5   

31   

77   

1   

POCI

$m

Total

$m

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

13    293,328   

(132)   

(151)   

—    102,797   

(7)   

(2)   

13    396,125   

(139)   

(153)   

13    199,114   

9   

—   

—   

—   

80,709   

64,529   

29,166   

6,342   

—    122,822   

—   

3,318   

(60)   

(48)   

(43)   

(14)   

(12)   

(22)   

(2)   

(43)   

(32)   

(33)   

(23)   

(13)   

(62)   

(2)   

$m

(68)   

(1)   

(69)   

(56)   

(31)   

(4)   

(2)   

(4)   

(5)   

—   

(69)   

POCI

$m

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

Total

$m

(351) 

(10) 

(361) 

(159) 

(111) 

(80) 

(39) 

(29) 

(89) 

(4) 

(361) 

  373,023   

22,327   

762   

13    396,125   

(139)   

(153)   

1 

Included in loans and other credit-related commitments and financial guarantees is $53bn relating to unsettled reverse repurchase agreements, 
which once drawn are classified as ‘Reverse repurchase agreements – non-trading’.

146

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net remeasurement of ECL arising 
from transfer of stage

Net new and further lending/ 
repayments

Change in risk parameters – credit 
quality 

Changes to models used for ECL 
calculation

Assets written off

Credit-related modifications that 
resulted in derecognition

Wholesale lending – reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and 
customers including loan commitments and financial guarantees
(Audited)

Non-credit impaired

Credit impaired

Stage 1

Stage 2

Stage 3

POCI

Total

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

At 1 Jan 2020

  925,652   

(867)   

88,169   

(1,103)   

9,289   

(3,906)   

Transfers of financial instruments

  (113,217)   

(493)    103,413   

770   

9,804   

(277)   

$m

$m

$m

$m

$m

$m

$m

345   

—   

$m

$m

$m

(99)   1,023,455   

(5,975) 

—   

—   

—   

— 

—   

(869) 

—   

476   

—   

(603)   

—   

(742)   

—   

10,451   

(437)   

(2,910)   

141   

(3,350)   

583   

(48)   

(1)   

4,143   

286 

—   

(261)   

—   

(2,349)   

—   

(3,120)   

—   

(39)   

—   

(5,769) 

—   

—   

—   

137   

—   

—   

—   

—   

—   

303   

—   

—   

—   

(1,537)   

1,537   

—   

(23)   

479   

7   

(123)   

—   

(30)   

—   

12   

—   

30   

—   

(4)   

—   

440 

(1,567)   

1,567 

(23)   

7 

26,700   

(304) 

Foreign exchange and other

18,219   

(20)   

7,990   

(157)   

At 31 Dec 2020

  841,105   

(1,465)    196,662   

(2,998)   

14,662   

(6,041)   

279   

(113)   1,052,708   

(10,617) 

ECL income statement change for 
the period

Recoveries

Others

Total ECL income statement 
change for the period

(85) 

(2,508) 

(3,279) 

(40) 

(5,912) 

46 

(59) 

(5,925) 

As shown in the above table, the allowance for ECL for loans and 
advances to customers and banks and relevant loan commitments 
and financial guarantees increased $4,642m during the period 
from $5,975m at 31 December 2019 to $10,617m at 31 December 
2020.

This increase was primarily driven by:

• $5,769m relating to underlying credit quality changes, including 
the credit quality impact of financial instruments transferring 
between stages; 

• $869m relating to the net remeasurement impact of stage 

transfers; and

• foreign exchange and other movements of $304m.

These were partly offset by:

• $1,567m of assets written off;

• $440m of changes to models used for ECL calculation;

• $286m relating to volume movements, which included the ECL 

allowance associated with new originations, assets 
derecognised and further lending/repayments; and

• $7m of credit-related modifications that resulted in 

derecognition.

The ECL charge for the period of $5,912m presented in the above 
table consisted of $5,769m relating to underlying credit quality 
changes, including the credit quality impact of financial 
instruments transferring between stage and $869m relating to the 
net remeasurement impact of stage transfers. These charges were 
partly offset by $440m in changes to models used for ECL 
calculation and $286m relating to underlying net book volume 
movements.

HSBC Holdings plc Annual Report and Accounts 2020

147

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Wholesale lending – reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and
customers including loan commitments and financial guarantees
(Audited)

Non-credit impaired

Credit impaired

Stage 1

Stage 2

Stage 3

POCI

Total

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

$m

$m

$m

$m

$m

$m

922,192   

(31,493)   

(902)   

78,266   

(1,012)   

9,239   

(3,987)   

(169)   

28,418   

276   

3,075   

(107)   

Gross 
carrying/ 
nominal 
amount

$m

334   

—   

—   

223   

—   

(268)   

—   

(38)   

—   

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

$m

$m

$m

(194)    1,010,031   

(6,095) 

—   

—   

—   

— 

—   

(83) 

27,918   

(134)   

(20,121)   

167   

(1,552)   

369   

137   

(1)   

6,382   

401 

—   

102   

—   

(193)   

—   

(1,514)   

—   

(51)   

—   

(1,656) 

(56)   

—   

—   

—   

—   

—   

(56) 

—   

(1,312)   

1,312   

(140)   

140   

(1,452)   

1,452 

—   

—   

—   

—   

—   

—   

13   

—   

—   

—   

1,606   

At 1 Jan 2019

Transfers of financial instruments

Net remeasurement of ECL arising 
from transfer of stage

Net new and further lending/
repayments

Changes to risk parameters – credit 
quality

Changes to models used for ECL 
calculation

Assets written off

Credit-related modifications that 
resulted in derecognition

Foreign exchange and other

7,035   

At 31 Dec 2019

925,652   

(867)   

88,169   

(1,103)   

9,289   

(3,906)   

—   

(17)   

(268)   

107   

125   

(66)   

—   

14   

345   

—   

7   

(268)   

8,762   

125 

(63) 

(99)    1,023,455   

(5,975) 

ECL income statement change for the 
period

Recoveries

Others 

Total ECL income statement change 
for the period

191 

(350) 

(1,183) 

(52) 

(1,394) 

47 

(24) 

(1,371) 

Wholesale lending – distribution of financial instruments to which the impairment requirements of IFRS 9 are applied by credit quality 

By geography

Europe 

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2020

By geography

Europe 

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2019

Gross carrying/nominal amount

Good Satisfactory

Sub-
standard

Credit 
impaired

$m

$m

$m

$m

Total

$m

Allowance 
for ECL

$m

Net

$m

Strong

$m

53,373

35,050

141,811

72,088

12,398

11,157

989

55,436

42,476

93,350

52,601

7,810

22,973

5,355

81,049

55,106

98,488

68,826

10,990

24,978

6,127

57,340

35,838

69,427

53,046

145,450  

106,313   

82,053  

12,036  

12,319  

3,919  

67,541   

6,003   

31,496   

24,860   

5,455   

7,713   

74,143

51,355

86,685   

55,379   

9,307   

18,327

12,357

4,493

2,558

1,448

5,964

3,049

33,281

4.9%

6,637

4,764

3,551

1,683

1,982

913

678

214,822  

(4,137)   

210,685 

149,753  

(3,123)   

146,630 

341,693  

(2,803)   

338,890 

197,756  

(1,196)   

196,560 

34,628  

65,985  

16,198  

(1,524)   

(660)   

(677)   

33,104 

65,325 

15,521 

13,761

673,326  

(9,801)   

663,525 

2.0%

100.0%

9,895

7,023

2,158   

1,263   

1,439   

3,320   

2,304   

4,799

3,420

215,604  

150,682  

1,553   

342,159   

721   

206,957   

1,703   

459   

327   

30,488   

72,454   

19,718   

(2,399) 

(1,658) 

(1,505)   

(793)   

(1,098)   

(282)   

(330)   

213,205

149,024

340,654 

206,164 

29,390 

72,172 

19,388 

Percentage of total credit quality

32.6%

27.5%

32.9%

219,728

184,924

221,632

231,064  

218,694   

202,708   

19,116   

8,841   

680,423   

(5,614)   

674,809 

Percentage of total credit quality

34.0%

32.1%

29.8%

2.8%

1.3%

100.0%

Our risk rating system facilitates the internal ratings-based approach under the Basel framework adopted by the Group to support 
calculation of our minimum credit regulatory capital requirement. The credit quality classifications can be found on page 121.

148

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
–  CRR 9/10

100.000   

—   

—   

523    —   

Wholesale lending – credit risk profile by obligor grade for loans and advances at amortised cost

Gross carrying amount

Allowance for ECL

Basel one-year PD 

range Stage 1

Stage 2 Stage 3 POCI

Total Stage 1 Stage 2 Stage 3 POCI

%

$m

$m

$m $m

$m

$m

$m

$m

$m

Total

$m

ECL 
coverage

Mapped 
external rating

%

 387,563   126,287   12,961   277    527,088   (1,101)   (2,444)   (5,837)    (112)    (9,494) 

 1.8 

Corporate and 
commercial

–  CRR 1

–  CRR 2

–  CRR 3

–  CRR 4

–  CRR 5

–  CRR 6

–  CRR 7

–  CRR 8

–  CRR 9/10

Non-bank 
financial 
institutions

–  CRR 1

–  CRR 2

–  CRR 3

–  CRR 4

–  CRR 5

–  CRR 6

–  CRR 7

–  CRR 8

Banks

–  CRR 1

–  CRR 2

–  CRR 3

–  CRR 4

–  CRR 5

–  CRR 6

–  CRR 7

–  CRR 8

–  CRR 9/10

At 31 Dec 2020

Corporate and
commercial

– CRR 1

– CRR 2

– CRR 3

– CRR 4

– CRR 5

– CRR 6

– CRR 7

– CRR 8

– CRR 9/10

Non-bank financial 
institutions

– CRR 1

– CRR 2

– CRR 3

– CRR 4

– CRR 5

– CRR 6

– CRR 7

– CRR 8

– CRR 9/10

Banks

– CRR 1

– CRR 2

– CRR 3

– CRR 4

– CRR 5

– CRR 6

– CRR 7

– CRR 8

– CRR 9/10

At 31 Dec 2019

0.000 to 0.053   36,047   

486   

—    —    36,533   

(8)   

(5)   

—    —   

0.054 to 0.169   81,298    3,140   

—    —    84,438   

(42)   

(36)   

—    —   

0.170 to 0.740  131,540    27,061   

—    —    158,601   

(262)   

(197)   

—    —   

0.741 to 1.927   91,385    35,376   

—    —    126,761   

(390)   

(375)   

—    —   

(13) 

(78) 

(459) 

(765) 

1.928 to 4.914   42,214    34,585   

—    —    76,799   

(330)   

(686)   

—    —    (1,016) 

4.915 to 8.860   3,523    14,560   

—    —    18,083   

(35)   

(476)   

—    —   

8.861 to 15.000   1,111    7,241   

—    —   

8,352   

(21)   

(322)   

—    —   

15.001 to 99.999  

445    3,838   

—    —   

4,283   

(13)   

(347)   

—    —   

(511) 

(343) 

(360) 

100.000   

—   

—   12,961   277    13,238   

—   

—   (5,837)    (112)    (5,949) 

 44.9 

  52,223    11,834   

523    —    64,580   

(46)   

(119)   

(100)    —   

(265) 

 0.4 

0.000 to 0.053   12,234   

0.054 to 0.169   15,128   

28   

49   

—    —    12,262   

—    —    15,177   

0.170 to 0.740   16,741    4,086   

—    —    20,827   

0.741 to 1.927   4,931    3,917   

—    —   

8,848   

1.928 to 4.914   2,859    2,797   

—    —   

5,656   

4.915 to 8.860  

103   

8.861 to 15.000  

87   

15.001 to 99.999  

140   

505   

329   

123   

—    —   

—    —   

—    —   

608   

416   

263   

523   

  79,654    2,004   

—    —    81,658   

0.000 to 0.053   62,291   

0.054 to 0.169   8,835   

0.170 to 0.740   5,098   

0.741 to 1.927   2,558   

1.928 to 4.914  

799   

4.915 to 8.860  

8.861 to 15.000  

71   

2   

46   

146   

398   

168   

43   

20   

1   

—    —    62,337   

—    —   

8,981   

—    —   

5,496   

—    —   

2,726   

—    —   

842   

—    —   

—    —   

91   

3   

15.001 to 99.999  

—    1,182   

—    —   

1,182   

100.000   

—   

—   

—    —   

—   

(3)   

(5)   

(12)   

(15)   

(10)   

(1)   

—   

—   

—   

(33)   

(10)   

(7)   

(5)   

(4)   

(1)   

(6)   

—   

—   

—   

—   

(1)   

(9)   

(27)   

(34)   

(22)   

(9)   

(17)   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

(3) 

(6) 

(21) 

(42) 

(44) 

(23) 

(9) 

(17) 

—   

(100)    —   

(100) 

(9)   

—   

—   

(2)   

(4)   

(1)   

—   

—   

(2)   

—   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

(42) 

(10) 

(7) 

(7) 

(8) 

(2) 

(6) 

— 

(2) 

— 

 519,440   140,125   13,484   277    673,326   (1,180)   (2,572)   (5,937)    (112)    (9,801) 

 472,253    59,599    8,315    332   540,499   

(672)   

(920)   

(3,747)   

(99)   

(5,438) 

0.000 to 0.053   44,234   

18   

—    —    44,252   

0.054 to 0.169   92,861    1,013   

—    —    93,874   

(7)   

(20)   

0.170 to 0.740  178,662    11,808   

—    —   190,470   

(164)   

0.741 to 1.927  105,708    17,829   

—    —   123,537   

(244)   

1.928 to 4.914   46,423    16,423   

—    —    62,846   

(190)   

4.915 to 8.860   3,323    7,592   

—    15    10,930   

8.861 to 15.000  

795    3,067   

—   

3    3,865   

15.001 to 99.999  

247    1,849   

—    —    2,096   

100.000   

—   

—    8,315    314    8,629   

(33)   

(11)   

(3)   

—   

—   

(10)   

(91)   

(151)   

(218)   

(141)   

(172)   

(137)   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

(7) 

(30) 

(255) 

(395) 

(408) 

(174) 

(183) 

(140) 

—   

(3,747)   

(99)   

(3,846) 

 44.6 

  65,661    4,832   

212    —    70,705   

(42)   

(28)   

(90)    —   

(160) 

0.000 to 0.053   16,616   

0.054 to 0.169   15,630   

—   

56   

—    —    16,616   

—    —    15,686   

0.170 to 0.740   21,562    1,333   

—    —    22,895   

0.741 to 1.927   7,535    1,169   

—    —    8,704   

1.928 to 4.914   4,024    1,738   

—    —    5,762   

4.915 to 8.860  

280   

517   

—    —   

797   

8.861 to 15.000  

15.001 to 99.999  

100.000   

12   

2   

—   

7   

12   

—   

—    —   

—    —   

19   

14   

212    —   

212   

(1)   

(4)   

(12)   

(12)   

(12)   

(1)   

—   

—   

—   

  67,769    1,450   

—    —    69,219   

(14)   

0.000 to 0.053   49,858   

0.054 to 0.169   10,689   

0.170 to 0.740   5,312   

0.741 to 1.927   1,725   

1.928 to 4.914  

71   

4.915 to 8.860  

113   

8.861 to 15.000  

1   

21   

68   

17   

31   

32   

2   

1   

—    —    49,879   

—    —    10,757   

—    —    5,329   

—    —    1,756   

—    —   

—    —   

—    —   

103   

115   

2   

15.001 to 99.999  

—    1,278   

—    —    1,278   

100.000   

—   

—   

—    —   

—   

(2)   

(7)   

(2)   

(1)   

—   

(2)   

—   

—   

—   

—   

—   

(4)   

(7)   

—    —   

—    —   

—    —   

—    —   

(11)   

—    —   

(4)   

—   

(2)   

—   

(2)   

—   

—   

—   

(1)   

—   

—   

—   

(1)   

—   

—    —   

—    —   

—    —   

(90)    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

(1) 

(4) 

(16) 

(19) 

(23) 

(5) 

— 

(2) 

(90) 

(16) 

(2) 

(7) 

(2) 

(2) 

— 

(2) 

— 

(1) 

— 

 605,683    65,881    8,527    332   680,423   

(728)   

(950)   

(3,837)   

(99)   

(5,614) 

 0.2 

 — 

 — 

 0.1 

 0.2 

 0.4 

 0.6 

 — 

 14.3 

 42.5 

 — 

 — 

 0.1 

 — 

 0.1 

 — 

 1.7 

 — 

 0.1 

 — 

 0.8 

 —  AA- and above

 0.1 

 0.3 

 0.6 

 1.3 

 2.8 

 4.1 

 8.4 

A+ to A-

BBB+ to BBB-

BB+ to BB-

BB- to B

B-

CCC+

CCC to C

D

 —  AA- and above

A+ to A-

BBB+ to BBB-

BB+ to BB-

BB- to B

B-

CCC+

CCC to C

D

 — 

 0.1 

 0.5 

 0.8 

 3.8 

 2.2 

 6.5 

 19.1 

 0.1 

 —  AA- and above

 0.1 

 0.1 

 0.3 

 0.2 

 6.6 

 — 

 0.2 

 — 

 1.5 

 1.0 

 — 

 — 

 0.1 

 0.3 

 0.6 

 1.6 

 4.7 

 6.7 

A+ to A-

BBB+ to BBB-

BB+ to BB-

BB- to B

B-

CCC+

CCC to C

D

AA- and above

A+ to A-

BBB+ to BBB-

BB+ to BB-

BB- to B

B-

CCC+

CCC to C

D

AA- and above

A+ to A-

BBB+ to BBB-

BB+ to BB-

BB- to B

B-

CCC+

CCC to C

D

AA- and above

A+ to A-

BBB+ to BBB-

BB+ to BB-

BB- to B

B-

CCC+

CCC to C

D

HSBC Holdings plc Annual Report and Accounts 2020

149

Risk review 
 
 
 
 
 
 
Risk

Commercial real estate

Commercial real estate lending includes the financing of 
corporate, institutional and high net worth customers who are 
investing primarily in income-producing assets and, to a lesser 
extent, in their construction and development. The portfolio is 
globally diversified with larger concentrations in Hong Kong, 
the UK and the US.

Our global exposure is centred largely on cities with economic, 
political or cultural significance. In more developed markets, our 
exposure mainly comprises the financing of investment assets, the 

redevelopment of existing stock and the augmentation of both 
commercial and residential markets to support economic and 
population growth. In less-developed commercial real estate 
markets, our exposures comprise lending for development assets 
on relatively short tenors with a particular focus on supporting 
larger, better capitalised developers involved in residential 
construction or assets supporting economic expansion.

Commercial real estate lending declined $5bn, including 
favourable foreign exchange movements of $2.4bn, mainly in 
Hong Kong and, to a lesser extent, within the UK.

Commercial real estate lending

Gross loans and advances

Stage 1

Stage 2

Stage 3

POCI

Europe

$m

22,639   

5,549   

1,114   

1   

Asia

$m

63,276   

11,686   

37   

—   

MENA

$m

1,147   

436   

250   

—   

North
 America

Latin 
America 

$m

$m

Total

$m

UK

$m

Hong Kong

$m

Of which:

7,373   

4,093   

42   

—   

1,269   

381   

240   

—   

95,704   

22,145   

1,683   

1   

16,207   

4,299   

966   

—   

48,735 

9,105 

18 

— 

At 31 Dec 2020

–  of which: renegotiated loans

Allowance for ECL

29,303   

74,999   

1,833   

11,508   

1,890   

119,533   

21,472   

57,858 

751   

(650)   

3   

(117)   

201   

(190)   

—   

(64)   

—   

(120)   

955   

(1,141)   

744   

(575)   

— 

(65) 

Gross loans and advances

Stage 1

Stage 2

Stage 3

POCI

At 31 Dec 2019

–  of which: renegotiated loans

Allowance for ECL

25,017   

3,988   

1,115   

1   

76,832   

2,673   

21   

—   

1,507   

10,938   

1,653   

115,947   

18   

208   

—   

508   

33   

—   

41   

27   

—   

7,228   

1,404   

1   

17,953   

2,953   

948   

—   

60,632 

1,696 

17 

— 

30,121   

79,526   

1,733   

11,479   

1,721   

124,580   

21,854   

62,345 

788   

(372)   

—   

(78)   

195   

(170)   

—   

(17)   

—   

(7)   

983   

(644)   

782   

(305)   

— 

(40) 

Refinance risk in commercial real estate

Commercial real estate lending tends to require the repayment of 
a significant proportion of the principal at maturity. Typically, a 
customer will arrange repayment through the acquisition of a new 
loan to settle the existing debt. Refinance risk is the risk that a 

Commercial real estate gross loans and advances maturity analysis

customer, being unable to repay the debt on maturity, fails to 
refinance it at commercial rates. We monitor our commercial real 
estate portfolio closely, assessing indicators for signs of potential 
issues with refinancing.

On demand, overdrafts or revolving

< 1 year

1–2 years

2–5 years

> 5 years

Europe

$m

Asia

$m

MENA

$m

North 
America

Latin 
America

$m

$m

Total

$m

UK  Hong Kong

$m

$m

Of which:

13,728   

25,075   

6,373   

6,241   

2,961   

18,396   

27,699   

3,829   

750   

119   

668   

296   

5,793   

3,112   

2,288   

315   

263   

434   

927   

266   

45,609   

12,131   

28,434   

37,823   

7,667   

4,991   

3,135   

1,215   

19,998 

13,237 

21,694 

2,929 

At 31 Dec 2020

29,303   

74,999   

1,833   

11,508   

1,890   

119,533   

21,472   

57,858 

On demand, overdrafts or revolving

< 1 year

1–2 years

2–5 years

> 5 years

13,808   

6,197   

7,797   

2,319   

21,625   

17,638   

35,557   

4,706   

816   

142   

509   

266   

5,905   

1,548   

3,511   

515   

135   

107   

1,332   

147   

42,289   

25,632   

48,706   

7,953   

11,775   

5,274   

4,347   

458   

At 31 Dec 2019

30,121   

79,526   

1,733   

11,479   

1,721   

124,580   

21,854   

16,937 

13,776 

27,860 

3,772 

62,345 

Collateral and other credit enhancements

(Audited)

Although collateral can be an important mitigant of credit risk, it is 
the Group’s practice to lend on the basis of the customer’s ability 
to meet their obligations out of cash flow resources rather than 
placing primary reliance on collateral and other credit risk 
enhancements. Depending on the customer’s standing and the 
type of product, facilities may be provided without any collateral 
or other credit enhancements. For other lending, a charge over 
collateral is obtained and considered in determining the credit 
decision and pricing. In the event of default, the Group may utilise 
the collateral as a source of repayment.

Depending on its form, collateral can have a significant financial 
effect in mitigating our exposure to credit risk. Where there is 
sufficient collateral, an expected credit loss is not recognised. This 
is the case for reverse repurchase agreements and for certain 
loans and advances to customers where the loan to value (‘LTV’) is 
very low.

Mitigants may include a charge on borrowers’ specific assets, 
such as real estate or financial instruments. Other credit risk 
mitigants include short positions in securities and financial assets 
held as part of linked insurance/investment contracts where the 
risk is predominantly borne by the policyholder. Additionally, risk 
may be managed by employing other types of collateral and credit 
risk enhancements, such as second charges, other liens and 

150

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commercial real estate loans and advances

The value of commercial real estate collateral is determined 
by using a combination of external and internal valuations 
and physical inspections. For CRR 1–7, local valuation policies 
determine the frequency of review on the basis of local market 
conditions because of the complexity of valuing collateral 
for commercial real estate. For CRR 8–10, almost all collateral 
would have been revalued within the last three years.

In Hong Kong, market practice is typically for lending to major 
property companies to be either secured by guarantees or 
unsecured. In Europe, facilities of a working capital nature are 
generally not secured by a first fixed charge, and are therefore 
disclosed as not collateralised.

unsupported guarantees. Guarantees are normally taken from 
corporates and export credit agencies. Corporates would normally 
provide guarantees as part of a parent/subsidiary relationship and 
span a number of credit grades. The export credit agencies will 
normally be investment grade. 

Certain credit mitigants are used strategically in portfolio 
management activities. While single name concentrations arise in 
portfolios managed by Global Banking and Corporate Banking, it is 
only in Global Banking that their size requires the use of portfolio 
level credit mitigants. Across Global Banking, risk limits and 
utilisations, maturity profiles and risk quality are monitored and 
managed proactively. This process is key to the setting of risk 
appetite for these larger, more complex, geographically distributed 
customer groups. While the principal form of risk management 
continues to be at the point of exposure origination, through the 
lending decision-making process, Global Banking also utilises loan 
sales and credit default swap (‘CDS’) hedges to manage 
concentrations and reduce risk. These transactions are the 
responsibility of a dedicated Global Banking portfolio management 
team. Hedging activity is carried out within agreed credit 
parameters, and is subject to market risk limits and a robust 
governance structure. Where applicable, CDSs are entered into 
directly with a central clearing house counterparty. Otherwise, the 
Group’s exposure to CDS protection providers is diversified among 
mainly banking counterparties with strong credit ratings.

CDS mitigants are held at portfolio level and are not included in 
the expected loss calculations. CDS mitigants are not reported in 
the following tables.

Collateral on loans and advances

Collateral held is analysed separately for commercial real estate 
and for other corporate, commercial and financial (non-bank) 
lending. The following tables include off-balance sheet loan 
commitments, primarily undrawn credit lines.

The collateral measured in the following tables consists of 
fixed first charges on real estate, and charges over cash and 
marketable financial instruments. The values in the tables 
represent the expected market value on an open market basis. No 
adjustment has been made to the collateral for any expected costs 
of recovery. Marketable securities are measured at their fair value.

Other types of collateral such as unsupported guarantees and 
floating charges over the assets of a customer’s business are not 
measured in the following tables. While such mitigants have value, 
often providing rights in insolvency, their assignable value is not 
sufficiently certain and they are therefore assigned no value for 
disclosure purposes.

The LTV ratios presented are calculated by directly associating 
loans and advances with the collateral that individually and 
uniquely supports each facility. When collateral assets are shared 
by multiple loans and advances, whether specifically or, more 
generally, by way of an all monies charge, the collateral value is 
pro-rated across the loans and advances protected by the 
collateral.

For credit-impaired loans, the collateral values cannot be directly 
compared with impairment allowances recognised. The LTV 
figures use open market values with no adjustments. Impairment 
allowances are calculated on a different basis, by considering 
other cash flows and adjusting collateral values for costs of 
realising collateral as explained further on page 294.

HSBC Holdings plc Annual Report and Accounts 2020

151

Risk reviewRisk

Wholesale lending – commercial real estate loans and advances including loan commitments by level of collateral for key 
countries/territories (by stage)
(Audited)

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Of which:

$m

%

$m

%

$m

55,376 

71,915 

36,408 

26,081 

5,098 

4,328 

5,477 

3,486 

 0.1   

 0.2   

 0.1   

 0.2   

 0.3   

 0.3   

 0.2   

7,205 

14,053 

4,665 

7,031 

1,932 

425 

1,463 

912 

 0.6   

 0.2   

 0.3   

 0.2   

 0.2   

 0.5   

 0.1   

29,422 

33,386 

22,361 

9,091 

1,093 

841 

769 

594 

132,768 

 0.1   

22,721 

 0.4   

63,577 

8,710 

18,383 

8,544 

8,097 

849 

893 

1,260 

517 

28,353 

1,038 

583 

177 

161 

149 

96 

474 

331 

 1.3   

 1.0   

 0.8   

 1.1   

 1.1   

 1.0   

 1.0   

3,337 

2,534 

1,132 

1,020 

350 

32 

713 

246 

 2.2   

 1.6   

 1.5   

 2.0   

 0.9   

 3.1   

 0.8   

1,084 

8,719 

5,359 

2,955 

319 

86 

196 

147 

 1.1   

6,584 

 1.8   

9,999 

 45.3   

 11.5   

 13.6   

 15.5   

 6.7   

 8.3   

 45.6   

635 

348 

56 

128 

139 

25 

195 

120 

 50.7   

 9.5   

 5.4   

 12.5   

 5.8   

 24.0   

 27.7   

2,095 

 35.9   

1,178 

 34.7   

— 

1 

1 

— 

— 

— 

— 

— 

1 

163,217 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 0.8   

— 

— 

— 

— 

— 

— 

— 

— 

— 

30,483 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 2.0   

— 

20 

11 

3 

— 

6 

— 

— 

20 

— 

— 

— 

— 

— 

— 

— 

— 

— 

73,596 

%

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.1 

 0.5 

 0.4 

 0.8 

 0.3 

 — 

 1.0 

 0.5 

 — 

 5.0 

 — 

 — 

 — 

 16.7 

 — 

 5.0 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.1 

Stage 1

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (A):

–  collateral value on A

Total

Stage 2

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

Stage 3

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (C):

–  collateral value on C

Total

POCI

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (D):

–  collateral value on D

Total

At 31 Dec 2020

152

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale lending – commercial real estate loans and advances including loan commitments by level of collateral for key 
countries/territories (by stage) (continued)

(Audited)

Stage 1

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (A):

–  collateral value on A

Total

Stage 2

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

Stage 3

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (C):

–  collateral value on C

Total

POCI

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (D):

–  collateral value on D

Total

At 31 Dec 2019

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Of which:

$m

%

$m

%

$m

61,820 

89,319 

46,318 

32,583 

5,018 

5,400 

6,563 

3,602 

 0.1   

 0.1   

 0.1   

 0.1   

 0.1   

 0.2   

 0.2   

7,266 

18,535 

7,018 

9,349 

1,649 

519 

682 

535 

 0.1   

 —   

 0.1   

 —   

 0.1   

 —   

 —   

32,478 

41,798 

28,776 

10,815 

1,436 

771 

1,627 

1,142 

157,702 

 0.1   

26,483 

 0.1   

75,903 

3,040 

5,184 

2,167 

1,986 

333 

698 

500 

203 

 1.2   

 1.1   

 1.1   

 0.9   

 2.1   

 1.1   

 0.6   

1,857 

1,419 

615 

712 

16 

76 

296 

56 

 1.2   

 1.2   

 1.8   

 0.6   

 6.3   

 1.3   

 0.3   

440 

1,501 

955 

497 

29 

20 

42 

25 

8,724 

 1.1   

3,572 

 1.1   

1,983 

315 

557 

87 

90 

89 

291 

773 

380 

 57.8   

 14.9   

 16.1   

 7.8   

 15.7   

 16.5   

 41.5   

1,645 

 35.6   

— 

1 

1 

— 

— 

— 

— 

— 

1 

168,072 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 0.5   

66 

404 

42 

69 

72 

221 

507 

166 

977 

— 

— 

— 

— 

— 

— 

— 

— 

— 

31,032 

 92.4   

 12.9   

 7.1   

 4.3   

 4.2   

 19.5   

 27.8   

 26.0   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 1.0   

— 

17 

6 

10 

— 

1 

— 

— 

17 

— 

— 

— 

— 

— 

— 

— 

— 

— 

77,903 

%

 — 

 — 

 — 

 0.1 

 0.1 

 — 

 0.1 

 — 

 0.2 

 0.6 

 0.3 

 1.0 

 — 

 — 

 — 

 0.5 

 — 

 11.8 

 16.7 

 — 

 — 

 — 

 — 

 11.8 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.1 

HSBC Holdings plc Annual Report and Accounts 2020

153

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Wholesale lending – commercial real estate loans and advances including loan commitments by level of collateral for key 
countries/territories
(Audited)

Rated CRR/PD1 to 7

Not collateralised

Fully collateralised

Partially collateralised (A):

–  collateral value on A

Total

Rated CRR/PD8

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

Rated CRR/PD9 to 10

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (C):

–  collateral value on C

Total

At 31 Dec 2020

Rated CRR/PD1 to 7

Not collateralised

Fully collateralised

Partially collateralised (A):

–  collateral value on A

Total

Rated CRR/PD8

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

Rated CRR/PD9 to 10

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (C):

–  collateral value on C

Total

At 31 Dec 2019

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

$m

%

$m

%

$m

%

Of which:

64,046 

89,664 

6,728 

3,994 

 0.3   

 0.3   

 0.4   

160,438 

 0.3   

10,527 

16,483 

2,174 

1,157 

29,184 

 1.1   

 0.4   

 0.3   

30,506 

41,861 

965 

741 

 0.6   

73,332 

40 

634 

282 

321 

14 

17 

9 

9 

 22.5   

 8.2   

 7.1   

 9.0   

 21.4   

 —   

 11.1   

15 

104 

15 

75 

5 

9 

2 

1 

 6.7   

 12.5   

 6.7   

 13.3   

 20.0   

 —   

 50.0   

— 

244 

102 

138 

4 

— 

— 

— 

 — 

 0.1 

 0.2 

 — 

 — 

 12.7 

 11.8 

 13.0 

 25.0 

 — 

 — 

683 

 9.1   

121 

 12.4   

244 

 12.7 

1,038 

584 

178 

161 

149 

96 

474 

331 

2,096 

163,217 

64,850 

94,299 

7,052 

3,796 

 45.3   

 11.5   

 13.5   

 15.5   

 6.7   

 8.3   

 45.6   

 35.9   

 0.8   

 0.1   

 0.1   

 0.2   

635 

348 

56 

128 

139 

25 

195 

120 

1,178 

30,483 

9,119 

19,833 

971 

586 

 50.7   

 9.5   

 5.4   

 12.5   

 5.8   

 24.0   

 27.7   

 34.7   

 2.0   

 0.3   

 0.1   

 0.1   

166,201 

 0.1   

29,923 

 0.1   

10 

204 

47 

120 

25 

12 

11 

9 

225 

315 

557 

87 

90 

89 

291 

774 

380 

1,646 

168,072 

 50.0   

 4.9   

 8.5   

 3.3   

 4.0   

 8.3   

 —   

 6.7   

 57.8   

 14.9   

 16.1   

 7.8   

 15.7   

 16.5   

 41.6   

 35.7   

 0.5   

4 

121 

27 

68 

15 

11 

7 

5 

132 

66 

404 

42 

69 

72 

221 

507 

166 

977 

31,032 

 100.0   

 5.0   

 14.8   

 1.5   

 6.7   

 —   

 —   

 7.6   

 92.4   

 12.9   

 7.1   

 4.3   

 4.2   

 19.5   

 27.8   

 26.0   

 1.0   

— 

20 

11 

3 

— 

6 

— 

— 

20 

73,596 

32,918 

43,299 

1,669 

1,167 

77,886 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

17 

6 

10 

— 

1 

— 

— 

17 

77,903 

 — 

 5.0 

 — 

 — 

 — 

 16.7 

 — 

 5.0 

 0.1 

 — 

 0.1 

 0.1 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 11.8 

 16.7 

 — 

 — 

 100.0 

 — 

 11.8 

 0.1 

154

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Other corporate, commercial and financial (non-bank) loans 
and advances

Other corporate, commercial and financial (non-bank) loans are 
analysed separately in the following table, which focuses on the 
countries/territories containing the majority of our loans and 
advances balances. For financing activities in other corporate and 
commercial lending, collateral value is not strongly correlated 
to principal repayment performance.

Collateral values are generally refreshed when an obligor’s general 
credit performance deteriorates and we have to assess the likely 
performance of secondary sources of repayment should it prove 
necessary to rely on them. 

Accordingly, the following table reports values only for customers 
with CRR 8–10, recognising that these loans and advances 
generally have valuations that are comparatively recent.

Wholesale lending – other corporate, commercial and financial (non-bank) loans and advances including loan commitments by level 
of collateral for key countries/territories (by stage)
(Audited)

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

$m

%

$m

%

$m

%

Of which:

Stage 1

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (A):

–  collateral value on A

Total

Stage 2

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

Stage 3

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (C):

–  collateral value on C

Total

POCI

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (D):

–  collateral value on D

Total

At 31 Dec 2020

617,592 

110,528 

37,991 

36,696 

13,542 

22,299 

52,892 

25,903 

 0.2   

 0.2   

 0.1   

 0.2   

 0.2   

 0.1   

 0.2   

122,554 

28,232 

7,367 

11,891 

2,624 

6,350 

6,826 

3,524 

 0.4   

 0.3   

 0.3   

 0.3   

 0.4   

 0.1   

 0.5   

95,061 

40,207 

14,744 

13,961 

6,522 

4,980 

19,163 

9,208 

781,012 

 0.2   

157,612 

 0.4   

154,431 

118,959 

37,753 

11,992 

16,982 

3,727 

5,052 

16,829 

9,425 

 1.6   

 1.3   

 1.3   

 1.6   

 1.2   

 0.9   

 1.5   

173,541 

 1.5   

7,852 

1,939 

637 

526 

294 

482 

2,847 

1,619 

 50.0   

 17.3   

 24.0   

 19.0   

 9.2   

 11.6   

 35.5   

37,430 

9,316 

2,498 

5,715 

502 

601 

3,984 

1,714 

50,730 

2,793 

585 

151 

182 

211 

41 

553 

337 

 2.6   

 2.1   

 1.5   

 2.2   

 3.2   

 2.0   

 2.7   

19,466 

15,044 

3,920 

6,657 

2,150 

2,317 

3,849 

2,104 

 2.5   

38,359 

 28.5   

 7.9   

 8.6   

 12.6   

 1.9   

 14.6   

 23.1   

865 

342 

83 

128 

49 

82 

592 

322 

 0.1 

 0.1 

 0.1 

 0.2 

 0.1 

 0.1 

 0.1 

 0.1 

 0.4 

 0.8 

 0.7 

 1.0 

 0.7 

 0.3 

 0.9 

 0.6 

 66.0 

 6.4 

 6.0 

 4.7 

 14.3 

 4.9 

 26.4 

12,638 

 41.7   

3,931 

 24.7   

1,799 

 41.6 

211 

63 

6 

11 

34 

12 

4 

4 

278 

967,469 

 39.8   

 41.3   

 50.0   

 9.1   

 64.7   

 —   

 75.0   

 40.6   

 1.0   

54 

— 

— 

— 

— 

— 

— 

— 

54 

212,327 

 63.0   

 —   

 —   

 —   

 —   

 —   

 —   

 63.0   

 1.3   

1 

45 

— 

11 

34 

— 

— 

— 

46 

194,635 

 — 

 51.1 

 — 

 9.1 

 64.7 

 — 

 — 

 50.0 

 0.6 

HSBC Holdings plc Annual Report and Accounts 2020

155

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Wholesale lending – other corporate, commercial and financial (non-bank) loans and advances including loan commitments by level 
of collateral for key countries/territories (by stage) (continued)
(Audited)

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Of which:

%

 — 

 0.1 

 0.1 

 0.1 

 0.1 

 0.1 

 0.1 

 — 

 0.7 

 0.6 

 0.6 

 0.7 

 0.5 

 0.2 

 0.4 

 0.6 

 83.5 

 12.8 

 33.3 

 4.8 

 7.5 

 25.0 

 48.3 

$m

%

$m

%

$m

680,079 

128,290 

48,012 

37,891 

13,072 

29,315 

52,890 

25,824 

 0.1   

 0.1   

 0.1   

 0.1   

 0.1   

 —   

 0.1   

132,197 

40,172 

13,831 

11,903 

3,399 

11,039 

8,122 

3,809 

 0.2   

 0.1   

 0.1   

 0.2   

 0.2   

 —   

 0.1   

116,536 

32,818 

11,009 

12,783 

4,697 

4,329 

20,162 

9,616 

861,259 

 0.1   

180,491 

 0.2   

169,516 

61,540 

21,126 

7,081 

8,482 

2,684 

2,879 

8,463 

3,669 

 1.2   

 0.8   

 0.9   

 0.9   

 0.9   

 0.6   

 0.8   

91,129 

 1.1   

 49.2   

 22.4   

 35.2   

 24.4   

 23.6   

 9.1   

 44.8   

4,768 

1,479 

335 

352 

373 

419 

1,367 

693 

7,614 

223 

28 

2 

26 

— 

— 

97 

57 

348 

960,350 

13,318 

3,139 

1,208 

1,111 

282 

538 

1,516 

370 

17,973 

1,899 

494 

103 

198 

101 

92 

369 

192 

 2.2   

 1.8   

 2.0   

 1.8   

 2.1   

 1.3   

 1.4   

13,308 

12,934 

3,845 

5,580 

1,646 

1,863 

3,768 

1,801 

 2.1   

30,010 

 33.0   

 12.6   

 17.5   

 8.6   

 20.8   

 7.6   

 20.1   

504 

86 

9 

21 

40 

16 

87 

34 

 43.2   

2,762 

 27.6   

677 

 70.0 

 32.7   

 3.6   

 50.0   

 —   

 —   

 —   

 33.0   

 30.5   

 0.5   

32 

— 

— 

— 

— 

— 

57 

19 

89 

201,315 

 96.9   

 —   

 —   

 —   

 —   

 —   

 1.8   

 36.0   

 0.7   

7 

10 

— 

10 

— 

— 

31 

30 

48 

200,251 

 — 

 — 

 — 

 — 

 — 

 — 

 90.3 

 58.3 

 0.4 

Stage 1

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (A):

–  collateral value on A

Total

Stage 2

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

Stage 3

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (C):

–  collateral value on C

Total

POCI

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (D):

–  collateral value on D

Total

At 31 Dec 2019

156

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale lending – other corporate, commercial and financial (non-bank) loans and advances including loan commitments by level 
of collateral for key countries/territories
(Audited)

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

$m

%

$m

%

$m

%

Of which:

Rated CRR/PD8

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (A):

–  collateral value on A

Total

Rated CRR/PD9 to 10

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

At 31 Dec 2020

Rated CRR/PD8

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (A):

–  collateral value on A

Total

Rated CRR/PD9 to 10

Not collateralised

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 75%

–  76% to 90%

–  91% to 100%

Partially collateralised (B):

–  collateral value on B

Total

At 31 Dec 2019

3,787 

1,107 

269 

480 

140 

218 

493 

352 

 7.1   

 5.2   

 4.1   

 6.3   

 5.0   

 4.1   

 8.1   

5,387 

 6.8   

8,062 

2,003 

644 

538 

327 

494 

2,851 

1,623 

12,916 

18,303 

2,499 

694 

246 

189 

97 

162 

279 

152 

 49.7   

 18.1   

 24.2   

 18.8   

 15.0   

 11.3   

 35.6   

 41.7   

 31.4   

 5.8   

 3.3   

 2.8   

 4.2   

 2.1   

 3.7   

 4.7   

3,472 

 5.2   

4,991 

1,507 

338 

377 

373 

419 

1,464 

750 

7,962 

11,434 

 48.5   

 22.0   

 35.2   

 22.8   

 23.6   

 9.1   

 44.0   

 42.7   

 31.3   

924 

171 

29 

87 

13 

42 

174 

83 

1,269 

2,847 

585 

151 

182 

211 

41 

553 

337 

3,985 

5,254 

285 

382 

120 

93 

42 

127 

53 

34 

720 

1,930 

494 

103 

198 

101 

92 

427 

211 

2,851 

3,571 

 8.7   

 9.4   

 10.3   

 6.9   

 23.1   

 9.5   

 9.2   

103 

15 

 25.2 

 — 

1 

— 

14 

— 

27 

13 

 — 

 — 

 — 

 — 

 3.7 

 8.7   

145 

 18.6 

 29.1   

 7.9   

 8.6   

 12.6   

 1.9   

 14.6   

 23.1   

 25.2   

 21.2   

 13.0   

 2.6   

 1.7   

 3.2   

 2.4   

 3.9   

 5.7   

 6.9   

 34.1   

 12.6   

 17.5   

 8.6   

 20.8   

 7.6   

 17.6   

 27.9   

 23.7   

865 

388 

84 

139 

83 

82 

592 

322 

1,845 

1,990 

10 

— 

— 

— 

— 

— 

73 

6 

83 

510 

96 

10 

30 

40 

16 

119 

64 

725 

808 

 66.0 

 11.6 

 6.0 

 5.0 

 34.9 

 4.9 

 26.4 

 41.8 

 40.2 

 70.0 

 — 

 — 

 — 

 — 

 — 

 2.7 

 12.0 

 82.5 

 11.5 

 — 

 3.3 

 7.5 

 — 

 58.8 

 69.2 

 63.4 

Other credit risk exposures

In addition to collateralised lending, other credit enhancements are 
employed and methods used to mitigate credit risk arising from 
financial assets. These are summarised below:

• Some securities issued by governments, banks and other 

financial institutions benefit from additional credit 
enhancements provided by government guarantees 
that cover the assets.

• Debt securities issued by banks and financial institutions 

include asset-backed securities (‘ABSs’) and similar 
instruments, which are supported by underlying pools of 
financial assets. Credit risk associated with ABSs is reduced 
through the purchase of credit default swap (‘CDS’) protection.

• Trading loans and advances mainly pledged against cash 

collateral are posted to satisfy margin requirements. There is 
limited credit risk on cash collateral posted since in the event of 

default of the counterparty this would be set off against the 
related liability. Reverse repos and stock borrowing are by their 
nature collateralised.

Collateral accepted as security that the Group is permitted to sell or repledge 
under these arrangements is described on page 330 of the financial 
statements.

• The Group’s maximum exposure to credit risk includes financial 
guarantees and similar contracts granted, as well as loan and 
other credit-related commitments. Depending on the terms of 
the arrangement, we may use additional credit mitigation if a 
guarantee is called upon or a loan commitment is drawn and 
subsequently defaults.

For further information on these arrangements, see Note 32 on the financial 
statements.

HSBC Holdings plc Annual Report and Accounts 2020

157

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Derivatives

We participate in transactions exposing us to counterparty credit 
risk. Counterparty credit risk is the risk of financial loss if the 
counterparty to a transaction defaults before satisfactorily settling 
it. It arises principally from over-the-counter (‘OTC’) derivatives 
and securities financing transactions and is calculated in both the 
trading and non-trading books. Transactions vary in value by 
reference to a market factor such as an interest rate, exchange 
rate or asset price.

Notional contract amounts and fair values of derivatives 

The counterparty risk from derivative transactions is taken into 
account when reporting the fair value of derivative positions. The 
adjustment to the fair value is known as the credit valuation 
adjustment (‘CVA’).

For an analysis of CVAs, see Note 12 on the financial statements.

The following table reflects by risk type the fair values and gross 
notional contract amounts of derivatives cleared through an 
exchange, central counterparty or non-central counterparty. 

Notional

amount

$m

2020

Fair value

Assets

Liabilities

$m

$m

Notional

amount

$m

2019

Fair value

Assets

Liabilities

$m

$m

Total OTC derivatives

 22,749,280   

372,373   

368,010    26,244,531   

282,778   

279,101 

–  total OTC derivatives cleared by central counterparties

  9,898,260   

74,054   

75,253    12,563,343   

45,140   

46,351 

–  total OTC derivatives not cleared by central counterparties

 12,851,020   

298,319   

292,757    13,681,188   

237,638   

232,750 

Total exchange traded derivatives

Gross

Offset

At 31 Dec

  1,332,438   

4,456   

4,094   

1,583,590   

1,956   

2,135 

 24,081,718   

376,829   

372,104    27,828,121   

284,734   

281,236 

(69,103)   

(69,103) 

307,726   

303,001 

(41,739)   

(41,739) 

242,995   

239,497 

The purposes for which HSBC uses derivatives are described in Note 15 on 
the financial statements.

commitments and guarantees, and foreign exchange movements, 
increased $1.6bn to $4.7bn at 31 December 2020.

Excluding foreign exchange movements, total personal lending 
was primarily driven by mortgage growth, which grew by $21.5bn. 
Mortgages grew $12.3bn in the UK; $6.4bn in Asia, notably $4.7bn 
in Hong Kong and $1.6bn in Australia; and $1.8bn in Canada. The 
allowance for ECL, excluding foreign exchange, attributable to 
mortgages of $0.8bn increased $0.2bn compared with 
31 December 2019.

The quality of both our Hong Kong and UK mortgage books 
remained high, with low levels of impairment allowances. The 
average LTV ratio on new mortgage lending in Hong Kong was 
61%, compared with an estimated 45% for the overall mortgage 
portfolio. The average LTV ratio on new lending in the UK was 
70%, compared with an estimated 51% for the overall mortgage 
portfolio. 

Excluding foreign exchange movements, other personal lending 
balances at 31 December 2020 declined by $6.5bn compared with 
31 December 2019. The decline was attributable to a $3.8bn 
decline in credit cards and a $2.4bn decline in loans and 
overdrafts.

The $3.8bn decrease in credit card lending was attributable to 
declines of $2.1bn in the UK, $0.5bn in Hong Kong and $0.3bn in 
the US. The $2.4bn decrease in loans and overdrafts was 
attributable to declines of $1.1bn in Hong Kong, $1.4bn in the UK, 
$0.5bn in Singapore and $0.3bn in MENA. These declines were 
partly offset by growth of $1bn in France, primarily in other 
personal lending guaranteed by Crédit Logement and $0.5bn in 
Switzerland.

The allowance for ECL, excluding foreign exchange, attributable to 
other personal lending of $4.0bn increased $1.4bn compared with 
31 December 2019. Excluding foreign exchange, the allowance for 
ECL attributable to credit cards increased by $0.7bn while loans 
and overdrafts increased by $0.7bn. 

The International Swaps and Derivatives Association (‘ISDA’) 
master agreement is our preferred agreement for documenting 
derivatives activity. It is common, and our preferred practice, 
for the parties involved in a derivative transaction to execute a 
credit support annex (‘CSA’) in conjunction with the ISDA master 
agreement. Under a CSA, collateral is passed between the parties 
to mitigate the counterparty risk inherent in outstanding positions. 
The majority of our CSAs are with financial institutional clients.

We manage the counterparty exposure on our OTC derivative 
contracts by using collateral agreements with counterparties and 
netting agreements. Currently, we do not actively manage 
our general OTC derivative counterparty exposure in the credit 
markets, although we may manage individual exposures in certain 
circumstances.

We place strict policy restrictions on collateral types and as a 
consequence the types of collateral received and pledged are, by 
value, highly liquid and of a strong quality, being predominantly 
cash.

Where a collateral type is required to be approved outside the 
collateral policy, approval is required from a committee of senior 
representatives from Markets, Legal and Risk.

See page 352 and Note 30 on the financial statements for details regarding 
legally enforceable right of offset in the event of counterparty default and 
collateral received in respect of derivatives.

Personal lending

This section presents further disclosures related to personal 
lending. It provides details of the regions, countries and products 
that are driving the change observed in personal loans and 
advances to customers, with the impact of foreign exchange 
separately identified. Additionally, Hong Kong and UK mortgage 
book LTV data is provided.

This section also provides a reconciliation of the opening 
1 January 2020 to 31 December 2020 closing gross carrying/
nominal amounts and associated allowance for ECL.

Further product granularity is also provided by stage, with 
geographical data presented for loans and advances to customers, 
loan and other credit-related commitments and financial 
guarantees.

At 31 December 2020, total personal lending for loans and 
advances to customers of $461bn increased by $26.5bn compared 
with 31 December 2019. This increase included favourable foreign 
exchange movements of $11.5bn. Excluding foreign exchange 
movements, there was growth of $15.1bn, primarily driven by 
$10.1bn in Europe and $3.4bn in Asia. The allowance for ECL 
attributable to personal lending, excluding off-balance sheet loan 

158

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
Total personal lending for loans and advances to customers at amortised cost by stage distribution

Gross carrying amount

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

$m

Total

$m

Stage 1

Stage 2

Stage 3

$m

$m

$m

By portfolio

First lien residential mortgages

–  of which: interest only (including offset)

–  affordability (including US adjustable rate 

mortgages)

Other personal lending 

–  other

–  credit cards

–  second lien residential mortgages

–  motor vehicle finance

336,666   
29,143   

12,233   

3,383   

352,282   

3,074   

351   

32,568   

13,265   

2,209   

606   

16,080   

93,468   

12,831   

2,228   

108,527   

74,174   

17,327   

593   

1,374   

7,288   

5,292   

100   

151   

1,489   

82,951   

680   

23,299   

51   

8   

744   

1,533   

(125)   

(9)   

(11)   

(702)   

(305)   

(386)   

(3)   

(8)   

Total

$m

(755) 

(116) 

(188)   

(19)   

(442)   

(88)   

(11)   

(5)   

(27) 

(2,214)   

(1,060)   

(914)   

(1,281)   

(9)   

(10)   

(665)   

(380)   

(10)   

(5)   

(3,976) 

(1,884) 

(2,047) 

(22) 

(23) 

At 31 Dec 2020

By geography

Europe 

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2020

430,134   

25,064   

5,611   

460,809   

(827)   

(2,402)   

(1,502)   

(4,731) 

200,120   

11,032   

2,511   

213,663   

163,338   

178,175   

118,252   

4,879   

40,387   

6,573   

9,476   

7,969   

5,133   

403   

4,613   

1,047   

1,721   

174,535   

1,169   

187,313   

206   

123,591   

251   

5,533   

1,378   

46,378   

302   

7,922   

430,134   

25,064   

5,611   

460,809   

(247)   

(223)   

(234)   

(102)   

(54)   

(93)   

(199)   

(827)   

(1,271)   

(1,230)   

(446)   

(237)   

(112)   

(200)   

(373)   

(826)   

(545)   

(241)   

(48)   

(152)   

(132)   

(151)   

(2,344) 

(1,998) 

(921) 

(387) 

(318) 

(425) 

(723) 

(2,402)   

(1,502)   

(4,731) 

Total personal lending for loans and other credit-related commitments and financial guarantees by stage distribution

Nominal amount

Allowance for ECL

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2020

Stage 1

Stage 2

Stage 3

$m

56,920   

54,348   

156,057   

118,529   

2,935   

15,835   

3,462   

$m

719   

435   

790   

10   

46   

124   

28   

$m

96   

92   

11   

10   

8   

38   

1   

Total

$m

57,735   

54,875   

156,858   

118,549   

2,989   

15,997   

3,491   

235,209   

1,707   

154   

237,070   

$m

(22)   

(21)   

—   

—   

(1)   

(11)   

(5)   

(39)   

$m

$m

(2)   

(2)   

—   

—   

—   

—   

—   

(2)   

—   

—   

—   

—   

—   

—   

—   

—   

Stage 1

Stage 2

Stage 3

Total

Total personal lending for loans and advances to customers at amortised cost by stage distribution (continued)

By portfolio

First lien residential mortgages

–  of which: interest only (including offset) 

–  affordability (including US adjustable rate 

mortgages)

Other personal lending

–  other

–  credit cards

–  second lien residential mortgages

–  motor vehicle finance

At 31 Dec 2019

By geography

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2019

Gross carrying amount

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

$m

Total

$m

Stage 1

Stage 2

Stage 3

$m

$m

$m

312,031   

31,201   

14,222   

101,638   

77,031   

22,285   

750   

1,572   

7,077   

1,602   

796   

8,674   

4,575   

3,959   

84   

56   

3,070   

322,178   

376   

33,179   

514   

15,532   

1,781   

1,193   

524   

55   

9   

112,093   

82,799   

26,768   

889   

1,637   

(39)   

(6)   

(3)   

(544)   

(229)   

(310)   

(1)   

(4)   

(68)   

(15)   

(3)   

(1,268)   

(451)   

(801)   

(6)   

(10)   

(422)   

(91)   

(3)   

(793)   

(491)   

(284)   

(10)   

(8)   

413,669   

15,751   

4,851   

434,271   

(583)   

(1,336)   

(1,215)   

(3,134) 

186,561   

153,313   

173,523   

117,013   

5,671   

41,148   

6,766   

6,854   

5,455   

5,855   

2,751   

247   

1,930   

865   

2,335   

1,612   

717   

189   

299   

195,750   

160,380   

180,095   

119,953   

6,217   

1,238   

44,316   

262   

7,893   

413,669   

15,751   

4,851   

434,271   

(112)   

(104)   

(223)   

(90)   

(50)   

(56)   

(142)   

(583)   

(538)   

(513)   

(339)   

(220)   

(58)   

(119)   

(282)   

(578)   

(370)   

(170)   

(44)   

(189)   

(141)   

(137)   

(1,228) 

(987) 

(732) 

(354) 

(297) 

(316) 

(561) 

(1,336)   

(1,215)   

(3,134) 

HSBC Holdings plc Annual Report and Accounts 2020

159

$m

(24) 

(23) 

— 

— 

(1) 

(11) 

(5) 

(41) 

Total

$m

(529) 

(112) 

(9) 

(2,605) 

(1,171) 

(1,395) 

(17) 

(22) 

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Total personal lending for loans and other credit-related commitments and financial guarantees by stage distribution (continued)

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2019

Stage 1

$m

51,575   

49,322   

149,336   

115,025   

3,150   

13,919   

4,312   

Nominal amount

Stage 2

Stage 3

$m

604   

493   

682   

27   

46   

256   

43   

$m

110   

105   

9   

3   

53   

20   

3   

Total

$m

52,289   

49,920   

150,027   

115,055   

3,249   

14,195   

4,358   

Stage 1

$m

(10)   

(8)   

—   

—   

—   

(1)   

(3)   

222,292   

1,631   

195   

224,118   

(14)   

Allowance for ECL

Stage 2

$m

Stage 3

$m

(2)   

(1)   

—   

—   

—   

—   

—   

(2)   

—   

—   

—   

—   

—   

—   

—   

—   

Total

$m

(12) 

(9) 

— 

— 

— 

(1) 

(3) 

(16) 

Exposure to UK interest-only mortgage loans

The following information is presented for HSBC branded UK 
interest-only mortgage loans with balances of $15.0bn. This 
excludes offset mortgages in the first direct brand and Private 
Bank mortgages.  

Of the interest-only mortgages that expired in 2018, 89% were 
repaid within 12 months of expiry with a total of 98% being repaid 
within 24 months of expiry. For interest-only mortgages expiring 
during 2019, 89% were fully repaid within 12 months of expiry.

The profile of maturing UK interest-only loans is as follows:

At the end of 2020, the average LTV ratio in the portfolio was 41% 
and 99% of mortgages had an LTV ratio of 75% or less. 

UK interest-only mortgage loans 

Expired interest-only mortgage loans

Interest-only mortgage loans by maturity

– 2021

– 2022

– 2023

– 2024

– 2025–2029

– Post 2029

At 31 Dec 2020

$m

169 

356 

392 

500 

407 

3,317 

9,914 

15,055 

Exposure to offset mortgage in first direct

The offset mortgage in first direct is a flexible way for our 
customers to take control of their finances. It works by grouping 
together the customer’s mortgage, savings and current accounts 

to off-set their credit and debit balances against their mortgage 
exposure which at the end of 2020 is of $8.6bn with an average 
LTV ratio of 37%. 

Personal lending – reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to 
customers including loan commitments and financial guarantees
(Audited)

Non-credit impaired

Stage 1

Stage 2

Credit impaired

Stage 3

Total

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

$m

$m

$m

$m

$m

$m

$m

$m

At 1 Jan 2020

Transfers of financial instruments

  635,961   

(597)    17,382   

(1,338)   

(16,019)   

(629)    13,370   

1,181   

Net remeasurement of ECL arising from transfer of stage

—   

431   

—   

30,891   

101   

(5,407)   

—   

—   

—   

(147)   

(3)   

—   

—   

—   

—   

14,513   

(22)   

1,425   

(1,215)    658,389   

(3,150) 

5,046   

2,649   

—   

(677)   

(552)   

(8)   

—   

—   

150   

24,807   

—   

—   

(1,258)   

5   

—   

—   

(1,409)   

1,407   

(1,409)   

153   

(32)   

16,091   

(555)   

408   

(2,025)   

(9)   

—   

(67)   

  665,346   

(866)    26,770   

(2,405)   

5,762   

(1,503)    697,878   

Net new and further lending/repayments

Change in risk parameters – credit quality 

Changes to models used for ECL calculation

Assets written off

Foreign exchange and other

At 31 Dec 2020

ECL income statement change for the period

382 

(2,181) 

(1,111) 

Recoveries

Other

Total ECL income statement change for the period

— 

(132) 

659 

(3,430) 

(7) 

1,407 

(121) 

(4,774) 

(2,910) 

280 

(25) 

(2,655) 

As shown in the above table, the allowance for ECL for loans and 
advances to customers and banks and relevant loan commitments 
and financial guarantees increased $1,624m during the period 
from $3,150m at 31 December 2019 to $4,774m at 31 December 
2020.
This increase was primarily driven by:
• $3,430m relating to underlying credit quality changes, including 
the credit quality impact of financial instruments transferring 
between stages;   

• $132m relating to the net remeasurement impact of stage 

transfers;

• foreign exchange and other movements of $121m; and
• $7m due to changes to models used for ECL calculation.

These were partly offset by:
• $1,407m of assets written off;
• $659m relating to volume movements, which included the ECL 

allowance associated with new originations, assets 
derecognised and further lending/repayments.

160

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The ECL charge for the period of $2,910m presented in the above 
table consisted of $3,430m relating to underlying credit quality 
changes, including the credit quality impact of financial 
instruments transferring between stages, $132m relating to the 

net remeasurement impact of stage transfers and $7m in changes 
to models used for ECL calculation. This was partly offset by 
$659m relating to underlying net book volume movements.

Personal lending – reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to customers
including loan commitments and financial guarantees (continued)
(Audited)

Non-credit impaired

Stage 1

Stage 2

Credit impaired

Stage 3

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Total

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

$m

(547)   
(374)   

$m

$m

16,838   
2,645   

(1,266)   
858   

$m

4,993   
2,106   

$m

$m

(1,148)   
(484)   

602,615   
—   

Gross 
carrying/ 
nominal 
amount

$m

580,784   
(4,751)   

—   

446   

—   

50,946   

3   

(2,348)   

—   

—   

—   

8,982   

635,961   

(100)   

(6)   

—   

(19)   

(597)   

343 

(408)   

453   

(1,015)   

60   

—   

(20)   

—   

(758)   

—   

—   

(76)   

281   

(1,190)   

14   

(1,345)   

1,345   

50   

43   

—   

47,840   

—   

—   

(1,345)   

9,279   

—   

—   

—   

247   

17,382   

(1,338)   

5,046   

(1,215)   

658,389   

(910) 

(971) 

At 1 Jan 2019
Transfers of financial instruments

Net remeasurement of ECL arising from transfer of 
stage

Net new and further lending/repayments

Change in risk parameters – credit quality

Changes to models used for ECL calculation

Assets written off

Foreign exchange and other

At 31 Dec 2019

ECL income statement change for the period

Recoveries

Other
Total ECL income statement change for the period

Personal lending – credit risk profile by internal PD band for loans and advances to customers at amortised cost 

Gross carrying amount

Allowance for ECL

First lien residential 
mortgages

–  Band 1

–  Band 2

–  Band 3

–  Band 4

–  Band 5

–  Band 6

–  Band 7

PD range1

Stage 1

Stage 2

Stage 3

Total

Stage 1

Stage 2

Stage 3

%

$m

$m

$m

$m

$m

$m

$m

Total

$m

  336,666    12,233   

3,383    352,282   

(125)   

(188)   

(442)   

(755) 

0.000 to 0.250   284,252   

1,283   

—    285,535   

0.251 to 0.500   16,259   

302   

—    16,561   

0.501 to 1.500   27,055   

1,755   

—    28,810   

1.501 to 5.000  

8,858   

5,134   

—    13,992   

5.001 to 20.000  

238   

1,806   

20.001 to 99.999  

100.000  

4   

—   

1,953   

—   

—   

2,044   

1,957   

—   

3,383   

3,383   

(36)   

(9)   

(64)   

(15)   

(1)   

—   

—   

(3)   

(3)   

(8)   

(32)   

(41)   

(101)   

—   

—   

—   

—   

—   

—   

—   

(442)   

(39) 

(12) 

(72) 

(47) 

(42) 

(101) 

(442) 

Other personal lending 

  93,468    12,831   

2,228    108,527   

(702)   

(2,214)   

(1,060)   

(3,976) 

–  Band 1

–  Band 2

–  Band 3

–  Band 4

–  Band 5

–  Band 6

–  Band 7

0.000 to 0.250   41,565   

0.251 to 0.500   13,053   

589   

518   

—    42,154   

—    13,571   

0.501 to 1.500   23,802   

1,280   

—    25,082   

1.501 to 5.000   11,787   

2,175   

—    13,962   

5.001 to 20.000  

3,234   

5,288   

20.001 to 99.999  

100.000  

27   

—   

2,981   

—   

—   

8,522   

3,008   

—   

2,228   

2,228   

(96)   

(31)   

(108)   

(270)   

(197)   

—   

—   

(8)   

(63)   

(37)   

(112)   

(821)   

(1,173)   

—   

—   

—   

—   

—   

—   

(104) 

(94) 

(145) 

(382) 

(1,018) 

(1,173) 

—   

(1,060)   

(1,060) 

At 31 Dec 2020

  430,134    25,064   

5,611    460,809   

(827)   

(2,402)   

(1,502)   

(4,731) 

First lien residential 
mortgages

–  Band 1

–  Band 2

–  Band 3

–  Band 4

–  Band 5

–  Band 6

–  Band 7

  312,031   

7,077   

3,070    322,178   

0.000 to 0.250   268,490   

0.251 to 0.500  

22,293   

0.501 to 1.500  

17,247   

1.501 to 5.000  

3,796   

5.001 to 20.000  

198   

20.001 to 99.999  

100.000  

7   

—   

284   

301   

2,313   

1,970   

1,383   

826   

—   

—    268,774   

—   

—   

—   

—   

—   

22,594   

19,560   

5,766   

1,581   

833   

3,070   

3,070   

Other personal lending

  101,638   

8,674   

1,781    112,093   

–  Band 1

–  Band 2

–  Band 3

–  Band 4

–  Band 5

–  Band 6

–  Band 7

0.000 to 0.250  

46,533   

0.251 to 0.500  

16,435   

0.501 to 1.500  

25,160   

1.501 to 5.000  

10,951   

5.001 to 20.000  

2,421   

20.001 to 99.999  

100.000  

138   

—   

60   

65   

317   

3,483   

3,434   

1,315   

—   

—   

—   

—   

—   

—   

—   

1,781   

46,593   

16,500   

25,477   

14,434   

5,855   

1,453   

1,781   

(39)   

(16)   

(4)   

(13)   

(5)   

(1)   

—   

—   

(544)   

(120)   

(38)   

(110)   

(144)   

(132)   

—   

—   

(68)   

(422)   

(529)   

—   

—   

(3)   

(7)   

(23)   

(35)   

—   

(1,268)   

—   

(26)   

(13)   

(329)   

(440)   

(460)   

—   

—   

—   

—   

—   

—   

—   

(422)   

(793)   

—   

—   

—   

—   

—   

—   

(793)   

(16)   

(4)   

(16)   

(12)   

(24)   

(35)   

(2,605)   

(120)   

(64)   

(123)   

(473)   

(572)   

(460)   

(793)   

At 31 Dec 2019

  413,669   

15,751   

4,851    434,271   

(583)   

(1,336)   

(1,215)   

(3,134)   

1  12-month point in time adjusted for multiple economic scenarios.

(422)   

13.7 

HSBC Holdings plc Annual Report and Accounts 2020

161

$m

(2,961) 
— 

(38) 

737 

(2,305) 

68 

1,345 

4 

(3,150) 

(1,538) 

314 

4 
(1,220) 

ECL 
coverage

%

 0.2 

 — 

 0.1 

 0.2 

 0.3 

 2.1 

 5.2 

 13.1 

 3.7 

 0.2 

 0.7 

 0.6 

 2.7 

 11.9 

 39.0 

 47.6 

 1.0 

0.2 

— 

— 

0.1 

0.2 

1.5 

4.2 

2.3 

0.3 

0.4 

0.5 

3.3 

9.8 

31.7 

44.5 

0.7 

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Collateral on loans and advances 

(Audited)

The following table provides a quantification of the value of fixed 
charges we hold over specific assets where we have a history 
of enforcing, and are able to enforce, collateral in satisfying a debt 
in the event of the borrower failing to meet its contractual 

obligations, and where the collateral is cash or can be realised by 
sale in an established market. The collateral valuation excludes 
any adjustments for obtaining and selling the collateral and, in 
particular, loans shown as not collateralised or partially 
collateralised may also benefit from other forms of credit 
mitigants.

Personal lending – residential mortgage loans including loan commitments by level of collateral for key countries/territories by stage

(Audited)

Stage 1

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 60%

–  61% to 70%

–  71% to 80%

–  81% to 90%

–  91% to 100%

Partially collateralised (A):

LTV ratio:

–  101% to 110%

–  111% to 120%

–  greater than 120%

–  collateral value on A

Total

Stage 2

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 60%

–  61% to 70%

–  71% to 80%

–  81% to 90%

–  91% to 100%

Partially collateralised (B):

LTV ratio:

–  101% to 110%

–  111% to 120%

–  greater than 120%

–  collateral value on B

Total

Stage 3

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 60%

–  61% to 70%

–  71% to 80%

–  81% to 90%

–  91% to 100%

Partially collateralised (C):

LTV ratio:

–  101% to 110%

–  111% to 120%

–  greater than 120%

–  collateral value on C

Total

At 31 Dec 2020

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Of which:

$m

%

$m

%

$m

354,102 

 —   

159,562 

174,370   

60,180 

48,159 

40,395 

23,339 

7,659 

973 

592 

101 

280 

847 

—   

 —   

 —   

 0.1   

 0.1   

 0.1   

0.4  

0.4  

0.5  

0.3  

76,535 

23,967 

23,381 

20,846 

12,936 

1,897 

289 

84 

45 

160 

212 

355,075 

 —   

159,851 

 —   

 —   

 —   

 —   

 —   

 —   

 0.1   

 —   

 —   

 —   

 —   

 —   

90,733 

54,866 

14,253 

6,042 

4,288 

6,837 

4,447 

336 

334 

— 

2 

328 

91,069 

12,252 

1.5  

4,229 

1.4  

1,802 

6,694 

2,223 

1,779 

987 

400 

169 

53 

28 

9 

16 

47 

1.1  

1.1  

1.6  

2.8  

4.9  

5.7  

13.6  

11.9  

16.8  

14.8  

2,442 

730 

606 

244 

139 

68 

4 

3 

— 

1 

4 

1.2  

1.3  

1.3  

2.9  

3.6  

3.3  

3.3  

1.5  

—  

8.5  

1,256 

253 

83 

111 

60 

39 

9 

9 

— 

— 

9 

12,305 

1.5  

4,233 

1.4  

1,811 

3,083 

9.8  

1,050 

12.3

1,472 

505 

435 

378 

195 

98 

328 

75 

56 

197 

228 

3,411 

370,791 

8.0  

8.7  

9.2  

11.5  

17.3  

24.3  

42.7  

30.4  

38.8  

48.5  

13.0  

0.2  

676 

144 

112 

81 

28 

9 

17 

9 

5 

3 

10 

1,067 

165,151 

10.9  

15.1  

12.9  

13.7  

22.4  

17.8  

22.9  

16.7  

17.6  

50.3  

12.5

0.1  

63

53 

6 

— 

2 

2 

— 

— 

— 

— 

— 

1 

63

92,943 

%

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

162

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Personal lending – residential mortgage loans including loan commitments by level of collateral for key countries/territories by stage
(continued)
(Audited)

Total

UK

Hong Kong

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Of which:

Stage 1

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 60%

–  61% to 70%

–  71% to 80%

–  81% to 90%

–  91% to 100%

Partially collateralised (A):

LTV ratio:

–  101% to 110%

–  111% to 120%

–  greater than 120%

–  collateral value on A

Total

Stage 2

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 60%

–  61% to 70%

–  71% to 80%

–  81% to 90%

–  91% to 100%

Partially collateralised (B):

LTV ratio:

–  101% to 110%

–  111% to 120%

–  greater than 120%

–  collateral value on B

Total

Stage 3

Fully collateralised 

LTV ratio:

–  less than 50%

–  51% to 60%

–  61% to 70%

–  71% to 80%

–  81% to 90%

–  91% to 100%

Partially collateralised (C):

LTV ratio:

–  101% to 110%

–  111% to 120%

–  greater than 120%

–  collateral value on C

Total

At 31 Dec 2019

$m

%

$m

%

$m

326,510 

 —   

143,772 

168,923 

55,287 

44,208 

33,049 

18,157 

6,886 

1,384 

843 

195 

346 

1,232 

327,894 

 —   

 —   

 —   

 —   

 —   

 —   

 0.1   

 0.1   

 0.2   

 0.1   

70,315 

21,898 

19,903 

17,649 

11,127 

2,880 

326 

89 

48 

189 

232 

 —   

144,098 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

86,049 

57,043 

13,169 

6,478 

3,195 

3,685 

2,479 

284 

281 

1 

2 

279 

86,333 

7,087 

 0.9   

1,941 

 1.0   

1,116 

3,781 

923 

909 

894 

425 

155 

76 

45 

10 

21 

69 

 0.5   

 1.1   

 1.2   

 1.1   

 1.6   

 4.4   

 7.2   

 5.4   

 11.1   

 9.0   

1,146 

233 

262 

231 

36 

33 

23 

20 

1 

2 

20 

 0.7   

 1.5   

 1.2   

 1.0   

 2.9   

 1.8   

 1.8   

 1.5   

 4.8   

 3.0   

892 

95 

59 

32 

25 

13 

1 

1 

— 

— 

1 

7,163 

 1.0   

1,964 

 1.0   

1,117 

2,725 

 9.0   

1,177 

 9.9   

1,337 

410 

358 

309 

178 

133 

371 

97 

62 

212 

305 

3,096 

338,153 

 7.1   

 7.0   

 7.9   

 13.4   

 13.8   

 21.8   

 47.6   

 36.4   

 37.8   

 55.6   

 13.7   

 0.2   

711 

159 

136 

100 

47 

24 

25 

11 

6 

8 

24 

1,202 

147,264 

 7.8   

 10.0   

 10.6   

 18.9   

 12.3   

 26.3   

 27.3   

 19.1   

 22.7   

 42.0   

 10.3   

 0.1   

44 

39 

3 

— 

1 

1 

— 

— 

— 

— 

— 

— 

44 

87,494 

%

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.5 

 0.5 

 0.2 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.5 

 — 

HSBC Holdings plc Annual Report and Accounts 2020

163

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Supplementary information

Wholesale lending – loans and advances to customers at amortised cost by country/territory

Gross carrying amount

Allowance for ECL

Europe

–  UK 

–  France

–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa (excluding 
Saudi Arabia)

–  Egypt

–  UAE

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

At 31 Dec 2020

Europe
–  UK 
–  France

–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa (excluding 
Saudi Arabia)

–  Egypt

–  UAE

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

At 31 Dec 2019

Corporate 
and 
commercial

Of which: 
real estate1

Non-bank 
financial 
institutions

$m

(3,918)   

(2,958)   

(645)   

(125)   

(14)   

(176)   

(95)   

(90)   

(229)   

(187)   

(86)   

(782)   

0   

(117)   

Corporate 
and 
commercial

Of which: 
real estate1

Non-bank 
financial 
institutions

$m

$m

$m

Total

$m

179,104   

128,933   

32,278   

8,309   

1,489   

8,095   

26,505   

18,890   

5,740   

364   

576   

935   

22,176   

201,280   

16,165   

145,098   

3,557   

1,156   

513   

785   

35,835   

9,465   

2,002   

8,880   

257,942   

162,039   

82,359   

64,216   

31,637   

289,579   

18,406   

180,445   

(2,766)   

(1,180)   

9,769   

7,223   

3,699   

28,443   

7,228   

18,859   

6,115   

14,567   

24,625   

2,162   

13,485   

8,978   

53,386   

30,425   

22,361   

600   

12,031   

10,244   

1,787   

1,813   

1,951   

81   

6,251   

1,968   

4,637   

50   

1,392   

1,839   

37   

1,690   

112   

14,491   

7,722   

6,645   

124   

1,833   

1,832   

1   

1,348   

3,075   

246   

11,117   

10,298   

3,945   

7,128   

35,571   

7,351   

19,221   

6,175   

15,456   

123   

362   

60   

889   

379   

13   

170   

196   

9,292   

7,708   

1,440   

144   

1,096   

1,083   

13   

25,004   

(1,512)   

2,175   

(157)   

13,655   

(1,019)   

9,174   

62,678   

38,133   

23,801   

744   

13,127   

11,327   

1,800   

(336)   

(637)   

(367)   

(243)   

(27)   

(661)   

(589)   

(72)   

$m

(632)   

(574)   

(40)   

—   

—   

(18)   

(162)   

(83)   

(2)   

(18)   

(2)   

(23)   

(27)   

(2)   

—   

(5)   

(187)   

(7)   

(176)   

(4)   

(73)   

(38)   

(27)   

(8)   

(113)   

(113)   

—   

$m

(185)   

(147)   

(26)   

(3)   

—   

(9)   

(38)   

(15)   

—   

(4)   

0   

(18)   

—   

—   

—   

(1)   

(9)   

(3)   

(2)   

(4)   

(23)   

(3)   

(9)   

(11)   

(10)   

(10)   

—   

Total

$m

(4,103) 

(3,105) 

(671) 

(128) 

(14) 

(185) 

(2,804) 

(1,195) 

(95) 

(94) 

(229) 

(205) 

(86) 

(782) 

0 

(118) 

(1,521) 

(160) 

(1,021) 

(340) 

(660) 

(370) 

(252) 

(38) 

(671) 

(599) 

(72) 

527,088   

127,027   

64,580   

591,668   

(9,494)   

(1,167)   

(265)   

(9,759) 

175,215   

126,760   

27,885   

9,771   

1,535   

9,264   

267,709   

168,380   

11,428   

6,657   

4,346   

26,594   

6,914   

19,986   

6,384   

17,020   

23,447   

1,889   

13,697   

7,861   

59,680   

34,477   

24,427   

776   

14,448   

12,352   

2,096   

26,587   

18,941   

5,643   

390   

554   

1,059   

85,556   

67,856   

1,993   

1,565   

63   

5,304   

1,597   

5,235   

28   

1,915   

1,816   

35   

1,695   

86   

15,128   

8,282   

6,556   

290   

1,665   

1,664   

1   

26,497   

18,545   

4,899   

1,743   

406   

904   

32,157   

19,776   

1,743   

2,622   

353   

5,911   

230   

618   

82   

822   

288   

16   

122   

150   

10,078   

8,975   

979   

124   

1,685   

1,625   

60   

201,712   

145,305   

32,784   

11,514   

1,941   

10,168   

299,866   

188,156   

13,171   

9,279   

4,699   

32,505   

7,144   

20,604   

6,466   

17,842   

23,735   

1,905   

13,819   

8,011   

69,758   

43,452   

25,406   

900   

16,133   

13,977   

2,156   

(2,304)   

(1,629)   

(423)   

(60)   

(1)   

(191)   

(1,449)   

(750)   

(70)   

(49)   

(222)   

(198)   

(40)   

(60)   

(2)   

(58)   

(1,087)   

(132)   

(683)   

(272)   

(274)   

(116)   

(136)   

(22)   

(324)   

(221)   

(103)   

(354)   

(303)   

(28)   

—   

—   

(23)   

(94)   

(51)   

(3)   

(3)   

(1)   

(29)   

(2)   

(2)   

—   

(3)   

(181)   

—   

(179)   

(2)   

(43)   

(14)   

(10)   

(19)   

(8)   

(8)   

—   

(81)   

(26)   

(52)   

—   

—   

(3)   

(52)   

(40)   

—   

(1)   

(2)   

(8)   

—   

—   

—   

(1)   

(2,385) 

(1,655) 

(475) 

(60) 

(1) 

(194) 

(1,501) 

(790) 

(70) 

(50) 

(224) 

(206) 

(40) 

(60) 

(2) 

(59) 

(13)   

(1,100) 

(3)   

(7)   

(3)   

(11)   

(2)   

(4)   

(5)   

(3)   

(3)   

—   

(135) 

(690) 

(275) 

(285) 

(118) 

(140) 

(27) 

(327) 

(224) 

(103) 

540,499   

130,752   

70,705   

611,204   

(5,438)   

(680)   

(160)   

(5,598) 

1  Real estate lending within this disclosure corresponds solely to the industry of the borrower. Commercial real estate on page 150 includes 

borrowers in multiple industries investing in income-producing assets and to a lesser extent, their construction and development.

164

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Personal lending – loans and advances to customers at amortised cost by country/territory

Gross carrying amount

Allowance for ECL

Europe

–  UK 
–  France1
–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa (excluding Saudi Arabia)

–  Egypt

–  UAE

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

At 31 Dec 2020

Europe
–  UK 
–  France1
–  Germany

–  Switzerland

–  other

Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa (excluding Saudi Arabia)

–  Egypt

–  UAE

–  other

North America

–  US

–  Canada

–  other

Latin America

–  Mexico

–  other

At 31 Dec 2019

First lien 
residential 
mortgages

Other 
personal

Of which: 
credit 
cards

$m

$m

$m

Total

$m

  162,630   

51,033   

8,471   

213,663   

  154,839   

19,696   

8,064   

174,535   

3,623   

23,982   

358   

27,605   

—   

1,195   

2,973   

368   

6,641   

346   

—   

—   

49   

368   

7,836   

3,319   

  141,581   

45,732   

11,186   

187,313   

91,997   

31,594   

7,573   

123,591   

First lien 
residential 
mortgages

$m

(364)   

(236)   

(43)   

—   

—   

(85)   

(80)   

—   

(12)   

(9)   

—   

(6)   

(41)   

—   

—   

(12)   

(43)   

—   

(37)   

(6)   

Other 
personal

$m

(1,980)   

(1,762)   

(120)   

—   

(79)   

(19)   

(841)   

(387)   

(47)   

(45)   

(37)   

(81)   

(102)   

(55)   

(15)   

(72)   

Of which: 
credit 
cards

$m

(859)   

(852)   

(5)   

—   

—   

(2)   

(563)   

(265)   

(45)   

(34)   

(26)   

(73)   

(35)   

(17)   

(5)   

(63)   

(275)   

(142)   

(8)   

(163)   

(104)   

(266)   

(226)   

(31)   

(9)   

(614)   

(578)   

(36)   

(3)   

(92)   

(47)   

(193)   

(182)   

(10)   

(1)   

(290)   

(268)   

(22)   

Total

$m

(2,344) 

(1,998) 

(163) 

— 

(79) 

(104) 

(921) 

(387) 

(59) 

(54) 

(37) 

(87) 

(143) 

(55) 

(15) 

(84) 

(318) 

(8) 

(200) 

(110) 

(425) 

(252) 

(67) 

(106) 

(723) 

(685) 

(38) 

514   

215   

167   

644   

841   

375   

277   

580   

863   

89   

432   

342   

20,922   

1,477   

359   

10,834   

5,761   

13,931   

6,476   

3,962   

5,533   

360   

2,999   

2,174   

1,373   

46,378   

(159)   

1,091   

20,571   

244   

24,471   

38   

1,406   

1,119   

287   

1,336   

7,922   

7,252   

670   

(26)   

(36)   

(97)   

(109)   

(107)   

(2)   

20,320   

933   

71   

9,679   

2,797   

7,394   

5,407   

2,983   

2,192   

—   

1,841   

351   

41,826   

18,430   

22,241   

1,155   

4,053   

3,901   

152   

602   

544   

288   

1,155   

2,964   

6,537   

1,069   

979   

3,341   

360   

1,158   

1,823   

4,552   

2,141   

2,230   

181   

3,869   

3,351   

518   

  352,282    108,527   

23,299   

460,809   

(755)   

(3,976)   

(2,047)   

(4,731) 

145,382   

50,368   

10,246   

195,750   

137,985   

22,395   

9,816   

160,380   

3,520   

21,120   

376   

24,640   

(266)   

(159)   

(39)   

—   

1,183   

2,694   

325   

6,165   

363   

—   

—   

54   

325   

7,348   

3,057   

131,864   

48,231   

12,144   

180,095   

86,892   

33,061   

8,043   

119,953   

16,997   

1,047   

67   

8,966   

2,840   

6,687   

5,286   

3,082   

2,303   

—   

1,920   

383   

39,065   

17,870   

19,997   

1,198   

3,564   

3,419   

145   

693   

528   

329   

1,190   

3,200   

7,033   

1,004   

1,193   

3,914   

346   

1,462   

2,106   

5,251   

2,551   

2,495   

205   

4,329   

3,780   

549   

603   

219   

204   

656   

980   

452   

297   

690   

1,042   

88   

517   

437   

1,742   

1,424   

271   

47   

1,594   

1,308   

286   

17,690   

1,575   

396   

10,156   

6,040   

13,720   

6,290   

4,275   

6,217   

346   

3,382   

2,489   

44,316   

20,421   

22,492   

1,403   

7,893   

7,199   

694   

—   

(6)   

(62)   

(42)   

(1)   

(5)   

(5)   

—   

(2)   

(22)   

(1)   

0   

(6)   

(62)   

—   

(59)   

(3)   

(122)   

(8)   

(21)   

(93)   

(37)   

(31)   

(6)   

(962)   

(828)   

(101)   

—   

(17)   

(16)   

(690)   

(353)   

(34)   

(21)   

(24)   

(74)   

(73)   

(60)   

(14)   

(37)   

(235)   

(3)   

(121)   

(111)   

(194)   

(160)   

(25)   

(9)   

(524)   

(488)   

(36)   

(438)   

(434)   

(3)   

—   

—   

(1)   

(463)   

(242)   

(33)   

(15)   

(18)   

(68)   

(33)   

(19)   

(4)   

(31)   

(111)   

(1)   

(54)   

(56)   

(142)   

(134)   

(7)   

(1)   

(241)   

(224)   

(17)   

(1,228) 

(987) 

(140) 

— 

(23) 

(78) 

(732) 

(354) 

(39) 

(26) 

(24) 

(76) 

(95) 

(61) 

(14) 

(43) 

(297) 

(3) 

(180) 

(114) 

(316) 

(168) 

(46) 

(102) 

(561) 

(519) 

(42) 

322,178   

112,093   

26,768   

434,271   

(529)   

(2,605)   

(1,395)   

(3,134) 

1 

Included in other personal lending at 31 December 2020 is $20,625m (31 December 2019: $17,585m) guaranteed by Crédit Lodgement.

HSBC Holdings plc Annual Report and Accounts 2020

165

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Change in reportable segments

Effective from 30 June 2020, we made the following realignments 
within our internal reporting:

• We simplified our matrix organisational structure by merging 

Global Private Banking and Retail Banking and Wealth 
Management to form Wealth and Personal Banking (‘WPB’). As 
a result, the gross carrying/nominal values and the associated 
allowance for ECL of Global Private Banking and Retail Banking 
and Wealth Management have been merged into WPB.

• We reallocated Markets Treasury from Corporate Centre to the 

global businesses. As a result, Market Treasury's gross 
carrying/nominal values and the associated allowance for ECL 
have been transferred from the Corporate Centre into the other 
global businesses.

Comparative data have been re-presented accordingly. There is no 
impact upon total gross carrying/nominal values, total allowance 
for ECL or the staging of financial instruments.

Summary of financial instruments to which the impairment requirements in IFRS 9 are applied – by global business

Gross carrying/nominal amount

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

Total Stage 1 Stage 2 Stage 3

POCI

$m

$m

$m

$m

$m

Total

$m

Loans and advances to customers at amortised cost

  869,920   163,185    19,095   

277    1,052,477    (1,974)    (4,965)    (7,439)   

(112)    (14,490) 

–  WPB

–  CMB

–  GBM

  442,641    25,694    5,753   

—    474,088   

(854)    (2,458)    (1,590)   

—   

(4,902) 

  238,517   101,960    10,408   

212    351,097   

(917)    (2,029)    (4,874)   

(96)   

(7,916) 

  187,564    35,461    2,934   

65    226,024   

(203)   

(465)   

(975)   

(16)   

(1,659) 

–  Corporate Centre

Loans and advances to banks at amortised cost

–  WPB

–  CMB

–  GBM

–  Corporate Centre

1,198   

70   

79,654    2,004   

16,837   

12,253   

519   

222   

33,361    1,166   

17,203   

97   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

81,658   

(33)   

17,356   

12,475   

(2)   

(2)   

34,527   

(23)   

17,300   

1,268   

—   

(13)   

Other financial assets measured at amortised cost

  768,216    3,975   

177   

40    772,408   

–  WPB

–  CMB

–  GBM

–  Corporate Centre

  167,053    1,547   

  111,299    1,716   

  391,967   

705   

97,897   

7   

50   

65   

56   

6   

39    168,689   

1    113,081   

—    392,728   

—   

97,910   

(9)   

(2)   

—   

(7)   

—   

(44)   

(22)   

(19)   

(3)   

—   

—   

—   

—   

—   

—   

—   

(42)   

(7)   

(25)   

(10)   

—   

—   

—   

—   

—   

—   

—   

(9)   

(9)   

—   

—   

—   

(13) 

(42) 

(4) 

(2) 

(30) 

(6) 

(175) 

(79) 

(61) 

(35) 

— 

(6)   

(80)   

(41)   

(17)   

(22)   

—   

Total gross carrying amount on-balance sheet at 
31 Dec 2020

 1,717,790   169,164    19,272   

317    1,906,543    (2,087)    (5,018)    (7,481)   

(121)    (14,707) 

Loans and other credit-related commitments

  604,485    54,217    1,080   

1    659,783   

(290)   

(365)   

(78)   

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Financial guarantees

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Total nominal amount off-balance sheet at 
31 Dec 2020

WPB

CMB

GBM

Corporate Centre

Debt instruments measured at FVOCI at 
31 Dec 2020

  232,027    2,591   

  111,800    29,150   

  260,527    22,476   

131   

—   

136   

779   

165   

—   

14,090    4,024   

269   

1,048   

23   

5,556    2,519   

7,482    1,482   

4   

—   

2   

146   

121   

—   

—    234,754   

(41)   

(2)   

—   

1    141,730   

(157)   

(203)   

(72)   

—    283,168   

(92)   

(160)   

131   

—   

—   

(6)   

—   

18,384   

(37)   

(62)   

(26)   

1,073   

8,222   

9,085   

4   

—   

(19)   

(17)   

(1)   

—   

(36)   

(26)   

—   

—   

(12)   

(14)   

—   

—   

1   

—   

1   

—   

—   

(1)   

—   

(1)   

—   

—   

—   

—   

—   

—   

—   

(734) 

(43) 

(433) 

(258) 

— 

(125) 

— 

(67) 

(57) 

(1) 

  618,575    58,241    1,349   

2    678,167   

(327)   

(427)   

(104)   

(1)   

(859) 

  159,988   

95,182   

  136,909   

5,838   

625   

313   

126   

389   

154   

39    160,806   

51   

93   

—   

10   

95,556   

—    137,128   

—   

6,227   

(27)   

(22)   

(24)   

(17)   

(10)   

(15)   

(3)   

(1)   

(6)   

(2)   

(3)   

(1)   

(8)   

(2)   

—   

—   

(60) 

(29) 

(28) 

(24) 

  397,917    1,453   

298   

49    399,717   

(90)   

(20)   

(21)   

(10)   

(141) 

166

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Summary of financial instruments to which the impairment requirements in IFRS 9 are applied – by global business (continued)1

Loans and advances to customers at amortised cost

  951,583   

80,182    13,378   

332   1,045,475   

(1,297)   

(2,284)   

(5,052)   

(99)   

(8,732) 

Gross carrying/nominal amount

Allowance for ECL

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

Total

Stage 1

Stage 2

Stage 3

$m

$m

$m

$m

POCI

$m

Total

$m

Other financial assets measured at amortised cost

  613,200   

1,827   

151   

1    615,179   

Loans and other credit-related commitments

  577,631   

21,618   

9    600,029   

(137)   

(133)   

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Loans and advances to banks at amortised cost

–  WPB

–  CMB

–  GBM

–  Corporate Centre

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Total gross carrying amount on-balance sheet at 
31 Dec 2019

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Financial guarantees

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Total nominal amount off-balance sheet at 
31 Dec 2019

WPB

CMB

GBM

Corporate Centre

Debt instruments measured at FVOCI at 
31 Dec 2019

  424,342   

16,797   

5,131   

—    446,270   

(602)   

(1,330)   

(1,312)   

—   

(3,244) 

  297,364   

46,423   

6,649   

212    350,648   

  228,770   

16,934   

1,598   

120    247,422   

1,107   

28   

67,769   

1,450   

14,636   

8,842   

30,391   

13,900   

393   

219   

818   

20   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

1,135   

69,219   

15,029   

9,061   

31,209   

13,920   

  109,423   

64,586   

  361,541   

77,650   

548   

904   

374   

1   

41   

51   

37   

22   

—    110,012   

1   

65,542   

—    361,952   

—   

77,673   

(520)   

(173)   

(2)   

(14)   

(1)   

(2)   

(9)   

(2)   

(38)   

(21)   

(10)   

(7)   

—   

(765)   

(3,190)   

(68)   

(4,543) 

(177)   

(550)   

(31)   

(931) 

(12)   

(2)   

(1)   

—   

(1)   

—   

(38)   

(30)   

(7)   

(1)   

—   

—   

—   

—   

—   

—   

—   

(42)   

(5)   

(26)   

(11)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(14) 

(16) 

(2) 

(2) 

(10) 

(2) 

(118) 

(56) 

(43) 

(19) 

— 

  1,632,552   

83,459    13,529   

333   1,729,873   

(1,349)   

(2,324)   

(5,094)   

(99)   

(8,866) 

  213,093   

1,945   

  117,703   

11,403   

  246,805   

8,270   

30   

—   

771   

185   

558   

28   

—   

—    215,223   

9    129,673   

—    255,103   

—   

30   

17,684   

2,340   

186   

4   

20,214   

972   

7,446   

9,263   

3   

4   

1   

1,442   

105   

894   

—   

80   

—   

—   

4   

—   

—   

977   

8,997   

10,237   

3   

(15)   

(69)   

(53)   

—   

(16)   

—   

(9)   

(7)   

—   

(1)   

(65)   

(67)   

—   

(22)   

—   

(12)   

(10)   

—   

(59)   

—   

(56)   

(3)   

—   

(10)   

—   

(6)   

(4)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(329) 

(16) 

(190) 

(123) 

— 

(48) 

— 

(27) 

(21) 

— 

  595,315   

23,958   

957   

13    620,243   

(153)   

(155)   

(69)   

—   

(377) 

  144,632   

378   

85,353   

  118,571   

62   

68   

6,093   

506   

—   

—   

—   

—   

—    145,010   

(13)   

1   

85,416   

—    118,639   

(5)   

(9)   

—   

6,599   

(12)   

(81)   

(19)   

(16)   

(11)   

—   

—   

—   

—   

—   

—   

—   

—   

(94) 

(24) 

(25) 

(23) 

  354,649   

1,014   

—   

1    355,664   

(39)   

(127)   

—   

—   

(166) 

1  2019 figures are restated for the change in reportable segments.

HSBC Holdings plc Annual Report and Accounts 2020

167

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Loans and advances to customers and banks metrics

First lien residential mortgages

Other personal lending

Personal lending

–  agriculture, forestry and fishing

–  mining and quarrying

–  manufacturing

–  electricity, gas, steam and air-conditioning supply

–  water supply, sewerage, waste management and remediation

–  construction

–  wholesale and retail trade, repair of motor vehicles and 

motorcycles

–  transportation and storage

–  accommodation and food

–  publishing, audiovisual and broadcasting

–  real estate

–  professional, scientific and technical activities

–  administrative and support services

–  public administration and defence, compulsory social security

–  education

–  health and care

–  arts, entertainment and recreation

–  other services

–  activities of households

–  extra-territorial organisations and bodies activities

–  government

–  asset-backed securities

Corporate and commercial

Non-bank financial institutions

Wholesale lending

Loans and advances to customers

Loans and advances to banks

At 31 Dec 2020

First lien residential mortgages

Other personal lending

Personal lending

–  agriculture, forestry and fishing

–  mining and quarrying

–  manufacturing

–  electricity, gas, steam and air-conditioning supply
–  water supply, sewerage, waste management and remediation  
–  construction

–  wholesale and retail trade, repair of motor vehicles and 

motorcycles

–  transportation and storage

–  accommodation and food

–  publishing, audiovisual and broadcasting

–  real estate

–  professional, scientific and technical activities

–  administrative and support services
–  public administration and defence, compulsory social security

–  education

–  health and care

–  arts, entertainment and recreation

–  other services

–  activities of households

–  extra-territorial organisations and bodies activities

–  government

–  asset-backed securities

Corporate and commercial

Non-bank financial institutions

Wholesale lending

Loans and advances to customers

Loans and advances to banks

At 31 Dec 2019

Gross 
carrying 
amount

Of which: 
stage 3 and 
POCI

Allowance 
for ECL

Of which: 
stage 3 and 
POCI

Change in 

ECL Write-offs

Recoveries

$m

352,282   

108,527   

460,809   

7,445   

11,947   

93,906   

16,200   

3,174   

14,600   

$m

3,383   

2,228   

5,611   

332   

813   

53   

47   

777   

$m

$m

$m

(755)   

(3,976)   

(4,731)   

(207)   

(365)   

(73)   

(37)   

(442)   

(1,060)   

(1,502)   

(150)   

(220)   

(945)   

(8)   

(22)   

(259)   

(2,363)   

(2,622)   

(28)   

(513)   

(652)   

(7)   

(8)   

$m

(92)   

(1,315)   

(1,407)   

(3)   

(311)   

(375)   

(14)   

—   

(590)   

(430)   

(151)   

(135)   

2,163   

(1,588)   

90,663   

3,208   

(2,532)   

(2,032)   

(1,560)   

(280)   

29,433   

26,071   

19,979   

780   

537   

164   

(493)   

(491)   

(189)   

127,027   

1,908   

(1,167)   

24,072   

26,423   

2,008   

2,122   

5,510   

3,437   

13,110   

802   

10   

8,538   

611   

531   

977   

3   

29   

269   

236   

410   

—   

—   

1   

—   

(398)   

(534)   

(14)   

(41)   

(186)   

(158)   

(408)   

(1)   

—   

(9)   

(13)   

(240)   

(130)   

(59)   

(738)   

(193)   

(315)   

(1)   

(9)   

(120)   

(87)   

(249)   

—   

—   

(1)   

—   

(308)   

(365)   

(94)   

(424)   

(219)   

(298)   

(5)   

(26)   

(127)   

(170)   

(360)   

—   

1   

2   

1   

(62)   

(28)   

(2)   

(47)   

(36)   

(61)   

—   

(6)   

(2)   

(2)   

(168)   

—   

—   

(5)   

—   

527,088   

13,238   

(9,494)   

(5,949)   

(5,311)   

(1,537)   

64,580   

523   

(265)   

591,668   

13,761   

(9,759)   

  1,052,477   

19,372   

(14,490)   

81,658   

—   

(42)   

(100)   

(6,049)   

(7,551)   

—   

(146)   

(5,457)   

(8,079)   

(23)   

(30)   

(1,567)   

(2,974)   

—   

  1,134,135   

19,372   

(14,532)   

(7,551)   

(8,102)   

(2,974)   

322,178   

112,093   

434,271   

6,696   

14,435   

3,070   

1,781   

4,851   

280   

323   

(529)   

(2,605)   

(3,134)   

(182)   

(226)   

104,380   

1,717   

(1,210)   

15,040   

3,501   

15,287   

94,681   

25,580   

24,656   

19,971   

175   

30   

884   

(80)   

(28)   

(564)   

1,633   

(1,184)   

617   

263   

162   

130,752   

1,330   

24,122   

25,714   

2,377   

1,900   

4,465   

2,824   

14,276   

791   

2   

8,313   

736   

540,499   

70,705   

611,204   

350   

527   

—   

16   

111   

30   

192   

—   

—   

7   

—   

8,647   

212   

8,859   

1,045,475   

13,710   

69,219   

—   

(422)   

(793)   

(1,215)   

(140)   

(134)   

(856)   

(25)   

(18)   

(499)   

(936)   

(158)   

(63)   

(34)   

(475)   

(145)   

(179)   

—   

(6)   

(28)   

(11)   

(107)   

(1,114)   

(1,221)   

(15)   

(31)   

(392)   

14   

(4)   

(171)   

(139)   

(1,206)   

(1,345)   

(6)   

(4)   

(332)   

(54)   

—   

(191)   

(330)   

(389)   

(93)   

(49)   

(17)   

(34)   

(47)   

(80)   

—   

6   

(6)   

3   

(37)   

(81)   

(31)   

(168)   

(10)   

(22)   

—   

(3)   

(13)   

(4)   

(237)   

(146)   

(87)   

(680)   

(209)   

(270)   

(8)   

(18)   

(57)   

(25)   

(199)   

(133)   

(79)   

(102)   

—   

—   

(14)   

(14)   

—   

—   

(6)   

—   

—   

2   

(8)   

—   

—   

—   

—   

—   

(5,438)   

(3,846)   

(1,331)   

(1,447)   

(160)   

(5,598)   

(8,732)   

(16)   

(90)   

(3,936)   

(5,151)   

—   

(71)   

(1,402)   

(2,623)   

(6)   

(5)   

(1,452)   

(2,797)   

—   

1,114,694   

13,710   

(8,748)   

(5,151)   

(2,629)   

(2,797)   

$m

35 

245 

280 

— 

— 

7 

— 

— 

13 

11 

1 

— 

— 

4 

1 

— 

— 

1 

1 

— 

4 

— 

1 

— 

— 

44 

2 

46 

326 

— 

326 

54 

260 

314 

— 

— 

8 

2 

— 

12 

13 

— 

— 

— 

6 

1 

— 

— 

— 

1 

— 

2 

— 

1 

— 

— 

46 

1 

47 

361 

— 

361 

168

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings

(Audited)

Risk in HSBC Holdings is overseen by the HSBC Holdings Asset 
and Liability Management Committee (‘Holdings ALCO’). The 
major risks faced by HSBC Holdings are credit risk, liquidity risk 
and market risk (in the form of interest rate risk and foreign 
exchange risk).

Credit risk in HSBC Holdings primarily arises from transactions 
with Group subsidiaries and its investments in those subsidiaries.

In HSBC Holdings, the maximum exposure to credit risk arises 
from two components:

• financial instruments on the balance sheet (see page 285); and

• financial guarantees and similar contracts, where the maximum 
exposure is the maximum that we would have to pay if the 
guarantees were called upon (see Note 32).

In the case of our derivative balances, we have amounts with a 
legally enforceable right of offset in the case of counterparty 
default that are not included in the carrying value. These offsets 
also include collateral received in cash and other financial assets.

The total offset relating to our derivative balances was $1.7bn at 
31 December 2020 (2019: $0.1bn).

The credit quality of loans and advances and financial 
investments, both of which consist of intra-Group lending and US 
Treasury bills and bonds, is assessed as ‘strong’, with 100% of the 
exposure being neither past due nor impaired (2019: 100%). For 
further details of credit quality classification, see page 121. 

Treasury risk

Overview

Treasury risk management

Capital risk in 2020

Structural foreign exchange risk in 2020

Interest rate risk in the banking book in 2020

Overview

Page

169

169

173

179

179

Treasury risk is the risk of having insufficient capital, liquidity or 
funding resources to meet financial obligations and satisfy 
regulatory requirements, together with the financial risks arising 
from the provision of pensions and other post-employment 
benefits to staff and their dependants. Treasury risk also includes 
the risk to our earnings or capital due to structural foreign 
exchange exposures and changes in market interest rates.

Treasury risk arises from changes to the respective resources and 
risk profiles driven by customer behaviour, management decisions 
or the external environment.

Approach and policy

(Audited)

Our objective in the management of treasury risk is to maintain 
appropriate levels of capital, liquidity, funding, foreign exchange 
and market risk to support our business strategy, and meet our 
regulatory and stress testing-related requirements.

Our approach to treasury management is driven by our strategic 
and organisational requirements, taking into account the 
regulatory, economic and commercial environment. We aim to 
maintain a strong capital and liquidity base to support the risks 
inherent in our business and invest in accordance with our 
strategy, meeting both consolidated and local regulatory 
requirements at all times.

Our policy is underpinned by our risk management framework, our 
internal capital adequacy assessment process (‘ICAAP’) and our 
internal liquidity adequacy assessment process (‘ILAAP’). The risk 
framework incorporates a number of measures aligned to our 
assessment of risks for both internal and regulatory purposes. 
These risks include credit, market, operational, pensions, structural 
foreign exchange, banking book foreign exchange risk and interest 
rate risk in the banking book.

The ICAAP and ILAAP provide an assessment of the Group’s 
capital and liquidity adequacy with consideration of HSBC’s risk 
metrics, business model, strategy, performance and planning, 
risks to capital, and the implications of stress testing to capital.

For further details, refer to our Pillar 3 Disclosures at 31 December 2020.

Treasury risk management

Key developments in 2020

In 2020, we established the Treasury Risk Management function. 
This function is a dedicated second line of defence, providing 
independent oversight of treasury activities across capital risk, 
liquidity and funding risk, structural foreign exchange risk, banking 
book foreign exchange risk, and interest rate risk in the banking 
book, together with pension risk. The approach to treasury risk 
management is evolving. This will operate across the Group 
focusing on both adequacy of capital and sufficiency of returns. In 
2020, we carried out several initiatives focused on treasury risk:

• We focused on the management of capital and liquidity to 
ensure we responded to the unprecedented customer and 
capital demands arising from the Covid-19 outbreak.

• In response to a written request from the PRA, we cancelled 

the fourth interim dividend for 2019 of $0.21 per ordinary share. 
Similar requests were also made to other UK incorporated 
banking groups. We also announced that we would make no 
quarterly or interim dividend payments or accruals in respect of 
ordinary shares until the end of 2020. In December 2020, the 
PRA announced a temporary approach to shareholder 
distributions for 2020. After considering the requirements of the 
temporary approach, the Board announced an interim dividend 
for 2020 of $0.15 per ordinary share. 

• In our response to the Covid-19 outbreak, we liaised with 

governments, central banks and regulatory authorities globally,  
to ensure there was continued support and provision of 
financial services to the real economy. The Bank of England’s 
Financial Policy Committee announced a reduction of the UK 
countercyclical buffer rate to 0% effective from March 2020. 
This change was reflected in the Group’s risk appetite 
statement, and together with other regulatory relief, resulted in 
a reduction to Group common equity tier 1 (‘CET1’) and 
leverage ratio requirements.

• We implemented the acceleration of some of the beneficial 
elements of the amendments to the Capital Requirements 
Regulation (‘CRR II’) that were originally scheduled for June 
2021. The relevant changes impacting the fourth quarter of 
2020 positions included a resetting of the transitional 
provisions in relation to recognising IFRS 9 provisions and the 
application of the revised small and medium-sized enterprises 
(‘SME’) supporting factor. It also included changes in the 
capital treatment of software intangible assets and the netting 
of the leverage ratio exposure measure of regular-way 
purchases and sales. Additionally, there were changes that 
enabled more favourable prudential treatment for investments 
in infrastructure, beneficial changes to prudent valuation 
adjustments and exemptions of market risk back-testing 
exceptions that arose due to the extraordinary market 
dislocations.

• The Group’s CET1 ratio was 15.9% at 31 December 2020 and 
the leverage ratio was 5.5%. The Group also continues to 
maintain the appropriate resources required for the risks to 
which it is exposed, while continuing to support local 
economies. This has been further informed by additional 
internal stress tests carried out in response to the Covid-19 
outbreak. Capital risk management practices continued to be 
enhanced across the Group through the Treasury Risk 
Management function, focusing on both adequacy of capital 
and sufficiency of returns.

• The Group’s liquidity levels were impacted by the drawdown of 

committed facilities and buy-backs of short-term debt. 
However, this was offset by increases in deposits, use of 
central bank facilities where appropriate, and the ability to issue 
in the short-term markets as they stabilised. As a result of these 

HSBC Holdings plc Annual Report and Accounts 2020

169

Risk review 
Risk

liability enhancing actions, the Group and all entities had 
significant surplus liquidity, resulting in heightened liquidity 
coverage ratios throughout 2020. At 31 December 2020, all of 
the Group’s material operating entities were above regulatory 
minimum levels of liquidity and funding.

• Declines in interest rates and the flattening of interest rate yield 
curves combined to put downwards pressure on net interest 
income (‘NII’). Balance sheet composition changed, with a 
significant build-up of liquidity that was deployed in short-term 
investments, which were predominantly cash, hold-to-collect-
and-sell securities and reverse repos. This factor, together with 
the lower level of interest rates, increased the sensitivity of NII 
to future changes in interest rates. In the scenario where 
interest rates fall significantly from current levels, contractual 
floors would dampen the effect on the average rate that would 
be paid on liabilities whereas the asset side of the balance 
sheet would be more likely to reprice lower, reducing 
commercial margin.

• During 2020 we worked with the fiduciaries of all our pension 

plans to ensure robust and timely actions were taken in 
response to the Covid-19 outbreak, including the smooth 
transition to remote working for plan providers and dealing 
appropriately with affected plan members. Our de-risking 
programmes provided protection against the volatility in 
financial markets that resulted from the outbreak’s economic 
impact.

For quantitative disclosures on capital ratios, own funds and RWAs, see 
pages 173 to 174. For quantitative disclosures on liquidity and funding 
metrics, see pages 176 to 178. For quantitative disclosures on interest rate 
risk in the banking book, see pages 179 to 180.

Governance and structure

The Global Head of Treasury Risk Management and Global Risk 
Analytics is the accountable risk steward for all treasury risks, the 
Group Head of Performance and Reward is the risk owner for 
pensions and the Group Treasurer is the risk owner for remaining 
treasury risks.

Capital and liquidity are the responsibility of the Group Executive 
Committee and directly addressed by the Group Risk Committee 
(‘GRC’). Treasury risks are generally managed through the 
Holdings Asset and Liability Management Committee (‘ALCO’) and 
local ALCOs and overseen by the Risk Management Meeting 
(‘RMM’). 

The Asset, Liability and Capital Management (‘ALCM’) function is 
responsible for managing interest rate risk in the banking book. It 
maintains the transfer pricing framework and informs the Holdings 
ALCO of the Group’s overall banking book interest rate exposure. 
Banking book interest rate positions may be transferred to be 
managed by the Markets Treasury business, previously known as 
Balance Sheet Management, within the market risk limits 
approved by the RMM. Effective governance of Markets Treasury 
is supported by the dual reporting lines it has to the Chief 
Executive Officer of Global Banking and Markets and to the Group 
Treasurer, with the Global Risk function acting as a second line of 
defence. 

Pension risk is managed by a network of local and regional 
pension risk forums. The Global Pensions Oversight Forum 
provides oversight of all pension plans sponsored by HSBC 
globally and is co-chaired by the Group Treasurer and the Global 
Head of Treasury Risk Management and Global Risk Analytics.

Capital, liquidity and funding risk management 
processes

Assessment and risk appetite

Our capital management policy is underpinned by a capital 
management framework and our ICAAP. The framework 
incorporates key capital risk appetites for CET1, total capital, 
minimum requirements for own funds and eligible liabilities 
(‘MREL’), and double leverage. The ICAAP is an assessment of the 
Group’s capital position, outlining both regulatory and internal 
capital resources and requirements resulting from HSBC’s 
business model, strategy, risk profile and management, 

170

HSBC Holdings plc Annual Report and Accounts 2020

performance and planning, risks to capital, and the implications of 
stress testing. Our assessment of capital adequacy is driven by an 
assessment of risks. These risks include credit, market, 
operational, pensions, insurance, structural foreign exchange and 
interest rate risk in the banking book. The Group ICAAP supports 
the determination of the consolidated capital risk appetite and 
target ratios as well as enables the assessment and determination 
of capital requirements by regulators. Subsidiaries prepare ICAAPs 
based on their local regulatory regimes in order to determine their 
own risk appetites and ratios.

HSBC Holdings is the provider of equity capital to its subsidiaries 
and also provides them with non-equity capital where necessary. 
These investments are substantially funded by HSBC Holdings’ 
own capital issuance and profit retention.

HSBC Holdings seeks to maintain a prudent balance between the 
composition of its capital and its investments in subsidiaries, 
including management of double leverage. Double leverage 
reflects the extent to which equity investments in operating 
entities are funded by holding company debt. Where Group capital 
requirements are less than the aggregate of operating entity 
capital requirements, double leverage can be used to improve 
Group capital efficiency provided it is managed appropriately and 
prudently in accordance with risk appetite. Double leverage is a 
constraint on managing our capital position, given the complexity 
of the Group’s subsidiary structure and the multiple regulatory 
regimes under which we operate. As a matter of long-standing 
policy, the holding company retains a substantial portfolio of high-
quality liquid assets (‘HQLA’), which at 31 December 2020 was in 
excess of $14bn. The portfolio of HQLA helps to mitigate holding 
company cash flow risk arising from double leverage, and 
underpins the strength of support the holding company can offer 
its subsidiaries in times of stress. Further mitigation is provided by 
additional tier 1 (‘AT1’) securities issued in excess of the regulatory 
requirements of our subsidiaries.

We maintain a comprehensive liquidity and funding risk 
management framework (‘LFRF’), which aims to enable us to 
withstand very severe liquidity stresses. The LFRF comprises 
policies, metrics and controls designed to ensure that Group and 
entity management have oversight of our liquidity and funding 
risks in order to manage them appropriately. We manage liquidity 
and funding risk at an operating entity level to ensure that 
obligations can be met in the jurisdiction where they fall due, 
generally without reliance on other parts of the Group. Operating 
entities are required to meet internal minimum requirements and 
any applicable regulatory requirements at all times. These 
requirements are assessed through the ILAAP, which ensures that 
operating entities have robust strategies, policies, processes and 
systems for the identification, measurement, management and 
monitoring of liquidity risk over an appropriate set of time 
horizons, including intra-day. The ILAAP informs the validation of 
risk tolerance and the setting of risk appetite. It also assesses the 
capability to manage liquidity and funding effectively in each 
major entity. These metrics are set and managed locally but are 
subject to robust global review and challenge to ensure 
consistency of approach and application of the LFRF across the 
Group.

Planning and performance

Capital and risk-weighted asset (‘RWA’) plans form part of the 
annual operating plan that is approved by the Board. Capital and 
RWA forecasts are submitted to the Group Executive Committee 
on a monthly basis, and capital and RWAs are monitored and 
managed against the plan. The responsibility for global capital 
allocation principles rests with the Group Chief Financial Officer 
supported by the Group Capital Management Meeting. This is a 
specialist forum addressing capital management, reporting into 
Holdings ALCO. 

Through our internal governance processes, we seek to strengthen 
discipline over our investment and capital allocation decisions, and 
to ensure that returns on investment meet management’s 
objectives. Our strategy is to allocate capital to businesses and 
entities to support growth objectives where returns above internal 
hurdle levels have been identified and in order to meet their 

regulatory and economic capital needs. We evaluate and manage 
business returns by using a return on average tangible equity 
measure.

Funding and liquidity plans form part of the annual operating plan 
that is approved by the Board. The critical Board-level appetite 
measures are the liquidity coverage ratio (‘LCR’) and net stable 
funding ratio (‘NSFR’). An appropriate funding and liquidity profile 
is managed through a wider set of measures:

• a minimum LCR requirement;

• a minimum NSFR requirement or other appropriate metric;

• a legal entity depositor concentration limit; 

• three-month and 12-month cumulative rolling term contractual 
maturity limits covering deposits from banks, deposits from 
non-bank financial institutions and securities issued;

• a minimum LCR requirement by currency;

• intra-day liquidity;

• the application of liquidity funds transfer pricing; and

• forward-looking funding assessments.

The LCR and NSFR metrics are to be supplemented by an internal 
liquidity metric in 2021. 

Risks to capital and liquidity

Outside the stress testing framework, other risks may be identified 
that have the potential to affect our RWAs and/or capital position. 
Downside and Upside scenarios are assessed against our capital 
management objectives and mitigating actions are assigned as 
necessary. We closely monitor future regulatory changes and 
continue to evaluate the impact of these upon our capital 
requirements. This includes the UK’s implementation of 
amendments to the Capital Requirements Regulation, the Basel III 
Reforms, and the regulatory impact from the UK’s withdrawal 
from the EU, as well as other regulatory statements including 
changes to IRB modelling requirements.  

We currently estimate that these regulatory changes could 
potentially increase RWAs, before any mitigating actions, by 
approximately 5% over 2022–23. We plan to take action to 
substantially mitigate a significant proportion of the increase.  

The Basel III Reforms introduce an output floor that will be 
introduced in 2023 with a five-year transitional provision. We 
estimate that there will be an additional RWA impact as a result of 
the output floor from 2027.  

In parallel with regulatory developments in the EU, the UK’s PRA 
is reviewing the requirements for the capitalisation of structural 
foreign exchange risk to align to a Pillar 1 approach. 

There remains a significant degree of uncertainty in the impact of 
the regulatory changes due to the number of national discretions 
and the need for further supporting technical standards to be 
developed. Furthermore, the impact does not take into 
consideration the possibility of offsets against Pillar 2, which may 
arise as shortcomings within Pillar 1 are addressed.  

We have applied the revised regulatory treatment of software 
assets that became law in the EU following its publication in 
December 2020. We are aware that the PRA intends to consult on 
this change with a view to returning to full deduction. In line with 
the PRA’s guidance, we have therefore excluded the capital 
benefit of $2.1bn from our decisions about distributions. 

Regulatory reporting processes and controls

There is a continued focus on the quality of regulatory reporting by 
the PRA and other regulators globally. We continue to strengthen 
our processes and controls, including commissioning independent 
external reviews of various aspects of regulatory reporting. As a 
result, there may be impacts on some of our regulatory ratios such 
as the CET1 and LCR. We continue to keep the PRA and other 
relevant regulators informed of adverse findings from external 
reviews and our progress in strengthening the control 
environment.
Further details can be found in the ‘Regulatory developments’ section of the 
Group’s Pillar 3 Disclosures at 31 December 2020. 

Stress testing and recovery planning

The Group uses stress testing to evaluate the robustness of plans 
and risk portfolios, and to meet the requirements for stress testing 
set by supervisors. Stress testing also informs the ICAAP and 
ILAAP and supports recovery planning in many jurisdictions. It is 
an important output used to evaluate how much capital and 
liquidity the Group requires in setting risk appetite for capital and 
liquidity risk. It is also used to re-evaluate business plans where 
analysis shows capital, liquidity and/or returns do not meet their 
target. 

In addition to a range of internal stress tests, we are subject to 
supervisory stress testing in many jurisdictions. These include the 
programmes of the Bank of England, the US Federal Reserve 
Board, the European Banking Authority, the European Central 
Bank and the Hong Kong Monetary Authority, as well as stress 
tests undertaken in other jurisdictions. The results of regulatory 
stress testing and our internal stress tests are used when 
assessing our internal capital requirements through the ICAAP. 
The outcomes of stress testing exercises carried out by the PRA 
and other regulators feed into the setting of regulatory minimum 
ratios and buffers.

The Group and subsidiaries have established recovery plans, 
which set out potential options management could take in a range 
of stress scenarios that could result in a breach of our internal 
capital buffers. This is to help ensure that our capital and liquidity 
position can be recovered even in an extreme stress event. 

During 2020, in light of the Covid-19 outbreak, we carried out 
additional internal testing on baseline and stressed scenarios. The 
results of these stress tests were considered in determining capital 
actions to manage the Group’s position.

Additionally, further stress testing was carried out to include 
scenarios relating to the impact of the UK’s withdrawal from the 
EU and elevated tensions between the US and China.

All entities monitor internal and external triggers that could 
threaten their capital, liquidity or funding positions. Entities have 
established recovery plans providing detailed actions that 
management would consider taking in a stress scenario should 
their positions deteriorate and threaten to breach risk appetite and 
regulatory minimum levels. 

Details of HSBC’s liquidity and funding risk management framework (‘LFRF’) 
can be found in the Group’s Pillar 3 Disclosures at 31 December 2020. 

Measurement of interest rate risk in the banking book 
processes

Assessment and risk appetite

Interest rate risk in the banking book is the risk of an adverse 
impact to earnings or capital due to changes in market interest 
rates. It is generated by our non-traded assets and liabilities, 
specifically loans, deposits and financial instruments that are not 
held for trading intent or held in order to hedge positions held with 
trading intent. Interest rate risk that can be economically hedged 
may be transferred to the Markets Treasury business. Hedging is 
generally executed through interest rate derivatives or fixed-rate 
government bonds. Any interest rate risk that Markets Treasury 
cannot economically hedge is not transferred and will remain 
within the global business where the risks originate.

The ALCM function uses a number of measures to monitor and 
control interest rate risk in the banking book, including:

• net interest income sensitivity;

• economic value of equity sensitivity; and

• hold-to-collect-and-sell stressed value at risk.

Net interest income sensitivity

A principal part of our management of non-traded interest rate risk 
is to monitor the sensitivity of expected net interest income (‘NII’) 
under varying interest rate scenarios (i.e. simulation modelling), 
where all other economic variables are held constant. This 
monitoring is undertaken at an entity level by local ALCOs, where 
entities forecast both one-year and five-year NII sensitivities across 
a range of interest rate scenarios.

HSBC Holdings plc Annual Report and Accounts 2020

171

Risk reviewRisk

Projected NII sensitivity figures represent the effect of pro forma 
movements in projected yield curves based on a static balance 
sheet size and structure. The exception to this is where the size of 
the balances or repricing is deemed interest rate sensitive, for 
example, non-interest-bearing current account migration and 
fixed-rate loan early prepayment. These sensitivity calculations do 
not incorporate actions that would be taken by Markets Treasury 
or in the business that originates the risk to mitigate the effect of 
interest rate movements. 

The NII sensitivity calculations assume that interest rates of all 
maturities move by the same amount in the ‘up-shock’ scenario. 
The sensitivity calculations in the ‘down-shock’ scenarios reflect 
no floors to the shocked market rates. However, customer 
product-specific interest rate floors are recognised where 
applicable. This is a change from the NII sensitivity methodology 
applied in the Annual Report and Accounts 2019, where market 
rates were floored to zero, unless the central bank rate was 
already negative as in the case of the euro, Swiss franc and 
Japanese yen.

Economic value of equity sensitivity

Economic value of equity (‘EVE’) represents the present value of 
the future banking book cash flows that could be distributed to 
equity providers under a managed run-off scenario. This equates 
to the current book value of equity plus the present value of future 
NII in this scenario. EVE can be used to assess the economic 
capital required to support interest rate risk in the banking book. 
An EVE sensitivity represents the expected movement in EVE due 
to pre-specified interest rate shocks, where all other economic 
variables are held constant. Operating entities are required to 
monitor EVE sensitivities as a percentage of capital resources.

Hold-to-collect-and-sell stressed value at risk

Hold-to-collect-and-sell stressed value at risk (‘VaR’) is a 
quantification of the potential losses to a 99% confidence level of 
the portfolio of securities held under a held-to-collect-and-sell 
business model in the Markets Treasury business. The portfolio is 
accounted for at fair value through other comprehensive income 
together with the derivatives held in designated hedging 
relationships with these securities. This is quantified based on the 
worst losses over a one-year period going back to the beginning of 
2007 and the assumed holding period is 60 days.

Hold-to-collect-and-sell stressed VaR uses the same models as 
those used for trading book capitalisation and covers only the 
portfolio managed by Markets Treasury under this business model.

Other Group risks

Structural foreign exchange exposures

Structural foreign exchange exposures represent net investments 
in subsidiaries, branches and associates, the functional currencies 
of which are currencies other than the US dollar. An entity’s 
functional currency is normally that of the primary economic 
environment in which the entity operates.

Exchange differences on structural exposures are recognised in 
other comprehensive income (‘OCI’). We use the US dollar as our 
presentation currency in our consolidated financial statements 
because the US dollar and currencies linked to it form the major 
currency bloc in which we transact and fund our business. 
Therefore, our consolidated balance sheet is affected by exchange 
differences between the US dollar and all the non-US dollar 
functional currencies of underlying subsidiaries.

Our structural foreign exchange exposures are managed with the 
primary objective of ensuring, where practical, that our 
consolidated capital ratios and the capital ratios of individual 
banking subsidiaries are largely protected from the effect of 
changes in exchange rates. We hedge structural foreign exchange 
exposures only in limited circumstances.

For further details of our structural foreign exchange exposures, see page 
179.

172

HSBC Holdings plc Annual Report and Accounts 2020

Banking book foreign exchange exposures

Banking book foreign exchange exposures arise from transactions 
in the banking book generating profit and loss or OCI reserves in a 
currency other than the reporting currency of the operating entity. 
Transactional foreign exchange exposure is transferred to Markets 
and Securities Services or Markets Treasury and managed within 
limits, with the exception of both exposure generating OCI 
reserves and limited residual foreign exchange exposure arising 
from timing differences or for other reasons.

HSBC Holdings risk management

As a financial services holding company, HSBC Holdings has 
limited market risk activities. Its activities predominantly involve 
maintaining sufficient capital resources to support the Group’s 
diverse activities; allocating these capital resources across the 
Group’s businesses; earning dividend and interest income on its 
investments in the businesses; payment of operating expenses; 
providing dividend payments to its equity shareholders and 
interest payments to providers of debt capital; and maintaining a 
supply of short-term liquid assets for deployment under 
extraordinary circumstances. 

The main market risks to which HSBC Holdings is exposed are 
banking book interest rate risk and foreign currency risk. Exposure 
to these risks arises from short-term cash balances, funding 
positions held, loans to subsidiaries, investments in long-term 
financial assets and financial liabilities including debt capital 
issued. The objective of HSBC Holdings’ market risk management 
strategy is to manage volatility in capital resources, cash flows and 
distributable reserves that could be caused by movements in 
market parameters. Market risk for HSBC Holdings is monitored 
by Holdings ALCO in accordance with its risk appetite statement.

HSBC Holdings uses interest rate swaps and cross-currency 
interest rate swaps to manage the interest rate risk and foreign 
currency risk arising from its long-term debt issues.

During 2020, HSBC Holdings undertook a variety of liability 
management exercises, including the issuance of fixed-rate 
eligible liabilities. Group Treasury generally hedged out the fixed-
rate interest rate risk on these liabilities in previous years, but as 
major interest rate markets remained at very low levels during 
2020, this was assessed on a case-by-case basis and in some 
cases the decision was made to retain the fixed-rate risk.

For quantitative disclosures on interest rate risk in the banking book, see 
pages 179 to 180.

Pension risk management processes

Our global pensions strategy is to move from defined benefit to 
defined contribution plans, where local law allows and it is 
considered competitive to do so. In 2020 we reviewed our risk 
appetite metrics and in 2021 we will continue to enhance and 
expand these to further assist the internal monitoring of our de-
risking programmes.

In defined contribution pension plans, the contributions that HSBC 
is required to make are known, while the ultimate pension benefit 
will vary, typically with investment returns achieved by investment 
choices made by the employee. While the market risk to HSBC of 
defined contribution plans is low, the Group is still exposed to 
operational and reputational risk.

In defined benefit pension plans, the level of pension benefit is 
known. Therefore, the level of contributions required by HSBC will 
vary due to a number of risks, including:

• investments delivering a return below that required to provide 

the projected plan benefits;

• the prevailing economic environment leading to corporate 
failures, thus triggering write-downs in asset values (both 
equity and debt);

• a change in either interest rates or inflation expectations, 
causing an increase in the value of plan liabilities; and

• plan members living longer than expected (known as longevity 

risk).

Following the end of the transition period following the UK's 
withdrawal from the EU, any reference to EU regulations and 
directives (including technical standards) should be read as a 
reference to the UK's version of such regulation or directive, as 
onshored into UK law under the European Union (Withdrawal) Act 
2018, as amended.

Capital figures and ratios in the previous table are calculated in 
accordance with the revised Capital Requirements Regulation and 
Directive, as implemented (‘CRR II’). The table presents them 
under the transitional arrangements in CRR II for capital 
instruments and after their expiry, known as the end point. The 
end point figures in the table above include the benefit of the 
regulatory transitional arrangements in CRR II for IFRS 9, which 
are more fully described below.

Where applicable, they also reflect government relief schemes 
intended to mitigate the impact of the Covid-19 outbreak.

Regulatory transitional arrangements for IFRS 9 
‘Financial Instruments’

We have adopted the regulatory transitional arrangements in 
CRR II for IFRS 9, including paragraph four of article 473a. Our 
capital and ratios are presented under these arrangements 
throughout the table above, including in the end point figures. 
Without their application, our CET1 ratio would be 15.7%.

The IFRS 9 regulatory transitional arrangements allow banks to 
add back to their capital base a proportion of the impact that 
IFRS 9 has upon their loan loss allowances during the first five 
years of use. The impact is defined as:

•  the increase in loan loss allowances on day one of IFRS 9 

adoption; and

• any subsequent increase in ECL in the non-credit-impaired 

book thereafter.

Any add-back must be tax affected and accompanied by a 
recalculation of exposure and RWAs. The impact is calculated 
separately for portfolios using the standardised (‘STD’) and internal 
ratings-based (‘IRB’) approaches. For IRB portfolios, there is no 
add-back to capital unless loan loss allowances exceed regulatory 
12-month expected losses. 

The EU’s CRR II ‘Quick Fix’ relief package enacted in June 2020 
increased from 70% to 100% the relief that banks may take for 
loan loss allowances recognised since 1 January 2020 on the
non-credit-impaired book.

In the current period, the add-back to CET1 capital amounted to 
$1.6bn under the STD approach with a tax impact of $0.4bn. At 31 
December 2019, the add-back to the capital base under the STD 
approach was $1.0bn with a tax impact of $0.2bn. 

Pension risk is assessed using an economic capital model that 
takes into account potential variations in these factors. The impact 
of these variations on both pension assets and pension liabilities is 
assessed using a one-in-200-year stress test. Scenario analysis 
and other stress tests are also used to support pension risk 
management. To fund the benefits associated with defined benefit 
plans, sponsoring Group companies, and in some instances 
employees, make regular contributions in accordance with advice 
from actuaries and in consultation with the plan’s trustees where 
relevant. These contributions are normally set to ensure that there 
are sufficient funds to meet the cost of the accruing benefits for 
the future service of active members. However, higher 
contributions are required when plan assets are considered 
insufficient to cover the existing pension liabilities. Contribution 
rates are typically revised annually or once every three years, 
depending on the plan.

The defined benefit plans invest contributions in a range of 
investments designed to limit the risk of assets failing to meet a 
plan’s liabilities. Any changes in expected returns from the 
investments may also change future contribution requirements. In 
pursuit of these long-term objectives, an overall target allocation is 
established between asset classes of the defined benefit plan. In 
addition, each permitted asset class has its own benchmarks, such 
as stock-market or property valuation indices or liability 
characteristics. The benchmarks are reviewed at least once every 
three to five years and more frequently if required by local 
legislation or circumstances. The process generally involves an 
extensive asset and liability review.

In addition, some of the Group’s pension plans hold longevity 
swap contracts. These arrangements provide long-term protection 
to the relevant plans against costs resulting from pensioners or 
their dependants living longer than initially expected. The most 
sizeable plan to do this is the HSBC Bank (UK) Pension Scheme, 
which holds longevity swaps covering approximately three-
quarters of the plan’s pensioner liabilities (50% with The Prudential 
Insurance Company of America and 25% with Swiss Re).

Capital risk in 2020

Capital overview

Capital adequacy metrics

Risk-weighted assets (‘RWAs’) ($bn)

Credit risk

Counterparty credit risk

Market risk

Operational risk

Total RWAs

Capital on a transitional basis ($bn)

Common equity tier 1 (‘CET1’) capital

Tier 1 capital

Total capital

Capital ratios on a transitional basis (%)

Common equity tier 1 ratio

Tier 1 ratio

Total capital ratio

Capital on an end point basis ($bn)

Common equity tier 1 (‘CET1’) capital

Tier 1 capital

Total capital

Capital ratios on an end point basis (%)

Common equity tier 1 ratio

Tier 1 ratio

Total capital ratio

Liquidity coverage ratio (‘LCR’)

Total high-quality liquid assets ($bn)

Total net cash outflow ($bn)

LCR ratio (%)

At

31 Dec

2020

31 Dec

2019

691.9   

42.8   

28.5   

94.3   

857.5   

136.1   

160.2   

184.4   

 15.9   

 18.7   

 21.5   

136.1   

158.5   

173.2   

 15.9   

 18.5   

 20.2   

677.9  
487.3  
 139.1   

676.6 

44.1 

29.9 

92.8 

843.4 

124.0 

148.4 

172.2 

14.7 

17.6 

20.4 

124.0 

144.8 

159.3 

14.7 

17.2 

18.9 

601.4 

400.5 

150.2 

HSBC Holdings plc Annual Report and Accounts 2020

173

Risk review 
 
 
 
 
 
 
 
 
 
 
 
Risk

Own funds

Own funds disclosure

(Audited)

Ref*

1

2

3

5

5a

6

28

29

36

43

44

45

51

57

58

59

Common equity tier 1 (‘CET1’) capital: instruments and reserves

Capital instruments and the related share premium accounts

–  ordinary shares

Retained earnings
Accumulated other comprehensive income (and other reserves)1
Minority interests (amount allowed in consolidated CET1)

Independently reviewed interim net profits net of any foreseeable charge or dividend

Common equity tier 1 capital before regulatory adjustments

Total regulatory adjustments to common equity tier 1

Common equity tier 1 capital

Additional tier 1 capital before regulatory adjustments

Total regulatory adjustments to additional tier 1 capital

Additional tier 1 capital

Tier 1 capital

Tier 2 capital before regulatory adjustments

Total regulatory adjustments to tier 2 capital

Tier 2 capital

Total capital

At

31 Dec

2020

$m

31 Dec

2019

$m

23,219   

23,219   

22,873 

22,873 

128,665   

127,188 

9,768   

4,079   

(252)   

165,479   

(29,429)   

136,050   

24,183   

(60)   

24,123   

160,173   

25,722   

(1,472)   

24,250   

1,735 

4,865 

(3,381) 

153,280 

(29,314) 

123,966 

24,453 

(60) 

24,393 

148,359 

25,192 

(1,401) 

23,791 

184,423   

172,150 

*  The references identify the lines prescribed in the European Banking Authority (‘EBA’) template, which are applicable and where there is a value.
1 Following the call and subsequent redemption of HSBC Holdings' non-cumulative preference shares, the remaining share premium that related to 

such preference shares is now treated as an 'other reserve' and included in CET1.

Throughout 2020, we complied with the PRA’s regulatory capital 
adequacy requirements, including those relating to stress testing. 
At 31 December 2020, our CET1 ratio increased to 15.9% from 
14.7% at 31 December 2019.

CET1 capital increased during the year by $12.1bn, mainly as a 
result of:

•

•

•

•

•

•

the cancellation of the fourth interim dividend of $3.4bn for 
2019;

favourable foreign currency translation differences of $3.4bn;

capital generation of $2.8bn net of dividends relating to other 
equity instruments;

a fall of $2.1bn in the deduction for other intangible assets due 
to changes to the capital treatment of software assets;

a $1.8bn increase in fair value through other comprehensive 
income reserve; and

a $1.8bn fall in the deduction for excess expected loss.

These increases were partly offset by:

•

•

an interim dividend for 2020 of $3.1bn; and

a $0.8bn fall in allowable non-controlling interest in CET1. This 
partly reflected the acquisition in May 2020 of additional 
shares representing 18.66% of the capital of HSBC Trinkaus 
and Burkhardt from Landesbank Baden-Württemberg, the 
principal minority shareholder.

We have applied the revised regulatory treatment of software 
assets, which became a UK requirement in December 2020. 
Subsequently, the PRA announced its intention to consult on a 
reversal of this change in due course and recommended firms do 
not base their distribution decision on any capital increase from 
applying this requirement. As a result, we have not considered the 
related capital benefit in our distributions. The impact of the 
change on our CET1 ratio was 0.2 percentage points. 

Our Pillar 2A requirement at 31 December 2020, as per the PRA’s 
Individual Capital Requirement based on a point-in-time 
assessment, was equivalent to  3.0% of RWAs, of which 1.7% was 
met by CET1.

Risk-weighted assets 

RWAs by global business

Credit risk

Counterparty credit risk

Market risk

Operational risk

At 31 Dec 2020

WPB

$bn

CMB

$bn

135.9   

300.0   

0.7   

1.6   

34.6   

172.8   

0.2   

0.9   

26.6   

327.7   

GBM Corporate Centre

$bn

168.6   

41.2   

22.9   

32.4   

265.1   

$bn

87.4   

0.7   

3.1   

0.7   

91.9   

Total

$bn

691.9 

42.8 

28.5 

94.3 

857.5 

174

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RWAs by geographical region

Credit risk

Counterparty credit risk

Market risk

Operational risk

At 31 Dec 2020

Footnotes

1

Europe

$bn

Asia

$bn

MENA

$bn

211.2   

307.3   

50.2   

23.7   

23.5   

25.9   

10.7   

20.9   

45.3   

1.4   

2.4   

6.2   

284.3   

384.2   

60.2   

North
America

Latin
America

$bn

96.1   

5.3   

4.7   

11.7   

117.8   

$bn

27.1   

1.7   

1.2   

5.2   

Total

$bn

691.9 

42.8 

28.5 

94.3 

35.2   

857.5 

1  RWAs are non-additive across geographical regions due to market risk diversification effects within the Group.

RWA movement by global business by key driver

RWAs at 1 Jan 2020

Asset size

Asset quality

Model updates

Methodology and policy

Acquisitions and disposals

Foreign exchange movements

Total RWA movement

RWAs at 31 Dec 2020

RWA movement by geographical region by key driver

RWAs at 1 Jan 2020

Asset size

Asset quality

Model updates

Methodology and policy

Acquisitions and disposals

Foreign exchange movements

Total RWA movement

RWAs at 31 Dec 2020

Credit risk, counterparty credit risk and operational risk

WPB

$bn

161.4   

2.2   

0.3   

2.7   

2.6   

—   

2.0   

9.8   

CMB

$bn

325.1   

(12.3)   

14.5   

0.9   

(8.6)   

—   

7.2   

1.7   

GBM

$bn

248.7   

(3.1)   

9.3   

(2.2)   

(13.9)   

—   

3.4   

(6.5)   

171.2   

326.8   

242.2   

Corporate 
Centre

Market
risk

$bn

78.3   

2.4   

0.4   

—   

6.2   

1.0   

0.5   

10.5   

88.8   

$bn

29.9   

1.1   

—   

(2.0)   

(0.5)   

—   

—   

(1.4)   

28.5   

Credit risk, counterparty credit risk and operational risk

Europe

$bn

Asia

$bn

MENA

$bn

North
America

Latin
America

$bn

$bn

257.9   

345.9   

55.5   

117.6   

36.6   

(9.9)   

7.2   

1.7   

(6.8)   

—   

10.7   

3.4   

10.9   

0.3   

(3.0)   

—   

5.8   

2.9   

17.4   

1.1   

1.3   

—   

(0.2)   

1.0   

(0.9)   

2.3   

(6.1)   

4.6   

(0.6)   

(3.2)   

—   

0.8   

(4.5)   

0.7   

0.5   

—   

(0.5)   

—   

(3.3)   

(2.6)   

260.8   

363.3   

57.8   

113.1   

34.0   

Market risk

$bn

29.9   

1.1   

—   

(2.0)   

(0.5)   

—   

—   

(1.4)   

28.5   

Total
RWAs

$bn

843.4 

(9.7) 

24.5 

(0.6) 

(14.2) 

1.0 

13.1 

14.1 

857.5 

Total
 RWAs

$bn

843.4 

(9.7) 

24.5 

(0.6) 

(14.2) 

1.0 

13.1 

14.1 

857.5 

Risk-weighted assets (‘RWAs’) rose by $14.1bn during the year, 
including an increase of $13.1bn due to foreign currency 
translation differences. The $1.0bn increase (excluding foreign 
currency translation differences) is described in the commentary 
below. During the period we recognised RWA reductions through 
our transformation programme of $51.5bn. These are included 
within the movements described below, primarily under asset size 
movements and methodology and policy changes.

Asset size

The $9.7bn fall in RWAs due to asset size movements was due to 
reductions in CMB and GBM, partly offset by increases in 
Corporate Centre, WPB and market risk.

The $12.3bn decrease in CMB RWAs was primarily due to 
management initiatives under our transformation programme, 
most notably in Europe, North America and Asia.

The $3.1bn fall in GBM RWAs was driven by $16.4bn of 
reductions under the transformation programme, largely in North 
America, Europe, Asia and Latin America. This was partly offset by 
lending growth, mostly in Asia and MENA, and mark-to-market 
movements in counterparty credit risk RWAs.

In Asia, an increase in the value of material holdings and lending 
growth in the property market drove increases in Corporate Centre 
and WPB RWAs of $2.4bn and $2.2bn respectively.

Market risk RWAs increased by $1.1bn, largely due to market 
conditions, partly offset by management initiatives.

Asset quality

Changes in asset quality led to an RWA increase of $24.5bn, 
mostly in CMB and GBM. This included credit migration of 

$29.7bn, largely caused by the Covid-19 outbreak. These 
downgrades were mostly in Asia, North America and Europe, 
partly offset by decreases due to portfolio mix changes.

Model updates

The $0.6bn fall in RWAs due to model updates comprised 
decreases in GBM and market risk, partly offset by increases in 
WPB and CMB.

The $2.2bn reduction in GBM RWAs was due to corporate model 
updates in our major regions, most significantly in North America.

Market risk RWAs fell by $2.0bn primarily as a result of changes to 
the calculation of risks not in VaR, and the implementation of a 
new model for an options portfolio.

The increases in WPB and CMB credit risk RWAs were mainly due 
to updates to French, Hong Kong and North American models.

Methodology and policy

The $14.2bn reduction in RWAs due to methodology and policy 
changes included reductions as a result of risk parameter 
refinements and regulatory responses to the Covid-19 outbreak, 
offset by changes in approach to credit risk exposures.

GBM and CMB reduced RWAs by $23.8bn, of which $11.5bn were 
under the transformation programme. These reductions stem from 
a variety of actions, including risk parameter refinements, 
improved collateral linkage, and data enhancement.

Changes under the CRR ‘Quick Fix’ relief package also reduced 
CMB and GBM RWAs. Implementation of the revised small and 
medium-sized enterprise supporting factor led to a $3.4bn fall in 
RWAs for CMB while the new infrastructure supporting factor 

HSBC Holdings plc Annual Report and Accounts 2020

175

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

caused a $0.5bn fall in GBM. Partly offsetting these reductions, the 
recent change in the regulatory treatment of software assets 
caused a $2.3bn increase in Corporate Centre RWAs.

At the start of 2020, we implemented two changes that led to a 
$6.4bn increase in our wholesale credit risk exposures. Application 
of the new securitisation framework to the pre-existing book 
caused RWAs to rise by $3.4bn, mainly in Corporate Centre and 
GBM. Following the conclusion of discussions with the PRA, we 
also transferred several UK corporate portfolios onto a Foundation 
IRB approach, causing a $3bn rise in RWAs in CMB and GBM.

Leverage ratio1

Corporate Centre and WPB RWAs increased by $5bn as a result of 
updates to exposures in Asia and the French retail business. 
The $0.5bn fall in market risk largely comprised reductions from 
updates to the calculation of stressed VaR and foreign exchange 
risk, partly offset by increases due to risks not in VaR.
Acquisitions and disposals

The increase in our shareholding of The Saudi British Bank from 
29.2% to 31.0% led to $1.0bn additional Corporate Centre RWAs.

Ref*

20

21

22

Tier 1 capital

Total leverage ratio exposure

Leverage ratio

EU-23 Choice of transitional arrangements for the definition of the capital measure

UK leverage ratio exposure – quarterly average

UK leverage ratio – quarterly average

UK leverage ratio – quarter end

Footnotes

At

31 Dec

2020

$bn

158.5   

2,897.1   

%

 5.5 

31 Dec

2019

$bn

144.8 

2,726.5 

%

 5.3 

Fully phased-in Fully phased-in

2,555.5   

2,535.4 

%

 6.1 

 6.2 

%

 5.8 

 5.7 

2

2

2

*  The references identify the lines prescribed in the EBA template.
1  The CRR II regulatory transitional arrangements for IFRS 9 are applied in both leverage ratio calculations.
2  UK leverage ratio denotes the Group’s leverage ratio calculated under the PRA’s UK leverage framework. This measure excludes qualifying central 

bank balances and loans under the UK Bounce Back Loan Scheme from the calculation of exposure.

Our leverage ratio calculated in accordance with the Capital 
Requirements Regulation was 5.5% at 31 December 2020, up 
from 5.3% at 31 December 2019, due to an increase in tier 1 
capital, offset by an increase in exposure primarily due to growth 
in central bank deposits and financial investments. The change in 
treatment of software assets benefited our leverage ratio by 0.1 
percentage points.

At 31 December 2020, our UK minimum leverage ratio 
requirement of 3.25% under the PRA’s UK leverage framework 
was supplemented by an additional leverage ratio buffer of 0.7% 
and a countercyclical leverage ratio buffer of 0.1%. These 
additional buffers translated into capital values of $17.9bn and 
$1.8bn respectively. We exceeded these leverage requirements.

Pillar 3 disclosure requirements

Pillar 3 of the Basel regulatory framework is related to market 
discipline and aims to make financial services firms more 
transparent by requiring publication of wide-ranging information 
on their risks, capital and management. Our Pillar 3 Disclosures at 
31 December 2020 is published on our website, www.hsbc.com/
investors.

Operating entities’ liquidity

HSBC UK Bank plc (ring-fenced bank)

HSBC Bank plc (non-ring-fenced bank)

The Hongkong and Shanghai Banking Corporation – Hong Kong branch

The Hongkong and Shanghai Banking Corporation – Singapore branch

Hang Seng Bank

HSBC Bank China

HSBC Bank USA

HSBC Continental Europe

HSBC Middle East – UAE branch

HSBC Canada

HSBC Mexico

176

HSBC Holdings plc Annual Report and Accounts 2020

Liquidity and funding risk in 2020

Liquidity metrics

At 31 December 2020, all of the Group’s material operating 
entities were above regulatory minimum liquidity and funding 
levels.

Each entity maintains sufficient unencumbered liquid assets to 
comply with local and regulatory requirements. The liquidity value 
of these liquidity assets for each entity is shown in the following 
table along with the individual LCR levels on a European 
Commission (‘EC’) basis. This basis may differ from local LCR 
measures due to differences in the way non-EU regulators have 
implemented the Basel III standards.

Each entity maintains sufficient stable funding relative to the 
required stable funding assessed using the NSFR or other 
appropriate metrics.

Given our continued focus on the quality of regulatory reporting, 
liquidity reporting processes are undergoing a detailed review, 
which may lead to impacts on some of our regulatory ratios, 
including LCR and NSFR. All entities are above regulatory 
minimums and are expected to continue to remain above risk 
appetite. 

The Group liquidity and funding position at the end of 2020 is 
analysed in the following sections.

Footnotes

1

2

3

3

4

4

LCR

%

198   

136   

195   

162   

212   

232   

130   

143   

280   

165   

198   

At 31 December 2020

HQLA

Net outflows

NSFR

$bn

121   

138   

146   

16   

50   

24   

106   

48   

11   

30   

10   

$bn

61   

102   

75   

10   

24   

10   

82   

34   

4   

18   

5   

%

164 

124 

146 

135 

151 

158 

130 

130 

164 

136 

139 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Operating entities’ liquidity (continued)

HSBC UK Bank plc (ring-fenced bank)

HSBC Bank plc (non-ring-fenced bank)

The Hongkong and Shanghai Banking Corporation – Hong Kong branch

The Hongkong and Shanghai Banking Corporation – Singapore branch

Hang Seng Bank

HSBC Bank China

HSBC Bank USA

HSBC Continental Europe

HSBC Middle East – UAE branch

HSBC Canada

HSBC Mexico

Footnotes

1

2

3

3

4

4

LCR

%

165 

142 

163 

147 

185 

180 

125 

152 

202 

124 

208 

At 31 December 2019

HQLA

Net outflows

$m

75

103

109

14

42

21

73

44

11

18

9

$m

45

72

67

10

23

11

59

29

5

14

4

NSFR

%

150

106

128

120

148

151

122

117

159

124

136

1 HSBC UK Bank plc refers to the HSBC UK liquidity group, which comprises four legal entities: HSBC UK Bank plc (including the Dublin branch), 
Marks and Spencer Financial Services plc, HSBC Private Bank (UK) Ltd and HSBC Trust Company (UK) Limited, managed as a single operating 
entity, in line with the application of UK liquidity regulation as agreed with the PRA.

2 HSBC Bank plc includes oversea branches and special purpose entities consolidated by HSBC for financial statements purposes.
3 The Hongkong and Shanghai Banking Corporation – Hong Kong branch and The Hongkong and Shanghai Banking Corporation – Singapore 

branch represent the material activities of The Hongkong and Shanghai Banking Corporation. Each branch is monitored and controlled for liquidity 
and funding risk purposes as a stand-alone operating entity.

4 HSBC Continental Europe and HSBC Canada represent the consolidated banking operations of the Group in France and Canada, respectively. 

HSBC Continental Europe and HSBC Canada are each managed as single distinct operating entities for liquidity purposes.

At 31 December 2020, all of the Group’s principal operating 
entities were well above regulatory minimum levels. 

The most significant movements in 2020 are explained below:

1  As defined in EU regulations, level 1 assets means ‘assets of 

extremely high liquidity and credit quality’, and level 2 assets means 
‘assets of high liquidity and credit quality’.

• HSBC UK Bank plc improved its liquidity ratio to 198%, mainly 

driven by growth in commercial and retail deposits.  

Liquidity pool by currency

• HSBC Bank plc and HSBC Continental Europe maintained a 

strong liquidity position, with an increase in HQLA mainly due 
to deposit growth. However the LCR declined, reflecting a 
reassessment of potential outflows, particularly with respect to 
committed facilities.

• The Hongkong and Shanghai Banking Corporation – Hong 

Kong branch, Hang Seng Bank and HSBC Bank China remained 
in a strong liquidity position, mainly as result of an increase in 
customer deposits.

• HSBC Bank USA remained in a strong liquidity position, mainly 
driven by an increase in deposits and a reduction in illiquid 
assets. 

• HSBC Bank Middle East – UAE branch remained in a strong 

liquidity position, with a liquidity ratio of 280%.

• HSBC Canada increased its LCR to 165%, mainly driven by 
increased customer deposits and covered bond issuance. 

 Liquid assets

$

£

€

HK$

Other

Total

$bn

$bn

$bn

$bn

$bn

$bn

Liquidity pool at 31 Dec 
2020

Liquidity pool at 31 Dec 
2019

  218    176    117   

74   

93    678 

179   

117   

93   

47   

165   

601 

Consolidated liquidity metrics

At 31 December 2020, the total HQLA held at entity level 
amounted to $857bn (31 December 2019: $646bn), an increase of 
$211bn, reflecting the increases in entity liquidity positions 
described above. Consistent with prior periods, the application of 
requirements under the EC Delegated Act resulted in an 
adjustment of $179bn (31 December 2019: $45bn) to reflect the 
limitations in the fungibility of entity liquidity around the Group. As 
a consequence, the Group consolidated LCR was 139% at 
31 December 2020 (31 December 2019: 150%). The $179bn of 
HQLA remains available to cover liquidity risk in the relevant 
entities. 

At 31 December 2020, the Group had a total of $678bn of highly 
liquid unencumbered LCR eligible liquid assets (31 December 
2019: $601bn) held in a range of asset classes and currencies. Of 
these, 90% were eligible as level 1 (31 December 2019: 90%). 

The following tables reflect the composition of the liquidity pool by 
asset type and currency at 31 December 2020: 

The methodology used in the Group consolidated LCR in relation 
to the treatment of part of the Group’s HQLA is currently under 
review. Upon implementation of this revised approach it is 
anticipated that the Group’s consolidated LCR will reduce, 
although remain within appetite. The liquidity position of the 
entities is unaffected by this change and remains the key focus.

Liquidity pool by asset type

Liquidity 
pool

Cash

Level 11

Level 21

Cash and balance at central bank

307   

307   

—   

$bn

$bn

$bn

$bn

— 

High-quality liquid assets (in entities)

EC Delegated Act adjustment

Central and local government 
bonds

Regional government public 
sector entities

International organisation and 
multilateral developments banks

Covered bonds

Other

Total at 31 Dec 2020

Total at 31 Dec 2019

312   

—   

263   

49 

12   

—   

11   

1 

14   

11   

22   

—   

—   

—   

14   

3   

10   

678   

307   

301   

601

158

383

— 

8 

12 

70 

60

Group LCR HQLA

Net outflows

Liquidity coverage ratio

31 Dec
2020

$bn

857

(179)

678

487

At

30 Jun 
2020

$bn

784

(130)

654

443

31 Dec 
2019

$bn

646

(45)

601

400

139%

148%

150%

HSBC Holdings plc Annual Report and Accounts 2020

177

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Sources of funding

Our primary sources of funding are customer current accounts and 
savings deposits payable on demand or at short notice. We issue 
secured and unsecured wholesale securities to supplement 
customer deposits, meet regulatory obligations and to change the 
currency mix, maturity profile or location of our liabilities. 

The following ‘Funding sources’ and ‘Funding uses’ tables provide 
a view of how our consolidated balance sheet is funded. In 
practice, all the principal operating entities are required to manage 
liquidity and funding risk on a stand-alone basis.

The tables analyse our consolidated balance sheet according to 
the assets that primarily arise from operating activities and the 
sources of funding primarily supporting these activities. Assets 
and liabilities that do not arise from operating activities are 
presented at a net balancing source or deployment of funds. 

In 2020, the level of customer accounts continued to exceed the 
level of loans and advances to customers. The positive funding 
gap was predominantly deployed in liquid assets.

Funding sources 
(Audited)

Customer accounts
Deposits by banks

Repurchase agreements – non-trading

Debt securities in issue

Cash collateral, margin and settlement accounts

Subordinated liabilities

2020

$m

  1,642,780   
82,080   
111,901   

95,492   

78,565   

21,951   

2019

$m

1,439,115 

59,022 
140,344 

104,555 

71,002 

24,600 

Financial liabilities designated at fair value

157,439   

164,466 

Liabilities under insurance contracts

Trading liabilities
–  repos

–  stock lending

–  other trading liabilities

Total equity

Other balance sheet liabilities

At 31 Dec

107,191   

75,266   

11,728   
4,597   

58,941   

204,995   

406,504   

97,439 

83,170 

558 
9,702 

72,910 

192,668 

338,771 

  2,984,164   

2,715,152 

Funding uses
(Audited)

Footnotes

2020
$m

2019
$m

Loans and advances to customers

  1,037,987   

1,036,743 

Loans and advances to banks

81,616   

69,203 

Reverse repurchase agreements – non-
trading

Prepayments, accrued income and other 
assets
–  cash collateral, margin and settlement 

230,628   

240,862 

1

76,859   

63,891 

accounts 

Assets held for sale

Trading assets
–  reverse repos
–  stock borrowing
–  other trading assets

Financial investments
Cash and balances with central banks

Other balance sheet assets

At 31 Dec

76,859   

63,891 

299   

123 

231,990   

254,271 

13,990   
8,286   

209,714   

490,693   

304,481   

529,611   

13,659 
7,691 

232,921 

443,312 

154,099 

452,648 

  2,984,164   

2,715,152 

1 

Includes only those financial instruments that are subject to the 
impairment requirements of IFRS 9. ‘Prepayments, accrued income 
and other assets’, as presented within the consolidated balance sheet 
on page 280, includes both financial and non-financial assets.

Wholesale term debt maturity profile

The maturity profile of our wholesale term debt obligations is set 
out in the following table.

The balances in the table are not directly comparable with those in 
the consolidated balance sheet because the table presents gross 
cash flows relating to principal payments and not the balance 
sheet carrying value, which includes debt securities and 
subordinated liabilities measured at fair value.

Wholesale funding cash flows payable by HSBC under financial liabilities by remaining contractual maturities

Due over 
1 month 
but not 
more than 
3 months

Due over 
3 months 
but not 
more than 
6 months

Due over 
6 months 
but not 
more than 
9 months

Due over 
9 months
but not more
than 
1 year

Due over
1 year
but not 
more than 
2 years

Due over 
2 years
but not 
more than 
5 years

Due over
5 years

Due not
more than
1 month

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

18,057   

16,848   

20,314   

15,208   

7,561   

20,768   

49,948    59,911    208,615 

4,048   

9,625   

2,075   

—   

8,440   

3,363   

1,539   

—   

—   

19   

119   

9,977   

3,915   

1,451   

28   

—   

171   

6,186   

4,684   

1,242   

—   

—   

45   

2,945   

2,005   

1,241   

750   

—   

41   

1,474   

1,454    1,546    36,070 

9,295   

35,834    49,209    117,930 

3,702   

2,514   

—   

4,979    6,765    22,994 

3,917   

—   

—   

—   

7,209 

1,094 

410   

1,865   

646   

3,316 

1,196   

3,387   

4,772   

3,051   

579   

3,373   

1,899    1,745    20,002 

618   

618   

—   

—   

—   

—   

237   

237   

—   

—   

—   

—   

12   

12   

—   

12   

12   

—   

6,081    22,941    29,901 

6,081    21,085    28,045 

—    1,856   

1,856 

18,675   

16,848   

20,551   

15,208   

7,573   

20,780   

56,029    82,852    238,516 

–  secured asset-backed commercial paper

1,094   

Debt securities issued

–  unsecured CDs and CP

–  unsecured senior MTNs

–  unsecured senior structured notes

–  secured covered bonds

–  secured ABS

–  others

Subordinated liabilities

–  subordinated debt securities

–  preferred securities

At 31 Dec 2020

Debt securities issued

–  unsecured CDs and CP

–  unsecured senior MTNs

–  unsecured senior structured notes

–  secured covered bonds

–  secured asset-backed commercial paper

–  secured ABS

–  others

Subordinated liabilities

–  subordinated debt securities

–  preferred securities

At 31 Dec 2019

17,728   

4,913   

8,198   

1,698   

—   

1,933   

—   

986   

1,523   

1,500   

23   

19,758   

12,280   

2,462   

1,386   

—   

—   

—   

3,630   

—   

—   

—   

15,654   

11,020   

695   

1,711   

—   

—   

248   

1,980   

22   

22   

—   

16,284   

8,745   

4,595   

1,003   

—   

—   

161   

1,780   

2,000   

2,000   

—   

16,132   

11,509   

35,836   

57,387    53,768    232,547 

1,156   

2,095   

1,578   

53,296 

1,753   

25,121   

42,316    38,812    123,952 

923   

1,139   

—   

—   

3,579   

6,102   

9,596   

25,998 

749   

—   

205   

3,661   

1,159   

—   

911   

—   

741   

6,708 

1,933 

2,266 

808   

5,026   

2,302   

1,882   

18,394 

—   

—   

—   

754   

754   

—   

2,424    26,809   

33,532 

2,424    24,587   

31,287 

—   

2,222   

2,245 

19,251   

19,758   

15,676   

18,284   

16,132   

36,590   

59,811    80,577    266,079 

178

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Structural foreign exchange risk in 2020

Structural foreign exchange exposures represent net investments 
in subsidiaries, branches and associates, the functional currencies 
of which are currencies other than the US dollar. Exchange 
differences on structural exposures are recognised in ‘Other 
comprehensive income’.

Net structural foreign exchange exposures

Footnotes

1

Currency of structural exposure

Hong Kong dollars

Pound sterling 

Chinese renminbi

Euros

Canadian dollars

Indian rupees

Mexican pesos

Saudi riyals

UAE dirhams

Malaysian ringgit

Singapore dollars

Australian dollars

Taiwanese dollars

Indonesian rupiah

Swiss francs

Korean won

Thai baht

Egyptian pound

Others, each less than $700m

At 31 Dec

2020

$m

47,623   
35,285   
32,165   
15,672   
5,123   
4,833   

4,139   
3,892   
3,867   
2,771   
2,473   
2,357   
2,036   
1,726   
1,444   
1,368   
991   
889   
6,858   
175,512   

2019

$m

46,527 

33,383 

28,847 

14,881 

4,416 

4,375 

4,600 
4,280 

4,105 

2,695 

2,256 

1,898 

1,957 

1,665 

1,188 

1,245 

910 

875 

7,029 

167,132 

1  At 31 December 2020, we had forward foreign exchange contracts 

of $11.2bn (2019: $10.5bn) in order to manage our sterling structural 
foreign exchange exposure. 

Shareholders’ equity would decrease by $2,427m (2019: $2,298m) 
if euro and sterling foreign currency exchange rates weakened by 
5% relative to the US dollar. 

Interest rate risk in the banking book in 2020

Net interest income sensitivity

The following tables set out the assessed impact to a hypothetical 
base case projection of our NII (excluding insurance) under the 
following scenarios:

• an immediate shock of 25 basis points (‘bps’) to the current 

market-implied path of interest rates across all currencies on 
1 January 2021 (effects over one year and five years); and

• an immediate shock of 100bps to the current market-implied 
path of interest rates across all currencies on 1 January 2021 
(effects over one year and five years).

The sensitivities shown represent our assessment of the change to 
a hypothetical base case NII, assuming a static balance sheet and 

NII sensitivity to an instantaneous change in yield curves (12 months)

no management actions from the Markets Treasury business. They 
incorporate the effect of interest rate behaviouralisation, managed 
rate product pricing assumptions and customer behaviour, 
including prepayment of mortgages or customer migration from 
non-interest-bearing to interest-bearing deposit accounts under 
the specific interest rate scenarios. Market uncertainty and our 
competitors’ behaviours also need to be factored in when 
analysing these results. The scenarios represent interest rate 
shocks to the current market implied path of rates.

The NII sensitivity analysis performed in the case of a down-shock 
does not include floors to the shocked market rates for wholesale 
assets and liabilities including those denominated in US dollars 
and sterling. Floors have however been maintained for deposits 
and loans to customers where this is contractual or where 
negative rates would not be applied. This is a change from the NII 
sensitivity approach published in the Annual Report and Accounts 
2019, where market rates were floored to zero, unless the central 
bank rate was already negative, as in the case of the euro, Swiss 
franc and Japanese yen. This reflects the increased risk of 
negative market interest rates going forward.

As such, the one-year and five-year NII sensitivities in the down-
shock scenarios have increased in December 2020 at Group level 
when compared with December 2019. This was driven by the 
change in approach, changes in the forecasted yield curves and 
changes in balance sheet composition. The NII sensitivities are 
forecasted for the whole period of one and five years each quarter.

The NII sensitivities shown are indicative and based on simplified 
scenarios. Immediate interest rate rises of 25bps and 100bps 
would increase projected NII for the 12 months to 31 December 
2021 by $1,647m and $5,348m, respectively. Conversely, falls of 
25bps and 100bps would decrease projected NII for the 12 months 
to 31 December 2021 by $1,508m and $4,854m, respectively. 

The sensitivity of NII for 12 months increased by $2,550m in the 
plus 100bps parallel shock and increased by $(1,542)m in the 
minus 100bps parallel shock, comparing December 2021 with 
December 2020. 

The increase in the sensitivity of NII for 12 months in the plus 
100bps parallel shock was mainly driven by the growth of rate 
insensitive customer deposits, against an increase in rate sensitive 
assets due to a general build-up of liquidity throughout the Group, 
which has been deployed in short-term investments 
(predominantly cash, held-to-collect-and-sell securities, and 
reverse repos) as well as shortening of Markets Treasury’s 
positioning in view of the significant drop in interest rates. 

The change in NII sensitivity for five years is also driven by the 
factors above. 

The tables do not include Markets Treasury management actions 
or changes in MSS net trading income that may further limit the 
impact.

The limitations of this analysis are discussed within the ‘Treasury 
risk management’ section on page 169. 

Change in Jan 2021 to Dec 2021 (based on balance sheet at 31 December 2020)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Change in Jan 2020 to Dec 2020 (based on balance sheet at 31 December 2019)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Currency

$

$m

HK$

$m

£

$m

€

$m

Other

$m

Total

$m

223   

(227)   

423   

(343)   

555   

(548)   

126   

(88)   

320   

1,647 

(302)   

(1,508) 

546   

1,267   

1,811   

502   

1,222   

5,348 

(565)   

(749)   

(1,906)   

(299)   

(1,335)   

(4,854) 

59   

(91)   

(16)   

198   

(255)   

504   

278   

(332)   

1,123   

(490)   

(1,023)   

(1,049)   

116   

11   

441   

(23)   

202   

(182)   

746   

(726)   

853 

(849) 

2,798 

(3,311) 

The net interest income sensitivities arising from the scenarios presented in the tables above are not directly comparable. This is due to timing 
differences relating to interest rate changes and the repricing of assets and liabilities.

HSBC Holdings plc Annual Report and Accounts 2020

179

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

NII sensitivity to an instantaneous change in yield curves (5 years)

Change in Jan 2021 to Dec 2021 (based on balance sheet at 31 December 2020)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Change in Jan 2020 to Dec 2020 (based on balance sheet at 31 December 2019)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Year 1

Year 2

Year 3

Year 4

Year 5

$m

$m

$m

$m

$m

Total

$m

1,647   

1,866   

1,930   

2,028   

2,100   

9,571 

(1,508)   

(1,986)   

(2,307)   

(2,045)   

(2,113)   

(9,959) 

5,348   

6,538   

7,083   

7,444   

7,736    34,149 

(4,854)   

(6,174)   

(7,087)   

(7,660)   

(8,323)   

(34,098) 

853   

1,158   

1,348   

1,449   

1,523   

6,331 

(849)   

(1,205)   

(1,402)   

(1,562)   

(1,649)   

(6,667) 

2,798   

4,255   

4,915   

5,155   

5,454   

22,577 

(3,311)   

(4,621)   

(5,289)   

(5,766)   

(6,164)   

(25,151) 

Sensitivity of capital and reserves

Hold-to-collect-and-sell stressed VaR is a quantification of the 
potential losses to a 99% confidence level of the portfolio of 
securities held under a hold-to-collect-and-and-sell business model 
in the Markets Treasury business. The portfolio is accounted for at 
fair value through other comprehensive income together with the 
derivatives held in designated hedging relationships with these 
securities. The mark-to-market of this portfolio therefore has an 
impact on CET1. Stressed VaR is quantified based on the worst 
losses over a one-year period going back to the beginning of 2007 
and the assumed holding period is 60 days. At December 2020, 
the stressed VaR of the portfolio was $2.94bn (2019: $3.2bn).

Alongside our monitoring of the stressed VaR of this portfolio, we 
also monitor the sensitivity of reported cash flow hedging reserves 
to interest rate movements on a yearly basis by assessing the 
expected reduction in valuation of cash flow hedges due to 
parallel movements of plus or minus 100bps in all yield curves. 

Although we allow rates to go negative in this assessment, we 
apply a floor on the shocks in the minus 100bps scenario set at the 
lower of either minus 50bps or the central bank deposit rate. 
These particular exposures form only a part of our overall interest 
rate exposure.

The following table describes the sensitivity of our cash flow 
hedge reported reserves to the stipulated movements in yield 
curves at the year end. The sensitivities are indicative and based 
on simplified scenarios. 

Comparing December 2020 with December 2019, the sensitivity of 
the cash flow hedging reserve reduced by $37m in the plus 
100bps scenario and reduced by $323m in the minus 100bps 
scenario. The reduction in the minus 100bps scenario was mainly 
driven by the significant downwards movement in sterling yields 
during 2020, which meant that the floor at minus 50bps had an 
impact across the yield curve.

Sensitivity of cash flow hedging reported reserves to interest rate movements

At 31 Dec 2020

+100 basis point parallel move in all yield curves

As a percentage of total shareholders’ equity

-100 basis point parallel move in all yield curves

As a percentage of total shareholders’ equity

At 31 Dec 2019

+100 basis point parallel move in all yield curves

As a percentage of total shareholders’ equity

-100 basis point parallel move in all yield curves

As a percentage of total shareholders’ equity

Third-party assets in Markets Treasury

For our Markets Treasury governance framework, see page 170.

Third-party assets in Markets Treasury increased by 40% 
compared with 31 December 2019. Commercial surplus went up 
in 2020 due to an increase in client deposits and lower credit 
growth. This was partly reflected in the increase of $135bn in 
‘Cash and balances at central banks’. 

Third-party assets in Markets Treasury 

Cash and balances at central banks

Trading assets

Loans and advances:

–  to banks

–  to customers

Reverse repurchase agreements

Financial investments

Other

At 31 Dec

$m

(665)

(0.34)%

409

0.21%

(702)

(0.38)%

732

0.4%

The increase of $42bn across ‘Loans and advances to banks’ and 
‘Reverse repurchase agreements’ was driven by the short-term 
investment of part of this surplus. The remainder was invested in 
high-quality liquid assets, contributing to the increase of $39bn in 
‘Financial Investments’.

2020

$m

263,656   

392   

34,555   

1,167   

61,693   

391,017   

8,724   

761,204   

2019

$m

129,114 

268 

24,466 

310 

29,868 

351,842 

7,655 

543,523 

Defined benefit pension plans

assets with determinable cash flows.

Market risk arises within our defined benefit pension plans to the 
extent that the obligations of the plans are not fully matched by 

For details of our defined benefit plans, including asset allocation, see Note 5 
on the financial statements, and for pension risk management, see page 172.

180

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Additional market risk measures applicable only to the 
parent company

HSBC Holdings monitors and manages foreign exchange risk and 
interest rate risk. In order to manage interest rate risk, HSBC 
Holdings uses the projected sensitivity of its NII to future changes 
in yield curves and the interest rate repricing gap tables.

During 2020, HSBC Holdings undertook a variety of liability 
management exercises, replacing approximately $11.5bn of short-
term fixed-rate debt and their corresponding hedges with longer 
term fixed-rate debt of five to 10 years. As major interest rate 
markets remained at very low levels during 2020, we left this 
replacement debt unhedged. In addition to these exercises, 
approximately $4bn of debt matured in 2020 and we issued 
$2.5bn of new debt. The impact of this can be observed in the 
‘Repricing gap analysis of HSBC Holdings’ table below, where the 
gap switched from a net liability to a net asset profile in the ‘Up to 
1 year’ bucket, with a concurrent liability gap increase in the ‘5 to 
10 years’ bucket. Additionally it can be observed in the NII 
sensitivity tables, where NII now increases as interest rates rise. 

Foreign exchange risk

HSBC Holdings’ foreign exchange exposures derive almost entirely 
from the execution of structural foreign exchange hedges on 

NII sensitivity to an instantaneous change in yield curves (12 months)

behalf of the Group as its business-as-usual foreign exchange 
exposures are managed within tight risk limits. At 31 December 
2020, HSBC Holdings had forward foreign exchange contracts of 
$11.2bn (2019: $10.5bn) to manage the Group’s sterling structural 
foreign exchange exposure.

Sensitivity of net interest income 

HSBC Holdings monitors NII sensitivity over a five-year time 
horizon, reflecting the longer-term perspective on interest rate risk 
management appropriate to a financial services holding company. 
These sensitivities assume that any issuance where HSBC 
Holdings has an option to reimburse at a future call date is called 
at this date. The table below sets out the effect on HSBC Holdings’ 
future NII over a five-year time horizon of incremental 25bps 
parallel falls or rises in all yield curves at the beginning of each 
quarter during the 12 months from 1 January 2021.

The NII sensitivities shown are indicative and based on simplified 
scenarios. Immediate interest rate rises of 25bps and 100bps 
would increase projected NII for the 12 months to 31 December 
2021 by $23m and $90m, respectively. Conversely, falls of 25bps 
and 100bps would decrease projected NII for the 12 months to 31 
December 2021 by $23m and $96m, respectively. 

Change in Jan 2021 to Dec 2021 (based on balance sheet at 31 December 2020)

+25bps

-25bps

+100bps

-100bps

Change in Jan 2020 to Dec 2020 (based on balance sheet at 31 December 2019)

+25bps

-25bps

+100bps

-100bps

NII sensitivity to an instantaneous change in yield curves (5 years)

Change in Jan 2021 to Dec 2021 (based on balance sheet at 31 December 2020)

+25bps

-25bps

+100bps

-100bps

Change in Jan 2020 to Dec 2020 (based on balance sheet at 31 December 2019)

+25bps

-25bps

+100bps

-100bps

$

$m

HK$

$m

13   

(12)   

50   

(51)   

(30)   

30   

(120)   

120   

—   

—   

—   

—   

—   

—   

—   

—   

£

$m

8   

(8)   

33   

(32)   

7   

(7)   

30   

(21)   

€

$m

Other

$m

Total

$m

2   

(3)   

7   

(13)   

2   

—   

(6)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

Year 1

Year 2

Year 3

Year 4

Year 5

$m

$m

$m

$m

$m

23   

(23)   

91   

(95)   

(21)   

23   

(96)   

99   

40   

(42)   

159   

(169)   

43   

(46)   

171   

(189)   

39   

(41)   

156   

(169)   

(14)   

12   

(64)   

61   

(13)   

8   

(53)   

41   

(14)   

9   

(54)   

38   

31   

(32)   

126   

(139)   

— 

(17)   

13   

(72)   

43   

23 

(23) 

90 

(96) 

(21) 

23 

(96) 

99 

Total

$m

176 

(184) 

702 

(761) 

(79) 

65 

(339) 

282 

The figures represent hypothetical movements in NII based on our 
projected yield curve scenarios, HSBC Holdings’ current interest 
rate risk profile and assumed changes to that profile during the 
next five years. 

The sensitivities represent our assessment of the change to a 
hypothetical base case based on a static balance sheet 
assumption, and do not take into account the effect of actions 
that could be taken to mitigate this interest rate risk.

Interest rate repricing gap table

The interest rate risk on the fixed-rate securities issued by HSBC 
Holdings is not included within the Group VaR, but is managed on 
a repricing gap basis. The following ‘Repricing gap analysis of 
HSBC Holdings’ table analyses the full-term structure of interest 
rate mismatches within HSBC Holdings’ balance sheet where debt 
issuances are reflected based on either the next repricing date if 
floating rate or the maturity/call date (whichever is first) if fixed 
rate.

HSBC Holdings plc Annual Report and Accounts 2020

181

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Repricing gap analysis of HSBC Holdings

Cash at bank and in hand:

–  balances with HSBC undertakings

Derivatives 

Loans and advances to HSBC undertakings 

Financial investments in HSBC undertakings

Investments in subsidiaries

Other assets 

Total assets 

Amounts owed to HSBC undertakings 

Financial liabilities designated at fair values 

Derivatives 

Debt securities in issue 

Other liabilities 

Subordinated liabilities 

Total equity 

Total liabilities and equity 

Off-balance sheet items attracting interest rate sensitivity 

Net interest rate risk gap at 31 Dec 2020

Cumulative interest rate gap 

Cash at bank and in hand:

–  balances with HSBC undertakings

Derivatives 

Loans and advances to HSBC undertakings 

Financial investments in HSBC undertakings

Investments in subsidiaries 

Other assets 

Total assets 

Amounts owed to HSBC undertakings 

Financial liabilities designated at fair values 

Derivatives 

Debt securities in issue 

Other liabilities 

Subordinated liabilities 

Total equity 

Total liabilities and equity 

Off-balance sheet items attracting interest rate sensitivity 

Net interest rate risk gap at 31 Dec 2019

1

Cumulative interest rate gap 

Footnotes

Total

$m

2,913   

4,698   

75,696   

17,485   

156,485   

1,721   

Up to
1 year

$m

2,913   

—   

25,610   

15,112   

5,381   

257   

From over 
1 to 5 years

From over 
5 to 10 years

More than
10 years

Non-interest
 bearing

$m

$m

$m

$m

—   

—   

—   

—   

—   

—   

22,190   

20,398   

2,000   

2,771   

7,660   

—   

—   

1,500   

—   

—   

—   

—   

— 

4,698 

5,498 

(398) 

141,944 

1,464 

258,998   

49,273   

32,621   

21,898   

2,000   

153,206 

(330)   

(25,664)   

(3,060)   

(64,029)   

(5,375)   

(17,916)   

(142,624)   

(258,998)   

2,382   

2,002   

72,182   

16,106   

163,948   

1,095   

257,715   

(464)   

(30,303)   

(2,021)   

(56,844)   

(2,203)   

(18,361)   

(147,519)   

(257,715)   

(330)   

(1,827)   

—   

—   

—   

(6,533)   

(13,535)   

—   

—   

—   

(750)   

—   

(9,932)   

(29,026)   

(22,063)   

(2,000)   

—   

—   

(1,464)   

(13,553)   

(20,324)   

15,396   

15,396   

—   

(3,839)   

(11,439)   

(50,837)   

11,562   

(6,654)   

8,742   

—   

—   

(1,780)   

(10,463)   

(9,198) 

(120,523) 

(46,576)   

(13,213)   

(134,819) 

2,492   

(22,186)   

(13,444)   

6,200   

(5,013)   

(18,457)   

70 

18,457 

— 

— 

(3,019) 

(3,060) 

(1,008) 

(5,375) 

(1,834) 

2,382   

—   

19,976   

13,054   

5,035   

102   

40,549   

(464)   

—   

—   

—   

—   

—   

—   

—   

—   

21,084   

24,739   

2,000   

3,006   

5,118   

—   

—   

3,924   

—   

—   

—   

—   

— 

2,002 

4,383 

46 

149,871 

993 

29,208   

28,663   

2,000   

157,295 

—   

—   

(14,628)   

(14,698)   

—   

—   

—   

(750)   

—   

(15,446)   

(22,336)   

(15,154)   

(2,000)   

—   

—   

(2,950)   

(18,860)   

(30,363)   

(8,674)   

(8,674)   

—   

(2,000)   

(10,707)   

(49,671)   

16,789   

(3,674)   

(12,348)   

—   

(2,543)   

(9,975)   

—   

(11,284)   

—   

(42,370)   

(14,034)   

6,796   

(6,911)   

6,469   

(5,565)   

(19,259)   

(24,824)   

— 

(227) 

(2,021) 

(1,908) 

(2,203) 

(2,534) 

(123,887) 

(132,780) 

309 

24,824 

— 

1 

Investments in subsidiaries and equity have been allocated based on call dates for any callable bonds. The prior year figures have been amended 
to reflect this.

Market risk

Market risk management

Market risk in 2020

Trading portfolios 

Non-trading portfolios 

Market risk balance sheet linkages

Overview

Page

182

183

184

185

186

Market risk is the risk that movements in market factors, such as 
foreign exchange rates, interest rates, credit spreads, equity prices 
and commodity prices, will reduce our income or the value of our 
portfolios. Exposure to market risk is separated into two portfolios: 
trading portfolios and non-trading portfolios.

Market risk management

Key developments in 2020

There were no material changes to our policies and practices for 
the management of market risk in 2020.

Governance and structure

The following diagram summarises the main business areas where 
trading and non-trading market risks reside, and the market risk 
measures used to monitor and limit exposures.

182

HSBC Holdings plc Annual Report and Accounts 2020

Risk types

Trading risk

Non-trading risk

• Foreign exchange and 

commodities
• Interest rates
• Credit spreads
• Equities

• Interest rates1
• Credit spreads
• Foreign exchange

Global business

GBM

Risk measure

Value at risk | Sensitivity 
| Stress testing

GBM, ALCM, CMB and 
WPB
Value at risk | Sensitivity | 
Stress testing

1  The interest rate risk on the fixed-rate securities issued by HSBC 

Holdings is not included in the Group value at risk. The management 
of this risk is described on page 181.

Where appropriate, we apply similar risk management policies and 
measurement techniques to both trading and non-trading 
portfolios. Our objective is to manage and control market risk 
exposures to optimise return on risk while maintaining a market 
profile consistent with our established risk appetite.

Market risk is managed and controlled through limits approved by 
the Group Chief Risk Officer for HSBC Holdings. These limits are 
allocated across business lines and to the Group’s legal entities. 
The majority of HSBC’s total value at risk (‘VaR’) and almost all 
trading VaR reside in GBM. Each major operating entity has an 
independent market risk management and control sub-function, 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
which is responsible for measuring, monitoring and reporting 
market risk exposures against limits on a daily basis. Each 
operating entity is required to assess the market risks arising in its 
business and to transfer them either to its local Markets and 
Securities Services or Markets Treasury unit for management, or 
to separate books managed under the supervision of the local 
ALCO. The Traded Risk function enforces the controls around 
trading in permissible instruments approved for each site as well 
as changes that follow completion of the new product approval 
process. Traded Risk also restricts trading in the more complex 
derivative products to offices with appropriate levels of product 
expertise and robust control systems.

Key risk management processes

Monitoring and limiting market risk exposures

Our objective is to manage and control market risk exposures 
while maintaining a market profile consistent with our risk 
appetite.

We use a range of tools to monitor and limit market risk exposures 
including sensitivity analysis, VaR and stress testing.

Sensitivity analysis

Sensitivity analysis measures the impact of individual market 
factor movements on specific instruments or portfolios, including 
interest rates, foreign exchange rates and equity prices. We use 
sensitivity measures to monitor the market risk positions within 
each risk type. Granular sensitivity limits are set for trading desks 
with consideration of market liquidity, customer demand and 
capital constraints, among other factors.

Value at risk

(Audited)

VaR is a technique for estimating potential losses on risk positions 
as a result of movements in market rates and prices over a 
specified time horizon and to a given level of confidence. The use 
of VaR is integrated into market risk management and calculated 
for all trading positions regardless of how we capitalise them. In 
addition, we calculate VaR for non-trading portfolios to have a 
complete picture of risk. Where we do not calculate VaR explicitly, 
we use alternative tools as summarised in the ‘Stress testing’ 
section below.

Our models are predominantly based on historical simulation that 
incorporates the following features:

• historical market rates and prices, which are calculated with 

reference to foreign exchange rates, commodity prices, interest 
rates, equity prices and the associated volatilities;

Risk not in VaR framework

The risks not in VaR (‘RNIV’) framework captures and capitalises 
material market risks that are not adequately covered in the VaR 
model.

Risk factors are reviewed on a regular basis and are either 
incorporated directly in the VaR models, where possible, or 
quantified through either the VaR-based RNIV approach or a stress 
test approach within the RNIV framework. While VaR-based RNIVs 
are calculated by using historical scenarios, stress-type RNIVs are 
estimated on the basis of stress scenarios whose severity is 
calibrated to be in line with the capital adequacy requirements. 
The outcome of the VaR-based RNIV approach is included in the 
overall VaR calculation but excluded from the VaR measure used 
for regulatory back-testing. In addition, the stressed VaR measure 
also includes risk factors considered in the VaR-based RNIV 
approach.

Stress-type RNIVs include a deal contingent derivatives capital 
charge to capture risk for these transactions and a de-peg risk 
measure to capture risk to pegged and heavily managed 
currencies.

Stress testing

Stress testing is an important procedure that is integrated into our 
market risk management framework to evaluate the potential 
impact on portfolio values of more extreme, although plausible, 
events or movements in a set of financial variables. In such 
scenarios, losses can be much greater than those predicted by 
VaR modelling.

Stress testing is implemented at legal entity, regional and overall 
Group levels. A set of scenarios is used consistently across all 
regions within the Group. The risk appetite around potential stress 
losses for the Group is set and monitored against a referral limit.

Market risk reverse stress tests are designed to identify 
vulnerabilities in our portfolios by looking for scenarios that lead to 
loss levels considered severe for the relevant portfolio. These 
scenarios may be quite local or idiosyncratic in nature, and 
complement the systematic top-down stress testing.

Stress testing and reverse stress testing provide senior 
management with insights regarding the ‘tail risk’ beyond VaR, for 
which our appetite is limited.

Trading portfolios

Trading portfolios comprise positions held for client servicing and 
market-making, with the intention of short-term resale and/or to 
hedge risks resulting from such positions.

• potential market movements that are calculated with reference 

Back-testing

to data from the past two years; and

• calculations to a 99% confidence level and using a one-day 

holding period.

The models also incorporate the effect of option features on the 
underlying exposures. The nature of the VaR models means that 
an increase in observed market volatility will lead to an increase in 
VaR without any changes in the underlying positions.

VaR model limitations

Although a valuable guide to risk, VaR is used with awareness of 
its limitations. For example:

• The use of historical data as a proxy for estimating future 

market moves may not encompass all potential market events, 
particularly those that are extreme in nature.

• The use of a one-day holding period for risk management 

purposes of trading and non-trading books assumes that this 
short period is sufficient to hedge or liquidate all positions.

• The use of a 99% confidence level by definition does not take 
into account losses that might occur beyond this level of 
confidence.

• VaR is calculated on the basis of exposures outstanding at the 

close of business and therefore does not reflect intra-day 
exposures.

We routinely validate the accuracy of our VaR models by back-
testing the VaR metric against both actual and hypothetical profit 
and loss. Hypothetical profit and loss excludes non-modelled items 
such as fees, commissions and revenue of intra-day transactions.

The number of back-testing exceptions is used to gauge how well 
the models are performing. We consider enhanced internal 
monitoring of a VaR model if more than five profit exceptions or 
more than five loss exceptions occur in a 250-day period.

We back-test our VaR at set levels of our Group entity hierarchy.

Market risk in 2020

Global financial conditions worsened rapidly with the onset of the 
Covid-19 outbreak from mid-February 2020. Market volatility 
reached extreme levels across most asset classes and equity 
prices fell sharply. In credit markets, spreads and yields reached 
multi-year highs. The gold market experienced Covid-19-related 
disruption in refining and transportation, affecting the relative 
pricing of gold futures contracts. Oil prices collapsed due to rising 
oversupply as demand reduced materially from the economic 
slowdown. Financial markets stabilised from April onwards, as 
governments in several developed countries announced economic 
recovery programmes and key central banks intervened to provide 
liquidity and support asset prices. Global equity markets 
substantially recovered from their losses in March and credit 

HSBC Holdings plc Annual Report and Accounts 2020

183

Risk reviewRisk

spreads reverted towards pre-Covid-19 levels. During the second 
half of 2020 markets remained susceptible to further bouts of 
volatility triggered by increases in Covid-19 cases and various 
geopolitical risks. Market sentiment improved after positive 
vaccine news and the US presidential elections in November 2020, 
adding momentum to the performance of risky assets.

We managed market risk prudently during 2020. Sensitivity 
exposures remained within appetite as the business pursued its 
core market-making activity in support of our customers during 
the outbreak. We also undertook hedging activities to protect the 
business from potential future deterioration in credit conditions. 
Market risk continued to be managed using a complementary set 
of exposure measures and limits, including stress and scenario 
analysis. 

Trading portfolios

Value at risk of the trading portfolios

Trading VaR was predominantly generated by the 

Daily VaR (trading portfolios), 99% 1 day ($m) 

Markets and Securities Services business. The Fixed Income 
business continued to be the key driver of trading VaR up to the 
end of 2020, although with a lower contribution than in the first 
half of the year. Interest rate risks from market-making activities 
were the main drivers of trading VaR.

Trading VaR at 31 December 2020 was higher than at 
31 December 2019. The moderate increase in trading VaR during 
the year and a spike in the first half of the year were due primarily 
to higher levels of market volatility reached in March and April 
2020, as a result of the economic impact of the Covid-19 outbreak. 
Trading VaR did not change significantly during the second half of 
the year and VaR remained in line with the normal range observed 
in 2019. Overall market risk in the trading book was actively 
managed during the year.

The daily levels of total trading VaR during 2020 are set out in the 
graph below.

The Group trading VaR for the year is shown in the table below.

Trading VaR, 99% 1 day1
(Audited)

Balance at 31 Dec 2020

Average

Maximum

Minimum

Balance at 31 Dec 2019

Average

Maximum

Minimum

Foreign
exchange and 
commodity

Interest
rate

$m

13.7   

11.0   

25.7   

5.6   

7.7   

6.9   

13.5   

4.1   

$m

20.3   

26.6   

43.5   

19.1   

28.2   

29.9   

36.5   

22.9   

Equity

$m

21.5   

27.3   

42.0   

13.6   

15.7   

16.2   

24.9   

12.4   

Portfolio 
diversification2

$m

(36.4)   

(38.3)   

(26.4)   

(29.0)   

Credit
spread

$m

24.3   

21.6   

44.1 

12.6 

15.2   

23.7   

33.2 

11.7 

Total3

$m

43.4 

48.1 

69.3 

33.6 

40.3 

47.8 

59.3 

33.3 

1  Trading portfolios comprise positions arising from the market-making and warehousing of customer-derived positions.
2  Portfolio diversification is the market risk dispersion effect of holding a portfolio containing different risk types. It represents the reduction in 
unsystematic market risk that occurs when combining a number of different risk types – such as interest rate, equity and foreign exchange – 
together in one portfolio. It is measured as the difference between the sum of the VaR by individual risk type and the combined total VaR. A 
negative number represents the benefit of portfolio diversification. As the maximum and minimum occurs on different days for different risk types, 
it is not meaningful to calculate a portfolio diversification benefit for these measures.

3  The total VaR is non-additive across risk types due to diversification effects.

Back-testing

During 2020, the Group experienced three loss back-testing 
exceptions against actual profit and losses, with no additional 
back-testing exceptions in the second half of 2020. The Group also 
experienced 10 loss back-testing exceptions against hypothetical 
profit and losses, including one back-testing exception in the 
second half of the year. The high number of hypothetical back-

184

HSBC Holdings plc Annual Report and Accounts 2020

testing exceptions that occurred from March 2020 was primarily 
due to the extreme market volatility resulting from the economic 
impact of the Covid-19 outbreak, which was significantly greater 
than the volatility used in the model calibration.

In recognition of the exceptional market environment in 2020, the 
PRA granted an exemption from the higher VaR multiplier for 
market risk RWA purposes arising from six out of 10 VaR back-

Trading totalInterest rate (‘IR’) tradingEquity (‘EQ’) tradingCredit spread (‘CS’) trading intentForeign exchange (‘FX’) tradingDiversificationDec-19Jan-20Feb-20Mar-20Apr-20May-20Jun-20Jul-20Aug-20Sep-20Oct-20Nov-20Dec-20-80-60-40-20020406080 
 
 
 
 
 
 
 
 
 
 
 
 
testing exceptions that occurred after the onset of the Covid-19 
outbreak. These six back-testing exceptions were granted on the 
basis that they were not the result of inherent model weaknesses 
but were driven by larger than normal market volatility in the first 
half of 2020 caused by the Covid-19 outbreak.

the interest rate management of our retail and commercial 
banking assets and liabilities, financial investments measured at 
fair value through other comprehensive income, debt instruments 
measured at amortised cost, and exposures arising from our 
insurance operations.

The hypothetical profit and loss reflects the profit and loss that 
would be realised if positions were held constant from the end of 
one trading day to the end of the next. This measure of profit and 
loss does not align with how risk is dynamically hedged, and is not 
therefore indicative of the actual performance of the business. 

Accordingly, of the 10 loss back-testing exceptions against 
hypothetical profit and losses, only two corresponded to actual 
profit and loss exceptions.

Despite the high number of loss exceptions, performance of the 
VaR model was in line with expectations when considered in the 
context of the extraordinary market movements observed in 
March and April 2020. During this period, market risk continued to 
be managed using a complementary set of exposure measures 
and limits, including stress and scenario analysis. This ensured 
that the business was prudently managed and performed well 
across the period.

Non-trading portfolios

Non-trading portfolios comprise positions that primarily arise from 

Daily VaR (non-trading portfolios), 99% 1 day ($m)

Value at risk of the non-trading portfolios

The VaR for non-trading activity at 31 December 2020 was higher 
than at 31 December 2019. The increase arose primarily from the 
effect of higher levels of market volatility observed in March and 
April 2020 due to the economic impact of the Covid-19 outbreak. 
Although the size of interest rate and credit exposures did not 
change significantly during the year, increased volatility of yields 
and spreads led to an increase in VaR and a reduction of the 
diversification benefit effects across these exposures.

Non-trading VaR includes the interest rate risk in the banking book 
transferred to and managed by Markets Treasury and the non-
trading financial instruments held by Markets Treasury. The 
management of interest rate risk in the banking book is described 
further in the ‘Net interest income sensitivity’ section.

The daily levels of total non-trading VaR over the last year are set 
out in the graph below.

The Group non-trading VaR for the year is shown in the table below.

Non-trading VaR, 99% 1 day

(Audited)

Balance at 31 Dec 2020

Average

Maximum

Minimum

Balance at 31 Dec 2019

Average

Maximum

Minimum

Interest
rate

$m

166.6   

150.2   

196.4   

59.0   

96.2   

65.9   

100.1   

49.2   

Credit
spread

$m

87.0   

82.5   

133.4   

44.2   

62.5   

44.2   

81.2 

26.6 

Portfolio
diversification1

$m

(5.7)   

(42.0)   

—   

—   

(28.2)   

(25.6)   

0  

0  

Total2

$m

247.8 

190.7 

274.6 

79.7 

130.5 

84.5 

132.8 

60.9 

1  Portfolio diversification is the market risk dispersion effect of holding a portfolio containing different risk types. It represents the reduction in 
unsystematic market risk that occurs when combining a number of different risk types – such as interest rate, equity and foreign exchange – 
together in one portfolio. It is measured as the difference between the sum of the VaR by individual risk type and the combined total VaR. A 
negative number represents the benefit of portfolio diversification. As the maximum and minimum occurs on different days for different risk types, 
it is not meaningful to calculate a portfolio diversification benefit for these measures.

2  The total VaR is non-additive across risk types due to diversification effects.

HSBC Holdings plc Annual Report and Accounts 2020

185

Non-trading totalIR non-tradingCS non-trading intentDiversificationDec-19Jan-20Feb-20Mar-20Apr-20May-20Jun-20Jul-20Aug-20Sep-20Oct-20Nov-20Dec-20-180-160-140-120-100-80-60-40-20020406080100120140160180200220240260280300Risk review 
 
 
 
 
 
 
 
 
Risk

Non-trading VaR excludes equity risk on securities held at fair 
value, structural foreign exchange risk and interest rate risk on 
fixed-rate securities issued by HSBC Holdings. HSBC’s 
management of market risks in non-trading books is described 
further in the Treasury Risk section.

Market risk balance sheet linkages

The following balance sheet lines in the Group’s consolidated 
position are subject to market risk:

Trading assets and liabilities

The Group’s trading assets and liabilities are in almost all cases 
originated by GBM. These assets and liabilities are treated as 
traded risk for the purposes of market risk management, other 
than a limited number of exceptions, primarily in Global Banking 
where the short-term acquisition and disposal of the assets are 
linked to other non-trading-related activities such as loan 
origination.

Derivative assets and liabilities

We undertake derivative activity for three primary purposes: to 
create risk management solutions for clients, to manage the 
portfolio risks arising from client business, and to manage and 
hedge our own risks. Most of our derivative exposures arise from 
sales and trading activities within GBM. The assets and liabilities 
included in trading VaR give rise to a large proportion of the 
income included in net income from financial instruments held for 
trading or managed on a fair value basis. Adjustments to trading 
income such as valuation adjustments are not measured by the 
trading VaR model.

For information on the accounting policies applied to financial instruments at 
fair value, see Note 1 on the financial statements

Resilience risk

Overview

Resilience risk is the risk that we are unable to provide critical 
services to our customers, affiliates and counterparties, as a result 
of sustained and significant operational disruption. Resilience risk 
arises from failures or inadequacies in processes, people, systems 
or external events.

Resilience risk management

Key developments in 2020

In line with the increasing expectations from customers, regulators 
and the Board, and in response to a continually evolving threat 
landscape that the wider industry faces, we combined Operational 
Risk and Resilience Risk to form a new Operational and Resilience 
Risk sub-function. This sub-function provides robust non-financial 
risk steward oversight of the management of risk by the Group 
businesses, functions, legal entities and critical business services. 
It also provides effective and timely independent challenge. We 
carried out several initiatives during the year:

• We developed regional hubs accountable for core Operational 

and Resilience Risk activities.

• We implemented teams aligned to businesses and functions, 
which were focused on emerging risks as well as material 
products and services.

• We deployed risk management oversight of the most material 

transformation programmes across the Group.

• We implemented central services including governance, 

reporting and transformation.

• We created a stand-alone assurance capability that provides 
independent review and evaluation of end-to-end processes, 
risks and key controls.

We prioritise our efforts on material risks and areas undergoing 
strategic growth, aligning our location strategy to this need. We 
also remotely provide oversight and stewardship, including 
support of chief risk officers, in territories where we have no 
physical presence.

186

HSBC Holdings plc Annual Report and Accounts 2020

Governance and structure

The Operational and Resilience Risk target operating model 
provides a globally consistent view across resilience risks, 
strengthening our risk management oversight while operating 
effectively as part of a simplified non-financial risk structure. We 
view resilience risk across seven risk types related to: third parties 
and supply chains; information, technology and cybersecurity; 
payments and manual processing; physical security; business 
interruption and contingency risk; building unavailability; and 
workplace safety.

A principal senior management meeting for operational and 
resilience risk governance is the Non-Financial Risk Management 
Board, chaired by the Group Chief Risk Officer, with an escalation 
path to the Group Risk Management Meeting. 

Key risk management processes

Operational resilience is our ability to anticipate, prevent, adapt, 
respond to, recover and learn from internal or external disruption, 
protecting customers, the markets we operate in and economic 
stability. Resilience is determined by assessing whether we are 
able to continue to provide our most important services, within an 
agreed level. We accept we will not be able to prevent all 
disruption but we prioritise investment to continually improve the 
response and recovery strategies for our most important business 
services.

Business operations continuity

As a result of the Covid-19 outbreak, we successfully implemented 
business continuity responses and continue to maintain the 
majority of service level agreements. We did not experience any 
major impacts to the supply chain from our third-party service 
providers due to the pandemic. The risk of damage or theft to our 
physical assets or criminal injury to our colleagues remains 
unchanged and no significant incidents impacted our buildings or 
people.

Regulatory compliance risk

Overview

Regulatory compliance risk is the risk that we fail to observe the 
letter and spirit of all relevant laws, codes, rules, regulations and 
standards of good market practice, which as a consequence incur 
fines and penalties and suffer damage to our business.

Regulatory compliance risk arises from the risks associated with 
breaching our duty to our customers and inappropriate market 
conduct, as well as breaching regulatory licensing, permissions 
and rules.

Regulatory compliance risk management

Key developments in 2020

In 2020, we made changes to our wider approach to the 
governance and structure of the Compliance function and 
continued to raise standards related to the conduct of our 
business, as set out below.

Governance and structure

In May, we introduced a new operating model to transform the 
Compliance function. We created a new Group capability called 
Group Regulatory Conduct, which was formed from the regulatory 
compliance and regulatory affairs capabilities, and the monitor 
liaison office team. The Group Head of Regulatory Conduct 
continues to report to the Group Chief Compliance Officer. The 
Group Regulatory Conduct capability works with the newly 
appointed regional chief compliance officers and their respective 
teams to help them identify and manage regulatory compliance 
risks across the Group. They also work together to ensure good 
conduct outcomes and provide enterprise-wide support on the 
regulatory agenda.

Key risk management processes

The Group Regulatory Conduct capability is responsible for setting 
global policies, standards and risk appetite to guide the Group’s 
management of regulatory compliance. It also devises clear 

 
 
 
frameworks and support processes to protect against regulatory 
compliance risks. The capability provides oversight, review and 
challenge to the regional chief compliance officers and their teams 
to help them identify, assess and mitigate regulatory compliance 
risks, where required. The Group’s regulatory compliance risk 
policies are regularly reviewed. Global policies and procedures 
require the prompt identification and escalation of any actual or 
potential regulatory breach. Relevant reportable events are 
escalated to the Group RMM and the GRC, as appropriate.

Conduct of business

In 2020, we continued to promote and encourage good conduct 
through our people’s behaviour and decision making to deliver fair 
outcomes for our customers, and to maintain financial market 
integrity. During 2020:

• We continued to champion a strong conduct and customer-
focused culture. We implemented a number of measures 
throughout the Covid-19 outbreak to support our customers in 
financial difficulties. We also maintained service and supported 
colleagues in unprecedented conditions.

• We continued our focus on culture and behaviours, adapting 

our controls and risk management processes to reflect 
significant levels of remote working throughout the year.

• We continued to invest significant resources to improve our 
compliance systems and controls relating to our activities in 
Global Markets and to ensure market integrity. These included 
enhancements to: pricing and disclosure, order management 
and trade execution; trade; voice and audio surveillance; front 
office supervision; and the enforcement and discipline 
framework for employee misconduct.

• We continued to emphasise – and worked to create – an 

environment in which employees are encouraged and feel safe 
to speak up. We placed a particular focus on the importance of 
well-being during the pandemic through regular top-down 
communications, virtual town halls, videos and podcasts. 

• We continued to embed conduct within our business line 
processes. We also considered and sought to mitigate the 
conduct impacts of the Group’s strategic transformation 
programme and other key business change programmes, 
including those relating to the UK’s departure from the EU and 
the Ibor transition. 

• We delivered our sixth annual global mandatory training course 

on conduct to reinforce the importance of conduct for all 
colleagues.

measures during this period to support the business and our 
customers. These included:

• We supported the most vulnerable customers and those in 

financial difficulty, including by increasing the awareness of 
fraud during this period.

• The Compliance function proactively engaged with other parts 

of the organisation to ensure financial crime risks were 
considered as part of Covid-19-related decisions.

• Compliance colleagues were seconded to other parts of the 
organisation to assist with supporting the establishment of 
government relief measures.

• We supported customers and the organisation through policy 
exceptions, including by allowing email instructions instead of 
face-to-face meetings, and introducing virtual onboarding.

We consistently review the effectiveness of our financial crime risk 
management framework, which includes consideration of 
geopolitical and wider economic factors. The sanctions regulatory 
environment remained changeable and uncertain during the 
course of 2020 due to the ongoing geopolitical tensions between 
the US and China, the end of the transition period following the 
UK’s departure from the EU, and the increasing divergence in 
sanctions policies between the US and the EU on Iran and Russia. 
Our policy is to comply with all applicable sanctions regulations in 
the jurisdictions in which we operate, and we continue to monitor 
the geopolitical landscape for ongoing developments. We also 
continued to progress several key financial crime risk 
management initiatives, including:

• We continued to strengthen our anti-fraud capabilities, 

focusing on threats posed by new and existing technologies, 
and have delivered a comprehensive fraud training programme 
across the Group.

• We continued to invest in the use of artificial intelligence (‘AI’) 
and advanced analytics techniques to manage financial crime 
risk, and we published our principles for the ethical use of Big 
Data and AI.

• We continued to work on strengthening our ability to combat 
money laundering and terrorist financing. In particular, we 
focused on the use of technology to enhance our risk 
management processes while minimising the impact to the 
customer. We also continued to develop our approach of 
intelligence-led financial crime risk management, in part, 
through enhancements to our automated transaction 
monitoring systems.

• We are refreshing our approach to conduct arrangements 

Governance and structure

across the Group with a view to ensuring that the 
arrangements remain appropriate for the nature of our 
business.

The Board continues to maintain oversight of conduct matters 
through the GRC.

Further details can be found under the ‘Our conduct’ section of 
www.hsbc.com/our-approach/risk-and-responsibility. 

Financial crime risk

Overview

Financial crime risk is the risk of knowingly or unknowingly 
helping parties to commit or to further illegal activity through 
HSBC, including money laundering, fraud, bribery and corruption, 
tax evasion, sanctions breaches, and terrorist and proliferation 
financing. Financial crime risk arises from day-to-day banking 
operations involving customers, third parties and employees. 

Financial crime risk management

Key developments in 2020

In 2020, we continued to strengthen our fight against financial 
crime and to enhance our financial crime risk management 
capability. Amid the challenges posed by the Covid-19 outbreak, 
we introduced a number of financial crime risk management 

Since establishing a global framework of financial crime risk 
management committees in 2018, we have continued to 
strengthen and review the effectiveness of our governance 
framework to manage financial crime risk. Formal governance 
committees are held across all countries, territories, regions and 
global businesses, and are chaired by the respective chief 
executive officers. They help to enable compliance with the letter 
and the spirit of all applicable financial crime laws and regulations, 
as well as our own standards, values and policies relating to 
financial crime risks. At a Group level, the Financial Crime Risk 
Management Meeting, chaired by the Group Chief Compliance 
Officer, has served as the pinnacle of this governance structure, 
ultimately responsible for the management of financial crime risk. 
As a reflection of the growing maturity and effectiveness of our 
financial crime risk management, this meeting was integrated with 
the Group Risk Management Meeting in January 2021. During the 
course of 2021, we will review the management of financial crime 
risk across the Group to identify other areas that could be 
simplified.

During 2020, we redesigned and delivered an integrated operating 
model for our Compliance function, with the accompanying 
restructure providing greater accountability to our regional 
Compliance teams. These teams, led by regional chief compliance 
officers, will support the Group Chief Compliance Officer in 
aligning the way in which we manage all compliance risks, 
including financial crime risk, to the needs and aims of the wider 

HSBC Holdings plc Annual Report and Accounts 2020

187

Risk review 
Risk

business. They will also support making our compliance risk 
management processes and procedures more efficient and 
effective.

Key risk management processes

We continued to deliver a programme to further enhance the 
policies and controls around identifying and managing the risks of 
bribery and corruption across our business. Recognising that the 
fight against financial crime is a constant challenge, we 
maintained our investment in operational controls and new 
technology to deter and detect criminal activity in the banking 
system. We continued to simplify our governance and policy 
frameworks, and our management information reporting process, 
which demonstrates the effectiveness of our financial crime 
controls. We remain committed to enhancing our risk assessment 
capabilities and to delivering more proactive risk management, 
including our ongoing investment in the next generation of 
capabilities to fight financial crime by applying advanced analytics 
and AI.

We are committed to working in partnership with the wider 
industry and the public sector in managing financial crime risk, 
protecting the integrity of the financial system, and helping to 
protect the communities we serve. We are a strong advocate of 
public-private partnerships and participate in a number of 
information-sharing initiatives around the world. We are a 
constructive partner to national governments and international 
standard setters, and support reforms being undertaken in key 
markets such as the UK and the EU where the Group is 
represented on the joint public-private Economic Crime Strategic 
Board and the Centre for European Policy Studies taskforce on 
anti-money laundering, respectively. We also work closely with 
peer banks in Singapore, and with the Monetary Authority of 
Singapore. In the US, we are a member of the Bank Secrecy Act 
Advisory Group, which has put forward recommendations for 
reform that have been supported by the US Treasury and the 
Financial Crimes Enforcement Network. 

We have been an advocate for a more effective international 
framework for managing financial crime risk, whether through 
engaging directly with intergovernmental bodies such as the 
Financial Action Task Force, or via our key role in industry groups 
such as the Wolfsberg Group and the Institute of International 
Finance.

Skilled Person/Independent Consultant

In December 2012, HSBC Holdings entered into a number of 
agreements, including an undertaking with the UK Financial 
Services Authority (replaced with a Direction issued by the UK 
Financial Conduct Authority (‘FCA’) in 2013 and again in 2020), as 
well as a cease-and-desist order with the US Federal Reserve 
Board (‘FRB’), both of which contained certain forward-looking 
anti-money laundering (‘AML’) and sanctions-related obligations. 
HSBC also agreed to retain an independent compliance monitor 
(who was, for FCA purposes, a ‘Skilled Person’ under section 166 
of the Financial Services and Markets Act and, for FRB purposes, 
an ‘Independent Consultant’) to produce periodic assessments of 
the Group’s AML and sanctions compliance programme. 

In 2020, HSBC’s engagement with the independent compliance 
monitor, acting in his roles as both Skilled Person and Independent 
Consultant, concluded. The role of FCA Skilled Person was 
assigned to a new individual in the second quarter of 2020.  
Separately, a new FRB Independent Consultant will be appointed 
pursuant to the cease-and-desist order.

The new Skilled Person has a narrower mandate to assess the 
remaining areas that require further work in order for HSBC to 
transition fully to business-as-usual financial crime risk 
management. The review is ongoing and is expected to complete 
later in 2021. The new Independent Consultant is expected to 
carry out the eighth annual review for the FRB during 2021.

In accordance with the Direction issued by the FCA to HSBC 
Holdings in 2020, the Group Risk Committee retains oversight of 
matters relating to anti-money laundering, sanctions, terrorist 
financing and proliferation financing. Throughout 2020, the Group 

188

HSBC Holdings plc Annual Report and Accounts 2020

Risk Committee received regular updates on the Skilled Person’s 
and the Independent Consultant’s reviews.

Model risk

Overview

Model risk is the potential for adverse consequences from 
business decisions informed by models, which can be exacerbated 
by errors in methodology, design or the way they are used. Model 
risk arises in both financial and non-financial contexts whenever 
business decision making includes reliance on models.

Key developments in 2020

In 2020, we carried out a number of initiatives to further develop 
and embed the Model Risk Management sub-function, including: 

• We appointed a Group Chief Model Risk Officer, which is a 

senior role reporting to the Group Chief Risk Officer. 

• We updated the model risk policy and introduced model risk 

standards to enable a more risk-based approach to model risk 
management while retaining a consistent approach. 

• Working with the businesses and functions, new model risk 
controls were developed in the risk control library. These 
controls formed the basis for model risk control assessments 
that have been implemented for businesses and functions.

• We updated the target operating model for Model Risk 

Management, referring to internal and industry best practice 
and added risk stewards for key businesses, functions and legal 
vehicles. The risk stewards will also provide close monitoring of 
changes in model behaviour, working closely with business and 
function model owners and sponsors.

• The independent model validation team began a transformation 
programme that will use advanced analytics and new workflow 
tools, with the objective of providing a more risk-based, 
efficient and effective management of model validation 
processes.

• The consequences of the Covid-19 outbreak on model 

performance and reliability resulted in enhanced monitoring of  
models and related model adjustments. Dramatic changes to 
model inputs such as GDP and unemployment rates made the 
model results unreliable. Model performance limitations have 
been most pronounced for IFRS 9 models, which calculate 
expected credit losses. As a result, greater reliance has been 
placed on management underlays and overlays based on 
business judgement to derive expected credit losses. 

• New IFRS 9 models for portfolios that required the largest 

model overlays during 2020 have been redeveloped, validated 
and implemented in the fourth quarter of 2020. Limited new 
data was available for the use in the recalibrations, therefore 
judgemental post-model adjustments were required to allow for 
the economic effects of the pandemic not captured by the 
models.

Governance and structure

We placed greater focus on our model risk activities during 2020, 
and to reflect this, we elevated Model Risk Management to a 
function in its own right within the Global Risk structure. 
Previously, structured as a sub-function within the Global Risk 
Strategy function, the team now reports directly to the Group 
Chief Risk Officer. Regional Model Risk Management teams 
support and advise all areas of the Group.

Key risk management processes

We use a variety of modelling approaches, including regression, 
simulation, sampling, machine learning and judgemental 
scorecards for a range of business applications. These activities 
include customer selection, product pricing, financial crime 
transaction monitoring, creditworthiness evaluation and financial 
reporting. Global responsibility for managing model risk is 
delegated from the RMM to the Group Model Risk Committee, 
which is chaired by the Group Chief Risk Officer. This committee 
regularly reviews our model risk management policies and 
procedures, and requires the first line of defence to demonstrate 

comprehensive and effective controls based on a library of model 
risk controls provided by Model Risk Management. 

insurance operations to better align to the Group’s capital risk 
framework.

Model Risk Management also reports on model risk to senior 
management on a regular basis through the use of the risk map, 
risk appetite metrics and top and emerging risks. 

We regularly review the effectiveness of these processes, 
including the model oversight committee structure, to help ensure 
appropriate understanding and ownership of model risk is 
embedded in the businesses and functions.

Insurance manufacturing operations risk

Overview

Insurance manufacturing operations risk management

Measurement

Key risk types

–  Market risk

–  Credit risk

–  Capital and liquidity risk

–  Insurance risk

Overview

Page

189

189

190

192

192

193

193

194

The majority of the risk in our insurance business derives from 
manufacturing activities and can be categorised as financial risk or 
insurance risk. Financial risks include market risk, credit risk and 
liquidity risk. Insurance risk is the risk, other than financial risk, of 
loss transferred from the holder of the insurance contract to 
HSBC, the issuer.

HSBC’s bancassurance model

We operate an integrated bancassurance model that provides 
insurance products principally for customers with whom we have 
a banking relationship.

The insurance contracts we sell relate to the underlying needs of 
our banking customers, which we can identify from our point-of-
sale contacts and customer knowledge. For the products we 
manufacture, the majority of sales are of savings, universal life and 
credit and term life contracts.

We choose to manufacture these insurance products in HSBC 
subsidiaries based on an assessment of operational scale and risk 
appetite. Manufacturing insurance allows us to retain the risks and 
rewards associated with writing insurance contracts by keeping 
part of the underwriting profit and investment income within the 
Group.

We have life insurance manufacturing subsidiaries in eight 
countries and territories, which are Hong Kong, France, Singapore, 
the UK, mainland China, Malta, Mexico and Argentina. We also 
have a life insurance manufacturing associate in India.

Where we do not have the risk appetite or operational scale to be 
an effective insurance manufacturer, we engage with a small 
number of leading external insurance companies in order to 
provide insurance products to our customers through our banking 
network and direct channels. These arrangements are generally 
structured with our exclusive strategic partners and earn the 
Group a combination of commissions, fees and a share of profits. 
We distribute insurance products in all of our geographical 
regions.

Insurance products are sold worldwide through branches, direct 
channels and third-party distributors.

Insurance manufacturing operations risk 
management

Key developments in 2020

There were no material changes to the insurance risk management 
framework in 2020. Policies and practices for the management of 
risks associated with the selling of insurance contracts outside of 
bancassurance channels were enhanced in response to this being 
an increasing area of importance for the insurance business. Also, 
enhancements were made to the capital risk framework for 

Governance and structure

(Audited)

Insurance risks are managed to a defined risk appetite, which 
is aligned to the Group’s risk appetite and risk management 
framework, including its three lines of defence model. For details 
of the Group’s governance framework, see page 107. The Global 
Insurance Risk Management Meeting oversees the control 
framework globally and is accountable to the WPB Risk 
Management Meeting on risk matters relating to the insurance 
business.

The monitoring of the risks within our insurance operations is 
carried out by insurance risk teams. Specific risk functions, 
including Wholesale Credit and Market Risk, Operational and 
Resilience Risk, and Compliance, support Insurance Risk teams in 
their respective areas of expertise.

Stress and scenario testing

(Audited)

Stress testing forms a key part of the risk management framework 
for the insurance business. We participate in local and Group-wide 
regulatory stress tests, as well as internally-developed stress and 
scenario tests, including Group internal stress test exercises.

These have highlighted that a key risk scenario for the insurance 
business is a prolonged low interest-rate environment. In order to 
mitigate the impact of this scenario, the insurance operations have 
taken a number of actions, including repricing some products to 
reflect lower interest rates, launching less capital intensive 
products, investing in more capital efficient assets and developing 
investment strategies to optimise the expected returns against the 
cost of economic capital.

Key risk management processes

Market risk

(Audited) 

All our insurance manufacturing subsidiaries have market risk 
mandates that specify the investment instruments in which they 
are permitted to invest and the maximum quantum of market risk 
that they may retain. They manage market risk by using, among 
others, some or all of the techniques listed below, depending on 
the nature of the contracts written:

• We are able to adjust bonus rates to manage the liabilities to 
policyholders for products with discretionary participating 
features (‘DPF’). The effect is that a significant portion of the 
market risk is borne by the policyholder.

• We use asset and liability matching where asset portfolios are 
structured to support projected liability cash flows. The Group 
manages its assets using an approach that considers asset 
quality, diversification, cash flow matching, liquidity, volatility 
and target investment return. It is not always possible to match 
asset and liability durations due to uncertainty over the receipt 
of all future premiums, the timing of claims and because the 
forecast payment dates of liabilities may exceed the duration of 
the longest dated investments available. We use models to 
assess the effect of a range of future scenarios on the values of 
financial assets and associated liabilities, and ALCOs employ 
the outcomes in determining how best to structure asset 
holdings to support liabilities.

• We use derivatives to protect against adverse market 

movements to better match liability cash flows.

• For new products with investment guarantees, we consider the 

cost when determining the level of premiums or the price 
structure.

• We periodically review products identified as higher risk, such 
as those that contain investment guarantees and embedded 
optionality features linked to savings and investment products, 
for active management.

HSBC Holdings plc Annual Report and Accounts 2020

189

Risk review 
Risk

• We design new products to mitigate market risk, such as 
changing the investment return sharing portion between 
policyholders and the shareholder.

• We exit, to the extent possible, investment portfolios whose 

risk is considered unacceptable.

• We reprice premiums charged on new contracts to 

Insurance risk

HSBC Insurance primarily uses the following techniques to 
manage and mitigate insurance risk:

• a formalised product approval process covering product design, 

pricing and overall proposition management (for example, 
management of lapses by introducing surrender charges);

policyholders.

Credit risk

(Audited)

Our insurance manufacturing subsidiaries are responsible for the 
credit risk, quality and performance of their investment portfolios. 
Our assessment of the creditworthiness of issuers and 
counterparties is based primarily upon internationally recognised 
credit ratings and other publicly available information.

Investment credit exposures are monitored against limits by our 
insurance manufacturing subsidiaries and are aggregated and 
reported to the Group Insurance Credit Risk and Group Credit Risk 
functions. Stress testing is performed on investment credit 
exposures using credit spread sensitivities and default 
probabilities.

We use a number of tools to manage and monitor credit risk. 
These include a credit report containing a watch-list of 
investments with current credit concerns, primarily investments 
that may be at risk of future impairment or where high 
concentrations to counterparties are present in the investment 
portfolio. Sensitivities to credit spread risk are assessed and 
monitored regularly.

Liquidity risk

(Audited)

Risk is managed by cash flow matching and maintaining sufficient 
cash resources, investing in high credit-quality investments with 
deep and liquid markets, monitoring investment concentrations 
and restricting them where appropriate, and establishing 
committed contingency borrowing facilities.

Insurance manufacturing subsidiaries complete quarterly liquidity 
risk reports and an annual review of the liquidity risks to which 
they are exposed.

• underwriting policy;

• claims management processes; and

• reinsurance which cedes risks above our acceptable thresholds 

to an external reinsurer thereby limiting our exposure.

Insurance manufacturing operations risk in 2020

Measurement

(Audited)

The risk profile of our insurance manufacturing businesses is 
measured using an economic capital approach. Assets and 
liabilities are measured on a market value basis, and a capital 
requirement is defined to ensure that there is a less than one-
in-200 chance of insolvency over a one-year time horizon, given 
the risks to which the businesses are exposed. The methodology 
for the economic capital calculation is largely aligned to the pan-
European Solvency II insurance capital regulations. The economic 
capital coverage ratio (economic net asset value divided by the 
economic capital requirement) is a key risk appetite measure.

The Covid-19 outbreak caused sales of insurance products to be 
lower than forecast in 2020, although we responded by expanding 
digital and remote servicing capabilities. To date there has been 
limited impact on claims or lapse behaviours, although this 
remains under close monitoring. The largest effect on insurance 
entities came from volatility in the financial markets and the 
material fall in interest rates, which impact levels of capital and 
profitability. Businesses responded by executing de-risking 
strategies followed by subsequent re-risking of positions as 
markets recovered. Enhanced monitoring of risks and pricing 
conditions continues.

190

HSBC Holdings plc Annual Report and Accounts 2020

 
 
The following tables show the composition of assets and liabilities by contract type and by geographical region.

Balance sheet of insurance manufacturing subsidiaries by type of contract1
(Audited)

Financial assets

–  trading assets

–  financial assets designated and otherwise mandatorily measured at fair 

value through profit or loss

–  derivatives

–  financial investments at amortised cost

–  financial investments at fair value through other comprehensive income

–  other financial assets

Reinsurance assets

PVIF

Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts

Deferred tax

Other liabilities

Total liabilities
Total equity
Total liabilities and equity at 31 Dec 2020

Financial assets

–  trading assets
–  financial assets designated and otherwise mandatorily measured at fair 

value through profit or loss

–  derivatives

–  financial investments at amortised cost

–  financial investments at fair value through other comprehensive income

–  other financial assets

Reinsurance assets

PVIF

Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts

Deferred tax

Other liabilities

Total liabilities

Total equity

Total liabilities and equity at 31 Dec 2019

Footnotes

With
DPF

$m

Unit-linked

Other 
contracts2

Shareholder
assets and 
liabilities

$m

$m

$m

Total

$m

84,478   

8,802   

18,932   

8,915   

121,127 

—   

—   

—   

—   

— 

3

4

5

3

4

5

26,002   

8,558   

3,508   

1,485   

39,553 

262   

39,891   

12,531   

5,792   

2,256   

—   

2,628   

89,362   

—   

84,931   

145   

—   

85,076   
—   
85,076   

3   

30   

—   

211   

65   

—   

1   

8,868   

2,285   

6,503   

5   

—   

8,793   
—   
8,793   

13   

13,984   

459   

968   

1,447   

—   

227   

3   

4,521   

1,931   

975   

2   

9,435   

721   

281 

58,426 

14,921 

7,946 

3,770 

9,435 

3,577 

20,606   

19,073   

137,909 

4,100   

15,827   

25   

—   

19,952   
—   
19,952   

—   

—   

6,385 

107,261 

1,400   

7,244   

8,644   
15,444   
24,088   

1,575 

7,244 

122,465 
15,444 
137,909 

73,929   

7,333   

17,514   

8,269   

107,045 

—   

—   

—   

—   

— 

21,652   

202   

35,299   

12,447   

4,329   

2,208   

—   

2,495   

78,632   

—   

77,147   

197   

—   

7,119   

3,081   

(6)   

18   

—   

202   

72   

—   

2   

7,407   

2,011   

6,151   

23   

—   

9   

13,436   

445   

543   

1,563   

—   

211   

19,288   

3,881   

14,141   

6   

—   

77,344   

8,185   

18,028   

—   

—   

—   

77,344   

8,185   

18,028   

2,426   

3   

4,076   

1,136   

628   

1   

8,945   

602   

34,278 

208 

52,829 

14,028 

5,702 

3,844 

8,945 

3,310 

17,817   

123,144 

—   

—   

1,297   

4,410   

5,707   

13,879   

19,586   

5,892 

97,439 

1,523 

4,410 

109,264 

13,879 

123,143 

1 Balance sheet of insurance manufacturing operations are shown before elimination of inter-company transactions with HSBC non-insurance 

operations.

2 ‘Other Contracts’ includes term insurance, credit life insurance, universal life insurance and investment contracts not included in the ‘Unit-linked’ 

or ‘With DPF’ columns.

3 Comprise mainly loans and advances to banks, cash and inter-company balances with other non-insurance legal entities.
4 Present value of in-force long-term insurance business.
5 ‘Deferred tax’ includes the deferred tax liabilities arising on recognition of PVIF.

HSBC Holdings plc Annual Report and Accounts 2020

191

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Balance sheet of insurance manufacturing subsidiaries by geographical region1,2
(Audited)

Financial assets

–  trading assets

–  financial assets designated and otherwise mandatorily measured at fair value through 

profit or loss

–  derivatives

–  financial investments – at amortised cost

–  financial investments – at fair value through other comprehensive income

–  other financial assets

Reinsurance assets

PVIF

Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts

Deferred tax

Other liabilities

Total liabilities

Total equity

Total liabilities and equity at 31 Dec 2020

Financial assets

–  trading assets

–  financial assets designated and otherwise mandatorily measured at fair value through 

profit or loss

–  derivatives

–  financial investments – at amortised cost

–  financial investments – at fair value through other comprehensive income

–  other financial assets

Reinsurance assets

PVIF

Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts

Deferred tax

Other liabilities

Total liabilities

Total equity

Total liabilities and equity at 31 Dec 2019

Footnotes

Europe

$m

Asia

$m

Latin 
America

$m

Total

$m

34,768   

85,259   

1,100   

121,127 

—   

—   

—   

— 

3

4

5

3

4

5

17,184   

22,099   

107   

531   

13,894   

3,052   

245   

884   

1,189   

174   

57,420   

706   

4,860   

3,521   

8,390   

2,332   

270   

—   

475   

321   

34   

4   

161   

56   

39,553 

281 

58,426 

14,921 

7,946 

3,770 

9,435 

3,577 

37,086   

99,502   

1,321   

137,909 

1,288   

5,097   

—   

6,385 

31,153   

74,994   

1,114   

107,261 

204   

2,426   

35,071   

2,015   

37,086   

1,348   

4,800   

86,239   

13,263   

99,502   

23   

18   

1,575 

7,244 

1,155   

122,465 

166   

15,444 

1,321   

137,909 

31,613   

74,237   

1,195   

107,045 

—   

—   

—   

— 

15,490   

18,562   

84   

100   

13,071   

2,868   

237   

945   

1,085   

33,880   

1,139   

28,437   

229   

2,212   

32,017   

1,862   

33,879   

124   

52,186   

582   

2,783   

3,604   

7,841   

2,176   

87,858   

4,753   

67,884   

1,275   

2,172   

76,084   

11,774   

87,858   

226   

—   

543   

375   

51   

3   

159   

49   

34,278 

208 

52,829 

14,028 

5,702 

3,844 

8,945 

3,310 

1,406   

123,144 

—   

1,118   

19   

26   

1,163   

243   

1,406   

5,892 

97,439 

1,523 

4,410 

109,264 

13,879 

123,143 

1 HSBC has no insurance manufacturing subsidiaries in the Middle East and North Africa or North America.
2 Balance sheet of insurance manufacturing operations are shown before elimination of inter-company transactions with HSBC non-insurance 

operations.

3 Comprise mainly loans and advances to banks, cash and inter-company balances with other non-insurance legal entities.
4 Present value of in-force long-term insurance business.
5 ‘Deferred tax’ includes the deferred tax liabilities arising on recognition of PVIF.

Key risk types

The key risks for the insurance operations are market risks, in 
particular interest rate and equity, and credit risks, followed by 
insurance underwriting risk and operational risks. Liquidity risk, 
while significant for the bank, is minor for our insurance 
operations.

Market risk

(Audited)

Description and exposure

Market risk is the risk of changes in market factors affecting 
HSBC’s capital or profit. Market factors include interest rates, 
equity and growth assets and foreign exchange rates. 

Our exposure varies depending on the type of contract issued. 
Our most significant life insurance products are contracts with 
discretionary participating features (‘DPF’) issued in France and 
Hong Kong. These products typically include some form of capital 
guarantee or guaranteed return on the sums invested by the 
policyholders, to which discretionary bonuses are added if allowed 
by the overall performance of the funds. These funds are primarily 

192

HSBC Holdings plc Annual Report and Accounts 2020

invested in bonds, with a proportion allocated to other asset 
classes to provide customers with the potential for enhanced 
returns.

DPF products expose HSBC to the risk of variation in asset returns, 
which will impact our participation in the investment performance. 

In addition, in some scenarios the asset returns can become 
insufficient to cover the policyholders’ financial guarantees, in 
which case the shortfall has to be met by HSBC. Amounts are held 
against the cost of such guarantees, calculated by stochastic 
modelling.

The cost of such guarantees is accounted for as a deduction from 
the present value of in-force ('PVIF') asset, unless the cost of such 
guarantees is already explicitly allowed for within the insurance 
contract liabilities under the local rules.

The following table shows the total reserve held for the cost of 
guarantees, the range of investment returns on assets supporting 
these products and the implied investment return that would 
enable the business to meet the guarantees.

The cost of guarantees increased to $1,105m (2019: $693m) 
primarily due to the reduction in swap rates in France and Hong 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Kong, partly offset by the impact of modelling changes in France 
and Hong Kong.

policyholder, but some market risk exposure typically remains, as 
fees earned are related to the market value of the linked assets.

For unit-linked contracts, market risk is substantially borne by the 

Financial return guarantees

(Audited)

Capital

Nominal annual return

Nominal annual return

Nominal annual return

At 31 Dec

Sensitivities

2020

Long-term  
investment 
returns on 
relevant 
portfolios

%

0.7–3.2  

2.3–3.6  

2.0–4.5  

2.0–4.2  

Investment 
returns implied 
by guarantee

%

 0.0 

0.1–1.9

2.0-3.9

4.0–5.0

Cost of 
guarantees

Investment 
returns implied 
by guarantee

$m

277 

515 

180 

133 

1,105 

%

 0.0 

0.1–2.0

2.0–4.0

4.1–5.0

2019

Long-term 
investment 
returns on 
relevant 
portfolios

%

1.3–3.9  

3.0–4.5  

2.4–4.5  

2.3–4.1  

Cost of 
guarantees

$m

110 

118 

355 

110 

693 

Changes in financial market factors, from the economic 
assumptions in place at the start of the year, had a positive impact 
on reported profit before tax of $102m (2019: $124m). The 
following table illustrates the effects of selected interest rate, 
equity price and foreign exchange rate scenarios on our profit for 
the year and the total equity of our insurance manufacturing 
subsidiaries.

Where appropriate, the effects of the sensitivity tests on profit 
after tax and equity incorporate the impact of the stress on the 
PVIF.

Due in part to the impact of the cost of guarantees and hedging 
strategies, which may be in place, the relationship between the 
profit and total equity and the risk factors is non-

linear, particularly in a low interest-rate environment. Therefore, 
the results disclosed should not be extrapolated to measure 
sensitivities to different levels of stress. For the same reason, the 
impact of the stress is not necessarily symmetrical on the upside 
and downside. The sensitivities are stated before allowance for 
management actions, which may mitigate the effect of changes in 
the market environment. The sensitivities presented allow for 
adverse changes in policyholder behaviour that may arise in 
response to changes in market rates. The differences between the 
impacts on profit after tax and equity are driven by the changes in 
value of the bonds measured at fair value through other 
comprehensive income, which are only accounted for in equity.

Sensitivity of HSBC’s insurance manufacturing subsidiaries to market risk factors

(Audited)

+100 basis point parallel shift in yield curves

-100 basis point parallel shift in yield curves 

10% increase in equity prices

10% decrease in equity prices

10% increase in US dollar exchange rate compared with all currencies

10% decrease in US dollar exchange rate compared with all currencies

Credit risk

(Audited)

Description and exposure

Credit risk is the risk of financial loss if a customer or counterparty 
fails to meet their obligation under a contract. It arises in two main 
areas for our insurance manufacturers:

• risk associated with credit spread volatility and default by debt 
security counterparties after investing premiums to generate a 
return for policyholders and shareholders; and

• risk of default by reinsurance counterparties and non-

reimbursement for claims made after ceding insurance risk.

The amounts outstanding at the balance sheet date in respect 
of these items are shown in the table on page 191.

The credit quality of the reinsurers’ share of liabilities under 
insurance contracts is assessed as ‘satisfactory’ or higher (as 
defined on page 121), with 100% of the exposure being neither 
past due nor impaired (2019: 100%). 

Credit risk on assets supporting unit-linked liabilities is 
predominantly borne by the policyholder. Therefore, our exposure 
is primarily related to liabilities under non-linked insurance and 
investment contracts and shareholders’ funds. The credit quality of 
insurance financial assets is included in the table on page 138. 

2020

2019

Effect on
profit after tax

Effect on
total equity

Effect on 
profit after tax

Effect on
total equity

$m

(67)   

(68)   

332   

(338)   

84   

(84)   

$m

(188)   

58   

332   

(338)   

84   

(84)   

$m

43   

(221)   

270   

(276)   

41   

(41)   

$m

(37) 

(138) 

270 

(276) 

41 

(41) 

The risk associated with credit spread volatility is to a large extent 
mitigated by holding debt securities to maturity, and sharing a 
degree of credit spread experience with policyholders.

Capital and liquidity risk

(Audited)

Description and exposure

Liquidity risk is the risk that an insurance operation, though 
solvent, either does not have sufficient financial resources 
available to meet its obligations when they fall due, or can secure 
them only at excessive cost.

The following table shows the expected undiscounted cash flows 
for insurance liabilities at 31 December 2020. The liquidity risk 
exposure is wholly borne by the policyholder in the case of unit-
linked business and is shared with the policyholder for non-linked 
insurance.

The profile of the expected maturity of insurance contracts at 
31 December 2020 remained comparable with 2019.
The remaining contractual maturity of investment contract 
liabilities is included in Note 29 on page 347.

HSBC Holdings plc Annual Report and Accounts 2020

193

Risk review 
 
 
 
 
 
 
 
 
 
 
Risk

Expected maturity of insurance contract liabilities

(Audited)

Unit-linked 

With DPF and Other contracts

At 31 Dec 2020

Unit-linked 

With DPF and Other contracts

At 31 Dec 2019

Insurance risk

Description and exposure

Insurance risk is the risk of loss through adverse experience, in 
either timing or amount, of insurance underwriting parameters 
(non-economic assumptions). These parameters include mortality, 
morbidity, longevity, lapses and unit costs.

The principal risk we face is that, over time, the cost of the 
contract, including claims and benefits, may exceed the total 
amount of premiums and investment income received. 

The tables on pages 191 and 192 analyse our life insurance risk 
exposures by type of contract and by geographical region. 

The insurance risk profile and related exposures remain largely 
consistent with those observed at 31 December 2019.

Sensitivities 

(Audited)

The following table shows the sensitivity of profit and total equity 
to reasonably possible changes in non-economic assumptions 
across all our insurance manufacturing subsidiaries.

Sensitivity analysis

(Audited)

Within 1 year

1-5 years

5-15 years

Over 15 years

Expected cash flows (undiscounted)

$m

1,407   

8,427   

9,834   

1,296   

7,907   

9,203   

$m

3,097   

30,156   

33,253   

3,153   

26,906   

30,059   

$m

2,976   

51,383   

54,359   

2,654   

50,576   

53,230   

$m

2,099   

75,839   

77,938   

1,955   

71,731   

73,686   

Total

$m

9,579 

165,805 

175,384 

9,058 

157,120 

166,178 

Mortality and morbidity risk is typically associated with life 
insurance contracts. The effect on profit of an increase in mortality 
or morbidity depends on the type of business being written. Our 
largest exposures to mortality and morbidity risk exist in Hong 
Kong.

Sensitivity to lapse rates depends on the type of contracts 
being written. For a portfolio of term assurance, an increase in 
lapse rates typically has a negative effect on profit due to the loss 
of future income on the lapsed policies. However, some contract 
lapses have a positive effect on profit due to the existence of 
policy surrender charges. We are most sensitive to a change in 
lapse rates on unit-linked and universal life contracts in Hong 
Kong and DPF contracts in France.

Expense rate risk is the exposure to a change in the cost 
of administering insurance contracts. To the extent that increased 
expenses cannot be passed on to policyholders, an increase in 
expense rates will have a negative effect on our profits.

Effect on profit after tax and total equity at 31 Dec

Effect on profit after tax and total equity at 10% increase in mortality and/or morbidity rates

Effect on profit after tax and total equity at 10% decrease in mortality and/or morbidity rates

Effect on profit after tax and total equity at 10% increase in lapse rates

Effect on profit after tax and total equity at 10% decrease in lapse rates

Effect on profit after tax and total equity at 10% increase in expense rates

Effect on profit after tax and total equity at 10% decrease in expense rates

2020

$m

(93)   

98   

(111)   

128   

(117)   

115   

2019

$m

(88) 

88 

(99) 

114 

(106) 

105 

194

HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate 
governance report

196 

198 

202 

Group Chairman’s governance statement

The Board

Senior management

204  How we are governed

209 

213 

Board activities during 2020

Board committees

229  Directors’ remuneration report

256 

260 

261 

264 

Share capital and other related disclosures

Internal control

Employees

Statement of compliance

265  Directors’ responsibility statement

HSBC is committed to high standards of corporate 
governance. We have a comprehensive range of 
policies and systems in place designed to ensure that 
the Group is well managed, with effective oversight 
and control.

195

Corporate governanceHSBC Holdings plc Annual Report and Accounts 2020Report of the Directors | Corporate governance report

Group Chairman’s governance statement

Despite the challenging environment, the Board 
remained informed on relevant issues, engaged  
with stakeholders, and oversaw the development  
of our new Group purpose and values.

As Group Chairman, I am ultimately 
responsible for the Group’s governance 
arrangements and the effective operation of 
the Board. I am also responsible for ensuring 
that the Board sets the right tone from the top 
of the organisation and monitors the Group’s 
culture. Given the unique challenges faced 
during 2020 as a result of the Covid-19 
outbreak, it was important that the Board was 
properly informed on a regular basis on all  
key issues and priorities affecting the Group.  
To achieve this, we increased our Board 
communication and met more frequently 
during 2020, albeit remotely and with 
scheduling flexed to meet the challenges  
of Directors based in different time zones.  
This allowed us to share insights and receive 
updates on key developments, supported by 
the attendance of external subject matter 
experts. 

Given the restrictions on travel and large 
gatherings, and the guidance available to us  
at the time, we took the decision to hold the 
2020 AGM behind closed doors. As we 
approach our 2021 AGM, we will continue to 
monitor the situation, and will prioritise the 
health and safety of the Board, our colleagues 
and of course our shareholders. Further details 
will be provided when our Notice of AGM is 
published on 24 March 2021.

Board changes
Following a thorough and robust search 
process, as more fully set out in the 
Nomination & Corporate Governance 
Committee report on page 213, the Board 
unanimously supported the appointment  
of Noel Quinn as Group Chief Executive on  
17 March 2020. Noel has provided strong 
direction and excellent leadership to HSBC 
through these unprecedented times.

Mark E Tucker
Group Chairman

“ Governance improvements will remain  
an area of focus for the Board and its 
subsidiaries in the years ahead as the  
Group aims to achieve its ambition of  
operating with world-class governance.”

Dear Shareholder

With the global pandemic and challenging 
macroeconomic and geopolitical environment, 
2020 was an extraordinary year for the Board. 
These challenges have highlighted the 
importance of our governance framework and 
operating practices. Against this backdrop,  
the Board oversaw the development of the 
Group’s future purpose and strategy led by  
the Group Chief Executive. We adapted our 
Board and senior management engagement 
schedule to ensure that as a Board, we 
continued to deliver on our responsibilities  
to our key stakeholders.

I would like to thank Sir Jonathan Symonds 
and Kathleen Casey who stepped down from 
the Board earlier this year. We subsequently 
appointed three new Directors, James Forese, 
Steven Guggenheimer and Eileen Murray, who 
collectively bring strong universal banking, 
operational and technology expertise. 

While the Board and its committees have 
operated well in a virtual environment, I do  
not underestimate the value of in-person 
meetings. Our three new Directors underwent 
a successful virtual non-executive Director 
induction programme during the year and we 
look forward to welcoming them in person at 
an appropriate point in the future.

196

HSBC Holdings plc Annual Report and Accounts 2020Today we also announce that Laura Cha will 
step down from the Board at the conclusion of 
our 2021 AGM in May. On behalf of the Board, 
I wish to thank Laura for her outstanding 
dedication and the enormous contribution  
she has made to the success of HSBC over 
many years. I greatly appreciate the support 
and counsel that she has provided to me 
personally on many occasions since I  
became the Group Chairman. 

The Board initiated a search for suitable 
candidates to join and strengthen the expertise 
on the Board, and further enhance our  
Board diversity and knowledge of Asia.  
I was delighted that last week we were able  
to announce the appointment of Dame Carolyn 
Fairbairn as an independent non-executive 
Director. Carolyn will bring a wealth of relevant 
experience to our Board and her appointment 
will be effective from 1 September 2021. I am 
pleased to report we are in advanced stages 
on other searches that will result in further 
strengthening the Board’s skill set. 

Board evaluation
In line with best practice, the Board and its 
committees again conducted a review of the 
effectiveness of our operation and practices. 

Our 2019 review identified a number of areas 
for improvement in the way that the Board 
operated. We took a number of actions during 
the second half of 2019 and throughout  
2020 to address the areas identified, which 
contributed to improved effectiveness despite 
the challenges posed by Covid-19 and the 
uncertain geopolitical environment. 

We took the decision to once again invite  
Dr Tracy Long, the independent board 
evaluator, to facilitate our 2020 review, provide 
assurance on the progress made, and identify 
any areas where further action was required. 
Further details of the process, findings and 
recommendations from the 2020 review can 
be found on page 211. 

Subsidiary governance
During the year, the Board requested  
the Group Company Secretary and Chief 
Governance Officer to undertake a review of 
subsidiary governance, including a review of 
the composition of the principal subsidiary 
boards. Following this exercise, principal 
subsidiaries will report to the Nomination & 
Corporate Governance Committee during 
2021 on their future board compositions and 
succession plans to help ensure that they have 

effective and diverse skill sets that are aligned 
with our future strategy. Further details  
are set out in the Nomination & Corporate 
Governance Committee report on page 213. 

issues, as well as training to provide the Board 
with insight and an understanding of the 
developing landscape and stakeholder 
expectations.

We enhanced our subsidiary accountability 
framework, which applies to all subsidiaries 
within the Group, by supplementing this with 
clear principles and provisions. The refreshed 
framework builds on the progress made to 
enhance Group standards with the aim of 
achieving world-class governance across  
all our subsidiaries.

We strengthened connectivity between  
the HSBC Holdings Board and principal 
subsidiaries by increasing the frequency of the 
Chairman’s Forum meetings. These monthly 
meetings – which I chair – are attended by the 
chairs of the Holdings Board committees and 
the chairs of the principal subsidiaries’ boards. 
Given the significant uncertainty and 
challenges that the Group, the industry and 
wider society encountered in 2020, these 
more frequent meetings proved hugely 
beneficial in identifying and navigating the 
challenges facing the Group globally.

Purpose and values
As we developed our purpose and values, the 
Board undertook significant engagement with 
key stakeholders. Their input was important 
and influenced the outcome. It is critical that 
the values and associated behaviours are 
embedded across the Group. Senior 
management’s success in embedding the 
purpose and values will be overseen by the 
Board. The Board and the Group Executive 
Committee set the tone from the top by 
adopting these refreshed values, which will 
inform the Board’s engagement practices  
and help facilitate an open and collaborative 
relationship with its stakeholders. The 
boardroom guidelines, which set out the  
ways of working between the Board and 
management and which were implemented  
in 2020, also support the engagement 
between the Board and management. 

Further details of the Board’s consideration 
when developing the purpose and values  
can be found in our section 172 statement  
on page 24.

Climate commitments
Environmental, social and governance (‘ESG’) 
issues have been an area of significant Board 
focus during 2020. This has been in the form 
of formal consideration of our strategy and 
ambitions in relation to ESG and climate 

Recognising the importance of these matters 
to our stakeholders, investors and customers, 
the Board was pleased to announce our 
updated climate ambition in October 2020. 
Further information is provided on pages 24 
and 44.

Workforce engagement
Members of the Board and subsidiary boards 
engaged actively with our employees during 
2020 in line with the requirements of the 2018 
UK Corporate Governance Code in relation to 
workforce engagement.

Despite travel restrictions, all of the non-
executive Directors engaged directly with 
members of the workforce across our global 
business lines, and through our employee 
resource groups. This has provided great 
insight into the views of the wider workforce 
and gave valuable context for the Directors  
in informing their discussions at the Board. 
Further details of our workforce engagement 
practices during 2020 can be found on  
page 210.

Looking ahead
I am pleased with the progress that the Board 
and broader Group have made in enhancing 
our governance practices during 2020. 
Governance improvements will remain an area 
of focus for the Board and its subsidiaries in 
the years ahead as the Group aims to achieve 
its ambition of operating with world-class 
governance.

As a result of the Covid-19 outbreak, we  
have had to adjust how we engage with our 
shareholders and other stakeholders, with 
in-person meetings substituted for virtual 
meetings where necessary. Despite this, we 
continued to engage fully with institutional 
investors. With encouraging news regarding 
successful vaccines, I look forward to 
resuming in-person engagement practices 
with our stakeholders when safe to do so.

Mark E Tucker
Group Chairman

23 February 2021

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Report of the Directors | Corporate governance report

The Board

The Board aims to promote the Group’s long-term 
success, deliver sustainable value to shareholders  
and promote a culture of openness and debate.

Chairman and executive Directors

Mark E Tucker (63) 
Group Chairman
Appointed to the Board: September 2017 
Group Chairman since: October 2017

Noel Quinn (59)
Group Chief Executive
Appointed to the Board: August 2019 
Group Chief Executive since: March 2020

Skills and experience: With over 30 years’ 
experience in financial services in Asia and the  
UK, Mark has a deep understanding of the industry 
and the markets in which we operate. 

Career: Mark was previously Group Chief Executive 
and President of AIA Group Limited (‘AIA’). Prior to 
joining AIA, he held various senior management 
roles with Prudential plc, including as Group Chief 
Executive for four years. He served on Prudential’s 
Board for 10 years. 

Mark previously served as non-executive Director of 
the Court of The Bank of England, as an independent 
non-executive Director of Goldman Sachs Group and 
as Group Finance Director of HBOS plc. 

External appointments: 
 – Chair of TheCityUK
 – Non-executive Chairman of Discovery Limited
 – Member of Build Back Better Council
 – Supporting Chair of Chapter Zero

Skills and experience: Noel has more than 30 
years’ banking and financial services experience, 
both in the UK and Asia, with over 28 years at HSBC.

Career: Noel was formally named Group Chief 
Executive in March 2020, having held the role on an 
interim basis since August 2019. He has held various 
management roles across HSBC since joining in 
1992. He was most recently Chief Executive Officer 
of Global Commercial Banking, having been 
appointed to the role in December 2015 and as a 
Group Managing Director in September 2016. Noel 
joined Forward Trust Group, a subsidiary of Midland 
Bank, in 1987 and joined HSBC in 1992 when the 
Group acquired Midland Bank. 

External appointments: 
 –  Chair of the Financial Services Task Force of the 

Ewen Stevenson (54)
Group Chief Financial Officer
Appointed to the Board: January 2019

Skills and experience: Ewen has over 25 years’ 
experience in the banking industry, both as an 
adviser to major banks and as an executive of  
large financial institutions. In addition to his existing 
leadership responsibilities for Group Finance,  
Ewen assumed responsibility for the oversight  
of the Group's transformation programme in 
February 2021 and will assume responsibility  
for the Group’s mergers and acquisitions activities  
in April 2021.  

Career: Ewen was Chief Financial Officer of  
Royal Bank of Scotland Group plc from 2014  
to 2018. Prior to this, Ewen spent 25 years with  
Credit Suisse, where his last role was co-Head  
of the EMEA Investment Banking Division  
and co-Head of the Global Financial  
Institutions Group.

Sustainable Market Initiative 

External appointments: None

Board committee membership key
Committee Chair
Group Audit Committee
Group Risk Committee
Group Remuneration Committee
Nomination & Corporate Governance Committee

For full biographical details of our Board members, see 
www.hsbc.com/who-we-are/leadership.

198

HSBC Holdings plc Annual Report and Accounts 2020Independent non-executive Directors

Laura Cha, GBM (71) 
Independent non-executive Director
Appointed to the Board: March 2011 

Henri de Castries (66)     
Independent non-executive Director
Appointed to the Board: March 2016 

James Forese (58)  
Independent non-executive Director
Appointed to the Board: May 2020

Steven Guggenheimer (55)     
Independent non-executive Director
Appointed to the Board: May 2020

Skills and experience: Laura  
has extensive regulatory and 
policymaking experience in the 
finance and securities sector in  
Hong Kong and mainland China.

Skills and experience: Henri has 
more than 25 years’ international 
experience in the financial services 
industry, working in global insurance 
and asset management.

Career: Laura was formerly Vice 
Chairman of the China Securities 
Regulatory Commission, becoming 
the first person outside mainland 
China to join the Central Government 
of the People’s Republic of China at 
Vice-Ministerial level. The Hong Kong 
Government awarded her the Grand 
Bauhinia Medal for public service. 

She has previously served  
as non-executive Director of China 
Telecom Corporation Limited, Bank  
of Communications Co., Ltd, and  
Tata Consultancy Services Limited.

External appointments: 
 –  Chair of Hong Kong Exchanges  

and Clearing Limited

 –  Non-executive Chair of The 

Hongkong and Shanghai Banking 
Corporation Limited

 –  Non-executive Director of  

The London Metal Exchange

 –  Non-executive Director of  

Unilever PLC

Career: Henri joined AXA S.A. in  
1989 and held a number of senior 
roles, including Chief Executive Officer 
from 2000. In 2010, he was appointed 
Chairman and Chief Executive, before 
stepping down in 2016. 

He has previously worked for the 
French Finance Ministry Inspection 
Office and the French Treasury 
Department.

External appointments: 
 –  Special Adviser to General Atlantic
 – Chairman of Institut Montaigne
 – Vice Chairman of Nestlé S.A.
 –  Non-executive Director of the French 

National Foundation for Political 
Science

 –  Member of the Global Advisory 
Council at LeapFrog Investments
 –  Senior Independent non-executive 

Director of Stellantis NV

Skills and experience: James has 
over 30 years’ international business 
and management experience in the 
finance industry.

Career: James formerly served as 
President of Citigroup. He began his 
career in securities trading with 
Salomon Brothers, one of Citigroup’s 
predecessor companies, in 1985. In 
addition to his most recent role as 
President and Chief Executive Officer 
of Citigroup’s Institutional Clients 
Group, he has been Chief Executive of 
its Securities and Banking division and 
head of its Global Markets business. 
On 1 January 2021, he became a 
non-executive Director of HSBC North 
America Holdings Inc. 

External appointments: 
 –  Non-executive Chairman of Global 

Bamboo Technologies
 – Trustee of Colby College

Skills and experience: Steven is an 
experienced technology executive 
with a strong track record of advising 
businesses on digital transformation. 
He brings extensive insight into 
technologies ranging from artificial 
intelligence to Cloud computing.

Career: Steven has more than  
25 years’ experience at Microsoft, 
where he has held a variety of senior 
leadership roles. These include: 
Corporate Vice President for AI 
Business; Corporate Vice President  
of AI and ISV Engagement; Chief 
Evangelist; and Corporate Vice 
President, Original Equipment 
Manufacturer. 

External appointments: 
 –  Non-executive Director of Forrit 

Technologies Limited

 – Advisor to Tensility Venture Fund
 –  Advisory Board Member of 5G  

Open Innovation Lab

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Report of the Directors | Corporate governance report

Independent non-executive Directors 

Irene Lee (67)     
Independent non-executive Director
Appointed to the Board: July 2015

Skills and experience: Irene has 
more than 40 years’ experience  
in the finance industry, having held 
senior investment banking and fund 
management roles in the UK, the  
US and Australia.

Dr José Antonio Meade Kuribreña 
(51)      
Independent non-executive Director
Appointed to the Board: March 2019

Skills and experience: José has 
extensive experience across a number 
of industries, including in public 
administration, banking, financial 
policy and foreign affairs.

Career: Irene held senior positions at 
Citibank, the Commonwealth Bank of 
Australia and SealCorp Holdings 
Limited.  

Other past appointments include 
being a member of the Advisory 
Council for J.P. Morgan Australia,  
a member of the Australian 
Government Takeovers Panel and a 
non-executive Director of Cathay 
Pacific Airways Limited.

External appointments: 
 –  Executive Chair of Hysan 

Development Company Limited
 –  Non-executive Director of The 

Hongkong and Shanghai Banking 
Corporation Limited

 –  Non-executive Director of Hang 

Seng Bank Limited

 –  Member of the Exchange Fund 

Advisory Committee of the Hong 
Kong Monetary Authority.

 –  Chair of Hang Seng Bank Limited 
(from the conclusion of its 2021 
AGM)

Career: Between 2011 and 2017,  
José held Cabinet-level positions  
in the federal government of Mexico, 
including as Secretary of Finance  
and Public Credit, Secretary of Social 
Development, Secretary of Foreign 
Affairs and Secretary of Energy. Prior 
to his appointment to the Cabinet, he 
served as Undersecretary and as  
Chief of Staff in the Ministry of  
Finance and Public Credit.

José is also a former Director General 
of Banking and Savings at the Ministry 
of Finance and Public Credit and 
served as Chief Executive Officer of 
the National Bank for Rural Credit.

External appointments: 
 –  Commissioner and Board Member 

of the Global Commission on 
Adaptation

 –  Non-executive Director of Alfa 

S.A.B. de C.V.

Heidi Miller (67)     
Independent non-executive Director
Appointed to the Board: September 2014

Eileen Murray (62) 
Independent non-executive Director
Appointed to the Board: July 2020

Skills and experience: Heidi  
has more than 30 years’ senior 
management experience in 
international banking and finance.

Career: Heidi was President of 
International at J.P. Morgan Chase & 
Co. between 2010 and 2012 where  
she led the bank’s global expansion 
and international business strategy 
across the investment bank, asset 
management, and treasury and 
securities services divisions. 
Previously, she ran the treasury  
and securities services division  
for six years. 

Other past roles included Chief 
Financial Officer of Bank One 
Corporation and Senior Executive Vice 
President of Priceline.com Inc. 

She has previously served in 
non-executive Director roles for 
General Mills Inc., Merck & Co Inc.  
and Progressive Corp. She was also a 
trustee of the International Financial 
Reporting Standards Foundation. She 
is currently Chair of HSBC North 
America Holdings Inc.

External appointments: 
 – Non-executive Director of Fiserv Inc.
 –  Chair of the Audit Committee of 

Fiserv, Inc.

Skills and experience: Eileen is  
an accomplished executive with 
extensive knowledge in financial 
technology and corporate strategy from 
a career spanning more than 40 years.

Career: Eileen most recently served 
as co-Chief Executive Officer of 
Bridgewater Associates, LP. Prior to 
joining Bridgewater, she was Chief 
Executive Officer for Investment Risk 
Management LLC and President and 
co-Chief Executive Officer of Duff 
Capital Advisors.

She started her professional career in 
1984 at Morgan Stanley, where she 
held several senior positions including 
Controller, Treasurer, and Global Head 
of Technology and Operations, as well 
as Chief Operating Officer for its 
Institutional Securities Group. From 
2002 to 2005, she was Head of Global 
Technology, Operations and Product 
Control at Credit Suisse and served on 
its management and executive board. 

External appointments: 
 –  Chair of the Financial Industry 

Regulatory Authority

 –  Non-executive Director of Compass 
 –  Non-executive Director of Guardian 
Life Insurance Company of America

 – Director of HumanityCorp
 –  Non-executive Director of Atlas 

Crest Investment Corp.

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HSBC Holdings plc Annual Report and Accounts 2020 
 
 
David Nish (60) 
Independent non-executive Director
Appointed to the Board: May 2016 
Senior Independent non-executive 
Director since February 2020 

Skills and experience: David has 
substantial international experience  
of financial services, corporate 
governance, financial accounting  
and operational transformation. 

Career: David served as Group Chief 
Executive Officer of Standard Life plc 
between 2010 and 2015, having joined 
the company in 2006 as Group 
Finance Director. He is also a former 
Group Finance Director of Scottish 
Power plc and was a partner at Price 
Waterhouse. 

David has also previously served as a 
non-executive Director of HDFC Life 
(India), Northern Foods plc, London 
Stock Exchange Group plc, the UK 
Green Investment Bank plc and Zurich 
Insurance Group.

External appointments: 
 –  Non-executive Director of Vodafone 

Group plc

Jackson Tai (70) 
Independent non-executive Director
Appointed to the Board: September 2016

Skills and experience: Jackson  
has significant experience as a 
non-executive Director, having held 
senior operating and governance  
roles across Asia, North America  
and Europe.

Career: Jackson was Vice Chairman 
and Chief Executive Officer of DBS 
Group and DBS Bank Ltd. between 
2002 and 2007, having served as Chief 
Financial Officer and then as President 
and Chief Operating Officer. He was 
previously a managing director and 
senior officer for Asia-Pacific, and 
executive director and Head of Japan 
Capital Markets in the investment 
banking division of J.P. Morgan & Co. 
Incorporated, where he worked for  
25 years.

Other former appointments include 
non-executive Director of Canada 
Pension Plan Investment Board, Royal 
Philips N.V., Bank of China Limited, 
Singapore Airlines, NYSE Euronext, 
ING Groep N.V., CapitaLand Ltd, 
SingTel Ltd. and Jones Lang LaSalle 
Inc. He also served as Vice Chairman 
of Islamic Bank of Asia.

External appointments: 
 –  Non-executive Director of Eli Lilly 

and Company

 –  Non-executive Director of 
MasterCard Incorporated

Pauline van der Meer Mohr (61) 

Independent non-executive Director
Appointed to the Board: September 2015

Skills and experience: Pauline has 
extensive legal, corporate governance 
and human resources experience 
across a number of different sectors.

Career: Pauline served on the 
Supervisory Board of ASML Holding 
N.V. between 2009 and 2018. She  
was formerly President of Erasmus 
University Rotterdam, a member of 
the Dutch Banking Code Monitoring 
Committee and a Senior Vice 
President and Head of Group Human 
Resources Director at ABN AMRO 
Bank N.V. and TNT N.V. She also held 
various executive roles at the Royal 
Dutch Shell Group.

External appointments:
 –  Chair of the Dutch Corporate 
Governance Code Monitoring 
Committee

 –  Chair of the Supervisory Board  

of EY Netherlands

 –  Deputy Chair of the Supervisory 

Board of Royal DSM N.V.

 –  Member of the Selection and 
Nomination Committee of the 
Supreme Court of the Netherlands

 –  Member of the Capital Markets 

Committee of the Dutch Authority 
for Financial Markets 

 –  Non-executive Director of Viatris, 

Inc.

Aileen Taylor (48) 
Group Company Secretary and 
Chief Governance Officer
Appointed: November 2019

Skills and experience: Aileen  
has significant governance and 
regulatory experience across 
various roles in the banking 
industry. She is a solicitor and a 
member of the European Corporate 
Governance Council, the GC100 and 
the Financial Conduct Authority’s 
Listing Authority Advisory Panel.

Career: Aileen spent 19 years at  
the Royal Bank of Scotland Group, 
having held various legal, risk  
and compliance roles. She was 
appointed Group Secretary in  
2010 and was most recently  
Chief Governance Officer and  
Board Counsel. 

Former Directors who served 
for part of the year 

Sir Jonathan Symonds
Sir Jonathan Symonds retired from the 
Board on 18 February 2020.

Kathleen Casey
Kathleen Casey retired from the Board 
on 24 April 2020.

 For full biographical details of our Board members,  
see www.hsbc.com/who-we-are/leadership.

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Senior management

Senior management, which includes the Group Executive 
Committee, supports the Group Chief Executive in the day-to-day 
management of the business and the implementation of strategy. 

Elaine Arden (52) 
Group Chief Human  
Resources Officer

Colin Bell (53) 
Chief Executive Officer,  
HSBC Bank plc and HSBC Europe

Jonathan Calvert-Davies (52) 
Group Head of Audit

Georges Elhedery (46) 
Co-Chief Executive Officer,  
Global Banking and Markets

Elaine joined HSBC as Group Chief 
Human Resources Officer in June 
2017. She was previously at the Royal 
Bank of Scotland Group, where she 
was Group Human Resources 
Director. She has held senior human 
resources and employee relations 
roles in a number of other financial 
institutions, including Clydesdale Bank 
and Direct Line Group. Elaine is a 
member of the Chartered Institute of 
Personnel and Development and a 
fellow of the Chartered Banker 
Institute.

Colin joined HSBC in July 2016 and 
was appointed Chief Executive Officer, 
HSBC Bank plc and HSBC Europe on 
22 February 2021. He previously held 
the role of Group Chief Compliance 
Officer, and also led the Group 
transformation oversight programme. 
Colin previously worked at UBS, which 
he joined in 2007, where he was the 
Global Head of Compliance and 
Operational Risk Control. Colin joined 
the British Army in 1990 and he served 
for 16 years in a variety of command 
and staff roles and completed the 
Joint Services Command and Staff 
College in 2001.  

Jonathan joined HSBC as Group Head 
of Audit in October 2019 and is a 
standing attendee of the Group 
Executive Committee. He has 30 years 
of experience providing assurance, 
audit and advisory services to the 
banking and securities industries in 
the UK, the US and Europe. Prior to 
joining HSBC, he led KPMG’s financial 
services internal audit services 
practice. His previous roles include 
leading PwC’s UK internal audit 
services practice. He also served as 
interim Group Head of Internal Audit at 
the Royal Bank of Scotland Group.

Georges joined HSBC in 2005 and was 
appointed as co-Chief Executive 
Officer of Global Banking and Markets 
in March 2020. He is also head of the 
Markets and Securities Services 
division of the business. Georges 
previously served as Chief Executive 
Officer for HSBC, Middle East, North 
Africa and Turkey and Head of Global 
Markets; Head of Global Banking and 
Markets, MENA; and Regional Head of 
Global Markets, MENA.

Kirsty Everett (44) 
Interim Group Chief Compliance 
Officer

Greg Guyett (57) 
Co-Chief Executive Officer, 
Global Banking and Markets

John Hinshaw (50) 
Group Chief Operating Officer

Bob Hoyt (56) 
Group Chief Legal Officer

Kirsty was appointed as Interim  
Group Chief Compliance Officer  
on 22 February 2021. She took on  
this role in addition to her existing 
responsibilities as the Global Chief 
Operating Officer for the Compliance 
function. She joined HSBC in March 
2019 as the Chief of Staff and Head of 
Digital Transformation for Compliance. 
Prior to joining HSBC, Kirsty was the 
designated Chief Compliance Officer, 
Head of Conduct Risk and Operational 
Risk, Head of Monitoring and 
Oversight at UBS, having originally 
joined from Deloitte in 2012.

Greg joined HSBC in October 2018 as 
Head of Global Banking and became 
co-Chief Executive Officer of Global 
Banking and Markets in March 2020. 
Prior to joining HSBC, he was 
President and Chief Operating Officer 
of East West Bank. Greg began his 
career as an investment banker at J.P. 
Morgan, where positions included: 
Chief Executive Officer for Greater 
China; Chief Executive Officer, Global 
Corporate Bank; Head of Investment 
Banking for Asia-Pacific; and Co-Head 
of Banking Asia-Pacific.

John became Group Chief Operating 
Officer in February 2020, having joined 
HSBC in December 2019. John has an 
extensive background in transforming 
organisations across a range of 
industries. Most recently, he served as 
Executive Vice President of Hewlett 
Packard and Hewlett Packard 
Enterprise, where he managed 
technology and operations and was 
Chief Customer Officer. He also held 
senior roles at Boeing and Verizon and 
served on the Board of Directors of 
BNY Mellon.

Bob joined HSBC as Group Chief Legal 
Officer in January 2021. He was most 
recently Group General Counsel at 
Barclays from 2013 to 2020. Prior to 
that he was General Counsel and Chief 
Regulatory Affairs Officer for The PNC 
Financial Services Group. Bob has 
served as General Counsel to the US 
Department of the Treasury under 
Secretary Paulson, and as Special 
Assistant and Associate Counsel to 
the White House under President 
George W. Bush.

202

HSBC Holdings plc Annual Report and Accounts 2020Nuno Matos (53) 
Chief Executive Officer,  
Wealth and Personal Banking 

Stephen Moss (54) 
Regional Chief Executive

Barry O’Byrne (45) 
Chief Executive Officer,  
Global Commercial Banking 

Pam Kaur (57) 
Group Chief Risk Officer

Pam was appointed Group Chief Risk 
Officer in January 2020, having joined 
HSBC in 2013. She was previously 
Head of Wholesale Market and Credit 
Risk and Chair of the enterprise-wide 
non-financial risk forum. Pam has also 
served as Group Head of Internal 
Audit and held a variety of audit and 
compliance roles at banks, including 
Deutsche Bank, RBS, Lloyds TSB and 
Citigroup. She serves as a non-
executive Director of Centrica plc.

Nuno joined HSBC in 2015 and was 
appointed Chief Executive Officer of 
Wealth and Personal Banking on 22 
February 2021. He was previously the 
Chief Executive Officer of HSBC Bank 
plc and HSBC Europe, a role he held 
from March 2020. He has also served 
as Chief Executive Officer of HSBC 
Mexico, and as regional head of Retail 
Banking and Wealth Management in 
Latin America. Prior to joining HSBC, 
he held senior positions at  
Santander Group.

Stephen joined HSBC in 1992. He was 
named Regional Chief Executive in 
March 2020, with responsibility for 
overseeing the Group's businesses in 
Europe (apart from HSBC UK); the 
Middle East, North Africa and Turkey 
(‘MENAT’); Latin America; and Canada. 
He previously held the role of Chief of 
Staff to the Group Chief Executive and 
oversaw the Group’s mergers and 
acquisitions and strategy and planning 
activities. Stephen will be appointed as 
CEO, MENAT, in April 2021 subject to 
regulatory approval. Stephen is a 
non-executive Director of The Saudi 
British Bank, HSBC Bank Middle East 
Limited, HSBC Middle East Holdings 
B.V, HSBC Latin America Holdings 
(UK) Limited and HSBC Bank Canada. 

Michael Roberts (60) 
President and Chief Executive 
Officer, HSBC USA

Michael joined HSBC in October 2019. 
He is an executive Director, President 
and CEO of HSBC North America 
Holdings Inc. He also serves as 
Chairman of HSBC Bank USA, N.A. 
and HSBC USA Inc. Michael will 
assume executive responsibility for the 
Group’s Canadian and Latin American 
businesses, in addition to his existing 
responsibilities in relation to the US. 
His expanded role as CEO, US and 
Americas will take effect from April 
2021. Previously, he spent 33 years  
at Citigroup in a number of senior 
leadership roles, most recently as 
Global Head of Corporate Banking  
and Capital Management and Chief 
Lending Officer of Citibank N.A. 

John David Stuart  
(known as Ian Stuart) (57) 
Chief Executive Officer,  
HSBC UK Bank plc

Ian has been Chief Executive Officer  
of HSBC UK Bank plc since April 2017 
and has worked in financial services 
for over four decades. He joined HSBC 
as Head of Commercial Banking 
Europe in 2014, having previously led 
the corporate and business banking 
businesses at Barclays and NatWest. 
He started his career at Bank of 
Scotland. Ian is a business 
ambassador for Meningitis Now  
and a member of the Economic  
Crime Strategic Board.

Peter Wong (69) 
Deputy Chairman and  
Chief Executive Officer,  
The Hongkong and Shanghai 
Banking Corporation Limited

Peter joined HSBC in 2005 and is 
Chairman and non-executive Director 
of HSBC Bank (China) Company 
Limited, and a non-executive Director 
of Hang Seng Bank Limited. Other 
appointments include Council Member 
of Hong Kong Trade Development 
Council, a member of its Belt and Road 
Committee; and Chairman of the Hong 
Kong General Chamber of Commerce.

Barry joined HSBC in April 2017 and 
was appointed Chief Executive of 
Global Commercial Banking in 
February 2020, having served in the 
role on an interim basis since August 
2019. He was previously Chief 
Operating Officer for Global 
Commercial Banking. Prior to joining 
HSBC, Barry worked at GE Capital for 
19 years in a number of senior 
leadership roles, including as CEO,  
GE Capital International and in CEO 
positions in Italy, France and the UK.

Additional members of the  
Group Executive Committee

Noel Quinn

Ewen Stevenson

Aileen Taylor

Biographies are provided on pages 
198 and 201.

203

Corporate governanceHSBC Holdings plc Annual Report and Accounts 2020 
 
Report of the Directors | Corporate governance report

How we are governed

We are committed to high standards of corporate governance. The 
Group has a comprehensive range of policies and procedures in 
place designed to ensure that it is well managed, with effective 
oversight and controls. We comply with the provisions of the UK 
Corporate Governance Code and the applicable requirements of 
the Hong Kong Corporate Governance Code. 

Board’s role, Directors’ responsibilities and 
attendance  

The Board, led by the Group Chairman, is responsible among other 
matters for:

• promoting the Group’s long-term success and delivering 

sustainable value to shareholders;

• establishing and approving the Group’s strategy and objectives 
and monitoring the alignment of the Group’s purpose, strategy 
and values with the desired culture;

Group. For further details of how the Board engages with the 
workforce, see page 210.

How Board governance was adapted for Covid-19

The Board oversaw the implementation of various governance 
changes introduced in response to the Covid-19 outbreak. Board 
and committee agendas were tailored to focus on key priorities 
taking into account the need to hold most meetings via 
videoconference. The challenges that arose from communicating 
across three time zones were navigated by remaining agile in 
meeting arrangements and through increased frequency of 
communications during the year.  
In addition to substantially increasing the frequency of Board and 
executive committee meetings, the following changes were 
implemented to improve connectivity, and provide an 
understanding of the challenges and priorities of the 
management team as it led the organisation through the crisis:
• The Group Chairman introduced a weekly Board update note.
• Management produced a weekly Board report on its response 

• setting the Group’s risk appetite and monitoring the Group’s 

to the Covid-19 outbreak.

risk profile; 

• approving and monitoring capital and operating plans for 

achieving strategic objectives; and

• approving material transactions.

The Board's terms of reference are available on our website at 
www.hsbc.com/who-we-are/leadership-and-governance/board-
responsibilities.

The Board's powers are subject to relevant laws, regulations and 
HSBC’s articles of association.

The role of the independent non-executive Directors is to support 
the development of proposals on strategy, hold management to 
account and ensure the executive Directors are discharging their 
responsibilities properly, while creating the right culture to 
encourage constructive challenge. Non-executive Directors also 
review the performance of management in meeting agreed goals 
and objectives. The Group Chairman meets with the non-executive 
Directors without the executive Directors in attendance after 
Board meetings and otherwise, as necessary. 

The roles of Group Chairman and Group Chief Executive are 
separate. There is a clear division of responsibilities between the 
leadership of the Board by the Group Chairman, and the executive 
responsibility for day-to-day management of HSBC’s business, 
which is undertaken by the Group Chief Executive. 

The majority of Board members are independent non-executive 
Directors. At 31 December 2020, the Board comprised the Group 
Chairman, 11 non-executive Directors, and two executive 
Directors who are the Group Chief Executive and the Group Chief 
Financial Officer. With effect from 1 January 2020, the role of the 
Group Chief Risk Officer ceased to be a member of the Board. 

For further details of the Board’s career background, skills, 
experience and external appointments, see pages 198 to 201.

Operation of the Board 

The Board is ordinarily scheduled to meet at least seven times a 
year. In 2020, due to the Covid-19 outbreak, the Board held 17 
meetings. The Board agenda is agreed by the Group Chairman, 
working with the Group Company Secretary and Chief Governance 
Officer and the Group Chief Executive. For more information, see 
the section on 'Board activities during 2020' on page 209.

The Group Chief Risk Officer and Group Chief Legal Officer are 
regular attendees at Board meetings, and other senior executives 
attend as required.

Outside of Board meetings, the Board Oversight Sub-Group, 
established by the Group Chairman, meets in advance of each 
Board meeting as an informal mechanism for a smaller group of 
Board members and management to discuss emerging issues. 
This group provides regular opportunities for members of the 
Board to communicate with senior management to deepen 
understanding of, and provide input into, key issues facing the 

204 HSBC Holdings plc Annual Report and Accounts 2020

• A Board Oversight Sub-Group was set up to provide guidance 

to the executive team on emerging issues.

• The chairs of our principal subsidiaries and the chairs of the 
Group's Board committees attended the Group Chairman’s 
Forum each month.

Technology governance

In light of the increasingly significant role of technology in the 
Group’s strategy, operations and growth prospects, in January 
2021 the Board approved the establishment of a Technology 
Governance Working Group for a period of 12 months.
The working group has been tasked with developing 
recommendations to strengthen the Board’s oversight of 
technology strategy, governance and emerging risks and 
enhance connectivity with the principal subsidiaries.
The working group will be jointly chaired by Eileen Murray and 
Steven Guggenheimer, given their expertise and experience in 
this area. Jackson Tai, the Group Risk Committee Chair, will be a 
member, along with other non-executive Directors to be 
nominated by each of our US, UK, European and Asian principal 
subsidiaries. The co-Chairs will each receive fees in respect of 
their leadership of the working group over the next 12 months. 
Details of these fees can be found on page 238.
Key IT and business staff will attend the Technology Governance 
Working Group to provide insights on key technology issues 
across the Group allowing the working group to make 
recommendations for enhanced Board oversight of technology.
The total time commitment expected of the co-chairs will be up 
to 30 days, reflective of the complexity and profile of the subject 
matter.

Board engagement with shareholders

In 2020, the Group Chairman, Senior Independent Director and 
the Group Company Secretary and Chief Governance Officer 
engaged with a number of our large institutional investors in over 
20 meetings, primarily ahead of the 2020 AGM. Topics that were 
raised included geopolitical tensions, primarily relating to Hong 
Kong, mainland China, the US and the UK, as well as Board 
composition, changes to the Group Executive Committee, our 
climate policy and the impact of the Covid-19 outbreak on the 
Group, its employees, customers and communities. 
The Group Remuneration Committee Chair also engaged with 
key investors and proxy advisory firms on our remuneration 
approach in respect of the 2020 performance year. During such 
engagements, the Group Remuneration Committee Chair kept 
investors informed on other matters including the Group’s 
response to the Covid-19 outbreak and the Group Chief 
Executive's and Group Chief Financial Officer's salary sacrifice 
and charitable donations.

 
 
 
Board roles, responsibilities and attendance

At 31 December 2020, the Board comprised the Group Chairman, 11 non-executive Directors and two executive Directors. The table 
below sets out their roles, responsibilities and attendance at Board meetings. For a full description of responsibilities see 
www.hsbc.com/who-we-are/leadership-and-governance/board-responsibilities.

Roles

Group Chairman
Mark E Tucker1,2

Executive Director
Group Chief Executive
Noel Quinn2

Executive Director
Chief Financial Officer
Ewen Stevenson2

Board 
attendance 
in 2020

Responsibilities

17/17

• Provides effective leadership of the Board and promotes the highest standards of corporate governance 

practices.

• Leads the Board in providing strong strategic oversight and setting the Board’s agenda, culture and 

values.

• Leads the Board in challenging management’s thinking and proposals, and foster open and constructive 

debate among Directors.

• Maintains external relationships with key stakeholders and communicates investors' views to the Board.
• Evaluates the performance of the Board, Committees, non-executive Directors and Group Chief 

Executive.

17/17

• Leads and directs the implementation of the Group’s business strategy, embedding the organisation’s 

culture and values.

• Leads the Group Executive Committee with responsibility for the day-to-day operations of the Group, 

under authority delegated to him from the Board.

• Maintains relationships with key stakeholders including the Group Chairman and the Board.

17/17

• Supports the Group Chief Executive in developing and implementing the Group strategy and 

recommends the annual budget and long-term strategic and financial plan.

17/17

17/17

17/17

12/12

12/12

17/17

17/17

16/17

5/7

17/17

17/17

5/5

2/2

Non-executive Directors
Senior Independent 
Director
David Nish2,3

Laura Cha3

Henri de Castries3

James Forese3

Steven Guggenheimer3

Irene Lee3

Dr José Antonio Meade 
Kuribreña3

Heidi Miller3,4

Eileen Murray3,4

Jackson Tai3

Pauline van der Meer Mohr3

Kathleen Casey3

Sir Jonathan Symonds3

Group Company Secretary 
and Chief Governance 
Officer
Aileen Taylor

• Leads the Finance function and is responsible for effective financial reporting, including the 

effectiveness of the processes and controls, to ensure the financial control framework is robust and fit 
for purpose.

• Maintains relationships with key stakeholders including shareholders.

• Supports the Group Chairman, acting as intermediary for non-executive Directors when necessary.
• Leads the non-executive Directors in the oversight of the Group Chairman, supporting the clear division 

of responsibility between the Group Chairman and the Group Chief Executive.

• Listens to shareholders' views if they have concerns that cannot be resolved through the normal 

channels.

• Develop and approve the Group strategy.
• Challenge and oversee the performance of management.
• Approve the Group’s risk appetite and review risk profile and performance.

• Maintains strong and consistent governance practices at Board level and throughout the Group.
• Supports the Group Chairman in ensuring effective functioning of the Board and its committees, and 

transparent engagement between senior management and non-executive Directors.

• Facilitates induction and professional development of non-executive Directors.
• Advises and supports the Board and management in ensuring effective end-to-end governance and 

decision making across the Group.

1  The non-executive Group Chairman was considered to be independent on appointment.
2  Mark Tucker, David Nish, Noel Quinn and Ewen Stevenson attended the AGM on 24 April 2020. As a consequence of the UK Government's 
Covid-19 guidance and prohibitions at the time of the AGM, only a limited number of Directors and essential personnel attended the AGM to 
ensure a quorum was present and to conduct the business of the meeting. 
Independent non-executive Director. All of the non-executive Directors are considered to be independent of HSBC. There are no relationships or 
circumstances that are likely to affect any individual non-executive Director’s judgement. All non-executive Directors have confirmed their 
independence during the year. Kathleen Casey and Sir Jonathan Symonds retired from the Board on 24 April 2020 and 18 February 2020 
respectively.

3 

4  Eileen Murray was unable to attend two Board meetings owing to prior commitments made before her appointment to the Board. Heidi Miller 

was unable to attend one Board meeting that was arranged at short notice owing to a pre-scheduled external commitment.

HSBC Holdings plc Annual Report and Accounts 2020 205

Corporate governance 
Report of the Directors | Corporate governance report

Board induction and training

The Group Company Secretary and Chief Governance Officer 
works with the Group Chairman to oversee appropriate induction 
and ongoing training programmes for the Board. On appointment, 
new Board members are provided with tailored, comprehensive 
induction programmes to fit with their individual experiences and 
needs, including the process for dealing with conflicts.  

The structure of the induction allows a Board member to 
contribute meaningfully from appointment. An early focus on 
induction supports good information flows within the Board and 
its committees and between senior management and non-
executive Directors, providing a better understanding of our 
culture and way of operating. During 2020 we welcomed three 
new non-executive Directors to our Board and also facilitated the 
Group Chief Executive’s induction. For illustrations of the typical 
induction modules, see the 'Directors' induction and ongoing 
development in 2020' table on the following page. 

Although there were constraints due to the Covid-19 outbreak, 
virtual meetings enabled our new non-executive Directors to 
engage with colleagues and key external personnel in a shorter 
time period than would have been the case if meeting in person.

When it is safe to recommence Board travel to our global 
locations, we will take opportunities to facilitate comprehensive 
face-to-face engagement. These opportunities provide invaluable 
insight and understanding of our business, customers, culture and 
people. 

Directors undertook routine training during 2020. They also 
participated in 'deep dive' sessions into specific areas of the 
Group’s strategic priorities, risk appetite and approach to 
managing certain risks. These focused on areas such as: 

technology and Cloud capability; climate change; financial crime; 
shareholder activism; and business and governance. External 
consultants, in conjunction with the Group Company Secretary 
and Chief Governance Officer, provided specific training to 
members of relevant boards and executive committees within 
scope for the Senior Managers and Certification Regime. This 
included practical examples of responsibility in decision making 
and discussion of relevant case studies. 

In addition, non-executive Directors discussed individual 
development areas with the Group Chairman during performance 
reviews and in conversations with the Group Company Secretary 
and Chief Governance Officer. The Group Company Secretary and 
Chief Governance Officer makes appropriate arrangements for any 
additional training needs identified using internal resources, or 
otherwise, at HSBC’s expense.

Between the induction and training programmes, the Directors’ 
understandings of key matters and risks for the business are 
supported so that they provide effective, informed and insightful 
challenge in their leadership and oversight roles.

Members of Board committees receive relevant training as 
appropriate. Directors may take independent professional advice 
at HSBC’s expense.

Board Directors who serve on principal subsidiary boards also 
receive training relevant to those boards. Opportunities exist for 
the principal subsidiary and principal subsidiary committee chairs 
to share their understanding in specific areas with the Board 
Directors.

'I was impressed with the smooth and thorough management 
of my induction at a time when the Covid-19 outbreak was 
otherwise creating confusion and uncertainty. 
Shifting quickly to a remote, video-enabled process allowed 
me to be introduced to other Board members and to meet a 
wide range of senior executives from across the global 
businesses, regions and functions in quick succession.
Conversations with management were informative and 
comprehensive. 
Where I had questions or wanted further conversations, the 
team responded swiftly and engaged in additional sessions as 
requested. Despite the lack of the usual in-person induction 
meetings, the open culture at HSBC helped me to come up 
the learning curve quickly and made me feel immediately 
welcomed.'

James Forese 
Non-executive Director

206 HSBC Holdings plc Annual Report and Accounts 2020

 
Directors’ induction and ongoing development in 2020

Director

Induction1

Kathleen Casey

Laura Cha

Henri de Castries

James Forese

Steven 
Guggenheimer

Irene Lee

José Antonio 
Meade Kuribreña

Heidi Miller

Eileen Murray

David Nish

Noel Quinn

Ewen Stevenson

Jackson Tai

Mark Tucker

Pauline van der 
Meer Mohr

ô
ô
ô
l

l

ô

ô

ô
l
ô
l
ô
ô

ô

ô

Strategy and 
business 
briefings2
l
l
l
l

Risk and
control3
l
l
l
l

Corporate 
governance4
l
l
l
l

Global mandatory 
training5
l
l
l
l

ARCC, Chairs and 
Remco Forum
l
l
ô
ô

l

l

l

l
l
l
ô
l
l
l

l

l

l

l

l
l
l
l
l
l
l

l

l

l

l

l
l
l
l
l
l
l

l

l

l

l

l
l
l
l
l
l
l

l

ô

l

l

l
ô
l
l
l
l
l

l

Subsidiary

ô
l
ô
ô

ô

l

ô

l
ô
ô
ô
ô
ô

ô

ô

1  The induction programme is delivered through formal briefings and introductory sessions with Board members, senior management, treasury 

executives, legal counsel, auditors, brokers, tax advisers and regulators. Topics covered included: values, culture and leadership; governance and 
stakeholder management; Directors’ legal and regulatory duties; anti-money laundering and anti-bribery; technical and business briefings; and 
strategy.

2  Directors participated in business strategy, market development and business briefings, which are global, regional and/or market-specific. 

Examples of specific sessions held in 2020 included 'Asia growth: build and strengthen in Hong Kong' and 'Strategic priority: growth of UK ring-
fenced bank'. 

3  Directors received risk and control training. Examples of specific sessions held in 2020 included 'Governance of climate-related risk', 'Wholesale 

and retail credit risk management', 'Forward-looking financial crime risk issues', ’Resolvability assessment framework’ and ‘Technology 
terminology’.

4  All Directors received corporate governance training including ‘Senior Managers and Certification Regime’ and ‘Climate and sustainable finance’.
5  Global mandatory training, issued to all Directors, mirrored training undertaken by all employees, including senior management. These included 
management of risk under the enterprise risk management framework, with a focus on operational risk; cyber risk and fraud; health, safety and 
well-being; data privacy and the protection of data of our customers and colleagues; combating financial crime, including understanding money 
laundering, sanctions, and bribery and corruption risks; and our values and conduct, including workplace harassment and speaking up.

Board committees

The Board delegates oversight of certain audit, risk, remuneration, 
nomination and governance matters to its committees. Each 
standing Board committee is chaired by a non-executive Board 
member and has a remit to cover specific topics in accordance 
with their respective terms of reference. Only independent non-
executive Directors are members of Board committees. Details of 
the work carried out by each of the Board committees can be 
found in the respective committee reports from page 213.

In addition, the Chairman’s Committee is convened to provide 
flexibility for the Board to consider ad hoc Board and routine 
matters between scheduled Board meetings. It meets with 
attendees determined by the nature of the proposed business to 
be discussed.

Board

Chairman’s
Committee

Group Audit 
Committee

Group Risk 
Committee

Group 
Remuneration 
Committee

Nomination & 
Corporate 
Governance 
Committee

HSBC Holdings plc Annual Report and Accounts 2020 207

Corporate governanceTo strengthen accountability and information flow, each principal 
subsidiary takes responsibility for the oversight of Group 
companies in its region through the subsidiary accountability 
framework. The guidance underpinning the framework principles 
defines how we escalate and cascade information and procedures 
between the Board, the principal subsidiary boards and their 
respective committees.

During 2020, a subsidiary governance review was undertaken by 
the Group Company Secretary and Chief Governance Officer to 
consider the application of the framework by the principal 
subsidiaries and certain material subsidiaries. This resulted in 
recommended changes to both the subsidiary accountability 
framework principles and their application. All relevant boards will 
consider and implement any recommendations and actions arising 
out of this review over the course of 2021. For further details of 
the subsidiary governance review, see the Nomination & 
Corporate Governance Committee report on page 213.  

The Group Chairman interacts regularly with the chairs of the 
principal subsidiaries, including through the Chairman’s Forum, 
which brings together the chairs of the principal subsidiaries and 
the chairs of the Group's audit, risk and remuneration committees 
to discuss Group-wide and regional matters. From March 2020, 
these meetings moved from twice a year to monthly, in response 
to the complex and dynamic environment. The Group Chairman 
hosted nine Chairman’s Forums, which were also attended by 
relevant executive management, to cover sessions on strategy, the 
economy, regulatory matters, cyber risk and resilience, 
implementation of the subsidiary accountability framework and 
corporate governance.

The chairs of each of the Group Audit Committee, Group Risk 
Committee and Group Remuneration Committee also have regular 
dialogues with the respective committees of the principal 
subsidiaries to ensure an awareness and coordinated approach to 
key issues. These interactions are reinforced through Audit and 
Risk Committee Chairs' Forums, and the Remuneration Committee 
Chairs' Forum, which are held several times a year. The chairs of 
the principal subsidiaries’ committees are invited to attend the 
relevant forums to raise and discuss current and future global 
issues, including regulatory priorities in each of the regions. 

Board members attend principal subsidiary meetings as guests 
from time to time. Similarly, principal subsidiary directors are 
invited to attend committee meetings at Group level, where 
relevant.

Report of the Directors | Corporate governance report

Relationship between Board and senior management 

The Board delegates day-to-day management of the business and 
implementation of strategy to the Group Chief Executive. The 
Group Chief Executive is supported in his day-to-day management 
of the Group by recommendations and advice from the Group 
Executive Committee ('GEC'), an executive forum that he chairs 
comprising members of senior management.

The Directors are encouraged to have free and open contact with 
management at all levels and full access to all relevant 
information. Non-executive Directors are encouraged to visit local 
business operations and meet local management when they 
attend off-site Board meetings and when travelling for other 
reasons, although this was not possible during 2020 due to the 
Covid-19 outbreak.

Executive governance
The Group’s executive governance is underpinned by the Group 
operating rhythm, which sets out the Board and executive 
engagement schedule. This was refreshed for 2020 to facilitate 
end-to-end governance flowing up from executive governance to 
the Board. 
The Group operating rhythm is characterised by three pillars: 
i. The GEC normally meets every week to discuss current and
emerging issues. However, during 2020 it met much more
frequently as a result of Covid-19.

ii. On a monthly basis, the GEC reviews the performance of
global businesses, principal geographical areas and legal
entities. These performance reviews are supplemented by
quarterly performance management review meetings
between the Group Chief Executive and the Group Chief
Financial Officer and each of the chief executive officers of
the global businesses, principal geographical areas and legal
entities on an individual basis.

iii. The GEC holds a strategy and governance meeting two weeks

in advance of each Board meeting.

Separate committees have been established to provide specialist 
oversight for matters delegated to the Group Chief Executive and 
senior management, in keeping with their responsibilities under 
the Senior Managers and Certification Regime. Some of these 
separate committees are dedicated sub-committees of the GEC, 
and some operate under individual accountability. These 
committees support the Group Chief Executive and GEC 
members in areas such as capital and liquidity, risk management, 
disclosure and financial reporting, restructuring and investment 
considerations, transformation programmes, people issues, 
diversity and inclusion, and talent and development. 
In addition to our regional company secretaries supporting our 
principal subsidiaries, we have corporate governance officers 
supporting our global lines of business, digital business services 
and our larger global functions to assist in effective end-to-end 
governance, consistency and connectivity across the Group.

Subsidiary governance

Subsidiaries are formally designated as principal subsidiaries by 
approval of the Board.  

The designated principal subsidiaries are:

Principal subsidiary

Oversight responsibility

The Hongkong and Shanghai 
Banking Corporation Limited
HSBC Bank plc

HSBC UK Bank plc

HSBC Middle East Holdings BV

HSBC North America Holdings Inc.

HSBC Latin America Holdings (UK) 
Limited
HSBC Bank Canada

Asia-Pacific

Europe, Bermuda (excluding 
Switzerland and UK ring-fenced 
activities)
UK ring-fenced bank and its 
subsidiaries
Middle East

US

Mexico and Latin America

Canada

208 HSBC Holdings plc Annual Report and Accounts 2020

Board activities during 2020

During 2020, the Board focused on resetting the strategic 
direction, supporting the Group Chief Executive and overseeing 
performance and risk. It considered performance against financial 
and other strategic objectives, key business challenges, emerging 
risks, business development, investor relations and the Group’s 
relationships with its stakeholders. The end-to-end governance 
framework facilitated discussion on strategy and performance by 
each of the global businesses and across the principal 
geographical areas, which enabled the Board to support executive 
management with its delivery of the Group’s strategy. 

The Board's key areas of focus in 2020 are set out by theme 
below.

Strategy and business performance

In February 2020, the Group’s strategic review and associated 
transformation programme was announced. This aimed to reshape 
underperforming businesses, simplify the organisation and reduce 
costs, to position the Group to increase returns for investors, 
create capacity for future investment and build a sustainable 
platform for growth.

In contrast to 2019 when the Board held two dedicated strategy 
sessions, given the evolving external landscape during 2020, the 
Board engaged in ongoing dialogue with management throughout 
the year to progress development of the Group strategy. As part of 
the strategy review, the Board considered organic and inorganic 
opportunities to grow and restructure the business, as well as 
disposal options.

The Board announced its new climate statement with the Group's 
ambition to align financed emissions to net zero by 2050 and 
become net zero for its own operations and supply chain by 2030, 
its aim to support clients on the road to a net zero carbon 
economy and a focus on sustainable finance opportunities. For 
further details of our new climate ambitions, see page 44.

The Board received external insights on topics such as the 
economic implications of the Covid-19 outbreak and ongoing 
geopolitical issues at regular intervals throughout the year.

Financial decisions

The Board approved key financial decisions throughout the year 
and approved the Annual Report and Accounts 2019, the Interim 
Report 2020 and the first quarter and the third quarter Earnings 
Releases.

The Board approved the annual operating plan for 2020 at the start 
of 2020 and since 31 December 2020 has approved the annual 
operating plan for 2021. The Board monitored the Group's 
performance against the approved 2020 annual operating plan, as 
well as the operating plans of each of the global businesses. The 
Board also approved the renewal of the debt issuance programme.

On 31 March 2020, HSBC announced that, in response to a 
written request from the Bank of England through the UK's 
Prudential Regulation Authority ('PRA'), the Board had cancelled 
the fourth interim dividend for 2019. Similar requests were also 
made to other UK incorporated banking groups. We also 
announced that until the end of 2020 we would make no quarterly 
or interim dividend payments or accruals in respect of ordinary 
shares. For further details of the dividend cancellation, see page 
256 and our section 172 statement on page 22.

In December 2020, the PRA announced a temporary approach to 
shareholder distributions for 2020 in which it set out a framework 
for Board decisions on dividends. After considering the 
requirements of the temporary approach, on 23 February 2021 the 
Board announced an interim dividend for 2020 of $0.15 per 
ordinary share.

The Board has adopted a policy designed to provide sustainable 
dividends going forward. We intend to transition towards a target 
payout ratio of between 40% and 55% of reported earnings per 
ordinary share (‘EPS’) for 2022 onwards, with the flexibility to 
adjust EPS for non-cash significant items such as goodwill or 
intangibles impairments. The Board believes this payout ratio 

approach will allow for a good level of income to shareholders and 
a progressive dividend, assuming good levels of economic and 
earnings growth.

The Group will not be paying quarterly dividends during 2021 but 
will consider whether to announce an interim dividend at the 2021 
half-year results in August. The Group will review whether to 
revert to paying quarterly dividends at or ahead of its 2021 results 
announcement in February 2022. The 2020 interim dividend will be 
paid in cash with no scrip alternative. The Group has decided to 
discontinue the scrip dividend option as it is dilutive, including to 
dividend per share progression over time.

The dividend policy could be supplemented by buy-backs or 
special dividends, over time and not in the near term, should the 
Group find itself in an excess capital position absent compelling 
investment opportunities to deploy that excess.

Risk, regulatory and legal considerations

The Board, advised by the Group Risk Committee, promotes a 
strong risk governance culture that shapes the Group’s risk 
appetite and supports the maintenance of a strong risk 
management framework, giving consideration to the 
measurement, evaluation, acceptance and management of risks, 
including emerging risks.

The Board considered the Group’s approach to risk including its 
regulatory obligations. A number of key frameworks, control 
documents, core processes and legal responsibilities were also 
reviewed and approved as required. These included:

• the Group's risk appetite framework and risk appetite

statement;

• the individual liquidity adequacy assessment process;

• the individual capital adequacy assessment process;

• the Group’s obligations under the Modern Slavery Act and

approval of the Modern Slavery Act statement;

• stress testing and capabilities required to meet the PRA’s

resolvability assessment framework;

• the revised terms of reference for the Board and Board

committees; and

• delegations of authority.

The Board also reviewed and monitored the implications of 
geopolitical developments during the year including US-China 
relations and the trade talks between the UK and the EU following 
the UK's departure, including no-deal contingency planning.

Technology

Throughout the year, the Board received regular updates on 
technology from the Group Chief Operating Officer, including the 
refreshed technology strategy and restructuring of the technology 
leadership function.

The newly appointed non-executive Directors with deep 
technology experience have worked in collaboration with the 
Group Chief Operating Officer to enhance the governance of 
technology.

The Board received technology training and educational sessions 
from both internal and external subject matter experts to 
understand further the evolving technology landscape.

People and culture

The Board continued to spend time discussing people and culture-
related topics. The Group Chief Executive led discussions on the 
development of a new people strategy to support the Group’s 
growth and transformation.

During the year, the Board shaped the revision of the Group's 
purpose and values statement, which was approved in December 
2020. A sub-group of the Board was created to assist the process. 
It met regularly with management to provide support, guidance 
and constructive challenge, seeking to ensure the revised purpose 
and values remained aligned with the Group's culture and future 
strategy. For further details of how stakeholder engagement was 

HSBC Holdings plc Annual Report and Accounts 2020 209

Corporate governanceReport of the Directors | Corporate governance report

used by the Board in setting the revised purpose and values, see 
the section 172 statement on page 22.

Governance

The Board continued to oversee the governance, smooth operation 
and oversight of the Group and its principal and material 
subsidiaries. During 2020, it undertook a review of subsidiary 
governance. For further details of the review and subsequent 
actions, see page 208.

Succession planning was considered by the Board following a 
thorough review at the Nomination & Corporate Governance 
Committee. During the year, Kathleen Casey retired as 
independent non-executive Director and Sir Jonathan Symonds 
retired as Deputy Group Chairman, Senior Independent Director 
and the Chair of the Group Audit Committee. The Board appointed 
David Nish in the role of Senior Independent Director and Chair of 
the Group Audit Committee, and appointed James Forese, Steven 
Guggenheimer and Eileen Murray as independent non-executive 
Directors. The Board, supported by the Nomination & Corporate 
Governance Committee, will continue to review the skills and 
experience of the Board as a whole to ensure that it comprises the 
relevant skills, experiences and competencies to discharge its 
responsibilities effectively.

For further details of the changes to the Board, see the 
Nomination & Corporate Governance Committee report on page 
213.

The Board monitored its compliance with the UK Corporate 
Governance Code and the Companies Act 2006 throughout the 
year.

Workforce engagement
The Board reaffirmed, in accordance with the UK Corporate 
Governance Code, that it would use ‘alternative arrangements’ in 
approaching workforce engagement. This flexible method 
allowed all non-executive Directors to have direct engagement 
across a wide network of employees in multiple geographies. 
The virtual working environment during the Covid-19 outbreak 
enabled more employees to participate in various workforce 
engagement activities. The programme of activities used a 
variety of interaction styles: more bespoke sessions with smaller 
groups; formal presentations; Q&A opportunities; and sessions to 
facilitate engagement across a breadth of experience and 
seniority. This enabled open dialogue and two-way discussions 
between non-executive Directors and employees. Non-executive 
Directors met with:
• employees of the innovation teams in Wealth and Personal 
Banking, Commercial Banking and Global Banking and 
Markets where discussions focused on bespoke business-
specific matters;

• representatives of global employee resource groups where 
wide-ranging issues were discussed such as employee 
sentiment;

• leaders and talent from Digital Business Services at an 

employee Exchange session; and

• participants in the Asia talent programme.
The Board received formal updates from the Group Chief 
Executive and the Group Chief Human Resources Officer on 
employee views and sentiment. These include results of 
employee engagement surveys, benchmarked data, and 
additional surveys to understand well-being throughout the 
Covid-19 outbreak. The Chairman’s Forum meetings also 
discussed employee feedback from the Group's subsidiaries.
As the Board considered the Group’s strategy and strategic 
initiatives throughout 2020, themes emerged that directly 
impacted the workforce. These helped shape subsequent 
workforce engagement sessions. These sessions continue to give 
the Board valuable insight on employee perspectives when 
reviewing proposals. For further details of how the Board 
considered the views of employees and other stakeholders, see 
the section 172 statement on page 22. 
The Board looks forward to continuing its workforce engagement 
programme and holding in-person sessions when possible in 
2021.

210 HSBC Holdings plc Annual Report and Accounts 2020

 
Board activities in 2020

Main topic

Sub-topic

Strategy

Group strategy

Regional strategy/Business line strategy

Environmental, social, governance

Business and 
financial 
performance

Region/Business line

Financial performance

Financial

Results and accounts

Dividends

Group annual operating plan

Risk

Risk function

Risk appetite

Regulatory

Capital and liquidity adequacy

Regulatory matters (including resolvability 
assessment framework)

Regulatory matters with regulators in 
attendance2

External

External insights

Technology

Strategic and operational

People and 
culture

Purpose, values and engagement 

Governance

Subsidiary governance framework

Policies and terms of reference

Board/committee effectiveness

Appointment and succession

Meetings at which topics were discussed1

Jan

Feb

Mar

Apr

May

Jun

Jul

Sep

Oct

Nov

Dec

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1  No formal Board meetings were held during August 2020.
2  Meetings attended by members of the Financial Conduct Authority, Prudential Regulation Authority, Monetary Authority of Singapore, Hong Kong 

Monetary Authority.

Board and committee effectiveness, 
performance and accountability 

The Board and its committees are committed to regular, 
independent evaluation of their effectiveness at least once every 
three years.

Following the externally facilitated review of the Board and 
committee effectiveness in 2019, conducted by the external 
service provider Dr Tracy Long of Boardroom Review Limited, the 
Nomination & Corporate Governance Committee again invited Dr 
Long to support the Board with its annual evaluation. She was 
invited to conduct a follow-up review on the Board's progress 
against the findings and recommendations from her 2019 report, 
and more broadly on the effectiveness of the Board's operations. 
Dr Long is independent and has no other connection to the Group 
or any individual Director.

This external review was complemented by a review of the Board 
committees led by the Group Company Secretary and Chief 
Governance Officer. Details of the Board committees’ 
effectiveness reviews, key findings and recommendations can be 
found in the respective committee reports on pages 213 to 232.

Dr Long acknowledged the progress that the Board had made in 
respect of her 2019 recommendations, with her 2020 review again 
focusing on the main themes from the previous review. These 
were: leadership, shared perspective, culture, end-to-end 
governance and future thinking. Qualitative feedback was 
gathered from one-to-one interviews held with members of the 
Board and regular Board attendees. 

At the December Board meeting, the key findings presented were:

• a strong focus on vision, strategy, and balancing short-term 

and long-term objectives; 

• a culture of collegiality and inclusion with positive team 

dynamics and healthy dialogue; 

• an open and transparent communication between the Board 

and management and the boards of the principal subsidiaries, a 
shared perspective on strategy and risk between the Board and 
management, with a focus on clarity of objectives; 

• a clear focus on operational resilience and support for clients, 
continuous Board and employee communications, attention to 
employee well-being, and documented lessons learned; 

• a clear focus on priorities, with sessions on current and 

dynamic topics as required; and 

• a strong link between culture and remuneration. 

Following Dr Long’s final report, the Group Chairman led a Board 
discussion in January 2021, at which the Board agreed the actions 
and priorities to be implemented, which will be monitored and 
addressed on an ongoing basis. Progress against these actions will 
be included in the Annual Report and Accounts 2021.

The following table outlines the main findings from the 2019 and 
2020 reviews, progress against the 2019 findings and the actions 
agreed by the Board to address the areas that were identified as 
requiring improvement.

During 2020, a review of the Group Chairman’s performance was 
led by the Senior Independent Director in consultation with the 
other independent non-executive Directors. Non-executive 
Directors also undergo regular individual reviews with the Group 
Chairman. The reviews confirmed that the Group Chairman and 
each Director were effective and had met their time commitments 
during the year.

The review of executive Directors’ performance, which helps 
determine the level of variable pay they receive each year, is 
contained in the Directors’ remuneration report on page 240.

HSBC Holdings plc Annual Report and Accounts 2020 211

Corporate governance 
Report of the Directors | Corporate governance report

Summary of Board effectiveness recommendations and actions:

Leadership

Recommendation from the 2019 and 2020 
evaluations
2019
• Continue to provide strong leadership 
through a culture of collaboration, 
transparency, open communication and 
cooperation.

2020
• Continue to focus on Board succession 

planning, building on the progress made 
during 2020 to facilitate and manage 
succession for Board and committee 
positions, cognisant of diversity in all 
aspects and making full use of external 
advisers and skills matrix analysis.
• Embed executive succession so that it 

translates into a stronger, more diversified 
talent pool for future senior leadership.

Progress against 2019 
recommendations
The Group Chairman enhanced his 
communication activities with the Board 
and executive management during 2020. 
Following the appointment of the new 
Group Chief Executive, the Group 
Chairman established a Board Oversight 
Sub-Group to engage further with 
management and provide a sounding 
board.

Agreed actions for 2020 
recommendations
The Nomination & Corporate Governance 
Committee will allocate additional time 
for discussion and debate of external 
candidates for non-executive Director 
succession and the internal and external 
talent pool for senior management roles 
including executive Directors.

Shared 
perspective

2019
• Build on the shared perspective by ensuring 
that the Board agenda allows sufficient 
time and visibility of longer-term strategic 
perspectives aligned to its appetite for 
business risk.

The Board adapted the Group operating 
rhythm and increased the frequency of 
meetings throughout the Covid-19 
outbreak to provide the opportunity to 
reflect and act in real-time on the 
evolving external factors.

The Board will continue to enhance the 
use of governance practices, such as the 
Board Oversight Sub-Group and the 
Group operating rhythm. It will also 
continue to use Board committees to 
underpin and deliver effective decision 
making.

2020
• Optimise use of Board information to 

enhance testing of the effectiveness of the 
strategic and business plans with reference 
to the evolving external factors and 
competitive landscape across its key 
markets.

2019
• Reflecting the improvement in corporate 
culture, keep culture on the agenda to 
ensure ongoing transparency and 
escalation of issues. Maintain visibility and 
insight into cultural initiatives and 
differences across global businesses.

2020
• Continue to review and determine the 
culture and key behaviours required to 
support the delivery of the revised strategy 
with a clear focus on pace and execution.

2019
• Maintain focus on improving the quality of 
information and increased communication 
channels with subsidiaries and other 
stakeholders, including the voice of 
employees.

Culture

End-to-end 
governance

Future thinking

2019
• Continue to develop the Board agenda to 

provide focus on emerging issues.

2020
• Maintain and evolve good quality papers 

and presentations to the Board to continue 
providing insight and supporting informed 
decision making.

Alongside the strategic review, the Board 
oversaw work on refreshing the Group’s 
purpose and values, driving a resetting of 
the culture to deliver the strategy.

The Group Chairman and Group Chief 
Executive will monitor progress of 
strategic decision making at pace. 
Increased insight into organisational 
cultural indicators provided to the Board 
will support delivering the desired 
organisational culture in line with 
strategy, purpose and values.

Communications with the principal 
subsidiary chairs was increased by 
holding monthly Chairman’s Forums for 
most of the year. The Board continued to 
engage with key investors and 
regulators, with some of the key 
regulators attending a session with the 
Board. There were additional 
opportunities for employees to engage 
throughout the year given the extreme 
circumstances brought about by the 
Covid-19 outbreak.

The Group Chairman, Group Chief 
Executive and Group Company Secretary 
and Chief Governance Officer met 
regularly throughout the year to plan 
Board meeting agendas to focus more 
effectively on emerging matters and 
external developments.

The Group Chairman and Group Chief 
Executive will sponsor a project to review 
Board reporting in 2021.

212 HSBC Holdings plc Annual Report and Accounts 2020

 
Board committees

Membership

Nomination & Corporate Governance Committee 

Member since

Meeting attendance in 
2020

Mark Tucker (Chair)

Kathleen Casey1

Laura Cha

Henri de Castries

James Forese

Steven Guggenheimer

Irene Lee

José Antonio Meade 
Kuribreña

Eileen Murray2 

Heidi Miller

David Nish

Jackson Tai

Pauline van der Meer Mohr

Sir Jonathan Symonds1

Oct 2017

Apr 2018

May 2014

Apr 2018

May 2020

May 2020

Apr 2018

Apr 2019

Jul 2020

Apr 2018

Apr 2018

Apr 2018

Apr 2016

Apr 2017

9/9

4/4

9/9

9/9

5/5

5/5

9/9

9/9

3/4

9/9

9/9

9/9

9/9

3/3

1  Sir Jonathan Symonds stepped down from the Board on 18 February 
2020. Kathleen Casey stepped down from the Board on 24 April 
2020. 

2  Eileen Murray was unable to attend one Committee meeting owing 
to a prior commitment made before her appointment to the Board 

Group Chief Executive succession

The choice of Group Chief Executive is a matter of significance, 
and it was therefore important that we allowed ourselves the time 
to fully assess our options before arriving at our decision, given 
the potential ramifications on the future success of the Group and 
our stakeholders. 

We conducted a thorough and robust search process with the 
support of an external search partner, Egon Zehnder, to identify 
the new Group Chief Executive. The Committee was delighted to 
have been able to source an internal candidate, in Noel Quinn, and 
believe that we identified the best candidate for the role and for 
the Group. Further information on Noel’s appointment is set out in 
our section 172 statement on page 22. Egon Zehnder provides 
assistance with senior recruitment at HSBC. It has no other 
connection with the Group or members of the Board.

Following Noel’s appointment on a permanent basis in March 
2020, the Committee agreed a comprehensive induction and 
development plan to best support him to succeed in leading the 
Group through the various challenges we face. The Committee 
monitored this throughout the year, and will continue to support 
Noel and his executive team in the delivery of our strategic and 
business priorities. 

Board composition

The composition of both the Board and its Committee continued 
to be a key focus during 2020, with progress made in ensuring 
that the Board possesses the necessary expertise to oversee, 
support and monitor management performance based on the 
longer-term strategy and developments in the external 
environment. 

In James Forese, Steven Guggenheimer and Eileen Murray, the 
Board has added deep experience in the areas of banking, 
technology and operations, which will remain critical to the 
Board’s discussions in the coming years. Further details on skills 
and previous experience are set out in the Board biographies on 
pages 198 to 201.

Russell Reynolds Associates supported the Board in identifying 
prospective non-executive Director candidates. It has also 
supported the Committee and the management team in senior 
executive succession planning, as part of an integrated approach 
to talent identification, assessment and development during 2020. 
Russell Reynolds also assists with senior recruitment at HSBC. 
They have no other connection with the Group or members of the 
Board.  

HSBC Holdings plc Annual Report and Accounts 2020 213

"The Committee's priorities in 2021 will continue to be 
composition, succession and development of the Board, as well as 
efforts to enhance the Group’s diversity, talent and bench strength 
for key executive positions."

Dear Shareholder

It has been a busy year for the Nomination & Corporate 
Governance Committee. This report provides an overview of the 
work of the Committee and its activities during the year.

Priorities during 2020

Succession planning for both the Board and our senior executive 
team remained a critical focus of the Committee in line with its 
responsibilities. In addition to the appointment of Noel as Group 
Chief Executive, we appointed three new independent non-
executive Directors during the year. Details of the appointments 
are set out below.

In line with our strategic focus on Asia, we considered proposals 
from management on ways to improve how we support and 
develop our talent under the Asia talent programme. Asian 
representation on the Board remains of critical importance, given 
the benefits that having members with deep knowledge and 
insight into Asian culture and business practices can bring to our 
discussions as a Board. 

Subsidiary governance has also been an area of focus for the 
Committee, and we have made great progress in this regard 
during the past couple of years. The Subsidiary Governance 
Review, which is summarised later in this report, has 
demonstrated the progress made while acknowledging there is 
more to do to support our ambition of achieving world-class 
governance across the Group.

Focus for 2021

The Committee's priorities in 2021 will continue to be 
composition, succession and development of the Board, as well as 
efforts to enhance the Group’s diversity, talent and bench strength 
for key executive positions. In developing our talent, the 
Committee will continue to focus on the promotion of diverse 
candidates to ensure that the Group Executive Committee and 
other senior management are representative of the customers, 
communities and markets in which we operate. 

As our strategy develops, we know that the skills and capabilities 
we require will evolve and the Committee has a key role to play. 

Mark E Tucker

Chair

Nomination & Corporate Governance Committee

23 February 2021

Corporate governance 
 
Report of the Directors | Corporate governance report

We refreshed our Board skills matrix in recognition of the 
changing context in which the Group is now operating and the 
strategic priorities. The revised skills matrix places greater 
emphasis on the need for competencies in areas such as 
transformation, ESG and climate given the Group’s ambitions in 
these areas. The skills matrix will be a key tool in ensuring that the 
Board has the necessary range of skills and experience to 
discharge its responsibilities, oversee management and respond to 
emerging trends. 

The Board remains committed to increasing its diversity, and 
ensuring that it is reflective of the markets and societies in which 
we serve. 

Board changes

There have been a number of changes to the Board during the 
past year. In addition to the appointment of the three new non-
executive Directors referred to above, in February 2020, we saw 
the departure of both Sir Jonathan Symonds and Kathleen Casey 
during 2020. David Nish was appointed in the role of Senior 
Independent Director and Chair of the Group Audit Committee in 
place of Sir Jonathan Symonds.

Laura Cha will retire from the Board at the conclusion of our 2021 
AGM at the end of May.

As mentioned earlier in the report, Dame Carolyn Fairbairn will join 
the Board on 1 September 2021. We are in the process of 
concluding a search for suitable candidates to join and further 
strengthen the expertise and experience on the Board and its 
committees. 

We have also considered our committee membership and as a 
result confirm that David Nish will step down from the Group 
Remuneration Committee following the publication of the Annual 
Report and Accounts 2020. David kindly agreed to remain a 
member throughout 2020 following his appointment as Senior 
Independent Director and GAC Chair in February 2020 to provide a 
strong link through all committees while new Board members 
were onboarded.

Senior executive succession and development

Following Noel’s appointment as Group Chief Executive on an 
interim basis in August 2019, he took steps to refresh the 
composition of the then Group Management Board and 
repositioned this as the Group Executive Committee. This included 
the appointment of new incumbents for seven roles, meaning that 
we actioned a significant number of our succession plans for our 
most senior executive positions. 

The Committee has therefore focused on rebuilding this bench 
strength during 2020 to ensure that we have a strong cohort of 
potential future leaders of HSBC. We have worked in partnership 
with Noel and our Group Chief Human Resources Officer to 
support an integrated approach to our assessment, development 
and external market benchmarking of executive talent.

The refreshed Group Executive Committee succession plan, which 
we discussed and approved at our meeting in December 2020, 
reflects the changing shape of the Group and involves greater 
diversity, in particular with regard to gender and ethnicity. 

In connection with this, and to ensure we support and develop 
talent from the Group’s key region, the Committee received an 
update on the Asia talent programme. This programme involves 
approximately 1,000 employees of high potential talent in the 
region and aims to support their development and progression 
both within the region and across the broader Group. 

Committee evaluation

The annual review of the effectiveness of the Board committees, 
including the Committee, was internally facilitated for 2020.  

Overall the review concluded that the Committee continued to 
operate effectively. The review made certain recommendations for 
improvement, in particular regarding the time allocated for 
discussion of key items to ensure that the Committee has 
sufficient opportunity to discuss topics such as senior executive 
succession and development in the required depth. The 

214 HSBC Holdings plc Annual Report and Accounts 2020

Committee has considered and discussed the outcomes of the 
evaluation and accepts the findings. 

The outcomes of the evaluation have been reported to the Board 
and the Committee will track progress on the recommendations 
during 2020.

Subsidiary governance review 

Following the implementation of the subsidiary accountability 
framework in 2019, during 2020 the Committee commissioned a 
governance review of the Group’s seven principal subsidiaries, 
plus three material subsidiaries in the form of Hang Seng Bank, 
HSBC Global Asset Management and HSBC Private Bank (Suisse). 

The review was led by our Group Company Secretary and Chief 
Governance Officer and focused on: 

• Board size, skills, tenure and fees;

• governance support; and 

• the relationship between the Group and its subsidiaries. 

Good boardroom practice and adherence to our Group governance 
expectations, including under the subsidiary accountability 
framework, were observed in the course of the review. 

A number of recommendations were identified to raise the 
standard and ensure consistent application of governance across 
the organisation, and to further improve the transparency and 
engagement between the Group and its subsidiaries. These 
included: 

• Subsidiary accountability framework: a review and update to 

the principles under the subsidiary accountability framework to 
clarify and provide greater guidance on the Group’s 
expectations; 

• Board composition, size and independence: clarification of the 

Group’s expectations on the size, composition and 
independence of subsidiary boards and length of board tenure, 
to encourage proactive refreshment of subsidiary board 
membership. A number of our longer-serving subsidiary 
Directors have announced their retirement from the Group as a 
result of this review; and 

• Board reporting and management information: the need for 

greater consistency in the quality of reporting and management 
information, with work underway to ensure that the Board and 
its committees, as well as individuals on subsidiary boards and 
other senior governance forums, receive the information they 
require to make informed decisions.

Given the success and strong support that the review received at 
both Group and subsidiary level, including the Group Executive 
Committee, it has been agreed that a review of our governance 
practices in our global businesses will be undertaken in 2021.

Governance 

Our decision to create the Chief Governance Officer role in 2019 
was in recognition of the significance the Board assigns to the 
governance agenda and the strategic importance of having best-
in-class governance at HSBC, including in the oversight of 
subsidiaries. This role is held by the Group Company Secretary, 
now designated as the Group Company Secretary and Chief 
Governance Officer, reporting to the Group Chairman. 

Despite the challenges we have faced as an organisation from a 
business and geopolitical perspective, we have made good 
progress in enhancing our overall governance arrangements 
during 2020, in particular the areas identified as requiring 
improvement in our 2019 Board effectiveness review. 

This has included our new governance operating rhythm, which 
was established to provide robust end-to-end governance and 
more efficient and effective governance meetings across the 
Board, Group Executive Committee and subsidiaries. The new 
Group operating rhythm has resulted in greater alignment 
between our Board and the Group Executive Committee, and has 
driven the sequencing of meetings to allow for our subsidiaries 
and global business to have input on key matters prior to 
discussion and approval at the Board. This has been particularly 

 
pertinent during 2020, given the central role that our subsidiaries 
hold in developing and executing our strategic priorities.  

In line with the Board’s commitment at the commencement of the 
UK Corporate Governance Code 2018, the Committee reviewed 
the Board’s choice of an alternative mechanism to engage with 
and understand the views of the wider workforce with reference to 
developing market practice. During 2020, the Committee 
confirmed that it remained confident that our preferred 
mechanism of 'alternative arrangements' remained effective and 
believed that this was most appropriate for an organisation of our 
scale and geographical diversity. Engagement with the workforce 
will continue to be a priority for the Board in 2021. Further details 
on the arrangements we have in place to facilitate workforce 
engagement can be found on page 210.

Diversity

The Board diversity policy sets out our approach to achieving our 
diversity ambitions, and helps to ensure that diversity and 
inclusion factors are taken into account in succession planning. 

In line with our ongoing commitment to diversity, we reviewed our 
Board diversity policy during 2020. This review included 
consideration of developments in best practice as well as 
regulatory expectations on board diversity, including those 
outlined by the PRA. 

A number of minor updates were made to the characteristics that 
the Board will take into account when considering candidates for 
future appointment as Directors. These included adding social 
backgrounds to the Board diversity policy as a factor for 
consideration, and making amendments to emphasise the link 
between diversity of thought with risk avoidance and improved 
decision making. The revised Board diversity policy is available at 
www.hsbc.com/who-we-are/leadership-and-governance/board-
responsibilities.

Our recent non-executive Director searches have prioritised 
diversity both in terms of gender and representation from those of 
Asia-Pacific heritage. These have been identified as areas where 
we needed to strengthen in anticipation of retirements from the 
Board in the coming years.

At the year-end, at 35% (five out of 14), our Board gender diversity 
met the Hampton-Alexander Review target of 33% female 
representation by the end of 2020. We have also met and 
exceeded the Parker Review targets of at least one Director from 
an ethnic minority background by 2021, with four members of our 
Board self-identifying as 'Directors of colour' in line with the 
definition set by Parker. 

The Board is also extremely focused on diversity across the wider 
organisation, and believes that this is a critical component of 

HSBC’s future success. Further details on activities to improve 
diversity across senior management and the wider workforce, 
together with representation statistics, can be found on pages 64 
to 65.

Independence of non-executive Directors

The Committee has delegated authority from the Board in relation 
to the assessment of the independence of non-executive Directors. 

In accordance with the UK and Hong Kong Corporate Governance 
Codes, the Committee has reviewed and confirmed that all non-
executive Directors who have submitted themselves for election 
and re-election at the AGM are considered to be independent. This 
conclusion was reached after consideration of all relevant 
circumstances that are likely to impair, or could appear to impair, 
independence.

Laura Cha, who joined the Board in 2011, will not be standing for 
re-election at the 2021 AGM. The Committee determined that 
Laura, notwithstanding her length of service, continues to be 
independent when taking into consideration all other relevant 
circumstances that are likely to impair, or could appear to impair, 
independence and that she will continue to be independent up to 
the date of the 2021 AGM when she will retire from the Board.

The Committee also has oversight of the composition of the 
boards of the Group’s regional principal subsidiaries and approves 
the appointment of Directors and senior management in those 
subsidiaries.

Matters considered during 2020

Board composition and succession

Board composition, including succession planning and skills 
matrices 

Approval of diversity and inclusion policy 

Approval of conflicts of interest policy 
Executive talent and development

Senior executive succession 
Approval of executive succession plans
Talent programmes
Governance 

Board and committee evaluation

Subsidiary governance 
Subsidiary and executive appointments 

Jan

Feb

Apr 

May

Jul

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Appointment process – assessment of new non-executive Directors

Step 1

Step 2

Step 3

Step 4

Step 5

The Committee agreed the 
desired criteria sought in 
the candidates for 
appointment to the Board. 
An external search partner 
was engaged. 

The Committee considered 
a long-list of candidates 
and agreed which should 
be prioritised. Relevant 
candidates were 
approached by the external 
search partner to 
understand their interest. 

Meetings were arranged 
between members of the 
Committee and priority non-
executive Director 
candidates. Feedback from 
the non-executive Directors 
was discussed alongside 
consideration of potential 
conflicts and other matters 
identified through due 
diligence. 

The Committee 
recommended the 
appointment of the non-
executive Director to the 
Holdings Board for 
approval, subject to 
completion of outstanding 
due diligence. 

Outstanding due diligence 
and associated procedures 
completed prior to 
announcement of 
appointment. Director 
onboarding and induction 
pack issued and completed.

HSBC Holdings plc Annual Report and Accounts 2020 215

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Report of the Directors | Corporate governance report

Group Audit Committee

Membership

David Nish (Chair)
Kathleen Casey1
James Forese
Eileen Murray2
Sir Jonathan Symonds1
Jackson Tai

Pauline van der Meer Mohr

Member since

Meeting attendance
 in 2020

May 2016

Mar 2014

May 2020

Jul 2020

Sep 2014

Dec 2018

Apr 2020

13/13

5/5

7/7

5/6

3/3

13/13

10/10

1  Sir Jonathan Symonds stepped down from the Board on 18 February 
2020. Kathleen Casey stepped down from the Board on 24 April 
2020.

2  Eileen Murray was unable to attend a meeting in July 2020 due to a 

prior commitment made before her appointment.

Key responsibilities 

The Committee’s key responsibilities include:

• monitoring and assessing the integrity of the financial 

statements, formal announcements and regulatory information 
in relation to the Group's financial performance, as well as 
significant accounting judgements;

• reviewing the effectiveness of, and ensuring that management 

has appropriate internal controls over, financial reporting;

• reviewing and monitoring the relationship with the external 
auditor and oversees its appointment, tenure, rotation, 
remuneration, independence and engagement for non-audit 
services; and

• overseeing the work of Global Internal Audit and monitoring 
and assessing the effectiveness, performance, resourcing, 
independence and standing of the function.

Committee governance 

The Committee keeps the Board informed and advises on matters 
concerning the Group's financial reporting requirements to ensure 
that the Board has exercised oversight of the work carried out by 
management, Global Internal Audit and the external auditor. 

The Group Chief Executive, Group Chief Financial Officer, Group 
Head of Finance, Group Chief Accounting Officer, Group Head of 
Audit, Group Chief Risk Officer and other members of senior 
management routinely attended meetings of the GAC. The 
external auditor attended all meetings. 

The Chair held regular meetings with management, Global Internal 
Audit and the external auditor to discuss agenda planning and 
specific issues as they arose during the year outside the formal 
Committee process. The Committee also regularly met separately 
with the Group Chief Legal Officer, internal and external auditors 
and other senior management to discuss matters in private. 

The Committee Secretary regularly met with the Chair to ensure 
the Committee fulfilled its governance responsibilities and to 
consider input from stakeholders when finalising meeting 
agendas, tracking progress on actions and Committee priorities. 

Meetings of the Committee usually take place a couple of days 
before the Board meeting to allow the Committee to report its 
findings and recommendations in a timely and orderly manner. 
This is done through the Chair who comments on matters of 
particular relevance and the Board receives copies of the 
Committee agenda and minutes of meetings.

"The Committee spent substantial time in understanding and 
assessing the effect of the Covid-19 outbreak on expected credit 
losses, the Group-wide transformation programme and other 
related accounting judgements and disclosures."

Dear Shareholder

I am pleased to present my first report to you as Chair of the 
Group Audit Committee (‘GAC’). The Committee had a busy year, 
holding 13 meetings. This report sets out some of the issues 
considered during 2020.

The Committee has strong, but diverse, financial services 
experience. To strengthen our skill set further, we welcomed 
Pauline van der Meer Mohr, James Forese and Eileen Murray as 
new members. Sir Jonathan Symonds and Kathleen Casey 
stepped down during the year and I would like to thank them for 
their insightful and significant contributions to the work of the 
GAC.

The Committee spent substantial time in understanding and 
assessing the effect of the Covid-19 outbreak on expected credit 
losses, the Group-wide transformation programme, the impact of 
regulatory change on the control environment, and other related 
accounting judgements and disclosures.

Given the Committee's role in relation to whistleblowing I regularly 
met with the Group Chief Compliance Officer and the Group Head 
of Whistleblowing Oversight to discuss material whistleblowing 
cases, enhancements to whistleblowing arrangements and plans 
for periodic updates to the Committee.

To develop a better understanding of the key issues and 
challenges at the local level, I attended a number of principal 
subsidiary audit committee meetings throughout the Group. These 
meetings were complemented by regular Audit and Risk 
Committee Chairs’ Forums throughout the year to ensure 
alignment of priorities and to strengthen our relationship with the 
principal subsidiaries.

The Committee received regular updates from the Group Head of 
Audit on the progress against the audit plan. During the year the 
audit plan was adjusted in response to new risks arising from the 
Covid-19 outbreak and assurance work in relation to major change 
programmes throughout the Group.

Our external auditor, PricewaterhouseCoopers LLP ('PwC'), has 
now completed its sixth audit. PwC continues to provide robust 
challenge to management and provide sound independent advice 
to the Committee on specific financial reporting judgements and 
the control environment.

An internal evaluation concluded that the Committee continued to 
operate effectively in 2020, and made certain recommendations 
for continual improvement.

David Nish

Chair, Group Audit Committee, 23 February 2021

216 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Matters considered during 2020

Reporting

Financial reporting matters including: 
– Review of financial statements, ensuring that disclosures are fair, 

balanced and understandable

– Significant accounting judgements
– Going concern assumptions and viability statement
– Supplementary regulatory information and the ESG Update

Regulatory reporting-related matters

Certificates from principal subsidiary audit committees

Control environment

Review of deficiencies and effectiveness of internal financial controls

Internal audit

Reports from Global Internal Audit

Annual audit plan, independence and effectiveness

External audit 

Reports from external audit, including external audit plan

Appointment, remuneration, non-audit services and effectiveness

Compliance

Accounting standards and critical accounting policies

Corporate governance codes and listing rules

Whistleblowing 

Whistleblowing arrangements and effectiveness

Jan

Feb

Apr

Jun

Jul

Sep

Oct

Dec

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Compliance with regulatory requirements

The Board has confirmed that each member of the 
Committee is independent according to the criteria from the 
US Securities and Exchange Commission, and the 
Committee continues to have competence relevant to the 
sector in which the Group operates. The Board has 
determined that David Nish, Jackson Tai and Eileen Murray 
are all ‘financial experts’ for the purposes of section 407 of 
the Sarbanes-Oxley Act and have recent and relevant 
financial experience for the purposes of the UK and Hong 
Kong Corporate Governance Codes. 

The Committee assessed the adequacy of resources of the 
accounting and financial reporting function. It also monitored the 
legal and regulatory environment relevant to its responsibilities. 

The GAC Chair had regular meetings with the regulators, including 
the UK’s PRA and the FCA. These included trilateral meetings 
involving the Group’s external auditor PwC.

How the Committee discharged its 
responsibilities

Connectivity with principal subsidiary audit committees

During the year the GAC Chair regularly met with the chairs of the 
principal subsidiary audit committees and attended meetings to 
enable closer links and deeper understanding on judgements 
around key issues. In addition, there was regular interaction with 
committee chairs across the Group through the Audit and Risk 
Committee Chairs’ Forum (‘ARCC’).

Appointments to the audit committees of the principal subsidiary 
audit committees were reviewed and endorsed by the GAC. The 
GAC Chair met with proposed new chairs prior to their 
appointment.  

On a half-yearly basis, principal subsidiary audit committees 
provided certifications to the GAC regarding the preparation of 
their financial statements, adherence to Group policies and 
escalation of any issues that required the attention of the GAC. 

Financial reporting

The Committee’s review of financial reporting during the year 
included the Annual Report and Accounts, Interim Report, quarterly 
earnings releases, analyst presentations and Pillar 3 disclosures.

As part of its review, the GAC evaluated management’s 
application of critical accounting policies, significant accounting 
judgements and compliance with disclosure requirements to 
ensure these were consistent, appropriate and acceptable under 
the relevant financial reporting requirements. The Committee gave 
careful consideration to the key performance metrics related to 

strategic priorities and ensured that the performance and outlook 
statements were fair, balanced and reflected the risks and 
uncertainties appropriately.   

During the year, the Committee received regular updates from 
management on the additional guidance and disclosures made in 
relation to the Covid-19 outbreak. The Committee considered and 
was satisfied with the management response to the Financial 
Reporting Council’s (‘FRC') comments on HSBC’s Annual Report 
and Accounts 2019 regarding goodwill impairment disclosures, 
and the industry-wide FRC publications, including the letter to 
audit committee chairs.  

In conjunction with the Group Risk Committee (‘GRC’), the GAC 
considered the current position of the Group, along with the 
emerging and principal risks, and carried out a robust assessment 
of the Group’s prospects, before making a recommendation to the 
Board on the Group’s long-term viability statement. The GAC also 
undertook a detailed review before recommending to the Board 
that the Group continues to adopt the going concern basis in 
preparing the annual and interim financial statements. Further 
details can be found on page 41.

The Committee’s review of the long-term viability statement and 
the adoption of the going concern basis factored in additional 
guidance issued by the FRC on financial reporting in light of the 
Covid-19 outbreak. 

Following review and challenge of the disclosures, the Committee 
recommended to the Board that the financial statements, taken as 
a whole, were fair, balanced and understandable. The financial 
statements provided the shareholders with the necessary 
information to assess the Group’s position and performance, 
business model, strategy and risks facing the business. 

Covid-19 impact on accounting judgements

The Committee devoted significant time, including additional 
meetings, to the review and challenge of management’s approach 
and analysis of IFRS 9 expected credit losses (‘ECL’) in light of the 
Covid-19 outbreak and other geopolitical events. In its review, the 
GAC gave due regard to the interpretation and application of 
additional guidelines in relation to the Covid-19 outbreak and 
estimating ECL that were issued by various regulators. 

The Committee gave careful consideration to the measurement of 
ECL, in particular the key judgements and management 
adjustments made in relation to the forward economic guidance, 
underlying economic scenarios, reasonableness of the weightings 
and the impact on financial statements and disclosures. 

There was detailed discussion on the risks to ECL models as the 
unprecedented nature of the pandemic meant that the severity of 
the economic conditions was outside the bounds of historical data 

HSBC Holdings plc Annual Report and Accounts 2020 217

Corporate governance 
 
Report of the Directors | Corporate governance report

and experience used to develop IFRS 9 models. The Committee 
challenged management on the approach to modelling ECL, 
specifically the use of Credit Risk judgements and invited HSBC’s 
credit experts to present their views to the Committee. 

At the request of the GAC Chair, Global Internal Audit carried out 
additional verification and assurance regarding the disclosures 
made in quarterly reporting on the range of ECL outlook and 
consistency of the ECL disclosures. The Group’s external auditor 
regularly shared its views with the Committee on the 
reasonableness of management assumptions, given the significant 
changes made to the estimation of ECL due to the impact of the 
Covid-19 outbreak on the design, implementation and operation of 
ECL controls. 

Other areas of significant accounting judgements requiring in-
depth review due to the Covid-19 pandemic included valuation of 
financial instruments, goodwill impairment, hedge accounting and 
investment in associates. Further details can be found in the 
'Principal activities and significant issues considered during 2020' 
table on page 220. 

Internal controls 

The GAC assessed the effectiveness of the internal control 
system for financial reporting and any developments 
affecting it. This was in support of the Board’s assessment of 
internal control over financial reporting, in accordance with 
section 404 of the Sarbanes-Oxley Act. 

The Committee received regular updates and confirmations that 
management had taken, or was taking, the necessary actions to 
remediate any failings or weaknesses identified through the 
operation of the Group’s framework of controls. Further details of 
how the Board reviewed the effectiveness of key aspects of 
internal control can be found on page 260.

In 2020 the updates provided to the Committee included the 
potential impacts on internal control from the Covid-19 outbreak. 
These impacts included both those directly relevant to operational 
processes and controls, such as where new or amended controls 
were required to administer government relief packages, and more 
indirect impacts such as from colleagues working under 
contingency arrangements. A number of additional assurance 
procedures were performed across the lines of defence to monitor, 
assess and mitigate these impacts, with results regularly reported 
to the Committee.

External auditor 

The Group’s external auditor is PwC, which has held the role 
for six years, and the senior audit partner is Scott Berryman 
who has been in the role since 2019. The Committee 
reviewed the external auditor’s approach and strategy for the 
annual audit and also received regular updates on the impact 
on the control environment from the Covid-19 outbreak and 
the Group transformation programme. Principal matters 
discussed with PwC are set out in its report on page 267.

PwC discussed the impact from the Covid-19 outbreak on the 
execution and delivery of the audit and the plans to deliver the 
audit through remote working and mitigating actions being taken. 
These included accelerating aspects of planning and performing a 
number of areas of audit earlier to factor in expected delays due to 
remote working. There was also discussion on additional relevant 
work in relation to significant accounting judgements, such as 
expected credit losses, and the impact of the Covid-19 outbreak 
on the basis for determining materiality.

During the year, the GAC assessed the effectiveness of PwC as the 
Group's external auditor, using a questionnaire that focused on the 
overall audit process, its effectiveness and the quality of output. 
The Committee gave particular focus to the actions being taken by 
PwC in response to the findings from the HSBC effectiveness 
review and the PwC firm-wide Audit Quality Review by the 
Financial Reporting Council. PwC highlighted the continuing 
investment in both additional resources and new technologies to 
improve the quality and consistency of the audit. The Committee 
Chair also met the PwC engagement quality control partner for 

218 HSBC Holdings plc Annual Report and Accounts 2020

HSBC privately to discuss the continuous audit improvement 
actions.

The GAC received an update on the partner rotation and 
succession for the Group and its principal subsidiaries and the 
steps taken to ensure effective transitions. 

The GAC monitored the policy on hiring employees or former 
employees of the external auditor, and there were no breaches of 
the policy highlighted during the year. The external auditor 
attended all Committee meetings and the GAC Chair maintains 
regular contact with the senior audit partner and his team 
throughout the year.

The Committee also assessed any potential threats to 
independence that were self-identified or reported by PwC. The 
GAC considered PwC to be independent and PwC, in accordance 
with professional ethical standards, provided the GAC with written 
confirmation of its independence for the duration of 2020. 

The Committee confirms it has complied with the provisions of the 
Competition and Markets Authority Order for the financial 
statements. The Committee acknowledges the provisions 
contained in the UK Corporate Governance Code in respect of 
audit tendering. In conformance with these requirements, HSBC 
will be required to tender for the audit for the 2025 financial year 
end and beyond, having appointed PwC from 
1 January 2015.

The Committee believed it would not be appropriate to re-tender 
as a change in auditor would have a significant impact on the 
organisation, including on the Global Finance function. A change 
would lead to disruption and an increase in operational risk given 
the ongoing impact from the Covid-19 pandemic and the 
significant strategic change underway through the Group 
transformation programme. In addition, the Committee is closely 
monitoring the consultations and proposals arising from the 
Competition and Market Authority's statutory audit market study, 
the Kingman Review of the Financial Reporting Council and the 
Brydon Review on the quality and effectiveness of audit on the 
future of the UK external audit market. The Committee will 
consider its audit tendering strategy in line with the outcomes of 
the UK audit reform and well in advance of re-tendering in 2025. 

The Committee has recommended to the Board that PwC should 
be reappointed as auditor. Resolutions concerning the 
reappointment of PwC and its audit fee for 2021 will be proposed 
to shareholders at the 2021 AGM.

Non-audit services

The Committee is responsible for setting, reviewing and 
monitoring the appropriateness of the provision of non-audit 
services by the external auditor. It also applies the Group’s policy 
on the award of non-audit services to the external auditor. During 
the year, GAC reviewed changes made to the Group’s policy 
resulting from the implementation of ‘The Financial Reporting 
Council Revised Ethical Standard 2019’ (effective in 2020) and 
changes to internal governance. The key change in the revised 
standard is the introduction of a ‘whitelist of services’ that the 
principal accountant can provide. All services not prescribed in the 
whitelist are prohibited. The non-audit services are carried out in 
accordance with the external auditor independence policy to 
ensure that services do not create a conflict of interest. All non-
audit services are either approved by the GAC, or by Group 
Finance when acting within delegated limits and criteria set by the 
GAC.

The non-audit services carried out by PwC included 45 
engagements approved during the year where the fees were over 
$100,000 but less than $1m. Global Finance, as a delegate of GAC, 
considered that it was in the best interests of the Group to use 
PwC for these services because they were: 

• audit-related engagements that were largely carried out by 

members of the audit engagement team, with the work closely 
related to the work performed in the audit; 

• engagements covered under other assurance services that 
require obtaining appropriate audit evidence to express a 
conclusion designed to enhance the degree of confidence of 

 
the intended users other than the responsible party about the 
subject matter information; or

• other permitted services to advisory attestation reports on 

internal controls of a service organisation primarily prepared for 
and used by third-party end users.

Eight engagements during the year were approved where the fees 
exceeded $1m. These were mainly engagements required by the 
regulator and incremental fees related to previously approved 
engagements. One new engagement outside the scope of the pre-
approved services related to preliminary advanced audit 
procedures for the adoption of IFRS 17 in 2023. 

Auditors‘ remuneration

Total fees payable

Fees for non-audit services

Global Internal Audit

2020

$m
130.2   
37.3   

2019

$m

110.7 

25.5 

The primary role of the Global Internal Audit function is to help the 
Board and management protect the assets, reputation and 
sustainability of the Group. Global Internal Audit does this by 
providing independent and objective assurance on the design and 
operating effectiveness of the Group’s governance, risk 
management and control framework and processes, prioritising 
the greatest areas of risk.

The independence of Global Internal Audit from day-to-day line 
management responsibility is critical to its ability to deliver 
objective audit coverage by maintaining an independent and 
objective stance. Global Internal Audit is free from interference by 
any element in the organisation, including on matters of audit 
selection, scope, procedures, frequency, timing, or internal audit 
report content. Global Internal Audit adheres to The Institute of 
Internal Auditors' mandatory guidance.

The Group Head of Audit reports to the Chair of the GAC and there 
are frequent meetings held between them. Results of audit work, 
together with an assessment of the Group’s overall governance, 
risk management and control framework and processes are 
reported regularly to the GAC, GRC and local audit and risk 
committees, as appropriate. This reporting highlights key themes 
identified through audit activity, business and regulatory 
developments, and provides an independent view of emerging and 
horizon risk, together with details of audit coverage.

Audit coverage is achieved using a combination of business and 
functional audits of processes and controls, risk management 
frameworks and major change initiatives, as well as regulatory 
audits, investigations and special reviews. In addition to the 
ongoing importance of regulatory-focused work, key risk theme 
categories for 2020 audit coverage were strategy, governance and 
culture, financial crime, conduct and compliance, financial 
resilience and operational resilience. In April 2020, in response to 
the Covid-19 outbreak, Global Internal Audit completed a risk-
based review to revise the 2020 annual audit plan to create 
capacity for real-time audits targeted at key risks arising from the 
pandemic. Real-time audits provide real-time, independent 
ongoing observations to management responding to the Covid-19 
outbreak. Issues are raised for significant observations that are not 
addressed in a timely manner. In addition, in response to the 
business update in February 2020, Global Internal Audit focused 
on governance over the transformation programme and performed 
project audit activity for selected complex and high-priority 
business cases.

Executive management is responsible for ensuring that issues 
raised by the Global Internal Audit function are addressed within 
an appropriate and agreed timetable. Confirmation to this effect 
must be provided to Global Internal Audit, which validates closure 
on a risk basis.

Consistent with previous years, the 2021 audit planning process 
includes assessing the inherent risks and strength of the control 
environment across the audit entities representing the Group. 
Results of this assessment are combined with a top-down analysis 
of risk themes by risk category to ensure that themes identified are 
addressed in the plan. Risk theme categories for the 2021 audit 

work continue to be strategy, governance and culture, financial 
crime, conduct and compliance, financial resilience, and 
operational resilience. During 2021, a quarterly assessment of key 
risk themes will form the basis of thematic reporting and plan 
updates and will ultimately drive the 2022 planning process. The 
annual audit plan and material plan updates are approved by the 
GAC. Based on regular internal audit reporting to the GAC, private 
sessions with the Group Head of Audit, the Global Professional 
Practices annual assessment and quarterly Quality Assurance 
updates, the GAC is satisfied with the effectiveness of the Global 
Internal Audit function and the appropriateness of its resources.  

Global Internal Audit maintains a close working relationship with 
HSBC’s external auditor, PwC. The external auditor is kept 
informed of Global Internal Audit’s activities and results, and is 
afforded free access to all internal audit reports and supporting 
records.

Principal activities and significant issues 
considered during 2020

Collaborative oversight by GAC and GRC

The GAC and GRC worked closely to ensure there were 
procedures to manage risk and oversee the internal control 
framework. They also worked together to ensure any 
common areas of responsibility were addressed 
appropriately with inter-committee communication or joint 
discussions with the Chairs. 

The Chairs are members of both committees and engage on the 
agendas of each other’s committees to further enhance 
connectivity, coordination and flow of information. This is further 
complemented with significant overlap in membership of the GAC 
and GRC to ensure deeper understanding and informed challenge 
at both meetings. 

During 2020, the GAC and GRC Chairs reviewed and challenged 
management’s proposals to transition the responsibility for 
oversight of entity level controls from the GAC to the GRC. The 
Chairs considered whether there was the suitable level of 
management seniority for ownership of entity level controls and 
whether there was regular and appropriate reporting to both 
committees to fulfil their oversight responsibilities.

In 2020, five ARCC Forums were held with the chairs of principal 
and regional subsidiaries’ audit and risk committees, together with 
senior management from these subsidiaries. The purpose of these 
ARCC Forums was to discuss mutual priorities, improvement and 
remediation programmes and forward-looking issues in relation to 
the management of risk and the internal control framework. The 
topics discussed at the ARCC Forums can be found in the GRC 
report on page 226.

Three areas of joint focus for the GAC and GRC during 2020 were:

Sustainable control environment

With oversight from the GAC, the Group Executive Committee 
continued a programme to ensure there is clear understanding, 
accountability and ownership for internal controls and end-to-end 
processes to deliver operational quality and consistent outcomes 
for customers and simpler operation of controls for colleagues. 

The GAC provided constructive challenge to management 
proposals and received regular progress updates on the work 
streams. Improvements were measured and tracked through a 
new enterprise-wide non-financial risk forum with escalation paths 
into the GAC and GRC. 

Financial reporting

The GAC reviewed and provided feedback on the assurance work 
and management’s opinion on internal controls over financial 
reporting, as required by the Sarbanes-Oxley Act. In conjunction 
with the GRC, the GAC monitored the remediation of significant 
deficiencies and weaknesses in entity level controls raised by 
management and the external auditor. The GAC will continue to 
monitor the progress of remediation as well as efforts to integrate 
requirements of the Sarbanes-Oxley Act with the operational risk 

HSBC Holdings plc Annual Report and Accounts 2020 219

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Report of the Directors | Corporate governance report

framework as part of the sustainable control environment 
programme. 

In 2020, the GAC and the GRC reviewed the risks arising from 
models used for the estimation of expected credit losses under 
IFRS 9, particularly given the economic backdrop of the Covid-19 
outbreak. The committees challenged the underlying economic 
scenarios, additional scenarios added by management and the 
reasonableness of the weightings applied to each scenario in order 
to understand the impact on the financial statements.

Monitoring changes to regulatory requirements

The GAC approved an annual priorities plan to review 
management’s response to current and future changes in 
regulatory requirements affecting financial reporting. In 2020, this 
included interpretation of new accounting standards, industry-
wide regulatory reform programmes and their impact on 
accounting judgements. The GAC will continue to monitor specific 
accounting issues identified during the year and future regulatory 
items that will impact the integrity of financial reporting, the Group 
and its relationships with regulators.

There continues to be an increased focus on the quality of 
regulatory reporting by the PRA and other regulators globally. The 
GAC will review the steps taken by management to strengthen the 
controls over regulatory reporting and as we strengthen our 
processes and controls, there may be impacts on some of our 
regulatory ratios.  

In conjunction with the GRC, the GAC continued to oversee the 
progress of management’s proposals and implementation of the 
Basel III Reforms and the Ibor transition. The GAC focused on the 
operational and control environment impacts from Basel III 
Reforms and Ibor transition on HSBC’s financial reporting and 
interdependencies with other Group transformation programmes.

Whistleblowing and ‘speak up’ culture

Whistleblowing is a key element of ‘speak up’ culture, with 
the Group’s whistleblowing channel, HSBC Confidential, 
offering a variety of ways for our people to raise 
whistleblowing concerns (see page 68 for further 
information). The GAC is responsible for the oversight of the 
effectiveness of the Group’s whistleblowing arrangements. 

The Group’s Chief Compliance Officer provides periodic 
reporting to the GAC on the efficacy of the whistleblowing 
arrangements, providing an assessment of controls and 
detailing the results of internal audit assessments. The 
Committee is also briefed on culture and conduct risks and 
associated management actions arising from whistleblowing 
cases. The Chair of the GAC acts as the Group’s 
whistleblowers’ champion, with responsibility for ensuring 
and overseeing the integrity, independence and effectiveness 
of HSBC’s policies and procedures on whistleblowing and 
the protection of whistleblowers. The Chair met with the 
Group Head of Whistleblowing Oversight throughout the 
year for briefings on material whistleblowing cases and 
assessments of the whistleblowing arrangements. 

The Committee has requested updates on a number of key areas 
during 2020, including an assessment of the timeliness of 
whistleblowing investigations. The arrangements were subject to 
an internal audit review during 2020, which rated the design, 
control and management oversight of the arrangements as 
satisfactory. As part of the ongoing assessment of the end-to-end 
arrangements, the Committee has requested a deeper review in 
key markets of the employee investigation function in which the 
whistleblowing arrangements have a dependency. An external 
benchmarking assessment was presented to the GAC in 
December 2020. This provided an overview of the overall 
effectiveness of whistleblowing arrangements and investigations 
processes against a number of industry peers, and best practice 
guidance issued by external consultancy and legal firms as well as 
the UK charity, Protect. The assessment reflected the significant 
progress made during 2020 such as the implementation of a new 
whistleblowing platform (Navex), the enhanced global minimum 
standards and improvements observed in the ‘speak up’ culture. In 
addition, governance was improved with a particular focus on key 
emerging conduct themes to enable timely management action, 
and a mechanism was introduced for whistleblowers to provide 
feedback post-investigation. The assessment also identified further 
opportunities for 2021 as part of the Group’s fit for the future 
programme with updates to be provided to the whistleblowing 
champion and the GAC throughout 2021.

Principal activities and significant issues considered during 2020 

Areas of focus

Key issues

Conclusions and actions

In exercising its oversight, the Committee assessed management's assurance and 
preparation of external financial reporting disclosures. The Committee was 
particularly focused on the ongoing Covid-19-related uncertainty and how 
management addressed and reflected the impact of the pandemic in external 
reporting and disclosures. The Committee reviewed the draft external reporting 
disclosures and provided feedback and challenge on the top sensitive disclosures, 
including key financial metrics and strategic priorities to ensure HSBC was 
consistent and transparent in its messaging. 
The GAC reviewed the approach to combining the ESG Update into the Annual 
Report and Accounts for the 2020 reporting period. This included consideration of 
the steps taken by management to address findings from Global Internal Audit 
regarding the controls and assurance processes for ESG content. The Committee 
will review the steps taken by management in developing the target operating 
model to deliver integrated reporting in 2021. 

The Committee reflected on the continued focus on the quality and reliability of 
regulatory reporting by the PRA and other regulators globally. The GAC reviewed 
management’s efforts to strengthen and simplify the end-to-end operating model, 
including commissioning independent external reviews of various aspects of 
regulatory reporting. The Committee discussed and provided management’s 
engagement plans with the Group’s regulators, including any potential impacts on 
some of our regulatory ratios such as CET1 and LCR. We continue to keep the 
PRA and other relevant regulators informed of our progress.  

The actions taken are summarised above in the 'Covid-19 impact on accounting 
judgements' section of this report. 

Financial and 
regulatory 
reporting

Key financial metrics and strategic priorities
The GAC considered the key judgements in relation 
to external reporting to track the key financial 
metrics and strategic priorities and to review the 
forecast performance and outlook.

Environmental, social and governance (‘ESG’) 
reporting
The Committee considered management's efforts to 
embed and enhance ESG reporting to demonstrate 
strong controls, operation and governance, 
including key performance indicators and assurance 
plans.
Regulatory reporting assurance programme
The GAC monitored the progress of the regulatory 
reporting assurance programme to enhance the 
Group’s regulatory reporting, impact on the control 
environment and oversee regulatory reviews and 
engagement.

Significant 
accounting 
judgements

Expected credit losses
The measurement of expected credit losses involves 
significant judgements, particularly under current 
economic conditions. There remains an elevated 
degree of uncertainty over ECL estimation under 
current macroeconomic, political and 
epidemiological uncertainties. Further details are 
provided in the 'Covid-19 impact on accounting 
judgements' section of this report. 

220 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Principal activities and significant issues considered during 2020  (continued)

Areas of focus

Key issues

Conclusions and actions

Significant 
accounting 
judgements

Long-term viability and going concern 
statement
During the year, the GAC has considered a wide 
range of information relating to present and future 
projections of profitability, cash flows, capital 
requirements and capital resources. These 
considerations include stressed scenarios that 
reflect the increasing uncertainty that the global 
Covid-19 outbreak has had on HSBC’s operations, 
as well as considering potential impacts from other 
top and emerging risks, and the related impact on 
profitability, capital and liquidity.

Goodwill and other non-financial assets 
impairment
During the year, management tested for impairment 
goodwill and other non-financial assets. Key 
judgements in this area relate to long-term growth 
rates, discount factors and what cash flows to 
include for each cash-generating unit tested, both in 
terms of compliance with the accounting standards 
and reasonableness of the forecast. During the 
year, the Group recognised $1.3bn impairment in 
relation to non-financial assets, following which a 
detailed analysis of various balance sheet amounts 
was initiated.

Associates (Bank of Communications Co., 
Limited and The Saudi British Bank) 
During the year, management performed the 
impairment review of HSBC’s investment in Bank of 
Communications Co., Ltd (‘BoCom’) and The Saudi 
British Bank (‘SABB’). The impairment reviews are 
complex and require significant judgements, such 
as projected future cash flows, discount rate, and 
regulatory capital assumptions.

Legal proceedings and regulatory matters
Management has used judgement in relation to the 
recognition and measurement of provisions, as well 
as the existence of contingent liabilities for legal 
and regulatory matters, including, for example, an 
FCA investigation into HSBC Bank’s and HSBC UK 
Bank’s compliance with the UK money laundering 
regulations and financial crime systems and 
controls requirements.

Valuation of defined benefit pension 
obligations 
The valuation of defined benefit pension obligations 
involves highly judgemental inputs and 
assumptions, of which the most sensitive are the 
discount rate, pension payments and deferred 
pensions, inflation rate and changes in mortality. 

Valuation of financial instruments 
Due to the volatile market conditions in 2020, 
management refined its approach to valuing 
Group’s investment portfolio. In addition, as losses 
were incurred on the novation of certain derivative 
portfolios, management considered whether fair 
value adjustments were required under the fair 
value framework. Management’s analysis provided 
insufficient evidence to support the introduction of 
these adjustments in line with IFRS.

Tax-related judgements
HSBC has recognised deferred tax assets to the 
extent that they are recoverable through expected 
future taxable profits. Significant judgement 
continues to be exercised in assessing the 
probability and sufficiency of future taxable profits, 
future reversals of existing taxable temporary 
differences and ongoing tax planning strategies.

UK customer remediation 
Management’s judgement is used in determining 
the assumptions used to calculate the Group’s 
remediation provisions, of which the most material 
are PPI and a programme in relation to the 
collections and recoveries operations of the bank. 

In accordance with the UK and Hong Kong Corporate Governance Codes, the 
Directors carried out a robust assessment of the principal risks of the Group and 
parent company. The GAC considered the statement to be made by the Directors 
and concluded that the Group and parent company will be able to continue in 
operation and meet liabilities as they fall due, and that it is appropriate that the 
long-term viability statement covers a period of three years.

The GAC received reports on management's approach to goodwill and other non-
financial assets impairment testing and challenged the approach and models 
used. The GAC also challenged management's key judgements and considered 
the reasonableness of the outcomes as a sense check against the business 
forecasts and strategic objectives of HSBC. The GAC reviewed the results of 
management’s detailed analysis of the balance sheet and agreed with the 
conclusions.

The GAC reviewed the judgements in relation to the impairment reviews of 
HSBC’s investment in BoCom and SABB, including the sensitivity of the results to 
estimates and key assumptions such as projected future cash flows and 
regulatory capital assumptions. Additionally, the GAC reviewed the models’ 
sensitivity to long-term assumptions including the continued appropriateness of 
the discount rates.

The GAC received reports from management on the legal proceedings and 
regulatory matters that highlight the accounting judgements for matters where 
these are required. The matters requiring significant judgements were highlighted. 
The GAC has reviewed these reports and agree with the conclusions reached by 
management.

The GAC has considered the effect of changes in key assumptions on the HSBC 
UK Bank plc section of the HSBC Bank (UK) Pensions Scheme, which is the 
principal plan of HSBC Group.

The GAC considered the key valuation metrics and judgements involved in the 
determination of the fair value of financial instruments. The GAC considered the 
valuation control framework, valuation metrics, significant year-end judgements 
and emerging valuation topics and agrees with the judgements applied by 
management.

The GAC considered the recoverability of deferred tax assets, in particular in the 
US and the UK. The GAC also considered management’s judgements relating to 
tax positions in respect of which the appropriate tax treatment is uncertain, open 
to interpretation or has been challenged by the tax authority.

The GAC considered and challenged management’s assumptions and the 
approach for estimating potential outflows relating to the calculations of the 
customer remediation provisions. 

HSBC Holdings plc Annual Report and Accounts 2020 221

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Report of the Directors | Corporate governance report

Principal activities and significant issues considered during 2020  (continued)

Areas of focus

Key issues

Conclusions and actions

Other 
accounting 
judgements

Long-term asset return assumptions in PVIF
Market volatility during 2020 resulted in further 
review of the long-term investment assumptions 
used in the measurement of the present value of in-
force business ('PVIF') intangible assets recorded on 
the balance sheet in relation to shareholder returns 
expected from long-term insurance contracts. 

Hedge accounting
Significant judgements relating to hedge 
accounting matters under current economic 
conditions include the impact of Covid-19 payment 
deferrals on the highly probable cash flow forecasts 
required by macro cash flow programmes; and 
whether hedge accounting relationships, where 
hedged items include interest rate floors and the 
hedging instrument does not, would be highly 
effective over the hedged horizon.

Transformation and sustainable control 
environment
The GAC will oversee the impact on the risk and 
control environment from the Group transformation 
programme.

Global Finance transformation
The Committee reviewed the proposals for the 
Global Finance organisational design, the migration 
to Cloud and the impact on financial controls. 

Group 
transformation

IFRS 17 'Insurance Contracts'
The Committee will oversee the transition to IFRS 
17 and consider the wider strategic implications of 
the change on the insurance business.

Regulatory 
change

222 HSBC Holdings plc Annual Report and Accounts 2020

The GAC reviewed the assumptions determined by management under existing 
insurance governance processes, which involve significant expert judgement, and 
concluded that they were supportable given internal and external benchmarks and 
information reviewed.

The GAC noted that the effect of Covid-19 payment deferrals on hedge 
accounting was limited and no additional actions were required. Additionally the 
GAC was informed about the mitigation actions management has taken to reduce 
the risk associated with floored hedged items, such as designating new hedge 
accounting relationships.

The Committee received regular updates on the Group transformation programme 
to review the impact on the risk and control environment and to oversee progress 
of the Group transformation programme. 
In these updates the Committee monitored the development of management’s 
approach to structuring and governing the Group transformation programme and 
risk management processes. This oversight helped satisfy the Committee of the 
appropriateness of these processes and associated benefits delivery. 
Management kept the Committee apprised of the changes and adjustments made 
to the Group transformation programme in response to Covid-19, and associated 
impact on the financial performance.
Management’s updates were supplemented by significant focus and assurance 
work from Global Internal Audit where a dedicated team continuously monitored 
and reviewed the Group transformation programme. This included carrying out a 
number of targeted audit reviews, in addition to audits of significant programmes. 
These reviews focused on key elements of change management.

The Committee has oversight for the adequacy of resources and expertise, as well 
as succession planning for the Global Finance function. During 2020, the 
Committee dedicated significant time to the review and progress of the multi-year 
Global Finance transformation programme, with the overall objectives being to 
improve the control environment and customer outcomes and to leverage 
technology to increase overall efficiency. In particular, the Committee discussed 
the challenges to Global Finance operations, including financial reporting, from 
the Covid-19 pandemic and sought assurance that controls were in place to 
maintain standards and quality. 
The Committee reviewed and challenged the key change programmes and 
delivery milestones and tracked the progress of the deliverables. In particular, the 
Committee considered the impact from the Global Finance transformation on the 
Group transformation programme, regulatory change programmes and where 
there were interdependencies and concentrations risks through key programmes 
such as Finance on the Cloud. There were frequent discussions with management 
with input from Global Internal Audit on the impact on key risks and controls, 
including steps taken to mitigate these risks. Management regularly updated the 
Committee on the approach and plans for regulatory engagement, including 
follow-up on the outcomes and actions to be taken post-meetings with regulators. 
The Group Chief Financial Officer had private sessions with the Committee to 
share his perspectives on the progress of the Global Finance transformation, areas 
of strategic priorities and where additional focus was required. The private 
sessions included discussion on succession planning and resourcing and areas 
where GAC members could support and guide management by leveraging 
members’ experience.

Management provided an update on the final standard amendments that were 
issued in June 2020 and discussed the impact on the transition programme 
necessitated by the one-year delay to the effective date, both from a policy 
implementation and model build perspective. The discussions highlighted the 
significant uncertainty that remained in the interpretation of key areas and the 
working assumptions adopted by management to enable design solutions, 
investment in technology and data infrastructure to proceed. 
The Committee discussed the impact from IFRS 17 on HSBC’s reported numbers 
in the financial statements and management will continue to consider how to 
appropriately apply the standard to HSBC’s insurance business, as well as 
monitoring insurance industry developments on disclosures. Management will 
continue to keep the Committee updated on plans for the investor narrative, 
taking into account the relevant disclosure requirements applicable to HSBC, and 
ongoing presentation of insurance results up to the time of the transition.

 
Principal activities and significant issues considered during 2020  (continued)

Areas of focus

Key issues

Conclusions and actions

Basel III Reform
The GAC considered the implementation of the 
Basel III Reform and the impact on the capital 
requirements and RWA assurance. This was 
considered in the context of the strategy and 
structure of the balance sheet.

Regulatory 
change

Interest rate benchmark replacement
The financial reporting risks of interest rate 
benchmark transition include the potential for 
volatility arising from financial instruments 
valuation, contract modification and hedge 
accounting. The transitions involve significant 
operational complexity for financial institutions, and 
industry approaches to transition continue to 
develop.

The Committee received an update on the progress and impact of the Basel III 
Reform programme on the Group. Management discussed the uncertainty over 
the final definition of the rules and the actions taken to ensure sufficient flexibility 
to make changes and mitigate risks from legislation being finalised at a later date.  
The discussion highlighted the dependencies of the Basel III Reform programme 
with other Group transformation programmes, in particular the dependency on 
adoption of the Finance on the Cloud solution and the impact on data delivery and 
storage. 
The Committee reviewed and challenged management on the findings from an 
audit on the programme structure, governance and the significant cost increase 
year on year. Management explained the actions being taken in response to the 
audit findings and the reasons for the increase in costs, which included delays to 
implementation dates caused by Covid-19.

The GAC noted management’s early adoption of ‘Interest Rate Benchmark Reform 
– Phase 2’ amendments to IFRSs in relation to benchmark reform, including the 
disclosures necessary to support adoption of the reliefs.
The Committee considered the risks and financial reporting impacts arising from 
the Ibor transition. Management discussed actions being taken to mitigate the 
risks, which included new product development and a client outreach programme 
to ensure readiness to migrate and explain the changes and outcomes arising 
from the transition to clients. Management advised about the operational 
challenges such as the updates to current systems and processes that were 
required to support the accounting for the Ibor transition and our external 
dependency on market and client readiness. In particular, management drew 
attention to the potentially material impact on hedge accounting programmes 
from the Ibor transition and the substantial costs and risks involved in the 
redocumentation of hedges. 
The Committee discussed the approach being taken across the industry with 
management and PwC and potential impacts on the control environment relevant 
to financial reporting from the Ibor transition.

Committee evaluation and effectiveness

Focus of future activities

The annual review of the effectiveness of the Board 
committees, including the GAC, was conducted internally in 
2020. Overall the review concluded that the GAC continued 
to operate effectively, and highlighted improvements made 
in 2020 in relation to Committee structure and focus. The 
review also made certain recommendations for continuous 
improvement, including in relation to further enhancing the 
quality of information presented to the meeting through 
revised executive governance oversight. The Committee has 
considered and discussed the outcomes of the evaluation 
and accepts the findings. 

The outcomes of the evaluation have been reported to the Board 
and the Committee will track progress on the recommendations 
during 2021.

At the beginning of each year the Committee discusses its key 
priorities for the year ahead. In 2021, the Committee will continue 
to monitor execution of the Group transformation programme and 
its impact on the risk and control environment. In monitoring the 
Group transformation programme, the Committee will consider 
the interdependencies between the Group transformation 
programme and implementation of large-scale regulatory change 
programmes such as Basel III Reforms, the Ibor transition and 
IFRS 17 'Insurance Contracts'. A major area of focus is also 
expected to be the GAC’s engagement with the UK Government’s 
consultation and proposals for the future of the UK external audit 
market.

HSBC Holdings plc Annual Report and Accounts 2020 223

Corporate governance 
 
 
Report of the Directors | Corporate governance report

Group Risk Committee 

Membership

Member since

Meeting attendance 
in 2020

Jackson Tai (Chair)
Kathleen Casey1
Steven Guggenheimer
José Antonio Meade Kuribreña

Heidi Miller

Eileen Murray

David Nish
Sir Jonathan Symonds1
Pauline van der Meer Mohr

Sep 2016

Jan 2020

May 2020
May 2019 

Sep 2014

Jul 2020

Feb 2020

Apr 2018

Apr 2018

8/8

3/3

4/4
8/8

8/8

3/3

7/7

2/2

8/8

1  Sir Jonathan Symonds stepped down from the Board on 18 February 
2020. Kathleen Casey stepped down from the Board on 24 April 
2020.

Key responsibilities

The Group Risk Committee has overall non-executive responsibility 
for oversight of risk-related matters and the risks impacting the 
Group. The GRC’s key responsibilities includes:

• advising the Board on risk appetite-related matters, and key 

regulatory submissions, including the ICAAP and ILAAP, as well 
as recovery and resolution planning;

• overseeing and advising the Board on all risk-related matters, 

including financial risks, non-financial risks and the 
effectiveness of the Group’s conduct framework;

• undertaking a review and challenge of the Group’s stress 

testing exercises; and

• reviewing the effectiveness of the Group’s enterprise risk 

management framework and internal controls systems (other 
than internal financial controls overseen by the GAC).

Committee governance

In carrying out its responsibilities, the GRC is supported by the 
participation of senior management, including Noel Quinn who 
attended six GRC meetings in 2020.
The Group Chief Risk Officer, Group Chief Financial Officer, Group 
Head of Audit, Group Chief Compliance Officer and Global Head of 
Risk Strategy are standing attendees and regularly attend GRC 
meetings to contribute their subject matter expertise and insight. 
They facilitate GRC members' review and challenge of current and 
forward-looking risk issues, working together with business, 
functional and regional leaders across all three lines of defence. 
The Chair also regularly meets with the Group Chief Risk Officer, 
the Group Head of Audit and external auditor, PwC, without 
management present.

The Chair also has regular meetings with members of senior 
management to discuss specific risk matters that arise during the 
year outside formal meetings. The Chair consults regularly with 
the Committee Secretary to ensure the GRC meets its governance 
responsibilities and to consider input from stakeholders when 
finalising meeting agendas, tracking progress on actions and 
Committee priorities.

“Geopolitical developments, civil unrest, the UK's trade negotiation 
with the EU and the Covid-19 outbreak introduced new challenges 
for our organisation, customers and people. The Group Risk 
Committee responded by working closely with management to 
understand and appropriately challenge scenario stress testing, 
early warning indicators and management of information."

Dear Shareholder

I am pleased to present the Group Risk Committee (‘GRC’) report.

Geopolitical developments, civil unrest in Hong Kong, the UK’s 
trade negotiations with the EU and the Covid-19 outbreak 
introduced new challenges for our organisation, customers and 
people. The GRC responded by working closely with management 
to understand and appropriately challenge scenario stress testing 
results, early warning indicators and key management metrics. 
Importantly, we monitored heightened capital and liquidity risks 
against the prospect of greater market volatility, large customer 
financing needs, rapid credit deterioration and lapses in fair 
outcomes for our customers. We reviewed and challenged the 
impact of forward economic growth assumptions on our markets 
and credit exposures. We maintained close watch over people and 
operational risks arising from fatigue, the health impact of the 
virus, and government-imposed restrictions.

The GRC continued to strengthen its composition and skills to 
promote proactive risk governance. During the year we welcomed 
seasoned technology and operations experts Steven 
Guggenheimer and Eileen Murray to the GRC. We also extended 
deep appreciation to Sir Jonathan Symonds and Kathleen Casey 
for their valuable insight and contribution upon their retirement 
from the GRC and the Board. 

The GRC convened eight formal meetings plus seven special 
sessions to review and challenge our most important 
responsibilities, including Group internal stress testing, internal 
liquidity adequacy assessment process ('ILAAP'), and internal 
capital adequacy assessment process ('ICAAP'). We also 
organised timely education sessions, including a full-day training 
on sanctions in Hong Kong for non-executive Directors and 
management in Asia-Pacific. 

Throughout 2020, the GRC and GAC coordinated closely our 
respective agendas, as evident in our five jointly organised 
regional Audit and Risk Committee Chairs’ Forums, which featured 
discussion on key audit and risk issues with our principal 
subsidiaries, ensuring alignment of priorities between the Group 
and its subsidiaries.

Jackson Tai

Chair 

Group Risk Committee

23 February 2021

224 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Matters considered by the GRC in 2020

Financial risk

Credit risk

Jan

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IT and operational risk including 
outsourcing, third-party risk 
management, cyber risk                                                

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Model risk                                

People and conduct risk

Risk appetite

Financial crime risk

Regulatory compliance
Legal risk                                                              l

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Feb

Mar

Apr

May

Jun

Jul

Sep

Oct

Nov

Dec

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How the GRC discharges its responsibilities

Monitoring changes to regulatory requirements 

During 2020, the GRC reshaped its meeting agenda to place 
greater emphasis on a regular review of the Group’s risk 
landscape and to track the management of information and 
desired outcomes for our most important risk areas. Each meeting 
now commences with a review of our enterprise risk landscape 
through the Group Chief Risk Officer’s update of the Group risk 
profile followed by a comprehensive review of critical 
management information, led by the Group Chief Risk Officer, and 
supported by the Group Chief Financial Officer, Group Chief 
Operating Officer, Group Chief Compliance Officer and Group 
Human Resources Officer. 

The GRC also reviewed internal and external audit reports and 
regular risk reports, which provided deeper reporting on the 
Group’s risk profile and highlighted the material current and 
forward-looking risks and issues, such that the GRC could 
effectively identify any areas that required more of the GRC's 
attention. A summary of coverage is set out in the table above.

Throughout the year, the GRC adhered to an agenda that sought 
to regularly address topics and oversight responsibilities set out in 
the Group risk taxonomy, while being flexible to undertake 
informed review and appropriate challenge of timely risk issues 
that have economic, commercial, regulatory and reputational 
implications for the Group’s franchise.  

Three thematic risk areas are described below to illustrate the 
GRC’s focus during the year.

Sustainable control environment 

During 2020, the GRC undertook in-depth reviews of a number of 
topics relating to the Group’s internal controls and the necessary 
culture change needed to improve the control environment. The 
GRC reviewed model enhancements needed as a result of changes 
in the economy due to the Covid-19 outbreak. The GRC also 
continued its review of the Group’s approach to operational 
resilience and identified improvements from a pilot study to 
identify areas for further enhancements. The GRC also reviewed 
the effectiveness of the Group’s anti-fraud controls. At the 
November meeting of the Committee, it was agreed the ultimate 
oversight for all of the Group’s entity level controls move from the 
GAC to the GRC. This change supports the Committee’s 
responsibility for review and oversight of the risk management 
culture, framework and internal control systems. 

Financial risk

The GRC provided informed review and constructive challenge to 
the Group’s regulatory submissions of ICAAP and ILAAP. It also 
monitored progress on the Group’s liquidity risk management 
improvement plan, including the development of the internal 
liquidity metric. It reviewed work by the Global Finance function 
on strengthening recovery planning. 

The GRC continued to maintain oversight of the Group’s regulatory 
and internal stress testing programmes, particularly in light of the 
impact of the Covid-19 outbreak with specific review and 
challenge of the key assumptions, strategic management actions 
and outcomes of the principal tests conducted. Through these 
reviews, the GRC assessed risks facing the Group to determine the 
principal risks to its long-term viability, including those that would 
threaten its solvency and liquidity.

During 2020, the GRC undertook review and challenge of a 
number of risk areas for which the Group has regulatory 
obligations or is facing regulatory change. These included 
operational resilience, climate risk and sanctions. The Committee 
received updates on regulators’ rules and guidance relating to 
operational resilience, which is designed to protect customers and 
maintain economic stability by preventing incidents leading to 
intolerable consumer harm, market disruption, and impact to the 
safety and soundness of firms. To reinforce continued emphasis 
and visibility on financial crime and sanctions compliance, the 
GRC organised a full-day training session on international 
sanctions early in the year in Hong Kong for our Asia-Pacific non-
executive Directors and management.

The GRC also considered the PRA’s latest requirements and 
expectations relating to evidencing of the embedding of climate 
risk management capabilities within regulated firms.

Activities outside formal meetings

The GRC organised a number of activities outside of its regular 
meeting cycle to facilitate more effective oversight of the risks 
impacting the Group. In particular, the GRC’s formal meetings 
continue to be supported by training and ‘walk-through’ sessions 
to raise the GRC’s understanding of the underlying domain issues, 
ensuring the GRC is well prepared in its informed review and 
constructive challenge. The chairs of principal subsidiary risk 
committees were also invited. Activities included, among others:

• a Directors' education session, held in October 2020, focusing 
on the increasingly complex international sanctions and export 
control landscape, including key sanctions challenges facing 
the Group with the imposition of new US sanctions following 
the US Hong Kong Autonomy Act. This education session was 
attended by 27 non-executive Directors from across the Group;

• a Directors' education session, held in November 2020, led by 
senior leaders in Group Treasury on the implementation of the 
internal liquidity metric, which is designed to provide an 
internal view of liquidity risk and to ensure the Group holds 
enough liquidity to meet and recover from a defined stress; 

• GRC Chair’s Working Sessions on a range of topics including 
financial crime developments, progress on FCA conduct 
remediation matters (May 2020), the Wealth and Personal 
Banking conduct programme (May 2020), progress on 
regulatory remediation programmes (January and December 
2020), the outcomes and implications of the 2020 Group 
internal stress test (November 2020), and progress on the 2020 
ICAAP and ILAAP submissions (November 2020); and

• three cybersecurity consultation sessions and regular updates 
on cyber developments such as cyber-crime, legislation and 
technology led by the GRC’s independent cybersecurity adviser.

Connectivity with principal subsidiary risk committees 

The risk committees of principal subsidiaries provided half-yearly 
confirmations to the GRC. These certifications confirmed that the 
principal subsidiary risk committees had challenged management 
on the quality of the information provided, reviewed the actions 
proposed by management to address any emerging issues or 
trends and that the risk management and internal control systems 
in place were operating effectively.

HSBC Holdings plc Annual Report and Accounts 2020 225

Corporate governance 
Report of the Directors | Corporate governance report

Throughout 2020, the GRC proactively encouraged principal 
subsidiary risk committee chairs to participate in regular GRC 
meetings and special review or learning sessions, leading to 
improved connectivity between the Group and principal subsidiary 
risk committees. In addition the GRC Chair participated in the 
meetings of principal subsidiary risk committees for Asia, the UK, 
Europe, the US, Latin America, Canada and the Middle East, with 
the aim of ensuring strong alignment, information sharing and 
connectivity between the GRC and principal subsidiaries.

Collaboration between the GRC and GAC

The GRC worked closely with the GAC to ensure that there are no 
gaps in risk oversight, and that any areas of significant overlap are 
appropriately addressed by inter-committee coordination or joint 
meetings where appropriate. The GRC and GAC Chairs are 
members of both committees to further enhance connectivity, 
coordination and flow of information.

Audit and Risk Committee Chairs' Forum

The Audit and Risk Committee Chairs' ('ARCC') Forum meetings 
continue to be one of the more collaborative GRC and GAC 
exercises. The forum meetings promote shared risk and audit 
subject matter expertise, align Group and subsidiary priorities, 
support the subsidiary accountability framework and promote 
two-way connectivity between the Group and principal subsidiary 
risk and audit committees. The meetings are jointly hosted by the 
GAC and GRC Chairs and attended by members of the GAC and 
GRC, the Group Executive Committee (more than half of whom 
attended at least one meeting), several Group non-executive 
Directors, the chairs of principal and regional subsidiary audit and 
risk committees, together with non-executive Directors and senior 
management from those subsidiaries.

In May, the ARCC Forum provided updates through video calls 
with the Asia-Pacific region and a combined call with the Europe, 
Middle East and Americas regions. This was followed by three 
ARCC Forum calls for each of the Asia-Pacific, UK, Europe and 
Middle East, and Americas regions in September and November.

The ARCC Forums provided an important opportunity for the GRC 
to understand locally-specific issues and priorities with potential 
read-across to other areas and regions of the Group. They also 
served to help the GRC hear the observations, concerns and 
achievements from subsidiary risk and audit chairs, with a 
particular focus on pressing issues or concerns (such as the 
Covid-19 outbreak, business restructuring, or macroeconomic 
issues); where Group initiatives need to be recalibrated to reflect 
regional constraints; cross-regional dependencies; and where the 
Group can progress faster. In light of the Covid-19 pandemic and 
highly uncertain macroeconomic environment, the ARCC Forum 
meetings included discussion on: 

• reinforcing the control environment and embedding of non-

financial risk management;

• sustaining operational integrity and resilience during a Covid-19 

and restructuring environment;

• need for even stronger risk appetite, credit, counterparty and 

conduct risk management during a Covid-19 and 
macroeconomic-sensitive environment;

• strengthening model risk management and our portfolio of 

models at the Group level and in the regions;

• subsidiaries’ role and responsibilities in our Group recovery and 

resolvability planning in a more macroeconomic-sensitive 
environment; and

• understanding the perspectives and feedback from regional 

subsidiaries.

Focus of future activities

The GRC’s focus for 2021 will include the following activities. It 
will:

• provide oversight of the execution risk arising from the Group 

transformation programme;

• oversee enhancements to our risk appetite statement so that it 

is more regular, forward-looking and risk responsive; 

• ensure the risk appetite statement is closely linked to our 

strategic goals, our annual operating plan, stress testing, ILAAP 
and ICAAP exercises, and our recovery and resolution planning;

• monitor and appropriately challenge management’s plans to 
manage and mitigate the impacts of geopolitical risks on our 
operations and portfolios in Asia, the Middle East and the rest 
of the world;

• monitor the impact of the Covid-19 outbreak on the Group’s 

customer franchise as well as on the capital and liquidity risk, 
credit risk, market risk, people and operational risk for the 
Group;

• monitor continued progress in financial crime compliance, 
including enhancements in our transaction monitoring 
programme and the application of new analytical tools and 
applications to improve our fraud detection and prevention;

• continue to monitor developments and enhancements in the 

Group’s management of conduct and culture, as well as people 
risk management;

• continue to review and challenge management’s progress in 
developing and implementing our operational resilience 
strategy;

• oversee the Group’s approach to climate risk management and 

climate risk appetite;

• review plans, jointly with the GAC, to strengthen the Group’s 

data strategy and management so that we can better serve our 
customers, protect customer data as well as strengthen model 
risk management, credit risk management and risk appetite, 
including climate risk appetite; and

• track progress regularly in remediating outstanding, unresolved 
regulatory actions across the Group and principal subsidiaries, 
including progress in closing-out any regulatory consent orders 
or matters requiring attention.

Committee evaluation

The GRC is committed to regular, independent evaluation of its 
own effectiveness. During 2020, the GRC undertook an internal 
GRC effectiveness exercise, which concluded that the GRC 
continued to operate effectively and in line with regulatory 
requirements.

The effectiveness exercise highlighted improvements made in 
2020 to anchor meetings with the regular review of the Group’s 
risk landscape and management information. Progress made in 
relation to the Committee’s operation and engagement with 
principal subsidiaries was acknowledged. The review also made 
certain recommendations for enhancement, including in relation to 
rebalancing the breadth of the GRC agenda, and increasing the 
use of alternative mechanisms to allow the GRC to efficiently 
exercise oversight of risk matters through additional education and 
supplementary sessions. The Committee has considered and 
discussed the outcomes of the evaluation and accepts the 
findings.

The outcomes of the evaluation have been reported to the Board 
and the Committee will track progress on the recommendations 
during 2020.

226 HSBC Holdings plc Annual Report and Accounts 2020

 
Principal activities and significant issues considered during 2020

Areas of focus

Key issues

Conclusions and actions

The Group risk appetite statement defines the 
Group’s risk appetite and tolerance thresholds and 
forms the basis of the first and second lines of 
defence’s management of risks, our capacity and 
capabilities to support our customers, and the 
pursuit of the Group’s strategic goals

Geopolitical developments and risks continue to 
present significant challenges for the Group’s 
customer franchise and for the resilience of our 
operations.

Managing operational risk and counterparty credit 
risk to enable the Group’s support of our 
customers, communities and the local economy 
throughout the Covid-19 outbreak.

Management’s operational resilience programme 
is being redesigned to enable our priority business 
services to continue to serve our customers in the 
event of unforeseen disruptions in our key 
markets. 

The GRC undertook its biannual risk appetite review and recommended the Group’s 
2020 risk appetite statement to the Board with enhancements to both financial and 
non-financial risk metrics. It then continued to work closely with Group Risk Strategy 
to enhance the 2021 risk appetite statement including a climate risk qualitative 
statement and quantitative measures that focus on the Group's exposure and risk 
profile to high transition risk sectors, as well as improvements to the suite of 
resilience risk metrics. The GRC also raised the importance of strengthening the 
granularity risk appetite statements to be forward-looking and risk-responsive at 
GRC meetings and at regional ARCC Forums. In the process, the GRC has reinforced 
the importance of stronger linkage of the risk appetite statements to the Group’s 
annual operating plan, strategic planning, stress testing exercises, annual capital 
adequacy and liquidity management exercises, and to the Group’s recovery and 
resolution planning.  

The GRC reviewed the Group’s readiness to address major geopolitical 
developments, including the short- and longer-term impact of civil unrest in Hong 
Kong and heightened trade tensions between the US and China on our Asia and 
global franchise, as well as our ability to maintain our high service levels in our 
multi-channels to serve our customers. The GRC also monitored the Group’s 
preparedness for financial market, operational and commercial disruptions arising 
out of protracted UK trade negotiations with the EU.

The GRC reviewed how the Group leveraged its capital and liquidity strength, robust 
credit standards, and digital capabilities to assist customers during the Covid-19 
outbreak and to maintain market strength. In doing so, the Committee closely 
assessed credit trends, economic outlook and the impact on portfolio credit quality. 
The GRC also reviewed the operational, reputational and conduct challenges in 
implementing government support schemes across different geographies and 
regulatory jurisdictions, including associated risks, controls and oversight.

The GRC maintained its focus on the Group’s policies, programmes and practices for 
strengthening and prioritising our ability to test, detect, resolve and recover from 
unforeseen operational disruptions in our key markets. With the goal of minimising 
harm to our customers and to the local financial markets, the GRC continued its 
review of the Group’s approach to operational resilience, which incorporates 
learnings from the Group's response to the Covid-19 outbreak across our franchise. 
The GRC’s oversight activities included:
• the review and challenge of progress on the formulation of a comprehensive 

operational resilience strategy including working with the Group Chief Control 
Officer on the programme to comply with regulatory standards for operational 
resilience; 

• the planned 'operationalisation' of critical business services and impact 

tolerances, and risk and control mapping to strengthen the ability to prevent, 
respond to, recover, and learn from operational disruptions, such as Covid-19;

• the embedding of ownership with first line business and function leaders to 

deliver operational resilience outcomes for customers, for the Group’s own safety 
and soundness, and to avoid disruptions to market integrity and financial stability; 
and

• the review and challenge of management’s progress in managing third-party risk 
in the context of an increasing reliance on technology services provided by third 
parties and growing regulatory scrutiny. 

Technology resilience is the risk of unmanaged 
disruption to any IT system within HSBC, as a 
result of malicious acts, accidental actions or poor 
IT practice or IT system failure.

The GRC reviewed the Committee’s approach to governance of technology risk and 
Cloud adoption, which was a high priority area under regulatory scrutiny. The GRC 
also continued its oversight and challenge of the Group’s cybersecurity strategy and 
management of cyber risks.

Risk appetite

Geopolitical 
developments 
and risks

Managing 
through the 
Covid-19 
outbreak

Operational 
resilience

Technology 
resilience 
including 
cybersecurity 
and Cloud 
strategy

The Group promotes a culture that is effective in 
managing risk and leads to fair conduct 
outcomes. 

It seeks to actively manage the risk of adverse 
impact due to not having the right people with  
the right skills doing the right thing, including 
risks associated with employment practices and 
relations.

People, conduct 
and culture

The GRC continued to exercise oversight in the area of people risk and employee 
conduct, supported by the Group Chief Human Resources Officer and Group 
business heads, including:
• regular monitoring of the Group’s progress in remediating the market conduct 

issues underlying the 2018 deferred prosecution agreement with the US 
Department of Justice and the related 2017 Federal Reserve Bank Consent Order;

• informed review and challenge of the alignment of risk and reward, satisfying 
itself that risk and compliance objectives and outcomes were reflected in the 
Group variable pay pool;

• discussion of the people risk issues arising due to the impact of the Covid-19 

outbreak; and

• the review of workplace harassment data and insights, action taken and 2020 

focus areas. 

HSBC Holdings plc Annual Report and Accounts 2020 227

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Principal activities and significant issues considered during 2020 (continued)

Areas of focus

Key issues

Conclusions and actions

Successful delivery of HSBC’s climate ambition 
will be determined by our ability to measure and 
manage all components of climate risk.

Climate risk

The GRC recognises the Group’s regulatory commitments due in 2021 and the 
Group’s own publicly stated climate risk targets, as well as the need to manage 
climate risk of the Group’s existing portfolios and future business. The GRC reviewed 
the Group’s approach to climate risk management and climate risk appetite 
including associated stress testing and scenario analysis.

The GRC oversees the Group’s management of its 
financial risk, particularly in the context of the 
challenges of the Covid-19 outbreak. 

The Group is committed to closely monitoring and 
managing the risk of knowingly or unknowingly 
helping parties to commit or to further potentially 
illegal activity, including both internal and external 
fraud. 

Capital and 
liquidity risk
including ICAAP 
and ILAAP

Financial crime 
risk

HSBC faces risk from the inappropriate or 
incorrect business decisions arising from the use 
of models that have been inadequately designed, 
implemented or used, or from models that do not 
perform in line with expectations and predictions.

Model risk

HSBC is required to show how its resolution 
strategy could be carried out in an orderly way, 
including identification of any risks to successful 
resolution.

Resolvability

The GRC reviewed the Group’s capability to track environmental and 
macroeconomic headwinds through early warning indicators and scenario stress 
testing. It also oversaw the Group’s progress in developing a range of strategic 
management actions capable of timely execution and the development of recovery 
and resolution capabilities that meet PRA and local regulatory expectations. The 
GRC also maintained oversight of the Group’s liquidity risk management with 
particular emphasis on the outlook, lessons learned from the Covid-19 outbreak, 
metric development, systems and controls, and regulatory feedback.

The GRC reviewed and challenged the assessment of the Group ICAAP and ILAAP 
programmes and engaged with Group management in overseeing and evaluating 
the Group’s forward-looking capital and liquidity strategies and capabilities, 
including the Group’s liquidity risk management improvement programme. 
Additionally, the GRC Chairs participated in several subsidiary risk committees’ 
review of ICAAP, leading up to final GRC review, challenge and recommendation of 
ICAAP to the Board.

Throughout 2020, the GRC reviewed the Group’s approach to managing its financial 
crime risk across a number of important areas. This included: 
• the Group’s progress in enhancing its transaction monitoring framework; 
• the fraud landscape, particularly against heightened Covid-19 conditions, the 
Group’s fraud risk profile and the impact of regulatory developments; and 
• the nature and scale of insider risk and the Group’s strategies for managing 

insider risk.

The GRC also maintained oversight of the ever-changing and increasingly complex 
international sanctions landscape in which the Group and its customers operate, as 
well as the Group’s approach to managing its compliance with sanctions regimes 
globally. The GRC held a full-day training session on sanctions in Hong Kong in 
January for our Asia-Pacific non-executive Directors and management. A further 
education session on sanctions was held for Group-wide non-executive Directors in 
October to address the US government imposition of sanctions in connection with 
its Hong Kong Autonomy Act.
Following the organisational restructuring of Financial Crime Compliance, the GRC 
requested the Committee’s independent financial crime advisers to examine the 
effectiveness of the financial crime function in the Group’s subsidiaries. 

The GRC raised awareness of progress and importance of models at a number of its 
meetings and at the regional Audit and Risk Committee Chairs’ Forums. It reviewed 
progress under the Group’s model risk transformation programme. The Committee 
oversaw the development and embedding of improved model risk management 
controls and oversight in the first line of defence, as well as enhancements to model 
risk governance. The GRC also considered the adverse impact of the Covid-19 
outbreak on model uncertainty including the need for enhancements as necessary.

The GRC monitored the Group’s progress in demonstrating that it has developed 
capabilities to support its own resolution, in line with the Group’s resolution strategy 
in order to meet new requirements from the Bank of England under its resolvability 
assessment framework by 1 January 2022, including the requirement to comply with 
the valuation in resolution requirement by 1 April 2021, to submit a self-assessment 
to the PRA/Bank of England by 1 October 2021 and to publicly disclose HSBC’s 
resolvability in June 2022. Together with the Group Chief Financial Officer, the GRC 
and GAC programmed our five regional Audit and Risk Committee Chairs' Forums to 
raise the importance of Boards and management of principal subsidiaries in 
upgrading their awareness and compliance with new regulatory standards for 
recovery and resolution. 

228 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Directors’ remuneration report

Membership

Group Remuneration Committee

Workforce remuneration

Our approach to Directors' remuneration

Annual report on remuneration

Additional remuneration disclosures

Page

232

233

235

239

253

All disclosures in the Directors’ remuneration report are unaudited 
unless otherwise stated. Disclosures marked as audited should be 
considered audited in the context of financial statements taken as 
a whole.

'The remuneration outcomes for 2020 strike the right balance between 
rewarding our employees for their exceptional efforts this year and being 
equitable in the broader context.'

Dear Shareholder 

I am pleased to present our 2020 Directors’ remuneration report 
on behalf of the members of the Group Remuneration Committee.

Making remuneration decisions in the face of the challenges 
presented by the Covid-19 pandemic required a delicate balancing 
of factors. Recognising our people for their performance is a key 
element of our reward strategy and helps to drive ongoing 
engagement, which is critically important as we navigate through 
the Covid-19 outbreak and the Group’s transformation. However, 
we must also recognise the impact of these circumstances on our 
stakeholders and the wider community.

Actions taken in response to Covid-19

In determining the remuneration outcomes, the Committee noted 
the following: 

• We did not apply for government support packages for our 
employees across the countries and territories in which we 
operate, and put employee well-being, customer experience, 
and supporting the economy at the centre of our response to 
the pandemic.

• Our front-line employees continued to serve customers in 

challenging circumstances. Our customer contact centres were 
fully operational during the period, and between 70% and 90% 
of branches remained open, as we continued to enhance our 
digital capabilities.

• We worked with governments to support national schemes, 
granting over 720,000 payment holidays to our personal 
customers and 237,000 loans to our wholesale customers. We 
provided more than $26bn in customer relief to our personal 
customers during the initial stages of the pandemic and more 
than $52bn in lending to wholesale customers, many of whom 
still require our support.

• In line with all other large UK-based banks and at the direct 
request of the Group’s lead regulator, the UK’s PRA, we 
cancelled the fourth interim dividend of 2019 and suspended 
dividend payments until the end of 2020. In December 2020, 
the PRA announced a temporary approach to shareholder 
distributions for 2020. After considering the requirements of the 
temporary approach, the Board announced an interim dividend 
for 2020 of $0.15 per ordinary share.

Member since

Meeting attendance in 
2020

Pauline van der Meer Mohr (Chair)

Henri de Castries

James Forese

Irene Lee

David Nish

Jan 2016

May 2017

May 2020

Apr 2018

May 2017

5/5

5/5

4/4

5/5

5/5

Reflecting on these actions, the Committee concluded that the 
2020 remuneration outcomes should strike the right balance 
between rewarding our employees for their exceptional efforts this 
year and being equitable in the broader context.

Performance and pay for 2020

Financial performance

The Group's financial performance deteriorated in 2020, reflecting 
the impact of the Covid-19 outbreak on the global economy. 
Adjusted profit before tax of $12bn was down 45% due to lower 
revenue and a higher expected credit loss charge directly linked to 
the impact of the pandemic.

However, the Group continued to make good progress on its 
strategic plan, demonstrated by a $51.5bn reduction of RWAs in 
2020 in low-return franchises and a 3% reduction in adjusted 
costs. Economic activity in Asia has proven to be resilient and is 
rebounding. We continue to elevate our ambition in the region by 
stepping up our investment.

Non-financial performance

We made progress in creating a simpler, more efficient 
organisation by combining our wholesale back office operations, 
and bringing our retail, wealth and private banking businesses 
together into a single global business. We also continue to 
increase investment in technology to drive improved customer 
experience and operational efficiency. Technology enhancements 
introduced in 2020 included automated lending processes for 
Covid-19 relief programmes, upgraded global payment systems, 
transformed customer onboarding processes, and use of Cloud 
technology for risk analytics systems. 

Remuneration funding approach

While events such as those seen in 2020 are rare, our 
remuneration framework was designed with the entire economic 
cycle in mind, including the possibility of exceptional years. We 
use a countercyclical funding methodology, with both a floor and 
a ceiling, to recognise that there will be times when profitability is 
exceptionally low or exceptionally high as a result of factors not 
directly linked to employee performance. In such years, factors 
such as applying franchise protection and limiting the risk of 
inappropriate behaviour need to be considered when setting the 
variable pay pool. Nonetheless, financial performance and 
affordability remain central tenets in determining the 
appropriateness of the variable pay pool.

Group variable pay pool

For 2020, the Committee reviewed and agreed the Group variable 
pay pool of $2,659m, taking into account performance against 
financial and non-financial metrics set out in the Group risk 
appetite statement, including conduct, and targets set out in our 
operating plan. This represents a 20.4% reduction in the pool 
compared with 2019, with the variable pay pool down 
approximately 15% in Global Banking and Markets, asset 
management and private banking, and approximately 22.5% in 
other areas of the Group. We also differentiated by market, with a 
better year-on-year outcome in Asia, reflecting the region's 
strategic importance and consistent contribution towards Group 
performance.

In determining the size of the pool, the Committee took into 
account the fact that overall financial performance was lower than 
what we had targeted at the start of the year, and certain non-
financial risk metrics were outside of our risk appetite. We also 
took into account the exceptional circumstances faced by our 
shareholders, including the impact of the regulatory request to 

HSBC Holdings plc Annual Report and Accounts 2020 229

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Report of the Directors | Corporate governance report

cancel the final 2019 dividend and suspend dividend payments 
until the end of 2020.

While it is appropriate that the pool is significantly lower this year, 
the Committee was cognisant of the extraordinary effort and 
performance of many of our colleagues in 2020. Equally, it is 
critical we retain talent for the long-term interests of our 
stakeholders. This is of particular importance in growth markets 
and our areas of strategic focus, and is most acute for our high 
performers who are helping us restore the business to our 
expected performance levels. As a result, the variable pay accrual 
was increased in the fourth quarter in response to financial 
performance and market pay challenges.

Review of workforce remuneration

Remuneration outcomes

In allocating the pool, the Committee decided that while the 
variable pay outcomes for junior colleagues should reflect Group 
performance, they should receive better outcomes with less 
differentiation relative to our senior employees. Overall, total 
compensation for our junior members of staff was broadly flat, 
which we felt was important given their significant efforts in a 
challenging year. Higher paid employees had an overall decrease 
in total compensation. We also made limited fixed pay increases 
for 2021 and targeted these towards our junior colleagues. As part 
of the year-end pay review, the Committee reviewed results of 
remuneration outcomes to ensure they were in line with our pay 
principles and the approach decided by the Committee for 2020.

Support for our employees

Throughout 2020, the well-being of our people was our paramount 
concern. Many employees had to juggle personal and professional 
priorities, while adapting to new and unfamiliar ways of working. 
In March 2020, we temporarily paused the redundancy 
programme intended to deliver the reduction in headcount that we 
set out in the transformation programme announced in February 
2020. The Board was conscious of the impact of proceeding with 
redundancies, particularly at the outset of the crisis given the 
significant stress for our people and communities, and the need to 
protect our capacity to serve our customers. The Board lifted the 
pause on the redundancy programme in June 2020 while 
continuing the freeze on the vast majority of external recruitment 
to make every effort to fill vacancies internally. We maintained a 
regular flow of communication and listened closely to our 
colleagues' needs, providing the support and flexibility required to 
help them manage their lives during the pandemic, and 
maintained their full pay without applying for government support 
packages. 

We ran a mid-year employee survey to determine how the 
Covid-19 outbreak was impacting our colleagues and how we 
could support them through this period. More than 50% of our 
total employee population responded, of which more than 89% 
said they were getting the information they needed from the 
organisation, 86% reported that they were getting the support 
they needed from their line manager and 86% of the respondents 
reported they felt confident in leadership. In addition, 75% of 
employees that participated in our 2020 Snapshot survey said they 
believed HSBC values their well-being.

For our departing colleagues, we took steps to offer them support 
on searching and applying for jobs and preparing for interviews. 
We also maintained a dedicated advice website, offered virtual 
workshops and provided access to career development tools to set 
them up for success outside HSBC.

Key remuneration decisions for Directors 

Voluntary decisions made by executive Directors

Reflecting on the severity of the impact of Covid-19 at the outset, 
our two executive Directors made personal contributions to the 
fight against the pandemic by donating to charity a quarter of their 
base salaries for six months, and our Group Chairman donated his 
entire fee for 12 months to charity. Additionally, as an 
organisation, we provided $25m in charitable donations, which 
went toward immediate medical relief, access to food, and care 

230 HSBC Holdings plc Annual Report and Accounts 2020

for the most vulnerable people. Our executive Directors also 
decided to voluntarily forgo any annual cash bonus for 2020 due 
to the impact of the suspension of dividends on our shareholders.

Executive Director annual performance assessment

With regard to performance-based pay for 2020, the financial 
measures in the executive Directors’ annual scorecards were 
aligned to the delivery of profit before tax, our strategic priority of 
reducing RWAs in low-return franchises and, for the Group Chief 
Financial Officer, effective management of Group costs. Following 
careful consideration, these targets were not revised for the 
significant economic impact of the Covid-19 outbreak to reflect 
the Committee’s view that reward for our executive Directors 
should align with the experience of our shareholders.   

Non-financial performance measures were linked to customer 
satisfaction, employee engagement and diversity, environmental 
stewardship, risk and compliance, and organisational 
simplification. The Committee noted strong non-financial 
performance as our commitment to delivering responsibly for our 
stakeholders remained unchanged throughout the pandemic. In 
addition to the actions noted to support our customers and the 
wider economy, customer and digital satisfaction scores increased 
in some of our scale markets, employee engagement scores 
improved, we met our diversity goal of having at least 30% 
women in senior management roles, and we achieved carbon 
reduction and sustainable finance and investment targets. We 
were also recognised by Euromoney for ‘Global Excellence in 
Leadership during the Covid-19 pandemic’ in its Awards for 
Excellence 2020.

Executive Director annual incentive scorecard outcome

The above resulted in an overall outcome of 64.50% for the Group 
Chief Executive and 63.75% for the Group Chief Financial Officer 
(further details of performance are provided on page 240). The 
Committee reviewed this outcome in the context of a number of 
internal and external considerations to determine whether it 
should exercise its discretion to reduce the outcome, including:

• overall share price performance in the year, which was 

significantly impacted by both the Covid-19 outbreak and the 
impact of the PRA’s request to suspend dividend payments;

• the impact of the bonus pool reduction on the total 

compensation for our wider workforce; 

• profit before tax and return on tangible equity ('RoTE') 

performance; and

• the positive actions taken by the Board to support our 

customers, colleagues and communities in these uncertain 
times.

The Committee determined the 2020 formulaic scorecard 
outcomes appropriately reward the executive Directors for their 
performance within the context of overall stakeholder experience. 
With the voluntary waiver of cash bonuses by executive Directors, 
the Group Chief Executive's effective payout was reduced to 
32.25% of its maximum, and the Group Chief Financial Officer's 
was reduced to 31.88%. The effective payouts are 51.43% and 
58.86% below their respective outcomes compared with 2019.

2020 long-term incentive ('LTI') for executive Directors

To reflect the Group’s strategy, and after listening to our 
shareholders, the Committee has agreed that the 2020 LTI will be 
based on four equally weighted measures.

• RoTE: We have retained a key measure of our financial 

performance and how we generate returns that deliver value 
for our shareholders.

• Capital reallocation to Asia: We have set a new metric to assess 
a key lever of our strategy and business transformation plan.

• Environment and sustainability: We have set a new measure to 

align with the Group’s climate ambition to bring our own 
operations to net zero by 2030 and support our customers in 
their transition to a more sustainable future. 

• Relative total shareholder return: We have retained this metric, 
which rewards executive Directors based on comparison of the 

 
total shareholder return performance of the Group and a 
relevant peer group.

2020 LTI grant size

The Committee is aware of shareholders’ expectations on the need 
to adjust the size of LTI awards to ensure they do not result in 
'windfall gains' in the event that the share price falls significantly 
due to the impact of the Covid-19 outbreak. While this does not 
impact outstanding LTI awards, the Committee agreed, in line with 
investor expectations, that the 2020 LTI awards should be subject 
to a 'windfall gain' adjustment at grant if the share price falls 
significantly relative to the grant price of the 2019 LTI. This is to 
ensure that the reward for our executive Directors aligns with the 
experience of our shareholders and is reflective of management 
performance over the performance period.

While the share price to be used for the 2020 LTI award is not 
known at this stage, the Committee has agreed, in line with 
investor expectations, if the 2020 LTI grant share price 
experiences a greater than 30% decline since the previous grant, 
this would be considered a material share price fall, and an 
adjustment percentage equal to half the share price percentage 
decline would be applied to the awards to mitigate the potential 
for 'windfall gains'.

Executive Directors' fixed pay for 2021

We have increased the base salary of our executive Directors by 
1.6% in line with the average increase for our Group employees. 
Additionally, in an expansion to his current remit, the Group Chief 
Financial Officer will assume responsibility for the Group’s 
transformation programme, effective immediately, and its mergers 
and acquisitions agenda, from April. In acknowledgement of the 
expanded remit and responsibilities, the Committee has decided to 
adjust his fixed pay allowance from £950,000 to £1,085,000 in 
accordance with the terms of the Directors’ remuneration policy 
approved at the 2019 AGM. The executive Directors have made 
the personal decision to donate 100% of their salary and fixed pay 
allowance increases for 2021 to charity given the ongoing 
challenging external environment.

Investor consultation

The Committee considers that regular dialogue with our 
shareholders, including outside of our policy vote years and 
especially during these uncertain times, is important to ensure our 
remuneration policy operates as intended and in line with 
shareholder expectations. In 2020, we met with a number of our 
significant shareholders and proxy voting agencies to hear their 
views on executive and wider workforce remuneration. As ever, 
we found this engagement to be very helpful as we considered the 
implementation of our remuneration policy, including the 'windfall 
gain' adjustment for the 2020 LTI award, and use of ESG 
measures in the forward-looking scorecards. Further details of the 
2020 LTI measures and targets are on page 243. The 2021 annual 
incentive scorecard is provided on page 249.

On behalf of the Committee, I would like to thank investors for 
their time during the consultations and their support for the 
direction of travel. 

The Group’s Directors’ remuneration policy is due to expire at the 
2022 AGM. During the course of 2021, we will be reviewing our 
current approach to Directors’ remuneration and will consult with 
our large shareholders and proxy advisory bodies with the aim of 
introducing a new policy in 2022. The review will continue to be 
based on our following key principles:

• The policy should be simple and transparent.

• There should be a strong alignment between rewards and the 

interests of our stakeholders, including shareholders, 
customers and employees.

• The policy should maintain a focus on long-term performance.

• The total compensation package should be competitive to 

ensure we can retain and attract talent.

• The structure should meet the expectations of investors and 

our regulators.

The Committee is concerned that over time, HSBC’s overall 
remuneration opportunity has fallen behind desired levels to 
reflect the calibre of the executives and market positioning. While 
conscious of external sentiment, one of the areas of focus for the 
Committee will therefore be ensuring that overall remuneration 
levels remain appropriate in the context of the above and support 
delivery of our strategic priorities. Any proposed changes would 
be discussed with shareholders and the proxy advisory bodies as 
part of the wider consultation on the remuneration policy in 2021. 

Our annual report on remuneration

As Chair of the Committee, I hope you will support the 2020 
Directors' remuneration report.

Pauline van der Meer Mohr

Chair

Group Remuneration Committee

23 February 2021

HSBC Holdings plc Annual Report and Accounts 2020 231

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Report of the Directors | Corporate governance report

Group Remuneration Committee

The Group Remuneration Committee is responsible for setting the 
overarching principles, parameters and governance of the Group's 
remuneration framework for all employees, and the remuneration 
of executive Directors, the Group Chairman and other senior 
Group employees. The Committee regularly reviews the 
framework in the context of consistent and effective risk 
management, and the regulatory requirements of multiple 
jurisdictions.

Matters considered during 2020

No Directors are involved in deciding their own remuneration. All 
members of the Committee are independent non-executive 
Directors of HSBC Holdings. A copy of the Committee’s terms of 
reference can be found on our website at www.hsbc.com/our-
approach/corporate-governance/board-committees.

The Committee met five times during 2020. James Forese was 
appointed as a member of the Committee on 1 May 2020. David 
Nish stepped down as a member of the Committee on 23 February 
2021. The following is a summary of the Committee’s key 
activities during 2020.

Remuneration framework and governance
Group variable pay pool, workforce performance and pay matters, Gender Pay Gap report, and employee surveys

Executive Director remuneration policy implementation, scorecards and pay proposals

Remuneration for other senior executives of the Group

Non-executive Director compensation
Shareholder consultation and proxy adviser views
Directors’ remuneration report

Regulatory, risk and audit

Information on material risk and audit events, and performance and remuneration impacts for individuals involved

Regulatory updates and filings, including approach and outcomes for the identification of Material Risk Takers

Jan

May

Jul

Sep

Dec

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Corporate governance briefings
Principal subsidiaries
Matters from subsidiary committees

Advisers

The Committee received input and advice from different advisers 
on specific topics during 2020. Deloitte LLP’s engagement with 
the Committee was extended during 2020. The Committee’s 
decision reflected the quality and objectivity of the independent 
advice that Deloitte had provided to the Committee on 
remuneration matters. Deloitte provided benchmarking data on 
remuneration policy matters and independent advice to the 
Committee. Deloitte also provided tax compliance and other 
advisory services to the Group. 
The Committee also received advice from Willis Towers Watson 
on market data and remuneration trends for senior management. 
Willis Towers Watson was appointed as remuneration adviser by 
management after considering invited proposals from similar 
consultancy firms. It provides actuarial support to Global Finance 
and benchmarking data and services related to benefits 
administration for our Group employees. To ensure the advice 
from Deloitte and Willis Towers Watson was objective, the 
Committee required the advice to be independent and distinct 
from any internal review and analysis on remuneration policy 
matters. The Committee was satisfied the advice provided by 
Deloitte and Willis Towers Watson was objective and independent 
in 2020. Deloitte is a founding member of the Remuneration 
Consultants Group and voluntarily operates under the code of 
conduct in relation to executive remuneration consulting in the 
UK.
For 2020, total fees of £173,900 and £68,289 were incurred in 
relation to remuneration advice provided by Deloitte and Willis 
Towers Watson, respectively. This was based on pre-agreed fees 
and a time-and-materials basis.
Attendees and interaction with other Board 
committees

During the year, Noel Quinn as the Group Chief Executive provided 
regular briefings to the Committee. In addition, the Committee 
engaged with and received updates from the following:
• Mark Tucker, Group Chairman;

• Elaine Arden, Group Chief Human Resources Officer; 

• Alexander Lowen, Group Head of Performance Management, 

Reward, Human Resources Transformation and People 
Analytics; 

• Pam Kaur, Group Chief Risk Officer;

• Colin Bell, Group Chief Compliance Officer;  

232 HSBC Holdings plc Annual Report and Accounts 2020

• Jonathan Calvert-Davies, Group Head of Audit; and 

• Aileen Taylor, Group Company Secretary and Chief Governance 

Officer.

The Committee also received feedback and input from the Group 
Risk Committee and Group Audit Committee on risk, conduct and 
compliance-related matters relevant to remuneration.
Review of workforce remuneration and related 
policies

In light of the year's challenging circumstances, the Committee's 
review and approval of the workforce remuneration strategy was 
particularly focused on ensuring protection for our junior 
employees and delivering appropriate pay differentiation for those 
areas of the business that performed well.
The Committee also reviewed the results of remuneration 
outcomes across the Group to ensure they were in line with our 
pay principles (as set out on page 233). This included details of 
variable remuneration adjustments and information on reward 
outcomes by performance and behaviour ratings. The Committee 
uses this information to assess the effectiveness of our 
remuneration framework and whether our framework aligns 
employee rewards with our values.
We measure our employees’ sentiment on performance and pay 
matters through our annual pay review surveys. In the first half of 
2020, the Committee reviewed the results of the most recent 
survey. A significant proportion of the respondents’ comments 
indicated improved sentiment towards our pay review process. 
The majority of employees believed their year-end ratings were a 
fair reflection of their performance and behaviour, and felt 
motivated to perform at their best following their performance 
review.

Committee effectiveness

The annual review of the effectiveness of the Board committees 
was internally facilitated during 2020. Overall, the review 
concluded that the Group Remuneration Committee continued to 
operate effectively, with a number of positive aspects of the 
operation and practices highlighted by the review. There were also 
areas of improvement identified, including the engagement 
dynamic with advisers. The Committee has considered and 
discussed the outcomes of the evaluation, and accepts the 
findings with a number of actions to address them already in 
progress. The outcomes of the evaluation have been reported to 
the Board and the Committee will track progress against the 
recommendations during 2021.

 
 
 
Our approach to workforce remuneration

Remuneration principles

Our performance and pay strategy aims to reward competitively the achievement of long-term sustainable performance by attracting, 
motivating and retaining the very best people, regardless of gender, ethnicity, age, disability or any other factor unrelated to performance 
or experience. It supports our people to perform their roles in the long-term interests of our stakeholders, which includes the customers 
and communities we serve, our shareholders and our regulators. The strategy is underpinned by: 

• decisions that are fair, appropriate and free from bias;

• a culture supportive of continuous feedback through manager and employee empowerment; 

• reward and recognition of sustainable performance and values-aligned behaviour; and

• a balanced, simple and transparent total reward package that supports employee well-being.

Spotlight on 2020: Our response to the Covid-19 outbreak 

These principles were key to facilitating the agile approach we took to pay and performance in response to the Covid-19 outbreak. In 
response to the challenging circumstances our colleagues faced, we offered them increased practical support, recognised them for their 
exceptional response to our customers and each other, and helped to ensure fair and appropriate treatment.

Appropriate practical support for our colleagues
• We took a country-based approach to our response to ensure that what we provided to our employees was appropriate for the 

conditions and restrictions in place in their location. 

•

Our priority was to support the well-being of our employees using a range of initiatives focusing on:

– enabling employees to work flexibly to support additional caring responsibilities;
– ensuring employees could purchase the equipment they needed to work from home wherever possible;
– providing financial assistance to employees who may have incurred additional costs, for example where normal commuting or 

onsite catering services were disrupted; and

– supporting mental and physical well-being with employee assistance programmes, access to Covid-19-related private medical 

treatment and flu vaccination initiatives.

• More than 50% of our total employee population responded to our mid-year employee survey. Of those who responded, 86% of 

employees reported they were getting the support they needed from their line manager, and 83% said they believed HSBC valued 
their well-being.

Recognising the exceptional response 
• We ran a ‘Spotlight’ campaign within our ‘At Our Best Recognition’ points programme that focused on recognising our Covid-19 

Heroes.

•

There were over 169,000 colleague recognitions made over a three-month period, a threefold increase in recognitions compared 
with previous Spotlight campaigns that we have run.

Helping managers to make fair decisions
•

The majority of our people underwent a change in working pattern and/or location as a result of the Covid-19 outbreak. We 
wanted to ensure our people are always recognised against relevant and achievable objectives with allowance for barriers to 
performance outside of their control.

•

In response to the Covid-19 outbreak, we issued specific guidance for managing performance under some of the most common 
scenarios our people found themselves in, to support our managers in continuing to make performance decisions.

HSBC Holdings plc Annual Report and Accounts 2020 233

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Our approach to performance and pay in 2020 for the broader workforce was underpinned by our remuneration principles. 

Principle

Our approach in 2020 

•

Fair, 
appropriate 
and free from 
bias

Our communications to managers encouraged them to challenge their assessments by questioning whether they 
were objective and based on fact. Managers in similar roles then came together to complete fairness reviews of the 
performance and behaviour ratings of their team and make any necessary adjustments based on the review of the peer group to 
mitigate the risk of bias and take a broader view of team performance. 

• We supported managers, particularly the less experienced ones, to make informed, consistent and fair pay 

•

decisions. Managers of 96% of our junior employees are supported by simplified or guided decision making. 
As part of our annual performance and pay review process, we undertook analytical reviews to check for and identify bias, 
and provide these reports to our senior management and Group Remuneration Committee as part of their review of annual pay 
review outcomes. 

• We made pay and performance reporting tools available to our managers for the purpose of undertaking an analytical review of 

pay decisions for their team. We continue to enhance these based on manager feedback to make these tools useful and 
increase usage.

• We regularly review our pay practices and in 2020 worked with independent third parties to review equal pay. 
•

If pay differences are identified that are not due to an objective reason such as performance or skills and 
experience, we made adjustments.

• We seek to create a culture where our people can fulfil their potential, gain new skills and develop their careers for the 

•

future.
In 2020, we enhanced our continuous feedback culture, Everyday Performance and Development, which supported our 
people to have regular conversations with their line managers about items such as their performance, pay, development and well-
being throughout the year. 

• We launched our Continuous Performance Management tool, including on mobile, to make it easier for our people as 
team members and as managers to share activities, feedback, achievements and progress regularly to drive conversations. 
• We encouraged colleagues to use our online career planning tools to help them with their thinking about future roles and 

•

•

the capabilities they require.
Line managers were provided with clear guidance materials to support them in making fair and appropriate decisions at key stages 
in the performance and pay decision-making process. We were clear on the decisions that managers are empowered to 
own and provided them with principles to support such decision making.
Employees also received notifications and guidance throughout the performance and pay review period to support their 
understanding of what is expected of them and what they can expect.

A culture of 
continuous 
feedback 
through 
manager and 
employee 
empowerment

Reward and 
recognition of 
sustainable 
performance 
and values-
aligned 
behaviour

• We have a robust performance management process that underpins our approach to reward and drives clear pay 

•

•

differentiation.
Group and business unit performance is used in determining the Group variable pay pool and its allocation to each 
business unit. Where performance in a year is weak, as measured by both financial and non-financial metrics, this will impact 
the relevant pool, while the final pool also considers the external operating environment and expectation of our stakeholders. 
Assessment of individual performance is made with reference to a balanced scorecard of clear and relevant financial and 
non-financial objectives, including appropriate risk and compliance objectives. 

• We believe it is important to recognise our people not just for results, but also for upholding our values. As such, 

subject to local law, employees receive a behaviour rating as well as a performance rating to ensure performance is assessed not 
only on what is achieved, but also on how it is achieved.

• We undertake analytical reviews to ensure there is clear pay differentiation across both performance and behaviour 
ratings, which are provided to senior management and the Group Remuneration Committee as part of their oversight of the 
remuneration outcomes for the Group’s workforce. 

• We recognise examples of exceptional positive conduct through an increase in variable pay, and apply a reduction in 

•

variable pay for misconduct or inappropriate behaviour that exposes us to financial, regulatory or reputational risk.
Our global ‘At Our Best’ recognition programme allows our people to recognise their colleagues for demonstrating 
our values, with an award of recognition points that can be redeemed against a wide range of goods. Over one million peer-to-
peer recognitions were made globally in 2020.

• We promote employee share ownership through variable pay deferral or voluntary enrolment in an all-employee share plan, which 

assists with incentivising long-term sustainable performance.

Balanced, 
simple and 
transparent 
total reward 
packages, 
which support 
employee well-
being  

• We maintain an appropriate balance between fixed pay, variable pay and employee benefits, taking into consideration 

•

an employee’s seniority, role, individual performance and the market. We are informed, but not driven, by market position and 
practice. 
For the 2020 pay review process, we have prioritised fixed pay increases for our global career bands 6 to 8 population, 
where it represents a higher proportion of total compensation, and towards locations and business areas which are particularly 
integral to the execution of the Group’s strategy. 

• We are committed to employee well-being and offer employee benefits that support the mental, physical and financial health 

•

of a diverse workforce.
All HSBC employees that work in a jurisdiction with a legal minimum wage are paid at or above this amount. In 2014, 
HSBC in the UK was formally accredited by the Living Wage Foundation for having adopted the ‘Living Wage’ and the ‘London 
Living Wage’.

234 HSBC Holdings plc Annual Report and Accounts 2020

 
Our approach to Directors' remuneration

This section summarises our remuneration policy for executive and non-executive Directors. The policy was approved at the AGM on 
12 April 2019 and is intended to apply for three performance years until the AGM in 2022. The full remuneration policy, including the 
policy on payment for loss of office, can be found on pages 175 to 184 of our Annual Report and Accounts 2018 and the Directors' 
Remuneration Policy Supplement, which is available under Group Results and Reporting in the Investor Relations section of 
www.hsbc.com.

Remuneration policy summary – executive Directors

Elements and objectives

Operation

Base salary1

To attract and retain key talent by being 
market competitive and rewarding 
ongoing contribution to role.

• Base salary is paid in cash on a monthly basis.
• Other than in exceptional circumstances, the base salary for the current 

executive Directors will not increase by more than 15% above the level at 
the start of the policy period in total for the duration of the policy.

Fixed pay allowance (‘FPA’)1

To deliver a level of fixed pay required 
to reflect the role, skills and experience 
of the Directors and to maintain a 
competitive total remuneration package 
for retention of key talent.

• The FPA is granted in instalments of immediately vested shares.
• On vesting, shares equivalent to the net number of shares delivered (after 
those sold to cover any income tax and social security) are subject to a 
retention period and released annually on a pro-rata basis over five years, 
starting from the March immediately following the end of the financial year 
for which the shares are granted.

• Dividends are paid on the vested shares held during the retention period.

Cash in lieu of pension

To attract and retain key talent by being 
market competitive.

• Cash in lieu of pension is paid on a monthly basis as 10% of base salary.
• This allowance, as a percentage of salary, is not more than the maximum 
contribution rate, as a percentage of salary, that HSBC could make for a 
majority of employees who are defined contribution members of the HSBC 
Bank (UK) Pension Scheme.

Implementation in 2021

Base salary will be increased by 
1.6% in line with the overall 
increase for Group employees. 
Base salary from 1 March 2021 
will be as follows:
• Noel Quinn: £1,291,000
• Ewen Stevenson: £753,000

FPA for 2021 will be as follows:
• Noel Quinn: £1,700,000
• Ewen Stevenson: will increase 
from £950,000 to £1,085,000 
from 1 March 2021

• No change to percentage of 

base salary.

Annual incentive

To drive and reward performance 
against annual financial and non-
financial objectives that are consistent 
with the strategy and align to 
shareholder interests.

Long-term incentive ('LTI')

To incentivise sustainable long-term 
performance and alignment with 
shareholder interests.

• The maximum opportunity is up to 215% of base salary.
• Annual incentive performance is measured against an individual scorecard. 
• At least 50% of any award is delivered in shares, which are normally 

• See page 249 for details of 
performance measures.

immediately vested.

• On vesting, shares equivalent to the net number of shares that have vested 
(after those sold to cover any income tax and social security payable) will 
be held for a retention period of up to one year, or such period as required 
by regulators.

• Awards will be subject to clawback (i.e. repayment or recoupment of paid 

vested awards) for a period of seven years from the date of award, 
extending to 10 years in the event of an ongoing internal/regulatory 
investigation at the end of the seven-year period. Any unvested awards will 
be subject to malus (i.e. reduction and/or cancellation) during any 
applicable deferral period.

• The Committee retains the discretion to:

apply a longer retention period;
increase the proportion of the award to be delivered in shares; and

–
–
– defer the vesting of a portion of the award.

• The maximum opportunity is up to 320% of base salary.
• The LTI is granted if the Committee considers that there has been 

• See page 249 for further 

details.

satisfactory performance over the prior year.

• The LTI is subject to a forward-looking three-year performance period from 

the start of the financial year in which the awards are granted.

• At the end of the performance period, awards will vest in five equal 

instalments, with the first vesting on or around the third anniversary of the 
grant date and the last instalment vesting on or around the seventh 
anniversary of the grant date.

• On vesting, shares equivalent to the net number of shares that have vested 
(after those sold to cover any income tax and social security payable) will 
be held for a retention period of up to one year, or such period as required 
by regulators.

• Awards are subject to malus provisions prior to vesting. Vested shares are 
subject to clawback for a period of seven years from the date of award, 
extending to 10 years in the event of an ongoing internal/regulatory 
investigation at the end of the seven-year period.

• Awards may be entitled to dividend equivalents during the vesting period, 
paid on vesting. Where awards do not receive dividend equivalents, the 
number of shares awarded can be determined using the share price 
discounted for the expected dividend yield.

1  The executive Directors have made the personal decision to donate 100% of their increases to salaries and increases to their fixed pay allowances 

for 2021 to charity given the ongoing challenging external environment. 

HSBC Holdings plc Annual Report and Accounts 2020 235

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Report of the Directors | Corporate governance report

Remuneration policy summary – executive Directors

Elements and objectives

Operation

Implementation in 2021

Benefits

To provide benefits in accordance with 
local market practice.

• Benefits include the provision of medical insurance, accommodation, car, 
club membership, independent legal advice in relation to a matter arising 
out of the performance of employment duties for HSBC, tax return 
assistance or preparation and travel assistance (including any associated 
tax due, where applicable). 

• Benefits to be provided as per 

policy. Details will be 
disclosed in the Annual Report 
and Accounts 2021 single 
figure of remuneration table.

• Additional benefits may also be provided when an executive is relocated or 

spends a substantial proportion of his/her time in more than one 
jurisdiction for business needs.

Executive Directors are expected to satisfy the following shareholding 
requirement as a percentage of base salary within five years from the date of 
their appointment:
• Group Chief Executive: 400%
• Group Chief Financial Officer: 300%

Executive Directors are eligible to participate in all-employee share plans, 
such as HSBC Sharesave, on the same basis as all other employees.

• No change to percentage of 

base salary.

• Participation in any such plans 
will be disclosed in the Annual 
Report and Accounts 2021, as 
required.

Shareholding guidelines

To ensure appropriate alignment with 
the interest of our shareholders.

All-employee share plans
To promote share ownership by all 
employees.

Illustration of release profile

The following chart provides an illustrative release profile of remuneration for executive Directors.

Illustration of release profile

Fixed pay 
allowance • Released in five equal annual instalments 
starting from March 2021.

2020

2021

2022

2023

2024

2025

2026

2027

2028

2029 u

u

u

u

u

u

Annual 
incentive

• Paid 50% in cash and 50% in immediately vested 
shares subject to a retention period of one year.
• Subject to clawback provisions for seven years 
from grant, which may be extended to 10 years 
in the event of an ongoing internal/regulatory 
investigation.

Perform
-ance 
period

Retained 
shares

u u u

u

Clawback

• Award granted taking into consideration 

performance over the prior year and also subject 
to a three-year forward-looking performance 
period.

• Subject to performance outcome, awards will 
vest in five equal annual instalments starting 
from the third anniversary of the grant date1.
• On vesting, shares are subject to a retention 

Long-term 
incentive

period of one year.

• Unvested awards subject to malus provisions.
• Subject to clawback provisions for seven years 
from grant, which may be extended to 10 years 
in the event of an ongoing internal/regulatory 
investigation.

Performance 
period

Vesting period

u

u u

u

Retention period u

u

u

u

u

Malus

Clawback

u

u

u

u

u

u

1  The seven-year vesting period and the one-year post-vesting retention period applied to shares granted under the LTI aligns with the minimum 

five-year holding period expected by shareholders and under the UK Corporate Governance Code as the share awards will be released over a 
period of eight years with a weighted-average holding period of six years.

The table below details how the Group Remuneration Committee addresses the principles set out in the UK Corporate Governance Code 
in respect of the Directors' remuneration policy.

236 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Provision

Clarity

Remuneration arrangements should be transparent and 
promote effective engagement with shareholders and the 
workforce.

Simplicity

Remuneration structures should avoid complexity and their 
rationale and operation should be easy to understand.

Risk

Remuneration structures should identify and mitigate 
against reputational and other risks from excessive 
rewards, as well as behavioural risks that can arise from 
target-based incentive plans.

Predictability

The range of possible values of rewards to individual 
Directors and any other limits or discretions should be 
identified and explained at the time of approving the policy.

Proportionality

The link between individual awards, the delivery of strategy 
and the long-term performance of the Group should be 
clear and outcomes should not reward poor performance. 

Alignment with culture

Incentive schemes should drive behaviours consistent with 
the Group's purpose, values and strategy. 

Approach

• The Committee regularly engages and consults with key shareholders to take into account 

shareholder feedback and to ensure there is transparency on our policy and its 
implementation. 

• Our employees were informed about the Directors' remuneration policy approved by our 

shareholders at our 2019 AGM. Details of our remuneration practices and our remuneration 
policy for Directors are published and available to all our employees.

• Our Directors' remuneration policy has been designed to achieve simplicity while 

complying with the provisions set out in the UK Corporate Governance Code and the 
remuneration rules of the UK's Prudential Regulation Authority and Financial Conduct 
Authority, as well as meeting the expectations of our shareholders. The objective of each 
remuneration element is explained and the amount paid in respect of each element of pay 
is clearly set out.

• In line with regulatory requirements, our remuneration practices promote sound and 
effective risk management while supporting our business objectives (see page 252). 
• Risk and conduct considerations are taken into account in setting the variable pay pool, 

from which any executive Director variable pay is funded.

• Executive Directors' annual and LTI scorecards include a mix of financial and non-financial 
measures. Financial measures in the scorecards are subject to a CET1 underpin to ensure 
CET1 remains within risk tolerance levels while achieving financial targets. In addition, the 
overall scorecard outcome is subject to a risk and compliance underpin.

• The deferred portion of any awards granted to executive Directors is subject to a seven-

year deferral period during which our malus policy can be applied. All variable pay awards 
that have vested are subject to our clawback policy for a period of up to seven years from 
the award date (extending to 10 years where an investigation is ongoing).

• The charts set out on page 7 of our Directors’ remuneration policy show how the total 

value of remuneration and its composition vary under different performance scenarios for 
executive Directors. The Directors' remuneration policy can be found at www.hsbc.com/
our-approach/corporate-governance/remuneration.

• The annual incentive scorecard rewards achievement of our annual operating targets and 

the LTI scorecard rewards achievement of long-term financial and shareholder value 
creation targets.

• The Committee retains the discretion to reduce (to zero if appropriate) the annual incentive 
and LTI payout based on the outcome of the relevant scorecards, if it considers that the 
payout determined does not appropriately reflect the overall position and performance of 
the Group during the performance period.

• In order for any annual incentive award to be made, each executive Director must achieve 

a required behaviour rating, which is assessed by reference to the HSBC Values. 

• Annual incentive and LTI scorecards contain non-financial measures linked to our wider 

social obligations. This includes measures related to reducing the environmental impact of 
our operations, improving customer satisfaction, diversity and employee engagement.
• Annually, senior employees participate in a 360 degree survey which gathers feedback on 

values-aligned behaviours.

HSBC Holdings plc Annual Report and Accounts 2020 237

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Remuneration policy – non-executive Directors

Non-executive Directors are not employees. They receive base 
fees for their service and further fees for additional Board duties, 
including but not limited to chairmanship, membership of a 
committee, or acting as the Senior Independent Director and/or 
Deputy Chairman.

Non-executive Directors also receive a travel allowance of £4,000 
towards the additional time commitment required for travel. 

Any other taxable or other expenses incurred in performing their 
role are reimbursed, as well as any related tax cost on such 
reimbursement.

All non-executive Directors are expected to satisfy a shareholding 
guideline of 15,000 shares within five years of their appointment.

There have been no changes to the non-executive Directors' fees 
from the remuneration policy approved at the AGM in 2019, with 
the exception of a revised fee for the Senior Independent Director. 
This change was approved by the Committee following Sir 
Jonathan Symonds' retirement from the Board and as Deputy 
Group Chairman and Senior Independent Director in February 

2020, when David Nish was appointed as Senior Independent 
Director. 

In addition, and in light of the increasingly significant role of 
technology in the Group’s strategy, operations and growth 
prospects, the Board approved the establishment of a Technology 
Governance Working Group for a period of 12 months. The 
working group has been tasked with developing recommendations 
to strengthen the Board’s oversight of technology strategy, 
governance and emerging risks.

The working group will be jointly chaired by Eileen Murray and 
Steven Guggenheimer, given their expertise and experience in this 
area. Jackson Tai, the Group Risk Committee Chair, will be a 
member, with other non-executive Directors members from our 
US, UK, European and Asian principal subsidiaries.

The time commitment expected of the co-Chairs will be up to 30 
days, reflective of the complexity and profile of the subject matter. 
As a result, the Group Remuneration Committee have determined 
a fee of £60,000. Members will not receive fees.

Accordingly, the following table sets out the fees for 2021.

Position
Non-executive Group Chairman1
Non-executive Director (base fee)
Senior Independent Director2
Group Risk Committee

Group Audit Committee and Group Remuneration Committee

Nomination & Corporate Governance Committee

Technology Governance Working Group 

2021 fees

£

1,500,000

127,000

200,000

150,000

40,000

75,000

40,000

––

33,000

60,000

Chair

Member

Chair

Member

Chair

Member

Co-Chair

1  The Group Chairman does not receive a base fee or any other fee in respect of chairing of the Nomination & Corporate Governance Committee.
2  For the period to 18 February 2020, a fee of £375,000 was paid in respect of the combined role of Deputy Group Chairman and Senior 

Independent Director.

Service contracts

Executive Directors

The length of service and notice periods of executive Directors are 
set at the discretion of the Committee, taking into account market 
practice, governance considerations, and the skills and experience 
of the particular candidate at that time.

Noel Quinn

Ewen Stevenson

Contract date (rolling)

18 March 2020

1 December 2018

Notice period
(Director and HSBC)

12 months

12 months

Service agreements for each executive Director are available for 
inspection at HSBC Holdings’ registered office. Consistent with 
the best interests of the Group, the Committee will seek to 
minimise termination payments. Directors may be eligible for a 
payment in relation to statutory rights. The Directors’ biographies 

are set out on pages 198 to 203, and include those directorships 
provided for under the Capital Requirements Regulation II.

Non-executive Directors

Non-executive Directors are appointed for fixed terms not 
exceeding three years, which may be renewed subject to their re-
election by shareholders at AGMs. Non-executive Directors do not 
have service contracts, but are bound by letters of appointment 
issued for and on behalf of HSBC Holdings, which are available for 
inspection at HSBC Holdings’ registered office. There are no 
obligations in the non-executive Directors’ letters of appointment 
that could give rise to remuneration payments or payments for 
loss of office.

Non-executive Directors’ current terms of appointment will expire 
as follows:

2021 AGM
Mark Tucker
Heidi Miller
Laura Cha
James Forese1
Steven Guggenheimer1
Eileen Murray1

2022 AGM
Irene Lee
José Antonio Meade Kuribreña
Pauline van der Meer Mohr
Henri de Castries

2023 AGM
David Nish
Jackson Tai

1 James Forese, Steven Guggenheimer and Eileen Murray were appointed following the 2020 AGM and therefore their initial three-year 

appointment terms are subject to approval of their election by shareholders at the 2021 AGM. Their initial three-year term of appointment will end 
at the conclusion of the 2024 AGM, subject to shareholders' approval at the relevant AGMs. 

238 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Annual report on remuneration

This section sets out how our approved Directors’ remuneration policy was implemented during 2020.

Single figure of remuneration

(Audited)

The following table shows the single figure of total remuneration of each executive Director for 2020, together with comparative figures.

Single figure of remuneration

(£000)
Base salary2
Fixed pay allowance

Cash in lieu of pension
Taxable benefits3
Non-taxable benefits3
Total fixed
Annual incentive4
Notional returns5
Replacement award6
Total variable

Total fixed and variable

Noel Quinn1

Ewen Stevenson

2020

1,266

1,700

127

186

59

3,338

799

17

— 

816

4,154

2019

503

695

50

41

23

1,312

665

—

—

665

1,977

2020

738

950

74

12

32

1,806

450

—

1,431

1,881

3,687

2019

719

950

107

16

28

1,820

1,082

—

1,974

3,056

4,876

1  Noel Quinn succeeded John Flint as interim Group Chief Executive with effect from 5 August 2019 and was appointed permanently into the role 
on 17 March 2020. The remuneration included in the single figure table above for 2019 is in respect of his services provided as an executive 
Director for that year.

2  As outlined on page 230, the executive Directors each donated a quarter of their base salary for six months in 2020. The base salary shown in the 

single figure of remuneration is the gross salary before charitable donations.

3  Taxable benefits include the provision of medical insurance, accommodation, car and tax return assistance (including any associated tax due, 

where applicable). Non-taxable benefits include the provision of life assurance and other insurance cover. 

4  Under the policy approved by shareholders, executive Directors can receive 50% of their annual incentive award in cash and the remaining 50% in 
immediately vested shares subject to a one-year retention period. As the executive Directors each decided not to take an annual cash bonus, the 
2020 annual incentive is the amount after this waiver and will be delivered in immediately vested shares subject to a one-year retention period. 
The total annual incentives waived by the Group Chief Executive and Group Chief Financial Officer were £799,000 and £450,000, respectively.
'Notional returns' refers to the notional return on deferred cash for awards made in prior years. The deferred cash portion of the annual incentive 
granted in prior years includes a right to receive notional returns for the period between the grant date and vesting date, which is determined by 
reference to a rate of return specified at the time of grant. A payment of notional return is made annually and the amount is disclosed on a paid 
basis in the year in which the payment is made. 

5 

6  As set out in the 2018 Directors' remuneration report, in 2019 Ewen Stevenson was granted replacement awards to replace unvested awards, 

which were forfeited as a result of him joining HSBC. The awards, in general, match the performance, vesting and retention periods attached to 
the awards forfeited, and will be subject to any performance adjustments that would otherwise have been applied. The values included in the table 
for 2019 relate to Ewen Stevenson's 2015 and 2016 LTI awards granted by The Royal Bank of Scotland Group plc ('RBS') for performance years 
2014 and 2015, respectively, and replaced with HSBC shares when Ewen Stevenson joined HSBC. These awards are not subject to further 
performance conditions and commenced vesting in March 2019. The total value is an aggregate of £1,121,308 for the 2015 LTI and £852,652 for 
the 2016 LTI. The 2016 LTI award value has been determined by applying the performance assessment outcome of 27.5% as disclosed in RBS's 
Annual Report and Accounts 2018 (page 70) to the maximum number of shares subject to performance conditions. Values in the table for 2020 
relate to his 2017 LTI award granted by RBS for performance year 2016, which was determined by applying the performance assessment 
outcome of 56.25% as disclosed in RBS's Annual Report and Accounts 2019 (page 91) to the maximum number of shares subject to performance 
conditions. This resulted in a payout equivalent to 78.09% of the RBS award shares that were forfeited and replaced with HSBC shares. A total of 
313,608 shares were granted in respect of his 2017 LTI replacement award at a share price of £6.643. The HSBC share price was £5.845 when 
the awards ceased to be subject to performance conditions, with no value attributable to share price appreciation. 

Benefits

The values of the significant benefits in the single figure table are set out in the following table1.

(£000)

Insurance benefit (non-taxable)

Car and driver (UK and Hong Kong)

Noel Quinn

2020

51

139

2019

—

—

1  The value of benefits provided to Noel Quinn in 2019 were not deemed significant. The insurance and car benefits for Ewen Stevenson are not 

included in the above table as they were not deemed significant.

HSBC Holdings plc Annual Report and Accounts 2020 239

Corporate governance 
 
Report of the Directors | Corporate governance report

Determining executive Directors’ performance

(Audited) 

Awards made to executive Directors reflected the Committee’s 
assessment of performance against scorecard objectives which 
were developed with consideration for the Group’s strategic 
priorities and risk appetite. The targets for financial measures were 
set at the start of the financial year. They were not revised for the 
significant economic impact of the Covid-19 outbreak due to the 
Committee’s desire that reward for our executive Directors should 
reflect the experience of our shareholders in the year. For non-
financial objectives, the performance assessment involved 
considering targets set in line with our disclosed commitments, 
such as carbon emissions reduction, diversity, survey results for 
employee experience and customer satisfaction measures, as 
detailed in the non-financial performance assessment table. 
Performance achieved against each measure was applied to the 
weighting of each objective to determine the outcome percentage. 
As part of this assessment, the Committee consulted the Group 
Risk Committee and took into consideration its feedback in 
determining outcomes for the executive Directors' risk and 
compliance measures. It also considered whether any discretion 
should be exercised with respect to the risk and compliance 
underpin.

As set out in the scorecard assessment table below, the target for 
profit before tax was not met. However, good progress was made 
against the targets set for RWA optimisation and cost-savings 
measures, and strong progress was made on the non-financial 
metrics, as our commitment to delivering responsibly for our 
stakeholders remained unchanged throughout the pandemic.

Overall, this level of performance resulted in a payout of 64.50% of 
the maximum for the Group Chief Executive and 63.75% for the 
Group Chief Financial Officer. The Committee reviewed these 
outcomes in the context of a number of internal and external 

Annual assessment

considerations to determine whether it should exercise its 
discretion to reduce the outcome, including:

• overall share price performance in the year, which was 

significantly impacted by both the Covid-19 outbreak and the 
impact of the regulator’s request to suspend dividend 
payments;

• the impact of the bonus pool reduction on the total 

compensation for our wider workforce; 

• profit before tax and RoTE performance; and

• the positive actions taken by the Board to support our 

customers, colleagues and communities in these difficult and 
uncertain times.

Taking the above into account, the Committee determined that the 
2020 formulaic scorecard outcome appropriately rewards the 
executive Directors for their performance within the context of 
overall stakeholder experience. With the voluntary waiver of cash 
bonuses by the executive Directors, the effective payout was 
reduced to 32.25% of the maximum for the Group Chief Executive 
(2019: 66.40%) and 31.88% for the Group Chief Financial Officer 
(2019: 77.50%).

In order for any annual incentive award to be made, each 
executive Director must achieve a minimum behaviour rating, 
which is assessed by reference to the HSBC Values. For 2020, 
both executive Directors met this requirement.

The maximum 2020 annual incentive opportunity for Noel Quinn 
was set at 195% of salary and for Ewen Stevenson at 191% of 
salary. 

Grow profit before tax1 ($bn)
RWA optimisation2 ($bn)
Cost savings ($bn)

Customer satisfaction

Employee experience

Environment

Risk and compliance

Personal objectives

Total

Maximum annual incentive opportunity 
(£000)

Annual incentive pre-cash waiver
(£000)

Annual incentive post-cash waiver 
(£000)

Minimum 
(25% 
payout)

19.91

35.00

1.00

Maximum 
(100% 

payout) Performance

23.38

44.90

1.60

14.77

51.50

1.04

See following section for non-
financial performance commentary

Group Chief Executive

Group Chief Financial Officer

Weighting 
(%)

Assessment 
(%)

Outcome
(%)

Weighting 
(%)

Assessment 
(%)

Outcome 
(%)

 30.0 

 20.0 

 — 

 10.0 

 10.0 

 10.0 

 10.0 

 10.0 

 100.0 

 20.0 

 20.0 

 10.0 

 10.0 

 10.0 

 10.0 

 10.0 

 10.0 

 100.0 

 — 

 — 

 100.0 

 20.00 

 — 

 80.0 

 95.0 

 85.0 

 85.0 

 100.0 

 — 

 8.00 

 9.50 

 8.50 

 8.50 

 10.00 

 64.50 

£2,478

£1,598

£799

 — 

 — 

 100.0 

 20.00 

 30.0 

 80.0 

 95.0 

 85.0 

 85.0 

 62.5 

 3.00 

 8.00 

 9.50 

 8.50 

 8.50 

 6.25 

 63.75 

£1,412

£900

£450

1  Profit before tax, as defined for Group annual bonus pool calculation. This definition excludes business disposal gains and losses, debt valuation 
and goodwill adjustments and variable pay expense. However, it takes into account fines, penalties and costs of customer redress, including 
provisions, which are excluded from the adjusted profit before tax. Other significant items are included or excluded in line with the principles 
underpinning the definition. The adjusted profit before tax as per adjusted results is found on page 2.

2  As set out in our February 2020 business update, our objective is to reduce RWAs in low-return franchises (in particular the US and the non-ring-
fenced bank in Europe and the UK) and redeploy capital in areas of faster growth and higher returns. Our target is to achieve a $100bn reduction 
by 2022, with a $35bn RWA reduction target for 2020. We achieved a reduction of $51.5bn during 2020, which included a reduction of $37.4bn 
in GBM, mainly in our non-ring-fenced bank and in the US, and $12.9bn in CMB, primarily in our ring-fenced bank.

240 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
Non-financial performance

Shared objectives for the Group Chief Executive and Group Chief Financial Officer

Objectives

Performance

Customer satisfaction
Re-engineer the business 
with digital technology to 
improve customer service

•

•

In our Wealth and Personal Banking business, our retail customer satisfaction scores in six of seven scale markets 
(excluding SABB) were ranked in the top three or improved at least two ranks against the benchmark, and three markets 
improved their digital satisfaction scores. Our private banking business did not meet either of its improvement targets. 
In our Commercial Banking business, four of seven scale markets (excluding SABB) improved their customer satisfaction 
scores and six improved their digital satisfaction scores. 

• Our Global Banking and Markets business met the target of improving on its 2019 net promoter score of 38, with a global 
net promoter score of 48 (compared with a global competitor score of 40). The global digital satisfaction score of 64% also 
exceeded the global competitor digital satisfaction score of 36%.
In Hong Kong, we launched a fully remote, digital account opening solution for business customers, while in the UK, we 
launched HSBC Kinetic, our new app-only digital banking offering for small and medium-sized business customers. In 
China, we launched Pinnacle, our new digital platform for wealth planning and insurance services.

•

• During the Covid-19 outbreak, we enhanced our digital capabilities to serve more customers remotely, with faster access 

and improved security. We also engaged with regulators to help customers gain better access to a broad range of banking 
products and services from their homes, including through remote consultations and sales.

• We maintained a high level of business continuity and customer support with 85% of colleagues equipped to work from 

home, all of our customer contact centres fully operational, and between 70% and 90% of our branches open for business.

• We worked with governments to support national schemes, granting over 720,000 payment holidays to our personal 
customers and 237,000 loans to our wholesale customers. We provided more than $26bn in customer relief to our 
personal customers during the initial stages of the pandemic and more than $52bn in lending to wholesale customers, 
many of whom still require our support.

• We helped our clients raise over $1.89tn in capital markets financing, and we retained a top-three position in green, social 

and sustainable finance bonds, according to Dealogic’s rankings. Our Global Banking and Markets business helped 
arrange more than $125bn of financing for our clients through social and Covid-19 relief bonds.

Employee experience
Improve engagement, 
diversity and succession

Employee engagement
• Our Employee Engagement Index, which measures employee survey sentiment on pride, advocacy, intent to stay, 

motivation and feeling of accomplishment questions, increased by five percentage points to 72%, meeting our target to 
improve the metric.

• During the Covid-19 outbreak, extra steps were undertaken to maintain a healthy culture, including: a regular dialogue 

with our colleagues through regular leadership calls and communications; listening closely to their needs; and providing 
the support and flexibility to manage their lives during the pandemic. A culture of ‘looking out for each other’ was 
encouraged and employee networks held regular support calls for employees, specifically those experiencing mental 
health challenges and those with caring responsibilities. 

• We ran a mid-year employee survey to determine how the Covid-19 outbreak was impacting our colleagues and how we 
could support them through this period. More than 50% of our total employee population responded, of which more than 
89% said they were getting the information they needed from the organisation, 86% reported that they were getting the 
support they needed from their line manager, and 86% of the respondents reported they felt confident in leadership. In 
addition, 75% of employees that participated in our 2020 Snapshot survey said they believed HSBC values their well-being.

Diversity and inclusion
• We met our aspirational target of achieving at least 30% women holding senior leadership positions by 2020.
• Several components of the global diversity and inclusion strategy were reprioritised throughout 2020 in direct response to 
the Black Lives Matter movement and the Covid-19 outbreak. Good progress was made, with key achievements including 
the design and launch of the global ethnicity inclusion programme, progression of the global disability confidence 
programme and the appointment of new executive sponsors for the ‘Embrace’ and ‘Balance’ employee resource groups.
• We delivered phase one of the global diversity data project, which collected and reported employee ethnicity data in 21 

countries and territories through a self-identification campaign.

Group Executive Committee succession planning
• Succession plans have been updated for all Group Executive Committee roles and approved by the Group Nomination & 

Corporate Governance Committee.

• The Group also identified a number of enterprise critical roles across the organisation and succession plans have also been 

updated for these roles with approval from the Group Executive Committee.

• The majority of ‘ready now’ and ‘develop in role’ successors on these plans have undergone leadership assessments with 
our third-party specialist provider, with all development plans documented. A global executive coaching panel is utilised 
and executive development solutions have been designed to be implemented in 2021.

• We reduced our carbon emission tonnes to 1.76 per full-time equivalent employee (‘FTE’), beating the target of 2.0 tonnes 
per FTE we had set for 2020. It was recognised that reduced travel and increased working from home due to the Covid-19 
outbreak impacted this outcome, and as a result, the performance assessment for this metric was revised down.
• We exceeded our sustainable finance and investment target of $24bn by facilitating, financing and investing in the 
development of clean energy, lower-carbon technologies and projects that contribute to the delivery of the Paris 
Agreement and the UN Sustainable Development Goals.

• We were recognised as 'The World's Best Bank for Sustainable Finance’ by Euromoney in its Awards for Excellence 2020.
• Awareness of climate change impacts across the organisation continued to increase, with 93% of relationship managers 

completing their required sustainability training modules.

•

•

In spite of the additional stress due to the operational challenges of the Covid-19 outbreak, enabled by the non-financial 
risk optimisation programme outcomes, the organisation maintained fair customer outcomes and a stable non-financial 
risk profile while implementing new products and adapting to significantly different ways of working. 
In 2020, we completed our financial crime risk operational effectiveness exercise programme, with all countries having 
passed the Global Standards exit criteria and assurance. While there was year-on-year improvement in performance 
against a number of specific financial crime risk metrics, it was recognised that some further work is still required. The 
executive Directors demonstrated strong commitment to the conduct framework, maintaining focus on fair outcomes for 
our customers and market integrity. In 2020, this included initiatives to minimise the impact of the Covid-19 crisis and 
protect the business with rapid introduction of initiatives and mitigation against unacceptable levels of conduct risk. 

HSBC Holdings plc Annual Report and Accounts 2020 241

Environment
Sustainable operations and 
sustainable finance

Risk and compliance
Achieve effective 
management of non-
financial risk Group-wide 
and fulfilment of regulatory 
obligations.
Achieve sustained delivery 
against the Global Conduct 
framework and effective 
financial crime risk 
management.

Corporate governance 
Report of the Directors | Corporate governance report

Personal measures for the Group Chief Executive and Group Chief Financial Officer

Objectives

Performance

Group Chief Executive
Simplify the Group operating model

Group Chief Financial Officer
• Deploy Cloud technologies in 

Global Finance function

• Reduce Finance function costs 

and number of full-time 
equivalents

• As part of the Group transformation programme, we commenced work on 'organisation simplification and design' 
by defining roles with clear accountabilities and decision rights, simplifying and minimising matrix reporting and 
realising transformation objectives through the redesign of certain structures across businesses and functions.
• The programme successfully delivered all key milestones in 2020, including: the establishment of design principles 
to shape the future organisation model and structures; the creation of the Group Organisational Design Authority 
to drive consistent design thinking; the simplification of the Group Executive Committee and the introduction of a 
clear operating rhythm to increase discipline and focus on strategy and performance delivery; the redesign of the 
majority of top leadership structures; the definition of a consistent role taxonomy across business and functions; 
and the identification of reductions in FTEs and cost, principally at senior levels.

• The Finance on the Cloud programme will transform the way the Global Finance function operates by rationalising 
operational processes, automation of data production and providing faster delivery of comprehensive data to our 
internal and external stakeholders. The programme has progressed into the execution phase in 2020, with the 
programme design, scope and implementation approach approved.

• The first phase of implementation, which relates to the risk-weighted assets reporting process for our UK entities, 
was successfully implemented in November 2020. Execution plans are in place for the further extension of Cloud 
technologies within the UK pilot in 2021, followed by a global deployment.

• The target of reducing Finance function costs to $0.8bn was met, but the target number of full-time equivalent 

staff in the function was not achieved.

2017 long-term incentive performance

The 2017 LTI award was granted to Marc Moses (former Group Chief Risk Officer) and Iain Mackay (former Group Finance Director)1. 

Assessment of the LTI award in respect of 2017 (granted in 2018)

Minimum

Target

Maximum

Measures (with weighting)

(25% payout)

(50% payout)

(100% payout)

Actual

Assessment Outcome

Average return on equity
(with CET1 underpin)2 (20%)

Cost-efficiency ratio (20%)
Relative total shareholder return3 
(20%)

Risk and compliance4 (25%)
• Achieve and sustain compliance with 
Global Financial Crime Compliance 
policies and procedures.

• Achieve a sustainable adoption of 
Group operation risk management 
framework, along with its policies and 
practices.

• Achieve and sustain delivery of global 
conduct outcomes and compliance 
with conduct of business regulatory 
obligations.

Strategy (15%)
Sustainable finance ($bn)5
Employee confidence6

Customer
(based on customer recommendation in
top five markets by revenue) 

Total7

9.0%

60.0%

At median of
peer group

10.0%

58.0%
Straight-line vesting 
between minimum 
and maximum

11.0%

55.5%

7.3%

62.4%

0.0%

0.0%

0.00%

0.00%

At upper quartile of
peer group

Rank 11th

0.0%

0.00%

Performance assessed by the Committee based on a number of 
qualitative and quantitative inputs such as Group Financial Crime Risk 
assessment against Financial Crime Compliance objectives, outcome 
of assurance and audit reviews, and achievement of long-term Group 
objectives and priorities during the performance period, with input 
and approval from the Group Risk Committee.

65.0%

65.0%

16.25%

30.0

65.0%

34.0

67.0%

37.0

70.0%

93.0

62.0%

100.0%

0.0%

5.00%

0.00%

Improvement in
recommendation in
three of top five 
markets for WPB, 
CMB and GBM.

Improvement in
recommendation in 
four of top five 
markets for WPB, 
CMB and GBM.

Improvement in
recommendation in all 
of top five markets for
WPB, CMB and GBM.

Improvement 
in three of 
top five 
markets

25.0%

1.25%

22.50%

1  Based on the scorecard outcome, 29,655 shares will vest with Iain Mackay and 86,491 shares will vest with Marc Moses (determined by pro-

rating their awards for time in employment during the performance period of 1 January 2018 to 31 December 2020). The awards will vest in five 
equal annual instalments commencing in March 2021. Using the average daily closing share prices over the three months to 31 December 2020 
of £3.604 the value of awards to vest with Iain Mackay and Marc Moses is £106,877 and £311,714, respectively.

2  Significant items are excluded from the profit attributable to ordinary shareholders of the company for the purpose of computing adjusted return 

on equity.

3  The peer group for the 2017 award is: Bank of America, Barclays, BNP Paribas, Citigroup, Credit Suisse Group, DBS Group Holdings, Deutsche 

Bank, JPMorgan Chase & Co., Lloyds Banking Group, Standard Chartered and UBS Group.

4  The performance outcome was reviewed and approved by the Group Risk Committee taking into account evidence of progress made during the 

three-year performance period. Specifically, it noted a steady improvement in financial crime risk related audit outcomes, a significant reduction of 
overdue and re-opened high and medium risk assurance issues and stabilisation of the global residual risk for anti-money laundering, sanctions, 
and anti-bribery and corruption. The non-financial risk optimisation programme made significant progress during 2020 to demonstrate operational 
risk management maturity in areas of focus. There was also a steady improvement in conduct ratings with significant improvement seen in Global 
Banking and Markets since 2018. The Group Risk Committee also noted the need for ongoing enhancements in certain areas and the need for 
further improvement in approach to conduct management.

5  Assessed based on cumulative financing and investment made to develop clean energy, lower-carbon technologies and projects that contribute to 

the delivery of the Paris Agreement and the UN Sustainable Development Goals.

6  Assessed based on results of the latest employee Snapshot survey question, ‘I am seeing the positive impact of our strategy’.
7  Taking into consideration the overall performance of the Group using a number of internal and external measures, including profit before tax, 
RoTE, share price and total shareholder returns, the Committee considered that the scorecard outcomes reflected the performance achieved.

242 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Long-term incentive awards
(Audited)

Long-term incentive in respect of 2020

After taking into account performance for 2020, the Committee 
decided to grant Noel Quinn and Ewen Stevenson LTI awards of 
£3,718,000 and £2,118,000, respectively. These awards will be 
subject to 'windfall gain' adjustments, as set out below. As the 
awards are not entitled to dividend equivalents in accordance with 
regulatory requirements, the number of shares to be awarded will 
be adjusted to reflect the expected dividend yield of the shares 
over the vesting period.

The 2020 LTI awards will have a three-year performance period 
starting 1 January 2021. During this period, performance will be 
assessed based on the 2020 LTI scorecard comprising four 
equally-weighted measures: two financial measures to incentivise 
value creation for our shareholders; a measure linked to our 
climate ambitions; and a measure for relative total shareholder 
return ('TSR').

RoTE was retained as a metric as it remains a key measure of our 
financial performance and how we generate returns that deliver 
value for our shareholders. Given the uncertainty from the 
economic impact of the Covid-19 outbreak, the Committee 
determined it was most appropriate to assess RoTE at the end of 
the performance period. This element of the award will continue to 
be subject to a CET1 underpin. 

Capital reallocation to Asia was added as a new metric as this is 
one of the key levers of our strategy and business transformation 
plan. This measure will be assessed based on the share of Group 
tangible equity allocated to Asia at the end of the performance 
period and is also subject to the CET1 underpin.

The environment and sustainability scorecard measure was added 
to align to our new climate ambition. Announced in October 2020, 
we set out how we aim to bring carbon emissions in our own 

Performance conditions for LTI awards in respect of 2020

operations to net zero by 2030 and support our customers in the 
transition to a more sustainable future with financing, facilitation 
and investments of $750bn to $1tn over the same time period. 
Scorecard targets are linked to this climate ambition and 
performance will be assessed based on the reduction in our 
carbon footprint and the financing we provide to our clients in 
their net zero transition. 

Relative TSR was retained as a metric in the scorecard as it 
rewards executive Directors based on comparison of the total 
shareholder return performance of the Group and a relevant peer 
group. No changes were made to the peer group used for this 
purpose. Given the planned strategic shifts in our geographical 
and business mix, notably future growth investment in Asia and 
wealth business, we will review our peer group for any relative 
TSR measure to be used for the 2021 LTI scorecard. The updated 
peer group will be set out in the Annual Report and Accounts 2021.

The LTI continues to be subject to a risk and compliance modifier, 
which gives the Committee the discretion to adjust down the 
overall scorecard outcome to ensure that the Group operates 
soundly when achieving its financial targets. For this purpose, the 
Committee will receive information including any risk metrics 
outside of tolerance for a significant period of time and any risk 
management failures that have resulted in significant customer 
detriment, reputational damage and/or regulatory censure.

To the extent performance conditions are satisfied at the end of 
the three-year performance period, the awards will vest in five 
equal annual instalments commencing from around the third 
anniversary of the grant date. On vesting, shares equivalent to the 
net number of shares that have vested (after those sold to cover 
any income tax and social security payable) will be held for a 
retention period of up to one year, or such period as required by 
regulators.

Measures
RoTE (with CET1 underpin)1

Capital reallocation to Asia (with CET1 
underpin)2

Environment and 
sustainability3

Carbon reduction

Sustainable finance 
and investment $bn

Minimum

(25% payout)

Target

(50% payout)

8.0%

45.0%

42.0%

200.0

9.0%

47.0%

48.0%

240.0

Maximum

Weighting

(100% payout)

10.0%

50.0%

51.0%

260.0

%

25.0

25.0

25.0

25.0

Relative TSR4

At median of the peer group

Straight-line vesting between 
minimum and maximum

At upper quartile of peer 
group

1 To be assessed based on RoTE at the end of the performance period. The measure will also be subject to a CET1 underpin. If the CET1 ratio at the 
end of the performance period is below the CET1 risk tolerance level set in the risk appetite statement, then the assessment for this measure will 
be reduced to nil.

2  To be assessed based on share of Group tangible equity (on a constant currency basis and excluding associates) allocated to Asia by 31 December 
2023. This metric will be measured on an organic basis and will exclude changes in Group tangible equity allocation resulting from acquisitions 
and disposals (and also part-acquisitions or part-disposals) of businesses and is subject to the CET1 underpin outlined above. 

3  Carbon reduction will be measured based on percentage reduction in total energy and travel emissions achieved by 31 December 2023 using 
2019 as the baseline. A sustainable finance and investment metric will assess cumulative financing provided over the period commencing on 
1 January 2020 and ending on 31 December 2023.

4  The peer group for the 2020 award is: Bank of America, Barclays, BNP Paribas, Citigroup, Credit Suisse Group, DBS Group Holdings, Deutsche 

Bank, J.P. Morgan Chase & Co., Lloyds Banking Group, Morgan Stanley, Standard Chartered and UBS Group. 

5  Awards will vest on a straight-line basis for performance between the minimum, target and maximum levels of performance set in this table.

2020 LTI grant size

The Committee is conscious of the external commentary on 
'windfall gains' from LTI awards given the impact of the Covid-19 
outbreak. The Committee is also aware that a number of investors 
have expressed their preference that, where executives may 
benefit from 'windfall gains', the Committee is proactive in 
considering award levels at the time of grant. Based on the above 
and discussions with investors and proxy voting agencies, the 
Committee agreed that the 2020 LTI awards should be subject to a 
'windfall gain' adjustment at grant if the share price falls 
significantly relative to the grant price of the 2019 LTI. This is to 
ensure reward for our executive Directors aligns with the 
experience of our shareholders and is reflective of management 

performance over the performance period. While the share price 
to be used for the 2020 LTI award is not known at this stage, the 
Committee agreed that, in line with investor expectations, if the 
2020 LTI grant share price experiences a greater than 30% decline 
since the previous grant, this would be considered a material fall 
in share price (based on review of historical share price volatility 
and the impact of significant external macroeconomic events). In 
such an event, an adjustment percentage equal to half the share 
price percentage decline will be applied to the awards to mitigate 
the potential for 'windfall gains'. This approach will apply to the 
2020 LTI award to be granted in 2021.

HSBC Holdings plc Annual Report and Accounts 2020 243

Corporate governance 
Report of the Directors | Corporate governance report

2018 long-term incentive award

The LTI granted in respect of 2018 included an ESG measure 
based on our objective disclosed in the Strategy Update in June 
2018 to achieve an 'Outperformer' rating from ratings provider 
Sustainalytics. Our 2018 Directors' remuneration report noted that 
in the event Sustainalytics changed its rating approach, the 
Committee retained the discretion to review and modify the 
assessment approach and targets to ensure the assessment 
approach achieved its original purpose.

Performance conditions for LTI awards in respect of 2018

Sustainalytics has since revised its methodology and replaced 
'performer' ratings with low, medium and high risk ratings. In 
2020, the Committee approved a revised assessment approach 
and targets that aim for HSBC to 'outperform' a set of peers using 
Sustainalytics' revised risk-based rating as detailed in the table 
below. The Committee is comfortable that the proposed targets 
are no more or less difficult to achieve than the original proposed 
targets.

Measures

Average RoTE (with CET1 
underpin)1
Employer advocacy2

Environmental, social and 
governance rank3

Minimum

(25% payout)

10.0%

65.0%

Target

(50% payout)

11.0%

70.0%

Maximum

(100% payout)

12.0%

75.0%

At median of the peer group

Straight-line vesting between 
minimum and maximum

At upper quartile of peer group

Weighting

%

 75.0 

 12.5 

 12.5 

1 If the CET1 ratio at the end of performance period is below the CET1 risk tolerance level set in the risk appetite statement, then the assessment for 

this measure will be reduced to nil.

2  To be assessed based on results of the latest employee Snapshot survey question: 'I would recommend this company as a great place to work'.
3  Peer group (in line with TSR peer group for the 2017 LTI, including three additional peers): Bank of America, Barclays, BNP Paribas, Citigroup, 
Credit Suisse Group, Deutsche Bank, DBS Group Holdings, J.P. Morgan Chase & Co., Lloyds Banking Group, Standard Chartered, UBS Group, 
ICBC, Itau and Santander.

Scheme interests awarded during 2020

(Audited)

The table below sets out the scheme interests awarded to 
Directors in 2020, as disclosed in the 2019 Directors’ remuneration 

report. No non-executive Directors received scheme interests 
during the financial year.

Scheme awards in 2020

(Audited)

Ewen Stevenson

Noel Quinn 

Type of interest 
Basis on which 
awarded
award made
LTI deferred shares2 % of salary 2
Deferred shares 3
Deferred cash 3

Annual incentive

Annual incentive

Face value 
awarded1
£000

Percentage 
receivable for 
minimum 
performance

Number of
shares
awarded

Date of award

End of performance 
period

24 February 2020  

24 February 2020  

24 February 2020  

2,680 

1,134 

886 

 25 

476,757

31 December 2022

 — 

 — 

201,702

31 December 2019

N/A

31 December 2019

1 The face value of the award has been computed using HSBC's closing share price of £5.622 taken on 21 February 2020. LTI awards are subject to 

2 

a three-year forward-looking performance period and vest in five equal annual instalments, between the third and seventh anniversary of the 
award date, subject to performance achieved. On vesting, awards will be subject to a one-year retention period. Awards are subject to malus 
during the vesting period and clawback for a maximum period of 10 years from the date of the award.
In line with regulatory requirements, scheme interests awarded during 2020 were not eligible for dividend equivalents. In accordance with the 
remuneration policy approved by shareholders at the 2019 AGM, the LTI award was determined at 290% of salary for Ewen Stevenson and the 
number of shares to be granted was determined by taking into account a share price discounted based on HSBC’s expected dividend yield of 5% 
per annum for the vesting period (i.e. £4.393). Noel Quinn did not receive the 2019 LTI award that was granted on 24 February 2020, as he was in 
the Group Chief Executive role in an interim capacity during 2019. 

3  2019 annual incentive award received by Noel Quinn for his role as Chief Executive Officer of Commercial Banking and interim Group Chief 
Executive.  As noted in the Annual Report and Accounts 2019, 60% of his annual incentive award was deferred and in line with regulatory 
requirements split between cash and shares. The awards will vest in five equal annual instalments between the third and seventh anniversary of 
the award date. On vesting, the deferred shares will be subject to a one-year retention period. As the deferred share awards are not eligible for 
dividend equivalents, the number of shares to be granted was determined by taking into account a share price discounted based on HSBC’s 
expected dividend yield of 5% per annum for the vesting period (i.e. £4.393).

The above table does not include details of shares issued as part of the fixed pay allowance and shares issued as part of the 2020 annual 
incentive award that vested on grant and were not subject to any further service or performance conditions. Details of the performance 
measures and targets for the LTI award in respect of 2019 are set out on the following page.

244 HSBC Holdings plc Annual Report and Accounts 2020

 
 
Performance conditions for LTI awards in respect of 2019

Measures
RoTE (with CET1 underpin)1, 2
Relative TSR3

Customers

Minimum

(25% payout)

10.0%

Target

(50% payout)

11.0%

Maximum

(100% payout)

12.0%

At median of the peer group

Straight-line vesting between 
minimum and maximum

At upper quartile of peer group

Performance will be assessed by the Committee taking into consideration:
• customer satisfaction scores at the start and end of the three-year performance period for our global 
businesses in home and scale markets as per data provided by an independent third party on HSBC’s 
performance across our products and services; and

• progress against customer objectives linked to our strategy over the next three years.

Weighting

%

33.3

33.3

33.3

1 To be assessed based on RoTE in the 2022 financial year. The measure will also be subject to a CET1 underpin. If the CET1 ratio at the end of 

performance period is below the CET1 risk tolerance level set in the risk appetite statement, then the assessment for this measure will be reduced 
to nil.

2  Awards will vest on a straight-line basis for performance between the minimum, target and maximum levels of performance set in this table.
3  The peer group for the 2019 award is: Bank of America, Barclays, BNP Paribas, Citigroup, Credit Suisse Group, DBS Group Holdings, Deutsche 

Bank, J.P. Morgan Chase & Co., Lloyds Banking Group, Morgan Stanley, Standard Chartered and UBS Group.

Executive Directors’ interests in shares

employment due to the following features of the policy: 

(Audited)

The shareholdings of all persons who were executive Directors in 
2020, including the shareholdings of their connected persons, at 
31 December 2020 (or the date they stepped down from the 
Board, if earlier) are set out below. The following table shows the 
comparison of shareholdings with the company shareholding 
guidelines. There have been no changes in the shareholdings of 
the executive Directors from 31 December 2020 to the date of this 
report.

Individuals are given five years from their appointment date to 
build up the recommended levels of shareholding. Unvested 
share-based incentives are not normally taken into consideration 
in assessing whether the shareholding requirement has been met.

The Committee reviews compliance with the shareholding 
requirement and has full discretion in determining if any unvested 
shares should be taken into consideration for assessing 
compliance with this requirement, taking into account shareholder 
expectations and guidelines. The Committee also has full 
discretion in determining any penalties for non-compliance.

With regard to the post-employment shareholding requirement, 
we believe that our remuneration structure achieves the objective 
of ensuring there is ongoing alignment of executive Directors' 
interests with shareholder experience post-cessation of their

Shares

(Audited)

• Shares delivered to executive Directors as part of the FPA have 
a five-year retention period, which continues to apply following 
a departure of an executive Director.

• Shares delivered as part of an annual incentive award are 

subject to a one-year retention period, which continues to apply 
following a departure of an executive Director.

• When an executive Director ceases employment as a good 

leaver under our policy, any LTI awards granted will continue to 
be released over a period of up to eight years, subject to the 
outcome of performance conditions.

An executive Director who ceases employment as a good leaver 
after a tenure of five years will have share interests not subject to 
further performance conditions equivalent in value to more than 
400% of salary assuming they receive a target payout of 50% for 
LTI awards.

HSBC operates an anti-hedging policy under which individuals are 
not permitted to enter into any personal hedging strategies in 
relation to HSBC shares subject to a vesting and/or retention 
period.

At 31 Dec 2020

Scheme interests

Shareholding 
guidelines
(% of salary)

Shareholding at 
31 Dec 20202 (% of 
salary)

Share
interests
(number
of shares)

Share options3

Shares awarded subject to 
deferral1

without 
performance 
conditions4

with
performance
conditions5

400%

300%

250%

 221 %  

 265 %  

n/a

778,958   

545,731   

n/a

—   

—   

n/a

554,556   

728,790   

n/a

— 

476,757 

n/a

Executive Directors
Noel Quinn6
Ewen Stevenson6
Group Managing Directors6

1 The gross number of shares is disclosed. A portion of these shares will be sold at vesting to cover any income tax and social security that falls due 

at the time of vesting.

2  The value of the shareholding is calculated using an average of the daily closing share prices in the three months to 31 December 2020 (£3.604).
3  As at 31 December 2020, Noel Quinn and Ewen Stevenson did not hold any options under the HSBC Holdings Savings-Related Share Option Plan 

(UK).

4  The amount for Ewen Stevenson reflects the award granted in May 2019, replacing the 2015 to 2018 LTIs forfeited by the Royal Bank of Scotland 
Group plc (‘RBS’) and is subject to any performance adjustments assessed and disclosed in the relevant Annual Report and Accounts of RBS. 

5  LTI awards granted in February 2020 are subject to the performance conditions as set out on page 244. 
6  All Group Managing Directors and executive Directors are expected to meet their shareholding guidelines within five years of the date of their 

appointment (Noel Quinn and Ewen Stevenson were appointed on 5 August 2019 and 1 January 2019 respectively).The shareholding guidelines 
for Group Managing Directors have been updated from 250,000 shares to 250% of reference salary from 1 January 2019 to align with the 
approach used for executive Directors.

HSBC Holdings plc Annual Report and Accounts 2020 245

Corporate governance 
Report of the Directors | Corporate governance report

Summary of shareholder return and Group Chief 
Executive remuneration

The following graph shows HSBC TSR performance (based on the 
daily spot Return Index in sterling) against the FTSE 100 Total 
Return Index for the 10-year period ended 31 December 2020.

The FTSE 100 Total Return Index has been chosen as a recognised 
broad equity market index of which HSBC Holdings is a member. 
The single figure remuneration for the Group Chief Executive over 
the past 10 years, together with the outcomes of the respective 
annual incentive and LTI awards, are presented in the following 
table.

HSBC TSR and FTSE 100 Total Return Index

2011

2012

2013

2014

2015

2016

2017

2018

2019

Group Chief Executive

Total single figure £000
Annual incentive1 (% of maximum)
Long-term incentive1,2,3 (% of maximum)

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

8,047

7,532

8,033

7,619

7,340

5,675

58%

50%

52%

40%

49%

49%

54%

44%

45%

41%

64%

–%

6,086

80%

2,387

76%

–%

100%

John 
Flint

4,582

76%

–%

2020

Noel 
Quinn

Noel 
Quinn

1,977

4,154

66%

32%

John 
Flint

2,922

61%

–%

–%   — %

1  The 2012 annual incentive figure for Stuart Gulliver used for this table includes 60% of the annual incentive disclosed in the 2012 Directors’ 

remuneration report, which was deferred for five years and subject to service conditions and satisfactory completion of the five-year deferred 
prosecution agreement with the US Department of Justice, entered into in December 2012 ('AML DPA') as determined by the Committee. The 
AML DPA performance condition was met and the award vested in 2018. The value of the award at vesting was included in the 2018 single figure 
of remuneration and included as long-term incentive for 2018. 

2  Long-term incentive awards are included in the single figure for the year in which the performance period is deemed to be substantially 

completed. For Group Performance Share Plan ('GPSP') awards, this is the end of the financial year preceding the date of grant. GPSP awards 
shown in 2011 to 2015 are therefore related to awards granted in 2012 to 2016. 

3  The GPSP was replaced by the LTI in 2016 and the value for GPSP is nil for 2016 as no GPSP award was made for 2016. LTI awards have a three-
year performance period and the first LTI award was made in February 2017. The value of the LTI awards expected to vest will be included in the 
total single figure of remuneration of the year in which the performance period ends. Noel Quinn did not receive the 2017 LTI award that had a 
performance period ended on 31 December 2020.

Comparison of Directors' and employees' pay

The following table compares the changes in each Director's pay with changes in employee pay between 2019 and 2020.

Annual percentage change in remuneration

Director/employees
Executive Directors1
Noel Quinn1
Ewen Stevenson
Non-executive Directors2
Kathleen Casey (retired on 24 April 2020)
Laura Cha
Henri de Castries
James Forese
Steven Guggenheimer
Irene Lee
José Antonio Meade Kuribreña
Heidi Miller
Eileen Murray
David Nish
Sir Jonathan Symonds (retired on 18 February 2020)
Jackson Tai
Mark Tucker
Pauline van der Meer Mohr
Employee group3

Base salary/fees

151.7%
2.6%

-65.0%
97.0%
4.1%
-
-
20.3%
28.7%
1.1%
-
108.7%
-86.5%
-10.8%
—%
17.7%
2.0%

2020

Benefits

353.7%
-25.0%

200.0%
-
-75.0%
-
-
-100.0%
100.0%
-100.0%
-
-50.0%
-4.8%
-78.9%
-77.5%
-75.0%
2.3%

Annual incentive

20.2%
-58.4%

-
-
-
-
-
-
-
-
-
-
-
-
-
-
-20.0%

1  Noel Quinn succeeded John Flint as interim Group Chief Executive with effect from 5 August 2019 and was appointed permanently into the role 

on 17 March 2020. The annual percentage change for Noel Quinn is based on remuneration reported in his 2019 single figure of remuneration (for 
the period 5 August 2019 to 31 December 2019) and his 2020 single figure of remuneration (for the period 1 January 2020 to 31 December 
2020). Based on his annualised 2019 compensation as an executive Director, his percentage change in salary, benefits and annual incentive is 
2.1%, 85.2% and -50.9%, respectively.
In some instances, non-executive Directors may have served only part of the year resulting in large year-on-year percentage changes in fees and/
or benefits. Page 248 provides the underlying single figure of remuneration for non-executive Directors used to calculate the figures above.

2 

3  Employee group consists of individuals employed by HSBC Group Management Services Ltd, the employing entity of the executive Directors, as 

no individuals are employed directly by HSBC Holdings.

246 HSBC Holdings plc Annual Report and Accounts 2020

HSBC TSRFTSE 100 Total Return IndexDec 2010Dec 2011Dec 2012Dec 2013Dec 2014Dec 2015Dec 2016Dec 2017Dec 2018Dec 2019Dec 2020100%200% 
 
Pay ratio

The following table shows the ratio between the total pay of the 
Group Chief Executive and the lower quartile, median and upper 
quartile pay of our UK employees.

Total pay ratio

2020

2019

Method

A

A

Lower 
quartile

139:1

169:1

Median

85:1

105:1

Upper 
quartile

43:1

52:1

Total pay and benefits amounts used to calculate the ratio

Lower quartile

Median

Upper quartile

Total 
pay and 
benefits

Total 
salary

Total 
pay and 
benefits

Total 
salary

Total 
pay and 
benefits

Total 
salary

29,833

23,264

48,703

36,972

96,386

75,000

28,920

24,235

46,593

41,905

93,365

72,840

(£)

Method

2020

2019

A

A

Our ratios have been calculated using the option ‘A’ methodology 
prescribed under the UK Companies (Miscellaneous Reporting) 
Regulations 2018. Under this option, the ratios are computed 
using full-time equivalent pay and benefits of all employees 
providing services in the UK at 31 December 2020. We believe this 
approach provides accurate information and representation of the 
ratios. The ratio has been computed taking into account the pay 
and benefits of over 40,000 UK employees, other than the 
individual performing the role of Group Chief Executive. We 
calculated our lower quartile, median and upper quartile pay and 
benefits information for our UK employees using:

• full-time equivalent annualised fixed pay, which includes salary 

and allowances, at 31 December 2020;

• variable pay awards for 2020, including notional returns paid 

during 2020; 

• gains realised from exercising awards from taxable employee 

share plans; and

• full-time equivalent value of taxable benefits and pension 

contributions. 

For this purpose, full-time equivalent fixed pay and benefits for 
each employee have been computed by using each employee’s 
fixed pay and benefits at 31 December 2020. Where an employee 
works part-time, fixed pay and benefits are grossed up, where 
appropriate, to full-time equivalent. One-off benefits provided on a 
temporary basis to employees on secondment to the UK have not 
been included in calculating the ratios above as these are not 
permanent in nature and in some cases, depending on individual 
circumstances, may not truly reflect a benefit to the employee.

Total pay and benefits for the Group Chief Executive used for this 
purpose is the total remuneration for Noel Quinn as reported in the 
single figure of remuneration table. Total remuneration does not 
include an LTI as he has not received an LTI award with a 
performance period that ended during 2020. In a year in which a 
value of an LTI is included in the single figure table of 
remuneration, the above ratios could be higher. 

Given the different business mix, size of the business, 
methodologies for computing pay ratios, estimates and 
assumptions used by other companies to calculate their respective 
pay ratios, as well as differences in employment and 
compensation practices between companies, the ratios reported 
above may not be comparable to those reported by other listed 
peers on the FTSE 100 and our international peers. 

The decrease in median ratio is primarily driven by the lower 
annual incentive award for the Group Chief Executive, reflecting 
the lower scorecard outcome and the voluntary waiver of the cash 
portion of the award. Without this waiver, the median ratio is 
102:1.

While total compensation for the Group Chief Executive declined 
compared with 2019, total pay and benefits for the median 

employee for 2020 was 5% higher at £48,703 compared with 
2019.

Our UK workforce comprises a diverse mix of employees across 
different businesses and levels of seniority, from junior cashiers in 
our retail branches to senior executives managing our global 
business units. We aim to deliver market-competitive pay for each 
role, taking into consideration the skills and experience required 
for the business. Our approach to pay is designed to attract and 
motivate the very best people, regardless of gender, ethnicity, age, 
disability or any other factor unrelated to performance or 
experience. We actively promote learning and development 
opportunities for our employees to provide them a framework to 
develop their career. As an individual progresses in their career we 
would expect their total compensation opportunity to also 
increase, reflecting their role and responsibilities.

Pay structure varies across roles in order to deliver an appropriate 
mix of fixed and variable pay. Junior employees have a greater 
portion of their pay delivered in a fixed component, which does 
not vary with performance and allows them to predictably meet 
their day-to-day needs. Our senior management, including 
executive Directors, generally have a higher portion of their total 
compensation opportunity structured as variable pay and linked to 
the performance of the Group, given their role and ability to 
influence the strategy and performance of the Group. Executive 
Directors also have a higher proportion of their variable pay 
delivered in shares, which vest over a period of seven years with a 
post-vesting retention period of one year. During this deferral and 
retention period, the awards are linked to the share price so the 
value of award realised by them after the vesting and retention 
period will be aligned to the performance of the Group.

We are satisfied that the median pay ratio is consistent with the 
pay, reward and progression policies for our UK workforce, taking 
into account the diverse mix of our UK employees, the 
compensation structure mix applicable to each role and our 
objective of delivering market competitive pay for each role 
subject to Group, business and individual performance.

Relative importance of spend on pay

The following chart shows the change in:

• total staff pay between 2019 and 2020; and

• dividends in respect of 2019 and 2020.

In 2019, we returned a total of $1bn to ordinary shareholders 
through share buy-backs.

Relative importance of spend on pay
ì

î

(56.7)%

0.4%

Return to shareholder

Employee pay

Dividends

Share buy-back

1  The fourth interim dividend of 2020, of $0.15 per ordinary share, is 

an approximation of the amount payable on 29 April 2021. 

2  The fourth interim dividend of 2019, of $0.21 per ordinary share, was 
cancelled in response to a written request from the UK’s Prudential 
Regulation Authority (‘PRA’). The 2019 dividends have been re-
presented accordingly.

HSBC Holdings plc Annual Report and Accounts 2020 247

$3,055m$6,063m$18,076m$18,002m$3,055m$7,063m2020¹2019²20202019Corporate governance 
 
Report of the Directors | Corporate governance report

Non-executive Directors

(Audited)

The following table shows the total fees and benefits of non-executive Directors for 2020, together with comparative figures for 2019.

Fees and benefits

(Audited)
(£000)

Kathleen Casey (retired on 24 April 2020)

Laura Cha

Henri de Castries

James Forese

Steven Guggenheimer

Irene Lee

José Antonio Meade Kuribreña

Heidi Miller

Eileen Murray

David Nish

Sir Jonathan Symonds (retired on 18 February 2020)

Jackson Tai

Mark Tucker

Pauline van der Meer Mohr

Total (£000)

Total ($000)

Footnotes

3,4

5

6

7

8

9

10

11

12

13

14

Fees1

2020

2019

78   

587   

202   

160   

134   

546   

202   

632   

120   

480   

86   

355   

1,500   

312   

5,394   

6,919

223   

298   

194   

—   

—   

454   

157   

625   

—   

230   

638   

398   

1,500   

265   

4,982   

6,390

Benefits2

2020

27   

—   

1   

—   

—   

—   

4   

7   

—   

8   

20   

12   

52   

2   

133   

171

2019

2020

2019

Total

9   

—   

4   

—   

—   

3   

2   

2   

—   

16   

21   

57   

231   

8   

353   

453

105   

587   

203   

160   

134   

546   

206   

639   

120   

488   

106   

367   

1,552   

314   

5,527   

7,090

232 

298 

198 

— 

— 

457 

159 

627 

— 

246 

659 

455 

1,731 

273 

5,335 

6,843

1 The Directors' remuneration policy was approved at the 2019 AGM and the new fees became effective from 13 April 2019. Fees include a travel 
allowance of £4,000 for non-UK based non-executive Directors and for all non-executive Directors effective from 1 June 2019. Given the travel 
restrictions in place, the Board was unable to travel to attend meetings in person. Therefore, the travel allowance available to all non-executive 
Directors was pro-rated to reflect the travel required of the Board during 2020. 

2  Benefits include taxable expenses such as accommodation, travel and subsistence relating to attendance at Board and other meetings at HSBC 

Holdings' registered offices. Amounts disclosed have been grossed up using a tax rate of 45%, where relevant. 

3  Appointed as a member of the Group Risk Committee on 17 January 2020.
4  Stepped down as a member of the Financial System Vulnerabilities Committee on 17 January 2020 when the Committee was demised.
5 

Includes fees of £423,800 (2019: £104,000) for her role as non-executive Chair and member of the Nomination Committee of The Hongkong and 
Shanghai Banking Corporation. Following approval of the non-executive Chair fee by the Group Remuneration Committee in 2020, Laura also 
received a pro-rated additional Chair fee of HK$201,639 paid in respect of the period from 6 December to 31 December 2019.  

6  Appointed to the Board and a member of the Group Audit Committee, Group Remuneration Committee and Nomination & Corporate Governance 

Committee on 1 May 2020.

7  Appointed to the Board and as a member of the Group Risk Committee and Nomination & Corporate Governance Committee on 1 May 2020. 
8 

Includes fees of £344,000 (2019: £260,000) in relation to her roles as a Director, Remuneration Committee Chair, Audit Committee member and 
Risk Committee member of The Hongkong and Shanghai Banking Corporation Limited. Fees in relation to her role as a Director, Risk Committee 
Chair and Audit Committee member, and from 28 December 2020 as a member of the Nomination Committee, of Hang Seng Bank Limited. 
Includes fees of £430,000 (2019: £431,000) in relation to her role as Chair of HSBC North America Holdings Inc. 

9 
10  Appointed to the Board and as member of the Group Audit Committee, Group Risk Committee and Nomination & Corporate Governance 

Committee on 1 July 2020.

11 Appointed as Senior Independent Director, Chair of the Group Audit Committee and member of the Group Risk Committee on 18 February 2020. 
12 Stepped down as Chair of the Financial System Vulnerabilities Committee on 17 January 2020 when the Committee was demised. 
13 The Group Chairman donated 100% of his 2020 fee to charities in the UK and Hong Kong supporting vulnerable people and in the local response 

to Covid-19.

14 Appointed as a member of the Group Audit Committee on 19 February 2020.

Non-executive Directors’ interests in shares

(Audited)

The shareholdings of persons who were non-executive Directors in 
2020, including the shareholdings of their connected persons, at 
31 December 2020, or date of cessation as a Director if earlier, are 
set out below. Non-executive Directors are expected to meet the 

shareholding guidelines within five years of the date of their 
appointment. All non-executive Directors who had been appointed 
for five years or more at 31 December 2020 met the guidelines 
except Irene Lee, who has committed to acquiring the remaining 
shares as soon as possible, and no later than the conclusion of the 
2021 AGM.

Shares

Kathleen Casey (retired on 24 April 2020)

Laura Cha

Henri de Castries 

James Forese (appointed to the Board on 1 May 2020) 

Steven Guggenheimer (appointed to the Board on 1 May 2020)

Irene Lee

José Antonio Meade Kuribreña

Heidi Miller

Eileen Murray (appointed to the Board on 1 July 2020)

David Nish 

Sir Jonathan Symonds (retired on 18 February 2020)

Jackson Tai 

Mark Tucker

Pauline van der Meer Mohr 

248 HSBC Holdings plc Annual Report and Accounts 2020

Shareholding guidelines 
(number of shares)

Share interests 
(number of shares)

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,000  

15,125 

16,200 

19,251 

115,000 

15,000 

11,904 

15,000 

15,700 

75,000 

50,000 

43,821 

66,515 

307,352 

15,000 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Voting results from Annual General Meeting

2020 Annual General Meeting voting results

Remuneration report
(votes cast)

Remuneration policy (2019)
(votes cast)

2021 annual incentive scorecards

The 2021 annual incentive scorecard measures for our executive 
Directors have been set against the backdrop of the continuing 
impact of the Covid-19 outbreak on the global economy; 
geopolitical risks, particularly those relating to trade and other 
tensions; and expectations that global interest rates will remain 
lower for longer. In this context, the Committee determined the 
scorecard measures should incentivise adapting our business 
model to a protracted, low interest-rate environment; reducing our 
operating costs; and transforming the Group. 

Therefore, the 2021 annual incentive scorecard includes financial 
measures linked to the reduction of the Group's cost base, the 
reduction of assets in low-return areas and the creation of 
opportunities in our high-growth areas. The scorecard also 
includes non-financial measures linked to delivering against our 
customer and employee objectives. 

The Committee will continue to retain discretion to adjust down 
the formulaic outcomes of scorecards, taking into account factors 
such as Group profits, wider business performance and 

2021 annual incentive scorecards measures and weightings

Measures

Adjusted costs

Revenue growth in Asia

RWA reduction in legacy assets/low-return areas

Customer satisfaction

Employee experience
Personal objectives1
Total

For

 96.47 %

Against

 3.53 %

Withheld

––

8,842,653,970
97.36%

323,238,790
2.64%

36,605,397
––

9,525,856,097

258,383,075

47,468,297

stakeholder experience, to ensure alignment between executive 
reward and the broader stakeholder experience.

The weightings and performance measures for the 2021 annual 
incentive award for executive Directors are disclosed below. The 
performance targets are commercially sensitive and it would be 
detrimental to the Group’s interests to disclose them at the start of 
the financial year. Subject to commercial sensitivity, we will 
disclose the targets for a given year in the Annual Report and 
Accounts for that year in the Directors‘ remuneration report.

Executive Directors will be eligible for an annual incentive award 
of up to 215% of base salary.

The 2021 annual incentive scorecards for our Group Managing 
Directors include similar measures as the executive Directors to 
drive performance in each of our businesses, functions and 
regions that contribute to the overall success of the Group. Their 
annual incentive scorecards will also include RoTE and 
environmental measures, which are aligned with achieving the 
three-year forward-looking performance targets in the 2020 LTI.

Group Chief 
Executive

Group Chief 
Financial Officer

%

 20.0 

 20.0 

 20.0 

 15.0 

 15.0 

 10.0 

 100.0 

%

 20.0 

 15.0 

 15.0 

 15.0 

 15.0 

 20.0 

 100.0 

1  For the Group Chief Executive, this includes the launch of our refreshed purpose and values, and the delivery of strategy at pace (equally weighted 

at 5% each). For the Group Chief Financial Officer, this includes Finance Cloud deployment, resolvability assessment framework attestation, 
climate stress tests, and Group Finance costs and FTE (equally weighted at 5% each).

The 2021 annual incentive scorecard is subject to a risk and 
compliance modifier, which allows the Committee the discretion 
to adjust down the overall scorecard outcome to ensure that the 
Group operates soundly when achieving its financial targets. For 
this purpose, the Committee will receive information including any 
risk thresholds outside of tolerance for a significant period of time 
and any risk management failures that have resulted in significant 
customer detriment, reputational damage and/or regulatory 
censure. 

2021 long-term incentives

Payments to past Directors

(Audited)

Details of the 2017 LTI outcome, in which Marc Moses (former 
Group Chief Risk Officer) and Iain Mackay (former Group Finance 
Director) participated, are outlined on page 242. No payments 
were made to, or in respect of, former Directors in the year in 
excess of the minimum threshold of £50,000 set for this purpose.

Payments for loss of office 

(Audited)

Details of the performance measures and targets for LTI awards to 
be made in 2021, in respect of 2020, are provided on page 243. 

No payments for loss of office were made to, or in respect of, 
former or current Directors in the year.

The performance measures and targets for awards to be made in 
respect of 2021, granted in 2022, will be provided in the Annual 
Report and Accounts 2021.

Total pension entitlements 

(Audited)

No employees who served as executive Directors during the year 
have a right to amounts under any HSBC final salary pension 
scheme for their services as executive Directors or are entitled to 
additional benefits in the event of early retirement. There is no 
retirement age set for Directors, but the normal retirement age for 
employees is 65.

External appointments

During 2020, executive Directors did not receive any fees from 
external appointments.

HSBC Holdings plc Annual Report and Accounts 2020 249

Corporate governance 
 
 
 
Report of the Directors | Corporate governance report

Remuneration structure for our Group employees

Total compensation, which comprises fixed and variable pay, is 
the key focus of our remuneration framework, with variable pay 
differentiated by performance and adherence to the HSBC Values. 

Overview of remuneration structure for employees

Remuneration components 
and objectives

Application

We set out below the key features and design characteristics of 
our remuneration framework, which apply on a Group-wide basis, 
subject to compliance with local laws:

Fixed pay
Attract and retain 
employees by paying 
market competitive pay for 
the role, skills and 
experience required for the 
business.

Benefits
Provided in accordance 
with local market practice.
Annual incentive1
Incentivise and reward 
performance based on 
annual financial and non-
financial measures 
consistent with the 
medium- to long-term 
strategy, stakeholder 
interests and adherence to 
HSBC Values.

Deferral
Alignment with the 
medium- to long-term 
strategy, stakeholder 
interests and adherence to 
the HSBC Values.

• Fixed pay may include salary, fixed pay allowance, cash in lieu of pension and other cash allowances in accordance with 

local market practices. These pay elements are based on predetermined criteria, are non-discretionary, are transparent and 
are not reduced based on performance.

• Fixed pay represents a higher proportion of total compensation for more junior employees.
• Elements of fixed pay may change to reflect an individual’s position, role or grade, cost of living in the country, individual 

skills, competencies, capabilities and experience.

• Fixed pay is generally delivered in cash on a monthly basis.

• Benefits may include, but are not limited to, the provision of a pension, medical insurance, life insurance, health assessment 

and relocation support.

• All employees are eligible to be considered for a discretionary variable pay award. Individual awards are determined against 

a balanced scorecard for performance in excess of that required to fulfil an employee's job description.    

• Annual incentives represent a higher proportion of total compensation for more senior employees and will be more closely 

aligned to Group and business performance as seniority increases. 

• Variable pay awards for all Group employees identified as Material Risk Takers ('MRTs') under European Union Regulatory 

Technical Standard ('RTS') 604/2014 are limited to 200% of fixed pay.2

• Awards are generally paid in cash and shares. For MRTs, at least 50% of the awards are in shares and/or where required by 

regulations, in units linked to asset management funds.

• A portion of the annual incentive award may be deferred and vest over a period of three to eight years.

• A Group-wide deferral approach is applicable to all employees. A portion of annual incentive awards above a specified 

threshold is deferred in shares vesting annually over a three-year period with 33% vesting on the first and second 
anniversaries of grant and 34% on the third anniversary. Local employees in France are granted deferred awards that vest 
66% on the second anniversary and 34% on the third anniversary.

• For MRTs identified in accordance with the UK's PRA and FCA remuneration rules, awards are generally subject to a 

minimum 40% deferral (60% for awards of £500,000 or more) over a minimum period of three years3. A longer deferral 
period is applied for certain MRTs as follows:
–

five years for individuals identified in a risk-manager MRT role under the PRA and FCA remuneration rules. This reflects 
the deferral period prescribed by both the PRA and the European Banking Authority for individuals performing key 
senior roles with the Group; or
seven years for individuals in PRA-designated senior management functions, being the deferral period mandated by the 
PRA as reflecting the typical business cycle period.

–

• Individuals based outside the UK who have not been identified at the Group level as an MRT, but who are identified as 

MRTs under local regulations, are generally subject to a three-year deferral period. In Germany, a deferral period of up to 
eight years is applied for members of the local management board and individuals in managerial roles reporting into the 
management board. In Malta, a five-year deferral period is applied for executive committee members. In Australia, local 
MRTs are subject to a four-year deferral period in respect of deferred cash awards. Local MRTs are also subject to the 
minimum deferral rates discussed above, except in China (where a minimum deferral rate of 50% is applied for the Chief 
Executive Officer), Germany (where a minimum deferral rate of 60% is applied for members of the local management board 
and individuals in managerial roles reporting into the management board) and Oman (where a minimum deferral rate of 
45% is applied).

• Where an employee is subject to more than one regulation, the requirement that is specific to the sector and/or country in 
which the individual is working is applied, subject to meeting the minimum requirements applicable under each regulation.
• All deferred awards are subject to malus provisions, subject to compliance with local laws. Awards granted to MRTs on or 

after 1 January 2015 are also subject to clawback.

• HSBC operates an anti-hedging policy for all employees, which prohibits employees from entering into any personal 

hedging strategies in respect of HSBC securities.

• Generally, the underlying instrument for all deferred awards is HSBC shares to ensure alignment between the long-term 

interest of our employees and shareholders.  

• For Group and local MRTs, excluding executive Directors where deferral is typically in the form of shares only, a minimum 
of 50% of the deferred awards is in HSBC shares and the balance is deferred into cash. In accordance with local regulatory 
requirements, for local MRTs in Brazil and Oman 100% of the deferred amount is delivered in shares or linked to the value 
of shares.

• For some employees in our asset management business, where required by the regulations applicable to asset 

management entities within the Group, at least 50% of the deferred award is linked to fund units reflective of funds 
managed by those entities, with the remaining portion of deferred awards being in the form of deferred cash awards.

Deferral instruments
Alignment with the 
medium- to long-term 
strategy, stakeholder 
interests and adherence to 
the HSBC Values.

250 HSBC Holdings plc Annual Report and Accounts 2020

 
Overview of remuneration structure for employees (continued)

Remuneration components 
and objectives

Application

Post-vesting retention 
period
Ensure appropriate 
alignment with 
shareholders.

• Variable pay awards made in HSBC shares or linked to relevant fund units granted to MRTs are generally subject to a one-

year retention period post-vesting. Local MRTs (except those in Brazil, France, Oman and Russia) are also generally subject 
to a one-year retention period post-vesting. For local MRTs in Brazil, France and Russia, a six-month retention period is 
applied. No retention period is applied for local MRTs in Oman. 

• MRTs who are subject to a five-year deferral period, except senior management or individuals in PRA- and FCA-designated 

senior management functions, have a six-month retention period applied to their awards.

Buy-out awards
Support recruitment of 
talent.

Guaranteed variable 
remuneration
Support recruitment of 
talent.

Severance payments
Adhere to contractual 
agreements with 
involuntary leavers.

• Buy-out awards may be offered if an individual holds any outstanding unvested awards that are forfeited on resignation 

from the previous employer.

• The terms of the buy-out awards will not be more generous than the terms attached to the awards forfeited on cessation of 

employment with the previous employer.

• Guaranteed variable remuneration is awarded in exceptional circumstances for new hires, and is limited to the individual’s 

first year of employment only.

• The exceptional circumstances where HSBC would offer guaranteed variable remuneration would typically involve a critical 
new hire and would also depend on factors such as the seniority of the individual, whether the new hire candidate has any 
competing offers and the timing of the hire during the performance year.

• Where an individual’s employment is terminated involuntarily for gross misconduct then, subject to compliance with local 

laws, the Group’s policy is not to make any severance payment in such cases. For such individuals, all outstanding 
unvested awards are forfeited. 

• For other cases of involuntary termination of employment the determination of any severance will take into consideration 

the performance of the individual, contractual notice period, applicable local laws and circumstances of the case.

• Generally, all outstanding unvested awards will normally continue to vest in line with the applicable vesting dates. Where 

relevant, any performance conditions attached to the awards, and malus and clawback provisions, will remain applicable to 
those awards.

• Severance amounts awarded to MRTs are not considered as variable pay for the purpose of application of the deferral and 

variable pay cap rules under the PRA and FCA remuneration rules where such amounts include: (i) payments of fixed 
remuneration that would have been payable during the notice and/or consultation period; (ii) statutory severance payments; 
(iii) payments determined in accordance with any approach applicable in the relevant jurisdictions; and (iv) payments made 
to settle a potential or actual dispute.

1  Executive Directors are also eligible to be considered for a long-term incentive award. See details on page 235.
2  Shareholders approved the increase in the maximum ratio between the fixed and variable components of total remuneration from 1:1 to 1:2 at the 
2014 AGM held on 23 May 2014 (98% in favour). The Group has not used the EBA discount rate for the purpose of computing the ratio between 
fixed and variable components of 2020 total remuneration. 
In accordance with the terms of the PRA and FCA remuneration rules, and subject to compliance with local regulations, the deferral requirement 
for MRTs is not applied to individuals where their total compensation is £500,000 or less and variable pay is not more than 33% of total 
compensation. For these individuals, the Group standard deferral applies.

3 

HSBC Holdings plc Annual Report and Accounts 2020 251

Corporate governance 
Report of the Directors | Corporate governance report

Link between risk, performance and reward

Our remuneration practices promote sound and effective risk 
management while supporting our business objectives. 

We set out below the key features of our remuneration 
framework, which help enable us to achieve alignment between 
risk, performance and reward, subject to compliance with local 
laws and regulations:

Alignment between risk and reward

Framework 
elements

Variable pay 
pool and 
individual 
performance 
scorecard

Application

The Group variable pay pool is expected to move in line with Group performance. We also use a countercyclical funding methodology, 
with both a floor and a ceiling, with the payout ratio generally reducing as performance increases to avoid pro-cyclicality. The floor 
recognises that even in challenging times, remaining competitive is important. The ceiling recognises that at higher levels of performance 
it is not always necessary to continue to increase the variable pay pool, thereby limiting the risk of inappropriate behaviour to drive 
financial performance.
The main quantitative and qualitative performance and risk metrics used for assessment of performance include:
• Group and business unit financial performance, including capital requirements;
• current and future risks, taking into consideration performance against the risk appetite statement (‘RAS’), annual operating plan and 

global conduct outcomes;

• fines, penalties and provisions for customer redress, which are automatically included in the Committee’s definition of profit; and
• assessment of individual performance with reference to a balanced scorecard of clear and relevant objectives. Objectives included in 
the performance scorecards of senior management take into account appropriate measures linked to sustainability risks, such as: 
reduction in carbon footprint; facilitating financing to help clients with their transition to net zero; employee diversity targets; and risk 
and compliance measures. A mandatory global risk objective is included in the scorecard of all other employees. All employees receive 
a behaviour rating as well as a performance rating, which ensures performance is assessed not only on what is achieved but also on 
how it is achieved.

Remuneration 
for control 
function staff

• The performance and reward of individuals in control functions, including risk and compliance employees, are assessed according to a 

balanced scorecard of objectives specific to the functional role they undertake. This is to ensure their remuneration is determined 
independent of the performance of the business areas they oversee.

• The Committee is responsible for approving the remuneration recommendations for the Group Chief Risk Officer and senior 

management in control functions.

• Group policy is for control functions staff to report into their respective function. Remuneration decisions for senior functional roles are 

led by, and must carry the approval of, the global function head.

• Remuneration is carefully benchmarked with the market and internally to ensure it is set at an appropriate level.

Variable pay 
adjustments 
and conduct 
recognition

• Variable pay awards may be adjusted downwards in circumstances including:
–  detrimental conduct, including conduct that brings HSBC into disrepute;
–  involvement in events resulting in significant operational losses, or events that have caused or have the potential to cause 
    significant harm to HSBC; and
–  non-compliance with the HSBC Values and other mandatory requirements or policies.

• Rewarding positive conduct may take the form of use of our global recognition programme, At Our Best, or positive adjustments to 

Malus

Clawback

Sales 
incentives

Identification 
of MRTs

variable pay awards.

Malus can be applied to unvested deferred awards granted in prior years in circumstances including:
• detrimental conduct, including conduct that brings the business into disrepute;
• past performance being materially worse than originally reported;
• restatement, correction or amendment of any financial statements; and
• improper or inadequate risk management.

Clawback can be applied to vested or paid awards granted to MRTs on or after 1 January 2015 for a period of seven years, extended to 
10 years for employees under the PRA's Senior Managers Regime in the event of ongoing internal/regulatory investigation at the end of 
the seven-year period. Clawback may be applied in circumstances including:
• participation in, or responsibility for, conduct that results in significant losses;
• failing to meet appropriate standards and propriety;
• reasonable evidence of misconduct or material error that would justify, or would have justified, summary termination of a contract of 

employment; and 

• a material failure of risk management suffered by HSBC or a business unit in the context of Group risk-management standards, 

policies and procedures.

• We generally do not operate commission-based sales plans.

• We identify individuals as MRTs based on the qualitative and quantitative criteria set out in the RTS. We also identify MRTs based on 

additional criteria developed internally. The following key principles underpin HSBC’s identification process:
– MRTs are identified at Group, HSBC Bank (consolidated) and HSBC UK Bank level.
– MRTs are also identified at other solo regulated entity level as required by the regulations.
– When identifying an MRT, HSBC considers an employee’s role within its matrix management structure. The global business and 

function that an individual works within takes precedence, followed by the geographical location in which they work.

• In addition to applying the qualitative and quantitative criteria specified in the RTS, we also identify additional MRTs based on our own 

internal criteria, which include compensation thresholds and individuals in certain roles and grades who otherwise would not be 
identified as MRTs under the criteria prescribed in the RTS.

• The list of MRTs, and any exclusions from it, is reviewed by chief risk officers and chief operating officers of the relevant global 

businesses and functions. The overall results are reviewed by the Group Chief Risk Officer.

• The Group Remuneration Committee reviews the methodology, key decisions regarding identification, and the results of the 

identification exercise, including proposed MRT exclusions.

252 HSBC Holdings plc Annual Report and Accounts 2020

 
Additional remuneration disclosures

This section provides disclosures required under the Hong Kong 
Ordinances, Hong Kong Listing Rules and the Pillar 3 remuneration 
disclosures.

For the purpose of the Pillar 3 remuneration disclosures, executive 
Directors and non-executive Directors are considered to be 
members of the management body. Members of the Group 
Executive Committee other than the executive Directors are 
considered as senior management.

MRT remuneration disclosures

The following tables set out the remuneration disclosures for 
individuals identified as MRTs for HSBC Holdings. Remuneration 
information for individuals who are only identified as MRTs at 
HSBC Bank plc, HSBC UK Bank plc or other solo-regulated entity 
levels is included, where relevant, in those entities' disclosures.

The 2020 variable pay information included in the following tables 
is based on the market value of awards. For share awards, the 
market value is based on HSBC Holdings' share price at the date 
of grant (unless indicated otherwise). For cash awards, it is the 
value of awards expected to be paid to the individual over the 
deferral period.

Remuneration – fixed and variable amounts (REM1)

Fixed ($m)

Variable2 ($m)

Executive Directors

Non-executive Directors

Senior management

Investment banking

Retail banking

Asset management

Corporate functions

Independent control 
functions

All other

Total

Cash-
based

Of 
which: 
deferred

Share-
based3

Of 
which: 
deferred

Other 
forms

Of 
which: 
deferred

Number 
of MRTs

Cash-
based1

Share-
based

2   

12   

15   

2.8   

7.0   

32.9   

3.4   

—   

—   

Total

6.2   

7.0   

—   

—   

—   

—   

11.2   

—   

32.9   

17.1   

10.3   

19.6   

541    342.4   

—    342.4    130.6   

65.7    138.6   

194    104.2   

—    104.2   

34.8   

15.2   

34.8   

33   

124   

20.5   

69.9   

—   

—   

20.5   

69.9   

8.1   

3.8   

5.7   

22.5   

10.4   

23.2   

11.9   

145   

67.6   

83   

64.3   

1.2   

1.3   

68.8   

18.0   

65.6   

17.7   

6.1   

9.0   

14.9   

7.6   

18.5   

10.3   

9.6   

—   

12.8   

74.6   

17.5   

3.0   

Total

11.2   

—   

Total 
($m)

17.4 

7.0 

36.7   

69.6 

—   

—   

—   

—    269.2    611.6 

—   

69.6    173.8 

1.8   

16.5   

37.0 

—   

45.7    115.6 

—   

—   

32.9    101.7 

36.2    101.8 

—   

—   

—   

—   

—   

2.7   

—   

—   

—   

  1,149    711.6   

5.9    717.5    248.8    120.5    266.5    147.3   

2.7   

1.8    518.0 

1,235.5

1  Cash-based fixed remuneration is paid immediately.
2  Variable pay awarded in respect of 2020. In accordance with shareholder approval received on 23 May 2014 (98% in favour), for each MRT the 

variable component of remuneration for any one year is limited to 200% of fixed component of the total remuneration.
In general, share-based awards are made in HSBC shares. Vested shares are subject to a retention period of up to one year.

3 

Guaranteed bonus, sign-on and severance payments (REM2)

Executive Directors

Senior management

Investment banking

Retail banking

Asset management

Corporate functions

Independent control functions

All other

Total

Guaranteed bonus and sign-
on payments1

Severance payments2

Made during 
year ($m)

Number of 
beneficiaries

Awarded 
during year 
($m)

Number of 
beneficiaries

Highest such 
award to a 
single person 
($m)

Paid during 
year ($m)

Number of 
beneficiaries

—   

—   

0.5   

0.9   

—   

1.0   

—   

—   

2.4   

—   

—   

1   

1   

—   

1   

—   

—   

3   

—   

—   

36.6   

5.3   

1.9   

5.8   

4.2   

4.4   

58.2   

—   

—   

38   

11   

4   

12   

10   

6   

81 

—   

—   

7.3   

1.8   

1.0   

2.0   

0.7   

1.3   

–  

—   

—   

35.0   

4.6   

1.9   

5.8   

3.6   

4.4   

55.3   

— 

— 

37 

11 

4 

12 

9 

6 

79 

1  No sign-on payments were made in 2020. A guaranteed bonus is awarded in exceptional circumstances for new hires, and in the first year only. 
The circumstances where HSBC would offer a guaranteed bonus would typically involve a critical new hire, and would also depend on factors 
such as the seniority of the individual, whether the new hire candidate has any competing offers and the timing of the hire during the performance 
year.
Includes payments such as payment in lieu of notice, statutory severance, outplacement service, legal fees, ex-gratia payments and settlements 
(excludes pre-existing benefit entitlements triggered on terminations).

2 

HSBC Holdings plc Annual Report and Accounts 2020 253

Corporate governance 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Directors | Corporate governance report

Deferred remuneration at 31 December1 (REM3)

Total outstanding2

Of which:
unvested

Of which: total 
outstanding 
deferred and 
retained exposed 
to ex post explicit 
and/or implicit 
adjustment

Total amount of 
amendment during 
the year due to ex 
post implicit 
adjustment

Total amount of 
amendment during 
the year due to ex 
post explicit 
adjustment3

Total amount of 
deferred paid out 
in the financial 
year4

3.6   

27.4   

195.0   

41.9   

8.1   

35.0   

23.6   

30.2   

9.7   

25.7   

183.3   

45.9   

5.6   

39.5   

28.8   

35.2   

—   

—   

—   

—   

7.0   

0.8   

0.2   

—   

3.6   

27.4   

195.0   

41.9   

8.1   

35.0   

23.6   

30.2   

9.1   

22.4   

146.0   

38.1   

4.2   

31.5   

26.2   

27.7   

—   

—   

—   

—   

5.6   

0.7   

0.1   

—   

3.6   

27.4   

195.0   

41.9   

8.1   

35.0   

23.6   

30.2   

9.7   

25.7   

183.3   

45.9   

5.6   

39.5   

28.8   

35.2   

—   

—   

—   

—   

7.0   

0.8   

0.2   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(5.4)   

(12.7)   

(90.5)   

(22.6)   

(2.7)   

(19.6)   

(14.5)   

(17.4)   

—   

—   

—   

—   

0.3   

0.1   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

0.1 

5.1 

62.7 

10.2 

3.4 

9.7 

4.5 

8.7 

2.5 

11.6 

130.6 

29.1 

4.3 

26.5 

18.0 

20.4 

— 

— 

— 

— 

1.7 

0.3 

0.1 

— 

$m

Cash

Executive Directors

Senior management

Investment banking

Retail banking

Asset management

Corporate functions

Independent control functions

All other

Shares

Executive Directors

Senior management

Investment banking

Retail banking

Asset management

Corporate functions

Independent control functions

All other

Other forms

Executive Directors

Senior management

Investment banking

Retail banking

Asset management

Corporate functions

Independent control functions

All other

1  This table provides details of balances and movements during performance year 2020. For details of variable pay awards granted for 2020, refer to 
the 'Remuneration – fixed and variable amounts' table. Deferred remuneration is made in cash and/or shares. Share-based awards are made in 
HSBC shares.
Includes unvested deferred awards and vested deferred awards subject to retention period at 31 December 2020.
Includes any amendments due to malus or clawback.  

2 
3 
4  Shares are considered as paid when they vest. Vested shares are valued using the sale price or the closing share price on the business day 

immediately preceding the vesting day.

MRTs’ remuneration by band1

€0 – 1,000,000

€1,000,000 – 1,500,000

€1,500,000 – 2,000,000

€2,000,000 – 2,500,000

€2,500,000 – 3,000,000

€3,000,000 – 3,500,000

€3,500,000 – 4,000,000

€4,000,000 – 4,500,000

€4,500,000 – 5,000,000

€5,000,000 – 6,000,000

€6,000,000 – 7,000,000

€7,000,000 – 8,000,000

€8,000,000 – 9,000,000

€9,000,000 – 10,000,000

Management body

All other

11   

—   

1   

—   

—   

—   

—   

—   

—   

1   

—   

—   

—   

1   

814   

179   

76   

27   

13   

11   

7   

1   

1   

3   

3   

—   

—   

—   

Total

825 

179 

77 

27 

13 

11 

7 

1 

1 

4 

3 

— 

— 

1 

1  Table prepared in euros in accordance with Article 450 of the European Union Capital Requirements Regulation, using the exchange rates 

published by the European Commission for financial programming and budget for December of the reported year as published on its website.

254 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Directors’ emoluments

The details of compensation paid to executive and non-executive Directors for the year ended 31 December 2020 are set out below.

Emoluments

Basic salaries, allowances and benefits in kind

Pension contributions
Performance-related pay paid or receivable1
Inducements to join paid or receivable

Compensation for loss of office

Notional return on deferred cash

Total

Total ($000)

Noel Quinn

Ewen Stevenson

Non-executive Directors

2020

£000

3,338   

—   

4,517   

—   

—   

17   

7,872   

10,097   

2019

£000

2020

£000

1,312   

1,806   

—   

665   

—   

—   

—   

1,977   

2,522   

—   

2,568   

1,431   

—   

—   

5,805   

7,446   

2019

£000

1,820   

—   

3,176   

1,974   

—   

—   

6,970   

8,890   

2020

£000

5,527   

—   

—   

—   

—   

—   

2019

£000

5,335 

— 

— 

— 

— 

— 

5,527   

7,090 

5,335 

6,843

1 Includes the value of the deferred and LTI awards at grant. 

The aggregate amount of Directors' emoluments (including both 
executive Directors and non-executive Directors) for the year 
ended 31 December 2020 was $24,624,520. As per our policy, 
benefits in kind may include, but are not limited to, the provision 
of medical insurance, income protection insurance, health 
assessment, life assurance, club membership, tax assistance, car 
benefit, travel assistance, provision of company owned-
accommodation and relocation costs (including any tax due on 
these benefits, where applicable). Post-employment medical 
insurance benefit was provided to former Directors, including 
Douglas Flint valued at £5,859 ($7,515), Stuart Gulliver valued at 
£5,859 ($7,515) and John Flint valued at £4,784 ($6,136). Tax 
support fees of £460 ($590) were also provided to Stuart Gulliver, 
giving a total aggregate value of £16,962 ($21,756) for benefits 
provided to past directors. The aggregate value of Director 
retirement benefits for current Directors is nil. Amounts are 
converted into US dollars based on the average year-to-date 
exchange rates for the respective year.

Emoluments

£000s

Basic salaries, allowances and benefits in kind

Pension contributions
Performance-related pay paid or receivable1
Inducements to join paid or receivable

Compensation for loss of office

Total

Total ($000)

1 Includes the value of deferred shares awards at grant.

There were payments under retirement benefit arrangements with 
two former Directors of $413,160. The provision at 31 December 
2020 in respect of unfunded pension obligations to former 
Directors amounted to $7,821,639.

Emoluments of senior management and five highest 
paid employees

The following tables set out the details of emoluments paid to 
senior management, which in this case comprises executive 
Directors and members of the Group Executive Committee, for the 
year ended 31 December 2020, or for the period of appointment in 
2020 as a Director or member of the Group Executive Committee. 
Details of the remuneration paid to the five highest paid 
employees, comprising one executive Director and four Group 
Managing Directors, for the year ended 31 December 2020, are 
also presented.

Five highest paid employees

Senior management

13,319   

15   

17,310   

—   

—   

30,644   

39,307   

36,831 

57 

34,431 

1,308 

848 

73,475 

94,247 

Emoluments by bands

Hong Kong dollars

$1,500,001 – $2,000,000

$4,500,001 – $5,000,000

$9,000,001 – $9,500,000

$9,500,001 – $10,000,000

$10,000,001 – $10,500,000

$13,500,001 – $14,000,000

$15,000,001 – $15,500,000

$24,500,001 – $25,000,000

$27,000,001 – $27,500,000

$28,000,001 – $28,500,000

$28,500,001 – $29,000,000

$29,000,001 – $29,500,000

$30,000,001 – $30,500,000

$41,000,001 – $41,500,000

$43,500,001 – $44,000,000

$44,000,001 – $44,500,000

$44,500,001 – $45,000,000

$48,500,001 – $49,000,000

$49,000,001 – $49,500,000

$50,500,001 – $51,000,000

$54,500,001 – $55,000,000

$66,500,001 – $67,000,000

$78,000,001 – $78,500,000

US dollars

$193,397 – $257,863

$580,191 – $644,657

$1,160,382 – $1,224,848

$1,224,848 – $1,289,313

$1,289,314 – $1,353,779

$1,740,573 – $1,805,039

$1,933,970 – $1,998,436

$3,158,818 – $3,223,284

$3,481,146 – $3,545,612

$3,610,078 – $3,674,543

$3,674,543 – $3,739,009

$3,739,009 – $3,803,475

$3,867,940 – $3,932,406

$5,286,185 – $5,350,651

$5,608,514 – $5,672,979

$5,672,979 – $5,737,445

$5,737,445 – $5,801,910

$6,253,170 – $6,317,636

$6,317,636 – $6,382,101

$6,511,033 – $6,575,499

$7,026,758 – $7,091,224

$8,573,934 – $8,638,400

$10,056,645 – $10,121,110

Number of  highest paid employees Number of senior management

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

1   

2   

1   

1   

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

1 

1 

1 

1 

1 

1 

1 

1 

— 

1 

1 

HSBC Holdings plc Annual Report and Accounts 2020 255

Corporate governance 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Directors | Corporate governance report

Share capital and other related disclosures

Share buy-back programme

HSBC Holdings did not announce a share buy-back to purchase its 
ordinary shares of $0.50 each during the year.

Dividends

Dividends for 2020

On 31 March 2020, HSBC announced that, in response to a 
written request from the Bank of England through the Prudential 
Regulation Authority ('PRA'), the Board had cancelled the fourth 
interim dividend for 2019. Similar requests were also made to 
other UK incorporated banking groups. We also announced that 
until the end of 2020 we would make no quarterly or interim 
dividend payments or accruals in respect of ordinary shares.

In December 2020, the PRA announced a temporary approach to 
shareholder distributions for 2020 in which it set out a framework 
for board decisions on dividends. On 23 February 2021, after 
considering the requirements of the temporary approach, the 
Directors approved an interim dividend for 2020 of $0.15 per 
ordinary share. The interim dividend will be payable on 29 April 
2021 in cash in US dollars, or in sterling or Hong Kong dollars at 
exchange rates to be determined on 19 April 2021.

The 2020 interim dividend will be paid in cash with no scrip 
alternative. The Group has decided to discontinue the scrip 
dividend option as it is dilutive, including to dividend per share 
progression over time.

As the interim dividend for 2020 was approved after 31 December 
2020, it has not been included in the balance sheet of HSBC as a 
liability. The distributable reserves of HSBC Holdings at 
31 December 2020 were $31.3bn.

A quarterly dividend of $15.50 per 6.20% non-cumulative US 
dollar preference share, Series A (‘Series A dollar preference 
share’), (equivalent to a dividend of $0.3875 per Series A American 
Depositary Share (‘ADS’), each of which represents 1/40th of a 
Series A dollar preference share), and £0.01 per Series A sterling 
preference share was paid on 16 March, 16 June, 15 September 
and 15 December 2020. The Series A dollar preference shares 
were redeemed on 13 January 2021.

Dividends for 2021

In December 2020, the PRA also announced that it intends to 
transition back to its standard approach to capital setting and 
shareholder distributions through 2021. In the meantime, for 2021 
dividends the PRA is content for appropriately prudent dividends 
to be accrued but not paid out. The PRA aims to provide a further 
update ahead of the 2021 half-year results of large UK banks.

The Group will not pay quarterly dividends during 2021 but will 
consider whether to announce an interim dividend at the 2021 
half-year results in August. 

The Group will review whether to revert to paying quarterly 
dividends at or ahead of its 2021 results announcement in 
February 2022.

A dividend of £0.01 per Series A sterling preference share was 
approved on 23 February 2021 for payment on 15 March 2021.

Share capital

Issued share capital

The nominal value of HSBC Holdings’ issued share capital paid 
up at 31 December 2020 was $10,346,810,550 divided into 
20,693,621,100 ordinary shares of $0.50 each, 1,450,000 non-
cumulative preference shares of $0.01 each and one non-
cumulative preference share of £0.01, representing approximately 
100.00%, 0.00%, and 0.00% respectively of the nominal value of 
HSBC Holdings’ total issued share capital paid up at 31 December 
2020. The 1,450,000 non-cumulative preference shares of $0.01 
each were redeemed on 13 January 2021.

256 HSBC Holdings plc Annual Report and Accounts 2020

Rights, obligations and restrictions attaching to shares

The rights and obligations attaching to each class of ordinary and 
non-cumulative preference shares in our share capital are set out 
in full in our Articles of Association. The Articles of Association 
may be amended by special resolution of the shareholders and can 
be found on our website at www.hsbc.com/who-we-are/
leadership-and-governance/board-responsibilities.

Ordinary shares

HSBC Holdings has one class of ordinary share, which carries no 
right to fixed income. There are no voting restrictions on the 
issued ordinary shares, all of which are fully paid. On a show 
of hands, each member present has the right to one vote at 
general meetings. On a poll, each member present or voting 
by proxy is entitled to one vote for every $0.50 nominal value 
of share capital held. There are no specific restrictions on 
transfers of ordinary shares, which are governed by the 
general provisions of the Articles of Association and prevailing 
legislation.

Information on the policy adopted by the Board for paying interim dividends 
on the ordinary shares may be found in the 'Shareholder information' section 
on page 371.

Dividend waivers

HSBC Holdings' employee benefit trusts, which hold shares in 
HSBC Holdings in connection with the operation of its share plans, 
have lodged standing instructions to waive dividends on shares 
held by them that have not been allocated to employees. There 
were no dividends waived during 2020 as there were no dividends 
paid on ordinary shares during 2020.

Preference shares

The preference shares, which have preferential rights to income 
and capital, do not, in general, confer a right to attend and vote at 
general meetings.

There are three classes of preference shares in the share capital of 
HSBC Holdings: non-cumulative US dollar preference shares of 
$0.01 each (‘dollar preference shares’); non-cumulative preference 
shares of £0.01 each (‘sterling preference shares’); and non-
cumulative preference shares of €0.01 (‘euro preference shares’). 
The sterling preference share in issue is a Series A sterling 
preference share. There are no dollar preference shares or euro 
preference shares in issue.

Information on dividends approved for 2020 and 2021 may be found in Note 
8 on the financial statements on page 309.

Further details of the rights and obligations attaching to the HSBC Holdings’ 
issued share capital may be found in Note 31 on the financial statements.

Compliance with Hong Kong Listing Rule 13.25A(2)

HSBC Holdings has been granted a waiver from strict compliance 
with Rule 13.25A(2) of the Rules Governing the Listing of 
Securities on the Stock Exchange of Hong Kong.

Under this waiver, HSBC’s obligation to file a Next Day Return 
following the issue of new shares, pursuant to the vesting of share 
awards granted under its share plans to persons who are not 
Directors, would only be triggered where it falls within one of the 
circumstances set out under Rule 13.25A(3).

Share capital changes in 2020

The following events occurred during the year in relation to the 
ordinary share capital of HSBC Holdings:

Scrip dividends

There were no scrip dividends issued during the year.

 
All-employee share plans

HSBC Holdings Savings-Related Share Option Plan (UK)

HSBC ordinary shares issued in £

Options over HSBC ordinary shares lapsed

Number

Aggregate
nominal
value

$

Exercise price

from
£

to
£

1,387,599   

693,800   

2.6270   

5.9640 

44,189,936   

22,094,968 

Options over HSBC ordinary shares granted in response to approximately 29,048 applications 
from HSBC employees in the UK on 24 September 2020

  111,469,393   

55,734.697 

HSBC International Employee Share Purchase Plan

679,640   

339,820   

3.0855   

HSBC share plans

HSBC Holdings
ordinary shares 
issued

Aggregate
nominal
value

$

Market value per share

from

£

to

£
5.9140 

Vesting of awards under the HSBC Share Plan 2011

53,029,316   

26,514,658   

3.2290   

5.6220 

HSBC Holdings
ordinary shares 
issued

Aggregate
nominal
value

$

Market value per share

from

£

to

£

Authorities to allot and to purchase shares and 
pre-emption rights

At the AGM in 2020, shareholders renewed the general authority 
for the Directors to allot new shares up to 13,554,626,552 ordinary 
shares, 15,000,000 non-cumulative preference shares of £0.01 
each, 15,000,000 non-cumulative preference shares of $0.01 each 
and 15,000,000 non-cumulative preference shares of €0.01 each. 
Shareholders also renewed the authority for the Directors to make 
market purchases of up to 2,033,193,983 ordinary shares, which 
was not exercised during the year.

In addition, shareholders gave authority for the Directors to grant 
rights to subscribe for, or to convert any security into, no more 
than 4,066,387,966 ordinary shares in relation to any issue by 
HSBC Holdings or any member of the Group of contingent 
convertible securities that automatically convert into or are 
exchanged for ordinary shares in HSBC Holdings in prescribed 
circumstances. For further details on the issue of contingent 
convertible securities, see Note 31 on the financial statements. 

Other than as disclosed in the tables above headed ‘Share capital 
changes in 2020’, the Directors did not allot any shares during 
2020.

Debt securities

In 2020, HSBC Holdings issued the equivalent of $15.95bn of debt 
securities in the public capital markets in a range of currencies and 
maturities in the form of senior securities to ensure it meets the 
current and proposed regulatory rules, including those relating to 
the availability of adequate total loss-absorbing capacity. For 
further details of capital instruments and bail-inable debt, see 
Notes 28 and 31 on pages 344 and 353.

Treasury shares

In accordance with the terms of a waiver granted by the Hong 
Kong Stock Exchange on 19 December 2005, HSBC Holdings 
will comply with the applicable law and regulation in the UK in 
relation to the holding of any shares in treasury and with the 
conditions of the waiver in connection with any shares it may hold 
in treasury. At 31 December 2020, pursuant to Chapter 6 of the UK 
Companies Act 2006, 325,273,407 ordinary shares were held in 
treasury. This was the maximum number of shares held at any 
time during 2020, representing 1.57% of the shares in issue as at 
31 December 2020. The nominal value of shares held in treasury 
was $162,636,704. 

Notifiable interests in share capital

At 31 December 2020, HSBC Holdings had received the following 
notification of major holdings of voting rights pursuant to the 
requirements of Rule 5 of the Disclosure, Guidance and 
Transparency Rules:

• BlackRock, Inc. gave notice on 3 March 2020 that on 

2 March 2020 it had the following: an indirect interest in HSBC 
Holdings ordinary shares of 1,235,558,490; qualifying financial 
instruments with 7,294,459 voting rights that may be acquired 
if the instruments are exercised or converted; and financial 
instruments with a similar economic effect to qualifying 
financial instruments, which refer to 2,441,397 voting rights, 
representing 6.07%, 0.03% and 0.01%, respectively, of the 
total voting rights at 2 March 2020.

No further notifications had been received pursuant to the 
requirements of Rule 5 of the Disclosure, Guidance and 
Transparency Rules between 31 December 2020 and 15 February 
2021.

At 31 December 2020, according to the register maintained by 
HSBC Holdings pursuant to section 336 of the Securities and 
Futures Ordinance of Hong Kong:

• BlackRock, Inc. gave notice on 1 September 2020 that on 

27 August 2020 it had the following interests in HSBC Holdings 
ordinary shares: a long position of 1,477,023,361 shares and a 
short position of 38,760,188 shares, representing 7.14% and 
0.19%, respectively, of the ordinary shares in issue at that date. 

• Ping An Asset Management Co., Ltd, gave notice on 

25 September 2020 that on 23 September 2020 it had a long 
position of 1,655,479,531 in HSBC Holdings ordinary shares, 
representing 8.00% of the ordinary shares in issue at that date.

Sufficiency of float

In compliance with the Rules Governing the Listing of Securities 
on The Stock Exchange of Hong Kong Limited, at least 25% of the 
total issued share capital has been held by the public at all times 
during 2020 and up to the date of this report.

Dealings in HSBC Holdings listed securities

The Group has policies and procedures that, except where 
permitted by statute and regulation, prohibit specified transactions 
in respect of its securities listed on The Stock Exchange of Hong 
Kong Limited. Except for dealings as intermediaries or as trustees 
by subsidiaries of HSBC Holdings, neither HSBC Holdings nor any 
of its subsidiaries has purchased, sold or redeemed any of its 
securities listed on The Stock Exchange of Hong Kong Limited 
during the year ended 31 December 2020.

HSBC Holdings plc Annual Report and Accounts 2020 257

Corporate governance 
 
 
 
 
 
 
 
Report of the Directors | Corporate governance report

Directors’ interests

Pursuant to the requirements of the UK Listing Rules and 
according to the register of Directors’ interests maintained by 
HSBC Holdings pursuant to section 352 of the Securities and 
Futures Ordinance of Hong Kong, the Directors of HSBC Holdings 
at 31 December 2020 had certain interests, all beneficial unless 
otherwise stated, in the shares or debentures of HSBC Holdings 
and its associated corporations. Save as stated in the following 

Directors’ interests – shares and debentures

table, no further interests were held by Directors, and no Directors 
or their connected persons were awarded or exercised any right to 
subscribe for any shares or debentures in any HSBC corporation 
during the year.

No Directors held any short position as defined in the Securities 
and Futures Ordinance of Hong Kong in the shares or debentures 
of HSBC Holdings and its associated corporations.

At 1 Jan
2020, or date of 
appointment, if later

Beneficial
owner

Child 
under 18 
or spouse

Jointly with 
another 
person

Footnotes

Trustee

Total
interests

At 31 Dec 2020 or date of cessation, if earlier

HSBC Holdings ordinary shares

Kathleen Casey (retired on 24 April 2020)

Laura Cha

Henri de Castries

James Forese (appointed to the Board on 1 May 2020)

Steven Guggenheimer (appointed to the Board on 1 May 
2020)

Irene Lee

José Antonio Meade Kuribreña 

Heidi Miller

Eileen Murray (appointed to the Board on 1 July 2020)

David Nish 

Noel Quinn 

Ewen Stevenson

Sir Jonathan Symonds (retired on 18 February 2020)

Jackson Tai 

Mark Tucker

Pauline van der Meer Mohr

1

1

1,4

1

1

1

2

2

1, 3

15,125   

15,125   

16,200   

16,200   

19,251   

19,251   

—   

115,000   

—   

—   

11,904   

11,904   

—   

15,000   

15,700   

15,700   

—   

75,000 

—   

—   

—   

—   

—   

—   

—   

—   

50,000   

—   

50,000   

441,925   

778,958   

233,972   

545,731   

—   

—   

43,821   

38,823   

4,998 

—   

—   

—   

—   

15,000   

—   

—   

—   

—   

—   

—   

66,515   

32,800   

11,965   

21,750   

307,352   

307,352   

15,000   

15,000   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

15,125 

16,200 

19,251 

115,000 

15,000 

11,904 

15,000 

15,700 

75,000 

50,000 

778,958 

545,731 

43,821 

66,515 

307,352 

15,000 

1 Kathleen Casey has an interest in 3,025, James Forese has an interest in 23,000, Steven Guggenheimer has an interest in 3,000, José Antonio 
Meade Kuribreña has an interest in 3,000, Heidi Miller has an interest in 3,140, Eileen Murray has an interest in 15,000 and Jackson Tai has an 
interest in 13,303 listed ADS, which are categorised as equity derivatives under Part XV of the Securities and Futures Ordinance of Hong Kong. 
Each ADS represents five HSBC Holdings ordinary shares.

2  Executive Directors’ other interests in HSBC Holdings ordinary shares arising from the HSBC Holdings Savings-Related Share Option Plan (UK) 

and the HSBC Share Plan 2011 are set out in the Scheme interests in the Directors’ remuneration report on page 229. At 31 December 2020, the 
aggregate interests under the Securities and Futures Ordinance of Hong Kong in HSBC Holdings ordinary shares, including interests arising 
through employee share plans and the interests above were: Noel Quinn – 1,333,514; and Ewen Stevenson – 1,751,278. Each Director’s total 
interests represents less than 0.01% of the shares in issue and 0.01% of the shares in issue excluding treasury shares.

3  Jackson Tai has a non-beneficial interest in 11,965 shares of which he is custodian.
4  On 19 May 2020, Steven Guggenheimer reported to HSBC that he had acquired 5,000 shares on 1 May 2020. Prior clearance was not obtained as 
required pursuant to the standards set out in the Hong Kong Model Code for Securities Transactions by Directors of Listed Issuers. Enhancements 
have been made to the Directors' onboarding process, along with communication throughout the year, to highlight share dealing obligations.

There have been no changes in the shares or debentures of the 
Directors from 31 December 2020 to the date of this report.

Listing Rule 9.8.4 and other disclosures

This section of the Annual Report and Accounts 2020 forms part of 
and includes certain disclosures required in the Report of the 
Directors incorporated by cross-reference, including under Listing 
Rule 9.8.4 and otherwise as applicable by law.

Corporate Governance Committee report sets out further detail on 
the Board selection process. The number of Directors (other than 
any alternate Directors) must not be fewer than five nor exceed 25. 
The Board may at any time appoint any person as a Director, 
either to fill a vacancy or as an addition to the existing Board. The 
Board may appoint any Director to hold any employment or 
executive office, and may revoke or terminate any such 
appointment. 

Content

Long-term incentives

Dividend waivers

Dividends

Change of control

Emissions

Energy efficiency

Section 172 and stakeholder engagement

Page references

243

256

256

260

46

53, 55

22

Principal activities of HSBC

12, 30, 85, 335

Business review and future developments

12–41, 43, 109, 118, 362

Directors’ governance

Appointment and re-election

A rigorous selection process is followed for the appointment of 
Directors. Appointments are made on merit and candidates are 
considered against objective criteria, having regard to the benefits 
of a diverse Board. Appointments are made in accordance with 
HSBC Holdings' Articles of Association. The Nomination & 

Non-executive Directors are appointed for an initial three-year 
term and, subject to continued satisfactory performance based 
upon an assessment by the Group Chairman and the Nomination 
& Corporate Governance Committee, are proposed for re-election 
by shareholders at each AGM. They typically serve two three-year 
terms. The Board may invite a Director to serve additional periods 
but any term beyond six years is subject to review with an 
explanation to be provided in the Annual Report and Accounts. 

Shareholders vote at each AGM on whether to elect and re-elect 
individual Directors. All Directors that stood for election and re-
election at the 2020 AGM were elected and re-elected by 
shareholders.

None of the Directors who retired during the year or who are not 
offering themselves for re-election at the 2021 AGM have raised 
concerns about the operation of the Board or the management of 
the company.

No executive Director is involved in deciding their own 
remuneration outcome.

258 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commitments

The terms and conditions of the appointments of non-executive 
Directors are set out in a letter of appointment, which includes the 
expectations of them and the estimated time required to perform 
their role. Letters of appointment of each non-executive Director 
are available for inspection at the registered office of HSBC 
Holdings. The current anticipated time commitment, which is 
subject to periodic review, is 75 days per year. Non-executive 
Directors who chair a Board committee are expected to devote up 
to 100 days per year to the Group. The Chair of the Group Risk 
Committee is expected to commit up to 150 days per year, 
reflecting the complexity of the role and responsibilities of this 
committee. All non-executive Directors confirm that they can meet 
this requirement, taking into account any other commitments they 
have.

Board approval is required for any non-executive Directors’ 
external commitments, with consideration given to time 
commitments and conflicts of interest.

Conflicts of interest

The Board has an established policy and set of procedures to 
ensure that the Board’s management of the Directors’ conflicts of 
interest policy operates effectively. The Board has the power to 
authorise conflicts where they arise, in accordance with the 
Companies Act 2006 and HSBC Holdings' Articles of Association. 
Details of all Directors’ conflicts of interest are recorded in the 
register of conflicts, which is maintained by the Group Company 
Secretary and Chief Governance Officer's office. Upon 
appointment, new Directors are advised of the policy and 
procedures for managing conflicts. Directors are required to notify 
the Board of any actual or potential conflicts of interest and to 
update the Board with any changes to the facts and circumstances 
surrounding such conflicts. The Board has considered, and 
authorised (with or without conditions) where appropriate, 
potential conflicts as they have arisen during the year in 
accordance with the said policy and procedures.

Directors' indemnity

The Articles of Association of HSBC Holdings contain a qualifying 
third-party indemnity provision, which entitles Directors and other 
officers to be indemnified out of the assets of HSBC Holdings 
against claims from third parties in respect of certain liabilities.

HSBC Holdings has granted, by way of deed poll, indemnities to 
the Directors, including former Directors who retired during the 
year, against certain liabilities arising in connection with their 
position as a Director of HSBC Holdings or of any Group company. 
Directors are indemnified to the maximum extent permitted by 
law.

The indemnities that constitute a 'qualifying third-party indemnity 
provision', as defined by section 234 of the Companies Act 2006, 
remained in force for the whole of the financial year (or, in the 
case of Directors appointed during 2020, from the date of their 
appointment). The deed poll is available for inspection at the 
registered office of HSBC Holdings.

Additionally, Directors have the benefit of Directors’ and officers’ 
liability insurance. 

Qualifying pension scheme indemnities have also been granted to 
the Trustees of the Group's pension schemes, which were in force 
for the whole of the financial year and remain in force as at the 
date of this report.

Contracts of significance

During 2020, none of the Directors had a material interest, directly 
or indirectly, in any contract of significance with any HSBC 
company. During the year, all Directors were reminded of their 
obligations in respect of transacting in HSBC securities and 
following specific enquiry all Directors have confirmed that they 
have complied with their obligations.

Additional non-financial disclosures

Additional non-financial disclosures detailing HSBC’s policies and 
practices in relation to the workforce, environment, social matters, 

human rights, and anti-corruption and anti-bribery matters are 
included in other sections of this Annual Report and Accounts 
2020.

Shareholder engagement

The Board is directly accountable to, and gives high priority to 
communicating with, HSBC’s shareholders. Information about 
HSBC and its activities is provided to shareholders in its Interim 
Reports and the Annual Report and Accounts as well as on 
www.hsbc.com.

To complement regular publications, there is continual dialogue 
between members of the Board and institutional investors 
throughout the year. For examples of such engagement see the 
Group Chairman's letter on page 196 and the Remuneration 
Committee Chair's letter on page 229.

Directors are encouraged to develop an understanding of the 
views of shareholders. Enquiries from individuals on matters 
relating to their shareholdings and HSBC’s business are 
welcomed. 

Any individual or institutional investor can make an enquiry by 
contacting the investor relations team, Group Chairman, Group 
Chief Executive, Group Chief Financial Officer and Group Company 
Secretary and Chief Governance Officer. Our Senior Independent 
Director is also available to shareholders if they have concerns that 
cannot be resolved or for which the normal channels would not be 
appropriate. He can be contacted via the Group Company 
Secretary and Chief Governance Officer at 8 Canada Square, 
London E14 5HQ. 

Annual General Meeting

The AGM in 2021 is planned to be held in London at 11:00am on 
Friday, 28 May 2021. Information on how to participate, both in 
advance and on the day, can be found in the Notice of the 2021 
AGM, which will be sent to shareholders on 24 March 2021 and 
be available on www.hsbc.com/agm. A live webcast will be 
available on www.hsbc.com. A recording of the proceedings will 
be available on www.hsbc.com shortly after the conclusion of the 
AGM. Due to the current environment these arrangements may 
change. Shareholders should monitor our website and 
announcements for any updates. Shareholders may send enquiries 
to the Board in writing via the Group Company Secretary and Chief 
Governance Officer, HSBC Holdings plc, 8 Canada Square, London 
E14 5HQ or by sending an email to 
shareholderquestions@hsbc.com.

General meetings and resolutions

Shareholders may require the Directors to call a general meeting 
other than an AGM, as provided by the UK Companies Act 2006. A 
valid request to call a general meeting may be made by members 
representing at least 5% of the paid-up capital of HSBC Holdings 
as carries the right of voting at its general meetings (excluding any 
paid-up capital held as treasury shares). A request must state the 
general nature of the business to be dealt with at the meeting and 
may include the text of a resolution that may properly be moved 
and is intended to be moved at the meeting. At any general 
meeting convened on such request, no business may be 
transacted except that stated by the requisition or proposed by the 
Board. 

Shareholders may request the Directors to send a resolution to 
shareholders for consideration at an AGM, as provided by the UK 
Companies Act 2006. A valid request must be made by (i) 
members representing at least 5% of the paid-up capital of HSBC 
Holdings as carries the right of voting at its general meetings 
(excluding any paid-up capital held as treasury shares), or (ii) at 
least 100 members who have a right to vote on the resolution at 
the AGM in question and hold shares in HSBC Holdings on which 
there has been paid up an average sum, per member, of at least 
£100. The request must be received by the company not later than 
(i) six weeks before the AGM in question; or (ii) if later, the time at 
which the notice of AGM is published.

A request may be in hard copy form or in electronic form, and 
must be authenticated by the person or persons making it. A 
request may be made in writing to HSBC Holdings at its UK 

HSBC Holdings plc Annual Report and Accounts 2020 259

Corporate governance 
Report of the Directors | Corporate governance report

address, referred to in the paragraph above or by sending an email 
to shareholderquestions@hsbc.com.

Events after the balance sheet date

For details of events after the balance sheet date, see Note 36 on 
the financial statements.

Change of control

The Group is not party to any significant agreements that take 
effect, alter or terminate following a change of control of the 
Group. The Group does not have agreements with any Director or 
employee that would provide compensation for loss of office or 
employment resulting from a takeover bid. 

Branches

The Group provides a wide range of banking and financial services 
through branches and offices in the UK and overseas.

Research and development activities

During the ordinary course of business the Group develops new 
products and services within the global businesses.

Political donations

HSBC does not make any political donations or incur political 
expenditure within the ordinary meaning of those words. We have 
no intention of altering this policy. However, the definitions of 
political donations, political parties, political organisations and 
political expenditure used in the UK Companies Act 2006 are very 
wide. As a result, they may cover routine activities that form part 
of the normal business activities of the Group and are an accepted 
part of engaging with stakeholders. To ensure that neither the 
Group nor any of its subsidiaries inadvertently breaches the UK 
Companies Act 2006, authority is sought from shareholders at the 
AGM to make political donations. 

HSBC provides administrative support to two political action 
committees ('PACs') in the US funded by voluntary political 
contributions by eligible employees. We do not control the PACs, 
and all decisions regarding the amounts and recipients of 
contributions are directed by the respective steering committee of 
each PAC, which are comprised of eligible employees. The PACs 
recorded combined political donations of $100,750 during 2020 
(2019: $119,600).

Charitable contributions

For details of charitable contributions, see page 50.

Internal control

The Board is responsible for maintaining and reviewing the 
effectiveness of risk management and internal control systems, 
and for determining the aggregate level and types of risks the 
Group is willing to take in achieving its strategic objectives. 

To meet this requirement and to discharge its obligations under 
the FCA Handbook and the PRA Handbook, procedures have been 
designed: for safeguarding assets against unauthorised use or 
disposal; for maintaining proper accounting records; and for 
ensuring the reliability and usefulness of financial information used 
within the business or for publication.

These procedures provide reasonable assurance against material 
misstatement, errors, losses or fraud. They are designed to provide 
effective internal control within the Group and accord with the 
Financial Reporting Council‘s guidance for Directors issued in 
2014, on risk management, internal control and related financial 
and business reporting. The procedures have been in place 
throughout the year and up to 23 February 2021, the date 
of approval of this Annual Report and Accounts 2020.

The key risk management and internal control procedures include 
the following:

Global principles

The Group's Global Principles set an overarching standard for all 
other policies and procedures and are fundamental to the Group’s 
risk management structure. They inform and connect our purpose, 

260 HSBC Holdings plc Annual Report and Accounts 2020

values, strategy and risk management principles, guiding us to do 
the right thing and treat our customers and our colleagues fairly at 
all times.

Risk management framework 

The risk management framework provides an effective and 
efficient approach to how we govern and oversee the organisation 
as well as how we monitor and mitigate risks to the delivery of our 
strategy. It applies to all categories of risk, covering core 
governance, standards and principles that bring together all of the 
Group’s risk management practices into an integrated structure.

Delegation of authority within limits set by the Board

Subject to certain matters reserved for the Board, the Group Chief 
Executive has been delegated authority limits and powers within 
which to manage the day-to-day affairs of the Group, including the 
right to sub-delegate those limits and powers. Each relevant Group 
Executive Committee member or executive Director has delegated 
authority within which to manage the day-to-day affairs of the 
business or function for which he or she is accountable. 

Delegation of authority from the Board requires those individuals 
to maintain a clear and appropriate apportionment of significant 
responsibilities and to oversee the establishment and maintenance 
of systems of control that are appropriate to their business or 
function. Authorities to enter into credit and market risk exposures 
are delegated with limits to line management of Group companies. 
However, credit proposals with specified higher-risk 
characteristics require the concurrence of the appropriate global 
function. Credit and market risks are measured and reported at 
subsidiary company level and aggregated for risk concentration 
analysis on a Group-wide basis.

Risk identification and monitoring

Systems and procedures are in place to identify, assess, control 
and monitor the material risk types facing HSBC as set out in the 
risk management framework. The Group‘s risk measurement and 
reporting systems are designed to help ensure that material risks 
are captured with all the attributes necessary to support well-
founded decisions, that those attributes are accurately assessed 
and that information is delivered in a timely manner for those risks 
to be successfully managed and mitigated.

Changes in market conditions/practices

Processes are in place to identify new risks arising from changes 
in market conditions/practices or customer behaviours, which 
could expose the Group to heightened risk of loss or reputational 
damage. The Group employs a top and emerging risks framework, 
which contains an aggregate of all current and forward-looking 
risks and enables it to take action that either prevents them 
materialising or limits their impact.

During 2020 unprecedented global economic events led to banks 
playing an expanded role to support society and customers. The 
Covid-19 outbreak and its impact on the global economy have 
impacted many of our customers’ business models and income, 
requiring significant levels of support from both governments and 
banks.

To meet the additional challenges, we supplemented our existing 
approach to risk management with additional tools and practices. 
We increased our focus on the quality and timeliness of the data 
used to inform management decisions, through measures such as 
early warning indicators, prudent active risk management of our 
risk appetite, and ensuring regular communication with our Board 
and other key stakeholders.

Responsibility for risk management

All employees are responsible for identifying and managing risk 
within the scope of their role as part of the three lines of defence 
model. This is an activity-based model to delineate management 
accountabilities and responsibilities for risk management and the 
control environment. The second line of defence sets the policy 
and guidelines for managing specific risk areas, provides advice 
and guidance in relation to the risk, and challenges the first line of 
defence (the risk owners) on effective risk management.

 
The Board delegated authority to the Group Audit Committee 
('GAC') and it reviewed the independence, autonomy and 
effectiveness of the Group's policies and procedures on 
whistleblowing, including the procedures for the protection of staff 
who raise concerns of detrimental treatment. 

Strategic plans

Strategic plans are prepared for global businesses, global 
functions and geographical regions within the framework of the 
Group’s overall strategy. Annual operating plans, informed by 
detailed analysis of risk appetite describing the types and quantum 
of risk that the Group is prepared to take in executing its strategy, 
are prepared and adopted by all major Group operating companies 
and set out the key business initiatives and the likely financial 
effects of those initiatives.

The effectiveness of the Group’s system of risk management and 
internal control is reviewed regularly by the Board, the Group Risk 
Committee ('GRC') and the GAC. 

During 2020, the Group continued to focus on operational 
resilience and invest in the non-financial risk infrastructure. There 
was a particular focus on material and emerging risks and areas 
undergoing strategic growth.

The GRC and the GAC received confirmation that executive 
management has taken or is taking the necessary actions to 
remedy any failings or weaknesses identified through the 
operation of the Group's framework of controls. In response to the 
Covid-19 outbreak, our business continuity responses have been 
successfully implemented and the majority of service level 
agreements continue to be maintained. 

Internal control over financial reporting

HSBC is required to comply with section 404 of the US Sarbanes-
Oxley Act of 2002 and assess its effectiveness of internal control 
over financial reporting at 31 December 2020. In 2014, the GAC 
endorsed the adoption of the COSO 2013 framework for the 
monitoring of risk management and internal control systems to 
satisfy the requirements of section 404 of the Sarbanes-Oxley Act.

The key risk management and internal control procedures over 
financial reporting include the following:

Entity level controls

The primary mechanism through which comfort over risk 
management and internal control systems is achieved is through 
assessments of the effectiveness of controls to manage risk, and 
the reporting of issues on a regular basis through the various risk 
management and risk governance forums. Entity level controls are 
a defined suite of internal controls that have a pervasive influence 
over the entity as a whole and meet the principles of the 
Committee of Sponsoring Organizations of the Treadway 
Commission ('COSO') framework. They include controls related to 
the control environment, such as the Group's values and ethics, 
the promotion of effective risk management and the overarching 
governance exercised by the Board and its non-executive 
committees. The design and operational effectiveness of entity 
level controls are assessed annually as part of the assessment of 
the effectiveness of internal controls over financial reporting. If 
issues are significant to the Group, they are escalated to the GRC 
and also to the GAC, if concerning financial reporting matters. The 
suite of entity level controls was updated in 2020 to simplify and 
align with the Group’s refreshed risk management framework.

Process level transactional controls

Key process level controls that mitigate the risk of financial 
misstatement are identified, recorded and monitored in 
accordance with the risk framework. This includes the 
identification and assessment of relevant control issues against 
which action plans are tracked through to remediation. Further 
details on HSBC’s approach to risk management can be found on 
page 107. The GAC has continued to receive regular updates on 
HSBC’s ongoing activities for improving the effective oversight of 
end-to-end business processes and management continued to 
identify opportunities for enhancing key controls, such as through 
the use of automation technologies.

Financial reporting

The Group’s financial reporting process is controlled using 
documented accounting policies and reporting formats, supported 
by detailed instructions and guidance on reporting requirements, 
issued to all reporting entities within the Group in advance of each 
reporting period end. The submission of financial information from 
each reporting entity is supported by a certification by the 
responsible financial officer and analytical review procedures at 
reporting entity and Group levels.

Disclosure Committee

Chaired by the Group Chief Financial Officer, the Disclosure 
Committee supports the discharge of the Group’s obligations 
under relevant legislation and regulation including the UK and 
Hong Kong listing rules, the UK Market Abuse Regulation and US 
Securities and Exchange Commission rules. In so doing, the 
Disclosure Committee is empowered to determine whether a 
new event or circumstance should be disclosed, including the 
form and timing of such disclosure, and review certain material 
disclosures made or to be made by the Group. The membership 
of the Disclosure Committee consists of senior management, 
including the Group Chief Financial Officer, Group Chief Legal 
Officer and Group Company Secretary and Chief Governance 
Officer. The Group's brokers, external auditors and its external 
legal counsel also attend as required. The integrity of disclosures 
is underpinned by structures and processes within the Global 
Finance and Global Risk functions that support rigorous analytical 
review of financial reporting and the maintenance of proper 
accounting records. As required by the Sarbanes-Oxley Act, the 
Group Chief Executive and the Group Chief Financial Officer have 
certified that the Group's disclosure controls and procedures 
were effective as at the end of the period covered by this Annual 
Report and Accounts 2020.

The annual review of the effectiveness of the Group's system of 
risk management and internal control over financial reporting was 
conducted with reference to the COSO 2013 framework. Based on 
the assessment performed, the Directors concluded that for the 
year ended 31 December 2020, the Group's internal control over 
financial reporting was effective.

PwC has audited the effectiveness of HSBC's internal control over 
financial reporting and has given an unqualified opinion.

Going concern

The Board, having made appropriate enquiries, is satisfied that the 
Group as a whole has adequate resources to continue operations 
for a period of at least 12 months from the date of this report, and 
it therefore continues to adopt the going concern basis in 
preparing the financial statements. For further details, see page 
41.

Employees

At 31 December 2020, HSBC had a total workforce equivalent to 
226,000 full-time employees compared with 235,000 at the end of 
2019 and 229,000 at the end of 2018. Our main centres of 
employment were the UK with approximately 40,000 employees, 
India with 39,000, Hong Kong with 29,000, mainland China with 
27,000, Mexico with 15,000, the US with 8,000 and France with 
7,000.

Our people span many cultures, communities and continents. By 
focusing on employee well-being, diversity, inclusion and 
engagement, as well as building our peoples’ skills and 
capabilities for now and for the future, we aim to create an 
environment where our people can fulfil their potential. We use 
confidential surveys to assess progress and make changes. We 
want to have an open culture where our people feel connected, 
supported to speak up and where our leaders encourage 
feedback. Where we make organisational changes, we support 
our people throughout the change and in particular where there 
are job losses. 

HSBC Holdings plc Annual Report and Accounts 2020 261

Corporate governance 
Report of the Directors | Corporate governance report

Employee relations

We consult with and, where appropriate, negotiate with employee 
representative bodies where we have them. It is our policy to 
maintain well-developed communications and consultation 
programmes with all employee representative bodies. There have 
been no material disruptions to our operations from labour 
disputes during the past five years.

We are committed to complying with the applicable employment 
laws and regulations in the jurisdictions in which we operate. 
HSBC’s global employment practices and relations policy provides 
the framework and controls through which we seek to uphold that 
commitment.

Diversity and inclusion

Our customers, suppliers and communities span many cultures 
and continents. We believe this diversity makes us stronger, and 
we are dedicated to building a diverse and connected workforce 
where everyone feels a sense of belonging.

Our Group People Committee, which is made up of Group 
Executive Committee members, governs our diversity and 
inclusion agenda. It meets regularly to agree actions to improve 
diverse representation and build a more inclusive culture where 
our colleagues can bring the best of themselves to work and 
deliver more equal outcomes for our stakeholders. Members of 
our Group Executive Committee are held to account for the actions 
they take on diversity via aspirational targets contained within 
their performance scorecards. Our people managers also have a 
component of their performance assessed on the degree to which 
they create team environments that are inclusive, motivating and 
nurturing. Every colleague at HSBC must treat each other with 
dignity and respect, creating an inclusive environment. Our 
policies make clear we do not tolerate unlawful discrimination, 
bullying or harassment on any grounds.

To align our approach to inclusion best practice, we participate in 
global diversity benchmarks, which help us to identify 
improvement opportunities. We also track a large number of 
diversity and inclusion metrics, which enable us to pinpoint 
inclusion barriers and take action where required.
Our gender diversity statistics are set out on page 64.

Further details of our diversity and inclusion activity, together with our Gender 
and Ethnicity UK Pay Gap Report 2020, can be found at www.hsbc.com/
diversitycommitments.

Employment of people with a disability

We believe in providing equal opportunities for all employees. The 
employment of people with a disability is included in this 
commitment. The recruitment, training, career development and 
promotion of people with a disability are based on the aptitudes 
and abilities of the individual. Should employees become disabled 
during their employment with us, efforts are made to continue 
their employment and, if necessary, appropriate training and 
reasonable equipment and facilities are provided. 

Employee development

A workforce capable of meeting the challenges of today and 
tomorrow requires significant support to develop the right skills. 
Whatever our colleagues’ career paths, we have a range of tools 
and resources to help them. 

A rapid shift to virtual learning 

The Covid-19 outbreak resulted in a halt to classroom training and 
rapid expansion in virtual learning. We prioritised the transition to 
remote working and helping people manage their well-being. The 
shift from physical classroom training to shorter virtual equivalents 
and online resources resulted in a total of 5.2 million hours and 2.9 
days per FTE in training in 2020. For further details on training 
hours and days by gender, region and seniority, see the ESG Data 
Pack at www.hsbc.com/esg. 

We converted or rebuilt technical, professional and personal 
classroom programmes to deliver online. New joiners to HSBC 
experienced an immersive virtual induction programme and virtual 
internships. Our global graduate induction programme moved 

262 HSBC Holdings plc Annual Report and Accounts 2020

entirely online with more than 100 leaders and graduate alumni 
welcoming approximately 650 graduates. 

Supporting self-development

We have a range of tools and resources to help colleagues take 
ownership of their development and career. 

• HSBC University is our one-stop shop for learning delivered via 
an online portal, network of global training centres and third-
party providers.

• Our My HSBC Career portal offers career development 

resources and information on managing change and on giving 
back to the organisation and the communities in which we 
operate. Over 100,000 of our colleagues made use of it in 2020. 

• We launched a global mentoring system in 2020 to enable 

colleagues to match with a mentor or mentee. At 31 December 
2020, we had in excess of 6,800 mentors and mentees in 58 
countries and territories.

Developing core skills 

Our managers are the critical link in supporting our colleagues. In 
2020, we redesigned our suite of training and resources for 
managers so they can focus on the most important skills including 
leading and supporting teams through change. 

Risk management remains central to development and is part of 
our mandatory training. Those at higher risk of exposure to 
financial wrongdoing experience more in-depth training on 
financial risks, such as money laundering, sanctions, bribery and 
corruption. Other programmes and resources address specific 
areas of risk, like management of third-party suppliers. 

Our Cyber Hub brings together training, insights, events and 
campaigns on how to combat cyber-crime. We are also supporting 
those who develop models and senior leaders with training to help 
them understand and apply our Principles on the Ethical Use of 
Big Data and Artificial Intelligence.

A learning and feedback culture 

We want our colleagues to be well prepared for changing 
workplace requirements and so have developed a flagship Future 
Skills programme to support them. We identified nine key 
behaviours we believe are necessary future skills for colleagues 
and built a curriculum of resources to support learners to develop 
these.

More than 1,000 colleagues now act as Future Skills Influencers, 
supporting their businesses and teams to invest in learning. In 
November 2020, we ran a week-long MySkills festival, which 
helped colleagues explore future skills through virtual events, 
interactive workshops and online resources. Demand to join 
sessions surpassed our expectations with more than 45,000 
registrations for events. 

Senior succession planning 

Developing future leaders is critical to our long-term success. The 
Group Executive Committee dedicates time to articulate the 
current and future capabilities required to deliver the business 
strategy, and identify successors for our most critical roles. 

Successors undergo robust assessment and participate in 
executive development. Potential successors for senior roles also 
benefit from coaching and mentoring and are moved into roles 
that build their skills and capabilities.

Health and safety

We are committed to providing a safe and healthy working 
environment for everyone. We strive to ensure we adopt best 
health and safety management practices across the organisation 
and aim for standards that reflect our core values.

Chief operating officers have overall responsibility for ensuring 
that global policies, procedures and safeguards are put into 
practice locally, and that all legal requirements are met. 

To put our commitment into practice, we delivered a range of 
programmes in 2020 to help us understand and manage 

 
 
effectively the risks we face and improve the buildings in which 
we operate:

unrelated to performance or experience with the Group, while 
performing their role in the long-term interests of our stakeholders.

• Based on expert medical advice, we created safe workplaces 
globally, designed to protect our employees, contractors and 
customers from the risks of Covid-19. We carried out 
approximately 1,700 Covid-19-related workplace enhancements 
globally, with measures involving: enhanced cleaning; training 
and awareness; public hygiene; and track and trace.

• We updated our advice on working from home, providing more 
awareness and best practices on good ergonomics and well-
being to be adopted during these unprecedented times.

• We delivered an improved health and safety training and 
awareness programme to 245,000 of our employees and 
contractors globally, ensuring roles and responsibilities were 
clear and understood.

• We completed the annual safety inspection on all of our 

buildings globally, subject to local Covid-19 restrictions, to 
ensure we were meeting our standards and continuously 
improving our safety performance.

• We continued to focus on enhancing the safety culture in our 

supply chain through our SAFER Together programme, 
covering the five key elements of best practice safety culture, 
including speaking up about safety, and recognising 
excellence. Our 2020 safety climate survey results showed a 
continued year-on-year increase in safety culture, and 
significantly above the industry average.

• Our Eat Well Live Well programme continued through 

educating and informing our colleagues on how to make 
healthy food and drink choices. We enhanced the programme 
to provide digital educational and information resources, 
including a suite of videos and recipe ideas. The programme 
was runner up in the 2020 Global Healthy Workplace Awards.

• We put in place effective storm preparation controls and 
processes to ensure the protection of our people and 
operations. In 2020, there were 41 named storms, which 
passed over 2,316 of our buildings and resulted in no injuries or 
business impact.

Employee health and safety

Number of workplace fatalities

Number of major injuries to employees

1

All injury rate per 100,000 employees

—   

15   

88   

1 

29 

189 

1

27

189

Footnotes

2020

2019

2018

1  Fractures, dislocation, concussion, loss of consciousness, overnight 

admission to hospital.

Remuneration 

HSBC’s pay and performance strategy is designed to reward 
competitively the achievement of long-term sustainable 
performance and attract and motivate the very best people, 
regardless of gender, ethnicity, age, disability or any other factor 

 HSBC Holdings Savings-Related Share Option Plan (UK)

For further details of the Group’s approach to remuneration, see page 233.

Employee share plans

Share options and discretionary awards of shares granted under 
HSBC share plans align the interests of employees with the 
creation of shareholder value. The following table sets out the 
particulars of outstanding options, including those held by 
employees working under employment contracts that are regarded 
as ‘continuous contracts’ for the purposes of the Hong Kong 
Employment Ordinance. The options were granted at nil 
consideration. No options have been granted to substantial 
shareholders and suppliers of goods or services, nor in excess of 
the individual limit for each share plan. No options were cancelled 
by HSBC during the year.

A summary for each plan of the total number of the options that 
were granted, exercised or lapsed during 2020 is shown in the 
following table. Further details required to be disclosed pursuant 
to Chapter 17 of the Rules Governing the Listing of Securities on 
The Stock Exchange of Hong Kong Limited are available on our 
website at www.hsbc.com/who-we-are/leadership-and-
governance/remuneration and on the website of The Stock 
Exchange of Hong Kong Limited at www.hkex.com.hk, or can be 
obtained upon request from the Group Company Secretary and 
Chief Governance Officer, 8 Canada Square, London E14 5HQ.

Particulars of options held by Directors of HSBC Holdings are set out on 
page 245.

Note 5 on the financial statements gives details of share-based payments, 
including discretionary awards of shares granted under HSBC share plans.

All-employee share plans

HSBC operates all-employee share option plans under which 
options are granted over HSBC ordinary shares. Subject to leaver 
provisions, options are normally exercisable after three or five 
years. During 2020, options were granted by reference to the 
average market value of HSBC Holdings ordinary shares on the 
five business days immediately preceding the invitation date, then 
applying a discount of 20%. The closing price for HSBC Holdings 
ordinary shares quoted on the London Stock Exchange on 
23 September 2020, the day before the options were granted and 
as derived from the Daily Official List, was £2.9025.

The HSBC Holdings Savings-Related Share Option Plan (UK) will 
expire on 24 April 2030, by which time the plan may be extended 
with approval from shareholders, unless the Directors resolve to 
terminate the plan at an earlier date. 

The HSBC International Employee Share Purchase Plan was 
introduced in 2013 and now includes employees based in 
27 jurisdictions, although no options are granted under this plan.

During 2020, approximately 171,000 employees were offered 
participation in these plans.

Dates of awards

Exercise price 

Usually exercisable

At

Granted

Exercised

Lapsed

At

from

to

from
(£)

to
(£)

from

to Footnotes

1 Jan 2020

during year

during year

during year

31 Dec 2020

20 Sep 2013 24 Sep 2020   2.6270    5.9640  1 Nov 2018 30 Apr 2026

1

  65,060,681    111,469,393   

1,387,599    44,189,936    130,952,539 

1  The weighted average closing price of the shares immediately before the dates on which options were exercised was £5.2014.

HSBC Holdings ordinary shares

HSBC Holdings plc Annual Report and Accounts 2020 263

Corporate governance 
 
 
 
 
 
  
oversight of internal control, other than internal control over 
financial reporting, and risk management systems. This is 
permitted under the UK Corporate Governance Code.

Notwithstanding that Laura Cha has served on the Board for more 
than nine years, the Board has determined that she continues to 
be independent when taking into consideration all other relevant 
circumstances that are likely to impair, or could appear to impair, 
independence. Laura will not be standing for re-election at the 
2021 AGM.

HSBC Holdings has codified obligations for transactions in Group 
securities in accordance with the requirements of the UK Market 
Abuse Regulation and the rules governing the listing of securities 
on HKEx, save that the HKEx has granted waivers from strict 
compliance with the rules that take into account accepted 
practices in the UK, particularly in respect of employee share 
plans. During the year, all Directors were reminded of their 
obligations in respect of transacting in HSBC Group securities and, 
except as disclosed on page 258, following specific enquiry all 
Directors have confirmed that they have complied with their 
obligations. 

On behalf of the Board

Mark E Tucker

Group Chairman

HSBC Holdings plc

Registered number 617987

23 February 2021

Report of the Directors | Corporate governance report

Statement of compliance 

The statement of corporate governance practices set out on pages 
195 to 265 and the information referred to therein constitutes the 
'Corporate governance report' and 'Report of the Directors' of 
HSBC Holdings. The websites referred to do not form part of this 
report. 

Relevant corporate governance codes, role profiles and policies

www.frc.org.uk

www.hkex.com.hk

www.hsbc.com/who-we-are/
leadership-and-governance/
board-responsibilities

UK Corporate Governance 
Code

Hong Kong Corporate 
Governance Code (set out in 
Appendix 14 to the Rules 
Governing the Listing of 
Securities on the Stock 
Exchange of Hong Kong 
Limited)

Descriptions of the roles and 
responsibilities of the:

– Group Chairman

– Group Chief Executive

– Senior Independent Director

– Board

Board and senior management www.hsbc.com/who-we-are/

Roles and responsibilities of the 
Board's committees

Board’s policies on:

– diversity and inclusion

– shareholder communication

– human rights

– remuneration practices and

governance

Global Internal Audit Charter

leadership-and-governance

www.hsbc.com/who-we-are/
leadership-and-governance/
board-committees

www.hsbc.com/who-we-are/
leadership-and-governance/
board-responsibilities

www.hsbc.com/who-we-are/
leadership-and-governance/
corporate-governance-codes/
internal-control

HSBC is subject to corporate governance requirements in both the 
UK and Hong Kong. During 2020, save to the extent referred to 
below, HSBC complied with the provisions and requirements of 
both the UK and Hong Kong Corporate Governance Codes. 

Following the UK Government’s introduction of social distancing 
measures and prohibition on non-essential travel and public 
gatherings, it was not possible for shareholders to attend the 2020 
Annual General Meeting (‘AGM’) in person. The Board was fully 
informed of all relevant AGM and shareholder matters but only a 
limited number of Directors and essential personnel attended the 
AGM to ensure the meeting was quorate and to enable the 
business of the meeting to be conducted. Shareholders were 
advised to vote by submitting a proxy in advance of the AGM and 
that they should only appoint the Chairman of the AGM to act as 
their proxy. To ensure that shareholders did not lose the 
opportunity to raise questions, shareholders were encouraged to 
submit questions for the Board via email in advance of the AGM. 
Responses to the most frequent questions across key themes 
were published on the HSBC website after due consideration by 
the Board. None of the questions submitted covered a topic that 
required consideration by the auditor. Given these measures, not 
all of the persons set out in paragraphs A.6.7 and E.1.2 of the 
Hong Kong Corporate Governance Code were able to attend the 
AGM.

Under the Hong Kong Code, the audit committee should be 
responsible for the oversight of all risk management and internal 
control systems. HSBC’s Group Risk Committee is responsible for 

264 HSBC Holdings plc Annual Report and Accounts 2020

Directors’ responsibility statement

The Directors are responsible for preparing the Annual Report and 
Accounts 2020, the Directors’ remuneration report and the 
financial statements in accordance with applicable law and 
regulations.

Company law requires the Directors to prepare financial 
statements for each financial year. Under that law, the Directors 
have prepared the parent company (‘Company’) and Group 
financial statements in accordance with International Financial 
Reporting Standards (‘IFRSs’) as adopted by the European Union. 
In preparing these financial statements, the Directors have also 
elected to comply with IFRSs, issued by the International 
Accounting Standards Board (‘IASB’). Under company law, the 
Directors must not approve the financial statements unless they 
are satisfied that they give a true and fair view of the state of 
affairs of the Company and Group, and of the profit or loss of the 
Company and Group for that period. In preparing these financial 
statements, the Directors are required to:

• select suitable accounting policies and then apply them

consistently;

• make judgements and estimates that are reasonable and

prudent;

Disclosure of information to auditors

In accordance with section 418 of the Companies Act 2006, the 
Directors’ report includes a statement, in the case of each Director 
in office as at the date the Report of the Directors is approved, 
that:

• so far as the Director is aware, there is no relevant audit

information of which the Company’s auditors are unaware; and

• they have taken all the steps they ought to have taken as a
Director in order to make themselves aware of any relevant
audit information and to establish that the Company’s auditors
are aware of that information.

On behalf of the Board

Mark E Tucker

Group Chairman

• state whether applicable IFRSs as adopted by the European

HSBC Holdings plc

Union and IFRSs issued by IASB have been followed, subject to
any material departures disclosed and explained in the financial
statements; and

Registered number 617987

23 February 2021

• prepare the financial statements on a going concern basis

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

The Directors are also responsible for safeguarding the assets of 
the Company and the Group and hence for taking reasonable 
steps for the prevention and detection of fraud and other 
irregularities. 

The Directors are responsible for keeping adequate accounting 
records that are sufficient to show and explain the Company’s 
transactions, and disclose with reasonable accuracy at any time 
the financial position of the Company and the Group enabling 
them to ensure that the financial statements and the Directors’ 
remuneration report comply with the Companies Act 2006 and, as 
regards the Group financial statements, Article 4 of the IAS 
Regulation. 

The Directors are responsible for the maintenance and integrity of 
the Annual Report and Accounts 2020 as they appear on the 
Company’s website. Legislation in the UK governing the 
preparation and dissemination of financial statements may differ 
from legislation in other jurisdictions.

The Directors consider that the Annual Report and Accounts 2020, 
taken as a whole, is fair, balanced and understandable, and 
provides the information necessary for shareholders to assess the 
Company’s position, performance, business model and strategy.

Each of the Directors, whose names and functions are listed in the 
‘Report of the Directors: Corporate governance report’ on pages 
198 to 201 of the Annual Report and Accounts 2020, confirms that, 
to the best of their knowledge:

• the Group financial statements, which have been prepared in
accordance with IFRSs as adopted by the EU, give a true and
fair view of the assets, liabilities, financial position, and profit or
loss of the Group; and

• the management report represented by the Report of the
Directors includes a fair review of the development and
performance of the business and the position of the Group,
together with a description of the principal risks and
uncertainties that it faces.

The Group Audit Committee has responsibility, delegated to it 
from the Board, for overseeing all matters relating to external 
financial reporting. The Group Audit Committee report on page 
216 sets out how the Group Audit Committee discharges its 
responsibilities. 

HSBC Holdings plc Annual Report and Accounts 2020 265

Corporate governanceFinancial 
statements

267  

 Independent auditors’ report to the members 
of HSBC Holdings plc

278 

Financial statements

288  Notes on the financial statements

Supporting our customers 
through transition finance 

We are supporting our customers to make progress 
towards their commitments to cut greenhouse gas 
emissions, in line with the goals of the Paris 
Agreement on climate change. We played a key role 
in the world’s first ‘transition’ Islamic bond, known as 
a sukuk, to help reduce carbon emissions in the 
aviation industry. Etihad Airways will use the $600m 
proceeds for energy-efficient aircraft and research 
and development into sustainable aviation fuel.

This sukuk included a commitment from Etihad to 
purchase a set amount of carbon offsets if it fails to 
meet its short-term target to reduce the carbon 
intensity of its passenger fleet.

We acted as joint global coordinator and joint 
sustainability structuring agent on the deal, as well 
as joint bookrunner and dealer manager.

266

HSBC Holdings plc Annual Report and Accounts 2020Independent auditors’ report to the members of HSBC Holdings plc

Report on the audit of the financial statements

Opinion

In our opinion, HSBC Holdings plc’s (‘HSBC’) group financial statements1 and company financial statements (the ‘financial statements’):

• give a true and fair view of the state of the group’s and of the company’s affairs as at 31 December 2020 and of the group’s and 

company’s profit and the group’s and company’s cash flows for the 12 month period (the "year") then ended;

• have been properly prepared in accordance with international accounting standards in conformity with the requirements of the 

Companies Act 2006; and

• have been prepared in accordance with the requirements of the Companies Act 2006.

Our opinion is consistent with our reporting to the Group Audit Committee (‘GAC’).

Separate opinion in relation to international financial reporting standards adopted pursuant to 
Regulation (EC) No 1606/2002 as it applies in the European Union

As explained in note 1.1(a) to the financial statements, the group, in addition to applying international accounting standards in 
conformity with the requirements of the Companies Act 2006, has also applied international financial reporting standards adopted 
pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union.

In our opinion, the group financial statements have been properly prepared in accordance with international financial reporting standards 
adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union.

Separate opinion in relation to IFRSs as issued by the IASB

As explained in note 1.1(a) to the financial statements, the group, in addition to applying international accounting standards in 
conformity with the requirements of Companies Act 2006, has also applied IFRSs as issued by the International Accounting Standards 
Board (IASB).

In our opinion, the group financial statements have been properly prepared in accordance with IFRSs as issued by the IASB.

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 
to the group.

Other than those disclosed in note 6 to the financial statements, we have provided no non-audit services to the group in the period under 
audit.

Our audit approach

Overview

This was the second year that it has been my responsibility to form this opinion on behalf of PricewaterhouseCoopers LLP ('PwC'), who 
you first appointed on 31 March 2015 in relation to that year’s audit. In addition to forming this opinion, in this report we have also 
provided information on how we approached the audit, how it changed from the previous year and details of the significant discussions 
that we had with the GAC.

Given the impact of Covid-19, substantially all of our interactions were undertaken virtually, including those between the engagement 
team, with the teams for Significant Subsidiaries and Operations Centres, and with HSBC Board members and management. Similarly, 
substantially all of our audit testing was performed remotely. For further details around the impact of Covid-19 on our audit, please see 
the ‘Impact of Covid-19’ key audit matter below.

Materiality

• Overall group materiality: $900m (2019: $1,000m) based on 5% of an adjusted profit before tax for the last three years.

• Overall company materiality: $855m (2019: $900m) being an amount capped below the overall group materiality. 

1  We have audited the financial statements, included within the Annual Report and Accounts (the ‘Annual Report’), which comprise: the 

consolidated and company balance sheets as at 31 December 2020, the consolidated and company income statements and the consolidated 
and company statements of comprehensive income for the year then ended, the consolidated and company statements of cash flows for the 
year then ended, the consolidated and company statements of changes in equity for the year then ended, and the notes to the financial 
statements, which include a summary of significant accounting policies and other explanatory information. Certain notes to the financial 
statements have been presented elsewhere in the Annual Report and Accounts 2020, rather than in the notes to the financial statements. These 
are cross-referenced from the financial statements and are identified as ‘(Audited)’. The relevant disclosures are included in the Risk review 
section on pages 113 to 194 and the Directors' remuneration report disclosures on pages 239 to 249.

HSBC Holdings plc Annual Report and Accounts 2020 267

Financial statementsIndependent auditors’ report to the members of HSBC Holdings plc

Audit scope

The scope of our audit and the nature, timing and extent of audit procedures performed were determined based on our risk assessment, 
taking into account changes from the prior year, the financial significance of subsidiaries and other qualitative factors. We executed the 
planned approach and concluded based on the results of our testing, ensuring that sufficient audit evidence had been obtained to 
support our opinion. 

Key audit matters

• Impact of Covid-19 (group and company)

• Expected credit losses - Impairment of loans and advances (group)

Investment in associate - Bank of Communications Company, Limited (‘BoCom’) (group)

•
• Impairment of goodwill and intangible assets (group)

• Valuation of financial instruments (group)

• Impairment of investments in subsidiaries (company)

• Valuation of defined benefit pensions obligations (group)

• IT access management (group)

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. In 
particular, we looked at where the directors made subjective judgements, for example in respect of significant accounting estimates that 
involved making assumptions and considering future events that are inherently uncertain.

Capability of the audit in detecting irregularities, including fraud

Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our 
responsibilities, outlined in the Auditors’ responsibilities for the audit of the financial statements section, 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 financial crime laws & regulations and regulatory compliance, including conduct of business, and we considered 
the extent to which non-compliance might have a material effect on the financial statements. We also considered those laws and 
regulations that have a direct impact on the preparation of the financial statements, such as the Companies Act 2006 and the UK and 
Hong Kong listing rules. 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 increase revenue or reduce costs, creating fictitious trades to hide losses or to improve financial performance, and 
management bias in accounting estimates. 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:

• Review of correspondence with and reports to the regulators, including the Prudential Regulation Authority (‘PRA’) and Financial 

Conduct Authority (‘FCA’);

• Reviewed reporting to the GAC and GRC in respect of compliance and legal matters;

• Review a sample of legal correspondence with legal advisors;

• Enquiries of management and review of internal audit reports in so far as they related to the financial statements;

• Obtain legal confirmations from legal advisors relating to material litigation and compliance matters;

• Assessment of matters reported on the group’s whistleblowing and ‘Speak up’ programmes and the results of management’s 

investigation of such matters; in so far as they related to the financial statements;

• Challenging assumptions and judgements made by management in its significant accounting estimates, in particular in relation to the 
determination of expected credit losses, and the impairment assessments of goodwill, intangible assets, the investment in BoCom, 
valuation of financial instruments, valuation of defined benefit pensions obligations and investment in subsidiaries (see related key 
audit matters below); 

• Obtaining confirmations from third parties to confirm the existence of a sample of transactions; and

• Identifying and testing journal entries, including those posted with certain descriptions, posted and approved by the same individual, 

backdated journals or posted by infrequent and unexpected users.

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.

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.

The impact of Covid-19 and valuation of financial instruments are new key audit matters this year. Otherwise, the key audit matters 
below are consistent with last year.

268 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
Impact of Covid-19 (group and company)

Nature of the key audit matter

The impact of the Covid-19 pandemic has resulted in unprecedented economic conditions and resulting government support programmes and regulatory 
interventions to support businesses and people. The Covid-19 pandemic has also changed the way that companies operate their businesses, with one of 
the most substantial impacts being the transition to remote working.
A substantial proportion of HSBC’s employees have been working remotely during 2020, with some consequential changes on their processes and the 
control environment, some of which were relevant for financial reporting purposes. Our audit team has also been working remotely for most of 2020, as 
have most of our teams auditing the Significant Subsidiaries and operational centres.
The impact of the Covid-19 pandemic and resulting uncertainty has impacted a number of the estimates in the group financial statements and company 
financial statements. The impact on the most significant accounting judgements and our audit is set out in the following other key audit matters in this 
opinion: 
• Expected credit losses - Impairment on loans and advances to customers; 
•
•
• Valuation of financial instruments; and
•

Investment in associate - BoCom;
Impairment of goodwill and intangible assets;

Impairment of investment in subsidiaries.

Matters discussed with the Group Audit Committee

We discussed our assessment of the impact of Covid-19 on HSBC’s operations and control environment with the GAC. We also explained how we 
planned to execute our audit with substantially all of our audit team working remotely. 

How our audit addressed the Key Audit Matter

We engaged with the Board and management at HSBC in a manner consistent with our previous audits, albeit remotely using video and telephone calls. 
Substantially all of the information and audit evidence we need for the HSBC audit is provided in electronic format. We shared information, including the 
audit evidence provided to us by HSBC, using share-screen functionality in video calls and our secure encrypted information sharing software. Where we 
would have previously inspected physical evidence, for example our stock counts of precious metals, these audit procedures were performed virtually.

We understood and assessed the transition of HSBC employees to working remotely on the control environment relevant to financial reporting, and 
reflected this in our audit approach for new or changed processes and controls.

Where the group undertook new business activities as a result of Covid-19, for example, the government sponsored lending programmes, we assessed 
the audit risks and designed appropriate audit procedures. 

We were not able to visit any of the audit teams for the Significant Subsidiaries and operational centres during our 2020 audit. However, consistent with 
our experience with HSBC, we engaged with and directed these teams in a manner consistent with our previous audits using video conferencing and 
telephone calls. This included ‘virtual visits’ to certain locations, in which we met with both the audit teams and local management. To ensure we were 
satisfied with the audits performed by the audit teams for the Significant Subsidiaries, we evaluated and reviewed audit evidence by remotely reviewing 
electronic audit files or using share-screen functionality in video conferencing.

Relevant references in the Annual Report and Accounts 2020

GAC Report, page 218.

HSBC Holdings plc Annual Report and Accounts 2020 269

Financial statementsIndependent auditors’ report to the members of HSBC Holdings plc

Expected credit losses - Impairment of loans and advances (group)

Nature of the key audit matter

forward looking economic scenarios and their likelihoods; 
customer risk ratings (‘CRRs’), and probability of defaults; and 
the recoverability of credit impaired wholesale exposures. 

Determining expected credit losses (‘ECL’) involves management judgement and is subject to a high degree of estimation uncertainty, both of which have 
significantly increased as a result of Covid-19.
Management makes various assumptions when estimating ECL. The significant assumptions that we focus on in our audit included those with greater 
levels of management judgement and for which variations had the most significant impact on ECL. Specifically these included,
•
•
•
The modelling methodologies that use these assumptions, as well as other data, to estimate ECL are complex and not standardised. The modelling 
methodologies are developed using historical experience, which can result in limitations in their reliability to appropriately estimate ECL. These limitations 
are often addressed with adjustments, which are inherently judgemental and subject to estimation uncertainty.
The impact of the Covid-19 pandemic has resulted in unprecedented economic conditions that vary across countries and industry sectors. Covid-19 
related government support programmes and regulatory interventions have impacted economic factors such as GDP and unemployment, and 
consequently the extent and timing of customer defaults.
These factors have increased the uncertainty around judgements made in determining the severity and likelihood of macroeconomic variable (‘MEV’) 
forecasts across the different economic scenarios used in ECL models. Furthermore, these conditions are outside the bounds of historical experience used 
to develop the models and where models produce plausible results, resulting in significantly greater limitations in their reliability to estimate ECLs.
Management has made significant adjustments to ECL to address these limitations through management judgemental adjustments to modelled 
outcomes. The nature and extent of these limitations and the resulting changes to ECL varies across retail and wholesale portfolios globally. In addition, 
certain models have been redeveloped during 2020.
The determination of CRRs is based on quantitative scorecards, with qualitative adjustments for relevant factors. The extent of qualitative adjustments has 
increased due to Covid-19. The uncertainty caused by Covid-19 also increases judgement involved in estimating expected cash flows and collateral 
valuations for specific impairments on credit impaired wholesale exposures.

Matters discussed with the Group Audit Committee

We held discussions with the GAC covering governance and controls over ECL, with a significant focus on the impact of Covid-19. We also discussed a 
number of other areas, including:
•

the severity and likelihood of MEV forecasts in economics scenarios, across countries for the impact of Covid-19, and specifically for the UK and Hong 
Kong in relation to the geopolitical risks relating to the UK’s withdrawal from the EU and US-China relations;
the determination and migration of customer risk ratings;
assumptions around the recoverability of significant wholesale exposures; 
the identification and assessment of model limitations and resulting changes and adjustments to ECL, in particular for approaches adopted in response 
to Covid-19;

•
•
•

• models that were redeveloped during the year;
• model validation and monitoring; and
•

the disclosures made to explain ECL, in particular the impact of Covid-19 on determining ECL and the resulting estimation uncertainty.

How our audit addressed the Key Audit Matter

credit reviews that determine CRRs for wholesale customers;
the input of critical data into source systems and the flow and transformation of critical data from source systems to the impairment models; and
the calculation and approval of management judgemental adjustments to modelled outcomes.

We assessed the design of governance and controls over the estimation of ECLs, as well as testing how effectively they operated. We observed 
management’s review and challenge governance forums for (1) the determination of MEV forecasts and their likelihood for different economic scenarios, 
and (2) the assessment of ECL for Retail and Wholesale portfolios, including the assessment of model limitations and approval of any resulting 
adjustments to modelled outcomes. 
We also tested controls over:
• model validation and monitoring;
•
•
•
We involved our economic experts in assessing the reasonableness of the severity and likelihood of MEV forecasts. These assessments considered the 
sensitivity of ECLs to variations in the severity and likelihood of MEVs for different economic scenarios.
We involved our modelling experts in assessing the appropriateness of modelling methodologies that were redeveloped during the year, and for a sample 
of those models, we independently reperformed the modelling for certain aspects of the ECL calculation. We also assessed the appropriateness of 
modelling methodologies that did not change during the year, giving specific consideration to Covid-19 and whether management judgemental 
adjustments were needed. In addition, we performed testing over:
•
•
•
•
We evaluated and tested the Credit Risk disclosures made in the Annual Report and Accounts 2020.

the compliance of ECL methodologies and assumptions with the requirements of IFRS9;
a sample of critical data used in the year end ECL calculation and to estimate management judgemental adjustments;
critical data, assumptions and discounted cash flows for a sample of credit impaired wholesale exposures; and
a sample of CRRs applied to wholesale exposures, including our credit experts assessing a sample by comparing to external sources.

Relevant references in the Annual Report and Accounts 2020

• Credit risk disclosures, page 119.
• GAC Report, page 220.
• Note 1.2(d): Financial instruments measured at amortised cost, page 292.
• Note 1.2(i): Impairment of amortised cost and FVOCI financial assets, page 293.

270 HSBC Holdings plc Annual Report and Accounts 2020

Investment in associate – BoCom (group)

Nature of the key audit matter

At 31 December 2020, the market value of the investment in BoCom, based on the share price, was $13.7bn lower than the carrying value of $21.2bn. 
This is an indicator of potential impairment. An impairment test was performed by management, with supporting sensitivity analysis, using a value in use 
('VIU') model. The VIU was $0.6bn in excess of the carrying value. On this basis, management concluded no impairment was required and the share of 
BoCom’s profits has been recognised in the consolidated income statement.
The methodology in the VIU model is dependent on various assumptions, both short term and long term in nature. These assumptions, which are subject 
to estimation uncertainty, are derived from a combination of management’s judgement, analysts’ forecasts and market data. The significant assumptions 
that we focused our audit on were those with greater levels of management judgement and for which variations had the most significant impact on the 
VIU. Specifically, these included 
• discount rates; 
•
•
•
•
•

forecast operating income; 
long term growth rates; 
future expected credit losses; 
effective tax rates; and 
regulatory capital requirements.

Matters discussed with the Group Audit Committee

We discussed the appropriateness of the VIU methodology and significant assumptions with the GAC, giving consideration to the macroeconomic 
environment, as well as Covid-19 and the outlook for the Chinese banking market. We considered reasonably possible alternatives for the significant 
assumptions. We also discussed the disclosures made in relation to BoCom, including the use of sensitivity analysis to explain estimation uncertainty and 
the conditions that would result in an impairment being recognised.

How our audit addressed the Key Audit Matter

We tested controls in place over significant assumptions and the model used to determine the VIU. We assessed the appropriateness of the methodology 
used, and the mathematical accuracy of the calculations, to estimate the VIU. In respect of the significant assumptions, our testing included the following:
• Challenging the basis for determining significant assumptions and, where relevant, their interrelationships;
• Obtaining and evaluating evidence where available for critical data relating to significant assumptions, from a combination of historic experience, 
external market information, third-party sources including analyst reports, information from BoCom management and historical publicly available 
BoCom financial information;

• Assessing the sensitivity of the VIU to reasonable variations in significant assumptions, both individually and in aggregate; and
• Determining a reasonable range for the discount rate used within the model, with the assistance of our valuation experts, and comparing it to the 

discount rate used by management.

We observed meetings in April, May, September and November 2020 between management and senior BoCom executive management, held specifically 
to identify facts and circumstances impacting assumptions relevant to the determination of the VIU.
We evaluated and tested the disclosures made in the Annual Report and Accounts 2020 in relation to BoCom.

Relevant references in the Annual Report and Accounts 2020

• GAC Report, page 221.
• Note 1.2(a): Critical accounting estimates and judgements, page 291.
• Note 18 Interests in associates and joint ventures, page 331.

HSBC Holdings plc Annual Report and Accounts 2020 271

Financial statements 
Independent auditors’ report to the members of HSBC Holdings plc

Impairment of goodwill and intangible assets (group)

Nature of the key audit matter

The impact of the Covid-19 pandemic has resulted in unprecedented economic conditions, impacting the performance of HSBC in both 2020 and the 
outlook into 2021 and beyond. This is considered by management to be an indicator of impairment.
An impairment test was performed by management, with supporting sensitivity analysis, using the higher of value in use (‘VIU’) and fair value less cost to 
sell. Management predominantly used VIU in its impairment tests, unless it believed that fair value less cost to sell would result in a higher recoverable 
amount for any cash generating unit (‘CGU’). The impairment test resulted in impairment charges of $1.3bn and $41m for software intangibles and 
goodwill being recognised respectively for certain CGUs. For the remaining CGUs, where the recoverable amount was higher than the carrying value, no 
impairment was recorded. The remaining goodwill and software intangibles on the balance sheet at 31 December 2020 are $5.9bn and $4.5bn 
respectively. 
The methodology in the models is dependent on various assumptions, both short term and long term in nature. These assumptions, which are subject to 
estimation uncertainty, are derived from a combination of management’s judgement, experts engaged by management and market data. The significant 
assumptions that we focused our audit on were those with greater levels of management judgement and for which variations had the most significant 
impact on the recoverable amount. Specifically, these included HSBC’s annual operating plan (AOP) for 2021 to 2025 including revenue forecasts and cost 
reduction targets, regulatory capital requirements, long term growth rates and discount rates.

Matters discussed with the Group Audit Committee

We discussed the appropriateness of methodologies used and significant assumptions with the GAC, giving consideration to the macroeconomic 
environment, as well as Covid-19 and HSBC’s strategy. We considered reasonably possible alternatives for significant assumptions. We also discussed 
the disclosures made in relation to goodwill and software intangibles, including the use of sensitivity analysis to explain estimation uncertainty and the 
conditions that would result in an impairment being recognised.

How our audit addressed the Key Audit Matter

We tested controls in place over significant assumptions and the model used to determine VIUs and fair values. We assessed the appropriateness of the 
CGUs and the methodology used, and the mathematical accuracy of the calculations, to estimate the recoverable amounts. In respect of the significant 
assumptions, our testing included the following:
•
• obtaining and evaluating evidence where available for critical data relating to significant assumptions, from a combination of historic experience and 

challenging the achievability of management’s AOP and the prospects for HSBC’s businesses;

external market and other financial information;
assessing whether the cash flows included in the model were in accordance with the relevant accounting standard;
assessing the sensitivity of the VIU to reasonable variations in significant assumptions, both individually and in aggregate; and

•
•
• determining a reasonable range for the discount rate used within the model, with the assistance of our valuation experts, and comparing it to the 

discount rate used by management.

We evaluated and tested the disclosures made in the Annual Report and Accounts 2020 in relation to goodwill and software intangibles.

Relevant references in the Annual Report and Accounts 2020

• GAC Report, page 221.
• Note 1.2(a): Critical accounting estimates and judgements, page 290.
• Note 1.2(n): Critical accounting estimates and judgements, page 299.
• Note 21: Goodwill and intangible assets, page 338.

Valuation of financial instruments (group)

Nature of the key audit matter

The financial instruments held by the group range from those that are traded daily on active markets with quoted prices, to more complex and bespoke 
positions. The valuation of financial instruments can require the use of prices or inputs which are not readily observable in the market. Where significant 
pricing inputs are unobservable, the financial instruments are classified as Level 3 (L3), per the IFRS 13 fair value hierarchy. Determining unobservable 
inputs in fair value measurement involves management judgement and is subject to a high degree of estimation uncertainty. 
The most material L3 financial instruments which are dependent on unobservable inputs are the group’s holding of $11.0bn of private equity (PE) 
investments held by the Global Banking and Markets and the Insurance businesses. The group also holds $758m of similar investments in the pension 
scheme assets for HSBC (UK) Bank plc. Covid-19 has resulted in markets being more volatile.  The level of judgement surrounding the valuation of PE 
investments increases in times of heightened market volatility. 
Fair value of the group’s PE investments is estimated using commonly accepted valuation methodologies, which are set out in the International Private 
Equity and Venture Capital Valuation Guidelines and includes the use of net asset value (NAV) statements from fund managers, the price of recent 
investments, the use of market comparables or discounted cash flow models. The fair value of most PE investments are based on NAV statements 
provided by fund managers. 

Matters discussed with the Group Audit Committee

We discussed with the GAC the appropriateness of the PE valuation approaches for PE investments. We also discussed the governance and controls over 
determining fair values, in particular, when markets are more volatile.

How our audit addressed the Key Audit Matter

We tested controls in place, including those relating to the assessment of valuations based on NAV statements and the fund managers that provide them. 
For fair values based on NAV statements from fund managers, we inspected NAV statements and engaged our valuation experts to test management’s 
assessment of the reliability of those valuations. For these valuations, we also:
•
•
• performed back testing of fair values to any recent transactions.
We evaluated the adequacy and extent of disclosures made in the Annual Report and Accounts 2020 in relation to valuation of L3 financial instruments.

compared fair value movements to movements in relevant market information, such as industry indices;
agreed NAV statements from fund managers to audited fund financial statements where they were available; and 

Relevant references in the Annual Report and Accounts 2020

• GAC Report, page 221.
• Note 1.2(c): Critical accounting estimates and judgements, page 292.
• Note 12: Fair values of financial instruments carried at fair value, page 314.

272 HSBC Holdings plc Annual Report and Accounts 2020

 
Impairment of investments in subsidiaries (company)

Nature of the key audit matter

The impact of the Covid-19 pandemic has resulted in unprecedented economic conditions, impacting the performance of HSBC in both 2020 and the 
outlook into 2021 and beyond. This is considered by management to be an indicator of impairment on the investment in subsidiaries. 
Management compared the net assets to the carrying value of each subsidiary. Where the net assets did not support the carrying value or the subsidiary 
made a loss during the period, management estimated the recoverable amount using the higher of value in use (‘VIU’) or fair value less cost to sell. 
Management predominantly used VIU in its impairment tests, unless it believed that fair value would result in a higher recoverable amount for any 
subsidiary. The impairment test resulted in impairment charges of $435m in relation to HSBC Overseas Holdings (UK) limited. The remaining investment in 
subsidiaries was $158bn at 31 December 2020.
The methodology in the models used to estimate the recoverable amount is dependent on various assumptions, both short term and long term in nature. 
These assumptions, which are subject to estimation uncertainty, are derived from a combination of management’s judgement, experts engaged by 
management and market data. The significant assumptions that we focused our audit on were those with greater levels of management judgement and 
for which variations had the most significant impact on the recoverable amount. Specifically, these included HSBC’s AOP for 2021 to 2025 including 
revenue forecasts and cost reduction targets, regulatory capital requirements, long term growth rates and discount rates.

Matters discussed with the Group Audit Committee

We discussed the appropriateness of methodologies used and significant assumptions with the GAC, giving consideration to the macroeconomic 
environment, as well as Covid-19 and HSBC’s strategy. We considered reasonably possible alternatives for significant assumptions. We also discussed 
the disclosures made in relation to investment in subsidiaries, including the use of sensitivity analysis to explain estimation uncertainty and the conditions 
that would result in an impairment being recognised.

How our audit addressed the Key Audit Matter

We tested controls in place over significant assumptions and the model used to determine the recoverable amounts. We assessed the appropriateness of 
the methodology used, and the mathematical accuracy of the calculations, to estimate the recoverable amounts. In respect of the significant assumptions, 
our testing included the following:
•
• obtaining and evaluating evidence where available for critical data relating to significant assumptions, from a combination of historic experience and 

challenging the achievability of management’s AOP and the prospects for HSBC’s businesses;

external market and other financial information;
assessing whether the cash flows included in the model were in accordance with the relevant accounting standard;
assessing the sensitivity of the VIU to reasonable variations in significant assumptions, both individually and in aggregate; and

•
•
• determining a reasonable range for the discount rate used within the model, with the assistance of our valuation experts, and comparing it to the 

discount rate used by management.

We evaluated and tested the disclosures made in the Annual Report and Accounts 2020 in relation to investment in subsidiaries.

Relevant references in the Annual Report and Accounts 2020
• Note 19: Investments in subsidiaries, page 335.

Valuation of defined benefit pensions obligations (group)

Nature of the key audit matter

The group has a defined benefit obligation of $44bn, of which $33bn relates to HSBC Bank (UK) pension scheme.  
The valuation of the defined benefit obligation for HSBC Bank (UK) is dependent on a number of actuarial assumptions. Management uses an actuarial 
expert to determine the valuation of the defined benefit obligation. The expert uses a valuation methodology that requires a number of market based 
inputs and other financial and demographic assumptions. The significant assumptions that we focused our audit on were those with greater levels of 
management judgement and for which variations had the most significant impact on the liability. Specifically, these included the discount rate, inflation 
rate and mortality rate.

Matters discussed with the Group Audit Committee

We discussed with the GAC the methodologies and significant assumptions used by management to determine the value of the defined benefit obligation. 

How our audit addressed the Key Audit Matter

We tested controls in place over the methodologies and the significant assumptions. We also evaluated the objectivity and competence of management’s 
expert involved in the valuation of the defined benefit obligation. 
We assessed the appropriateness of the methodology used, and the mathematical accuracy of the calculations, to estimate the liability. In respect of the 
significant assumptions, our actuarial experts understood the judgements made by management and management’s actuarial expert in determining the 
significant assumptions, and compared these assumptions to our independently compiled expected ranges based on market observable indices and our 
market experience. We also tested the members data used in calculating the obligation.
We evaluated and tested the disclosures made in the Annual Report and Accounts 2020 in relation to defined benefit pension obligation. 

Relevant references in the Annual Report and Accounts 2020

• GAC Report, page 221.
• Note 1.2(k): Critical accounting estimates and judgements, page 298.
• Note 5: Employee compensation and benefits, page 301.

HSBC Holdings plc Annual Report and Accounts 2020 273

Financial statements 
Independent auditors’ report to the members of HSBC Holdings plc

IT access management (group)

Nature of the key audit matter

HSBC has operations across a number of countries supporting a wide range of products and services, resulting in an IT environment that is large, complex 
and increasingly reliant on third parties. HSBC’s financial reporting processes rely upon a significant element of this IT environment, both within Finance 
and the business and operations more broadly.
Access management controls are an important part of the IT environment to ensure both access and changes made to systems and data are appropriate. 
Our audit approach planned to rely extensively on the effectiveness of IT access management controls. 
As part of our audit work in prior periods, control deficiencies were identified in relation to IT access management for systems and data relevant to 
financial reporting. Management has an ongoing remediation programme to address these matters.

Matters discussed with the Group Audit Committee

The significance of IT access management to our audit was discussed at GAC meetings during the year, as well as progress on management’s 
remediation programme, control deficiencies identified and our related audit responses.

How our audit addressed the Key Audit Matter

IT access management controls were tested for systems and data relevant to financial reporting that we planned to rely upon as part of our audit. 
Specifically we tested controls over:
authorising new access requests;
•
•
the timely removal of access rights;
• periodic monitoring of the appropriateness of access rights to systems and data;
•
•
•
•
• understanding and assessing reliance on third parties, including Service Organisation controls reports.  
We also independently assessed password policies and system configurations, and performed substantive audit procedures in relation to access right 
removal, privileged access, IT user information and segregation of duties.
We performed further testing where control deficiencies were identified, including:
• where inappropriate access was identified, we understood and assessed the nature of the access, and obtained additional evidence on the 

restricting highly privileged access to appropriate personnel;
the accuracy of information about IT users to facilitate access management;
segregation of access across IT and business functions;
changes made to systems and data; and

appropriateness of activities performed; and, 

• we identified and tested compensating business controls and performed other audit procedures where IT compensating controls were not sufficient to 

address the audit risk. 

Relevant references in the Annual Report and Accounts 2020
• Effectiveness of internal controls, page 260.

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

Overall materiality
How we determined it

$900m (2019: $1,000m).
5% of a three year average of adjusted profit before tax.

Rationale for benchmark 
applied

We believe a standard benchmark of 5% of adjusted profit before tax is an 
appropriate quantitative indicator of materiality, although certain items could also 
be material for qualitative reasons. This benchmark is standard for listed entities 
and consistent with the wider industry. 
We selected adjusted profit because, as discussed on page 77, management 
believes it better reflects the performance of the group. We excluded the 
adjustments made by management on page 311 for certain customer redress 
programmes and fair value movements of financial instruments, as in our opinion 
they are recurring items that form part of ongoing business performance.Whilst 
adjusted profit before tax is still considered the most suitable benchmark, we have 
used a three year average to reflect the significant impact Covid-19 has had on 
performance in 2020.

Financial statements - company

$855m (2019: $900m).
0.75% of total assets. This would result 
in an overall materiality of $1.9bn and 
was therefore reduced below this 
materiality for the group.

A benchmark of total assets has been 
used as the company’s primary purpose 
is to act as a holding company with 
investments in the group’s subsidiaries, 
not to generate operating profits and 
therefore a profit based measure is not 
relevant.

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 of account balances, classes of transactions and disclosures, for example in determining sample sizes. 
Our performance materiality was 75% of overall materiality, amounting to $675m (2019: $750m) for the group financial statements and 
$641m (2019: $675m) for the company financial statements. In determining the performance materiality, we considered a number of 
factors - the history of misstatements, our risk assessment and aggregation risk, and the effectiveness of controls.

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 $60m and $855m. Certain components were audited to a local statutory audit 
materiality that was less than the materiality we allocated them.

We agreed with the GAC that we would report to them misstatements identified during our group and company audit above $45m 
(2019: $50m), as well as misstatements below those amounts that, in our view, warranted reporting for qualitative reasons.

274 HSBC Holdings plc Annual Report and Accounts 2020

 
 
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, reflecting the structure of the group and the company, the processes and controls relevant to financial reporting, and the 
industry in which they operate. Our audit approach incorporated a number of key aspects:

(1) Audit approach to HSBC’s global businesses

We designed audit approaches for the products and services that substantially make up HSBC’s global businesses, such as lending, 
deposits and derivatives. These global business approaches were designed by partners and team members who are specialists in the 
relevant businesses. These approaches were provided to the audit partners and teams around the world that contributed to the group 
audit. 

(2) Audit work for Significant Subsidiaries:

Through our risk assessment and scoping we identified certain entities (collectively the Significant Subsidiaries) for which we obtained 
audit opinions. We obtained full scope audit opinions for Hongkong and Shanghai Banking Corporation Limited, HSBC Bank plc, HSBC 
UK Bank plc, HSBC North America Holdings Ltd, HSBC Bank Canada and HSBC Mexico S.A. We obtained audit opinions over specific 
balances for HSBC Global Services (UK) Limited and HSBC Group Management Services Limited and HSBC Bank Middle East Limited - 
UAE Operations. The audits for HSBC Bank plc, HSBC UK Bank plc, HSBC Global Services (UK) Limited and HSBC Group Management 
Services Limited were performed by other PwC teams in the UK. All other audits were performed by other PwC network firms.

We worked with the Significant Subsidiaries in 2020 to develop an approach for rotating certain smaller locations in and out of scope 
over a number of reporting periods. These locations, which are subject to local external audits, are individually relatively small compared 
to the group. Notwithstanding their size, the rotational approach is designed to ensure that over time these locations are subject to audit 
work as part of the group audit. India was removed from the scope of the Hongkong and Shanghai Banking Corporation audit for 2020 
and Singapore was included.

We asked the partners and teams reporting to us on the Significant Subsidiaries to work to assigned materiality levels reflecting the size 
of the operations they audited. The performance materiality levels ranged from $45m to $641m. Certain Significant Subsidiaries were 
audited to a local statutory audit materiality that was less than our overall group materiality. 

We were in active dialogue throughout the year with the partners and teams responsible for the audits of the Significant Subsidiaries. 
This included consideration of how they planned and performed their work, including their use of the global business approaches. We 
attended Audit Committee meetings for some of Significant Subsidiaries. We also attended meetings with management in each of these 
Significant Subsidiaries at the year-end. 

The audit of The Hongkong and Shanghai Banking Corporation in Hong Kong relied upon work performed by other teams in Hong Kong 
and the PwC network firms in Malaysia, mainland China and Singapore. Similarly, the audit of HSBC Bank plc and HSBC UK Bank plc in 
the UK relied upon work performed by other teams in the UK and the PwC network firms in France and Germany. We considered how 
the audit partners and teams for the Significant Subsidiaries instructed and provided oversight to the work performed in these locations. 
Collectively, PwC network firms completed audit procedures covering 88% of assets and 73% of total operating income.

(3) Audit work performed at Operations Centres

A significant amount of the operational processes and controls which are critical to financial reporting are undertaken in operations 
centres run by Digital Business Services ('DBS') across 12 different locations. Financial reporting processes are performed in HSBC’s 
four Finance Operations Centres. We coordinated and provided oversight on the audit work performed by PwC teams in the UK, Poland, 
China, Sri Lanka, Malaysia, India and the Philippines. This work was relied upon by us, as well as the PwC teams auditing the Significant 
Subsidiaries.

(4)  Audit procedures undertaken at a group level and on the company

We ensured that appropriate further work was undertaken for the HSBC group and company. This work included auditing, for example, 
the impairment assessment of goodwill and intangible assets, the consolidation of the group’s results, the preparation of the financial 
statements, certain disclosures within the Directors' remuneration report, litigation provisions and exposures, taxation, and 
management’s entity level and oversight controls relevant to financial reporting. Subsidiaries' balances that were not identified as part of 
a Significant Subsidiary were subject to procedures which mitigated the risk of material misstatement, including testing of entity level 
controls, information technology general controls, testing at the Operations Centre, analytical review procedures and understanding and 
assessing the outcome of local external audits.

(5) Using the work of others

We continued to make use of evidence provided by others. This included testing of controls performed by Global Internal Audit and 
management themselves in some low risk areas. We used the work of PwC experts, for example, valuation experts for our work around 
the assumptions used in the impairment assessment over goodwill and actuaries on the estimates used in determining pension 
liabilities. An increasing number of controls are operated on behalf of HSBC by third parties. We rely on audit evidence that is scoped 
and provided by other auditors that are engaged by those third parties. For example, we obtain a report evidencing the testing of 
external systems and controls supporting HSBC’s payroll and HR processes.

Conclusions relating to going concern

Our evaluation of the directors’ assessment of the group's and the company’s ability to continue to adopt the going concern basis of 
accounting included:

• Performing a risk assessment to identify factors that could impact the going concern basis of accounting, including the impact of 

Covid-19 and geopolitical risks.

• Understanding and evaluating the group’s financial forecasts and the group’s stress testing of liquidity and regulatory capital, 

including the severity of the stress scenarios that were used.

• Reading and evaluating the adequacy of the disclosures made in the financial statements in relation to going concern.

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

In 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.

HSBC Holdings plc Annual Report and Accounts 2020 275

Financial statementsIndependent auditors’ report to the members of HSBC Holdings plc

However, because not all future events or conditions can be predicted, this conclusion is not a guarantee as to the group's and the 
company's ability to continue as a going concern.

In relation to the group's and the company’s 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.

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 Report of the Directors', 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.

Strategic Report and Report of the Directors

In our opinion, based on the work undertaken in the course of the audit, the information given in the Strategic Report and Report of the 
Directors' for the year ended 31 December 2020 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 company and their environment obtained in the course of the audit, we 
did not identify any material misstatements in the Strategic Report and Report of the Directors.

Directors’ Remuneration

In our opinion, the part of the Directors' Remuneration Report to be audited has been properly prepared in accordance with the 
Companies Act 2006.

 Corporate governance statement

The Listing Rules 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 company’s compliance with the provisions of the UK Corporate Governance Code 
specified for our review. 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.

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 and we have nothing 
material to add or draw attention to in relation to:

• The directors’ confirmation that they have carried out an assessment of the emerging and principal risks;

• The disclosures in the Annual Report and Accounts 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 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 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 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 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 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 GAC.

We have nothing to report in respect of our responsibility to report when the directors’ statement relating to the 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.

276 HSBC Holdings plc Annual Report and Accounts 2020

Responsibilities for the financial statements and the audit

Responsibilities of the directors for the financial statements

As explained more fully in the Directors' responsibilities statement, 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 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 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.

Our audit testing might include testing complete populations of certain transactions and balances, possibly using data auditing 
techniques. 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 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 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 financial statements and the part of the Directors' Remuneration Report to be audited are not in agreement with the accounting 

records and returns.

We have no exceptions to report arising from this responsibility.

Appointment

Following the recommendation of the GAC, we were appointed by the members on 31 March 2015 to audit the financial statements for 
the year ended 31 December 2015 and subsequent financial periods. The period of total uninterrupted engagement is six years, covering 
the years ended 31 December 2015 to 31 December 2020.

Scott Berryman (Senior Statutory Auditor)

for and on behalf of PricewaterhouseCoopers LLP

Chartered Accountants and Statutory Auditors

London

23 February 2021

HSBC Holdings plc Annual Report and Accounts 2020 277

Financial statements  
Financial statements

Financial statements

Consolidated income statement 

Consolidated statement of comprehensive income 

Consolidated balance sheet 

Consolidated statement of cash flows

Consolidated statement of changes in equity 

HSBC Holdings income statement

HSBC Holdings statement of comprehensive income

HSBC Holdings balance sheet

HSBC Holdings statement of cash flows

HSBC Holdings statement of changes in equity 

Consolidated income statement

for the year ended 31 December

Net interest income
–  interest income1,2
–  interest expense3
Net fee income

–  fee income

–  fee expense

Page

278

279

280

281

282

284

284

285

286

287

Net income from financial instruments held for trading or managed on a fair value basis

Net income/(expense) from assets and liabilities of insurance businesses, including related derivatives, 
measured at fair value through profit or loss

Changes in fair value of designated debt and related derivatives4
Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss

Gains less losses from financial investments

Net insurance premium income

Other operating income

Total operating income

Net insurance claims and benefits paid and movement in liabilities to policyholders

Net operating income before change in expected credit losses and other credit impairment 
charges

Change in expected credit losses and other credit impairment charges

Net operating income

Employee compensation and benefits

General and administrative expenses
Depreciation and impairment of property, plant and equipment and right-of-use assets5
Amortisation and impairment of intangible assets

Goodwill impairment

Total operating expenses

Operating profit

Share of profit in associates and joint ventures

Profit before tax

Tax expense

Profit for the year

Attributable to:

–  ordinary shareholders of the parent company

–  preference shareholders of the parent company

–  other equity holders

–  non-controlling interests

Profit for the year

Basic earnings per ordinary share

Diluted earnings per ordinary share

Notes*

2

3

3

3

3

4

4

5

21

18

7

9

9

2020

$m

27,578   

41,756   

(14,178)   

11,874   

15,051   

(3,177)   

9,582   

2019

$m

30,462   

54,695   

(24,233)   

12,023   

15,439   

(3,416)   

10,231   

2018

$m

30,489 

49,609 

(19,120) 

12,620 

16,044 

(3,424) 

9,531 

2,081   

3,478   

(1,488) 

231   

455   

653   

10,093   

527   

63,074   

(12,645)   

50,429   

(8,817)   

41,612   

(18,076)   

(11,115)   

(2,681)   

(2,519)   

(41)   

(34,432)   

7,180   

1,597   

8,777   

(2,678)   

6,099   

3,898   

90   

1,241   

870   

6,099   

$

0.19   

0.19   

90   

812   

335   

10,636   

2,957   

71,024   

(14,926)   

56,098   

(2,756)   

53,342   

(18,002)   

(13,828)   

(2,100)   

(1,070)   

(7,349)   

(42,349)   

10,993   

2,354   

13,347   

(4,639)   

8,708   

5,969   

90   

1,324   

1,325   

8,708   

$

0.30   

0.30   

(97) 

695 

218 

10,659 

960 

63,587 

(9,807) 

53,780 

(1,767) 

52,013 

(17,373) 

(15,353) 

(1,119) 

(814) 

— 

(34,659) 

17,354 

2,536 

19,890 

(4,865) 

15,025 

12,608 

90 

1,029 

1,298 

15,025 

$

0.63 

0.63 

*  For Notes on the financial statements, see page 288.
1 

Interest income includes $35,293m (2019: $45,708m) of interest recognised on financial assets measured at amortised cost and $5,614m (2019: 
$8,259m) of interest recognised on financial assets measured at fair value through other comprehensive income. 
Interest revenue calculated using the effective interest method comprises interest recognised on financial assets measured at either amortised 
cost or fair value through other comprehensive income. 
Interest expense includes $12,426m (2019: $21,922m) of interest on financial instruments, excluding interest on financial liabilities held for 
trading or designated or otherwise mandatorily measured at fair value. 

2 

3 

4  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch. 
5 

Includes depreciation of the right-of-use assets of $1,029m (2019: $912m). Right-of-use assets have been recognised from 1 January 2019 
following the adoption of IFRS 16. Comparatives have not been restated.

278 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of comprehensive income

for the year ended 31 December 

Profit for the year

Other comprehensive income/(expense)

Items that will be reclassified subsequently to profit or loss when specific conditions are met:

Debt instruments at fair value through other comprehensive income

–  fair value gains/(losses)

–  fair value gains transferred to the income statement on disposal

–  expected credit (recoveries)/losses recognised in the income statement

–  income taxes

Cash flow hedges

–  fair value gains/(losses)

–  fair value (gains)/losses reclassified to the income statement

–  income taxes

Share of other comprehensive income/(expense) of associates and joint ventures 

–  share for the year

Exchange differences

Items that will not be reclassified subsequently to profit or loss:

Remeasurement of defined benefit asset/liability

–  before income taxes

–  income taxes

Changes in fair value of financial liabilities designated at fair value upon initial recognition arising from changes in 
own credit risk

–  before income taxes

–  income taxes

Equity instruments designated at fair value through other comprehensive income

–  fair value gains/(losses)

–  income taxes

Effects of hyperinflation

Other comprehensive income/(expense) for the period, net of tax

Total comprehensive income for the year

Attributable to:

–  ordinary shareholders of the parent company

–  preference shareholders of the parent company

–  other equity holders

–  non-controlling interests 

Total comprehensive income for the year

2020

$m

2019

$m

2018

$m

6,099   

8,708   

15,025 

1,750   

2,947   

(668)   

48   

(577)   

471   

(157)   

769   

(141)   

(73)   

(73)   

1,152   

1,793   

(365)   

109   

(385)   

206   

551   

(286)   

(59)   

21   

21   

(243) 

(168) 

(95) 

(94) 

114 

19 

(267) 

317 

(31) 

(64) 

(64) 

4,855   

1,044   

(7,156) 

834   

1,223   

(389)   

167   

190   

(23)   

212   

212   

—   

193   

8,409   

14,508   

12,146   

90   

1,241   

1,031   

14,508   

13   

(17)   

30   

(2,002)   

(2,639)   

637   

366   

364   

2   

217   

1,017   

9,725   

6,838   

90   

1,324   

1,473   

9,725   

(329) 

(388) 

59 

2,847 

3,606 

(759) 

(27) 

(71) 

44 

283 

(4,670) 

10,355 

8,083 

90 

1,029 

1,153 

10,355 

HSBC Holdings plc Annual Report and Accounts 2020 279

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

Consolidated balance sheet

Assets

Cash and balances at central banks

Items in the course of collection from other banks

Hong Kong Government certificates of indebtedness

Trading assets

Financial assets designated and otherwise mandatorily measured at fair value through profit or loss

Derivatives

Loans and advances to banks

Loans and advances to customers

Reverse repurchase agreements – non-trading

Financial investments

Prepayments, accrued income and other assets

Current tax assets

Interests in associates and joint ventures

Goodwill and intangible assets

Deferred tax assets

Total assets

Liabilities and equity

Liabilities

Hong Kong currency notes in circulation

Deposits by banks

Customer accounts

Repurchase agreements – non-trading

Items in the course of transmission to other banks

Trading liabilities

Financial liabilities designated at fair value

Derivatives

Debt securities in issue

Accruals, deferred income and other liabilities

Current tax liabilities

Liabilities under insurance contracts

Provisions

Deferred tax liabilities

Subordinated liabilities

Total liabilities

Equity

Called up share capital

Share premium account

Other equity instruments

Other reserves

Retained earnings

Total shareholders’ equity

Non-controlling interests

Total equity

Total liabilities and equity

At

31 Dec

2020

$m

31 Dec

2019

$m

Notes*

11

14

15

16

22

18

21

7

23

24

15

25

26

4

27

7

28

31

31

304,481   

154,099 

4,094   

40,420   

231,990   

45,553   

307,726   

81,616   

4,956 

38,380 

254,271 

43,627 

242,995 

69,203 

1,037,987   

1,036,743 

230,628   

490,693   

156,412   

954   

26,684   

20,443   

4,483   

240,862 

443,312 

136,680 

755 

24,474 

20,163 

4,632 

2,984,164   

2,715,152 

40,420   

82,080   

38,380 

59,022 

1,642,780   

1,439,115 

111,901   

140,344 

4,343   

75,266   

157,439   

303,001   

95,492   

128,624   

690   

107,191   

3,678   

4,313   

21,951   

4,817 

83,170 

164,466 

239,497 

104,555 

118,156 

2,150 

97,439 

3,398 

3,375 

24,600 

2,779,169   

2,522,484 

10,347   

14,277   

22,414   

8,833   

140,572   

196,443   

8,552   

10,319 

13,959 

20,871 

2,127 

136,679 

183,955 

8,713 

204,995   

192,668 

2,984,164   

2,715,152 

*  For Notes on the financial statements, see page 288.

The accompanying notes on pages 288 to 370 and the audited sections in: ‘Risk’ on pages 106 to 194 (including ‘Measurement 
uncertainty and sensitivity analysis of ECL estimates’ on pages 127 to 135), and ‘Directors’ remuneration report’ on pages 229 to 255 
form an integral part of these financial statements.

These financial statements were approved by the Board of Directors on 23 February 2021 and signed on its behalf by:

Mark E Tucker
Group Chairman

Ewen Stevenson
Group Chief Financial Officer

280 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of cash flows

for the year ended 31 December

Profit before tax
Adjustments for non-cash items:
Depreciation, amortisation and impairment

Net gain from investing activities

Share of profits in associates and joint ventures

Gain on disposal of subsidiaries, businesses, associates and joint ventures

Change in expected credit losses gross of recoveries and other credit impairment charges

Provisions including pensions

Share-based payment expense

Other non-cash items included in profit before tax
Elimination of exchange differences1
Changes in operating assets and liabilities

Change in net trading securities and derivatives

Change in loans and advances to banks and customers

Change in reverse repurchase agreements – non-trading

Change in financial assets designated and otherwise mandatorily measured at fair value

Change in other assets

Change in deposits by banks and customer accounts

Change in repurchase agreements – non-trading

Change in debt securities in issue

Change in financial liabilities designated at fair value

Change in other liabilities

Dividends received from associates

Contributions paid to defined benefit plans

Tax paid

Net cash from operating activities

Purchase of financial investments

Proceeds from the sale and maturity of financial investments

Net cash flows from the purchase and sale of property, plant and equipment

Net cash flows from purchase/(disposal) of customer and loan portfolios

Net investment in intangible assets

Net cash flow from acquisition and disposal of subsidiaries, businesses, associates and joint ventures

Net cash from investing activities

Issue of ordinary share capital and other equity instruments

Cancellation of shares

Net sales/(purchases) of own shares for market-making and investment purposes

Redemption of preference shares and other equity instruments
Subordinated loan capital repaid2
Dividends paid to shareholders of the parent company and non-controlling interests

Net cash from financing activities

Net increase/(decrease) in cash and cash equivalents

Cash and cash equivalents at 1 Jan

Exchange differences in respect of cash and cash equivalents
Cash and cash equivalents at 31 Dec3
Cash and cash equivalents comprise:

–  cash and balances at central banks

–  items in the course of collection from other banks

–  loans and advances to banks of one month or less

–  reverse repurchase agreements with banks of one month or less

–  treasury bills, other bills and certificates of deposit less than three months

–  cash collateral and net settlement accounts

–  less: items in the course of transmission to other banks
Cash and cash equivalents at 31 Dec3

2020

$m
8,777   

5,241   

(541)   

(1,597)   

—   

9,096   

1,164   

433   

(906)   

(25,749)   

13,150   

(14,131)   

9,950   

(1,962)   

(19,610)   

226,723   

(28,443)   

(9,075)   

(6,630)   

20,323   

761   

(495)   

(4,259)   

182,220   

(496,669)   

476,990   

(1,446)   

1,362   

(2,064)   

(603)   

(22,430)   

1,497   

—   

(181)   

(398)   

(3,538)   

(2,023)   

(4,643)   

155,147   

293,742   

19,434   
468,323   

2019

$m
13,347   

10,519   

(399)   

(2,354)   

(929)   

3,012   

2,423   

478   

(2,297)   

(3,742)   

(18,910)   

(53,760)   

(7,390)   

(2,308)   

(21,863)   

79,163   

(25,540)   

19,268   

20,068   

23,124   

633   

(533)   

(2,267)   

29,743   

(445,907)   

413,186   

(1,343)   

1,118   

(2,289)   

(83)   

2018

$m
19,890 

1,933 

(126) 

(2,536) 

— 

2,280 

1,944 

450 

(1,303) 

4,930 

20,855 

(44,071) 

(25,399) 

(1,515) 

6,766 

(5,745) 

35,882 

18,806 

4,500 

(2,187) 

910 

(332) 

(3,417) 

32,515 

(399,458) 

386,056 

(1,196) 

(204) 

(1,848) 

4 

(35,318)   

(16,646) 

—   

(1,000)   

141   

—   

(4,210)   

(9,773)   

(14,842)   

(20,417)   

312,911   

1,248   
293,742   

6,001 

(1,998) 

133 

(6,078) 

(4,077) 

(10,762) 

(16,781) 

(912) 

323,718 

(9,895) 
312,911 

304,481   

154,099   

162,843 

4,094   

51,788   

65,086   

30,023   

17,194   

(4,343)   

4,956   

41,626   

65,370   

20,132   

12,376   

(4,817)   

468,323   

293,742   

5,787 

39,460 

74,702 

21,685 

14,075 

(5,641) 

312,911 

Interest received was $45,578m (2019: $58,627m; 2018: $45,291m), interest paid was $17,740m (2019: $27,384m; 2018: $14,172m) and 
dividends received (excluding dividends received from associates, which are presented separately above) were $1,158m (2019: $2,369m; 
2018: $1,702m).

1 Adjustment to bring changes between opening and closing balance sheet amounts to average rates. This is not done on a line-by-line basis, as 

details cannot be determined without unreasonable expense. 

2 Subordinated liabilities changes during the year are attributable to repayments of $(3.5)bn (2019: $(4.2)bn; 2018: $(4.1)bn) of securities. Non-

cash changes during the year included foreign exchange gains/(losses) of $0.5bn (2019: $0.6bn; 2018: $(0.6)bn) and fair value gains/(losses) of 
$1.1bn (2019: $1.4bn; 2018: $(1.4)bn).

3 At 31 December 2020, $41,912m (2019: $35,735m; 2018: $26,282m) was not available for use by HSBC, of which $16,935m (2019: $19,353m; 

2018: $19,755m) related to mandatory deposits at central banks.

HSBC Holdings plc Annual Report and Accounts 2020 281

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

Consolidated statement of changes in equity

for the year ended 31 December

Other reserves

Called up
share
capital
and
share
premium

Other
equity
instru-
ments

Retained
earnings3,4

Financial
assets
at
FVOCI
reserve

Cash
flow
hedging
reserve

Foreign
exchange
reserve

Merger
and other
reserves4,5

Total
share-
holders’
equity

Non-
controlling
interests

$m

$m

$m

$m

$m

$m

$m

$m

$m

Total
equity

$m

  24,278   20,871    136,679   

(108)   

(2)   

(25,133)   

27,370   183,955   

8,713   192,668 

—   

—   

—   
—   

5,229   

—   

—   

—   

—    5,229   

870    6,099 

1,118   

1,913   

459   

4,758   

—    8,248   

161    8,409 

—   

—   

—   

1,746   

—   

—   

—    1,746   

4    1,750 

—   

—   

—   
—   

—   

—   

167   

—   

—   

459   

—   

—   

—   

—   

167   

459   

45   

12   

212 

471 

—   

—   

167   

—   

—   

—   

—   

167   

—   

167 

At 1 Jan 2020

Profit for the year

Other comprehensive income (net of tax)

–  debt instruments at fair value through 

other comprehensive income

–  equity instruments designated at fair value 

through other comprehensive income

–  cash flow hedges

–  changes in fair value of financial liabilities 

designated at fair value upon initial 
recognition arising from changes in own 
credit risk

–  remeasurement of defined benefit asset/

liability

—   

—   

831   

—   

—   

—   

—   

831   

3   

834 

–  share of other comprehensive income of 

associates and joint ventures

–  effects of hyperinflation

–  exchange differences

Total comprehensive income for the 
year

Shares issued under employee remuneration 
and share plans
Capital securities issued1

Dividends to shareholders
Redemption of securities2
Transfers6
Cost of share-based payment arrangements

Other movements
At 31 Dec 2020

At 1 Jan 2019

Profit for the year

Other comprehensive income (net of tax)

–  debt instruments at fair value through 

other comprehensive income

– equity instruments designated at fair value 

through other comprehensive income

–  cash flow hedges

–  changes in fair value of financial liabilities 

designated at fair value upon initial 
recognition arising from changes in own 
credit risk

–  remeasurement of defined benefit asset/

—   

—   

—   

—   
—   
—   

(73)   

193   

—   

—   

—   

—   

—   

—   

—   

—   

—   

4,758   

(73)   

—   
—   
—    4,758   

193   

—   

—   

(73) 

193 

97    4,855 

—   

—   

6,347   

1,913   

459   

4,758   

—    13,477   

1,031    14,508 

346   

—   

(339)   

—    1,500   

(3)   

—   

—   

—   

—   

—   

—   

—   

—   

(1,331)   

(1,450)   

435   

434   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

7   

—    1,497   

—   

7 

—    1,497 

—    (1,331)   

(692)   

(2,023) 

—    (1,450)   

—   

(1,450) 

(435)   

—   

—   

434   

—   

—   

— 

434 

—   

(200)   
  24,624   22,414    140,572   

43   

11   
1,816   

—   
457   

—   
(20,375)   

—   

(146)   
26,935   196,443   

(500)   

(646) 
8,552   204,995 

23,789    22,367   

138,191   

(1,532)   

(206)   

(26,133)   

29,777    186,253   

7,996    194,249 

—   

—   

—   

—   

7,383   

—   

—   

—   

(1,759)   

1,424   

204   

1,000   

—   

—   

7,383   

869   

1,325   

8,708 

148   

1,017 

—   

—   

—   

1,146   

—   

—   

—   

1,146   

6   

1,152 

—   

—   

—   

—   

—   

—   

278   

—   

—   

204   

—   

—   

—   

—   

278   

204   

88   

2   

366 

206 

—   

—   

(2,002)   

—   

—   

—   

—   

(2,002)   

—   

(2,002) 

liability

—   

—   

5   

—   

—   

—   

—   

5   

8   

13 

–  share of other comprehensive income of 

associates and joint ventures

–  effects of hyperinflation

–  exchange differences

Total comprehensive income for the year

Shares issued under employee remuneration 
and share plans

Shares issued in lieu of dividends and 
amounts arising thereon

Dividends to shareholders
Redemption of securities2
Transfers6
Cost of share-based payment arrangements
Cancellation of shares7
Other movements

—   

—   

—   

—   

—   

—   

—   

—   

21   

217   

—   

—   

—   

—   

—   

—   

—   

5,624   

1,424   

204   

—   

—   

1,000   

1,000   

—   

—   

—   

—   

21   

217   

1,000   

8,252   

—   

—   

44   

21 

217 

1,044 

1,473   

9,725 

557   

—   

(495)   

—   

—   

—   

—   

62   

—   

62 

—   

—   

—   

—   

2,687   

(11,683)   

—   

(1,496)   

—   

—   

(68)   

—   

—   

—   

—   

—   

(12)   

2,475   

478   

(1,000)   

414   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(2)   

—   

—   

—   

—   

—   

—   

—   

—   

2,687   

—   

2,687 

—    (11,683)   

(777)    (12,460) 

—   

(1,508)   

(2,475)   

—   

—   

478   

68   

(1,000)   

—   

414   

—   

—   

—   

—   

21   

(1,508) 

— 

478 

(1,000) 

435 

(25,133)   

27,370    183,955   

8,713    192,668 

At 31 Dec 2019

24,278    20,871   

136,679   

(108)   

282 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of changes in equity (continued)

for the year ended 31 December

Other reserves

Called up
share
capital and
share
premium

Other
equity
instru-
ments

Financial
assets at
FVOCI
reserve

Cash
flow
hedging
reserve

Retained
earnings3,4

Foreign
exchange
reserve

Merger
and other
reserves5

Total
share-
holders’
equity

Non-
controlling
interests

Total
equity

$m

$m

$m

$m

$m

$m

$m

$m

$m

$m

20,337    22,250   

139,414   

(1,371)   

(222)   

(19,072)   

27,308    188,644   

7,580    196,224 

—   

—   

—   

—   

—   

—   

—   

—   

13,727   

—   

2,765   

(245)   

—   

—   

(245)   

—   

—   

16   

—   

—   

—   

(7,061)   

—    13,727   

1,298    15,025 

—   

(4,525)   

(145)   

(4,670) 

—   

—   

—   

—   

(245)   

—   

2   

(243) 

(27)   

(27) 

—   

—   

—   

—   

16   

—   

—   

16   

3   

19 

—   

—   

2,847   

—   

—   

—   

—   

2,847   

—   

2,847 

At 1 Jan 2018

Profit for the year

Other comprehensive income (net of tax)

–  debt instruments at fair value through 

other comprehensive income

–  equity instruments designated at fair value 

through other comprehensive income

–  cash flow hedges

–  changes in fair value of financial liabilities 
designated at fair value due to movement 
in own credit risk

–  remeasurement of defined benefit asset/

liability

—   

—   

(301)   

—   

—   

—   

—   

(301)   

(28)   

(329) 

–  share of other comprehensive income of 

associates and joint ventures

–  effects of hyperinflation

–  exchange differences

Total comprehensive income for the year

Shares issued under employee remuneration 
and share plans

Shares issued in lieu of dividends and 
amounts arising thereon
Capital securities issued1
Dividends to shareholders
Redemption of securities2
Transfers6
Cost of share-based payment arrangements
Cancellation of shares7
Other movements

—   

—   
—   

—   

—   

—   
—   

—   

(64)   

283   
—   

—   

—   
—   

—   

—   
—   

—   

—   
(7,061)   

—   

—   
—   

(64)   

283   
(7,061)   

—   

—   
(95)   

(64) 

283 
(7,156) 

16,492   

(245)   

16   

(7,061)   

—   

9,202   

1,153    10,355 

721   

—   

(610)   

—   

—   

—   

—   

111   

—   

111 

—   

—   

1,494   

—    5,968   

—   

—   

(11,547)   

—   

—   
—   
—   

(5,851)   
—   
—   

2,731   

—   

—   

—   

(237)   
(2,200)   
450   

(4,998)   

(67)   

—   

—   

—   

—   
—   
—   

—   

84   

—   

—   

—   

—   
—   
—   

—   

—   

—   

—   

—   

—   
—   
—   

—   

—   

—   

1,494   

—   

5,968   

—   

—   

1,494 

5,968 

—    (11,547)   

(710)    (12,257) 

—   
2,200   
—   

(6,088)   
—   
450   

269   

(1,998)   

—   
—   
—   

—   

(6,088) 
— 
450 

(1,998) 

—   

17   

(27)   

(10) 

At 31 Dec 2018

23,789    22,367   

138,191   

(1,532)   

(206)   

(26,133)   

29,777    186,253   

7,996    194,249 

1  During 2020 HSBC Holdings issued $1,500m of perpetual subordinated contingent convertible securities. In 2018, HSBC Holdings issued 

$4,150m, £1,000m and SGD750m of perpetual subordinated contingent convertible capital securities on which there were $60m of external 
issuance costs, $49m of intra-Group issuance costs and $11m of tax benefits. Under IFRSs these issuance costs and tax benefits are classified as 
equity.

2  During 2020, HSBC Holdings called $1,450m 6.20% non-cumulative US dollar preference shares. For further details, see Note 31 in the Annual 
Report and Accounts 2020. In 2019, HSBC Holdings redeemed $1,500m 5.625% perpetual subordinated capital securities on which there were 
$12m of external issuance costs. In 2018, HSBC Holdings redeemed $2,200m 8.125% perpetual subordinated capital securities and its $3,800m 
8.000% perpetual subordinated capital securities, Series 2, on which there were $172m of external issuance costs and $23m of intra-Group 
issuance costs wound down. Under IFRSs external issuance costs are classified as equity.

3  At 31 December 2020, retained earnings included 509,825,249 treasury shares (2019: 432,108,782; 2018: 379,926,645). In addition, treasury 

shares are also held within HSBC’s Insurance business retirement funds for the benefit of policyholders or beneficiaries within employee trusts for 
the settlement of shares expected to be delivered under employee share schemes or bonus plans, and the market-making activities in Global 
Markets.

4  Cumulative goodwill amounting to $5,138m has been charged against reserves in respect of acquisitions of subsidiaries prior to 1 January 1998, 
including $3,469m charged against the merger reserve arising on the acquisition of HSBC Bank plc. The balance of $1,669m has been charged 
against retained earnings.

5  Statutory share premium relief under section 131 of the Companies Act 1985 (the ‘Act’) was taken in respect of the acquisition of HSBC Bank plc 
in 1992, HSBC Continental Europe in 2000 and HSBC Finance Corporation in 2003, and the shares issued were recorded at their nominal value 
only. In HSBC’s consolidated financial statements, the fair value differences of $8,290m in respect of HSBC Continental Europe and $12,768m in 
respect of HSBC Finance Corporation were recognised in the merger reserve. The merger reserve created on the acquisition of HSBC Finance 
Corporation subsequently became attached to HSBC Overseas Holdings (UK) Limited (‘HOHU’), following a number of intra-Group 
reorganisations. During 2009, pursuant to section 131 of the Companies Act 1985, statutory share premium relief was taken in respect of the 
rights issue and $15,796m was recognised in the merger reserve.  

6 Permitted transfers from the merger reserve to retained earnings were made when the investment in HSBC Overseas Holdings (UK) Limited was 

previously impaired. In 2018, a part reversal of this impairment resulted in a transfer from retained earnings back to the merger reserve of 
$2,200m. In 2019, an additional impairment of $2,475m was recognised and a permitted transfer of this amount was made from the merger 
reserve to retained earnings. During 2020, a further impairment of $435m was recognised and a permitted transfer of this amount was made 
from the merger reserve to retained earnings.

7 For further details, see Note 31 in the Annual Report and Accounts 2020. In August 2019, HSBC announced a share buy-back of up to $1.0bn, 
which was completed in September 2019. In May 2018, HSBC announced a share buy-back of up to $2.0bn, which was completed in August 
2018. 

HSBC Holdings plc Annual Report and Accounts 2020 283

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

HSBC Holdings income statement 

for the year ended 31 December 

Net interest expense

–  interest income

–  interest expense

Fee (expense)/income

Net income from financial instruments held for trading or managed on a fair value basis
Changes in fair value of designated debt and related derivatives1
Changes in fair value of other financial instruments mandatorily measured at fair value through profit or 
loss

Gains less losses from financial investments
Dividend income from subsidiaries2
Other operating income

Total operating income

Employee compensation and benefits

General and administrative expenses

Impairment of subsidiaries

Total operating expenses

Profit before tax

Tax (charge)/credit

Profit for the year

Notes*

3

3

3

5

2020

$m

(2,632)   

473   

(3,105)   

(12)   

801   
(326)   

1,141   

—   

8,156   

1,889   

9,017   

(56)   

(4,276)   

(435)   

(4,767)   

4,250   

(165)   

4,085   

2019

$m

(2,554)   

1,249   

(3,803)   

(2)   

1,477   
(360)   

1,659   

—   

15,117   

1,293   

16,630   

(37)   

(4,772)   

(2,562)   

(7,371)   

9,259   

(218)   

9,041   

2018

$m

(1,112) 

2,193 

(3,305) 

0 

245 
(77) 

43 

4 

55,304 

960 

55,367 

(37) 

(4,507) 

2,064 

(2,480) 

52,887 

(62) 

52,825 

*  For Notes on the financial statements, see page 288.
1  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch.
2  The 2018 year included $44,893m (2020 and 2019: nil) return on capital from HSBC Finance (Netherlands) resulting from restructuring the 

Group’s Asia operation to meet resolution and recovery requirements.

HSBC Holdings statement of comprehensive income

for the year ended 31 December

Profit for the year

Other comprehensive income/(expense)

Items that will not be reclassified subsequently to profit or loss:

Changes in fair value of financial liabilities designated at fair value upon initial recognition arising from changes in 
own credit risk

–  before income taxes

–  income taxes

Other comprehensive income/(expense) for the year, net of tax

Total comprehensive income for the year

2020

$m

2019

$m 

2018

$m 

4,085   

9,041   

52,825 

176   

176   

—   

176   

(396)   

(573)   

177   

(396)   

865 

1,090 

(225) 

865 

4,261   

8,645   

53,690 

284 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings balance sheet

Assets

Cash and balances with HSBC undertakings

Financial assets with HSBC undertakings designated and otherwise mandatorily measured at fair value

Derivatives

Loans and advances to HSBC undertakings

Financial investments

Prepayments, accrued income and other assets

Current tax assets

Investments in subsidiaries

Intangible assets

Total assets at 31 Dec

Liabilities and equity

Liabilities

Amounts owed to HSBC undertakings

Financial liabilities designated at fair value

Derivatives

Debt securities in issue

Accruals, deferred income and other liabilities

Subordinated liabilities
Current tax liabilities

Deferred tax liabilities

Total liabilities

Equity

Called up share capital

Share premium account

Other equity instruments

Merger and other reserves

Retained earnings

Total equity

Total liabilities and equity at 31 Dec

*  For Notes on the financial statements, see page 288.

31 Dec 2020

31 Dec 2019

Notes*

$m

$m

15

24

15

25

28

31

2,913   

65,253   

4,698   

10,443   

17,485   

1,445   

—   

2,382 

61,964 

2,002 

10,218 

16,106 

559 

203 

160,660   

161,473 

276   

333 

263,173   

255,240 

330   

25,664   

3,060   

64,029   

4,865   

17,916   

71   

438   

464 

30,303 

2,021 

56,844 

1,915 

18,361 

— 

288 

116,373   

110,196 

10,347   

14,277   

22,414   

34,757   

65,005   

146,800   

263,173   

10,319 

13,959 

20,743 

37,539 

62,484 

145,044 

255,240 

The accompanying notes on pages 288 to 370 and the audited sections in: ‘Risk’ on pages 106 to 194 (including ‘Measurement 
uncertainty and sensitivity analysis of ECL estimates’ on pages 127 to 135), and ‘Directors’ remuneration report’ on pages 229 to 255 
form an integral part of these financial statements.

These financial statements were approved by the Board of Directors on 23 February 2021 and signed on its behalf by:

Mark E Tucker
Group Chairman

Ewen Stevenson
Group Chief Financial Officer 

HSBC Holdings plc Annual Report and Accounts 2020 285

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

HSBC Holdings statement of cash flows 

for the year ended 31 December

Profit before tax

Adjustments for non-cash items

–  depreciation, amortisation and impairment/expected credit losses

–  share-based payment expense
–  other non-cash items included in profit before tax1
Changes in operating assets and liabilities

Change in loans to HSBC undertakings

Change in financial assets with HSBC undertakings designated and otherwise mandatorily measured at fair value

Change in net trading securities and net derivatives

Change in other assets

Change in financial investments

Change in debt securities in issue

Change in financial liabilities designated at fair value

Change in other liabilities

Tax received

Net cash from operating activities

Purchase of financial investments

Proceeds from the sale and maturity of financial investments 

Net cash outflow from acquisition of or increase in stake of subsidiaries

Repayment of capital from subsidiaries

Net investment in intangible assets

Net cash from investing activities

Issue of ordinary share capital and other equity instruments

Redemption of other equity instruments

Cancellation of shares

Subordinated loan capital repaid

Debt securities issued

Debt securities repaid

Dividends paid on ordinary shares

Dividends paid to holders of other equity instruments

Net cash from financing activities

Net increase/(decrease) in cash and cash equivalents

Cash and cash equivalents at 1 January

Cash and cash equivalents at 31 Dec

Cash and cash equivalents comprise:

–  cash at bank with HSBC undertakings

–  loans and advances to banks of one month or less

–  treasury and other eligible bills

2020

$m

4,250   

442   

87   

1   

354   

(327)   

(3,289)   

(1,657)   

(633)   

449   

3,063   

1,258   

1,366   

270   

5,192   

(11,652)   

9,342   

(2,558)   

1,516   

(33)   

(3,385)   

1,846   

—   

—   

(1,500)   

15,951   

(16,577)   

—   

(1,331)   

(1,611)   

196   

5,980   

6,176   

2,913   

249   

3,014   

2019

$m

9,259   

2,657   

72   

1   

2018

$m

52,887 

(46,878) 

70 

— 

2,584   

(46,948) 

41,471   

(38,451)   

(1,433)   

(437)   

(70)   

1,899   

1,227   

437   

459   

17,018   

(19,293)   

6,755   

(3,721)   

—   

(44)   

(16,303)   

500   

—   

(1,006)   

(4,107)   

10,817   

—   

(7,582)   

(1,414)   

(2,792)   

(2,077)   

8,057   

5,980   

2,382   

102   

3,496   

7,293 

(7,305) 

758 

231 

— 

(1,094) 

(740) 

(1,883) 

301 

3,570 

— 

— 

(8,992) 

3,627 

(121) 

(5,486) 

6,652 

(6,093) 

(1,998) 

(1,972) 

19,513 

(1,025) 

(8,693) 

(1,360) 

5,024 

3,108 

4,949 

8,057 

3,509 

4,548 

— 

Interest received was $1,952m (2019: $2,216m; 2018: $2,116m), interest paid was $3,166m (2019: $3,819m; 2018: $3,379m) and 
dividends received were $8,156m (2019: $15,117m; 2018: $10,411m).

1  The 2018 year included $44,893m (2020 and 2019: nil) return on capital from HSBC Finance (Netherlands) resulting from restructuring the 

Group’s Asia operation to meet resolution and recovery requirements.

286 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings statement of changes in equity 

for the year ended 31 December

Called up
share
capital

Share
premium

Other
equity
instruments

Retained
earnings1

Financial
assets at
FVOCI reserve

Merger 
and other
reserves

Total
shareholders’
equity

$m

$m

$m

$m

$m

$m

$m

Other reserves

At 1 Jan 2020

Profit for the year

Other comprehensive income (net of tax)

–  changes in fair value of financial liabilities designated at fair value 

due to movement in own credit risk 

Total comprehensive income for the year

Shares issued under employee share plans
Capital securities issued

Dividends to shareholders

Redemption of capital securities 
Transfers4
Other movements5
At 31 Dec 2020

At 1 Jan 2019

Profit for the year

Other comprehensive income (net of tax)
–  changes in fair value of financial liabilities designated at fair value 

due to movement in own credit risk

Total comprehensive income for the year

Shares issued under employee share plans

Shares issued in lieu of dividends and amounts arising thereon
Cancellation of shares2
Capital securities issued

Dividends to shareholders

Redemption of capital securities
Transfers4
Other movements

At 31 Dec 2019

At 31 Dec 2017

Impact on transition to IFRS 9

At 1 Jan 2018

Profit for the year

Other comprehensive income (net of tax)

–  changes in fair value of financial liabilities designated at fair value 

due to movement in own credit risk

Total comprehensive income for the year

Shares issued under employee share plans

Shares issued in lieu of dividends and amounts arising thereon
Cancellation of shares3
Capital securities issued

Dividends to shareholders

Redemption of capital securities 
Transfers4
Other movements

At 31 Dec 2018

  10,319    13,959   

—   

—   

—   

—   

28   

—   

—   
—   
—   

—   

—   

—   

—   

—   
318   
—   

—   
—   
—   

—   

20,743   
—   
—   

62,484   
4,085   
176   

—   

—   

—   
1,500   

—   
—   
—   

176   

4,261   

2,540   
(15)   
(1,331)   
(1,450)   
435   

171   

(1,919)   

  10,347    14,277   

22,414   

65,005   

10,180    13,609   

22,231   

61,434   

—   

—   

—   

—   

36   

171   

(68)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

521   

(171)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(1,488)   

—   

—   

9,041   

(396)   

(396)   

8,645   

(56)   

2,687   

(1,000)   

—   

(11,683)   

(20)   

2,475   

2   

10,319    13,959   

20,743   

62,484   

10,160    10,177   

—   

—   

10,160    10,177   

—   

—   

—   

—   

42   

83   

—   

—   

—   

—   

679   

(83)   

(105)   

2,836   

—   

—   

—   

—   

—   

—   

—   
—   

—   
—   
10,180    13,609   

22,107   
—   
22,107   
—   
—   

—   

—   

—   

—   

—   

23,903   
949   

24,852   
52,825   
865   

865   
53,690   
—   

1,494   

(4,998)   

5,967   

—   

—   

(11,547)   

(5,843)   

—   
—   

(236)   

(2,200)   
379   

22,231   

61,434   

—   
—   
—   

—   
—   
—   

—   

—   

—   
—   
—   
—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

59   
(59)   

—   
—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   
—   
—   

37,539   

145,044 

—   

—   

—   

—   

(2,347)   

—   

—   

—   

(435)   

—   
34,757   

4,085 

176 

176 

4,261 

539 

1,485 

(1,331) 

(1,450) 

— 

(1,748) 
146,800 

39,899   

147,353 

—   

—   

—   

—   

—   

—   

68   

—   

—   

—   

(2,475)   

47   

9,041 

(396) 

(396) 

8,645 

501 

2,687 

(1,000) 

— 

(11,683) 

(1,508) 

— 

49 

37,539   

145,044 

37,381   
—   
37,381   
—   
—   

—   

—   

—   

—   

269   

—   

—   

—   

2,200   

49   
39,899   

103,787 

890 

104,677 

52,825 

865 

865 

53,690 

721 

1,494 

(1,998) 

5,967 

(11,547) 

(6,079) 

— 

428 
147,353 

Dividends per ordinary share at 31 December 2020 were nil (2019: $0.51; 2018: $0.51).

1  At 31 December 2020, retained earnings included 326,766,253 ($2,521m) treasury shares (2019: 326,191,804 ($2,543m); 2018: 326,503,319 

($2,546m)).

2 In August 2019, HSBC announced a share buy-back of up to $1.0bn, which was completed in September 2019.
3  The 2018 year included a re-presentation of the cancellation of shares to retained earnings and capital redemption reserve in respect of the 2018 

share buy-back, under which retained earnings has been reduced by $3,000m, share premium increased by $2,836m and other reserves 
increased by $164m.  

4  At 31 December 2020, an impairment of $435m of HSBC Overseas Holdings (UK) Limited (2019: $2,475m) was recognised and a permitted 

transfer of $435m (2019: $2,475m) was made from the merger reserve to retained earnings. In 2018, a part reversal of the impairment of HSBC 
Overseas Holdings (UK) Limited resulted in a transfer from retained earnings back to the merger reserve of $2,200m.
Includes an adjustment to retained earnings for a repayment of capital by a subsidiary of $1,650m, which had been recognised as dividend 
income in 2019.

5 

HSBC Holdings plc Annual Report and Accounts 2020 287

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Notes on the financial statements

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

Basis of preparation and significant accounting policies

Net fee income

Net income/(expense) from financial instruments measured at fair 
value through profit or loss 

Insurance business

Employee compensation and benefits

Auditors’ remuneration 

Tax

Dividends

Earnings per share

Segmental analysis

Trading assets 

Fair values of financial instruments carried at fair value 

Fair values of financial instruments not carried at fair value 

Financial assets designated and otherwise mandatorily measured 
at fair value through profit or loss

Derivatives

Financial investments

Assets pledged, collateral received and assets transferred

Interests in associates and joint ventures

Investments in subsidiaries

Structured entities

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

Page

288

299

300

300

301

307

307

309

310

311

313

314

321

322

323

328

330

331

335

336

Goodwill and intangible assets

Prepayments, accrued income and other assets

Trading liabilities

Financial liabilities designated at fair value

Debt securities in issue

Accruals, deferred income and other liabilities

Provisions

Subordinated liabilities

Maturity analysis of assets, liabilities and off-balance sheet 
commitments

Offsetting of financial assets and financial liabilities

Called up share capital and other equity instruments

Contingent liabilities, contractual commitments and guarantees

Finance lease receivables

Legal proceedings and regulatory matters

Related party transactions

Events after the balance sheet date

HSBC Holdings’ subsidiaries, joint ventures and associates

Page

338

341

341

341

342

342

343

344

347

352

353

355

356

356

360

362

362

1

Basis of preparation and significant accounting policies

1.1  Basis of preparation

(a)  Compliance with International Financial Reporting Standards

The consolidated financial statements of HSBC and the separate financial statements of HSBC Holdings comply with international 
accounting standards in conformity with the requirements of the Companies Act 2006 and have also applied international financial 
reporting standards adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union. These financial statements 
are also prepared in accordance with International Financial Reporting Standards (‘IFRSs’) as issued by the International Accounting 
Standards Board (‘IASB’), including interpretations issued by the IFRS Interpretations Committee, as there are no applicable differences 
from IFRSs as issued by the IASB for the periods presented. ‘Interest Rate Benchmark Reform – Phase 2’, which amends IFRS 9, IAS 39 
‘Financial Instruments,’ IFRS 7 ‘Financial Instruments,’ IFRS 4 ‘Insurance Contracts’ and IFRS 16 ‘Leases’, was adopted for use in the UK 
and the EU in January 2021 and has been early adopted as set out below. Therefore, there were no unendorsed standards effective for 
the year ended 31 December 2020 affecting these consolidated and separate financial statements.

Standards adopted during the year ended 31 December 2020

 Interest Rate Benchmark Reform – Phase 2 

Interest Rate Benchmark Reform Phase 2: Amendments to IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 issued in August 2020 represents 
the second phase of the IASB’s project on the effects of interest rate benchmark reform, addressing issues affecting financial statements 
when changes are made to contractual cash flows and hedging relationships as a result of the reform.

Under these amendments, changes made to a financial instrument measured at other than fair value through profit or loss that are 
economically equivalent and required by interest rate benchmark reform do not result in the derecognition or a change in the carrying 
amount of the financial instrument, but instead require the effective interest rate to be updated to reflect the change in the interest rate 
benchmark. In addition, hedge accounting will not be discontinued solely because of the replacement of the interest rate benchmark if 
the hedge meets other hedge accounting criteria.

These amendments apply from 1 January 2021 with early adoption permitted. HSBC adopted the amendments from 1 January 2020 and  
made the additional disclosures as required by the amendments. Further information is included in Note 15 and in ‘Financial instruments 
impacted by Ibor reform’ on page 113.

Other changes

In addition, HSBC adopted a number of interpretations and amendments to standards, which had an insignificant effect on the 
consolidated financial statements of HSBC and the separate financial statements of HSBC Holdings. 

In 2018, HSBC adopted IFRS 9 and made voluntary presentation changes, including to certain financial liabilities, which contain both 
deposit and derivative components, and to cash collateral, margin and settlement accounts. The impact of this is included in the HSBC 
Holdings statement of changes in equity for that year end.

Other than as noted above, accounting policies have been consistently applied.

(b) Differences between IFRSs and Hong Kong Financial Reporting Standards

There are no significant differences between IFRSs and Hong Kong Financial Reporting Standards in terms of their application to HSBC, 
and consequently there would be no significant differences had the financial statements been prepared in accordance with Hong Kong 
Financial Reporting Standards. The ‘Notes on the financial statements’, taken together with the ‘Report of the Directors’, include the 
aggregate of all disclosures necessary to satisfy IFRSs and Hong Kong reporting requirements. 

288 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
(c)

Future accounting developments

Minor amendments to IFRSs

The IASB has not published any minor amendments effective from 1 January 2021 that are applicable to HSBC. However, the IASB has 
published a number of minor amendments to IFRSs that are effective from 1 January 2022 and 1 January 2023. HSBC expects they will 
have an insignificant effect, when adopted, on the consolidated financial statements of HSBC and the separate financial statements of 
HSBC Holdings. 

New IFRSs

IFRS 17 ‘Insurance Contracts’

IFRS 17 ‘Insurance Contracts’ was issued in May 2017, with amendments to the standard issued in June 2020. The standard sets out the 
requirements that an entity should apply in accounting for insurance contracts it issues and reinsurance contracts it holds. Following the 
amendments, IFRS 17 is effective from 1 January 2023. The Group is in the process of implementing IFRS 17. Industry practice and 
interpretation of the standard are still developing. Therefore, the likely numerical impact of its implementation remains uncertain. 
However, we have the following expectations as to the impact compared with the Group’s current accounting policy for insurance 
contracts, which is set out in policy 1.2(j) below:

• Under IFRS 17, there will be no PVIF asset recognised; rather the estimated future profit will be included in the measurement of the 
insurance contract liability as the contractual service margin (‘CSM’) and gradually recognised in revenue as services are provided 
over the duration of the insurance contract. The PVIF asset will be eliminated to equity on transition, together with other adjustments 
to assets and liabilities to reflect IFRS 17 measurement requirements and any consequential amendments to financial assets in the 
scope of IFRS 9;

• IFRS 17 requires increased use of current market values in the measurement of insurance liabilities. Depending on the measurement 
model, changes in market conditions for certain products (measured under the General Measurement Approach) are immediately 
recognised in profit or loss, while for other products (measured under the Variable Fee Approach) they will be included in the 
measurement of CSM.

• In accordance with IFRS 17, directly attributable costs will be included in the results of insurance services as profit is recognised over 
the duration of insurance contracts. Costs that are not directly attributable will remain in operating expenses. This will result in a 
reduction in operating expenses compared with the current accounting policy.

(d)  Foreign currencies

HSBC’s consolidated financial statements are presented in US dollars because the US dollar and currencies linked to it form the major 
currency bloc in which HSBC transacts and funds its business. The US dollar is also HSBC Holdings’ functional currency because the US 
dollar and currencies linked to it are the most significant currencies relevant to the underlying transactions, events and conditions of its 
subsidiaries, as well as representing a significant proportion of its funds generated from financing activities.

Transactions in foreign currencies are recorded at the rate of exchange on the date of the transaction. Assets and liabilities denominated 
in foreign currencies are translated at the rate of exchange at the balance sheet date, except non-monetary assets and liabilities 
measured at historical cost, which are translated using the rate of exchange at the initial transaction date. Exchange differences are 
included in other comprehensive income or in the income statement depending on where the gain or loss on the underlying item is 
recognised. In the consolidated financial statements, the assets and liabilities of branches, subsidiaries, joint ventures and associates 
whose functional currency is not US dollars are translated into the Group’s presentation currency at the rate of exchange at the balance 
sheet date, while their results are translated into US dollars at the average rates of exchange for the reporting period. Exchange 
differences arising are recognised in other comprehensive income. On disposal of a foreign operation, exchange differences previously 
recognised in other comprehensive income are reclassified to the income statement.

(e)  Presentation of information

Certain disclosures required by IFRSs have been included in the sections marked as (‘Audited’) in this Annual Report and Accounts 2020 
as follows:

• disclosures concerning the nature and extent of risks relating to insurance contracts and financial instruments are included in the 

‘Risk review’ on pages 106 to 194;

• the ‘Own funds disclosure’ included in the ‘Risk review’ on page 174; and

• disclosures relating to HSBC’s securitisation activities and structured products are included in the ‘Risk review’ on pages 106 to 194.

HSBC follows the UK Finance Disclosure Code (‘the UKF Disclosure Code’). The UKF Disclosure Code aims to increase the quality and 
comparability of UK banks’ disclosures and sets out five disclosure principles together with supporting guidance agreed in 2010. In line 
with the principles of the UKF Disclosure Code, HSBC assesses good practice recommendations issued from time to time by relevant 
regulators and standard setters, and will assess the applicability and relevance of such guidance, enhancing disclosures where 
appropriate.

(f)  Critical accounting estimates and judgements

The preparation of financial information requires the use of estimates and judgements about future conditions. In view of the inherent 
uncertainties and the high level of subjectivity involved in the recognition or measurement of items, highlighted as the ‘critical 
accounting estimates and judgements’ in section 1.2 below (including impairment of non-financial assets for the first time), it is possible 
that the outcomes in the next financial year could differ from those on which management’s estimates are based. This could result in 
materially different estimates and judgements from those reached by management for the purposes of these financial statements. 
Management’s selection of HSBC’s accounting policies that contain critical estimates and judgements reflects the materiality of the 
items to which the policies are applied and the high degree of judgement and estimation uncertainty involved.

(g)  Segmental analysis

HSBC’s Chief Operating Decision Maker is the Group Chief Executive, who is supported by the rest of the Group Executive Committee 
(‘GEC’), which operates as a general management committee under the direct authority of the Board. Operating segments are reported 
in a manner consistent with the internal reporting provided to the Group Chief Executive and the GEC.

HSBC Holdings plc Annual Report and Accounts 2020 289

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Measurement of segmental assets, liabilities, income and expenses is in accordance with the Group’s accounting policies. Segmental 
income and expenses include transfers between segments, and these transfers are conducted at arm’s length. Shared costs are included 
in segments on the basis of the actual recharges made.

(h) Going concern

The financial statements are prepared on a going concern basis, as the Directors are satisfied that the Group and parent company have 
the resources to continue in business for the foreseeable future. In making this assessment, the Directors have considered a wide range 
of information relating to present and future conditions, including future projections of profitability, cash flows, capital requirements and 
capital resources. These considerations include stressed scenarios that reflect the increasing uncertainty that the global Covid-19 
outbreak has had on HSBC’s operations, as well as considering potential impacts from other top and emerging risks, and the related 
impact on profitability, capital and liquidity. 

1.2  Summary of significant accounting policies

(a)  Consolidation and related policies

Investments in subsidiaries

Where an entity is governed by voting rights, HSBC consolidates when it holds – directly or indirectly – the necessary voting rights to 
pass resolutions by the governing body. In all other cases, the assessment of control is more complex and requires judgement of other 
factors, including having exposure to variability of returns, power to direct relevant activities, and whether power is held as agent or 
principal.

Business combinations are accounted for using the acquisition method. The amount of non-controlling interest is measured either at fair 
value or at the non-controlling interest’s proportionate share of the acquiree’s identifiable net assets. This election is made for each 
business combination. 

HSBC Holdings’ investments in subsidiaries are stated at cost less impairment losses.

Goodwill

Goodwill is allocated to cash-generating units (‘CGUs’) for the purpose of impairment testing, which is undertaken at the lowest level at 
which goodwill is monitored for internal management purposes. HSBC’s CGUs are based on geographical regions subdivided by global 
business, except for Global Banking and Markets, for which goodwill is monitored on a global basis.

Impairment testing is performed at least once a year, or whenever there is an indication of impairment, by comparing the recoverable 
amount of a CGU with its carrying amount.

Goodwill is included in a disposal group if the disposal group is a CGU to which goodwill has been allocated or it is an operation within 
such a CGU. The amount of goodwill included in a disposal group is measured on the basis of the relative values of the operation 
disposed of and the portion of the CGU retained.

Critical accounting estimates and judgements

The review of goodwill and non-financial assets (see Note 1.2(n)) for impairment reflects management’s best estimate of the future cash flows of the CGUs 
and the rates used to discount these cash flows, both of which are subject to uncertain factors as follows:

Judgements

Estimates

• The accuracy of forecast cash flows is subject to a 

high degree of uncertainty in volatile market 
conditions. Where such circumstances are 
determined to exist, management re-tests goodwill 
for impairment more frequently than once a year 
when indicators of impairment exist. This ensures 
that the assumptions on which the cash flow 
forecasts are based continue to reflect current 
market conditions and management’s best 
estimate of future business prospects

• The future cash flows of the CGUs are sensitive to the cash flows projected for the periods for 
which detailed forecasts are available and to assumptions regarding the long-term pattern of 
sustainable cash flows thereafter. Forecasts are compared with actual performance and verifiable 
economic data, but they reflect management’s view of future business prospects at the time of 
the assessment

• The rates used to discount future expected cash flows can have a significant effect on their 

valuation, and are based on the costs of capital assigned to individual CGUs. The cost of capital 
percentage is generally derived from a capital asset pricing model, which incorporates inputs 
reflecting a number of financial and economic variables, including the risk-free interest rate in the 
country concerned and a premium for the risk of the business being evaluated. These variables 
are subject to fluctuations in external market rates and economic conditions beyond 
management’s control

• Key assumptions used in estimating goodwill and non-financial asset impairment are described in 

Note 21

HSBC sponsored structured entities

HSBC is considered to sponsor another entity if, in addition to ongoing involvement with the entity, it had a key role in establishing that 
entity or in bringing together relevant counterparties so the transaction that is the purpose of the entity could occur. HSBC is generally 
not considered a sponsor if the only involvement with the entity is merely administrative.

Interests in associates and joint arrangements

Joint arrangements are investments in which HSBC, together with one or more parties, has joint control. Depending on HSBC’s rights 
and obligations, the joint arrangement is classified as either a joint operation or a joint venture. HSBC classifies investments in entities 
over which it has significant influence, and that are neither subsidiaries nor joint arrangements, as associates.

HSBC recognises its share of the assets, liabilities and results in a joint operation. Investments in associates and interests in joint 
ventures are recognised using the equity method. The attributable share of the results and reserves of joint ventures and associates is 
included in the consolidated financial statements of HSBC based on either financial statements made up to 31 December or pro-rated 
amounts adjusted for any material transactions or events occurring between the date the financial statements are available and 31 
December.

Investments in associates and joint ventures are assessed at each reporting date and tested for impairment when there is an indication 
that the investment may be impaired. Goodwill on acquisitions of interests in joint ventures and associates is not tested separately for 
impairment, but is assessed as part of the carrying amount of the investment.

290 HSBC Holdings plc Annual Report and Accounts 2020

 
Critical accounting estimates and judgements

The most significant critical accounting estimates relate to the assessment of impairment of our investment in Bank of Communications Co. Limited 
(‘BoCom’), which involves estimations of value in use:

Judgements

Estimates

• Management’s best estimate of BoCom’s earnings are based on management’s 
explicit forecasts over the short to medium term and the capital maintenance 
charge, which is management’s forecast of the earnings that need to be withheld in 
order for BoCom to meet regulatory requirements over the forecast period, both of 
which are subject to uncertain factors

• Key assumptions used in estimating BoCom’s value in use, the sensitivity of the 
value in use calculations to different assumptions and a sensitivity analysis that 
shows the changes in key assumptions that would reduce the excess of value in use 
over the carrying amount (the ‘headroom’) to nil are described in Note 18

(b) 

Income and expense

Operating income

Interest income and expense

Interest income and expense for all financial instruments, excluding those classified as held for trading or designated at fair value, are 
recognised in ‘Interest income’ and ‘Interest expense’ in the income statement using the effective interest method. However, as an 
exception to this, interest on debt instruments issued by HSBC for funding purposes that are designated under the fair value option to 
reduce an accounting mismatch and on derivatives managed in conjunction with those debt instruments is included in interest expense.

Interest on credit-impaired financial assets is recognised using the rate of interest used to discount the future cash flows for the purpose 
of measuring the impairment loss.

Non-interest income and expense

HSBC generates fee income from services provided at a fixed price over time, such as account service and card fees, or when HSBC 
delivers a specific transaction at a point in time, such as broking services and import/export services. With the exception of certain fund 
management and performance fees, all other fees are generated at a fixed price. Fund management and performance fees can be 
variable depending on the size of the customer portfolio and HSBC’s performance as fund manager. Variable fees are recognised when 
all uncertainties are resolved. Fee income is generally earned from short-term contracts with payment terms that do not include a 
significant financing component.

HSBC acts as principal in the majority of contracts with customers, with the exception of broking services. For most brokerage trades, 
HSBC acts as agent in the transaction and recognises broking income net of fees payable to other parties in the arrangement.

HSBC recognises fees earned on transaction-based arrangements at a point in time when it has fully provided the service to the 
customer. Where the contract requires services to be provided over time, income is recognised on a systematic basis over the life of the 
agreement.

Where HSBC offers a package of services that contains multiple non-distinct performance obligations, such as those included in account 
service packages, the promised services are treated as a single performance obligation. If a package of services contains distinct 
performance obligations, such as those including both account and insurance services, the corresponding transaction price is allocated 
to each performance obligation based on the estimated stand-alone selling prices.

Dividend income is recognised when the right to receive payment is established. This is the ex-dividend date for listed equity securities, 
and usually the date when shareholders approve the dividend for unlisted equity securities.

Net income/(expense) from financial instruments measured at fair value through profit or loss includes the following: 

• ‘Net income from financial instruments held for trading or managed on a fair value basis’: This comprises net trading income, which 

includes all gains and losses from changes in the fair value of financial assets and financial liabilities held for trading and other 
financial instruments managed on a fair value basis, together with the related interest income, expense and dividends, excluding the 
effect of changes in the credit risk of liabilities managed on a fair value basis. It also includes all gains and losses from changes in the 
fair value of derivatives that are managed in conjunction with financial assets and liabilities measured at fair value through profit or 
loss.

• ‘Net income/(expense) from assets and liabilities of insurance businesses, including related derivatives, measured at fair value 

through profit or loss’: This includes interest income, interest expense and dividend income in respect of financial assets and liabilities 
measured at fair value through profit or loss; and those derivatives managed in conjunction with the above that can be separately 
identifiable from other trading derivatives.

• ‘Changes in fair value of designated debt instruments and related derivatives’: Interest paid on debt instruments and interest cash 

flows on related derivatives is presented in interest expense where doing so reduces an accounting mismatch.

• ‘Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss’: This includes interest 

on instruments that fail the solely payments of principal and interest test, see (d) below.

The accounting policies for insurance premium income are disclosed in Note 1.2(j).

(c)  Valuation of financial instruments 

All financial instruments are initially recognised at fair value. Fair value is the price that would be received to sell an asset or paid 
to transfer a liability in an orderly transaction between market participants at the measurement date. The fair value of a financial 
instrument on initial recognition is generally its transaction price (that is, the fair value of the consideration given or received). However, 
if there is a difference between the transaction price and the fair value of financial instruments whose fair value is based on a quoted 
price in an active market or a valuation technique that uses only data from observable markets, HSBC recognises the difference as a 
trading gain or loss at inception (a ‘day 1 gain or loss’). In all other cases, the entire day 1 gain or loss is deferred and recognised in the 
income statement over the life of the transaction until the transaction matures, is closed out, the valuation inputs become observable or 
HSBC enters into an offsetting transaction. The fair value of financial instruments is generally measured on an individual basis. However, 

HSBC Holdings plc Annual Report and Accounts 2020 291

Financial statements 
Notes on the financial statements

in cases where HSBC manages a group of financial assets and liabilities according to its net market or credit risk exposure, the fair value 
of the group of financial instruments is measured on a net basis but the underlying financial assets and liabilities are presented 
separately in the financial statements, unless they satisfy the IFRS offsetting criteria.

Critical accounting estimates and judgements

The majority of valuation techniques employ only observable market data. However, certain financial instruments are classified on the basis of valuation 
techniques that feature one or more significant market inputs that are unobservable, and for them, the measurement of fair value is more judgemental:

Judgements

Estimates

• An instrument in its entirety is classified as valued using significant unobservable 

• Details on the Group’s level 3 financial instruments and the 

inputs if, in the opinion of management, a significant proportion of the instrument’s 
inception profit or greater than 5% of the instrument’s valuation is driven by 
unobservable inputs

sensitivity of their valuation to the effect of applying reasonable 
possible alternative assumptions in determining their fair value 
are set out in Note 12

• ‘Unobservable’ in this context means that there is little or no current market data 
available from which to determine the price at which an arm’s length transaction 
would be likely to occur. It generally does not mean that there is no data available 
at all upon which to base a determination of fair value (consensus pricing data 
may, for example, be used)

(d)  Financial instruments measured at amortised cost

Financial assets that are held to collect the contractual cash flows and which contain contractual terms that give rise on specified dates 
to cash flows that are solely payments of principal and interest are measured at amortised cost. Such financial assets include most loans 
and advances to banks and customers and some debt securities. In addition, most financial liabilities are measured at amortised cost. 
HSBC accounts for regular way amortised cost financial instruments using trade date accounting. The carrying value of these financial 
assets at initial recognition includes any directly attributable transactions costs. If the initial fair value is lower than the cash amount 
advanced, such as in the case of some leveraged finance and syndicated lending activities, the difference is deferred and recognised 
over the life of the loan through the recognition of interest income.

HSBC may commit to underwriting loans on fixed contractual terms for specified periods of time. When the loan arising from the lending 
commitment is expected to be held for trading, the commitment to lend is recorded as a derivative. When HSBC intends to hold the 
loan, the loan commitment is included in the impairment calculations set out below.

Non-trading reverse repurchase, repurchase and similar agreements

When debt securities are sold subject to a commitment to repurchase them at a predetermined price (‘repos’), they remain on the 
balance sheet and a liability is recorded in respect of the consideration received. Securities purchased under commitments to resell 
(‘reverse repos’) are not recognised on the balance sheet and an asset is recorded in respect of the initial consideration paid. Non-trading 
repos and reverse repos are measured at amortised cost. The difference between the sale and repurchase price or between the purchase 
and resale price is treated as interest and recognised in net interest income over the life of the agreement.

Contracts that are economically equivalent to reverse repo or repo agreements (such as sales or purchases of debt securities entered 
into together with total return swaps with the same counterparty) are accounted for similarly to, and presented together with, reverse 
repo or repo agreements.

(e)  Financial assets measured at fair value through other comprehensive income 

Financial assets held for a business model that is achieved by both collecting contractual cash flows and selling and which contain 
contractual terms that give rise on specified dates to cash flows that are solely payments of principal and interest are measured at fair 
value through other comprehensive income (‘FVOCI’). These comprise primarily debt securities. They are recognised on the trade date 
when HSBC enters into contractual arrangements to purchase and are normally derecognised when they are either sold or redeemed. 
They are subsequently remeasured at fair value and changes therein (except for those relating to impairment, interest income and 
foreign currency exchange gains and losses) are recognised in other comprehensive income until the assets are sold. Upon disposal, the 
cumulative gains or losses in other comprehensive income are recognised in the income statement as ‘Gains less losses from financial 
instruments’. Financial assets measured at FVOCI are included in the impairment calculations set out below and impairment is 
recognised in profit or loss.

(f)  Equity securities measured at fair value with fair value movements presented in other comprehensive income

The equity securities for which fair value movements are shown in other comprehensive income are business facilitation and other 
similar investments where HSBC holds the investments other than to generate a capital return. Gains or losses on the derecognition of 
these equity securities are not transferred to profit or loss. Otherwise, equity securities are measured at fair value through profit or loss 
(except for dividend income, which is recognised in profit or loss).

(g)  Financial instruments designated at fair value through profit or loss

Financial instruments, other than those held for trading, are classified in this category if they meet one or more of the criteria set out 
below and are so designated irrevocably at inception:

• the use of the designation removes or significantly reduces an accounting mismatch;

• a group of financial assets and liabilities or a group of financial liabilities is managed and its performance is evaluated on a fair value 

basis, in accordance with a documented risk management or investment strategy; and

• the financial liability contains one or more non-closely related embedded derivatives.

Designated financial assets are recognised when HSBC enters into contracts with counterparties, which is generally on trade date, and 
are normally derecognised when the rights to the cash flows expire or are transferred. Designated financial liabilities are recognised 
when HSBC enters into contracts with counterparties, which is generally on settlement date, and are normally derecognised when 
extinguished. Subsequent changes in fair values are recognised in the income statement in ‘Net income from financial instruments held 
for trading or managed on a fair value basis’ or ‘Net income/(expense) from assets and liabilities of insurance businesses, including 
related derivatives, measured at fair value through profit or loss’ except for the effect of changes in the liabilities’ credit risk, which is 
presented in ‘Other comprehensive income’, unless that treatment would create or enlarge an accounting mismatch in profit or loss.

292 HSBC Holdings plc Annual Report and Accounts 2020

 
Under the above criterion, the main classes of financial instruments designated by HSBC are:

• Debt instruments for funding purposes that are designated to reduce an accounting mismatch: The interest and/or foreign exchange 

exposure on certain fixed-rate debt securities issued has been matched with the interest and/or foreign exchange exposure on certain 
swaps as part of a documented risk management strategy.

• Financial assets and financial liabilities under unit-linked and non-linked investment contracts: A contract under which HSBC does not 
accept significant insurance risk from another party is not classified as an insurance contract, other than investment contracts with 
discretionary participation features (‘DPF’), but is accounted for as a financial liability. Customer liabilities under linked and certain 
non-linked investment contracts issued by insurance subsidiaries are determined based on the fair value of the assets held in the 
linked funds. If no fair value designation was made for the related assets, at least some of the assets would otherwise be measured at 
either fair value through other comprehensive income or amortised cost. The related financial assets and liabilities are managed and 
reported to management on a fair value basis. Designation at fair value of the financial assets and related liabilities allows changes in 
fair values to be recorded in the income statement and presented in the same line.

• Financial liabilities that contain both deposit and derivative components: These financial liabilities are managed and their performance 

evaluated on a fair value basis.

(h)  Derivatives

Derivatives are financial instruments that derive their value from the price of underlying items such as equities, interest rates or other 
indices. Derivatives are recognised initially and are subsequently measured at fair value through profit or loss. Derivatives are classified 
as assets when their fair value is positive or as liabilities when their fair value is negative. This includes embedded derivatives in financial 
liabilities, which are bifurcated from the host contract when they meet the definition of a derivative on a stand-alone basis.

Where the derivatives are managed with debt securities issued by HSBC that are designated at fair value, the contractual interest is 
shown in ‘Interest expense’ together with the interest payable on the issued debt.

Hedge accounting

When derivatives are not part of fair value designated relationships, if held for risk management purposes they are designated in hedge 
accounting relationships where the required criteria for documentation and hedge effectiveness are met. HSBC uses these derivatives or, 
where allowed, other non-derivative hedging instruments in fair value hedges, cash flow hedges or hedges of net investments in foreign 
operations as appropriate to the risk being hedged.

Fair value hedge

Fair value hedge accounting does not change the recording of gains and losses on derivatives and other hedging instruments, but 
results in recognising changes in the fair value of the hedged assets or liabilities attributable to the hedged risk that would not otherwise 
be recognised in the income statement. If a hedge relationship no longer meets the criteria for hedge accounting, hedge accounting is 
discontinued and the cumulative adjustment to the carrying amount of the hedged item is amortised to the income statement on a 
recalculated effective interest rate, unless the hedged item has been derecognised, in which case it is recognised in the income 
statement immediately.

Cash flow hedge

The effective portion of gains and losses on hedging instruments is recognised in other comprehensive income and the ineffective 
portion of the change in fair value of derivative hedging instruments that are part of a cash flow hedge relationship is recognised 
immediately in the income statement within ‘Net income from financial instruments held for trading or managed on a fair value basis’. 
The accumulated gains and losses recognised in other comprehensive income are reclassified to the income statement in the same 
periods in which the hedged item affects profit or loss. When a hedge relationship is discontinued, or partially discontinued, any 
cumulative gain or loss recognised in other comprehensive income remains in equity until the forecast transaction is recognised in the 
income statement. When a forecast transaction is no longer expected to occur, the cumulative gain or loss previously recognised in 
other comprehensive income is immediately reclassified to the income statement.

Net investment hedge

Hedges of net investments in foreign operations are accounted for in a similar way to cash flow hedges. The effective portion of gains 
and losses on the hedging instrument is recognised in other comprehensive income and other gains and losses are recognised 
immediately in the income statement. Gains and losses previously recognised in other comprehensive income are reclassified to the 
income statement on the disposal, or part disposal, of the foreign operation.

Derivatives that do not qualify for hedge accounting

Non-qualifying hedges are derivatives entered into as economic hedges of assets and liabilities for which hedge accounting was not 
applied.

(i) 

Impairment of amortised cost and FVOCI financial assets

Expected credit losses (‘ECL’) are recognised for loans and advances to banks and customers, non-trading reverse repurchase 
agreements, other financial assets held at amortised cost, debt instruments measured at FVOCI, and certain loan commitments and 
financial guarantee contracts. At initial recognition, allowance (or provision in the case of some loan commitments and financial 
guarantees) is required for ECL resulting from default events that are possible within the next 12 months, or less, where the remaining 
life is less than 12 months (’12-month ECL’). In the event of a significant increase in credit risk, allowance (or provision) is required for 
ECL resulting from all possible default events over the expected life of the financial instrument (‘lifetime ECL’). Financial assets where 
12-month ECL is recognised are considered to be ‘stage 1’; financial assets that are considered to have experienced a significant 
increase in credit risk are in ‘stage 2’; and financial assets for which there is objective evidence of impairment so are considered to be in 
default or otherwise credit impaired are in ‘stage 3’. Purchased or originated credit-impaired financial assets (‘POCI’) are treated 
differently, as set out below.

Credit impaired (stage 3)

HSBC determines that a financial instrument is credit impaired and in stage 3 by considering relevant objective evidence, primarily 
whether: 

• contractual payments of either principal or interest are past due for more than 90 days; 

HSBC Holdings plc Annual Report and Accounts 2020 293

Financial statementsNotes on the financial statements

• there are other indications that the borrower is unlikely to pay, such as when a concession has been granted to the borrower for 

economic or legal reasons relating to the borrower’s financial condition; and

• the loan is otherwise considered to be in default.

If such unlikeliness to pay is not identified at an earlier stage, it is deemed to occur when an exposure is 90 days past due, even where 
regulatory rules permit default to be defined based on 180 days past due. Therefore, the definitions of credit impaired and default are 
aligned as far as possible so that stage 3 represents all loans that are considered defaulted or otherwise credit impaired.

Interest income is recognised by applying the effective interest rate to the amortised cost amount, i.e. gross carrying amount less ECL 
allowance.

Write-off

Financial assets (and the related impairment allowances) are normally written off, either partially or in full, when there is no realistic 
prospect of recovery. Where loans are secured, this is generally after receipt of any proceeds from the realisation of security. In 
circumstances where the net realisable value of any collateral has been determined and there is no reasonable expectation of further 
recovery, write-off may be earlier.

Renegotiation

Loans are identified as renegotiated and classified as credit impaired when we modify the contractual payment terms due to significant 
credit distress of the borrower. Renegotiated loans remain classified as credit impaired until there is sufficient evidence to demonstrate a 
significant reduction in the risk of non-payment of future cash flows and retain the designation of renegotiated until maturity or 
derecognition.

A loan that is renegotiated is derecognised if the existing agreement is cancelled and a new agreement is made on substantially different 
terms, or if the terms of an existing agreement are modified such that the renegotiated loan is a substantially different financial 
instrument. Any new loans that arise following derecognition events in these circumstances are considered to be POCI and will continue 
to be disclosed as renegotiated loans.

Other than originated credit-impaired loans, all other modified loans could be transferred out of stage 3 if they no longer exhibit any 
evidence of being credit impaired and, in the case of renegotiated loans, there is sufficient evidence to demonstrate a significant 
reduction in the risk of non-payment of future cash flows over the minimum observation period, and there are no other indicators of 
impairment. These loans could be transferred to stage 1 or 2 based on the mechanism as described below by comparing the risk of a 
default occurring at the reporting date (based on the modified contractual terms) and the risk of a default occurring at initial recognition 
(based on the original, unmodified contractual terms). Any amount written off as a result of the modification of contractual terms would 
not be reversed.

Loan modifications other than renegotiated loans

Loan modifications that are not identified as renegotiated are considered to be commercial restructuring. Where a commercial 
restructuring results in a modification (whether legalised through an amendment to the existing terms or the issuance of a new loan 
contract) such that HSBC’s rights to the cash flows under the original contract have expired, the old loan is derecognised and the new 
loan is recognised at fair value. The rights to cash flows are generally considered to have expired if the commercial restructure is at 
market rates and no payment-related concession has been provided. Mandatory and general offer loan modifications that are not 
borrower-specific, for example market-wide customer relief programmes, have not been classified as renegotiated loans and generally 
have not resulted in derecognition, but their stage allocation is determined considering all available and supportable information under 
our ECL impairment policy. 

Significant increase in credit risk (stage 2)

An assessment of whether credit risk has increased significantly since initial recognition is performed at each reporting period by 
considering the change in the risk of default occurring over the remaining life of the financial instrument. The assessment explicitly or 
implicitly compares the risk of default occurring at the reporting date compared with that at initial recognition, taking into account 
reasonable and supportable information, including information about past events, current conditions and future economic conditions. 
The assessment is unbiased, probability-weighted, and to the extent relevant, uses forward-looking information consistent with that 
used in the measurement of ECL. The analysis of credit risk is multifactor. The determination of whether a specific factor is relevant and 
its weight compared with other factors depends on the type of product, the characteristics of the financial instrument and the borrower, 
and the geographical region. Therefore, it is not possible to provide a single set of criteria that will determine what is considered to be a 
significant increase in credit risk, and these criteria will differ for different types of lending, particularly between retail and wholesale. 
However, unless identified at an earlier stage, all financial assets are deemed to have suffered a significant increase in credit risk when 
30 days past due. In addition, wholesale loans that are individually assessed, which are typically corporate and commercial customers, 
and included on a watch or worry list, are included in stage 2.

For wholesale portfolios, the quantitative comparison assesses default risk using a lifetime probability of default (‘PD’), which 
encompasses a wide range of information including the obligor’s customer risk rating (‘CRR’), macroeconomic condition forecasts and 
credit transition probabilities. For origination CRRs up to 3.3, significant increase in credit risk is measured by comparing the average PD 
for the remaining term estimated at origination with the equivalent estimation at the reporting date. The quantitative measure of 
significance varies depending on the credit quality at origination as follows:

Origination CRR

0.1–1.2
2.1–3.3

Significance trigger – PD to increase by

15bps
30bps

For CRRs greater than 3.3 that are not impaired, a significant increase in credit risk is considered to have occurred when the origination 
PD has doubled. The significance of changes in PD was informed by expert credit risk judgement, referenced to historical credit 
migrations and to relative changes in external market rates.

For loans originated prior to the implementation of IFRS 9, the origination PD does not include adjustments to reflect expectations of 
future macroeconomic conditions since these are not available without the use of hindsight. In the absence of this data, origination PD 
must be approximated assuming through-the-cycle (‘TTC’) PDs and TTC migration probabilities, consistent with the instrument’s 

294 HSBC Holdings plc Annual Report and Accounts 2020

 
underlying modelling approach and the CRR at origination. For these loans, the quantitative comparison is supplemented with additional 
CRR deterioration-based thresholds, as set out in the table below:

Origination CRR

0.1
1.1–4.2
4.3–5.1
5.2–7.1
7.2–8.2
8.3

Additional significance criteria – number of CRR grade notches deterioration 
required to identify as significant credit deterioration (stage 2) (> or equal to) 

5 notches
4 notches
3 notches
2 notches
1 notch
0 notch

Further information about the 23-grade scale used for CRR can be found on page 121. 

For certain portfolios of debt securities where external market ratings are available and credit ratings are not used in credit risk 
management, the debt securities will be in stage 2 if their credit risk increases to the extent they are no longer considered investment 
grade. Investment grade is where the financial instrument has a low risk of incurring losses, the structure has a strong capacity to meet 
its contractual cash flow obligations in the near term, and adverse changes in economic and business conditions in the longer term may, 
but will not necessarily, reduce the ability of the borrower to fulfil their contractual cash flow obligations.

For retail portfolios, default risk is assessed using a reporting date 12-month PD derived from credit scores, which incorporates all 
available information about the customer. This PD is adjusted for the effect of macroeconomic forecasts for periods longer than 
12 months and is considered to be a reasonable approximation of a lifetime PD measure. Retail exposures are first segmented into 
homogeneous portfolios, generally by country, product and brand. Within each portfolio, the stage 2 accounts are defined as accounts 
with an adjusted 12-month PD greater than the average 12-month PD of loans in that portfolio 12 months before they become 30 days 
past due. The expert credit risk judgement is that no prior increase in credit risk is significant. This portfolio-specific threshold identifies 
loans with a PD higher than would be expected from loans that are performing as originally expected, and higher than what would have 
been acceptable at origination. It therefore approximates a comparison of origination to reporting date PDs.

Unimpaired and without significant increase in credit risk (stage 1)

ECL resulting from default events that are possible within the next 12 months (‘12-month ECL’) are recognised for financial instruments 
that remain in stage 1.

Purchased or originated credit impaired 

Financial assets that are purchased or originated at a deep discount that reflects the incurred credit losses are considered to be POCI. 
This population includes the recognition of a new financial instrument following a renegotiation where concessions have been granted 
for economic or contractual reasons relating to the borrower’s financial difficulty that otherwise would not have been considered. The 
amount of change-in-lifetime ECL is recognised in profit or loss until the POCI is derecognised, even if the lifetime ECL are less than the 
amount of ECL included in the estimated cash flows on initial recognition.

Movement between stages

Financial assets can be transferred between the different categories (other than POCI) depending on their relative increase in credit risk 
since initial recognition. Financial instruments are transferred out of stage 2 if their credit risk is no longer considered to be significantly 
increased since initial recognition based on the assessments described above. Except for renegotiated loans, financial instruments are 
transferred out of stage 3 when they no longer exhibit any evidence of credit impairment as described above. Renegotiated loans that 
are not POCI will continue to be in stage 3 until there is sufficient evidence to demonstrate a significant reduction in the risk of non-
payment of future cash flows, observed over a minimum one-year period and there are no other indicators of impairment. For loans that 
are assessed for impairment on a portfolio basis, the evidence typically comprises a history of payment performance against the original 
or revised terms, as appropriate to the circumstances. For loans that are assessed for impairment on an individual basis, all available 
evidence is assessed on a case-by-case basis.

Measurement of ECL

The assessment of credit risk and the estimation of ECL are unbiased and probability-weighted, and incorporate all available information 
that is relevant to the assessment including information about past events, current conditions and reasonable and supportable forecasts 
of future events and economic conditions at the reporting date. In addition, the estimation of ECL should take into account the time 
value of money.

In general, HSBC calculates ECL using three main components: a probability of default, a loss given default (’LGD’) and the exposure at 
default (‘EAD’).

The 12-month ECL is calculated by multiplying the 12-month PD, LGD and EAD. Lifetime ECL is calculated using the lifetime PD instead. 
The 12-month and lifetime PDs represent the probability of default occurring over the next 12 months and the remaining maturity of the 
instrument respectively.

The EAD represents the expected balance at default, taking into account the repayment of principal and interest from the balance sheet 
date to the default event together with any expected drawdowns of committed facilities. The LGD represents expected losses on the 
EAD given the event of default, taking into account, among other attributes, the mitigating effect of collateral value at the time it is 
expected to be realised and the time value of money.

HSBC leverages the Basel II IRB framework where possible, with recalibration to meet the differing IFRS 9 requirements as set out in the 
following table:

HSBC Holdings plc Annual Report and Accounts 2020 295

Financial statements 
Notes on the financial statements

Model 

Regulatory capital

IFRS 9

PD

EAD

LGD

Other

• Through the cycle (represents long-run average PD throughout a 

• Point in time (based on current conditions, adjusted to take into 

full economic cycle)

account estimates of future conditions that will impact PD)

• The definition of default includes a backstop of 90+ days past 

• Default backstop of 90+ days past due for all portfolios

due, although this has been modified to 180+ days past due for 
some portfolios, particularly UK and US mortgages

• Cannot be lower than current balance

• Amortisation captured for term products

• Downturn LGD (consistent losses expected to be suffered during 

• Expected LGD (based on estimate of loss given default including 

a severe but plausible economic downturn)

• Regulatory floors may apply to mitigate risk of underestimating 

downturn LGD due to lack of historical data 

• Discounted using cost of capital
• All collection costs included

the expected impact of future economic conditions such as 
changes in value of collateral)

• No floors
• Discounted using the original effective interest rate of the loan
• Only costs associated with obtaining/selling collateral included

• Discounted back from point of default to balance sheet date

While 12-month PDs are recalibrated from Basel II models where possible, the lifetime PDs are determined by projecting the 12-month 
PD using a term structure. For the wholesale methodology, the lifetime PD also takes into account credit migration, i.e. a customer 
migrating through the CRR bands over its life.

The ECL for wholesale stage 3 is determined on an individual basis using a discounted cash flow (‘DCF’) methodology. The expected 
future cash flows are based on the credit risk officer’s estimates as at the reporting date, reflecting reasonable and supportable 
assumptions and projections of future recoveries and expected future receipts of interest. Collateral is taken into account if it is likely 
that the recovery of the outstanding amount will include realisation of collateral based on the estimated fair value of collateral at the time 
of expected realisation, less costs for obtaining and selling the collateral. The cash flows are discounted at a reasonable approximation 
of the original effective interest rate. For significant cases, cash flows under four different scenarios are probability-weighted by 
reference to the economic scenarios applied more generally by the Group and the judgement of the credit risk officer in relation to the 
likelihood of the workout strategy succeeding or receivership being required. For less significant cases, the effect of different economic 
scenarios and work-out strategies is approximated and applied as an adjustment to the most likely outcome.

Period over which ECL is measured

Expected credit loss is measured from the initial recognition of the financial asset. The maximum period considered when measuring 
ECL (be it 12-month or lifetime ECL) is the maximum contractual period over which HSBC is exposed to credit risk. For wholesale 
overdrafts, credit risk management actions are taken no less frequently than on an annual basis and therefore this period is to the 
expected date of the next substantive credit review. The date of the substantive credit review also represents the initial recognition of the 
new facility. However, where the financial instrument includes both a drawn and undrawn commitment and the contractual ability to 
demand repayment and cancel the undrawn commitment does not serve to limit HSBC’s exposure to credit risk to the contractual notice 
period, the contractual period does not determine the maximum period considered. Instead, ECL is measured over the period HSBC 
remains exposed to credit risk that is not mitigated by credit risk management actions. This applies to retail overdrafts and credit cards, 
where the period is the average time taken for stage 2 exposures to default or close as performing accounts, determined on a portfolio 
basis and ranging from between two and six years. In addition, for these facilities it is not possible to identify the ECL on the loan 
commitment component separately from the financial asset component. As a result, the total ECL is recognised in the loss allowance for 
the financial asset unless the total ECL exceeds the gross carrying amount of the financial asset, in which case the ECL is recognised as 
a provision.

Forward-looking economic inputs

HSBC applies multiple forward-looking global economic scenarios determined with reference to external forecast distributions 
representative of our view of forecast economic conditions. This approach is considered sufficient to calculate unbiased expected loss in 
most economic environments. In certain economic environments, additional analysis may be necessary and may result in additional 
scenarios or adjustments, to reflect a range of possible economic outcomes sufficient for an unbiased estimate. The detailed 
methodology is disclosed in ‘Measurement uncertainty and sensitivity analysis of ECL estimates’ on page 127. 

Critical accounting estimates and judgements

The calculation of the Group’s ECL under IFRS 9 requires the Group to make a number of judgements, assumptions and estimates. The most significant are 
set out below:

Judgements

Estimates

• Defining what is considered to be a significant increase in credit risk
• Determining the lifetime and point of initial recognition of overdrafts and credit cards
• Selecting and calibrating the PD, LGD and EAD models, which support the calculations, 

including making reasonable and supportable judgements about how models react to current 
and future economic conditions

• Selecting model inputs and economic forecasts, including determining whether sufficient and 

appropriately weighted economic forecasts are incorporated to calculate unbiased expected loss

• The sections marked as audited on pages 127 to 
141, ‘Measurement uncertainty and sensitivity 
analysis of ECL estimates’ set out the 
assumptions used in determining ECL and 
provide an indication of the sensitivity of the 
result to the application of different weightings 
being applied to different economic assumptions

• Making management adjustments to account for late breaking events, model and data 

limitations and deficiencies, and expert credit judgements 

(j) 

Insurance contracts

A contract is classified as an insurance contract where HSBC accepts significant insurance risk from another party by agreeing to 
compensate that party on the occurrence of a specified uncertain future event. An insurance contract may also transfer financial risk, but 
is accounted for as an insurance contract if the insurance risk is significant. In addition, HSBC issues investment contracts with 
discretionary participation features (‘DPF‘), which are also accounted for as insurance contracts as required by IFRS 4 ‘Insurance 
Contracts’.

296 HSBC Holdings plc Annual Report and Accounts 2020

 
  
Net insurance premium income

Premiums for life insurance contracts are accounted for when receivable, except in unit-linked insurance contracts where premiums are 
accounted for when liabilities are established. Reinsurance premiums are accounted for in the same accounting period as the premiums 
for the direct insurance contracts to which they relate.

Net insurance claims and benefits paid and movements in liabilities to policyholders

Gross insurance claims for life insurance contracts reflect the total cost of claims arising during the year, including claim handling costs 
and any policyholder bonuses allocated in anticipation of a bonus declaration.

Maturity claims are recognised when due for payment. Surrenders are recognised when paid or at an earlier date on which, following 
notification, the policy ceases to be included within the calculation of the related insurance liabilities. Death claims are recognised when 
notified.

Reinsurance recoveries are accounted for in the same period as the related claim.

Liabilities under insurance contracts

Liabilities under non-linked life insurance contracts are calculated by each life insurance operation based on local actuarial principles. 
Liabilities under unit-linked life insurance contracts are at least equivalent to the surrender or transfer value, which is calculated by 
reference to the value of the relevant underlying funds or indices.

Future profit participation on insurance contracts with DPF

Where contracts provide discretionary profit participation benefits to policyholders, liabilities for these contracts include provisions for 
the future discretionary benefits to policyholders. These provisions reflect the actual performance of the investment portfolio to date and 
management’s expectation of the future performance of the assets backing the contracts, as well as other experience factors such as 
mortality, lapses and operational efficiency, where appropriate. The benefits to policyholders may be determined by the contractual 
terms, regulation, or past distribution policy.

Investment contracts with DPF

While investment contracts with DPF are financial instruments, they continue to be treated as insurance contracts as required by IFRS 4. 
The Group therefore recognises the premiums for these contracts as revenue and recognises as an expense the resulting increase in the 
carrying amount of the liability.

In the case of net unrealised investment gains on these contracts, whose discretionary benefits principally reflect the actual performance 
of the investment portfolio, the corresponding increase in the liabilities is recognised in either the income statement or other 
comprehensive income, following the treatment of the unrealised gains on the relevant assets. In the case of net unrealised losses, a 
deferred participating asset is recognised only to the extent that its recoverability is highly probable. Movements in the liabilities arising 
from realised gains and losses on relevant assets are recognised in the income statement.

Present value of in-force long-term insurance business

HSBC recognises the value placed on insurance contracts and investment contracts with DPF, which are classified as long-term and in-
force at the balance sheet date, as an asset. The asset represents the present value of the equity holders’ interest in the issuing 
insurance companies’ profits expected to emerge from these contracts written at the balance sheet date. The present value of in-force 
business (‘PVIF’) is determined by discounting those expected future profits using appropriate assumptions in assessing factors such as 
future mortality, lapse rates and levels of expenses, and a risk discount rate that reflects the risk premium attributable to the respective 
contracts. The PVIF incorporates allowances for both non-market risk and the value of financial options and guarantees. The PVIF asset 
is presented gross of attributable tax in the balance sheet and movements in the PVIF asset are included in ‘Other operating income’ on 
a gross of tax basis.

(k)  Employee compensation and benefits

Share-based payments

HSBC enters into both equity-settled and cash-settled share-based payment arrangements with its employees as compensation for the 
provision of their services.

The vesting period for these schemes may commence before the legal grant date if the employees have started to render services in 
respect of the award before the legal grant date, where there is a shared understanding of the terms and conditions of the arrangement. 
Expenses are recognised when the employee starts to render service to which the award relates.

Cancellations result from the failure to meet a non-vesting condition during the vesting period, and are treated as an acceleration of 
vesting recognised immediately in the income statement. Failure to meet a vesting condition by the employee is not treated as a 
cancellation, and the amount of expense recognised for the award is adjusted to reflect the number of awards expected to vest. 

Post-employment benefit plans

HSBC operates a number of pension schemes including defined benefit, defined contribution and post-employment benefit schemes.

Payments to defined contribution schemes are charged as an expense as the employees render service.

Defined benefit pension obligations are calculated using the projected unit credit method. The net charge to the income statement 
mainly comprises the service cost and the net interest on the net defined benefit asset or liability, and is presented in operating 
expenses. Remeasurements of the net defined benefit asset or liability, which comprise actuarial gains and losses, return on plan assets 
excluding interest and the effect of the asset ceiling (if any, excluding interest), are recognised immediately in other comprehensive 
income. The net defined benefit asset or liability represents the present value of defined benefit obligations reduced by the fair value of 
plan assets (see policy (c)), after applying the asset ceiling test, where the net defined benefit surplus is limited to the present value of 
available refunds and reductions in future contributions to the plan.

The cost of obligations arising from other post-employment plans are accounted for on the same basis as defined benefit pension plans.

HSBC Holdings plc Annual Report and Accounts 2020 297

Financial statements 
Notes on the financial statements

Critical accounting estimates and judgements

The most significant critical accounting estimates relate to the determination of key assumptions applied in calculating the defined benefit pension 
obligation for the principal plan.

Judgements

Estimates

• A range of assumptions could be applied, and different assumptions could 

significantly alter the defined benefit obligation and the amounts recognised in 
profit or loss or OCI.

• The calculation of the defined benefit pension obligation includes assumptions with 
regard to the discount rate, inflation rate, pension payments and deferred pensions, 
pay and mortality. Management determines these assumptions in consultation with 
the plan’s actuaries.

• Key assumptions used in calculating the defined benefit pension obligation for the 
principal plan and the sensitivity of the calculation to different assumptions are 
described in Note 5

(l) 

Tax

Income tax comprises current tax and deferred tax. Income tax is recognised in the income statement except to the extent that it relates 
to items recognised in other comprehensive income or directly in equity, in which case the tax is recognised in the same statement as 
the related item appears.

Current tax is the tax expected to be payable on the taxable profit for the year and on any adjustment to tax payable in respect of 
previous years. HSBC provides for potential current tax liabilities that may arise on the basis of the amounts expected to be paid to the 
tax authorities. 

Deferred tax is recognised on temporary differences between the carrying amounts of assets and liabilities in the balance sheet, and the 
amounts attributed to such assets and liabilities for tax purposes. Deferred tax is calculated using the tax rates expected to apply in the 
periods in which the assets will be realised or the liabilities settled.

Current and deferred tax are calculated based on tax rates and laws enacted, or substantively enacted, by the balance sheet date.

Critical accounting estimates and judgements

The recognition of deferred tax assets depends on judgements

Judgements

Estimates

• Assessing the probability and sufficiency of future taxable profits, taking into 
account the future reversal of existing taxable temporary differences and tax 
planning strategies including corporate reorganisations

(m)  Provisions, contingent liabilities and guarantees

Provisions

Provisions are recognised when it is probable that an outflow of economic benefits will be required to settle a present legal or 
constructive obligation that has arisen as a result of past events and for which a reliable estimate can be made.

Critical accounting estimates and judgements

The recognition and measurement of provisions requires the Group to make a number of judgements, assumptions and estimates. The most significant are 
set out below:
Judgements

Estimates

• Determining whether a present obligation exists. Professional 
advice is taken on the assessment of litigation and similar 
obligations

• Provisions for legal proceedings and regulatory matters typically 

require a higher degree of judgement than other types of 
provisions. When matters are at an early stage, accounting 
judgements can be difficult because of the high degree of 
uncertainty associated with determining whether a present 
obligation exists, and estimating the probability and amount of 
any outflows that may arise. As matters progress, management 
and legal advisers evaluate on an ongoing basis whether 
provisions should be recognised, revising previous estimates as 
appropriate. At more advanced stages, it is typically easier to 
make estimates around a better defined set of possible 
outcomes

• Provisions for legal proceedings and regulatory matters remain very sensitive to 
the assumptions used in the estimate. There could be a wider range of possible 
outcomes for any pending legal proceedings, investigations or inquiries. As a 
result it is often not practicable to quantify a range of possible outcomes for 
individual matters. It is also not practicable to meaningfully quantify ranges of 
potential outcomes in aggregate for these types of provisions because of the 
diverse nature and circumstances of such matters and the wide range of 
uncertainties involved

• Provisions for customer remediation also require significant levels of estimation. 

The amounts of provisions recognised depend on a number of different 
assumptions, the most significant of which are the uphold rate and average 
redress for complaints yet to be worked. More information about these 
assumptions is included in Note 27

Contingent liabilities, contractual commitments and guarantees 

Contingent liabilities

Contingent liabilities, which include certain guarantees and letters of credit pledged as collateral security, and contingent liabilities 
related to legal proceedings or regulatory matters, are not recognised in the financial statements but are disclosed unless the probability 
of settlement is remote.

Financial guarantee contracts

Liabilities under financial guarantee contracts that are not classified as insurance contracts are recorded initially at their fair value, which 
is generally the fee received or present value of the fee receivable. 

HSBC Holdings has issued financial guarantees and similar contracts to other Group entities. HSBC elects to account for certain 
guarantees as insurance contracts in HSBC Holdings’ financial statements, in which case they are measured and recognised as 
insurance liabilities. This election is made on a contract-by-contract basis, and is irrevocable.

298 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
(n) 

Impairment of non-financial assets

Software under development is tested for impairment at least annually. Other non-financial assets are property, plant and equipment, 
intangible assets (excluding goodwill) and right-of-use assets. They are tested for impairment at the individual asset level when there is 
indication of impairment at that level, or at the CGU level for assets that do not have a recoverable amount at the individual asset level. 
In addition, impairment is also tested at the CGU level when there is indication of impairment at that level. For this purpose, CGUs are 
considered to be the principal operating legal entities divided by global business.

Impairment testing compares the carrying amount of the non-financial asset or CGU with its recoverable amount, which is the higher of 
the fair value less costs of disposal or the value in use. The carrying amount of a CGU comprises the carrying value of its assets and 
liabilities, including non-financial assets that are directly attributable to it and non-financial assets that can be allocated to it on a 
reasonable and consistent basis. Non-financial assets that cannot be allocated to an individual CGU are tested for impairment at an 
appropriate grouping of CGUs. The recoverable amount of the CGU is the higher of the fair value less costs of disposal of the CGU, 
which is determined by independent and qualified valuers where relevant, and the value in use, which is calculated based on appropriate 
inputs (see Note 21).

When the recoverable amount of a CGU is less than its carrying amount, an impairment loss is recognised in the income statement to 
the extent that the impairment can be allocated on a pro-rata basis to the non-financial assets by reducing their carrying amounts to the 
higher of their respective individual recoverable amount or nil. Impairment is not allocated to the financial assets in a CGU.

Impairment loss recognised in prior periods for non-financial assets is reversed when there has been a change in the estimate used to 
determine the recoverable amount. The impairment loss is reversed to the extent that the carrying amount of the non-financial assets 
would not exceed the amount that would have been determined (net of amortisation or depreciation) had no impairment loss been 
recognised in prior periods.

Critical accounting estimates and judgements

The review of goodwill and other non-financial assets for impairment reflects management’s best estimate of the future cash flows of the CGUs and the 
rates used to discount these cash flows, both of which are subject to uncertain factors as described in the Critical accounting estimates and judgements in 
Note 1.2(a). 

2

Net fee income

Net fee income by global business

Wealth and
Personal
Banking

Commercial
Banking

2020

Global
Banking and
Markets

Corporate
Centre

Funds under management

Cards

Broking income

Credit facilities

Account services

Underwriting

Global custody

Unit trusts

Remittances

Imports/exports

Insurance agency commission

Other

Fee income

Less: fee expense

Net fee income 

Funds under management

Cards

Broking income

Credit facilities

Account services

Underwriting

Global custody

Unit trusts

Remittances

Imports/exports

Insurance agency commission

Other

Fee income

Less: fee expense

Net Fee income

$m
1,686   

1,564   

862   

93   

431   

5   

189   

881   

77   

—   

307   

1,123   

7,218   

(1,810)   

5,408   

Wealth and
Personal 
Banking
$m

Commercial
Banking
$m

1,597   

1,602   

485   

90   

991   

3   

135   

1,011   

77   

1   

356   

1,284   

7,632   

(1,998)   

5,634   

120   

358   

40   

785   

654   

6   

18   

22   

362   

497   

20   

887   

3,769   

(380)   

3,389   

$m
126   

360   

61   

740   

598   

9   

22   

18   

313   

417   

17   

893   

3,574   

(349)   

3,225   

20191

Global
Banking and
Markets

$m

460   

15   

532   

743   

365   

821   

564   

2   

311   

164   

1   

$m
477   

25   

616   

626   

264   

1,002   

723   

—   

288   

160   

1   

2,369   

6,551   

(3,284)   

3,267   

Corporate
Centre

$m

—   

—   

—   

—   

(7)   

(1)   

—   

—   

(3)   

—   

—   

2,353   

6,331   

(3,292)   

3,039   

(2,282)   

(2,293)   

2,254   

(39)   

$m
—   

—   

—   

—   

—   

(1)   

—   

—   

(1)   

—   

—   

Total

$m
2,289 

1,949 

1,539 

1,459 

1,293 

1,015 

934 

899 

677 

577 

325 

(2,290)   

(2,292)   

2,266   

(26)   

2,095 

15,051 

(3,177) 

11,874 

2018

Total

$m

2,221 

1,956 

1,210 

1,723 

2,177 

723 

736 

1,038 

778 

709 

404 

2,369 

16,044 

(3,424) 

12,620 

Total

$m

2,177   

1,975   

1,057   

1,618   

2,003   

829   

717   

1,035   

747   

662   

377   

2,242   

15,439   

(3,416)   

12,023   

1  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly. For further guidance, see Note 10: 

Segmental Analysis on page 311.

HSBC Holdings plc Annual Report and Accounts 2020 299

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Net fee income includes $5,858m of fees earned on financial assets that are not at fair value through profit or loss, other than amounts 
included in determining the effective interest rate (2019: $6,647m; 2018: $7,522m), $1,260m of fees payable on financial liabilities that 
are not at fair value through profit or loss, other than amounts included in determining the effective interest rate (2019: $1,450m; 2018: 
$1,682m), $3,426m of fees earned on trust and other fiduciary activities (2019: $3,110m; 2018: $3,165m) and $267m of fees payable 
relating to trust and other fiduciary activities (2019: $237m; 2018: $175m).

3

Net income from financial instruments measured at fair value through profit or loss

Net income/(expense) arising on:

Net trading activities

Other instruments managed on a fair value basis

Net income from financial instruments held for trading or managed on a fair value basis

Financial assets held to meet liabilities under insurance and investment contracts

Liabilities to customers under investment contracts

Net income/(expense) from assets and liabilities of insurance businesses, including related 
derivatives, measured at fair value through profit or loss

Derivatives managed in conjunction with HSBC’s issued debt securities

Other changes in fair value
Changes in fair value of designated debt and related derivatives

Footnotes

1

2020

$m

11,074   

(1,492)   

9,582   

2,481   

(400)   

2,081   

2,619   

(2,388)   

231   

2019

$m

16,121   

(5,890)   

10,231   

3,830   

(352)   

3,478   

2,561   

(2,471)   

90   

Changes in fair value of other financial instruments mandatorily measured at fair value through profit or 
loss

Year ended 31 Dec

455   

812   

12,349   

14,611   

1  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch.

HSBC Holdings

Net income/(expense) arising on:

–  trading activities

–  other instruments managed on a fair value basis

Net income from financial instruments held for trading or managed on a fair value basis

Derivatives managed in conjunction with HSBC Holdings-issued debt securities

Other changes in fair value

Changes in fair value of designated debt and related derivatives

Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss

2020

$m

(336)   

1,137   

801   

694   

(1,020)   

(326)   

1,141   

1,616   

2019

$m

(559)   

2,036   

1,477   

764   

(1,124)   

(360)   

1,659   

2,776   

2018

$m

6,982 

2,549 

9,531 

(1,585) 

97 

(1,488) 

(626) 

529 

(97) 

695 

8,641 

2018

$m

(176) 

421 

245 

(337) 

260 

(77) 

43 

211 

Non-linked
insurance

 Linked life
insurance

$m

8,321   

(362)   

7,959   

9,353   

(1,465)   

7,888   

8,616   

(672)   

7,944   

$m

579   

(8)   

571   

489   

(7)   

482   

422   

(7)   

415   

Investment
contracts with
DPF1

$m

Total

$m

1,563   

10,463 

—   

(370) 

1,563   

10,093 

2,266   

—   

2,266   

2,300   

—   

2,300   

12,108 

(1,472) 

10,636 

11,338 

(679) 

10,659 

Year ended 31 Dec

4

Insurance business

Net insurance premium income

Gross insurance premium income

Reinsurers’ share of gross insurance premium income

Year ended 31 Dec 2020

Gross insurance premium income

Reinsurers’ share of gross insurance premium income

Year ended 31 Dec 2019

Gross insurance premium income

Reinsurers’ share of gross insurance premium income

Year ended 31 Dec 2018

1  Discretionary participation features.

300 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net insurance claims and benefits paid and movement in liabilities to policyholders

Gross claims and benefits paid and movement in liabilities

–  claims, benefits and surrenders paid

–  movement in liabilities

Reinsurers’ share of claims and benefits paid and movement in liabilities

–  claims, benefits and surrenders paid

–  movement in liabilities

Year ended 31 Dec 2020

Gross claims and benefits paid and movement in liabilities

–  claims, benefits and surrenders paid

–  movement in liabilities

Reinsurers’ share of claims and benefits paid and movement in liabilities

–  claims, benefits and surrenders paid

–  movement in liabilities

Year ended 31 Dec 2019

Gross claims and benefits paid and movement in liabilities

–  claims, benefits and surrenders paid

–  movement in liabilities

Reinsurers’ share of claims and benefits paid and movement in liabilities

–  claims, benefits and surrenders paid

–  movement in liabilities

Year ended 31 Dec 2018

1 Discretionary participation features.

Liabilities under insurance contracts

Gross liabilities under insurance contracts at 1 Jan 2020

Claims and benefits paid

Increase in liabilities to policyholders

Exchange differences and other movements

Gross liabilities under insurance contracts at 31 Dec 2020

Reinsurers’ share of liabilities under insurance contracts

Net liabilities under insurance contracts at 31 Dec 2020

Gross liabilities under insurance contracts at 1 Jan 2019

Claims and benefits paid

Increase in liabilities to policyholders

Exchange differences and other movements

Gross liabilities under insurance contracts at 31 Dec 2019

Reinsurers’ share of liabilities under insurance contracts

Net liabilities under insurance contracts at 31 Dec 2019

Non-linked
insurance

Linked life
insurance

Investment
contracts with
DPF1

$m

10,050   

3,695   

6,355   

(366)   

(430)   

64   

$m

1,112   

900   

212   

(4)   

(10)   

6   

$m

1,853   

2,083   

(230)   

—   

—   

—   

Total

$m

13,015 

6,678 

6,337 

(370) 

(440) 

70 

9,684   

1,108   

1,853   

12,645 

11,305   

3,783   

7,522   

(1,402)   

(411)   

(991)   

9,903   

8,943   

3,852   

5,091   

(605)   

(311)   

(294)   

8,338   

1,217   

900   

317   

(4)   

(17)   

13   

3,810   

1,921   

1,889   

—   

—   

—   

16,332 

6,604 

9,728 

(1,406) 

(428) 

(978) 

1,213   

3,810   

14,926 

(446)   

1,088   

(1,534)   

191   

(181)   

372   

(255)   

1,724   

1,869   

(145)   

—   

—   

—   

1,724   

10,221 

6,809 

3,412 

(414) 

(492) 

78 

9,807 

 Non-linked
insurance

 Linked life
insurance

Investment
contracts with
DPF1

Footnotes

2

2

$m

65,324   

(3,695)   

10,050   

785   

72,464   

(3,434)   

69,030   

57,283   

(3,804)   

11,326   

519   

65,324   

(3,521)   

61,803   

$m

6,151   

(900)   

1,112   

86   

6,449   

(14)   

6,435   

5,789   

(900)   

1,217   

45   

6,151   

(71)   

6,080   

$m

25,964   

(2,083)   

1,853   

2,544   

Total

$m

97,439 

(6,678) 

13,015 

3,415 

28,278   

107,191 

—   

(3,448) 

28,278   

103,743 

24,258   

(1,900)   

3,789   

(183)   

25,964   

—   

25,964   

87,330 

(6,604) 

16,332 

381 

97,439 

(3,592) 

93,847 

1 Discretionary participation features.
2 ‘Exchange differences and other movements’ includes movements in liabilities arising from net unrealised investment gains recognised in other 

comprehensive income.

The key factors contributing to the movement in liabilities to policyholders included movements in the market value of assets supporting 
policyholder liabilities, death claims, surrenders, lapses, new business, the declaration of bonuses and other amounts attributable to 
policyholders. 

5

Employee compensation and benefits

Wages and salaries

Social security costs

Post-employment benefits

Year ended 31 Dec

2020

$m

15,752   

1,378   

946   

18,076   

2019

$m

15,581   

1,472   

949   

18,002   

2018

$m

14,751 

1,490 

1,132 

17,373 

HSBC Holdings plc Annual Report and Accounts 2020 301

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Average number of persons employed by HSBC during the year by global business

Wealth and Personal Banking

Commercial Banking

Global Banking and Markets

Corporate Centre

Year ended 31 Dec

2020
144,615   
45,631   
49,055   
411   
239,712   

20191
148,680   

46,584   

51,313   

478   

20181
144,109 

48,983 

49,217 

541 

247,055   

242,850 

1  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly. For further guidance, see Note 10: 

Segmental analysis on page 311.

Average number of persons employed by HSBC during the year by geographical region

Europe

Asia

Middle East and North Africa

North America

Latin America

Year ended 31 Dec

2020
64,886   
129,923   
9,550   
15,430   
19,923   
239,712   

2019
66,392   

133,624   

9,798   

16,615   

20,626   

2018
67,007 

127,992 

9,798 

17,350 

20,703 

247,055   

242,850 

Reconciliation of total incentive awards granted to income statement charge

Total incentive awards approved for the current year

Less: deferred bonuses awarded, expected to be recognised in future periods

Total incentives awarded and recognised in the current year

Add: current year charges for deferred bonuses from previous years

Other

Income statement charge for incentive awards

Share-based payments

2020

$m

2,659   

(239)   

2,420   

286   

2   

2,708   

2019

$m

3,341   

(337)   

3,004   

327   

(55)   

3,276   

‘Wages and salaries’ includes the effect of share-based payments arrangements, of which $434m was equity settled (2019: $478m; 
2018: $450m), as follows:

Conditional share awards

Savings-related and other share award option plans

Year ended 31 Dec

HSBC share awards

Award

Policy

2020

$m

411

51

462

2019

$m

521

30

551

2018

$m

3,473 

(351) 

3,122 

322 

(70) 

3,374 

2018

$m

499

23

522

Deferred share awards 
(including annual incentive 
awards, LTI awards 
delivered in shares) and 
Group Performance Share 
Plans (‘GPSP’)

An assessment of performance over the relevant period ending on 31 December is used to determine the amount of the 
award to be granted.
•  Deferred awards generally require employees to remain in employment over the vesting period and are generally not 

subject to performance conditions after the grant date. An exception to these are the LTI awards, which are subject to 
performance conditions.

•  Deferred share awards generally vest over a period of three, five or seven years.
•  Vested shares may be subject to a retention requirement post-vesting. GPSP awards are retained until cessation of 

employment.

•  Awards are subject to a malus provision prior to vesting.
•  Awards granted to Material Risk Takers from 2015 onwards are subject to clawback post-vesting.

International Employee 
Share Purchase Plan 
(‘ShareMatch’)

The plan was first introduced in Hong Kong in 2013 and now includes employees based in 27 jurisdictions.
•  Shares are purchased in the market each quarter up to a maximum value of £750, or the equivalent in local currency.
•  Matching awards are added at a ratio of one free share for every three purchased.
•  Matching awards vest subject to continued employment and the retention of the purchased shares for a maximum 

period of two years and nine months.

Movement on HSBC share awards

Conditional share awards outstanding at 1 Jan

Additions during the year

Released in the year

Forfeited in the year

Conditional share awards outstanding at 31 Dec

Weighted average fair value of awards granted ($)

302 HSBC Holdings plc Annual Report and Accounts 2020

2020

Number

(000s)

97,055   

72,443   

(60,673)   

(5,352)   

103,473   

7.28   

2019

Number

(000s)

94,897 

71,858 

(67,737) 

(1,963) 

97,055 

7.89 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC share option plans

Main plans

Policy

Savings-related share 
option plans (‘Sharesave’)

•   From 2014, employees eligible for the UK plan could save up to £500 per month with the option to use the savings to 

acquire shares.

• These are generally exercisable within six months following either the third or fifth anniversary of the commencement 

of a three-year or five-year contract, respectively.

• The exercise price is set at a 20% (2019: 20%) discount to the market value immediately preceding the date of 

invitation.

Calculation of fair values

The fair values of share options are calculated using a Black-Scholes model. The fair value of a share award is based on the share price 
at the date of the grant. 

Movement on HSBC share option plans

Outstanding at 1 Jan 2020

Granted during the year

Exercised during the year

Expired during the year

Forfeited during the year

Outstanding at 31 Dec 2020

– of which exercisable
Weighted average remaining contractual life (years)

Outstanding at 1 Jan 2019

Granted during the year

Exercised during the year

Expired during the year

Forfeited during the year

Outstanding at 31 Dec 2019
– of which exercisable

Weighted average remaining contractual life (years)

1  Weighted average exercise price.
2  The weighted average fair value of options granted during the year was $0.47 (2019: $1.36).
3  The weighted average share price at the date the options were exercised was $7.08 (2019: $7.99).

Post-employment benefit plans

Footnotes

2

3

2

3

Savings-related
share option plans

Number

(000s)

65,060   

111,469   

(1,387)   

(43,032)   

(1,158)   

130,952   

8,170   

3.68

57,065   

32,130   

(11,806)   

(11,321)   

(1,008)   

65,060   

2,149   

2.77

WAEP1

£

4.81 

2.63 

4.48 

4.81 

4.88 

2.97 

4.50 

4.92 

4.69 

4.40 

5.46 

4.99 

4.81 

4.53 

The Group operates pension plans throughout the world for its employees. ‘Pension risk management processes’ on page 172 contains 
details of the policies and practices associated with these pension plans, some of which are defined benefit plans. The largest defined 
benefit plan is the HBUK section of the HSBC Bank (UK) Pension Scheme (‘the principal plan’), created as a result of the HSBC Bank (UK) 
Pension Scheme being fully sectionalised in 2018 to meet the requirements of the Banking Reform Act.

HSBC holds on its balance sheet the net surplus or deficit, which is the difference between the fair value of plan assets and the 
discounted value of scheme liabilities at the balance sheet date for each plan. Surpluses are only recognised to the extent that they are 
recoverable through reduced contributions in the future or through potential future refunds from the schemes. In assessing whether a 
surplus is recoverable, HSBC has considered its current right to obtain a future refund or a reduction in future contributions together 
with the rights of third parties such as trustees.

The principal plan

The principal plan has a defined benefit section and a defined contribution section. The defined benefit section was closed to future 
benefit accrual in 2015, with defined benefits earned by employees at that date continuing to be linked to their salary while they remain 
employed by HSBC. The plan is overseen by an independent corporate trustee, who has a fiduciary responsibility for the operation of the 
plan. Its assets are held separately from the assets of the Group.

The investment strategy of the plan is to hold the majority of assets in bonds, with the remainder in a diverse range of investments. It 
also includes some interest rate swaps to reduce interest rate risk and inflation swaps to reduce inflation risk.

The latest funding valuation of the plan at 31 December 2019 was carried out by Colin G Singer of Willis Towers Watson Limited, who is 
a Fellow of the UK Institute and Faculty of Actuaries, using the projected unit credit method. At that date, the market value of the plan’s 
assets was £31.1bn ($41.1bn) and this exceeded the value placed on its liabilities on an ongoing basis by £2.5bn ($3.3bn), giving a 
funding level of 109%. These figures include defined contribution assets amounting to £2.4bn ($3.2bn). The main differences between 
the assumptions used for assessing the defined benefit liabilities for this funding valuation and those used for IAS 19 are more prudent 
assumptions for discount rate, inflation rate and life expectancy. The next funding valuation will have an effective date of 31 December 
2022.

Although the plan was in surplus at the valuation date, HSBC continues to make further contributions to the plan to support a lower-risk 
investment strategy over the longer term. The remaining contribution is £160m ($218m) to be paid in 2021. The main employer of the 
principal plan is HSBC UK Bank plc, with additional support from HSBC Holdings plc. The HSBC Bank (UK) Pension Scheme is fully 
sectionalised and no entities outside the ring fence participate in the HBUK section. The sectionalisation, which took place in 2018, did 
not materially affect the overall funding position of the plan.

HSBC Holdings plc Annual Report and Accounts 2020 303

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

The actuary also assessed the value of the liabilities if the plan were to have been stopped and an insurance company asked to secure all 
future pension payments. This is generally larger than the amount needed on the ongoing basis described above because an insurance 
company would use more prudent assumptions and include an explicit allowance for the future administrative expenses of the plan. 
Under this approach, the amount of assets needed was estimated to be £33bn ($44bn) at 31 December 2019.

Guaranteed minimum pension equalisation

Following a judgment issued by the High Court of Justice of England and Wales in 2018, we estimated the financial effect of equalising 
benefits in respect of guaranteed minimum pension (‘GMP’) equalisation, and any potential conversion of GMPs into non-GMP benefits, 
to be an approximate 0.9% increase in the principal plan’s liabilities, or £187m ($239m). This was recognised in the income statement in 
2018. A further judgment by the High Court on 20 November 2020 ruled that GMPs should also be equalised for those who had 
previously transferred benefits from the principal plan to another arrangement, with £13m ($17m) consequently being recognised in 
2020. We continue to assess the impact of GMP equalisation.

Income statement charge

Defined benefit pension plans

Defined contribution pension plans

Pension plans

Defined benefit and contribution healthcare plans

Year ended 31 Dec

2020

$m
146   
775   
921   
25   
946   

2019

$m

176   

758   

934   

15   

949   

2018

$m

355 

756 

1,111 

21 

1,132 

Net assets/(liabilities) recognised on the balance sheet in respect of defined benefit plans

Defined benefit pension plans

Defined benefit healthcare plans

At 31 Dec 2020

Total employee benefit liabilities (within Note 26 ‘Accruals, deferred income and other 
liabilities’)

Total employee benefit assets (within Note 22 ‘Prepayments, accrued income and 
other assets’)

Defined benefit pension plans

Defined benefit healthcare plans

At 31 Dec 2019

Total employee benefit liabilities (within Note 26 ‘Accruals, deferred income and other 
liabilities’)

Total employee benefit assets (within Note 22 ‘Prepayments, accrued income and other assets’)

HSBC Holdings

Fair value of
plan assets

Present value
of defined
benefit
obligations

Effect of
limit on plan
surpluses

$m

$m

52,990   

(43,995)   

114   

(639)   

53,104   

(44,634)   

47,567   

121   

47,688   

(40,582)   

(580)   

(41,162)   

$m

(44)   

—   

(44)   

(16)   

—   

(16)   

Total

$m

8,951 

(525) 

8,426 

(2,025) 

10,450 

6,969 

(459) 

6,510 

(1,771) 

8,280 

Employee compensation and benefit expense in respect of HSBC Holdings’ employees in 2020 amounted to $56m (2019: $37m). The 
average number of persons employed during 2020 was 59 (2019: 60). Employees who are members of defined benefit pension plans are 
principally members of either the HSBC Bank (UK) Pension Scheme or the HSBC International Staff Retirement Benefits Scheme. HSBC 
Holdings pays contributions to such plans for its own employees in accordance with the schedules of contributions determined by the 
trustees of the plans and recognises these contributions as an expense as they fall due. 

304 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Defined benefit pension plans

Net asset/(liability) under defined benefit pension plans 

At 1 Jan 2020

Service cost

–  current service cost

–  past service cost and gains/(losses) from settlements

Net interest income/(cost) on the net defined benefit asset/
(liability)

Remeasurement effects recognised in other comprehensive 
income

–  return on plan assets (excluding interest income)
–  actuarial gains/(losses)2
–  other changes

Exchange differences

Benefits paid
Other movements4
At 31 Dec 2020

At 1 Jan 2019

Service cost

–  current service cost

–  past service cost and losses from settlements

Net interest income/(cost) on the net defined benefit asset/
(liability)

Remeasurement effects recognised in other comprehensive 
income

–  return on plan assets (excluding interest income)
–  actuarial gains/(losses)2,3
–  other changes3
Exchange differences

Benefits paid
Other movements4
At 31 Dec 2019

Fair value of plan 
assets

Present value of 
defined benefit 
obligations

Effect of the asset 
ceiling

Net defined benefit 
asset/(liability)

Principal1
plan

$m

Other
plans

$m

Principal1
plan

$m

Other
plans

$m

Principal1
plan

$m

37,874   

9,693   

(30,158)   

(10,424)   

—   

—   

—   

—   

—   

—   

(68)   

(28)   

(40)   

(172)   

(184)   

12   

726   

233   

(575)   

(245)   

3,173   

3,173   

—   

—   

1,446   

(1,148)   

434   

879   

(2,118)   

(547)   

692   

—   

—   

(2,118)   

187   

249   

—   

(1,100)   

(652)   

1,148   

83   

(134)   

—   

(428)   

(119)   

(387)   

727   

58   

42,505   

10,485   

(33,005)   

(10,990)   

34,074   

8,725   

(26,616)   

(9,967)   

—   

—   

—   

—   

—   

—   

(64)   

(40)   

(24)   

(246)   

(183)   

(63)   

939   

269   

(728)   

(293)   

2,205   

2,205   

—   

—   

1,300   

(1,014)   

370   

867   

870   

—   

(3)   

181   

(620)   

271   

(2,548)   

—   

(2,548)   

—   

(1,036)   

1,014   

(180)   

(521)   

—   

(507)   

(14)   

(180)   

694   

89   

37,874   

9,693   

(30,158)   

(10,424)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

Other
plans

$m

Principal1
plan

$m

(16)   

7,716   

—   

—   

—   

(68)   

(28)   

(40)   

Other
plans

$m

(747) 

(172) 

(184) 

12 

—   

151   

(12) 

(26)   

1,055   

—   

—   

(26)   

(2)   

—   

—   

3,173   

(2,118)   

—   

346   

—   

300   

306 

692 

(428) 

42 

(140) 

75 

141 

(44)   

9,500   

(549) 

(35)   

7,458   

(1,277) 

—   

—   

—   

(64)   

(40)   

(24)   

(246) 

(183) 

(63) 

—   

211   

(24) 

20   

—   

—   

20   

(1)   

—   

—   

(343)   

2,205   

(2,548)   

—   

264   

—   

190   

(16)   

7,716   

366 

870 

(507) 

3 

— 

74 

360 

(747) 

1  For further details of the principal plan, see page 303.
2  Actuarial gains/(losses) for our principal plan includes losses relating to financial assumptions of $3,179m (2019: $3,049m), gains relating to 

demographic assumptions of $86m (2019: $186m) and experience adjustments of $975m (2019: $315m). Actuarial gains/(losses) for our other 
plans includes losses relating to financial assumptions of $564m (2019: $847m), gains relating to demographic assumptions of $49m (2019: 
$94m) and experience adjustments of $87m (2019: $246m).

3  The comparatives have been re-presented to reclassify gains and losses relating to demographic and experience assumptions in other plans from 

'other changes' to 'actuarial gains and losses’.

4  Other movements include contributions by HSBC, contributions by employees, administrative costs and taxes paid by plan.

HSBC expects to make $376m of contributions to defined benefit pension plans during 2021. Benefits expected to be paid from the 
plans to retirees over each of the next five years, and in aggregate for the five years thereafter, are as follows:

Benefits expected to be paid from plans

The principal plan1,2
Other plans1

2021

$m

1,274   

495   

2022

$m

1,312   

520   

2023

$m

1,352   

486   

2024

$m

1,393   

472   

2025

$m

1,434   

470   

2026-2030

$m

7,840 

2,322 

1  The duration of the defined benefit obligation is 17.4 years for the principal plan under the disclosure assumptions adopted (2019: 18.1 years) and 

13.5 years for all other plans combined (2019: 13.2 years).

2  For further details of the principal plan, see page 303.

HSBC Holdings plc Annual Report and Accounts 2020 305

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Fair value of plan assets by asset classes

31 Dec 2020

Quoted
market price
in active
market

No quoted
market price
in active
market

$m

$m

Value

$m

42,505   

37,689   

4,816   

268   

7   

36,198   

35,479   

1,973   

4,066   

10,485   

1,484   

7,624   

(57)   

1,434   

—   

2,203   

9,512   

1,069   

7,143   

—   

1,300   

261   

719   

1,973   

1,863   

973   

415   

481   

(57)   

134   

Thereof
HSBC1

$m

Value

$m

31 Dec 2019

Quoted
market price
in active
market

No quoted
market price
in active
market

$m

$m

Thereof
HSBC1

$m

973   
—   
—   
973   
—   

54   
3   
10   
—   
41   

37,874   

33,921   

3,953   

1,183 

662   

312   

31,699   

31,699   

2,052   

3,461   

9,693   

2,065   

6,608   

—   

1,020   

—   

1,910   

8,702   

1,455   

6,376   

—   

871   

350   

—   

2,052   

1,551   

991   

610   

232   

—   

149   

— 

— 

1,183 

— 

239 

2 

8 

— 

229 

The principal plan2
Fair value of plan assets

–  equities

–  bonds

–  derivatives

–  other

Other plans

Fair value of plan assets

–  equities

–  bonds

–  derivatives

–  other

1  The fair value of plan assets includes derivatives entered into with HSBC Bank plc as detailed in Note 35. These derivatives are presented within 

the principal plan at 31 December 2020. Comparatives have been re-presented.

2  For further details on the principal plan, see page 303.

Post-employment defined benefit plans’ principal actuarial financial assumptions

HSBC determines the discount rates to be applied to its obligations in consultation with the plans’ local actuaries, on the basis of current 
average yields of high-quality (AA-rated or equivalent) debt instruments with maturities consistent with those of the defined benefit 
obligations.

Key actuarial assumptions for the principal plan1

UK
At 31 Dec 2020

At 31 Dec 2019

Discount rate

Inflation rate Rate of increase for pensions

Rate of pay increase

%

 1.45 

 2.00 

%

 3.05 

 3.10 

%

 3.00 

 2.90 

%

 2.75 

 3.65 

1  For further details on the principal plan, see page 303.

Mortality tables and average life expectancy at age 601 for the principal plan

UK

At 31 Dec 2020

At 31 Dec 2019

Mortality
table

Life expectancy at age 60 for
a male member currently:

Life expectancy at age 60 for
a female member currently:

Aged 60

Aged 40

Aged 60

Aged 40

SAPS S32
SAPS S23

27.0

28.0

28.5

29.4

28.1

28.2

29.7

29.8

1  For further details of the principal plan, see page 303.
2  Self-administered pension scheme (‘SAPS’) S3 table (males: 'Normal health pensioners, Light' version; females: 'Normal health pensioners, 
Heavy' version) with a multiplier of 1 for both male and female pensioners. Improvements are projected in accordance with the continual 
mortality investigation (‘CMI’) 2019 core projection model with a long-term rate of improvement of 0.25% per annum and a long-term rate of 
improvement of 1.25% per annum. Separate tables have been applied to lower-paid pensioners and dependant members.

3  Self-administered pension scheme (‘SAPS’) S2 table (males: 'Normal health pensioners' version; females: 'All pensioners' version) with a 

multiplier of 0.94 for male and 1.15 for female pensioners. Improvements are projected in accordance with the continual mortality investigation 
(‘CMI’) 2019 core projection model with an initial addition to improvements of 0.25% per annum and a long-term rate of improvement of 1.25% 
per annum. Separate tables have been applied to lower-paid pensioners and dependant members.

The effect of changes in key assumptions on the principal plan1

Discount rate – increase/decrease of 0.25%

Inflation rate – increase/decrease of 0.25%

Pension payments and deferred pensions – increase/decrease of 0.25%

Pay – increase/decrease of 0.25%

Change in mortality – increase of 1 year

1  For further details of the principal plan, see page 303.

Impact on HBUK section of the 
HSBC Bank (UK) Pension Scheme obligation

Financial impact of increase

Financial impact of decrease

2020

$m
(1,383)   
871   
1,307   
60   
1,453   

2019

$m
(1,305)   
781   
1,100   
73   

1,267 

2020

$m
1,475   
(830)   
(1,222)   
(59)   
N/A

2019

$m
1,395 

(738) 

(1,026) 

(72) 

N/A

The above sensitivity analyses are based on a change in an assumption while holding all other assumptions constant. In practice, this in 
unlikely to occur, and changes in some of the assumptions may be correlated. When calculating the sensitivity of the defined benefit 
obligation to significant actuarial assumptions the same method (present value of the defined benefit obligation calculated with the 
projected unit credit method at the end of the reporting period) has been applied as when calculating the defined benefit asset 
recognised in the balance sheet. The methods and types of assumptions used in preparing the sensitivity analysis did not change 
compared with the prior period.

306 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Directors’ emoluments

Details of Directors’ emoluments, pensions and their interests are disclosed in the Directors’ remuneration report on page 229.

6

Auditor’s remuneration

Audit fees payable to PwC

Other audit fees payable

Year ended 31 Dec

Fees payable by HSBC to PwC

Fees for HSBC Holdings’ statutory audit

Fees for other services provided to HSBC

–  audit of HSBC’s subsidiaries

–  audit-related assurance services

–  other assurance services

–  taxation compliance services

–  taxation advisory services

–  other non-audit services
Year ended 31 Dec

2020

$m

92.9

1.0

93.9

2020

$m
21.9   

108.3   

71.0   

17.2   

20.1   

—   

—   

—   

2019

$m

85.2

0.9

86.1

2019

$m
15.7   

95.0   

69.5   

10.0   

12.2   

1.6   
—   
1.7   

2018

$m

86.6

0.9

87.5

2018

$m
16.4 

103.1 

70.2 

11.4 

13.5 

1.4 
0.1 

6.5 

130.2   

110.7   

119.5 

Footnotes

1

2

3,4

3

1 Fees payable to PwC for the statutory audit of the consolidated financial statements of HSBC and the separate financial statements of HSBC 
Holdings. They include amounts payable for services relating to the consolidation returns of HSBC Holdings’ subsidiaries, which are clearly 
identifiable as being in support of the Group audit opinion. 

2 Including services for assurance and other services that relate to statutory and regulatory filings, including interim reviews.
3 Including permitted services relating to attestation reports on internal controls of a service organisation primarily prepared for and used by third 

party end user, including comfort letters.

4 Includes reviews of PRA regulatory reporting returns in 2020.

No fees were payable by HSBC to PwC as principal auditor for the following types of services: internal audit services and services related 
to litigation, recruitment and remuneration.

Fees payable by HSBC’s associated pension schemes to PwC

Audit of HSBC’s associated pension schemes

Year ended 31 Dec

2020

$000
316   
316   

2019

$000

250   

250   

2018

$000

172 

172 

No fees were payable by HSBC’s associated pension schemes to PwC as principal auditor for the following types of services: internal 
audit services, other assurance services, services related to corporate finance transactions, valuation and actuarial services, litigation, 
recruitment and remuneration, and information technology.

In addition to the above, the estimated fees paid to PwC by third parties associated with HSBC amounted to $12.3m (2019: $17.2m; 
2018: $14.0m). In these cases, HSBC was connected with the contracting party and may therefore have been involved in appointing 
PwC. These fees arose from services such as auditing mutual funds managed by HSBC and reviewing the financial position of corporate 
concerns that borrow from HSBC.

Fees payable for non-audit services for HSBC Holdings are not disclosed separately because such fees are disclosed on a consolidated 
basis for the Group.

7

Tax

Tax expense

Current tax

–  for this year

–  adjustments in respect of prior years

Deferred tax

–  origination and reversal of temporary differences

–  effect of changes in tax rates

–  adjustments in respect of prior years

Year ended 31 Dec

Footnotes

1

2

2020

$m
2,700   

2,883   

(183)   

(22)   

(341)   

58   

261   

2019

$m
3,768   

3,689   

79   

871   

684   

(11)   

198   

2018

$m
4,195 

4,158 

37 

670 

656 

17 

(3) 

2,678   

4,639   

4,865 

1  Current tax included Hong Kong profits tax of $888m (2019: $1,413m; 2018: $1,532m). The Hong Kong tax rate applying to the profits of 

subsidiaries assessable in Hong Kong was 16.5% (2019: 16.5%; 2018: 16.5%). 
In addition to amounts recorded in the income statement, a tax charge of $7m (2019: charge of $6m) was recorded directly to equity.

2 

Tax reconciliation

The tax charged to the income statement differs from the tax charge that would apply if all profits had been taxed at the UK corporation 
tax rate as follows:

HSBC Holdings plc Annual Report and Accounts 2020 307

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Profit before tax

Tax expense

Taxation at UK corporation tax rate of 19.00% (2019: 19.00%; 2018: 19.00%)

Impact of differently taxed overseas profits in overseas locations

Items increasing tax charge in 2020:

–  non-UK movements in unrecognised deferred tax

–  UK tax losses not recognised

–  other permanent disallowables

–  local taxes and overseas withholding taxes

–  bank levy

–  adjustments in respect of prior period liabilities

–  impacts of hyperinflation

–  impact of changes in tax rates

–  non-deductible regulatory settlements

–  non-deductible goodwill write-down

Items reducing tax charge in 2020:
–  non-taxable income and gains

–  deductions for AT1 coupon payments

–  effect of profits in associates and joint ventures

–  UK banking surcharge

–  non-deductible UK customer compensation

–  non-taxable gain on dilution of shareholding in SABB

–  other items

Year ended 31 Dec

2020

$m

8,777 

1,668 

178 

%

2019

$m

13,347 

 19.0   

 2.0   

2,536 

253 

608 

444 

322 

228 

202 

78 

65 

58 

33 

— 

(515) 

(310) 

(250) 

(113) 

(18) 

— 

— 

 6.9   

 5.1   

 3.6   

 2.6   

 2.3   

 0.9   

 0.7   

 0.6   

 0.4   

 —   

 (5.8)   
 (3.5)   

 (2.8)   

 (1.3)   

 (0.2)   

 —   

 —   

12 

364 

481 

484 

184 

277 

29 

(11) 

5 

1,421 

(844) 

(263) 

(467) 

29 

382 

(181) 

(52) 

%

 19.0   

 1.9   

 0.1   

 2.7   

 3.6   

 3.6   

 1.4   

 2.1   

 0.2   

 (0.1)   

 —   

 10.7   

 (6.3)   

 (2.0)   

 (3.5)   

 0.2   

 2.9   

 (1.3)   

 (0.4)   

2018

$m

19,890 

3,779 

264 

32 

435 

396 

437 

191 

34 

78 

17 

153 

— 

(691) 

— 

(492) 

229 

16 

— 

(13) 

2,678 

 30.5   

4,639 

 34.8   

4,865 

%

 19.0 

 1.3 

 0.2 

 2.2 

 2.0 

 2.2 

 1.0 

 0.2 

 0.4 

 0.1 

 0.8 

 — 

 (3.5) 

 — 

 (2.5) 

 1.1 

 0.1 

 — 

 (0.1) 

 24.5 

The Group’s profits are taxed at different rates depending on the country or territory in which the profits arise. The key applicable tax 
rates for 2020 include Hong Kong (16.5%), the US (21%) and the UK (19%). If the Group’s profits were taxed at the statutory rates of the 
countries in which the profits arose, then the tax rate for the year would have been 21.00% (2019: 20.90%). The effective tax rate for the 
year of 30.5% (2019: 34.8%) was lower than for 2019. The effective tax rate for 2019 included a non-deductible impairment of goodwill 
of $7.3bn (10.7% increase in effective tax rate) and a higher level of non-deductible customer compensation (3.1% increase in effective 
tax rate compared with 2020), both of which are non-recurring items. This was partly offset by the impact of non-recognition of deferred 
tax, mainly in the UK ($0.4bn) and France ($0.4bn), being greater in 2020 than 2019 (9.2% increase in effective tax rate compared with 
2019).  

Following an amendment to IAS 12 effective 1 January 2019, the income tax consequences of distributions, including AT1 coupon 
payments, were recorded in the income statement tax expense. The 2018 reconciliation has not been restated. 

Accounting for taxes involves some estimation because the tax law is uncertain and its application requires a degree of judgement, 
which authorities may dispute. Liabilities are recognised based on best estimates of the probable outcome, taking into account external 
advice where appropriate. We do not expect significant liabilities to arise in excess of the amounts provided. HSBC only recognises 
current and deferred tax assets where recovery is probable. 

Movement of deferred tax assets and liabilities

Loan
impairment
provisions

Unused tax
losses and
tax credits

Derivatives, FVOD1
and other
investments

Insurance
business

Expense
provisions

Fixed 
assets

Retirement 
obligations

Other

Total

Footnotes

Assets

Liabilities

At 1 Jan 2020

Income statement

Other comprehensive income

Equity

Foreign exchange and other adjustments

At 31 Dec 2020

Assets

Liabilities

Assets

Liabilities

At 1 Jan 2019

Income statement

Other comprehensive income

Equity

Foreign exchange and other adjustments

At 31 Dec 2019

Assets

Liabilities

2

2

2

2

$m

983   

—   

983   

295   

—   

—   

(36)   

1,242   

1,242   

—   

982   

—   

982   

45   

—   

—   

(44)   

983   

983   

—   

$m

1,414   

—   

1,414   

355   

—   

—   

52   

1,821   

1,821   

—   

1,156   

—   

1,156   

266   

—   

—   

(8)   

1,414   

1,414   

—   

$m

$m

$m

$m

$m

$m

$m

979   

—   

650   1,002   

—    422   5,450 

(558)   

(1,621)   

—    —   

(1,613)   

(401)   (4,193) 

421   

(1,621)   

650   1,002   

(1,613)   

21   1,257 

(274)   

(32)   

(81)    (112)   

(190)   

61   

22 

(23)   

—   

(281)   

—   

—   

31   

—    —   

(387)   

(660)   (1,070) 

—    —   

—    —    — 

(4)   

11   

(116)    304   

(39) 

(157)   

(1,622)   

565    901   

(2,306)   

(274)    170 

548   

—   

565    901   

—    960   6,037 

(705)   

(1,622)   

—    —   

(2,306)   (1,234)   (5,867) 

492   

—   

629    1,151   

—   

738    5,148 

(376)   

(1,271)   

—    —   

(1,387)   

(283)   (3,317) 

116   

(1,271)   

629    1,151   

(1,387)   

455    1,831 

(386)   

544   

—   

147   

421   

979   

(303)   

(18)   

(185)   

(149)   

(141)   

(871) 

—   

—   

(47)   

—    —   

—    —   

30   

(391)    183 

—    —    — 

39   

36   

(107)   

98    114 

(1,621)   

650    1,002   

(1,613)   

21    1,257 

—   

650    1,002   

—   

422    5,450 

(558)   

(1,621)   

—    —   

(1,613)   

(401)   (4,193) 

1  Fair value of own debt.
2  After netting off balances within countries, the balances as disclosed in the accounts are as follows: deferred tax assets $4,483m (2019: $4,632m) 

and deferred tax liabilities $4,313m (2019: $3,375m). 

308 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In applying judgement in recognising deferred tax assets, management has critically assessed all available information, including future 
business profit projections and the track record of meeting forecasts.

The Group’s net deferred tax asset of $0.2bn (2019: $1.3bn) included $2.4bn (2019: $2.8bn) of deferred tax assets relating to the US, of 
which $1.0bn related to US tax losses that expire in 13 to 17 years. Management expects the US deferred tax asset to be substantially 
recovered in seven to eight years, with the majority recovered in the first five years. During 2020, the Group derecognised $250m of 
deferred tax asset relating to US state tax losses as management did not consider there to be sufficient evidence of future taxable profits 
against which to recover these losses before they expire. Management’s assessment of the likely availability of future taxable profits 
against which to recover the US deferred tax assets takes into consideration the reversal of existing taxable temporary differences, past 
business performance and forecasts of future business performance. The most recent financial forecasts approved by management 
cover a five-year period and the forecasts have been extrapolated beyond five years by assuming that performance remains constant 
after the fifth year.

The Group’s net deferred tax asset of $0.2bn (2019: $1.3bn) also included a net UK deferred tax asset of $0.6bn (2019: liability of 
$0.5bn), of which $0.5bn related to UK banking tax losses created in 2020. The net UK deferred tax asset of $0.6bn excludes the 
deferred tax liability arising on the UK pension scheme surplus, the reversal of which is not taken into account when estimating future 
taxable profits. The UK deferred tax asset is supported by forecasts of taxable profit, also taking into consideration the history of 
profitability in the combined UK banking entities and the fact that the loss arising in 2020 arose due to an identifiable and non-recurring 
reason, being the economic impacts of Covid-19.

Unrecognised deferred tax

The amount of gross temporary differences, unused tax losses and tax credits for which no deferred tax asset is recognised in the 
balance sheet was $15.6bn (2019: $9.9bn). This amount included unused UK corporation tax losses of $9.3bn (2019: $7.3bn) which were 
not recognised due to uncertainty regarding the availability of sufficient future taxable profits against which to recover them. Of the total 
amounts unrecognised, $11.5bn (2019: $7.4bn) had no expiry date, $0.7bn (2019: $1.3bn) was scheduled to expire within 10 years and 
the remaining balance is expected to expire after 10 years.

Deferred tax is not recognised in respect of the Group’s investments in subsidiaries and branches where HSBC is able to control the 
timing of remittance or other realisation and where remittance or realisation is not probable in the foreseeable future. The aggregate 
temporary differences relating to unrecognised deferred tax liabilities arising on investments in subsidiaries and branches is $12.1bn 
(2019: $13.4bn) and the corresponding unrecognised deferred tax liability was $0.7bn (2019: $1.0bn).

8

Dividends

Dividends to shareholders of the parent company

Dividends paid on ordinary shares

In respect of previous year:

–  fourth interim dividend

In respect of current year:

–  first interim dividend

–  second interim dividend

–  third interim dividend

Total
Total dividends on preference shares classified as 
equity (paid quarterly)

Total coupons on capital securities classified as 
equity 

Dividends to shareholders 

2020

Per
share

$

Total

$m

Settled
in scrip

$m

Per
share

$

2019

Total

$m

Settled
in scrip

$m

Per
share

$

2018

Total

$m

Settled 
in scrip

$m

—   

—   

—   

0.21   

4,206   

1,160   

0.21   

4,197   

393 

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

0.10   

0.10   

0.10   

0.51   

2,013   

2,021   

2,029   

375   

795   

357   

10,269   

2,687   

0.10   

0.10   

0.10   

0.51   

2,008   

1,990   

1,992   

213 

181 

707 

10,187   

1,494 

62.00   

90 

62.00   

90 

62.00   

90 

1,241 

1,331 

1,324 

11,683 

1,270 

11,547 

HSBC Holdings plc Annual Report and Accounts 2020 309

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Total coupons on capital securities classified as equity 

Perpetual subordinated capital securities

$2,200m issued at 8.125%

$3,800m issued at 8.000%

Perpetual subordinated contingent convertible securities

$1,500m issued at 5.625%

$2,000m issued at 6.875%

$2,250m issued at 6.375%

$2,450m issued at 6.375%

$3,000m issued at 6.000%

$2,350m issued at 6.250%

$1,800m issued at 6.500%

$1,500m issued at 4.600%

€1,500m issued at 5.250%

€1,000m issued at 6.000%

€1,250m issued at 4.750%

£1,000m issued at 5.875%

SGD1,000m issued at 4.700%

SGD750m issued at 5.000%

Total

2020

Footnotes

First call date Per security

1, 3

2, 3

4

Apr 2013  

Dec 2015  

$0.000   

$0.000   

Nov 2019  

$56.250   

Jun 2021  

$68.750   

Sep 2024  

$63.750   

Mar 2025  

$63.750   

May 2027  

$60.000   

Mar 2023  

$62.500   

Mar 2028  

$65.000   

5

Jun 2031  

$46.000   

Sep 2022  

€52.500   

Sep 2023  

€60.000   

€47.500   
July 2029  
£58.750   
Sep 2026  
Jun 2022   SGD47.000   

Sep 2023   SGD50.000   

Total

$m

—   
—   

—   

138   

143   

156   

180   

147   

117   
—   
90   

67   

67   

74   

35   

27   

2019

Total

$m

—   
—   

84   

138   

143   

156   

180   

147   

117   
—   

88   

66   

68   

75   

34   

28   

2018

Total

$m

89 

76 

84 

138 

143 

156 

180 

73 

59 
— 

95 

72 

70 

— 

35 

— 

1,241   

1,324   

1,270 

1 Discretionary coupons are paid quarterly on the perpetual subordinated capital securities, in denominations of $25 per security.
2 Discretionary coupons are paid semi-annually on the perpetual subordinated contingent convertible securities, in denominations of each 

security’s issuance currency 1,000 per security.
3 For further details of these securities, see Note 31.
4 This security was called by HSBC Holdings on 22 November 2019 and was redeemed and cancelled on 17 January 2020. Between the date of 
exercise of the call option and the redemption, this security was considered to be a subordinated liability. For further details on additional tier 1 
securities, see Note 31.

5 This security was issued by HSBC Holdings on 17 December 2020. The first call date commences six calendar months prior to the reset date of 

17 June 2031.

After the end of the year, the Directors approved an interim dividend in respect of the financial year ended 31 December 2020 of $0.15 
per ordinary share, a distribution of approximately $3,055m. The interim dividend will be payable on 29 April 2021 to holders on the 
Principal Register in the UK, the Hong Kong Overseas Branch Register or the Bermuda Overseas Branch Register on 12 March 2021. No 
liability was recorded in the financial statements in respect of the interim dividend for 2020.

On 4 January 2021, HSBC paid a coupon on its €1,250m subordinated capital securities, representing a total distribution of €30m 
($36m).  No liability was recorded in the balance sheet at 31 December 2020 in respect of this coupon payment.

9

Earnings per share

Basic earnings per ordinary share is calculated by dividing the profit attributable to ordinary shareholders of the parent company by the 
weighted average number of ordinary shares outstanding, excluding own shares held. Diluted earnings per ordinary share is calculated 
by dividing the basic earnings, which require no adjustment for the effects of dilutive potential ordinary shares, by the weighted average 
number of ordinary shares outstanding, excluding own shares held, plus the weighted average number of ordinary shares that would be 
issued on conversion of dilutive potential ordinary shares. 

Profit attributable to the ordinary shareholders of the parent company

Profit attributable to shareholders of the parent company

Dividend payable on preference shares classified as equity

Coupon payable on capital securities classified as equity

Year ended 31 Dec

Basic and diluted earnings per share

2020

$m
5,229   
(90)   
(1,241)   
3,898   

2019

$m

2018

$m

7,383   

13,727 

(90)   

(1,324)   

5,969   

(90) 

(1,029) 

12,608 

2020

Number 
of shares

Profit

Footnotes

$m

(millions)

Per
 share

$

2019

Number
of shares

Profit

$m

(millions)

Per
share

$

Profit

$m

2018

Number
of shares

(millions)

3,898   

20,169   

0.19   

5,969   

20,158   

0.30   

12,608   

19,896   

Per
share

$

0.63 

Basic

Effect of dilutive 
potential ordinary 
shares

Diluted

1

1

73 

75 

87 

3,898   

20,242   

0.19   

5,969   

20,233   

0.30   

12,608   

19,983   

0.63 

1 Weighted average number of ordinary shares outstanding (basic) or assuming dilution (diluted).

The number of anti-dilutive employee share options excluded from the weighted average number of dilutive potential ordinary shares is 
14.6 million (2019: 1.1 million; 2018: nil).

310 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
10 Segmental analysis

The Group Chief Executive, supported by the rest of the Group Executive Committee (‘GEC’), is considered the Chief Operating Decision 
Maker (‘CODM’) for the purposes of identifying the Group’s reportable segments. Global business results are assessed by the CODM on 
the basis of adjusted performance that removes the effects of significant items and currency translation from reported results. Therefore, 
we present these results on an adjusted basis as required by IFRSs. The 2019 and 2018 adjusted performance information is presented 
on a constant currency basis. The 2019 and 2018 income statements are converted at the average rates of exchange for 2020, and the 
balance sheets at 31 December 2019 and 31 December 2018 at the prevailing rates of exchange on 31 December 2020. 

Our operations are closely integrated and, accordingly, the presentation of data includes internal allocations of certain items of income 
and expense. These allocations include the costs of certain support services and global functions to the extent that they can be 
meaningfully attributed to global businesses. While such allocations have been made on a systematic and consistent basis, they 
necessarily involve a degree of subjectivity. Costs that are not allocated to global businesses are included in Corporate Centre.

Where relevant, income and expense amounts presented include the results of inter-segment funding along with inter-company and 
inter-business line transactions. All such transactions are undertaken on arm’s length terms. The intra-Group elimination items for the 
global businesses are presented in Corporate Centre.

Change in reportable segments 

Effective from the second quarter of 2020, we made the following realignments within our internal reporting to the GEC and CODM:

• We simplified our matrix organisational structure by combining Global Private Banking and Retail Banking and Wealth Management 

to form Wealth and Personal Banking. 

• We reallocated our reporting of Markets Treasury, hyperinflation accounting in Argentina and HSBC Holdings net interest expense 

from Corporate Centre to the global businesses. 

Comparative data have been re-presented accordingly. 

Our global businesses

We provide a comprehensive range of banking and related financial services to our customers in our three global businesses. The 
products and services offered to customers are organised by these global businesses.

• Wealth and Personal Banking (‘WPB’) provides a full range of retail banking and wealth products to our customers from personal 

banking to ultra high net worth individuals. Typically, customer offerings include retail banking products, such as current and savings 
accounts, mortgages and personal loans, credit cards, debit cards and local and international payment services. We also provide 
wealth management services, including insurance and investment products, global asset management services, investment 
management and Private Wealth Solutions for customers with more sophisticated and international requirements.

• Commercial Banking (‘CMB’) offers a broad range of products and services to serve the needs of our commercial customers, 

including small and medium-sized enterprises, mid-market enterprises and corporates. These include credit and lending, international 
trade and receivables finance, treasury management and liquidity solutions (payments and cash management and commercial cards), 
commercial insurance and investments. CMB also offers customers access to products and services offered by other global 
businesses, such as Global Banking and Markets, which include foreign exchange products, raising capital on debt and equity 
markets and advisory services.

• Global Banking and Markets (‘GBM’) provides tailored financial solutions to major government, corporate and institutional clients and 
private investors worldwide. The client-focused business lines deliver a full range of banking capabilities including financing, advisory 
and transaction services, a markets business that provides services in credit, rates, foreign exchange, equities, money markets and 
securities services, and principal investment activities.

HSBC adjusted profit before tax and balance sheet data

Net operating income/(expense) before change in expected credit 
losses and other credit impairment charges

1

22,013   

13,312   

15,303   

–  external

–  inter-segment

of which: net interest income/(expense)
Change in expected credit losses and other credit impairment (charges)/
recoveries

Net operating income/(expense)

Total operating expenses

Operating profit/(loss)

Share of profit in associates and joint ventures

Adjusted profit before tax

Share of HSBC’s adjusted profit before tax

Adjusted cost efficiency ratio 

Adjusted balance sheet data

Loans and advances to customers (net)

Interests in associates and joint ventures

Total external assets

Customer accounts

Wealth and 
Personal 
Banking

Commercial
Banking

2020

Global
Banking and
Markets

Corporate 
Centre

Footnotes

$m

$m

$m

$m

19,990   
2,023   
15,090   

(2,855)   

19,158   

(15,024)   

4,134   

6   

13,741   

18,162   

(429)   

9,317   

(4,754)   

8,558   

(6,689)   

1,869   

(1)   

(2,859)   

4,518   

(1,209)   

14,094   

(9,264)   

4,830   

—   

4,140   

1,868   

4,830   

%

 34.1 

 68.3 

$m

%

 15.4 

 50.2 

$m

%

 39.7 

 60.5 

$m

Total

$m

50,366 

50,366 

— 

27,599 

(262)   

(1,527)   

1,265   

(1,326)   

1   

(8,817) 

(261)   

(482)   

(743)   

2,054   

1,311   

%

 10.8 

 (184.0) 

$m

41,549 

(31,459) 

10,090 

2,059 

12,149 

%

 100.0 

 62.5 

$m

469,186   

343,182   

224,364   

1,255   

1,037,987 

447   

14   

143   

26,080   

26,684 

881,918   

570,295   

1,347,440   

184,511   

2,984,164 

834,759   

470,428   

336,983   

610   

1,642,780 

HSBC Holdings plc Annual Report and Accounts 2020 311

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC adjusted profit before tax and balance sheet data (continued)

Wealth and 
Personal 
Banking

Commercial
Banking

20192

Global
Banking and
Markets

Footnotes

$m

$m

$m

Net operating income/(expense) before change in expected credit losses 
and other credit impairment charges

1

–  external

–  inter-segment

of which: net interest income/(expense)

Change in expected credit losses and other credit impairment (charges)/
recoveries
Net operating income/(expense)

Total operating expenses

Operating profit/(loss)

Share of profit in associates and joint ventures

Adjusted profit before tax

Share of HSBC’s adjusted profit before tax

Adjusted cost efficiency ratio 

Adjusted balance sheet data

Loans and advances to customers (net)

Interests in associates and joint ventures

Total external assets

Customer accounts

25,565   

21,252   

4,313   

17,423   

(1,348)   

24,217   

(15,388)   

8,829   

54   

8,883   

%

 40.1 

 60.2 

$m

15,164   

16,094   

(930)   

10,957   

(1,162)   

14,002   

(6,832)   

7,170   

—   

7,170   

%

 32.4 

 45.1 

$m

14,869   

20,314   

(5,445)   

5,223   

(153)   

14,716   

(9,544)   

5,172   

—   

5,172   

%

 23.4 

 64.2 

$m

Corporate 
Centre

$m

(654)   

(2,716)   

2,062   

(3,264)   

36   

(618)   

(755)   

(1,373)   

2,297   

924   

%

 4.2 

 (115.4) 

$m

Total

$m

54,944 

54,944 

— 

30,339 

(2,627) 

52,317 

(32,519) 

19,798 

2,351 

22,149 

%

 100.0 

 59.2 

$m

455,618   

353,781   

252,131   

1,166   

1,062,696 

449   

793,100   

768,151   

14   

16   

24,941   

25,420 

523,585   

1,310,772   

156,354   

2,783,811 

397,182   

304,094   

780   

1,470,207 

1   Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2   A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly.

HSBC adjusted profit before tax and balance sheet data (continued)

Net operating income/(expense) before change in expected credit losses 
and other credit impairment charges

1

–  external

–  inter-segment

of which: net interest income/(expense)

Change in expected credit losses and other credit impairment (charges)/
recoveries

Net operating income/(expense)

Total operating expenses

Operating profit/(loss)

Share of profit in associates and joint ventures

Adjusted profit before tax

Share of HSBC’s adjusted profit before tax

Adjusted cost efficiency ratio 

Adjusted balance sheet data

Loans and advances to customers (net)

Interests in associates and joint ventures

Total external assets

Customer accounts

Wealth and 
Personal 
Banking

Commercial
Banking

20182

Global
Banking and
Markets

Footnotes

$m

$m

$m

23,551   

19,096   

4,455   

16,418   

(1,072)   

22,479   

(14,614)   

7,865   

32   

7,897   

%

 37.3 

 62.1 

$m

14,374   

14,675   

(301)   

10,220   

(683)   

13,691   

(6,307)   

7,384   

—   

7,384   

%

 34.8 

 43.9 

$m

15,056   

18,780   

(3,724)   

4,880   

34   

15,090   

(9,316)   

5,774   

—   

5,774   

%

 27.2 

 61.9 

$m

Corporate
Centre

$m

(883)   

(453)   

(430)   

Total

$m

52,098 

52,098 

— 

(2,070)   

29,448 

101   

(782)   

(1,486)   

(2,268)   

2,412   

144   

%

 0.7 

 (168.3) 

$m

(1,620) 

50,478 

(31,723) 

18,755 

2,444 

21,199 

%

 100.0 

 60.9 

$m

419,231   

344,855   

253,319   

1,599   

1,019,004 

399   

741,222   

729,902   

—   

—   

22,753   

23,152 

520,403   

1,261,807   

128,021   

2,651,453 

372,551   

306,438   

831   

1,409,722 

1    Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2  A change in reportable segments was made in 2020. Comparative data have been re-presented accordingly.

Reported external net operating income is attributed to countries and territories on the basis of the location of the branch responsible for 
reporting the results or advancing the funds:

Reported external net operating income by country/territory

–  UK

–  Hong Kong

–  US

–  France

–  other countries

Footnotes

1

2020

$m

50,429   

9,163   

15,783   

4,474   

1,753   

2019

$m

56,098   

9,011   

18,449   

4,471   

1,942   

19,256   

22,225   

2018

$m

53,780 

10,340 

17,162 

4,379 

1,898 

20,001 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

312 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Adjusted results reconciliation

2020

Significant

Adjusted

items Reported Adjusted

Footnotes

$m

$m

$m

$m

Revenue

ECL

1

  50,366   

63    50,429    54,944   

(8,817)   

—   

(8,817)   

(2,627)   

2019

2018

Currency
translation

Significant

 items Reported Adjusted

Currency
translation

Significant
items

Reported

$m

471   

(129)   

$m

$m

$m

$m

$m

$m

683    56,098    52,098   

1,854   

(172)    53,780 

—   

(2,756)   

(1,620)   

(147)   

—   

(1,767) 

Operating expenses

  (31,459)   

(2,973)    (34,432)    (32,519)   

(223)   

(9,607)    (42,349)    (31,723)   

(1,280)   

(1,656)    (34,659) 

Share of profit in associates 
and joint ventures 

  2,059   

(462)   

1,597    2,351   

3   

—   

2,354   

2,444   

92   

—   

2,536 

Profit/(loss) before tax

  12,149   

(3,372)   

8,777    22,149   

122   

(8,924)    13,347    21,199   

519   

(1,828)    19,890 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

Adjusted balance sheet reconciliation

2020

Reported and
adjusted

$m

Adjusted

$m

2019

Currency 
translation

Reported

Adjusted

2018

Currency 
translation

$m

$m

$m

$m

Loans and advances to customers (net)

1,037,987   

1,062,696   

(25,953)   

1,036,743   

1,019,004   

(37,308)   

Interests in associates and joint ventures

26,684   

25,420   

(946)   

24,474   

23,152   

(745)   

Reported

$m

981,696 

22,407 

Total external assets

Customer accounts

2,984,164   

2,783,811   

(68,659)   

2,715,152   

2,651,453   

(93,329)   

2,558,124 

1,642,780   

1,470,207   

(31,092)   

1,439,115   

1,409,722   

(47,079)   

1,362,643 

Adjusted profit reconciliation

Year ended 31 Dec

Adjusted profit before tax

Significant items

–  customer redress programmes (revenue)

–  disposals, acquisitions and investment in new businesses (revenue)

–  fair value movements on financial instruments

–  restructuring and other related costs (revenue) 

–  costs of structural reform

–  customer redress programmes (operating expenses)

–  disposals, acquisitions and investment in new businesses (operating expenses)

–  impairment of goodwill and other intangible assets

–  past service costs of guaranteed minimum pension benefits equalisation

–  restructuring and other related costs (operating expenses)

–  settlements and provisions in connection with legal and other regulatory matters

–  impairment of goodwill (share of profit in associates and joint ventures)

–  currency translation on significant items

Currency translation

Reported profit before tax

Footnotes

2020

$m

2019

$m

12,149   

(3,372)   

(21)   

(10)   

264   

(170)   

—   

54   

—   

22,149   

(8,924)   

(163)   

768   

84   

—   

(158)   

(1,281)   

—   

(1,090)   

(7,349)   

(17)   

(1,908)   

(12)   

(462)   

—   

(827)   

61   

—   

(59)   

122   

1

2

3

4

5

2018

$m

21,199 

(1,828) 

53 

(113) 

(100) 

— 

(361) 

(146) 

(52) 

— 

(228) 

(66) 

(816) 

— 

1 

519 

8,777   

13,347   

19,890 

Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives. 

1 
2  Comprises losses associated with the RWA reduction commitments and gains relating to the business update in February 2020.
3  Comprises costs associated with preparations for the UK’s exit from the European Union, costs to establish the UK ring-fenced bank (including 

4 

the UK ServCo group) and costs associated with establishing an intermediate holding company in Hong Kong. 
Includes impairment of software intangible assets of $189m (of the total software intangible asset impairment of $1,347m) and impairment of 
tangible assets of $197m.

5  During the year, The Saudi British Bank ('SABB'), an associate of HSBC, impaired the goodwill that arose following the merger with Alawwal 

bank in 2019. HSBC's post-tax share of the goodwill impairment was $462m.

11 Trading assets

Treasury and other eligible bills

Debt securities

Equity securities

Trading securities

Loans and advances to banks

Loans and advances to customers

Year ended 31 Dec

Footnotes

1

1

2020

$m

24,035   

102,846   

77,643   

204,524   

8,242   

19,224   

2019

$m

21,789 

126,043 

78,827 

226,659 

8,402 

19,210 

231,990   

254,271 

1  Loans and advances to banks and customers include reverse repos, stock borrowing and other accounts.

HSBC Holdings plc Annual Report and Accounts 2020 313

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Trading securities1

US Treasury and US Government agencies

UK Government 

Hong Kong Government 

Other governments 

Asset-backed securities

Corporate debt and other securities 

Equity securities 

At 31 Dec

Footnotes

2

3

2020

$m

17,393   

8,046   

6,500   

70,580   

4,253   

20,109   

77,643   

2019

$m

25,722 

10,040 

9,783 

72,456 

4,691 

25,140 

78,827 

204,524   

226,659 

1 Included within these figures are debt securities issued by banks and other financial institutions of $10,876m (2019: $17,846m), of which 

$1,298m (2019: $2,637m) are guaranteed by various governments.

2 Includes securities that are supported by an explicit guarantee issued by the US Government.
3 Excludes asset-backed securities included under US Treasury and US Government agencies.

12 Fair values of financial instruments carried at fair value

Control framework

Fair values are subject to a control framework designed to ensure that they are either determined or validated by a function independent 
of the risk taker.

Where fair values are determined by reference to externally quoted prices or observable pricing inputs to models, independent price 
determination or validation is used. For inactive markets, HSBC sources alternative market information, with greater weight given to 
information that is considered to be more relevant and reliable. Examples of the factors considered are price observability, instrument 
comparability, consistency of data sources, underlying data accuracy and timing of prices.

For fair values determined using valuation models, the control framework includes development or validation by independent support 
functions of the model logic, inputs, model outputs and adjustments. Valuation models are subject to a process of due diligence before 
becoming operational and are calibrated against external market data on an ongoing basis. 

Changes in fair value are generally subject to a profit and loss analysis process and are disaggregated into high-level categories 
including portfolio changes, market movements and other fair value adjustments.

The majority of financial instruments measured at fair value are in GBM. GBM’s fair value governance structure comprises its Finance 
function, Valuation Committees and a Valuation Committee Review Group. Finance is responsible for establishing procedures governing 
valuation and ensuring fair values are in compliance with accounting standards. The fair values are reviewed by the Valuation 
Committees, which consist of independent support functions. These committees are overseen by the Valuation Committee Review 
Group, which considers all material subjective valuations.

Financial liabilities measured at fair value

In certain circumstances, HSBC records its own debt in issue at fair value, based on quoted prices in an active market for the specific 
instrument. When quoted market prices are unavailable, the own debt in issue is valued using valuation techniques, the inputs for which 
are either based on quoted prices in an inactive market for the instrument or are estimated by comparison with quoted prices in an 
active market for similar instruments. In both cases, the fair value includes the effect of applying the credit spread that is appropriate to 
HSBC’s liabilities. The change in fair value of issued debt securities attributable to the Group’s own credit spread is computed as follows: 
for each security at each reporting date, an externally verifiable price is obtained or a price is derived using credit spreads for similar 
securities for the same issuer. Then, using discounted cash flow, each security is valued using a Libor-based discount curve. The 
difference in the valuations is attributable to the Group’s own credit spread. This methodology is applied consistently across all 
securities.

Structured notes issued and certain other hybrid instruments are included within trading liabilities and are measured at fair value. 
The credit spread applied to these instruments is derived from the spreads at which HSBC issues structured notes. 

Gains and losses arising from changes in the credit spread of liabilities issued by HSBC, recorded in other comprehensive income, 
reverse over the contractual life of the debt, provided that the debt is not repaid at a premium or a discount.

Fair value hierarchy

Fair values of financial assets and liabilities are determined according to the following hierarchy:

• Level 1 – valuation technique using quoted market price. These are financial instruments with quoted prices for identical instruments 

in active markets that HSBC can access at the measurement date.

• Level 2 – valuation technique using observable inputs. These are financial instruments with quoted prices for similar instruments in 

active markets or quoted prices for identical or similar instruments in inactive markets and financial instruments valued using models 
where all significant inputs are observable.

• Level 3 – valuation technique with significant unobservable inputs. These are financial instruments valued using valuation techniques 

where one or more significant inputs are unobservable.

314 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
Financial instruments carried at fair value and bases of valuation

2020

2019

Level 1

Level 2

Level 3

$m

$m

$m

Total

$m

Level 1

Level 2

Level 3

$m

$m

$m

Total

$m

Recurring fair value measurements at 31 Dec

Assets

Trading assets

Financial assets designated and otherwise mandatorily 
measured at fair value through profit or loss

Derivatives

Financial investments

Liabilities

Trading liabilities

  167,980   

61,511   

2,499    231,990   

186,653   

62,639   

4,979   

254,271 

19,711   

14,365   

11,477   

45,553   

18,626   

15,525   

9,476   

43,627 

2,602    302,454   

2,670    307,726   

1,728   

239,131   

2,136   

242,995 

  303,654   

94,746   

3,654    402,054   

261,341   

93,018   

3,218   

357,577 

53,290   

21,814   

162   

75,266   

66,925   

16,192   

53   

83,170 

Financial liabilities designated at fair value

1,267    150,866   

5,306    157,439   

9,549   

149,901   

5,016   

164,466 

Derivatives

1,788    297,025   

4,188    303,001   

1,331   

235,864   

2,302   

239,497 

Balances from 2019 have been re-presented to disclose a consistent application of the levelling methodology, primarily for private debt 
and equity and real estate investments during the period. This resulted in $15.1bn and $2.9bn moving into Levels 2 and 3, respectively, 
from Level 1. The change has impacted the disclosure for ‘Financial investments’ and ‘Financial assets designated and otherwise 
mandatorily measured at fair value’.

Transfers between Level 1 and Level 2 fair values

At 31 Dec 2020

Transfers from Level 1 to Level 2

Transfers from Level 2 to Level 1

At 31 Dec 2019

Transfers from Level 1 to Level 2

Transfers from Level 2 to Level 1

Financial
investments

$m

Trading
assets

$m

4,514   

7,764   

3,891   

5,517   

7,965   

4,184   

3,304   

2,726   

Assets

Designated and otherwise
mandatorily measured at 
fair value

Liabilities

Derivatives

Trading
liabilities

Designated
at fair value

Derivatives

$m

$m

$m

$m

$m

245   

328   

—   

673   

—   

1   

24   

111   

155   

433   

278   

220   

7,414   

—   

—   

—   

— 

— 

— 

117 

Balances from 2019 have been re-presented to disclose a consistent application of the levelling methodology.

Transfers between levels of the fair value hierarchy are deemed to occur at the end of each quarterly reporting period. Transfers into and 
out of levels of the fair value hierarchy are primarily attributable to observability of valuation inputs and price transparency.

Fair value adjustments

We adopt the use of fair value adjustments when we take into consideration additional factors not incorporated within the valuation 
model that would otherwise be considered by a market participant. We classify fair value adjustments as either ‘risk-related’ or ‘model-
related’. The majority of these adjustments relate to GBM. Movements in the level of fair value adjustments do not necessarily result in 
the recognition of profits or losses within the income statement. For example, as models are enhanced, fair value adjustments may no 
longer be required. Similarly, fair value adjustments will decrease when the related positions are unwound, but this may not result in 
profit or loss.

Global Banking and Markets fair value adjustments

2020

2019

GBM

$m

Corporate
Centre

$m

Type of adjustment

Risk-related 

–  bid-offer 

–  uncertainty 

–  credit valuation adjustment

–  debt valuation adjustment

–  funding fair value adjustment

–  other 

Model-related 

–  model limitation 

–  other 

Inception profit (Day 1 P&L reserves)

At 31 Dec

1,170   

514   

106   

445   

(120)   

204   

21   

74   

70   

4   

104   

1,348   

28   

—   

1   

27   

—   

—   

—   

—   

—   

—   

—   

28   

1,261   

GBM

$m

1,118   

506   

115   

355   

(126)   

241   

27   

71   

68   

3   

72   

Corporate
Centre

$m

47 

1 

1 

38 

— 

7 

— 

3 

3 

— 

— 

50 

We  reallocated  our  reporting  of  Markets  Treasury  and  the  funding  costs  of  HSBC  Holdings  debt  from  Corporate  Centre  to  the  global 
businesses. Comparative data have been re-presented accordingly.

Fair value adjustment changes were mainly driven by an increase in inception profit (Day 1 P&L reserves), and an increase in credit 
valuation adjustment (‘CVA’) due to widening credit spreads and changes to derivative exposures caused by interest rates moves.

HSBC Holdings plc Annual Report and Accounts 2020 315

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Notes on the financial statements

Bid-offer

IFRS 13 ‘Fair value measurement’ requires the use of the price within the bid-offer spread that is most representative of fair value. 
Valuation models will typically generate mid-market values. The bid-offer adjustment reflects the extent to which bid-offer costs would 
be incurred if substantially all residual net portfolio market risks were closed using available hedging instruments or by disposing of or 
unwinding the position.

Uncertainty

Certain model inputs may be less readily determinable from market data and/or the choice of model itself may be more subjective. 
In these circumstances, an adjustment may be necessary to reflect the likelihood that market participants would adopt more 
conservative values for uncertain parameters and/or model assumptions than those used in HSBC’s valuation model.

Credit and debt valuation adjustments 

The credit valuation adjustment (‘CVA’) is an adjustment to the valuation of over-the-counter (‘OTC’) derivative contracts to reflect the 
possibility that the counterparty may default and that HSBC may not receive the full market value of the transactions.

The debt valuation adjustment (‘DVA’) is an adjustment to the valuation of OTC derivative contracts to reflect the possibility that HSBC 
may default, and that it may not pay the full market value of the transactions. 

HSBC calculates a separate CVA and DVA for each legal entity, and for each counterparty to which the entity has exposure. With the 
exception of central clearing parties, all third-party counterparties are included in the CVA and DVA calculations, and these adjustments 
are not netted across Group entities. 

HSBC calculates the CVA by applying the probability of default (‘PD’) of the counterparty, conditional on the non-default of HSBC, 
to HSBC’s expected positive exposure to the counterparty and multiplying the result by the loss expected in the event of default. 
Conversely, HSBC calculates the DVA by applying the PD of HSBC, conditional on the non-default of the counterparty, to the expected 
positive exposure of the counterparty to HSBC and multiplying the result by the loss expected in the event of default. Both calculations 
are performed over the life of the potential exposure.

For most products HSBC uses a simulation methodology, which incorporates a range of potential exposures over the life of the portfolio, 
to calculate the expected positive exposure to a counterparty. The simulation methodology includes credit mitigants, such as 
counterparty netting agreements and collateral agreements with the counterparty.

The methodologies do not, in general, account for ‘wrong-way risk’. Wrong-way risk is an adverse correlation between the 
counterparty’s probability of default and the mark-to-market value of the underlying transaction. The risk can either be general, perhaps 
related to the currency of the issuer country, or specific to the transaction concerned. When there is significant wrong-way risk, a trade-
specific approach is applied to reflect this risk in the valuation.

Funding fair value adjustment

The funding fair value adjustment (‘FFVA’) is calculated by applying future market funding spreads to the expected future funding 
exposure of any uncollateralised component of the OTC derivative portfolio. The expected future funding exposure is calculated by a 
simulation methodology, where available, and is adjusted for events that may terminate the exposure, such as the default of HSBC or 
the counterparty. The FFVA and DVA are calculated independently.

Model limitation

Models used for portfolio valuation purposes may be based upon a simplified set of assumptions that do not capture all current and 
future material market characteristics. In these circumstances, model limitation adjustments are adopted.

Inception profit (Day 1 P&L reserves)

Inception profit adjustments are adopted when the fair value estimated by a valuation model is based on one or more significant 
unobservable inputs. The accounting for inception profit adjustments is discussed in Note 1.

316 HSBC Holdings plc Annual Report and Accounts 2020

Fair value valuation bases

Financial instruments measured at fair value using a valuation technique with significant unobservable inputs – Level 3

Assets

Designated 
and 
otherwise 
mandatorily 
measured at 
fair value 
through 
profit or 
loss

Derivatives

$m

$m

Financial 
investments

$m

Trading 
assets

$m

Liabilities

Total

$m

Trading 
liabilities

Designated 
at fair value

Derivatives

$m

$m

$m

Private equity including strategic 
investments 

Asset-backed securities 

Loans held for securitisation 

Structured notes 

Derivatives with monolines 

Other derivatives 

Other portfolios 

At 31 Dec 2020

Private equity including strategic 
investments 

Asset-backed securities 

Loans held for securitisation 

Structured notes 

Derivatives with monolines 

Other derivatives 

Other portfolios 

At 31 Dec 2019

930   

1,286   

—   

—   

—   

—   

523   

—   

—   

—   

—   

4   

10,971   

25   

—   

—   

—   

—   

481   

—   

—   

—   

—   

68   

11,905   

1,834   

—   

—   

68   

2,602   

—   

2,602   

3,891   

1,438   

3,654   

1,972   

2,499   

11,477   

2,670   

20,300   

716   

874   

—   

—   

—   

—   

4   

934   

1   

3   

—   

—   

8,831   

28   

39   

—   

—   

—   

1,628   

3,218   

4,037   

4,979   

578   

9,476   

—   

—   

—   

—   

66   

2,070   

—   

9,551   

1,836   

40   

3   

66   

2,070   

6,243   

2,136   

19,809   

4   

—   

—   

29   

—   

—   

129   

162   

4   

—   

—   

47   

—   

—   

2   

53   

—   

—   

—   

5,301   

—   

—   

5   

—   

—   

—   

—   

—   

4,187   

1   

5,306   

4,188   

—   

—   

—   

5,016   

—   

—   

—   

—   

—   

—   

—   

—   

2,302   

—   

Total

$m

4 

— 

— 

5,330 

— 

4,187 

135 

9,656 

4 

— 

— 

5,063 

— 

2,302 

2 

5,016   

2,302   

7,371 

Balances from 2019 have been re-presented to disclose a consistent application of the levelling methodology. This resulted in an 
increase of $2.9bn of assets in Level 3. ‘Other portfolios’ increased by $1.4bn and ‘Private equity including strategic investments’ 
increased by $1.5bn.

Level 3 instruments are present in both ongoing and legacy businesses. Loans held for securitisation, derivatives with monolines, certain 
‘other derivatives’ and predominantly all Level 3 ABSs are legacy positions. HSBC has the capability to hold these positions.

Private equity including strategic investments

The fair value of a private equity investment (including strategic investments) is estimated on the basis of an analysis of the investee’s 
financial position and results, risk profile, prospects and other factors; by reference to market valuations for similar entities quoted in an 
active market; the price at which similar companies have changed ownership; or from published net asset values (‘NAVs’) received. If 
necessary, adjustments are made to the NAV of funds to obtain the best estimate of fair value.

Asset-backed securities

While quoted market prices are generally used to determine the fair value of the asset-backed securities (‘ABSs’), valuation models are 
used to substantiate the reliability of the limited market data available and to identify whether any adjustments to quoted market prices 
are required. For certain ABSs, such as residential mortgage-backed securities, the valuation uses an industry standard model with 
assumptions relating to prepayment speeds, default rates and loss severity based on collateral type, and performance, as appropriate. 
The valuations output is benchmarked for consistency against observable data for securities of a similar nature.

Structured notes

The fair value of Level 3 structured notes is derived from the fair value of the underlying debt security, and the fair value of the 
embedded derivative is determined as described in the paragraph below on derivatives. These structured notes comprise principally 
equity-linked notes issued by HSBC, which provide the counterparty with a return linked to the performance of equity securities and 
other portfolios. 

Examples of the unobservable parameters include long-dated equity volatilities and correlations between equity prices, and interest and 
foreign exchange rates.

Derivatives

OTC derivative valuation models calculate the present value of expected future cash flows, based upon ‘no arbitrage’ principles. For 
many vanilla derivative products, the modelling approaches used are standard across the industry. For more complex derivative 
products, there may be some differences in market practice. Inputs to valuation models are determined from observable market data 
wherever possible, including prices available from exchanges, dealers, brokers or providers of consensus pricing. Certain inputs may not 
be observable in the market directly, but can be determined from observable prices via model calibration procedures or estimated from 
historical data or other sources.

HSBC Holdings plc Annual Report and Accounts 2020 317

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Notes on the financial statements

Reconciliation of fair value measurements in Level 3 of the fair value hierarchy

Movement in Level 3 financial instruments

Assets

Liabilities

At 1 Jan 2020

3,218   

4,979   

Financial 
investments

Footnotes

$m

Trading 
assets

$m

Designated 
and otherwise 
mandatorily 
measured at 
fair value 
through profit 
or loss

Derivatives

Trading 
liabilities

Designated 
at fair value

Derivatives

$m

$m

9,476   

504   

2,136   

2,281   

$m

53   

307   

$m

5,016   

(59)   

$m

2,302 

3,398 

—   

2,281   

307   

—   

3,398 

504   

—   

—   

286   

—   

286   

3,701   

1   

(2,042)   

(435)   

(140)   

126   

—   

—   

—   

143   

—   

143   

—   

—   

—   

(1,542)   

(565)   

217   

—   

—   

—   

17   

—   

17   

66   

6   

(260)   

(26)   

(9)   

8   

(59)   

—   

—   

204   

—   

204   

—   

1,876   

—   

— 

— 

— 

169 

— 

169 

— 

— 

— 

(1,531)   

(1,462) 

(777)   

577   

(528) 

309 

11,477   

2,670   

162   

5,306   

4,188 

(6)   

(6)   

—   

—   

—   

115   

—   

115   

687   

—   

(1,579)   

(1,122)   

(1,790)   

1,215   

2,499   

(32)   

412   

707   

(32)   

—   

707   

—   

—   

412   

—   

—   

—   

1   

1   

—   

—   

(91)   

(1,621) 

—   

(1,621) 

(91)   

—   

— 

— 

Total gains/(losses) recognised in profit or loss 

–  net income/(losses) from financial instruments 

held for trading or managed on a fair value basis

–  changes in fair value of other financial 

instruments mandatorily measured at fair value 
through profit or loss

–  gains less losses from financial investments at 
fair value through other comprehensive income

–  expected credit loss charges and other credit risk 

charges

Total gains recognised in other comprehensive 
income (‘OCI’)

1

–  financial investments: fair value gains

–  exchange differences 

Purchases 

New issuances 

Sales 

Settlements 

Transfers out 

Transfers in 

At 31 Dec 2020

Unrealised gains/(losses) recognised in profit or 
loss relating to assets and liabilities held at 31 Dec 
2020

–  net income/(losses) from financial instruments 

held for trading or managed on a fair value basis

–  changes in fair value of other financial 

instruments mandatorily measured at fair value 
through profit or loss

–  loan impairment recoveries and other credit risk 

provisions

17   

—   

—   

17   

—   

394   

270   

124   

671   

—   

(674)   

(530)   

(101)   

659   

3,654   

—   

—   

—   

—   

318 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Movement in Level 3 financial instruments (continued)

Assets

Liabilities

Designated 
and otherwise 
mandatorily 
measured at 
fair value 
through profit 
or loss

Financial 

investments Trading assets

Derivatives

Trading 
liabilities

Designated at 
fair value

Derivatives

Footnotes

$m

2,796   

6   

$m

6,759   

(112)   

$m

$m

7,080   

2,423   

587   

278   

$m

58   

(4)   

$m

5,328   

195   

$m

1,756 

930 

At 1 Jan 2019

Total gains/(losses) recognised in profit or loss 

–  net income/(losses) from financial instruments 
held for trading or managed on a fair value 
basis

–  changes in fair value of other financial 

instruments mandatorily measured at fair value 
through profit or loss

–  gains less losses from financial investments at 

fair value through other comprehensive 
income

–  expected credit loss charges and other credit 

risk charges

Total gains/(losses) recognised in other 
comprehensive income (‘OCI’) 

–  financial investments: fair value gains

–  exchange differences 

1

Purchases 

New issuances 

Sales 

Settlements 

Transfers out 

Transfers in 

At 31 Dec 2019

Unrealised gains/(losses) recognised in profit or 
loss relating to assets and liabilities held at 
31 Dec 2019
–  net income/(losses) from financial instruments 
held for trading or managed on a fair value 
basis

–  changes in fair value of other financial 

instruments mandatorily measured at fair value 
through profit or loss

–  loan impairment recoveries and other credit 

risk provisions 

—   

(112)   

—   

278   

(4)   

—   

930 

—   

—   

587   

—   

—   

195   

10   

(4)   

309   

301   

8   

693   

—   

(56)   

(329)   

(488)   

287   

3,218   

—   

—   

76   

—   

76   

2,206   

154   

(895)   

(2,107)   

(1,558)   

456   

4,979   

—   

—   

(4)   

—   

(4)   

2,506   

—   

(276)   

(434)   

(23)   

40   

—   

—   

49   

—   

49   

—   

—   

—   

(100)   

(710)   

196   

9,476   

2,136   

—   

—   

1   

—   

1   

8   

6   

(9)   

(7)   

(9)   

9   

53   

—   

—   

18   

—   

18   

157   

1,601   

(193)   

(1,048)   

(1,079)   

37   

5,016   

— 

— 

— 

52 

— 

52 

— 

— 

— 

(162) 

(473) 

199 

2,302 

(4)   

(22)   

465   

279   

—   

57   

(407) 

—   

(22)   

—   

279   

—   

—   

(407) 

—   

(4)   

—   

—   

465   

—   

—   

—   

—   

—   

57   

—   

— 

— 

1 

Included in ‘financial investments: fair value gains/(losses)’ in the current year and ‘exchange differences’ in the consolidated statement of 
comprehensive income.

Balances from 2019 have been re-presented to disclose a consistent application of the levelling methodology. The result of this is an 
increase of $2.9bn of assets in Level 3. ‘Financial investments’ increased by $1.2bn and ‘Private equity including strategic investments 
financial assets designated and otherwise mandatorily measured at fair value’ increased by $1.7bn.

Transfers between levels of the fair value hierarchy are deemed to occur at the end of each quarterly reporting period. Transfers into and 
out of levels of the fair value hierarchy are primarily attributable to observability of valuation inputs and price transparency. 

Effect of changes in significant unobservable assumptions to reasonably possible alternatives

Sensitivity of fair values to reasonably possible alternative assumptions

Reflected in profit or loss

Reflected in OCI

Reflected in profit or loss

Reflected in OCI

2020

2019

Derivatives, trading assets and 
trading liabilities 

Financial assets and liabilities 
designated and otherwise 
mandatorily measured at fair value 
through profit or loss

Financial investments

At 31 Dec

Favourable
changes
$m

Un-
favourable
changes
$m

Favourable
changes
$m

Un-
favourable
changes
$m

Favourable
changes
$m

Un-
favourable
changes
$m

Favourable
changes
$m

Footnotes

1

229   

(244)   

—   

—   

255   

(230)   

—   

644   

35   

908   

(643)   

(35)   

(922)   

—   

110   

110   

—   

(110)   

(110)   

618   

48   

921   

(503)   

(53)   

(786)   

—   

81   

81   

Un-
favourable
changes

$m

— 

— 

(81) 

(81) 

1 

‘Derivatives, trading assets and trading liabilities’ are presented as one category to reflect the manner in which these instruments are risk-
managed. 

HSBC Holdings plc Annual Report and Accounts 2020 319

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Balances from 2019 have been re-presented to disclose a consistent application of the levelling methodology. The result of this is an 
increase in ‘Financial investments reflected through OCI’ and ‘Financial asset designated and mandatorily measured at fair value 
reflected in profit or loss’ of $59m and $86m respectively.

The sensitivity analysis aims to measure a range of fair values consistent with the application of a 95% confidence interval. 
Methodologies take account of the nature of the valuation technique employed, as well as the availability and reliability of observable 
proxy and historical data.

When the fair value of a financial instrument is affected by more than one unobservable assumption, the above table reflects the most 
favourable or the most unfavourable change from varying the assumptions individually.

Key unobservable inputs to Level 3 financial instruments

The following table lists key unobservable inputs to Level 3 financial instruments and provides the range of those inputs at 31 December 
2020.

Quantitative information about significant unobservable inputs in Level 3 valuations 

Private equity including strategic 
investments 

Asset-backed securities 

Fair value

Assets Liabilities

$m

$m

Valuation
techniques

  11,905   

  1,834   

4  See below

— 

2020

Full range
of inputs

2019

Full range
of inputs

Lower Higher

Lower

Higher

Key unobservable
inputs

See below

–  collateralised loan/debt obligation

59  

— 

Market proxy 

Prepayment rate  

–  other ABSs 

Loans held for securitisation
Structured notes 

–  equity-linked notes 

–  FX-linked notes 

–  other 
Derivatives with monolines 

Other derivatives 

–  interest rate derivatives

   securitisation swaps 

   long-dated swaptions 

   other 

–  FX derivatives

   FX options 

   other 

–  equity derivatives

   long-dated single stock options 

   other 

–  credit derivatives

   other 

Other portfolios 

–  structured certificates

–  repurchase agreements
–  other1

At 31 Dec 2020

0%

0

0

5%

9%

1%

0%

6%

8%

9%

100

101

90%

93%

23%

2%

7%

22%

  1,775   

—   

Market proxy 
—  Market proxy
— 

Bid quotes 

Bid quotes

—    5,330 

—    4,069 

—   

—   

68   

Model – Option model 

Equity volatility 

Model – Option model 
608  Model – Option model 
653 

Equity correlation 

FX volatility 

—  Model – Discounted cash flow

Credit spread 

2%

2%

0%

0

0

9%

100

101

6% 115%

(4)%

0%

88%

36%

  2,602    4,187   
  1,300    1,414   

285   

529   

486   

468   

152   

316   

707  Model – Discounted cash flow
370  Model – Option model 
337 

466 
194  Model – Option model 
272 

754    2,244 
583    1,091  Model – Option model 
171    1,153 

Prepayment rate 

IR volatility 

6%

6%

6%

28%

FX volatility

0%

43%

1%

25%

Equity volatility

0% 120%

0%

89%

80   

80   
  3,891   

—   

872   
  3,019   

63 

63 
135 

—  Model – Discounted cash flow
128  Model – Discounted cash flow

Credit volatility  

IR curve

—

0%

—

5%

4%

1%

4%

8%

7 

  20,300    9,656 

1 

‘Other’ includes a range of smaller asset holdings.

Private equity including strategic investments

Given the bespoke nature of the analysis in respect of each private equity holding, it is not practical to quote a range of key 
unobservable inputs.

Prepayment rates

Prepayment rates are a measure of the anticipated future speed at which a loan portfolio will be repaid in advance of the due date. They 
vary according to the nature of the loan portfolio and expectations of future market conditions, and may be estimated using a variety of 
evidence, such as prepayment rates implied from proxy observable security prices, current or historical prepayment rates and 
macroeconomic modelling.

Market proxy

Market proxy pricing may be used for an instrument when specific market pricing is not available but there is evidence from instruments 
with common characteristics. In some cases it might be possible to identify a specific proxy, but more generally evidence across a wider 
range of instruments will be used to understand the factors that influence current market pricing and the manner of that influence.

Volatility

Volatility is a measure of the anticipated future variability of a market price. It varies by underlying reference market price, and by strike 
and maturity of the option. Certain volatilities, typically those of a longer-dated nature, are unobservable and are estimated from 
observable data. The range of unobservable volatilities reflects the wide variation in volatility inputs by reference market price. The core 
range is significantly narrower than the full range because these examples with extreme volatilities occur relatively rarely within the 
HSBC portfolio.

320 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Correlation

Correlation is a measure of the inter-relationship between two market prices and is expressed as a number between minus one and one. 
It is used to value more complex instruments where the payout is dependent upon more than one market price. There is a wide range of 
instruments for which correlation is an input, and consequently a wide range of both same-asset correlations and cross-asset 
correlations is used. In general, the range of same-asset correlations will be narrower than the range of cross-asset correlations.

Unobservable correlations may be estimated based upon a range of evidence, including consensus pricing services, HSBC trade prices, 
proxy correlations and examination of historical price relationships. The range of unobservable correlations quoted in the table reflects 
the wide variation in correlation inputs by market price pair.

Credit spread

Credit spread is the premium over a benchmark interest rate required by the market to accept lower credit quality. In a discounted cash 
flow model, the credit spread increases the discount factors applied to future cash flows, thereby reducing the value of an asset. Credit 
spreads may be implied from market prices and may not be observable in more illiquid markets.

Inter-relationships between key unobservable inputs

Key unobservable inputs to Level 3 financial instruments may not be independent of each other. As described above, market variables 
may be correlated. This correlation typically reflects the manner in which different markets tend to react to macroeconomic or other 
events. Furthermore, the effect of changing market variables on the HSBC portfolio will depend on HSBC’s net risk position in respect of 
each variable.

HSBC Holdings

Basis of valuing HSBC Holdings’ financial assets and liabilities measured at fair value

Valuation technique using observable inputs: Level 2

Assets at 31 Dec

–  derivatives 

–  designated and otherwise mandatorily measured at fair value through profit or loss

Liabilities at 31 Dec

–  designated at fair value 

–  derivatives 

13 Fair values of financial instruments not carried at fair value

Fair values of financial instruments not carried at fair value and bases of valuation

2020

$m

2019

$m

4,698   

65,253   

25,664   

3,060   

2,002 

61,964 

30,303 

2,021 

At 31 Dec 2020

Assets

Loans and advances to banks

Loans and advances to customers

Reverse repurchase agreements – non-trading

Financial investments – at amortised cost

Liabilities

Deposits by banks

Customer accounts

Repurchase agreements – non-trading

Debt securities in issue

Subordinated liabilities

At 31 Dec 2019

Assets

Loans and advances to banks

Loans and advances to customers

Reverse repurchase agreements – non-trading

Financial investments – at amortised cost

Liabilities

Deposits by banks

Customer accounts

Repurchase agreements – non-trading

Debt securities in issue

Subordinated liabilities

Carrying
amount

$m

81,616   

1,037,987   

230,628   

88,639   

82,080   

1,642,780   

111,901   

95,492   

21,951   

69,203   

1,036,743   

240,862   

85,735   

59,022   

1,439,115   

140,344   

104,555   

24,600   

Fair value

Quoted market
price Level 1

Observable
inputs Level 2

Significant
unobservable
inputs Level 3

$m

$m

$m

Total

$m

—   

—   

—   

28,722   

—   

—   

3   

—   

—   

—   

—   

16   

26,202   

—   

—   

—   

—   

—   

80,457   

9,888   

230,330   

67,572   

81,996   

1,642,988   

111,898   

96,371   

28,552   

68,508   

10,365   

240,199   

62,572   

58,951   

1,439,362   

140,344   

104,936   

28,861   

1,339   

81,796 

1,025,573   

1,035,461 

272   

507   

—   

143   

—   

657   

—   

739   

1,027,178   

691   

287   

—   

150   

—   

—   

385   

230,602 

96,801 

81,996 

1,643,131 

111,901 

97,028 

28,552 

69,247 

1,037,543 

240,906 

89,061 

58,951 

1,439,512 

140,344 

104,936 

29,246 

Other financial instruments not carried at fair value are typically short term in nature and reprice to current market rates frequently. 
Accordingly, their carrying amount is a reasonable approximation of fair value. They include cash and balances at central banks, items in 
the course of collection from and transmission to other banks, Hong Kong Government certificates of indebtedness and Hong Kong 
currency notes in circulation, all of which are measured at amortised cost.

HSBC Holdings plc Annual Report and Accounts 2020 321

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Valuation

Fair value is an estimate of the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction 
between market participants at the measurement date. It does not reflect the economic benefits and costs that HSBC expects to flow 
from an instrument’s cash flow over its expected future life. Our valuation methodologies and assumptions in determining fair values for 
which no observable market prices are available may differ from those of other companies.

Loans and advances to banks and customers

To determine the fair value of loans and advances to banks and customers, loans are segregated, as far as possible, into portfolios of 
similar characteristics. Fair values are based on observable market transactions, when available. When they are unavailable, fair values 
are estimated using valuation models incorporating a range of input assumptions. These assumptions may include: value estimates from 
third-party brokers reflecting over-the-counter trading activity; forward-looking discounted cash flow models, taking account of expected 
customer prepayment rates, using assumptions that HSBC believes are consistent with those that would be used by market participants 
in valuing such loans; new business rates estimates for similar loans; and trading inputs from other market participants including 
observed primary and secondary trades. From time to time, we may engage a third-party valuation specialist to measure the fair value of 
a pool of loans.

The fair value of loans reflects expected credit losses at the balance sheet date and estimates of market participants’ expectations of 
credit losses over the life of the loans, and the fair value effect of repricing between origination and the balance sheet date. For credit-
impaired loans, fair value is estimated by discounting the future cash flows over the time period they are expected to be recovered.

Financial investments

The fair values of listed financial investments are determined using bid market prices. The fair values of unlisted financial investments 
are determined using valuation techniques that incorporate the prices and future earnings streams of equivalent quoted securities.

Deposits by banks and customer accounts

The fair values of on-demand deposits are approximated by their carrying value. For deposits with longer-term maturities, fair values are 
estimated using discounted cash flows, applying current rates offered for deposits of similar remaining maturities.

Debt securities in issue and subordinated liabilities

Fair values in debt securities in issue and subordinated liabilities are determined using quoted market prices at the balance sheet date 
where available, or by reference to quoted market prices for similar instruments.

Repurchase and reverse repurchase agreements – non-trading

Fair values of repurchase and reverse repurchase agreements that are held on a non-trading basis provide approximate carrying 
amounts. This is due to the fact that balances are generally short dated.

HSBC Holdings

The methods used by HSBC Holdings to determine fair values of financial instruments for the purposes of measurement and disclosure 
are described above.

Fair values of HSBC Holdings’ financial instruments not carried at fair value on the balance sheet

Assets at 31 Dec

Loans and advances to HSBC undertakings 

Financial investments – at amortised cost

Liabilities at 31 Dec

Amounts owed to HSBC undertakings 

Debt securities in issue 

Subordinated liabilities 

2020

2019

Carrying amount

Fair value1

Carrying amount

Fair value1

$m

$m

$m

$m

10,443   

17,485   

330   

64,029   

17,916   

10,702   
17,521   

330   
67,706   
22,431   

10,218   

16,106   

464   

56,844   

18,361   

10,504 

16,121 

464 

59,140 

22,536 

1  Fair values (other than Level 1 financial investments) were determined using valuation techniques with observable inputs (Level 2).

14 Financial assets designated and otherwise mandatorily measured at fair value through profit

or loss

Securities

–  treasury and other eligible bills

–  debt securities 

–  equity securities 

Loans and advances to banks and 
customers

Other

At 31 Dec

2020

Designated at 
fair value

Mandatorily 
measured at fair 
value

$m

2,492   

635   

1,857   

—   

—   

—   

2,492   

$m

39,088   

26   

5,250   

33,812   

2,988   

985   

43,061   

Designated at fair 
value

2019

Mandatorily 
measured at fair 
value

$m

2,344   

630   

1,714   

—   

1   

—   

2,345   

$m

35,808   

31   

4,838   

30,939   

4,555   

919   

41,282   

Total

$m
41,580   
661   
7,107   
33,812   

2,988   
985   
45,553   

Total

$m

38,152 

661 

6,552 

30,939 

4,556 

919 

43,627 

322 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Securities1

Hong Kong Government 

Other governments 

Asset-backed securities

Corporate debt and other securities 

Equities 

At 31 Dec

Footnotes

2

2020

Designated at 
fair value

Mandatorily 
measured at fair 
value

$m

22   

648   

—   

1,822   

—   

2,492   

$m

—   

674   

235   

4,367   

33,812   

39,088   

Designated at fair 
value

2019

Mandatorily 
measured at fair 
value

$m

4   

666   

—   

1,674   

—   

2,344   

$m

—   

754   

363   

3,752   

30,939   

35,808   

Total

$m
22   
1,322   
235   
6,189   
33,812   
41,580   

Total

$m

4 

1,420 

363 

5,426 

30,939 

38,152 

1 

Included within these figures are debt securities issued by banks and other financial institutions of $1,180m (2019 re-presented: $1,244m), of 
which nil (2019: nil) are guaranteed by various governments.

2  Excludes asset-backed securities included under US Treasury and US Government agencies.

15 Derivatives

Notional contract amounts and fair values of derivatives by product contract type held by HSBC

Notional contract amount

Fair value – Assets

Trading

Hedging

Trading

Hedging

$m

$m

$m

$m

Total

$m

Foreign exchange 

Interest rate 

Equities 

Credit 

Commodity and other 

7,606,446   

35,021   

106,696   

309   

107,005   

108,903   

  15,240,867   

157,436   

249,204   

1,914   

251,118   

236,594   

652,288   

269,401   

120,259   

—   

—   

—   

14,043   

2,590   

2,073   

—   

—   

—   

14,043   

15,766   

2,590   

2,073   

3,682   

3,090   

Fair value – Liabilities

Trading

Hedging

$m

$m

1,182   

2,887   

—   

—   

—   

Total

$m

110,085 

239,481 

15,766 

3,682 

3,090 

Gross total fair values

  23,889,261   

192,457   

374,606   

2,223   

376,829   

368,035   

4,069   

372,104 

Offset (Note 30)

At 31 Dec 2020

Foreign exchange 

Interest rate 

Equities 

Credit 

Commodity and other 

Gross total fair values

Offset (Note 30)

At 31 Dec 2019

  23,889,261   

192,457   

374,606   

2,223   

307,726   

368,035   

4,069   

303,001 

(69,103) 

(69,103) 

8,207,629   

31,899   

84,083   

17,895,349   

177,006   

183,668   

455   

1,208   

84,538   

84,498   

184,876   

175,095   

1,077,347   

345,644   

93,245   

—   

—   

—   

9,053   

4,744   

1,523   

—   

—   

—   

9,053   

4,744   

1,523   

11,237   

5,597   

2,038   

740   

2,031   

—   

—   

—   

27,619,214   

208,905   

283,071   

1,663   

284,734   

278,465   

2,771   

27,619,214   

208,905   

283,071   

1,663   

242,995   

278,465   

2,771   

(41,739) 

85,238 

177,126 

11,237 

5,597 

2,038 

281,236 

(41,739) 

239,497 

The notional contract amounts of derivatives held for trading purposes and derivatives designated in hedge accounting relationships 
indicate the nominal value of transactions outstanding at the balance sheet date. They do not represent amounts at risk.

Derivative assets and liabilities increased during 2020, driven by yield curve movements and changes in foreign exchange rates.

Notional contract amounts and fair values of derivatives by product contract type held by HSBC Holdings with subsidiaries

Notional contract amount

Assets

Trading

Hedging

Trading

Hedging

$m

23,413   

47,569   

70,982   

24,980   

48,937   

73,917   

$m

—   

34,006   

34,006   

—   

36,769   

36,769   

$m

506   

966   

1,472   

161   

435   

596   

$m

—   

3,221   

3,221   

—   

1,406   

1,406   

Total

$m

506   

4,187   

4,693   

161   

1,841   

2,002   

Liabilities

Trading

Hedging

$m

870   

2,176   

3,046   

766   

1,072   

1,838   

$m

—   

8   

8   

—   

183   

183   

Total

$m

870 

2,184 

3,054 

766 

1,255 

2,021 

Foreign exchange 

Interest rate 

At 31 Dec 2020

Foreign exchange 

Interest rate 

At 31 Dec 2019

Use of derivatives

For details regarding the use of derivatives, see page 186 under ‘Market risk’.

Trading derivatives

Most of HSBC’s derivative transactions relate to sales and trading activities. Sales activities include the structuring and marketing of 
derivative products to customers to enable them to take, transfer, modify or reduce current or expected risks. Trading activities include 
market-making and risk management. Market-making entails quoting bid and offer prices to other market participants for the purpose of 
generating revenue based on spread and volume. Risk management activity is undertaken to manage the risk arising from client 
transactions, with the principal purpose of retaining client margin. Other derivatives classified as held for trading include non-qualifying 
hedging derivatives.

Substantially all of HSBC Holdings’ derivatives entered into with subsidiaries are managed in conjunction with financial liabilities 
designated at fair value.

HSBC Holdings plc Annual Report and Accounts 2020 323

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Derivatives valued using models with unobservable inputs

The difference between the fair value at initial recognition (the transaction price) and the value that would have been derived had 
valuation techniques used for subsequent measurement been applied at initial recognition, less subsequent releases, is as shown in the 
following table:

Unamortised balance of derivatives valued using models with significant unobservable inputs

Unamortised balance at 1 Jan

Deferral on new transactions 

Recognised in the income statement during the year:

–  amortisation

–  subsequent to unobservable inputs becoming observable 

–  maturity, termination or offsetting derivative 

Exchange differences 

Other

Unamortised balance at 31 Dec

1 This amount is yet to be recognised in the consolidated income statement. 

Hedge accounting derivatives

Footnotes

1

2020

$m
73   
232   
(205)   
(116)   
(4)   
(85)   
4   
—   
104   

2019

$m

86 

145 

(154) 

(80) 

(3) 

(71) 

1 

(5) 

73 

HSBC applies hedge accounting to manage the following risks: interest rate, foreign exchange and net investment in foreign operations.  
Further details on how these risks arise and how they are managed by the Group can be found in the ‘Risk review’.

Fair value hedges

HSBC enters into fixed-for-floating-interest-rate swaps to manage the exposure to changes in fair value caused by movements in market 
interest rates on certain fixed-rate financial instruments that are not measured at fair value through profit or loss, including debt 
securities held and issued.

HSBC hedging instrument by hedged risk

Hedged risk
Interest rate3
At 31 Dec 2020

Interest rate3
At 31 Dec 2019

Notional amount1

$m

121,573   

121,573   

122,753   

122,753   

Hedging instrument

Carrying amount

Assets

$m

1,675   

1,675   

1,056   

1,056   

Liabilities

$m

3,761 

3,761 

2,208 

2,208 

Balance sheet 
presentation

Derivatives  

Derivatives  

Change in fair value2

$m

(1,894) 

(1,894) 

(1,531) 

(1,531) 

1 The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions 

outstanding at the balance sheet date. They do not represent amounts at risk.

2 Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3 The hedged risk ‘interest rate’ includes inflation risk.

HSBC hedged item by hedged risk

Carrying amount

Accumulated fair value hedge adjustments included in 
carrying amount2

Assets

Liabilities

Assets

Liabilities

Change in fair 
value1

Recognised 
in profit and 
loss

Hedged risk

$m

$m

$m

$m

Balance sheet presentation

$m

$m

Profit and loss 
presentation

Hedged item

Ineffectiveness

Interest rate3

  102,260 

3,392 

6 

2,280 

12,148 

89 

3 

56 

Financial assets designated 
and otherwise mandatorily 
measured at fair value 
through other 
comprehensive income  

2,456 

Loans and advances to 

banks  

1 

(11) 

Loans and advances to 

customers  

1,620 

Debt securities in issue  

3 

Deposits by banks  

21 

(613) 

18 

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

At 31 Dec 2020

  104,546   

12,237   

3,451   

1,623 

1,883   

(11) 

324 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC hedged item by hedged risk (continued)

Hedged item

Ineffectiveness

Carrying amount

Accumulated fair value hedge adjustments included in 
carrying amount2

Assets

Liabilities

Assets

Liabilities

Change in fair 
value1

Recognised in 
profit and loss

Hedged risk

$m

$m

$m

$m

Balance sheet presentation

$m

$m

90,617 

1,859 

other comprehensive income  

2,304 

Financial assets designated and 
otherwise mandatorily 
measured at fair value through 

Interest rate3

153 

1,897 

4 

12 

15,206 

3,009 

At 31 Dec 2019

92,667   

18,215   

1,875   

Loans and advances to banks  

Loans and advances to 

customers  

Debt securities in issue  

Deposits by banks  

797 

39 

836 

5 

24 

(1,011) 

202 

1,524   

(7) 

(7) 

Profit and loss 
presentation

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

1 Used in effectiveness testing; comprising amount attributable to the designated hedged risk that can be a risk component.
2 The accumulated amount of fair value adjustments remaining in the statement of financial position for hedged items that have ceased to be 

adjusted for hedging gains and losses were assets of $855m for FVOCI and assets of $17m for debt issued.

3 The hedged risk ‘interest rate’ includes inflation risk.

HSBC Holdings hedging instrument by hedged risk

Hedged risk
Interest rate3
At 31 Dec 2020

Interest rate3
At 31 Dec 2019

Notional amount1,4

$m

34,006   

34,006   

36,769   

36,769   

Hedging instrument

Carrying amount

Assets

$m

3,221   

3,221   

1,406   

1,406   

Liabilities

$m

8 

8 

183 

183 

Balance sheet 
presentation

Derivatives  

Derivatives  

Change in fair value2

$m

1,927 

1,927 

1,704 

1,704 

1 The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions 

outstanding at the balance sheet date; they do not represent amounts at risk.

2 Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3 The hedged risk ‘interest rate’ includes foreign exchange risk.
4 The notional amount of non-dynamic fair value hedges is equal to $34,006m, of which the weighted-average maturity date is February 2028 and 

the weighted-average swap rate is 1.71%. The majority of these hedges are internal to the Group. 

HSBC Holdings hedged item by hedged risk

Hedged item

Accumulated fair value 
hedge adjustments included 
in carrying amount2
Liabilities

Assets

Carrying amount

Assets

Liabilities

Hedged risk

$m

$m

$m

$m

Balance sheet 
presentation

Change in fair 
value1

Recognised in
profit and loss

$m

$m

Interest rate3

At 31 Dec 2020

—   

37,338   

—   

37,338 

Interest rate3

At 31 Dec 2019

—   

38,126   

—   

38,126 

Debt 
securities

in issue  

Debt securities

in issue  

3,027 

3,027 

1,088 

1,088 

(1,910)   
(1,910)   

(1,697)   

(1,697)   

17 
17 

7 

7 

Ineffectiveness

Profit and loss
presentation

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

Net income from financial 
instruments held for 
trading or managed on a 
fair value basis

1 Used in effectiveness testing; comprising amount attributable to the designated hedged risk that can be a risk component.
2 The accumulated amount of fair value adjustments remaining in the statement of financial position for hedged items that have ceased to be 

adjusted for hedging gains and losses were liabilities of $62.8m for debt issued.

3 The hedged risk ‘interest rate’ includes foreign exchange risk.

Sources of hedge ineffectiveness may arise from basis risk, including but not limited to the discount rates used for calculating the fair 
value of derivatives, hedges using instruments with a non-zero fair value, and notional and timing differences between the hedged items 
and hedging instruments. 

For some debt securities held, HSBC manages interest rate risk in a dynamic risk management strategy. The assets in scope of this 
strategy are high-quality fixed-rate debt securities, which may be sold to meet liquidity and funding requirements.

The interest rate risk of the HSBC fixed-rate debt securities issued is managed in a non-dynamic risk management strategy.

HSBC Holdings plc Annual Report and Accounts 2020 325

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Cash flow hedges

HSBC’s cash flow hedging instruments consist principally of interest rate swaps and cross-currency swaps that are used to manage the 
variability in future interest cash flows of non-trading financial assets and liabilities, arising due to changes in market interest rates and 
foreign-currency basis. 

HSBC applies macro cash flow hedging for interest rate risk exposures on portfolios of replenishing current and forecasted issuances of 
non-trading assets and liabilities that bear interest at variable rates, including rolling such instruments. The amounts and timing of future 
cash flows, representing both principal and interest flows, are projected for each portfolio of financial assets and liabilities on the basis 
of their contractual terms and other relevant factors, including estimates of prepayments and defaults. The aggregate cash flows 
representing both principal balances and interest cash flows across all portfolios are used to determine the effectiveness and 
ineffectiveness. Macro cash flow hedges are considered to be dynamic hedges.

HSBC also hedges the variability in future cash flows on foreign-denominated financial assets and liabilities arising due to changes in 
foreign exchange market rates with cross-currency swaps, which are considered dynamic hedges.

Hedging instrument by hedged risk

Hedging instrument

Hedged item

Ineffectiveness

Carrying amount

Hedged risk

Notional 
amount1

Assets

Liabilities

$m

$m

$m

Balance sheet 
presentation

Change in fair 
value2

Change in fair 
value3

Recognised in 
profit and loss 

$m

$m

$m

Foreign currency

24,506   

309   

448 

Derivatives  

(630)   

(630)   

Interest rate

At 31 Dec 2020

35,863   

60,369   

239   

548   

2 

450 

Derivatives  

519   

(111)   

514   

(116)   

Foreign currency

21,385   

455   

254 

Derivatives  

341   

341   

Interest rate

At 31 Dec 2019

54,253   

75,638   

152   

607   

46 

300 

Derivatives  

195   

536   

193   

534   

— 

5 

5 

— 

2 

2 

Profit and loss 
presentation

Net income from
financial instruments
held for trading or
managed on a fair
value basis

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

1 The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions 

outstanding at the balance sheet date. They do not represent amounts at risk.

2 Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3 Used in effectiveness assessment; comprising amount attributable to the designated hedged risk that can be a risk component.

Sources of hedge ineffectiveness may arise from basis risk, including but not limited to timing differences between the hedged items 
and hedging instruments and hedges using instruments with a non-zero fair value.

Reconciliation of equity and analysis of other comprehensive income by risk type

Cash flow hedging reserve at 1 Jan 2020

Fair value gains/(losses)

Fair value (gains)/losses reclassified from the cash flow hedge reserve to the income statement in respect of:

Hedged items that have affected profit or loss

Income taxes

Others

Cash flow hedging reserve at 31 Dec 2020

Cash flow hedging reserve at 1 Jan 2019

Fair value gains/(losses)

Fair value (gains)/losses reclassified from the cash flow hedge reserve to the income statement in respect of:

Hedged items that has affected profit or loss

Income taxes

Others

Cash flow hedging reserve at 31 Dec 2019

Hedges of net investments in foreign operations

Interest rate Foreign currency

$m

204   

514   

(107)   

(79)   

(37)   

495   

(26)   

193   

99   

(53)   

(9)   

204   

$m

(205) 

(630) 

822 

(23) 

(1) 

(37) 

(182) 

341 

(371) 

4 

3 

(205) 

The Group applies hedge accounting in respect of certain consolidated net investments. Hedging is undertaken for Group structural 
exposure to changes in the US dollar-sterling exchange rate using forward foreign exchange contracts or by financing with foreign 
currency borrowings. This risk arises due to the Group investment in sterling functional currency subsidiaries and is only hedged for 
changes in spot exchange rates. At 31 December 2020, the fair values of outstanding financial instruments designated as hedges of net 
investments in foreign operations were assets of nil (2019: nil), liabilities of $733m (2019: $485m) and notional derivative contract values 
of $10,500m (2019: $10,500m). These values are included in ‘Derivatives’ presented in the balance sheet. Ineffectiveness recognised in 
‘Net income from financial instruments held for trading or managed on a fair value basis’ in the year ended 31 December 2020 was nil 
(2019: nil) and the net investment hedge reserve was a negative $56m as of 31 December 2020 ($304m in 2019 and $780m in 2018). 
There were no amounts reclassified to the profit and loss account during the accounting periods presented.

326 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interest rate benchmark reform: Amendments to IFRS 9 and IAS 39 ‘Financial Instruments’

The first set of amendments (‘Phase 1’) to IFRS 9 and IAS 39, published in September 2019 and endorsed in January 2020, primarily 
allows the assumption that interbank offered rates (‘Ibors’) are to continue unaltered for the purposes of forecasting hedged cash flows 
until such time as the uncertainty of transitioning to near risk-free rates (‘RFRs’) is resolved. The second set of amendments (‘Phase 2’), 
issued in August 2020 and endorsed in January 2021, allows the modification of hedge documentation to reflect the components of 
hedge relationships that have transitioned to RFRs on an economically equivalent basis as a direct result of the Ibor transition.

While the application of Phase 1 amendments is mandatory for accounting periods starting on or after 1 January 2020, the Group chose 
to early adopt the Phase 2 amendments from the beginning of 2020. Significant judgement will be required in determining when Ibor 
transition uncertainty is resolved and therefore decide when Phase 1 amendments cease to apply and when some of the Phase 2 
amendments can be applied.

The notional value of the derivatives impacted by the Ibors reform but which are not used in designated hedge accounting relationships 
is disclosed on page 113 in the section ‘Financial instruments impacted by the Ibor reform’.

The Group has cash flow and fair value hedge accounting relationships that are exposed to different Ibors, predominantly US dollar 
Libor, sterling Libor and Euribor, as well as overnight rates subject to the market-wide benchmarks reform such as the European 
Overnight Index Average rate (‘Eonia’). Existing financial instruments (such as derivatives, loans and bonds) designated in relationships 
referencing these benchmarks are expected to transition to RFRs in different ways and at different times. External progress on the 
transition to RFRs is being monitored, with the objective of ensuring a smooth transition for the Group’s hedge accounting relationships. 
The specific issues arising will vary with the details of each hedging relationship, but may arise due to the transition of existing products 
included in the designation, a change in expected volumes of products to be issued, a change in contractual terms of new products 
issued, or a combination of these factors. Some hedges may need to be de-designated and new relationships entered into, while others 
may survive the market-wide benchmarks reform.

The hedge accounting relationships that are affected by Phase 1 and Phase 2 amendments are presented in the balance sheet as 
‘Financial assets designated and otherwise mandatorily measured at fair value through other comprehensive income’, ‘Loans and 
advances to customers’, ‘Debt securities in issue’ and ‘Deposits by banks’.

The notional amounts of interest rate derivatives designated in hedge accounting relationships represent the extent of the risk exposure 
managed by the Group that is expected to be directly affected by market-wide Ibors reform and in scope of Phase 1 and Phase 2 
amendments. The cross-currency swaps designated in hedge accounting relationships and affected by Ibor reform are not significant 
and have not been presented below:

Hedging instrument impacted by Ibor reform

Fair value hedges

Cash flow hedges

At 31 Dec 2020

Fair value hedges

Cash flow hedges

At 31 Dec 2019

€ 

$m

17,792   

8,344   

26,136   

20,378   

5,724   

26,102   

Impacted by Ibor reform

Hedging instrument

£

$m

3,706   

2,522   

6,228   

4,533   

6,594   

11,127   

$

$m

32,789   

8,705   

41,494   

41,274   

15,750   

57,024   

Other

$m

10,128   

6,797   

16,925   

13,435   

15,979   

29,414   

Total

$m

64,415   

26,368   

90,783   

79,620   

44,047   

123,667   

Not impacted 
by Ibor reform

$m

57,157   

9,495   

66,652   

43,133   

10,206   

53,339   

Notional
amount1

$m

121,572 

35,863 

157,435 

122,753 

54,253 

177,006 

1 The notional contract amounts of interest rate derivatives designated in qualifying hedge accounting relationships indicate the nominal value of 

transactions outstanding at the balance sheet date; they do not represent amounts at risk.

During 2019, the main market event in scope of Ibor reform was the change to the calculation of Eonia to be calculated as the euro 
short-term rate (‘€STR’) plus a fixed spread of 8.5 basis points. This event had no material impact to the valuation of components of 
designated hedge accounting relationships and there were no discontinuations of existing designated relationships. The main market 
events in scope of Ibor reform during 2020 were the changes applied by central clearing counterparties to remunerating euro and US 
dollar collateral. While there was a minimal valuation impact to the derivatives in scope that are used for hedge accounting, these 
changes had no discontinuation impact to any of the designated relationships affected.

For further details of Ibor transition, see ‘Areas of special interest’ in the Risk review on page 116.

Hedging instrument impacted by Ibor reform held by HSBC Holdings

Fair value hedges

At 31 Dec 2020

Fair value hedges

At 31 Dec 2019

Impacted by Ibor reform

Hedging instrument

€

$m

4,290   

4,290   

3,928   

3,928   

£

$m

5,393   

5,393   

5,222   

5,222   

$

$m

21,081   

21,081   

Other

$m

3,242   

3,242   

Total

$m

34,006   

34,006   

24,500   

24,500   

3,119   

3,119   

36,769   

36,769   

Not impacted 
by Ibor reform

$m

—   

—   

—   

—   

Notional 
amount

$m

34,006 

34,006 

36,769 

36,769 

HSBC Holdings plc Annual Report and Accounts 2020 327

Financial statements 
 
 
 
 
 
 
 
 
 
2020

$m

402,054   
118,163   
281,467   
2,337   
87   
88,639   
11,757   
76,882   
490,693   

2019

$m

357,577 

95,043 

260,536 

1,913 

85 

85,735 

10,476 

75,259 

443,312 

Fair value

Dividends 
recognised

$m

904   

1,387   

46   

2,337   

738   

1,124   

51   

1,913   

$m

22 

22 

3 

47 

22 

19 

9 

50 

Notes on the financial statements

16 Financial investments

Carrying amount of financial investments

Financial investments measured at fair value through other comprehensive income

–  treasury and other eligible bills

–  debt securities

–  equity securities

–  other instruments

Debt instruments measured at amortised cost

–  treasury and other eligible bills

–  debt securities

At 31 Dec

Equity instruments measured at fair value through other comprehensive income

Type of equity instruments

Investments required by central institutions

Business facilitation

Others

At 31 Dec 2020

Investments required by central institutions

Business facilitation

Others

At 31 Dec 2019

Financial investments at amortised cost and fair value

US Treasury

US Government agencies

US Government-sponsored entities

UK Government

Hong Kong Government

Other governments

Asset-backed securities

Corporate debt and other securities

Equities

At 31 Dec

Footnotes

2

3

2020

2019

Amortised cost

Fair value1

Amortised cost

Fair value1

$m

75,531   

19,851   

10,691   

28,094   

55,483   

178,091   

2,708   

110,015   

1,410   

481,874   

$m
78,251   
20,320   
11,224   
28,754   
55,507   
180,881   
2,536   
118,960   
2,337   
498,770   

$m

79,633   

26,356   

8,070   

28,621   

47,824   

140,510   

2,954   

101,750   

1,241   

436,959   

$m

80,589 

26,387 

8,259 

28,973 

47,820 

142,511 

2,889 

107,364 

1,913 

446,705 

1 

Included within ‘fair value’ figures are debt securities issued by banks and other financial institutions of $62bn (2019: $61bn), of which $10bn 
(2019: $11bn) are guaranteed by various governments.

2 Includes securities that are supported by an explicit guarantee issued by the US Government.
3 Excludes asset-backed securities included under US Government agencies and sponsored entities.

Maturities of investments in debt securities at their carrying amount

Up to 1 year 

1 to 5 years

5 to 10 years

Over 10 years

Debt securities measured at fair value through other comprehensive income

72,250   

131,859   

$m

$m

Debt securities measured at amortised cost

At 31 Dec 2020

Debt securities measured at fair value through other comprehensive income

Debt securities measured at amortised cost

At 31 Dec 2019

6,135   

16,499   

78,385   

148,358   

61,833   

5,472   

67,305   

123,740   

14,395   

138,135   

$m

42,168   

19,437   

61,605   

42,831   

21,431   

64,262   

$m

35,190   

34,811   

70,001   

32,132   

33,961   

66,093   

Total

$m

281,467 

76,882 

358,349 

260,536 

75,259 

335,795 

328 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Contractual maturities and weighted average yields of investment debt securities

Up to 1 year

1 to 5 years

5 to 10 years

Over 10 years

Amount

$m

Yield

%

Amount

$m

Yield

%

Amount

$m

Yield

%

Amount

$m

Yield

%

Debt securities measured at fair value 
through other comprehensive income

US Treasury 

US Government agencies 

US Government-sponsored agencies 

UK Government 

Hong Kong Government 

Other governments 

Asset-backed securities 

Corporate debt and other securities 

Total amortised cost at 31 Dec 2020

Total carrying value 

Debt securities measured at amortised cost

US Treasury 

US Government agencies 

US Government-sponsored agencies 

Hong Kong Government 

Other governments 

Asset-backed securities 

Corporate debt and other securities 

Total amortised cost at 31 Dec 2020

Total carrying value 

6,596 

— 

30 

2,765 

84 

51,507 

18 

10,831 

71,831 

72,250 

3,769 

— 

110 

13 

179 

— 

2,064 

6,135 

6,135 

 1.2   

 —   

 2.8   

 1.5   

 1.6   

 1.7   

 2.9   

 2.1   

 0.1   

 —   

 2.5   

 3.0   

 3.4   

 —   

 3.3   

22,945 

95 

789 

5,126 

247 

62,587 

93 

35,615 

127,497 

131,859 

4,618 

9 

258 

23 

370 

— 

11,221 

16,499 

16,497 

 1.6   

 1.8   

 2.2   

 0.8   

 1.6   

 2.3   

 1.4   

 1.4   

 1.6   

 3.8   

 2.7   

 1.6   

 4.1   

 —   

 3.4   

15,618 

43 

2,988 

6,220 

167 

8,184 

399 

7,169 

40,788 

42,168 

3,003 

13 

436 

118 

426 

— 

15,441 

19,437 

19,439 

 1.5   

 2.8   

 2.5   

 0.2   

 1.8   

 1.6   

 1.8   

 1.8   

 2.0   

 4.5   

 2.2   

 2.6   

 3.8   

 —   

 3.4   

4,195 

12,608 

4,968 

4,910 

— 

2,089 

2,199 

2,583 

33,552 

35,190 

969 

7,084 

1,112 

12 

1,011 

2 

24,621 

34,811 

34,812 

 2.3 

 1.8 

 1.8 

 2.3 

 — 

 4.3 

 1.2 

 3.4 

 2.8 

 2.6 

 3.3 

 4.8 

 4.2 

 6.0 

 3.8 

The maturity distributions of ABSs are presented in the above table on the basis of contractual maturity dates. The weighted average 
yield for each range of maturities is calculated by dividing the annualised interest income for the year ended 31 December 2020 by the 
book amount of debt securities at that date. The yields do not include the effect of related derivatives.

HSBC Holdings

HSBC Holdings carrying amount of financial investments

Debt instruments measured at amortised cost

–  treasury and other eligible bills

–  debt securities

At 31 Dec

Financial investments at amortised cost and fair value

US Treasury

US Government agencies

US Government-sponsored entities

At 31 Dec

2020

$m

10,941   

6,544   

17,485   

2019

$m

10,081 

6,025 

16,106 

2020

2019

Amortised cost

Fair value

Amortised cost

Fair value

$m

$m

$m

17,485   

17,521   

16,106   

—   

—   

—   

—   

—   

—   

$m

16,121 

— 

— 

17,485   

17,521   

16,106   

16,121 

Maturities of investments in debt securities at their carrying amount

Debt securities measured at amortised cost

At 31 Dec 2020

Debt securities measured at amortised cost

At 31 Dec 2019

Up to 1 year

1 to 5 years

5 to 10 years

Over 10 years

$m

3,767   

3,767   

3,010   

3,010   

$m

2,777   

2,777   

3,015   

3,015   

$m

—   

—   

—   

—   

$m

—   

—   

—   

—   

Total

$m

6,544 

6,544 

6,025 

6,025 

Contractual maturities and weighted average yields of investment debt securities

Debt securities measured at amortised cost

US Treasury 

US Government agencies 

US Government-sponsored agencies 

Total amortised cost at 31 Dec 2020

Total carrying value 

Up to 1 year

1 to 5 years

5 to 10 years

Over 10 years

Amount

$m

Yield

%

Amount

$m

Yield

%

Amount

$m

Yield

%

Amount

$m

Yield

%

3,767 

 1.5   

2,777 

— 

— 

3,767 

3,767 

 —   

 —   

— 

— 

2,777 

2,777 

 0.3   

 —   

 —   

— 

— 

— 

— 

— 

 —   

 —   

 —   

— 

— 

— 

— 

— 

 — 

 — 

 — 

HSBC Holdings plc Annual Report and Accounts 2020 329

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

The weighted average yield for each range of maturities is calculated by dividing the annualised interest income for the year ended 
31 December 2020 by the book amount of debt securities at that date. The yields do not include the effect of related derivatives.

17 Assets pledged, collateral received and assets transferred

Assets pledged

Financial assets pledged as collateral

Treasury bills and other eligible securities 

Loans and advances to banks 

Loans and advances to customers 

Debt securities 

Equity securities

Other 

Assets pledged at 31 Dec

2020

$m
12,774   
236   
43,168   
67,312   
26,101   
60,810   
210,401   

2019

$m

14,034 

1,975 

26,017 

60,995 

24,626 

50,231 

177,878 

Assets pledged as collateral include all assets categorised as encumbered in the disclosure on page 78 of the Pillar 3 Disclosures at 31 December 2020.

The amount of assets pledged to secure liabilities may be greater than the book value of assets utilised as collateral. For example, in the 
case of securitisations and covered bonds, the amount of liabilities issued plus mandatory over-collateralisation is less than the book 
value of the pool of assets available for use as collateral. This is also the case where assets are placed with a custodian or a settlement 
agent that has a floating charge over all the assets placed to secure any liabilities under settlement accounts.

These transactions are conducted under terms that are usual and customary for collateralised transactions including, where relevant, 
standard securities lending and borrowing, repurchase agreements and derivative margining. HSBC places both cash and non-cash 
collateral in relation to derivative transactions.

Hong Kong currency notes in circulation are secured by the deposit of funds in respect of which the Hong Kong Government certificates 
of indebtedness are held.

Financial assets pledged as collateral which the counterparty has the right to sell or repledge

Trading assets 

Financial investments

At 31 Dec

Collateral received

2020

$m

64,225   

16,915   

81,140   

2019

$m

63,163 

10,782 

73,945 

The fair value of assets accepted as collateral relating primarily to standard securities lending, reverse repurchase agreements, swaps of 
securities and derivative margining that HSBC is permitted to sell or repledge in the absence of default was $447,101m 
(2019: $468,798m). The fair value of any such collateral sold or repledged was $246,520m (2019: $304,261m).

HSBC is obliged to return equivalent securities. These transactions are conducted under terms that are usual and customary to standard 
securities lending, reverse repurchase agreements and derivative margining.

Assets transferred

The assets pledged include transfers to third parties that do not qualify for derecognition, notably secured borrowings such as debt 
securities held by counterparties as collateral under repurchase agreements and equity securities lent under securities lending 
agreements, as well as swaps of equity and debt securities. For secured borrowings, the transferred asset collateral continues to be 
recognised in full while a related liability, reflecting the Group’s obligation to repurchase the assets for a fixed price at a future date, is 
also recognised on the balance sheet. Where securities are swapped, the transferred asset continues to be recognised in full. There is no 
associated liability as the non-cash collateral received is not recognised on the balance sheet. The Group is unable to use, sell or pledge 
the transferred assets for the duration of the transaction, and remains exposed to interest rate risk and credit risk on these pledged 
assets. With the exception of ‘Other sales’ in the following table, the counterparty’s recourse is not limited to the transferred assets.

Transferred financial assets not qualifying for full derecognition and associated financial liabilities

At 31 Dec 2020

Repurchase agreements

Securities lending agreements

Other sales (recourse to transferred assets only)

At 31 Dec 2019
Repurchase agreements

Securities lending agreements

Other sales (recourse to transferred assets only)

Carrying amount of:

Fair value of:

Transferred
assets

Associated
liabilities

Transferred
assets

Associated
liabilities

$m

$m

$m

$m

Net
position

$m

52,413   

38,364   

3,564   

45,831   

35,122   

2,971   

51,092 

124 

3,478   

3,619   

3,564   

55 

45,671 

3,225 

2,885   

2,974   

2,897   

77 

330 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
18 Interests in associates and joint ventures

Carrying amount of HSBC’s interests in associates and joint ventures

Interests in associates

Interests in joint ventures

Interests in associates and joint ventures

Principal associates of HSBC

Bank of Communications Co., Limited

The Saudi British Bank

2020

$m

26,594   

90   

26,684   

2019

$m
24,384 

90 

24,474 

2020

Carrying amount

$m

21,248   

4,215   

Fair value1
$m

7,457   

4,197   

2019

Carrying amount

Fair value1

$m

18,982   

4,370   

$m

10,054 

5,550 

1 Principal associates are listed on recognised stock exchanges. The fair values are based on the quoted market prices of the shares held (Level 1 in 

the fair value hierarchy).

Bank of Communications Co., Limited 

The Saudi British Bank 

Footnotes

Country of incorporation
and principal place of
business

People’s Republic of 
China

At 31 Dec 2020

Principal
activity

Banking services

1

Saudi Arabia

Banking services

HSBC’s
interest
%

 19.03 

 31.00 

1     In December 2020, HSBC purchased additional shares and increased its shareholding in The Saudi British Bank (‘SABB’) from 29.2% to 31.0%. 

SABB will continue to be accounted for as an associate of HSBC.

A list of all associates and joint ventures is set out in Note 37.

Bank of Communications Co., Limited 

The Group’s investment in Bank of Communications Co., Limited (‘BoCom’) is classified as an associate. Significant influence in BoCom 
was established with consideration of all relevant factors, including representation on BoCom’s Board of Directors and participation in a 
Resource and Experience Sharing (‘RES’) agreement. Under the RES, HSBC staff have been seconded to assist in the maintenance of 
BoCom’s financial and operating policies. Investments in associates are recognised using the equity method of accounting in 
accordance with IAS 28, whereby the investment is initially recognised at cost and adjusted thereafter for the post-acquisition change in 
the Group’s share of BoCom’s net assets. An impairment test is required if there is any indication of impairment.

Impairment testing

At 31 December 2020, the fair value of the Group’s investment in BoCom had been below the carrying amount for approximately nine 
years. As a result, the Group performed an impairment test on the carrying amount, which confirmed that there was no impairment at 
31 December 2020 as the recoverable amount as determined by a value-in-use (‘VIU’) calculation was higher than the carrying value. 

BoCom

At 31 Dec 2020

VIU

$bn

21.8   

Carrying value

Fair value

$bn

21.2   

$bn

7.5   

VIU

$bn

21.5   

At 31 Dec 2019

Carrying value

Fair value

$bn

19.0   

$bn

10.1 

Compared with 31 December 2019, the extent to which the VIU exceeds the carrying value (‘headroom’) decreased by $1.9bn. The 
reduction in headroom was principally due to the impact on the VIU from BoCom's actual performance, which was lower than earlier 
forecasts due to the impact of the Covid-19 outbreak and the disruption to global economic activity, downward revisions to 
management's best estimates of BoCom's future earnings in the short to medium term, and the net impact of revisions to certain long-
term assumptions. Both the VIU and the carrying value increased due to the impact of foreign exchange movements.

In future periods, the VIU may increase or decrease depending on the effect of changes to model inputs. The main model inputs are 
described below and are based on factors observed at period-end. The factors that could result in a change in the VIU and an 
impairment include a short-term underperformance by BoCom, a change in regulatory capital requirements or an increase in uncertainty 
regarding the future performance of BoCom resulting in a downgrade of the forecast of future asset growth or profitability. An increase 
in the discount rate as a result of an increase in the risk premium or risk-free rates could also result in a reduction of VIU and an 
impairment. At the point where the carrying value exceeds the VIU, impairment would be recognised. 

If the Group did not have significant influence in BoCom, the investment would be carried at fair value rather than the current carrying 
value.

Basis of recoverable amount

The impairment test was performed by comparing the recoverable amount of BoCom, determined by a VIU calculation, with its carrying 
amount. The VIU calculation uses discounted cash flow projections based on management’s best estimates of future earnings available 
to ordinary shareholders prepared in accordance with IAS 36. Significant management judgement is required in arriving at the best 
estimate. There are two main components to the VIU calculation. The first component is management’s best estimate of BoCom’s 
earnings, which is based on explicit forecasts over the short to medium term. This results in forecast earnings growth that is lower than 
recent historical actual growth and also reflects the uncertainty arising from the current economic outlook. Earnings beyond the short to 
medium term are then extrapolated into perpetuity using a long-term growth rate to derive a terminal value, which comprises the 
majority of the VIU. The second component is the capital maintenance charge (‘CMC’), which is management’s forecast of the earnings 

HSBC Holdings plc Annual Report and Accounts 2020 331

Financial statements 
 
 
 
 
 
 
 
 
Notes on the financial statements

that need to be withheld in order for BoCom to meet regulatory capital requirements over the forecast period, meaning that CMC is 
deducted when arriving at management’s estimate of future earnings available to ordinary shareholders. The principal inputs to the CMC 
calculation include estimates of asset growth, the ratio of risk-weighted assets to total assets and the expected minimum regulatory 
capital requirements. An increase in the CMC as a result of a change to these principal inputs would reduce VIU. Additionally, 
management considers other factors, including qualitative factors, to ensure that the inputs to the VIU calculation remain appropriate.

Key assumptions in value-in-use calculation

We used a number of assumptions in our VIU calculation, in accordance with the requirements of IAS 36:

• Long-term profit growth rate: 3% (2019: 3%) for periods after 2024, which does not exceed forecast GDP growth in mainland China 

and is consistent with forecasts by external analysts.

• Long-term asset growth rate: 3% (2019: 3%) for periods after 2024, which is the rate that assets are expected to grow to achieve 

long-term profit growth of 3%.

• Discount rate: 11.37% (2019: 11.24%). This is based on a capital asset pricing model (‘CAPM’) calculation for BoCom, using market 

data. Management also compares the rate derived from the CAPM with discount rates from external sources. The discount rate used 
is within the range of 10.3% to 15.0% (2019: 10.0% to 15.0%) indicated by external sources. The increased rate reflects the net 
impact of updates to certain components of CAPM due to elevated levels of risk arising from the impact of the Covid-19 outbreak and 
the disruption to global economic activity.

• Expected credit losses (‘ECL’) as a percentage of customer advances: This ranges from 0.98% to 1.22% (2019: 0.95%) in the short to 

medium term, reflecting increases due to the Covid-19 outbreak and BoCom's actual results. For periods after 2024, the ratio is 
0.88% (2019: 0.76%), which is slightly higher than BoCom’s average ECL in recent years. This ratio was increased to reflect trends in 
BoCom’s actual results in recent years of increasing ECL and of changes to BoCom’s loan portfolio.

• Risk-weighted assets as a percentage of total assets: This ranges from 61% to 62% (2019: 61%) in the short to medium term, 

reflecting increases that may arise from higher ECL in the short term, followed by reductions that may arise from a subsequent 
lowering of ECL and a continuation of the trend of strong retail loan growth. For periods after 2024, the ratio is 61% (2019: 61%). 
These rates are similar to BoCom’s actual results in recent years and are slightly below forecasts disclosed by external analysts.

• Operating income growth rate: This ranges from 3.5% to 6.7% (2019: 4.9% to 9.4%) in the short to medium term, and is lower than 
BoCom’s actual results in recent years and the forecasts disclosed by external analysts, reflecting economic pressures from the 
Covid-19 outbreak, global trade tensions and industry developments in mainland China.

• Cost-income ratio: This ranges from 36.3% to 36.8% (2019: 37.1% to 38.8%) in the short to medium term. These ratios are similar to 

BoCom's actual results in recent years and slightly higher than forecasts disclosed by external analysts.

• Effective tax rate: This ranges from 7.8% to 16.5% (2019: 12.0% to 17.0%) in the short to medium term, reflecting BoCom’s actual 
results and an expected increase towards the long-term assumption through the forecast period. For periods after 2024, the rate is 
16.8% (2019: 22.5%), which is higher than the recent historical average. This rate was reduced on expectations of a lower effective 
tax rate in the long term, reflecting BoCom’s actual results in recent years and forecast financial asset composition, and forecasts 
disclosed by external analysts. 

• Capital requirements: This was based on a capital adequacy ratio of 11.5% (2019: 11.5%) and tier 1 capital adequacy ratio of 9.5% 

(2019: 9.5%), based on the minimum regulatory requirements.

The following table shows the change to each key assumption in the VIU calculation that on its own would reduce the headroom to nil:

Key assumption

• Long-term profit growth rate

• Long-term asset growth rate

• Discount rate

Changes to key assumption to reduce headroom to nil

• Decrease by 22 basis points

• Increase by 20 basis points

• Increase by 26 basis points

• Expected credit losses as a percentage of customer advances

• Increase by 3 basis points

• Risk-weighted assets as a percentage of total assets

• Operating income growth rate

• Cost-income ratio

• Long-term effective tax rate

• Capital requirements – capital adequacy ratio

• Capital requirements – tier 1 capital adequacy ratio

• Increase by 136 basis points

• Decrease by 28 basis points

• Increase by 77 basis points

• Increase by 216 basis points

• Increase by 26 basis points

• Increase by 90 basis points

The following table further illustrates the impact on VIU of reasonably possible changes to key assumptions. This reflects the sensitivity 
of the VIU to each key assumption on its own and it is possible that more than one favourable and/or unfavourable change may occur at 
the same time. The selected rates of reasonably possible changes to key assumptions are largely based on external analysts’ forecasts, 
which can change period to period.

332 HSBC Holdings plc Annual Report and Accounts 2020

 
Sensitivity of VIU to reasonably possible changes in key assumptions

Favourable change

Unfavourable change

Increase in VIU

bps

$bn

VIU

$bn

Decrease in VIU

bps

$bn

VIU

$bn

At 31 Dec 2020

Long-term profit growth rate 

Long-term asset growth rate

Discount rate 

Expected credit losses as a percentage of customer advances

Risk-weighted assets as a percentage of total assets 

Operating income growth rate

Cost-income ratio 

Long-term effective tax rate

Capital requirements – capital adequacy ratio

Capital requirements – tier 1 capital adequacy ratio

At 31 Dec 2019

Long-term profit growth rate

Long-term asset growth rate

Discount rate

—   

(50)   

—   

2020 to 2024: 96
2025 onwards: 
76

(40)   

2   

(149)   

(316)   

—   

—   

—   

(50)   

(54)   

Expected credit losses as a percentage of customer advances

Risk-weighted assets as a percentage of total assets

Operating income growth rate

Cost-income ratio

Long-term effective tax rate

Capital requirements – capital adequacy ratio

Capital requirements – tier 1 capital adequacy ratio

2019 to 2023: 90
2024 onwards: 70

(96)   

14   

(175)   

(352)   

—   

—   

—    21.8   

1.4    23.2   

1.2    23.0   

2.3    24.1 

0.1    21.9   

0.2    22.0   

1.3    23.1   

0.9    22.7   

—    21.8   

—    21.8   

—   

21.5   

1.4   

1.4   

22.9   

22.9   

1.0   

22.5 

0.4   

21.9   

—   

21.8   

1.0   

1.0   

—   

—   

22.5   

22.5   

21.5   

21.5   

(50)   

—   

53   

2020 to 2024: 
122
2025 onwards: 
95

166   

(69)   

120   

820   

297   

263   

(50)   

—   

56   

2019 to 2023: 108
2024 onwards: 81

12   

(102)   

95   

250   

337   

322   

(1.3)    20.5 

—    21.8 

(1.2)    20.6 

(2.1)    19.7 

(0.8)    21.0 

(1.5)    20.3 

(1.2)    20.6 

(2.2)    19.6 

(7.8)    14.0 

(5.3)    16.5 

(1.3)   

—   

(1.2)   

20.2 

21.5 

20.3 

(1.2)   

20.3 

—   

(1.8)   

(1.2)   

(0.7)   

(8.2)   

(6.0)   

21.5 

19.7 

20.3 

20.8 

13.3 

15.5 

Considering the interrelationship of the changes set out in the table above, management estimates that the reasonably possible range of 
VIU is $18.2bn to $24.2bn (2019: $18.5bn to $22.8bn). The range is based on the favourable/unfavourable change in the earnings in the 
short- to medium-term, and long-term expected credit losses as a percentage of customer advances as set out in the table above. All 
other long-term assumptions, the discount rate and the basis of the CMC have been kept unchanged when determining the reasonably 
possible range of the VIU.

Selected financial information of BoCom

The statutory accounting reference date of BoCom is 31 December. For the year ended 31 December 2020, HSBC included the 
associate’s results on the basis of the financial statements for the 12 months ended 30 September 2020, taking into account changes in 
the subsequent period from 1 October 2020 to 31 December 2020 that would have materially affected the results.

Selected balance sheet information of BoCom

Cash and balances at central banks 

Loans and advances to banks and other financial institutions 

Loans and advances to customers 

Other financial assets 

Other assets 

Total assets 

Deposits by banks and other financial institutions 

Customer accounts 

Other financial liabilities 

Other liabilities 

Total liabilities 

Total equity 

At 30 Sep

2020

$m

121,987   

107,334   

870,728   

508,328   

44,622   

2019

$m

112,239 

108,026 

730,510 

435,740 

40,101 

1,652,999   

1,426,616 

273,708   

1,012,732   

207,110   

31,105   

290,492 

868,627 

131,772 

23,074 

1,524,655   

1,313,965 

128,344   

112,651 

Reconciliation of BoCom’s total shareholders’ equity to the carrying amount in HSBC’s consolidated financial statements

HSBC’s share of total shareholders’ equity

Goodwill and other intangible assets 

Carrying amount  

At 30 Sep

2020

$m

20,743   

505   

21,248   

2019

$m

18,509 

473 

18,982 

HSBC Holdings plc Annual Report and Accounts 2020 333

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Selected income statement information of BoCom

Net interest income 

Net fee and commission income 

Change in expected credit losses and other credit impairment charges
Depreciation and amortisation 

Tax expense 

Profit for the year 

Other comprehensive income 

Total comprehensive income 

Dividends received from BoCom 

The Saudi British Bank

For the 12 months ended 30 Sep

2020

$m

21,994   

6,398   

(9,698)   

(2,072)   

(858)   

10,261   

(769)   

9,492   

633   

2019

$m
20,558 

6,411 

(7,479) 

(1,934) 

(1,636) 

11,175 

315 

11,490 

613 

The Group’s investment in The Saudi British Bank (‘SABB’) is classified as an associate. In June 2019, the merger between SABB and
Alawwal bank (‘Alawwal’) became effective, which reduced HSBC’s 40% interest in SABB to 29.2%. On 3 December 2020, HSBC 
purchased additional shares in SABB, which increased the Group’s shareholding to 31%. HSBC remains the largest shareholder in SABB. 
Significant influence in SABB is established via representation on the Board of Directors. Investments in associates are recognised using 
the equity method of accounting in accordance with IAS 28, as described previously for BoCom.

Impairment testing

At 31 December 2020, the fair value of the Group’s investment in SABB of $4.20bn was below the carrying amount of $4.22bn. As a 
result, the Group performed an impairment test on the carrying amount, which confirmed no impairment. The recoverable amount as 
determined by a VIU calculation is $4.74bn.

The basis of recoverable amount

The impairment test was performed by comparing the recoverable amount of SABB, determined by a VIU calculation, with its carrying 
amount. The VIU calculation uses discounted cash flow projections based on management’s best estimates of future earnings available 
to ordinary shareholders prepared in accordance with IAS 36, which requires significant management judgement. A key component to 
the VIU calculation is management’s best estimate of SABB’s earnings, which is based on explicit forecasts over the short to medium 
term. This reflects the uncertainty arising from the current economic outlook. Earnings beyond the short to medium term are then 
extrapolated in perpetuity using a long-term growth rate to derive a terminal value, which comprises the majority of the VIU. 
Additionally, management considers other factors (including qualitative factors) to ensure that the inputs to the VIU calculation remain 
appropriate.

Key assumptions in value-in-use calculation

We used a number of assumptions in our VIU calculation, in accordance with the requirements of IAS 36:

• Long-term profit growth rate: 2.85% for periods after 2024. This does not exceed forecast GDP growth in Saudi Arabia.

• Long-term asset growth rate: 2.85% for periods after 2024. This is the rate that assets are expected to grow to achieve long-term 

profit growth of 2.85%.

• Discount rate: 10.4%. This is based on a CAPM calculation for Saudi Arabia using market data. Management also compares the rate 

derived from the CAPM with cost of capital rates from external sources.

• Management’s judgement in estimating the cash flows of SABB: Cash flow projections have considered the scale of the entity 

following the merger with Alawwal, current market conditions and our macroeconomic outlook.

Sensitivity of VIU to reasonably possible changes in key assumptions

At 31 December 2020, the Group’s investment in SABB was sensitive to reasonably possible adverse changes in key assumptions 
supporting the recoverable amount. The most sensitive inputs to the impairment test are set out in the following table. A reasonable 
change in a single key assumption may not result in impairment, although taken together a combination of reasonable changes in key 
assumptions could result in a recoverable amount that is lower than the carrying amount.

Key assumption

• Cash flow projections

• Discount rate

Reasonably possible change

• Cash flow projections decrease by 15%. This could result in an impairment of $0.2bn.

• Discount rate increases by 100 basis points. This does not result in impairment.

334 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
19 Investments in subsidiaries

Main subsidiaries of HSBC Holdings

Europe

HSBC Bank plc 

HSBC UK Bank plc

HSBC Continental Europe
HSBC Trinkaus & Burkhardt AG1 
Asia

Hang Seng Bank Limited 

HSBC Bank (China) Company Limited 

HSBC Bank Malaysia Berhad 

HSBC Life (International) Limited 

Place of incorporation 
or registration

HSBC’s 
interest %

Share class

At 31 Dec 2020

England and Wales

England and Wales

France

Germany

100

100

99.99

99.33

£1 Ordinary, $0.01 Non-cumulative third Dollar 
Preference

£1 Ordinary

€5 Actions

Stückaktien no par value

Hong Kong

62.14

HK$5 Ordinary

People’s Republic of 
China

Malaysia

Bermuda

100

100

100

100

CNY1 Ordinary

RM0.5 Ordinary

HK$1 Ordinary

Ordinary no par value

The Hongkong and Shanghai Banking Corporation Limited 

Hong Kong

Middle East and North Africa

HSBC Bank Middle East Limited 

United Arab Emirates 100

$1 Ordinary and $1 Cumulative Redeemable 
Preference shares (CRP)

North America

HSBC Bank Canada 

HSBC Bank USA, N.A. 

Latin America

Canada

US

100

100

Common no par value and Preference no par value

$100 Common and $0.01 Preference

HSBC Mexico, S.A., Institución de Banca Múltiple,
Grupo Financiero HSBC 

Mexico

99.99

MXN2 Ordinary

1  The Group acquired the remaining minority equity interest in HSBC Trinkaus & Burkhardt AG on 1 February 2021. The Group now owns 100% of 

this subsidiary.

Details of the debt, subordinated debt and preference shares issued by the main subsidiaries to parties external to the Group are 
included in Note 25 ‘Debt securities in issue’ and Note 28 ‘Subordinated liabilities’, respectively.

A list of all related undertakings is set out in Note 37. The principal countries of operation are the same as the countries and territories of 
incorporation except for HSBC Life (International) Limited, which operates mainly in Hong Kong.

HSBC is structured as a network of regional banks and locally incorporated regulated banking entities. Each bank is separately 
capitalised in accordance with applicable prudential requirements and maintains a capital buffer consistent with the Group’s risk 
appetite for the relevant country or region. HSBC’s capital management process is incorporated in the annual operating plan, which is 
approved by the Board.

HSBC Holdings is the primary provider of equity capital to its subsidiaries and also provides them with non-equity capital where 
necessary. These investments are substantially funded by HSBC Holdings’ issuance of equity and non-equity capital, and by profit 
retention. The net reduction in investments in subsidiaries was partly due to the impairment of HSBC Overseas Holdings (UK) Limited of 
$0.4bn.

As part of its capital management process, HSBC Holdings seeks to maintain a balance between the composition of its capital and its 
investment in subsidiaries. Subject to this, there is no current or foreseen impediment to HSBC Holdings’ ability to provide funding for 
such investments. During 2020, consistent with the Group’s capital plan, the Group’s subsidiaries did not experience any significant 
restrictions on paying dividends or repaying loans and advances. Also, there are no foreseen restrictions envisaged with regard to 
planned dividends or payments. However, the ability of subsidiaries to pay dividends or advance monies to HSBC Holdings depends on, 
among other things, their respective local regulatory capital and banking requirements, exchange controls, statutory reserves, and 
financial and operating performance.

The amount of guarantees by HSBC Holdings in favour of other Group entities is set out in Note 32.

Information on structured entities consolidated by HSBC where HSBC owns less than 50% of the voting rights is included in Note 20 
‘Structured entities’. In each of these cases, HSBC controls and consolidates an entity when it is exposed, or has rights, to variable 
returns from its involvement with the entity and has the ability to affect those returns through its power over the entity.

Subsidiaries with significant non-controlling interests

Hang Seng Bank Limited

Proportion of ownership interests and voting rights held by non-controlling interests

Place of business

Profit attributable to non-controlling interests 

Accumulated non-controlling interests of the subsidiary 

Dividends paid to non-controlling interests 

Summarised financial information: 

–  total assets

–  total liabilities 

–  net operating income before changes in expected credit losses and other credit impairment charges
–  profit for the year 

–  total comprehensive income for the year 

2020

2019

 37.86 %

Hong Kong

37.86%

Hong Kong

$m
843  
7,604  
625  

224,483  
202,907  
4,568  
2,230  
2,535  

$m

1,229 

7,262 

720 

212,485 

191,819 

5,558 

3,251 

3,461 

HSBC Holdings plc Annual Report and Accounts 2020 335

Financial statementsNotes on the financial statements

20 Structured entities

HSBC is mainly involved with both consolidated and unconsolidated structured entities through the securitisation of financial assets, 
conduits and investment funds, established either by HSBC or a third party.

Consolidated structured entities

Total assets of HSBC’s consolidated structured entities, split by entity type

At 31 Dec 2020

At 31 Dec 2019

Conduits

Conduits

Securitisations

HSBC
managed funds

$bn

6.9   

8.6   

$bn

11.7   

9.6   

$bn

5.3   

6.8   

Other

$bn

10.8   

6.7   

Total

$bn

34.7 

31.7 

HSBC has established and manages two types of conduits: securities investment conduits (‘SICs’) and multi-seller conduits.

Securities investment conduits

The SICs purchase highly rated ABSs to facilitate tailored investment opportunities.

• At 31 December 2020, Solitaire, HSBC’s principal SIC, held $1.9bn of ABSs (2019: $2.1bn). It is currently funded entirely by 

commercial paper (‘CP’) issued to HSBC. At 31 December 2020, HSBC held $2.1bn of CP (2019: $3.2bn).

Multi-seller conduit

HSBC’s multi-seller conduit was established to provide access to flexible market-based sources of finance for its clients. Currently, HSBC 
bears risk equal to the transaction-specific facility offered to the multi-seller conduit, amounting to $9.6bn at 31 December 2020 (2019: 
$12.4bn). First loss protection is provided by the originator of the assets, and not by HSBC, through transaction-specific credit 
enhancements. A layer of secondary loss protection is provided by HSBC in the form of programme-wide enhancement facilities.

Securitisations

HSBC uses structured entities to securitise customer loans and advances it originates in order to diversify its sources of funding for asset 
origination and capital efficiency purposes. The loans and advances are transferred by HSBC to the structured entities for cash or 
synthetically through credit default swaps, and the structured entities issue debt securities to investors.

HSBC managed funds

HSBC has established a number of money market and non-money market funds. Where it is deemed to be acting as principal rather than 
agent in its role as investment manager, HSBC controls these funds.

Other

HSBC has entered into a number of transactions in the normal course of business, which include asset and structured finance 
transactions where it has control of the structured entity. In addition, HSBC is deemed to control a number of third-party managed funds 
through its involvement as a principal in the funds.

Unconsolidated structured entities

The term ‘unconsolidated structured entities’ refers to all structured entities not controlled by HSBC. The Group enters into transactions 
with unconsolidated structured entities in the normal course of business to facilitate customer transactions and for specific investment 
opportunities.

336 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
Nature and risks associated with HSBC interests in unconsolidated structured entities

Total asset values of the entities ($m)

Securitisations

HSBC managed 
funds

Non-HSBC 
managed funds

Other

0–500

500–2,000

2,000–5,000

5,000–25,000

25,000+

Number of entities at 31 Dec 2020

Total assets in relation to HSBC’s interests in the unconsolidated 
structured entities

–  trading assets 

–  financial assets designated and otherwise mandatorily measured at fair 

value 

–  loans and advances to customers

–  financial investments 

–  other assets 
Total liabilities in relation to HSBC’s interests in the unconsolidated 
structured entities

–  other liabilities 

Other off-balance sheet commitments

HSBC’s maximum exposure at 31 Dec 2020

Total asset values of the entities ($m)

0–500

500–2,000

2,000–5,000

5,000–25,000

25,000+
Number of entities at 31 Dec 2019

Total assets in relation to HSBC’s interests in the unconsolidated 
structured entities

–  trading assets 

–  financial assets designated and otherwise mandatorily measured at fair 

value 

–  loans and advances to customers

–  financial investments 

–  other assets 
Total liabilities in relation to HSBC’s interests in the unconsolidated 
structured entities

–  other liabilities 
Other off-balance sheet commitments

HSBC’s maximum exposure at 31 Dec 2019

86   

9   

—   

—   

—   

95   

$bn

4.4   

—   

—   

4.4   

—   

—   

—   

—   

0.1   

4.5   

91   

12   

—   

—   

—   

103   

$bn

5.3   

—   

—   

5.3   

—   

—   

—   

—   

0.3   

5.6   

292   

1,430   

94   

32   

14   

5   

437   

$bn

9.9   

0.3   

8.6   

—   

1   

—   

—   

—   

0.5   

10.4   

236   

70   

28   

14   

3   

351   

$bn

9.1   

0.2   

8.4   

—   

0.5   

—   

—   

—   

0.3   

9.4   

733   

389   

311   

41   

2,904   

$bn

17.5   

3.2   

13.8   

—   

0.5   

—   

—   

—   

4.9   

22.4   

670   

642   

345   

260   

39   

1,956   

$bn

15.1   

3.5   

10.7   

0.4   

0.5   

—   

—   

—   

3.9   

19.0   

47   

2   

—   

—   

—   

49   

$bn

2.1   

—   

—   

1.5   

—   

0.6   

0.3   

0.3   

1.2   

3.6   

70   

7   

—   

—   

2   

79   

$bn

4.2   

1.3   

—   

2.3   

—   

0.6   

0.3   

0.3   

0.7   

4.6   

Total

1,855 

838 

421 

325 

46 

3,485 

$bn

33.9 

3.5 

22.4 

5.9 

1.5 

0.6 

0.3 

0.3 

6.7 

40.9 

1,067 

731 

373 

274 

44 

2,489 

$bn

33.7 

5 

19.1 

8 

1 

0.6 

0.3 

0.3 

5.2 

38.6 

The maximum exposure to loss from HSBC’s interests in unconsolidated structured entities represents the maximum loss it could incur 
as a result of its involvement with these entities regardless of the probability of the loss being incurred.

• For commitments, guarantees and written credit default swaps, the maximum exposure to loss is the notional amount of potential 

future losses.

• For retained and purchased investments and loans to unconsolidated structured entities, the maximum exposure to loss is the 

carrying value of these interests at the balance sheet reporting date.

The maximum exposure to loss is stated gross of the effects of hedging and collateral arrangements that HSBC has entered into in order 
to mitigate the Group's exposure to loss.

Securitisations

HSBC has interests in unconsolidated securitisation vehicles through holding notes issued by these entities. In addition, HSBC has 
investments in ABSs issued by third-party structured entities.

HSBC managed funds

HSBC establishes and manages money market funds and non-money market investment funds to provide customers with investment 
opportunities. Further information on funds under management is provided on page 90.

HSBC, as fund manager, may be entitled to receive management and performance fees based on the assets under management. HSBC 
may also retain units in these funds.

Non-HSBC managed funds

HSBC purchases and holds units of third-party managed funds in order to facilitate business and meet customer needs.

Other

HSBC has established structured entities in the normal course of business, such as structured credit transactions for customers, to 
provide finance to public and private sector infrastructure projects, and for asset and structured finance transactions.

HSBC Holdings plc Annual Report and Accounts 2020 337

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

In addition to the interests disclosed above, HSBC enters into derivative contracts, reverse repos and stock borrowing transactions with 
structured entities. These interests arise in the normal course of business for the facilitation of third-party transactions and risk 
management solutions.

HSBC sponsored structured entities

The amount of assets transferred to and income received from such sponsored structured entities during 2020 and 2019 were not 
significant.

21 Goodwill and intangible assets

Goodwill

Present value of in-force long-term insurance business

Other intangible assets

At 31 Dec

Footnotes

1

2020

$m
5,881   
9,435   
5,127   
20,443   

2019

$m

5,590 

8,945 

5,628 

20,163 

1 Included within other intangible assets is internally generated software with a net carrying value of $4,452m (2019: $4,829m). During the year, 
capitalisation of internally generated software was $1,934m (2019: $2,086m), impairment was $1,322m (2019: $38m) and amortisation was 
$1,085m (2019: $947m).

Movement analysis of goodwill

Gross amount

At 1 Jan 

Exchange differences

Other

At 31 Dec

Accumulated impairment losses

At 1 Jan

Impairment losses

Exchange differences

At 31 Dec

Net carrying amount at 31 Dec

Goodwill

Impairment testing

2020

$m

22,084   
967   
84   
23,135   

(16,494)   
(41)   
(719)   
(17,254)   
5,881   

2019

$m

22,180 

(154) 

58 

22,084 

(9,194) 

(7,349) 

49 

(16,494) 

5,590 

In previous years the Group’s annual impairment test in respect of goodwill allocated to each CGU was performed at 1 July. Beginning in 
2020 the annual impairment test will be performed as at 1 October to better align the timing of the test with cash flow projections 
approved by the Board. A review for indicators of impairment is undertaken at each subsequent quarter-end.

Basis of the recoverable amount

The recoverable amount of all CGUs to which goodwill has been allocated was equal to its value in use (‘VIU’) at each respective testing 
date. The VIU is calculated by discounting management’s cash flow projections for the CGU. At 1 October 2020, all CGUs supporting 
goodwill had a VIU larger than their respective carrying amounts. The key assumptions used in the VIU calculation for each individually 
significant CGU that is not impaired are discussed below.

Key assumptions in VIU calculation – significant CGUs at 1 October 2020

Goodwill at
1 Oct
2020

Discount 
rate

Growth rate
beyond initial
cash flow

Goodwill at
1 Jul
2020

Discount
rate

Nominal
growth rate
beyond initial
cash flow
projections

Goodwill at 
31 Dec 
2019

Discount
rate

Nominal
growth rate
beyond initial
cash flow
projections

Cash-generating unit Europe – WPB1

$m

3,582 

%

 9.6 

%

$m

 1.9   

3,496 

%

 8.3 

%

$m

 3.2   

3,464 

%

 8.3 

%

 1.7 

1   CGU tested as Europe – RBWM at 31 December 2019. Details regarding our change in global businesses are set out in Note 10.

At 1 October 2020, aggregate goodwill of $2,059m (1 July 2019: $2,938m; 31 December 2019: $2,126m) had been allocated to CGUs 
that were not considered individually significant. The Group’s CGUs do not carry on their balance sheets any significant intangible assets 
with indefinite useful lives, other than goodwill.

Management’s judgement in estimating the cash flows of a CGU

The cash flow projections for each CGU are based on plans approved by the Board. The Board challenges and endorses planning 
assumptions in light of internal capital allocation decisions necessary to support our strategy, current market conditions and 
macroeconomic outlook. For the 1 October 2020 impairment test, cash flow projections until the end of the first quarter of 2025 were 
considered. As required by IFRSs, estimates of future cash flows exclude estimated cash inflows or outflows that are expected to arise 
from restructuring initiatives before an entity has a constructive obligation to carry out the plan, and would therefore have recognised a 
provision for restructuring costs.

338 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Discount rate

The rate used to discount the cash flows is based on the cost of capital assigned to each CGU, which is derived using a capital asset 
pricing model (‘CAPM’). CAPM depends on a number of inputs reflecting financial and economic variables, including the risk-free rate 
and a premium to reflect the inherent risk of the business being evaluated. These variables are based on the market’s assessment of the 
economic variables and management’s judgement. The discount rates for each CGU are refined to reflect the rates of inflation for the 
countries within which the CGU operates. In addition, for the purposes of testing goodwill for impairment, management supplements 
this process by comparing the discount rates derived using the internally generated CAPM, with the cost of capital rates produced by 
external sources for businesses operating in similar markets.

Long-term growth rate

The long-term growth rate is used to extrapolate the cash flows in perpetuity because of the long-term perspective within the Group of 
business units making up the CGUs. These growth rates reflect inflation for the countries within which the CGU operates or from which 
it derives revenue.

Sensitivities of key assumptions in calculating VIU

At 31 December 2020, Europe – WPB was sensitive to reasonably possible adverse changes in key assumptions supporting the 
recoverable amount. In making an estimate of reasonably possible changes to assumptions, management considers the available 
evidence in respect of each input to the model, such as the external range of discount rates observable, historical performance against 
forecast and risks attaching to the key assumptions underlying cash flow projections. A reasonable change in one or more of these 
assumptions could result in an impairment.

Input

Key assumptions

Associated risks

Reasonably possible change

Cash-generating unit
Europe – WPB

Cash flow 
projections

• Level of interest rates and 

• Uncertain regulatory 

• Cash flow projections decrease by 30%.

yield curves.

environment.

• Competitors’ position 
within the market.
• Level and change in 
unemployment rates.

• Customer remediation and 

regulatory actions.

Discount rate • Discount rate used is a 

• External evidence 

• Discount rate increases by 100bps. This does not 

reasonable estimate of a 
suitable market rate for 
the profile of the business.

suggests that the rate 
used is not appropriate to 
the business.

result in an impairment.

Sensitivity of VIU to reasonably possible changes in key assumptions and changes to current assumptions to achieve nil headroom

In $bn (unless otherwise stated)

At 31 December 2020

Carrying amount

VIU

Impact on VIU

100 bps increase in the discount rate – single variable

30% decrease in cash flow projections – single variable

Cumulative impact of all changes

Changes to key assumption to reduce headroom to nil – single variable

Discount rate – bps

Cash flows – %

30 June impairment indicators review

Europe – WPB

11.1 

16.4 

(2.3) 

(6.0) 

(7.6) 

 271 

 (26.5) 

At 30 June 2020, we considered the pervasive macroeconomic deterioration caused by the outbreak of Covid-19, along with the impact 
on forecast profitability in some businesses, to be an indicator of goodwill impairment. As a result, an interim impairment test was 
performed by comparing the estimated recoverable amount of each CGU carrying goodwill, determined by a VIU calculation, with its 
carrying amount. At 30 June 2020, the goodwill allocated to Middle East and North Africa – WPB ($41m) was fully impaired. This CGU 
carried no further significant non-financial assets.

Other intangible assets

Impairment testing

We considered the pervasive macroeconomic deterioration caused by the outbreak of Covid-19, along with the impact of forecast 
profitability in some businesses, to be indicators of intangible asset impairment during the period. The impairment tests were performed 
by comparing the net carrying amount of CGUs containing intangible assets with their recoverable amounts. Recoverable amounts were 
determined by calculating an estimated VIU or fair value, as appropriate, for each CGU. Our cash flow forecasts were updated for 
changes in the external outlook, although economic and geopolitical risks increase the inherent estimation uncertainty.

We recognised $1.3bn of capitalised software impairment related principally to businesses within HSBC Bank plc, our non-ring-fenced 
bank in Europe, and to a lesser degree businesses within HSBC USA Inc. This impairment reflected underperformance and deterioration 
in the future forecasts of these businesses, substantially relating to prior periods in HSBC Bank plc.

Key assumptions in VIU calculation

We used a number of assumptions in our VIU calculation, in accordance with the requirements of IAS 36:

• Management’s judgement in estimating future cash flows: We considered past business performance, the scale of the current impact 

from the Covid-19 outbreak on our operations, current market conditions and our macroeconomic outlook to estimate future 
earnings. As required by IFRSs, estimates of future cash flows exclude estimated cash inflows or outflows that are expected to arise 
from restructuring initiatives before an entity has a constructive obligation to carry out the plan, and would therefore have recognised 

HSBC Holdings plc Annual Report and Accounts 2020 339

Financial statements 
 
 
 
 
 
 
Notes on the financial statements

a provision for restructuring costs. For some businesses, this means that the benefit of certain strategic actions are not included in 
this impairment assessment, including capital releases.

• Long-term growth rates: The long-term growth rate is used to extrapolate the cash flows in perpetuity because of the long-term 

perspective of the businesses within the Group.

• Discount rates: Rates are based on a CAPM calculation considering market data for the businesses and geographies in which the 

Group operates. Discount rates ranged from 8.5% to 9.7% for HSBC Bank plc's businesses.

Future software capitalisation

We will continue to invest in digital capabilities to meet our strategic objectives. However, software capitalisation within businesses 
where impairment was identified will not resume until the performance outlook for each business indicates future profits are sufficient to 
support capitalisation. The cost of additional software investment in these businesses will be recognised as an operating expense until 
such time.

Sensitivity of estimates relating to non-financial assets 

As explained in Note 1.2(a), estimates of future cash flows for cash-generating units (‘CGUs’) are made in the review of goodwill and 
non-financial assets for impairment. Non-financial assets include other intangible assets shown above, and owned property, plant and 
equipment and right-of-use assets (see Note 22). The most significant sources of estimation uncertainty are in respect of the goodwill 
balances disclosed above. There are no non-financial asset balances relating to individual CGUs which involve estimation uncertainty 
that represents a significant risk of resulting in a material adjustment to the results and financial position of the Group within the next 
financial year. Non-financial assets are widely distributed across CGUs within the legal entities of the Group, including Corporate Centre 
assets that cannot be allocated to CGUs and are therefore tested for impairment at consolidated level, and the recoverable amounts of 
other intangible assets, owned property, plant and equipment, and right-of-use assets cannot be lower than individual asset fair values 
less costs to dispose, where relevant. At HSBC Holdings plc consolidated level, Corporate Centre assets that cannot be allocated to 
CGUs within the legal entities of the Group were sensitive to reasonably possible adverse changes in cash flow projections and discount 
rates, which could result in a recoverable amount that is lower than the carrying amount. Corporate Centre non-financial assets include 
owned property, plant and equipment ($2.1bn), right-of-use assets ($0.6bn) and other intangible assets ($0.5bn). A 12% decrease in cash 
flow projections or a 110bps increase in the discount rate (from 10.5% to 11.6%) would reduce the current CGU headroom ($27.5bn) to 
nil.

Present value of in-force long-term insurance business

When calculating the present value of in-force long-term (‘PVIF’) insurance business, expected cash flows are projected after adjusting 
for a variety of assumptions made by each insurance operation to reflect local market conditions, and management’s judgement of 
future trends and uncertainty in the underlying assumptions is reflected by applying margins (as opposed to a cost of capital 
methodology) including valuing the cost of policyholder options and guarantees using stochastic techniques. 

Actuarial Control Committees of each key insurance entity meet on a quarterly basis to review and approve PVIF assumptions. All 
changes to non-economic assumptions, economic assumptions that are not observable and model methodologies must be approved by 
the Actuarial Control Committee.

Movements in PVIF

At 1 Jan

Change in PVIF of long-term insurance business

–  value of new business written during the year

–  expected return

–  assumption changes and experience variances (see below)

–  other adjustments

Exchange differences and other movements

At 31 Dec

Footnotes

1

2020

$m

8,945   

382   

776   

(1,003)   

604   

5   

108   

9,435   

2019

$m

7,149 

1,749 

1,225 

(836) 

1,378 

(18) 

47 

8,945 

1 ‘Expected return’ represents the unwinding of the discount rate and reversal of expected cash flows for the period.

Assumption changes and experience variances

Included within this line item are:

• $132m (2019: $1,126m), directly offsetting interest rate-driven changes to the valuation of liabilities under insurance contracts;

• $247m (2019: $36m), reflecting the future expected sharing of returns with policyholders on contracts with discretionary participation 

features (‘DPF’), to the extent this sharing is not already included in liabilities under insurance contracts; and

• $225m (2019: $216m), driven by other assumptions changes and experience variances.

Key assumptions used in the computation of PVIF for main life insurance operations

Economic assumptions are set in a way that is consistent with observable market values. The valuation of PVIF is sensitive to observed 
market movements and the impact of such changes is included in the sensitivities presented below.

Weighted average risk-free rate

Weighted average risk discount rate

Expense inflation

2020

2019

Hong Kong

France1

Hong Kong

France1

%

 0.71 

 4.96 

 3.00 

%

 0.34 

 1.34 

 1.60 

%

 1.84 

 5.44 

 3.00 

%

 0.44 

 1.27 

 1.70 

1 For 2020, the calculation of France’s PVIF assumes a risk discount rate of 1.34% (2019: 1.27%) plus a risk margin of $213m (2019: $130m).

340 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
Sensitivity to changes in economic assumptions

The Group sets the risk discount rate applied to the PVIF calculation by starting from a risk-free rate curve and adding explicit 
allowances for risks not reflected in the best-estimate cash flow modelling. Where the insurance operations provide options and 
guarantees to policyholders, the cost of these options and guarantees is accounted for as a deduction from the PVIF asset, unless the 
cost of such guarantees is already allowed for as an explicit addition to liabilities under insurance contracts. For further details of these 
guarantees and the impact of changes in economic assumptions on our insurance manufacturing subsidiaries, see page 193.

Sensitivity to changes in non-economic assumptions

Policyholder liabilities and PVIF are determined by reference to non-economic assumptions, including mortality and/or morbidity, lapse 
rates and expense rates. For further details on the impact of changes in non-economic assumptions on our insurance manufacturing 
operations, see page 194.

22 Prepayments, accrued income and other assets

Prepayments and accrued income

Settlement accounts

Cash collateral and margin receivables

Assets held for sale

Bullion 

Endorsements and acceptances 

Reinsurers’ share of liabilities under insurance contracts (Note 4) 

Employee benefit assets (Note 5)

Right-of-use assets

Owned property, plant and equipment

Other accounts 

At 31 Dec

2020

$m
8,114   
17,316   
59,543   
299   
20,151   
10,278   
3,448   
10,450   
4,002   
10,412   
12,399   
156,412   

2019

$m

9,057 

14,744 

49,148 

123 

14,830 

10,198 

3,592 

8,280 

4,222 

10,480 

12,006 

136,680 

Prepayments, accrued income and other assets include $105,469m (2019: $92,979m) of financial assets, the majority of which are 
measured at amortised cost.

23 Trading liabilities

Deposits by banks

Customer accounts

Other debt securities in issue (Note 25)

Other liabilities – net short positions in securities

At 31 Dec

1 ‘Deposits by banks’ and ‘Customer accounts’ include repos, stock lending and other amounts.

24 Financial liabilities designated at fair value

HSBC

Deposits by banks and customer accounts

Liabilities to customers under investment contracts

Debt securities in issue (Note 25)

Subordinated liabilities (Note 28)

Preferred securities (Note 28)

At 31 Dec

Footnotes

1

1

2020

$m

6,689   

10,681   

1,582   

56,314   

75,266   

2019

$m

4,187 

6,999 

1,404 

70,580 

83,170 

Footnotes

1, 2

2020

$m
19,176   
6,385   
121,034   
10,844   
—   
157,439   

2019

$m
17,660 

5,893 

130,364 

10,130 

419 

164,466 

1  Structured deposits placed at HSBC Bank USA are insured by the Federal Deposit Insurance Corporation, a US government agency, up to 

2 

$250,000 per depositor.
In 2020, cash prime brokerage balances of $3,889m have been presented as a single balance, resulting in a reclassification from customer 
accounts at amortised cost to provide more relevant information on the effect of these transactions on the Group’s financial position. 
Comparatives have not been re-presented.

The carrying amount of financial liabilities designated at fair value was $9,333m more than the contractual amount at maturity 
(2019: $6,120m more). The cumulative amount of change in fair value attributable to changes in credit risk was a loss of $2,542m (2019: 
loss of $2,877m). 

HSBC Holdings plc Annual Report and Accounts 2020 341

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings

Debt securities in issue (Note 25)

Subordinated liabilities (Note 28)

At 31 Dec

2020

$m

19,624   

6,040   

25,664   

2019

$m

24,687 

5,616 

30,303 

The carrying amount of financial liabilities designated at fair value was $3,019m more than the contractual amount at maturity
(2019: $2,227m more). The cumulative amount of change in fair value attributable to changes in credit risk was a loss of $1,210m (2019: 
$1,386m).

25 Debt securities in issue

HSBC

Bonds and medium-term notes 

Other debt securities in issue 

Total debt securities in issue

Included within:

–  trading liabilities (Note 23)

–  financial liabilities designated at fair value (Note 24)

At 31 Dec

HSBC Holdings

Debt securities 

Included within:

–  financial liabilities designated at fair value (Note 24)

At 31 Dec

26 Accruals, deferred income and other liabilities

Accruals and deferred income

Settlement accounts

Cash collateral and margin payables

Endorsements and acceptances

Employee benefit liabilities (Note 5)

Lease liabilities

Other liabilities

At 31 Dec

2020

$m

176,570   
41,538   
218,108   

(1,582)   
(121,034)   
95,492   

2020

$m
83,653   

(19,624)   
64,029   

2020

$m
10,406   
13,008   
65,557   
10,293   
2,025   
4,614   
22,721   
128,624   

2019

$m

180,969 

55,354 

236,323 

(1,404) 

(130,364) 

104,555 

2019

$m

81,531 

(24,687) 

56,844 

2019

$m

11,808 

14,356 
56,646 

10,127 

1,771 

4,604 

18,844 

118,156 

Accruals, deferred income and other liabilities include $120,229m (2019: $111,395m) of financial liabilities, the majority of which are 
measured at amortised cost.

342 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
27 Provisions

Provisions (excluding contractual commitments)

At 1 Jan 2020

Additions

Amounts utilised

Unused amounts reversed

Exchange and other movements

At 31 Dec 2020
Contractual commitments1
At 1 Jan 2020

Net change in expected credit loss provision and other 
movements

At 31 Dec 2020

Total provisions

At 31 Dec 2019

At 31 Dec 2020

Provisions (excluding contractual commitments)

At 1 Jan 2019

Additions

Amounts utilised

Unused amounts reversed

Exchange and other movements

At 31 Dec 2019
Contractual commitments1
At 1 Jan 2019

Net change in expected credit loss provision and other 
movements

At 31 Dec 2019

Total provisions

At 31 Dec 2018

At 31 Dec 2019

Restructuring
costs

Legal proceedings
and regulatory
matters

$m

$m

Customer
remediation

$m

Other
provisions

$m

356   

698   

(322)   

(74)   

13   

671   

605   

347   

(177)   

(75)   

56   

756   

1,646   

189   

(739)   

(240)   

2   

858   

280   

222   

(125)   

(80)   

8   

305   

130   

402   

(203)   

(34)   

61   

356   

1,128   

282   

(660)   

(158)   

13   

605   

788   

1,674   

(837)   

(49)   

70   

1,646   

357   

223   

(81)   

(108)   

(111)   

280   

Total

$m

2,887 

1,456 

(1,363) 

(469) 

79 

2,590 

511 

577 

1,088 

3,398 

3,678 

2,403 

2,581 

(1,781) 

(349) 

33 

2,887 

517 

(6) 

511 

2,920 

3,398 

1  Contractual commitments include the provision for contingent liabilities measured under IFRS 9 ‘Financial Instruments’ in respect of financial 

guarantees and the expected credit loss provision on off-balance sheet guarantees and commitments.

Further details of ‘Legal proceedings and regulatory matters’ are set out in Note 34. Legal proceedings include civil court, arbitration or 
tribunal proceedings brought against HSBC companies (whether by way of claim or counterclaim) or civil disputes that may, if not 
settled, result in court, arbitration or tribunal proceedings. Regulatory matters refer to investigations, reviews and other actions carried 
out by, or in response to the actions of, regulators or law enforcement agencies in connection with alleged wrongdoing by HSBC.

Customer remediation refers to HSBC’s activities to compensate customers for losses or damages associated with a failure to comply 
with regulations or to treat customers fairly. Customer remediation is often initiated by HSBC in response to customer complaints and/or 
industry developments in sales practices and is not necessarily initiated by regulatory action. Further details of customer remediation are 
set out in this note.

At 31 December 2020, $0.3bn (2019: $1.1bn) of the customer remediation provision related to the estimated liability for redress in 
respect of the possible mis-selling of payment protection insurance (‘PPI’) policies in previous years. Of the $1.1bn balance at 31 
December 2019, $0.6bn has been utilised during 2020 and an unused release of $0.1bn was recognised.

At 31 December 2020, a provision of $0.3bn (2019: $0.3bn) was held relating to the estimated liability for redress payable to customers 
following a review of historical collections and recoveries practices in the UK.

For further details of the impact of IFRS 9 on undrawn loan commitments and financial guarantees, presented in ‘Contractual 
commitments’, see Note 32. This provision results from the adoption of IFRS 9 and has no comparatives. Further analysis of the 
movement in the expected credit loss provision is disclosed within the 'Reconciliation of allowances for loans and advances to banks 
and customers including loan commitments and financial guarantees' table on page 136.

HSBC Holdings plc Annual Report and Accounts 2020 343

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

28 Subordinated liabilities

HSBC’s subordinated liabilities

At amortised cost

–  subordinated liabilities

–  preferred securities

Designated at fair value (Note 24)

–  subordinated liabilities

–  preferred securities

At 31 Dec

Issued by HSBC subsidiaries

Issued by HSBC Holdings

2020

$m

21,951   

20,095   

1,856   

10,844   

10,844   

—   

32,795   

10,223   

22,572   

2019

$m

24,600 

22,775 

1,825 

10,549 

10,130 

419 

35,149 

12,363 

22,786 

Subordinated liabilities rank behind senior obligations and generally count towards the capital base of HSBC. Capital securities may be 
called and redeemed by HSBC subject to prior notification to the PRA and, where relevant, the consent of the local banking regulator. If 
not redeemed at the first call date, coupons payable may reset or become floating rate based on interbank rates. On subordinated 
liabilities other than floating rate notes, interest is payable at fixed rates of up to 10.176%.

The balance sheet amounts disclosed in the following table are presented on an IFRS basis and do not reflect the amount that the 
instruments contribute to regulatory capital, principally due to regulatory amortisation and regulatory eligibility limits.

344 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
2020

$m

900   

900   

—   

956   

956   

750   

500   

300   

300   

2019

$m

900 

900 

420 

925 

1,345 

750 

500 

300 

300 

1,850   

1,850 

409   

583   

981   

306   

812   

3,091   

4,941   

400   

400   

124   

124   

—   

222   

200   

422   

—   

497   

533   

700   

396 

549 

875 

296 

785 

2,901 

4,751 

400 

400 

122 

122 

748 

221 

202 

1,171 

1,246 

463 

496 

700 

HSBC’s subsidiaries subordinated liabilities in issue

Additional tier 1 capital securities guaranteed by HSBC Holdings

$900m

10.176% non-cumulative step-up perpetual preferred securities, series 2 

Additional tier 1 capital securities guaranteed by HSBC Bank plc

£300m

£700m

5.862% non-cumulative step-up perpetual preferred securities 

5.844% non-cumulative step-up perpetual preferred securities 

Tier 2 securities issued by HSBC Bank plc

$750m

$500m

$300m

$300m

£300m

£350m

£500m

£225m

£600m

Undated floating rate primary capital notes

Undated floating rate primary capital notes

Undated floating rate primary capital notes, series 3

7.65% subordinated notes 

6.50% subordinated notes 

5.375% callable subordinated step-up notes

5.375% subordinated notes 

6.25% subordinated notes 

4.75% subordinated notes 

Footnotes

First call date Maturity date

1

1

2

Jun 2030

Apr 2020

Nov 2031

Jun 1990

Sep 1990

Jun 1992

— 

May 2025  

— 

Jul 2023  

3

Nov 2025

Nov 2030  

— 

— 

— 

Aug 2033  

Jan 2041  

Mar 2046  

Tier 2 securities issued by The Hongkong and Shanghai Banking Corporation Ltd

$400m

Primary capital undated floating rate notes (third series)

Jul 1991

Tier 2 securities issued by HSBC Bank Malaysia Berhad

MYR500m

5.05% subordinated bonds

Tier 2 securities issued by HSBC USA Inc.

$750m

$250m

5.00% subordinated notes 

7.20% subordinated debentures 

Other subordinated liabilities each less than $150m

Tier 2 securities issued by HSBC Bank USA, N.A.

$1,250m

$1,000m

$750m

$700m

4.875% subordinated notes 

5.875% subordinated notes 

5.625% subordinated notes 

7.00% subordinated notes 

Tier 2 securities issued by HSBC Finance Corporation

$2,939m

6.676% senior subordinated notes

Tier 2 securities issued by HSBC Bank Canada

7

7

8

8

5

5

Nov 2022

Nov 2027  

— 

— 

Sep 2020  

Jul 2097  

— 

— 

— 

— 

Aug 2020  

Nov 2034  

Aug 2035  

Jan 2039  

6,7

— 

Jan 2021  

509   

507 

1,730   

2,905 

Other subordinated liabilities each less than $150.00m

Oct 1996

Nov 2083  

Securities issued by other HSBC subsidiaries

Other subordinated liabilities each less than $200m

Subordinated liabilities issued by HSBC subsidiaries at 31 Dec

4

9   

9   

26 

26 

232   

236 

10,223   

12,363 

1 See paragraph below, ‘Guaranteed by HSBC Holdings or HSBC Bank plc’.
2  HSBC Bank plc exercised the call option on the security in April 2020 and the security was subsequently redeemed.
3  The interest rate payable after November 2025 is the sum of the three-month sterling Libor plus 1.5 percentage points.
4  These securities are included in the capital base of HSBC, a subset of which are included in accordance with the grandfathering provisions under 
CRR II, with the exception of $109m in relation to securities which matured 31 December 2020, settlement expected in June 2021, which are no 
longer eligible for inclusion in the capital base of HSBC. 

5  HSBC tendered for these securities in November 2019. The principal balance is $358m and $383m respectively. The original notional value of 

these securities are $1,000m and $750m respectively.

6  HSBC tendered for these securities in 2017. In January 2018, a further tender was conducted. The principal balance is $507m. The original 

notional of these securities is $2,939m. This instrument matured and settled in January 2021. 

7  These securities are ineligible for inclusion in the capital base of HSBC.
8  These securities matured in 2020 and were redeemed.

HSBC Holdings’ subordinated liabilities

At amortised cost 

Designated at fair value (Note 24)

At 31 Dec

2020

$m

17,916   

6,040   

23,956   

2019

$m

18,361 

5,616 

23,977 

HSBC Holdings plc Annual Report and Accounts 2020 345

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings’ subordinated liabilities in issue

Tier 2 securities issued by HSBC Holdings

Amounts owed to third parties

$2,000m

$1,500m

$1,500m

$488m

$222m

$2,000m

$2,500m

$1,500m

$1,500m

£650m

£650m

£750m

£900m

4.25% subordinated notes

4.25% subordinated notes

4.375% subordinated notes

7.625% subordinated notes

7.35% subordinated notes

6.50% subordinated notes

6.50% subordinated notes

6.80% subordinated notes

5.25% subordinated notes

5.75% subordinated notes

6.75% subordinated notes

7.00% subordinated notes

6.00% subordinated notes

€1,500m

€1,000m

3.0% subordinated notes

3.125% subordinated notes

Amounts owed to HSBC undertakings

$900m

10.176% subordinated step-up cumulative notes

Other securities issued by HSBC Holdings

Amounts owed to third parties

$1,500m

5.625% contingent convertible securities

At 31 Dec

Footnotes

2,3

2

2

1

1

1

1

1

2

2

2

2

2

2

2

4

First call

date

Maturity

date

2020

$m

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

 Mar 2024  

Aug 2025  

 Nov 2026  

May 2032  

Nov 2032  

May 2036  

Sep 2037  

Jun 2038  

Mar 2044  

Dec 2027  

Sep 2028  

Apr 2038  

Mar 2040  

Jun 2025  

Jun 2028  

Jun 2030

Jun 2040  

Nov 2019

Jan 2020  

2,151   

1,702   

1,736   

541   

243   

2,034   

3,033   

1,490   

2,092   

1,130   

884   

1,157   

1,483   

1,916   

1,472   

23,064   

892   

892   

—   

—   

23,956   

2019

$m

2,076 

1,611 

1,626 

545 

245 

2,036 

2,738 

1,490 

1,886 

1,059 

855 

1,064 

1,294 

1,736 

1,321 

21,582 

892 

892 

1,503 

1,503 

23,977 

1 Amounts owed to third parties represent securities included in the capital base of HSBC as tier 2 securities in accordance with the grandfathering 

provisions under CRR II. Prior period figures are included on a CRD IV basis.

2 These securities are included in the capital base of HSBC as fully CRR II-compliant tier 2 securities on an end point basis.
3  These subordinated notes are measured at amortised cost in HSBC Holdings, where the interest rate risk is hedged using a fair value hedge, 

while they are measured at fair value in the Group.

4  This security was called by HSBC Holdings on 22 November 2019 and was redeemed and cancelled on 17 January 2020. Between the date of 
exercise of the call option and the redemption, this security was considered to be a subordinated liability. Refer to Note 31 for further details on 
additional tier 1 securities.

Guaranteed by HSBC Holdings or HSBC Bank plc

Capital securities guaranteed by HSBC Holdings or HSBC Bank plc were issued by the Jersey limited partnerships. The proceeds of these 
were lent to the respective guarantors by the limited partnerships in the form of subordinated notes. They qualify as additional tier 1 
capital for HSBC under CRR II by virtue of the application of grandfathering provisions. The capital security guaranteed by HSBC Bank 
plc also qualifies as additional tier 1 capital for HSBC Bank plc (on a solo and a consolidated basis) under CRR II by virtue of the same 
grandfathering process.

These preferred securities, together with the guarantee, are intended to provide investors with rights to income and capital distributions 
and distributions upon liquidation of the relevant issuer that are equivalent to the rights that they would have had if they had purchased 
non-cumulative perpetual preference shares of the relevant issuer. There are limitations on the payment of distributions if such payments 
are prohibited under UK banking regulations or other requirements, if a payment would cause a breach of HSBC’s capital adequacy 
requirements, or if HSBC Holdings or HSBC Bank plc has insufficient distributable reserves (as defined).

HSBC Holdings and HSBC Bank plc have individually covenanted that, if prevented under certain circumstances from paying 
distributions on the preferred securities in full, they will not pay dividends or other distributions in respect of their ordinary shares, or 
repurchase or redeem their ordinary shares, until the distribution on the preferred securities has been paid in full.

If the consolidated total capital ratio of HSBC Holdings falls below the regulatory minimum required or if the Directors expect it to do so 
in the near term, provided that proceedings have not been commenced for the liquidation, dissolution or winding up of HSBC Holdings, 
the holders’ interests in the preferred securities guaranteed by HSBC Holdings will be exchanged for interests in preference shares 
issued by HSBC Holdings that have economic terms which are in all material respects equivalent to the preferred securities and their 
guarantee.

If the preferred securities guaranteed by HSBC Bank plc are outstanding in November 2048, or if the total capital ratio of HSBC Bank plc 
(on a solo or consolidated basis) falls below the regulatory minimum required, or if the Directors expect it to do so in the near term, 
provided that proceedings have not been commenced for the liquidation, dissolution or winding up of HSBC Bank plc, the holders’ 
interests in the preferred security guaranteed by HSBC Bank plc will be exchanged for interests in preference shares issued by HSBC 
Bank plc that have economic terms which are in all material respects equivalent to the preferred security and its guarantee. 

Tier 2 securities

Tier 2 capital securities are either perpetual or dated subordinated securities on which there is an obligation to pay coupons. These 
capital securities are included within HSBC's regulatory capital base as tier 2 capital under CRR II, either as fully eligible capital or by 
virtue of the application of grandfathering provisions. In accordance with CRR II, the capital contribution of all tier 2 securities is 
amortised for regulatory purposes in their final five years before maturity.

346 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
29 Maturity analysis of assets, liabilities and off-balance sheet commitments

The table on page 348 provides an analysis of consolidated total assets, liabilities and off-balance sheet commitments by residual 
contractual maturity at the balance sheet date. These balances are included in the maturity analysis as follows:

• Trading assets and liabilities (including trading derivatives but excluding reverse repos, repos and debt securities in issue) are 

included in the ‘Due not more than 1 month’ time bucket, because trading balances are typically held for short periods of time.

• Financial assets and liabilities with no contractual maturity (such as equity securities) are included in the ‘Due over 5 years’ time 
bucket. Undated or perpetual instruments are classified based on the contractual notice period, which the counterparty of the 
instrument is entitled to give. Where there is no contractual notice period, undated or perpetual contracts are included in the 
‘Due over 5 years’ time bucket.

• Non-financial assets and liabilities with no contractual maturity are included in the ‘Due over 5 years’ time bucket.

• Financial instruments included within assets and liabilities of disposal groups held for sale are classified on the basis of the 

contractual maturity of the underlying instruments and not on the basis of the disposal transaction.

• Liabilities under insurance contracts are included in the ‘Due over 5 years’ time bucket. Liabilities under investment contracts 

are classified in accordance with their contractual maturity. Undated investment contracts are included in the ‘Due over 5 years’ time 
bucket, although such contracts are subject to surrender and transfer options by the policyholders.

• Loan and other credit-related commitments are classified on the basis of the earliest date they can be drawn down.

HSBC Holdings plc Annual Report and Accounts 2020 347

Financial statements 
Notes on the financial statements

HSBC

Maturity analysis of assets, liabilities and off-balance sheet commitments

Due over
1 month
but not
more than
3 months

Due over
3 months
but not
more than
6 months

Due over
6 months
but not
more than
9 months

Due over
9 months
but not
more than
1 year

Due over
1 year
but not
more than
2 years

Due over
2 years
but not
more than
5 years

Due not
more than
1 month

Due over
5 years

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

Financial assets

Cash and balances at central banks

  304,481   

Items in the course of collection from other banks  

4,094   

Hong Kong Government certificates of 
indebtedness

40,420   

—   

—   

—   

Trading assets

  228,434   

1,778   

Financial assets designated or otherwise 
mandatorily measured at fair value

Derivatives

3,061   

  306,561   

240   

15   

—   

—   

—   

458   

466   

12   

—   

—   

—   

135   

262   

14   

—   

—   

—   

67   

—   

—   

—   

—   

—    304,481 

—   

4,094 

—   

644   

—   

474   

—   

40,420 

—    231,990 

454   

1,424   

1,992   

37,654   

45,553 

14   

441   

424   

245    307,726 

Loans and advances to banks

51,652   

11,283   

5,640   

3,068   

2,284   

4,059   

3,359   

271   

81,616 

Loans and advances to customers

  172,306   

70,746   

65,838   

44,392   

38,606    112,440    206,448    327,211   1,037,987 

–  personal

51,711   

9,645   

7,918   

7,270   

7,033   

26,318   

70,447    275,736    456,078 

–  corporate and commercial

  101,684   

55,009   

51,755   

31,529   

28,553   

76,225    125,393   

47,446    517,594 

–  financial
Reverse repurchase agreements – non-trading

18,911   
  157,234   

6,092   
44,658   

6,165   
16,655   

5,593   
5,113   

3,020   
1,324   

9,897   
3,058   

10,608   
2,586   

4,029   

64,315 
—    230,628 

Financial investments

47,270   

77,450   

44,255   

14,523   

24,112   

48,741    100,007    134,335    490,693 

Accrued income and other financial assets

93,118   

5,951   

2,743   

475   

458   

267   

444   

2,107    105,563 

Financial assets at 31 Dec 2020

 1,408,631    212,121    136,067   

67,982   

67,319    171,074    315,734    501,823   2,880,751 

Non-financial assets

—   

—   

—   

—   

—   

—   

—    103,413    103,413 

Total assets at 31 Dec 2020

 1,408,631    212,121    136,067   

67,982   

67,319    171,074    315,734    605,236   2,984,164 

Off-balance sheet commitments received

Loan and other credit-related commitments

60,849   

—   

—   

—   

—   

—   

—   

—   

60,849 

Financial liabilities

Hong Kong currency notes in circulation

Deposits by banks
Customer accounts1
–  personal

40,420   

—   

60,973   

1,396   

—   

714   

—   

695   

—   

197   

—   

—   

—   

40,420 

718   

16,757   

630   

82,080 

 1,533,595   

61,376   

22,568   

9,375   

8,418   

4,467   

2,859   

122   1,642,780 

  766,631   

32,429   

15,511   

6,276   

5,825   

3,591   

1,976   

39    832,278 

–  corporate and commercial

  588,887   

22,856   

5,963   

2,966   

2,058   

–  financial
Repurchase agreements – non-trading

  178,077   
  102,633   

6,091   
3,979   

1,094   
2,165   

Items in the course of transmission to other 
banks

Trading liabilities

Financial liabilities designated at 
fair value

4,343   

—   

70,799   

3,377   

—   

400   

133   
386   

—   

143   

535   
675   

—   

185   

627   

249   
16   

—   

289   

777   

106   
1,035   

37    624,171 

46    186,331 
1,012    111,901 

—   

72   

—   

4,343 

1   

75,266 

18,434   

7,333   

6,973   

6,775   

6,593   

14,182   

40,510   

56,639    157,439 

–  debt securities in issue: covered bonds

—   

—   

—   

—   

—   

1,239   

2,918   

—   

4,157 

–  debt securities in issue: unsecured

10,762   

4,470   

5,522   

5,604   

5,530   

10,455   

31,710   

42,825    116,878 

–  subordinated liabilities and preferred securities
–  other2
Derivatives

—   

—   

—   

—   

—   

—   

3,912   

6,932   

10,844 

7,672   

2,863   

1,451   

1,171   

1,063   

2,488   

1,970   

6,882   

25,560 

  300,902   

264   

198   

38   

55   

237   

726   

581    303,001 

Debt securities in issue

–  covered bonds

–  otherwise secured

–  unsecured

6,552   

12,329   

14,964   

9,764   

3,878   

9,215   

16,618   

22,172   

95,492 

—   

—   

28   

—   

750   

1,275   

999   

—   

1,094   

1,585   

1,001   

1,000   

—   

274   

1,640   

1,590   

3,052 

8,184 

5,458   

10,744   

13,935   

8,764   

3,128   

7,666   

13,979   

20,582   

84,256 
3,053    120,341 
21,951 

18,413   

Accruals and other financial liabilities
Subordinated liabilities

96,821   
619   

9,794   
—   

3,886   
237   

692   
—   

1,174   
12   

1,742   
12   

3,179   
2,658   

Total financial liabilities at 31 Dec 2020

 2,236,091   

99,848   

52,105   

27,868   

21,187   

30,878   

84,414    102,623   2,655,014 

Non-financial liabilities

—   

—   

—   

—   

—   

—   

—    124,155    124,155 

Total liabilities at 31 Dec 2020

 2,236,091   

99,848   

52,105   

27,868   

21,187   

30,878   

84,414    226,778   2,779,169 

Off-balance sheet commitments given

Loan and other credit-related commitments

–  personal

–  corporate and commercial 

–  financial 

  842,974   

  235,606   

  471,410   

  135,958   

435   

172   

250   

13   

172   

27   

138   

7   

243   

47   

194   

2   

296   

115   

178   

3   

180   

125   

37   

18   

299   

288   

11   

—   

171    844,770 

171    236,551 

—    472,218 

—    136,001 

348 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Accrued income and other financial assets

80,661   

5,544   

2,532   

915   

495   

432   

363   

2,037   

92,979 

Maturity analysis of assets, liabilities and off-balance sheet commitments (continued)

Due over
1 month
but not
more than
3 months

Due over
3 months
but not
more than
6 months

Due over
6 months
but not
more than
9 months

Due over
9 months
but not
more than
1 year

Due over
1 year
but not
more than
2 years 

Due over
2 years
but not
more than
5 years 

Due not
more than
1 month

Due over
5 years

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

Financial assets

Cash and balances at central banks
Items in the course of collection from other banks  

  154,099   

4,956   

Hong Kong Government certificates of 
indebtedness 

Trading assets 

Financial assets designated at fair value 

Derivatives 

Loans and advances to banks

Loans and advances to customers

–  personal 

–  corporate and commercial

–  financial 
Reverse repurchase agreements 
– non-trading

Financial investments 

Financial assets at 31 Dec 2019

Non-financial assets 

Total assets at 31 Dec 2019

Off-balance sheet commitments received

Loan and other credit-related commitments

Financial liabilities

Hong Kong currency notes in circulation 

Deposits by banks
Customer accounts1
–  personal 

–  corporate and commercial

–  financial 

Repurchase agreements – non-trading 

Items in the course of transmission to other 
banks

Trading liabilities 

Financial liabilities designated at fair value 

—   

—   

—   

644   

74   

150   

—   

—   

—   

412   

381   

24   

—   

—   

—   

62   

200   

27   

—   

—   

—   

452   

422   

22   

—   

—   

—   

152   

780   

112   

—   

—   

—   

540   

—   

—   

154,099 

4,956 

—   

—   

38,380 

254,271 

2,356   

34,568   

43,627 

294   

425   

242,995 

38,380   

  252,009   

4,846   

  241,941   

41,554   

7,826   

4,877   

2,592   

2,859   

6,848   

2,005   

642   

69,203 

  190,675   

82,379   

61,254   

36,005   

36,755   

106,203   

227,811   

295,661    1,036,743 

51,893   

14,547   

8,562   

7,245   

6,931   

22,923   

66,761   

252,275   

431,137 

  118,585   

61,629   

45,924   

25,006   

25,069   

71,751   

147,139   

39,958   

535,061 

20,197   

6,203   

6,768   

3,754   

4,755   

11,529   

13,911   

3,428   

70,545 

  164,741   

38,997   

17,933   

8,226   

6,305   

2,298   

2,362   

—   

240,862 

36,128   

64,472   

35,795   

17,485   

18,202   

48,427   

90,193   

132,610   

443,312 

  1,209,990    200,086    123,208   

65,512   

65,512   

165,252   

325,924   

465,943    2,621,427 

—   

—   

—   

—   

—   

—   

—   

93,725   

93,725 

  1,209,990    200,086    123,208   

65,512   

65,512   

165,252   

325,924   

559,668    2,715,152 

63,199   

—   

—   

—   

—   

—   

—   

—   

63,199 

38,380   

46,397   

—   

—   

4,167   

2,773   

—   

454   

—   

844   

  1,287,358   

81,038   

38,343   

11,530   

11,342   

  646,843   

49,405   

29,320   

  479,763   

24,214   

  160,752   

  132,042   

7,419   

3,402   

7,162   

1,861   

1,579   

8,484   

2,621   

425   

1,882   

6,852   

3,009   

1,481   

59   

—   

2,455   

5,275   

3,631   

1,119   

525   

354   

—   

876   

4,075   

2,646   

1,388   

41   

2   

—   

29   

—   

1,056   

38,380 

59,022 

154    1,439,115 

71   

41   

42   

747,252 

519,317 

172,546 

1,024   

140,344 

—   

—   

4,817 

83,170 

4,817   

82,130   

12,844   

—   

209   

—   

265   

—   

148   

—   

102   

—   

287   

4,667   

4,236   

4,552   

5,196   

26,081   

43,534   

63,356   

164,466 

–  debt securities in issue: covered bonds 

—   

—   

—   

—   

1,139   

—   

2,663   

1,159   

4,961 

–  debt securities in issue: unsecured 

8,884   

2,046   

2,946   

3,757   

3,030   

22,950   

34,753   

47,036   

125,402 

–  subordinated liabilities and preferred securities

23   

—   

—   

–  other 

Derivatives 

Debt securities in issue 

–  covered bonds 

–  otherwise secured 

–  unsecured 

3,937   

2,621   

1,290   

  237,901   

105   

73   

—   

795   

10   

—   

—   

1,027   

3,131   

18   

68   

2,131   

3,987   

540   

8,396   

6,765   

10,550 

23,553 

782   

239,497 

8,183   

17,374   

12,799   

13,152   

11,382   

14,572   

20,048   

7,045   

104,555 

—   

2,015   

—   

2   

—   

248   

—   

161   

—   

—   

749   

219   

998   

958   

—   

1,663   

1,747 

5,266 

6,168   

17,372   

12,551   

12,991   

11,382   

13,604   

18,092   

5,382   

97,542 

Accruals and other financial liabilities

Subordinated liabilities 

87,796   

9,078   

3,914   

1,502   

—   

22   

1,244   

1,993   

2,058   

1,592   

2,823   

2,890   

111,395 

100   

755   

424   

19,804   

24,600 

Total financial liabilities at 31 Dec 2019

  1,939,350    120,040   

64,004   

34,965   

31,101   

51,439   

72,351   

96,111    2,409,361 

Non-financial liabilities 

—   

—   

—   

—   

—   

—   

—   

113,123   

113,123 

Total liabilities at 31 Dec 2019

  1,939,350    120,040   

64,004   

34,965   

31,101   

51,439   

72,351   

209,234    2,522,484 

Off-balance sheet commitments given

Loan and other credit-related commitments

–  personal

–  corporate and commercial

–  financial

  794,336   

  221,952   

  460,569   

  111,815   

600   

40   

117   

443   

590   

39   

96   

455   

313   

56   

52   

205   

551   

167   

381   

3   

442   

208   

218   

16   

458   

392   

66   

—   

318   

797,608 

299   

223,153 

19   

461,518 

—   

112,937 

1 ‘Customer accounts’ includes $463,524m (2019: $408,090m) insured by guarantee schemes.
2 In 2020, cash prime brokerage balances of $3,889m have been presented as a single balance, resulting in a reclassification from customer 

accounts at amortised cost to provide more relevant information on the effect of these transactions on the Group’s financial position. 
Comparatives have not been re-presented.

HSBC Holdings plc Annual Report and Accounts 2020 349

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings

Maturity analysis of assets, liabilities and off-balance sheet commitments (continued)

Due over
1 month
but not
more than
3 months

Due over
3 months
but not
more than
6 months

Due over
6 months
but not
more than
9 months

Due over
9 months
but not
more than
1 year

Due over
1 year
but not
more than
2 years 

Due over
2 years
but not
more than
5 years 

Due not
more than
1 month

Due over
5 years

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

Financial assets

Cash at bank and in hand:

–  balances with HSBC undertakings

Derivatives 

2,913   

1,473   

—   

—   

—   

5   

Loans and advances to HSBC undertakings 

—   

600   

120   

—   

—   

—   

—   

—   

—   

—   

9   

—   

—   

1,131   

2,080   

2,913 

4,698 

312   

6,027   

3,384   

10,443 

Financial assets with HSBC undertakings 
designated and otherwise mandatorily measured 
at fair value

—   

451   

—   

—   

—   

4,320   

23,203   

37,279   

65,253 

Financial investments

3,701   

3,769   

2,924   

799   

3,528   

2,764   

Accrued income and other financial assets

1,015   

275   

100   

33   

22   

—   

—   

—   

—   

—   

17,485 

1,445 

Total financial assets at 31 Dec 2020

9,102   

5,095   

3,149   

832   

3,550   

7,405   

30,361   

42,743    102,237 

Non-financial assets 

—   

—   

—   

—   

—   

—   

—    160,936    160,936 

Total assets at 31 Dec 2020

9,102   

5,095   

3,149   

832   

3,550   

7,405   

30,361    203,679    263,173 

Financial liabilities

Amounts owed to HSBC undertakings 

Financial liabilities designated at fair value 

–  debt securities in issue 

–  subordinated liabilities and preferred securities 

Derivatives 

Debt securities in issue 

Accruals and other financial liabilities

Subordinated liabilities 

31 Dec 2020

Non-financial liabilities 

Total liabilities at 31 Dec 2020

Off-balance sheet commitments given

Undrawn formal standby facilities, credit lines 
and other commitments to lend 

Financial assets

Cash at bank and in hand:

–  balances with HSBC undertakings

Derivatives 

Loans and advances to HSBC undertakings 
Loans and advances to HSBC undertakings 
designated at fair value

—   

—   

—   

—   

3,052   

—   

3,769   

—   

330   

984   

984   

—   

—   

503   

689   

—   

—   

859   

859   

—   

—   

—   

—   

—   

—   

—   

1,621   

563   

301   

—   

6,821   

2,506   

2,781   

—   

—   

—   

6,821   

2,506   

2,781   

57   

—   

620   

—   

620   

—   

—   

—   

—   

—   

—   

12   

—   

12   

—   

12   

—   

—   

—   

330 

3,088   

3,810   

16,923   

25,664 

3,088   

2,108   

12,585   

19,624 

—   

—   

1,702   

4,338   

—   

8   

6,040 

3,060 

2,186   

24,489   

34,667   

64,029 

—   

—   

1   

36   

4,865 

4,067   

13,849   

17,916 

5,274   

32,367   

65,483    115,864 

—   

—   

509   

509 

5,274   

32,367   

65,992    116,373 

—   

—   

—   

—   

—   

—   

—   

—   

— 

2,382   

596   

102   

—   

—   

672   

—   

—   

120   

—   

—   

—   

—   

—   

25   

—   

—   

—   

—   

—   

—   

—   

230   

—   

1,176   

2,382 

2,002 

600   

1,909   

6,790   

10,218 

—   

458   

24,845   

36,661   

61,964 

Financial investments in HSBC undertakings

2,754   

3,493   

1,873   

2,251   

2,721   

3,014   

Accrued income and other financial assets

93   

277   

97   

48   

16   

12   

—   

—   

—   

—   

16,106 

543 

Total financial assets at 31 Dec 2019

5,927   

4,442   

2,090   

2,324   

2,737   

4,084   

26,984   

44,627   

93,215 

Non-financial assets 

Total assets at 31 Dec 2019

Financial liabilities

Amounts owed to HSBC undertakings 

Financial liabilities designated at fair value 

–  debt securities in issue

–  subordinated liabilities and preferred securities

Derivatives 

Debt securities in issue 

Accruals and other financial liabilities

Subordinated liabilities 

Total financial liabilities at 31 Dec 2019

Non-financial liabilities 

Total liabilities at 31 Dec 2019

Off-balance sheet commitments given

Undrawn formal standby facilities, credit lines 
and other commitments to lend

—   

—   

—   

—   

—   

—   

—   

162,025   

162,025 

5,927   

4,442   

2,090   

2,324   

2,737   

4,084   

26,984   

206,652   

255,240 

—   

—   

—   

—   

1,838   

—   

900   

1,503   

4,241   

—   

464   

—   

—   

—   

—   

—   

574   

—   

1,038   

—   

4,241   

1,038   

—   

—   

—   

—   

—   

—   

303   

—   

303   

—   

303   

—   

—   

—   

—   

—   

—   

55   

—   

55   

—   

55   

—   

—   

—   

—   

—   

—   

10   

—   

10   

—   

10   

—   

5,651   

5,651   

—   

20   

—   

—   

6,710   

17,942   

6,710   

12,326   

—   

85   

5,616   

78   

464 

30,303 

24,687 

5,616 

2,021 

10,134   

23,786   

22,924   

56,844 

—   

—   

—   

35   

1,877 

2,076   

14,782   

18,361 

15,805   

32,657   

55,761   

109,870 

—   

—   

326   

326 

15,805   

32,657   

56,087   

110,196 

—   

—   

—   

—   

—   

—   

—   

—   

— 

Contractual maturity of financial liabilities

The following table shows, on an undiscounted basis, all cash flows relating to principal and future coupon payments (except for trading 
liabilities and derivatives not treated as hedging derivatives). For this reason, balances in the following table do not agree directly with 
those in our consolidated balance sheet. Undiscounted cash flows payable in relation to hedging derivative liabilities are classified 
according to their contractual maturities. Trading liabilities and derivatives not treated as hedging derivatives are included in the ‘Due not 
more than 1 month’ time bucket and not by contractual maturity.

350 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In addition, loans and other credit-related commitments and financial guarantees are generally not recognised on our balance sheet. The 
undiscounted cash flows potentially payable under loan and other credit-related commitments and financial guarantees are classified on 
the basis of the earliest date they can be called.

Cash flows payable by HSBC under financial liabilities by remaining contractual maturities

Deposits by banks

Customer accounts

Repurchase agreements – non-trading

Trading liabilities
Financial liabilities designated at fair value1
Derivatives

Debt securities in issue

Subordinated liabilities

Other financial liabilities

Loan and other credit-related commitments
Financial guarantees2
At 31 Dec 2020

Proportion of cash flows payable in period

Deposits by banks

Customer accounts

Repurchase agreements – non-trading

Trading liabilities

Financial liabilities designated at fair value

Derivatives

Debt securities in issue

Subordinated liabilities

Other financial liabilities

Loan and other credit-related commitments
Financial guarantees2
At 31 Dec 2019

Proportion of cash flows payable in period

Due not more
than 1 month

Due over
1 month but
not more than
3 months

Due over
3 months but
not more than
1 year

Due over
1 year but not
more than
5 years

$m

$m

$m

$m

Due over
5 years

$m

Total

$m

61,001   

1,442   

1,639   

17,352   

632   

82,066 

1,530,584   

64,809   

40,755   

102,664   

3,984   

3,257   

—   

—   

7,720   

1,058   

—   

75,266   

18,815   

300,158   

7,556   

19,243   

59,835   

55,475   

356   

579   

1,830   

6,551   

12,709   

29,520   

28,787   

739   

140,094   

170   

9,120   

1,102   

5,113   

7,024   

5,030   

153   

1,644,021 

1,017   

111,980 

—   

2,128   

24,075   

28,812   

75,266 

160,924 

305,051 

101,642 

37,847 

2,887   

162,244 

2,235,872   

100,146   

101,208   

128,636   

115,179   

2,681,041 

842,945   

18,200   

434   

13   

740   

93   

480   

37   

171   

41   

844,770 

18,384 

3,097,017   

100,593   

102,041   

129,153   

115,391   

3,544,195 

87%

3%

3%

4%

3%

46,471   

1,288,577   

132,156   

83,170   

13,447   

237,897   

8,757   

1,847   

127,898   

4,167   

81,037   

3,403   

—   

4,666   

105   

4,227   

62,105   

3,565   

—   

14,747   

522   

17,374   

38,423   

—   

9,079   

2,908   

6,792   

3,371   

9,900   

368   

—   

76,155   

1,076   

36,584   

5,197   

5,637   

1,084   

59,320 

191   

1,441,810 

1,036   

—   

68,045   

1,691   

8,177   

27,892   

2,992   

140,528 

83,170 

177,060 

241,291 

109,315 

37,844 

152,398 

1,940,220   

119,831   

133,289   

138,288   

111,108   

2,442,736 

795,243   

20,007   

601   

37   

561   

102   

886   

68   

317   

—   

797,608 

20,214 

2,755,470   

120,469   

133,952   

139,242   

111,425   

3,260,558 

85%

4%

4%

4%

3%

1 

In 2020, cash prime brokerage balances of $3,889m have been presented as a single balance, resulting in a reclassification from customer 
accounts at amortised cost to provide more relevant information on the effect of these transactions on the Group’s financial position. 
Comparatives have not been re-presented.

2  Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

HSBC Holdings

HSBC Holdings’ primary sources of liquidity are dividends received from subsidiaries, interest on and repayment of intra-Group loans 
and securities, and interest earned on its own liquid funds. HSBC Holdings also raises funds in the debt capital markets to meet the 
Group’s minimum requirement for own funds and eligible liabilities. HSBC Holdings uses this liquidity to meet its obligations, including 
interest and principal repayments on external debt liabilities, operating expenses and collateral on derivative transactions.

HSBC Holdings is also subject to contingent liquidity risk by virtue of credit-related commitments and guarantees and similar contracts 
issued relating to its subsidiaries. Such commitments and guarantees are only issued after due consideration of HSBC Holdings’ ability 
to finance the commitments and guarantees and the likelihood of the need arising.

HSBC Holdings actively manages the cash flows from its subsidiaries to optimise the amount of cash held at the holding company level. 
During 2020, consistent with the Group’s capital plan, the Group’s subsidiaries did not experience any significant restrictions on paying 
dividends or repaying loans and advances. Also, there are no foreseen restrictions envisaged with regard to planned dividends or 
payments. However, the ability of subsidiaries to pay dividends or advance monies to HSBC Holdings depends on, among other things, 
their respective local regulatory capital and banking requirements, exchange controls, statutory reserves, and financial and operating 
performance.

HSBC Holdings currently has sufficient liquidity to meet its present requirements.

Liquidity risk in HSBC Holdings is overseen by Holdings ALCO. This risk arises because of HSBC Holdings’ obligation to make payments 
to debt holders as they fall due and to pay its operating expenses. The liquidity risk related to these cash flows is managed by matching 
external debt obligations with internal loan cash flows and by maintaining an appropriate liquidity buffer that is monitored by Holdings 
ALCO.

The balances in the following table are not directly comparable with those on the balance sheet of HSBC Holdings as the table 
incorporates, on an undiscounted basis, all cash flows relating to principal and future coupon payments (except for derivatives not 
treated as hedging derivatives). Undiscounted cash flows payable in relation to hedging derivative liabilities are classified according to 
their contractual maturities. Derivatives not treated as hedging derivatives are included in the ‘On demand’ time bucket.

In addition, loan commitments and financial guarantees and similar contracts are generally not recognised on our balance sheet. The 
undiscounted cash flows potentially payable under financial guarantees and similar contracts are classified on the basis of the earliest 
date on which they can be called.

HSBC Holdings plc Annual Report and Accounts 2020 351

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Cash flows payable by HSBC Holdings under financial liabilities by remaining contractual maturities

Due not more
than 1 month

Due over 1
month but not
more than 3
months

Due over 3
months but
not more than
1 year

Due over 1
year but not
more than 5
years

Amounts owed to HSBC undertakings 

Financial liabilities designated at fair value

Footnotes

Derivatives 

Debt securities in issue 

Subordinated liabilities 

Other financial liabilities 

Loan commitments 

Financial guarantees

At 31 Dec 2020

Amounts owed to HSBC undertakings 

Financial liabilities designated at fair value 

Derivatives 

Debt securities in issue 

Subordinated liabilities 

Other financial liabilities 

Loan commitments 

Financial guarantees

At 31 Dec 2019

1

1

$m 

—   

70   

3,085   

135   

82   

3,769   

7,141   

—   

13,787   

20,928   

—   

88   

1,838   

128   

1,588   

956   

4,598   

—   

11,061   

15,659   

Due over
5 years

$m

—   

$m

—   

$m

—   

1,412   

9,110   

16,104   

2   

—   

3,354   

31,567   

726   

370   

7,513   

—   

—   

37,103   

21,552   

36   

Total

$m

330 

27,805 

3,087 

72,919 

30,029 

4,865 

$m

330   

1,109   

—   

760   

156   

690   

3,045   

5,864   

48,190   

74,795   

139,035 

—   

—   

—   

—   

—   

—   

—   

—   

— 

13,787 

3,045   

5,864   

48,190   

74,795   

152,822 

464   

168   

—   

244   

154   

519   

—   

784   

—   

1,137   

718   

365   

—   

—   

14,776   

18,184   

105   

38,690   

5,743   

—   

78   

25,310   

21,533   

—   

464 

34,000 

2,021 

65,509 

29,736 

1,840 

1,549   

3,004   

59,314   

65,105   

133,570 

—   

—   

—   

—   

—   

—   

—   

—   

1,549   

3,004   

59,314   

65,105   

— 

11,061 

144,631 

1  Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

30 Offsetting of financial assets and financial liabilities

In the following table, the ‘Amounts not set off in the balance sheet’ include transactions where:

• the counterparty has an offsetting exposure with HSBC and a master netting or similar arrangement is in place with a right to set off 

only in the event of default, insolvency or bankruptcy, or the offset criteria are otherwise not satisfied; and 

• in the case of derivatives and reverse repurchase/repurchase, stock borrowing/lending and similar agreements, cash and non-cash 

collateral has been received/pledged.

For risk management purposes, the net amounts of loans and advances to customers are subject to limits, which are monitored and the 
relevant customer agreements are subject to review and updated, as necessary, to ensure the legal right to set off remains appropriate.

352 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Offsetting of financial assets and financial liabilities

Amounts subject to enforceable netting arrangements

Amounts not set off in the
balance sheet

Gross
amounts

Amounts
offset

Net
amounts in
the balance
sheet

Financial
instruments

Non-cash
collateral

Cash
collateral

Net
amount

Amounts not
subject to
enforceable
netting
arrangements5

Footnotes

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

Financial assets

Derivatives (Note 15)

Reverse repos, stock 
borrowing and similar 
agreements classified as:

–  trading assets

–  non-trading assets 

Loans and advances to 
customers

At 31 Dec 2020

Derivatives (Note 15)

Reverse repos, stock 
borrowing and similar 
agreements classified as:

–  trading assets 

–  non-trading assets

Loans and advances to 
customers

At 31 Dec 2019

Financial liabilities

Derivatives (Note 15)

Repos, stock lending and 
similar agreements 
classified as:

–  trading liabilities

–  non-trading liabilities 

Customer accounts

At 31 Dec 2020

Derivatives (Note 15)

Repos, stock lending and 
similar agreements 
classified as:

–  trading liabilities 

–  non-trading liabilities

Customer accounts

At 31 Dec 2019

1

2

3

1

2

3

1

2

4

1

2

4

  368,057   

(69,103)   

298,954   

(230,758)   

(13,766)   

(48,154)   

6,276   

8,772    307,726 

21,204   

(461)   

20,743   

(709)   

(20,030)   

  318,424   

(115,678)   

202,746   

(13,936)   

(188,646)   

—   

(73)   

4   

91   

1,534    22,277 

28,258    231,004 

30,983   

(10,882)   

20,101   

(17,031)   

—   

—   

3,070   

428    20,529 

  738,668   

(196,124)   

542,544   

(262,434)   

(222,442)   

(48,227)   

9,441   

38,992    581,536 

277,261   

(41,739)   

235,522   

(171,371)   

(13,095)   

(47,404)   

3,652   

7,473    242,995 

21,465   

(280)   

21,185   

(1,553)   

(19,630)   

348,561   

(134,772)   

213,789   

(28,826)   

(184,495)   

—   

(189)   

2   

279   

165   

21,350 

27,549    241,338 

33,039   

(10,128)   

22,911   

(18,893)   

—   

—   

4,018   

735   

23,646 

680,326   

(186,919)   

493,407   

(220,643)   

(217,220)   

(47,593)   

7,951   

35,922    529,329 

  364,121   

(69,103)   

295,018   

(230,758)   

(21,387)   

(37,343)   

5,530   

7,983    303,001 

16,626   

(461)   

16,165   

(709)   

(15,456)   

—   

  200,999   

(115,678)   

85,321   

(13,936)   

(71,142)   

(215)   

—   

28   

159    16,324 

26,580    111,901 

41,177   

(10,882)   

30,295   

(17,031)   

—   

—   

13,264   

13    30,308 

  622,923   

(196,124)   

426,799   

(262,434)   

(107,985)   

(37,558)   

18,822   

34,735    461,534 

275,286   

(41,739)   

233,547   

(171,371)   

(20,137)   

(37,844)   

4,195   

5,950    239,497 

10,494   

(280)   

232,675   

(134,772)   

36,750   

(10,128)   

10,214   

97,903   

26,622   

(1,553)   

(8,656)   

(28,826)   

(68,638)   

—   

(357)   

5   

82   

46   

10,260 

42,441    140,344 

(18,893)   

—   

—   

7,729   

31   

26,653 

555,205   

(186,919)   

368,286   

(220,643)   

(97,431)   

(38,201)   

12,011   

48,468    416,754 

1  At 31 December 2020, the amount of cash margin received that had been offset against the gross derivatives assets was $7,899m (2019: 
$2,350m). The amount of cash margin paid that had been offset against the gross derivatives liabilities was $17,955m (2019: $8,303m).

2  For the amount of repos, reverse repos, stock lending, stock borrowing and similar agreements recognised on the balance sheet within ‘Trading 
assets’ $22,277m (2019: $21,350m) and ‘Trading liabilities’ $16,324m (2019: $10,260m), see the ‘Funding sources and uses’ table on page 178.

3  At 31 December 2020, the total amount of ‘Loans and advances to customers’ was $1,037,987m (2019: $1,036,743m), of which $20,101m 

(2019: $22,911m) was subject to offsetting.

4  At 31 December 2020, the total amount of ‘Customer accounts’ was $1,642,780m (2019: $1,439,115m), of which $30,295m (2019: $26,622m) 

was subject to offsetting.

5  These exposures continue to be secured by financial collateral, but we may not have sought or been able to obtain a legal opinion evidencing 

enforceability of the right of offset.

31 Called up share capital and other equity instruments

Called up share capital and share premium

HSBC Holdings ordinary shares of $0.50 each, issued and fully paid

At 1 Jan

Shares issued under HSBC employee share plans

Shares issued in lieu of dividends

Less: Shares repurchased and cancelled

At 31 Dec

2020

2019

Footnotes

Number

$m

Number

  20,638,524,545   

10,319   

20,360,841,496   

55,096,555   

—   

—   
  20,693,621,100   

1

28   

—   

71,588,032   

341,872,011   

—   
10,347   

(135,776,994)   
20,638,524,545   

$m

10,180 

36 

171 

(68) 
10,319 

HSBC Holdings plc Annual Report and Accounts 2020 353

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings 6.2% non-cumulative US dollar preference shares, Series A 

At 1 Jan and 31 Dec

HSBC Holdings share premium

At 31 Dec

Total called up share capital and share premium

At 31 Dec

Footnotes

2

2020

Number

1,450,000   

$m

—   

2019

Number

1,450,000   

2020

$m
14,277   

2020

$m

24,624   

$m

— 

2019

$m

13,959 

2019

$m

24,278 

1  All HSBC Holdings ordinary shares in issue, excluding 325,273,407 shares held in treasury, confer identical rights, including in respect of capital, 

2 

dividends and voting.
In 2019 this security was included in the capital base of HSBC as additional tier 1 capital in accordance with the CRR II rules, by virtue of the 
application of grandfathering provisions. This security was called by HSBC Holdings on 10 December 2020 and was redeemed and cancelled on 
13 January 2021. Between the date of exercise of the call option and the redemption, this security was considered as an other liability.

HSBC Holdings 6.20% non-cumulative US dollar preference shares, Series A of $0.01 

The 6.20% non-cumulative US dollar preference shares, Series A of $0.01 each were redeemed on 13 January 2021.

HSBC Holdings non-cumulative preference share of £0.01 

The one non-cumulative sterling preference share of £0.01 (‘sterling preference share’) has been in issue since 29 December 2010 and is 
held by a subsidiary of HSBC Holdings. Dividends are paid quarterly at the sole and absolute discretion of the Board. The sterling 
preference share carries no rights of conversion into ordinary shares of HSBC Holdings and no right to attend or vote at shareholder 
meetings of HSBC Holdings. These securities can be redeemed by HSBC Holdings at any time, subject to prior approval by the PRA.

Other equity instruments

HSBC Holdings includes three types of additional tier 1 capital securities in its tier 1 capital. Two are presented in this Note and they are 
the HSBC Holdings non-cumulative preference shares outlined above and the contingent convertible securities described below. These 
are accounted for as equity because HSBC does not have an obligation to transfer cash or a variable number of its own ordinary shares 
to holders under any circumstances outside its control. See Note 28 for additional tier 1 securities accounted for as liabilities.

Additional tier 1 capital – contingent convertible securities

HSBC Holdings continues to issue contingent convertible securities that are included in its capital base as fully CRR II-compliant 
additional tier 1 capital securities on an end point basis. These securities are marketed principally and subsequently allotted to corporate 
investors and fund managers. The net proceeds of the issuances are typically used for HSBC Holdings’ general corporate purposes and 
to further strengthen its capital base to meet requirements under CRR II. These securities bear a fixed rate of interest until their initial call 
dates. After the initial call dates, if they are not redeemed, the securities will bear interest at rates fixed periodically in advance for five-
year periods based on credit spreads, fixed at issuance, above prevailing market rates. Interest on the contingent convertible securities 
will be due and payable only at the sole discretion of HSBC Holdings, and HSBC Holdings has sole and absolute discretion at all times to 
cancel for any reason (in whole or part) any interest payment that would otherwise be payable on any payment date. Distributions will 
not be paid if they are prohibited under UK banking regulations or if the Group has insufficient reserves or fails to meet the solvency 
conditions defined in the securities’ terms.

The contingent convertible securities are undated and are repayable at the option of HSBC Holdings in whole typically at the initial call 
date or on any fifth anniversary after this date. In addition, the securities are repayable at the option of HSBC in whole for certain 
regulatory or tax reasons. Any repayments require the prior consent of the PRA. These securities rank pari passu with HSBC Holdings’ 
sterling preference shares and therefore rank ahead of ordinary shares. The contingent convertible securities will be converted into fully 
paid ordinary shares of HSBC Holdings at a predetermined price, should HSBC’s consolidated non-transitional CET1 ratio fall below 
7.0%. Therefore, in accordance with the terms of the securities, if the non-transitional CET1 ratio breaches the 7.0% trigger, the 
securities will convert into ordinary shares at fixed contractual conversion prices in the issuance currencies of the relevant securities, 
equivalent to £2.70 at the prevailing rate of exchange on the issuance date, subject to anti-dilution adjustments.

354 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
HSBC’s additional tier 1 capital – contingent convertible securities in issue which are accounted for in equity

$1,500m

$2,000m

$2,250m

$2,450m

$3,000m
$2,350m

$1,800m

$1,500m

€1,500m

€1,000m

€1,250m
£1,000m

5.625% perpetual subordinated contingent convertible securities

6.875% perpetual subordinated contingent convertible securities

6.375% perpetual subordinated contingent convertible securities 

6.375% perpetual subordinated contingent convertible securities

6.000% perpetual subordinated contingent convertible securities 
6.250% perpetual subordinated contingent convertible securities

6.500% perpetual subordinated contingent convertible securities

4.600% perpetual subordinated contingent convertible securities

5.250% perpetual subordinated contingent convertible securities

6.000% perpetual subordinated contingent convertible securities

4.750% perpetual subordinated contingent convertible securities
5.875% perpetual subordinated contingent convertible securities

SGD1,000m 4.700% perpetual subordinated contingent convertible securities
5.000% perpetual subordinated contingent convertible securities
SGD750m

At 31 Dec

Footnotes

1

2

First call
date

Nov 2019  

Jun 2021  

Sep 2024  

Mar 2025  

May 2027  

Mar 2023  

Mar 2028  

Jun 2031  

Sep 2022  

Sep 2023  

Jul 2029  

Sep 2026   

Jun 2022  

Sep 2023  

2020

$m
—   
2,000   
2,250   
2,450   
3,000   
2,350   
1,800   
1,500   
1,945   
1,123   
1,422   
1,301   
723   
550   
22,414   

2019

$m

1,494 

1,998 

2,244 

2,460 

2,997 

2,347 

1,798 

— 

1,943 

1,120 

1,420 

1,299 

723 

549 

22,392 

1  This security was called by HSBC Holdings on 22 November 2019 and was redeemed and cancelled on 17 January 2020. Between the date of 

exercise of the call option and the redemption, this security was considered to be a subordinated liability. See Note 28.

2  This security was issued by HSBC Holdings on 17 December 2020. The first call date commences six calendar months prior to the reset date of 

17 June 2031.

Shares under option

For details of the options outstanding to subscribe for HSBC Holdings ordinary shares under the HSBC Holdings Savings-Related Share 
Option Plan (UK), see Note 5.

Aggregate options outstanding under these plans

31 Dec 2020

31 Dec 2019

Number of
HSBC Holdings
ordinary shares Usual period of exercise

Exercise price 

Number of
HSBC Holdings
ordinary shares

Usual period of exercise

Exercise price

130,952,539 

2019 to 2026

£2.6270–£5.9640  

65,060,681 

2018 to 2025

£4.0472–£5.9640

Maximum obligation to deliver HSBC Holdings ordinary shares

At 31 December 2020, the maximum obligation to deliver HSBC Holdings ordinary shares under all of the above option arrangements 
and the HSBC International Employee Share Purchase Plan, together with GPSP awards, long-term incentive awards and deferred share 
awards granted under the HSBC Share Plan 2011, was 238,278,952 (2019: 163,567,253). The total number of shares at 31 December 
2020 held by employee benefit trusts that may be used to satisfy such obligations to deliver HSBC Holdings ordinary shares was  
5,179,531 (2019: 5,397,395).

32 Contingent liabilities, contractual commitments and guarantees

Guarantees and other contingent liabilities:

–  financial guarantees

–  performance and other guarantees

–  other contingent liabilities

At 31 Dec

Commitments:

–  documentary credits and short-term trade-related transactions 

–  forward asset purchases and forward deposits placed

–  standby facilities, credit lines and other commitments to lend

At 31 Dec

Footnotes

2

HSBC

2020

$m

HSBC Holdings1

2019

$m

2020

$m

2019

$m

18,384   
78,114   
1,219   
97,717   

7,178   
66,506   
771,086   
844,770   

20,214   
75,933   
1,576   
97,723   

6,316   
56,326   
734,966   
797,608   

13,787   

11,061 

— 

119   

— 

289 

13,906   

11,350 

—   

—   

—   

—   

— 

— 

— 

— 

1  Guarantees by HSBC Holdings are all in favour of other Group entities.
2 

Includes $659,783m of commitments at 31 December 2020 (31 December 2019: $600,029m), to which the impairment requirements in IFRS 9 
are applied where HSBC has become party to an irrevocable commitment.

The preceding table discloses the nominal principal amounts of off-balance sheet liabilities and commitments for the Group, which 
represent the maximum amounts at risk should the contracts be fully drawn upon and the clients default. As a significant portion of 
guarantees and commitments are expected to expire without being drawn upon, the total of the nominal principal amounts is not 
indicative of future liquidity requirements. The expected credit loss provision relating to guarantees and commitments under IFRS 9 is 
disclosed in Note 27.

The majority of the guarantees have a term of less than one year, while guarantees with terms of more than one year are subject to 
HSBC’s annual credit review process.

Contingent liabilities arising from legal proceedings, regulatory and other matters against Group companies are excluded from this note 
but are disclosed in Notes 27 and 34.

HSBC Holdings plc Annual Report and Accounts 2020 355

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Financial Services Compensation Scheme

The Financial Services Compensation Scheme (‘FSCS’) provides compensation, up to certain limits, to eligible customers of financial 
services firms that are unable, or likely to be unable, to pay claims against them. The FSCS may impose a further levy on the Group to 
the extent the industry levies imposed to date are not sufficient to cover the compensation due to customers in any future possible 
collapse. The ultimate FSCS levy to the industry as a result of a collapse cannot currently be estimated reliably. It is dependent on 
various uncertain factors including the potential recoveries of assets by the FSCS, changes in the level of protected products (including 
deposits and investments) and the population of FSCS members at the time.

Associates

HSBC’s share of associates’ contingent liabilities, contractual commitments and guarantees amounted to $53.1bn at 31 December 2020 
(2019: $46.7bn). No matters arose where HSBC was severally liable.

33 Finance lease receivables

HSBC leases a variety of assets to third parties under finance leases, including transport assets (such as aircraft), property and general 
plant and machinery. At the end of lease terms, assets may be sold to third parties or leased for further terms. Rentals are calculated to 
recover the cost of assets less their residual value, and earn finance income.

Lease receivables:

No later than one year 

One to two years

Two to three years

Three to four years

Four to five years

Later than one year and no later than five years 

Later than five years 

At 31 Dec

Total future
minimum
payments

2020

Unearned
finance
income

$m

$m

3,108   

2,476   

2,055   

1,380   

787   

6,698   

4,221   

(257)   

(196)   

(143)   

(109)   

(80)   

(528)   

(451)   

14,027   

(1,236)   

Present
value

$m

2,851   
2,280   

1,912   

1,271   

707   
6,170   
3,770   
12,791   

Total future
minimum
payments

$m

2019

Unearned
finance
income

$m

1,674   

1,634   

1,889   

1,704   

1,558   
6,785   

6,136   

(157)   

(155)   

(151)   

(136)   

(132)   
(574)   

(614)   

Present
value

$m

1,517 

1,479 

1,738 

1,568 

1,426 
6,211 

5,522 

14,595   

(1,345)   

13,250 

34 Legal proceedings and regulatory matters

HSBC is party to legal proceedings and regulatory matters in a number of jurisdictions arising out of its normal business operations. 
Apart from the matters described below, HSBC considers that none of these matters are material. The recognition of provisions is 
determined in accordance with the accounting policies set out in Note 1. While the outcomes of legal proceedings and regulatory 
matters are inherently uncertain, management believes that, based on the information available to it, appropriate provisions have been 
made in respect of these matters as at 31 December 2020 (see Note 27). Where an individual provision is material, the fact that a 
provision has been made is stated and quantified, except to the extent that doing so would be seriously prejudicial. Any provision 
recognised does not constitute an admission of wrongdoing or legal liability. It is not practicable to provide an aggregate estimate 
of potential liability for our legal proceedings and regulatory matters as a class of contingent liabilities.

Bernard L. Madoff Investment Securities LLC

Bernard L. Madoff (‘Madoff’) was arrested in December 2008 and later pleaded guilty to running a Ponzi scheme. His firm, Bernard L. 
Madoff Investment Securities LLC (‘Madoff Securities’), is being liquidated in the US by a trustee (the ‘Trustee’).

Various non-US HSBC companies provided custodial, administration and similar services to a number of funds incorporated outside the 
US whose assets were invested with Madoff Securities. Based on information provided by Madoff Securities as at 30 November 2008, 
the purported aggregate value of these funds was $8.4bn, including fictitious profits reported by Madoff.

Based on information available to HSBC, the funds’ actual transfers to Madoff Securities minus their actual withdrawals from Madoff 
Securities during the time HSBC serviced the funds are estimated to have totalled approximately $4bn. Various HSBC companies have 
been named as defendants in lawsuits arising out of Madoff Securities’ fraud.

US litigation: The Trustee has brought lawsuits against various HSBC companies and others in the US Bankruptcy Court for the 
Southern District of New York (the ‘US Bankruptcy Court’), seeking recovery of transfers from Madoff Securities to HSBC in an amount 
not yet pleaded or determined. HSBC and other parties to the actions have moved to dismiss the Trustee’s claims. The US Bankruptcy 
Court granted HSBC’s motion to dismiss with respect to certain of the Trustee’s claims in November 2016. In February 2019, the US 
Court of Appeals for the Second Circuit (the ‘Second Circuit Court of Appeals’) reversed that dismissal. Following the US Supreme 
Court’s denial of certiorari in June 2020, the cases were remanded to the US Bankruptcy Court, where they are now pending.

Fairfield Sentry Limited, Fairfield Sigma Limited and Fairfield Lambda Limited (together, ‘Fairfield’) (in liquidation since July 2009) have 
brought a lawsuit in the US against fund shareholders, including HSBC companies that acted as nominees for clients, seeking restitution 
of redemption payments. In December 2018, the US Bankruptcy Court issued an opinion, which ruled in favour of the defendants’ 
motion to dismiss in respect of certain claims by the liquidators for Fairfield and granted a motion by the liquidators to file amended 
complaints. As a result of that opinion, all claims against one of the HSBC companies, and certain claims against the remaining HSBC 
defendants, were dismissed. In May 2019, the liquidators appealed certain issues from the US Bankruptcy Court to the US District Court 
for the Southern District of New York (the ’New York District Court’) and, in January 2020, the liquidators filed amended complaints on 
the claims remaining in the US Bankruptcy Court. In March 2020, HSBC and other parties to the action moved to dismiss the amended 
complaints in the US Bankruptcy Court. In December 2020, the US Bankruptcy Court granted in part and denied in part the defendants’ 
motion. This action remains pending in the US Bankruptcy Court and the New York District Court.

356 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
UK litigation: The Trustee has filed a claim against various HSBC companies in the High Court of England and Wales, seeking recovery 
of transfers from Madoff Securities to HSBC in an amount not yet pleaded or determined. The deadline for service of the claim has been 
extended to September 2021 for UK-based defendants and November 2021 for all other defendants.

Cayman Islands litigation: In February 2013, Primeo Fund (‘Primeo’) (in liquidation since April 2009) brought an action against HSBC 
Securities Services Luxembourg (‘HSSL’) and Bank of Bermuda (Cayman) Limited (now known as HSBC Cayman Limited), alleging 
breach of contract and breach of fiduciary duty and claiming damages and equitable compensation. The trial concluded in February 
2017 and, in August 2017, the court dismissed all claims against the defendants. In September 2017, Primeo appealed to the Court of 
Appeal of the Cayman Islands and, in June 2019, the Court of Appeal of the Cayman Islands dismissed Primeo’s appeal. In August 2019, 
Primeo filed a notice of appeal to the UK Privy Council, which has listed the first of two possible hearings for April 2021.

Luxembourg litigation: In April 2009, Herald Fund SPC (‘Herald’) (in liquidation since July 2013) brought an action against HSSL 
before the Luxembourg District Court, seeking restitution of cash and securities that Herald purportedly lost because of Madoff 
Securities’ fraud, or money damages. The Luxembourg District Court dismissed Herald’s securities restitution claim, but reserved 
Herald’s cash restitution claim and its claim for money damages. Herald has appealed this judgment to the Luxembourg Court of 
Appeal, where the matter is pending. In late 2018, Herald brought additional claims against HSSL and HSBC Bank plc before the 
Luxembourg District Court, seeking further restitution and damages.

In October 2009, Alpha Prime Fund Limited (‘Alpha Prime’) brought an action against HSSL before the Luxembourg District Court, 
seeking the restitution of securities, or the cash equivalent, or money damages. In December 2018, Alpha Prime brought additional 
claims before the Luxembourg District Court seeking damages against various HSBC companies. These matters are currently pending 
before the Luxembourg District Court.

In December 2014, Senator Fund SPC (‘Senator’) brought an action against HSSL before the Luxembourg District Court, seeking 
restitution of securities, or the cash equivalent, or money damages. In April 2015, Senator commenced a separate action against the 
Luxembourg branch of HSBC Bank plc asserting identical claims before the Luxembourg District Court. In December 2018, Senator 
brought additional claims against HSSL and HSBC Bank plc Luxembourg branch before the Luxembourg District Court, seeking 
restitution of Senator’s securities or money damages. These matters are currently pending before the Luxembourg District Court.

Ireland litigation: In November 2013, Defender Limited brought an action against HSBC Institutional Trust Services (Ireland) Limited 
(‘HTIE’) and others, based on allegations of breach of contract and claiming damages and indemnification for fund losses. The trial 
commenced in October 2018. In December 2018, the Irish High Court issued a judgment in HTIE’s favour on a preliminary issue, holding 
that Defender Limited had no effective claim against HTIE. This judgment concluded the trial without further issues in dispute being 
heard. In February 2019, Defender Limited appealed the decision. In July 2020, the Irish Supreme Court ruled in part in favour of 
Defender Limited and returned the case to the High Court for further proceedings, which will resume in April 2021.

There are many factors that may affect the range of possible outcomes, and any resulting financial impact, of the various Madoff-related 
proceedings described above, including but not limited to the multiple jurisdictions in which the proceedings have been brought. Based 
upon the information currently available, management’s estimate of the possible aggregate damages that might arise as a result of all 
claims in the various Madoff-related proceedings is up to or exceeding $500m, excluding costs and interest. Due to uncertainties and 
limitations of this estimate, any possible damages that might ultimately arise could differ significantly from this amount.
Anti-money laundering and sanctions-related matters

In December 2012, HSBC Holdings entered into a number of agreements, including an undertaking with the UK Financial Services 
Authority (replaced with a Direction issued by the UK Financial Conduct Authority (‘FCA’) in 2013 and again in 2020) as well as a cease-
and-desist order with the US Federal Reserve Board (‘FRB’), both of which contained certain forward-looking anti-money laundering 
(‘AML’) and sanctions-related obligations. HSBC also agreed to retain an independent compliance monitor (who was, for FCA purposes, 
a ‘Skilled Person’ under section 166 of the Financial Services and Markets Act and, for FRB purposes, an ‘Independent Consultant’) to 
produce periodic assessments of the Group’s AML and sanctions compliance programme. In 2020, HSBC’s engagement with the 
independent compliance monitor, acting in his roles as both Skilled Person and Independent Consultant, concluded. The role of FCA 
Skilled Person was assigned to a new individual in the second quarter of 2020. Separately, a new FRB Independent Consultant will be 
appointed pursuant to the cease-and-desist order. The roles of each of the FCA Skilled Person and the FRB Independent Consultant are 
discussed on page 188.

The FCA is conducting an investigation into HSBC Bank plc’s and HSBC UK Bank plc’s compliance with UK money laundering 
regulations and financial crime systems and controls requirements. HSBC continues to cooperate with the FCA’s investigation, which is 
at or nearing completion.

In May 2014, a shareholder derivative action was filed by a shareholder of HSBC Holdings purportedly on behalf of HSBC Holdings, 
HSBC Bank USA N.A. (‘HSBC Bank USA’), HSBC North America Holdings Inc. and HSBC USA Inc. (the ‘Nominal Corporate Defendants’) 
in New York state court against certain current and former directors and officers of the Nominal Corporate Defendants (the ‘Individual 
Defendants’). The complaint alleges that the Individual Defendants breached their fiduciary duties to the Nominal Corporate Defendants 
and caused a waste of corporate assets by allegedly permitting and/or causing the conduct underlying the five-year deferred prosecution 
agreement with the US Department of Justice (‘DoJ’), entered into in December 2012. In November 2015, the New York state court 
granted the Nominal Corporate Defendants’ motion to dismiss, but the appellate court reversed the decision in November 2018 and 
reinstated the action. In June 2020, the parties reached an agreement to resolve this derivative action, under which HSBC has received a 
payment from directors and officers liability insurance providers and will continue for a period of time certain corporate governance 
practices. In November 2020, the court issued an order granting final settlement approval and dismissing the action. This matter is now 
concluded.

Since November 2014, a number of lawsuits have been filed in federal courts in the US against various HSBC companies and others on 
behalf of plaintiffs who are, or are related to, victims of terrorist attacks in the Middle East or of cartel violence in Mexico. In each case, it 
is alleged that the defendants aided and abetted the unlawful conduct of various sanctioned parties in violation of the US Anti-Terrorism 
Act. Currently, 10 actions remain pending in federal courts in New York or the District of Columbia. In March, September and October 
2019, the courts granted HSBC’s motions to dismiss in three of these cases. In October 2020, the appellate court affirmed the dismissal 
of one of the actions on appeal. An appeal remains pending in another case, and plaintiffs are seeking certification to appeal in the third 
case. HSBC filed motions to dismiss in three further cases, with two of the motions granted in June 2020, and the third granted in 
November 2020. These dismissals are subject to appeal. The four remaining actions are at a very early stage.

There are many factors that may affect the range of outcomes, and the resulting financial impact, of these matters, which could be 
significant.

HSBC Holdings plc Annual Report and Accounts 2020 357

Financial statementsNotes on the financial statements

London interbank offered rates, European interbank offered rates and other benchmark interest rate 
investigations and litigation

Euro interest rate derivatives: In December 2016, the European Commission (the ‘EC’) issued a decision finding that HSBC, among 
other banks, engaged in anti-competitive practices in connection with the pricing of euro interest rate derivatives in early 2007. The EC 
imposed a fine on HSBC based on a one-month infringement. HSBC appealed the decision and, in September 2019, the General Court of 
the European Union (the ‘General Court’) issued a decision largely upholding the EC’s findings on liability but annulling the fine. HSBC 
and the EC have both appealed the General Court’s decision to the European Court of Justice.

US dollar Libor: Beginning in 2011, HSBC and other panel banks have been named as defendants in a number of private lawsuits filed 
in the US with respect to the setting of US dollar Libor. The complaints assert claims under various US laws, including US antitrust and 
racketeering laws, the US Commodity Exchange Act (‘US CEA’) and state law. The lawsuits include individual and putative class actions, 
most of which have been transferred and/or consolidated for pre-trial purposes before the New York District Court.

In 2017 and 2018, HSBC reached agreements with plaintiffs to resolve putative class actions brought on behalf of the following five 
groups of plaintiffs: persons who purchased US dollar Libor-indexed bonds; persons who purchased US dollar Libor-indexed exchange-
traded instruments; US-based lending institutions that made or purchased US dollar Libor-indexed loans; persons who purchased US 
dollar Libor-indexed interest rate swaps and other instruments directly from the defendant banks and their affiliates; and persons who 
purchased US dollar Libor-indexed interest rate swaps and other instruments from certain financial institutions that are not the 
defendant banks or their affiliates. The New York District Court has granted final approval of each of the five referenced settlements. 
Additionally, a number of other US dollar Libor-related actions remain pending against HSBC in the New York District Court and the 
Second Circuit Court of Appeals.

Intercontinental Exchange (‘ICE’) Libor: Between January and March 2019, HSBC and other panel banks were named as defendants 
in three putative class actions filed in the New York District Court on behalf of persons and entities who purchased instruments paying 
interest indexed to US dollar ICE Libor from a panel bank. The complaints allege, among other things, misconduct related to the 
suppression of this benchmark rate in violation of US antitrust and state law. In July 2019, the three putative class actions were 
consolidated, and the plaintiffs filed a consolidated amended complaint. In March 2020, the court granted the defendants’ joint motion 
to dismiss in its entirety. This matter is on appeal.

Singapore interbank offered rate (‘Sibor’), Singapore swap offer rate (‘SOR’) and Australia bank bill swap rate (‘BBSW’): 
In July and August 2016, HSBC and other panel banks were named as defendants in two putative class actions filed in the New York 
District Court on behalf of persons who transacted in products related to the Sibor, SOR and BBSW benchmark rates. The complaints 
allege, among other things, misconduct related to these benchmark rates in violation of US antitrust, commodities and racketeering 
laws, and state law. 

In the Sibor/SOR litigation, following a decision on the defendants’ motion to dismiss in October 2018, the claims against a number of 
HSBC entities were dismissed, and The Hongkong and Shanghai Banking Corporation Limited (‘HBAP’) remained as the only HSBC 
defendant in this action. In October 2018, HBAP filed a motion for reconsideration of the decision based on the issue of personal 
jurisdiction. This motion was denied in April 2019. Also in October 2018, the plaintiffs filed a third amended complaint naming only the 
Sibor panel members, including HBAP, as defendants. The court dismissed the third amended complaint in its entirety in July 2019 
against all defendants. In August 2019, the plaintiffs filed an appeal to the Second Circuit Court of Appeals, which remains pending.

In the BBSW litigation, in November 2018, the court dismissed all foreign defendants, including all the HSBC entities, on personal 
jurisdiction grounds. In April 2019, the plaintiffs filed an amended complaint, which the defendants moved to dismiss. In February 2020, 
the court again dismissed the plaintiffs’ amended complaint against all the HSBC entities.

There are many factors that may affect the range of outcomes, and the resulting financial impact, of these matters, which could be 
significant.

Foreign exchange-related investigations and litigation

Since at least 2014, the EC has been conducting an investigation into trading activities by a number of banks, including HSBC, in the 
foreign exchange spot market. HSBC is cooperating with this investigation. 

In January 2021, HSBC Holdings exited its three-year deferred prosecution agreement with the Criminal Division of the DoJ (the ‘FX 
DPA’), regarding fraudulent conduct in connection with two particular transactions in 2010 and 2011. HSBC Holdings entered into the 
FX DPA in January 2018, following the conclusion of the DoJ’s investigation into HSBC’s historical foreign exchange activities. Under 
the terms of the FX DPA, the DoJ is expected to file a motion to dismiss the charges deferred by the FX DPA in due course.

In December 2016, Brazil’s Administrative Council of Economic Defense initiated an investigation into the onshore foreign exchange 
market and identified a number of banks, including HSBC, as subjects of its investigation. 

In June 2020, the Competition Commission of South Africa, having initially referred a complaint for proceedings before the South African 
Competition Tribunal in February 2017, filed a revised complaint against 28 financial institutions, including HSBC Bank plc and HSBC 
Bank USA, for alleged anti-competitive behaviour in the South African foreign exchange market. In August 2020, HSBC Bank plc and 
HSBC Bank USA filed an application to dismiss the revised complaint, which remains pending.

In late 2013 and early 2014, various HSBC companies and other banks were named as defendants in various putative class actions 
consolidated in the New York District Court. The consolidated complaint alleged, among other things, that the defendants conspired to 
manipulate the WM/Reuters foreign exchange benchmark rates. In September 2015, HSBC reached an agreement with the plaintiffs 
to resolve the consolidated action, and the court granted final approval of the settlement in August 2018.

A putative class action complaint making similar allegations on behalf of retail customers of foreign exchange products was filed in the 
US District Court for the Northern District of California in 2015, and was subsequently transferred to the New York District Court where it 
remains pending. In 2017, putative class action complaints making similar allegations on behalf of purported indirect purchasers of 
foreign exchange products were filed in New York and were subsequently consolidated in the New York District Court. In April 2020, 
HSBC reached an agreement with the plaintiffs to resolve the indirect purchaser action. In November 2020, the New York District Court 
granted final approval of the settlement.

In September 2018, various HSBC companies and other banks were named as defendants in two motions for certification of class 
actions filed in Israel alleging foreign exchange-related misconduct. In July 2019, the Tel Aviv Court allowed the plaintiffs to consolidate 
their claims and, in September 2019, the plaintiffs filed a motion for certification of the consolidated class action. In August 2020, HSBC 

358 HSBC Holdings plc Annual Report and Accounts 2020

Bank plc filed a motion to dismiss and, in January 2021, HSBC Holdings filed a motion seeking to challenge the service of the motion for 
certification on defendants outside Israel. These motions remain pending.

In November and December 2018, complaints alleging foreign exchange-related misconduct were filed in the New York District Court 
and the High Court of England and Wales against HSBC and other defendants by certain plaintiffs that opted out of the US class action 
settlement. In May 2020, the New York District Court granted in part and denied in part the defendants’ motion to dismiss the US opt-
out actions. These matters remain at an early stage. It is possible that additional civil actions will be initiated against HSBC in relation to 
its historical foreign exchange activities.

There are many factors that may affect the range of outcomes, and the resulting financial impact, of these matters, which could be 
significant.

Precious metals fix-related litigation

Gold: Beginning in March 2014, numerous putative class actions were filed in the New York District Court and the US District Courts for 
the District of New Jersey and the Northern District of California, naming HSBC and other members of The London Gold Market Fixing 
Limited as defendants. The complaints allege that, from January 2004 to June 2013, the defendants conspired to manipulate the price of 
gold and gold derivatives for their collective benefit in violation of US antitrust laws, the US CEA and New York state law. The actions 
were consolidated in the New York District Court. The defendants’ motion to dismiss the consolidated action was granted in part and 
denied in part in October 2016. In June 2017, the court granted the plaintiffs leave to file a third amended complaint, naming a new 
defendant. In October 2020, HSBC reached a settlement in principle with the plaintiffs to resolve the consolidated action. The settlement 
remains subject to court approval.

Beginning in December 2015, numerous putative class actions under Canadian law were filed in the Ontario and Quebec Superior Courts 
of Justice against various HSBC companies and other financial institutions. The plaintiffs allege that, among other things, from January 
2004 to March 2014, the defendants conspired to manipulate the price of gold and gold derivatives in violation of the Canadian 
Competition Act and common law. These actions are ongoing.

Silver: Beginning in July 2014, numerous putative class actions were filed in federal district courts in New York, naming HSBC and 
other members of The London Silver Market Fixing Limited as defendants. The complaints allege that, from January 2007 to December 
2013, the defendants conspired to manipulate the price of silver and silver derivatives for their collective benefit in violation of US 
antitrust laws, the US CEA and New York state law. The actions were consolidated in the New York District Court. The defendants’ 
motion to dismiss the consolidated action was granted in part and denied in part in October 2016. In June 2017, the court granted the 
plaintiffs leave to file a third amended complaint, which names several new defendants. The court has denied the pre-existing 
defendants’ request for leave to file a joint motion to dismiss, and discovery is proceeding.

In April 2016, two putative class actions under Canadian law were filed in the Ontario and Quebec Superior Courts of Justice against 
various HSBC companies and other financial institutions. The plaintiffs in both actions allege that, from January 1999 to August 2014, 
the defendants conspired to manipulate the price of silver and silver derivatives in violation of the Canadian Competition Act and 
common law. These actions are ongoing.

Platinum and palladium: Between late 2014 and early 2015, numerous putative class actions were filed in the New York District 
Court, naming HSBC and other members of The London Platinum and Palladium Fixing Company Limited as defendants. The complaints 
allege that, from January 2008 to November 2014, the defendants conspired to manipulate the price of platinum group metals (‘PGM’) 
and PGM-based financial products for their collective benefit in violation of US antitrust laws and the US CEA. In March 2017, the 
defendants’ motion to dismiss the second amended consolidated complaint was granted in part and denied in part. In June 2017, the 
plaintiffs filed a third amended complaint. In March 2020, the court granted the defendants' motion to dismiss the third amended 
complaint but granted the plaintiffs leave to re-plead certain claims. The plaintiffs have filed an appeal.

Based on the facts currently known, it is not practicable at this time for HSBC to predict the resolution of these matters, including the 
timing or any possible impact on HSBC, which could be significant.

Film finance litigation

In July and November 2015, two actions were brought by individuals against HSBC Private Bank (UK) Limited (‘PBGB’) in the High Court 
of England and Wales seeking damages on various alleged grounds, including breach of duty to the claimants, in connection with their 
participation in certain Ingenious film finance schemes. These actions are ongoing. 

In December 2018, a separate action was brought against PBGB in the High Court of England and Wales by multiple claimants seeking 
damages for alleged unlawful means conspiracy and dishonest assistance in connection with lending provided by PBGB to third parties 
in respect of certain Ingenious film finance schemes in which the claimants participated. In June 2019, a similar claim was issued 
against PBGB in the High Court of England and Wales by additional claimants. These actions are ongoing.

In June 2020, two separate claims were issued against HSBC UK Bank plc (as successor to PBGB’s business) by two separate groups of 
investors in Eclipse film finance schemes in connection with PBGB’s role in the development of such schemes. These matters are at an 
early stage.

In February 2020, a claim was issued against HSBC UK Bank plc (as successor to PBGB’s business) by two individuals in relation to the 
Zeus film finance schemes. The claimants failed to serve the claim on time, and this claim has now lapsed. Separately, in June 2020, 
HSBC UK Bank plc received an application for disclosure of documents by a law firm acting on behalf of a number of investors in the 
Zeus film finance schemes. This application was dismissed by the court in November 2020.

It is possible that additional actions or investigations will be initiated against HSBC UK Bank plc as a result of PBGB’s historical 
involvement in the provision of certain film finance-related services.

Based on the facts currently known, it is not practicable to predict the resolution of these matters, including the timing or any possible 
impact on HSBC, which could be significant.

HSBC Holdings plc Annual Report and Accounts 2020 359

Financial statementsNotes on the financial statements

Other regulatory investigations, reviews and litigation

HSBC Holdings and/or certain of its affiliates are subject to a number of other investigations and reviews by various regulators and 
competition and law enforcement authorities, as well as litigation, in connection with various matters relating to the firm’s businesses 
and operations, including:

• investigations by tax administration, regulatory and law enforcement authorities in Argentina, India and elsewhere in connection with 

allegations of tax evasion or tax fraud, money laundering and unlawful cross-border banking solicitation;

• an investigation by the US Commodity Futures Trading Commission regarding interest rate swap transactions related to bond 

issuances;

• an investigation by the FCA in connection with collections and recoveries operations in the UK;

• an information request from the UK Competition and Markets Authority concerning the financial services sector;

• a putative class action brought in the New York District Court relating to the Mexican government bond market;

• two group actions pending in the US courts and a claim issued in the High Court of England and Wales in connection with HSBC 

Bank plc’s role as a correspondent bank to Stanford International Bank Ltd from 2003 to 2009; and

• litigation brought against various HSBC companies in the US courts relating to residential mortgage-backed securities, based 

primarily on (a) claims brought against HSBC Bank USA in connection with its role as trustee on behalf of various securitisation 
trusts; and (b) claims against several HSBC companies seeking that the defendants repurchase various mortgage loans.

There are many factors that may affect the range of outcomes, and the resulting financial impact, of these matters, which could be 
significant.

35 Related party transactions

Related parties of the Group and HSBC Holdings include subsidiaries, associates, joint ventures, post-employment benefit plans for 
HSBC employees, Key Management Personnel (‘KMP’) as defined by IAS 24, close family members of KMP and entities that are 
controlled or jointly controlled by KMP or their close family members. KMP are defined as those persons having authority and 
responsibility for planning, directing and controlling the activities of HSBC Holdings. These individuals also constitute ‘senior 
management’ for the purposes of the Hong Kong Listing Rules. In applying IAS 24, it was determined that for this financial reporting 
period all KMP included Directors, former Directors and senior management listed on pages 198 to 203 and that the roles of Chief Legal 
Officer, Group Head of Audit, Group Chief Human Resources Officer, Group Chief Compliance Officer, Group Company Secretary and 
Chief Governance Officer did not meet the criteria for KMP as provided for in the standard.

Particulars of transactions with related parties are tabulated below. The disclosure of the year-end balance and the highest amounts 
outstanding during the year is considered to be the most meaningful information to represent the amount of the transactions and 
outstanding balances during the year.

Key Management Personnel

Details of Directors’ remuneration and interest in shares are disclosed in the ‘Directors’ remuneration report’ on pages 229 to 255. 
IAS 24 ‘Related party disclosures’ requires the following additional information for key management compensation.

Compensation of Key Management Personnel

Short-term employee benefits 

Other long-term employee benefits 

Share-based payments 

Year ended 31 Dec

Shareholdings, options and other securities of Key Management Personnel

Number of options held over HSBC Holdings ordinary shares under employee share plans 

Number of HSBC Holdings ordinary shares held beneficially and non-beneficially 

At 31 Dec

2020

2019

2018

$m
39   
5   
20   
64   

$m
64   

8   

27   

99   

2020

(000s)

27   
11,916   
11,943   

$m
52 

6 

34 

92 

2019

(000s)

18 
15,546 

15,564 

Advances and credits, guarantees and deposit balances during the year with Key Management Personnel

Key Management Personnel

Advances and credits

Guarantees

Deposits

Footnotes

1

2020

2019

Balance at
31 Dec

$m

221   

30   

281   

Highest amounts
outstanding
during year

$m

357   

55   

874   

Balance at
31 Dec

$m

283   

34   

268   

Highest amounts
outstanding
during year

$m

328 

34 

659 

1  Advances and credits entered into by subsidiaries of HSBC Holdings plc during 2020 with Directors and former Directors, disclosed pursuant to 

section 413 of the Companies Act 2006, totalled $4.7m (2019: $3m).

360 HSBC Holdings plc Annual Report and Accounts 2020

 
 
 
 
 
 
 
 
 
 
 
 
 
Some of the transactions were connected transactions as defined by the Rules Governing The Listing of Securities on The Stock 
Exchange of Hong Kong Limited, but were exempt from any disclosure requirements under the provisions of those rules. The above 
transactions were made in the ordinary course of business and on substantially the same terms, including interest rates and security, as 
for comparable transactions with persons of a similar standing or, where applicable, with other employees. The transactions did not 
involve more than the normal risk of repayment or present other unfavourable features.

Associates and joint ventures

The Group provides certain banking and financial services to associates and joint ventures including loans, overdrafts, interest and non-
interest bearing deposits and current accounts. Details of the interests in associates and joint ventures are given in Note 18.

Transactions and balances during the year with associates and joint ventures

Unsubordinated amounts due from joint ventures

Unsubordinated amounts due from associates

Amounts due to associates 

Amounts due to joint ventures

Guarantees and commitments

2020

2019

Highest balance 
during the year

Balance at
31 Dec

Highest balance
during the year

Balance at
31 Dec

$m
147   

4,330   

5,466   

102   

433   

$m
147   

2,942   

2,226   

102   
283   

$m
132   

4,554   

2,517   

28   
647   

$m
123 

2,054 

516 

28 
407 

The above outstanding balances arose in the ordinary course of business and on substantially the same terms, including interest rates 
and security, as for comparable transactions with third-party counterparties.

Post-employment benefit plans

At 31 December 2020, $3.5bn (2019: $3.9bn re-presented) of HSBC post-employment benefit plan assets were under management by 
HSBC companies, earning management fees of $13m in 2020 (2019: $8m). The 2019 plan assets under management by HSBC 
companies have been re-presented to exclude $1.5bn of assets identified to be managed by third parties. At 31 December 2020, HSBC’s 
post-employment benefit plans had placed deposits of $452m (2019: $530m) with its banking subsidiaries, earning interest payable to 
the schemes of nil (2019: $0.3m). The above outstanding balances arose from the ordinary course of business and on substantially the 
same terms, including interest rates and security, as for comparable transactions with third-party counterparties.

The combined HSBC Bank (UK) Pension Scheme enters into swap transactions with HSBC to manage inflation and interest rate 
sensitivity of its liabilities and selected assets. At 31 December 2020, the gross notional value of the swaps was $7.7bn (2019: $9.9bn); 
these swaps had a positive fair value to the scheme of $1.0bn (2019: $1.2bn); and HSBC had delivered collateral of $1.0bn (2019: 
$1.2bn) to the scheme in respect of these arrangements. All swaps were executed at prevailing market rates and within standard market 
bid/offer spreads.

HSBC Holdings

Details of HSBC Holdings’ subsidiaries are shown in Note 37.

Transactions and balances during the year with subsidiaries

Assets 

Cash and balances with HSBC undertakings

Financial assets with HSBC undertakings designated and otherwise mandatorily 
measured at fair value

Derivatives 

Loans and advances to HSBC undertakings

Prepayments, accrued income and other assets

Investments in subsidiaries 

Total related party assets at 31 Dec

Liabilities

Amounts owed to HSBC undertakings 

Derivatives 

Accruals, deferred income and other liabilities

Subordinated liabilities

Total related party liabilities at 31 Dec

Guarantees and commitments

2020

2019

Highest balance
during the year

Balance at
31 Dec

Highest balance
during the year

$m

$m

$m

Balance at
31 Dec

$m

5,476   

2,913   

5,029   

2,382 

65,253   

5,784   

10,785   

1,838   

161,546   

250,682   

581   

3,376   

2,737   

892   

7,586   

65,253   

4,698   

10,443   

1,363   

160,660   

245,330   

330   

3,060   

1,936   

892   

6,218   

15,661   

13,787   

61,964   

3,902   

43,436   

655   

163,258   

278,244   

1,553   

2,183   

—   

892   

4,628   

11,541   

61,964 

2,002 

10,218 

480 

161,473 

238,519 

464 

2,021 

— 

892 

3,377 

11,061 

The above outstanding balances arose in the ordinary course of business and on substantially the same terms, including interest rates 
and security, as for comparable transactions with third-party counterparties.

Some employees of HSBC Holdings are members of the HSBC Bank (UK) Pension Scheme, which is sponsored by a separate Group 
company. HSBC Holdings incurs a charge for these employees equal to the contributions paid into the scheme on their behalf. 
Disclosure in relation to the scheme is made in Note 5.

HSBC Holdings plc Annual Report and Accounts 2020 361

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

36 Events after the balance sheet date

 .

An interim dividend for 2020 of $0.15 per ordinary share (a distribution of approximately $3,055m) was declared by the Directors after 
31 December 2020. HSBC Holdings called $1,450m 6.20% non-cumulative US dollar preference shares on 10 December 2020. The 
security was redeemed and cancelled on 13 January 2021. These accounts were approved by the Board of Directors on 23 February 
2021 and authorised for issue. 

37 HSBC Holdings’ subsidiaries, joint ventures and associates

In accordance with section 409 of the Companies Act 2006 a list of HSBC Holdings plc subsidiaries, joint ventures and associates, the 
registered office addresses and the effective percentages of equity owned at 31 December 2020 are disclosed below.

Unless otherwise stated, the share capital comprises ordinary or common shares that are held by Group subsidiaries. The ownership 
percentage is provided for each undertaking. The undertakings below are consolidated by HSBC unless otherwise indicated.

362 HSBC Holdings plc Annual Report and Accounts 2020

 
Subsidiaries

Subsidiaries

452 TALF Plus ABS Opportunities SPV LLC

452 TALF SPV LLC

Almacenadora Banpacifico S.A. (In Liquidation)
Assetfinance December (F) Limited

Assetfinance December (H) Limited

Assetfinance December (M) Limited (In 
Liquidation)

Assetfinance December (P) Limited

Assetfinance December (R) Limited

Assetfinance June (A) Limited

Assetfinance June (D) Limited

Assetfinance Limited

Assetfinance March (B) Limited

Assetfinance March (D) Limited

Assetfinance March (F) Limited

Assetfinance September (F) Limited

Assetfinance September (G) Limited

B&Q Financial Services Limited

Banco HSBC S.A.

Banco Nominees (Guernsey) Limited
Banco Nominees 2 (Guernsey) Limited

Banco Nominees Limited

Beau Soleil Limited Partnership

Beijing Miyun HSBC Rural Bank Company 
Limited

Billingsgate Nominees Limited (In Liquidation)

Canada Crescent Nominees (UK) Limited

Canada Square Nominees (UK) Limited

Capco/Cove, Inc.

Card-Flo #1, Inc.

Card-Flo #3, Inc.

CC&H Holdings LLC

CCF HOLDING (LIBAN) S.A.L. (In Liquidation)

Charterhouse Administrators ( D.T.) Limited

Charterhouse Management Services Limited

Charterhouse Pensions Limited

Chongqing Dazu HSBC Rural Bank Company 
Limited

Chongqing Fengdu HSBC Rural Bank Company 
Limited

Chongqing Rongchang HSBC Rural Bank 
Company Limited

COIF Nominees Limited
Cordico Management AG (In Liquidation)

100.00

100.00

99.99

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

74.99

100.00

100.00

100.00

100.00

100.00

100.00

N/A
100.00

Corsair IV Financial Services Capital Partners-B, 
LP

N/A

Dalian Pulandian HSBC Rural Bank Company 
Limited

Decision One Mortgage Company, LLC
Dem 9

Dempar 1

Desarrollo Turistico, S.A. de C.V. (In 
Liquidation)

Electronic Data Process México, S.A. de C.V.

Equator Holdings Limited (In Liquidation)

Eton Corporate Services Limited

Far East Leasing SA (In Dissolution)

Flandres Contentieux S.A.

Foncière Elysées

Fujian Yongan HSBC Rural Bank Company 
Limited

Fulcher Enterprises Company Limited

Fundacion HSBC, A.C.

Giller Ltd.

GPIF Co-Investment, LLC

100.00

N/A

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

% of share class 
held by immediate 
parent company 
(or by the Group 
where this varies)

Footnotes

Subsidiaries

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

13

13

14

15

16

17

16

16

16

15

16

18

15

16

16

15

16

19

20

20

21

Griffin International Limited

Grundstuecksgesellschaft Trinkausstrasse 
Kommanditgesellschaft

Grupo Financiero HSBC, S. A. de C. V.

Guangdong Enping HSBC Rural Bank 
Company Limited

Guangzhou HSBC Real Estate Company Ltd 

Hang Seng (Nominee) Limited

Hang Seng Bank (China) Limited

Hang Seng Bank (Trustee) Limited

Hang Seng Bank Limited

Hang Seng Bullion Company Limited

Hang Seng Credit Limited

Hang Seng Data Services Limited

Hang Seng Finance Limited

Hang Seng Financial Information Limited

Hang Seng Indexes (Netherlands) B.V.

Hang Seng Indexes Company Limited

Hang Seng Insurance Company Limited

Hang Seng Investment Management Limited

Hang Seng Investment Services Limited

Hang Seng Life Limited

0, 22

Hang Seng Real Estate Management Limited

Hang Seng Securities Limited

10, 23

Hang Seng Security Management Limited

24

16

16

25

13

13

26

27

16

16

16

10, 28

10, 29

10, 30

0, 16

31

0, 185

10, 32

0, 33

4, 34

4, 34

14

14

17

20

35

34

34

10, 36

37

9, 14

25

0, 13

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(62.14)

(99.99)

Haseba Investment Company Limited

HFC Bank Limited (In Liquidation)
High Time Investments Limited

Honey Green Enterprises Ltd.

Honey Grey Enterprises Limited

Honey Silver Enterprises Limited

Household International Europe Limited (In 
Liquidation)

Household Pooling Corporation

Housing (USA) LLP

HSBC (BGF) Investments Limited

HSBC (General Partner) Limited

HSBC (Guernsey) GP PCC Limited

HSBC (Kuala Lumpur) Nominees Sdn Bhd

HSBC (Malaysia) Trustee Berhad

HSBC (Singapore) Nominees Pte Ltd

HSBC Agency (India) Private Limited

HSBC Alternative Credit Strategies General 
Partner S.a r.l.

HSBC Alternative Investments Limited

HSBC Amanah Malaysia Berhad

HSBC Americas Corporation (Delaware)
HSBC Argentina Holdings S.A.

HSBC Asia Holdings B.V.

HSBC Asia Holdings Limited

HSBC Asia Pacific Holdings (UK) Limited

HSBC Asset Finance (UK) Limited

HSBC Asset Finance M.O.G. Holdings (UK) 
Limited

HSBC Asset Management (India) Private 
Limited

HSBC Assurances Vie (France)

HSBC Australia Holdings Pty Limited

HSBC BANK (CHILE)

HSBC Bank (China) Company Limited

HSBC Bank (General Partner) Limited

HSBC Bank (Mauritius) Limited

HSBC Bank (RR) (Limited Liability Company)

HSBC Bank (Singapore) Limited

HSBC Bank (Taiwan) Limited

HSBC Bank (Uruguay) S.A.

HSBC Bank (Vietnam) Ltd.

HSBC Bank A.S.

100.00

N/A

99.99

100.00

100.00

100.00

100.00

100.00

62.14

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

100.00

100.00

100.00

100.00

100.00

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(99.99)

Footnotes

16

0, 38

14

10, 39

40

37

41

37

37

37

37

37

37

37

42

37

37

37

37

37

37

37

37

37

17

37

43

44

44

17

45

16

2, 47

20

48

49

50

51

0, 52

16

48

13

53

16

2, 44

16

16

16

54

55

56

57

10, 58

47

59

0, 11, 60

50

61

62

63

64

HSBC Holdings plc Annual Report and Accounts 2020 363

Financial statements% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

Footnotes

Subsidiaries

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

(94.54)

 (99.99) 

53

65

56

21

66

0, 47

0, 47

67

48

68

5, 69

70

71

16

16

3, 72

15

19

44

44

44

44

44

44

0, 73

13

0, 47

44

13

14

74

74

16

16

75

0, 13

34

48

44

16

56

20

76

77

Notes on the financial statements

Subsidiaries

HSBC Bank Argentina S.A.

HSBC Bank Armenia cjsc

HSBC Bank Australia Limited

HSBC Bank Bermuda Limited

HSBC Bank Canada

HSBC Bank Capital Funding (Sterling 1) LP

HSBC Bank Capital Funding (Sterling 2) LP
HSBC Bank Egypt S.A.E

HSBC Bank Malaysia Berhad

HSBC Bank Malta p.l.c.

HSBC Bank Middle East Limited

HSBC Bank Middle East Limited 
Representative Office Morocco SARL (In 
Liquidation)

HSBC Bank Oman S.A.O.G.

HSBC Bank Pension Trust (UK) Limited

HSBC Bank plc

HSBC Bank USA, National Association

HSBC Branch Nominee (UK) Limited

HSBC Brasil Holding S.A.

HSBC Broking Forex (Asia) Limited

HSBC Broking Futures (Asia) Limited

HSBC Broking Futures (Hong Kong) Limited

HSBC Broking Securities (Asia) Limited

HSBC Broking Securities (Hong Kong) Limited

HSBC Broking Services (Asia) Limited

HSBC Canadian Covered Bond (Legislative) 
Guarantor Limited Partnership

HSBC Capital (USA), Inc.

HSBC Capital Funding (Dollar 1) L.P.

HSBC Capital Limited

HSBC Card Services Inc.

HSBC Casa de Bolsa, S.A. de C.V., Grupo 
Financiero HSBC

HSBC Cayman Limited

HSBC Cayman Services Limited

HSBC City Funding Holdings

HSBC Client Holdings Nominee (UK) Limited

HSBC Client Nominee (Jersey) Limited

HSBC Columbia Funding, LLC

HSBC Continental Europe

HSBC Corporate Advisory (Malaysia) Sdn Bhd

HSBC Corporate Finance (Hong Kong) Limited

HSBC Corporate Trustee Company (UK) 
Limited

HSBC Custody Nominees (Australia) Limited

HSBC Custody Services (Guernsey) Limited

HSBC Daisy Investments (Mauritius) Limited

HSBC Diversified Loan Fund General Partner 
Sarl

HSBC Electronic Data Processing (Guangdong) 
Limited

HSBC Electronic Data Processing (Malaysia) 
Sdn Bhd

HSBC Electronic Data Processing (Philippines), 
Inc.

HSBC Electronic Data Processing India Private 
Limited

HSBC Electronic Data Processing Lanka 
(Private) Limited

HSBC Electronic Data Service Delivery (Egypt) 
S.A.E.

HSBC Enterprise Investment Company (UK) 
Limited (In Liquidation)

HSBC Epargne Entreprise (France)

HSBC Equator (UK) Limited (In Liquidation)

HSBC Equipment Finance (UK) Limited

HSBC Equity (UK) Limited

HSBC Europe B.V.

100.00

100.00

100.00

100.00

100.00

N/A

N/A

99.63

100.00

70.03

100.00

100.00

51.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

100.00

N/A

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

99.99

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

364 HSBC Holdings plc Annual Report and Accounts 2020

HSBC Executor & Trustee Company (UK) 
Limited

HSBC Factoring (France)

HSBC Finance (Netherlands)

HSBC Finance Corporation

HSBC Finance Limited

HSBC Finance Mortgages Inc.

HSBC Finance Transformation (UK) Limited

HSBC Financial Services (Lebanon) s.a.l.

HSBC Financial Services (Middle East) Limited 
(In Liquidation)

HSBC Financial Services (Uruguay) S.A. (In 
Liquidation)

HSBC FinTech Services (Shanghai) Company 
Limited

HSBC Germany Holdings GmbH

HSBC Global Asset Management (Bermuda) 
Limited

HSBC Global Asset Management (Canada) 
Limited

HSBC Global Asset Management 
(Deutschland) GmbH

HSBC Global Asset Management (France)

HSBC Global Asset Management (Hong Kong) 
Limited

HSBC Global Asset Management 
(International) Limited (In Liquidation)

HSBC Global Asset Management (Japan) K. K.

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.65

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

(99.99)

(99.33)

(99.99)

HSBC Global Asset Management (Malta) 
Limited

100.00

(70.03)

HSBC Global Asset Management (México), 
S.A. de C.V., Sociedad Operadora de Fondos 
de Inversión, Grupo Financiero HSBC

100.00

(99.99)

Footnotes

15

34

2, 16

13

16

84

16

85

86

87

88

38

3, 21

66

38

55

22

89

90

91

14

HSBC Global Asset Management (Oesterreich) 
GmbH

100.00

(99.33)

6, 92

HSBC Global Asset Management (Singapore) 
Limited

100.00

50

HSBC Global Asset Management (Switzerland) 
AG

100.00

(99.66)

4, 93

HSBC Global Asset Management (Taiwan) 
Limited

HSBC Global Asset Management (UK) Limited

HSBC Global Asset Management (USA) Inc.

HSBC Global Asset Management Argentina 
S.A. Sociedad Gerente de Fondos Comunes de 
Inversión

HSBC Global Asset Management Holdings 
(Bahamas) Limited

HSBC Global Asset Management Limited

HSBC Global Custody Nominee (UK) Limited

HSBC Global Custody Proprietary Nominee 
(UK) Limited

HSBC Global Services (Canada) Limited

10, 78

HSBC Global Services (China) Holdings Limited

79

80

81

82

83

17

55

17

15

16

16

HSBC Global Services (Hong Kong) Limited

HSBC Global Services (UK) Limited

HSBC Global Services Limited

HSBC Global Shared Services (India) Private 
Limited (In Liquidation)

HSBC Group Management Services Limited

HSBC Group Nominees UK Limited

HSBC Holdings B.V.

HSBC IM Pension Trust Limited

HSBC Infrastructure Debt GP 1 S.à r.l.

HSBC Infrastructure Debt GP 2 S.à r.l.

HSBC Infrastructure Limited

HSBC INKA Investment-AG TGV

HSBC Inmobiliaria (Mexico), S.A. de C.V.

HSBC Institutional Trust Services (Asia) Limited

HSBC Institutional Trust Services (Bermuda) 
Limited

 (99.99) 

100.00

100.00

100.00

100.00

(99.99)

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

100.00

100.00

N/A

N/A

100.00

100.00

100.00

100.00

100.00

(99.33)

(99.99)

94

16

95

96

97

2, 16

16

1, 16

98

16

44

16

2, 16

1, 51

16

2, 16

16

16

0, 52

0, 52

16

12, 99

14

44

21

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

Footnotes

Subsidiaries

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

Footnotes

Subsidiaries
HSBC Institutional Trust Services (Mauritius) 
Limited
HSBC Institutional Trust Services (Singapore) 
Limited

HSBC Insurance (Asia) Limited

HSBC Insurance (Asia-Pacific) Holdings 
Limited

HSBC Insurance (Bermuda) Limited

HSBC Insurance (Singapore) Pte. Limited

HSBC Insurance Agency (USA) Inc.

HSBC Insurance Brokers (Philippines) Inc

HSBC Insurance Holdings Limited

HSBC Insurance SAC 1 (Bermuda) Limited

HSBC Insurance SAC 2 (Bermuda) Limited

HSBC Insurance Services (Lebanon) S.A.L. (In 
Liquidation)

HSBC Insurance Services Holdings Limited

HSBC International Finance Corporation 
(Delaware)

HSBC International Trustee (BVI) Limited

HSBC International Trustee (Holdings) Pte. 
Limited

HSBC International Trustee Limited

HSBC Inversiones S.A.

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

100.00

99.99

100.00

100.00

100.00

100.00

100.00

99.99

HSBC InvestDirect (India) Limited

100.00

(99.98)

HSBC InvestDirect Financial Services (India) 
Limited
HSBC InvestDirect Sales & Marketing (India) 
Limited
HSBC InvestDirect Securities (India) Private 
Limited

HSBC Investment Bank Holdings B.V.

HSBC Investment Bank Holdings Limited

HSBC Investment Company (Egypt) S.A.E (In 
Liquidation)

HSBC Investment Company Limited

HSBC Investment Funds (Canada) Inc.

HSBC Investment Funds (Hong Kong) Limited

HSBC Investment Funds (Luxembourg) SA

HSBC Invoice Finance (UK) Limited

HSBC Issuer Services Common Depositary 
Nominee (UK) Limited
HSBC Issuer Services Depositary Nominee 
(UK) Limited

HSBC Latin America B.V.

HSBC Latin America Holdings (UK) Limited

HSBC Leasing (Asia) Limited

HSBC Leasing (France)

HSBC Life (Cornell Centre) Limited

HSBC Life (Edwick Centre) Limited

HSBC Life (International) Limited

HSBC Life (Property Investment) Limited

HSBC Life (Property Light) Limited

HSBC Life (Property) Limited

HSBC Life (Tsing Yi Industrial) Limited

HSBC Life (UK) Limited

HSBC Life Assurance (Malta) Limited

HSBC LU Nominees Limited

HSBC Management (Guernsey) Limited

HSBC Markets (USA) Inc.

HSBC Marking Name Nominee (UK) Limited

HSBC Master Trust Trustee Limited

HSBC Mexico, S.A., Institucion de Banca 
Multiple, Grupo Financiero HSBC

HSBC Middle East Finance Company Limited

HSBC Middle East Holdings B.V.

HSBC Middle East Leasing Partnership

HSBC Middle East Securities L.L.C

HSBC Mortgage Corporation (Canada)

HSBC Mortgage Corporation (USA)

99.99

(99.98)

98.99

(98.98)

99.99

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

N/A

N/A

100.00

100.00

(97.81)

(99.99)

(70.03)

(80.00)

59

50

100

101

21

50

95

102

2, 16

21

21

103

16

104

8, 105

50

106

57

107

107

51

107

16

16

108

2, 16

109

22

52

110

16

16

16

2, 16

44

34

100

100

21

100

100

100

100

16

91

16

20

13

16

16

14

111

2, 112

0, 113

0, 114

115

13

HSBC Nominees (Asing) Sdn Bhd

HSBC Nominees (Hong Kong) Limited

HSBC Nominees (New Zealand) Limited

HSBC Nominees (Tempatan) Sdn Bhd

HSBC North America Holdings Inc.

HSBC Operational Services GmbH

HSBC Overseas Holdings (UK) Limited
HSBC Overseas Investments Corporation (New 
York)

HSBC Overseas Nominee (UK) Limited

HSBC Participaciones (Argentina) S.A.

HSBC PB Corporate Services 1 Limited

HSBC PB Services (Suisse) SA

HSBC Pension Trust (Ireland) DAC

HSBC Pensiones, S.A.

HSBC PI Holdings (Mauritius) Limited

HSBC Portfoy Yonetimi A.S.

HSBC Preferential LP (UK)

HSBC Private Bank (Luxembourg) S.A.

HSBC Private Bank (Suisse) SA

HSBC Private Bank (UK) Limited

HSBC Private Banking Holdings (Suisse) SA

HSBC Private Banking Nominee 3 (Jersey) 
Limited

HSBC Private Equity Investments (UK) Limited

HSBC Private Trustee (Hong Kong) Limited

HSBC Private Wealth Services (Canada) Inc.

HSBC Professional Services (India) Private 
Limited

HSBC Property (UK) Limited

HSBC Property Funds (Holding) Limited

HSBC Provident Fund Trustee (Hong Kong) 
Limited

HSBC Qianhai Securities Limited

HSBC Real Estate Leasing (France)

HSBC Realty Credit Corporation (USA)

HSBC REGIO Fund General Partner S.à r.l.

HSBC REIM (France)

HSBC Retirement Benefits Trustee (UK) Limited

HSBC Retirement Services Limited

HSBC Savings Bank (Philippines) Inc.

HSBC Securities (Asia) Limited (In Liquidation)

HSBC Securities (Canada) Inc.

HSBC Securities (Egypt) S.A.E.

HSBC Securities (Japan) Limited

HSBC Securities (Singapore) Pte Limited

HSBC Securities (South Africa) (Pty) Limited

HSBC Securities (Taiwan) Corporation Limited

HSBC Securities (USA) Inc.

HSBC Securities and Capital Markets (India) 
Private Limited

HSBC Securities Asia Nominees Limited (In 
Liquidation)

HSBC Securities Brokers (Asia) Limited

HSBC Securities Investments (Asia) Limited

HSBC Securities Services (Bermuda) Limited

HSBC Securities Services (Guernsey) Limited

HSBC Securities Services (Ireland) DAC

HSBC Securities Services (Luxembourg) S.A.

HSBC Securities Services Holdings (Ireland) 
DAC

HSBC Securities Services Nominees Limited

HSBC Seguros de Retiro (Argentina) S.A.

HSBC Seguros de Vida (Argentina) S.A.

HSBC Seguros, S.A de C.V., Grupo Financiero 
HSBC

HSBC Service Company Germany GmbH

HSBC Service Delivery (Polska) Sp. z o.o.

HSBC Services (France)

HSBC Services Japan Limited

100.00

100.00

100.00

100.00

100.00

90.10

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

48

44

116

48

3, 13

117

2, 16

118

16

53

119

120

121

14

59

122

16

52

123

16

120

124

16

44

109

125

16

16

44

10, 126

34

13

52

55

1, 2, 16

1, 16

127

44

98

67

16

50

128

129

13

51

44

44

44

21

20

121

52

121

44

53

53

3, 14

130

131

34

132

(89.49)

(99.99)

(51.00)

(99.99)

(99.99)

(94.65)

(99.99)

(99.99)

(99.99)

(99.33)

(99.99)

HSBC Holdings plc Annual Report and Accounts 2020 365

Financial statementsNotes on the financial statements

Subsidiaries

HSBC Services USA Inc.

HSBC Servicios Financieros, S.A. de C.V

HSBC Servicios, S.A. DE C.V., Grupo 
Financiero HSBC

HSBC SFH (France)

HSBC SFT (C.I.) Limited
HSBC Software Development (Guangdong) 
Limited
HSBC Software Development (India) Private 
Limited
HSBC Software Development (Malaysia) Sdn 
Bhd

HSBC Specialist Investments Limited

HSBC Technology & Services (China) Limited

HSBC Technology & Services (USA) Inc.

HSBC Transaction Services GmbH

HSBC Trinkaus & Burkhardt (International) S.A.

HSBC Trinkaus & Burkhardt AG
HSBC Trinkaus & Burkhardt Gesellschaft fur 
Bankbeteiligungen mbH
HSBC Trinkaus Europa Immobilien-Fonds Nr. 5 
GmbH

HSBC Trinkaus Family Office GmbH

HSBC Trinkaus Immobilien Beteiligungs KG

HSBC Trinkaus Real Estate GmbH

HSBC Trust Company (Canada)

HSBC Trust Company (Delaware), National 
Association

HSBC Trust Company (UK) Limited

HSBC Trust Company AG (In Liquidation)

HSBC Trustee (C.I.) Limited

HSBC Trustee (Cayman) Limited

HSBC Trustee (Guernsey) Limited

HSBC Trustee (Hong Kong) Limited

HSBC Trustee (Singapore) Limited

HSBC UK Bank plc

HSBC UK Client Nominee Limited

HSBC UK Holdings Limited

HSBC USA Inc.

HSBC Ventures USA Inc.

HSBC Violet Investments (Mauritius) Limited

HSBC Wealth Client Nominee Limited

HSBC Yatirim Menkul Degerler A.S.

HSI Asset Securitization Corporation

HSI International Limited

HSIL Investments Limited

Hubei Macheng HSBC Rural Bank Company 
Limited

Hubei Suizhou Cengdu HSBC Rural Bank 
Company Limited

Hubei Tianmen HSBC Rural Bank Company 
Limited

Hunan Pingjiang HSBC Rural Bank Company 
Limited

Imenson Limited

Infrared NF China Real Estate Investments LP

INKA Internationale Kapitalanlagegesellschaft 
mbH

Inmobiliaria Banci, S.A. de C.V.

Inmobiliaria Bisa, S.A. de C.V.

Inmobiliaria Grufin, S.A. de C.V.

Inmobiliaria Guatusi, S.A. de C.V.

James Capel & Co. Limited

James Capel (Nominees) Limited

James Capel (Taiwan) Nominees Limited

John Lewis Financial Services Limited

Keyser Ullmann Limited

Lion Corporate Services Limited

Lion International Corporate Services Limited

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

Footnotes

Subsidiaries

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

Footnotes

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.33

(99.99)

(99.99)

(99.99)

(99.33)

(99.33)

100.00

(99.33)

(99.33)

(99.33)

(99.33)

(99.33)

(62.14)

(62.14)

(99.33)

(99.68)

(99.99)

(99.99)

(99.99)

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

100.00

100.00

99.98

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

133

14

14

4, 55

20

134

135

79

16

136

13

6, 137

52

38

38

38

6, 38

38

6, 38

115

104

16

31

124

138

20

44

50

15

15

2, 16

118

13

76

1, 15

122

13

37

16

139

Lion International Management Limited

Lion Management (Hong Kong) Limited

Lyndholme Limited

Marks and Spencer Financial Services plc
Marks and Spencer Unit Trust Management 
Limited

Maxima S.A. AFJP (In Liquidation)

Mexicana de Fomento, S.A. de C.V.

Midcorp Limited

Midland Bank (Branch Nominees) Limited

Midland Nominees Limited

MIL (Cayman) Limited

MW Gestion SA

Promocion en Bienes Raices, S.A. de C.V.

Prudential Client HSBC GIS Nominee (UK) 
Limited
PT Bank HSBC Indonesia

PT HSBC Sekuritas Indonesia

R/CLIP Corp.

Real Estate Collateral Management Company

Republic Nominees Limited

Republic Overseas Capital Corporation

RLUKREF Nominees (UK) One Limited

RLUKREF Nominees (UK) Two Limited

S.A.P.C. - Ufipro Recouvrement

Saf Baiyun

Saf Guangzhou

Saf Zhu Jiang Shi Ba

Saf Zhu Jiang Shi Er

Saf Zhu Jiang Shi Jiu

Saf Zhu Jiang Shi Liu

Saf Zhu Jiang Shi Qi

Saf Zhu Jiang Shi Wu

SCI HSBC Assurances Immo

Serai Limited

Serai Technology Development (Shanghai) 
Limited

SFM

SFSS Nominees (Pty) Limited

Shandong Rongcheng HSBC Rural Bank 
Company Limited

Shenzhen HSBC Development Company Ltd

Sico Limited

SNC Dorique

SNC Les Mercuriales

SNC Les Oliviers D'Antibes

SNC Makala

SNCB/M6 - 2008 A

SNCB/M6-2007 A

SNCB/M6-2007 B

Société Française et Suisse

10, 140

Somers Dublin DAC

141

10, 142

37

0, 186

137

14

14

14

14

16

16

16

16

16

44

1, 106

Somers Nominees (Far East) Limited

Sopingest

South Yorkshire Light Rail Limited

St Cross Trustees Limited
Sun Hung Kai Development (Lujiazui III) 
Limited

Swan National Limited

Tasfiye Halinde HSBC Odeme Sistemleri 
Bilgisayar Teknolojileri Basin Yayin Ve Musteri 
Hizmetleri (In Liquidation)

The Hongkong and Shanghai Banking 
Corporation Limited

The Venture Catalysts Limited

Tooley Street View Limited

Tower Investment Management

Trinkaus Australien Immobilien Fonds Nr. 1 
Brisbane GmbH & Co. KG

Trinkaus Australien Immobilien-Fonds Nr. 1 
Treuhand-GmbH

100.00

100.00

100.00

100.00

100.00

99.98

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

85.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

60.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

(99.90)

(99.99)

(98.93)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

106

1, 44

44

143

143

53

14

16

15

15

74

53

14

16

144

145

13

13

20

95

1, 16

1, 16

34

4, 34

4, 34

4, 34

4, 34

4, 34

4, 34

4, 34

4, 34

55

1, 44

10, 147

34

128

10, 148

149

150

1, 9, 151

(99.99)

1, 9, 34

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

55

1, 9, 34

34

4, 34

4, 34

34

121

21

34

16

15

10, 152

16

153

44

16

2, 16

154

100.00

(99.33)

38

100.00

(99.33)

6, 38

366 HSBC Holdings plc Annual Report and Accounts 2020

Subsidiaries

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

Footnotes

Trinkaus Europa Immobilien-Fonds Nr.3 Objekt 
Utrecht Verwaltungs-GmbH

100.00

(99.33)

38

Trinkaus Immobilien-Fonds 
Geschaeftsfuehrungs-GmbH

Trinkaus Immobilien-Fonds Verwaltungs-
GmbH

Trinkaus Private Equity Management GmbH

Trinkaus Private Equity Verwaltungs GmbH

Tropical Nominees Limited

Turnsonic (Nominees) Limited

Valeurs Mobilières Elysées

Wardley Limited

Wayfoong Nominees Limited

Wayhong (Bahamas) Limited

Westminster House, LLC

Woodex Limited

Yan Nin Development Company Limited

Joint ventures

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

N/A

100.00

100.00

(99.33)

(99.33)

(99.33)

(99.99)

(62.14)

6, 38

38

6, 38

74

15

34

44

44

97

0, 13

21

37

The undertakings below are joint ventures and equity accounted.

Joint ventures

CCF & Partners Asset Management Limited

Global Payments Technology Mexico S.A. De 
C.V.

House Network Sdn Bhd
HSBC Life Insurance Company Limited

HSBC Pollination Climate Asset Management 
Limited

ProServe Bermuda Limited

The London Silver Market Fixing Limited

Vaultex UK Limited

% of share class 
held by immediate 
parent company (or 
by the Group where 
this varies)

100.00

(99.99)

50.00

25.00

50.00

40.00

50.00

N/A

50.00

Associates

The undertakings below are associates and equity accounted.

% of share class 
held by immediate 
parent company (or 
by the Group where 
this varies)

Footnotes

100.00

(99.33)

6, 38

Associates

Bank of Communications Co., Ltd.

Barrowgate Limited

BGF Group PLC

Bud Financial Limited

Canara HSBC Oriental Bank of Commerce Life 
Insurance Company Limited

CFAC Payment Scheme Limited

Chemi & Cotex (Rwanda) Limited

Chemi & Cotex Kenya Limited

Chemi and Cotex Industries Limited

Contour

Episode Six Limited

EPS Company (Hong Kong) Limited

EURO Secured Notes Issuer

GIE GNIFI

GZHS Research Co Ltd

Hang Seng Qianhai Fund Management 
Company Limited

HCM Holdings Limited (In Liquidation)

19.03

15.31

24.56

10.82

26.00

33.33

33.99

33.99

33.99

10.80

9.10

38.66

16.66

N/A

20.50

43.49

50.99

HSBC Canadian Covered Bond (Legislative) GP 
Inc.

100.00

Footnotes

16

14

155

156

157

158

HSBC Jintrust Fund Management Company 
Limited

HSBC Saudi Arabia, a Saudi closed Joint Stock 
Company

Icon Brickell LLC (In Liquidation)

Jeppe Star Limited

Liquidity Match LLC

London Precious Metals Clearing Limited

MENA Infrastructure Fund (GP) Ltd

0, 1, 159

160

Novo Star Limited

Quantexa Ltd

Services Epargne Entreprise

Simon Group LLC

sino AG

The London Gold Market Fixing Limited

The Saudi British Bank

Trade Information Network

Trinkaus Europa Immobilien-Fonds Nr. 7 Frankfurt 
Mertonviertel KG

Vizolution Limited

We Trade Innovation Designated Activity 
Company

49.00

66.18

N/A

33.99

N/A

30.00

33.33

33.99

10.99

14.18

N/A

24.77

25.00

30.99

16.67

N/A

17.95

8.52

161

162

163

1, 164

165

166

1, 167

1, 168

169

191

187

44

170

0, 1, 171

172

1, 10, 173

17

73

174

175

0, 176

177

0, 188

189

178

179

146

180

0, 190

181

159

182

192

0, 38

1, 183

1, 184

HSBC Holdings plc Annual Report and Accounts 2020 367

Financial statements 
Notes on the financial statements

Footnotes for Note 37

Description of Shares

0

1

2
3
4
5
6
7
8
9
10
11
12

Where an entity is governed by voting rights, HSBC consolidates 
when it holds – directly or indirectly – the necessary voting rights 
to pass resolutions by the governing body. In all other cases, the 
assessment of control is more complex and requires judgement 
of other factors, including having exposure to variability of 
returns, power to direct relevant activities, and whether power is 
held as an agent or principal. HSBC’s consolidation policy is 
described in Note 1.2(a).
Management has determined that these undertakings are 
excluded from consolidation in the Group accounts as these 
entities do not meet the definition of subsidiaries in accordance 
with IFRS. HSBC’s consolidation policy is described in Note 
1.2(a).
Directly held by HSBC Holdings plc
Preference Shares
Actions
Redeemable Preference Shares
GmbH Anteil
Limited and Unlimited Liability Shares
Non-Participating Voting Shares
Parts
Registered Capital Shares
Russian Limited Liability Company Shares
Stückaktien

Registered offices

13

14

15

16
17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

c/o The Corporation Trust Company 1209 Orange Street, 
Wilmington, Delaware, United States of America, 19801

Paseo de la Reforma 347 Col. Cuauhtemoc, Mexico, 06500

1 Centenary Square, Birmingham, United Kingdom, B1 1HQ

8 Canada Square, London, United Kingdom, E14 5HQ
Hill House 1 Little New Street, London, United Kingdom, EC4A 
3TR

5 Donegal Square South, Northern Ireland, Belfast, United 
Kingdom, BT1 5JP

1909 Avenida Presidente Juscelino Kubitschek, 19° andar, 
Torre Norte, São Paulo Corporate Towers, São Paulo, Brazil, 
04551-903

Arnold House St Julians Avenue, St Peter Port, Guernsey, GY1 
3NF

37 Front Street, Hamilton, Bermuda, HM 11

HSBC Main Building 1 Queen's Road Central, Hong Kong

First Floor, Xinhua Bookstore Xindong Road (SE of 
roundabout), Miyun District, Beijing, China

Deloitte LLP, 1 New Street Square, London, EC4A 3HQ, United 
Kingdom

95 Washington Street Buffalo, New York, United States of 
America, 14203

Corporation Service Company 251 Little Falls Drive, 
Wilmington, Delaware, United States of America, 19808

Solidere - Rue Saad Zaghloul Immeuble - 170 Marfaa, P.O. Box 
17 5476 Mar Michael, Beyrouth, Lebanon, 11042040

No 1, Bei Huan East Road Dazu County, Chongqing, China

No 107 Ping Du Avenue (E), Sanhe Town, Fengdu County, 
Chongqing, China

No. 3, 5, 7, Haitang Erzhi Road Changyuan, Rongchang, 
Chongqing, China, 402460

Bederstrasse 49, Zurich, Switzerland, CH-8002

First & Second Floor, No.3 Nanshan Road, Pulandian , Dalian, 
Liaoning, China

CT Corporation System 225 Hillsborough Street, Raleigh, North 
Carolina, United States Of America, 27603

38 avenue Kléber, Paris, France, 75116

MMG Tower, 23 floor Ave. Paseo del Mar Urbanizacion Costa 
del Este, Panama

No. 1 1211 Yanjiang Zhong Road, Yongan, Fujian, China

83 Des Voeux Road Central, Hong Kong

368 HSBC Holdings plc Annual Report and Accounts 2020

Registered offices

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

71

72

73

Königsallee 21/23, Düsseldorf, Germany, 40212

No.44 Xin Ping Road Central, Encheng, Enping, Guangdong, 
China, 529400

Room 1701-010 Heung Kong Building, 37 Jin Long Rd, 
Nansha District, Guangzhou, China

34/F and 36/F, Hang Seng Bank Tower 1000 Lujiazui Ring 
Road, Pilot Free Trade Zone, Shanghai, Shanghai, China, 
200120

Claude Debussylaan 10 Office Suite 20, 1082MD, Amsterdam, 
Netherlands

Commerce House, Wickhams Cay 1, P.O. Box 3140, Road 
Town, Tortola, British Virgin Islands, VG1110

1 Queen's Road Central, Hong Kong

The Corporation Trust Company of Nevada 311 S. Division 
Street, Carson City, Nevada, United States of America, 89703

Corporation Service Company 2711 Centerville Road, Suite 
400, Wilmington, Delaware, United States of America, 19808

HSBC House Esplanade, St. Helier, Jersey, JE4 8UB

10th Floor South Tower, Bangunan HSBC, No. 2, Leboh 
Ampang, Kuala Lumpur, Malaysia, 50100

13th Floor, South Tower 2 Leboh Ampang, Kuala Lumpur, 
Malaysia, 50100

10 Marina Boulevard #48-01 Marina Bay Financial Centre, 
Singapore, 018983

52/60 M G Road Fort, Mumbai, India, 400 001

16 Boulevard d'Avranches, Luxembourg, Luxembourg, L-1160

557 Bouchard Level 20, Ciudad de Buenos Aires, Capital 
federal, Argentina, C1106ABG

3rd Floor Merchantile Bank Chamber 16, Veer Nariman Road, 
Fort, Mumbai, India, 400001

Immeuble Cœur Défense 110 esplanade du Général de Gaulle, 
Courbevoie, France, 92400

Level 36 Tower 1 International Towers Sydney, 100 
Barangaroo Avenue, Sydney, New South Wales, Australia, 
2000

Isidora Goyenechea 2800 23rd floor, Las Condes, Santiago, 
Chile, 7550647

HSBC Building Shanghai ifc, 8 Century Avenue, Pudong, 
Shanghai, China, 200120

6th floor HSBC Centre 18, Cybercity, Ebene, Mauritius, 72201

2 Paveletskaya square building 2, Moscow, Russian 
Federation, 115054

13F-14F, 333 Keelung Road, Sec.1, Taipei, 110, Taiwan

25 de Mayo 471, Montevideo, Uruguay, 11000

The Metropolitan 235 Dong Khoi Street, District 1, Ho Chi Minh 
City, Viet Nam

Esentepe mah. Büyükdere Caddesi No.128, Istanbul, Turkey, 
34394

66 Teryan street, Yerevan, Armenia, 0009

885 West Georgia Street 3rd Floor, Vancouver, British 
Columbia, Canada, V6C 3E9

306 Corniche El Nil, P.O. Box 124, Maadi, Egypt, 11728

116 Archbishop Street, Valletta, Malta

Level 1, Building No. 8, Gate Village Dubai International 
Financial Centre, United Arab Emirates, P.O. Box 30444

Majer Consulting, Office 54/44, Building A1, Residence Ryad 
Anfa, Boulevard Omar El Khayam, Casa Finance City (CFC), 
Casablanca, Morocco

Al Khuwair Office PO Box 1727 PC111 CPO Seeb, Muscat, 
Oman

1800 Tysons Boulevard Suite 50, Tysons, Virginia, United 
States of America, 22102

66 Wellington Street West, Suite 5300, Toronto, Ontario, 
Canada, M5K 1E6

 
Registered offices

Registered offices

74

75

76

77

78

79

80

81

82

83

84

85

86

87

88

89

90

91

92

93

94

95
96

97
98

99

P.O. Box 1109, Strathvale House, Ground floor, 90 North 
Church Street, George Town, Grand Cayman, Cayman Islands, 
KY1-1102

HSBC House Esplanade, St. Helier, Jersey, JE1 1HS

c/o Rogers Capital St. Louis Business Centre, Cnr Desroches & 
St Louis Streets, Port Louis, Mauritius

49 avenue J.F. Kennedy, Luxembourg, Luxembourg, 
1855

4-17/F, Office Tower 2 TaiKoo Hui, No. 381 Tian He Road, Tian 
He District, Guangzhou, Guangdong, China

Suite 1005, 10th Floor, Wisma Hamzah Kwong, Hing No. 1, 
Leboh Ampang, Kuala Lumpur, Malaysia, 50100

HSBC, Filinvest One Bldg Northgate Cyberzone, Filinvest 
Corporate City, Alabang, Muntinlupa City, Philippines, 1781

HSBC House Plot No.8 Survey No.64 (Part), Hightec City 
Layout Madhapur, Hyderabad, India, 500081

439, Sri Jayawardenapura Mawatha Welikada, Rajagiriya, 
Colombo, Sri Lanka

Smart Village 28th Km Cairo- Alexandria Desert Road Building, 
Cairo, Egypt

Suite 300 3381 Steeles Avenue East, Toronto, Ontario, Canada, 
M2H 3S7

Centre Ville 1341 Building - 4th Floor Patriarche Howayek 
Street (facing Beirut Souks), PO Box Riad El Solh, Lebanon, 
9597

3rd Floor, HSBC Bank Middle East Limited Building, Al Souq 
Road, P.O Box 4604, Dubai, United Arab Emirates

World Trade Center Montevideo Avenida Luis Alberto de 
Herrera 1248, Torre 1, Piso 15, Oficina 1502, Montevideo, 
Uruguay, CP 11300

Room 655, Building A, No. 888, Huan Hu West Two Road, Lin 
Gang New Area of Shanghai (Pilot) Free Trade Zone, China, 
Shanghai, Shanghai, China

HSBC House Esplanade, St. Helier, Jersey, JE4 8WP

HSBC Building 11-1, Nihonbashi 3-chome, Chuo-ku, Tokyo, 
Japan, 103-0027

80 Mill Street, Qormi, Malta, QRM 3101

Herrengasse 1-3, Wien, Austria, 1010

26 Gartenstrasse, Zurich, Switzerland, 8002

24th Fl. 97-99, Sec.2, Tunhwa S. Rd., Taipei, Taiwan, R.O.C.,  
Taiwan

452 Fifth Avenue, New York, United States of America, 
Bouchard 557, Piso 18°, Cdad. Autónoma de Buenos Aires, 
Argentina, 1106

Mareva House 4 George Street, Nassau, Bahamas
70 York Street, Toronto, Ontario, Canada, M5J 1S9

Breite Str. 29/31, Düsseldorf, Germany, 40213

100

101

102

103

104

18th Floor, Tower 1, HSBC Centre 1 Sham Mong Road, 
Kowloon, Hong Kong

Level 32, HSBC Main Building 1 Queen's Road Central, Hong 
Kong SAR, Hong Kong

7/F HSBC Centre 3058 Fifth Ave West, Bonifacio Global City, 
Taguig City, Philippines

HSBC Building Minet El Hosn, Riad el Solh, Beirut 1107-2080, 
Lebanon, P.O. Box 11-1380

300 Delaware Avenue Suite 1401, Wilmington, Delaware, 
United States Of America, 19801

105 Woodbourne Hall, Road Town, Tortola, British Virgin Islands, 

P.O. Box 916

106

107

108

109

110

Craigmuir Chambers, PO Box 71, Road Town, Tortola, British 
Virgin Islands

9-11 Floors, NESCO IT Park Building No. 3 Western Express 
Highway, Goregaon (East), Mumbai, India, 400063

3, Aboul Feda Street Zamalek, Cairo, Egypt

300-885 West Georgia Street, Vancouver, British Columbia, 
Canada, V6C 3E9

21 Farncombe Road Worthing, United Kingdom, BN11 2BW

111

112

113

114

115

116

117

118

119

120

121

122

123

124

125

126

127

128

129

130

Plot No.312-878 Mezzanine Floor, Bldg. of Sheikh Hamdan Bin 
Rashid, Dubai Creek, Dubai, United Arab Emira

Level 1, Building No. 8, Gate Village Dubai International 
Financial Centre, PO Box 30444, United Arab Emirates

Unit 101 Level 1, Gate Village Building No. 8 Dubai 
International Financial Centre (DIFC), Dubai, United Arab 
Emirates, PO Box 506553

Office No.16 Owned by HSBC Bank Middle East Limited, 
Dubai Branch, Bur Dubai, Burj Khalifa, Dubai, United Arab 
Emirates
885 West Georgia Street Suite 300, Vancouver, British 
Columbia, Canada, V6C 3E9

HSBC Tower, Level 21, 188 Quay Street, Auckland, New 
Zealand, 1010

21-23 Yorckstraße, Düsseldorf, Nordrhein-Westfalen, 
Germany, 40476

The Corporation Trust Incorporated, 2405 York Road, Suite 
201, Lutherville Timonium, Maryland, United Sta

HSBC House Esplanade, St. Helier, Jersey, JE1 1GT

Quai des Bergues 9-17, Geneva, Switzerland, 1201

1 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, 
D02 P820

Esentepe mah. Büyükdere Caddesi No.128, Istanbul, Turkey, 
34394

Quai des Bergues 9-17, Geneva, Switzerland, 1201

HSBC House Esplanade, St Helier, Jersey, JE1 1GT

52/60 M G Road, Fort, Mumbai, India, 400 001

Block 27 A&B, Qianhai Enterprise Dream Park No. 63 Qianwan 
Yi Road, Shenzhen-Hong Kong Cooperation Zone, Shenzhen, 
China, 518052

Unit 1 GF The Commerical Complex Madrigal Avenue, Ayala 
Alabang Village, Muntinlupa City, Philippines, 17

1 Mutual Place 107 Rivonia Road, Sandton, Sandton, Gauteng, 
South Africa, 2196

13F 333 Keelung Road, Sec.1, Taipei, Taiwan, 110

Hansaallee 3, Düsseldorf, Germany, 40549

Kapelanka 42A, Krakow, Poland, 30-347

131
132 MB&H Corporate Services Ltd Mareva House, 4 George Street, 

Nassau, Bahamas

133

134

135

136

137

138

139

140

141

142

143

C T Corporation System 820 Bear Tavern Road, West Trenton, 
New Jersey, United States Of America, 08628

L22, Office Tower 2, Taikoo Hui, 381 Tianhe Road, Tianhe 
District, Guangzhou, Guangdong, China

HSBC Centre River Side, West Avenue, 25B Raheja woods, 
Kalyaninagar, Pune, India, 411006

Level 19, HSBC Building, Shanghai ifc 8 Century Avenue 
Pudong, Shanghai, China

Yorckstraße 21 - 23, Duesseldorf, Germany, 40476

P.O. Box 309 Ugland House, Grand Cayman, Cayman Islands, 
KY1-1104

No. 56 Yu Rong Street, Macheng, China, 438300

No. 205 Lie Shan Road Suizhou, Hubei, China

Building 3, Yin Zuo Di Jing Wan Tianmen New City, Tianmen, 
Hubei Province, China

RM101, 102 & 106 Sunshine Fairview, Sunshine Garden, 
Pedestrian Walkway, Pingjiang, China

Kings Meadow Chester Business Park, Chester, United 
Kingdom, CH99 9FB

144 World Trade Center 1, Floor 8-9 Jalan Jenderal Sudirman 

Kavling 29 - 31, Jakarta, Indonesia, 12920

145

146

147

5th Floor, World Trade Center 1, Jl. Jend. Sudirman Kav. 
29-31, Jakarta, Indonesia, 12920

75 Park Lane, Croydon, Surrey, United Kingdom, CR9 1XS

Unit B02 20/F No. 168 Yin Cheng Zhong Road, Pilot Free Trade 
Zone, Shanghai, China, 200120

148

No.198-2 Chengshan Avenue (E), Rongcheng, China, 264300

HSBC Holdings plc Annual Report and Accounts 2020 369

Financial statementsNotes on the financial statements

Registered offices

Registered offices

185

186

187

188

189

190

191

c/o Walkers Corporate Services Limited, Walker House, 87 
Mary Street, George Town, Grand Cayman, KY1 – 90

Oak House Hirzel Street, St Peter Port, Guernsey, GY1 2NP

9/F Amtel Bldg, 148 des Voeux Rd Central, Central, Hong Kong

100 Town Square Place, Suite 201, Jersey City, NJ 07310, 
United States of America

1-2 Royal Exchange Buildings, Royal Exchange, London, 
United Kingdom, EC3V 3LF

25 W 25th St. New   York, NY 10001, United States of America

50 Raffles Place, #32-01 Singapore Land Tower, 048623, 
Singapore

192

3 More London Riverside, London, United Kingdom, SE1 2AQ

149

Room 1303-13062 Marine Center Main Tower, 59 Linhai Rd, 
Nanshan District, Shenzhen, China

150 Woodbourne Hall, Road Town, Tortola, British Virgin Islands, 

P.O. Box 3162

151

152

153

154

155

156

43 rue de Paris, Saint Denis, France, 97400

RM 2112, HSBC Building, Shanghai ifc No. 8 Century Road, 
Pudong, Shanghai, China, 200120

Esentepe mah. Büyükdere Caddesi No.128, Istanbul, Turkey, 
34394

11 Dr. Roy’s Drive PO Box 694GT, Grand Cayman, Cayman 
Islands, KY1-1107

Lot 6.05, Level 6, KPMG Tower 8 First Avenue, Bandar Utama, 
Petaling Jaya, Selangor Darul Ehsan, Malaysia

18/F Unit 2101, 2113, 2113A, 2115 and 2116 of 21/F, HSBC 
Building, 8 Century Avenue, China (Shanghai) Pilot Free Trade 
Zone, Shanghai, China, 200120

3 More London Riverside, London, United Kingdom, SE1 2AQ

157
158 c/o MUFG Fund Services (Bermuda) Limited The Belvedere 

Building, 69 Pitts Bay Road, Pembroke, Bermuda, HM

159

160

161

162

163

164

165

166

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

c/o Hackwood Secretaries Limited One Silk Street, London, 
United Kingdom, EC2Y 8HQ

All Saints Triangle Caledonian road, London, United Kingdom, 
N19UT

No.188, Yin Cheng Zhong Road China (Shanghai), Pilot Free 
Trade Zone, Shanghai, China

49/F The Lee Gardens, 33 Hysan Avenue, Hong Kong

13-15 York Buildings, London, United Kingdom, WC2N 6JU

First Floor The Bower, 207 Old Street, England, United 
Kingdom, EC1V 9NR

Unit No. 208, 2nd Floor, Kanchenjunga Building 18, 
Barakhamba Road, New Delhi, India, 110001

65 Gresham Street 6th Floor, London, United Kingdom, EC2V 
7NQ

PO 4978, Kigali, Rwanda

Plot LR No. 487 Dagoretti / Ruthimitu, P.O. Box 14362, 
Nairobi, Kenya, 00800

Plot No. 89-90 Mbezi Industrial Area Box 347, Dar es Salaam 
City, Tanzania, United Republic of Tanzania

3 avenue de l'Opera, Paris, France, 75001

37 avenue Henri Lafleur, Nouméa, New Caledonia, BP K3 
98849

Room 1303, 106 Feng Ze Dong Road, Nansha District, 
Guangzhou, Guangdong, China

Flat 209, Hedge Fund Centre of Qianhai Shenzhen-Hong Kong 
Fund Town No. 128 Guiwan Five Road, Qianhai Shenzhen-
Hong Kong Cooperation Zone, Shenzhen, China
17F, HSBC Building, Shanghai ifc 8 Century Avenue, Pudong, 
Shanghai, China

HSBC Building 7267 Olaya - Al Murrooj, Riyadh, Saudi Arabia, 
12283 - 2255

C T Corporation System 1200 South Pine Island Road 
Plantation, Florida, United States of America, 33324

c/o Trident Trust Company Trident Chambers, PO Box 146, 
Tortola, British Virgin Islands

Office 705, Level 8, Tower 2, Al Fattan Currency House, DIFC, 
P.O.Box 506553, Dubai, UAE

Jayla Place Wickhams Cay I, PO Box 3190, Road Town, British 
Virgin Islands

32 rue du Champ de Tir, Nantes, France, 44300

Ernst-Schneider-Platz 1, Duesseldorf, Germany, 40212

Al Amir Abdulaziz Ibn Mossaad Ibn Jalawi Street, Riyadh, 
Saudi Arabia

Office Block A, Bay Studios Business Park, Fabian Way, 
Swansea, Wales, United Kingdom, SA1 8QB

10 Earlsfort Terrace, Dublin, Ireland, D02 T380

370 HSBC Holdings plc Annual Report and Accounts 2020

Shareholder information

Interim dividend for 2020

Interim dividends for 2021

Other equity instruments

2020 Annual General Meeting 

Earnings releases and interim results 

Shareholder enquiries and communications 

Stock symbols 

Investor relations 

Where more information about HSBC is available

Taxation of shares and dividends

Approach to ESG reporting

Cautionary statement regarding forward-looking statements

Certain defined terms

Abbreviations

Page

371

371

371

371

372

372

373

373

373

374

375

375

376

377

A glossary of terms used in this Annual Report and Accounts can be found in the Investors section of www.hsbc.com.

Interim dividend for 2020

The Directors have approved an interim dividend for 2020 of $0.15 per ordinary share. Information on the currencies in which 
shareholders may elect to have the cash dividend paid will be sent to shareholders on or about 24 March 2021. The interim dividend will 
be paid in cash with no scrip alternative, as it is dilutive. The timetable for the interim dividend is:

Announcement 

Shares quoted ex-dividend in London, Hong Kong and Bermuda and American Depositary Shares (‘ADS’) quoted ex-dividend 
in New York

Record date – London, Hong Kong, New York, Bermuda

Mailing of Annual Report and Accounts 2020 and/or Strategic Report 2020 and dividend documentation 

Final date for receipt by registrars of forms of election, Investor Centre electronic instructions and revocations of standing instructions 
for dividend elections

Exchange rate determined for payment of dividends in sterling and Hong Kong dollars
Payment date

1 Removals to and from the Overseas Branch register of shareholders in Hong Kong will not be permitted on this date.

Footnotes

1

23 February 2021

11 March 2021

12 March 2021

24 March 2021

15 April 2021

19 April 2021

29 April 2021

Interim dividends for 2021

In December 2020, the PRA announced that it intends to transition back to its standard approach to capital setting and shareholder 
distributions through 2021. In the meantime, for 2021 dividends the PRA is content for appropriately prudent dividends to be accrued but 
not paid out and the PRA aims to provide a further update ahead of the 2021 half-year results of large UK banks. As a result, the Group 
will not be paying quarterly dividends during 2021 but will consider whether to announce an interim dividend at the 2021 half-year results 
in August.

The Group will review whether to revert to paying quarterly dividends at or ahead of its 2021 results announcement in February 2022. 

The Board has adopted a policy designed to provide sustainable dividends going forward. We intend to transition towards a target payout 
ratio of between 40% and 55% of reported earnings per ordinary share (‘EPS’) for 2022 onwards, with the flexibility to adjust EPS for non-
cash significant items such as goodwill or intangibles impairments. The dividend policy could be supplemented by buy-backs or special 
dividends, over time and not in the near term, should the Group find itself in an excess capital position absent compelling investment 
opportunities to deploy that excess.

Dividends are declared in US dollars and, at the election of the shareholder, paid in cash in one of, or in a combination of, US dollars, 
pounds sterling and Hong Kong dollars. The Group has decided to discontinue the scrip dividend option as it is dilutive, including to 
dividend per share progression over time.

Other equity instruments

Additional tier 1 capital – contingent convertible securities

HSBC continues to issue contingent convertible securities that are included in its capital base as fully CRR II-compliant additional tier 1 
capital securities. For further details on these securities, please refer to Note 31 on the financial statements. 

In 2020, HSBC issued $1,500m 4.600% Perpetual Contingent Convertible Securities on 17 December 2020. 

2020 Annual General Meeting

All resolutions considered at the 2020 Annual General Meeting held at 11:00 am on 24 April 2020 at 8 Canada Square, London E14 5HQ, 
UK were passed on a poll.

HSBC Holdings plc Annual Report and Accounts 2020 371

Additional information 
 
Additional information

Earnings releases and interim results

First and third quarter results for 2021 will be released on 27 April 2021 and 25 October 2021 respectively. The interim results for the six 
months to 30 June 2021 will be issued on 2 August 2021.  

Shareholder enquiries and communications

Enquiries

Any enquiries relating to shareholdings on the share register (for example, transfers of shares, changes of name or address, lost share 
certificates or dividend cheques) should be sent to the Registrars at the address given below. The Registrars offer an online facility, 
Investor Centre, which enables shareholders to manage their shareholding electronically.

Principal Register:

Hong Kong Overseas Branch Register:

Bermuda Overseas Branch Register:

Computershare Investor Services PLC

Computershare Hong Kong Investor 

Investor Relations Team

The Pavilions

Bridgwater Road

Bristol BS99 6ZZ

United Kingdom

Services Limited

Rooms 1712-1716, 17th Floor

Hopewell Centre 

183 Queen’s Road East 

HSBC Bank Bermuda Limited

37 Front Street

Hamilton HM 11

Bermuda

Telephone: +44 (0) 370 702 0137

Hong Kong

Telephone: +1 441 299 6737

Email via website: 

Telephone: +852 2862 8555

Email: hbbm.shareholder.services@hsbc.bm

www.investorcentre.co.uk/contactus

Email: hsbc.ecom@computershare.com.hk

Investor Centre:

www.investorcentre.co.uk

Investor Centre:

www.investorcentre.com/hk

Investor Centre:

www.investorcentre.com/bm

Any enquiries relating to ADSs should be sent to the depositary:

The Bank of New York Mellon

Shareowner Services

PO Box 505000

Louisville, KY 40233-5000

USA

Telephone (US): +1 877 283 5786

Telephone (International): +1 201 680 6825

Email: shrrelations@cpushareownerservices.com

Website: www.mybnymdr.com

If you have elected to receive general shareholder communications directly from HSBC Holdings, it is important to remember that your 
main contact for all matters relating to your investment remains the registered shareholder, or custodian or broker, who administers the 
investment on your behalf. Therefore, any changes or queries relating to your personal details and holding (including any administration 
of it) must continue to be directed to your existing contact at your investment manager or custodian or broker. HSBC Holdings cannot 
guarantee dealing with matters directed to it in error.

Shareholders who wish to receive a hard copy of this Annual Report and Accounts 2020 should contact HSBC’s Registrars. Please visit 
www.hsbc.com/investors/investor-contacts for further information. You can also download an online version of the report from 
www.hsbc.com.

Electronic communications

Shareholders may at any time choose to receive corporate communications in printed form or to receive notifications of their availability 
on HSBC’s website. To receive notifications of the availability of a corporate communication on HSBC’s website by email, or revoke or 
amend an instruction to receive such notifications by email, go to www.hsbc.com/investors/shareholder-information/manage-your-
shareholding. If you provide an email address to receive electronic communications from HSBC, we will also send notifications of your 
dividend entitlements by email. If you received a notification of the availability of this document on HSBC’s website and would like to 
receive a printed copy, or if you would like to receive future corporate communications in printed form, please write or send an email 
(quoting your shareholder reference number) to the appropriate Registrars at the address given above. Printed copies will be provided 
without charge.

372 HSBC Holdings plc Annual Report and Accounts 2020

 
Chinese translation

A Chinese translation of this Annual Report and Accounts 2020 will be available upon request after 24 March 2021 from the Registrars:

Computershare Hong Kong Investor Services Limited

Computershare Investor Services PLC

Rooms 1712-1716, 17th Floor 

Hopewell Centre 

183 Queen’s Road East

Hong Kong

The Pavilions

Bridgwater Road

Bristol BS99 6ZZ

United Kingdom 

Please also contact the Registrars if you wish to receive Chinese translations of future documents, or if you have received a Chinese 
translation of this document and do not wish to receive them in future.

Stock symbols

HSBC Holdings ordinary shares trade under the following stock symbols:

London Stock Exchange

Hong Kong Stock Exchange

*HSBC’s Primary market

HSBC delisted from Euronext Paris on 22 December 2020

Investor relations

HSBA*

5

New York Stock Exchange (ADS)

Bermuda Stock Exchange

HSBC

HSBC.BH

Enquiries relating to HSBC’s strategy or operations may be directed to:

Richard O’Connor, Global Head of Investor Relations

Mark Phin, Head of Investor Relations, Asia-Pacific

HSBC Holdings plc

8 Canada Square

London E14 5HQ

United Kingdom

Telephone: +44 (0) 20 7991 6590

Email: investorrelations@hsbc.com

The Hongkong and Shanghai Banking

Corporation Limited

1 Queen’s Road Central

Hong Kong

Telephone: 852 2822 4908

Email: investorrelations@hsbc.com.hk

Where more information about HSBC is available

This Annual Report and Accounts 2020 and other information on HSBC may be downloaded from HSBC’s website: www.hsbc.com.
Reports, statements and information that HSBC Holdings files with the Securities and Exchange Commission are available at 
www.sec.gov. Investors can also request hard copies of these documents upon payment of a duplicating fee by writing to the SEC at the 
Office of Investor Education and Advocacy, 100 F Street N.E., Washington, DC 20549-0213 or by emailing PublicInfo@sec.gov. Investors 
should call the Commission at (1) 202 551 8090 if they require further assistance. Investors may also obtain the reports and other 
information that HSBC Holdings files at www.nyse.com (telephone number (1) 212 656 3000).

HM Treasury has transposed the requirements set out under CRD IV and issued the Capital Requirements Country-by-Country Reporting 
Regulations 2013. The legislation requires HSBC Holdings to publish additional information in respect of the year ended 31 December 
2020 by 31 December 2021. This information will be available on HSBC’s website: www.hsbc.com/tax.

HSBC Holdings plc Annual Report and Accounts 2020 373

Additional informationAdditional information

Taxation of shares and dividends

Taxation – UK residents

The following is a summary, under current law and the current 
published practice of HM Revenue and Customs (‘HMRC’), of 
certain UK tax considerations that are likely to be material to the 
ownership and disposition of HSBC Holdings ordinary shares. The 
summary does not purport to be a comprehensive description of 
all the tax considerations that may be relevant to a holder of 
shares. In particular, the summary deals with shareholders who 
are resident solely in the UK for UK tax purposes and only with 
holders who hold the shares as investments and who are the 
beneficial owners of the shares, and does not address the tax 
treatment of certain classes of holders such as dealers in 
securities. Holders and prospective purchasers should consult 
their own advisers regarding the tax consequences of an 
investment in shares in light of their particular circumstances, 
including the effect of any national, state or local laws.
Taxation of dividends

Currently, no tax is withheld from dividends paid by 
HSBC Holdings.
UK resident individuals

UK resident individuals are generally entitled to a tax-free annual 
allowance in respect of dividends received. The amount of the 
allowance for the tax year beginning 6 April 2020 is £2,000. To the 
extent that dividend income received by an individual in the 
relevant tax year does not exceed the allowance, a nil tax rate will 
apply. Dividend income in excess of this allowance will be taxed at 
7.5% for basic rate taxpayers, 32.5% for higher rate taxpayers and 
38.1% for additional rate taxpayers.
UK resident companies 

Shareholders that are within the charge to UK corporation 
tax should generally be entitled to an exemption from UK 
corporation tax on any dividends received from HSBC Holdings. 
However, the exemptions are not comprehensive and are subject 
to anti-avoidance rules.
If the conditions for exemption are not met or cease to be 
satisfied, or a shareholder within the charge to UK corporation tax 
elects for an otherwise exempt dividend to be taxable, the 
shareholder will be subject to UK corporation tax on dividends 
received from HSBC Holdings at the rate of corporation tax 
applicable to that shareholder.
Scrip dividends

HSBC Holdings plc did not pay any ordinary share dividends 
during 2020.   
Taxation of capital gains

The computation of the capital gains tax liability arising on 
disposals of shares in HSBC Holdings by shareholders subject to 
UK tax on capital gains can be complex, partly depending on 
whether, for example, the shares were purchased since April 1991, 
acquired in 1991 in exchange for shares in The Hongkong and 
Shanghai Banking Corporation Limited, or acquired subsequent to 
1991 in exchange for shares in other companies.
For capital gains tax purposes, the acquisition cost for ordinary 
shares is adjusted to take account of subsequent rights and 
capitalisation issues. Any capital gain arising on a disposal of 
shares in HSBC Holdings by a UK company may also be adjusted 
to take account of indexation allowance if the shares were 
acquired before 1 January 2018, although the level of indexation 
allowance that is given in calculating the gain would be frozen at 
the value that would apply to the disposal of assets acquired on or 
after 1 January 2018. If in doubt, shareholders are recommended 
to consult their professional advisers.
Stamp duty and stamp duty reserve tax

Transfers of shares by a written instrument of transfer generally 
will be subject to UK stamp duty at the rate of 0.5% of the 
consideration paid for the transfer (rounded up to the next £5), and 
such stamp duty is generally payable by the transferee. An 
agreement to transfer shares, or any interest therein, normally will 

374 HSBC Holdings plc Annual Report and Accounts 2020

give rise to a charge to stamp duty reserve tax at the rate of 0.5% 
of the consideration. However, provided an instrument of transfer 
of the shares is executed pursuant to the agreement and duly 
stamped before the date on which the stamp duty reserve tax 
becomes payable, under the current published practice of HMRC it 
will not be necessary to pay the stamp duty reserve tax, nor to 
apply for such tax to be cancelled. Stamp duty reserve tax is 
generally payable by the transferee.
Paperless transfers of shares within CREST, the UK’s paperless 
share transfer system, are liable to stamp duty reserve tax at the 
rate of 0.5% of the consideration. In CREST transactions, the tax is 
calculated and payment made automatically. Deposits of shares 
into CREST generally will not be subject to stamp duty reserve tax, 
unless the transfer into CREST is itself for consideration. Following 
the case HSBC pursued before the European Court of Justice 
(Case C-569/07 HSBC Holdings plc and Vidacos Nominees Ltd v 
The Commissioners for HM Revenue and Customs) and a 
subsequent case in relation to depositary receipts, HMRC 
accepted that the charge to stamp duty reserve tax at 1.5% on the 
issue of shares (and transfers integral to capital raising) to a 
depositary receipt issuer or a clearance service was incompatible 
with European Union law, and would not be imposed.
Following the UK’s departure from the European Union and the 
expiry of the transition period, the 1.5% stamp duty reserve tax 
charge on issues of shares to overseas clearance services and 
depositary receipt issuers is still disapplied, but no assurance can 
be given that legislation will not be amended in the future to 
reintroduce the charge.
Taxation – US residents

The following is a summary, under current law, of the principal UK 
tax and US federal income tax considerations that are likely to be 
material to the ownership and disposition of shares or American 
Depositary Shares (‘ADSs’) by a holder that is a US holder, as 
defined below, and who is not resident in the UK for UK tax 
purposes.
The summary does not purport to be a comprehensive description 
of all of the tax considerations that may be relevant to a holder of 
shares or ADSs. In particular, the summary deals only with US 
holders that hold shares or ADSs as capital assets, and does not 
address the tax treatment of holders that are subject to special tax 
rules. These include banks, tax-exempt entities, insurance 
companies, dealers in securities or currencies, persons that hold 
shares or ADSs as part of an integrated investment (including a 
‘straddle’ or ‘hedge’) comprised of a share or ADS and one or 
more other positions, and persons that own directly or indirectly 
10% or more (by vote or value) of the stock of HSBC Holdings. 
This discussion is based on laws, treaties, judicial decisions and 
regulatory interpretations in effect on the date hereof, all of which 
are subject to change.
For the purposes of this discussion, a ‘US holder’ is a beneficial 
holder that is a citizen or resident of the United States, a US 
domestic corporation or otherwise is subject to US federal income 
taxes on a net income basis in respect thereof.
Holders and prospective purchasers should consult their own 
advisers regarding the tax consequences of an investment in 
shares or ADSs in light of their particular circumstances, including 
the effect of any national, state or local laws.
Any US federal tax advice included in this Annual Report and 
Accounts 2020 is for informational purposes only. It was not 
intended or written to be used, and cannot be used, for the 
purpose of avoiding US federal tax penalties.
Taxation of dividends

Currently, no tax is withheld from dividends paid by HSBC 
Holdings. For US tax purposes, a US holder must include cash 
dividends paid on the shares or ADSs in ordinary income on the 
date that such holder or the ADS depositary receives them, 
translating dividends paid in UK pounds sterling into US dollars 
using the exchange rate in effect on the date of receipt. A US 
holder that elects to receive shares in lieu of a cash dividend must 
include in ordinary income the fair market value of such shares on 
the dividend payment date, and the tax basis of those shares will 
equal such fair market value.

Subject to certain exceptions for positions that are held for less 
than 61 days, and subject to a foreign corporation being 
considered a ‘qualified foreign corporation’ (which includes not 
being classified for US federal income tax purposes as a passive 
foreign investment company), certain dividends (‘qualified 
dividends’) received by an individual US holder generally will be 
subject to US taxation at preferential rates. Based on the 
company’s audited financial statements and relevant market and 
shareholder data, HSBC Holdings was not and does not anticipate 
being classified as a passive foreign investment company. 
Accordingly, dividends paid on the shares or ADSs generally 
should be treated as qualified dividends.

Taxation of capital gains

Gains realised by a US holder on the sale or other disposition of 
shares or ADSs normally will not be subject to UK taxation unless 
at the time of the sale or other disposition the holder carries on a 
trade, profession or vocation in the UK through a branch or agency 
or permanent establishment and the shares or ADSs are or have 
been used, held or acquired for the purposes of such trade, 
profession, vocation, branch or agency or permanent 
establishment. Such gains will be included in income for US tax 
purposes, and will be long-term capital gains if the shares or ADSs 
were held for more than one year. A long-term capital gain 
realised by an individual US holder generally will be subject to US 
tax at preferential rates.

Inheritance tax

Shares or ADSs held by an individual whose domicile is 
determined to be the US for the purposes of the United States –
United Kingdom Double Taxation Convention relating to estate 
and gift taxes (the ‘Estate Tax Treaty’) and who is not for such 
purposes a national of the UK will not, provided any US federal 
estate or gift tax chargeable has been paid, be subject to UK 
inheritance tax on the individual’s death or on a lifetime transfer of 
shares or ADSs except in certain cases where the shares or ADSs 
(i) are comprised in a settlement (unless, at the time of the 
settlement, the settlor was domiciled in the US and was not a 
national of the UK), (ii) are part of the business property of a UK 
permanent establishment of an enterprise, or (iii) pertain to a UK 
fixed base of an individual used for the performance of 
independent personal services. In such cases, the Estate Tax 
Treaty generally provides a credit against US federal tax liability for 
the amount of any tax paid in the UK in a case where the shares or 
ADSs are subject to both UK inheritance tax and to US federal 
estate or gift tax.

Stamp duty and stamp duty reserve tax – ADSs

If shares are transferred to a clearance service or American 
Depositary Receipt (‘ADR’) issuer (which will include a transfer of 
shares to the depositary) under the current published HMRC 
practice, UK stamp duty and/or stamp duty reserve tax will be 
payable. The stamp duty or stamp duty reserve tax is generally 
payable on the consideration for the transfer and is payable at the 
aggregate rate of 1.5%.

The amount of stamp duty reserve tax payable on such a transfer 
will be reduced by any stamp duty paid in connection with the 
same transfer.

No stamp duty will be payable on the transfer of, or agreement to 
transfer, an ADS, provided that the ADR and any separate 
instrument of transfer or written agreement to transfer remain at 
all times outside the UK, and provided further that any such 
transfer or written agreement to transfer is not executed in the UK. 
No stamp duty reserve tax will be payable on a transfer of, or 
agreement to transfer, an ADS effected by the transfer of an ADR.

US backup withholding tax and information reporting

Distributions made on shares or ADSs and proceeds from the sale 
of shares or ADSs that are paid within the US, or through certain 
financial intermediaries to US holders, are subject to information 
reporting and may be subject to a US ‘backup’ withholding tax. 
General exceptions to this rule happen when the US holder: 
establishes that it is a corporation (other than an S corporation) or 
other exempt holder; or provides a correct taxpayer identification 

number, certifies that no loss of exemption from backup 
withholding has occurred and otherwise complies with the 
applicable requirements of the backup withholding rules. Holders 
that are not US taxpayers generally are not subject to information 
reporting or backup withholding tax, but may be required to 
comply with applicable certification procedures to establish that 
they are not US taxpayers in order to avoid the application of such 
information reporting requirements or backup withholding tax to 
payments received within the US or through certain financial 
intermediaries.

Approach to ESG reporting

The information set out in the ESG review on pages 42 to 75, 
taken together with other information relating to ESG issues, aims 
to provide key ESG information and data relevant to our operations 
for the year ended 31 December 2020. In this context, we have 
also considered our obligations under the Environmental, Social 
and Governance Reporting Guide contained in Appendix 27 to The 
Rules Governing the Listing of Securities on the Stock Exchange of 
Hong Kong Limited (‘ESG Guide’). We comply with the ‘comply or 
explain’ provisions in the ESG Guide, save with respect to the 
following:

• A1(b) on emissions laws/regulations: we are fully compliant 
with our publication of information regarding scope 1 and 2 
carbon emissions, but we only partially publish information on 
scope 3 carbon emissions, as the data required for that 
publication is not yet fully available. Our progress on publishing 
information with respect to scope 3 is referenced on page 45;

• A1.3 on total hazardous waste produced, A1.6 on the handling 

of hazardous and non-hazardous waste, A2.2 on water 
consumption and A2.5 on packaging material: taking into 
account the nature of our business, we do not consider these to 
be material issues for our stakeholders; and

• A2.1 on direct energy consumption: taking into account the 

nature of our business, we do not consider this to be a material 
issue for our stakeholders. We report on what we consider to 
be our most relevant operational sustainability KPIs as set out 
on page 47. 

This is aligned with the materiality reporting principle that is set 
out in the ESG Guide. See ‘How we decide what to measure’ on 
page 43 for further information on how we determine what issues 
are material to our stakeholders. 

We will continue to develop and refine our reporting and 
disclosures on ESG issues in line with feedback received from our 
investors and other stakeholders, and in view of our obligations 
under the ESG Guide. 

Cautionary statement regarding forward-
looking statements

This Annual Report and Accounts 2020 contains certain forward-
looking statements with respect to HSBC’s financial condition; 
results of operations and business, including the strategic 
priorities; 2021 financial, investment and capital targets; and ESG 
targets/commitments described herein.

Statements that are not historical facts, including statements 
about HSBC’s beliefs and expectations, are forward-looking 
statements. Words such as ‘will’, ‘should’, ‘expects’, ‘targets’, 
‘anticipates’, ‘intends’, ‘plans’, ‘believes’, ‘seeks’, ‘estimates’, 
‘potential’ and ‘reasonably possible’, variations of these words and 
similar expressions are intended to identify forward-looking 
statements. These statements are based on current plans, 
information, data, estimates and projections, and therefore undue 
reliance should not be placed on them. Forward-looking 
statements speak only as of the date they are made. HSBC makes 
no commitment to revise or update any forward-looking 
statements to reflect events or circumstances occurring or existing 
after the date of any forward-looking statements.

Written and/or oral forward-looking statements may also be made 
in the periodic reports to the US Securities and Exchange 
Commission, summary financial statements to shareholders, proxy 

HSBC Holdings plc Annual Report and Accounts 2020 375

Additional informationAdditional information

statements, offering circulars and prospectuses, press releases 
and other written materials, and in oral statements made by 
HSBC’s Directors, officers or employees to third parties, including 
financial analysts. 

Forward-looking statements involve inherent risks and 
uncertainties. Readers are cautioned that a number of factors 
could cause actual results to differ, in some instances materially, 
from those anticipated or implied in any forward-looking 
statement. These include, but are not limited to:

•   changes in general economic conditions in the markets in 

which we operate, such as continuing or deepening recessions 
and fluctuations in employment and creditworthy customers 
beyond those factored into consensus forecasts (including, 
without limitation, as a result of the Covid-19 pandemic); the 
Covid-19 pandemic, which is expected to continue to have 
adverse impacts on our income due to lower lending and 
transaction volumes, lower wealth and insurance 
manufacturing revenue, and lower or negative interest rates in 
markets where we operate, as well as, more generally, the 
potential for material adverse impacts on our financial 
condition, results of operations, prospects, liquidity, capital 
position and credit ratings; deviations from the market and 
economic assumptions that form the basis for our ECL 
measurements (including, without limitation, as a result of the 
Covid-19 pandemic or the UK's exit from the EU); potential 
changes in dividend policy; changes in foreign exchange rates 
and interest rates, including the accounting impact resulting 
from financial reporting in respect of hyperinflationary 
economies; volatility in equity markets; lack of liquidity in 
wholesale funding or capital markets, which may affect our 
ability to meet our obligations under financing facilities or to 
fund new loans, investments and businesses; geopolitical 
tensions or diplomatic developments producing social 
instability or legal uncertainty, such as the unrest in Hong 
Kong, the continuing US-China tensions and the emerging 
challenges in UK-China relations, which in turn may affect 
demand for our products and services and could result in 
(among other things) regulatory, reputational and market risks 
for HSBC; the efficacy of government, customer, and HSBC's 
actions in managing and mitigating climate change and in 
supporting the global transition to net zero carbon emissions, 
which may cause both idiosyncratic and systemic risks 
resulting in potential financial and non-financial impacts; 
illiquidity and downward price pressure in national real estate 
markets; adverse changes in central banks’ policies with 
respect to the provision of liquidity support to financial 
markets; heightened market concerns over sovereign 
creditworthiness in over-indebted countries; adverse changes 
in the funding status of public or private defined benefit 
pensions; societal shifts in customer financing and investment 
needs, including consumer perception as to the continuing 
availability of credit; exposure to counterparty risk, including 
third parties using us as a conduit for illegal activities without 
our knowledge; the expected discontinuation of certain key 
Ibors and the development of near risk-free benchmark rates, 
which may require us to enhance our capital position and/or 
position additional capital in specific subsidiaries; and price 
competition in the market segments we serve;

•   changes in government policy and regulation, including the 

monetary, interest rate and other policies of central banks and 
other regulatory authorities in the principal markets in which 
we operate and the consequences thereof (including, without 
limitation, actions taken as a result of the Covid-19 pandemic); 
initiatives to change the size, scope of activities and 
interconnectedness of financial institutions in connection with 
the implementation of stricter regulation of financial institutions 
in key markets worldwide; revised capital and liquidity 
benchmarks, which could serve to deleverage bank balance 
sheets and lower returns available from the current business 
model and portfolio mix; imposition of levies or taxes designed 
to change business mix and risk appetite; the practices, pricing 
or responsibilities of financial institutions serving their 
consumer markets; expropriation, nationalisation, confiscation 

376 HSBC Holdings plc Annual Report and Accounts 2020

of assets and changes in legislation relating to foreign 
ownership; the UK’s exit from the EU, which may result in a 
prolonged period of uncertainty, unstable economic conditions 
and market volatility, including currency fluctuations; passage 
of the Hong Kong national security law and restrictions on 
telecommunications, as well as the US Hong Kong Autonomy 
Act, which have caused tensions between China, the US and 
the UK; general changes in government policy that may 
significantly influence investor decisions; the costs, effects and 
outcomes of regulatory reviews, actions or litigation, including 
any additional compliance requirements; and the effects of 
competition in the markets where we operate including 
increased competition from non-bank financial services 
companies; and

•   factors specific to HSBC, including our success in adequately 
identifying the risks we face, such as the incidence of loan 
losses or delinquency, and managing those risks (through 
account management, hedging and other techniques); our 
ability to achieve our financial, investment, capital and ESG 
targets/commitments, which may result in our failure to 
achieve any of the expected benefits of our strategic priorities; 
model limitations or failure, including, without limitation, the 
impact that the consequences of the Covid-19 pandemic have 
had on the performance and usage of financial models, which 
may require us to hold additional capital, incur losses and/or 
use compensating controls, such as overlays and overrides, to 
address model limitations; changes to the judgements, 
estimates and assumptions we base our financial statements 
on; changes in our ability to meet the requirements of 
regulatory stress tests; a reduction in the credit ratings 
assigned to us or any of our subsidiaries, which could increase 
the cost or decrease the availability of our funding and affect 
our liquidity position and net interest margin; changes to the 
reliability and security of our data management, data privacy, 
information and technology infrastructure, including threats 
from cyber-attacks, which may impact our ability to service 
clients and may result in financial loss, business disruption and/
or loss of customer services and data; changes in insurance 
customer behaviour and insurance claim rates; our dependence 
on loan payments and dividends from subsidiaries to meet our 
obligations; changes in accounting standards, which may have 
a material impact on the way we prepare our financial 
statements; changes in our ability to manage third-party, fraud 
and reputational risks inherent in our operations; employee 
misconduct, which may result in regulatory sanctions and/or 
reputational or financial harm; changes in skill requirements, 
ways of working and talent shortages, which may affect our 
ability to recruit and retain senior management and diverse and 
skilled personnel; and changes in our ability to develop 
sustainable finance products and our capacity to measure the 
climate impact from our financing activity, which may affect 
our ability to achieve our climate ambition. Effective risk 
management depends on, among other things, our ability 
through stress testing and other techniques to prepare for 
events that cannot be captured by the statistical models it uses; 
and our success in addressing operational, legal and regulatory, 
and litigation challenges; and other risks and uncertainties we 
identify in ‘Top and emerging risks’ on pages 110 to 116.

Certain defined terms

Unless the context requires otherwise, ‘HSBC Holdings’ means 
HSBC Holdings plc and ‘HSBC’, the ‘Group’, ‘we’, ‘us’ and ‘our’ 
refer to HSBC Holdings together with its subsidiaries. Within this 
document the Hong Kong Special Administrative Region of the 
People’s Republic of China is referred to as ‘Hong Kong’. When 
used in the terms ‘shareholders’ equity’ and ‘total shareholders’ 
equity’, ‘shareholders’ means holders of HSBC Holdings ordinary 
shares and those preference shares and capital securities issued 
by HSBC Holdings classified as equity. The abbreviations ‘$m’, 
‘$bn’ and ‘$tn’ represent millions, billions (thousands of millions) 
and trillions of US dollars, respectively.

 
Abbreviations

Currencies

£

CA$

€

HK$

MXN

RMB

SGD

$

A

ABS¹

ADR

ADS

AGM

AI

AIEA

ALCM

ALCO

AML

British pound sterling

Canadian dollar

Euro

Hong Kong dollar

Mexican peso

Chinese renminbi

Singapore dollar

United States dollar

Asset-backed security

American Depositary Receipt

American Depositary Share

Annual General Meeting

Artificial intelligence

Average interest-earning assets

Asset, Liability and Capital Management

Asset and Liability Management Committee

Anti-money laundering

AML DPA

Five-year deferred prosecution agreement with the US 
Department of Justice, entered into in December 2012

ARCC

AT1

B

Audit and Risk Committee Chairs’ Forum

Additional tier 1

Basel Committee Basel Committee on Banking Supervision

Basel II¹

Basel III¹

BoCom

BoE

Bps¹

BVI

C

CAPM

CDS¹

CEA

CET1¹

CGUs

CMB

CMC

CODM

COSO

CP¹

CRD IV¹

CRR¹

CRR II¹

CSA

CVA¹

D

2006 Basel Capital Accord

Basel Committee’s reforms to strengthen global capital and 
liquidity rules

Bank of Communications Co., Limited, one of China’s largest 
banks

Bank of England

Basis points. One basis point is equal to one-hundredth of a 
percentage point

British Virgin Islands

Capital asset pricing model

Credit default swap

Commodity Exchange Act (US)

Common equity tier 1

Cash-generating units

Commercial Banking, a global business

Capital maintenance charge

Chief Operating Decision Maker

2013 Committee of the Sponsors of the Treadway 
Commission (US)

Commercial paper

Customer risk rating

Revised Capital Requirements Regulation and Directive, as 
implemented

Credit support annex

Credit valuation adjustment

Deferred Shares Awards of deferred shares define the number of HSBC 

Holdings ordinary shares to which the employee will become 
entitled, generally between one and seven years from the 
date of the award, and normally subject to the individual 
remaining in employment

Dodd-Frank

Dodd-Frank Wall Street Reform and Consumer Protection Act 
(US)

DoJ
DPD

DPF

DVA¹

E

EAD¹

EBA

EC

US Department of Justice
Days past due

Discretionary participation feature of insurance and 
investment contracts

Debt valuation adjustment

Exposure at default

European Banking Authority

European Commission

ECB

ECL

EEA

Eonia

EPS

ESG

€STR

EU

Euribor

EVE

F

European Central Bank

Expected credit losses. In the income statement, ECL is 
recorded as a change in expected credit losses and other 
credit impairment charges. In the balance sheet, ECL is 
recorded as an allowance for financial instruments to which 
only the impairment requirements in IFRS 9 are applied

European Economic Area

Euro Overnight Index Average

Earnings per ordinary share

Environmental, social and governance

Euro short-term rate

European Union

Euro interbank offered rate

Economic value of equity

FAST-Infra

Finance to Accelerate the Sustainable Transition-
Infrastructure

FCA

FFVA

FPA

FRB

FRC

FSB

FSCS

FTE

FTSE

FVOCI¹

FVPL¹

FX DPA

G

GAAP

GAC

GBM

GDP

GDPR

GEC

GLCM

Financial Conduct Authority (UK)

Funding fair value adjustment estimation methodology on 
derivative contracts

Fixed pay allowance

Federal Reserve Board (US)

Financial Reporting Council

Financial Stability Board

Financial Services Compensation Scheme

Full-time equivalent staff

Financial Times Stock Exchange index

Fair value through other comprehensive income

Fair value through profit or loss

Three-year deferred prosecution agreement with the US 
Department of Justice, entered into in January 2018

Generally accepted accounting principles

Group Audit Committee

Global Banking and Markets, a global business

Gross domestic product

General Data Protection Regulation

Group Executive Committee

Global Liquidity and Cash Management

Global Markets

HSBC’s capital markets services in Global Banking and 
Markets

GMP

GPSP

GRC

Group

GTRF

H

Guaranteed minimum pension

Group Performance Share Plan

Group Risk Committee

HSBC Holdings together with its subsidiary undertakings

Global Trade and Receivables Finance

HKEx

HKMA

HMRC

HNAH

The Stock Exchange of Hong Kong Limited

Hong Kong Monetary Authority

HM Revenue and Customs

HSBC North America Holdings Inc.

Holdings ALCO

HSBC Holdings Asset and Liability Management Committee

Hong Kong

Hong Kong Special Administrative Region of the People’s 
Republic of China

HQLA

HSBC

High-quality liquid assets

HSBC Holdings together with its subsidiary undertakings

HSBC Bank

HSBC Bank plc, also known as the non-ring-fenced bank

HSBC Bank Middle East Limited

HSBC Bank 
Middle East
HSBC Bank USA HSBC Bank USA, N.A., HSBC’s retail bank in the US
HSBC Canada

The sub-group, HSBC Bank Canada, HSBC Trust Company 
Canada, HSBC Mortgage Corporation Canada and HSBC 
Securities Canada, consolidated for liquidity purposes

HSBC 
Continental 
Europe

HSBC Finance

HSBC Continental Europe

HSBC Finance Corporation, the US consumer finance 
company (formerly Household International, Inc.)

HSBC Holdings

HSBC Holdings plc, the parent company of HSBC

HSBC Holdings plc Annual Report and Accounts 2020 377

Capital Requirements Regulation and Directive

Hang Seng Bank Hang Seng Bank Limited, one of Hong Kong’s largest banks

Additional informationAdditional information

HSBC Private 
Bank (Suisse)

HSBC Private Bank (Suisse) SA, HSBC’s private bank in 
Switzerland

Repo¹

Sale and repurchase transaction

Reverse repo

Security purchased under commitments to sell

RFB

RFR

RMBS

RMM

RNIV

RoE

RoTE

RWA¹

S

SABB

SAPS

SDG

SE¹

SEC

Ring-fenced bank

Risk-free rate

Residential mortgage backed security

Group Risk Management Meeting

Risk not in VaR

Return on average ordinary shareholders’ equity

Return on average tangible equity

Risk-weighted asset

The Saudi British Bank

Self-administered pension scheme

United Nation’s Sustainable Development Goals

Structured entity

Securities and Exchange Commission (US)

ServCo group

Separately incorporated group of service companies planned 
in response to UK ring-fencing proposals

Sibor

SIC

SID

SME

SOFR

Solitaire

Sonia

SPE¹

T

T1

T2

TCFD¹

TLAC¹

TRLibor

TSR¹

U

UAE

UK

UN

US

V

VaR¹

VIU

W

WPB

Singapore interbank offered rate

Securities investment conduit

Senior Independent Director

Small and medium-sized enterprise

Secured Overnight Financing Rate

Solitaire Funding Limited, a special purpose entity managed 
by HSBC

Sterling Overnight Index Average

Special purpose entity

Tier 1

Tier 2

Task Force on Climate-related Financial Disclosures

Total loss-absorbing capacity

Turkish Lira interbank offered rate

Total shareholder return

United Arab Emirates

United Kingdom

United Nations

United States of America

Value at risk

Value in use

Wealth and Personal Banking, a global business

1  A full definition is included in the glossary to the Annual Report and 
Accounts 2020 which is available at www.hsbc.com/investors.

HSBC UK

HSBC USA

HSI

HSSL

HTIE

I

IAS

IASB

IBA

Ibor

ICAAP

IFRSs

ILAAP

IRB¹

ISDA

K

KMP

L

LCR

LFRF

LGBT+

LGD¹

Libor

LTI

LTV¹

M

HSBC UK Bank plc, also known as the ring-fenced bank

The sub-group, HSBC USA Inc (the holding company of 
HSBC Bank USA) and HSBC Bank USA, consolidated for 
liquidity purposes

HSBC Securities (USA) Inc.

HSBC Securities Services (Luxembourg)

HSBC International Trust Services (Ireland) Limited

International Accounting Standards

International Accounting Standards Board

ICE Benchmark Administration

Interbank offered rate

Internal capital adequacy assessment process

International Financial Reporting Standards

Internal liquidity adequacy assessment process

Internal ratings-based

International Swaps and Derivatives Association

Key Management Personnel

Liquidity coverage ratio

Liquidity and funding risk management framework

Lesbian, gay, bisexual and transgender. The plus sign 
denotes other non-mainstream groups on the spectrums of 
sexual orientation and gender identity

Loss given default

London interbank offered rate

Long-term incentive

Loan-to-value ratio

Mainland China

People’s Republic of China excluding Hong Kong and Macau

MENA

MREL

MRT¹

N

Net operating 
income

NII

NIM

NSFR

NYSE

O

OCI

OECD

OFAC

OTC¹

P

PACTA

PBT

PD¹

Performance 
shares¹

Ping An

POCI

PPI

PRA

PRC

Middle East and North Africa

Minimum requirement for own funds and eligible liabilities

Material Risk Taker

Net operating income before change in expected credit 
losses and other credit impairment charges/Loan impairment 
charges and other credit provisions, also referred to as 
revenue

Net interest income

Net interest margin

Net stable funding ratio

New York Stock Exchange

Other comprehensive income

Organisation of Economic Co-operation and Development

Office of Foreign Assets Control

Over-the-counter

Paris Agreement Capital Transition Assessment

Profit before tax

Probability of default

Awards of HSBC Holdings ordinary shares under employee 
share plans that are subject to corporate performance 
conditions

Ping An Insurance (Group) Company of China, Ltd, the 
second-largest life insurer in the PRC

Purchased or originated credit-impaired financial assets

Payment protection insurance

Prudential Regulation Authority (UK)

People’s Republic of China

Principal plan

HSBC Bank (UK) Pension Scheme

PVIF

PwC

R

RAS

Present value of in-force long-term insurance business and 
long-term investment contracts with DPF

The member firms of the PwC network, including 
PricewaterhouseCoopers LLP

Risk appetite statement

378 HSBC Holdings plc Annual Report and Accounts 2020

HSBC Holdings plc
Incorporated in England on 1 January 1959 with  
limited liability under the UK Companies Act  
Registered in England: number 617987

Registered Office and Group Head Office
8 Canada Square  
London E14 5HQ 
United Kingdom

Telephone: 44 020 7991 8888  
Facsimile: 44 020 7992 4880  
Web: www.hsbc.com

Registrars
Principal Register
Computershare Investor Services PLC  
The Pavilions 
Bridgwater Road 
Bristol BS99 6ZZ 
United Kingdom

Telephone: 44 0370 702 0137 
Email: via website 
Web: www.investorcentre.co.uk/contactus

Hong Kong Overseas Branch Register
Computershare Hong Kong Investor Services Limited 
Rooms 1712-1716, 17th floor 
Hopewell Centre 
183 Queen’s Road East 
Hong Kong

Telephone: 852 2862 8555 
Email: hsbc.ecom@computershare.com.hk 
Web: www.investorcentre.com/hk

Bermuda Overseas Branch Register
Investor Relations Team 
HSBC Bank Bermuda Limited 
37 Front Street 
Hamilton HM11 
Bermuda

Telephone: 1 441 299 6737 
Email: hbbm.shareholder.services@hsbc.bm 
Web: www.investorcentre.com/bm 

ADR Depositary

The Bank of New York Mellon  
Shareowner Services 
PO Box 505000 
Louisville, KY 40233-5000 
USA

Telephone (US): 1 877 283 5786 
Telephone (International): 1 201 680 6825 
Email: shrrelations@cpushareownerservices.com 
Web: www.mybnymdr.com

Corporate Brokers
Morgan Stanley & Co. International plc 
25 Cabot Square 
London E14 4QA 
United Kingdom

Bank of America Securities 
2 King Edward Street 
London EC1A 1HQ 
United Kingdom

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

© Copyright HSBC Holdings plc 2021

All rights reserved 

No part of this publication may be reproduced, stored in a retrieval 
system, or transmitted, in any form or by any means, electronic, 
mechanical, photocopying, recording, or otherwise, without the prior 
written permission of HSBC Holdings plc

Published by Global Finance, HSBC Holdings plc, London 

Designed by Superunion, London (Strategic Report  
and ESG review) and by Global Finance with Superunion  
(rest of Annual Report and Accounts)

Printed by Park Communications Limited, London, on Nautilus 
SuperWhite board and paper using vegetable oil-based inks.  
Made in Austria, the stocks comprise 100% de-inked  
post-consumer waste. Pulps used are totally chlorine-free. 

The FSC® recycled logo identifies a paper which contains  
100% post-consumer recycled fibre certified in accordance  
with the rules of the Forest Stewardship Council®.

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HSBC Holdings plc

8 Canada Square
London E14 5HQ
United Kingdom
Telephone: +44 (0)20 7991 8888
www.hsbc.com
Incorporated in England with limited liability
Registered number 617987