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HSBC

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FY2021 Annual Report · HSBC
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HSBC Holdings plc
Annual Report and  
Accounts 2021

Contents

Strategic report

Highlights

Group Chairman’s statement 
Group Chief Executive’s review

2 
4  Who we are
6 
8 
12  Our strategy
15  How we do business
21  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 ('ESG') review

43  Our approach to ESG
45  Environmental
66  Social
79  Governance

Financial review

90 
Financial summary
98  Global businesses and 

geographical regions
117  Reconciliation of alternative 
performance measures

Risk review

121  Our approach to risk
124  Top and emerging risks
131  Areas of special interest
135  Our material banking risks

Corporate governance report

218  Group Chairman’s governance statement
220  Biographies of Directors and 

senior management

237  Board committees
254  Directors’ remuneration report

Financial statements

298  Independent auditors’ report
308  Financial statements
318  Notes on the financial statements

Additional information

397  Shareholder information
405  Abbreviations

HSBC Holdings plc Annual Report and Accounts 2021

We have changed how we provide the 
disclosures against the Task Force on 
Climate-related Disclosures (‘TCFD’) 
framework by embedding the content 
previously provided in our stand-alone  
TCFD Update within this Annual Report and 
Accounts 2021. The summary TCFD disclosure 
can be found on page 19.

This Strategic Report was approved by the 
Board on 22 February 2022. 

Mark E Tucker 
Group Chairman

A reminder 
The currency we report in is US dollars. 

Adjusted measures 
We supplement our IFRSs figures with 
non-IFRSs 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 2021 for the year ended 
31 December 2021 (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 2021

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. 

Our purpose, ambition and values reflect our strategy and support our focus on execution.

Read more on our values, strategy and purpose on pages 4, 12 and 15.

Key themes of 2021

The Group continued to make progress on our strategic aims, although challenges remain:

Financial performance

Strategic transformation

Climate ambition

Performance reflected an improvement in 
global economic conditions, which resulted  
in releases of expected credit loss allowances, 
the impact of lower interest rates, and 
continued cost discipline. All of our regions 
were profitable, and our Asia operations 
continued to perform strongly. The outlook  
for net interest income is now significantly 
more positive.

We have made progress in areas of strength 
and expanded our digital capabilities across 
key products. During the year, we announced  
a number of strategic transactions including 
the planned sale of our retail banking business 
in France and our exit of mass market retail in 
the US. We also announced acquisitions in 
Singapore and India to develop our wealth 
capabilities across Asia.

Read more on pages 2 and 26. 

Read more on page 12. 

We are helping to mobilise the transition to a 
net zero global economy. Since 2020, we have 
supported our customers’ transition to net zero 
and a sustainable future by providing and 
facilitating sustainable finance and investment. 
We have published our thermal coal phase-out 
policy and have set targets to reduce our 
on-balance sheet financed emissions of two 
priority sectors: oil and gas, and power and 
utilities by 2030.

Read more on page 18.

Delivery against our financial targets

Return on average tangible equity

8.3%

Gross RWA reduction

$104bn

Target: ≥10% over the medium term.
(2020: 3.1%)

Since the start of the programme.  
Updated target: >$110bn by end of 2022.

Adjusted operating expenses

Common equity tier 1 capital ratio

$32.1bn

15.8%

Updated target: 2022 adjusted operating 
expenses in line with 2021. Previous target: 
≤$31bn in 2022 (at December 2020 foreign 
exchange rates). (2020: $32.4bn)

Target: >14%, managing in the range of  
14% to 14.5% in the medium term; and 
manage the range down further long term.
(2020: 15.9%)

Dividend per share

$0.25

2021 payout ratio: 40.3%
Target: sustainable cash dividends  
with a payout ratio of 40% to 55%  
from 2022 onwards.

For our financial targets, we define medium  
term as three to four years and long term as  
five to six years, commencing 1 January 2020. 

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

ESG performance indicators and targets 

Gender diversity

31.7%

Sustainable finance and investment

Net zero in our own operations

$126.7bn

50.3%

Women in senior leadership roles.
(2020: 30.3%)

Cumulative total provided and facilitated 
since January 2020. (2020: $44.1bn)

Cumulative reduction in absolute greenhouse 
gas emissions from 2019 baseline

Customer satisfaction

6 out of 10

Customer satisfaction

4 out of 13

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

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

 Read more on how we set and define our environmental, social and governance metrics on page 17.
 Read more on our financed emissions scope, methodology and terminology on page 47 and our 
definition of sustainable finance and investment on page 53.

Financed emissions targets by 2030

34%  

Mt CO2e reduction in 
oil and gas absolute  
on-balance sheet 
financed emissions

0.14

Mt CO2e/TWh  
power and utilities 
on-balance sheet 
financed emissions 
intensity, representing 
75% reduction  
from 2019

HSBC Holdings plc Annual Report and Accounts 2021

1

Strategic report 
 
Strategic report

Highlights

Financial performance reflected improved global economic conditions, and we continued 
to make progress against our four strategic pillars.

Financial performance (vs 2020)

 – Reported profit after tax up $8.6bn to 
$14.7bn and reported profit before tax 
up $10.1bn to $18.9bn. The increase was 
driven by a net release of expected credit 
losses and other credit impairment charges 
(‘ECL’) and a higher share of profit from our 
associates. Adjusted profit before tax 
up 79% to $21.9bn.

 – All regions were profitable in 2021, 
notably HSBC UK Bank plc, where 
reported profit before tax increased by 
$4.5bn to $4.8bn. Our Asia operations 
contributed $12.2bn to reported profit before 
tax and all other regions reported a material 
recovery in profitability, reflecting favourable 
ECL movements.

 – Reported revenue down 2% to $49.6bn, 
primarily reflecting the impact of lower global 
interest rates and a decrease in revenue in 
Markets and Securities Services (‘MSS’) 
compared with a strong comparative period. 
Notwithstanding these factors, we saw 
revenue growth in areas of strategic focus, 
including Wealth, in part due to favourable 
market impacts in life insurance 

manufacturing, and Global Trade and 
Receivables Finance (‘GTRF’). Adjusted 
revenue down 3% to $50.1bn.

 – Net interest margin (‘NIM’) of 1.20%, 

down 12 basis points (‘bps’) from 2020, 
with stabilisation in the second half of 2021. 

 – Reported ECL were a net release of 
$0.9bn, compared with an $8.8bn 
charge in 2020, reflecting an improvement 
in economic conditions relative to 2020, and 
better than expected levels of credit 
performance. In the fourth quarter of 2021, 
we recognised a net ECL charge of $450m, 
which included an increase in allowances to 
reflect recent developments in China’s 
commercial real estate sector.

 – Reported operating expenses broadly 

unchanged at $34.6bn. Adjusted 
operating expenses down 1% to $32.1bn, 
despite inflationary pressures, as the impact 
of our cost-saving initiatives and a reduction 
in the UK bank levy charge absorbed higher 
performance-related pay and continued 
growth in technology investment.

 – Customer lending balances in 2021 

up $8bn on a reported basis and $23bn 
on a constant currency basis, primarily 
driven by growth in mortgage balances, 
mainly in the UK and Hong Kong.

 – Common equity tier 1 (‘CET1’) capital 
ratio of 15.8%, down 0.1 percentage 
points. Capital generation was more than 
offset by dividends, the up to $2bn share  
buy-back announced in October, foreign 
exchange movements and other deductions. 
Risk-weighted assets (‘RWAs’) reduced 
despite new Pillar 1 requirements for 
structural foreign exchange, reflecting 
actions under our transformation 
programme.

 – The Board has approved a second 

interim dividend of $0.18 per share, 
making a total for 2021 of $0.25 per 
share. We also intend to initiate a further 
share buy-back of up to $1bn, to commence 
after the existing up to $2bn buy-back 
has concluded.

Strategic progress

 – In our wealth business in Asia, we 

attracted net new invested assets of 
$36bn in 2021. We also announced 
acquisitions in Singapore and India to 
develop our wealth capabilities across 
the region.

 – Our cost-reduction programme continues 
to progress with $2.2bn of cost savings 
recognised in 2021. Since the start of the 
programme in 2020, we have delivered 
savings of $3.3bn, with costs to 
achieve of $3.6bn.

Outlook

 – In line with our climate change resolution, 
we published our thermal coal phase-
out policy and have set on-balance sheet 
financed emission targets for our oil and 
gas, and power and utilities sectors.

 – In 2021, we continued to support our 

customers in the transition to net zero and a 
sustainable future. Since 1 January 2020, 
we have provided and facilitated 
$126.7bn towards our ambition of 
$750bn to $1tn by 2030.

 – We continued the transformation of our 
US business and HSBC Bank plc, our UK 
non-ring-fenced bank and Europe, reducing 
costs and RWAs. Furthermore, we 
announced the exit of mass market 
retail in the US, and the planned sale of 
our retail operations in France. During 
2022, we expect to recognise a pre-tax loss, 
excluding transaction costs, of around 
$2.7bn upon the classification of our France 
retail operations as ‘held for sale’.

We carry good business momentum into 2022 
in most areas and expect mid-single-digit 
lending growth over the year. However, we 
expect a weaker Wealth performance in Asia 
in the first quarter of 2022.

We expect ECL charges to normalise towards 
30bps of average loans in 2022, based on 
current consensus economic forecasts and 
default experience, noting we retain $0.6bn 
of Covid-19-related allowances as at the end 
of 2021. Uncertainty remains given recent 
developments in China’s commercial real 
estate sector, while inflationary pressures 
persist in many of our markets.

We continue to target 2022 adjusted operating 
expenses in line with 2021, despite inflationary 
pressures, with cost to achieve spend of 
$3.4bn expected to generate over $2bn of cost 
savings in 2022. In 2023, we intend to manage 
growth in adjusted operating expenses to 
within a range of 0% to 2%, compared with 
2022 (on an IFRS 4 basis), with cost savings 
of at least $0.5bn from actions taken in 2022 
helping to offset inflation.

We expect mid-single-digit RWA growth in 
2022 through a combination of business 
growth, acquisitions and regulatory changes, 
partly offset by additional RWA savings. This 

growth, together with capital returns are 
expected to normalise our CET1 position to 
be within our 14% to 14.5% target operating 
range during 2022.

Our net interest income outlook is now 
significantly more positive. If policy rates were 
to follow the current implied market 
consensus, we would expect to deliver a RoTE 
of at least 10% for 2023, one year ahead of our 
previous expectations.

We continue to target dividends within our 
40% to 55% dividend payout ratio range.

2

HSBC Holdings plc Annual Report and Accounts 2021

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 (%)

Net interest margin (%)

Basic earnings per share ($)

Diluted earnings per share ($)

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

Dividend payout ratio (%)1

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 (%)2

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 ($)

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

For the year ended

2021

49,552

18,906

14,693

12,607

69.9

1.20

0.62

0.62

0.25

40.3  

50,090

21,916

64.2

(0.09)

7.1

8.3

2020

 50,429 

 8,777 

 6,099 

 3,898 

 68.3 

 1.32 

 0.19 

 0.19 

 0.15 

78.9

 51,770 

 12,271 

 62.6 

 0.87 

 2.3 

 3.1 

2019

 56,098 

 13,347 

 8,708 

 5,969 

 75.5 

 1.58 

 0.30 

 0.30 

 0.30 

100.0

 56,435 

 22,681 

 59.5 

 0.26 

 3.6 

 8.4 

At 31 December

2021

2,957,939

1,045,814

2020

2019

 2,984,164 

 2,715,152 

 1,037,987 

 1,036,743 

1,710,574

 1,642,780 

 1,439,115 

2,209,513

 2,092,900 

 1,922,822 

61.1

198,250

158,193

8.76

7.88

 63.2 

 196,443 

 156,423 

 8.62 

 7.75 

 72.0 

 183,955 

 144,144 

 8.00 

 7.13 

15.8

 15.9 

 14.7 

838,263

 857,520 

 843,395 

21.2

5.2

717

138

 21.5 

 5.5 

 678 

 139 

 20.4 

 5.3 

 601 

 150 

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)

 20,073 

 20,189 

 20,184 

 20,272 

 20,206 

 20,280 

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

20,197

 20,169 

 20,158 

For reconciliations of our reported results to an adjusted basis, including lists of significant items, see page 98. Definitions and calculations of other alternative 
performance measures are included in our ‘Reconciliation of alternative performance measures’ on page 117.
1 Dividend per ordinary share, in respect of the period, expressed as a percentage of basic earning per share.
2  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).

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 195. Leverage ratios 
are calculated using the end point definition of capital and the IFRS 9 regulatory transitional arrangements. References to EU regulations and directives (including 
technical standards) should, as applicable, be read as references to the UK’s version of such regulation and/or directive, as onshored into UK law under the 
European Union (Withdrawal) Act 2018, and as may be subsequently amended under UK law.

HSBC Holdings plc Annual Report and Accounts 2021

3

Strategic reportStrategic report

Who we are

About HSBC 

With assets of $3.0tn and operations in 64 countries and territories at 31 December 2021, HSBC is one of the largest banking and financial services 
organisations in the world. Approximately 40 million customers bank with us and we employ around 220,000 full-time equivalent staff. We have 
around 187,000 shareholders in 128 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 15.

Our global businesses 

We serve our customers through three global 
businesses. On pages 30 to 36 we provide  
an overview of our performance in 2021 for 
each of our global businesses, as well as our 
Corporate Centre. In each of our global 
businesses, we focus on delivering growth in 
areas where we have distinctive capabilities 
and have significant opportunities.

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. 

Adjusted revenue by global business1

 For further information on how we are 
governed, see our corporate governance 
report on page 217. 

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 $437m in 2021.

WPB 43%
CMB 27%
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. The global functions include Corporate 
Governance and Secretariat, Communications and Brand, Finance, Human Resources, Internal Audit, Legal, Risk and Compliance, Sustainability 
and Strategy. Digital Business Services provides real estate, procurement, technology and operational services to the business.

4

HSBC Holdings plc Annual Report and Accounts 2021

Who we are

Our global reach

Multi-award winning

We aim to create long-term value for our shareholders and capture opportunity. One of our goals 
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

10%

UK
31%

Rest of Europe

Mainland China

8%

3%

Euromoney Awards for Excellence 2021
 – Best Bank for Sustainable Finance in Asia 
 – Best Bank for Sustainable Finance in the 

Middle East

 – Best Bank for Transaction Services in Asia
 – Best Bank for Transaction Services in the 

Middle East 

 – Western Europe’s Best Bank for SMEs

Euromoney Trade Finance Survey 2021
 – Number 1 Trade Finance Bank in the UK

The Banker, Transaction Banking Awards 2021
 – Transaction Bank of the Year for Asia-Pacific
 – Transaction Bank of the Year for Middle East

Asiamoney Global RMB Poll 2021
 – Best overall bank for global, onshore and 

offshore RMB products and services 

Asian Private Banker Awards for Distinction 
2021
 – Best Private Bank – Asia Pacific
 – Best Private Bank – Wealth Continuum

Payments Awards 2021 
 – B2B Payments Innovation of the Year

Latin America

2%

Middle East  and North Africa 

2%

Rest of Asia

Hong Kong

11% 33%

 See page 97 for further information on our customers and approach to geographical information.

Engaging with our stakeholders 

Customers

Employees

Investors

Communities

Regulators and 
governments

Suppliers

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 21.

HSBC Holdings plc Annual Report and Accounts 2021

5

Strategic report 
 
 
 
Strategic report

Group Chairman’s statement

The progress we made in 2021 means that HSBC is well 
placed to open up a world of opportunity for our customers 
as economic recovery continues.

investors all continued along their ESG 
journeys in 2021, as public awareness  
grew and activism around climate change  
in particular increased. HSBC has long 
understood that good ESG performance goes 
hand-in-hand with good financial performance, 
and it is now abundantly clear that the action 
businesses take on sustainability is an 
important lens through which they are being 
viewed and assessed by their stakeholders.

Progress
HSBC delivered a good financial performance 
in 2021. Reported profit before tax was 
$18.9bn, an increase of $10.1bn as compared 
with 2020, while adjusted profit before tax was 
$21.9bn, up 79%. All of our regions were 
profitable in 2021, supported by the global 
economic recovery, demonstrating the value 
of our global network. There was also good 
growth in focus areas such as Asia wealth 
and trade. In line with the dividend policy 
announced in February 2021, the Board 
approved a second interim dividend for 2021 
of $0.18, meaning the full year dividends for 
2021 are $0.25.

Good progress has been made in executing 
our strategic plan. A number of key milestones 
were reached in 2021 – including resolving the 
future of our retail businesses in France and 
the US, the organic build-out of HSBC 
Personal Wealth Planning in mainland China, 
and acquisitions in Singapore and India to 
accelerate the development of our wealth 
capabilities across Asia. At the same time, our 
work to digitise HSBC and to play a leading 
role in the net zero transition has continued  
at pace. There is more to do – and it will be 
important to see successive consecutive 
quarters of growth – but good momentum 
exists across our businesses. 

Board of Directors
Due to ongoing travel restrictions and safety 
concerns, the Board has not been able to meet 
in person for two years. We look forward to 
reconnecting with each other and welcoming 
those Board members we are yet to meet in 
person. At the same time, we have come to 
appreciate the benefits of this new way of 
working – which include more regular 
dialogue, less travel and reduced costs – 
and we will therefore use a hybrid model 
going forward. 

Mark E Tucker
Group Chairman

2021 was another challenging year. 
While Covid-19 vaccines were rolled 
out globally, some countries dealt with 
very significant outbreaks and many 
more operated under various restrictions 
at different points. As in 2020, this took 
a huge toll on our customers, our 
people, the communities we serve 
and our shareholders. 

My colleagues once again demonstrated their 
resilience, their professionalism and, above all, 
their exceptional commitment to serving our 
customers. Our purpose as an organisation is 
to open up a world of opportunity. Our people 
have brought this to life in the way they have 
supported our customers and each other. On 
behalf of the Board, I would like to thank them 
warmly for everything they have done, and 
continue to do.

ESG was another major theme of 2021. The 
pandemic has exposed the fragility of the 
planet and society as a whole. It has also 
created a catalyst for change and highlighted 
the associated commercial opportunities. 
Businesses, governments, regulators and 

6

HSBC Holdings plc Annual Report and Accounts 2021

Group Chairman’s statement

” HSBC has long understood that good 
ESG performance goes hand-in-hand 
with good financial performance.”

and value. For our suppliers, it can mean 
supporting them to grow their businesses 
and strengthen their own supply chains.  
And for the communities we serve, it can 
mean being a responsible citizen and leading 
the net zero transition.

Stakeholder engagement has been a priority 
for the Board in 2021. For example, the Board 
oversaw HSBC’s continuing work in support  
of our ambition to align our financed emissions 
to net zero by 2050 or sooner. This included 
engaging shareholders and leading NGOs 
ahead of the 2021 AGM, when our special 
resolution on the next steps in relation to  
our climate ambition was overwhelmingly 
approved. We also reviewed and approved 
a new thermal coal phase-out policy, which 
we announced in December 2021 and is 
designed to allow HSBC to help facilitate the 
transition to net zero in both developed and 
developing markets. 

Thank you
Finally, I would like to reiterate how grateful 
I am to all my colleagues for the great 
dedication and care they have shown to our 
customers and to each other over the past 
year. Their tremendous efforts have, above 
everything else, made us what we are today 
– and will shape what we become tomorrow.

Mark E Tucker
Group Chairman

22 February 2022

We were pleased to hold our first hybrid  
AGM in May 2021, which the majority of 
shareholders attended virtually. It is a matter 
of deep regret to me, and to the Board as a 
whole, that we have been unable to meet our 
loyal Hong Kong shareholders face-to-face. 
We look forward to doing so again as soon 
as it is practicable and safe. In the meantime, 
a hybrid meeting does at least allow for 
constructive engagement and discussions 
with shareholders, which we continue to 
value highly.

At the 2021 AGM, Laura Cha, Henri de 
Castries and Heidi Miller all retired from the 
Board. We also recently announced that Irene 
Lee and Pauline van der Meer Mohr will step 
down from the Board at the conclusion of our 
2022 AGM in April. I am enormously grateful  
to them all for their important and valuable 
contributions to the Board, the committees 
and the subsidiary entities on which they have 
served. We welcomed Dame Carolyn Fairbairn 
and Rachel Duan to the Board on 1 September. 
Both Carolyn and Rachel bring a wealth of 
skills and expertise that will be of great value 
to the Board’s discussions.

External environment 
The roll-out of vaccines around the world and 
a robust global economic recovery mean we 
entered 2022 in a better state than we might 
have expected a year ago. There are clearly 
still significant challenges ahead, foremost 
among which is the uncertainty caused by the 
spread of the Omicron variant, and potentially 
other variants in the future. Supply chain 
bottlenecks, high energy and food prices, 
surging consumer demand and higher wages 
have combined to drive up inflation. Central 
banks have already begun to respond by 
tightening monetary policy and this is likely 
to continue in 2022.

Global economic growth forecasts are fairly 
resilient – our own forecast is 4.1% global  
GDP growth in 2022. However, there remains 
a great deal of uncertainty given the wide 
range of responses from governments to  
the different challenges they face. 

After China’s strong recovery, growth slowed 
in the second half of 2021. As a result, we 
expect China’s government to take action to 
ease monetary and fiscal policies, with the  
aim of shoring up growth. Meanwhile, India’s 
economy is set to grow rapidly, but growth is 
expected to be slower in the UK and the US. 

Global trade performed well in 2021, with 
volumes rising above pre-pandemic levels 
despite ongoing supply chain disruptions. 
Looking forward, trade growth could be 
further boosted by the lifting of restrictions 
on movement that remain in place in some 
countries. There are also signs that supply 
chain bottlenecks will ease as the year  
goes on, although when and how remains 
uncertain. The Regional Comprehensive 
Economic Partnership is expected to 
reinforce Asia’s central role in global trade. 
Along with the bilateral trade deals being 
struck by some countries, it also shows that 
trade liberalisation continues to advance in 
some parts of the world.

Although there is currently no long-term 
agreement between the UK and the EU on 
access to financial services, we have worked 
for a number of years to ensure we will be able 
to maintain a full service for our clients under 
all potential scenarios. Ideally, the temporary 
arrangements on access to financial services 
will be retained so as to minimise disruption 
and enable the UK financial services industry 
to continue to offer the many benefits  
it brings to the UK and EU economies. 
However, we are well prepared for a broad 
range of outcomes.

As a global bank operating in more than 
60 countries and territories, with a history 
stretching back more than 156 years, we 
always have experienced – and always will 
experience – geopolitical tensions. However, 
we remain alive to the potential impact that 
geopolitics can have on our business, as well 
as on our clients. The relationship between the 
US and China remains a prominent feature of 
the external environment, but we do not 
currently expect it to change significantly in 
the near future. We also expect the mutual 
economic benefits brought by the UK-China 
relationship to outweigh any short-term 
pressures. We continue to engage with all 
governments and remain focused on serving 
the needs of our customers in both East and 
West, and the many points in between.

Stakeholder engagement
Our purpose of opening up a world of 
opportunity is equally applicable to our 
different stakeholders. For our people, it  
can mean helping them to develop new skills 
and advance in their careers, as well as being 
diverse and inclusive. For our shareholders, 
it can mean creating sustainable returns  

HSBC Holdings plc Annual Report and Accounts 2021

7

Strategic reportStrategic report 

Group Chief Executive’s review

We are making good progress transforming and growing 
HSBC, which is helping us to open up a world of opportunity 
for our customers, our colleagues and our shareholders.

As we do so, we will be guided by the  
values underpinning our purpose – we value 
difference, we succeed together, we take 
responsibility and we get it done. These are 
the behaviours that will help us to identify and 
unlock new opportunities – and together they 
represent the kind of organisation we want 
HSBC to be.

With our purpose and values firmly in mind, 
we made good progress in 2021 against all 
four of our strategic pillars: focus on our 
strengths, digitise at scale, energise for growth 
and transition to net zero. Delivering against 
them contributed to a strong financial 
performance, which was supported  
by the global economic recovery. All of our 
regions were profitable and we have built  
a strong platform for future growth.

For some of our customers, the first priority 
has remained navigating the ongoing impact 
of Covid-19, particularly in markets that 
suffered severe outbreaks or faced restrictions 
during the course of 2021. To this end, I must 
again offer my deep thanks to my colleagues, 
who have exemplified our values in supporting 
our customers and each other, all the while 
continuing to deal with the pandemic 
themselves.

As economies recovered and opened up, we 
have helped more and more of our customers 
to look beyond the immediate horizon and 
towards the opportunities we can open up  
for them. In 2021, we helped almost 269,000 
personal customers to buy their first homes. 
We lent $47bn to help our business banking 
customers to run, grow and digitise their 
businesses. We launched new products and 
services that make it easier for our customers 
to bank with us, and allow us to focus our 
efforts on serving them. We facilitated $799bn 
of trade, which has helped businesses and 
economies around the world to recover and 
grow again.

As our people also began to look to the future, 
we created opportunities for them too. We 
helped more than 30,000 colleagues move 
into new roles in 2021, and over 115,000 
colleagues to develop future-ready skills 
through our learning programmes. An 
increasing number of these programmes 
focused on building skills and capabilities  
in areas like data and sustainability, which  
are essential to our future.

Noel Quinn
Group Chief Executive 

A year ago, we refreshed our core 
purpose as an organisation. ‘Opening up 
a world of opportunity’ was the outcome 
of extensive consultation with colleagues 
and customers around the globe. I have 
been delighted by the way it has been 
embraced across HSBC – and in the 
many conversations I have had with 
colleagues, I have been greatly 
encouraged by how they see their 
roles contributing towards it. 

Opening up a world of opportunity draws 
heavily on HSBC’s past, but it also 
encapsulates what we need to focus on to 
succeed now and in the future. Opportunities 
have always come in many shapes and forms, 
some of which have required us to change 
and evolve to make the most of them. We 
need to keep challenging ourselves to find and 
capture these opportunities. This is how we 
will help our customers to grow and succeed 
over the long term. 

8

HSBC Holdings plc Annual Report and Accounts 2021

Group Chief Executive’s review

” The opportunities of the 
future will be defined by  
the single greatest challenge  
of our time – the need for 
everyone to make the  
low-carbon transition.”

More than anything else, the opportunities 
of the future will be defined by the single 
greatest challenge of our time – the need for 
everyone to make the low-carbon transition. 
To seize them, we must change, adapt, 
invest and innovate. Since 2019, we have 
reduced greenhouse gas emissions across 
our operations by more than half. We also 
provided and facilitated $82.6bn of 
sustainable finance and investment – 
bringing the cumulative total since 1 January 
2020 to $126.7bn, towards our ambition of 
$750bn to $1tn by 2030. Furthermore, we 
have collaborated with other banks and 
financial institutions to help accelerate the 
transition through initiatives including the 
Net-Zero Banking Alliance, the Glasgow 
Financial Alliance for Net Zero and the 
Sustainable Markets Initiative’s Financial 
Services Taskforce.

Financial performance
The global economic recovery supported our 
2021 financial performance, as the release of 
expected credit losses resulted in an 
improvement in the profitability of the Group 
and all global businesses. Our interest-rate 
sensitive business lines continued to be 
adversely impacted by low interest rates, but 
our net interest margin remained broadly 
stable during 2021 and the outlook is now 
significantly more positive. After absorbing the 
impact of low interest rates for some time, we 
believe we have turned the corner on revenue. 
We have also seen good fee income growth, 

good growth in mortgage balances and our 
lending pipelines across both retail and 
wholesale remain strong. Our insurance 
business also continues to perform well, 
notably in Asia where we have seen strong 
growth in value of new business, despite the 
border between Hong Kong and mainland 
China remaining closed.

As a consequence, the Group delivered 
$18.9bn of reported profit before tax, up 
$10.1bn on the prior year, and $21.9bn of 
adjusted profits, up 79%. We were profitable 
in every region, with Asia leading the way 
and material increases in profits in the UK, 
continental Europe, the US and the 
Middle East.

Adjusted revenue was down 3%, due mainly 
to the impact of interest rate cuts. However, 
trade balances grew by 23% overall, while 
loans and advances increased by $23bn for 
the year.

Our cost reduction programmes were able to 
absorb increased technology investment and 
higher performance-related pay, with adjusted 
operating expenses down by 1%. Return on 
tangible equity was 8.3%. If rates follow the 
path currently implied by the market, we 
would expect to reach a return on tangible 
equity of at least 10% for 2023, one year 
ahead of our previous expectations.

In the fourth quarter of 2021, we took a charge 
on expected credit losses, due to changing 
market conditions in the mainland China 
commercial real estate sector. Since the year 
end, there has been some positive sentiment 
as a consequence of new policy actions. They 
will take time to impact the market and we will 
continue to support our clients, with whom we 
have good and long-standing relationships.

Our funding, liquidity and capital all remain 
strong. We grew deposits by $90bn on a 
constant currency basis, with growth in all 
three global businesses. Our common equity 
tier 1 ratio was 15.8%. As a consequence, 
we are able to announce a second interim 
dividend of $0.18, bringing the full-year 
dividends for 2021 to $0.25 per ordinary share. 
This is within our target payout ratio, and our 
aim is for a sustainable dividend in 2022.

HSBC Holdings plc Annual Report and Accounts 2021

9

Strategic reportStrategic report | Group Chief Executive’s review

Strategic progress

In 2021, we made good progress 
against our strategic pillars.

We brought in 

$36.2bn 

of net new invested assets in Asia Wealth. 

We provided and facilitated 

$82.6bn 

of sustainable finance and investment. 

Our strong capital position and confidence in 
the business enabled us to announce a share 
buy-back of up to $2bn in October 2021. We 
also intend to initiate a further share buy-back 
of up to $1bn, to commence after the existing 
buy-back of up to $2bn has concluded. 

We are also helping to create sustainable 
returns for shareholders by driving underlying 
growth across the business. We have much 
more to do, but I am encouraged by what we 
have achieved so far.

Focus on our strengths
We have made good progress restructuring 
our portfolio of businesses, with the aim of 
investing in those areas in which we are 
strongest and withdrawing from those 
areas in which we lack the necessary  
scale to compete.

Over the last two years, we reduced gross  
risk-weighted assets by a cumulative $104bn, 
against our original three-year target of 
$110bn. Given this progress, we now expect 
to exceed this target by the end of 2022. In 
Global Banking and Markets, adjusted 
risk-weighted assets were 10% lower in 2021, 
as we moved capital and resources mainly into 
Asia and the Middle East. The extensive work 
undertaken to transform this business since 
2019 was also designed to mitigate the 
impact of Basel III reforms.

We reached two key milestones for our 
transformation as we took steps to resolve 
the future of our businesses in the US and 
continental Europe. In the US, we entered 
into an agreement to sell our mass market 

retail business, which has now been 
completed on schedule. We also entered into 
an agreement to sell our retail banking 
activities in France, which we expect to 
complete in 2023. Both deals will help our US 
and continental Europe businesses to become 
more focused, better aligned to the Group and 
the international needs of our wholesale and 
wealth management customers.

In Asia, we continued to enhance our wealth 
proposition, including through the launch of 
HSBC Greater Bay Area Connect and more 
than 30 new asset management products 
across the region. In December, we received 
regulatory approval to acquire the remaining 
50% stake in HSBC Life China, our joint 
venture insurance company in mainland China. 
All of this is enabling us to significantly expand 
our capabilities to serve the growing wealth 
and insurance needs of our customers in 
China, particularly in the Greater Bay Area.

We accelerated the development of our wealth 
capabilities across the rest of Asia by several 
years through two acquisitions. We entered 
into an agreement to buy AXA Singapore, 
which was completed earlier this month and 
will expand our insurance and wealth 
franchise in our ASEAN regional hub. We also 
agreed to buy L&T Investment Management 
to strengthen our asset management business 
in India. Both deals represent significant steps 
towards our ambition of being a leading 
wealth manager in Asia. 

The overall investment we have made in Asia 
wealth was evidenced by strong customer 
acquisition, and significantly increased assets 
and balances, year-on-year. Net new invested 
assets in Asia wealth were $36.2bn, which 
was more than double the previous year.

In Commercial Banking, we grew our lending 
by $11bn and our international account 
opening increased by 13% in 2021, while trade 
balances grew by 30% and are now above 
pre-pandemic levels. 

Digitise at scale
We invested $6bn in technology in 2021, 
as we continued to drive change in the  
way we approach technology across the 
organisation and ultimately improve the 
customer experience.

Around 97% of transactions are now fully 
automated. For example, automated credit 
and lending systems processed around $15bn 

of personal loans in 2021. Our use of the Cloud 
increased to cover 27% of technology 
services, giving us more processing power 
and speed, while we also increased our use 
of Agile across technology roles.

Almost half of our retail customers are now 
active on mobile, and we have developed new 
products and improved existing ones so we 
can better meet their needs. Our revamped 
mobile app is now available across 24 markets 
and Global Money was extended to more 
markets, allowing more of our international 
retail customers to hold, manage and send 
funds in various currencies. Corporate 
customers carried out over 9 million payments 
through the HSBCnet app – an increase of 58% 
year-on-year. HSBC Kinetic – our award-
winning mobile banking app for business 
customers in the UK – has acquired more than 
24,000 customers since it was launched.

Energise for growth
We have taken further steps to create a 
dynamic and inclusive culture, which helps 
us to attract and retain the best people.

After listening to our people, we introduced a 
hybrid working model, wherever appropriate, 
which allows us to strike the right balance 
between office-based work and home-based 
work. We have also taken the opportunity 
during Covid-19 to reconfigure much of our 
head office workspace to better facilitate 
team-based Agile working methods. We are 
still learning about what works, but we believe 
that trusting our colleagues to find the right 
balance is integral to building the culture we 
aspire to at HSBC. As a consequence of hybrid 
working, we will need less office space. In 
2021, we reduced our global office footprint 
by more than 3.4 million square feet – 
equivalent to 18%.

We were pleased to exceed our target for 
30% women in leadership roles globally in 
2020, and we set a new target of 35% by 
2025. HSBC was named in the Bloomberg 
Gender-Equality Index last month, with our 
overall score increasing by 21 percentage 
points in 2021 and outperforming the financial 
services average by 15 percentage points. 
We also continued to work to improve 
ethnicity representation, especially for Black 
colleagues. However, we still have a way to 
go to get to where we want, and need, to 
be on both measures.

10

HSBC Holdings plc Annual Report and Accounts 2021

Group Chief Executive’s review

” We were profitable in every 
region, with Asia leading 
the way and material 
increases in profits in the 
UK, continental Europe, 
the US and the Middle East.”

In our most recent colleague survey,  
our employee engagement index was  
72%, which is unchanged on 2020 and  
4 percentage points above the average  
for the financial services sector.

assets without hindering growth. HSBC 
was presented with the Terra Carta seal by 
HRH the Prince of Wales in recognition of the 
work that we are doing to create truly 
sustainable markets. 

Transition to net zero
The industrial landscape of the world is being 
transformed by the transition to net zero. I am 
determined that HSBC will play a leading role 
in driving this change.

At the 2021 AGM, 99.7% of shareholders 
backed our special resolution on climate 
change, providing a strong endorsement 
of our climate plan and our commitment to 
support our customers on their transitions to 
a low-carbon future. However, we do not take 
this support for granted, and we have taken 
a number of further steps to maintain our 
leadership role.

In September, we partnered with Temasek, 
subject to regulatory approval, to launch a 
new debt financing fund for sustainable 
infrastructure in south-east Asia, with $150m 
of seed capital and the ambition to deploy 
$1bn of financing over five years. 

At the COP26 meeting in Glasgow, HSBC  
was one of over 100 public and private 
organisations behind the launch of FAST-Infra, 
a labelling system that aims to increase 
investor confidence in the sustainability 
credentials of projects in emerging markets. 
We are also supporting the Energy Transition 
Mechanism, a public-private partnership led 
by the Asian Development Bank that aims 
for the materially earlier retirement of coal 

After also joining the Powering Past Coal 
Alliance, we published a new thermal coal 
policy to phase out the financing of coal-fired 
power and thermal coal mining in EU and 
OECD markets by 2030, and globally by 2040. 
This fulfilled the commitment approved by  
our shareholders and followed a period of 
extensive engagement with our stakeholders. 
It has two clear objectives: to drive thermal 
coal phase-out within the timeframe required 
to reach net zero by 2050; and to help enable 
the energy transition in developing economies.

We are committed to working with our clients 
to develop valid, science-based transition 
plans to understand – sector-by-sector and 
client-by-client – how we will move to net zero 
by 2050. These transition plans and the targets 
within them must be predicated on the 
science relevant to the individual sectors. 
We will use them as a basis for further 
engagement and decision making, including 
how we drive change within our portfolios. 
As part of this process, we have disclosed 
interim targets for on-balance sheet financed 
emissions in the oil and gas, and power and 
utilities sectors. In the year ahead, we plan to 
set interim targets for financed emissions 
across a range of other sectors. We will also 
work on our climate transition plan, which will 
be published in 2023 and will bring together 
in one place how we will embed our net zero 
targets into our strategy, processes, policies 
and governance.

2022
We have good momentum coming into 2022 
and are confident that we can continue to 
execute against our strategy. We also remain 
cognisant of the potential impact that further 
Covid-19-related uncertainty and continued 
inflation might have on us and our clients.

Throughout HSBC’s history, our people have 
always demonstrated great professionalism 
and commitment to those we serve, and that 
is as evident today as it has ever been. Despite 
the personal and professional challenges they 
continue to face after two years of living with 
the pandemic, I am proud of my colleagues, 
and the sense of duty and care they continue 
to show towards our customers and each 
other. Our success – now and in the future – is 
testament to them and all they continue to do 
for our bank.

Noel Quinn
Group Chief Executive

22 February 2022

HSBC Holdings plc Annual Report and Accounts 2021

11

Strategic reportStrategic report

Our strategy

We are implementing our strategy across the four strategic pillars aligned to our purpose, 
values and ambition announced in February 2021.

Progress on our commitments in 2021

In 2021, we made good progress on our 
strategy across all of our global businesses. 

In Wealth and Personal Banking, we had 
strong wealth revenue momentum and 
augmented our fee generating portfolios  
with acquisitions in asset management and 
insurance to build further scale. In Commercial 
Banking, we saw strong growth in fee income, 

and momentum in trade volumes. In Global 
Banking and Markets, we had strong 
countercyclical revenue even as we exceeded 
our expectations on RWA rundowns and client 
exits. To support our global businesses, we 
also continued to invest in technology, develop 
our talent and culture, and play a role in the 
transition to a global net zero economy. 

Our efforts to date are paving the way for 
us to accelerate execution of the growth 
opportunities across our businesses and 
international network and, in turn, to help 
meet our targets and ambitions.

Shifting capital to areas with the highest returns and growth

In line with our strategy, we set out aspirations in February 2021 to accelerate the shift of capital and resources to areas that have demonstrated 
the highest returns and where we are strongest, principally in Asia, with a pivot to fee income generating businesses such as wealth. We saw 
strong progress across all parameters in 2021. While the proportion of fee and insurance income increased relative to 2020, reflecting fee and 
insurance revenue growth, this metric was also favourably impacted by lower net interest income due to 2020 interest rate reductions, as well  
as favourable market impacts in life insurance manufacturing.

Capital allocation and planned revenue concentration
Asia
(as a % of Group tangible equity)1

Wealth and Personal Banking
(as a % of Group tangible equity)2

Adjusted fees and insurance revenue
(as a % of total adjusted revenue)

2020

2021

42%

2020

42%

2021

25%

2020

27%

2021

Medium- to long-term aspiration

c.50%

Medium- to long-term aspiration

c.35%

Medium- to long-term aspiration
2020

1 Based on tangible equity of the Group’s major legal entities excluding associates, holding companies, and consolidation adjustments.
2 WPB tangible equity as a share of tangible equity allocated to the global businesses (excluding Corporate Centre). Excludes holding companies, and 
  consolidation adjustments.

28%

33%

c.35%

Progress against Group targets

Adjusted operating expenses in 2021

Gross RWA reduction1 

RoTE3 in 2021

$32.1bn

Updated target: 2022 adjusted operating 
expenses in line with 2021. Previous target: 
≤$31bn in 2022 (at December 2020 foreign 
exchange rates).

$104bn

Since the start of the programme. Updated 
target: >$110bn by end of 2022.

8.3%

Target: ≥10% over the medium term.

Dividend payout ratio2

CET1 ratio in 2021 

40.3%

Target: sustainable cash dividends 
with a payout ratio of 40% to 55% 
from 2022 onwards.

15.8%

Target: >14%, managing in the range of 14% 
to 14.5% in the medium term; and manage 
range down further long term.

 For our financial targets, we define medium term 
as three to four years and long term as five to six 
years, commencing 1 January 2020. Further 
explanation of performance against Group 
financial targets may be found on page 26.

1 Given progress to date, we now expect to exceed our $110bn reduction target by the end of 2022.
2  In line with our dividend policy, we retain the flexibility to adjust earnings per ordinary share (‘EPS’) for non-cash significant items. In 2022, we intend to adjust EPS 

to exclude the forecast loss on the sale of our retail banking operations in France.

3 If policy rates were to follow the current implied market consensus, we would expect to deliver a return on average tangible equity (‘RoTE’) of at least 10% for 2023.

12

HSBC Holdings plc Annual Report and Accounts 2021

Our strategy

Our strategy

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 continue to focus on areas where we are strongest and have opportunities to grow. 

Wealth and Personal Banking
In Wealth and Personal Banking, we have 
continued to make progress in the execution 
of our wealth, asset management and 
insurance strategy, notably in Asia. We grew 
our net new invested assets from $53bn in 
2020 to $64bn, with $36bn coming from Asia, 
where we saw an increase of 138%. This 
contributed to a 5% increase in Wealth and 
Personal Banking wealth balances to $1.67tn, 
including 5% growth in Asset Management’s 
funds under management to $630bn. In Asia, 
Wealth and Personal Banking wealth revenue 
– which comprises wealth, insurance, private 
banking, and asset management – grew by 
10% to $5.8bn. This included a 40% growth in 
value of new business in insurance to $917m. 
We continued to enhance our wealth product 
offerings in the region, including launching 
Greater Bay Area Wealth Management 
Connect, and over 30 new asset management 
products. Globally, Wealth and Personal 
Banking customer lending balances were 
$489bn, an increase of 6% compared with 
2020, notably reflecting mortgage balance 
growth across all regions, but particularly in 
the UK and Hong Kong.

Commercial Banking
Our Commercial Banking business continued 
to grow our lending pipeline and maintain 
leadership in supporting cross-border trade. 
Customer lending volume increased 3% to 
$349bn in 2021, mainly from continued 
growth in trade and term lending. The 
recovery in global trade volumes was also 
reflected in higher fee income in Global Trade 
and Receivables Finance, where we saw a  
9% revenue growth compared with 2020. 
Over the same period, fee income in the 
overall Commercial Banking business also 
grew 9%, reaching approximately $3.6bn and 
surpassing pre-pandemic levels in 2019. 
We also committed to investing in global 
platforms and improving SME propositions 
in our key markets. Since the launch of our 
digital business banking account Kinetic in 
the UK in August 2020, we have reached 
approximately 24,000 customers at the 
end of 2021.

Global Banking and Markets
We repositioned our capital and resources in 
Global Banking and Markets to create capacity 
for growth opportunities, mainly into Asia and 
the Middle East, and to serve international 
clients that are aligned to our strategy. As part 
of our transformation programme, we reduced 
adjusted RWAs by approximately 10% to 
$236bn at 31 December 2021, driven by saves 
in our Western franchise, comprising our 
Europe and Americas businesses. Despite  
the focus on repositioning, the business 
performed well in 2021, with overall revenue 
reaching approximately $15bn, driven by 
strong performances in Equities, Capital 
Markets and Advisory and Securities Services. 
Collaboration with other businesses through 
cross-selling products remains important for 
us. In 2021, the business facilitated $2.5bn  
into Commercial Banking, an increase of 12% 
compared with 2020, and $1.4bn into Wealth 
and Personal Banking, an increase of 2%. 

$64bn

Net new invested assets in 2021.

$3.6bn

Fee income in 2021. 

18%

Adjusted RWA reduction in the West in 2021.

Repositioning for growth
We are repositioning our portfolio to support our areas of growth.

Restructuring the US and Europe
We aim to create capacity for growth by 
refocusing our US business and HSBC Bank 
plc, our non-ring-fenced bank in Europe and 
the UK. In May and June respectively, we 
announced the exit of mass market retail in the 
US, and the planned sale of our retail 
operations in France. Our plan to exit our US 
mass market retail banking business was 
completed in February 2022, which includes 
approximately $8.8bn of deposits held for sale 
and exiting and winding down approximately 
125 branches, leaving us with approximately 
25 international wealth centres. The planned 
sale of our France retail business includes a 
network (using values at 31 December 2021) 
of 244 retail branches, approximately 800,000 
customers, $24.9bn in customer loans and 
$22.6bn in deposits balances.

We also made strong progress in 2021 on 
reducing the capital and cost base in the 
two franchises. During the year, adjusted 
RWAs decreased $7bn in the US to $78bn at 
31 December 2021, while in HSBC Bank plc,  
they decreased by $22bn to $141bn. The 
respective balances at 31 December 2021 
included approximately $1.3bn relating to the 
announced US mass market retail disposal 
and approximately $7bn relating to the 
planned disposal of our France retail business. 
We also lowered the adjusted cost base in 
these franchises by 5% compared with 2020 
to $10.4bn, in spite of strong inflationary 
pressures in these markets.

Repositioning Asia for growth
We announced three key acquisitions in 2021 
to further strengthen our wealth franchise in 
Asia. In August, we entered an agreement to 

acquire AXA Singapore for $529m, with the 
intention to merge the business with the 
operations of our existing HSBC Life Singapore 
franchise. The acquisition was recently 
completed on 11 February 2022. The 
combined business would be the seventh 
largest life insurer in Singapore, based on 
annualised new premiums, and the fourth 
largest retail health insurer, based on gross 
premiums, with over 600,000 policies in-force, 
data as of end of 2020. In December, we 
announced the agreement to fully acquire 
L&T Investment Management, the 12th largest 
mutual fund management company in India 
with assets under management of $10.8bn 
and over 2.4 million portfolios as of September 
2021. We also received regulatory approval to 
acquire the remaining 50% stake in HSBC Life 
China, bringing our shareholder ownership to 
100% upon completion.

HSBC Holdings plc Annual Report and Accounts 2021

13

Strategic report 
 
Strategic report | Our strategy

Digitise at scale

We continue to invest in our technology and 
operational capabilities to drive operating 
productivity across businesses and 
geographies and to offer better client 
experience. In 2021, approximately $6.0bn, 
or 19%, of our overall adjusted operating 
expenses were dedicated to technology (net 
of saves from our transformation programme), 
up from approximately $5.7bn in 2020. We 
aspire to progressively increase the share 
to greater than 21% by 2025. 

We have made progress on automating our 
organisation at scale. Our Cloud adoption rate, 
which is the percentage of our technology 
services on the private or public Cloud, 
increased from approximately 20% in 2020 to 
27% in 2021. We are also promoting an agile 

workforce to help equip our colleagues for 
the future of work. At the end of 2021, 15% 
of our total technology workforce in the 
global businesses and functions were aligned 
to at least one agile team per agile blueprint. 
This marks a significant improvement from 
5% in 2020.

Our digital engagement with customers also 
improved. At the end of 2021, 43% of our 
customers active on our mobile services had 
logged onto a HSBC mobile app at least once 
in the last 30 days, compared with 38% in 
2020. Our wholesale clients executed over 
9 million payments on HSBCnet’s mobile 
banking app, a 58% increase compared with 
2020. During the same period, the percentage 
of Commercial Banking transactions enabled 

digitally for HSBCnet grew from 83% to 94% 
in the 18 Asian markets where HSBCnet is 
available for wholesale clients. Across all our 
trade digital channels, 84% of transactions in 
2021 were initiated digitally by our customers, 
compared with 69% of transactions in 2020. 
Seeing these improvements, we endeavour 
to continue investing in technology that helps 
enhance our customers’ digital experiences.

Technology spend
as % of total adjusted operating expenses

2020

2020
2021

2025 ambition
2021

18

19

>21

Energise for growth 

In February 2021, we set out the case for 
a more effective, agile and empowered 
organisation that could execute on our 
ambitious journey. 

In 2021, our employee engagement score, 
a gauge of an employee’s propensity to 
recommend HSBC as a great place to work, 
was in line with 2020 at 72%, but notably up 
from 67% in 2019. This represents a strong 
endorsement of various initiatives around our 
purpose and values in our organisation.

Transition to net zero

Recruiting the right talent and diversifying our 
workforce remain important to us. We had 
31.7% of senior leadership roles held by 
women, which are roles classified as those 
at band 3 and above in our global career 
band structure. We are on track to meet 
our ambition of having more than 35% 
representation of women in these roles 
by 2025. 

We continue to energise our colleagues 
through initiatives that help develop their 
future skills and learning opportunities, 
especially in areas including data, digital and 
sustainability. In 2021, the average hours of 
training per full-time equivalent staff ('FTE')
increased to 26.7 hours from 23.0 hours 
in 2020. 

 We outline how we put our purpose and values 
into practice in the following 'How we do 
business' section. For further details on how 
we plan to energise for growth, see the Social 
section in the ESG review on page 66.

In November, we participated in COP26 to play 
our part in bringing together the public and 
private sector to mobilise this transition. We 
also made good progress on our ambitions, 
including setting targets for our on-balance 
sheet financed emissions and launching 
innovative climate solutions and products 
to support our customers in their transition 
to a net zero future. 

a policy to phase out thermal coal financing in 
EU and OECD markets by 2030, and globally 
by 2040. We have also set targets for our 
on-balance sheet financed emissions for the 
oil and gas, and power and utilities sectors. 
On the journey to net zero, we recognise that 
individual markets have their own unique 
circumstances that we intend to factor in 
when laying out our net zero approach.

Becoming a net zero bank
We have set a climate ambition to become net 
zero in our operations and supply chain by 
2030, and align our financed emissions to the 
Paris Agreement goal of net zero by 2050. In 
2021, we reduced our organisation’s absolute 
greenhouse gas emissions in our operations to 
341,000 tonnes, a decrease of 50.3% from the 
2019 baseline (the data for 2019 and 2020 has 
been revised as we have updated our air travel 
reporting methodology to include the cabin 
class travel and the impact of radiative forces, 
and therefore, the percentage change from 
2019 baseline is based on the revised 
methodology). In December, we published 

Supporting customers through transition
Our ambition is to support our customers in 
their transition to net zero and a sustainable 
future. In 2021, we provided and facilitated 
$82.6bn of sustainable finance and 
investment, taking the cumulative amount 
to $126.7bn since 1 January 2020, as part of 
our $750bn to $1tn by 2030 ambition. This 
comprised support including facilitation of 
capital flow and access to capital markets 
for sustainability-linked outcomes, as well as 
financing and investments in environmental 
and social goals such as decarbonisation of 
energy systems.

Unlocking new climate solutions 
Scaled innovation in critical areas such as next 
generation climate technologies, nature-based 
solutions and sustainable infrastructure will be 
critical to tackling climate change. In 
September, we launched a new debt financing 
fund for sustainable infrastructure in south-
east Asia in partnership (subject to regulatory 
approval) with Temasek, with $150m of seed 
capital and the ambition to deploy $1bn of 
financing over five years. We are leading the 
FAST-Infra initiative, which we co-founded 
to establish a consistent, globally applicable 
labelling system to identify and evaluate 
sustainable infrastructure assets. We are also 
supporting the Energy Transition Mechanism, 
a public-private partnership led by the Asian 
Development Bank, which endeavours to 
accelerate the retirement of coal-fired power 
stations and increase demand and 
investments in renewable energy. 

 For further details on our climate ambition, see 
the Environmental section in the ESG review 
on page 45.

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HSBC Holdings plc Annual Report and Accounts 2021

How we do business

 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 our ambition is 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. Since the world 
changed in 2020, we adapted to new ways of 
working and endeavoured to provide support 
to our customers during this challenging 
period. On the following page, we have set 
out further ways that we continued to support 
our stakeholders.

Fair outcomes
Our conduct approach guides us to do the 
right thing and to focus on the impact we have 
for our customers and the financial markets in 
which we operate. It complements our 
purpose and values and – together with more 
formal policies and the tools we have to do our 
jobs – provides a clear path to achieving our 

purpose and delivering our strategy. For 
further information on conduct, see page 83. 
For further details on our purpose-led conduct 
approach framework, see www.hsbc.com/
who-we-are.

Developing the skills of colleagues is critical 
to energising our organisation. We foster a 
culture of learning through a range of 
resources, providing colleagues with a breadth 
of educational materials and opportunities. 

As we continue to reshape the organisation, 
we are committed to managing change well, 
and redeploying impacted colleagues. In 2021, 
23% of colleagues impacted through 
restructuring programmes found new jobs 
within HSBC.

Our climate ambition
We have set a 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 
have set on-balance sheet financed emissions 
targets for the oil and gas, and power and 
utilities sectors, aligned to the International 
Energy Agency’s (‘IEA’) net zero scenario, 
underpinned by a clear science-based 
strategy. To support our goal of net zero 
financed emissions, it will be crucial to unlock 
transition finance for our portfolio of clients. 

 For further details of our ESG disclosures, see 
our ESG review on page 42.

Our colleagues
Understanding the experience of colleagues 
is central to our efforts to open up a world of 
opportunity. Through our employee survey, 
Snapshot, we capture their views on issues 
from our strategy to their well-being to the 
future of work. These views will guide our 
approach as we embrace hybrid working. 

We value difference among our colleagues, 
which is why we continue to build an inclusive 
workforce. Having surpassed our 2020 target 
to reach 30% women in senior leadership 
roles – classified as those at band 3 and above 
in our global career band structure – we have 
made strong progress towards our goal to 
achieve 35% by 2025, with 31.7% achieved 
in 2021.

We expanded the ability for our colleagues to 
share their diversity characteristics, with over 
70% now able to self-identify their ethnic 
heritage, gender identity, disability and sexual 
orientation. This will help us to set locally 
appropriate goals, reflective of our markets. 
In July 2020, we set out our early global race 
commitments, which included the goal of 
doubling the number of Black employees in 
senior roles over the following five years. In 
2021, we put in place important foundations 
to achieve this goal. 

Update on our purpose and values

We relaunched our purpose in March 2021. 
We have been pleased to see how quickly 
our colleagues have embraced 'Opening up 
a world of opportunity’ as our purpose, and 
how they are delivering against it. You can 
find some examples from 2021 below. 
We have enabled the recognition of 
colleagues who have lived up to our 
values, and there have been over 600,000 
recognitions made in 2021.

 – We helped 268,771 people buy their first 
home, lending $92.9bn in mortgages. 

 – We provided $47bn in loans to our 

business banking customers to help 
support, grow, internationalise and digitise 
their businesses.

 – We facilitated $799bn of trade globally 
to help economies grow and prosper.

 – We supported over 270,000 students 

move internationally to study by providing 
key financial products including account 
openings, fund transfer and day-to-day 
finance management in their new countries.

 – Over 115,000 colleagues made use of 
our new learning platform, Degreed, 
during 2021.

 – We enabled over 30,000 colleagues to 
progress their careers at the Group by 
helping them move into new roles.

HSBC Holdings plc Annual Report and Accounts 2021

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Strategic reportStrategic report | How we do business

Engaging with our stakeholders and our material ESG topics 

Engaging with our stakeholders is core to being a responsible business. To determine material topics that our stakeholders are interested in, we 
conduct a number of activities throughout the year, including engagements outlined in the table below. Disclosure standards such as the TCFD, 
World Economic Forum (‘WEF’) Stakeholder Capitalism Metrics and Sustainability Accounting Standards Board (‘SASB’), as well as the ESG Guide 
under the Hong Kong Stock Exchange Listing Rules and other applicable rules and regulations, are considered as part of the identification of 
material issues and disclosures.

Our stakeholders How we engage

Material topics highlighted by the engagement1

Customers

Our customers’ voices are heard through our interactions with them, 
surveys and by listening to their complaints

 – Customer advocacy

 – Cybersecurity

Communities

We welcome dialogue with external stakeholders, including non-
governmental organisations (‘NGOs’) and other civil societies groups. We 
engage directly on specific issues and by taking part in external forums and 
working groups

Employees

Our colleagues’ voices are heard through our employee Snapshot survey, 
Exchange meetings and our ‘speak-up’ channels, including our global 
whistleblowing platform, HSBC Confidential

Investors

We engage with our shareholders through our AGMs, virtual and in-person 
meetings, conferences and our annual investor survey

 – Financial inclusion and community investment

 – Diversity and inclusion, in particular gender and ethnicity 

profile and pay gap 

 – Employee training

 – Coal financing policies

 – Becoming a net zero bank in our own operations and 

financed emissions

Regulators and 
governments

We proactively engage with regulators and governments to facilitate strong 
relationships via virtual and in-person meetings, responses to consultations 
individually and jointly via the industry bodies

 – Anti-bribery and corruption

Suppliers

Our ethical and environmental code of conduct for suppliers of goods and 
services sets out how we engage with our suppliers on ethical and 
environmental performance

 – Supply chain management

1  Material topics highlighted through the engagement form part of our ESG disclosures suite together with other requirements and are not exhaustive or exclusive to 
one stakeholder group. For further details on our disclosures, see our ESG review and ESG Data Pack, as well as our ESG reporting centre at www.hsbc.com/esg.

Supporting our stakeholders through 
Covid-19
The Covid-19 pandemic continues to create 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. 

The pandemic continued to pose significant 
challenges for our customers. Our immediate 
priority has been to do what we can to provide 
them with support and flexibility. We 
continued to take 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.

Employee well-being remains a top priority 
as we transition to new ways of working and 
continue to navigate through the pandemic. 
The support we provide is driven by the 
feedback from our people surveys. In 2021, 
we launched new tools and training to 
support mental, physical and financial health. 
We are also enabling more colleagues to work 
flexibly and continue to follow social 

distancing and protection measures in line 
with local guidance. We firmly believe that 
helping our people to be healthy and happy 
is a key enabler of our strategy, and benefits 
the people and communities we serve.

We continued to engage with our investors 
virtually and restarted face-to-face meetings 
where local guidance allowed.

We also donated a further $11.5m towards 
Covid-19 relief efforts to support the 
communities in which we operate, primarily 
in India.

Our COP26 actions

COP26, the UN climate change conference 
held in Glasgow, Scotland, in November, was 
a critical moment for the financial sector, 
including HSBC, to demonstrate how we are 
helping to accelerate the transition to net 
zero. The Glasgow Financial Alliance for Net 
Zero, which we are part of, announced 
potentially transformative measures for the 
sector, including setting short-term 
science-based targets, annual reporting of 
progress, embedding climate risk 
management into businesses, and mobilising 
transition finance for emerging and 
developing countries.

Our delegation, including our Group Chief 
Sustainability Officer, Celine Herweijer 
(pictured here at COP26) was involved in 

a series of major announcements around 
finance, energy transition, sustainable 
infrastructure and nature. This included 
joining the Powering Past Coal Alliance, a 
global coalition of countries, cities, regions 
and businesses focused on tackling the 
challenge of ending the world’s reliance on 
coal. We also announced that we are 
supporting the Asian Development Bank in 
the pioneering Energy Transition Mechanism 
initiative, which is working with developing 
countries on early retirement of coal power 
assets and unlocking new investment in 
clean energy, while supporting reskilling of 
workers in directly affected communities.

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HSBC Holdings plc Annual Report and Accounts 2021

How we do business

Our ESG ambitions, metrics and targets

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

The 2021 annual incentive scorecards of the 
Group Chief Executive, Group Chief Financial 
Officer and Group Executives contain customer 

and employee measures linked to the outcomes 
that underpin the ESG metrics below. These 
carry a 30% weighting in the scorecards of the 
Group Chief Executive and Group Chief 
Financial Officer. In addition, a 25% weighting 
is given to environment and sustainable finance 
measures in the 2020 and 2021 long-term 
incentive (‘LTI’) scorecards, which have 
three-year performance periods ending on 
31 December 2023 and 31 December 2024, 
respectively. The targets for these measures 
are linked to our climate ambition of achieving 
net zero in our operations and supply chain by 

2030 and supporting our clients in their 
transition to net zero and a sustainable future. 
For a summary of how all financial and 
non-financial metrics link to executive 
remuneration outcomes, see pages 261 
to 273 in the Directors’ remuneration report. 

The table below sets out how we have made 
progress against the following ESG-related 
ambitions and targets.

Ambition/target

Progress to date

Environmental

Becoming a net zero bank

Ambition to align our financed emissions 
to achieve net zero by 2050 or sooner

Disclosed interim targets for the oil and gas, 
and power and utilities sectors (for further 
details, see page 47)

Published thermal coal phase-out policy 
(for further details, see page 62)

Supporting our customers

Social

Customer satisfaction

Employee engagement

Employee gender diversity

Employee ethnicity diversity

Governance

Global conduct

Ambition to be net zero in our own 
operations and supply chain by 2030 
or sooner

50.3% cumulative reduction in absolute 
operational greenhouse gas emissions 
from 2019 baseline1

Ambition to support our customers in their 
transition to net zero and a sustainable future 
with $750bn to $1tn of sustainable finance 
and investment by 2030

Cumulative progress of $126.7bn 
since 20202

Target to be ranked top three and/or improve 
customer satisfaction rank

Target to maintain employee engagement 
score at 72%

Target to reach 35% women in senior 
leadership roles by the end of 2025

6 out of 10 WPB markets sustained 
top-three rank and/or improved rank 
in customer satisfaction3

4 out of 13 CMB markets sustained 
top-three rank and/or improved rank 
in customer satisfaction3

Employee engagement score of 72%4

Women in senior leadership roles of 31.7%5

Target to at least double the number of 
Black senior leaders by 2025

Increased number of Black senior leaders 
by 17.5% from 2020 baseline5

Target to achieve at least 98% of employees 
complete conduct and financial crime 
training each year

99% of staff completed training6

1  This absolute greenhouse gas emission figure covers scope 1, scope 2 and scope 3 (business travel) emissions. The data for 2019 and 2020 has been revised as we 
have updated our air travel reporting methodology to include the cabin class travel and the impact of radiative forces. For further details, see the ESG review on 
page 52. For further details on how this target links with the scorecards, see page 261.

2  In October 2020, we announced our ambition to provide and facilitate between $750bn to $1tn of sustainable finance and investment by 2030. For further details 

and breakdown, see the ESG review on page 43. For details on how this target links with the scorecards, see page 261.

3  Rank position reported for markets where net promoter score (‘NPS’) is live. In WPB, markets comprised: the UK, Hong Kong, Malaysia, Singapore, mainland 

China, Australia, UAE, Canada, Mexico and the US. In CMB, markets comprised: the UK, Hong Kong, Malaysia, Singapore, Pearl River Delta, mainland China, India, 
Indonesia, Australia, UAE, Canada, Mexico and the US. For further details on customer satisfaction, see the ESG review on page 67. For further details on how this 
target links with the scorecards, see page 269.

4 For further details, see the ESG review on page 75. For details on how this target links with the scorecards, see page 269.
5  Senior leadership is classified as those at band 3 and above in our global career band structure. Ethnicity target progress tracked from 31 December 2020 baseline. 

For further details, see the ESG review on page 72. For details on how this target links with the scorecards, see page 269.

6  The completion rate shown relates to the 2021 'Fighting financial crime' training module. The latest global regulatory conduct training has been launched in 

January 2022 and will run through the first quarter of 2022.

HSBC Holdings plc Annual Report and Accounts 2021

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Strategic reportStrategic report | How we do business

How we measure our net zero progress

One of our strategic pillars is to support the 
transition to a net zero global economy. We 
believe our most significant contribution will be 
to align our financed emissions to the Paris 
Agreement goal to achieve net zero by 2050 or 
sooner. The Paris Agreement aims to limit the 
rise in global temperatures to well below 2°C, 
preferably to 1.5°C, above pre-industrial levels. 
To limit the rise in global temperatures to 1.5°C, 
the global economy would need to reach net 
zero greenhouse gas emissions by 2050.

In May 2021, a climate change resolution 
proposed by the Board was backed by more 
than 99% of our shareholders at our AGM. 
The resolution included a commitment to set 
out the next steps in our transition to net 
zero, including setting sector-based targets, 
publishing a thermal coal phase-out policy and 
reporting annually on our progress. We also 

indicated that we would provide further details 
on our approach to assessing financed 
emissions by the end of 2021. 

We have set on-balance sheet financed 
emissions 2030 targets for the oil and gas, and 
power and utilities sectors, focusing on the 
companies within these sectors which we 
believe account for the majority of emissions 
in the sector. For further details including 
scope, methodology, assumptions and 
limitations, see page 47.

In the year ahead we plan to set interim targets 
for financed emissions across a wide range of 
sectors, alongside a broad transformation 
programme to embed the climate transition 
into our core business and risk processes. 
We will also begin work on our climate 
transition plan, which will bring together – 
in one place – how we plan to embed our net 
zero targets into the Group’s strategy, 
processes, policies and governance. We plan 
to publish this in 2023, and update on progress 
annually thereafter.

We continue to track our progress against our 
ambition to provide and facilitate $750bn to 
$1tn of sustainable finance and investment by 
2030, aligned to our published data dictionary, 
and our transformation to a net zero bank by 
reducing our operations and our supply chain 
emissions to net zero by 2030. 

We know this is a journey and recognise that 
certain metrics and targets may need to be 
revised as a result of changes or developments 
in methodology, climate science and 
improvements in data quality. In the following 
table, we set out our metrics and indicators 
and assess our progress against them.

Ambition

Metrics and indicators

Progress to date

Becoming a net zero bank1
Align our financed emissions to achieve net zero 
by 2050 or sooner

 – Absolute emissions for oil and gas sector

(Mt CO2e)

 – Physical emissions intensity for power and

utilities sector (Mt CO2e/TWh)

 – Percentage of wholesale loans and

advances in high transition risk sectors

 – Thermal coal financing exposure ($)

 – Illustrative impacts of climate scenarios

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

 – Absolute operational greenhouse gas

emissions (tonnes CO2e)

Supporting our customers
Support our customers in their transition to net 
zero and a sustainable future
Unlocking new climate solutions 
Help transform sustainable infrastructure into 
a global asset class, and create a pipeline 
of bankable projects

 – Percentage of renewable electricity

sourced (GWh)

 – Energy consumption (GWh)

 – Sustainable finance and investment

provided and facilitated ($bn)

 – Natural capital investment

 – Climate technology investment

 – Philanthropic investment to climate

innovation ventures, renewable energy,
and nature-based solutions

Set a Mt CO2e target of 34% reduction 
in oil and gas absolute on-balance sheet 
financed emissions by 2030 from 2019 
baseline (see page 47)
Set a target for power and utilities on-
balance sheet financed emissions intensity 
of 0.14 Mt CO2e/ TWh, representing 75% 
reduction by 2030 from 2019 baseline 
(see page 47)
≤20.0% of wholesale loans and 
advances to high transition risk sectors 
at 31 December 2021

Expanded the transition risk questionnaire 
to cover more sectors (see page 133)
Published a thermal coal phase-out policy 
incorporating a target to reduce exposure 
to thermal coal financing by at least 25% 
by 2025, and by 50% by 2030, using 2020 
data as the baseline
Ran our first climate stress test, covering 
our wholesale corporate lending, 
commercial real estate, retail mortgages 
and our own properties (see page 57)
50.3% cumulative reduction in absolute 
greenhouse gas emissions from 
2019 baseline 
Remained stable from 37.4% in 2020 
to 37.5%
20.6% cumulative reduction in energy 
consumption from 2019 baseline
$126.7bn cumulative progress since 2020 
(for further breakdown see page 53)

Climate Asset Management is one of the 
three founding partners of Natural Capital 
Investment Alliance, which aims to 
mobilise $10bn towards natural capital 
themes (see page 55)
Lending commitments of $65m and raised 
our target to $250m (see page 55)
Provided $28.4m to our NGO partners 
since 2020, as part of the Climate Solutions 
Partnership (see page 77)

1  Our reported scope 3 greenhouse gas emissions of our own operations in 2021 is related to business travel. The data for 2019 and 2020 has been revised as we 

have updated our air travel reporting methodology to include the cabin class travel and the impact of radiative forces. For further details on scope 1, 2 and 3, and 
our progress on greenhouse gas emissions and renewable energy targets, see page 51 and our ESG Data Pack at www.hsbc.com/esg.

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HSBC Holdings plc Annual Report and Accounts 2021

How we do business

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

 – We do not fully disclose impacts on 
financial planning and performance 
(including proportions of revenue, costs 
and balance sheet related to climate-related 
opportunities), quantitative scenario 
analysis, detailed climate risk exposures for 
all sectors and geographies or physical risk 
metrics. This is due to transitional challenges 
in relation to data limitations. We expect 
these data limitations to be addressed in 
the medium term as more reliable data 
becomes available and technology 
solutions are implemented.

 – We currently disclose partial scope 3 

greenhouse gas emissions. In relation to 
on-balance sheet financed emissions, we 
are disclosing our scope 3 greenhouse gas 
emissions for oil and gas, and the power and 
utilities sectors. Future disclosure on scope 
3 financed emissions (customers) and 
supply chain emissions (suppliers), as well 
as related risks is reliant on both our 
customers and suppliers publicly disclosing 
their carbon emissions and related risks. 
We aim to disclose financed emissions for 
additional sectors by 2023, as set out in 
our Financed Emissions – Approach and 
Methodology Update published in 
December 2021, which can be found at 
www.hsbc.com/who-we-are/esg-and-
responsible-business/esg-reporting-centre.

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. We recognise that further work lies 
ahead as we develop our management and 
metrics capabilities.

The information set out on page 63 in this 
Annual Report and Accounts 2021 aims to 
provide key climate-related information and 
cross-references to where additional 
information can be found. In this context, 
we have considered our ‘comply or explain’ 
obligation under the UK’s Financial Conduct 
Authority’s Listing Rules, and confirm that we 
have made disclosures consistent with the 
TCFD Recommendations and Recommended 
Disclosures in this Annual Report and 
Accounts 2021 save for certain items, which 
we summarise below and describe in more 
detail in the information set out on page 63 
and in the additional information section 
on page 402.

There are certain areas where we have not 
included climate-related disclosures, a 
summary of these are set out below:

 – Given that climate scenarios are mainly 

focused on medium- to long-term horizons, 
rather than short-term, we have set interim 
2030 targets for on-balance sheet financed 
emissions for the oil and gas and power and 
utilities sectors. HSBC intends to review the 
financed emissions baseline and targets 
annually, where relevant, to help ensure that 
they are aligned with market practice and 
current climate science.

Leading on an inaugural 
green bond

We were joint lead manager and 
bookrunner as Arab Petroleum 
Investments Corporation (‘APICORP’) in 
September 2021 raised $750m with its 
inaugural green bond. The multilateral 
development bank, founded in 1975 by 
the 10 Arab oil-exporting countries, has 
a strategic focus to promote the energy 
sector within the region to a more 
sustainable future. As set out in its 
green bond framework, APICORP will 
use the proceeds to finance or invest in 
projects focused on renewable energy, 
pollution prevention and control, and 
green buildings.

Supporting renewable projects  
through our operations

We are expanding our efforts to bring additional renewable 
electricity in the markets where we operate, as part of our 
ambition to source 100% renewable power across our operations 
by 2030. In September 2021, we signed a power purchase 
agreement that supported the development of the Sorbie Wind 
Farm project in Ayrshire, south-west of Glasgow. This agreement 
will create a new renewable electricity source that will benefit us, 
as well as our customers and the wider communities we serve.

This power purchase agreement will be our fourth project in the 
UK, supporting wind or solar projects, and will result in 
approximately 90% of our UK electricity being sourced from 
such renewable projects. 

HSBC Holdings plc Annual Report and Accounts 2021

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Strategic report | 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.

Employee matters 
We are opening up a world of opportunity for 
our colleagues through building an inclusive 
organisation that values difference, takes 
responsibility, and seeks different perspectives 
for the overall benefit of our customers.

We want to encourage a dynamic culture where 
our colleagues can expect to be treated with 
dignity and respect. We are an organisation that 
takes action where we find behaviours that fall 
short of this aspiration. We monitor our progress 
through metrics that we value and have 
benchmarked against peers. 

Listening to our colleagues is critical to the 
business we conduct, and is reflected in our 
purpose and values, which were established 
through the largest employee engagement 
programme in our history. 

We continue to seek innovative ways that 
encourage and provide opportunities for our 
people to speak up. We recognise that at times 
people may not feel comfortable speaking up 
through the usual channels. HSBC Confidential 
is our global whistleblowing channel, allowing 
our colleagues past and present to raise 
concerns confidentially and, if preferred, 
anonymously (subject to local laws). 

Having surpassed our 2020 target to reach 30% 
women in senior leadership roles (classified as 
those at band 3 and above in our global career 
band structure), we aim to reach 35% by 2025, 
with 31.7% achieved in 2021. 

In July 2020, we set out our early global race 
commitments, which included the goal of 
doubling the number of Black employees in 
senior roles over the next five years. To support 
our ambition, we have placed a strong focus on 
enhancing the quality and transparency of our 
ethnicity data through the expansion of our 

self-identification capability. We will use this 
data to develop market-specific goals that are 
connected to the communities we serve. While 
we know we need to do more, we have put in 
place important foundations in 2021 through 
leadership development, inclusive hiring 
practices and investing in the next generation of 
high-performing, diverse talent. 

The table below outlines high-level 
diversity metrics. 

All employees

Male

Female

Senior leadership1

Male

Female

Directors

Male

Female

48%

52%

68%

32%

62%

38%

1  Senior leadership is classified as those at band 3 
and above 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 70.

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 climate solutions and 
innovation, and contribute to disaster relief 
based on need. For further details of our 
programmes see 'Communities' on page 77.

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, is available on www.hsbc.com/who-we-
are/esg-and-responsible-business/esg-
reporting-centre.

Anti-corruption and anti-bribery
We require compliance with all applicable 
anti-bribery and corruption laws in all markets 
and jurisdictions in which we operate. These 
include the UK Bribery Act, the US Foreign 
Corrupt Practices Act, the Hong Kong 
Prevention of Bribery Ordinance and France’s 
'Sapin II' law. 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 our commitment 
to ethical behaviours and conduct as part of 
our environmental, social and corporate 
governance.

Environmental matters
For details of our climate ambition and 
carbon emission metrics, see the ESG review 
on page 45.

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.

Engaging colleagues in future skills

Our colleagues have explored digital, data, sustainability and 
personal skills as part of our ‘Future Skills’ campaign. Colleagues 
engaged with various tools, assessments and industry experts 
over 44,000 times throughout the campaign, and learned how 
these skills are critical for the future of our organisation. 
Colleagues identified specific skills they wanted to develop and 
assessed them through our skills platform to shape their 
development plan.

We helped a number of colleagues to share their own skills with 
others through our partnership with Ashoka. In 2021 we 
launched the global Green Skills Innovation Challenge to support 
innovations that connect people with the skills to support a green 
transition. Out of 340 submissions, 12 winners were selected, 
each receiving a prize of up to $20,000 alongside support and 
mentoring from HSBC colleagues.

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HSBC Holdings plc Annual Report and Accounts 2021

Board decision making and engagement with stakeholders

Board decision making and 
engagement with stakeholders

The Board is committed to effective engagement with all our stakeholders and seeks  
to understand the interests of and impacts on them when making decisions.

Section 172 (1) statement

This section, from pages 21 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 key considerations for the Board

The Group continued to focus on its 
engagement with our key stakeholders, 
acknowledging that this engagement is core 
to being a responsible business. Our key 
stakeholders remain the same as last year, 
namely our customers, employees, investors, 
communities, regulators and governments, 
and suppliers. How the Group has engaged 
with our stakeholders more generally is 
explained on page 16. The Board recognises 
the importance of building strong relationships 
with our stakeholders to help broaden 
understanding of their needs and concerns 
and ultimately to help us deliver our strategy. 
In discharging its responsibilities, the Directors 
sought to understand, and have regard to, the 
interests and priorities of these stakeholders, 
including in relation to material decisions that 
were taken by the Board during the course 
of the year.

Virtual and physical meetings
During 2021, despite the ongoing logistical 
challenges of meeting physically as a result 
of the Covid-19 pandemic, the Board was 
determined to maintain an active engagement 
programme with as many stakeholders as 
possible. The move to virtual meetings 
presented new and effective opportunities 
to engage. The Board met virtually with one 
of our major suppliers of technology services 
on the US west coast, which provided 
insights into technological advances and the 
growing importance of data management and 
security. During this meeting, the participants 
shared their respective views on the net zero 
transition journey, and the Board was able 
to gain a clear understanding of the 
supplier’s plans. 

Several Board members were also able to 
connect with our global graduate community 
on occasion, thanks to virtual facilities. 
Meeting in this way meant a far broader set of 
views was able to be shared than if the 

meeting had been in person. The exchanges 
with the graduates gave the Directors a real 
appreciation of the challenges they had faced 
in joining and working for HSBC during 
lockdown conditions. 

As part of the engagement programme 
during the year, the Board continued to meet 
directly with many of its other stakeholders, 
in particular our colleagues, regulators and 
investors. It was also kept informed of relevant 
stakeholder matters through management 
dialogue and reports. Where circumstances 
permitted, Board members gathered for 
stakeholder meetings in person, including 
at our offices in the UK and Hong Kong, 
with examples of these engagements 
detailed below.

In May 2021, HSBC was pleased to be able to 
host its first hybrid AGM and engage with its 
investors despite the challenges at the time. 
Following focused discussions, the Board 
committed to creating an opportunity to 
enable as much shareholder participation as 
possible. This event allowed shareholders to 
either physically attend the meeting under 
strict and safe conditions in line with the 
advice from the UK Government, or to attend 
virtually, together with all Board members 
who attended either physically or virtually. The 
virtual participation option offered through the 
hybrid solution allowed shareholders to ask 
questions of the Board in person, by telephone 
and online, as well as vote live by electronic 
means during the meeting. While restrictions 
meant, regrettably, it was not possible to hold 
the annual Informal Shareholders’ Meeting in 
Hong Kong, the hybrid AGM helped facilitate 
the connection of our Hong Kong-based 
shareholders directly to the Board. Given the 
success of the hybrid approach, we intend to 
host hybrid AGM meetings in the future.

Engaging during the Covid-19 pandemic
The Covid-19 pandemic continued to underpin 
the need to ensure careful consideration of the 
interests of the Group’s stakeholders. 
Throughout the year, the Board maintained 
close interaction with management on its 
plans for a gradual return to office working 
under safe conditions, and careful 
consideration was given to our support for 
colleagues’ mental and physical well-being. 
Care was taken to include the views and 
opinions of our colleagues in developing new 
ways of working, including hybrid working 
solutions where appropriate. By engaging 
with colleagues, including graduates, the 
Board was able to discuss and reflect, both 
in and outside of the boardroom, on the 
learnings gained from such sessions, including 
on how to improve induction and ongoing 
employee support programmes. It was also 
able to give its support to management to 
continue these initiatives.

Doing business responsibly
Given the nature of our business, maintaining 
a transparent and trusting relationship with 
our regulators is key to helping to ensure that 
we do business responsibly and that we can 
respond to all challenges appropriately. 
The Group Chairman and the Group Chief 
Executive met with our regulators in the UK 
and Hong Kong on a regular basis. As part of 
such meetings, our regulators were kept 
updated on our strategic plans and progress. 
On certain occasions, the Group Chairman 
and the Group Chief Executive also met with 
government officials globally to foster good 
relations. Several Board members were – and 
continue to be – actively involved in climate 
initiatives and attend global events such as at 
the COP26 Summit in Glasgow. The Board 
also remained informed of management 
interaction with national governments, on 
matters such as forbearance schemes and 
climate matters. 

HSBC Holdings plc Annual Report and Accounts 2021

21

Strategic reportStrategic report | Board decision making and engagement with stakeholders

Stakeholder engagement and key considerations for the Board continued

The Board and its committees reviewed and 
considered regular reporting on emerging 
risks, performance, execution and actions 
being taken in response. This regular reporting 
and an annual programme of learning served 
to inform the Board about stakeholder matters 
and supported its decision making. For further 
details on the Board’s activities during the 
year, including training, see pages 229 to 234. 
The impact of the Covid-19 pandemic on the 
Group and our stakeholders remained of 
material concern. The impact of the decision 
taken in 2020 to cancel the fourth interim 
dividend for 2019 and suspend dividends for 
2020 was a key consideration when the Board 
was deliberating on its approach to 
distributions for 2021. The Board sought to 
balance emerging risks, performance and its 
duties to shareholders, while remaining 

conscious of its responsibilities to support 
communities and help customers manage 
financial challenges and changing demands. 
The 'Principal decisions' disclosure below 
includes details on how the Board took the 
decision to introduce dividend payments in 
2021. Further details are also provided in 
‘Financial decisions’ on page 232 and 
‘Dividends’ on page 287.

To educate the Board on the broader impacts 
of the Covid-19 pandemic, the Board invited a 
leading immunologist to its meeting in 
December. Through this engagement, the 
Board gained valuable independent insight 
into what assistance may be required globally 
in support of the recovery to our communities, 
customers, suppliers and employees.

Adapting our engagement programme
As restrictions are lifted, and when safe to 
do so, the Board intends to meet regularly 
in person both as a Board, and with our 
stakeholders globally. In the meantime, the 
Board continues to remain agile in adapting 
its ongoing engagement programme so that 
it continues to be informed by a broad range 
of activities with stakeholders. This helps the 
Board fulfil its duties and support decision 
making as it oversees the execution of the 
Group strategy in line with our purpose and 
values and strategic plans. Examples of how 
the Board has engaged with stakeholders 
are set out below, as well as in ‘Board 
engagement with shareholders’ on page 228 
and ‘Workforce engagement’ on page 233.

Customers

Employees

Investors

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 help support them to 
achieve their financial aims and succeed in our 
purpose and strategy. Examples of Board 
engagement with customers in 2021 included:

 – The Group Chairman met on a very regular 
basis with customers, globally, for a variety 
of reasons including to hear customer 
feedback, build relationships, and 
strengthen connectivity between our 
customers, businesses and functions.

 – The Group Chairman met with and listened 
to a number of key clients in person in the 
US, UK and Hong Kong.

 – The Group Chief Executive provided reports
to the Board, which contained updates on 
key customer meetings, sentiment, and net 
promoter scores for each global business. 
The net promoter score is a key 
measurement of customer sentiment, 
satisfaction and areas of concern and 
improvement.

 – Following an enhancement to digital 

chat services for customers in Bermuda, 
the Board requested feedback from 
customers gained through a satisfaction 
survey and real-time customer prompts to 
help shape improvements in automation 
across the Group.

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 it. 
Examples of the Board’s engagement with our 
employees in 2021 included:

 – Our Directors partnered with each of our 

employee resource groups, supporting and 
attending employee resource group events.
These included sessions covering diversity, 
inclusion, disability, ethnicity and gender, 
the pandemic, climate, purpose and values, 
and culture. Following these events, the 
Board, in its formal meetings, discussed its 
learnings and where further support could 
be offered. 

 – Twice a year, the Board discussed the 

results of Snapshot surveys, which provide 
employee feedback, and which in 2021 
focused on home working, culture, 
behaviours and pay. 

 – The Group Chairman visited Hong Kong in 
July and August, where he met with local 
leadership and took time to hear from a 
group of over 500 employees.

 – The Group Chief Executive reported to the 
Board on his engagement with colleagues, 
including discussions about the return to the 
office, culture, new joiners, purpose and 
values, female leadership and graduate 
induction. His engagements also included 
virtual exchange sessions and town halls 
with employees globally, and in person in 
Singapore and the US.

 – The Group Chief Risk and Compliance 

Officer provided a weekly Board note on 
risk matters relating to our response to 
the Covid-19 pandemic and employee 
support initiatives.

We seek to understand investor needs 
through ongoing dialogue. Examples of 
the Board engaging with investors in 
2021 included:

 – The Board discussed external market 

sentiment and invited our corporate brokers
to share their thoughts and perceptions.

 – Directors held virtual and in-person 

meetings with investors, ratings agencies
and peers to understand evolving views, 
trends and sentiment.

 – The Group Chairman visited Hong Kong 

during July and August where he spent time 
with several of our shareholders in person. 

 – The Chair of the Group Remuneration 
Committee held meetings with key 
investors, including to discuss the new 
remuneration policy.

 – Investor Relations provided weekly updates 
to the Board, including on market activity, 
investor engagement and sentiment.

 – Numerous investor and corporate 

governance roadshows, forums and 
meetings with key investors took place and 
were hosted by a combination of the Group 
Chairman, Group Chief Executive, Group 
Chief Financial Officer and the Senior 
Independent non-executive Director, and 
often with management in attendance.

22

HSBC Holdings plc Annual Report and Accounts 2021

Board decision making and engagement with stakeholders

Stakeholder engagement and key considerations for the Board continued

Communities

Regulators and governments

Suppliers

We seek to play an important role in 
supporting the communities in which we 
operate through our corporate social 
responsibility and broader engagement 
activities. Examples of the Board’s 
engagement with communities in 2021 
included:

Maintaining constructive dialogue and 
relations with the relevant authorities in the 
markets in which we operate helps support 
the effective functioning of economies globally 
and the achievement of our strategic aims. 
Examples of the Board’s engagement with 
regulators and governments in 2021 included:

 – The Board received ESG and climate-related 

– Executive and non-executive Directors 

attended ‘continuous assessment’ meetings 
with the UK’s Prudential Regulation 
Authority ('PRA’) and other individual 
regulatory meetings.

– The PRA attended a Board meeting for its 

annual presentation to discuss the outcome 
and progress of its periodic summary 
meeting letter, and in a separate meeting, the 
UK’s Financial Conduct Authority (‘FCA’) 
attended to present its annual firm evaluation 
letter.

– The Group Chairman led a meeting with 
the supervisory college of regulators.

– Directors held regular dialogue and meetings 
with governments and regulators globally, 
with some representing HSBC at 
government-led forums.

– The Group Chairman and Group Chief 

Executive both participated at the G7 Climate 
conference and COP26.

updates and policies, which detailed 
community engagement activity and 
stakeholder sentiment.

 – The Group Chairman and Group Chief 

Executive both participated at COP26, and 
the Group Chairman presented at Chapter 
Zero events.

 – The Group Chief Executive supported 

the World Economic Forum’s disclosures
on climate.

 – The Board supported employee resource 

group community initiatives, such as 
introducing 'safe places' in selected HSBC 
branches for the whole community as 
needed, and education in schools and 
universities on topics such as technology 
and climate.

 – A leading immunologist provided an update
to the Board on the impact of the Covid-19 
pandemic, providing insight into what 
assistance may be required from HSBC to 
our communities, customers and 
employees.

Principal decisions

Our suppliers provide the Group with vital 
resources, expertise and services to help us 
operate our business effectively and execute 
our strategy. We work with our suppliers to 
help ensure mutually beneficial relationships 
on a global and local level. In some cases, our 
suppliers are also our customers. Plans have 
been made to meet with more third-party 
providers of services once travel can safely 
resume. Examples of the Board’s engagement 
with suppliers in 2021 included:

 – The Group Chief Operating Officer 
provided reports to the Board, with 
updates on third-party suppliers and 
operational resilience.

 – Directors held a virtual meeting with one 

of our key technology suppliers to discuss 
technology developments and 
improvements and to better understand 
the supplier’s net zero ambition and 
transition plans.

 – The Group Audit Committee Chair met 

with the four major accountancy firms and 
challenger audit firms in preparation for 
a future audit tender.

The Board operates having regard to the duties of the Directors, including the relevant matters set out in section 172(1)(a)-(f) of the Companies Act 
2006. Specific examples of key areas of focus and considerations affecting the Board’s decision-making process during 2021 are set out below.

Acquisitions and disposals activity 

During 2021, the Board took several key 
decisions to acquire and divest certain 
businesses in support of the Group’s 
strategic aims.

In furtherance of the Group’s strategy and ambition, 
the Board considered several material and strategic 
acquisition and disposal opportunities throughout 
2021. Two of these opportunities considered by the 
Board are highlighted below. In each case, in 
discussing these proposals and taking its decisions, 
members of the Board exercised their statutory 
duties including the duty to act in the way that they 
considered, in good faith, would be most likely to 
promote the success of the company for the benefit 
of its members as a whole.

The first strategic acquisition opportunity the Board 
considered in 2021 concerned the purchase of 
AXA’s insurance business in Singapore. In its 
meeting, the Board discussed that this was a rare 
opportunity for inorganic growth and a key step in 
helping to achieve the Group’s ambition of becoming 
a leading wealth manager in Asia, by expanding its 
insurance and wealth franchise in Singapore, a 
strategically important scale market and a major hub 

for the Group’s wealth business in the ASEAN 
region. The Board considered a number of benefits 
in making this investment, including synergies with 
the Group’s asset management and private wealth 
solutions business, and the ability to materially scale 
up the Group’s presence in the regional insurance 
market, providing an excellent platform for future 
growth and further opportunities for customers. The 
proposed acquisition was subject to a combination 
of discussions with and approvals from various 
stakeholders, including UK, Singapore and Hong 
Kong regulators as well as pre-notifications to local 
union authorities. In order to support successful 
integration and transformation plans, management 
recommended to the Board that key employee talent 
should be identified and secured. As part of this key 
talent selection process, certain important skills and 
qualities were taken into account, including diversity 
and inclusion, as well as culture, to form the right 
leadership team for the acquired business to 
succeed. In making its final decision to approve the 
acquisition, the Board took these relevant 
stakeholder considerations and other factors into 
account, including an assessment of the financial 
merits and risks of the transaction, and paid 
particular attention to the section 172 factors of the 
likely consequences of any decision in the long term 
and the interests of the Group’s employees.

The Board subsequently considered a separate 
proposal for the disposal of the Group's non-core 
retail banking business in France. The Board’s 

decision to approve the disposal was aligned 
to the Group’s strategic aim of being a leading 
wholesale bank in continental Europe, and took 
into account the impact on our shareholders and 
other stakeholders.

In this case, the Board considered there to be a 
number of benefits to the disposal, including 
simplifying the Group structure, helping to mitigate 
transformation risk of the business in Europe, and 
allowing management to focus on the completion of 
the European wholesale transformation programme. 
Several key stakeholders were consulted ahead of 
the decision. Consultation with relevant French 
works’ councils was undertaken alongside Director 
and management engagement with French and UK 
regulators to elicit their views on the proposed 
disposal. The Board noted that completion of the 
disposal would involve engagement with additional 
key stakeholders, including relevant regulators and 
bondholders. In taking its decision, the Board 
considered all relevant factors including the Group’s 
strategic goals and the benefits of the transaction, 
while also taking into account the loss associated 
with the disposal, the interests of stakeholders and 
alternative proposals in respect of the retail business. 
As a result, the Board agreed to proceed with the 
disposal on the basis that it considered it to be in 
the best interests of the company’s members as 
a whole and would promote the long-term success 
of the company.

HSBC Holdings plc Annual Report and Accounts 2021

23

Strategic reportStrategic report | Board decision making and engagement with stakeholders

Principal decisions continued

Climate agenda

In 2021 the Board was actively and 
directly engaged with the Group’s 
response to the climate change agenda, 
proposing a resolution and agreeing 
relevant policies aligned to our ambition 
to support the transition to a net zero 
global economy.

Following the announcement of the Group’s climate 
ambition in October 2020 and ahead of the 2021 
AGM, the Board received a shareholder requisitioned 
resolution from ShareAction, together with a number 
of other shareholders, in relation to the Group’s 
climate agenda. Selected Board members and senior 
management engaged extensively with ShareAction, 
certain co-filers and other shareholders, to 
understand their perspectives and rationale in 
submitting the shareholder resolution. As a result 
of such engagements, the Board carried out further 
discussions in its meetings to consider our approach 
in terms of sectorial priorities and associated 
timelines, in order to help support the delivery of our 
climate ambition most effectively, while recognising 
our responsibilities to our customers and 
communities across the diverse range of markets 
in which we operate. Ultimately, following further 
engagement and discussion, the Board welcomed 
and agreed the decision by ShareAction, on behalf 
of the co-filers, to withdraw the requisitioned 
resolution and in its place, support HSBC’s own 
climate change resolution at the 2021 AGM. The 
HSBC resolution outlined the next phase of the 
Group’s net zero strategy, with a particular emphasis 
on how it would support its customers on their own 
transition journeys. As well as the engagement with 

Dividend payments and share buy-backs 

Following the decision in 2020 to cancel 
dividend payments, the Board took action 
in 2021 to consider dividend payments, 
the Group’s dividend policy and share 
buy-backs.

Following the PRA’s announcement in December 
2020 that it was supportive of UK banks resuming 
dividend payments under certain conditions, at its 
first meeting in January 2021 the Board turned its 
attention to whether it would be appropriate to 
restart dividend payments. In considering this, the 
Board reflected on the impact on the decision it took 
in 2020 to suspend dividend payments and the views 
of stakeholders in respect of the suspension. The 
reactions and interests of our investors based on 
feedback from our external brokers and meetings 
with investors by individual Board members and 
management were key considerations for the Board 
in considering whether to restart dividend payments, 
especially given the impact of this decision on our 
shareholders, including those based in Hong Kong, 
who rely heavily on the income derived from our 
dividends. The Board also had regard to regulatory 
considerations, including the PRA’s requirements for 
banks resuming dividends and other relevant factors 
such as our financial performance for 2020 and our 
earnings forecasts for 2021 and 2022. Having 

stakeholders, in formulating the Group’s climate 
approach including its climate change resolution, 
the Board took into consideration the role we seek 
to play in setting and leading a standard for the 
financial services sector, as it collectively works to 
tackle climate change. The Board was also mindful 
of the crucial importance of working with customers 
on their own transition and how the Group could 
help support this outcome. The Board’s decision to 
propose the HSBC climate change resolution and 
recommendation that shareholders vote in favour of 
it took account of these reasons, and gave due 
regard to section 172 factors, in particular the impact 
of the decision on the environment and communities 
the company serves, our valuable relationships with 
customers and investors, and the long-term success 
of the company.

The climate change resolution was passed at the 
2021 AGM, with 99.7% of our shareholders 
supporting our resolution, providing a strong 
endorsement of our climate plan and our 
commitment to support our customers on their 
transitions to a low-carbon future. The resolution 
committed us to: setting out the next steps in our 
transition, including through short- and medium-
term sector-based targets; publishing a policy to 
phase out the financing of coal power and thermal 
coal mining by 2030 in EU and OECD countries, and 
by 2040 globally; and reporting annually on our 
progress. We also indicated that we would provide 
further details by the end of 2021 on our approach 
to assessing financed emissions and setting targets.

In December 2021 the Board approved the 
publication of the thermal coal phase-out policy, and 
further details on our approach to assessing financed 
emissions and setting targets. In doing so the Board 
took into consideration the requirements of the 
climate resolution and the extensive engagement 
with stakeholders, both before and after the 2021 

AGM. In Board meeting discussions, Directors 
considered long-term objectives including the 
responsibility of helping to ensure continued and 
expanding access to affordable electricity in the 
markets we serve, many of which are presently 
highly reliant on thermal coal. The Board also 
considered the need to phase out the financing 
of coal-fired power and thermal coal mining in 
recognition of the rapid decline in coal emissions 
required for any viable pathway to 1.5˚C and the 
important role for HSBC to play in helping to finance 
our clients’ transition to net zero. The Board noted 
that the policy was a key part of executing the 
Group’s ambition to align its financed emissions to 
net zero by 2050 or sooner and would be reviewed 
annually based on evolving science and 
internationally recognised guidance, given the fast 
changing landscape. For further details on our 
policy and approach, see page 62.

Since publication of the thermal coal phase-out 
policy, stakeholder engagement has continued, 
including with key institutional investors to discuss 
with them the policy, its impacts and alignment with 
our ambition to help finance our clients’ transition to 
net zero. Extensive engagement also continues to 
take place among employees and with clients as 
we implement the policy.

In their respective roles as chair of Chapter Zero and 
chair of the Financial Services Taskforce, both the 
Group Chairman and the Group Chief Executive are 
at the forefront of climate matters, demonstrating 
their leadership and commitment to understanding 
and collaborating on these critical matters, mirroring 
the Board’s and the Group’s commitment to the 
transition to net zero as a key part of delivering 
our strategy.

considered these factors and also taking into 
account its section 172 duty to consider the likely 
consequences of any decision in the long term, in 
its February meeting, the Board was pleased to 
approve an interim dividend for the full-year ending 
2020. In that same meeting, the Board considered 
and approved a revised dividend policy designed to 
provide sustainable dividends. In considering the 
revised dividend policy, the Board discussed and 
acknowledged the need to offer good income to our 
investors while giving management the flexibility to 
reinvest capital to grow the firm. These factors are 
important to the long-term success of the company. 
During the year, engagement continued with the 
PRA for dividends in respect of the 2021 financial 
year. In August 2021, the Board also agreed to 
approve an interim dividend for the first six months 
of 2021 in line with the dividend policy, taking into 
account the Group’s performance, market 
expectations and the shareholders’ interests.

the UK and Hong Kong, as well as views and inputs 
with regards to customer, employee, investor and 
community stakeholder considerations. Together, 
these inputs enabled the Board to conclude that the 
share buy-back would likely be viewed positively by 
the market and be considered to represent an 
appropriate balance between shareholder return and 
investment. The Board’s assessment of our capital 
position took account of the company’s ability to 
conduct its business and to support the communities 
in which it serves. Taking these stakeholder views 
and other relevant matters into account as 
prescribed by section 172, including our strong 
capital position and notwithstanding the growth 
opportunities available to us at the time of the 
decision, the Board considered that a return of 
capital by way of share buy-back would be in the 
best interests of investors as a whole having regard 
to the long-term success of the company and 
thereby approved the share buy-back.

In addition, having indicated in the Annual Report 
and Accounts 2020 that the Group would consider 
share buy-backs over time, in October 2021 the 
Board approved the announcement of a share 
buy-back of up to $2bn. In reaching this decision, 
the Board considered our actual and potential 
financial performance during the year to date and 
our capital position (including in light of regulatory 
requirements). The Board also considered expected 
reactions and interests of our investors (including 
based on feedback from our external brokers) and 
peer analysis. Regulatory approvals were sought in 

24

HSBC Holdings plc Annual Report and Accounts 2021

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 2021 to help 
ensure remuneration outcomes were consistent with those principles, 
see page 278. 

The 2021 Group variable pay pool has been determined taking into 
account the improvement in financial performance, with adjusted profit 
before tax up 79%, the reinstatement of dividends and the capital return 
to shareholders through share buy-backs, as well as performance 
against the strategic plan. It also took into account the challenges the 
Group faces with regard to a very competitive market for talent. 

 For details of how the Group Remuneration Committee sets the pool, 
see page 254.

Remuneration for our executive Directors

Our current 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. We are proposing to roll forward our 
current remuneration policy for shareholders’ approval at the 2022 
AGM. We have made no changes to the remuneration structure or to 
the maximum opportunity payable for each element of remuneration. 
Details of the proposed policy can be found on page 257. Variable pay 
for our executive Directors is driven by scorecard achievement, with 
measures and targets set to align pay outcomes with the delivery of our 
strategy and plan for the year.

Single figure of remuneration

(£000)

Base salary1

Fixed pay allowance ('FPA')1

Cash in lieu of pension

Taxable benefits2

Non-taxable benefits2

Total fixed

Annual incentive3

Notional returns4

Replacement award5

Total variable

Total fixed and variable

($m)

2021

2020

3,495

2,659

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

2019

Group Chief Executive

Group Chief Financial Officer

57.30%

60.43%

The table below shows the amount our executive Directors earned in 
2021. For details of Directors’ pay and performance for 2021, see the 
Directors’ remuneration report on page 254.

Noel Quinn

Ewen Stevenson

2021

1,288

1,700

129

95

71

3,283

1,590

22

—

1,612

4,895

2020

 1,266 

 1,700 

 127 

 186 

 59 

 3,338 

 799 

 17 

 — 

 816 

 4,154 

2021

751

1,062

75

3

42

1,933

978

—

754

1,732

3,665

2020

 738 

 950 

 74 

 12 

 32 

 1,806 

 450 

 — 

 1,431 

 1,881 

 3,687 

1  Executive Directors made the personal decision to donate 100% of their base salary increases for 2021 to charity given the ongoing challenging external environment. 

Ewen Stevenson also donated his FPA increase for 2021 to charity. Figures shown in the table above are the gross figures before charitable donations. 

2  Taxable benefits include the provision of medical insurance, 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. 

3  Noel Quinn and Ewen Stevenson both voluntarily waived the cash portion of their 2020 annual incentive. Without this voluntary waiver, the 2020 annual incentive 

of Noel Quinn and Ewen Stevenson would have been £1,598,000 and £900,000, respectively. 

4  The deferred cash awards granted in prior years includes a right to receive notional returns for the period between the grant and vesting date. This is determined 

by reference to a rate of return specified at the time of grant and paid annually, with the amount disclosed on a paid basis. 

5  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. The values included in the table for 2020 relate to his 2017 LTI 
award granted by the Royal Bank of Scotland Group plc ('RBS'), now renamed as NatWest Group plc ('NatWest'), for performance year 2016, which was 
determined by applying the performance assessment outcome of 56.25% as disclosed in NatWest'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 NatWest 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. The value included in the table 
for 2021 relates to Ewen Stevenson's 2018 LTI replacement award granted by NatWest for performance year 2017 and was subject to a pre-vest performance 
test assessed and disclosed by NatWest in its Annual Report and Accounts 2020 (page 135). As no adjustment was proposed for Ewen Stevenson by NatWest, 
a total of 177,883 shares granted in respect of his 2018 LTI replacement award ceased to be subject to performance conditions. These awards were granted at 
a share price of £6.643 and the HSBC share price was £4.240 when the awards ceased to be subject to performance conditions, with no value attributable to 
share price appreciation.

HSBC Holdings plc Annual Report and Accounts 2021

25

Strategic report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 2021 was supported 
by the improved economic outlook and 
resultant release in ECL allowances, which 
materially improved our profitability. While 
lower policy rates adversely impacted revenue 
compared with 2020, the interest rate outlook 
is now significantly more positive.

Reported profit before tax of $18.9bn 
increased by 115%, while our return on 
average tangible equity (‘RoTE’) improved by 

5.2 percentage points to 8.3%. The growth in 
reported profit was due to a net release of 
ECL, compared with a significant charge in 
2020, as well as an increase in share of profit 
from associates and joint ventures, while 
reported operating expenses remained 
broadly unchanged. These factors were partly 
offset by lower reported revenue.

In 2021, all of our regions were profitable. 
Notwithstanding lower policy rates, our Asia 

business continued to perform strongly, 
delivering 65% of Group reported profits, 
while there was a material recovery in 
profitability in all of our other regions.

The Group maintained its strong capital 
position, with a CET1 ratio of 15.8% at 
31 December 2021, and increased both 
customer deposit and lending balances.

Group financial targets

Return on average tangible equity

Adjusted operating expenses

Capital and dividend policy

8.3%

(2020: 3.1%)

$32.1bn

(2020: $32.4bn)

In February 2020, we announced a multi-year 
plan to substantially reduce the cost base 
and accelerate the pace of change, with 
the aim of becoming leaner, simpler and 
more competitive.

During 2021, we continued to demonstrate 
strong cost control, with adjusted operating 
expenses of $32.1bn, a reduction of 1% 
compared with 2020. 

Adjusted operating expenses for 2022 are 
expected to be in line with 2021, with 
inflationary impacts, continued investment 
and the impact of acquisitions and disposals 
broadly offset by further savings from our 
cost-reduction programme. This compares 
with our original target of $31bn or less 
(based on average December 2020 rates 
of foreign exchange).

Our cost reduction programme remains 
on track to deliver cost saves of between 
$5bn and $5.5bn in the period from 2020 
to 2022, while spending around $7bn in 
costs to achieve.

Cumulatively, since the start of our cost 
programme in 2020, we have generated 
savings of $3.3bn, with costs to achieve of 
$3.6bn, which included actions to restructure 
our businesses in Europe and the US.

The Group is targeting a reported RoTE 
greater than or equal to 10% in the medium 
term. In 2021, RoTE was 8.3%, an increase of 
5.2 percentage points from 2020, primarily 
reflecting net releases of ECL. Our net 
interest income outlook is now significantly 
more positive. If policy rates were to follow 
the current implied market consensus, we 
would expect to deliver a RoTE of at least 
10% for 2023.

Gross RWA reductions

$104bn

Since the start of the programme.

To improve the return profile of the Group, we 
are targeting a gross RWA reduction, mainly in 
low-returning parts of the Group.

During 2021, we updated the list of clients we 
are remediating and also implemented other 
methodology changes to improve how we 
align the tracking and reporting of reductions 
to how the programme is being managed. In 
line with these changes, we also increased our 
gross RWA reduction target from $100bn to 
$110bn by the end of 2022, updating executive 
scorecards accordingly.

At 31 December 2021, the Group had achieved 
cumulative RWA reductions of $104bn since 
the start of the programme, including 
accelerated saves of $9.6bn made in 2019. 
Given progress to date, we now expect to 
exceed our $110bn reduction target by the 
end of 2022.

.
26

HSBC Holdings plc Annual Report and Accounts 2021

CET1 ratio

15.8%

Dividend payout ratio

40.3%

At 31 December 2021, our CET1 ratio was 
15.8%. We expect mid-single-digit RWA 
growth in 2022 through a combination of 
business growth, acquisitions and regulatory 
changes, partly offset by additional RWA 
savings. This growth, together with capital 
returns are expected to normalise our CET1 
position to be within our 14% to 14.5% target 
operating range during 2022. Once we are 
within the target operating range, we intend 
to actively manage our CET1 position to stay 
within this range. However, due to normal 
capital volatility, we may be above or below 
this range in any given quarter. Our ambition 
remains to manage this operating range down 
in the longer term.

The Board has approved a second interim 
dividend for 2021 of $0.18 per ordinary share. 
The total dividend per share in 2021 of $0.25 
results in a dividend payout ratio of 40.3% of 
reported earnings per share (‘EPS’), relative to 
our target range of between 40% and 55% 
from 2022 onwards. We also intend to initiate 
a further share buy-back of up to $1bn, to 
commence after the existing up to $2bn 
buy-back has concluded.

In line with our dividend policy, we retain the 
flexibility to adjust EPS for non-cash significant 
items. In 2022, we intend to adjust EPS to 
exclude the forecast loss on the planned sale 
of our retail banking operations in France.

Financial overview

Reported results

Reported profit 
Reported profit after tax of $14.7bn was 
$8.6bn higher than in 2020.

Reported profit before tax of $18.9bn was 
$10.1bn higher than in 2020. The increase was 
primarily due to a net release in reported ECL, 
reflecting an improvement in the forward 
economic outlook, notably in the UK, 
compared with the significant build-up of 
stage 1 and stage 2 allowances in 2020. We 
also reported an increase in the share of profit 
from associates, while reported operating 
expenses remained broadly unchanged.

Lower reported revenue primarily reflected the 
impact of 2020 global interest rate reductions, 
as well as a decline in revenue in GBM’s 
Markets and Securities Services ('MSS') 
business compared with a strong performance 
in 2020. Reported revenue also included the 
net favourable impact of certain volatile items:

 – In WPB, favourable market impacts in life

insurance manufacturing of $504m
compared with favourable movements
in 2020 of $90m.

 – In GBM, MSS included favourable

movements in credit and funding valuation
adjustments, as favourable adjustments of
$30m compared with adverse adjustments
of $252m in 2020.

 – In Corporate Centre, there were adverse fair
value movements on our long-term debt 
and associated swaps of $99m (2020: 
$150m favourable).

In 2021, all of our regions were profitable. 
Despite the impact of lower global interest 
rates, our Asia business continued to perform 
strongly. In addition, there was a material 
recovery in profitability in all other regions, 
primarily reflecting a net release in ECL as the 
economic outlook improved.

IFRS 17 ‘Insurance Contracts’ sets the 
requirements that an entity should apply in 
accounting for insurance contracts it issues 
and reinsurance contracts it holds. IFRS 17 is 
effective from 1 January 2023 and could have 
a significant adverse impact on the profitability 
of our insurance business. For further details 
on the impact of IFRS 17 on the results of our 
insurance operations, see page 318.

Reported revenue
Reported revenue of $49.6bn was $0.9bn or 
2% lower than in 2020. The reduction primarily 
reflected a fall in net interest income as a result 
of the impact of lower global interest rates, 
notably affecting our deposit franchises in 
WPB and in Global Liquidity and Cash 
Management (‘GLCM’) in CMB and GBM. In 
GBM’s MSS business, revenue decreased in 
Global Foreign Exchange and Global Debt 
Markets, compared with a strong 2020, 
although revenue increased in Equities from 
higher volatility and there were favourable 
movements in credit and funding valuation 
adjustments. In addition, revenue was lower in 
Corporate Centre.

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

These reductions were in part mitigated by 
revenue growth in Wealth in WPB of $1.2bn, 
notably from a net favourable movement in 
market impacts in life insurance 
manufacturing, and growth in investment 
distribution, asset management and new 
business in insurance. GBM revenue also 
benefited from favourable valuation gains in 
Principal Investments. In CMB, revenue 
increased in Credit and Lending as margins 
improved, and a recovery in trade volumes 
resulted in higher fee income in Global Trade 
and Receivables Finance (‘GTRF’). 

The reduction in reported revenue included 
adverse fair value movements on financial 
instruments of $0.5bn, although these were 
more than offset by the favourable impact 
of foreign currency translation differences 
of $1.4bn.

Reported ECL
Reported ECL were a net release of $0.9bn, 
compared with a charge of $8.8bn in 2020. 
The net release in 2021 reflected an 
improvement in the economic outlook, notably 
in the UK, partly offset by an increase in 
allowances in the fourth quarter, reflecting 
recent developments in China’s commercial 
real estate sector. This compared with the 
significant build-up of stage 1 and stage 2 
allowances in 2020 due to the worsening 
economic outlook at the onset of the Covid-19 
pandemic. The reduction in ECL also reflected 
historically low levels of stage 3 charges, 
although with some normalisation during the 
fourth quarter, as well as the non-recurrence 
of a significant charge in 2020 related to a 
corporate exposure in Singapore.

For further details on the calculation of ECL, 
including the measurement uncertainties and 
significant judgements applied to such 
calculations, the impact of the economic 
scenarios and management judgemental 
adjustments, see pages 144 to 152.

2021

$m

2020

$m

2019

$m

49,552

 50,429 

 56,098 

928

 (8,817)

 (2,756)

50,480

(34,620)

15,860

3,046

18,906

(4,213)

14,693

 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 

Reported operating expenses
Reported operating expenses of $34.6bn 
were broadly unchanged compared with 
2020. This included the impact of our cost 
saving initiatives, as well as lower impairments 
of goodwill and other intangible assets, as 
2021 included a $0.6bn impairment of 
goodwill related to our WPB business in Latin 
America to reflect the macroeconomic 
outlook, as well as the impact of foreign 
exchange rate deterioration and inflationary 
pressures, notably on our Argentina business. 
However, 2020 included a $1.3bn impairment 
of intangible assets, mainly in Europe. There 
was also a $0.6bn reduction in the UK bank 
levy due to a change in the basis of calculation 
to only include the UK balance sheet rather 
than the global balance sheet, as well as a 
credit of $0.1bn relating to the 2020 charge. 

These decreases were broadly offset by an 
increase in performance-related pay of 
$0.7bn as Group performance improved, and 
by an increase in investment in technology 
of $0.9bn (gross of cost savings of $0.5bn). 
The remaining increase primarily reflected 
inflationary impacts, non-technology 
investment in regulatory programmes, and 
business growth notably Asia wealth 
investment. In addition, there was an adverse 
impact of foreign currency translation 
differences of $1.1bn.

In February 2020, we announced a plan to 
substantially reduce the cost base by 2022 
and accelerate the pace of change. We 
continue to target $5bn to $5.5bn of cost 
saves for 2020 to 2022, while spending around 
$7bn in costs to achieve, which are included in 
restructuring and other related costs. 
Cumulative spend since the start of the 
programme in 2020 was $3.6bn, with 
cumulative saves of $3.3bn. In 2021, the total 
spend was $1.8bn with saves during the year 
of $2.2bn.

HSBC Holdings plc Annual Report and Accounts 2021

27

Strategic reportStrategic report | Financial overview

Reported results continued

Reported share of profit from associates 
and joint ventures
Reported share of profit in associates and joint 
ventures of $3.0bn was $1.4bn higher, 
primarily reflecting a higher share of profit 
from Bank of Communications Co., Limited 
(‘BoCom’), British Growth Fund (‘BGF’) and 
The Saudi British Bank (‘SABB’). For BGF in 
the UK, this was due to a recovery in asset 

valuations relative to 2020, and for SABB, 
this was primarily due to the non-recurrence 
of our share of its goodwill impairment 
charge in 2020.

Tax expense
The effective tax rate for 2021 of 22.3% was 
lower than the 30.5% for 2020. The effective 
tax rate for 2021 was increased by the impact 

Adjusted performance

Our reported results are prepared in 
accordance with IFRSs, as detailed in the 
financial statements on page 318.

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 
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.

of substantively enacted legislation to increase 
the UK statutory tax rate from 1 April 2023. 
The 2020 effective tax rate was high, due 
mainly to the non-recognition of deferred tax 
on losses in the UK and France.

 For reconciliations of our reported results to an 
adjusted basis, including lists of significant items, 
see page 98. Definitions and calculations of other 
alternative performance measures are included 
in our ‘Reconciliation of alternative performance 
measures’ on page 90 and ‘Reconciliation of 
alternative performance measures’ on page 117.

Adjusted results

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

2021

$m

2020

$m

2019

$m

2021 vs 2020

$m

50,090

 51,770 

 56,435 

(1,680)

Change in expected credit losses and other credit impairment charges 

928

 (9,282)

 (2,687)

10,210

%

(3)

110

1

87

39

79

2021

$m

2020

$m

2019

$m

18,906

 8,777 

 13,347 

—

 (11)

 240

3,010

 3,505 

 9,094 

—

38

—

242

587

—

 — 

(33)

 10 

 158 

 1,444 

 (768)

(264)

 (84)

 1,090 

 7,349 

 17 

 — 

(32,148)

 (32,409)

 (33,563)

261

18,870

 10,079 

 20,185 

8,791

3,046

 2,192 

 2,496 

854

21,916

 12,271 

 22,681 

9,645

Reconciliation of reported to adjusted profit before tax

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 $21.9bn was 
$9.6bn or 79% higher than in 2020, primarily 
due to a net release of adjusted ECL due to 
an improvement in the economic outlook, 
notably in the UK, compared with the 
significant build-up of stage 1 and stage 2 
allowances in 2020. Adjusted share of profit 
from associates and joint ventures increased 
and adjusted operating expenses fell, 
reflecting strong cost discipline.

Reported profit before tax

Currency translation

Significant items:

 – costs of structural reform

 – customer redress programmes

These factors were in part offset by lower 
adjusted revenue, primarily reflecting a fall 
in net interest income as a result of the impact 
of lower global interest rates and a reduction 
in MSS revenue in GBM, compared with a 
strong performance in 2020.

 – disposals, acquisitions and investment

in new businesses

 – fair value movements on financial instruments

 – impairment of goodwill and other intangibles

 – past service costs of guaranteed minimum pension

benefits equalisation

 – restructuring and other related costs

2,143

 2,078 

 – 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

—

—

—

 827 

 (61)

 12 

 462 

 — 

 133 

 229 

Adjusted profit before tax

21,916

 12,271 

 22,681 

28

HSBC Holdings plc Annual Report and Accounts 2021

 
Financial overview

Adjusted performance continued

Adjusted revenue
Adjusted revenue of $50.1bn was $1.7bn or 3% 
lower than in 2020. The reduction was 
primarily in net interest income due to the 
impact of lower global interest rates, mainly 
affecting our deposit franchises within WPB 
and in GLCM in CMB and GBM. In GBM’s MSS 
business, revenue decreased in Global Foreign 
Exchange and Global Debt Markets, compared 
with a strong 2020, although revenue 
increased in Equities from higher volatility and 
there were favourable movements in credit and 
funding valuation adjustments of $301m. In 
addition, revenue was lower in Corporate 
Centre from a net adverse fair value movement 
relating to the economic hedging of interest 
rate and exchange rate risk on our long-term 
debt with associated swaps.

These reductions were in part mitigated by 
revenue growth of $1.1bn in Wealth in WPB, 
notably from a net favourable movement in 
market impacts in life insurance manufacturing 
of $434m, and growth in investment 
distribution, asset management and new 
business in insurance. In GBM, there were 
higher favourable revaluations in Principal 
Investments compared with 2020, and 
increased revenue in Capital Markets and 
Advisory. In CMB, revenue grew in Credit and 
Lending as margins improved, and a recovery 
in trade volumes resulted in higher fee income 
in GTRF.

Balance sheet and capital

Balance sheet strength
At 31 December 2021, our total assets of 
$3.0tn were $26bn or 1% lower than at 31 
December 2020 on a reported basis and 
included adverse effects of foreign currency 
translation differences of $46bn.

The decrease in total assets reflected lower 
derivative assets and a fall in financial 
investments, reflecting a redeployment of our 
commercial surplus into cash, which rose by 
$99bn, in part due to higher customer 
deposits. Loans and advances to customers 
increased by $8bn on a reported basis and 
$23bn on a constant currency basis, mainly 
from growth in mortgage balances.

Reported loans and advances to customers 
of $1.0tn were 61.1% as a percentage of 
customer accounts, compared with 63.2% at 
31 December 2020, primarily reflecting growth 
in customer account balances.

Adjusted ECL
Adjusted ECL, which removes the period-on-
period effects of foreign currency translation 
differences, were a net release of $0.9bn 
compared with a charge of $9.3bn in 2020. 
These reflected releases as a result of an 
improvement in the economic outlook, notably 
in the UK, partly offset by an increase in 
allowances in the fourth quarter, reflecting 
recent developments in China’s commercial 
real estate sector. This compared with the 
significant build-up of stage 1 and stage 2 
allowances in 2020 due to the worsening 
economic outlook at the onset of the Covid-19 
pandemic. The reduction in ECL also reflected 
historically low levels of stage 3 charges in 
2021, although with some normalisation 
during the fourth quarter, as well as the 
non-recurrence of a significant stage 3 
charge in 2020 related to a corporate 
exposure in Singapore.

Adjusted operating expenses
Adjusted operating expenses of $32.1bn were 
$0.3bn or 1% lower than in 2020. This 
reflected a favourable impact of $2.2bn from 
our cost-saving initiatives. It also included a 
reduction of $0.6bn in the UK bank levy, 
reflecting a change in the basis of calculation 
to only include the UK balance sheet rather 
than the global balance sheet, as well as a 
credit of $0.1bn relating to the 2020 charge. 

Distributable reserves
The distributable reserves of HSBC Holdings 
at 31 December 2021 were $32.2bn, 
compared with $31.3bn at 31 December 2020. 
The increase was primarily driven by profits 
generated of $10.8bn, offset by ordinary 
dividend payments and additional tier 1 
coupon distributions of $5.8bn, other reserves 
movements of $2.1bn and $2bn related to our 
share buy-back programme.

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

Total assets
($bn)

$2,958bn

Common equity tier 1 ratio
(%)

15.8%

2021

2020

2019

2019

2,958

2021

2,984

2020

2,715

2019

2019

15.8

15.9

14.7

These reductions were partly offset by a 
higher performance-related pay of $0.7bn as 
Group performance improved, and an increase 
of $0.9bn in investment in technology (gross 
of cost savings of $0.5bn), which included 
enhancements to our digital capabilities. 
The remaining increase included inflation, 
non-technology investment in regulatory 
programmes and business growth, including 
Asia wealth investment.

The number of employees expressed in full-time 
equivalent staff (‘FTE’) at 31 December 2021 
was 219,697, a decrease of 6,362 compared 
with 31 December 2020. The number of 
contractors at 31 December 2021 was 6,192, 
an increase of 500, primarily as a result of our 
growth and transformation initiatives.

Adjusted share of profit from associates 
and JVs
Adjusted share of profit from associates and 
joint ventures of $3.0bn was $0.9bn or 39% 
higher than in 2020, including increases in 
share of profits from BoCom and SABB. Our 
share of profit also rose from BGF in the UK 
due to a recovery in asset valuations relative 
to 2020.

constraints 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 189.

Our CET1 ratio at 31 December 2021 was 
15.8%, down 0.1 percentage points from 
2020. Capital generation was more than offset 
by dividends, the up to $2bn share buy-back 
announced in October, foreign exchange 
movements and other deductions. RWAs 
reduced despite new Pillar 1 requirements for 
structural foreign exchange, reflecting actions 
under our transformation programme.

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 2021, we held high-quality liquid 
assets of $717bn. This excludes high-quality 
liquid assets in legal entities which are not 
transferable due to local restrictions. 

 For further details, see page 193.

HSBC Holdings plc Annual Report and Accounts 2021

29

Strategic reportStrategic report | Global businesses

Wealth and  
Personal Banking

Contribution to Group adjusted profit 
before tax   

$7.0bn
(32%)

We serve more than 38 million customers 
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.

WPB grew customer deposits, lending and 
wealth sales, as markets emerged from the 
pandemic in 2021. Performance was 
favourably impacted by a net release of 
adjusted ECL provisions and strong wealth 
sales in Asia, although adjusted revenue was 
affected by the impact of lower interest rates, 
despite strong balance sheet growth. Aligned 
with our strategy, we continued to invest in 
our digital capabilities and people to expand 
our wealth franchise in Asia, and address our 
customers’ international needs.

Adjusted results

2021

$m

2020

$m

2019

$m

Net operating income

 22,110 

 22,571 

 26,140 

2021 vs 2020

$m

(461)

%

(2)

Change in expected credit 
losses and other credit 
impairment charges

 288 

 (3,005)

 (1,376)

 3,293 

 110 

Operating expenses

(15,384)

 (15,443)

 (15,823)

 59 

 – 

Share of profit in  
associates and JVs

Profit before tax

RoTE excluding  
significant items (%)1

 34 

 7 

 54 

 27  >200

 7,048 

 4,130 

 8,995 

 2,918 

 71 

15.2

 9.1 

 19.7 

1  Since 1 January 2021, the UK bank levy has been included in the calculation of this measure. Comparative 

data have not been re-presented.

Opening up the gateway to 
international banking

We are making it easier than ever for our customers to manage their 
money around the world. 

Global Money Account, our multi-currency account for personal 
customers, allows customers to hold, manage and send cash in 
various currencies without paying any fees. Having launched Global 
Money in the US in 2020, we expanded these capabilities into the 
UAE, Singapore and the Channel Islands and Isle of Man in 2021, 
and we aim to double the number of markets in 2022. 

Our international account opening is getting simpler. It is now 
possible to open accounts in mainland China and either Singapore 
or the UK, in the same visit to a branch, and 80% faster than in 2020. 
Hong Kong identity card holders in Australia, Canada, Singapore, 
the US and the UK can now open an account online in 10 minutes, 
down from four weeks, with immediate access to mobile banking.

30

HSBC Holdings plc Annual Report and Accounts 2021

Global businesses | Wealth and Personal Banking

Management view of adjusted revenue

Wealth

 – investment distribution1

 – Global Private Banking

net interest income

non-interest income

 – life insurance manufacturing2

 – asset management

Personal Banking

 – net interest income1

 – non-interest income

Other2,3

Net operating income4

2021

$m

9,123

3,488

1,826

647

1,179

2,590

1,219

12,254

10,858

1,396

733

22,110

2020

$m

8,004

3,252

1,789

688

1,101

1,890

1,073

13,330

12,070

1,260

1,237

22,571

2019

$m

8,923

3,322

1,917

911

1,006

2,632

1,052

16,068

14,381

1,687

1,149

26,140

2021 vs 2020

$m

1,119

236

37

(41)

78

700

146

(1,076)

(1,212)

136

(504)

(461)

%

14 

7 

2 

(6)

7 

37 

14 

(8)

(10)

11 

(41)

(2)

1  In the fourth quarter of 2021, revenue of $62m for the full-year related to wealth lending was moved from Personal Banking to investment distribution. Comparative 

data have not been re-presented. 

2  In the fourth quarter of 2021, revenue of $53m for the full-year, primarily related to interest on capital held in our insurance business, was moved from ‘Other’ to life 

insurance manufacturing (2020: $79m, 2019: $144m). Comparative data have been re-presented.

3  ‘Other’ includes the distribution (where applicable) of retail and credit protection insurance, disposal gains and other non-product specific income. It also includes 

allocated revenue from Markets Treasury, HSBC Holdings interest expense and Argentina hyperinflation.

4 ’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

$1.7tn

WPB wealth balances at 31 December 2021, 
up 5% from 31 December 2020 with net new 
invested assets of $64bn. 

$23bn

Growth in WPB mortgage book, notably in 
the UK (up 7%) and Hong Kong (up 7%) since 
31 December 2020.

Adjusted profit before tax
($bn)

$7.0bn

2021

2020

2019

2019
Net operating income
($bn)

$22.1bn

2021

2020

2019

2019

7.0

4.1

9.0

22.1

22.6

26.1

Financial performance
Adjusted profit before tax of $7.0bn was 
$2.9bn or 71% higher than in 2020. This 
reflected a net release of adjusted ECL as the 
economic outlook improved, compared with 
the significant build-up of allowances in 2020. 
Adjusted revenue fell as the impact of lower 
global interest rates resulted in a decrease in 
net interest income. This was partly offset by 
an increase in Wealth revenue of $1.1bn due 
to a net favourable movement of $434m in 
market impacts in insurance, higher new 
business in insurance (up $0.3bn), as well as 
growth in investment distribution (up $0.2bn) 
and asset management (up $0.1bn).

Adjusted revenue of $22.1bn was $0.5bn or 
2% lower.

In Personal Banking, revenue of $12.3bn was 
down $1.1bn or 8%.

 – Net interest income was $1.2bn lower due to
narrower margins following the fall in global
interest rates in 2020 due to the Covid-19
pandemic. This reduction was partly
mitigated by deposit balance growth of
$29bn or 4% and higher retail mortgage
lending of $22bn or 7% across all regions,
particularly in the UK and Hong Kong.

 – Non-interest income increased by $0.1bn or
11%, driven by growth of mortgage fees in
the UK and higher transaction volumes and
spending on cards.

In Wealth, revenue of $9.1bn was up $1.1bn 
or 14%.

 – Life insurance manufacturing revenue was
$0.7bn higher, driven by a net favourable
movement in market impacts of $434m. A
favourable movement of $504m compared
with a favourable movement of $70m in

2020, as equity markets performed strongly 
in 2021 compared with volatile conditions 
in 2020. The value of new business written 
was $0.3bn or 41% higher, reflecting market 
share growth, notably in Hong Kong, where 
we continued to scale up our health 
platforms and significantly broadened 
engagement with domestic customers.

 – Investment distribution revenue was $0.2bn
or 7% higher, driven by higher mutual fund
sales in Hong Kong and mainland China.

 – Asset management revenue was $0.1bn
or 14% higher, driven by an increase in
management fees, reflecting growth of
$28bn in invested assets, and higher
performance fees.

 – Global Private Banking revenue was $37m
or 2% higher due to growth in non-interest
income of $78m or 7% driven by a rise in
investment revenue, reflecting higher fees
from advisory and discretionary mandates.
This was partly offset by a reduction in net
interest income of $41m or 6% as a result of
the impact of lower global interest rates.

In Other, revenue fell by $0.5bn, reflecting a 
reduction in revenue allocated from Markets 
Treasury, lower interest income earned on 
capital held in the business and adverse 
valuations on properties.

Adjusted ECL were a net release of $0.3bn, 
reflecting an improvement in the economic 
outlook. This compared with a charge of 
$3.0bn in 2020 due to the significant 
build-up of allowances as a result of the 
Covid-19 pandemic.

Adjusted operating expenses of $15.4bn were 
$0.1bn lower, as the benefits of our cost-
saving initiatives funded our continued 
investment in wealth in Asia and offset higher 
performance-related pay.

HSBC Holdings plc Annual Report and Accounts 2021

31

Strategic reportStrategic report | Global businesses 

Commercial Banking

Contribution to Group adjusted profit 
before tax   

$6.7bn
(31%)

We support businesses in 53 countries 
and territories, ranging from small 
enterprises to large companies 
operating globally.  

We help businesses grow by supporting 
their financial needs, facilitating cross-
border trade and payment services, and 
providing access to products and 
services. We help them access 
international markets, provide expert 
financial advice and offer a full suite 
of products and services from across 
the Group’s other businesses.

CMB supported our customers’ liquidity and 
working capital needs, growing lending and 
deposit balances in 2021. We enabled our 
clients to participate in the recovery in global 
trade volumes while dealing with supply chain 
constraints, increasing our fee income and 
trade-related lending. We also more than 
doubled our sustainable finance and 
investment compared with 2020. Performance 
was favourably impacted by the net release of 
adjusted ECL provisions, partly offset by the 
impact of lower interest rates globally on 
adjusted revenue. 

Adjusted results 

2021

$m

2020

$m

2019

$m

Net operating income

13,415

13,718

15,594

2021 vs 2020

$m

(303)

%

(2)

Change in expected credit 
losses and other credit 
impairment charges

300

(4,989)

(1,194)

5,289

 106 

Operating expenses

(6,973)

(6,897)

(7,028)

(76)

(1)

Share of profit in 
associates and JVs

Profit before tax

1

(1)

1

2  200 

6,743

1,831

7,373

4,912  >200

RoTE excluding significant 
items (%)1

10.8

1.3

13.0

1  Since 1 January 2021, the UK bank levy has been included in the calculation of this measure. Comparative 

data have not been re-presented.

Supporting SMEs on the move

HSBC Kinetic provides cutting edge technology solutions to our 
customers and opens up a world of opportunity for small 
businesses. Launched on Apple’s App store in 2020, Kinetic is an 
app-based business account that allows sole traders and other 
small and medium-sized enterprises to apply for an account in 
minutes and manage their finances on the go. Onboarding is fast, 
with 87% of accounts approved within 48 hours during the second 
half of 2021. A range of new features and services have been added 
to the app throughout the year, which include credit cards, digital 
cheque deposits, a cashflow toolkit and predictive smart alerts 
informing customers about critical cash shortfalls in advance.

Designed using insights from over 3,000 small and medium-sized 
enterprises, we brought Kinetic to 21,000 additional customers 
during 2021, reaching 24,000 users at the end of 2021, achieving 
an Apple rating of 4.8.

32

HSBC Holdings plc Annual Report and Accounts 2021

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

 – of which: share of revenue for Markets and Securities

Services and Banking products

2021

$m

1,945

6,052

3,575

1,843

1,065

2020

$m

1,784

5,828

4,252

1,854

950

2019

$m

1,876

5,617

6,066

2,035

965

Net operating income2

13,415

13,718

15,594

2021 vs 2020

$m

161

224

(677)

(11)

115

(303)

%

9

4 

(16)

(1)

 12 

(2)

1  Includes CMB’s share of revenue from the sale of Markets and Securities Services and Banking products to CMB customers. GBM’s share of revenue from the sale 

of these products to CMB customers is included within the corresponding lines of the GBM management view of adjusted revenue. Also includes allocated 
revenue from Markets Treasury, HSBC Holdings interest expense and Argentina hyperinflation.

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

Adjusted ECL were a net release of $0.3bn, 
compared with a charge of $5.0bn in 2020. 
ECL in 2021 reflected a release of stage 1 and 
stage 2 allowances as the economic outlook 
improved, notably in the UK, although ECL 
were a net charge of $0.2bn in the fourth 
quarter, including an increase in allowances 
relating to recent developments in China’s 
commercial real estate sector. This compared 
with the significant build-up of allowances in 
2020 as a result of the adverse economic 
outlook due to the Covid-19 pandemic. The 
reduction in ECL also included lower stage 3 
charges in 2021, and as 2020 included a 
significant charge related to a corporate 
exposure in Singapore. 

Adjusted operating expenses of $7.0bn were 
$0.1bn or 1% higher, primarily reflecting an 
increase in performance-related pay. We 
continued to invest in our digital and 
transactional banking capabilities, as well 
as simplifying customer journeys for both 
onboarding and lending, and enhancing 
self-service capabilities. These investments 
helped us drive operational and hiring 
efficiencies, resulting in cost reductions, in 
addition to the impact of our cost-saving 
initiatives. From 2021, the UK bank levy was 
partially allocated to global businesses, which 
was previously retained in Corporate Centre, 
resulting in an additional $47m of operating 
expenses in 2021.

During 2021, we delivered $13bn of gross 
RWA reductions, taking our cumulative total 
to $26bn since January 2020, as part of our 
transformation programme.

Divisional highlights

9%

Growth in adjusted net fee income from 
$3.3bn in 2020 to $3.6bn in 2021, rising 
above pre-pandemic levels.

30%

Growth in GTRF lending from $44.4bn in 
2020 to $57.6bn in 2021, growing to above 
pre-pandemic levels.

Adjusted profit before tax
($bn)

$6.7bn

2021

2020

2019

2019
Net operating income
($bn)

$13.4bn

2021

2020

2019

2019

6.7

1.8

7.4

13.4

13.7

15.6

Financial performance
Adjusted profit before tax of $6.7bn was 
$4.9bn higher than in 2020. This reflected a 
net release of adjusted ECL of $0.3bn in 2021 
as the economic outlook improved, compared 
with a charge of $5.0bn in 2020 due to a 
significant build-up of allowances and a 
notable charge related to a corporate exposure 
in Singapore. This was partly offset by a 
decline in adjusted revenue, mainly due to the 
impact of lower global interest rates.

Adjusted revenue of $13.4bn was $0.3bn or 
2% lower.

 – In GLCM, revenue decreased by $0.7bn or
16%, reflecting the impact of lower global
interest rates, mainly in Hong Kong and the
UK. This was partly offset by a 14% increase
in year-on-year average deposit balances,
with growth particularly in Hong Kong, the
UK and the US, as well as from an 11%
increase in fee income, with growth across
all regions.

 – In Markets products, Insurance and

Investments and Other, revenue reduced by
$11m or 1%, reflecting the impact of lower
global interest rates on income earned on
capital held in the business and lower
Markets Treasury revenue. This reduction
was partly offset by a 12% increase in
revenue from the sale of GBM products to
CMB customers, notably Global Markets
and Capital Markets and Advisory, as well as
higher insurance and investment revenue.

 – In Credit and Lending, revenue increased by
$0.2bn or 4%, reflecting wider margins and
a 9% increase in fee income, notably in the
UK and North America. During 2021, we
grew balances in Asia, although year-on-
year average balances decreased, as
customers' funding requirements fell due to
Covid-19 restrictions, notably in Europe and
North America.

 – In GTRF, revenue rose by $0.2bn or 9%,
driven by an 8% growth in fee income
across all regions, partly reflecting a
recovery in global trade volumes, as well as
a 9% increase in average balances, notably
in Asia, and higher margins in the UK.

HSBC Holdings plc Annual Report and Accounts 2021

33

Strategic report 
Strategic report | Global businesses

Global Banking  
and Markets

Contribution to Group adjusted profit 
before tax   

$5.3bn
(24%)

We repositioned our capital and 
resources in Global Banking and 
Markets to create capacity for growth 
opportunities, mainly into Asia and the 
Middle East, and to serve international 
clients that are aligned to our strategy. 
Our product specialists deliver a 
comprehensive range of transaction 
banking, financing, capital markets and 
advisory, as well as risk management 
services. Our products, combined with 
our expertise across industries, enable 
us to help clients achieve their 
sustainability goals.

GBM adjusted profit before tax increased, 
reflecting a net release in adjusted ECL in 
2021. While adjusted revenue fell, there was 
continued momentum in Equities, Capital 
Markets and Advisory, as well as our 
Securities Services business, where during 
2021 assets under custody surpassed $10tn 
for the first time. We also continued to invest 
in technology to support our clients and to 
improve our operational resilience. 

Adjusted results 

2021

$m

2020

$m

2019

$m

Net operating income

15,002

15,768

15,282

2021 vs 2020

$m

(766)

%

 (5)

Change in expected credit  
losses and other credit 
impairment charges

337

(1,289)

(155)

1,626

 126 

Operating expenses

(10,006)

(9,640)

(9,891)

(366)

 (4) 

Share of profit in associates  
and JVs

—

—

1

—

 — 

Profit before tax

5,333

4,839

5,237

494

 10

RoTE excluding significant  
items (%)1

8.6

6.7

9.8

1  Since 1 January 2021, the UK bank levy has been included in the calculation of this measure. Comparative 

data have not been re-presented.

Supporting customers to net zero

Etihad Airways has pledged to reduce CO2 emissions to 50% of 
2019 levels by 2035 on the way to reaching net zero by 2050.

As part of this transition, we helped the UAE’s national airline raise 
$1.2bn with the first sustainability-linked loan in the global aviation 
industry to embed publicly disclosed environment, social and 
governance targets. We held joint ESG structuring and coordinator 
roles, as well as being joint bookrunner and mandated lead arranger. 
The targets included the amount of carbon emissions Etihad cuts 
from its passenger fleet, with financial penalties and incentives of 
up to $5.5m.

The loan builds on a $600m sustainability-linked Islamic bond, 
or sukuk, we helped arrange in October 2020.

34

HSBC Holdings plc Annual Report and Accounts 2021

Global businesses | Global Banking and Markets

Management view of adjusted revenue 

1

Markets and Securities Services

 – Securities Services

 – Global Debt Markets

 – Global Foreign Exchange

 – Equities

 – Securities Financing

– Credit and funding valuation adjustments

Banking

 – Global Trade and Receivables Finance

 – Global Liquidity and Cash Management

 – Credit and Lending

 – Capital Markets and Advisory

 – Other2

GBM Other

 – Principal Investments

 – Other3

Net operating income4

2021

$m

8,288

1,923

878

3,355

1,224

878

30

6,610

714

1,838

2,596

1,256

206

104

377

(273)

15,002

2020

$m

8,997

1,832

1,464

4,140

844

988

(271)

6,748

706

2,034

2,687

1,073

248

23

115

(92)

2019

$m

7,984

2,075

1,043

3,179

598

1,056

33

7,571

703

2,751

2,785

872

460

(273)

267

(540)

15,768

15,282

2021 vs 2020

$m

(709)

91

(586)

(785)

380

(110)

301

(138)

8

(196)

(91)

183

(42)

81

262

(181)

(766)

%

(8)

5

(40)

(19)

45

(11)

>100

(2)

1

(10)

(3)

17

(10)

>100

>100

>(100)

(5)

1  From 1 June 2020, revenue from Issuer Services, previously reported in Securities Services, was reported in Banking. This resulted in $80m revenue being 

recorded in Securities Services in 2020. Comparative data have not been re-presented. 

2 Includes portfolio management, earnings on capital and other capital allocations on all Banking products.
3 Includes notional tax credits and Markets Treasury, HSBC Holdings interest expense and Argentina hyperinflation.
4 ‘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

48%

Adjusted revenue generated in Asia in 2021. 

$28.9bn

Reduction in reported RWAs compared with 
31 December 2020.

Adjusted profit before tax
($bn)

$5.3bn

2021

2020

2019

2019
Net operating income
($bn)

$15.0bn

2021

2020

2019

2019

Financial performance 
Adjusted profit before tax of $5.3bn was 
$0.5bn or 10% higher than in 2020. This 
reflected a net release of adjusted ECL, 
compared with a significant build-up of 
allowances in 2020, although adjusted revenue 
fell and adjusted operating expenses rose.

 – Revenue in Credit and Lending and GTRF

was adversely affected by strategic actions
taken to reduce RWAs.

 – Capital Markets and Advisory benefited

from a strong performance in leveraged and
acquisition finance, particularly in the US,
although debt underwriting volumes fell.

Adjusted revenue of $15.0bn decreased by 
$0.8bn compared with 2020.

In MSS, revenue fell by $0.7bn or 8%, 
compared with a strong comparative period, 
primarily in Global Foreign Exchange and 
Global Debt Markets, from a reduction in 
client activity.

 – In Equities, our diversified product mix and

geographical coverage enabled us to benefit
from volatility in Asian markets, particularly
in wealth products, resulting in revenue
growth of $0.4bn or 45%.

 – In Securities Services, we continued to grow
fees from client inflows and market-related
growth, and increased average assets under
custody by 18% to over $10tn. Net interest
income decreased by 16% as lower global
interest rates were in part mitigated by
growth in average cash balances.

In Banking, revenue fell by $0.1bn or 2%.

5.3

4.8

5.2

 – In GLCM, revenue fell by $0.2bn or 10%, 

as lower global interest rates compressed 
margins. This was partly offset by growth in 
average balances of 4% and increased fee 
income, reflecting higher transaction volumes.

15.0

15.8

15.3

Adjusted ECL were a net release of $0.3bn, 
reflecting an improved economic outlook. This 
compared with a net charge of $1.3bn in 2020. 
ECL in 2021 also included an increase in 
allowances in the fourth quarter, reflecting 
recent developments in China’s commercial 
real estate sector.

Adjusted operating expenses of $10.0bn were 
$0.4bn or 4% higher from an increase in 
performance-related pay of approximately 
$0.2bn and higher technology investment. 
From 2021, the UK bank levy was partially 
allocated to global businesses, which was 
previously retained in Corporate Centre, 
resulting in an additional $0.2bn of operating 
expenses in 2021. These increases were partly 
offset by the impact of our cost-saving 
initiatives.

At 31 December 2021, we had delivered $77bn 
of cumulative gross RWA reductions as part of 
our transformation programme, reflecting the 
completion of structural elements of our 
transformation programme and approximately 
90% of our target.

HSBC Holdings plc Annual Report and Accounts 2021

35

Strategic reportStrategic report | Global businesses 

Corporate Centre

The results of Corporate Centre primarily 
comprise the share of profit from our 
interests in our associates and joint 
ventures. It also includes Central 
Treasury, stewardship costs and 
consolidation adjustments.

Corporate Centre performance improved from 
2020, mainly due to a higher adjusted share of 
profit from associates and joint ventures and a 
lower UK bank levy charge.

Financial performance
Adjusted profit before tax of $2.8bn was 
$1.3bn higher than in 2020 due to an increased 
adjusted share of profit from associates and 
joint ventures and a net favourable movement 
in adjusted operating expenses, partly offset 
by adverse movements in adjusted revenue.

Adjusted revenue decreased by $0.2bn, mainly 
in Central Treasury, from a net adverse fair 
value movement of $0.3bn relating to the 
economic hedging of interest rate and 
exchange rate risk on our long-term debt with 
associated swaps. This was partly offset by 
the non-recurrence of revaluation losses on 
investment properties in 2020.

Adjusted operating expenses were a net credit 
of $0.2bn, which was $0.6bn favourable 
compared with 2020. This was driven by a 
reduction of $0.6bn in the UK bank levy, 
reflecting a change in the basis of calculation 
to only include the UK balance sheet rather 
than the global balance sheet, and by a credit 
of $0.1bn relating to the 2020 charge. In 
addition, in 2021 the UK bank levy was 
partially allocated to our global businesses, 

notably to GBM, resulting in a further 
reduction of $0.2bn. The effect of these 
changes resulted in a net credit of $0.1bn 
in Corporate Centre, compared with a charge 
of $0.8bn in 2020. This decrease was partly 
offset by lower recoveries from our 
global businesses.

Adjusted share of profit in associates and joint 
ventures of $3.0bn increased by $0.8bn. The 
increases were from BoCom and SABB, as 
well as from BGF in the UK, reflecting a 
recovery in asset valuations relative to 2020.

Adjusted results 

Net operating income

Change in expected credit losses and other credit 
impairment charges

Operating expenses

Share of profit in associates and JVs

Profit before tax

RoTE excluding significant items (%)1

2021

$m

(437)

3

215

3,011

2,792

5.6

2020

$m

 (287)

 1 

 (429)

 2,186 

 1,471 

 3.1 

2019

$m

 (581)

 38 

 (821)

 2,440 

 1,076 

 0.8 

2021 vs 2020

$m

(150)

2

644

825

1,321

%

(52)

200

150

38

90

1 Since 1 January 2021, the UK bank levy has been included in the calculation of this measure. Comparative data have not been re-presented.

Management view of adjusted revenue 

Central Treasury1

Legacy portfolios

Other2

Net operating income3

2021

2020

$m

(99)

(33)

(305)

(437)

$m

157

(20)

(424)

(287)

2019

$m

179

(115)

(645)

(581)

2021 vs 2020

$m

(256)

(13)

119

(150)

%

>(100)

(65)

28

(52)

1   Central Treasury includes adverse valuation differences on issued long-term debt and associated swaps of $99m (2020: gains of $151m; 2019: gains of $146m).
2  Revenue from Markets Treasury, HSBC Holdings net interest expense and Argentina hyperinflation were allocated to the global businesses, to align them better 

with their revenue and expense. The total Markets Treasury revenue component of this allocation for 2021 was $2,339m (2020: $2,849m; 2019: $2,075m).

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 2021

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

The Covid-19 pandemic and its effect on the 
global economy have continued to impact our 
customers and our organisation. Despite the 
successful roll-out of vaccines around the 
world, a varying degree of uncertainty 
remained throughout 2021. This was caused 
by new variants of Covid-19, varying vaccine 
effectiveness rates and the need for the 
reimposition of government-imposed 
restrictions. While the global economic 
recovery in 2021 eased financial difficulties 
for some of our customers, the future effects 
remain uncertain.

Throughout the pandemic, we have 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 our 
balance sheet and liquidity remained strong. 
This helped us to support our customers both 
during periods of government-imposed 
restrictions and when these restrictions 
were eased.

Tensions between China and the US, the UK, 
the EU, India and other countries were 
heightened during 2021. In addition, the 
potential for an escalation of hostilities 
between Russia and Ukraine further 
complicates the geopolitical landscape. 
The macroeconomic, trade and regulatory 
environments have become increasingly 
fragmented through disruptions to supply 
chains, increasing inflationary pressures, and 
market concerns regarding potential impacts 
following instability in China’s commercial real 
estate sector. We continue to monitor the 
situation closely.

We continued to focus on improving 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 

Key risk appetite metrics

Component Measure

Capital

CET1 ratio – end point basis

Risk 
appetite

≥13.0%

2021

15.8%

Change in 
expected 
credit losses 
and other credit 
impairment 
charges

Change in expected credit losses and other credit 
impairment charges as a % of advances: (WPB)

≤0.50%

(0.06)%

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

≤0.45%

(0.10)%

balance of return for the risk assumed, while 
remaining within acceptable risk levels. 
Additionally, it supports senior management in 
allocating capital, funding and liquidity 
optimally to finance growth, while monitoring 
exposure to non-financial risks. 

recovery and resolution planning to help 
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. 

Capital and liquidity are at the core of our risk 
appetite framework, with forward-looking 
statements informed by stress testing. We 
continue to evolve our climate risk appetite to 
reflect the risks from climate change, setting 
out the measures we intend to take to support 
our climate ambition and our commitments to 
regulators, investors and stakeholders. 

During 2021, metrics monitoring the change 
in expected credit losses and other credit 
impairment charges returned to within their 
defined risk appetite thresholds. This was 
achieved by the release in allowances for 
expected credit losses, reflecting: an 
improvement of the economic outlook; the 
adaption of our strategy following the Covid-19 
pandemic; enhancements to how we monitor 
risks; reviews of our portfolios that are highly 
vulnerable to the economic environment; and 
the implementation of additional review 
measures 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 

In 2021, the Bank of England (‘BoE’) required 
all major UK banks to conduct a solvency 
stress test to assess whether the capital 
buffers that banks had built during the 
Covid-19 pandemic were sufficient to deal 
with a prevailing stress period. This exercise 
differed from previous BoE stress tests, which 
were used to determine the capital 
requirements for participating banks. The 2021 
solvency stress test incorporated a ‘double 
dip’ scenario, whereby an economy faces a 
recession and then a partial or full recovery 
for a short period of time before entering a 
second recessionary period. Additionally, 
it represented an intensification of the 
macroeconomic shocks seen in 2020, with 
economic weaknesses persisting around the 
world, leading to ongoing weaknesses in 
global GDP. 

We also conducted our own internal stress 
test, which explored the potential impacts of 
key vulnerabilities to which we are exposed, 
including geopolitical issues and the Covid-19 
pandemic. The internal stress test considered 
the impacts of various risk scenarios across all 
risk types and on capital resources. The results 
of the internal stress test were shared with 
senior management, and showed that after 
taking appropriate actions, the Group would 
remain adequately capitalised.

In 2021, the Prudential Regulation Authority 
(‘PRA’) requested all major UK banks to run 
a climate-related stress test to explore the 
impacts of a set of scenarios: an early policy 
action, a late policy action and no additional 

HSBC Holdings plc Annual Report and Accounts 2021

37

Strategic reportStrategic report | Risk overview

Managing risk continued

policy action. To support the requirements for 
assessing the impacts of climate change, we 
have developed a set of capabilities to execute 
climate stress testing and scenario analysis. 
These are used to improve our understanding 
of our risk exposures for risk management and 
business decision making. In addition to the 
PRA requirements, we also delivered 
regulatory climate change stress testing 
exercises to a number of other regulators 
including the Hong Kong Monetary Authority 
and the Monetary Authority of Singapore. 
These have provided us with insights to 
identify appropriate areas of further 
development and actions to mitigate against 
the impact of climate change. 

Risks related to Covid-19

A global vaccination roll-out in 2021 helped 
reduce the social and economic impact of the 
Covid-19 pandemic, although there has been 
significant divergence in the speed at which 
vaccines have been deployed around the 
world. By the end of 2021, high vaccination 
rates had ensured that many Covid-19-related 
restrictions on activity in developed markets 
had been lifted and travel constraints were 
easing. However, the emergence of the 
Omicron variant in late 2021 demonstrated the 
continued risk new variants pose. There 
remains a divergence in approach taken by 
countries to the level of restrictions on activity 
and travel in response to the pandemic. Such 
diverging approaches to future pandemic 
waves could prolong or worsen supply chain 
and international travel disruptions. A full 
return to pre-pandemic levels of social 
interaction across all our key markets is 
unlikely in the short to medium term. 

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 help 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. We continue to 
invest in business and technical controls 
to help defend against these threats. 

We are making progress with the 
implementation of our business transformation 
plans, while seeking to ensure that we are able 
to manage safely the risks of the restructuring, 
which include execution, operational, 
governance, reputational, conduct and 
financial risks. 

 For further details on our risk management 
framework and risks associated with our banking 
and insurance manufacturing operations, see 
pages 135 and 136 respectively.

Our ECL models continue to be impacted by 
the pandemic, as a result of the continued 
economic uncertainty caused by new 
Covid-19 variants. We continued to carry out 
enhanced monitoring of model outputs and 
use of model overlays, including management 
judgemental adjustments based on the expert 
judgement of senior credit risk managers. In 
addition, we recalibrated certain key loss 
models to take into account the impacts of 
Covid-19 on critical model inputs. We also 
responded to complex conduct considerations 
and heightened risk of fraud related to the 
varying government support measures and 
restrictions. The continued economic 
uncertainty resulting from the pandemic could 
adversely impact our revenue assumptions, 
notably volume growth.

Our operations have been resilient throughout 
the pandemic. However, the operational 
support functions on which the Group relies 
are based in a number of countries worldwide, 
some of which have been particularly affected 
by the Covid-19 pandemic during 2021. As a 
result, business continuity responses have 
been implemented and the majority of service 
level agreements have been maintained in 
locations where the Group operates. We 
continue to monitor the situation closely, 
in particular in those countries and regions 
where Covid-19 infections are most prevalent 
and/or where travel restrictions are in place.

 For further details on our approach to the risks 
related to Covid-19, see ‘Areas of special interest’ 
on page 131.

Geopolitical and macroeconomic risks

The macroeconomic, trade and regulatory 
environment has become increasingly 
fragmented, with the spread of new variants of 
Covid-19, alongside other factors, continuing to 
disrupt supply chains in several industries 
globally. It remains to be seen how supply 
chains will be impacted by the Omicron or 
other future variants. The mismatch between 
supply and demand has pushed up commodity 
and other prices, particularly in the energy 
sector, creating further challenges for 
monetary authorities and our customers. 
Against the backdrop of both a vaccine-led 
economic recovery and increasing inflationary 
pressures, interest rates generally rose during 
2021. Central banks in developed markets have 
either begun, or are expected to soon begin, 
to raise benchmark rates in order to help ease 
inflationary pressures, although rates are 
expected to remain low by historical 
standards, as uncertainties over the 
economic outlook continue.

Market concerns remain about repercussions 
for the Chinese domestic economy from recent 

instability in its commercial real estate sector. 
Such repercussions may occur directly through 
financial exposures to the Chinese commercial 
real estate sector, or indirectly through the 
effect of a slowdown in economic activity in 
China and in the supply chain to the real estate 
sector. According to the Chinese government’s 
‘three red lines’ framework used to govern the 
real estate sector, at 31 December 2021 we 
had no direct credit exposure to developers in 
the 'red' category, noting that deteriorating 
operating performance and challenging 
liquidity conditions were seen more broadly 
across the sector. We continue to monitor the 
situation closely, including potential indirect 
impacts, and seek to take mitigating actions 
as required.

In December 2021, the OECD published model 
rules that provided a template for countries to 
implement a new global minimum tax rate of 
15% from 2023. In January 2022, the UK 
government opened a consultation on how the 
UK plans to implement the rules. The impact 
on HSBC will depend on exactly how the UK 

implements the model rules, as well as the 
profitability and local tax liabilities of HSBC’s 
operations in each tax jurisdiction from 2023. 
Separately, potential changes to tax legislation 
and tax rates in the countries in which we 
operate could increase our effective tax rate 
in future as governments seek revenue to pay 
for Covid-19 support packages.

Heightened tensions across the geopolitical 
landscape could also have implications for the 
Group and its customers. The relationship 
between the UK and the EU may come under 
further strain in 2022 with a number of 
potential areas of tension, notably the Northern 
Ireland Protocol, with possible repercussions 
for the operation of the EU-UK Trade and 
Cooperation Agreement. Diplomatic tensions 
between China and the US, and extending to 
the UK, the EU, India and other countries, and 
developments in Hong Kong and Taiwan, 
may affect the Group, creating regulatory, 
reputational and market risks. The US, the UK, 
the EU, Canada and other countries have 
imposed various sanctions and trade 

38

HSBC Holdings plc Annual Report and Accounts 2021

Risk overview

Geopolitical and macroeconomic risks continued

restrictions on Chinese individuals and 
companies. In response, China has announced 
sanctions, trade restrictions and laws that 
could impact the Group and its customers. 

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

The financial impact on the Group of 
geopolitical risks in Asia is heightened owing to 
the strategic importance of the region in terms 
of profitability and prospects for growth. 

Additionally, the US, the UK and the EU have 
threatened to expand sanctions significantly 
against Russia in response to an increasing risk 
of hostilities in Ukraine, which, together with 

any military conflict, could impact global 
markets as well as the Group and its 
customers. We continue to monitor 
developments and seek to manage the 
associated impacts on our customers 
and business.

 For further details on our approach to geopolitical 
and macroeconomic risks, see ‘Top and 
emerging risks’ on page 124.

Climate risk

In 2021, the pace and volume of policy and 
regulatory changes and expectations 
increased, amid a global focus on formalising 
climate risk management, stress testing and 
scenario analysis and disclosures. We aim to 
manage climate risk across all our businesses 
in line with our Group-wide risk management 
framework. Our most material risks in terms of 
managing climate risk relate to corporate and 
retail client financing within our banking 
portfolio, but there are also significant 
responsibilities in relation to asset ownership 
by our insurance business and employee 

pension plans, as well as from the activities 
of our asset management business. 

Climate change can have an impact across our 
risk taxonomy through both transition and 
physical channels. These have the potential to 
cause both idiosyncratic and systemic risks, 
resulting in potential financial and non-
financial impacts for HSBC. 

We continue to monitor the impacts of climate 
risk and accelerate the development of our 
climate risk management capabilities, through 

our dedicated climate risk programme. While 
financed emissions and other climate risk 
reporting has improved over time, data 
remains of limited quality and consistency. 
Developments in data and methodologies are 
expected to continue to help improve and 
enhance our measurement and reporting of 
climate risk and financed emissions. 

 For further details of our approach to climate 
risk management, see ‘Areas of special interest’ 
on page 131.

transitioned prior to 31 December 2021. 
The programme continues to support 
customers with transitioning remaining 
contracts linked to these rates, as well as 
customers whose contracts are utilising 
‘synthetic’ sterling or Japanese yen Libor rates. 
In 2022, the programme will focus on the 
transition of these remaining contracts in 
addition to the wider portfolio of US dollar 
Libor legacy contracts.

At 31 December 2021, our exposure to 
contracts referencing rates that were demised 
from the end of 2021 included: contracts that 
have been transitioned but are yet to reach the 
next subsequent relevant interest payment 
date; contracts where the Ibor rate exposure 
only arises at a future date; legacy Ibor 
contracts that included robust industry 
fallback provisions that were invoked after 
31 December 2021; and a small proportion of 
so-called ‘tough legacy’ contracts which will 
either use a ‘synthetic’ Libor or a contractual 
fallback rate. 

For any ‘tough legacy’ contracts we continue 
to work with our clients and investors with the 
aim of transitioning them to appropriate 
products and interest rates at the earliest 
opportunity. In the meantime, these contracts 
will be valued using the appropriate interest 
rate methodology. 

The key risks associated with Ibor transition 
beyond 2021 are unchanged and include 
regulatory compliance risk, resilience risk, 
financial reporting risk, legal risk and market 
risk. For ‘tough legacy’ contracts, we closely 
monitor legal, resilience and regulatory 
compliance risks. For the US dollar legacy 
portfolio these risks continue to be actively 
managed and mitigated with a focus on 
ensuring that fair outcomes for our clients 
are achieved.

 For further details on our approach to Ibor 
transition, see ‘Top and emerging risks’ on 
page 124.

Ibor transition

During 2021, our interbank offered rate (‘Ibor’) 
transition programme – which is tasked with 
the development of new near risk-free rate 
(‘RFR’) products and the transition of legacy 
Ibor products – continued to facilitate 
engagement with our clients, and finalise IT 
and operational changes necessary to enable 
an orderly transition from Ibors to RFRs, or 
alternative benchmarks, such as policy interest 
rates. Following the announcement by ICE 
Benchmark Administration Limited in March 
2021 that the publication of the US dollar 
London interbank offer rate (‘Libor’) would be 
extended to 30 June 2023, the Group’s 
transition programme focused mainly on client 
engagement for sterling, Swiss franc, euro and 
Japanese yen Libor interest rates, as well as 
Euro Overnight Index Average (‘Eonia’). These 
interest rate benchmarks were all demised 
from the end of 2021 although six sterling and 
Japanese yen settings are currently being 
published under an amended methodology, 
commonly known as ‘synthetic’ Libor. Over 
90% of legacy contracts referencing rates that 
were demised from the end of 2021 were 

Top and emerging risks

Our top and emerging risks identify 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 have the potential to 
have a material adverse impact on the 
financial results, reputation or business model 

Our suite of top and emerging risks is subject 
to regular review by senior governance 

of the Group. We actively manage and take 
actions to mitigate our top risks, Emerging 
risks are those that while they could have a 
material impact on our risk profile were they 
to occur, are not considered immediate and 
are under regular review.

forums. In December 2021, we amended our 
top and emerging risks. ‘Environmental, social 
and governance’ replaced ‘Climate-related 
risks’ to cover the wider scope of climate, 
nature and human rights risks. ‘Digitalisation 
and technological advances’ was added as a 
new risk to capture the emerging strategic and 
operational risks associated with the 
advancement of technology. 

HSBC Holdings plc Annual Report and Accounts 2021

39

Strategic report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

Environmental, 
social and 
governance

Digitalisation and 
technological 
advances 

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 macroeconomic risks and risks posed by heightened tensions across the geopolitical landscape. 
We adopt procedures and controls based on an assessment of the potential impacts on our portfolios. We 
maintain heightened monitoring activities to identify sectors and customers experiencing financial difficulties 
from the Covid-19 pandemic. In light of geopolitical tensions, we assess those sectors likely to be particularly 
impacted by laws and regulatory actions resulting from such tensions.

We help protect our customers and organisation by investing in our cybersecurity capabilities, helping us to 
execute our business priorities and grow safely. We focus on controls to prevent, detect and mitigate the impacts 
of persistent and increasingly advanced cyber threats. We closely monitor the continued dependency on 
widespread remote working and online facilities. 

We monitor regulatory and wider industry developments closely and engage with regulators, as appropriate, to 
help ensure new regulatory requirements are implemented effectively and in a timely way, adjusting our policies, 
procedures and relevant controls as required. We keep abreast of the emerging regulatory compliance and conduct 
agenda. Current areas of focus include developments in areas such as ESG, operational resilience, digital and 
technology changes (including payments), how we are ensuring good customer outcomes (including addressing 
customer vulnerabilities), regulatory reporting and employee compliance.

We continued to support our customers as our financial crime landscape evolved due to the Covid-19 pandemic, 
and as geopolitical, socioeconomic and technological shifts occurred across our markets. We continued to make 
improvements to our financial crime controls as emerging risks were identified, and to invest in advanced analytics 
and artificial intelligence as key elements of our next generation of tools to fight financial crime. 

We remain focused on completing the system and product updates to support additional geographies in the 
transition of demising Libor benchmarks, in particular US dollar Libor. We continue to support the transition of all 
legacy contracts referencing demised and demising Ibor benchmarks, including from any sterling or Japanese 
yen contracts using ‘synthetic’ Libor. Throughout 2022, there will be an increasing focus on customer 
engagement for US dollar Libor-related transition activities. 

ESG risk has increased owing to the pace and volume of regulatory developments globally, with the focus on 
formalising climate risk management, enhanced disclosures, and integration of other ESG risks such as nature-
related risks and human rights. Some stakeholders are also placing more emphasis on financial institutions’ 
actions and investment decisions in respect of ESG matters. We continue to develop our approach and engage 
with our stakeholders on ESG risk. 

We monitor advances in technology to understand how changes may impact our customers and business. 
We closely monitor and assess the potential for consequent financial crime and the resulting impact on 
payment transparency and architecture.

We monitor and improve IT systems and network resilience to minimise service disruption and improve customer 
experience. To support the business strategy, we continue to strengthen our end-to-end service management, 
build and deployment controls and system monitoring capabilities. 

We monitor workforce capacity and capability requirements in line with our published growth strategy. We have 
measures to support our people to work safely during the Covid-19 pandemic, and to integrate them back into 
the workplace as government restrictions ease. We monitor people risks that may arise due to business 
transformation to help manage redundancies sensitively and support impacted employees.

We continually enhance our third-party risk management framework as our supply chain evolves, and to stay 
aligned to the latest regulatory expectations. We closely monitor for Covid-19-related impacts on the delivery 
of services to the Group, with businesses and functions taking appropriate action where needed. 

We continue to strengthen our oversight of models and model risk controls. We are redeveloping our capital 
models to reflect the evolving regulatory requirements, and in some cases the potential effects from the Covid-19 
pandemic. Ibor models impacted by the switch to new alternative risk-free rates are also being redeveloped. We 
enhanced the oversight of models used in financial reporting processes in light of the potential impacts from the 
uncertain external environment.

We protect our customers and organisation by making focused investments in capabilities that manage data risk. 
We focus on controls that manage data governance, usage, integrity, privacy and retention. During 2021, we 
refreshed our data strategy and continued to improve our approach to data risk management and reporting.

We continue to monitor and manage our change execution risk, including our capacity and resources to meet 
the increased levels of change associated with the delivery of our strategic priorities and regulatory 
requirements. We are working to deliver sustainable change efficiently and safely, through the embedding of 
a change framework launched in May 2021. 

Risk heightened during 2021 

 Risk remained at the same level as 2020

40

HSBC Holdings plc Annual Report and Accounts 2021

Long-term viability and going concern statement

Long-term viability and going 
concern statement 

 – reports and updates regarding regulatory
and internal stress testing. During 2021,
the Bank of England (‘BoE’) mandated an
industry-wide solvency stress test exercise,
which incorporated a ‘double dip’ scenario
and represented an intensification of the
macroeconomic shocks seen in 2020. The
outcomes of the stress test showed that
taking account of strategic management
actions, the Group would remain
adequately capitalised;

 – the results of our 2021 climate stress testing
and scenario analysis exercise. No issues
were identified around the going concern
status of the Group. Further details of the
insights from the 2021 climate stress test
are explained from page 57;

 – 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; and

 – reports and updates from management

on the operational resilience of the Group.

Aileen Taylor
Group Company Secretary and  
Chief Governance Officer

22 February 2022

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 2024. 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

2022–2026.

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 40. These 
include risks related to geopolitical and 
macroeconomic risks (including in relation to 
Covid-19), which have remained at the same 
level as 2020. Environmental, social and 
governance risk has replaced the former 
Climate-related risks theme to cover the wider 
scope of climate, nature and human rights, 
and digitalisation and technological advances 
has been added as a new theme to capture 
the emerging strategic and operational risks 
associated with the advancement of 
technology. Both of these risks were at a 
heightened level during 2021.

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. 

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 121) and top
and emerging risks (see page 124);

 – the impact on the Group due to the Covid-19
pandemic including the emergence of the
Delta and Omicron variants; recent
instability in China’s commercial real estate
sector; and strained economic and
diplomatic tensions between China and the
US, the UK, the EU and other countries;

HSBC Holdings plc Annual Report and Accounts 2021

41

Strategic reportEnvironmental, social 
and governance review

Our ESG review sets out our approach to our environment, customers, employees 
and governance. It also explains how we aim to achieve our purpose and deliver 
our  strategy in a way that is sustainable and how we build strong relationships 
with all of our stakeholders.

43 

45 

66 

79 

Our approach to ESG

Environmental 

Social

Governance

42

HSBC Holdings plc Annual Report and Accounts 2021

Our approach to ESG

Our approach to ESG

We are on a journey to incorporate environmental, social and governance 
principles throughout the organisation, as we have taken material steps 
to embed sustainability into our purpose and corporate strategy.

About the ESG review 

Our 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. 

We continue to make progress on our climate 
ambition to support our customers in their 
transition to net zero and a sustainable future, 
including through providing and facilitating 
sustainable finance and investment, as we 
set out on the following pages. 

In May 2021, a climate change resolution 
proposed by the Board was backed by more 
than 99% of our shareholders at our Annual 
General Meeting (‘AGM’), including a 
commitment to set, disclose and implement a 
strategy with short- and medium-term targets 
to align our provision of finance with the goals 
and timelines of the Paris Agreement. It also 
included a commitment to publish a policy 
to phase out the financing of coal-fired power 
and thermal coal mining, by 2030 in the  
EU/OECD, and 2040 in all other markets.

We have disclosed our baseline financed 
emissions for two priority sectors – oil and 
gas, and power and utilities – and set targets 
to reduce on-balance sheet financed 
emissions in these sectors. In assessing 
financed emissions, we are focusing our 
analysis on those parts of the sectors  
that we believe are most material in terms  
of greenhouse gas emissions. 

We are also working with peers and industry 
bodies to mobilise the financial system to 
take action on climate change, biodiversity 
and nature.

Through a series of surveys, we aim to listen 
to our customers to put them at the centre of 
our decision making. If things do go wrong, 
we aim to take action in a timely manner.

Our colleagues have needed to adapt at pace 
due to the impact of the Covid-19 pandemic. 
This has offered us the opportunity to rethink 

Environmental

 – Since 2020, we have provided and facilitated $126.7bn of sustainable finance and

investment towards our ambition of $750bn to $1tn by 2030.

 – In line with the climate change resolution, we published our thermal coal phase-out policy.

For the oil and gas sector, we target a 34% Mt CO2e reduction in oil and gas absolute
on-balance sheet financed emissions by 2030, from a 2019 baseline. For the power and
utilities sector, we target a 0.14 Mt CO2e/TWh power and utilities on-balance sheet
financed emissions intensity, representing a 75% reduction from 2019.

Read more in the Environmental section on page 45.

Social

 – We aim to be a top-three bank for customer satisfaction. Even though our performance,
using the net promoter score, improved in many markets in which we operate, we still
have work to do to improve our rank position against competitors, as some have
accelerated their performance faster than us.

Read more in the Customers section on page 67.

 – In 2021, 31.7% of women occupied senior leadership roles, with a target to achieve 35% by 

2025. We have put in place important foundations to support our goal of doubling the number
of Black employees in senior leadership roles by 2025.

 – Employee engagement, which is our headline measure, remained unchanged in 2021 

at 72% following a five-point increase from 2019 and was four points above benchmark.

Read more in the Employees section on page 70.

Governance

 – Governance activities are managed through a combination of specialist governance

infrastructure, and regular meetings and committees, where appropriate. We expect that
our ESG governance approach will continue to develop, in line with our evolving approach
to ESG matters and stakeholder expectations.

 – In seeking to safeguard the financial system, we monitor on average over 1.1 billion

transactions each month for signs of financial crime.

Read more in the Governance section on page 79.

how our colleagues work, considering 
what worked well during the pandemic, 
and what challenges they face. Our future 
of work strategy will provide a framework 
through which we will implement hybrid 
working principles and adopt new 
technologies and working practices  
to enhance productivity, engagement  
and well-being.

We run a Snapshot survey every six 
months and report insights to our Group 
Executive Committee and the Board. We 
received 272,718 responses to our two 
Snapshot surveys in 2021, with record 
response rates. We will look to continue  

to focus on those aspects of the employee 
experience that we know to have the 
greatest impact on employee sentiment: 
fostering a healthy work-life balance, trust 
towards leadership, career progression 
opportunities and confidence in the 
company’s future.

We are on a journey to embed ESG 
principles across the organisation, 
including incorporating climate change-
related risks within the risk framework, 
training our workforce, incorporating 
climate-related targets within executive 
scorecards, and engaging with customers 
and suppliers.

HSBC Holdings plc Annual Report and Accounts 2021

43

ESG reviewESG review | Our approach to ESG

How we decide what to measure

Consistent with the scope of financial 
information presented in our Annual Report 
and Accounts, the ESG review covers the 
operations of HSBC Holdings plc and its 
subsidiaries. Given the relative immaturity 
of the ESG data in general, we are on a 
continuous journey to ensure completeness 
and robustness.

 For further information on our approach to 
reporting, see the ‘Additional information’ 
section on page 401.

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 plan to continue to assess our 
approach to ensure we remain relevant in 
what we measure and publicly report.

Recognising the need for a consistent and 
global set of ESG metrics, we started to report 
against the core World Economic Forum 
(‘WEF’) ‘Stakeholder Capitalism Metrics’ 
within the Annual Report and Accounts 2021 
for the first time.

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 with to identify the issues that 
are most important to them and consequently 
also matter to our own business.

Our ESG Committee (previously the 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, 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), and other applicable laws 
and regulations to choose what we measure 
and publicly report in this ESG review.

Our reporting around ESG

We report on ESG matters within this ESG review and throughout our Annual Report and Accounts, including the 'How we do business' section of 
the Strategic Report (pages 15 to 20), this ESG review (pages 43 to 88), and the ‘Climate-related risks’ section of our Risk review (pages 131 to 135). 
In addition, we have other supplementary materials, including our ESG Data Pack, which provides a more granular breakdown of ESG information.

Detailed data

ESG Data Pack

Additional reports

UK Pay Gap Report 2021

Modern Slavery and Human 
Trafficking Statement 2021

Indices

SASB Index 2021

WEF Index 2021

For further details of our supplementary materials, see our ESG reporting centre at www.hsbc.com/esg.

We have changed how we are presenting our TCFD disclosures
Our overall approach to TCFD can be found on page 19 and additional information is included on page 63. Further details, which last year 
were presented in a separate supplement, have been embedded in this section and the Risk review section on pages 131 to 135.

Assurance relating to ESG data

We recognise the importance of ESG 
disclosures and the quality of data 
underpinning it. Certain aspects of our 
ESG disclosures are subject to independent 
assurance and we will continue to 
enhance our approach in line with 
external expectations.

For 2021, PwC provided stand-alone limited 
assurance reports in accordance with 
International Standard on Assurance 
Engagements 3000 (Revised) ‘Assurance 
Engagements other than Audits or Reviews 
of Historical Financial Information’ and, in 
respect of the greenhouse gas emissions, 
in accordance with International Standard 

on Assurance Engagements 3410 ‘Assurance 
engagements on greenhouse gas statements’, 
issued by the International Auditing and 
Assurance Standards Board, on the following 
specific ESG-related metrics:

 – our progress towards our ambition to
provide and facilitate $750bn to $1tn
of sustainable finance and investment
(see page 53).

– our Green Bond Report 2021 (published in 

December 2021);

– our 2019 baseline for financed emissions   

related to our climate change resolution (see 
page 48);

– our own operations' scope 1, 2 and 3

(business travel) greenhouse gas emissions 
data (see page 52); and

Our data dictionaries and methodologies for 
preparing the above ESG-related metrics and 
PwC’s assurance reports can be found on: 
www.hsbc.com/who-we-are/esg-and-
responsible-business/esg-reporting-centre.

44

HSBC Holdings plc Annual Report and Accounts 2021

Environmental

Environmental

We are accelerating new solutions to the climate crisis and 
supporting the transition of industries and markets to a net 
zero future, moving to net zero ourselves as we help our 
customers do so too.

At a glance

Our climate ambition
Our net zero ambition represents one of our 
four strategic pillars. At the core of it is an 
ambition to support our customers on their 
transition to net zero, so that the greenhouse 
gas emissions from our portfolio of clients 
reaches net zero by 2050. We also aim to 
be net zero in our operations and supply 
chain by 2030. 

We aim to provide and facilitate $750bn to 
$1tn of sustainable finance and investment 
to support our customers in their transition 
to net zero and a sustainable future by 2030. 
To  support our ambition of net zero financed 
emissions, unlocking transition finance for our 
portfolio of clients will be crucial.

As we describe in the following pages, we 
have set on-balance sheet financed emissions 
targets for the oil and gas, and power and 
utilities sectors, aligned to the IEA’s net zero 
scenario, underpinned by a clear science-
based strategy.

Our approach to climate risk
We recognise that to achieve our climate 
ambition we need to further enhance our 
approach to managing climate risk. We have 
established a dedicated programme to develop 
a strong climate risk management capability. 

We manage climate risks in line with our risk 
management framework and three lines of 
defence model. We also use stress testing and 
scenario analysis to assess how these risks 
will impact our customers, business and 
infrastructure. This approach gives the  
Board and senior management visibility and 
oversight of the climate risks that could have 
the greatest impact on HSBC, and helps us 
identify opportunities to deliver sustainable 
growth in support of our climate ambition. 
For further details on our approach to climate 
risk management, see Environmental, social 
and governance risk on page 125 and 
Climate-related risks on page 131.

Impact on financial statements
We have assessed the impact of climate 
risk on our balance sheet and have concluded 
that there is no material impact on the financial 
statements for the year ended 31 December 
2021. We considered the impact on expected 
credit losses, classification and measurement 
of financial instruments, our owned properties, 
as well as our long-term viability and 
going concern. 

During the year we also conducted a stress 
test to understand the impact of climate risk. 
While the focus of the exercise was solely  
on banking book impairments and RWAs,  
no issues were identified regarding the going 
concern status of the Group. For further details 
on how climate risk can impact HSBC in the 
medium to long term, including credit risk, 
see page 131.

In this section

Our climate 
ambition

Becoming a net zero bank We aim to achieve net zero in our financed emissions by 2050,  

and in our own operations and supply chain by 2030.

Measuring our 
financed emissions

Our approach to our 
own operations

Supporting customers 
through transition

In delivering our financed emissions ambition, we have initially 
focused on the oil and gas, and power and utilities sectors.

We aim to reduce energy consumption by 50% by 2030, against 
a 2019 baseline.

Our ability to finance the transformation of businesses and 
infrastructure is key to building a sustainable future for our 
customers and society. 

Unlocking climate 
solutions and innovations

We are working closely with a range of partners to accelerate 
investment in natural resources, technology and sustainable 
infrastructure.

Biodiversity and natural 
capital strategy

By addressing nature-related risks and investing in nature,  
we have an opportunity to accelerate the transition to net zero.

Our approach 
to climate risk

Managing risk for our 
stakeholders

We manage climate risk across all our businesses in line with our 
Group-wide risk management framework.

Insights from scenario 
analysis

Enhancing our climate change stress testing and scenario analysis 
capability is crucial in identifying and understanding climate-
related risks and opportunities.

Our approach to 
sustainability policies

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.

Our approach 
to climate 
reporting

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

Our TCFD index provides our responses to each of the 11 
recommendations and summarises where additional information 
can be found.

 Page 46

 Page 47

 Page 51

 Page 53

 Page 55

 Page 55

 Page 56

 Page 57

 Page 62

 Page 63

HSBC Holdings plc Annual Report and Accounts 2021

45

ESG reviewESG review | Environmental

Our climate ambition

Becoming a net zero bank

We are committed to a net zero future. 
We recognise that our planet urgently needs 
drastic and lasting action to protect our 
communities, businesses and the natural 
environment from the damaging effects of 
climate change. 

The Paris Agreement aims to limit the rise 
in global temperatures to well below 2°C, 
preferably to 1.5°C, compared with pre-
industrial levels. To limit the rise in global 
temperatures to 1.5°C, the global economy 
would need to reach net zero greenhouse gas 
emissions by 2050. Our ability to steer finance 
for the transformation of businesses and 
infrastructure will be key in helping to enable 
the transition to a net zero global economy.

We believe we can make the most significant 
impact by working with our customers to 
support their transition to a net zero future. We 
aim to align our financed emissions to net zero 
by 2050 or sooner. 

We intend to set targets on a sector by sector 
basis that are consistent with net zero 
outcomes by 2050. In assessing financed 
emissions, we focus on those parts of the 
sector that are most material in terms of 
greenhouse gas emissions, and where we 
believe engagement and climate action have 
the greatest potential to effect change, taking 
into account industry and scientific guidance. 

As an asset manager, we will work towards 
the target of net zero emissions across all 
assets under management by 2050 or sooner.

Our ambition is to become net zero in our 
operations and supply chain. This covers our 
direct and indirect greenhouse gas emissions, 
known as scope 1, 2 and 3 emissions. As well 
as transforming our own operations and 
supply chain to net zero across our own 
organisation by 2030, we are asking our 
suppliers to do the same.

The next two sections provide further details 
on how we are measuring our progress on our 
financed emissions ambition and the progress 
made to date on our own operations and 
supply chain.

The diagram below shows how these 
ambitions map to our scope 1, 2 and 3 
emissions.

Supporting an energy 
provider through  
the transition

In March 2021, Air Liquide S.A., a 
French multinational specialised in 
gases, technologies and services, 
presented its plan to achieve carbon 
neutrality by 2050. The company has 
placed the use of a competitive 
low-carbon hydrogen offering at the 
cornerstone of its energy transition 
ambition, while aiming to decarbonise 
its production assets. We aim to 
support our clients through the 
transition. In May, we acted as a joint 
bookrunner for Air Liquide Finance’s 
inaugural green bond and helped them 
to raise €500m, which will be dedicated 
to eligible sustainable projects including 
hydrogen, biogas, carbon capture, air 
gases, energy efficiency and green 
buildings in accordance with its 
sustainable finance framework.

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 
include those related to investments 
and financed emissions.

Our own
operations and 
supply chain

Scope 2
Indirect

Scope 3
Indirect

Scope 1
Direct

Scope 3
Indirect

Our financed 
emissions

Electricity, 
steam 
heating and 
cooling 

Company
facilities

Company
vehicles

Supply 
chain 

Business 
travel

Employee
commuting1

Investments and 
financed emissions

Upstream activities

HSBC Holdings

Downstream activities

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

1 HSBC-sponsored shuttles only

46

HSBC Holdings plc Annual Report and Accounts 2021

Environmental

Measuring our financed emissions 

We announced our ambition to become a net 
zero bank in October 2020, including an aim 
to align our financed emissions to net zero by 
2050 or sooner. In May 2021, shareholders 
approved a climate change resolution at our 
AGM that commits us to set, disclose and 
implement a strategy with short- and 
medium-term targets to align our provision 
of finance with the goals and timelines of the 
Paris Agreement. 

Our analysis of financed emissions considers 
on-balance sheet financing, including project 
finance and direct lending, as well as financing 
we help clients access through capital markets 
activities. Given the different nature of these 
two forms of financing, we distinguish 
between ‘on-balance sheet financed’ and 
‘facilitated’ emissions where necessary in 
our reporting. Our analysis covers financing 
from both Global Banking and Markets, and 
Commercial Banking.

Financed emissions link the financing we 
provide to our customers and their activities 

in the real economy, and helps provide an 
indication of the greenhouse gas emissions 
associated with those activities. They form 
part of our scope 3 emissions, which include 
emissions associated with the use of a 
company’s products and services.

Our initial disclosures
We started with measuring our financed 
emissions for two emissions-intensive sectors: 
the oil and gas, and power and utilities 
sectors. On the following pages, we report  
on the results of our analysis for these two 
sectors. We plan to measure and report on an 
annual basis, and intend to extend our analysis 
in our Annual Report and Accounts 2022 and 
related disclosures. 

Our analysis relies on data disclosed by our 
customers and other sources that may result 
in a time lag of one year or longer. We chose 
to use 2019 data as the basis for our initial 
disclosures, having taken into consideration 
potential distortions to economic activity 
caused by the Covid-19 pandemic during 2020. 

The following pages also set out our initial 
2030 targets to align our on-balance sheet 
financed emissions for the oil and gas, and 
power and utilities sectors to the International 
Energy Agency’s (‘IEA’) net zero emissions  
by 2050 scenario. The scenario provides a 
science-based decarbonisation pathway for 
the global economy that is consistent with 
a 1.5°C global warming target. 

In developing our approach, we engaged  
with industry initiatives to help formulate our 
methodology for assessing and measuring 
financed emissions. In 2021, we were one of 
43 founding members of the Net-Zero Banking 
Alliance ('NZBA'), which seeks to reinforce, 
accelerate, and support the implementation 
of decarbonisation strategies for the banking 
sector. We also joined the Partnership for 
Carbon Accounting Financials (‘PCAF’), which 
seeks to define and develop greenhouse gas 
accounting standards for financial institutions.

What is included in 
our analysis

In 2021, we assessed our financed 
emissions related to the oil and gas, and 
power and utilities sectors using 2019 data. 
We believe these sectors are most material 
in terms of emissions, and are where we 
believe engagement and climate action 
have the greatest potential to effect change. 

For the oil and gas sector, we focused  
on upstream companies, and integrated  
or diversified energy companies. Our 
assessment of this portfolio included scope 
1, 2 and 3 greenhouse gas emissions of 
financed counterparties. By focusing on 
upstream and diversified energy producers, 
and including scope 3 greenhouse gas 
emissions, we believe we are accounting for 
the majority of emissions across the sector. 
These include emissions associated with 
the ultimate use of oil and gas products as  
a fuel source. We have excluded midstream 
and downstream companies within the 
sector to limit double-counting and to 

Sector 

Value chain in scope 

concentrate engagement with customers 
whose products contribute most to 
greenhouse gas emissions in the 
global economy.

For the power and utilities sector, our analysis 
focused on upstream power generation 
companies, including scope 1 and 2 
greenhouse gas emissions of financed 
counterparties. We believe power generation 
is where the majority of sector emissions 
occur through the use of fossil fuel as a source 
of energy. In analysing the power and utilities 
sector, we did not take account of scope 3 
greenhouse gas emissions because we believe 
them to be immaterial. We believe upstream 
power producers have the most potential to 
reduce greenhouse gas emissions by shifting 
to renewables and other sources of low-
emissions power generation.

Regarding the different types of greenhouse 
gas measured, we include CO2 and methane 
(measured in CO2e) for the oil and gas 
sectors, and CO2 only for the power and 
utilities sector due to data availability and 
emissions materiality.

To calculate on-balance sheet financed 
emissions, we used drawn balances at 31 
December 2019 related to wholesale credit 
and lending, which included business loans, 
trade and receivables finance, and project 
finance as the value of finance provided to 
customers in our analysis. We only included 
facilities with an original duration of  
12 months or longer having considered 
industry guidance. We plan to continue to 
review the scope of facilities included in our 
analysis and update our approach following 
industry guidance.

For facilitated emissions, we used the 
apportioned value of underwriting for debt 
and equity issuances and syndicated loans 
as the proportion of funds provided to 
companies. We refer to these collectively 
as capital markets activities. Although we 
applied a similar methodology to assess 
facilitated and on-balance sheet financed 
emissions, using PCAF guidance as our 
foundation, we expect to continue to  
report them separately for transparency.

Oil and gas

Upstream
(e.g. extraction)

Midstream
(e.g. transport)

Downstream
(e.g. fuel use)

Integrated/
diversified

Included in analysis

Power and
utilities

Upstream
(e.g. generation)

Midstream (e.g. transmission
and distribution)

Downstream
(e.g. retail)

HSBC Holdings plc Annual Report and Accounts 2021

47

ESG reviewESG review | Environmental

Measuring our financed emissions continued

Our analysis of oil and gas, and power 
and utilities portfolios

The table below summarises the results of our 
assessment of financed emissions using 2019 
data. It indicates the emissions associated 
with our financing activities in terms of both 
absolute emissions and emissions per unit of 
output relevant to each sector. The table also 
includes the PCAF data quality scores for the 
various components of our analysis, as 
explained further in the box on this page.

From our analysis, total absolute on-balance 
sheet financed emissions associated with our 
oil and gas portfolio were more than three 
times greater than those from power and 
utilities. Similarly, the emissions associated 
with each dollar invested, or economic 
intensity, for our oil and gas portfolio is  
more than triple that of our power and  
utilities portfolio. More than 80% of  
on-balance sheet financed emissions for  
our oil and gas portfolio were attributed  
to our customers’ scope 3 emissions. 

We found that data quality scores varied 
across the different components of our 
analysis, although not significantly. For the  
oil and gas portfolio, data quality scores for 
scope 3 emissions were found to be slightly 
higher due to lower availability of reported 
data. Differences between the data quality 
scores for on-balance sheet financed and 
facilitated emissions reflect the different 
composition of the customers and weighting 
of finance provided in each portfolio.

Financed emissions using 2019 data

Notes on data and 
methodology

PCAF provides guidance on how to assess 
and disclose greenhouse gas emissions 
associated with loans and investments. 
It also provides a common approach for 
addressing variability in the data available 
to assess emissions. 

We applied PCAF’s data quality score to  
the sources of data we used to determine 
counterparty emissions. The PCAF scores 
can be seen in the table below. 

The majority of our clients do not yet report 
the full scope of greenhouse gas emissions 
included in our analysis, in particular scope 
3 emissions. In the absence of client-
reported emissions, we estimated 
emissions using proxies based on company 
production and revenue figures. We 
validated data inputs used in our analysis 
with the global relationship managers for 
the top clients ranked by financed emissions 
and covering a significant majority of total 
financed emissions for each sector portfolio. 
Although we sought to minimise the use  
of non-company specific data, we applied 
industry averages in our analysis where 
company-specific data was unavailable.

The methodology and data used to assess 
financed emissions and set targets is new 
and evolving, and we expect industry 
guidance, market practice, and regulations 
to continue to change. We plan to refine 
our analysis using the data sources and 
methodologies available for the sectors 
we analyse, including, among others, the 
Science Based Targets initiative (‘SBTi’) and 
the Paris Agreement Capital Transition 
Assessment (‘PACTA’) methodology. We 
expect our data quality scores to improve 
over time as companies continue to expand 
their disclosures to meet growing regulatory 
and stakeholder expectations.

Our initial set of baselines and targets may 
require updating as data availability changes 
over time and methodology and climate 
science evolve. We plan to report financed 
emissions and progress against our targets 
annually and seek to be transparent in  
our disclosures about the methodologies 
applied. However, financed emissions 
figures may not be reconcilable or 
comparable year-on-year and targets  
may require re-evaluation.

 For further details of our approach and 
methodology, see our Financed Emissions – 
Approach and Methodology Update at www.
hsbc.com/who-we-are/esg-and-responsible-
business/esg-reporting-centre.

Absolute emissions1

Emissions intensity2

PCAF data quality scores3

Scope 1–2

Scope 3

Physical intensity  
(per unit of output)

Scope 1–2

Scope 3

On-balance sheet financed emissions — wholesale credit lending and project finance (2019)4,5

Oil and gas

Power and utilities

Facilitated emissions – capital markets (2019)6

Oil and gas

Power and utilities

6.0†

10.1†

3.9†

4.4†

29.8†

N/A

25.6†

N/A

68.4

0.55

70.7

0.36

2.9†

3.0†

2.4†

3.5†

3.4†

N/A

2.9†

N/A

1  Absolute emissions are measured by million tonnes of carbon dioxide equivalent (‘Mt CO2e’). 
2  For the oil and gas portfolio, physical emissions intensity is measured in million tonnes of carbon dioxide equivalent per exajoule (‘Mt CO2e/EJ’); for the power and 

utilities sector, it is measured in million tonnes of carbon dioxide equivalent per terawatt hour (‘Mt CO2e/TWh’). 

3  PCAF scores where 1 is high and 5 is low. This is a weighted average score based on loans/advances for on-balance sheet financed emissions, and apportioned 

value for facilitated emissions.

4  Total loans and advances analysed in 2019 were $23.5bn, comprising $12.3bn for the oil and gas sector, and $11.2bn for the power and utilities sector, representing 
1.8% and 1.6% respectively of wholesale credit and lending and project finance at 31 December 2019. This compares with a total wholesale loan exposure of 7% 
for these two sectors overall, as reported in our TCFD disclosures for 2019, which covered the full value chain and all financing activities. On-balance sheet 
economic intensity for the oil and gas sector was 2.9 Mt CO2e/$bn, and for power and utilities it was 0.9 Mt CO2e/$bn. 

5  For the oil and gas sector, the value chain analysed covers upstream and integrated/diversified operations. For the power and utilities sector, the value chain 

analysed covers upstream operations.

6 Total capital markets activities analysed in 2019 was $21.1bn, comprising $15.4bn for oil and gas, and $5.7bn for power and utilities.
†  Data is subject to limited assurance by PwC in accordance with International Standard on Assurance Engagements 3410. ‘Assurance engagements on greenhouse 

gas statements’. For further details, see our Financed Emissions Methodology and PwC Assurance Report, which are available at www.hsbc.com/who-we-are/
esg-and-responsible-business/esg-reporting-centre.

48

HSBC Holdings plc Annual Report and Accounts 2021

Environmental

Measuring our financed emissions continued

Our oil and gas, and power and 
utilities targets
We have defined targets to 2030 for the 
on-balance sheet financed emissions of our oil 
and gas, and power and utilities portfolios, as 
set out below. These are aligned with global 
sector decarbonisation pathways set out by 
the IEA in its net zero emissions by 2050 
scenario. For facilitated emissions, we are 
supporting efforts to establish an industry 
standard. When this becomes available, we 
intend to refresh our analysis and set interim 
targets. The methodology for targets is set out 
in our Financed Emissions Methodology, 
which is available at www.hsbc.com/
who-we-are/esg-and-responsible-business/
esg-reporting-centre.

For the oil and gas sector, we target a 
reduction of 34% in absolute on-balance 
sheet financed emissions by 2030, using  
2019 as our baseline. Our target is equal to  
the percentage reduction that the IEA 
indicates in its scenario for global sector 
emissions to 2030 from a 2019 baseline.  
We chose to use an absolute emissions metric 
in order to reflect a direct link to reducing 
greenhouse gas emission in the real economy. 
Our on-balance sheet financed emissions for 
2019 was 35.8 million tonnes of carbon 
dioxide equivalent (‘Mt CO2e’).

For the power and utilities sector, we target an 
on-balance sheet financed emissions intensity 
of 0.14 million tonnes of carbon dioxide 
equivalent per terawatt hour (‘Mt CO2e/TWh’) 
by 2030. Our emissions intensity target is 
equal to the global sector average emissions 
intensity for 2030 set out by the IEA, and 
represents a 75% reduction compared with 
our baseline of 0.55 Mt CO2e/TWh for 2019. 
We chose to use an emissions intensity 
metric, rather than absolute emissions, as the 
basis for our 2030 target for the power and 
utilities portfolio to reflect the need to reduce 
global greenhouse gas emissions from power 
generation while also meeting the anticipated 
increase in electricity demand. Electrification 
is central to the transition pathways for 
transport, heating, and other economic 

activities. This will require scaling up 
investment and financing for renewable and 
other low-emission sources of electricity to 
meet demand. 

Our approach to target setting is in line with 
industry guidance on assessing portfolio 
alignment, including from – among others – 
the NZBA and the Financial Services Taskforce 
('FSTF'). Our approach does not rely on 
purchasing offsets to achieve any financed 
emissions targets we set. 

In selecting a reference scenario to assess 
alignment to net zero, we reviewed the IEA’s 
net zero emissions by 2050 scenario against 
other available science-based 1.5°C scenarios. 
We believe it provides the greatest level of 
detail for assessing alignment across relevant 
sectors at a global level. Choosing this 
scenario allows us to make comparisons of 
our portfolio targets with other banks and 
peers who use this same scenario.

We have used the global decarbonisation 
pathway set out by the IEA’s net zero 
emissions by 2050 scenario by sector as the 
reference for setting targets for our oil and 
gas, and power and utilities portfolios. The 
IEA’s net zero emissions by 2050 scenario 
does not currently provide decarbonisation 
pathways at a regional level. We completed 
analysis to help ensure a global pathway is 
relevant for our financing portfolio and we will 
continue to assess this as further information 
becomes available over time. For further 
details on the IEA net zero by 2050 scenario, 
see www.iea.org/reports/net-zero-by-2050.

Oil and gas – absolute emissions
(Mt CO2e)

e
2
O
C
t

M

40

35

30

25

20

15

10

5

0

Key:

Target 34%
reduction
by 2030
from 2019

2019

2025

2030

2035

2040

2045

2050

HSBC 2019 on-balance sheet financed
emissions baseline
IEA Net Zero Emissions by 2050 scenario

Power and utilities – emissions 
intensity (Mt CO2e/TWh)

Target 0.14 Mt CO2e/TWh
by 2030, representing
75% reduction from 2019

/

h
W
T
e
2
O
C
t

M

0.60

0.55

0.50

0.45

0.40

0.35

0.30

0.25

0.20

0.15

0.10

0.5

0

2019

2025

2030

2035

2040

2045

2050

Key:

HSBC 2019 on-balance sheet financed
emissions baseline
IEA Net Zero Emissions by 2050 scenario

Helping to power a European first

We used our global reach and local expertise to attract a diverse base of international and 
domestic investors in March 2021 when Greece’s largest power producer issued a €650m 
high-yield sustainability-linked bond – a first for Europe. We acted as joint global coordinator 
and left-lead bookrunner on the bond, which committed Public Power Corporation to reducing 
its carbon emissions by 40% by the end of 2022, or face higher financing costs. We were also 
ratings adviser and ESG structuring adviser supporting the company in achieving an improved 
sustainability performance target, measured using a Sustainalytics rating. Public Power 
Corporation has committed to end its reliance on lignite – low-grade brown coal – plants  
over the next few years and significantly boost its solar and wind power capacity.

HSBC Holdings plc Annual Report and Accounts 2021

49

ESG review 
 
ESG review | Environmental

Measuring our financed emissions continued

Embedding financed emissions analysis 
into our business
Our net zero ambition is underpinned by our 
relationships with customers and collective 
engagement, so that we are able to support 
our customers to take action to address 
climate change in their own activities. 

To achieve this, we aim to embed how we 
manage and assess financed emissions within 
our financing portfolios to provide a basis for 
informing client engagement and business 
management decisions from a climate 
perspective. 

There are three key components we are 
undertaking to achieve these objectives. 

 – We are placing climate and sustainability 
at the centre of our engagement with 
customers, and in particular those 
customers with the greatest potential 
to effect change.

 – We are seeking to support our customers in 
their transition to net zero and a sustainable 
future. We aim to provide and facilitate 
$750bn to $1tn of sustainable finance  
and investment by 2030 (see page 53).

 – We are working to embed financed 

emissions considerations into our business 
activities and culture. Our global businesses 
have had active roles alongside our 
Corporate Sustainability, Global Risk and 
Compliance, and Global Finance functions 
in developing our financed emissions 
approach in 2021. Collaboration across  

Financed emissions targets to 2030

the organisation will continue to be 
essential. This includes plans to strengthen 
our climate data and analytics capability  
to inform decision making and portfolio 
management, as well as expanding the 
resources to support business engagement.

As part of our annual disclosures for the year 
ending 31 December 2022, we plan to report 
baseline financed emissions and targets for 
the following sectors: coal mining; aluminium; 
cement; iron and steel; and transport 
(including automotive, aviation and shipping). 
We expect to also report on the agriculture, 
and commercial and residential real estate 
sectors in our annual disclosures for the year 
ending 31 December 2023 at the latest, 
following baseline analysis for these sectors.

In 2022 we will begin work on our climate 
transition plan, which will bring together – in 
one place – how we plan to embed our 2050 
and 2030 net zero targets into the Group’s 
strategy, processes, policies and governance. 
We plan to publish this in 2023, and update on 
progress annually thereafter as part of our 
annual disclosures.

The transition to a net zero global economy 
has implications for our customers across 
industries and geographies. It introduces  
new risks that need to be managed, as well as 
opportunities. Given our global presence and 
relationships with clients across industries and 
customer groups, we recognise the role we 
can play in helping catalyse this change.

Steering the automobile 
transition

We have been working with Ford Motor 
Co. towards its sustainability goals with 
two sustainability-linked transactions  
in 2021. In September, we supported 
Ford as it extended its revolving credit 
facilities worth a combined $15.5bn. 
Ford amended the credit facilities to 
include sustainability-linked targets, 
which included lower emissions from 
global manufacturing facilities and 
reduced exhaust emissions from 
passenger vehicles sold in Europe.

In November, we also acted as a joint 
lead manager on Ford’s $2.5bn inaugural 
10-year green bond under its new 
sustainable finance framework. This 
framework targets investments in clean 
transportation, clean manufacturing, 
advancing economic opportunity and 
equity for underrepresented and/or 
disadvantaged populations and 
community revitalisation.

Oil and gas

Power and utilities

Target metric

Our 2019 baseline

Our 2030 targets1

Absolute emissions 
(Mt CO2e)2

Physical 
emissions intensity  
(Mt CO2e/TWh)3

35.8

0.55

34%
Mt CO2e reduction in oil and gas absolute  
on-balance sheet financed emissions

0.14
Mt CO2e/TWh power and utilities on-balance sheet financed 
emissions intensity, representing 75% reduction from 2019

1  Our 2030 targets are based on IEA net zero emissions by 2050 scenario references. The methodology for targets is set out in our Financed Emissions Methodology, 

which is available at www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre.

2 For oil and gas, the IEA indicates in its scenario a reduction of 34% in global sector scope 1, 2 and 3 emissions (Mt CO2e) to 2030 from a 2019 baseline. 
3 For power and utilities, the IEA indicates a global sector scope 1 and 2 emissions intensity at 2030 of 0.14 Mt CO2e/TWh electricity produced.

50

HSBC Holdings plc Annual Report and Accounts 2021

Environmental

Our approach to our own operations

Part of our ambition to be a net zero bank is  
to achieve net zero carbon emissions in our 
operations and supply chain by 2030 or sooner. 

Reduce, replace and remove
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. We plan to remove 
the remaining emissions that cannot be 
reduced or replaced by procuring, in 
accordance with prevailing regulatory 
requirements, high-quality offsets at a 
later stage. 

Our energy consumption
In October 2020, we announced our ambition 
to reduce our energy consumption by 50% by 
2030, against a 2019 baseline. To do this, we 
plan to reduce our energy consumption by 
optimising the use of our real estate portfolio.

In 2017, we announced our ambition to 
achieve 100% renewable power across our 
operations by 2030, joining other global 
companies in the RE100 initiative. In 2021, 
37.5% of our electricity was renewable, mainly 
due to our power purchase agreements of 
wind and solar energy in the UK, Mexico and 
India. As part of this energy replacement 
strategy, in September 2021, we signed our 
fourth power purchase agreement for the  
UK. This agreement, which will support the 
development of the Sorbie Wind Farm project 
in Ayrshire, south-west of Glasgow, will result 
in approximately 90% of our UK electricity 
being sourced from such renewable projects 
(for further details, see page 19). We continue 
to look for opportunities to procure green 
energy in each of our markets. A key challenge 
is the limited opportunity to pursue power 
purchase agreements or green tariffs in key 
markets due to regulations. 

We are considering the impact on our 
emissions from our colleagues working from 
home during the Covid-19 pandemic, and in 
the future, as they embrace more flexible ways 
of working. Using the EcoAct methodology, 
we calculated the emissions of our colleagues 
working from home was 4% of total electricity 
emissions in 2021. This only includes energy 
consumption from the IT equipment and 
lighting. We do not report employee home 
working emissions in our scope 1 and 2 
performance data.

Business travel and employee commuting
Our travel emissions continued to reduce in 
2021 as a result of ongoing international travel 
restrictions caused by the pandemic. As 
international travel gradually resumes, we will 
update our internal policies with the aim to 
halve travel emissions by 2030, compared with 
pre-pandemic levels. We will continue to 
encourage the use of technological solutions 
where possible to provide connectivity with 
colleagues and customers. To ensure we are 
following best practices, we updated our air 
travel reporting methodology in 2021 to 
include cabin class and indirect climate change 
effects in our travel emission calculations. 

We continue to pursue the reduction of 
vehicles we use in our global markets, and 
accelerate the use of electric vehicles.

Focus on natural resources
Alongside our net zero operations ambition, 
our aim is to be a responsible consumer of 
natural resources. Building on the success 
of our previous operational environmental 
strategy, we are identifying the key 
opportunities where we can lessen our  
wider environmental impact over the coming 
decade. We plan to set interim and  
2030 global targets to maintain short-term 
momentum while also changing behaviour 
through ambitious long-term goals.

Our environmental 
and sustainability 
management policies

Our buildings policy recognises that 
regulatory and environmental 
requirements vary across geographies 
and may include environmental 
certification. The policy is supported 
by Corporate Services procedures on 
environmental and sustainability 
management, ensuring HSBC's 
properties continually reduce their overall 
direct impact on the environment. 
Detailed design considerations 
documented in our Global Engineering 
Standards aim to reduce or avoid 
depletion of critical resources like energy, 
water, land, and raw materials. Suppliers 
are required to adhere to strict 
environmental management principles 
and reduce their impact on the 
environment in which they operate.

Our presence in environmentally sensitive areas

As a global organisation, our branches, offices and data centres may be located in – or near – 
areas of water stress and/or protected areas of biodiversity, as we support our customers and 
communities in these locations. 

Approximately 28% of our global offices, branches and data centres are located in areas 
identified as being subject to high and very high water stress, accounting for 37% of our 
annual water consumption. These are predominantly urban or city centre locations with  
large, concentrated populations. Our industry is a low user of potable water, and we have 
implemented measures to further reduce water consumption through the installation of flow 
restrictors, auto-taps and low or zero flush sanitary fittings. 

In addition, 1.7% of our global office, branch and data centre portfolio lies in protected areas 
and areas of biodiversity. We strive through our design, construction and operational 
standards to ensure that, where possible, our premises do not adversely affect the 
environment or natural resources in these areas.

HSBC Holdings plc Annual Report and Accounts 2021

51

ESG reviewESG review | Environmental

Our approach to our own operations continued

Engaging 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. 

In 2020, we began the three-year process  
of encouraging our largest suppliers to make 
their own carbon commitments, and to 
disclose their emissions via the CDP supply 
chain programme. The target for 2021 was for 
suppliers representing 45% of total supplier 
spend to have completed the CDP 
questionnaire. In total, suppliers representing 
51.2% of total supplier spend completed the 
CDP questionnaire. 

We will continue to engage with our supply chain 
with the aim of increasing the response rate, and 
have expanded the scope of our engagement 
with the CDP programme for 2022. 

This engagement has allowed us to work on 
a new supply chain emissions methodology 
using actual supplier data. While substantial 
progress has been made, this methodology 
requires further refinement before it is ready 
to be disclosed. 

Our aim is to use real supplier data where we 
have it through our engagement with the CDP 
programme. Where we do not have CDP data 
for suppliers, we will use industry averages 
and spend data to define the contribution to 
our supply chain emissions.

In 2021, we also updated our supplier selection 
process to include carbon emissions questions 
in new commercial engagements. This signals 
to our suppliers the importance we place in 
the transition to net zero, from the start of 
the engagement.

Working with our 
Cloud partners

Using Cloud technologies is one of the 
ways we are reducing our IT carbon 
footprint. Our Cloud providers run more 
efficiently than our own data centres due 
to the lower impact of shared resources. 
In 2021, we engaged with our Cloud 
partners to improve our understanding 
of our carbon footprint on Cloud, and 
collaborate towards more efficient 
applications. Our partners also continue 
to assist in the education of our internal 
IT colleagues by delivering sustainability 
learning sessions, and sharing research 
and experience.

Our greenhouse gas emissions in 2021
We report our emissions following the 
Greenhouse Gas Protocol, which incorporates 
the scope 2 market-based emissions 
methodology. We report greenhouse gas 
emissions resulting from the energy used in 
our buildings and employees’ business travel. 
Due to the nature of our primary business, 
carbon dioxide is the main type of 
greenhouse gas applicable to our operations. 
While the amount is immaterial, our current 
reporting also incorporates methane and 
nitrous oxide for completeness. We do not 
report employee home working emissions 
in our scope 1 and 2 performance data. 
Our environmental data for our own 
operations is based on a 12-month period 
to 30 September.

In 2021, we continued to decrease our 
emissions, achieving a 50.3% reduction 
compared with our 2019 baseline. This was 
mainly attributed to travel restrictions and the 
reduction of usage of our buildings due to the 
Covid-19 pandemic. We also implemented 

over 700 energy conservation measures that 
amounted to an estimated energy avoidance in 
excess of 14.9 million kWh.

In 2021, we collected data on energy use and 
business travel for our operations in 28 countries 
and territories, which accounted for 
approximately 92% of our FTEs. To estimate  
the emissions of our operations in countries and 
territories where we have operational control and 
a small presence, we scale up the emissions data 
from 92% to 100%. We then apply emission 
uplift rates to reflect uncertainty concerning the 
quality and coverage of emission measurement 
and estimation. 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.

 For further details on our methodology,  
our third-party assurance report and relevant 
environment key facts, see our ESG Data Pack 
at www.hsbc.com/esg.

Greenhouse gas emissions
(total and FTE)2

900,000

800,000

700,000

600,000

500,000

400,000

)
s
e
n
n
o
t
(

s
n
o
i
s
s
i
m
e

e
2
O
C

l

a
t
o
T

300,000

2019

Key:

4.0

3.5

3.0

2.5

2.0

1.5

C
O
2
e

p
e
r

F
T
E
(
t
o
n
n
e
s
)

2020

1.0

2021

Total greenhouse gas emissions (tonnes CO2e)

Greenhouse gas emissions per FTE
(tonnes CO2e/ FTE)

Greenhouse gas emissions in 
tonnes CO2e

Greenhouse gas emissions in tonnes 
CO2e per FTE

Energy consumption in kWh in ‘000s

2021

20202

2021

20202

Total

341,000 444,000

Total

1.52

1.93

Total Group

Scope 1 – direct1

22,000

20,000

UK only

2021

2020

833

227

928

247

Scope 2 – indirect1

307,000 343,000

Scope 3 – indirect 
(Upstream activities – 
business travel only)1

Included  
energy UK

12,000

81,000

10,000 

8,000

1  Data in 2021 is subject to limited assurance by PwC in accordance with International Standard on 

Assurance Engagements 3410 ‘Assurance engagements on greenhouse gas statements’. For further 
details, see GHG Reporting Guideline 2021 and PwC Assurance Report at www.hsbc.com/our-
approach/esg-information/esg-reporting-and-policies. 

2  Data for 2019 and 2020 has been revised as we have updated our air travel reporting methodology to 
include the cabin class travel and the impact of radiative forces. The emissions of HSBC's vehicle fleet 
were reported under scope 3 for these two years. For 2019 and 2020, see CO2 Emissions Reporting 
Guideline, ESG Data Pack, and PwC Assurance Report, which are available at www.hsbc.com/
our-approach/esg-information/esg-reporting-and-policies. 

52

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
Environmental

Supporting 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 is by 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.

In 2021, we acted on more green, social, 
sustainability and sustainability-linked bonds 
for clients than in 2020. We were mandated to 
act as structuring adviser on nine ESG-related 
government bonds, including for the UK, 
Saudi Arabia, Canada and Indonesia. We were 
recognised by Euromoney as the Best Bank 
for Sustainable Finance in Asia and the Middle 
East for 2021. 

In 2021, we continued to expand the horizons 
of sustainable finance: 

 – We acted as global coordinator and 

bookrunner for POSCO, the South Korean 
steelmaker, when it raised a €1.06bn 
five-year green convertible bond, which was 
South Korea’s first green convertible bond 
and its largest equity-linked deal, to help 
establish and expand its rechargeable 
battery and hydrogen business.

 – We launched a £500m Green SME Fund 
in the UK to help remove the barriers  
small businesses face in the transition  
to a lower-carbon economy. 

 – We partnered with Walmart and CDP to 

create the industry’s first sustainable supply 
chain finance programme to use science-
based targets to encourage suppliers to 
reduce emissions in alignment with the 
Paris Agreement. The initiative also included 
additional criteria for suppliers to meet 
certain scores on their environmental 
disclosures with the CDP. 

 – We launched green mortgages for 

customers in the UAE and Singapore  
to finance their purchase of homes that 
have been respectively accredited by the 
LEED and BCA Green Mark schemes as 
energy efficient. 

 – We supported the transition within  

the aviation sector, acting as the sole 
coordinator for a £1bn sustainability-linked 
loan – backed by the UK’s export credit 
agency, UK Export Finance – to British 
Airways plc, with the loan margin linked 
to aircraft fuel efficiency.

Sustainable finance summary1

Balance sheet-related transactions provided

Capital markets/advisory (facilitated)

Investments (assets under 
management – flows)

Total contribution2

Cumulative 
progress 
since 2020 
($bn)

36.6

78.7

11.4

126.7

2020 
($bn)

10.4

30.0

3.7

44.1

2021 
($bn)

26.2

48.7

7.7

82.6

1  This table has been prepared in accordance with our Sustainable Finance Data Dictionary 2021, which 
includes green, social and sustainability activities. The amounts provided and facilitated include: the 
limits agreed for balance sheet-related transactions provided, the proportional share of facilitated 
capital markets/advisory activities and the net new flows of sustainable investments within assets 
under management. For our sustainable finance ambition and progress figure, see www.hsbc.com/
who-we-are/esg-and-responsible-business/esg-reporting-centre.

2  Data is subject to limited assurance by PwC in accordance with International Standard on Assurance 
Engagements 3000 (Revised) ‘Assurance Engagements other than Audits or Reviews of Historical 
Financial Information’. For our Sustainable Finance Data Dictionary 2021 and PwC Assurance Report, 
see www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre.

Transition solutions
We aim to help our customers transition 
to net zero and a sustainable future through 
providing and facilitating between $750bn and 
$1tn of sustainable finance and investment by 
2030. Our sustainable finance ambition has 
enabled sustainable infrastructure and energy 
systems, promoted decarbonisation efforts 
across the real economy, and enhanced investor 
capital through sustainable investment. 

Since 1 January 2020, we have provided and 
facilitated $109.8bn of sustainable finance, 
$11.7bn of sustainable investment and $5.2bn 
of sustainable infrastructure spanning more 
than 1,193 transactions, as defined in our data 
dictionary. This comprised 29% of green, 
social and sustainability-linked lending to 
companies, 9% of investments managed and 
distributed on behalf of investors, and 62% 
that facilitated the flow of capital and provided 
access to capital markets. Our data dictionary 
defining our sustainable finance and 
investment continues to evolve, which takes 
into account the revised marketing standards 
and guidelines. Our progress will be published 
each year, and we will seek to continue to be 
independently assured.

 The breakdown of our sustainable finance and 
investment progress is included in our ESG Data 
Pack. The detailed definitions of the contributing 
activities for sustainable finance are available in 
our revised Sustainable Finance Data Dictionary 
2021. For our ESG Data Pack, Sustainable 
Finance Data Dictionary and PwC Assurance 
Report, see www.hsbc.com/who-we-are/
esg-and-responsible-business/esg- 
reporting-centre. 

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  

$126.7bn 

Cumulative progress since 2020 on  
our ambition to provide and facilitate 
sustainable finance and investment.
(Target: $750bn to $1tn by 2030)

Sustainable finance 
and investment

We define sustainable finance and 
investment as:

 – any form of financial service that 

integrates ESG criteria into business 
or investment decisions; and

 – financing, investing and advisory 

activities that support the 
achievement of UN Sustainable 
Development Goals (‘SDGs’), 
including but not limited to the aims 
of the Paris Agreement on 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-centre.

HSBC Holdings plc Annual Report and Accounts 2021

53

ESG reviewESG review | Environmental

Supporting customers through transition continued

a new generation of sustainable infrastructure 
quickly. 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 this, we are leading the Finance 
to Accelerate the Sustainable Transition-
Infrastructure (‘FAST-Infra’) initiative, which  
in November 2021 launched the Sustainable 
Infrastructure (SI) label (see box to the right). 

In September 2021, we partnered with 
Temasek to establish (subject to regulatory 
approval) a debt financing platform dedicated 
to sustainable infrastructure projects with an 
initial focus on south-east Asia. The platform 
aims to deploy blended finance at scale over 
time to unlock more marginally bankable 
projects and create a tradeable asset class. 
We also co-chair the Coalition for Climate 
Resilient Investment, which was launched 
at the UN Climate Action Summit to help 
investors and policymakers understand 
infrastructure investments and incorporate 
physical climate risk 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. 

We expanded our investment offering for 
private banking and wealth clients, launching 
several cross-border ESG funds including a 
Sustainable Healthcare fund, to help investors 
generate long-term returns while contributing 
to the UN SDGs on good health and well-
being. We launched a green certificate of 
deposit for the first time in renminbi to clients 
in Hong Kong and Singapore, as well as the 
first Hong Kong dollar-denominated 
sustainability-linked bonds to clients in Hong 
Kong. We also expanded our ESG offering to 
emerging markets, including a Global Equity 
Climate Change fund in India that helps clients 
to capture emerging opportunities during the 
low-carbon transition journey. 

HSBC Asset Management strengthened  
its proposition with the formation of a new 
Sustainability Office, which is responsible  
for the delivery of our sustainability strategy 
and business-wide transition to sustainable 
investment. Our endeavour is to influence 
the markets through active engagement on 
ESG issues. HSBC Asset Management’s 
stewardship activities, through its portfolio 
managers and other investment analysts, 
led to ESG issues being raised in engagements 
with over 1,800 corporate and non-corporate 
issuers in 73 markets in 2021. We also voted 
on over 84,000 resolutions at over 8,400 
company meetings in 72 markets by year end. 

At HSBC Life, our insurance business, we 
continued to build our sustainable investment 
portfolios to support the UN SDGs and the 
Paris Agreement. During 2021, we made an 
effort to increase our sustainable investment 
across our different manufacturing entities in 
Asia, Europe and Latin America. The intent is 
to continue to build on the work and grow the 
assets under management. While previously, 
HSBC Life invested in only green bonds within 
the spectrum of traditional bond instruments, 
in 2021 it also invested in social, sustainability 
and sustainability-linked bonds.

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 in our client engagement 
and investment solutions across our 
business functions.

We provide our customers with ESG insights 
and foster industry development. HSBC Global 
Research published over 200 climate and 
ESG-related reports in 2021, accompanied by 
approximately 525 client meetings and close 
to 30 client webcasts and events. 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 five episodes of the 
ESG Brief podcast. ESG Insights from HSBC 

The Sustainable 
Infrastructure (SI) label

In 2021, FAST-Infra launched the 
Sustainable Infrastructure (SI) Label – a 
consistent, globally applicable labelling 
system designed to identify and 
evaluate sustainable infrastructure 
assets. The use of the label will help to 
address the estimated $6.9tn of annual 
investment that the OECD says is 
required until 2030 to meet the 
sustainable infrastructure objectives  
of the Paris Agreement. We helped 
conceive the FAST-Infra initiative, 
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.

Global Research are also repackaged  
for retail investors as a series known as 
#WhyESGMatters. Through our sustainable 
finance think tank, HSBC Centre of 
Sustainable Finance, we launched 42 reports 
and collaborated with 15 partners to provide 
thought leadership on decarbonisation 
strategies and strengthen the financial system 
response to climate change. The centre  
and our reports are publicly available at  
www.sustainablefinance.hsbc.com. 

 For further details of our net zero ambition,  
see www.hsbc.com/who-we-are/our-climate-
strategy/becoming-a-net-zero-bank.

Developing a beacon of green luxury

The former US embassy at Grosvenor Square, London, is being converted into a luxury hotel 
and could become a model of sustainability for future hospitality developments. Qatari Diar – 
the property arm of Qatar’s sovereign wealth fund – is converting the former embassy into the 
Chancery Rosewood, which will feature green roofs, energy efficiency measures and a system 
to reduce water consumption. The Chancery Rosewood is aspiring to achieve a BREEAM 
‘Outstanding’ rating for sustainable development, which would make it the first five-star hotel 
and first UK hotel to achieve this rating under the 2014 assessment scheme. As mandated lead 
arranger, facility and security agent, hedge coordinator, and green loan coordinator, in April 
2021 we helped Qatari Diar secure a £450m green loan for the landmark development.

54

HSBC Holdings plc Annual Report and Accounts 2021

Environmental

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. 

EverGreening Alliance in November 2021, 
supporting the alliance’s aim to deliver a 
$150m nature-based carbon programme 
in Africa.

We are working closely with a range of 
partners to accelerate investment in natural 
resources, technology and sustainable 
infrastructure to reduce emissions and 
address climate change.

Climate Asset Management is one of the  
three founding partners of the Natural Capital 
Investment Alliance, which aims to mobilise 
$10bn towards natural capital themes by the 
end of 2022.

Natural capital as an emerging 
asset class
As part of our goal to unlock new climate 
solutions, we announced the launch of  
Climate Asset Management, a joint venture 
with Pollination, in 2020. Climate Asset 
Management’s ambition is to become the 
world’s largest dedicated natural capital  
asset management company. Its investment 
strategies are grounded in nature-based 
investments, including sustainable forestry, 
regenerative agriculture, nature-based carbon 
projects, and exploration of new forms of 
natural capital. Climate Asset Management 
established a partnership with the Global 

Backing new technology and innovation
Addressing climate change requires innovative 
ideas. By connecting financing with fresh 
thinking, we can help climate solutions to 
scale to support sustainable growth. 

Our Climate Solutions Partnership aims to 
scale up climate innovation ventures and 
nature-based solutions, as well as help the 
energy sector transition towards renewable 
sources in Asia. For further details, see 
page 77. 

We have expanded our venture debt platform 
to support climate technology hardware and 
software companies that are growing rapidly. 
In 2020, we committed to fund $100m to 
climate technology (climate tech) companies 
through this platform. We closed our first  
two deals in 2021 and expect to achieve the 
$100m goal by the end of the first quarter  
of 2022. Consequently, we have raised our 
commitment to $250m.

HSBC Asset Management has also developed 
a new venture capital capability that provides 
institutional and private banking customers 
with opportunities to invest in technology 
start-ups addressing global climate change 
challenges. We launched the first fund in 
November 2021 and provided it with  
a cornerstone investment.

Our climate technology venture debt  
and venture capital platforms invest in 
companies that are developing innovative 
technological solutions that help companies 
and governments understand, track and 
reduce their greenhouse gas emissions.

Biodiversity and natural capital strategy 

We recognise that achieving net zero goes 
hand in hand with halting and reversing nature 
loss. Nature loss, which refers to the decline 
of natural capital, ecosystem services and 
biodiversity, is one of the greatest systemic 
risks to the global economy and the health 
of people and the planet. 

Investing in nature
By addressing nature-related risks and 
investing in nature, we have an opportunity 
to accelerate the transition to net zero, help 
tackle climate change and open up a more 
resilient and inclusive global economy.

We recognise that more needs to be done to 
assess and manage our exposure to nature-
related risks and that collective initiatives are 
needed to progress at pace. In 2021, we joined 
several working groups dedicated to helping 
us progress on this journey, such as the 
Taskforce on Nature-related Financial 
Disclosures (‘TNFD’). For further details on 
the nature-related initiatives we have joined, 
see ‘Key external memberships’ in the box 
on the right.

Catalyst for change
We are committed to playing a key role as a 
catalyst for change, using our scale, influence, 
and financing to help preserve natural capital 
and protect biodiversity as a component of our 
net zero ambition. In 2021, we facilitated green 
and blue bonds, as well as provided lending to 
corporate and sovereign clients for sustainable 
projects. Highlights included:

 – We co-led the provision of $90m of green 

loan facilities to support Instar Asset 
Management’s acquisition of PRT Growing 
Services, North America’s largest producer 
of container-grown forest seedlings. 

 – We launched the world’s first broad-based 

biodiversity screened equity indices, 
developed jointly with Euronext and  
Iceberg Data Lab, to explore ways to apply  
a biodiversity benchmark to trading and 
investment activities. 

 – Our asset management business published 

its biodiversity policy to publicly explain how 
our analysts address nature-related issues. 
In 2021, it also engaged with companies in 
the food industry on how to manage their 
suppliers’ impact on biodiversity. For further 
details on the biodiversity policy, see:  
www.assetmanagement.hsbc.com/
about-us/responsible-investing/policies. 

Key external 
memberships

Our nature-related external memberships 
and endorsements include:

 – Taskforce on Nature-related Financial 

Disclosures 

 – Cambridge Institute on Sustainability 
Leadership’s nature-related financial 
risks working group

 – Accountability Alignment on 
Deforestation Working Group 

 – Business for Nature’s Call to Action 

 – Get Nature Positive

 – Signatory by the asset management 

business to the Finance for 
Biodiversity pledge

  For further details of our sustainability-
related memberships, see www.hsbc.
com/who-we-are/our-climate-strategy/
sustainability-memberships.

HSBC Holdings plc Annual Report and Accounts 2021

55

ESG reviewESG review | Environmental

Our approach to climate risk
Managing risk for our stakeholders

We see managing climate risk as an 
opportunity to create value for our customers, 
investors, people and communities in which 
we operate. We manage climate risk across all 
our businesses in line with our Group-wide risk 
management framework. Our most material 
risks in terms of managing climate risk relate 
to corporate and retail client financing within 
our banking portfolio, but there are also 
significant responsibilities in relation to asset 
ownership by our insurance business and 
employee pension plans, as well as from the 
activities of our asset management business. 

We tailor our underlying policies and controls 
to manage the different risks and exposures  
to reflect these respective roles to meet the 
needs of our key stakeholders. In the table 
below, we set out our duties to our 
stakeholders in our four more material roles.

 For further details of our approach to climate risk, 
see Environmental, social and governance risk on 
page 125 and Climate-related risks on page 131.

Banking
Our banking business is well positioned to 
support our 40 million personal, wealth and 
corporate customers manage their own 
climate risk through financing. For our 
wholesale customers, we use our corporate 

questionnaire as part of our transition risk 
framework to understand their climate 
strategies and risk. We also use our climate 
change stress testing and scenario analysis 
capabilities to provide insights on the 
long-term effects of transition and physical 
risks across our retail and wholesale banking 
portfolios (for further details, see page 57).  
In December, we announced our thermal coal 
phase-out policy (see page 62) and we will  
use our deep relationships to partner with 
customers in this sector to help them 
transition to cleaner, safer and cheaper  
energy alternatives. 

Asset management
HSBC Asset Management managed over 
$630bn assets – including assets managed for 
parts of HSBC Insurance and employee 
pensions – at the end of 2021. With the 
majority of assets managed in ESG-integrated 
strategies, it treats climate change risk as a 
key feature of the investment decision-making 
process. Investment teams examine and 
determine the level of importance of potential 
ESG risks that could impact current and/or 
future value of issuers. These risks are 
reflected in proprietary issuer ESG scoring 
methodology and are embedded into 
investment processes. Portfolio management 
tools also enable investment teams to assess 

Banking
We seek to manage the climate risk in 
our banking portfolios through our 
developing risk appetite and policies for 
our financial and non-financial risks. This 
helps enable us to identify opportunities 
to support our customers, while 
continuing to meet the expectations of 
our shareholders and regulators.

Employee pensions
Our employee pension plans each manage 
climate risk in line with their fiduciary duties 
and local regulatory requirements, with 
global corporate policy encouraging 
consideration of ESG risks when selecting 
investments. We are developing internal 
climate risk exposure reporting for our largest 
plans, pending more widespread adoption of 
consistent reporting standards. 

their portfolios for climate-related risks, as part 
of ongoing portfolio management activities. 
We continue to lead on the analysis of 
climate-related issues, in particular transition 
risks, and their impact on financial markets. 
Our analysts carry out proprietary research 
and collaborate with outside experts and 
industry initiatives.

Employee pensions 
The Trustee of the HSBC Bank (UK) Pension 
Scheme, our largest plan with $51bn assets 
under management, announced an ambition 
in 2021 to achieve net zero greenhouse gas 
emissions across its defined benefit and 
defined contribution assets by 2050. To help 
achieve this, it is targeting a real economy 
emissions reduction interim target of 50% 
by 2030 for its equity and corporate 
bond mandates.

The weight given to climate-related factors 
in the asset allocation of this plan’s defined 
contribution fund was strengthened during 
2021 to target additional green revenue and 
lower carbon emissions and reserves, and 
now excludes companies whose revenues 
are substantially derived from coal extraction 
or coal power generation. 

 For further details of the HSBC Bank (UK) Pension 
Scheme’s annual TCFD statements, see https://
futurefocus.staff.hsbc.co.uk/-/media/project/
futurefocus/information-centre/pensioner/
other-information/2020-tcfd-statement.pdf.

Insurance 
In 2021, our Insurance business, which has life 
insurance manufacturing subsidiaries in eight 
markets, a life insurance manufacturing 
associate in India and assets under 
management of approximately $123bn, 
developed a methodology for climate stress 
testing. It ran stress tests across the major 
portfolios considering adverse stresses as a 
result of transition risks on wholesale credit 
risks within the insurance investment portfolio. 

Customers

Employees

Customers

Investors

Employees

Communities

Customers

Investors

Communities

Suppliers

Investors

Regulators and 
Employees
governments

Regulators and 
Customers
governments

Communities

Suppliers

Employees

Regulators and 
governments

Investors

Suppliers

Customers

Communities

Employees

Regulators and 
governments

Investors

Suppliers

Communities

Regulators and 
governments

Suppliers

Climate risk

Asset management
As part of our asset management business’s 
fiduciary duty to clients, our solutions 
integrate key climate and sustainability 
considerations. Climate risk management is a 
key feature of our investment decision making 
and portfolio management. We also engage 
directly with companies on priority topics 
related to climate risk to drive positive change.

Insurance
Our insurance business offers long-term life 
and health products. We manage climate 
risks, including wholesale credit risk, in 
assets to meet customer investment returns. 
We also take into consideration mortality and 
morbidity risks for customers as a result of 
climate risk. We have established an evolving 
ESG programme to meet changing external 
expectations and customer demands. 

The insurance business began a review of its 
sustainability policy to align with the Group’s 
new thermal coal phase-out policy published 
in December 2021. Risk appetite has been 
articulated relating to key ESG aspects.  
ESG standards have been implemented into 
insurance product development processes 
and operational capabilities. 

In response to regulatory developments, 
HSBC’s insurance entities in the EU and UK 
have implemented key disclosure-related 
regulatory requirements, which mainly 
impacts insurance-based investment products 
manufactured and/or sold by HSBC.

Customers

Employees

Customers

Investors

Employees

Communities

Customers

Investors

Communities

Suppliers

Investors

Regulators and 
Employees
governments

Regulators and 
Customers
governments

Communities

Suppliers

Employees

Regulators and 
Customers
governments

Investors

Suppliers

Employees

Communities

Customers

Investors

Regulators and 
Employees
governments

Communities

Suppliers

Investors

Regulators and 
governments

Communities

Suppliers

Regulators and 
governments

Suppliers

56

HSBC Holdings plc Annual Report and Accounts 2021

Environmental

Insights from scenario analysis

Our 2021 climate stress testing  
and scenario analysis exercise
A crucial component of our climate ambitions 
is having the ability to identify and understand 
climate-related risks and opportunities, and 
having insights on how our customers and 
business could be impacted under a range  
of climate change scenarios. 

In 2021, we ran our first Group-wide climate 
change scenario analysis exercise, following 
on from a pilot exercise carried out in 2020. 
The 2021 exercise focused on the portfolios 
most exposed to climate risk: our wholesale 
corporate lending, commercial real estate and 
retail mortgage portfolios. We performed our 
assessment over a 30-year time horizon, 
reflecting the long-term nature and effects of 
transition and physical risks. For all portfolios, 
our assessments considered:

 – transition risk arising from the process of 
moving to a net zero economy, including 
changes in policy, technology, and 
consumer behaviour and stakeholder 
perception, which will each impact 
borrowers’ operating income, financing 
requirements and asset values; and 

 – physical risk arising from the increased 

frequency and severity of weather events, 
such as hurricanes and floods, or chronic 
shifts in weather patterns, which will each 
impact property values, repair costs and 
lead to business interruptions.

Our progress in 2021
Climate change scenario analysis requires 
bespoke data, modelling techniques and 
analysis. In order to integrate climate 
considerations in our analysis, we used the 
people, processes, controls, and governance 
structures from traditional stress tests. 
Building on that, throughout 2021, we 
continued to develop our climate change 
scenario analysis capabilities, including:

 – We identified new data requirements and 
sourced data for a vast number of inputs 
representing climate, macroeconomic and 
financial variables.

 – We built and refined climate change models 
for wholesale corporate lending, commercial 
real estate and retail mortgage portfolios. 
Our models incorporated sector-specific 
adjustments for the higher risk industrial 
sectors. These portfolios represent a 
material part of our lending activities.  
The models projected the impact of climate 
change and produced outputs such as 
credit ratings, which helped us assess  
the financial impact on our portfolios. 

 – We held training sessions covering all 

levels of seniority from our colleagues to 
Board Directors, to allow our people to 
effectively understand, review, challenge 
and use the outcomes.

 – Following the execution of results, we 

revisited the end-to-end process to learn key 
lessons and make continuous improvements 
for the next stress testing cycle.

The process has involved engaging with 
stakeholders across our Finance, Corporate 
Sustainability and Risk functions, as well as 
global businesses at Group and regional levels. 
We held ‘in-depth’ sessions with the Group 
Risk Management Meeting (‘RMM’), Group 
Risk Committee (‘GRC’) and the Group 
Executive Committee covering data, models, 
risk assessments and outcomes. A series of 
governance meetings culminating with the 
RMM and GRC reviewed, challenged and 
approved the overall outcomes of this exercise.

Our framework 
We have created – and continue to develop 
– a target state framework for climate change 
stress testing and scenario analysis. This 
framework uses many of the building blocks 
from of our traditional capital stress testing 
framework, but it demands larger and richer 
data that feeds innovative and granular 
forecasting solutions. All activities in this 
framework need to be embedded in our 
business-as-usual processes to help drive 
business decisions.

The following pages highlight some  
of the analysis conducted. The nature  
of the scenarios, our developing 
capabilities, and limitations of the 
analysis have led to outcomes that  
are directionally indicative of climate 
change headwinds, but they are not  
a direct forecast. Developments in 
climate science, data, methodology, 
and scenario analysis techniques will 
help us shape our approach further.  
We therefore expect this view of risk  
to change over time.

Scenarios and time horizons

We have developed capabilities to define 
parameters for bespoke scenario modelling. 
Our 2021 climate-related scenario analysis 
was run on a suite of specific scenarios 
published by the Network of Central Banks 
and Supervisors for Greening the Financial 
System (‘NGFS’). The NGFS scenarios test a 
broad range of possible outcomes and have 
been created as a starting point for central 
banks and supervisors, encompassing  
a complex set of social, political and 
economic assumptions. The scenarios  
we considered were:

 – An Orderly scenario assumes climate 

policies are introduced early and become 
gradually more stringent. As a result of 

early action to tackle global warming  
and climate change, both physical and 
transition risks are relatively subdued.  
A moderate level of carbon sequestration 
(which is the process of capturing and 
storing atmospheric carbon dioxide) is 
factored into the scenario.

 – A Disorderly scenario explores higher 
transition risk due to policies being 
delayed or divergent across countries  
and sectors. Carbon prices are typically 
higher for a given temperature outcome. 
There is a low level of carbon 
sequestration assumed in this scenario 
due to the absence of timely and sizable 
investments in such technologies.

 – A Hot house world scenario assumes that 
some climate policies are implemented in 
some jurisdictions, but global efforts are 
insufficient to halt significant global 
warming. Critical temperature thresholds 
are exceeded, leading to severe physical 
risks and irreversible impacts like sea-level 
rise. This scenario also assumes a low 
level of carbon sequestration.

 Further details of these scenarios are available 
at: www.ngfs.net/ngfs-scenarios-portal. 

HSBC Holdings plc Annual Report and Accounts 2021

57

ESG reviewESG review | Environmental

Insights from scenario analysis continued

How climate change is impacting our 
wholesale corporate lending portfolio
The table below illustrates the level of 
climate-related risk to which we are exposed 
within six key wholesale sectors. We have 
focused on these sectors because they are 
most likely to be impacted by climate risk. 
We assessed these sectors against Orderly, 
Disorderly and Hot house scenarios over a 
30-year horizon. The two transition risk 
scenarios (Orderly and Disorderly) have the 
most impact on our wholesale portfolio and 
therefore the commentary focuses on these 
scenarios. While cumulative impacts over the 
2020 to 2050 scenario horizon are broadly 
similar, the Disorderly scenario has a delayed 
disruptive transition and the Orderly scenario 
starts to impact the portfolio immediately.

Wholesale corporate lending portfolio methodology

We have developed a standardised 
framework to assess the financial impact of 
climate change on our wholesale corporate 
counterparties. We carried out granular 
modelling for material counterparties, 
projecting how their financial position 
might be impacted under each scenario. 
As data limitations often posed a 
challenge, we performed a high-level 
impact assessment for less material 
counterparties.

For simplicity, we assumed that our 
counterparty exposures would remain 
static over the 30-year horizon under all 

scenarios. Sectors already transitioning, 
such as those with electric vehicles and 
renewable energy, are assumed to 
continue transitioning at a conservative 
level, based on verifiable data and scenario 
assumptions. Companies with government 
support are also assumed to benefit.  
We have not considered the impact of 
individual counterparties’ plans to adapt  
to climate change or the potential impact  
of supply chain disruptions. The analysis 
was performed on a sample of the portfolio 
that focused on our most material 
counterparties and regions. Results should 
therefore be interpreted accordingly. 

Impact for key wholesale transition risk sectors1

Projected impact

Sector

Sub-sectors

Orderly Disorderly Hot house Impact analysis

Building and 
construction

Construction

Steel

Cement

Oil and gas

Integrated

Services

Downstream

Upstream

Midstream

Automotive

Original equipment 
manufacturers

Dealers

Suppliers

Power and 
utilities

Gas and water utilities

Power generation 
companies

Transmission, distribution 
and other electricity 
companies

Chemicals

Chemical companies

Pharmaceutical companies

Metals and 
mining

Core miners (bulk, base/ 
diversified, precious metals)

Pure traders/services

d

e

e

c

c

d

d

d

c

d

c

c

c

c

e

d

d

c

d

e

e

c

c

d

d

d

c

d

c

c

b

c

d

d

d

c

d

d

b

c

b

c

c

c

b

c

b

b
b

b

a

c

c

c

c

Companies with carbon-intensive production activities, such  
as steel and cement companies, are significantly impacted  
under the Orderly and Disorderly scenarios due to their expected 
vulnerability to carbon price increases and limited options 
currently available to transition.

A number of our oil and gas counterparties are operating in 
regions with low extraction costs, and are expected to be more 
resilient in transition scenarios. 

Profiting from greater diversification and size, integrated 
companies perform relatively better compared with 
counterparties specialised on one part of the value chain. 

Impacts are broadly similar in the automotive sector under the 
transition risk scenarios due to a similar cumulative effect of 
electrical vehicle sales and carbon pricing over the 30 years. 
As expected, companies with existing investments in electrical 
vehicle manufacturing tend to be less impacted, particularly 
as they scale up over time. Dealers experience a more 
severe downgrade due to carbon pricing impacting current 
financial positions.

Coal-focused companies are materially impacted in the transition 
scenarios. In contrast, renewables-focused counterparties benefit 
in the transition risk scenarios from the increase in demand for 
their products, lower carbon tax impacts and lower investment 
requirements. Overall, the ability of power and utilities companies 
to transfer costs to customers and the exposure to renewable-
based power generators offsets negative impacts from fossil 
fuel-based counterparties.

Carbon-intensive processes significantly impact part of the 
chemicals sub-sector in the transition risk scenarios. In contrast, 
companies in the pharmaceutical and other sub-sectors tend to 
have less carbon-intensive processes, naturally leading to lower 
carbon costs and abatement expenses.

As expected, coal-focused companies are heavily impacted under 
the transition risk scenarios. Energy transition miners, including 
companies mining lithium or copper, are less impacted due to 
an increased demand for electrification. Diversified miners also 
perform relatively better as they are able to shift away from coal 
to other minerals. Overall, energy transition and diversified miners 
offset some of the downgrades.

Lower Impact

a b c d e

Higher impact

1  This heat map is based on projected change in average credit ratings between 2020 and 2050 of counterparties 

by sector/sub-sector. Colours are defined based on the distribution of credit rating changes for the six key 
wholesale sectors. The bigger the credit rating downgrade, the more severely the counterparty is impacted. 

58

HSBC Holdings plc Annual Report and Accounts 2021

Retail mortgage portfolio 
methodology

We used granular models to assess our 
material retail mortgage portfolios 
exposed to a high degree of climate 
change. After simulating thousands of 
weather events and assessing their 
impact on each property’s value, we 
estimated expected physical losses 
under all scenarios. Key parameters 
included insurance coverage, public 
defences and building resilience 
archetypes. Transition risk was 
modelled considering the changes in 
key macroeconomic variables and 
region-specific policies, such as the 
requirement for homes to have certain 
minimum-rated energy performance 
certificates ('EPC') in the UK.

Environmental

Insights from scenario analysis continued

Impacts across mortgage portfolios are 
primarily driven by the increased risk of 
flooding, including river, surface and coastal 
flooding. While relatively small proportions of 
the portfolios are predicted to be impacted by 
flooding events, the severity of these events is 
expected to increase over time. Under a Hot 
house scenario, sea levels are expected to rise 
up to 1.5 metres, which would increase the 
risk of coastal flooding for parts of the Hong 
Kong portfolio in the latter part of the century. 
The table shows that the Hot house scenario 
puts 25.6% of properties in Hong Kong at risk 
of a 0.5 metre to 1.5 metres 1-in-100-year flood 
event, up 18.7% from 6.9% in the Orderly and 
Disorderly scenarios.

The risk of extreme wind stress has also been 
considered and is only deemed material in 
Hong Kong, where typhoons regularly occur. 
Buildings standards in Hong Kong mean that 
structures are designed to withstand high 
wind speeds, and the severity of wind events 
is not predicted to materially change between 
now and the end of the century. 

We take into account the transition risk for 
our retail mortgage portfolio as part of our 
business-as-usual lending and scenario 
analysis exercises. We focused on physical 
risk on this page because our current 
analysis shows it to be a material climate 
risk for this business. 

Impact of climate risk on our retail 
mortgage portfolios
We assessed the impact of various peril risks 
that our retail mortgage customers could face, 
including flooding, wildfires and windstorms. 
These risks influence property values and the 
ability and willingness of borrowers to service 
their debts. Another risk driver is the ability to 
respond and adapt to new and emerging 
regulatory requirements, such as new energy 
efficiency standards, which may influence 
property values.

The table below focuses on our most material 
retail mortgage portfolios in Hong Kong and 
the UK – covering 66% of our retail mortgage 
portfolio as of 31 December 2020. It 
demonstrates the potential physical risks of 
river, surface and coastal flooding, and how 
this may vary under the Orderly, Disorderly 
and Hot house scenarios. We show the 
projected change in flood depth in metres 
given a 1-in-100-year flood event. Since the 
Orderly and Disorderly scenarios use the same 
physical risk forecasts, these are combined 
into a single column.

Our analysis indicates that the most 
pronounced effects of physical risk on our 
retail mortgage customers are under a Hot 
house scenario characterised by a more than 
3°C increase in global temperatures, which 
leads to an increase in the frequency and 
severity of extreme weather events. There are 
also risks posed by the transition to a net zero 
economy, predominantly through 
macroeconomic disruption, as well as some 
country-specific policies that may be enacted 
to meet these targets, including introduction 
of minimum energy efficiency standards.

Exposure to flooding 
Proportion of properties predicted to be impacted by floods given a 1-in-100-year severity flood 
event (%)

Scenarios

20201

2050

20201

2050

Hong Kong

UK

Flood depth in metres

0–0.5

0.5–1.5

>1.5

Orderly and 
Disorderly, 
+1.5ºC2

Hot house, 
+>3°C3

Orderly and 
Disorderly, 
+1.5ºC2

Hot house, 
+>3°C3

92.1

6.9

1.0

92.0

6.9

1.1

73.3

25.6

1.1

98.5

1.3

0.2

97.5

2.3

0.2

96.1

3.6

0.3

1 Represents the baseline flood risk in 2020.
2  Represents the flood risk in 2050 under a climate scenario aligned to a 1.5°C increase in global temperatures.
3  Represents the flood risk in 2050 under a climate scenario aligned to a more than 3°C increase in global 

temperatures.

HSBC Holdings plc Annual Report and Accounts 2021

59

ESG reviewESG review | Environmental

Insights from scenario analysis continued

Impact of climate risk on our commercial 
real estate portfolios 
We assessed the impact of various perils that 
our commercial real estate customers could 
be vulnerable to, including flooding, wildfires 
and windstorms. The map below illustrates  
the potential impact of physical risk on our 
commercial real estate portfolio in Hong Kong 
under the Hot house scenario. We have 
focused on this portfolio as it is our most 
material commercial real estate portfolio in 
terms of exposure. The map shows a 
projected increase in average damage ratio, 
which represents the ratio between the cost of 
potential damage due to climate-related perils 
and the value of the property. The key peril 
drivers in our results are coastal, river and 
surface water flooding, and wind under a Hot 
house scenario.

Exposure to physical risk in Hong Kong 
under a Hot house scenario
The chart shows the increase in average 
damage ratio between 2020 and 2050 using 
a simple average for locations of our 
commercial real estate properties in each 
district. Our approach assumes an 
acceleration of physical risk impacts from 
later in the century.

Change in average damage ratio (2020–2050)

Negligible change
vs. 2020

Provided by Marsh LTD

Increase vs. 2020

The table alongside shows the projected 
increase in financial impact over 30 years  
for our most material commercial real estate 
portfolios – Hong Kong, the UK, Canada 
and the US, which cover 77% of the total 
commercial real estate portfolio as of 
31 December 2020 – under the Orderly, 
Disorderly and Hot house scenarios. The 
increase in projected financial impact 
represents the increase in expected credit 
losses relative to exposure. The commentary 
highlights the key reasons for the change in 
impact between the Orderly scenario and 
alternative scenarios. 

Under the Hot house scenario, the impacts 
are driven primarily by the increased risk of 
flooding (coastal, riverine and surface water). 
In this scenario, Hong Kong and the UK would 
be particularly impacted by coastal flooding 
due to the estimated rise in the sea level of 
up to 1.5 metres, with an increase in the 
frequency and severity of extreme weather 
events. Risks posed by the transition to a net 
zero economy also exist, which manifest 
mainly through macroeconomic disruption 
under the Disorderly scenario, as well as 
country-specific policies enacted to meet 
these targets, such as, minimum energy 
efficiency standards in the UK. 

We are continuing to refine the data used for 
physical and transition risk assessment of our 
portfolios together with our modelling 
capabilities which use these inputs.

Commercial real estate 
portfolio methodology

The commercial real estate 
methodology is tailored to individual 
property characteristics and is used to 
analyse the impact on borrowers’ credit 
risk. We have also taken into account 
existing property insurance in our 
portfolio. Transition risk drivers include 
country-specific net zero policies, such 
as requirements for EPCs, and the 
associated macroeconomic disruption.

Impact on commercial real estate for key countries/territories

Countries/
territories

Country/territory-
specific EPC 
policies in the 
scenario

Hong Kong

–

Canada

US

UK2

–

–

Energy efficiency 
standards 
introduced via 
EPC policies

Projected impact1

Orderly, 
+1.5°C

Disorderly, 
+1.5°C

Hot house, 
+>3°C

a

a

a

a

a

b

Higher value of 
collateral helps 
reduce impact

Increased risk of 
coastal flooding

b

b

Macroeconomic 
disruption due to 
late policy action

Increased risk  
of riverine and 
surface water 
flooding

b

a

Macroeconomic 
disruption due to 
late policy action

No material 
increase of 
physical risk due 
to location of 
properties

b

b

Increased risk of 
coastal flooding

Macroeconomic 
disruption and 
stricter EPC 
policies due to late 
policy action

Lower Impact

a b c d e

Higher impact

1  Projected impacts from perils include flooding (coastal, river and surface water), wind and wildfires, 

without taking into account client adaptation plans or management actions.

2  UK financial projections include transition risks related to meeting minimum energy efficiency standards, 

whereas the other countries/territories do not.

60

HSBC Holdings plc Annual Report and Accounts 2021

 
This forward-looking data will inform real  
estate planning. We will continue to improve  
our understanding of how extreme weather 
events impact our building portfolio as climate 
risk assessment tools improve and evolve. 
Additionally, we buy insurance for property 
damage and business interruption, and consider 
insurance as a loss mitigation strategy 
depending on its availability and price.

We regularly review and enhance our building 
selection process and global engineering 
standards, and will continue to assess historic 
claims data to help ensure our building selection 
and design standards reflect the potential 
impacts of climate change.

Environmental

Insights from scenario analysis continued

Understanding the resilience of our 
critical properties
Climate change poses a physical risk to the 
buildings that we occupy as an organisation, 
including our offices, retail branches and data 
centres. We measure the impacts of climate 
and weather events to our buildings on an 
ongoing basis, using historical, current and 
scenario modelled forecast data. In 2021, there 
were 47 major events that had no impact on 
the availability of our buildings. 

We use stress testing to evaluate the potential 
for impact to our owned or leased premises. 
Our scenario stress test, conducted in 2021, 
analysed how seven different climate change-
related hazards – comprising coastal inundation, 
extreme heat, extreme winds, wildfires, riverine 
flooding, soil movement due to drought, and 
surface water flooding – could impact 250 of 
our critical buildings. 

The 2021 scenario stress test of 250 of our 
critical buildings modelled climate change with 
a Hot house scenario that projects that the rise 
in the temperature of the world will likely exceed 
4°C by 2100. It also modelled a less severe 
scenario that projects that global warming will 
likely be limited to 2°C, in line with the upper 
limit ambition of the Paris Agreement.

Key findings from the 4°C or greater Hot house 
scenario included:

 – By 2050, 22 of our 250 critical buildings  
will have a high potential for impact due  
to climate change, with insurance-related 
losses estimated to be in excess of 10%  
of the insured value of our buildings.

 – The eight most affected locations face 

hazards relating to surface flooding, rising 
river levels and landslides, as well as coastal 
flooding from rising sea levels and storms. 
Of the remaining 14 locations, 11 are data 
centres where the predominant hazards 
emanate from a mixture of temperature 
extremes, water stress and drought for 
which the specific direct physical impact 
could be soil movement. The other three  
are offices where the predominant hazard  
is coastal flooding.

 – A further 25 locations have the potential to 
be impacted by climate change, albeit to a 
lesser extent, with insurance-related losses 
estimated at between 5% and 10% of the 
insured value of our buildings.

A key finding from the 2°C, less severe 
scenario showed:

 – The total number of buildings at risk reduces 

from 47 to 35, with the same eight key 
facilities still at risk by 2050 from the 
same perils.

Regulatory climate stress tests 
Regulators in an increasing number of 
jurisdictions are incorporating climate factors 
in their supervisory tools, with different 
aspects considered around the world.  
We have built flexibility into our approach  
to climate stress tests to support these 
differences. During 2021, we completed 
a number of climate stress tests in response 
to regulatory requirements from the Bank of 
England, the Hong Kong Monetary Authority 
and the Monetary Authority of Singapore. 
We expect to complete further tests in 2022. 

Any specific outcomes and balances disclosed 
in this section should not be assumed to be 
those that have fed into our aggregated final 
climate results for the Bank of England’s 
biennial exploratory scenario.

Our priority next steps 
While we have conducted a number of climate 
change scenario analyses and stress tests in 
2021, we continue to broaden and enhance 
our capabilities in order to overcome the 
limitations identified. These include enhancing 
our climate data repository, expanding 
scenario analysis methodology beyond  
credit risk, forecasting key climate metrics, 
integrating climate scenario analysis into 
risk management, business decisions and 
strategic planning. Together, they will help 
us define and monitor targets to support the 
Group’s climate strategy. We aim to continue 
to improve on scenario analysis disclosures in 
line with regulatory expectations, supported 
by robust control processes and governance.

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61

ESG reviewESG review | Environmental

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. We have joined various partnerships 
to support our role in this, including the 
Powering Past Coal Alliance and World 
Economic Forum’s Principles for Financing 
a Just and Urgent Energy Transition.

Our policies
Our sustainability risk policies cover 
agricultural commodities, chemicals, energy, 
forestry, mining and metals, thermal coal, 
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 clients 
are managing these risks responsibly. Such 
customers are subject to greater due diligence 
and generally require additional approval by 
sustainability risk specialists. 

Our sustainability policies continue to be 
aligned with our approach to climate risk, 
and our net zero ambition. 

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 
Reinforcing our ambition to support our 
clients’ transition to lower carbon through 
transition financing – and particularly to the 
phase-out of thermal coal – we published our 
thermal coal phase-out policy, which we 
introduced in December 2021 (see right). 

Governance and implementation
Within our Global Risk and Compliance 
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 2021, 
these local sustainability risk managers 
continued to be supported by regional 
reputational risk managers across the Group 
who have taken on additional oversight 
responsibilities for sustainability risk. 

The Sustainability Risk Oversight Forum,  
made up of senior members of the Global  
Risk and Compliance function and global 
businesses, continued to oversee the 
development and implementation of policies 
that identify, manage and mitigate the Group’s 
sustainability risk, including a refreshed 
assurance framework in 2021. This framework 
has been designed to take a more holistic view 
of the ESG risks we face in our sustainability 
risk policies, including:

 – monitoring ESG news across the 

sustainability risk policies;

 – overseeing clients considered to  
be of higher risk or under exit;

 – reviewing client files across the 
sustainability risk policies; and

 – setting and reporting against a defined 
set of key control indicators aligned  
to our risk appetite.

The framework is used to monitor the in-scope 
portfolio and keep track if there is any 
deterioration in the risk ratings. With the 
respective risk rating assigned, our 
sustainability risk specialists will take the 
necessary actions to mitigate unacceptable 
risks. If necessary, we will proactively end the 
client relationship. 

Our thermal coal  
phase-out policy

In fulfilment of our commitment approved 
by shareholders at the AGM in May 2021, 
we published a policy to phase out 
thermal coal financing in EU and OECD 
markets by 2030, and globally by 2040. 
This incorporates project finance, direct 
lending, or arranging or underwriting of 
capital markets transactions to in-scope 
clients, as well as the refinancing of 
existing finance facilities.

Every year we commit to review our 
policy and targets, taking into account 
evolving science and internationally 
recognised guidance.

Using our TCFD disclosures in 2020 
as our baseline, we intend to reduce 
thermal coal financing exposure by 
at least 25% by 2025, and by 50% by 
2030. These targets will be reviewed 
in conjunction with assessments of 
client transition plans. For further 
details, see www.hsbc.com/news-and-
media/hsbc-news/were-phasing-out-
coal-financing.

As shown in the wholesale loan exposure 
table on page 133, within the power and 
utilities, and metals and mining sectors, 
and recognising external party 
assessments of power generation and 
mining capacity, our exposure to thermal 
coal at 31 December 2021 was $1.0bn 
(2020: $1.2bn) or 0.2% of the total 
wholesale loans and advances figures.

In 2021, HSBC, together with other 
financial institutions, participated in 
capital markets transactions relating  
to clients who own or operate thermal 
coal-fired powered plants or thermal coal 
mines. HSBC facilitated a total of $1.3bn 
out of the total of these transactions. 

Biodiversity and natural capital-related policies

We have taken several steps to unlock the value of natural capital in the global economy, and 
help tackle biodiversity loss and other nature-related financial risks. However, we recognise 
we are at the beginning of our journey.

We regularly assess our clients for their commitment to sustainable business practices, and 
have clear policies to help mitigate the risk of nature loss. Our sustainability risk policies are 
designed to provide several protections against financing, which will have a negative impact on 
nature. These include our forestry and agricultural commodities policies, which put an 
emphasis on customers involved with the major forest-risk commodities to obtain independent 
certification that their businesses operate in a sustainable manner. These include requiring palm 
oil customers to commit to ‘No Deforestation, No Peat and No Exploitation’. Our World 
Heritage Sites and Ramsar-designated wetlands policy prohibits the financing of any project 
that threatens the special natural characteristics of these internationally protected areas.

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HSBC Holdings plc Annual Report and Accounts 2021

Environmental

Our approach to climate reporting
Task Force on Climate-related Financial Disclosures (‘TCFD’) 

The table below sets out the 11 TCFD recommendations and summarises where additional information can be found.

Where we have not included climate-related financial disclosures consistent with all of the TCFD Recommendations and Recommended 
Disclosures, the reasons for this and steps we are taking are set out in the additional information section on page 402.

Recommendation

Governance

Response

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

Process, frequency and training

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

updates throughout the year and receives ESG-related training.

Sub-committee accountability,  
processes and frequency 

Examples of the Board and relevant Board 
committees taking climate into account

 – The Group Risk Committee exercises oversight of climate risks. 

 – The Group Audit Committee reviews and challenges ESG and climate-related reporting and 

disclosure, including the climate change resolution and scenario analysis disclosure.

 – 2021 was a significant year for the Group in its efforts to support the transition to net zero – a 
key pillar of our overall Group strategy – with the passing of our climate change resolution at 
our 2021 AGM and the publication of our thermal coal phase-out policy being two of the most 
notable achievements. In January 2022, the Board also approved the necessary investment 
required to develop and implement a revised operating model for the Group's Sustainability 
function to help ensure delivery against our sustainability ambitions.

Disclosure 
location

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

 – The GRC and GAC convened a joint meeting to review the thermal coal phase-out policy and 

Page 241

our approach to financed emissions. 

Who manages climate-related risks  
and opportunities

 – The Group Executive Committee (‘GEC’) manages our climate ambition with management 
responsibilities integrated into the relevant business and functional areas. It oversees and 
directs the climate-related opportunities. It discussed climate-related issues at six meetings 
in 2021.

 – The Group Chief Executive is responsible for overseeing the delivery of the sustainable finance 

and investment ambition and realisation of commercial opportunities.

 – The Group Chief Sustainability Officer holds joint responsibility for the ESG committee that 

supports Group Executives in the development and delivery of ESG strategy, key policies and 
material commitments by providing oversight, coordination and management of ESG 
commitments and activities.

 – The Group Chief Risk and Compliance Officer and the chief risk officers of our PRA-regulated 

businesses are the senior managers responsible for climate financial risks under the UK Senior 
Managers Regime. 

How management reports to the Board

 – The Group Chief Executive, the Group Chief Financial Officer, and the Chief Risk and 

Compliance Officer provide regular verbal and written updates to the Board. 

 – The ESG Committee will regularly report to the Board on progress against our ESG ambitions, 

climate strategy and related commitments.

Processes used to inform management

 – The Group Chief Financial Officer provides an ESG dashboard including key climate-related 

metrics within a quarterly report, presented to the GEC.

 – Management is informed by a number of specialist ESG governance forums.

Strategy

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

Processes used to determine material risks 
and opportunities

Relevant short, medium, and long term 
time horizons

Transition or physical climate-related 
issues identified 

 – We use scenario analysis to help us identify and understand climate-related risks. 

 – 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. 

 – For wholesale customers, we use a questionnaire as part of the independent review of risk, 
to understand their climate strategies and risks. It also helps us to identify potential business 
opportunities to support the transition.

 – We aim to achieve net zero in our financed emissions by 2050, and in our own operations and 

supply chain by 2030. 

 – We aim to provide and facilitate $750bn to $1tn of sustainable finance and investment for our 

customers in their transition to net zero and a sustainable future between 2020 and 2030.

 – We have taken these time horizons into our consideration. We consider short term to be less 

than one year, medium term to be by 2030 and long term to be by 2050. 

 – Transition or physical climate-related risk impacts may manifest across our risk taxonomy 

across all time horizons.

 – We are supporting our customers in their transition through our sustainable finance and 

investment ambition. Our sustainable finance data dictionary includes a detailed definition 
of contributing activities.

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63

ESG review 
 
ESG review | Environmental

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

Recommendation

Response

Risks and opportunities by sector and/
or geography

 – For our wholesale exposure we have focused on a group lens as a starting point, primarily due 
to data limitations on client carbon emissions. Our scenario analysis shows that transition risk 
represents a more material risk for corporate customers, and physical risk is more material for 
our retail customers.

 – Opportunities include sustainable finance, sustainable investment and sustainable infrastructure.

Concentrations of credit exposure 
to carbon-related assets

 – We have identified and disclosed six sectors where our corporate customers have the highest 
climate risk, which are: oil and gas; building and construction; chemicals; automotive; power 
and utilities; and metals and mining. 

 – We have also disclosed our exposure to thermal coal.

 – Our approach to financed emissions has focused primarily on oil and gas, and power and 

utilities, and the specific areas of the value chain which are most carbon intensive. We will  
aim to enhance our scope 3 emissions disclosure by encouraging our customers to publicly 
disclose their carbon emissions.

b) Describe the impact of climate-related risks and opportunities on the organisation’s businesses, strategy and financial planning

Impact on strategy, business, and 
financial planning

 – Transition to net zero represents one of our four strategic pillars. We aim to be net zero in our 

operations and supply chain by 2030 and in our financed emissions by 2050.

 – Due to transitional challenges, including data and system limitations, we do not currently fully 

disclose the way in which climate-related issues have affected our financial planning and 
performance. We have considered the impact of climate-related issues on our businesses, 
strategy, and financial planning, and will aim to further enhance our processes in relation to 
acquisitions/divestments and access to capital.

Impact on products and services

 – We aim to help our customers' transition to net zero and a sustainable future through providing 

and facilitating between $750bn and $1tn of sustainable finance and investment by 2030.

Impact on supply chain and/or value chain

Impact on adaptation and mitigation 
activities

Impact on operations 

 – We have started targeting our largest suppliers to encourage them to make their own carbon 
commitments, and to disclose their emissions. We take into account climate-related risks as 
part of our third-party risk management process.

 – We announced our ambition to achieving 100% renewable power across our operations by 

2030, and continue to look for opportunities to procure green energy. We regularly review and 
enhance our building selection process and global engineering standards, to help ensure our 
building selection and design standards reflect the potential impacts of climate change.

 – We have analysed the resilience of our critical properties, identifying 22 of our 250 critical 

buildings have a high potential for impact due to climate change by 2050. This will inform real 
estate planning. Our business continuity processes, including people and infrastructure, will 
continue to evolve to take in account of climate-related risks across regions and markets to 
avoid concentration risk. 

Impact on investment in research 
and development

 – We are working with the World Resources Institute and WWF, focusing our collective efforts 
on climate-related innovation, nature-based solutions and energy efficiency initiatives in Asia.

How we are striving to meet 
investor expectations

 – The climate change resolution that was passed at our 2021 AGM committed us to publishing 
our thermal coal phase-out policy and setting short- and medium-term targets to align our 
provision of finance with the goals and timelines of the Paris Agreement.

c)  Describe the resilience of the organisation’s strategy, taking into consideration different climate-related scenarios,  

including a 2°C or lower scenario

Embedding climate into scenario analysis

 – We use the people, processes, controls and governance structures from our traditional capital 

stress tests for our climate-related scenario analysis, as well as bespoke data, modelling 
techniques and analysis.

Key drivers of performance and how these 
have been taken into account

 – In 2021, we ran our first climate stress testing and scenario analysis exercise. For all portfolios, 

our assessments considered transition risk and physical risk.

 – We do not currently fully disclose the impacts of transition and physical risk quantitatively, due 
to transitional challenges such as data limitations and evolving science and methodologies.

Scenarios used and how they factored 
in government policies

 – Our climate-related scenario analysis was run on a suite of scenarios including Hot house, 
Orderly and Disorderly scenarios, which incorporated a complex set of social, political and 
economic decisions, including taking into account government policies.

How our strategies may change and adapt 

 – As our approach matures, we will look to begin incorporating our analysis into our core 

banking processes including strategic planning and risk appetite.

 – We regularly review and enhance our own building selection process and design standards 

to help these reflect the potential impacts of climate change.

Risk management

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

Traditional banking risk types considered

 – Our key climate risk types are: wholesale credit risk, retail credit risk, regulatory compliance 

risk, resilience risk and strategic (reputational) risk.

 – We tailor our underlying policies and controls to manage the different risks and exposures to 
reflect our respective roles in asset management, employee pensions and insurance to meet 
the needs of our key stakeholders.

Disclosure 
location

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HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
Environmental

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

Recommendation

Response

Process

 – The process of identification and assessment of climate risk differs according to the risk type, 
taking into account material risk drivers. We use scenario analysis to assess our portfolio's 
exposure, which takes into account emerging regulatory requirements, and we use our 
transition risk questionnaire to request information from our corporate customers.

Disclosure 
location

Page 131

Integration into policies and procedures

 – We are integrating climate risk into the supporting policies, processes and controls for our key 
climate risks and we will continue to update these as our climate risk management capabilities 
mature over time.

Page 131

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

Process and how we make decisions

 – The Group Risk Management Meeting receives scheduled updates on climate risk, and receive 

regular updates on our climate risk appetite and top and emerging climate risks.

 – Our developing climate risk appetite metrics aim to support the oversight and management 

of the financial and non-financial risks from climate change.

 – Our approach to climate risk management is developing and how we manage these risks will 

vary by risk type. We will continue to align to our risk management framework when 
determining the materiality of its exposure to climate-related risks.

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

management framework

How we have aligned and integrated 
our approach 

How we take into account interconnections 
between entities, functions

Metrics and targets

 – Our approach to climate risk management is aligned to our Group-wide risk management 

framework and three lines of defence model.

 – Our dedicated climate risk programme continues to accelerate the development of our climate 

risk management capabilities, taking into account relevant interconnections within global 
businesses, functions and entities.

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

management process

Metrics used to assess the impact of 
climate-related risks on our loan portfolio

Metrics used to assess progress 
against opportunities

 – We disclose our wholesale loan exposure to the six high transition risk sectors. It is also used to 
be a metric, together with our transition risk questionnaire to assess impact of climate risk and 
help inform risk management. 

 – We are starting to measure climate risk for our retail portfolio, starting with retail properties 

in the UK.

 – Our climate risk management information dashboard includes metrics relating to our key 

climate risks, and is reported to the Global Climate Risk Oversight Forum. However, we do not 
fully disclose metrics used to assess the impact of climate-related risks on retail lending, parts 
of wholesale lending and other financial intermediary business activities.

 – We track our net zero progress using multiple metrics, tailoring methodologies to the 

specific measures.

 – We do not currently fully disclose the proportion of revenue or proportion of assets aligned 

with climate-related opportunities, relevant forward-looking metrics or internal carbon prices 
due to transitional challenges including data and system limitations.

Board or senior management incentives

 – We use a number of climate-related metrics within annual incentive scorecards, including 

those of the Group Chief Executive and Group Chief Financial Officer.

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

Our own operations

 – We report scope 1, 2 and part of scope 3 greenhouse gas emissions resulting from the energy 

Measuring our on-balance sheet 
financed emissions

used in our buildings and employees’ business travel. 

 – Future disclosure on scope 3 supply chain emissions (suppliers), as well as its related risks 

is reliant on our suppliers publicly disclosing their carbon emissions.

 – We have started to measure our scope 3 portfolio impact, beginning with the oil and gas, and 

power and utilities sectors.

 – Future disclosure on scope 3 financed emissions (customers) is reliant on our customers 

publicly disclosing their carbon emissions.

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

Details of targets set and whether they 
are absolute or intensity based

 – One of our strategic pillars is to support the transition to a net zero global economy. To support 
our ambition to align our financed emissions to achieve net zero by 2050 or sooner, we have set 
a new absolute on-balance sheet financed emissions 2030 target for the oil and gas sector, and 
an on-balance sheet financed emissions intensity 2030 target for the power and utilities sector.

 – Given that climate scenarios are mainly focused on medium- to long-term horizons, rather than 
short-term, we have set interim 2030 targets for on-balance sheet financed emissions for the 
oil and gas, and power and utilities sectors. We do not currently disclose targets used to 
measure and manage physical risk, due to transitional challenges and data limitations. We do 
not consider water usage to be a material target for our business and therefore we have not 
included a target in this year’s disclosure.

Other key performance indicators used

 – We also use other indicators to assess our progress including energy consumption and 

percentage of renewable electricity sourced.

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HSBC Holdings plc Annual Report and Accounts 2021

65

ESG review 
 
 
ESG review

Social

We aim to play an active role in opening up a world of 
opportunity for our customers, colleagues and communities 
as we bring the benefits of connectivity and global economy 
to more people around the world.

At a glance

Our relationships 
Our purpose is opening up a world of 
opportunity, and we aim to bring that  
purpose to our customers, employees  
and the communities in which we operate.

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. Through a series of 
surveys, we aim to listen to our customers to 
put them at the centre of our decision making. 
If things do go wrong, we aim to take action 
in a timely manner.

In this section

Our organisation has been shaped by the 
many cultures, communities and continents 
we serve, with almost 220,000 full-time 
equivalent employees (‘FTEs’) in 64 countries 
with 160 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. 

We have a long-standing commitment to 
support our communities, in areas where we 
can make a difference and support sustainable 
economic growth. We believe that financial 
services, when accessible and fair, can  
reduce inequality and help more people 
access opportunities.

Our culture is underpinned by our values:  
we value difference, we succeed together,  
we take responsibility, and we get it done.

Customers

Customer satisfaction

While customer satisfaction improved during the year, we have 
work to do to improve our rank position against competitors.

How we listen

We aim to be open and consistent in how we track, record and 
manage complaints.

Employees

The future of work

As the Covid-19 pandemic tested our colleagues, we expect the 
way we work to change as the workforce meets new demands.

Inclusion

We value diversity of thought and we are building an inclusive 
environment that reflects our customers and communities.

Learning and skills
development

We aim to build a dynamic, inclusive culture where colleagues can 
develop skills and experiences that help them fulfil their potential.

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Listening to our colleagues We run a Snapshot survey every six months and report insights 

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to our Group Executive Committee and the Board.

Well-being

Our global well-being programme is a key enabler of our people 
strategy, especially as we move to a more hybrid way of working. 

Communities

Supporting communities

We focus on a number of priorities where we can make  
a difference and support sustainable economic growth.

Financial inclusion

We aim to build financial health and remove barriers people  
can face in accessing financial services.

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Social | Customers

Customers

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.

We aim to listen, learn and act on our 
customers’ feedback, and use the net 
promoter score (‘NPS’) system to compare  

our customer satisfaction performance against 
our peers. We manage customer feedback 
when things go wrong and report on our 
actions against our key customer complaints.

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’).

Customer satisfaction

We remain committed to improving 
customers’ experiences. In 2021, we gathered 
feedback from over one million customers 
across our three global businesses to help 
us understand our strengths and the areas 
of focus.

feedback, accelerating our use of digital 
real-time surveys to capture insight. By sharing 
this and other feedback with our front-line 
teams, and allowing them to respond directly 
to customers, we are improving how we 
address issues and realising opportunities. 

Our recommendation scores improved in 
more than 60% of our markets, although  
we still have work to do to improve our rank 
position against competitors, as some have 
accelerated their performance faster than us. 

Listening to drive continuous 
improvement
Throughout 2021, we continued to embed our 
new feedback system so we can better listen, 
learn and act on our customers’ feedback.  
We use NPS to provide a consistent measure 
of our performance. NPS 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’.

How we fared
In WPB, our NPS rose in seven markets. 
In Hong Kong, mainland China and UAE, 
we were ranked in the top-three banks, and 
in the UK, Malaysia and Mexico we improved 
rank positions. Our rank in Singapore and the 
US remained flat while our positions slipped in 
Australia and Canada. Customers told us we 
needed to focus on: making digital platforms 
more accessible, making payments easier, 
improving our account opening experience 
and helping customers better monitor their 
spending. We have made a commitment to 
invest in making these things better. In our 
private bank, our global NPS increased to 31, 
compared with 9 in 2020. This was largely 
due to an increase in our scores in Hong Kong, 
the US and Germany, with scores in 
Switzerland, the UK and Luxembourg 
also performing strongly.

We run studies that allow us to benchmark 
ourselves against other banks. In 2021, these 
were live in 10 WPB markets and 13 CMB 
markets, and in our key regions for our private 
bank and GBM. These will be expanded to 
other key markets in 2022. We try to make it 
as easy as possible for customers to give us 

In CMB, NPS rose in eight of our 13 key 
markets, with our rank positions in Malaysia, 
India, UAE and Mexico either improving or in 
the top three against competitors. In Hong 
Kong, we placed a stronger emphasis on 
innovation from a product and digital banking 
perspective. In the UK, as we continued to 

navigate the broader impacts of Covid-19, 
we faced challenges providing consistent 
levels of customer service. We are prioritising 
areas where we can improve the experience 
customers have with us.

In GBM, our NPS increased in Asia and  
the US. We ranked in first place in Asia,  
an improvement from third place in 2020.  
In the US, our NPS increased by 16 points, 
consequently placing us in sixth place versus 
our ninth place ranking in 2020. While our NPS 
declined in Europe by four points compared 
with 2020, our score improved among our 
key clients. 

Number of markets in top three 
or improving rank1

WPB

CMB

2021

6 out of 10

4 out of 13

1  In WPB, markets comprised: the UK, Hong Kong, 
Malaysia, Singapore, mainland China, Australia, 
UAE, Canada, Mexico and the US. In CMB, 
markets comprised: the UK, Hong Kong, 
Malaysia, Singapore, Pearl River Delta, mainland 
China, India, Indonesia, Australia, UAE, Canada, 
Mexico and the US. Rank positions are provided 
using data gathered through third-party 
research agencies. 

Acting on feedback

We continued to focus on our digital 
capabilities in 2021 to enable better 
customer experiences.

In WPB, we introduced new mobile account 
opening functionality in Hong Kong, leading 
to improved NPS, and reaching an all-time 
high of 62 in March. We also launched 
Trade25, our new stock trading platform for 
18 to 25 year-olds. By the end of the year, 
1,800 users had opted into the programme. 
A new online banking platform was 
delivered across 20 markets to improve 
navigation and usability.

In CMB, our digital self-service programme 
launched to enable our customers to 
undertake more of their day-to-day banking 
online. Since introduction in early 2021, in 
the UK, over 140,000 customers changed 
their details online, 71,000 customers 
managed their debit and credit cards and 
389,000 cheques were deposited using the 
mobile application.

In GBM, our digitised account onboarding 
and lifecycle management platform has 
been extended to 21 markets with enhanced 
features and capabilities including one  
time password and e-sign functionality. 
Integrated electronic identification and 
verification capabilities have also been 
deployed to simplify the onboarding 
experience for our clients.

HSBC Holdings plc Annual Report and Accounts 2021

67

ESG reviewESG review | Social | Customers

How we listen

To improve how we serve our customers, we 
must be open to feedback and acknowledge 
when things go wrong. We have adapted 
quickly to support our customers facing  
new challenges and new ways of working, 
especially as a result of Covid-19-related 
lockdown restrictions. 

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. 
As the table on the right demonstrates, we 
have a consistent set of principles that enable 
us to remain customer-focused throughout 
the complaints process. 

 For further details on complaints volumes  
by geography, see our ESG Data Pack at  
www.hsbc.com/esg.

How we handle complaints
Our principles

Our actions

Making it easy 
for customers 
to complain

Customers can complain via the channel that best suits them. 
We provide a point of contact along with clear information on 
next steps and timescales. 

Acknowledging 
complaints

All colleagues welcome complaints as opportunities and exercise 
empathy to acknowledge our customers' issues. Complaints are 
escalated if they cannot be resolved at first point of contact. 

Keeping the 
customer up 
to date

Ensuring fair 
resolution

Providing 
available rights

Undertaking 
root cause 
analysis

We set clear expectations and keep customers informed throughout 
the complaint resolution process via their preferred channel.

We thoroughly investigate all complaints to address concerns  
and ensure the right outcome for our customers. 

We provide customers with information on their rights and the 
appeal process if they are not satisfied with the outcome of  
the complaint. 

Complaint causes are analysed on a regular basis to identify and 
address any systemic issues and to inform process improvements. 

Wealth and Personal  
Banking (‘WPB’)
In 2021, we received approximately 1.2 million 
complaints from customers. The ratio of 
complaints per 1,000 customers per month 
in our large markets reduced from 2.7 to 2.5. 

In the UK, complaints relating to our response 
to the Covid-19 pandemic reduced, due to the 
decline in demand for financial support, 
payment holidays and additional lending. 
In the UK, we also implemented various 
initiatives to resolve common customer 
pain points and have provided our people 
with enhanced guidance to help them 
identify complaints.

The increase in complaints in Mexico was 
driven by unrecognised charges in debit  
and credit cards caused by fraud attacks. In 
response, our fraud teams have taken actions 
to protect customers, including enhanced 
monitoring and customer alerts.

Our complaint management platform, now 
live in 11 markets, allows us to deliver a more 
customer-focused experience when managing 
feedback. We have streamlined complaints 
procedures, introduced greater automation to 
track complaints and provide customers with 
regular updates, and enhanced our reporting. 
Our new global complaints dashboard enables 
us to identify trends, and put in place actions 
to resolve emerging issues.

The increase in complaints in Hong Kong 
mainly related to stresses to our operations 
caused by events including frauds, Covid-19-
related government schemes and new 
business initiatives. We are addressing these 
by offering new flexible solutions, customer 
education on fraud prevention and enhanced 
digital services.

In our private bank in 2021, we received  
431 complaints, a 25% decrease on 2020, 
largely due to the reduction in administration 
and service issues. Within this category, 
approximately 50% were attributable to 
processing errors/delays and client reporting 
delays/errors. In 2021, the private bank 
resolved 431 complaints.

Acting on feedback

In 2021, we revised our global complaint 
handling policy to simplify our process,  
and set a principle-based approach.  
We aim to ensure we recognise those 
customers with enhanced care needs  
to deliver fair outcomes.

In March 2021, we were the first bank in 
Hong Kong to allow fully digital international 
account opening for both permanent and 
non-permanent residents through the launch 
of a new international account opening 
service through our internet banking.

Since October 2021, our UK customers have 
benefited from enriched transaction details 
for their debit and credit cards on the mobile 
app. The app provides a simpler interface, 
includes improved transaction descriptions 
and helps support customers where they 
are querying transactions through the 
dispute process.

Contact centres are accelerating the  
digital transformation to deliver enhanced 
customer experience by streamlining and 
automating processes. In 2021, we launched 

68

HSBC Holdings plc Annual Report and Accounts 2021

WPB complaint volumes1
(per 1,000 customers per month)

Total2

UK3

Hong Kong3

Mexico3

2021

2020

2.5

1.6

0.7

5.5

2.7

2.1

0.6

4.9

1  A complaint is any expression of dissatisfaction 
about HSBC’s activities, products or services 
whether justified or not. 

2  Markets included: Hong Kong, mainland China, 

France, the UK, UAE, Mexico, Canada, US.

3  The UK, Mexico and Hong Kong make up 84% 

of total complaints.

14 new chat deployments, four new 
chatbots and security improvements  
that included voice biometrics and SMS 
passwords that drive towards delivering 
seamless customer experiences when 
connecting with our contact centres.

Social | Customers

How we listen continued
Commercial Banking (‘CMB’)

In 2021, we received 82,238 customer 
complaints, a decrease of 22% from 2020. 
Of the overall volumes, 82% came from the 
UK, 10% from Hong Kong and 2% from 
France. We resolved 81,968 complaints. 

in March 2021. In Hong Kong, the number of 
complaints received were significantly lower 
in 2021 due to a reduction in our due diligence 
reviews of customers as part of our global 
standards programme. 

The most common complaint related to 
operations, namely payment processing errors 
and delays. However, complaints in this 
category fell markedly compared with 2020, 
largely due to the significant reduction in 
complaints relating to the Bounce Back Loan 
Scheme in the UK after the scheme was closed 

Encouraging our people to capture and log 
complaints allows us to continually improve 
the products and services we offer. To support 
this we rolled out a new complaints tool 
across 36 markets to ensure effective complaint 
handling remains at the front and centre of 
how we operate.

CMB complaint volumes1
(000s)

Total

UK2

2021

2020

82.2

105.1

67.1

81.9

Hong Kong2

8.2

16.3

Acting on feedback

We seek to ensure that we treat customers 
fairly when managing complaints, especially 
those who may be considered vulnerable or 
who have enhanced care needs. In 2021, 
we introduced a way to identify complaints 
from such customers so that they get the 
right outcomes.

The majority of complaints related to 
payment processing. To improve our 
customers’ experience when making 

payments, we launched SMS and We Chat 
notifications in Hong Kong to accelerate 
payment screening times. 

provided customers with more digital 
channels including web chat and upgraded 
our Business Banking mobile app. 

The second highest contributor to complaint 
volumes related to contact centres, in 
particular the time taken for our customers 
to be served. In the UK these complaints 
were driven by a rise in customer demand 
and operational challenges increasing call 
wait times. To improve response times, we 

We continued to strengthen our financial 
crime procedures as part of our 
commitment to safeguard our customers. 
While complaints related to these processes 
and procedures remained high they fell by 
2% compared with 2020. 

Global Banking and Markets (‘GBM’)

We received 1,429 customer complaints 
in 2021, which was in line with complaint 
volumes in 2020. Of the complaints received 
in 2021, 92% were closed.

Our Global Liquidity and Cash Management 
business recorded the most complaints, 
corresponding to the high transaction volumes 
associated with this business. Complaint 
volumes were broadly stable throughout the 
year, with no material incidents observed. 
Some examples of complaints raised include 
temporary issues with system performance, 
and customers citing query resolution times.

GBM complaint volumes1

2021

2020

Total

1,429

1,432

Global Banking

282

309

Global Markets 
and Securities 
Services

Global Liquidity 
and Cash 
Management3

309

363

838

760

Acting on feedback

We have developed a client feedback tool to 
replace several legacy complaints logging 
tools for all GBM businesses. The tool is 
scheduled to go live across all GBM markets 
by September 2022. 

While global systems were stable throughout 
2021, where issues occurred we deployed 
resources to restore services quickly, and 
performed root-cause analysis to ensure fixes 
were implemented.

1  A complaint is any expression of dissatisfaction, whether justified or not, relating to the provision of, or failure to provide, a specific product or service or service activity.
2  For our CMB business, the UK and Hong Kong make up 92% of total complaints.
3  Global Liquidity and Cash Management excludes 1,190 complaints relating to payment operations, which is part of Digital Business Services.

HSBC Holdings plc Annual Report and Accounts 2021

69

ESG reviewESG review | Social | Employees

Employees

Opening up a world of opportunity applies to 
colleagues, as well as our customers. We do 
this by building a diverse and inclusive 
organisation that prioritises well-being. We 
invest in the development of talent, creating a 
culture of learning and we empower our 
colleagues to shape the future of work. 

The future of work 

The way we work is continuing to adapt as 
our workforce meets new demands, and as 
expectations change. In addition to this, our 
colleagues are developing new skills and 
working more flexibly than ever before.

Adapting at pace
During the Covid-19 pandemic, our  
colleagues adapted at pace in a fast-changing 
environment to provide continuity of service for 
our customers. This offered us the opportunity 
to rethink the future of work, taking the best of 
what we learnt to attract a better and more 
diverse workforce. 

To support our approach, we created three 
guiding principles: 

 – Customer focus: We aim to make sure the 

way we work helps deliver the best 
commercial outcomes for our customers.

 – Team commitment: We will connect with 

each other, build our community and 
collaborate.

 – Flexibility: We will provide our colleagues 

with more choice on how, when and where 
we work, suitable for the roles we do. 

Our future of work initiative is driven by 
feedback and insights that we gain from  
our colleagues. In April 2021, our return to 
workplace survey revealed approximately  
70% of colleagues wanted individual flexibility 

We were founded on the strength of diverse 
experience, and we continue to seek different 
perspectives to ensure we are prepared to 
move at pace, and deliver on behalf of our 
colleagues, customers and shareholders. We 
regularly listen to our colleagues through 
surveys and Exchange sessions. The insight 
we collect shapes our approach to colleague 
engagement and support.

around location and hours. In October 2021, 
our employee focus groups showed 
approximately 85% of colleagues wanted 
leaders to set an example and encourage our 
new ways of working.

In 2021, we started to formalise hybrid working 
arrangements, splitting time between home, 
office or other locations. We developed 
e-learnings and conversation guides to help 
managers discuss hybrid ways of working  
with their teams. We also created films and 
communications, showcasing how leaders  
and colleagues were role modelling new ways 
of working.

To further support individual flexibility,  
we created a new global flexible working 
framework and best practice guidelines to 
enable all colleagues to have more choice 
around how and where they work. 

Our June 2021 Snapshot survey revealed there 
are five key areas our colleagues want us to  
get right for hybrid working to be successful: 

 – improve communication;

 – offer the right level of flexibility;

 – provide fit-for-purpose technology;

 – facilitate collaboration; and

 – enable our leaders to lead hybrid teams.

Our culture is underpinned by our values: 
we value difference, we succeed together, 
we take responsibility, and we get it done.

In line with this feedback, we improved 
technology platforms including the accelerated 
deployment of Microsoft Teams and improved 
remote internet connection capabilities. We 
have commenced refurbishment of buildings 
to support better collaboration, while ensuring 
the safety of our colleagues by continuing to 
provide social distancing measures. The future 
of work will remain an area of focus in 2022 
and beyond.

We recognise we do not have all the  
answers, so we will continue to take a  
‘test and learn’ approach, closely evaluating 
our success through regular feedback and 
business performance. 

66% 

of employees whose roles allow them 
to work remotely told us their ideal 
work pattern would be hybrid, 
according to the Snapshot employee 
survey in December 2021.

Spotlight on hybrid working

Our colleagues in mainland China – one of the first markets to reopen following Covid-19-related 
restrictions – embraced our new hybrid ways of working.

Managers assessed role types against a global ‘workstyle’ framework, which considers issues 
such as local laws, regulations and the need for face-to-face contact. This helped management 
understand and role model a balance between home and office working. Managers were then 
encouraged to have open discussions with their teams, supported by HR guidelines, around  
how individuals could be supported to work more flexibly. Following these changes, we received 
feedback that showed that ways of working had changed, and where roles allowed, hybrid 
working was now seen to be the standard way to work. 

70

HSBC Holdings plc Annual Report and Accounts 2021

Social | Employees

Inclusion

We value diversity of thought and we  
are building an environment that reflects  
our customers and communities. We are 
committed to attracting, developing and 
retaining diverse talent by fostering an 
inclusive culture.

We recognise the importance of data in 
driving change, and in 2021 placed an 
increased focus on capturing diversity data  
in markets where this is possible from a legal, 
data privacy and cultural perspective. 

We are now using data science to uncover 
barriers to more equal representation  
across the organisation.

Our approach to inclusion is organised under four pillars: 

Investing in talent
To ensure that we have diversity 
of thought and represent the 
communities we serve it is imperative 
that we attract, hire and develop 
high-performing diverse talent. 
Our recruitment, retention and 
development initiatives include 
the following:

 – In recruitment, it is now mandatory 
for all hiring managers to carry out 
inclusive hiring training. For external 
recruitment, we work with agencies 
that specialise in promoting more 
diverse hires at all levels of seniority.

 – To support our people managers 

and colleagues, we have invested  
in expanding our leadership 
development programmes, and in 
initiatives relating to mental health 
and neurodiversity. We are also the 
first UK employer to be accredited 
as menopause friendly.

 – We run targeted leadership 

programmes for underrepresented 
groups, and we have reviewed 
succession plans and pipelines  
for senior leadership roles in our  
key markets with a focus on 
representation of female and 
ethnically diverse talent. 

 For further details on awards 
and employee programmes, 
see the ESG Data Pack at 
www.hsbc.com/esg. 

Investing in employee networks
Tens of thousands of colleagues  
are part of our employee networks, 
focusing on age, disability, mental 
health, ethnicity, faith, gender, LGBT+, 
working parents, carers, and wider 
common interest groups. Each 
network is supported by an 
executive sponsor. Some highlights 
from 2021 include:

 – Balance, our gender network, 

launched an initiative that now  
runs across all employee networks, 
providing structured small group 
executive coaching sessions led  
by internal leaders in 38 markets. 
Nearly 3,000 colleagues have 
benefited to date.

 – Embrace, our ethnicity network, 
hosted global panel sessions on 
World Day for Cultural Diversity to 
discuss the importance of ethnic and 
cultural inclusion and the actions 
needed to bring about sustainable 
change. In the US, Embrace held 
career insights workshops 
showcasing the skills needed for 
various internal vacancies. 

 – Our Pride network launched ‘How  
to be an LGBT+ Ally’ e-learning in  
10 languages. Approximately 2,500 
colleagues completed the training 
within five months, including the 
Group Executive Committee.

Investing in data
The diversity data we collect is 
reviewed by our Group Executive 
Committee on a quarterly basis and 
is used to make evidence-based 
decisions and hold us accountable for 
progress against our commitments. 
We will use diversity data to enhance 
our understanding of employee 
sentiment across diverse groups 
and to enable us to assess the 
inclusiveness of our hiring processes. 
In 2021, highlights included:

 – We have expanded our self-

identification capability to 38 
markets, enabling 91% of our 
workforce to share their 
ethnic heritage. 

 – Employees can now also share 

their disability, gender identity and 
sexual orientation data. These 
self-identification options were 
enabled for 90%, 80% and 70% 
of our workforce respectively, in 
markets where this was permitted 
from a legal, regulatory and 
cultural perspective.

 – As part of the hiring process,  

we have enabled candidates in  
12 markets, including five of our 
largest, to share their diversity data. 
We will add a further seven markets 
in 2022.

Supporting customers 
and communities 
We are committed to supporting  
the diverse communities we serve, 
with actions across HSBC, and in our 
personal and wholesale businesses 
specifically, including:

 – We empowered female 

entrepreneurs to increase the  
scale of their business through 
masterclasses, coaching and 
networking as part of HSBC  
Roar, a customer coaching and 
networking programme launched  
by HSBC Global Business Banking  
in partnership with AllBright.

 – We redesigned our retail banking 

apps in line with accessibility 
guidelines and transformed the 
physical appearance of our credit 
and debit cards to make them 
more accessible.

 – We demonstrated our commitment 
to promoting a culture of respect 
and equality by becoming a 
signatory in 2021 to the UN 
Standards of Conduct for Business: 
Tackling discrimination against 
lesbian, gay, bi, trans, and 
intersex people. 

 For further details of how we are 
making financial services more 
accessible and fair, see ‘Financial 
inclusion’ on page 78.

Disability confidence

Our employee networks are essential to fostering an inclusive culture. Our Ability network 
celebrated International Day of People with Disabilities in partnership with PurpleSpace, 
which launched the Purple Light Up movement to build disability confidence for 
employees and customers. Global events were held to celebrate the contribution of 
colleagues with disabilities, raise awareness of our disability confidence goals, and build 
empathy and allyship. 

In 2021, we made progress on our ambition to become a disability confident organisation. 
Key highlights were: running more than 50 digital accessibility sessions attended by 
15,000 employees and partners; launching local Ability networks in India and Poland,  
and increasing membership across the Group; and welcoming six new colleagues with 
Down’s Syndrome to work in our UK branches.

HSBC Holdings plc Annual Report and Accounts 2021

71

ESG reviewESG review | Social | Employees

Inclusion continued

Women in senior leadership
After achieving our ambition of 30% women 
in senior leadership positions in 2020, we set 
a new goal to reach 35% by 2025. At the end 
of 2021, we had 31.7% of women in senior 
leadership roles.

Appointments of external female candidates 
into senior positions were 37.6%, up from 
31.7% in 2020. Promotions of women into 
senior leadership roles were 43.2%. 

We put in place important foundations in 2021 
through leadership development programmes, 
inclusive hiring, and investing in the next 
generation of high-performing diverse talent.

Our Accelerating into Leadership programme 
was expanded to include ethnically diverse 
men as well as women in middle management. 
In the UK, we piloted the Solaris Bridge 
development programme for high-performing 
Black women.

UK workforce. There are more men than 
women in senior and higher-paid roles, and 
more women than men in junior roles. We also 
have a number of senior, global, head office 
roles based in the UK. 

 For further details on our gender representation, 
ethnicity representation, pay gap data, and 
actions we are taking, see www.hsbc.com/
diversitycommitments and the ESG Data Pack 
at www.hsbc.com/esg.

Talent programmes – including Accelerating 
Female Leaders and our Explore leadership 
course – have provided skills and coaching 
to help high-performing women progress 
their careers at an accelerated rate.

We have partnered with organisations that 
specialise in engaging ethnically diverse talent 
for graduate, mid-career and leadership 
recruitment, and request diverse candidate 
slates from our recruitment partners.

Gender diversity statistics 

Holdings 
Board

Group 
Executive 
Committee

8

5

17

4

Combined 
executive 
committee and 
direct reports1

169

87

Senior 
leadership2

All employees

6,382

2,968

108,296

116,441

Male 

Female

62%

38%

81%

19%

66%

34%

68%

32%

48%

52%

1  Combined executive committee and direct reports 

includes HSBC Group Executives, General 
Managers, Managing Directors, Group Company 
Secretary and Chief Governance Officer and their 
direct reports (excluding administrative staff). 
2  Senior leadership is classified as those at band 3 
and above in our global career band structure.

Our ethnicity commitments
In July 2020, we made a commitment to 
double the number of Black colleagues in 
senior leadership positions by 2025. We have 
focused on the UK and US markets, where 
most of our Black colleagues are based. In 
2021 we grew our number of Black senior 
leaders by 17.5%.

Our global campaign to invite colleagues to 
provide us with data on how they identify has 
provided us with a more robust understanding 
of the ethnic profile of our workforce. Using 
this data, in 2022 we are refining our ethnic 
diversity goals to work towards a diverse 
senior leadership representation that better 
reflects the communities we serve. We will 
maintain our focus on goals for Black senior 
leaders and will also establish goals for other 
underrepresented ethnically diverse groups.

We are building our pipeline of future talent 
through grants, scholarships and internships. 
We have signed up to the UK 10,000 Black 
Interns initiative, pledging to hire 35 interns 
– which is the highest number of places 
among all financial services companies. In 
the UK we also donated £2m to the #Merky 
Foundation to support 30 Stormzy Scholars 
at the University of Cambridge over the next 
three years. In the US, we have established 
an $800,000 scholarship with the Executive 
Leadership Council to fund Black students 
interested in a career at HSBC. 

Representation and pay gap reporting
We publish our gender representation, 
ethnicity representation and pay gap data 
annually to ensure we continue to make 
progress and to help us identify new areas for 
action. We have been reporting our gender 
representation and pay gap data for the UK 
since 2017. In 2020, we voluntarily extended 
our reporting to include ethnicity for the UK 
and gender for the US. In 2021, we extended 
this further to include ethnicity for the US 
and gender for mainland China, Hong Kong, 
India and Mexico. This covers 70% of our 
organisation, providing a clear view of 
overall representation.

While we are confident in our approach to pay, 
until women and ethnically diverse colleagues 
are appropriately represented at every level 
across the organisation, and we have more 
complete ethnicity self-identification data, 
we will continue to see gaps in average pay. 
We review our pay practices regularly and 
work with independent third parties to review 
equal pay. If pay differences are identified  
that are not due to objective, tangible reasons 
such as performance or skills and experience, 
we make adjustments. 

In 2021, our median aggregate UK-wide 
gender pay gap, including all reported HSBC 
entities, was 46.7%, compared with 48.0% in 
2020, and the ethnicity pay gap was -6.0%, 
compared with -5.6% in 2020. Our overall UK 
gender pay gap is driven by the shape of our 

72

HSBC Holdings plc Annual Report and Accounts 2021

Percentage of our senior leadership 
who are women

31.7%

(2020: 30.3%; 2019: 29.4%; 2018: 28.2%)

Ethnicity declaration

52.4%

Colleagues who have shared their ethnic 
heritage with us to date, out of 91% who 
are able to do so.

Diversity data
During 2021, our inclusion team worked 
with legal, regulatory and diversity  
and inclusion colleagues in each of our 
markets to ensure we enabled as many 
colleagues as possible to share their 
data on a voluntary basis. 

This was one of the biggest global 
initiatives we have run, and has resulted 
in significant engagement from 
colleagues sharing their ethnicity 
data so far. 

It will be a multi-year process for 
colleagues and candidates to feel 
comfortable sharing their diversity data 
with us. We will need to demonstrate the 
robustness of our data security controls, 
deliver on our commitments to use this 
data to progress representation targets, 
identify and remove inclusion barriers 
and enhance our inclusion culture. 

Social | Employees

Learning and skills development 

We aim to build a dynamic, inclusive culture 
where colleagues can develop skills and 
undertake experiences that help them fulfil 
their potential. This determines not only how 
we develop our people but also how we 
recruit, identify and nurture talent. 

Our resources 
We use a range of resources to help 
colleagues take ownership of their 
development and career including: 

 – HSBC University is our home for learning 
and skills, which is accessed online and 
through a network of training centres. 
Learning is organised through technical 
academies aligned to businesses and 
functions and enterprise-wide academies.

 – Our My HSBC Career portal offers career 

development information and resources to 
help colleagues manage the various stages 
of their career from joining through to 
career progression.

 – HSBC Talent Marketplace is a new online 

platform using artificial intelligence (‘AI’) to 
match those keen to learn specific skills while 
they work, with opportunities to support 
relevant projects alongside existing work.

Developing strong foundations
We expect all colleagues to complete global 
mandatory training each year. It plays a critical 
role in shaping our culture, ensuring a focus on 
the issues that are fundamental to working with 
us – such as sustainability, financial crime risk, 
and our intolerance of bullying and harassment. 
New joiners attend our Global Discovery 
programme designed to enhance their 
knowledge of the organisation and engage 
them with our purpose, values and strategy. 

As our risks and opportunities change,  
our technical academies offer general and 
targeted development. Our Risk Academy 
provides learning for every employee in 
traditional areas of risk like financial crime risk 
but also offers more specialised development 
for those in high-risk roles and for emerging 
issues like climate risk or the ethics of AI 
and Big Data.

A focus on skills
Our approach to learning is skills based. 
Our academies work with businesses and 
functions to identify the key skills and 
capabilities they need in the future. We also 
help colleagues identify, assess and develop 
the skills that match their aspirations. 

In 2021, we ran a Future Skills campaign called 
Focus 4, encouraging colleagues to identify 
four skills to prioritise in their development 
plans. During four themed weeks colleagues 
attended various events that introduced them 
to areas such as data, digital and sustainability 
skills, as well as personal skills including 
critical thinking and resilience. 

Changing how we learn 
Colleagues can access HSBC University online 
via a learning platform called Degreed. This 
helps them identify, assess and develop skills 
through internal and external courses and 
resources in a way that suits them. Launched 
in 2021, usage of Degreed grew significantly 
through the year.

Degreed materials range from short videos, 
articles or podcasts to packaged programmes 
or curated learning pathways that link content 
in a logical structure. Degreed changes the 
nature of learning, balancing time-intensive 
classroom learning with simple accessible  
and timely content. By December, more than 
115,000 colleagues were registered on the 
platform, and in 2021, overall training volumes 
were up to 26.7 hours per FTE from 23 hours 
per FTE in 2020. 

Most development happens while our 
colleagues work. In 2021, we launched an 
AI-based platform called Talent Marketplace, 
which matches colleagues to projects and 
experiences based on their aspirations. By 
December, this had been rolled out to nearly 
50,000 colleagues in the US, India, Singapore 
and the UK, and will be rolled out globally 
in 2022.

Leadership development
It remains critical to our ability to energise for 
growth that we manage people effectively and 
our leaders make an impact. In recent years, 
we have refreshed how we provide leadership 
development. In 2021, we launched a new 
executive development curriculum for our 
most senior leaders, combining internal 
programmes and business school activities 
with targeted technical programmes on key 
topics and skills. 

Retaining and identifying future talent
The starting point to identifying talent is having 
a recruitment process that is fair and inclusive. 
In February 2021, we launched inclusive hiring 
training to help managers make decisions in 
line with our hiring principles. Managers can 
now only hire once they have completed this 
training, with over 13,500 managers receiving 
certification in 2021. 

As we reshape HSBC we recognise that 
managing change well is critical. To that 
end, we have committed to focusing on 
redeploying those colleagues impacted by 
restructuring. In 2021, 23% of staff impacted 
found new jobs within HSBC, compared with 
14% in 2020. 

Our global graduate programme welcomed 
650 new colleagues to the organisation in 
2021. We held a three-day virtual induction 
to help graduates understand the programme 
and how they can play their part in bringing 
our purpose, strategy and values to life.

The Group Executive Committee takes time 
to identify successors for our most critical 
roles. Successors undergo robust assessment 
and participate in executive development 
programmes. 

Training at HSBC

5.9 million 

Training hours carried out by our  
colleagues in 2021.
(2020: 5.2 million)

New routes to 
opportunity

Our Talent Marketplace platform helps 
our colleagues to open up a world of 
new opportunities to develop their  
skills, connections and careers to 
complement traditional learning.

Colleagues can create a profile that 
describes their skills, experience and 
aspirations. The system uses AI to 
match projects to potential candidates, 
providing our colleagues with an 
opportunity to learn and offering project 
owners a diverse pool of talent from 
which to draw.  

Having launched in a number of 
countries in 2021, Talent Marketplace is 
helping our colleagues to connect with 
each other around the world and realise 
new opportunities. For example, one 
Singapore-based colleague who 
wanted to improve their communication 
skills and was matched with a 
London-based project owner who 
needed local market knowledge and 
language skills. 

HSBC Holdings plc Annual Report and Accounts 2021

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Listening to our colleagues

We were founded on the strength of different 
experiences, attributes and voices. We believe 
that seeking out and listening to the views of 
our colleagues is a fundamental part of who 
we are and how we work. This has been 
especially important in 2021, as we look to 
define the future of work, support colleague 
well-being and develop the skills to enable 
future success.

Listening to colleague sentiment
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. We complement these 
all-employee surveys with targeted listening 
activity throughout the year, and in 2022 we 
will move to one all-employee Snapshot 
survey to reduce the risk of survey fatigue.

We received 272,718 responses to our two 
Snapshot surveys in 2021, with a record 
response rate of 64% in June and 61% in 
December, up from 62% and 56% respectively 
in the same periods of 2020. 

Employee listening to support our 
people priorities
In addition to our regular Snapshot surveys, 
we captured monthly feedback through  
a series of pulse surveys from September 
2020 through to April 2021 to understand 
colleagues’ views on returning to the 
workplace and their preferences for the future 
of work, with more than 60,000 participants. 
This feedback was complemented by a virtual 
focus group involving 3,400 colleagues across 
20 markets in September 2021, deep-diving 
into hybrid working. We will continue to 
monitor employee attitudes and preferences 
for the future of work through our Snapshot 

surveys and other targeted research.  
For further details on the future of work,  
see page 70.

We also used our Snapshot surveys and virtual 
focus groups to engage with colleagues about 
learning and skills development, with over 
1,100 participants to a series of virtual focus 
groups in March 2021 on learning, 
development and skills for the future. In our 
December Snapshot, 76% of colleagues said 
that where they work, people are empowered 
to seek opportunities to learn and develop 
new skills. For further details on learning and 
skills development, see page 73.

Employee well-being has remained a central 
focus of our Snapshot research throughout 
2021 with a dedicated section of each survey 
focused on colleague well-being. For further 
details on well-being, see page 76.

We also used Snapshot and pulse surveys 
to measure the progress of our refreshed 
purpose, strategy and values, which we 
launched in February 2021. By the end of 
2021, 78% of colleagues said they were aware 
of these, and 82% of those believed that we 
have the right purpose, strategy and values 
to drive success (see below).

Fostering an inclusive working 
environment
We expect our people to treat each other 
with dignity and respect and do not tolerate 
bullying or harassment on any grounds.

Over the past few years, we have 
strengthened our approach to bullying  
and harassment, improving our collective 
understanding of, and response to, these 
issues. In 2021, we reinforced expected 
standards of conduct with a refreshed  

global anti-bullying and harassment code, 
supplemented with local codes to reflect 
cultural context while maintaining consistent 
high standards across the Group. 

We have added further anti-bullying and 
harassment messages to our mandatory 
training for all our colleagues, and continued 
our campaign to encourage colleagues to be 
‘active bystanders’ and speak up when they 
see or experience poor behaviours or things 
that do not seem right. 

We have mandatory local procedures for 
handling employee concerns, including 
complaints of bullying and harassment. 
Where investigations are required, we have 
a global framework setting the standards for 
those investigations and an additional quality 
assurance process. We monitor bullying and 
harassment cases to inform our response 
and identify actions that could prevent 
future issues. The data is reported to 
management committees.

We are not complacent and know that this 
journey continues. Our refreshed values will 
guide and inform our plans for 2022 to 
continue to create and promote an inclusive 
working environment.

Employee engagement and turnover 

Employee
engagement

Voluntary
turnover

Involuntary
turnover

2021 

2020

72%

72%

12.7%

7.7%

3.8%

3.6%

Embedding our new purpose and values

Following the launch of our new purpose 
and values in February 2021, we have 
continued to embed them in how 
we operate. 

As well as building awareness through 
communications, we have helped leaders, 
teams and individuals explore how they 
bring them to life through workshops, 
webinars and team discussions. We have 
further embedded the new values and their 
associated behaviours into our learning 
programmes, recognition schemes and 
performance management processes across 
HSBC. We continue to find ways to make 
our purpose and values a cornerstone of 
how we communicate, conduct business 
and deliver employee services.

Awareness of the new purpose and values 
has been consistently high, at 78% in June 
and December 2021. As evidence that the 
new purpose and values are becoming 
embedded, we had positive change in 
sentiment during the year. Among colleagues 
who were aware of our purpose and values, 
76% of respondents to the December 
Snapshot survey believed that they will lead 
to meaningful changes in how we work. This 
was a seven point increase from the survey 
result in June. Similarly, a total of 77% of 
employees stated in December that people 
around them demonstrate the values in how 
they work, which was a seven point increase 
from June. Overall, 82% of aware employees 
believed that we have the right purpose, 
strategy and values to drive success.

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Social | Employees

Listening to our colleagues continued 

Measuring our progress against peers
We use seven 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

Employee 
engagement

Employee 
focus

Score1

vs 
2020

HSBC vs 

benchmark2 Questions that make up the index

72

0

+4

71

-1

+3

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.

Strategy

72

+4

+2

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.

Change 
leadership

74

Speak-up

75

0

0

-2

+8

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

76

+1

+5

I trust my direct manager.
I trust senior leadership in my area.
Where I work, people are treated fairly.

Career (new)3

67

+2

+3

I feel able to achieve my career objectives at this company.
I believe that we have fair processes for moving/promoting people into new roles.
My line manager actively supports my career development.

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.

3 The career index was introduced in early 2021. It comprises questions that were asked in earlier surveys so we are able to report a comparison with 2020.

Managing employee engagement
Three of our seven Snapshot indices improved 
in 2021, following significant increases in 
2020. Employee engagement, which is our 
headline measure, was four points above 
benchmark and five points above 2019 levels. 
The measure was unchanged from 2020, as 
were the speak-up and change leadership 
indices. The employee focus index dropped 
by one point, but remained three points above 
the benchmark. 

Our response to the Covid-19 pandemic 
remained a strong positive driver of employee 
sentiment in 2021. Employee feedback 
frequently references flexibility and the ability to 
work from home as an important factor in why 
they would recommend HSBC as a great place 
to work, with employee well-being, HSBC’s 
Covid-19 response and the working 
environment having the greatest positive 
influence on employee engagement. Looking 
beyond the pandemic, we will continue to focus 
on aspects of the wider employee experience 
that our research shows are the strongest 
drivers of employee engagement. This included 
ensuring that colleagues feel a sense of 
belonging, feel trust towards leadership, see 
career progression opportunities at HSBC and 
are confident in the company’s future. 

Our strategy index continued to strengthen 
with employees increasingly confident about 
the future. We still trailed the benchmark by 
five points for employees stating that they see 
the positive impact of our strategy. We hope 
to address this through a renewed focus on 
our purpose and strategy as part of our 2022 
employee engagement activities. 

We note that voluntary turnover increased 
from 7.7% in 2020 to 12.7% in 2021, consistent 
with trends across the wider employment 
market. Our Snapshot survey showed a slight 
decrease in employees who intend to stay 
with HSBC for five or more years, from 65% in 
2020 to 64% in 2021. Our research shows that 
how employees feel about their career at 
HSBC is a key driver of their intent to stay. 
Ensuring that our people have the opportunity 
to develop new skills and further their careers 
with HSBC is therefore important for retaining 
talent. We are reassured that against this 
backdrop, our career index increased by two 
points since 2020 and was three points above 
the external benchmark. 

Employee engagement

72%

Employee engagement index score 
(2020: 72%)

74%

Of colleagues feel confident about this 
company’s future 
(2020: 70%) 

67%

Of colleagues feel they can achieve their 
career objectives at this company 
(2020: 66%) 

 For further details on how employee engagement 
scores, including among colleagues identifying 
as part of an ethnic minority or as having a 
disability, have an impact on executive Director 
remuneration scorecards, see page 268 in our 
corporate governance report.

HSBC Holdings plc Annual Report and Accounts 2021

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ESG reviewESG review | Social | Employees

Well-being

We are deeply committed to supporting the 
well-being of our colleagues as we transition 
to new ways of working and support our 
colleagues through the pandemic. Guided  
by data and feedback from our employee 
surveys, our approach will continue to adapt 
to ensure our services remain relevant. 

In 2021, our global well-being programme 
covered three pillars: mental, physical and 
financial. In 2022, we added social well-being 
as a fourth pillar. 

Mental well-being 
Despite the immense challenges of the 
Covid-19 pandemic, 82% of colleagues in our 
December Snapshot survey rated their mental 
well-being as positive, compared with 81% in 
2020. However, colleagues faced challenges, 
with 27% asking for more support in this area. 
To address this, we made Headspace, a 
meditation app, available to all colleagues 
globally. Since July 2021, 23,000 colleagues 
have used Headspace to access guided 
exercises and meditations. 

All colleagues took part in mental health 
awareness training, as part of our global 
mandatory training programme. We updated 
our mental health e-learning to help 
colleagues identify signs of mental ill-health  
in other colleagues, in both remote and 
face-to-face settings, as well as to help have 
supportive conversations with customers. 
Despite being voluntary the e-learning has 
been completed by 26,000 colleagues, with 
18% of these being line managers. 

To celebrate World Mental Health Day, we  
ran a global awareness campaign and created 
a film featuring colleagues sharing personal 
stories. Throughout October 2021, we held 
over 60 virtual events globally, featuring 
external experts providing advice on mental 
health-related topics. 

We know from employee surveys that 
colleagues are more likely to report better 
mental well-being when they are physically 
active, have a good work-life balance, and 
have regular well-being conversations with 
their manager. We recognise there is more  
we can do to support these good habits and 
will prioritise addressing them in 2022. 

During the pandemic, we preserved pay and 
benefits, and introduced hardship funds in 
some markets, which allowed colleagues  
to apply for financial support. In 2021, we 
expanded our employee banking proposition, 
HSBC Together, into Asia and parts of Europe, 
providing financial guidance and seminars in 
seven countries, covering 53% of colleagues. 

Physical well-being
Employee Snapshot surveys revealed 75% 
of colleagues rated their physical well-being 
positively, compared with 73% in 2020. As 
a result of the pandemic, access to doctor 
appointments became limited in some 
locations. To reduce the risk of serious 
illnesses going undetected, we increased 
the number of markets where we offered 
telemedicine services, allowing colleagues 
to have appointments with doctors virtually. 
Coverage of our workforce increased from 
50% in 2020 to 66% in 2021. We have 
continued to provide access to private 
medical insurance in the majority of our 
countries, covering 98% of permanent 
employees. In certain countries we provide 
on-site medical centres that the majority of 
employees can access.

In June, we ran a month-long global physical 
well-being campaign, featuring guidance from 
sport ambassadors and our Chief Medical 
Adviser on topics including management of 
chronic conditions, exercise, nutrition and 
symptoms that should not be ignored. 

Financial well-being
Snapshot surveys revealed a decrease in 
financial well-being, with 64% of colleagues 
reporting positively, compared with 68%  
in 2020. However, colleagues felt more 
supported to manage their financial well-
being, at 58%, an increase of two points, and 
more confident talking about their financial 
well-being with their line manager, at 56%, 
an increase of six points.

We also introduced employee share plans in 
mainland China and Poland for the first time, 
meaning 90% of colleagues can invest in 
HSBC shares.

Social well-being 
At the beginning of 2022, we formalised social 
well-being as a new pillar of our programme. 
This was done to address challenges around 
reduced in-person connections, and to 
continue the development of our colleagues’ 
work-life balance. 

We will prioritise promoting team cohesion in 
a hybrid environment, with 25% of colleagues 
indicating they would like better technology 
and support with interacting with one another. 
Snapshot surveys revealed 76% of colleagues 
say they can integrate their work and personal 
life positively, compared with 74% in 2020. We 
will continue to facilitate this by introducing 
flexible working policies in line with our future 
of work initiative (see page 69). 

In 2021, we refreshed our At Our Best 
recognition online platform, which allows 
for real-time recognition and appreciation 
between colleagues. In 2021, the total number 
of recognitions made was 1.1 million. In 2022, 
we will evolve the programme to encourage 
more recognitions, including through access 
on mobile devices.

Global Centre for Healthy Workplace 
Awards 2021
 – Best global healthy workplace 

programme, multinational employer

Advocating change for positive mental health

In January 2021, we helped found and launch 
the Global Business Collaboration for Better 
Workplace Mental Health. It is the first global 
business-led initiative of its kind designed to 
advocate for – and accelerate – positive 
change for mental health in the workplace. 

Despite important progress in some countries, 
there remains a lack of evidence, best practice 
and tools, to effectively implement global 
approaches to workplace mental health.  
This challenge is exacerbated by cultural 
complexities and stigma. 

Together with academic experts and 
not-for-profit organisations, we want to 
create a world where all business leaders 
recognise, have the right tools, and commit 
to take tangible and evidence-based action 
on mental health in the workplace, 
enabling their workplace to thrive.

This initiative seeks to advance progress 
around the world by committing business 
leaders to a pledge to create mentally 
healthy workplaces, and by freely sharing 
insights and best practices to create  
a roadmap for change, wherever an 
organisation is on its journey.

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Social | Communities

Communities

We have a long-standing commitment to 
support the communities in which we operate, 
in areas where we can make a difference and 
support sustainable economic growth.

Our Future Skills strategy aims to provide our 
customers, colleagues and communities with 
the employability and financial capability skills 

and knowledge needed to thrive in the 
post-pandemic environment, and through the 
transition to a sustainable future. Our five-year 
Climate Solutions Partnership, powered by 
$100m of our philanthropic funding, aims to 
scale up climate innovation ventures and 
nature-based solutions, and to help transition 
the energy sector towards renewable sources. 

We also recognise the importance of listening 
to – and addressing – local community needs 
and causes. We earmark approximately a 
quarter of our funding for causes that are 
important to communities across our network, 
such as environmental protection or 
healthcare.

Supporting communities

Future skills
Our Future Skills strategy, launched in 2018, 
has supported over 5.2 million people through 
more than $156m in charitable donations. 
Current projections from our charity partners 
indicate our support during 2021 reached more 
than 1.2 million people through donations  
of $41.8m.

With the global economy still feeling the 
effects and restrictions from the Covid-19 
pandemic, our colleagues and partners have 
continued to deliver programmes aimed at 
ensuring that people likely to be most impacted 
are not left behind. We also funded global 
research by The Prince’s Trust group of 
charities, to get a true understanding of how 
young people feel about the future of work  
in this context.

We support our charity partners to deliver  
a combination of global and locally-led 
programmes, including:

 – Junior Achievement’s International 

Innovation Challenges, which encourage 
young people to use their creativity to help 
communities develop financial capability;

 – our Green Skills Innovation Challenge with 

Ashoka – a global network for social 
entrepreneurs – which recognised 12 
innovators who are simultaneously solving 
environmental and social problems;

Charitable giving in 2021

Social, including Future Skills: 39%
Environment, including the Climate 
Solutions Partnership: 18%
Local priorities: 22%
Disaster relief and other giving: 21%

 – the Technovation Girls programme, which 
aims to address the lack of diversity in  
the technology sector by equipping young 
women and girls with the skills to become 
technology entrepreneurs and leaders;

 – Soliya, an international non-profit 

organisation, whose work enables young 
adults to gain the skills needed to thrive in 
a connected world; and

 – the Ryerson Diversity Institute’s Pursue 
Entrepreneurship programme, which 
supports Black high school students and 
recent graduates to develop leadership skills 
and explore careers in entrepreneurship.

Our High Impact grants programme allows  
our teams to apply for additional funding to 
support local projects. This year we awarded 
$7.4m to 26 projects, which will be distributed 
over two years.

Climate Solutions Partnership
Working with the World Resources Institute 
and WWF, we are focusing our collective 
efforts on three global themes: climate-related 
innovation, nature-based solutions and energy 
efficiency initiatives in Asia. We see these as 
having the potential to make a significant 
impact in the mission to achieve a net zero, 
resilient and sustainable future. Since 2020, 
we have provided $28.4m to our NGO partners.

Local priorities
Our support for Covid-19 relief efforts 
continued in 2021, with a further $10m 
donated in India. Focusing on the longer-term 
response to the pandemic, we also launched a 
one-year programme with UNICEF to support 
the employability and financial capability of 
young people in Mexico, Indonesia and India.

Employee volunteering
We offer paid volunteering days, and 
encourage our people to give time, skills and 
knowledge to causes within their communities. 
In 2021, our colleagues gave over 79,000 hours 
to community activities during work time.

Engagement with pressure groups
We aim to maintain a constructive dialogue 
on important topics that are often raised 
by campaigning organisations and 
pressure groups.

Skills impact bond

In 2021, we supported India’s first skills 
impact bond, issued by the National 
Skills Development Corporation, a 
public-private partnership set up by 
India’s Ministry of Finance. We are 
providing $4.3m as one of four outcome 
funders, who commit to pay out once 
the partnership achieves its stated 
objectives. Over the next four years,  
the partnership aims to equip 50,000 
young people with skills and vocational 
training, and to help them to find 
employment. Our philanthropic funding 
towards the bond aims to prove the 
concept of this innovative approach,  
and act as a catalyst for much wider 
impact in the future.

Total cash giving towards 
charitable programmes 

$113.8m

Hours volunteered during work time

>79,000

People reached through our Future 
Skills programme

1.2 million

HSBC Holdings plc Annual Report and Accounts 2021

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ESG reviewESG review | Social | Communities

Financial inclusion

We believe that financial services, when 
accessible and fair, can reduce inequality and 
help more people access opportunities. We 
aim to play an active role in opening up a 
world of opportunity for individuals by building 
financial health and removing the different 
barriers that people can face in accessing 
financial services.

Access to products and services
We remain committed to supporting 
individuals experiencing homelessness or 
housing difficulties through our ‘no fixed 
address’ service in the UK and Hong Kong. 
We continue to support survivors of human 
trafficking in the UK, as well as refugees and 
unified screening mechanism claimants in 
Hong Kong through the provision of basic 
banking services. In 2021, HSBC UK also 
supported 150 Afghan settlers who arrived in 
the country as part of a resettlement scheme 
to open bank accounts, a crucial first step to 
moving their lives forward. In May 2021, as 
part of our ongoing efforts to create innovative 
product offerings, we introduced basic 
banking services for ethnic minority 
customers in Hong Kong who have a  
limited understanding of English or Chinese. 

Making banking accessible
Number of accounts opened for homeless, 
refugees and survivors of human trafficking

2021

2020

2019

2019

2,295

840

244

Access to financial education
We continue to invest in financial education 
content and features across different channels, 
to help customers, colleagues and communities 
be confident users of financial services. 
Throughout 2020 and 2021, we received over 
2.8 million unique visitors to our digital financial 
education content, making progress towards 
our 2019 goal of reaching 4 million unique 
visitors by the end of 2022. In the UK, we have 
a financial fitness score that provides individuals 
with an indicative score on the healthiness of 
their finances based on details about their 
spending, borrowing and saving habits, as 
well as tips to improve their financial fitness. 

Our financial education offering is extended  
to our colleagues in the form of online learning 
modules, empowering them to improve their 
skills and enhance their financial well-being. 
We also deliver digital content and webinars to 
employees of our corporate clients on a broad 
range of financial topics. These are supported 
by financial health checks – a one-on-one 
conversation on a non-advised basis to 
discuss individuals’ circumstances based 
on their learning. 

We support charity programmes that deliver 
financial education to our local communities. 
In 2021, we launched our Saving for Good 
programme in partnership with JA Worldwide 
– Injaz Al-Arab. The programme aims to equip 
economically vulnerable migrant workers in 
Bahrain, Egypt, Kuwait, Qatar and the UAE 
with financial literacy skills to strengthen their 
financial resilience. 

We understand the importance of building 
financial capability in children to ensure  
future resilience, and continue to collaborate 
with partners to deliver financial education 
programmes such as Money Heroes. In 2021, 
HSBC UK also introduced a programme to 
tackle the unhealthy spending habits associated 

with the increased amount of gaming that 
young people are engaging with today.  
The programme featured digital tools, videos 
and in-school lesson plans to educate children 
and parents on the issue. 

Inclusive design 
We aim to ensure that our banking products 
and services are designed to be accessible for 
customers experiencing either temporary or 
permanent challenging circumstances, such 
as disability, impairment or a major life event. 
For further details on our new HSBC UK 
accessible card features, see page 297.

We strive to make our digital channels 
accessible so they are usable by everyone, 
regardless of ability. We have now reviewed 
our browser-based websites in 27 retail 
markets and our mobile banking services  
in 21 markets against the Web Content 
Accessibility Guidelines 2.0 AA standards, 
which are stipulated by the World Wide Web 
Consortium. We are continuing to make 
progress in this area.

We also want to be more explicit about 
catering for neurodiverse users and have 
launched our first Neurodiversity Guidelines. 
The purpose of these guidelines is to provide 
members of HSBC digital teams with guidance 
for how they should design, code and create 
digital content to support the needs of people 
who are neurodiverse.

Within our insurance business, we are 
redesigning the layout of our documents, 
adding in visual graphics and simplifying 
the language used.

 For further details of our product design and  
our product responsibilities, please see page 83. 

Supporting women and minority-led businesses

a network that helps women in business 
connect with funding and growth 
opportunities. Together with AllBright, we 
launched HSBC Roar in 2021, a customer 
coaching and networking programme for 
female entrepreneurs. 

We are aiming to support our diverse 
customers by opening up a world of 
opportunity for women and minorities. In 
October 2021, we committed to allocating 
$100m in lending for companies that are 
founded and led by women and minorities 
through HSBC Ventures, which provides 
capital to start-ups and early stage 
businesses around the world. We 
understand it is critical to provide financial 
support to founders who are historically 
underrepresented, so that their businesses 
can grow and expand. Since 2019, we have 
also been in partnership with AllBright, 

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HSBC Holdings plc Annual Report and Accounts 2021

Governance 

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 strive to 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 217.

How ESG is governed

We expect that our ESG governance approach is likely to continue to develop, in line with 
our evolving approach to ESG matters and stakeholder expectations.

Our respect for 
human rights

As set out in our Human Rights Statement, we strive for continual improvement in our 
approach to human rights. 

Conduct: Our product 
responsibilities

Our conduct approach guides us to do the right thing and to focus on the impact we have 
on our customers and the geographies in which we operate.

Cybersecurity

Data privacy

We invest heavily in our business and technical controls to help prevent, detect and mitigate 
cyber threats.

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 with 
our suppliers

We require suppliers to meet our compliance and financial stability requirements, as well 
as to comply with our supplier ethical code of conduct.

Safeguarding the 
financial system

Whistleblowing

A responsible approach 
to tax

Acting with integrity

We have continued our efforts to combat financial crime risks and reduce their impact on 
our organisation, customers and communities that we serve.

Our global whistleblowing channel, HSBC Confidential, allows our colleagues and other 
stakeholders to raise concerns confidentially.

We seek to pay our fair share of tax in all jurisdictions in which we operate. 

We aim to act with courageous integrity and learn from past events to prevent 
their recurrence.

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HSBC Holdings plc Annual Report and Accounts 2021

79

ESG reviewESG review | Governance 

How ESG is governed 

The Board takes overall responsibility for ESG 
strategy, overseeing executive management  
in developing the approach, execution and 
associated reporting. Progress against our 
ESG ambitions is reviewed through Board 
discussion and review of key topics such as 
updates on net zero, customer experience and 
employee sentiment. Board members receive 
ESG-related training as part of their ongoing 
development, and seek out further 
opportunities to build their skills and 
experience in this area. For further details on 
Board members' ESG skills and experience, 
see page 220. For further details on their 
induction and training in 2021, see page 229.
Given the wide-ranging remit of ESG matters, 
the governance activities are managed 
through a combination of specialist 
governance infrastructure and regular 
meetings and committees, where appropriate. 
These include the Disclosure Committee, 
which provides oversight for the scope and 

content of ESG disclosures, and the Group 
People Committee, which provides oversight 
support for the Group’s approach to 
performance management. 

For some areas, such as climate where our 
approach is more advanced, dedicated 
governance activities exist to support the 
wide range of activities, from sustainable 
finance solution development in the 
Sustainability Execution Review Group to 
climate risk management in the Climate 
Risk Oversight Forum. 

The Group Chief Risk and Compliance Officer 
and the chief risk officers of our Prudential 
Regulation Authority-regulated businesses are 
the senior managers responsible for climate 
financial risks under the UK Senior Managers 
Regime. The chief risk officers attend Board 
meetings and where appropriate provide 
regular verbal and written updates to the 

Board and Group Executive Committee. 
Climate risks are also considered in the Group 
Risk Management Meeting and the Group 
Risk Committee, with scheduled updates 
provided, as well as detailed reviews of 
material matters, such as climate-related 
stress testing exercises.

The below table details the main specialist 
governance forums, their responsibilities  
and the responsible executives for the 
management of ESG matters. We expect  
that our ESG governance approach is likely to 
continue to develop, in line with our evolving 
approach to ESG matters and stakeholder 
expectations. The Board is regularly provided 
with specific updates on ESG matters, 
including the thermal coal phase-out policy 
and exposures, human rights, and employee 
well-being.

Governance forums

Responsible for:

Responsibility held by:

ESG Committee (new)

Sustainability Execution 
Review Group (new)

Social management forums

Governance management 
forums

Digital Business Services 
ESG Forum

Human Rights Steering 
Committee

Climate Risk Oversight Forum 

Group Reputational 
Risk Committee

Supports Group Executives in the development and 
delivery of ESG strategy, key policies and material 
commitments by providing oversight, coordination  
and management of ESG commitments and activities

Oversees the delivery of our ambition to provide and 
facilitate $750bn to $1tn of sustainable finance and 
investment, and realisation of commercial opportunities

Group Chief Sustainability Officer 
and Group Company Secretary and 
Chief Governance Officer

Group Chief Executive

Oversees employee engagement, diversity and 
inclusion, community engagement, customer 
satisfaction, and social considerations for stakeholders

Group Chief Human Resources 
Officer and Group Chief 
Communications Officer

Oversees subsidiaries, business conduct and ethics, 
corporate governance, whistleblowing, reputational 
factors, data privacy and human rights

Group Chief Risk and Compliance 
Officer and Group Company Secretary 
and Chief Governance Officer

Group Chief Operating Officer

Group Chief Risk and 
Compliance Officer

Oversees the global delivery of ESG activities within our 
own operations, services and technology elements of 
our strategy

Supports global leadership in promoting, enhancing  
and reflecting human rights in execution of the Group's 
strategic goals, as well as developing the Group’s 
Human Rights, and Modern Slavery and Human 
Trafficking statements and associated oversight 
of implementation

Oversees all global risk activities relating to climate 
risk management, including physical and transition 
risks. Equivalent forums have been established at 
regional level

Oversees global executive support for identification, 
management and ongoing monitoring of reputational 
risks, including those related to ESG matters

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Governance 

Our respect for human rights

As set out in our Human Rights Statement, we 
follow the UN Guiding Principles on Business 
and Human Rights (‘UNGPs’). In 2021, with the 
help of external stakeholders, we continued to 
review and improve our approach.

Our priorities on human rights
We respect all categories of human rights in 
the Universal Declaration of Human Rights. 
We focus our attention on those rights we 
assess as most likely to be affected by our 
business activities and by those of our 
customers and suppliers. 

Such assessment takes account of a range  
of factors, including geographical and cultural 
context and economic sectors, and is subject 
to periodic review. After a policy review and 
prioritisation process, including consultation 
across key business units, we identified 
discrimination and modern slavery as the  
two priority human rights issues on which  
we could use our influence to make the most 
positive impact. These priorities also align 
closely with our commitments on diversity  
and inclusion and those we have made under 
the UN Global Compact and under the WEF 
metrics on risk for incidents of child and forced 
or compulsory labour. 

 For further details on our approach to tackling 
discrimination, see www.hsbc.com/
diversitycommitments. For further details on 
our work on inclusion in the workplace, see 
‘Inclusion’ on page 71.
 For further details of our approach to tackling 
modern slavery, including steps taken to 
eliminate child and forced labour practices, 
see www.hsbc.com/modernslaveryact.

Our priority human rights issues in 2021

Issues

Discrimination

Modern slavery

In the 
workplace

In our services

Our 
employees

Suppliers' 
employees

Customers Communities

◆

◆

◆

◆

◆

◆

◆

◆

Financial crime controls 
The risk of us causing, contributing or being 
linked to negative human rights impacts  
is also mitigated by our financial crime 
framework, with global policies to mitigate 
money laundering, sanctions, and bribery  
and corruption risks, including those where 
protecting human rights and preventing 
financial crime converge. Our financial crime 
controls include customer due diligence, 
sanctions screening, transaction monitoring, 
negative news screening, and targeted 
investigations.

 For further details of how we fight financial 
crime, see www.hsbc.com/who-we-are/
esg-and-responsible-business/fighting- 
financial-crime.

Sector policies
To meet our responsibility for respecting 
human rights under the UNGPs, we consider 
those rights that may be adversely impacted 
through involvement in high-risk sectors.  
Our sector policies for agricultural 
commodities, energy, forestry, mining and 
metals all refer specifically to human rights. 
These considerations include issues such as 
forced labour, harmful or exploitative child 
labour, trafficking, land rights, the rights of 
indigenous peoples such as ‘free prior and 
informed consent’, workers’ rights, and the 
health and safety of communities. 

Our policy for financing forest plantations and 
downstream supply chain operations in, or 
sourced from, high-risk countries is linked 
to certification by the Forestry Stewardship 
Council or the Programme for the 
Endorsement of Forest Certification. Through 
our membership of international certification 
schemes such as the Forestry Stewardship 
Council, the Roundtable on Sustainable Palm 
Oil and the Equator Principles, we actively 
support the continual improvement of 
standards aimed at respecting human rights. 

 For further details of our policy prohibitions and 
other financing restrictions, see our sector-
specific sustainability risk policies at www.hsbc.
com/who-we-are/esg-and-responsible-business/
managing-risk/sustainability-risk. 

Sustainable finance and the just transition

Our leading role in providing and facilitating sustainable finance to businesses around the 
world is another way in which we contribute to the rights of the communities we serve. We 
support the drive for a ‘just transition’ to net zero, harnessing political momentum for action 
with policies and finance to support disadvantaged sectors and communities. On 29 October 
2021, we joined other private sector institutions in signing up to the WEF Just and Urgent 
Energy Transition principles.

We are also harnessing our leadership position in sustainable finance to create products that 
will help our clients to support social development, mobility and capability building in line 
with International Capital Markets Association social bonds principles released in 2021.

 For further details of how we support our customers with sustainable finance, see ‘Supporting 
customers through the transition’ on page 53.

HSBC Holdings plc Annual Report and Accounts 2021

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ESG reviewESG review | Governance 

Our respect for human rights continued

Supporting change
We continued to expand our Survivor Bank 
programme, which has now benefited over 
1,000 survivors of modern slavery and human 
trafficking in the UK, and is a model for 
making financial services more accessible to 
vulnerable communities worldwide. We built 
on this experience in developing access to 
banking services for customers in the UK 
and in Hong Kong with no fixed abode.

In Hong Kong, we also introduced basic 
banking services for ethnic minority customers 
who do not speak English or Chinese. The 
service allows ethnic minorities who speak 
Hindi, Punjabi, Nepali and Urdu to open a 
Hong Kong Dollar Statement Savings account, 
by providing tailored material in each of the 
four languages. In addition, we hired part-time 
ethnic minority customer service ambassadors 
to offer further support at six designated 
branches. In May 2021, the Hong Kong Equal 
Opportunities Commission named HSBC a 
Gold Awardee in the inaugural Equal 
Opportunity Employer Recognition scheme, 
which recognises organisations for setting an 
example in promoting and implementing equal 
opportunities employment policies.

These initiatives support several different 
human rights, such as the right to adequate 
living standards and the right to own property. 
As well as benefiting the communities we 
serve in the UK and Hong Kong, these 
initiatives allowed us to work alongside 
local non-governmental organisations, 
learning from their understanding of 
human rights impacts.

We are committed to working with 
governments to help create inclusive 
communities. In 2021, we supported the 
development of regulation related to human 
rights, including as an adviser to the UK 
Government on developing their online 
Registry of Statements under the Modern 
Slavery Act. 

Stakeholder engagement

In 2021, as part of an internal survey of 
senior executives, we gathered information 
from across our network on our 
engagement with civil society stakeholders 
and those who represent individuals or 
groups at risk of impact from our activities 
or from the activities of those with whom 
we have business relationships. As a result 
of this work, we acknowledged the need to 
expand our engagement in future. We also 
took steps to ensure that our approach to 
human rights was well understood by our 
colleagues. In 2021:

 – We offered a detailed course on human 

trafficking to new employees in the 
Global Risk Operations function, 
highlighting the importance of 
identification and reporting.

 – We provided detailed briefings to more 
than 250 senior colleagues on human 
rights and the UNGPs.

 – We provided training materials to 

colleagues in our Procurement team 
on modern slavery.

 – We delivered training on anti-

discrimination as part of our diversity 
and inclusion programme.

As we develop our approach to human 
rights, we will focus on training modules 
for our colleagues, supplemented by 
role-specific training. We also intend to 
improve the process for our suppliers to 
ensure that the key elements of our ethical 
code of conduct that relate to human rights 
are clearly and regularly communicated. 
For retail customers, we aim to 
communicate our approach and 
expectations through our public 
statements, and for our business 
customers, we aim to integrate our 
approach to human rights more clearly 
into our processes.

In developing the initiatives described 
above, we drew upon expertise from within 
our organisation, including the insights of 
specialist staff in key departments and of 
200 senior executives from every part of 
our network. We also engaged the support 
of external advisers with expertise in 
human rights as they relate to business. 

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Governance 

Conduct: Our product responsibilities

Following the refresh of our purpose and 
values, we have taken the opportunity to align 
and simplify our conduct approach, making 
conduct easier to understand and showing 
how it fulfils our value ‘we take responsibility’. 

 – We offer a carefully selected range of 

products that are managed through product 
inventories, helping to ensure they continue 
to meet customers’ needs and continue to 
deliver a fair exchange of value. 

Meeting our customers’ needs 
Our customers’ interests are at the centre of 
everything we do, and we have policies and 
procedures in place that set the standards 
required to protect them. These include: 

Our conduct approach guides us to do the 
right thing and to focus on the impact we 
have on our customers and the financial 
markets in which we operate. It focuses 
on five clear outcomes: 

 – We understand our customers’ needs. 

 – We provide products and services that  

offer a fair exchange of value. 

 – We serve customers’ ongoing needs,  

and will put it right if we make a mistake. 

 – We act with integrity in the financial markets 

we operate in. 

 – We operate with resilience and security  
to avoid harm to customers and markets. 

Our conduct approach is embedded into the 
way we develop, distribute, structure and 
execute products and services. For further 
details of our approach to conduct, see 
page 208.

Designing products and services 
Our approach to product design and 
development – including how we advertise 
our products – is set out in our policies, and 
provides a clear basis from which strategic 
product and service decisions can be made. 
Our global businesses each take the 
following approach:

 – We carry out robust testing during the 

design and development of a product to 
help ensure there is an identifiable need 
in the market.

 – We consider the complexity of products 

and the possible financial risks to customers 
when determining the target market.

 – We regularly review products to help ensure 

they remain relevant 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.

Our GBM business also considers our impact 
on the integrity of markets when introducing 
new products. 

Oversight of product design and sales is 
provided by governance committees chaired 
and attended by senior executives who are 
accountable for ensuring we manage risks 
appropriately, and within appetite, to ensure 
fair customer outcomes.

In 2021, we continued to develop our product 
governance. In CMB, we deployed our new 
Google Cloud-based product inventory,  
which has improved the way we manage  
our products. Our product management and 
governance system supports our colleagues 
throughout the product lifecycle, from product 
development to demise. In GBM’s markets 
business, we continued to focus on the 
development of our ESG product suite across 
all asset classes, ensuring we maintain our 
position as an innovator of ESG products.

In WPB, we are developing our sustainable 
product suite, and remain committed to help 
mitigate against greenwashing risks. For 
further details on the Group’s sustainable 
finance and investment ambition, see page 53.

 – providing information on products and 

services that is clear, fair and not misleading;

 – enabling customers to understand the key 

features of products and services, especially 
the risks, exclusions and limitations;

 – enabling customers to make informed 
decisions before purchasing a product  
or service; and

 – checking that customers are offered 

appropriate products and, where relevant, 
received the right advice.

Supporting customers with enhanced 
care needs
Our strategy to support customers with 
enhanced care needs continues to be a core 
focus. We have guidelines and have developed 
procedures to ensure we provide the right 
outcomes for customers who may require 
enhanced care. We have made a number  
of improvements to our products, services, 
governance and oversight, as well  
as developed our colleagues’ skills  
and capabilities. 

In our CMB business in the UK, we identify 
customers with enhanced care needs  
to ensure we tailor our approach in our 
communications, services and product 
design. This is supported by post-sale calls 
with these customers to ensure we identify 
and support their needs fairly. In our UK retail 
branches, we have launched a daily quiet hour 
to help those needing access to banking in  
a calmer environment. For further details  
on inclusive product design, see ‘Financial 
inclusion’ on page 78.

Managing incentives for front-line colleagues

In WPB, we continued to apply a discretionary 
approach to incentivising our front-line 
colleagues rather than applying a formulaic link  
to sales. Following the review of incentives during 
2020, we continued to embed the changes with 
the aim to be even more customer-centric and 
focused on employee development. We also 
continued to strengthen our approach to 
third-party sales agents that distribute our 
products, such as insurance and retail, 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.

In our CMB and GBM businesses, we recognise 
and reward exceptional conduct demonstrated 
by our colleagues while discouraging misconduct 
and inappropriate behaviour that exposes us  
to financial, regulatory and reputational risks. 
During the annual pay review, we apply 
adjustments to variable pay to employees  
who exhibit either exceptional behaviours, or 
behaviours not aligned to our values. In addition, 
the businesses have specific goals to help  
drive conduct outcomes and ensure they are 
incorporated into how employees achieve their 
goals. CMB has created a scorecard reference 
guide, and GBM has specific mandatory  
conduct objectives applicable to all global  
GBM colleagues.

HSBC Holdings plc Annual Report and Accounts 2021

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Conduct: Our product responsibilities continued

Supporting customers during Covid-19 
We responded rapidly to the changing 
environment caused by the Covid-19 
pandemic. Many of our personal banking and 
wealth customers needed financial relief as a 
result of the pandemic, which we sought to 
address in a responsible way. We provided 
significant financial relief to our WPB 
customers in several markets. These solutions 
varied by market and were aligned with 
government or regulatory guidance in each 
jurisdiction. At its peak in 2021, we had 
payment relief measures offered to 1.6 million 
customers, which equated to $31bn in 
balances. We support customers that are 
in arrears or experiencing financial difficulty, 
in line with our policies and procedures.

In our CMB business, we made more than  
56 Covid-19-related enhancements to 
products in specific countries. We continue  
to review these to ensure they remain 
appropriate. We aim to support our customers 
as and when any relief products are demised. 

In Asia, given the ongoing Covid-19 
environment, our CMB business temporarily 
enabled manual payments processes in 
Bangladesh, India and Maldives to support 
relevant customers and ensure continuity of 
services and payment handling. 

Ensuring sales quality
In WPB, we consider our customers’ financial 
needs and personal circumstances to assist us 
in offering suitable product recommendations. 
This is achieved through measures such as:

 – a globally consistent risk rating methodology 

for investment products, which is 
customised for local regulatory 
requirements; and

 – a thorough customer risk profiling 

methodology to assess customers’ financial 
objectives, attitudes towards risk, financial 
ability to bear investment risk, and 
knowledge and experience.

In WPB, sales quality and mystery shopping 
reviews assess whether customers receive a 
fair outcome. If any issues are identified, we 
investigate the root cause, put things right 
and act to reduce the risk of the issue 
occurring again. 

In CMB, we operate focused sales outcome 
testing to ensure that we correctly explain 
product features and pricing. We look at 
different customer needs and circumstances, 
particularly where customers may have 
enhanced needs. In 2021, we identified issues 
relating to documentation, sales process and 
pricing. Subsequently we ensured we put 
things right for our customers and took the 
necessary internal action. 

In GBM’s markets business, we undertake 
sample-based testing on sales of products  
to customers to ensure that product features 
and pricing have been correctly explained  
and sales processes have been adhered to. 
Feedback is collated centrally and acted upon 
in a timely manner.

Transition from Ibor

As a result of the planned cessation of the 
London interbank offered rates (‘Libor’), 
Euro Overnight Index Average (‘Eonia’) 
and other benchmarks collectively 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 Ibor-based products, 
and our commercial strategy is designed 
to minimise value transfer when 
transitioning their products from  
Ibor to alternative rates.

Transition from Libor and Eonia 
benchmarks to alternative risk-free rates 
(‘RFRs’) progressed significantly over 
2021 and all industry cessation 
milestones were met. We continued to 
proactively support the transition, or 
inclusion of contractual fallback 
provisions where more appropriate, of 
customers’ legacy contracts referencing 
sterling, Japanese yen, euro and Swiss 
franc Libor to RFR products, or other 
alternatives, by the end of 2021. We 
completed this transition in line with 
regulatory expectations and met our goal 
of transitioning more than 90% of 
contracts by the end of 2021, with the 
balance continuing to be actively 
transitioned in early 2022 ahead of the 
next interest rate reset.

 For further details of the transition from 
Ibors, see ‘Ibor transition’ in the Risk 
section on page 126.

Training our colleagues to support our customers

In WPB, we provide training to our 
employees through our product 
management academy. In 2021, more  
than 750 of our colleagues completed over 
2,000 courses, relating to customer insight, 
customer-focused design, communications, 
product development, balance sheet 
management and governance. We created 
global training, with over 60,000 courses 
completed by colleagues to manage 
situations for customers with enhanced 
care needs, assigning to both customer-
facing and non-customer-facing colleagues.

In CMB, we focused on training all our 
UK-based colleagues on meeting the needs 
of customers who require enhanced care 
due to their circumstances. We delivered 
tailored training to our product managers 
to ensure that customers with enhanced 
care needs are considered across each 
stage of the product lifecycle. 

In GBM, we continued to develop and roll 
out interactive conduct training that focuses 
on behaviour. Following the successful 
completion of the training by 21,000 
colleagues early in 2021, this has now been 
adapted to cover joiners and those who 
have taken on a new management role.

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Governance 

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 cyber-attacks may result in 
financial loss, disruption for customers or 
loss of data. This could negatively affect 
our reputation and ability to attract and 
retain customers.

Prevent, detect and mitigate
We invest in business and technical controls 
to help prevent, detect and mitigate cyber 
threats. We apply a 'defence in depth’ 
approach to cyber controls, recognising 
the complexity of our environment. Our 
abilities to detect and respond to attacks 
through round-the-clock security operations 
centre capabilities help to reduce the impact 
of attacks. 

We continually evaluate threat levels for the 
most prevalent attack types and their potential 
outcomes. We have an internal cyber 
intelligence and threat analysis capability, 
which proactively collects and analyses 
external cyber information. We input into the 
broader cyber intelligence community through 
technical expertise in investigations and 
contributions to the cyber-sharing ecosystem 
in the financial services industry, alongside 
government agencies around the world.

As we continue to grow and digitise at scale, 
we may be exposed to new cyber threats.  
In 2021, we further strengthened our cyber 
defences and enhanced our cybersecurity 
capabilities to help reduce the likelihood and 
impact of advanced malware, security 
vulnerabilities being exploited, data leakage 
and unauthorised access. These defences  
are grounded in controls that help to mitigate 
cyber-attacks and build upon a proactive data 
analytical approach to help identify advanced 
targeted threats.

Policy and governance
We have a comprehensive range of 
cybersecurity policies and systems designed 
to help ensure that the organisation is well 
managed, with oversight and control.

We operate a three lines of defence model, 
aligned to the operational risk management 
framework, to help ensure 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 needed. 
These controls are executed in line with 
policies produced by our Resilience Risk 
teams, the second line of defence, which 
provide independent review and challenge. 
They are overseen by the Global Internal  
Audit function, the third line of defence.

We regularly report and review cyber risk and 
control effectiveness at relevant governance 
forums and to the Board to help ensure 
visibility and oversight. We also report across 
the global businesses, functions and regions 
to help ensure visibility and governance of 
risks and mitigating controls.

We also work with our third parties to help 
reduce the threat of cyber-attacks impacting 
our business processes. We have an 
assessment capability designed to review  
third parties’ compliance with our information 
security policies and standards. 

Cyber training and awareness
We understand the important role our people 
play in protecting against cybersecurity 
threats. Our mission is to equip every 
colleague with the tools to help prevent, 
mitigate and report cyber incidents to keep 
our organisation and customers’ data safe.

We provide cybersecurity training and 
awareness to all our people, ranging from our 
top executives to IT developers to front-line 
relationship managers around the world. 

We aim to ensure that cybersecurity is  
an integrated part of the building and 
maintenance of our technology environment. 
Over 90% of our IT developers hold at least 
one of our internal security certifications 
to help ensure we build secure systems 
and products. 

We host an annual cyber awareness campaign 
for all colleagues, covering topics such as 
social engineering, remote working security 
and data management.

Our dedicated cybersecurity training and 
awareness team provides monthly webinars 
and bespoke training to our colleagues, 
customers, regulators, governments and 
cross-sector partners.

We know it is critical that we protect our 
customers. While online banking has brought 
enormous benefits for our customers, it has 
increased the threat of cyber-attacks. We 
provide a wide range of education and 
guidance about how to stay safe online  
to both customers and our colleagues.

Over 99%

Employees completed mandatory 
cybersecurity training on time.

Over 90%

IT developers who hold at least one of our 
internal secure developer certifications.

Over 75

Cybersecurity education events held globally.

Over 95%

Survey respondents to cybersecurity 
education events who said they have  
a better understanding of cybersecurity 
following these events.

Protecting customers online

We are a founding sponsor of Get Safe 
Online, a joint initiative between the UK 
Government, police law enforcement and 
businesses. It gives free advice in plain 
English about internet safety. We are 
committed to help our customers stay  
safe and secure when banking online.  
Our online security centres provide security 
guidance from ‘How to protect devices 
from security threats’ to ‘Learn to spot 
fake websites’.

HSBC Holdings plc Annual Report and Accounts 2021

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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 aim to provide a 
consistent global approach to managing data 
privacy risk, and must be applied by all of our 
global businesses and global functions. Our 
privacy principles are available at www.hsbc.
com/who-we-are/esg-and-responsible-
business/managing-risk/operational-risk.

We conduct regular employee training and 
awareness 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 where we operate, 
through which customers and stakeholders 
can raise any concerns regarding the privacy 
of their data.

Our dedicated privacy teams report to the 
highest level of management on data privacy 
risks and issues, and oversee our global data 
privacy programmes. We review data privacy 

regularly at multiple governance forums, 
including at Board level, to help ensure there 
is appropriate challenge and visibility among 
senior executives. As part of our three lines  
of defence model, our Global Internal Audit 
function provides independent assurance  
as to whether our data privacy risk 
management approaches and processes 
are designed and operating effectively. In 
addition, we have established data privacy 
governance structures, and continue to 
embed accountability across all businesses 
and functions.

We continue to implement industry practices 
for data privacy and security. Our privacy 
teams work closely with industry bodies and 
research institutions to drive the design, 
implementation and monitoring of privacy 
solutions. We conduct regular reviews and 
privacy risk assessments, and continue to 
develop solutions to strengthen our data 
privacy controls. In 2021, we implemented 
new tooling to improve accountability for data 
privacy. We have procedures to articulate the 
actions needed to deal with data privacy 
considerations. 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.

Intellectual property rights practices
We have policies, controls and guidance to 
manage risk relating to intellectual property. 
This is to ensure that intellectual property 
is identified, maintained and protected 
appropriately, and to help ensure we do  
not infringe third-party intellectual property 
rights during the course of business and/
or operation. 

These policies and controls support our 
management of intellectual property risk, 
and operate to help ensure that intellectual 
property risk is controlled consistently and 
effectively in line with our risk appetite.

The ethical use of  
Big Data and AI

Big Data technologies and artificial 
intelligence give us the ability to process 
and analyse data at a depth and breadth 
not previously possible. While this 
technology offers significant potential 
benefits for our customers, it also poses 
potential ethical risks for the financial 
services industry and society as a whole. 
We have developed a set of principles to 
help us consider and address the ethical 
issues that could arise. HSBC’s Principles 
for the Ethical Use of Big Data and 
Artificial Intelligence are available at 
www.hsbc.com/who-we-are/esg-and-
responsible-business/our-conduct.

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, and to comply with our supplier 
ethical code of conduct. 

Ethical code of conduct 
We have an ethical and environmental code  
of conduct for suppliers of goods and services, 
which must be complied with by all suppliers. 
The code of conduct provides suppliers with 
an outline for economic, environmental and 
social standards and the requirements for 
having a reasonable governance and 
management structure.

At the end of 2021, we had approximately 
9,600 contracted suppliers. In 2021, we had 
8,144 engagements with suppliers that 

resulted in either the confirmation that they 
adhered to our code of conduct or that their 
own code of conduct had been reviewed and 
accepted by Strategic Procurement Services.

We formalise commitments to the ethical code 
with clauses in our suppliers’ contracts, which 
support the right to audit and act if a breach 
is discovered.

Managing environmental and social risk
We use an ESG reputational risk tool to 
identify environmental and social risk for 
supplier engagements with a contract value 
over $500,000. The tool provides an ESG 
reputational risk score for the supplier. In 2021, 
2,248 ESG reputational risk assessments were 
undertaken. A high-risk score drives a manual 
review to assess the extent of the risk and 
whether we are willing to accept the 
heightened risk and onboard the supplier. We 
are reviewing the reputational risk process to 
ensure we focus on sectors with high ESG risk 
going forward.

In 2021, we produced an internal toolkit to 
explain how Strategic Procurement Services 
can integrate net zero initiatives into everyday 
procurement activity. The toolkit, which 
outlines our net zero ambition and provides 
practical guidance on how Strategic 
Procurement Services can improve the way  
it drives net zero initiatives, is available to our 
teams globally to ensure a consistent approach. 

 For further details of the number of suppliers by 
geographical region, see the ESG Data Pack at 
www.hsbc.com/esg.

86

HSBC Holdings plc Annual Report and Accounts 2021

Governance 

Safeguarding the financial system

We have continued our efforts to combat 
financial crime risks and reduce their impact 
on our organisation, customers and 
communities that we serve. These financial 
crime risks include money laundering, fraud, 
bribery and corruption, tax evasion, 
sanctions breaches, terrorist financing and 
proliferation financing. 

We pay due care and attention to ethical 
questions when considering the use of 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.

We are committed to acting with integrity  
and have built a strong financial crime risk 
management framework across all global 
businesses and all countries and territories  
in which we operate. The financial crime risk 
framework, which is overseen by the Board, 
is supported by our holistic financial crime 
policies that enable adherence to applicable 
laws and regulations globally. 

Annual mandatory training is provided to all 
colleagues, with additional targeted training 
tailored to certain individuals. We carry out 
regular risk assessments, identifying where 
we need to respond to evolving financial crime 
threats, as well as conducting monitoring and 
testing of our financial crime programme, with 
applicable findings included within our policies 
and framework. 

We continue to invest in new technology such 
as contextual monitoring in our trade finance 
business, the enhancement of our fraud 
monitoring and market surveillance 
capabilities, and the application of machine 
learning to improve the accuracy and 
timeliness of our detection capabilities.  

Our anti-bribery and corruption policy
Our global anti-bribery and corruption policy 
requires that all activity must be: conducted 
without intent to bribe or corrupt; reasonable 
and transparent; considered to not be lavish 
nor disproportionate to the professional 
relationship; appropriately documented  
with business rationale; and authorised at  
an appropriate level of seniority. There were  
no concluded, nor live active, legal cases 
regarding bribery or corruption brought 
against HSBC or its employees in 2021.

Our global anti-bribery and corruption policy 
requires that we identify and mitigate the risk 
of our customers and third parties committing 
bribery or corruption. We utilise anti-money 
laundering controls, including customer  
due diligence and transaction monitoring,  
to identify and mitigate the risk that our 
customers are involved in bribery or 
corruption. We perform a bribery risk 
assessment on all third parties, and impose 
risk-based controls on the third parties that 
expose us to bribery or corruption risk.

 For further details on our financial crime risk 
management framework, see page 208.

The scale of our work

Each month, on average, we monitor 
over 1.1 billion transactions for signs of 
financial crime. During 2021, we filed 
over 56,000 suspicious activity reports 
to law enforcement and regulatory 
authorities where we identified potential 
financial crime. In addition, we screen 
approximately 116 million customer 
records monthly for sanctions exposure.

99% 

Total percentage of employees who have 
received training on the organisation’s 
anti-corruption policies and procedures. 

Whistleblowing

We want colleagues and stakeholders to have 
confidence in speaking up when they observe 
unlawful or unethical behaviour. We offer a 
range of speak-up channels to listen to their 
concerns and have a zero tolerance for acts 
of retaliation. However, we recognise that 
sometimes people may still not be 
comfortable using these routes. 

Listening through whistleblowing 
channels
Our global whistleblowing channel, HSBC 
Confidential, allows our colleagues and 
stakeholders to raise concerns confidentially 
and, if preferred, anonymously (subject to 
local laws).

In the majority of countries, HSBC Confidential 
concerns are raised through an independent 
third-party provider that offers 24/7 hotlines 
and a multiple language web portal to our 
colleagues. We also provide an external  
email address for concerns about accounting, 
internal financial controls or auditing matters 
(accountingdisclosures@hsbc.com). 

In 2021, while we continued to actively 
promote speak-up opportunities, the volume 
of HSBC Confidential concerns reduced by 
11%, driven in part, we believe, by the 
continued change to the working environment 
during the Covid-19 pandemic. Of the HSBC 
Confidential concerns closed in 2021, 87% 
related to colleagues’ behaviour and personal 
conduct concerns, 9% to security and fraud 
risks, 3% to compliance risks and less than  
1% to other issues. 

Concerns are investigated proportionately  
and independently, with action taken where 
appropriate. Actions can include disciplinary 
action, dismissal, and adjustments to variable 
pay and performance ratings.

Compliance sets whistleblowing policy and 
procedures, and provides the Group Audit 
Committee with periodic reports on the 
effectiveness of whistleblowing arrangements. 
These reports are informed by first line of 
defence control assessments, second line 
assurance reviews and third line internal and 
external audit reports. 

The Group Audit Committee has overall 
oversight of whistleblowing arrangements. 
The chair of the Group Audit Committee acts 
as HSBC’s whistleblowers’ champion with 
responsibility for ensuring and overseeing 
the integrity, independence and effectiveness 
of our whistleblowing policies and procedures. 

 Further details of the role of the Group Audit 
Committee in relation to whistleblowing can 
be found on page 244. 

Whistleblowing concerns raised  
(subject to investigation) in 2021 

2,224

(2020: 2,510)

Substantiated and partially  
substantiated whistleblowing  
cases in 2021 

42%

(2020: 42%)

HSBC Holdings plc Annual Report and Accounts 2021

87

ESG reviewESG review | Governance 

A responsible approach to tax

We seek to pay our fair share of tax in all 
jurisdictions in which we operate and to 
minimise the likelihood of customers using 
our products and services to evade or 
inappropriately avoid tax. We also abide  
by international protocols that affect our 
organisation. Our approach to tax and 
governance processes is designed to 
achieve these goals. 

Through adoption of the Group’s risk 
management framework, we have put in  
place regularly maintained controls. These  
aim to ensure, among other things, that we  
do not adopt inappropriately tax-motivated 
transactions or products and that tax planning 
is scrutinised and supported by genuine 
commercial activity. HSBC has no appetite for 
using aggressive tax structures. We continue 
to commit to making a significant investment 
globally in implementation and maintenance 
of appropriate tax risk processes and controls.

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. 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. Given 
the size and complexity of our organisation, 
which operates across over 60 jurisdictions, 
a number of areas of differing interpretation 
or disputes with tax authorities exist at any 
point in time. We cooperate with the 
relevant local tax authorities to mutually 
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 (15% or below). We 
have identified 14 such jurisdictions in which 
we had active subsidiaries during 2021. We 
continually monitor the number of active 
subsidiaries within each jurisdiction as part 
of our ongoing entity rationalisation 
programme. We ensure that our entities 
active in nil or low tax jurisdictions have 
clear business rationale for why they are 
based in these locations and appropriate 
transparency over their activities.

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. Initiatives include the US 
Foreign Account Tax Compliance Act, the 
OECD Standard for Automatic Exchange of 
Financial Account Information (‘Common 
Reporting Standard’), and the UK legislation 
on the corporate criminal offence of failing 
to prevent the facilitation of tax evasion.

 – We implement processes that aim to 

ensure that inappropriately tax-motivated 
products and services are not provided 
to our customers.

Our tax contributions
The effective tax rate for the year was 22.3%. 
Further details are provided on page 338.

As highlighted below, in addition to paying 
$6.3bn of our own tax liabilities during 2021, 
we collected taxes of $9.2bn on behalf of 
governments around the world. A more 
detailed geographical breakdown of the taxes 
paid in 2021 is provided in the ESG Data Pack. 

Taxes paid – by type of tax

Taxes paid – by region

Taxes collected – by region

Tax on profits $2,711m (2020: $3,873m)
Withholding taxes $366m (2020: $386m)
Employer taxes $1,125m (2020: $1,121m)
Bank levy $479m (2020: $1,011m)
Irrecoverable VAT $1,315m (2020: $1,389m)
Other duties and levies1 $278m (2020: $278m)

Europe $3,170m (2020: $3,022m)
Asia-Pacific $2,077m (2020: $3,911m)
Middle East and North Africa $236m 
(2020: $299m)
North America $469m (2020: $382m)
Latin America $322m (2020: $444m)

Europe $3,177m (2020: $3,462m)
Asia-Pacific $3,584m (2020: $3,595m)
Middle East and North Africa $78m 
(2020: $90m)
North America $1,081m (2020: $1,089m)
Latin America $1,343m (2020: $1,302m)

1 Other duties and levies includes property taxes of $126m (2020: $129m).

Acting with integrity

We aim to act with courageous integrity and 
learn from past events to prevent their 
recurrence. We recognise that restoration of 
trust in our industry remains a significant 
challenge as past misdeeds continue to be 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 
colleagues to ensure they can be rightly proud 
of the organisation where they work. 

We aim to make decisions based on doing the 
right thing for our customers and never 
compromising our ethical standards or integrity. 

Further information regarding the measures that 
we have taken to prevent the recurrence of past 
mistakes can be found at www.hsbc.com/
who-we-are/esg-and-responsible-business/
esg-reporting-and-policies. 

A chart reflecting fines and penalties arising 
out of significant investigations involving 
criminal, regulatory, competition or other law 
enforcement authorities, and costs relating  
to payment protection insurance remediation  
is available in the ESG Data Pack at  
www.hsbc.com/esg.

88

HSBC Holdings plc Annual Report and Accounts 2021

Financial  
review

The financial review gives detailed reporting 
of our financial performance at Group  
level as well as across our different global 
businesses and geographical regions.

90  

Financial summary

98  

 Global businesses and geographical regions

117  

 Reconciliation of alternative performance measures

Expanding opportunities beyond 
the branches

Mainland China has Asia’s largest pool of wealth and is set to 
become the world’s biggest life insurance market by 2030. 
Pinnacle is therefore critical to our ambition to be one of Asia’s 
leading wealth managers. Colleagues run specialist seminars for 
our customers, using digital tablets to facilitate visiting them in 
their homes and offices, and are further supported by an 
award-winning HSBC River bespoke financial planning mobile 
app. We have nearly 700 digitally enabled wealth planners 
across five mainland cities, and are looking to accelerate the 
trajectory of our hiring towards a target of 3,000 planners, 
supported by the recent regulatory approval to take full 
ownership of our life insurance manufacturing joint venture.

HSBC Holdings plc Annual Report and Accounts 2021

89

Financial reviewFinancial summary

Financial summary

Use of alternative performance measures 

Future accounting developments

Critical accounting estimates and judgements

Consolidated income statement 

Income statement commentary 

Consolidated balance sheet 

Page

90

90

90

91

92

95

Use of alternative performance measures

Our reported results are prepared in accordance with IFRSs 
as detailed in the financial statements starting on page 308.

To measure our performance, we supplement our IFRSs figures 
with non-IFRSs measures, which 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 117. All alternative performance measures are 
reconciled to the closest reported performance measure.

The global business segmental results are presented on an 
adjusted basis in accordance with IFRS 8 ‘Operating Segments’ as 
detailed in Note 10 ‘Segmental analysis’ on page 341.

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 98 to 101 and pages 108 to 113 detail the 
effects of significant items on each of our global business 
segments, geographical regions and selected countries/territories 
in 2021, 2020 and 2019.

Foreign currency translation differences

Foreign currency translation differences reflect the movements of 
the US dollar against most major currencies during 2021. 

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 2021 are computed by 
retranslating into US dollars for non-US dollar branches, subsidiaries, joint 
ventures and associates:
•

the income statements for 2020 and 2019 at the average rates of 
exchange for 2021; and
the balance sheets at 31 December 2020 and 31 December 2019 at the 
prevailing rates of exchange on 31 December 2021.

•

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.

90

HSBC Holdings plc Annual Report and Accounts 2021

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.

Future accounting developments

IFRS 17 ‘Insurance Contracts’

IFRS 17 ‘Insurance Contracts’ was issued in May 2017, with 
amendments to the standard issued in June 2020. It has been 
adopted for use in the EU but not yet for use in the UK. 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 impact of its implementation 
remains uncertain. We expect to provide an update on the likely 
impacts on our insurance business at or around our 2022 interim 
results announcement. For the purpose of planning the Group’s 
financial resources, our initial assumption (based on analysis of 
the expected 2022 position) is that the accounting changes may 
result in a reduction in the reported profit of our insurance 
business by approximately two thirds on the transition to IFRS 17, 
albeit with a range of expected outcomes. A similar impact is 
expected on the equity of the insurance business, primarily 
reflecting the elimination of the present value of in-force business 
('PVIF') asset and creation of the contractual service margin (the 
latter impacting tangible equity). The return on average ordinary 
shareholders' equity ('RoE') of the insurance business is not 
expected to be significantly impacted. At 31 December 2021, the 
equity associated with our insurance manufacturing operations 
was $17.0bn, including PVIF assets of $9.5bn and an associated 
deferred tax liability of $1.6bn. These assumptions may change 
significantly in the period prior to adoption of the standard.

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 323.

• Deferred tax assets: The most significant judgements relate to 
judgements made in respect of expected future profitability. 
See Note 1.2(l) on page 327.

• 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 321.

• 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 319.

• 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 319.

• 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 328.

• 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 327.

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
Change 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 

Net insurance premium income 

Other operating income/(expense)

Total operating income 

2021

$m

2020
$m

26,489   

27,578   

13,097   

11,874   

7,744   

9,582   

2019
$m

30,462   

12,023   

10,231   

2018
$m

30,489   

12,620   

9,531   

2017
$m

28,176 

12,811 

8,426 

4,053   

2,081   

3,478   

(1,488)   

2,836 

(182)   

231   

90   

(97)   

155 

798   

569   

455   

653   

812   

335   

695 

218   

10,870   

10,093   

10,636   

10,659   

502   

527   

2,957   

960   

N/A

1,150 

9,779 

443 

63,940   

63,074   

71,024   

63,587   

63,776 

Net insurance claims and benefits paid and movement in liabilities to policyholders 

(14,388)   

(12,645)   

(14,926)   

(9,807)   

(12,331) 

Net operating income before change in expected credit losses and other 
credit impairment charges/Loan impairment charges and other credit risk provisions2

Change in expected credit losses and other credit impairment charges

Loan impairment charges and other credit risk provisions

Net operating income 

49,552   

50,429   

56,098   

53,780   

51,445 

928   

(8,817)   

(2,756)   

(1,767) 

N/A

N/A

N/A

N/A

N/A  

(1,769) 

50,480   

41,612   

53,342   

52,013   

49,676 

Total operating expenses excluding impairment of goodwill and other intangible assets

(33,887)   

(33,044)   

(34,955)   

(34,622)   

(34,849) 

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 (paid in the period)3

Dividend payout ratio4
Post-tax return on average total assets

Return on average ordinary shareholders’ equity

Return on average tangible equity

Effective tax rate

(733)   

(1,388)   

(7,394)   

(37)   

(35) 

15,860   

3,046   

18,906   

(4,213)   

14,693   

7,180   

1,597   

8,777   

(2,678)   

6,099   

10,993   

17,354   

14,792 

2,354   

2,536   

2,375 

13,347   

19,890   

17,167 

(4,639)   

(4,865)   

(5,288) 

8,708   

15,025   

11,879 

12,607   

3,898   

5,969   

12,608   

9,683 

7   

90   

1,303   

1,241   

776   

870   

14,693   

6,099   

90   

1,324   

1,325   

8,708   

90   

1,029   

1,298   

90 

1,025 

1,081 

15,025   

11,879 

2021

$

0.62   

0.62   

0.22   

%
 40.3 

0.5   

 7.1 

 8.3 

2020

$

0.19   

0.19   

—   

%
 78.9 

0.2   

 2.3 

 3.1 

2019

$

0.30   

0.30   

0.51   

%
 100.0 

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 

 22.3   

30.5   

34.8   

24.5   

30.8 

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 

3 

provisions, also referred to as revenue. 
Includes an interim dividend of $0.07 per ordinary share in respect of the financial year ending 31 December 2021, paid in September 2021, and 
an interim dividend of $0.15 per ordinary share in respect of the financial year ending 31 December 2020, paid in April 2021.

4  Dividend per ordinary share, in respect of the period, expressed as a percentage of basic earning per share.

Unless stated otherwise, all tables in the Annual Report and Accounts 2021 are presented on a reported basis.

For a summary of our financial performance in 2021, see page 27.
For further financial performance data for each global business and geographical region, see pages 98 to 101 and 106 to 116 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 341.

HSBC Holdings plc Annual Report and Accounts 2021

91

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial summary

Income statement commentary

The following commentary compares Group financial performance for the year ended 2021 with 2020.

Net interest income

Interest income

Interest expense 

Net interest income

Year ended

Quarter ended

31 Dec

2021

$m

36,188   

(9,699)   

26,489   

31 Dec

2020

$m

41,756   

(14,178)   

27,578   

31 Dec

2019

$m

54,695   

(24,233)   

30,462   

31 Dec

2021

$m

9,219   

(2,438)   

6,781   

30 Sep

2021

$m

9,010   

(2,400)   

6,610   

31 Dec

2020

$m

9,301 

(2,682) 

6,619 

Average interest-earning assets 

2,209,513   

2,092,900   

1,922,822   

2,251,433   

2,207,960   

2,159,003 

Gross interest yield1
Less: gross interest payable1
Net interest spread2
Net interest margin3

%

 1.64 

 (0.53) 

 1.11 

 1.20 

%

 2.00 

 (0.81) 

 1.19 

 1.32 

%

 2.84 

 (1.48) 

 1.36 

 1.58 

%

 1.62 

 (0.52) 

 1.10 

 1.19 

%

 1.62 

 (0.53) 

 1.09 

 1.19 

%

 1.71 

 (0.60) 

 1.11 

 1.22 

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

2021

2020

2019

Average
balance

Interest
income

$m

$m

Yield

%

Average
balance

Interest
income

$m

$m

Yield

%

Average
balance

Interest
income

$m

$m

Short-term funds and loans and advances 
to banks

450,678    1,105 

 0.25   

298,255   

1,264 

 0.42   

212,920   

2,411 

Loans and advances to customers

  1,060,658    26,071 

 2.46   

1,046,795    29,391 

 2.81   

1,021,554    35,578 

Reverse repurchase agreements – non-trading

206,246    1,019 

 0.49   

221,901   

438,840    6,729 

 1.53   

463,542   

53,091    1,264 

 2.38   

62,407   

1,819 

8,143 

1,139 

 0.82   

 1.76   

 1.83   

224,942   

4,690 

417,939    10,705 

45,467   

1,311 

  2,209,513    36,188 

 1.64   

2,092,900    41,756 

 2.00   

1,922,822    54,695 

Financial investments 

Other interest-earning assets 

Total interest-earning assets 

Summary of interest expense by type of liability

Deposits by banks1
Customer accounts2
Repurchase agreements – non-trading

Debt securities in issue – non-trading

Other interest-bearing liabilities

Total interest-bearing liabilities

1 
2 

Including interest-bearing bank deposits only. 
Including interest-bearing customer accounts only.

2021

Average
balance

Interest
expense

$m

$m

Cost

%

2020

Average
balance

Interest
expense

$m

$m

330 

Cost

%

2019

Average
balance

Interest
expense

$m

$m

702 

75,671   

198 

 0.26   

65,536   

 0.50   

52,515   

  1,362,580    4,099 

 0.30   

1,254,249   

6,478 

 0.52   

1,149,483    11,238 

114,201   

363 

 0.32   

125,376   

193,137    3,603 

 1.87   

219,610   

70,929    1,436 

 2.02   

76,395   

963 

4,944 

1,463 

 0.77   

 2.25   

 1.92   

160,850   

211,229   

59,980   

4,023 

6,522 

1,748 

  1,816,518    9,699 

 0.53   

1,741,166    14,178 

 0.81   

1,634,057    24,233 

Yield

%

 1.13 

 3.48 

 2.08 

 2.56 

 2.88 

 2.84 

Cost

%

 1.34 

 0.98 

 2.50 

 3.09 

 2.91 

 1.48 

Net interest income (‘NII’) for 2021 was $26.5bn, a decrease of 
$1.1bn or 4% compared with 2020. This reflected lower average 
market interest rates across the major currencies compared with 
2020. This was partly offset by interest income associated with the 
increase in average interest-earning assets (‘AIEA’) of $116.6bn or 
5.6%.

Net interest margin (‘NIM’) for 2021 of 1.20% was 12 basis 
points (‘bps’) lower compared with 2020 as the reduction in the 
yield on AIEA of 36bps was partly offset by the fall in funding 
costs of average interest-bearing liabilities of 28bps. The decrease 
in NIM in 2021 included the adverse effects of foreign currency 
translation differences. Excluding this, NIM fell by 11bps.

Excluding the favourable effects of foreign currency translation 
differences, net interest income decreased by $1.8bn or 6.2%.

NII for the fourth quarter was $6.8bn, up 2.4% compared with the 
previous year. The increase was driven by a change in funding 
composition leading to a reduction of debt securities and an 
increase in lower-yielding customer deposits. This was partly 
offset by lower interest income  on AIEA, primarily driven by a 
shift of balances from financial investments to lower yielding 
short-term funds, and reduced yields on customer loans. 
Compared with the previous quarter, NII was up 2.5%. The 
increase was mainly driven by higher interest rates on other 
interest-earning assets as well as growth in AIEA.

NIM for the fourth quarter of 2021 was 1.19%, down 3bps year-
on-year, predominantly driven by a change in balance sheet 
composition towards lower yielding short-term funds and loans 
and advances to banks. NIM remained unchanged compared with 
the previous quarter. 

Interest income for 2021 of $36.2bn decreased by $5.6bn or 
13%, primarily due to the lower average interest rates compared 
with 2020 as the yield on AIEA fell by 36bps. This was partly offset 
by income from balance sheet growth, predominantly in Asia and 
the UK. In particular, balances of short-term funds and loans and 
advances to banks grew by $152.4bn, and loans and advances to 
customers grew by $13.9bn. The decrease in interest income 
included $0.9bn from the favourable effects of foreign currency 

92

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
translation differences. Excluding these, interest income decreased 
by $6.5bn.

shareholders respectively participate in the investment 
performance of the associated assets.

Interest income of $9.2bn in the fourth quarter was down $0.1bn 
year-on-year. The decline was predominantly driven by a change 
in the balance sheet composition where high-yielding financial 
investments decreased by $33.8bn, while low-yielding short-term 
funds and loans and advances to banks increased by $138.8bn. 
Compared with the previous quarter interest income was up 
$0.2bn, mainly due to improved yield on other interest-earning 
assets, as well as growth in AIEA.

Interest expense for 2021 of $9.7bn represented a decrease by 
$4.5bn or 32% compared with 2020. This reflected a decrease in 
funding costs of 28bps, mainly arising from lower interest rates 
paid on interest-bearing customer accounts, debt securities in 
issue and repurchase agreements. Funding costs further declined 
due to a change in funding composition from debt securities to 
low-yielding customer deposits, which grew by $108bn, 
predominantly in Asia and Europe. The decrease in interest 
expense included the adverse effects of foreign currency 
translation differences of $0.3bn. Excluding this, interest expense 
decreased by $4.8bn.

Interest expense of $2.4bn in the fourth quarter of 2021 was down 
$0.2bn year-on-year. The decline was predominantly driven by an 
improved funding mix, with additional funding from lower costing 
customer accounts, coupled with the impact of lower market 
interest rates. Compared with the previous quarter, the interest 
expense was materially unchanged.

Net fee income of $13.1bn was $1.2bn higher than in 2020, and 
included a favourable impact from foreign currency translation 
differences of $0.3bn. Net fee income grew in all of our global 
businesses.

In WPB, net fee income increased by $0.5bn. Fee income grew, 
mainly in Wealth, as improved market sentiment resulted in 
increased customer demand. This increase included higher fee 
income from funds under management, notably in Hong Kong, the 
UK and France, and from unit trusts in Asia. Cards income grew as 
spending increased compared with 2020. This also resulted in 
higher fee expense.

In CMB, net fee income increased by $0.4bn. Fee income 
increased from credit facilities, as well as from trade products, as 
global trade volumes recovered during 2021. Income from account 
services and remittances also rose as customer activity increased.

In GBM, net fee income increased by $0.3bn. This was driven by 
higher fee income from growth in corporate finance activity and in 
account services, which included higher activity from transaction 
banking clients. Fee income also increased in remittances, credit 
facilities, funds under management and global custody, reflecting 
a higher level of client activity compared with 2020.

Net income from financial instruments held for trading or 
managed on a fair value basis of $7.7bn was $1.8bn lower 
compared with 2020 and included adverse fair value movements 
on non-qualifying hedges of $0.4bn. 

The remaining reduction was mainly in GBM, as 2020 benefited 
from higher market volatility supporting a particularly strong 
performance within Global Foreign Exchange and Global Debt 
Markets, notably in the UK and the US.

Net income from assets and liabilities of insurance 
businesses, including related derivatives, measured at fair 
value through profit or loss of $4.1bn, compared with $2.1bn in 
2020. This increase primarily reflected favourable equity market 
performances in France and Hong Kong and higher gains on unit 
trust assets, supporting insurance and investment contracts. This 
compared with 2020, which was adversely impacted by the onset 
of the Covid-19 pandemic. 

This favourable 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 

Change in fair value of designated debt and related 
derivatives was $0.4bn adverse compared with 2020. These 
movements were driven by the widening of long-term interest rate 
curves between the periods, driven by the gradual recovery of 
major economies.

All 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 96.

Changes in fair value of other financial instruments 
mandatorily measured at fair value through profit or loss of 
$0.8bn was $0.3bn higher compared with 2020. This primarily 
reflected the impact of adverse movements in equity markets in 
the first half of 2020 following the onset of the Covid-19 
pandemic, as well as from favourable equity market movements 
during 2021.

Gains less losses from financial investments of $0.6bn were 
$0.1bn lower compared with 2020, primarily reflecting lower gains 
on the disposal of debt securities.

Net insurance premium income of $10.9bn was $0.8bn higher 
than in 2020, primarily reflecting higher sales volumes, particularly 
in France, the UK and Singapore.

Other operating income of $0.5bn was broadly unchanged 
compared with 2020, as a $0.3bn decrease in net favourable 
movements in PVIF was broadly offset by the gain on the sale of a 
property in Germany and the non-recurrence of revaluation losses 
on investment properties in Hong Kong in 2020.

The change in PVIF included a net reduction of $0.7bn from 
assumption changes and experience variances, primarily reflecting 
increased interest rates and the effect of sharing higher 
investment returns with policyholders in Hong Kong and 
Singapore. These were partly offset by France where higher 
interest rates reduced the cost of guarantees. The net reduction 
due to assumption changes was partly offset by a $0.3bn increase 
in the value of new business written, primarily in Hong Kong.

PVIF is presented in accordance with IFRS 4 ‘Insurance Contracts’. 
As set out in our Annual Report and Accounts 2020, IFRS 17 
‘Insurance Contracts’ is effective from 1 January 2023. Under 
IFRS 17, there will be no PVIF asset recognised. Instead, the 
estimated future profit will be included in the measurement of the 
insurance contract liability as the contractual service margin and 
gradually recognised in revenue as services are provided over the 
duration of the insurance contract. 

Net insurance claims and benefits paid and movement in 
liabilities to policyholders was $1.7bn higher, primarily due to 
higher returns on financial assets supporting contracts where the 
policyholder is subject to part or all of the investment risk and 
higher sales volumes, particularly in France and the UK.

Changes in expected credit losses and other credit 
impairment charges (‘ECL’) were a net release of $0.9bn, 
compared with a charge of $8.8bn in 2020. The net release in 
2021 reflected an improvement in the economic outlook, notably 
in the UK, partly offset by an increase in allowances in the fourth 
quarter, reflecting recent developments in China’s commercial real 
estate sector. This compared with the significant build-up of stage 
1 and stage 2 allowances in 2020 due to the worsening economic 
outlook at the onset of the Covid-19 pandemic. The reduction in 
ECL also reflected historically low levels of stage 3 charges, 
although with some normalisation during the fourth quarter, as 
well as the non-recurrence of a significant charge in 2020 related 
to a corporate exposure in Singapore.

For further details on the calculation of ECL, including the 
measurement uncertainties and significant judgements applied to 
such calculations, the impact of the economic scenarios and 
management judgemental adjustments, see pages 144 to 152.

HSBC Holdings plc Annual Report and Accounts 2021

93

Financial review 
Financial summary

Operating expenses – currency translation and significant items

Significant items

–  customer redress programmes

–  impairment of goodwill and other intangibles

–  past service costs of guaranteed minimum pension benefits equalisation
–  restructuring and other related costs1
–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items

Currency translation

Year ended 31 Dec

Year ended

2021

$m

2,472   

49   

587   

—   

1,836   

—   

2,472   

2020

$m

3,095 

(54) 

1,090 

17 

1,908 

12 

122 

(1,072) 

2,023 

1   The year ended 2020 included impairment of software intangible assets of $189m (of the total software intangible asset impairment of $1,347m) 

and impairment of tangible assets of $197m.

Operating expenses

Gross employee compensation and benefits

Capitalised wages and salaries 

Goodwill impairment

Property and equipment

Amortisation and impairment of intangibles

UK bank levy

Legal proceedings and regulatory matters
Other operating expenses1
Total operating expenses (reported)

Total significant items (including currency translation on significant items)

Currency translation

Total operating expenses (adjusted)

Year ended

2021

$m

19,612 

(870)   

587 

5,145 

1,438 

116 

106 

8,486 

34,620 

(2,472)   

32,148 

2020

$m

19,396

(1,320) 

41

5,322

2,519

802

289

7,383

34,432

(3,095) 

1,072 

32,409

1      Other  operating  expenses  includes  professional  fees,  contractor  costs,  transaction  taxes,  marketing  and  travel.  The  increase  was  driven  by  the 

spend related to our cost reduction programme, as well as from the growth in investment in technology and regulatory programmes. 

Staff numbers (full-time equivalents)

Global businesses

Wealth and Personal Banking

Commercial Banking

Global Banking and Markets

Corporate Centre

At 31 Dec

Operating expenses of $34.6bn were broadly unchanged 
compared with 2020. This included the impact of our cost saving 
initiatives, as well as lower impairments of goodwill and other 
intangible assets, as 2021 included a $0.6bn impairment of 
goodwill related to our WPB business in Latin America to reflect 
the macroeconomic outlook, as well as the impact of foreign 
exchange rate deterioration and inflationary pressures, notably on 
our Argentina business. However, 2020 included a $1.3bn 
impairment of intangible assets, mainly in Europe. There was also 
a $0.6bn reduction in the UK bank levy due to a change in the 
basis of calculation to only include the UK balance sheet rather 
than the global balance sheet, as well as a credit of $0.1bn relating 
to the 2020 charge.

These decreases were broadly offset by an increase in 
performance-related pay of $0.7bn as Group performance 
improved, and by an increase in investment in technology of 
$0.9bn (gross of cost savings of $0.5bn). The remaining increase 
primarily reflected inflationary impacts, non-technology 
investment in regulatory programmes, and business growth 
notably Asia wealth investment. In addition, there was an adverse 
impact of foreign currency translation differences of $1.1bn. 

In February 2020, we announced a plan to substantially reduce the 
cost base by 2022 and accelerate the pace of change. We 
continue to target $5bn to $5.5bn of cost saves for 2020 to 2022, 
while spending around $7bn in costs to achieve, which are 
included in restructuring and other related costs. Cumulative costs 
to achieve spend since the start of the programme in 2020 was 

94

HSBC Holdings plc Annual Report and Accounts 2021

2021

2020

2019

130,185   

135,727   

141,341 

42,969   

46,166   

377   

43,221   

46,729   

382   

44,706 

48,859 

445 

219,697   

226,059   

235,351 

$3.6bn, with related saves of $3.3bn. In 2021, the total cost to 
achieve spend was $1.8bn with saves during the year of $2.2bn.

Share of profit in associates and joint ventures of $3.0bn 
was $1.4bn higher, primarily reflecting a higher share of profit 
from The Saudi British Bank (‘SABB’) due to the non-recurrence of 
our share of its goodwill impairment charge in 2020, and an 
increased share of profit from BoCom. Our share of profit also rose 
from Business Growth Fund in the UK due to a recovery in asset 
valuations relative to 2020.

At 31 December 2021, 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. The excess of the 
VIU of BoCom and its carrying value has increased over the 
period, reflecting the impact of BoCom’s performance on the VIU.

For more information, see Note 19: Interests in associates and 
joint ventures on page 359. 

Tax expense

The effective tax rate for 2021 of 22.3% was lower than the 30.5% 
for 2020. The effective tax rate for 2021 was increased by the 
impact of substantively enacted legislation to increase the UK 
statutory tax rate from 1 April 2023. The 2020 effective tax rate 
was high, due mainly to the non-recognition of deferred tax on 
losses in the UK and France.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 customers1
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.

2021

$m

2020

$m

2019

$m

2018

$m

2017

$m

403,018   

248,842   

304,481   

231,990   

154,099   

254,271   

162,843   

238,130   

180,624 

287,995 

49,804   

45,553   

43,627   

41,111 

N/A   

N/A

N/A

N/A  

196,882   

307,726   

242,995   

207,825   

83,136   

81,616   

69,203   

1,045,814   

1,037,987   

1,036,743   

241,648   

446,274   

242,521   

230,628   

490,693   

253,490   

240,862   

443,312   

230,040   

72,167   

981,696   

242,804   

407,433   

204,115   

N/A

29,464 

219,818 

90,393 

962,964 

201,553 

389,076 

159,884 

2,957,939   

2,984,164   

2,715,152   

2,558,124   

2,521,771 

101,152   

82,080   

59,022   

56,331   

69,922 

1,710,574   

1,642,780   

1,439,115   

1,362,643   

1,364,462 

126,670   

111,901   

140,344   

165,884   

84,904   

145,502   

191,064   

78,557   

112,745   

199,994   

75,266   

157,439   

303,001   

95,492   

107,191   

204,019   

83,170   

164,466   

239,497   

104,555   

97,439   

84,431   

148,505   

205,835   

85,342   

87,330   

194,876   

167,574   

113,690 

2,751,162   

2,779,169   

2,522,484   

2,363,875   

2,323,900 

198,250   

196,443   

183,955   

186,253   

190,250 

8,527   

8,552   

8,713   

7,996   

7,621 

206,777   

204,995   

192,668   

194,249   

197,871 

2,957,939   

2,984,164   

2,715,152   

2,558,124   

2,521,771 

130,002 

184,361 

94,429 

216,821 

64,546 

85,667 

A more detailed consolidated balance sheet is contained in the financial statements on page 310.

Five-year selected financial information

Called up share capital 
Capital resources1
Undated subordinated loan capital 
Preferred securities and dated subordinated loan capital2
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 ($)3
Tangible net asset value per ordinary share at year-end ($)4
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: € 

2021

$m

2020

$m

2019

$m

2018

$m

10,316   

10,347   

10,319   

10,180   

177,786   

184,423   

172,150   

173,238   

1,968   

28,568   

838,263   

198,250   

(22,414)   

175,836   

(17,643)   

158,193   

61.1%

6.62%

8.76   

7.88   

7.84   

20,632   

20,073   

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   

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   

2017

$m

10,160 

182,383 

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 

20,189   

20,272   

20,280   

20,059   

20,065 

0.739   

0.880   

0.732   

0.816   

0.756   

0.890   

0.783   

0.873   

0.740 

0.834 

1   Capital resources are regulatory total capital, the calculation of which is set out on page 193.
2   Including perpetual preferred securities, details of which can be found in Note 28: Subordinated liabilities on page 370.
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. 
4   The definition of tangible net asset value per ordinary share is total ordinary shareholder’s equity excluding goodwill, PVIF and other intangible 

assets (net of deferred tax), divided by the number of basic ordinary shares in issue, excluding own shares held by the company, including those 
purchased and held in treasury. 

HSBC Holdings plc Annual Report and Accounts 2021

95

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial summary

Balance sheet commentary compared with 
31 December 2020

At 31 December 2021, our total assets were $3.0tn, which were 
$26bn or 1% lower on a reported basis and $19bn or 1% higher on 
a constant currency basis.

The decrease in total assets reflected lower derivative assets and a 
fall in financial investments, in part reflecting a redeployment of 
our commercial surplus into cash. Reported customer lending 
balances were $8bn higher, mainly from growth in mortgage 
balances.

Reported loans and advances to customers as a percentage of 
customer accounts was 61.1%, which was lower compared with 
63.2% at 31 December 2020. This was due to an increase in 
customer accounts as corporate customers continued to build up 
liquidity and personal customers grew their savings accounts.

Assets

Cash and balances at central banks increased by $99bn or 
32%, mainly in the UK and the US, as we redeployed our 
commercial surplus to cash to increase liquidity for our clients and 
as a result of deposit inflows.

Trading assets increased by $17bn or 7%, notably from an 
increase in equity securities held, particularly in Hong Kong and 
the US, largely driven by client demand. These were partly offset 
by a reduction of debt securities in the US. 

Derivative assets decreased by $111bn or 36%, primarily in the 
UK and France. This reflected adverse revaluation movements on 
interest rate contracts due to higher long-term yield curve rates in 
most major markets. Foreign exchange contracts also decreased 
as a result of foreign exchange rate movements in the UK and 
Hong Kong and lower client demand in the US. The decrease in 
derivative assets was consistent with the decrease in derivative 
liabilities, as the underlying risk is broadly matched.

Loans and advances to customers of $1.0tn increased by $8bn 
on a reported basis, which included adverse effects of foreign 
currency translation differences of $16bn. On a constant currency 
basis, customer lending balances were $23bn higher, despite $3bn 
of loans and advances to customers being reclassified to assets 
held for sale in the US.

The commentary below is on a constant currency basis.

Customer lending increased in WPB by $27bn to $489bn, mainly 
from growth in mortgage balances of $23bn, notably in the UK (up 
$10bn), Hong Kong (up $7bn) and Canada (up $4bn) as housing 
market activity continued to increase.

In CMB, customer lending of $349bn was $11bn higher, as we 
grew trade lending by $13bn, reflecting a recovery in global trade 
volumes, which more than offset a reduction in other term 
lending.

In GBM, lending of $207bn fell by $14bn, due to a reduction in 
other term lending mainly in the UK.

Reverse repurchase agreements – non-trading increased by 
$11bn or 5%, primarily in Asia due to client demand. This was 
partly offset by the redeployment of our commercial surplus to 
cash in the US.

There was also an increase in balances eligible for netting in the 
UK, resulting in an overall balance reduction.

Financial investments decreased by $44bn or 9%, mainly as we 
reduced our holdings of debt securities and treasury bills through 
a combination of disposals and maturities. A notable portion of 
these funds was redeployed into cash as we managed our 
commercial surplus.

96

HSBC Holdings plc Annual Report and Accounts 2021

Other assets decreased by $11bn due to lower cash collateral as 
derivative balances decreased, partly offset by an increase from 
the reclassification of loans and advances to customers to assets 
held for sale, reflecting our exit of mass market retail banking in 
the US. 

Liabilities

Customer accounts of $1.7tn increased by $68bn or 4% on a 
reported basis, which included adverse effects of foreign currency 
translation differences of $23bn. On a constant currency basis, 
customer accounts were $90bn higher, with growth across all of 
our global businesses, despite a reclassification of $10bn to 
liabilities of disposal groups held for sale in the US. The increase 
was primarily in the UK, Hong Kong and the rest of Asia, as 
corporate customers continued to build up liquidity and personal 
customers grew their savings as spending remained below pre-
pandemic levels.

Deposits by banks increased by $19bn or 23%, primarily in the 
UK, relating to the utilisation of a Bank of England scheme to 
provide loans to corporate customers during the year. There were 
also increases in Hong Kong and the US.

Repurchase agreements – non-trading increased by $15bn or 
13%, primarily in Hong Kong, as client demand increased.

Derivative liabilities decreased by $112bn or 37%, which is 
consistent with the decrease in derivative assets, since the 
underlying risk is broadly matched.

Other liabilities decreased by $4bn or 2% due to lower cash 
collateral as derivative balances decreased, partly offset by an 
increase from a reclassification of customer accounts to liabilities 
held for sale, reflecting our exit of mass market retail banking in 
the US.

Equity

Total shareholders’ equity, including non-controlling interests, 
increased by $2bn or 1% compared with 31 December 2020. This 
reflected the effects of profits generated of $15bn, partly offset by 
a reduction in other comprehensive income (‘OCI’) of $5bn, 
dividend payments and coupon distributions on securities 
classified as equity of $6bn and a $2bn reduction related to our 
share buy-back programme. Movements in OCI included fair value 
losses on debt instruments of $2bn, driven by unrealised losses on 
fixed rate bonds due to higher long-term yield curve rates, and 
adverse foreign exchange differences of $2bn.

Risk-weighted assets

Risk-weighted assets (‘RWAs’) totalled $838.3bn at 31 December 
2021, a $19.2bn decrease since 2020. Excluding foreign currency 
translation differences, RWAs fell by $6.3bn in 2021. This was due 
to the following movements:

• a $4.7bn asset size increase, mostly caused by CMB and WPB 

lending growth in Asia, while lending fell in GBM;

• a $8.0bn reduction in RWAs due to changes in asset quality 
from favourable portfolio mix and credit migration, mostly in 
CMB and WPB in Asia and North America; and

• a $3.0bn fall in RWAs due to changes in methodology and 

policy. This was primarily the result of risk parameter 
refinements in GBM and CMB, partly offset by higher market 
risk RWAs following our adoption of a Pillar 1 approach to the 
capitalisation of structural foreign exchange.

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
–  US1
–  Canada

–  other

Latin America

–  Mexico

–  other

At 31 Dec

2021

$m

667,769   

535,797   

56,841   

22,509   

10,680   

41,942   

792,098   

549,429   

57,572   

59,266   

28,240   

24,507   

16,500   

15,483   

6,019   

35,082   

42,629   

20,943   

4,258   

6,699   

10,729   

178,565   

111,921   

58,071   

8,573   

29,513   

23,583   

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 

5,930   
1,710,574   

5,258 
1,642,780 

1   At 31 December 2021, customer accounts of $8.8bn relating to the disposal of the US retail banking business met the criteria to be classified as 
held for sale and are reported within ‘Accruals, deferred income and other liabilities’ on the balance sheet. Refer to Note 36 on page 387 for 
further details.

Loans and advances, deposits by currency

$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 2021

USD

GBP

21,474   

3,991   

HKD

524   

169,055   

280,909   

223,714   

190,529   

284,900   

224,238   

37,962   

20,909   

2,757   

EUR

3,970   

83,457   

87,427   

24,393   

CNY

Others1

Total

6,545   

46,632   

83,136 

44,093   

244,586   

1,045,814 

50,638   

291,218   

1,128,950 

5,049   

10,082   

101,152 

453,864   

463,232   

318,702   

133,604   

65,052   

276,120   

1,710,574 

491,826   

484,141   

321,459   

157,997   

70,101   

286,202   

1,811,726 

At

31 Dec 2020

USD

GBP

HKD

17,959   

173,117   

191,076   

30,239   

433,647   

463,886   

3,495   

280,803   

284,298   

7,856   

431,143   

438,999   

7,155   

222,138   

229,293   

2,884   

310,197   

313,081   

EUR

4,601   

89,851   

94,452   

25,291   

135,851   

161,142   

CNY

6,063   

37,671   

43,734   

4,904   

60,971   

65,875   

Others

42,343   

Total

81,616 

234,407   

1,037,987 

276,750   

1,119,603 

10,906   

82,080 

270,971   

1,642,780 

281,877   

1,724,860 

1   ‘Others’ includes items with no currency information available ($11,028m for loans to banks, $64,491m for loans to customers, $23m for deposits 

by banks and $5m for customer accounts).

HSBC Holdings plc Annual Report and Accounts 2021

97

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses

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

98

98

101

101

106

108

114

The Group Chief Executive, supported by the rest of the Group 
Executive Committee (‘GEC'), reviews operating activity on a 
number of bases, including by global business and geographical 
region. Our global businesses – Wealth and Personal Banking, 

Commerical Banking, and Global Banking and Markets – along 
with Corporate Centre are our reportable segments under IFRS 8 
‘Operating Segments’ and are presented below and in Note 10: 
Segmental analysis on page 341. 

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. From 2021, the UK bank levy was 
partially allocated to global businesses, which was previously 
retained in Corporate Centre. Comparative periods have not been 
re-presented.

The results of geographical regions are presented on a reported 
basis on page 106 and an adjusted basis on page 108.

Reconciliation of reported and adjusted items – global businesses

Supplementary unaudited analysis of significant items by global business is presented below.

Revenue1
Reported 

Significant items

–  customer redress programmes
–  fair value movements on financial instruments2
–  restructuring and other related costs3
Adjusted 

ECL

Reported 

Adjusted

Operating expenses

Reported 

Significant items

–  customer redress programmes

–  impairment of goodwill and other intangibles

–  restructuring and other related costs

Adjusted 

Share of profit in associates and joint ventures

Reported 

Adjusted

Profit before tax

Reported

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)

Reported

Adjusted 

Customer accounts

Reported

Adjusted 

Wealth and 
Personal Banking

Commercial
Banking

2021

Global
Banking and
Markets

Corporate 
Centre

$m

$m

$m

$m

22,117   

13,431   

14,588   

(7)   

7   

—   

(14)   

(16)   

(18)   

(1)   

3   

414   

—   

19   

395   

22,110   

13,415   

15,002   

288   

288   

300   

300   

337   

337   

(16,306)   

(7,055)   

(10,203)   

922   

39   

587   

296   

82   

1   

—   

81   

197   

—   

—   

197   

(15,384)   

(6,973)   

(10,006)   

(584)   

147   

—   

224   

(77)   

(437)   

3   

3   

(1,056)   

1,271   

9   

—   

1,262   

215   

34   

34   

1   

1   

—   

—   

3,011   

3,011   

6,133   

6,677   

4,722   

915   

(7)   

922   

66   

(16)   

82   

611   

414   

197   

7,048   

6,743   

5,333   

1,374   

1,418   

147   

1,271   

2,792   

Total

$m

49,552 

538 

(11) 

242 

307 

50,090 

928 

928 

(34,620) 

2,472 

49 

587 

1,836 

(32,148) 

3,046 

3,046 

18,906 

3,010 

538 

2,472 

21,916 

488,786   

349,126   

488,786   

349,126   

207,162   

207,162   

740   

740   

1,045,814 

1,045,814 

859,029   

506,688   

859,029   

506,688   

344,205   

344,205   

652   

652   

1,710,574 

1,710,574 

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. 

98

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Wealth and 
Personal Banking

Commercial
Banking

2020

Global
Banking and
Markets

Revenue1
Reported 

Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses
–  fair value movements on financial instruments2
–  restructuring and other related costs3
–  currency translation on significant items

Adjusted 

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

Significant items

–  customer redress programmes

–  impairment of goodwill and other intangibles

–  past service costs of guaranteed minimum pension benefits 

equalisation

–  restructuring and other related costs4
–  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

Significant items
–  impairment of goodwill5
–  currency translation on significant items

Adjusted

Profit/(loss) before tax

Reported

Currency translation

Significant items

–  revenue 

–  operating expenses

–  share of profit in associates and joint ventures

Adjusted 

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

$m

$m

$m

21,999   

560   

12   

5   

9   

—   

—   

(2)   

13,294   

405   

19   

16   

—   

1   

1   

1   

14,994   

456   

318   

—   

—   

2   

307   

9   

22,571   

13,718   

15,768   

(2,855)   

(150)   

(3,005)   

(4,754)   

(235)   

(4,989)   

(1,209)   

(80)   

(1,289)   

(15,446)   

(6,900)   

(10,169)   

(432)   

435   

(64)   

294   

—   

192   

—   

13   

(214)   

217   

1   

45   

—   

165   

—   

6   

(451)   

980   

—   

577   

—   

326   

2   

75   

(15,443)   

(6,897)   

(9,640)   

6   

1   

—   

—   

—   

7   

(1)   

—   

—   

—   

—   

(1)   

3,704   

1,639   

(21)   

447   

12   

435   

—   

(44)   

236   

19   

217   

—   

—   

—   

—   

—   

—   

—   

3,616   

(75)   

1,298   

318   

980   

—   

4,130   

1,831   

4,839   

469,186   

(6,900)   

462,286   

834,759   

(10,768)   

823,991   

343,182   

(4,989)   

338,193   

470,428   

(6,048)   

464,380   

224,364   

(3,672)   

220,692   

336,983   

(5,819)   

331,164   

Corporate 
Centre

$m

142   

(28)   

(401)   

—   

1   

(267)   

(138)   

3   

(287)   

1   

—   

1   

(1,917)   

25   

1,463   

9   

174   

17   

1,225   

10   

28   

(429)   

Total

$m

50,429 

1,393 

(52) 

21 

10 

(264) 

170 

11 

51,770 

(8,817) 

(465) 

(9,282) 

(34,432) 

(1,072) 

3,095 

(54) 

1,090 

17 

1,908 

12 

122 

(32,409) 

1,592   

1,597 

132   

462   

462   

—   

133 

462 

462 

— 

2,186   

2,192 

(182)   

129   

1,524   

(401)   

1,463   

462   

1,471   

1,255   

(24)   

1,231   

610   

(17)   

593   

8,777 

(11) 

3,505 

(52) 

3,095 

462 

12,271 

1,037,987 

(15,585) 

1,022,402 

1,642,780 

(22,652) 

1,620,128 

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.
In 2020, 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.

5 

HSBC Holdings plc Annual Report and Accounts 2021

99

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses

Reconciliation of reported and adjusted items (continued)

Revenue1
Reported 

Currency translation

Significant items

–  customer redress programmes
–  disposals, acquisitions and investment in new businesses2
–  fair value movements on financial instruments3
–  currency translation on significant items

Adjusted 

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

Significant items
–  costs of structural reform4
–  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 

Wealth and 
Personal Banking

Commercial
Banking

2019

Global
Banking and
Markets

$m

$m

$m

25,552   

358   

230   

155   

52   

7   

16   

15,256   

327   

14,894   

303   

11   

7   

—   

4   

—   

85   

—   

—   

84   

1   

26,140   

15,594   

15,282   

(1,437)   

61   

(1,376)   

(17,351)   

(431)   

1,959   

—   

1,264   

431   

180   

(69)   

153   

(1,192)   

(2)   

(1,194)   

(9,905)   

(184)   

3,061   

4   

17   

2,956   

51   

—   

33   

(162)   

7   

(155)   

(337)   

4,236   

42   

—   

3,962   

217   

2   

13   

(15,823)   

(7,028)   

(9,891)   

55   

(1)   

54   

6,819   

(13)   

2,189   

230   

1,959   

8,995   

—   

1   

1   

4,159   

142   

3,072   

11   

3,061   

7,373   

—   

1   

1   

942   

(26)   

4,321   

85   

4,236   

5,237   

Corporate 
Centre

$m

396   

22   

(999)   

1   

(820)   

(179)   

(1)   

(581)   

35   

3   

38   

(29)   

511   

112   

—   

—   

379   

6   

14   

(821)   

2,299   

141   

2,440   

Total

$m

56,098 

1,010 

(673) 

163 

(768) 

(84) 

16 

56,435 

(2,756) 

69 

(2,687) 

(42,349) 

(981) 

9,767 

158 

1,281 

7,349 

827 

(61) 

213 

(33,563) 

2,354 

142 

2,496 

1,427   

13,347 

137   

(488)   

(999)   

511   

1,076   

240 

9,094 

(673) 

9,767 

22,681 

(13,790)   

(1,303)   

443,025   

346,105   

246,492   

1,121   

1,036,743 

5,855   

2,611   

1,570   

20   

10,056 

448,880   

348,716   

248,062   

1,141   

1,046,799 

753,769   

388,723   

295,880   

4,645   

3,410   

2,738   

758,414   

392,133   

298,618   

743   

17   

760   

1,439,115 

10,810 

1,449,925 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3 
4  Comprises costs associated with preparations for the UK’s exit from the European Union.

Includes $0.8bn dilution gain following the merger of The Saudi British Bank (‘SABB’) with Alawwal bank.
Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.

100 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted risk-weighted assets

Risk-weighted assets

Reported
Adjusted1

Risk-weighted assets

Reported

Currency translation
Adjusted1

Risk-weighted assets

Reported

Currency translation
Adjusted1

Wealth and 
Personal 
Banking

Commercial
Banking

At 31 Dec 2021

Global
Banking and
Markets

Corporate 
Centre

$bn

$bn

$bn

$bn

Total

$bn

178.3   

178.3   

332.9   

332.9   

236.2   

236.2   

90.9   

90.9   

838.3 

838.3 

At 31 Dec 2020

172.8   

(2.7)   

170.1   

327.7   

(5.3)   

322.4   

265.1   

(4.1)   

261.0   

91.9   

(0.8)   

91.1   

857.5 

(12.9) 

844.6 

At 31 Dec 2019

162.6   

(0.3)   

162.3   

325.9   

1.5   

327.4   

273.4   

(0.6)   

272.8   

81.5   

0.1   

81.6   

843.4 

0.7 

844.1 

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)

2021

Net operating income before change in expected credit losses and other credit 
impairment charges2

–  net interest income

–  net fee income/(expense)

–  other income

ECL

Net operating income
Total operating expenses3
Operating profit

Share of profit in associates and joint ventures

Profit before tax

2020

Net operating income before change in expected credit losses and other credit 
impairment charges2

–  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

Consists of1

Total 
WPB

$m

Banking 
operations

Insurance 
manufacturing

Global Private 
Banking

Asset 
management

$m

$m

$m

$m

22,110   

14,198   

5,894   

2,018   

288   

16,440   

11,237   

4,405   

798   

292   

22,398   

16,732   

(15,384)   

(12,401)   

7,014   

34   

7,048   

4,331   

16   

4,347   

22,571   

15,470   

5,519   

1,582   

(3,005)   

19,566   

(15,443)   

4,123   

7   

4,130   

17,840   

12,536   

4,175   

1,129   

(2,866)   

14,974   

(12,774)   

2,200   

6   

2,206   

2,625   

2,316   

(620)   

929   

(17)   

2,608   

(589)   

2,019   

18   

2,037   

1,869   

2,249   

(527)   

147   

(67)   

1,802   

(486)   

1,316   

1   

1,317   

1,826   

1,219 

647   

933   

246   

14   

1,840   

(1,565)   

275   

—   

275   

1,789   

688   

843   

258   

(71)   

1,718   

(1,429)   

289   

—   

289   

(2) 

1,176 

45 

(1) 

1,218 

(829) 

389 

— 

389 

1,073 

(3) 

1,028 

48 

(1) 

1,072 

(754) 

318 

— 

318 

HSBC Holdings plc Annual Report and Accounts 2021 101

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses

WPB – summary (adjusted basis) (continued)

2019
Net operating income before change in expected credit losses and other credit 
impairment charges2

–  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

Consists of1

Total 
WPB

$m

Banking 
operations

Insurance 
manufacturing

Global Private 
Banking

Asset 
management

$m

$m

$m

$m

26,140   

17,820   

5,753   

2,567   

(1,376)   

24,764   

(15,823)   

8,941   

54   

8,995   

20,508   

14,737   

4,684   

1,087   

(1,286)   

19,222   

(13,085)   

6,137   

11   

6,148   

2,663   

2,179   

(726)   

1,210   

(66)   

2,597   

(485)   

2,112   

43   

2,155   

1,917   

1,052 

911   

797   

209   

(24)   

1,893   

(1,480)   

413   

—   

413   

(7) 

998 

61 

— 

1,052 

(773) 

279 

— 

279 

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. This differs from 

the WPB Life insurance manufacturing revenue shown in the managed view of adjusted revenue on page 31, which excludes the impact of 
Argentina hyperinflation and includes the effect of goodwill adjustments.

3  Operating expenses in Global Private Banking in 2021 included a one-off charge of $0.1bn, which did not meet the criteria to be classified as a 

significant item.

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. 

These results are prepared in accordance with current IFRSs which 
will change following adoption of IFRS 17 ‘Insurance Contracts’, 
effective from 1 January 2023. Further information about the 
adoption of IFRS 17 is provided on page 90.

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/(expenses) 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

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 charges3

2021

2020

2019

WPB

$m  

All global 
businesses

$m

WPB

$m

All global 
businesses

$m

WPB

$m

All global 
businesses

$m

2,316   

2,492   

2,249   

2,414   

2,179   

2,318 

(620)   

105   

(725)   

(652)   

128   

(780)   

(527)   

111   

(638)   

(564)   

132   

(696)   

(726)   

108   

(834)   

(750) 

131 

(881) 

6   

—   

66   

84   

(107)   

(117) 

4,061   

4,100   

2,066   

2,019   

3,671   

3,654 

86   

90   

13   

13   

5   

5 

10,516   

10,998   

9,822   

10,313   

10,572   

10,932 

192   

100   

175   

93   

333   

368   

347   

381   

1,801   

1,724   

1,814 

1,769 

16,557   

17,203   

14,022   

14,626   

17,395   

17,856 

(13,932)   

(14,442)   

(12,153)   

(12,653)   

(14,732)   

(15,115) 

2,625   

2,761   

1,869   

1,973   

2,663   

2,741 

Change in expected credit losses and other credit impairment charges

(17)   

(20)   

(67)   

(78)   

(66)   

Net operating income

Total operating expenses

Operating profit

Share of profit in associates and joint ventures
Profit before tax of insurance manufacturing operations4
Annualised new business premiums of insurance manufacturing operations

Insurance distribution income earned by HSBC bank channels

2,608   

2,741   

1,802   

1,895   

2,597   

(589)   

(618)   

(486)   

(514)   

(485)   

2,019   

2,123   

1,316   

1,381   

2,112   

18   

2,037   

2,838   

762   

18   

2,141   

2,892   

832   

1   

1,317   

2,320   

751   

1   

1,382   

2,384   

816   

43   

2,155   

3,348   

961   

(70) 

2,671 

(506) 

2,165 

43 

2,208 

3,427 

1,057 

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 2020: $5m favourable (reported: $1,377m), 2019: $73m favourable (reported: $2,135m).

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 2021 of $12m (2020: increase of $5m, 2019: reduction of $1m) and an increase in profit before tax in 2021 of $10m (2020: increase of 
$12m, 2019: increase of $3m). These effects are recorded within ‘All global businesses’.

102 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Insurance manufacturing

• Other operating income of $0.2bn decreased by $0.2bn 

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 $2.1bn increased by $0.8bn or 55% 
compared with 2020.

Adjusted net operating income before change in expected credit 
losses and other credit impairment changes was $0.8bn or 40% 
higher than in 2020. 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 $4.1bn in 2021 compared with $2.0bn in 2020. 
This increase primarily reflected favourable equity market 
performance in France and Hong Kong and higher gains on unit 
trust assets, supporting insurance and investment contracts. 
This compared with 2020, which was adversely impacted by 
the onset of the Covid-19 pandemic.

• This favourable movement resulted in a corresponding 

movement in liabilities to policyholders and PVIF (see ‘Other 
operating income’ below), to the extent to which policyholders 
and shareholders respectively participate in the investment 
performance of the associated assets.

• Net insurance premium income of $11bn was $0.7bn higher 

than in 2020, primarily reflecting higher sales volumes 
particularly in France, the UK and Singapore.

compared with 2020, mainly from adverse movements in PVIF. 
This included a reduction of $0.7bn due to assumption changes 
and experience variances, primarily reflecting increased interest 
rates and the effect of sharing higher investment returns with 
policyholders in Hong Kong and Singapore, partly offset in 
France where higher interest rates reduced the cost of 
guarantees. The net reduction from assumption changes and 
experience variances was partly offset by a $0.3bn increase in 
the value of new business written, primarily in Hong Kong.

• Net insurance claims and benefits paid and movement in 

liabilities to policyholders was $1.8bn higher, primarily due to 
higher returns on financial assets supporting contracts where 
the policyholder is subject to part or all of the investment risk 
and higher sales volumes, particularly in France and the UK.

Adjusted operating expenses of $0.6bn increased by 20% 
compared with 2020, 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. Higher ANP during the 
period reflected improved new business volumes, mainly in Hong 
Kong.

Insurance distribution income from HSBC channels included 
$486m (2020: $476m; 2019: $665m) on HSBC manufactured 
products, for which a corresponding fee expense is recognised 
within insurance manufacturing, and $346m (2020: $340m; 
2019: $392m) on products manufactured by third-party providers. 
The WPB component of this distribution income was $433m 
(2020: $428m; 2019: $589m) from HSBC manufactured products 
and $329m (2020: $323m; 2019: $372m) from third-party 
products.

WPB: Wealth adjusted revenue by geography

The following table shows the adjusted revenue of our Wealth business by region. Our Wealth business comprises investment 
distribution, life insurance manufacturing, Global Private Banking and Asset Management.

Wealth adjusted revenue by geography

Europe

Asia

MENA

North America

Latin America

Total

WPB: Wealth balances

2021

$m

2,381   

5,780   

180   

530   

252   

2020

$m

1,859   

5,246   

163   

520   

216   

2019

$m

2,402 

5,587 

126 

562 

246 

9,123   

8,004   

8,923 

The following table shows the wealth balances, which include invested assets and wealth deposits. Invested assets comprise customer 
assets either managed by our Asset Management business or by external third-party investment managers, as well as self-directed 
investments by our customers.

HSBC Holdings plc Annual Report and Accounts 2021 103

Financial review 
 
 
 
 
 
 
 
 
Global businesses

WPB – reported wealth balances1

Global Private Banking invested assets

–  managed by Global Asset Management

–  external managers, direct securities and other

Retail invested assets

–  managed by Global Asset Management

–  external managers, direct securities and other

Asset Management third-party distribution
Reported invested assets1
Wealth deposits (Premier, Jade and Global Private Banking)2
Total reported wealth balances

2021

$bn

351   

67   

284   

434   

229   

205   

334   

1,119   

551   

1,670   

2020

$bn

326 

66 

260 

407 

219 

188 

317 

1,050 

538 

1,588 

1 

Invested 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.

2  Premier, Jade and Global Private Banking deposits, which include Prestige deposits in Hang Seng Bank, form part of the total WPB customer 

accounts balance of $859bn (2020: $835bn) on page 98.

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 

Asset Management – reported funds under management

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. 

Opening balance

Net new invested assets

Net market movements

Foreign exchange and others

Closing balance

Asset Management – reported funds under management by geography

Europe

Asia

MENA

North America

Latin America

Closing balance

2021

$bn

602   

27   

18   

(17)   

630   

2021

$bn

367   

180   

5   

69   

9   

630   

2020

$bn

506 

53 

17 

26 

602 

2020

$bn

346 

176 

6 

65 

9 

602 

At 31 December 2021, Asset Management funds under 
management amounted to $630bn, an increase of $28bn or 5%. 
The increase reflected strong net new invested assets, primarily 
from passive and managed solutions investment products. There 
was a positive market performance, although this was largely 
offset by adverse foreign exchange translation.

Global Private Banking: client assets

Global Private Banking client assets comprises invested assets and 
deposits, 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

Opening balance

Net new invested assets

Increase/(decrease) in deposits

Net market movements

Foreign exchange and others

Closing Balance

Global Private Banking – reported client assets by geography1

Europe 

Asia 

North America

Closing balance

2021

$bn

394   

19   

4   

17   

(11)   

423   

2021

$bn

174   

178   

71   

423   

2020

$bn

361 

3 

3 

6 

21 

394 

2020

$bn

174 

176 

44 

394 

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. 

104 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Retail invested assets

The following table shows the invested assets of our retail 
customers. These comprise customer assets either managed by 
our Asset Management business or by external third-party 

investment managers as well as self-directed investments by our 
customers. Retail invested 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.

Retail invested assets

Opening balance
Net new invested assets1
Net market movements

Foreign exchange and others

Closing balance

Retail invested assets by geography

Europe

Asia

MENA

North America

Latin America

Closing balance

2021

$bn

407   

26   

5   

(4)   

434   

2021

$bn

81   

293   

4   

47   

9   

434   

2020

$bn

380 

10 

5 

12 

407 

2020

$bn

71 

281 

4 

42 

9 

407 

1 

‘Retail net new invested assets’ covers nine markets, comprising Hong Kong including Hang Seng Bank (Hong Kong), mainland China, Malaysia, 
Singapore, HSBC Bank UK, UAE, US, Canada and Mexico. The net new invested assets related to all other geographies is reported in ‘exchange 
and other’.

WPB invested assets 

Net new invested assets represents the net customer inflows from 
retail invested assets, Asset Management third-party distribution 
and Global Private Banking invested assets. It excludes all 

customer deposits. The net new invested assets in the table below 
is non-additive from the tables above, as net new invested assets 
managed by Asset Management that is generated by retail clients 
or Global Private Banking will be recorded in both businesses.

WPB: Invested assets

Opening balance

Net new invested assets

Net market movements

Foreign exchange and others

Closing balance

WPB: Net new invested assets by geography

Europe

Asia

MENA

North America

Latin America

Total

2021

$bn

1,050   

64   

33   

(28)   

2020

$bn

925 

53 

21 

51 

1,119   

1,050 

2021

$bn

17   

36   

—   

10   

1   

64   

2020

$bn

21 

15 

— 

16 

1 

53 

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 2021, we held $10.8tn of 
assets as custodian, 7% higher than at 31 December 2020. The 
balance comprised $10.0tn of assets in Securities Services, which 
were recorded at market value, and $0.8tn of assets in Issuer 
Services, recorded at book value. 

The growth was driven by Securities Services balances, from net 
client asset inflows, including increases from new client 
mandates, notably in Asia, the US and the UK, and favourable 
market movements. These increases were partly offset by the 
adverse impact of currency translation differences.

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 2021, the value of assets held 
under administration by the Group amounted to $4.9tn, which was 
10% higher than at 31 December 2020. The balance comprised 
$3.0tn of assets in Securities Services, which were recorded at 
market value, and $1.9tn of assets in Issuer Services, recorded at 
book value. 

The increase was mainly driven by Securities Services balances, 
from a net inflow of client assets, particularly in the UK and Hong 
Kong, and from favourable market movements.

HSBC Holdings plc Annual Report and Accounts 2021 105

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)1
Net operating income before change in
expected credit losses and other credit
impairment charges2

Change in expected credit losses and other credit
impairment charges

2021

Europe

$m

Asia

$m

MENA

$m

North 
America

Latin 
America

Intra-HSBC

$m

$m

$m

Total

$m

6,454   

12,596   

1,299   

3,882   

5,871   

774   

2,845   

2,056   

2,195   

1,100   

26,489 

514   

—   

13,097 

2,602   

3,643   

431   

426   

476   

166   

7,744 

1,670   

2,340   

—   

—   

45   

(2)   

4,053 

1,973   

(3)   

3,523   

1,316   

(3)   

59   

54   

673   

40   

(1,263)   

798 

(212)   

(7,988)   

(2,629) 

20,104   

25,763   

2,560   

6,054   

3,058   

(7,987)   

49,552 

1,601   

(840)   

132   

238   

(203)   

—   

928 

Net operating income 

21,705   

24,923   

2,692   

6,292   

2,855   

(7,987)   

50,480 

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

(18,099)   

(15,136)   

(1,536)   

(4,905)   

(2,198)   

7,987   

(33,887) 

(95)   

3,511   

268   

(24)   

9,763   

2,486   

1,148   

1,374   

275   

—   

(8)   

(13)   

(593)   

3,779   

12,249   

1,423   

1,374   

%

20.0

90.5

$m

%

64.8

58.8

$m

%

7.5

60.3

$m

%

7.3

81.2

$m

64   

17   

81   

%

0.4

91.3

$m

—   

—   

—   

—   

$m

(733) 

15,860 

3,046 

18,906 

%

100.0

69.9

$m

Loans and advances to customers (net)

  397,090    492,525   

26,375    108,717   

21,107   

—    1,045,814 

Total assets 

Customer accounts
Risk-weighted assets3

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)1
Net operating income before change in expected credit losses and 
other credit impairment charges2

Change in expected credit losses and other credit
impairment charges

  1,354,483    1,261,707   

70,974    362,150   

46,602   

(137,977)    2,957,939 

  667,769    792,098   

42,629    178,565   

29,513   

—    1,710,574 

  261,115    396,206   

60,223    110,412   

35,915 

  838,263 

5,695   

3,499   

14,318   

5,418   

1,465   

695   

2,836   

1,795   

1,960   

467   

1,304   

—   

27,578 

11,874 

2020

3,266   

4,273   

402   

997   

593   

51   

9,582 

327   

1,699   

—   

—   

55   

—   

2,081 

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 

Total assets 

Customer accounts
Risk-weighted assets3

  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   

284,322   

384,228   

60,181   

117,755   

27,478   

35,240   

—    1,642,780 

—   

857,520 

106 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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)1
Net operating income before loan impairment (charges)/recoveries 
and other credit risk provisions2

Change in expected credit losses and other credit
impairment (charges)/recoveries

Europe

$m

Asia

$m

5,601   

3,668   

16,607   

5,325   

MENA

$m

1,781   

685   

2019

North 
America

Latin 
America

Intra-HSBC/
global 
impairment4

$m

3,241   

1,804   

$m

2,061   

540   

$m

1,171   

1   

Total

$m

30,462 

12,023 

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)   

(117)   

(237)   

(740)   

—   

(2,756) 

Net operating income 

17,118   

29,695   

3,593   

6,350   

2,776   

(6,190)   

53,342 

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

(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)   

—   

(7,394) 

10,993 

2,354 

(3,962)   

13,347 

 (29.6) 

$m

%

 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 assets3

  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   

280,983   

366,375   

57,492   

121,953   

28,237   

38,460   

—    1,439,115 

—   

843,395 

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.
4 

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.

HSBC Holdings plc Annual Report and Accounts 2021 107

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items – geographical regions

Reconciliation of reported and adjusted items

Revenue1
Reported2
Significant items2
–  customer redress programmes
–  fair value movements on financial instruments3
–  restructuring and other related costs2,4
Adjusted2
ECL

Reported 

Adjusted

Operating expenses
Reported2
Significant items2
–  customer redress programmes

–  impairment of goodwill and other intangibles
–  restructuring and other related costs2
Adjusted2
Share of profit in associates and joint ventures

Reported 

Adjusted

Profit before tax

Reported

Significant items
–  revenue2
–  operating expenses2
Adjusted 

Loans and advances to customers (net)

Reported

Adjusted 

Customer accounts

Reported

Adjusted 

2021

Europe

$m

Asia

$m

MENA

$m

North
America

Latin
America

$m

$m

Total

$m

20,104   

25,763   

2,560   

6,054   

3,058   

49,552 

125   

(11)   

226   

(90)   

(164)   

—   

11   

(175)   

—   

—   

—   

—   

10   

—   

5   

5   

5   

—   

—   

5   

538 

(11) 

242 

307 

20,229   

25,599   

2,560   

6,064   

3,063   

50,090 

1,601   

1,601   

(840)   

(840)   

132   

132   

238   

238   

(203)   

(203)   

928 

928 

(18,194)   

(15,160)   

(1,544)   

(4,918)   

(2,791)   

(34,620) 

1,367   

509   

49   

—   

—   

—   

1,318   

509   

56   

—   

—   

56   

432   

670   

2,472 

—   

—   

432   

—   

587   

83   

49 

587 

1,836 

(16,827)   

(14,651)   

(1,488)   

(4,486)   

(2,121)   

(32,148) 

268   

268   

2,486   

2,486   

275   

275   

—   

—   

17   

17   

3,046 

3,046 

3,779   

12,249   

1,423   

1,374   

81   

18,906 

1,492   

125   

1,367   

345   

(164)   

509   

56   

—   

56   

442   

10   

432   

5,271   

12,594   

1,479   

1,816   

675   

3,010 

5   

670   

756   

538 

2,472 

21,916 

  397,090    492,525   

26,375    108,717   

21,107   1,045,814 

  397,090    492,525   

26,375    108,717   

21,107   1,045,814 

  667,769    792,098   

42,629    178,565   

29,513   1,710,574 

  667,769    792,098   

42,629    178,565   

29,513   1,710,574 

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.

108 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Revenue1
Reported

Significant items

–  customer redress programmes
–  fair value movements on financial instruments2
–  restructuring and other related costs3
Adjusted

ECL

Reported 

Adjusted

Operating expenses

Reported 

Significant items

–  customer redress programmes

–  restructuring and other related costs

Adjusted

Share of profit in associates and joint ventures

Reported 

Adjusted

Profit before tax

Reported

Significant items

–  revenue 

–  operating expenses

Adjusted 

Loans and advances to customers (net)

Reported

Adjusted 

Customer accounts

Reported

Adjusted 

2021

Hong 
Kong

$m

Mainland 
China

$m

UK

$m

US

$m

Mexico

$m

16,415   

14,463   

3,734   

4,006   

2,341 

(18)   

(11)   

220   

(227)   

61   

—   

7   

54   

(41)   

—   

—   

(41)   

14   

—   

5   

9   

15 

— 

— 

15 

16,397   

14,524   

3,693   

4,020   

2,356 

1,645   

1,645   

(608)   

(608)   

(89)   

(89)   

205   

205   

(224) 

(224) 

(14,808)   

(7,955)   

(2,773)   

(3,683)   

(1,565) 

1,193   

49   

1,144   

227   

—   

227   

32   

—   

32   

355   

—   

355   

59 

— 

59 

(13,615)   

(7,728)   

(2,741)   

(3,328)   

(1,506) 

267   

267   

16   

16   

2,461   

2,461   

3,519   

1,175   

(18)   

1,193   

4,694   

5,916   

3,333   

288   

61   

227   

(9)   

(41)   

32   

6,204   

3,324   

—   

—   

528   

369   

14   

355   

897   

17 

17 

569 

74 

15 

59 

643 

  306,464    311,947   

54,239   

52,678   

18,043 

  306,464    311,947   

54,239   

52,678   

18,043 

  535,797    549,429   

59,266    111,921   

23,583 

  535,797    549,429   

59,266    111,921   

23,583 

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 2021 109

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items (continued)

Revenue1
Reported2
Currency translation2
Significant items2
–  customer redress programmes

–  disposals, acquisitions and investment in new businesses
–  fair value movements on financial instruments3
–  restructuring and other related costs2,4
–  currency translation on significant items
Adjusted2 
ECL

Reported 

Currency translation

Adjusted

Operating expenses
Reported 2
Currency translation2
Significant items2
–  customer redress programmes

–  impairment of goodwill and other intangibles

–  past service costs of guaranteed minimum pension benefits equalisation
–  restructuring and other related costs2,5
–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items
Adjusted2 
Share of profit/(loss) in associates and joint ventures

Reported 

Currency translation

Significant items
–  impairment of goodwill6
–  currency translation on significant items

Adjusted

Profit/(loss) before tax

Reported

Currency translation

Significant items
–  revenue2 
–  operating expenses2
–  share of profit in associates and joint ventures

Adjusted

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

2020

Europe

$m

Asia

$m

MENA

$m

North
America

$m

Latin
America

$m

Total

$m

18,419   

26,922   

2,628   

6,375   

3,020   

50,429 

1,171   

(233)   

21   

—   

(254)   

(9)   

9   

335   

(36)   

—   

—   

(5)   

(32)   

1   

(58)   

109   

(69)   

1,393 

(1)   

—   

—   

—   

—   

(1)   

42   

—   

10   

(2)   

35   

(1)   

—   

—   

—   

(3)   

—   

3   

(52) 

21 

10 

(264) 

170 

11 

19,357   

27,221   

2,569   

6,526   

2,951   

51,770 

(3,751)   

(2,284)   

(758)   

(900)   

(1,124)   

(8,817) 

(337)   

(57)   

3   

(24)   

(50)   

(465) 

(4,088)   

(2,341)   

(755)   

(924)   

(1,174)   

(9,282) 

(18,874)   

(13,662)   

(1,586)   

(5,307)   

(1,938)   

(34,432) 

(1,000)   

2,335   

(54)   

803   

17   

1,425   

12   

132   

(198)   

171   

—   

—   

—   

171   

—   

—   

39   

81   

—   

64   

—   

19   

—   

(2)   

(69)   

603   

—   

223   

—   

378   

—   

2   

61   

81   

—   

—   

—   

91   

—   

(10)   

(1,072) 

3,095 

(54) 

1,090 

17 

1,908 

12 

122 

(17,539)   

(13,689)   

(1,466)   

(4,773)   

(1,796)   

(32,409) 

1   

—   

—   

—   

—   

1   

1,856   

133   

—   

—   

—   

1,989   

(4,205)   

12,832   

(166)   

2,102   

(233)   

2,335   

—   

213   

135   

(36)   

171   

—   

(2,269)   

13,180   

(265)   

—   

462   

462   

—   

197   

19   

(16)   

542   

(1)   

81   

462   

545   

—   

—   

—   

—   

—   

—   

168   

16   

645   

42   

603   

—   

829   

5   

—   

—   

—   

—   

5   

(37)   

(58)   

81   

—   

81   

—   

1,597 

133 

462 

462 

— 

2,192 

8,777 

(11) 

3,505 

(52) 

3,095 

462 

(14)   

12,271 

408,495   

473,165   

28,700   

107,969   

19,658    1,037,987 

(9,176)   

(4,397)   

(1,423)   

199   

(788)   

(15,585) 

399,319   

468,768   

27,277   

108,168   

18,870    1,022,402 

629,647   

762,406   

41,221   

182,028   

27,478    1,642,780 

(12,835)   

(6,887)   

(1,748)   

234   

(1,416)   

(22,652) 

616,812   

755,519   

39,473   

182,262   

26,062    1,620,128 

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 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.
In 2020, 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.

6 

110 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Revenue1
Reported

Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses
–  fair value movements on financial instruments2
–  restructuring and other related costs3
–  currency translation on significant items

Adjusted

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

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

–  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

2020

Mainland 
China

$m

US

$m

Mexico

$m

13,886   

16,345   

3,088   

4,590   

2,234 

1,048   

(180)   

21   

—   

(256)   

48   

7   

(29)   

14   

—   

—   

—   

15   

(1)   

220   

(5)   

—   

—   

(1)   

(4)   

—   

—   

41   

—   

10   

(2)   

33   

—   

124 

(11) 

— 

— 

(1) 

(12) 

2 

14,754   

16,330   

3,303   

4,631   

2,347 

(3,256)   

(824)   

(306)   

2   

(3,562)   

(822)   

(114)   

(9)   

(123)   

(622)   

(1,050) 

—   

(69) 

(622)   

(1,119) 

(14,855)   

(7,312)   

(2,211)   

(4,194)   

(1,376) 

(875)   

1,430   

(54)   

650   

17   

693   

12   

112   

14   

99   

—   

—   

—   

100   

—   

(1)   

(152)   

20   

—   

—   

—   

19   

—   

1   

—   

556   

—   

223   

—   

333   

—   

—   

(74) 

42 

— 

— 

— 

42 

— 

— 

(14,300)   

(7,199)   

(2,343)   

(3,638)   

(1,408) 

1   

—   

1   

(2)   

—   

(2)   

1,849   

132   

1,981   

—   

—   

—   

5 

— 

5 

(4,224)   

8,207   

2,612   

(226)   

(187) 

(133)   

1,250   

(180)   

1,430   

(13)   

113   

14   

99   

191   

15   

(5)   

20   

(3,107)   

8,307   

2,818   

—   

597   

41   

556   

371   

(19) 

31 

(11) 

42 

(175) 

  314,530    302,454   

46,113   

58,082   

17,296 

(2,764)   

(1,741)   

1,278   

—   

(471) 

  311,766    300,713   

47,391   

58,082   

16,825 

  504,275    531,489   

56,826    117,485   

22,220 

(4,432)   

(3,060)   

1,575   

—   

(605) 

  499,843    528,429   

58,401    117,485   

21,615 

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 2021 111

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items (continued)

Revenue1
Reported2
Currency translation2
Significant items

–  customer redress programmes
–  disposals, acquisitions and investment in new businesses3
–  fair value movements on financial investments4
–  currency translation on significant items 
Adjusted2
ECL

Reported 

Currency translation

Adjusted

Operating expenses
Reported2,6
Currency translation2
Significant items6
–  costs of structural reform5
–  customer redress programmes
–  goodwill impairment6
–  restructuring and other related costs

–  settlements and provisions in connection with legal and regulatory matters

–  currency translation on significant items 
Adjusted2,6
Share of profit/(loss) in associates and joint ventures

Reported

Currency translation

Adjusted

Profit/(loss) before tax
Reported6
Currency translation6
Significant items6
–  revenue 
–  operating expenses6
Adjusted

Loans and advances to customers (net)

Reported

Currency translation

Adjusted 

Customer accounts

Reported

Currency translation

Adjusted 

2019

Europe

$m

Asia

$m

MENA

$m

North
America

$m

Latin
America

$m

Total

$m

18,056   

30,419   

3,710   

6,587   

3,516   

56,098 

1,353   

354   

41   

163   

—   

(137)   

15   

35   

—   

—   

35   

—   

(72)   

(827)   

—   

(828)   

—   

1   

99   

68   

—   

59   

9   

—   

(666)   

1,010 

10   

—   

1   

9   

—   

(673) 

163 

(768) 

(84) 

16 

19,450   

30,808   

2,811   

6,754   

2,860   

56,435 

(938)   

(69)   

(1,007)   

(724)   

(11)   

(735)   

(117)   

4   

(113)   

(237)   

(4)   

(241)   

(740)   

149   

(591)   

(2,756) 

69 

(2,687) 

(21,759)   

(13,297)   

(1,549)   

(5,583)   

(2,389)   

(42,349) 

(1,246)   

4,655   

154   

1,281   

2,522   

538   

(60)   

220   

(177)   

127   

4   

—   

—   

123   

(1)   

1   

59   

112   

—   

—   

97   

15   

—   

—   

(61)   

544   

—   

—   

431   

113   

—   

—   

386   

367   

—   

—   

337   

38   

—   

(8)   

(981) 

9,767 

158 

1,281 

7,349 

827 

(61) 

213 

(18,350)   

(13,347)   

(1,378)   

(5,100)   

(1,636)   

(33,563) 

(12)   

1   

(11)   

2,070   

142   

2,212   

283   

—   

283   

(4,653)   

18,468   

2,327   

39   

4,696   

41   

4,655   

308   

162   

35   

127   

(9)   

(715)   

(827)   

112   

—   

—   

—   

767   

34   

612   

68   

544   

82   

18,938   

1,603   

1,413   

13   

(1)   

12   

2,354 

142 

2,496 

400   

13,347 

(132)   

377   

10   

367   

645   

240 

9,094 

(673) 

9,767 

22,681 

393,850   

477,727   

28,556   

113,474   

23,136    1,036,743 

8,549   

4,264   

(1,482)   

1,165   

(2,440)   

10,056 

402,399   

481,991   

27,074   

114,639   

20,696    1,046,799 

528,718   

697,358   

38,126   

146,676   

28,237    1,439,115 

11,240   

4,003   

(2,091)   

1,183   

(3,525)   

10,810 

539,958   

701,361   

36,035   

147,859   

24,712    1,449,925 

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 $0.8bn dilution gain following the merger of The Saudi British Bank (‘SABB’) with Alawwal bank.
3 
4 
Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.
5  Comprises costs associated with preparations for the UK’s exit from the European Union.
6  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.

112 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Revenue1
Reported

Currency translation

Significant items

–  customer redress programmes

–  disposals, acquisitions and investment in new businesses
–  fair value movements on financial instruments2
–  currency translation on significant items

Adjusted

ECL

Reported 

Currency translation

Adjusted

Operating expenses

Reported 

Currency translation

Significant items
–  costs of structural reform3
–  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 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

13,538   

19,412   

1,148   

153   

3,101   

219   

40   

162   

—   

(139)   

17   

26   

—   

—   

26   

—   

1   

—   

—   

1   

—   

US

$m

Mexico

$m

4,638   

—   

66   

—   

59   

7   

—   

2,555 

(129) 

7 

— 

— 

8 

(1) 

14,726   

19,591   

3,321   

4,704   

2,433 

(714)   

(58)   

(772)   

(459)   

(3)   

(462)   

(129)   

(9)   

(138)   

(170)   

—   

(170)   

(491) 

25 

(466) 

(16,157)   

(6,935)   

(2,111)   

(4,033)   

(1,390) 

(1,010)   

1,941   

101   

1,281   

405   

8   

146   

(51)   

65   

4   

—   

61   

(1)   

1   

(153)   

7   

—   

—   

6   

—   

1   

—   

93   

—   

—   

93   

—   

—   

71 

19 

— 

— 

20 

— 

(1) 

(15,226)   

(6,921)   

(2,257)   

(3,940)   

(1,300) 

(12)   

1   

(11)   

31   

—   

31   

(3,345)   

12,049   

81   

1,981   

40   

1,941   

99   

91   

26   

65   

2,016   

143   

2,159   

2,877   

200   

8   

1   

7   

(1,283)   

12,239   

3,085   

—   

—   

—   

435   

—   

159   

66   

93   

594   

13 

(1) 

12 

687 

(34) 

26 

7 

19 

679 

303,041   

306,964   

42,380   

63,588   

20,426 

7,175   

(372)   

4,054   

—   

(1,561) 

310,216   

306,592   

46,434   

63,588   

18,865 

419,642   

499,955   

48,323   

90,834   

23,051 

9,935   

(606)   

4,622   

—   

(1,762) 

429,577   

499,349   

52,945   

90,834   

21,289 

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 2021 113

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Analysis by country

Profit/(loss) before tax by country/territory within global businesses

Europe
–  UK1
–  of which: HSBC UK Bank plc (ring-fenced bank)

–  of which: HSBC Bank plc (non-ring-fenced bank)

–  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
–  other2
Year ended 31 Dec 2021

Wealth and
Personal
Banking

Commercial 
Banking

Global Banking 
and Markets

Corporate
Centre

$m

1,817   

1,511   

2,047   

176   

(712)   

236   

17   

46   

7   

4,366   

4,076   

146   

20   

14   

(95)   

37   

145   

14   

9   

194   

79   

91   

17   

7   

60   

(131)   

141   

50   

(304)   

305   

(609)   

$m

2,893   

2,475   

2,929   

259   

(713)   

163   

82   

10   

163   

2,364   

1,303   

132   

265   

12   

288   

(23)   

107   

16   

264   

235   

42   

3   

—   

190   

1,023   

472   

544   

7   

162   

88   

74   

$m

(299)   

(487)   

127   

220   

(834)   

(97)   

155   

—   

130   

3,193   

920   

131   

593   

111   

586   

145   

231   

106   

370   

805   

163   

342   

65   

235   

697   

524   

145   

28   

326   

222   

104   

$m

(632)   

20   

(318)   

(17)   

355   

(133)   

67   

(12)   

(574)   

2,326   

(383)   

(26)   

232   

(8)   

2,554   

(20)   

(13)   

(5)   

(5)   

189   

(2)   

(61)   

274   

(22)   

(406)   

(337)   

(62)   

(7)   

(103)   

(46)   

(57)   

Total

$m

3,779 

3,519 

4,785 

638 

(1,904) 

169 

321 

44 

(274) 

12,249 

5,916 

383 

1,110 

129 

3,333 

139 

470 

131 

638 

1,423 

282 

375 

356 

410 

1,374 

528 

768 

78 

81 

569 

(488) 

6,133   

6,677   

4,722   

1,374   

18,906 

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 of $587m. As per Group accounting policy, HSBC’s cash-generating units are based on geographical 
regions, subdivided by global business.    

114 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Profit/(loss) before tax by country/territory within global businesses (continued)

Wealth and
Personal
Banking

Commercial
 Banking

Global
Banking
and Markets

Corporate
Centre

Europe
–  UK1
–  of which: HSBC UK Bank plc (ring-fenced bank)

–  of which: HSBC Bank plc (non-ring-fenced bank)

–  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

$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’).

HSBC Holdings plc Annual Report and Accounts 2021 115

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Profit/(loss) before tax by country/territory within global businesses (continued)

Wealth and 
Personal Banking

Commercial
 Banking

Global
Banking
and Markets

Corporate
Centre

Europe
–  UK1
–  of which: HSBC UK Bank plc (ring-fenced bank)

–  of which: HSBC Bank plc (non-ring fenced bank)

–  of which: Holdings and other

–  France

–  Germany

–  Switzerland
–  other2
Asia

–  Hong Kong

–  Australia

–  India

–  Indonesia

–  mainland China

–  Malaysia

–  Singapore

–  Taiwan

–  other

Middle East and North Africa

–  Egypt

–  UAE

–  Saudi Arabia
–  other2
North America

–  US

–  Canada
–  other2
Latin America

–  Mexico
–  other2
GBM goodwill impairment2
Year ended 31 Dec 2019

$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. 

116 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

117

117

118

119

119

Use of alternative performance measures

Our reported results are prepared in accordance with IFRSs 
as detailed in our financial statements starting on page 308.

As described on page 90, 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 is 
annualised profit attributable to ordinary shareholders, excluding 
changes in PVIF and significant items (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. Since 1 January 2021, the UK bank levy has no longer 
been excluded from the calculation of this measure. Comparative 
data have not been re-presented.

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)

Decrease/(increase) in PVIF (net of tax)

Profit attributable to the ordinary shareholders, excluding goodwill, other
intangible assets impairment and PVIF

Significant items (net of tax) and other adjustments1
Profit attributable to the ordinary shareholders, excluding goodwill impairment, PVIF and significant items1
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 items1

2021

$m

12,607   

608   

(58)   

13,157   

2,086   

15,243   

2020

$m

3,898   

1,036   

(253)   

4,681   

2,402   

7,083   

2019

$m

5,969 

7,349 

(1,248) 

12,070 

2,251 

14,321 

199,295   

189,719   

189,035 

(22,814)   

(22,326)   

(23,614) 

176,481   

167,393   

165,421 

(17,705)   

(17,292)   

(22,574) 

158,776   

150,101   

142,847 

1,278   

422   

1,032 

160,054   

150,523   

143,879 

%

 7.1 

 8.3 

 9.5 

%

 2.3 

 3.1 

 4.7 

%

 3.6 

 8.4 

 10.0 

1  Since 1 January 2021, the UK bank levy has no longer been excluded from the calculation of this measure. Comparative data have not been re-

presented.

HSBC Holdings plc Annual Report and Accounts 2021 117

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 2021

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)1
Other adjustments

$m

6,133   

(1,540)   

4,593   

(735)   

3,858   

(65)   

850   

3   

$m

6,677   

(1,783)   

4,894   

(665)   

4,229   

4   

51   

(4)   

$m

4,722   

(1,020)   

3,702   

(618)   

3,084   

—   

517   

(3)   

$m

1,374   

130   

1,504   

Total

$m

18,906 

(4,213) 

14,693 

(68)   

(2,086) 

1,436   

12,607 

3   

1,269   

11   

(58) 

2,687 

7 

Profit attributable to ordinary shareholders, excluding PVIF, significant 
items1

Average tangible shareholders’ equity excluding fair value of own debt, DVA and 
other adjustments

4,646   

4,280   

3,598   

2,719   

15,243 

30,587   

39,487   

41,816   

48,164   

160,054 

Return on average tangible equity excluding significant items (%)1

 15.2 

 10.8 

 8.6 

 5.6 

 9.5 

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

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

3,704   

(509)   

3,195   

(736)   

2,459   

(242)   

190   

20   

Year ended 31 Dec 2020

1,639   

(661)   

978   

(673)   

305   

(10)   

208   

(14)   

3,616   

(977)   

2,639   

(784)   

1,855   

—   

958   

(25)   

(182)   

(531)   

(713)   

(8)   

(721)   

(1)   

2,041   

60   

8,777 

(2,678) 

6,099 

(2,201) 

3,898 

(253) 

3,397 

41 

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 

1  Since 1 January 2021, the UK bank levy has no longer been excluded from the calculation of this measure. Comparative data have not been re-

presented.

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

2021

$m

2020

$m

2019

$m

198,250   

196,443   

183,955 

(22,414)   

(22,414)   

(22,276) 

175,836   

174,029   

161,679 

(17,643)   

(17,606)   

(17,535) 

158,193   

156,423   

144,144 

20,073   

20,184   

20,206 

$

$

$

8.76   

7.88   

8.62   

7.75   

8.00 

7.13 

118 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Post-tax return and average total shareholders’
equity on average total assets

Average total shareholders’ equity to average total assets is 
average total shareholders' equity divided by average total assets 
for the period.

Post-tax return on average total assets is profit after tax 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

2021

$m

2020

$m

2019

$m

14,693   

6,099   

8,708 

199,295   

189,719   

189,035 

  3,012,437   

2,936,939   

2,712,376 

%

 0.5 

 6.62 

%

 0.2 

 6.46 

%

 0.3 

 6.97 

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. 

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

2021

$m

928   

928   

2020

$m

(8,817)   

(465)   

(9,282)   

2019

$m

(2,756) 

69 

(2,687) 

  1,057,412   

1,047,114   

1,021,238 

(8,487)   

20,243   

22,292 

Average gross loans and advances to customers – at most recent balance sheet foreign exchange rates

  1,048,925   

1,067,357   

1,043,530 

%

%

%

Ratio

Expected credit losses and other credit impairment charges as % of average gross loans and advances to customers

 (0.09) 

 0.87 

 0.26 

HSBC Holdings plc Annual Report and Accounts 2021 119

Financial review 
 
 
 
 
 
 
 
 
Risk  
review

Our risk review outlines our approach to risk 
management, how we identify and monitor 
top and emerging risks, and the actions we 
take to mitigate them. In addition, it explains 
our material banking risks, including how 
we manage capital.

121  Our approach to risk

121  Our risk appetite 

121  Risk management 

124  Key developments in 2021

124  Top and emerging risks

124  Externally driven

129 

Internally driven

131   Areas of special interest

131   Risks related to Covid-19

131   Climate-related risks

135   Our material banking risks

137   Credit risk

189   Treasury risk

203   Market risk

207   Resilience risk

208   Regulatory compliance risk

208   Financial crime risk

209   Model risk

210  

Insurance manufacturing operations risk

Investing in technology  
to screen suspicious activities

We screen the names of more than 112 million personal and 
corporate customers every day against external and internal 
watchlists to identify potential financial crime risks and their 
impact on our customers and organisation. This currently 
generates approximately 350,000 alerts for our colleagues to 
review each month. In October, working with technology 
company Silent Eight, we launched a global automated alert 
adjudication tool for name screening, which will be able to 
close 50% of the false positives without human intervention. 
This will help us increase the speed and accuracy of 
monitoring adherence to risk appetite, while reducing the 
cost of compliance.

120

HSBC Holdings plc Annual Report and Accounts 2021

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 risks, 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 our risk appetite and 

strong risk management capability.

• We aim to deliver sustainable and diversified 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.

• We are committed to managing the climate risks that have an 
impact on our financial position, and delivering on our net zero 
ambition. 

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 and Compliance 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. This review was last carried out in 
2019 and 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 any 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 123.

The implementation of our business strategy, which includes a 
major transformation programme, remains a key focus. As we 
implement change initiatives, we actively manage the execution 
risks. We also perform periodic risk assessments, including 
against strategies, to help ensure retention of key personnel for 
our continued safe operation.

We aim to use a comprehensive risk management approach 
across the organisation and across all risk types, underpinned by 
our culture and values. This is outlined in our risk management 
framework, including the key principles and practices that we 
employ in managing material risks, both financial and non-
financial. The framework fosters continual monitoring, promotes 
risk awareness and encourages a sound operational and strategic 
decision-making and escalation process. It also supports a 
consistent approach to identifying, assessing, managing and 
reporting the risks we accept and incur in our activities, with clear 
accountabilities. We continue to actively review and develop our 
risk management framework and enhance our approach to 
managing risk, through our activities with regard to: people and 
capabilities; governance; reporting and management information; 
credit risk management models; and data. 

We merged our Group Risk and Compliance functions on 
1 July 2021 to take an increasingly comprehensive view of risk, 
and enhance cross-discipline collaboration on key areas such as 
fraud, credit and conduct risk. This merger did not have an impact 
on our policies and practices regarding the management of risk. 
Led by the Group Chief Risk and Compliance Officer, this merged 
function plays an important role in reinforcing our culture and 
values. It focuses on creating an environment that encourages our 
people to speak up and do the right thing.

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Group Risk and Compliance is independent from the global 
businesses, including our sales and trading functions, to provide 
challenge, oversight and appropriate balance in risk/reward 
decisions. 

Our risk management framework

The following diagram and descriptions summarise key aspects of 
the risk management framework, including governance, structure, 
risk management tools and our culture, which together help align 
employee behaviour with risk appetite.

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 232).

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 123 and 135). 

Our ‘three lines of defence’ model defines roles and responsibilities for 
risk management. An independent Global Risk and Compliance function 
helps ensure the necessary balance in risk/return decisions (see page 
123).

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

Systems and infrastructure

Operational and resilience risk management defines minimum standards 
and processes for managing operational risks and internal controls.

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 and Compliance 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 and Compliance 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. 

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 Group RMM. This 
structure is summarised in the following table.

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Governance structure for the management of risk and compliance

Authority

Membership

Responsibilities include:

Risk Management Meeting  Group Chief Risk and Compliance 
Officer
Group Chief Legal Officer
Group Chief Executive
Group Chief Financial Officer
All other Group Executive Committee 
members

Global Risk Executive 
Committee

Global business/regional 
risk management meetings

Group Chief Risk and Compliance 
Officer
Chief risk officers of HSBC’s 
global businesses and regions
Heads of Global Risk and Compliance 
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 and Compliance Officer in exercising Board-

delegated risk 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

• Supporting the Group Chief Risk and Compliance Officer in providing strategic 
direction for the Global Risk and Compliance function, setting priorities and 
providing oversight

• Overseeing a consistent approach to accountability for, and mitigation of, risk and 

compliance across the Group

• Supporting the Group Chief Risk and Compliance 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 237.

.

Our responsibilities

All our people are responsible for identifying and managing 
risk within the scope of their roles. Roles are defined using the 
three lines of defence model, which takes into account our 
business and functional structures as described below.

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 as to whether our risk 
management approach and processes are designed and 
operating effectively.

Global Risk and Compliance function

Our Global Risk and Compliance function 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 and Compliance is 
made up of sub-functions covering all risks to our business. 
Forming part of the second line of defence, the Global Risk and 
Compliance function 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. 

We have 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. 

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 

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Risk reviewRisk

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 Bank of England 
(‘BoE’) stress tests required in the UK, 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, helps 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 2021

We continued to actively manage the risks resulting from the 
Covid-19 pandemic and its impacts on our customers and 
operations during 2021, as well as other key risks described in this 
section. In addition, we enhanced our risk management in the 
following areas:

• We streamlined the articulation of our risk appetite framework, 
providing further clarity on how risk appetite interacts with 
strategic planning and recovery planning processes.

• We continued to simplify our approach to non-financial risk 
management, with the implementation of more effective 
oversight tools and techniques to improve end-to-end 
identification and management of these risks.

• We accelerated the transformation of our approach to 

managing financial risks across the businesses and risk 
functions, including initiatives to enhance portfolio monitoring 
and analytics, credit risk management, traded risk 
management, treasury risk management and models used to 
manage financial risks.

• We are progressing with a comprehensive regulatory reporting 

programme to strengthen our global processes, improve 
consistency, and enhance controls.

• We launched an enhanced approach to conduct for all 

colleagues, businesses and geographies, establishing the 
outcomes to be achieved for customers and markets in all risk 
disciplines, operations and technologies and integrating it into 
our approach to culture and our risk management 
arrangements.    

• We continued to enhance our approach to portfolio risk 

management, through clearly defined roles and responsibilities, 
and improving our data and management information reporting 
capabilities.

• The Climate Risk Oversight Forum continued to shape and 

oversee our approach to climate risk. We appointed a Head of 
Climate Risk in support of our climate change strategy and to 
oversee the development of our climate risk management 
capabilities. The climate risk programme continues to drive the 
delivery of our enhanced climate risk management approach.

• We continued to improve the effectiveness of our financial 

crime controls with a targeted update of our fraud controls. We 
refreshed our financial crime policies, ensuring they remained 
up to date and addressed changing and emerging risks, and we 
continued to meet our regulatory obligations.

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• We introduced enhanced governance and oversight around 

management judgemental adjustments and related processes 
for IFRS 9 models and Sarbanes-Oxley controls.

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. 
We update our top and emerging risks as necessary.

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 are 
manifesting themselves in divergent regulatory standards and 
compliance regimes, presenting long-term strategic challenges for 
multinational businesses.

The Covid-19 pandemic brought supply chain issues into focus, 
with shortages appearing across several regions and products 
throughout 2020 and 2021, and it is not expected that these issues 
will ease significantly before mid-2022.  

The pandemic has also heightened geopolitical tensions, which 
could have implications for the Group and its customers. 

The Group will continue to need to consider potential regulatory, 
reputational and market risks arising from the evolving geopolitical 
landscape. In 2021, there was an escalation of diplomatic tensions 
between China and the US, and increasingly extending to the UK, 
the EU, India and other countries.  

The US-China relationship in particular remains complex, with 
tensions over a number of critical issues. The US, the UK, the EU, 
Canada and other countries have imposed various sanctions and 
trade restrictions on Chinese individuals or companies, and the US 
continues to develop its approach to perceived strategic 
competition with China.

Among these, the US Hong Kong Autonomy Act authorises the 
imposition of secondary sanctions against non-US financial 
institutions found to be knowingly engaged in significant 
transactions with individuals and entities subject to US sanctions 
for engaging in certain activities that undermine Hong Kong’s 
autonomy. In addition, the US has imposed restrictions on US 
persons’ ability to buy or sell certain publicly traded securities 
linked to a number of prominent Chinese companies.

There is also a risk of increased sanctions being imposed by the 
US and other governments in relation to human rights, technology 
and other issues with China, and this could create a more complex 
operating environment for the Group and its customers. Notably, 
alongside the EU, UK, and Canada, the US has increasingly 
imposed sanctions and other measures in response to allegations 
of human rights abuses in Xinjiang.

China, in turn, has announced a number of its own sanctions and 
trade restrictions that target, or provide authority to target, foreign 
individuals or companies. These have been imposed mainly 
against certain public officials associated with the implementation 
of foreign sanctions against China. China has also promulgated 
new laws that provide a legal framework for imposing further 
sanctions and export restrictions, including laws prohibiting 
implementation of – or compliance with – foreign sanctions 
against China and creating a private right of action in Chinese 
courts for damages caused by third parties implementing foreign 
sanctions or other discriminatory measures. 

These and any future measures and countermeasures that may be 
taken by the US, China and other countries may affect the Group, 
its customers and the markets in which the Group operates.

As the geopolitical landscape evolves, 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 compliance, 
reputational and political risks for the Group. We maintain 
dialogue with our regulators in various jurisdictions on the impact 
of legal and regulatory obligations on our business and customers.

Tensions between Russia and the US and a number of European 
states have heightened significantly following the increasing risk 
of hostilities between Russia and Ukraine. While negotiations are 
ongoing to seek a resolution, a continuation of or any further 
deterioration to the situation could have significant geopolitical 
implications, including economic, social and political 
repercussions on a number of regions that may impact HSBC and 
its customers. In addition, the US, the UK and the EU have 
threatened a significant expansion of sanctions and trade 
restrictions against Russia in the event of a Russian incursion into 
Ukraine, and Russian countermeasures are also possible.

Expanding data privacy and cybersecurity laws in a number of 
markets could pose potential challenges to intra-group data 
sharing. These developments could increase financial institutions’ 
compliance burdens in respect of cross-border transfers of 
personal information. 

Political disagreements between the UK and the EU, notably over 
the future operation of the Northern Ireland Protocol, have meant 
work on the creation of a framework for voluntary regulatory 
cooperation in financial services following the UK’s withdrawal 
from the EU has stalled. While negotiations are continuing, it is 
unclear whether or when an agreement will be reached, and this 
has led to speculation that the UK may trigger Article 16 of the 
Protocol, which could suspend the operation of the Protocol in 
certain respects. Any decision to do so could be met with 
retaliatory action by the EU, complicating the terms of trade 
between the UK and the EU and potentially preventing progress in 
other areas such as financial services. We are monitoring the 
situation closely, including the potential impacts on our 
customers.  

Our global presence and diversified customer base should help 
mitigate the direct impacts on our financial position of the absence 
of a comprehensive EU-UK agreement on financial services. Our 
wholesale and markets footprint in the EU provides a strong 
foundation for us to build upon. Over the medium to long term, 
the UK’s withdrawal from the EU may impact markets and 
increase economic risk, particularly in the UK, which could 
adversely impact our profitability and prospects for growth in this 
market.

Monetary and fiscal policies in developed markets will likely 
remain broadly accommodative for some time owing to 
uncertainty over the economic outlook, although rising global 
inflation – partly on the back of higher energy prices – is putting 
pressure on central banks to tighten monetary policy. The US 
Federal Reserve Board began tapering its asset purchases in 
November 2021 and financial markets currently expect it to raise 
the Federal Funds rate over the next year. The European Central 
Bank is on course to end its extraordinary asset purchase 
programme in March 2022. 

Persistent supply issues or further increases in energy prices – for 
instance as a result of escalation in the Russia-Ukraine crisis – 
could keep inflation high and force central banks to tighten 
monetary policies faster than currently envisaged. Conversely, 
monetary policy tightening may be constrained by the emergence 
and spread of new Covid-19 variants that dampen economic 
recovery. We continue to monitor our risk profile closely in the 
context of uncertainty over monetary policy.

The global economic recovery in 2021 eased financial difficulties 
for some of our customers, which contributed to a reduction in 
ECL charges. For further details on customer relief programmes, 
see page 159. 

Mitigating actions 

• We closely monitor geopolitical and economic developments in 
key markets and sectors and undertake scenario analysis where 
appropriate. This helps 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 regularly review 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 continue to monitor the UK’s relationship with the EU, and 
assess the potential impact on our people, operations and 
portfolios.

• We have taken steps, where necessary, to enhance physical 

security in geographical areas deemed to be at high risk from 
terrorism and military conflicts.

Environmental, social and governance risk

We are subject to financial and non-financial risks associated with 
environmental, social and governance (‘ESG’) related matters. Our 
current areas of focus are climate risk, nature-related risks and 
human rights risks. These can impact us both directly and 
indirectly through our customers. For details on how we govern 
ESG, see page 80.

Climate-related risk increased over 2021, owing to the pace and 
volume of policy and regulatory changes globally particularly on 
climate risk management, stress testing and scenario analysis and 
disclosures. If we fail to meet evolving regulatory expectations or 
requirements on climate risk management, this could have 
regulatory compliance and reputational impacts.

We face increased reputational, legal and regulatory risk as we 
make progress towards our net zero ambition, with stakeholders 
likely to place greater focus on our actions such as the 
development of climate-related policies, our disclosures and 
financing and investment decisions relating to our ambition. We 
will face additional risks if we are perceived to mislead 
stakeholders in respect of our climate strategy, the climate impact 
of a product or service, or the commitments of our customers. 

To track and report on progress towards achieving our ambition, 
we rely on internal and, where appropriate and available, external 
data, guided by certain industry standards. While emissions 
reporting has improved over time, data remains of limited quality 
and consistency. Methodologies we have used may develop over 
time in line with market practice and regulations, as well as owing 
to developments in climate science. Any developments in data and 
methodologies could result in revisions to reported data going 
forward, including on financed emissions, meaning that reported 
figures may not be reconcilable or comparable year-on-year. We 
may also have to reevaluate our progress towards our climate-
related targets in future and this could result in reputational, legal 
and regulatory risks. 

Climate risk will also have an impact on model risk, as models play 
an important role in risk management and the financial reporting 
of climate-related risks. The uncertain impacts of climate change 
and data limitations present challenges to creating reliable and 
accurate model outputs. 

We could also face increased resilience risk, retail credit risk and 
wholesale credit risk owing to the increase in frequency and 
severity of weather events and chronic shifts in weather patterns. 
These risks could affect our own critical operations, impacting our 
customers and resulting in losses to our operations. Our 
customers’ operations and assets could also be affected, reducing 
their ability to afford mortgage or loan repayments, and leading to 
credit risk impacts. 

There is increasing evidence that a number of nature-related risks 
beyond climate change – which include risks that can be 

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Risk reviewRisk

represented more broadly by economic dependence on nature – 
can and will have significant economic impact. These risks arise 
when the provision of natural services – such as water availability, 
air quality, and soil quality – is compromised by overpopulation, 
urban development, natural habitat and ecosystem loss, and other 
environmental stresses beyond climate change. They can show 
themselves in various ways, including through macroeconomic, 
market, credit, reputational, legal and regulatory risks, for both 
HSBC and our customers. In 2021, we added nature-related risks 
as a new emerging risk driver, under the umbrella theme of ESG 
risks and we continue to engage with investors, regulators and 
customers on nature-related risks to evolve our approach and 
understand best practice risk mitigation.

Regulation and disclosure requirements in relation to human 
rights, and to modern slavery in particular, are increasing. 
Businesses are expected to explain more about their efforts to 
identify and respond to the risk of negative human rights impacts 
arising from the actions of their employees, suppliers, customers 
and those in whom they invest. 

Mitigating actions

• We continue to deepen our understanding of the drivers of 
climate risk as well as manage our exposure. A dedicated 
Climate Risk Oversight Forum is responsible for shaping and 
overseeing our approach and providing support in managing 
climate risk. For further details on the Group’s ESG governance 
structure, see page 80.

• Our climate risk programme continues to accelerate the 

development of our climate risk management capabilities 
across four key pillars – governance and risk appetite, risk 
management, stress testing and scenario analysis, and 
disclosures. We are also enhancing our approach to 
greenwashing risk management. 

• In December, we published our thermal coal phase-out policy, 

which committed to phase out the financing of coal-fired power 
and thermal coal mining in EU/OECD markets by 2030, and 
globally by 2040. The policy helps us chart the path to net zero 
and is a component of our approach towards managing the 
climate risk of our lending portfolio.

• Climate stress tests and scenarios are being used to further 

improve our understanding of our risk exposures for use in risk 
management and business decision making.

• We are undertaking training and adding additional roles with 

specialist skills to manage climate-related model risk. 

• We have delivered climate risk training to our legal entity 

boards and wider target audiences. 

• With the help of external stakeholders, we continued to review 
and improve our approach to human rights issues, following 
the UN Guiding Principles on Business and Human Rights.

• In 2021, we joined several industry working groups dedicated 
to helping us assess and manage nature-related risks, such as 
the Taskforce on Nature-related Financial Disclosure (‘TNFD’). 
Our asset management business also published its biodiversity 
policy to publicly explain how our analysts address nature-
related issues.

• We continue to engage with our customers, investors and 

regulators proactively on the management of ESG risks. We 
also engage with initiatives, 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 details on our approach to climate risk management, see ‘Areas of 
special interest’ on page 131.

For further details on ESG risk management see ‘Financial crime risk 
environment and ‘Regulatory compliance risk environment including conduct’ 
on page 129.

Our ESG review can be found on page 43.

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Ibor transition

Interbank offered rates (‘Ibors’) have historically been used 
extensively to set interest rates on different types of financial 
transactions and for valuation purposes, risk measurement and 
performance benchmarking.

Following the UK’s Financial Conduct Authority (‘FCA’) 
announcement 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, we have been actively 
working to transition legacy contracts from Ibors to products 
linked to near risk-free replacement rates (‘RFRs’) or alternative 
reference rates. In March 2021, in accordance with the 2017 FCA 
announcement, ICE Benchmark Administration Limited (‘IBA’) 
announced that it would cease publication of 24 of the 35 main 
Libor currency interest rate benchmark settings from the end of 
2021, and that the most widely used US dollar Libor settings 
would cease from 30 June 2023. The FCA subsequently used its 
regulatory powers to compel IBA to publish the remaining six 
sterling and Japanese yen settings, from 1 January 2022, under an 
amended methodology, commonly known as ‘synthetic’ Libor. As 
a result, our focus during 2021 was on the transition of legacy 
contracts referencing the Euro Overnight Index average (‘Eonia’) 
and the Libor settings that demised from the end of 2021, 
including those settings subsequently being published on a 
‘synthetic’ basis. 

During 2021, we continued the development of IT and RFR 
product capabilities, implemented supporting operational 
processes, and engaged with our clients to discuss options for the 
transition of their legacy contracts. The successful implementation 
of new processes and controls, as well as the transition of 
contracts away from Ibors, reduced the heightened financial and 
non-financial risks to which we were exposed. However, while all 
but exceptional new Libor contract issuance ceased during 2021, 
or from the end of 2021 for US dollar Libor, we remain exposed to 
material risks. These include from so-called ‘tough legacy’ 
contracts, which have not been able to be transition to a new RFR 
rate and will use a ‘synthetic’ Libor or a contractual fallback rate, 
and from legacy contracts that reference the remaining US dollar 
Libor tenors, which are expected to demise from June 2023.

Financial risks have been largely mitigated as a result of the 
implementation of model and pricing changes. However, 
differences in US dollar Libor and its replacement RFR, Secured 
Overnight Funding Rate (‘SOFR’), create a basis risk in the trading 
book and banking book due to the asymmetric adoption of SOFR 
across assets, liabilities and products that we need to actively 
manage through appropriate financial hedging. Additionally, the 
comparatively limited use of the SOFR benchmark for new RFR 
products to date and lack of alignment around conventions could 
potentially delay transition of some US dollar contracts into 2023. 
This would compress the amount of time to transition these 
contracts, which could lead to heightened operational and 
conduct-related risk.

Additional non-financial risks, including regulatory compliance 
risk, resilience risk, financial reporting risk, and legal risk also 
remain for ‘tough legacy’ contracts, and the US dollar legacy 
portfolio. These risks continue to be actively managed and 
mitigated with a focus on ensuring that fair outcomes for our 
clients are achieved.

These risks are present in different degrees across our product 
offering.

Transition of legacy contracts  

During 2021 we successfully transitioned over 90% of legacy Ibor 
lending contracts in sterling, Swiss franc, euro and Japanese yen 
Libor interest rates, as well as Eonia, directly or via appropriate 
fallback mechanisms. The majority of the remaining contracts will 
transition in advance of their next interest payment date, with only 
a small proportion of ‘tough legacy’ contracts remaining. We 
expect that out of approximately 5,000 lending contracts there will 
be less than 50 ‘tough legacy’ contracts, the majority of which will 
be transitioned to alternative rates during 2022. Our approach to 
transition ‘tough legacy’ and US dollar Libor legacy contracts will 

differ by product and business area, but will be based on the 
lessons learned from the successful transition of contracts during 
2021. We will continue to communicate with our clients and 
investors in a structured manner and be client led in the timing 
and nature of the transition. 

For derivatives, approximately 99% of our sterling, Swiss franc, 
euro and Japanese yen Libor interest rate exposures at the end of 
2021 had successfully transitioned directly or via appropriate 
fallback mechanisms, leaving a small number of ‘tough legacy’ 
contracts. Out of the approximately 13,000 bilateral derivatives 
trades there are expected to be less than 20 that remain ‘tough 
legacy’, the majority of which are expected to mature or transition 
in 2022. We anticipate our ‘tough legacy’ and US dollar exposure 
will continue to reduce through 2022 as a result of contract 
maturities, and active transition. We will continue to look to 
actively reduce our US dollar exposure by transitioning trades 
ahead of the demise date of 30 June 2023, by working with our 
clients to determine their needs and discuss how we transition 
their contracts. Additionally, we are working with market 
participants, including clearing houses, to ensure we are able to 
transition our cleared derivative contracts as the US dollar Libor 
benchmark demise date approaches. 

For our loan book, approximately 85% of our reported exposure at 
the end of 2021 linked to sterling, Swiss franc, euro and Japanese 
yen Libor interest rate contracts required no further client 
negotiation but remained drawn as they have yet to reach their 
next interest payment date. The majority of the remaining 
exposure linked to benchmarks that demised from the end of 2021 
relates to contracts where discussions with our clients and other 
market participants, for syndicated transactions, have continued 
into early 2022, in advance of their next scheduled interest 
payment date, and this has led to further transitions being 
completed. A small number of ‘tough legacy’ contracts, less than 
50, that were unable to transition prior to their first interest 
payment date in 2022, are expected to use legislative reliefs, such 
as ‘synthetic’ Libor, or an alternative rate determined by the 
contractual fallback language, and in the main will be transitioned 
during 2022. For the remaining demising Ibors, notably US dollar 
Libor, we have implemented new products and processes and 
updated our systems in readiness for transition. In our US retail 
bank, our mortgage products are offered in SOFR, and the 
transition of legacy contracts will occur once an industry spread 
adjustment is available. Global Banking, Commercial Banking and 
Global Private Banking have begun to engage with clients who 
have upcoming contract maturities with a view to refinancing 
using an appropriate replacement rate. Further communications 
and outreach to customers with US dollar Libor contracts with 
later maturities will occur in due course. 

For the Group’s own debt securities issuances, in 2021 HSBC 
launched a consent solicitation to remediate Ibor references in five 
of its English law governed regulatory capital and MREL sterling 
and Singapore dollar instruments. The proposed amendments 
were successfully adopted on all of the sterling instruments, but 
were not adopted with respect to the Singapore dollar instruments 
as the minimum quorum requirements were not met. The terms of 
these two instruments provide for an Ibor benchmark being used 
to reset the coupon rate if HSBC chooses not to redeem the 
instruments on the respective call date, or dates, for each series. 
We remain mindful of the various factors that impact on the Ibor 
remediation strategy for our regulatory capital and MREL 
instruments, including – but not limited to – timescales for 

cessation of relevant Ibor rates, constraints relating to the 
governing law of outstanding instruments, and the potential 
relevance of legislative solutions. We remain committed in seeking 
to remediate or mitigate relevant risks relating to Ibor-demise, as 
appropriate, on our outstanding regulatory capital and MREL 
instruments before the relevant calculation dates, which may 
occur post-cessation of the relevant Ibor rate or rates. Where we 
hold bonds issued by other institutions, we have remained 
dependent on the issuer’s agents to engage in the transition 
process, although analysis will be undertaken of the issuers in US 
dollar Libor bonds to reduce our exposure, as occurred through 
2021. 

The completion of an orderly transition from the remaining Ibors, 
notably US dollar Libor, continues to be our programme’s key 
objective through 2022 and 2023, with the aim of putting systems 
and processes in place to help achieve this. 

Mitigating actions 

• Our global Ibor transition programme, which is overseen by the 

Group Chief Risk and Compliance Officer, will continue to 
deliver IT and operational processes to meet its objectives.

• We carry out extensive training, communication and client 

engagement to facilitate appropriate selection of new rates and 
products. 

• We have dedicated teams in place to support the transition.

• We actively transitioned legacy contracts and ceased new 

issuance of Libor-based contracts, other than those allowed 
under regulatory exemptions, with associated monitoring and 
controls. 

• We assess, monitor and dynamically manage risks arising from 

Ibor transition, and implement specific mitigating controls 
when required.

• We continue to actively engage with regulatory and industry 
bodies to mitigate risks relating to ‘tough legacy’ contracts.

Financial instruments impacted by Ibor reform

(Audited)

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.

HSBC Holdings plc Annual Report and Accounts 2021

127

Risk reviewRisk

At 31 Dec 2021

Non-derivative financial assets

Loans and advances to customers

Other financial assets
Total non-derivative financial assets2

Non-derivative financial liabilities

Financial liabilities designated at fair value

Debt securities in issue

Other financial liabilities

Total non-derivative financial liabilities

Derivative notional contract amount

Foreign exchange

Interest rate

Others

Total derivative notional contract amount

At 31 Dec 2020

Non-derivative financial assets

Loans and advances to customers

Other financial assets
Total non-derivative financial assets2

Non-derivative financial liabilities

Financial liabilities designated at fair value

Debt securities in issue

Other financial liabilities

Total non-derivative financial liabilities

Derivative notional contract amount

Foreign exchange

Interest rate

Others

Total derivative notional contract amount

Financial instruments yet to transition to alternative 
benchmarks, by main benchmark

USD Libor

GBP Libor

JPY Libor

$m

$m

$m

70,932   

18,307   

5,131   

1,098   

76,063   

19,405   

370   

—   

370   

20,219   

4,019   

1,399   

5,255   

2,998   

—   

78   

—   

—   

28,472   

4,097   

1,399   

Others1

$m

8,259 

2 

8,261 

1 

— 

— 

1 

137,188   

5,157   

31,470   

9,652 

  2,318,613   

284,898   

72,229   

133,667 

—   

—   

—   

— 

  2,455,801   

290,055   

103,699   

143,319 

85,378   

8,770   

94,148   

43,681   

2,906   

46,587   

371   

—   

371   

10,751 

12 

10,763 

24,350   

5,840   

3,412   

33,602   

6,219   

1,548   

—   

964   

—   

—   

7,183   

1,548   

128 

416 

5 

549 

196,774   

6,374   

28,411   

2,848,552   

1,190,491   

479,789   

11   

—   

—   

22,762 

492,197 

— 

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, THBFIX 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 beyond the date by which the 
reference interest rate benchmark is expected to cease; and

• are recognised on HSBC’s consolidated balance sheet.

In March 2021, the administrator of Libor, IBA, announced that the 
publication date of most US dollar Libor tenors has been extended 
from 31 December 2021 to 30 June 2023. Publication of one-week 
and two-month tenors ceased after 31 December 2021. This 
change, together with the extended publication dates of Sibor, 
SOR and THBFIX, reduce the amounts presented at 31 December 
2021 in the above table as some financial instruments included at 
31 December 2020 will reach their contractual maturity date prior 
to the extended publication dates. Comparative data have not 
been re-presented.

128

HSBC Holdings plc Annual Report and Accounts 2021

Financial crime risk environment

Financial institutions remain under considerable regulatory 
scrutiny regarding their ability to prevent and detect financial 
crime. The financial crime threats we face have continued to 
evolve, often in tandem with broader geopolitical, socioeconomic 
and technological shifts in our markets, leading to challenges such 
as managing conflicting laws and approaches to legal and 
regulatory regimes. 

Financial crime risk evolved during the Covid-19 pandemic, 
notably with the manifestation of fraud risks linked to the 
economic slowdown and resulting deployment of government 
relief measures. The accelerated digitisation of financial services 
has fostered significant changes to the payments ecosystem, 
including a multiplicity of providers and new payment 
mechanisms, not all of which are subject to the same level of 
regulatory scrutiny or regulations as financial institutions. This is 
presenting increasing challenges to the industry in terms of 
maintaining required levels of transparency, notably where 
institutions serve as intermediaries. Developments around digital 
assets and currencies, notably the role of stablecoins and central 
bank digital currencies, have continued at pace, with an increasing 
regulatory and enforcement focus on the financial crimes linked to 
these types of assets. 

Expectations with respect to the intersection of ESG issues and 
financial crime as our organisation, customers and suppliers 
transition to net zero, are increasing, not least with respect to 
potential ‘greenwashing’. Companies also face a heightened 
regulatory focus on both human rights issues and environmental 
crimes from a financial crime perspective. We also continue to 
face increasing challenges presented by national data privacy 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
requirements, which may affect our ability to manage financial 
crime risks holistically and effectively.   

Mitigating actions

• We are strengthening our fraud and surveillance controls, and 
investing in next generation capabilities to fight financial crime 
through the application of advanced analytics and artificial 
intelligence (‘AI’). 

• We are looking at the impact of a rapidly changing payments 
ecosystem to ensure our financial crime controls remain 
appropriate for changes in customer behaviour and gaps in 
regulatory coverage, including the development of procedures 
and controls to manage the risks associated with direct and 
indirect exposure to digital assets and currencies. 

• We are assessing our existing policies and control framework 
to ensure that developments in the ESG space are considered 
and the risks mitigated.

• We 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 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, notably with 
respect to the enhanced, and transparent, use of technology. 

Regulatory compliance risk environment including 
conduct

We keep abreast of the emerging regulatory compliance and 
conduct agenda, which currently includes, but is not limited to: 
ESG matters; operational resilience; how digital and technology 
changes, including payments, are impacting financial institutions; 
how we are ensuring good customer outcomes, including 
addressing customer vulnerabilities; regulatory reporting; and 
employee compliance. We monitor regulatory developments 
closely and engage with regulators, as appropriate, to help ensure 
new regulatory requirements are implemented effectively and in a 
timely way.

The competitive landscape in which the Group operates may be 
impacted by future regulatory changes and government 
intervention. In the UK, potential regulatory developments include 
any legislative changes resulting from a statutory review of ring-
fencing, which has been undertaken by an independent panel 
appointed by HM Treasury. The panel has recommended several 
adjustments to the regime and HM Treasury is reviewing these 
recommendations. Legislative amendments may be proposed in 
due course. 

Mitigating actions

• We monitor for regulatory developments to understand the 

evolving regulatory landscape and respond with changes in a 
timely way.

• We engage, wherever possible, with governments and 

regulators to make a positive contribution to regulations and 
ensure that new requirements are considered properly and can 
be implemented effectively. We hold regular meetings with 
relevant authorities to discuss strategic contingency plans, 
including those arising from geopolitical issues.  

• We launched our simplified conduct approach to align to our 
new purpose and values, in particular the value ‘we take 
responsibility’.

Cyber threat and unauthorised access to systems

Together with other organisations, we continue to operate in an 
increasingly hostile cyber threat environment. This requires 
ongoing investment in business and technical controls to defend 
against these threats, including potential unauthorised access to 
customer accounts, attacks on our systems, and attacks on our 
third-party suppliers.

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 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 industry bodies and working groups 
to collaborate on tactics employed by cyber-crime groups and 
to collaborate in fighting, detecting and preventing cyber-
attacks on financial organisations.

Digitalisation and technological advances 

Developments in technology and changes in regulations are 
enabling new entrants to the industry. This challenges HSBC to 
continue to innovate and optimise in order to take advantage of 
new digital capabilities to best serve our customers, and adapt our 
products to attract and retain customers. As a result, we may need 
to increase our investment in our business to modify or adapt our 
existing products and services or develop new products and 
services to respond to our customers’ needs.

Mitigating actions:

• We continue to monitor this emerging risk, as well as the 

advances in technology, and changes in customer behaviours 
to understand how these may impact our business. 

• We closely monitor and assess financial crime and the impact 

on payment transparency and architecture.

Internally driven

Data management

We use a large number of systems and growing quantities of data 
to support our customers. Risk arises if data is incorrect, 
unavailable, misused, or unprotected. Along with other banks and 
financial institutions, we need to meet external regulatory 
obligations and laws that cover data, such as the Basel Committee 
on Banking Supervision’s 239 guidelines and the General Data 
Protection Regulation (‘GDPR’).

Mitigating actions 

• Through our global data management framework, we monitor 
proactively the quality, availability and security of data that 
supports our customers and internal processes. We resolve any 
identified data issues in a timely manner.

• We have made improvements to our data policies and are 

implementing an updated control framework to enhance the 
end-to-end management of data risk by our global businesses, 
global functions and regions.

• We protect customer data via our data privacy framework, 

which establishes practices, design principles and guidelines 
that enable us to demonstrate compliance with data privacy 
laws and regulations.

• We continue to modernise our data and analytics infrastructure 
through investments in Cloud technology, data visualisation, 
machine learning and AI.

• We educate our employees on data risk and data management 

and have delivered global mandatory training on the 
importance of protecting data and managing data 
appropriately.

HSBC Holdings plc Annual Report and Accounts 2021

129

Risk reviewRisk

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. This 
included GDP; unemployment rates; housing prices; and the 
varying government support measures introduced. 

We prioritised the redevelopment of internal ratings-based (‘IRB’) 
and internal model 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. Submission of these models to the UK’s 
Prudential Regulation Authority (‘PRA’) and other key regulators 
for feedback and approval is in progress. Some IMM and internal 
model approach (‘IMA’) models have been approved for use and 
feedback has been received for some IRB models. Climate risk 
modelling is a key focus for the Group as HSBC’s commitment to 
sustainability has become a critical part of the Group’s strategy.

Mitigating actions

• We further enhanced the monitoring, review and challenge 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.

• Model Risk Management works closely with businesses to 
ensure that IRB/IMM/IMA models in development meet risk 
management, pricing and capital management needs. Global 
Internal Audit provides assurance over the risk management 
framework for models.

• Additional assurance work is performed by the model risk 

governance teams, which act as second lines of defence. The 
teams test whether controls implemented by model users 
comply with model risk policy and if model risk standards are 
adequate.

• Models using advanced machine learning techniques are 
validated and monitored to ensure that risks that are 
determined by the algorithms have adequate oversight and 
review.

Risks arising from the receipt of services from 
third parties

We use third parties to provide a range of goods and services. 
Risks arising from the use of third-party providers and their supply 
chain may be harder to identify. It is critical that we ensure we 
have appropriate risk management policies, processes and 
practices over the selection, governance and oversight of third 
parties and their supply chain, particularly for key activities that 
could affect our operational resilience. Any deficiency in the 
management of risks associated with our third parties could affect 
our ability to support our customers and meet regulatory 
expectations.

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. A 
very competitive employment market will continue to test our 
ability to attract and retain talent. Changed working arrangements, 
local Covid-19 restrictions and health concerns during the 
pandemic have also impacted 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 pandemic. 
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 encourage 
our people leaders to focus on talent retention at all levels, with 
an empathetic mindset and approach, while ensuring the whole 
proposition of working at HSBC is well understood.

• Our Future Skills curriculum helps 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.

IT systems infrastructure and resilience

We operate an extensive and complex technology landscape, 
which must remain resilient in order to support customers, the 
organisation and markets globally. Risks arise where technology is 
not understood or maintained, and development of technology is 
not controlled.   

Mitigating actions

• We continue to invest in transforming how software solutions 
are developed, delivered and maintained. We concentrate on 
improving system resilience and service continuity testing. We 
continue to ensure security is built into our software 
development life cycle and improve our testing processes and 
tools. 

• We continue to upgrade many of our IT systems, simplify our 

service provision and replace older IT infrastructure and 
applications. These enhancements supported global 
improvements in service availability during 2021 for both our 
customers and colleagues.

Change execution risk

We have continued our increased investment in strategic change 
to support the delivery of our strategic priorities and regulatory 
commitments. This requires change to be executed safely and 
efficiently. 

Mitigating actions

Mitigating actions

• We have enhanced our control framework for external supplier 
arrangements to ensure the risks associated with third-party 
arrangements are understood and managed effectively by our 
global businesses, global functions and regions.   

• We have applied the same control standards to intra-group 

arrangements as we have for external third-party arrangements 
to ensure we are managing them effectively.

• We are implementing the changes required by the new global 

third-party risk policy to comply with new regulations as 
defined by our regulators.

• A global transformation programme is progressing with the 
delivery of strategic change commitments made in February 
2020 to restructure our business, reallocate capital into higher 
growth and higher return businesses and markets, and to 
simplify our organisation to improve operational resilience and 
reduce costs.

• The remit of the Transformation Oversight Executive 
Committee, established in 2020 to oversee the global 
transformation programme, was expanded in 2021 to oversee 
the prioritisation, strategic alignment and management of 
execution risk for all change portfolios and initiatives.

130

HSBC Holdings plc Annual Report and Accounts 2021

• We continue to work to strengthen our change management 
practices to deliver sustainable change, increased adoption of 
Agile ways of working, and a more consistent standard of 
delivery. The Transformation Oversight Executive Committee 
oversees the continued embedding of our improved Group-
wide change framework released in May 2021, which sets out 
the mandatory principles and standards relating to leading and 
delivering change.

Areas of special interest

During 2021, 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 pandemic and climate-related 
risks.

Risks related to Covid-19 

Despite the successful roll-out of vaccines around the world, the 
Covid-19 pandemic and its effect on the global economy have 
continued to impact our customers and organisation. The global 
vaccination roll-out in 2021 helped reduce the social and economic 
impact of the Covid-19 pandemic, although there has been 
significant divergence in the speed at which vaccines have been 
deployed around the world. Most developed countries have now 
vaccinated a large proportion of their populations, but many less 
developed countries have struggled to secure supplies and are at 
an earlier stage of their roll-out. By the end of 2021, high 
vaccination rates had ensured that many Covid-19-related 
restrictions on activity in developed markets had been lifted and 
travel constraints were easing. However, the emergence of the 
Omicron variant in late 2021 demonstrated the continued risk new 
variants pose. 

The pandemic necessitated governments to respond at 
unprecedented levels to protect public health, and to support local 
economies and livelihoods. The resulting government support 
measures and restrictions created additional challenges, given the 
rapid pace of change and significant operational demands. 
Renewed outbreaks, particularly those resulting from the 
emergence of variants of the virus, emphasise the ongoing threat 
of Covid-19 and could result in further tightening of government 
restrictions. There remains a divergence in approach taken by 
countries to the level of restrictions on activity and travel. Such 
diverging approaches to future pandemic waves could prolong or 
worsen supply chain and international travel disruptions. The 
evolving Covid-19 restrictions in Hong Kong, including travel, 
public gathering and social distancing restrictions, are impacting 
the Hong Kong economy, and may affect the ability to attract and 
retain staff.

We continue to support our personal and business customers 
through market-specific measures initiated during the Covid-19 
pandemic, and by supporting those remaining national 
government schemes that focus on the parts of the economy most 
impacted by the pandemic. For further details of our customer 
relief programmes, see page 159.

The rapid introduction and varying nature of the government 
support schemes introduced throughout the Covid-19 pandemic 
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 remaining government support schemes are unwound. 
These events have also led to increased litigation risk.

The impact of the pandemic on the long-term prospects of 
businesses in the most vulnerable sectors of the economy – such 
as retail, hospitality, travel and commercial real estate – remains 
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. 

As economic conditions improve, and government support 
measures come to an end, there is a risk that the outputs of IFRS 9 

models may have a tendency to underestimate loan losses. To 
help mitigate this risk, model outputs and management 
adjustments are closely monitored and independently reviewed at 
the Group and country level for reliability and appropriateness. For 
further details on model risk, see page 209.

Despite the ongoing economic recovery, significant uncertainties 
remain in assessing the duration and impact of the Covid-19 
pandemic, including whether any subsequent outbreaks result in a 
reimposition of government restrictions. There is a risk that 
economic activity remains below pre-pandemic levels for a 
prolonged period, increasing inequality across markets, and it will 
likely be some time before societies return to pre-pandemic levels 
of social interactions. As a result, there may still be a requirement 
for additional mitigating actions including further use of 
adjustments, overlays and model redevelopment.

Governments and central banks in major economies have 
deployed extensive measures to support their local populations. 
This is expected to reverse partially in 2022. Central banks in major 
markets are expected to raise interest rates, but such increases are 
expected to be gradual and monetary policy is expected to remain 
accommodative overall. Policy tightening in major emerging 
markets has already begun in order to counteract rising inflation 
and the risk of capital outflows. Governments are also expected to 
reduce the level of fiscal support they offer households and 
businesses as the appetite for broad lockdowns and public health 
restrictions decreases. Government debt has risen in most 
advanced economies, and is expected to remain high into the 
medium term. High government debt burdens have raised fiscal 
vulnerabilities, increasing the sensitivity of debt service costs to 
interest rate increases and potentially reducing the fiscal space 
available to address future economic downturns. Our Central 
scenario used to calculate impairment assumes that economic 
activity will continue to recover through 2022, surpassing peak 
pre-pandemic levels of GDP in all our key markets. It is assumed 
that private sector growth accelerates, ensuring a strong recovery 
is sustained even as pandemic-related fiscal support is withdrawn. 
However, 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 of ECL estimates’ on page 144.

We continue to monitor the situation closely, and given the novel 
and prolonged nature of the pandemic, additional mitigating 
actions may be required.

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 net zero 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 our customers 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. 

How climate risk can impact our customers

Climate change could impact our customers in two main ways. 
Firstly, customer business models may fail to align to a net zero 
economy, which could mean that new climate-related regulation 
would have a material impact on their business. Secondly, 
extreme weather events or chronic changes in weather patterns 

HSBC Holdings plc Annual Report and Accounts 2021

131

Risk reviewRisk

may damage our customers’ assets leaving them unable to 
operate their business or potentially even live in their home.

One of the most valuable ways we can help our customers 
navigate the transition challenges and to become more resilient to 
the physical impacts of climate change is through financing and 
investment. To do this effectively, we must understand the risks 
they are facing. 

The table below summarises the key categories of transition and 
physical risk, with examples of how our customers might be 
affected financially by climate change and the shift to a low-
carbon economy. 

Climate risk

Transition

Policy and 
legal

Technology

End-demand 
(market)
Reputational

Physical

Acute

Main causes of financial impact on customers

Mandates on, and regulation of, existing 
products and services 
Litigation from parties who have suffered 
from the effects of climate change
Replacement of existing products with lower 
emission options
Changing consumer behaviour

Increased scrutiny following a change in 
stakeholder perceptions of climate-related 
action or inaction

Increased frequency and severity of weather 
events

Chronic

Changes in precipitation patterns
Rising temperatures

For further details on how we manage climate risk for our other 
stakeholders, see the ESG review on page 56. 

Integrating climate into enterprise-wide risk management

Our approach to climate risk management is aligned to our Group-
wide risk management framework and three lines of defence 
model, which sets out how we identify, assess and manage our 
risks. This approach ensures the Board and senior management 
have visibility and oversight of our key climate risks. 

Climate risk appetite

Our developing climate risk appetite measures support the 
oversight and management of the financial and non-financial risks 
from climate change, meet regulatory expectations and support 
the business to deliver our climate ambition in a safe and 
sustainable way. Our initial measures are focused on the oversight 
and management of our key climate risks: wholesale credit risk, 
retail credit risk, reputational risk, resilience risk and regulatory 
compliance. These measures are implemented at a global and 
regional level. We continue to develop climate risk appetite 
measures and our future ambition for our climate risk appetite is 
to:

• adapt the risk appetite metrics to incorporate forward-looking 

transition plans and net zero commitments;

• expand metrics to consider other financial and non-financial 

risks; and

• use enhanced scenario analysis capabilities.

Climate risk policies, processes and controls

We are integrating climate risk into the policies, processes and 
controls for our key climate risks and we will continue to update 
these as our climate risk management capabilities mature over 
time. We have updated our policy on product management, and 
developed the first version of a climate risk scoring tool for our 
corporate portfolios. In addition, we published and started to 
implement our new thermal coal phase-out policy. For further 
details on our thermal coal phase-out policy, see page 62.

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HSBC Holdings plc Annual Report and Accounts 2021

Climate risk governance and reporting

Our global and regional Climate Risk Oversight Forums are 
responsible for the oversight, management and escalation of 
climate risks across the Group and are supported by specific 
forums for our global businesses, as well as for our Risk and 
Compliance function. These include the Sustainability Risk 
Oversight Forum, the WPB Risk Management Meeting and the 
Regulatory Compliance ESG and Climate Risk Working Group. 

Our climate risk management information dashboard includes 
metrics relating to our key climate risks, and is reported to the 
Group Climate Risk Oversight Forum. The Group Risk 
Management Meeting and the Group Risk Committee receive 
scheduled updates on climate risk, and receive regular updates on 
our climate risk appetite and top and emerging climate risks.

For further details on the Group’s ESG governance structure, see 
page 80.

The Group Chief Risk and Compliance Officer is the key senior 
manager responsible for the management of climate-related 
financial risks under the UK Senior Managers Regime. The Group 
Chief Risk and Compliance Officer is the overall accountable 
executive for the Group’s climate risk programme, including 
responsibility for governance, risk management, stress testing and 
scenario analysis and disclosures.

Climate risk programme

Our dedicated programme continues to accelerate the 
development of our climate risk management capabilities. The key 
achievements in 2021 include: 

• We delivered tailored training sessions to our legal entity 

boards.

• We delivered training to colleagues across the three lines of 
defence so they can understand climate risk as part of their 
role, and we also included an introduction to our climate 
ambition in our global mandatory training.

• We developed our climate risk scoring tool for corporate 
customers for use in priority regions, which builds on our 
corporate transition questionnaire.

• We introduced a risk appetite based on monitoring climate risk 
exposure at property level across the UK mortgage portfolio.

• We have continued to develop our climate stress testing and 
scenarios capabilities, including model development and 
delivered regulatory climate stress tests. These are being used 
to further improve our understanding of our risk exposures for 
use in risk management and business decision making. For 
more detail on our approach to climate stress testing and 
scenario analysis, see page 57.

We will continue to enhance our climate risk management 
capabilities throughout 2022. This will include the further roll-out 
of training, refinement of our risk appetite, enhancement of our 
climate risk scoring tool and increasing the availability and quality 
of data so that new metrics can be developed.

How climate risk can impact HSBC

Below, we provide details on how climate risk impacts to our 
customers might manifest across our key climate risks, and the 
potential timeframes involved using the TCFD’s four main drivers 
of transition climate risk – policy and legal, technology, end-
demand (market) and reputational – and two physical risk drivers – 
acute and chronic. 

Risk management framework

Risk type

Timescale1
Transition risk drivers2
–  policy and legal

–  technology

–  end-demand (market)

–  reputational
Physical risk drivers2
–  acute – increased frequency and severity of weather events

–  chronic – changes in weather patterns

Financial risks

Non-financial risk

Wholesale 
credit

Retail credit

Strategic risk 
(reputational)

Resilience risk

Regulatory 
compliance risk

All term 
periods

Medium–long 
term

All term 
periods

All term 
periods

Short–medium

l
l
l
l

l
l

l

l
l

l
l

l

l
l

l

1  Short-term: less than one year; medium term: period to 2030; long term: period to 2050. 
2  Transition and physical risk drivers defined by TCFD.

Wholesale credit risk

Identification and assessment

We have identified six key sectors where our wholesale credit 
customers have the highest climate risk, based on their carbon 
emissions. These are oil and gas, building and construction, 
chemicals, automotive, power and utilities, and metals and 
mining. We continue to roll out our transition and physical risk 
questionnaire to our largest customers in high-risk sectors, with 
the addition of four more sectors: agriculture, manufacturing, real 
estate and transportation. The questionnaires will help us to 
assess and improve our understanding of the impact of climate 
changes on our customers’ business models and any related 
transition strategies. It also helps us to identify potential business 
opportunities to support the transition. In 2022, we intend to 
increase the scope of the questionnaires by adding more countries 
to the scope.

Management

In 2021, we developed a scoring tool, which provides a climate 
risk score for each customer based on questionnaire responses. 
The climate risk score will then be used in portfolio level 
management information to assess and compare clients. The 
scoring tool will be enhanced and refined over time as more data 
becomes available. The results of the tool have been provided to 
business and risk management teams. During 2021, we also 
performed a climate-related stress test, as explained further on 
page 58. In 2022 we aim to further embed climate risk 
considerations in our credit risk management processes. 
Aggregation and reporting

We currently internally report our transition risk exposure and 
RWAs consumed by the six high-risk sectors in the wholesale 
portfolio. 

We also report the proportion of questionnaire responses that 
reported either having a board policy or management plan for 
transition risk. Our key wholesale credit exposures are included as 
part of our broader ESG management information dashboard, 
which is presented to the Group Executive Committee each 
quarter. In addition, a representative from wholesale credit risk 
attends the Global Climate Risk Oversight Forum to ensure 
consideration of this risk type, and we report our exposure through 
the climate risk management information dashboard at this 
meeting.

We will continue to report these metrics in 2022 and will aim to 
cascade these measures to global businesses and to provide 
insight on the climate risk profile of our portfolio and customers.

In the table below, we capture our lending activity, including 
environmentally responsible and sustainable finance activities, to 
customers within the six high risk sectors. Green financing for 
large companies that work in high transition sectors is also 
included. The overall exposure has increased slightly to 20.0% 
(2020:19.6%). For further details on how we designate 
counterparties as high transition risk, see footnote 2. 

Since 2019, we have received responses from customers within 
the six high transition risk sectors, which represent 56% of our 
exposure, an increase in coverage of 15% since last year. The 
breakdown of our customer responses is presented by sector in 
the table below. 

Within the power and utilities, and metals and mining sectors 
shown in the table below, and recognising external third-party 
assessments of power generation and mining capacity, our 
exposure to thermal coal is 0.2% of the total wholesale loans and 
advances figures.

Wholesale loan exposure to transition risk sectors and customer questionnaire responses at 31 December 2021

Automotive

Chemicals

Construction 
and building 
materials 

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 either having a 
board policy or a management plan4

Sector weight as proportion of high transition risk sector4

≤ 2.8

≤ 3.4

≤ 4.5

≤ 2.4

≤ 3.4

≤ 3.5

≤ 20.0

59

65

14

44

76

17

56

76

22

52

57

12

64

77

17

59

90

18

56

75

100

1  Amounts shown in the table also include green and other sustainable finance loans, which support the transition to the net zero 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. For Global Banking and Markets clients, the main business of a group of connected 
counterparties is identified by the relationship manager for the group. For Commercial Banking clients, the main business of a group of connected 
counterparties is identified based on the largest industry of HSBC’s total lending limits to the group. 

3  Total wholesale loans and advances to customers and banks amount to $662bn (2020: $673bn).
4  All percentages are weighted by exposure.

HSBC Holdings plc Annual Report and Accounts 2021

133

Risk reviewRisk

Retail credit risk

Identification and assessment

We manage retail credit risk under a framework of controls that 
enable the identification and assessment of credit risk across the 
retail portfolio.

In 2021, we completed a Group-wide climate scenario analysis 
and stress testing exercise. This enabled us to enhance our 
understanding and assess the impact of physical risk to our 
mortgage portfolio under three potential future climate scenarios, 
with a focus on the UK, Hong Kong and Canada.

Additionally, for the UK mortgage portfolio, we considered the 
impact of potential minimum energy performance certificate 
(‘EPC’) rating requirements, as well as changes to the availability 
of buildings insurance following the demise of FloodRe. These 
factors were considered alongside macroeconomic drivers, given 
the supplemental data available for the UK.

FloodRe is a scheme between the UK Government and the 
insurance industry that aims to improve the availability and 
affordability of flood cover for properties in high flood risk areas. It 
is currently in place until 2039.

Understanding the impact of future climate risk relies heavily upon 
the availability of quality data, as well as on the evolution of 
climate risk modelling expertise. As this matures, we plan to 
expand our approach to additional markets. 

Management

We are focusing on embedding climate risk into retail credit risk 
management processes, prioritising the largest residential 
mortgage portfolios.

We continue to update our risk management framework to reflect 
lessons learnt.

Aggregation and reporting

We manage and monitor the integration of climate risk across 
Wealth and Personal Banking through the Risk Management 
Meeting.

We have also developed and are implementing metrics to support 
active risk management, which will be tracked and monitored 
through relevant credit risk meetings. 

A representative from Retail Credit Risk attends the Group Climate 
Risk Oversight Forum to ensure this risk type is considered. 

How we are starting to measure climate risk 

We are starting to measure climate risk with the most material 
market, which is the UK, where the primary risk facing properties 
is flooding.

Using a risk methodology that considers a combination of the 
likelihood and severity of flood hazard affecting individual 
properties, we estimate that on a total volume basis, and at 
present day levels, 3.5% of the UK retail banking mortgage 
portfolio is at high risk of flooding, and 0.3% is at a very high risk. 
This is based on 94% coverage of our mortgage portfolio and is 
reliant on flood data provided by Ambiental Risk Analytics, flood 
risk experts and suppliers of flood models to more than 50% of the 
UK insurance industry.

This data will enable monitoring and reporting of properties at risk 
of flooding, which will support activities to educate impacted 
customers and protect the Group from incurring losses as a result 
of climate events.

Our transition risk efforts in the UK have focused on obtaining 
current and potential energy efficiency ratings for individual 
properties, sourced from property EPC data. 

The UK Government has a stated ambition to improve the EPC 
ratings of housing stock as set out in its Clean Growth Strategy.  
We are working towards improving the proportion of properties on 
our book with an EPC rating of C or above and on improving the 
EPC data coverage.

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HSBC Holdings plc Annual Report and Accounts 2021

We have approximately 53% of properties in our portfolio with a 
valid EPC certificate (i.e. dated within the last 10 years) and 35.7% 
of these are rated A to C. 

For further details and metrics relating to physical and transition 
risk to our UK mortgage portfolio, see our ESG Data Pack at 
www.hsbc.com/esg.

Reputational risk

Identification and assessment

We implement sustainability risk policies, including the Equator 
Principles, as part of our broader reputational risk framework. We 
focus on sensitive sectors that may have a high adverse impact on 
people or the environment, and in which we have a significant 
number of customers. A key area of focus is high-carbon sectors, 
which include oil and gas, power generation, mining, agricultural 
commodities and forestry. During 2021 we published our thermal 
coal phase-out policy. 

Management

As the primary point of contact for our customers, our relationship 
managers are responsible for checking that our customers meet 
policies aimed at reducing carbon impacts. Our global network of 
more than 75 sustainability risk managers provides local policy 
support and expertise to relationship managers. A central 
Sustainability Risk team provides a higher level of guidance and is 
responsible for the oversight of policy compliance and 
implementation over wholesale banking activities. During 2021, 
we introduced a refreshed assurance framework, which takes a 
risk-based approach focusing on higher risks. 

For further details on our sustainability risk policies, see our ESG 
review on page 62.

Aggregation and reporting

Our Sustainability Risk Oversight Forum provides a Group-wide 
forum for senior members of our Global Risk and Compliance 
team and global businesses. It also oversees the development and 
implementation of sustainability risk policies. Cases involving 
complex sustainability risk issues related to customers, 
transactions or third parties are managed through the reputational 
risk and client selection governance process. We report annually 
on our implementation of the Equator Principles and the corporate 
loans, project-related bridge loans and advisory mandates 
completed under the principles. With the introduction of Equator 
Principles IV, a training programme was delivered to raise the 
awareness of the changes and obligations therein. 

For the latest report, see: www.hsbc.com/who-we-are/our-climate-
strategy/sustainability-risk/equator-principles.

A representative from Reputational risk attends the Group Climate 
Risk Forum to ensure consideration of this risk type. 

Regulatory compliance risk

Identification and assessment

Compliance, as a sub-function within Group Risk and Compliance, 
continues to prioritise the identification and assessment of 
compliance risks that may arise from climate risk. Although not an 
exhaustive list, key regulatory compliance risks under 
consideration include those related to product management, mis-
selling, marketing, conflicts of interest and regulatory change.

An area of particular focus is the risk of greenwashing. We regard 
greenwashing as the act of knowingly or unknowingly misleading 
stakeholders regarding our climate ambition, the climate impact/
benefits of a product or service or regarding the climate 
commitments of our customers. For the Compliance function, 
product-based greenwashing is a key area of focus. When 
considering product-based greenwashing, we seek to:

• effectively and consistently consider climate risk factors in the 
development and ongoing governance of new, changed or 
withdrawn products and services through the enhancement of 
existing risk management frameworks utilised within the 
Group’s operating entities and lines of business, enabling 
climate risks to be identified and assessed in a timely manner; 

• ensure that climate-related products and services offered to 
customers are appropriately designed and that related sales 
practices and marketing materials are clear, fair and not 
misleading; and 

• develop climate-related products and services consistent with 
the evolving expectations of the Group’s regulators and other 
relevant authorities.

Management

We continue to develop our compliance policies and underlying 
measurement capability to enhance the management of climate 
risks in line with our climate ambition and risk appetite. As such, 
we have integrated and are continuing to enhance climate risk 
considerations within our product and customer life-cycle policies.  
Our policies set the minimum standards that are required to 
manage the risk of breaches of our regulatory duty to customers, 
including those related to climate risk, ensuring fair customer 
outcomes are achieved.

The Compliance sub-function placed significant focus in 2021 on 
supporting and improving the capability of Compliance colleagues 
through climate-specific training, communications and guidance 
materials to ensure the robust identification, assessment and 
management of climate risks. 

Aggregation and reporting

The Compliance sub-function continues to operate an ESG and 
Climate Risk Working Group. This group tracks and monitors the 
integration and embedding of Climate risk within the management 
of regulatory compliance risks and controls more generally, and 
monitors ongoing regulatory and legislative changes across the 
sustainability and climate risk agenda. 

We have also developed and implemented climate risk metrics 
and indicators aligned to wider regulatory compliance risks. 

Our material banking risks

The Compliance sub-function is also represented at the Group’s 
Climate Risk Oversight Forum to ensure this risk type is 
considered.

Resilience risk

Identification and assessment

Our assessment of climate risk identified building unavailability, 
workplace safety, information technology and cybersecurity risk, 
transaction processing risk, and third-party risk as the key risks 
facing our operational resilience. 

In 2021 we repeated and extended our scenario stress testing. We 
will continue to work with our partners to identify and assess 
emerging climate risks.

Management

In 2021, we reviewed existing policies, processes and controls, 
which were then revised as required. This work will continue in 
subsequent years.

Identification of new tooling, both internally and through 
collaboration with business partners, for the management of 
climate risk is ongoing with new tooling being introduced as 
appropriate. 

Our stress test results will continue to inform our approach to 
climate risk management.

Aggregation and reporting

Our exposure to climate risk will continue to be aggregated and 
reported to the Group Climate Risk Forum and other relevant 
formal governance forums.

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 137)
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 189)
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, together with pension 
and insurance risk.

Market risk (see page 203)
Market risk is the risk of an 
adverse financial impact on 
trading activities arising from 
changes in market parameters 
such as interest rates, foreign 
exchange rates, asset prices, 
volatilities, correlations and 
credit spreads.

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 the 
external environment

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. 

HSBC Holdings plc Annual Report and Accounts 2021

135

Risk reviewRisk

Description of risks – banking operations (continued)

Risks

Arising from

Measurement, monitoring and management of risk

Resilience risk (see page 207)
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 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 208)
Regulatory compliance risk is 
the risk associated with 
breaching our duty to clients 
and other counterparties, 
inappropriate market conduct 
and breaching related financial 
services regulatory standards.

Regulatory compliance risk 
arises from the failure to 
observe relevant laws, codes, 
rules and regulations and can 
manifest itself in poor market or 
customer outcomes and lead to 
fines, penalties and reputational 
damage to our business. 

Financial crime risk arises from 
day-to-day banking operations 
involving customers, third 
parties and employees. 

Financial crime risk (see page 208)
Financial crime risk is the risk of 
knowingly or unknowingly 
helping parties to commit or to 
further potentially illegal activity 
through HSBC, including 
money laundering, fraud, 
bribery and corruption, tax 
evasion, sanctions breaches, 
and terrorist and proliferation 
financing.

Model risk (see page 209)
Model risk is the risk of 
inappropriate or incorrect 
business decisions arising from 
the use of models that have 
been inadequately designed, 
implemented or used or that 
model does not perform in line 
with expectations and 
predictions.

Model risk arises in both 
financial and non-financial 
contexts whenever business 
decision making includes 
reliance on models. 

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 of, and assessment by, our 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.

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 214)
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 216)
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.

136

HSBC Holdings plc Annual Report and Accounts 2021

 
 
Credit risk 

Overview

Credit risk management

Credit risk in 2021

Summary of credit risk

Stage 2 decomposition as at December 2021

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

137

137

139

  140 

143

143

144

152

155

159

162

176

183

188

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 2021

There were no material changes to the policies and practices 
for the management of credit risk in 2021. We continued to apply 
the requirements of IFRS 9 ‘Financial Instruments’ within the 
Credit Risk sub-function.

Due to the Covid-19 pandemic and its continued effects on the 
global economy we provided short-term support to customers 
through market-specific measures under the current credit policy 
framework. We have also implemented the guidance provided by 
regulators on managing the credit portfolio as required throughout 
the course of the customer relief life cycle.

The extent of our support depends on the degree of country-
specific government support measures, restrictions, associated 
policy responses, and the effects of new Covid-19 variants.

The majority of the customer relief programmes that we provided 
during the Covid-19 pandemic ended by 31 December 2021 and 
will not be reassessed under the revised definition of default. For 
further details of market-specific measures to support our personal 
and business customers, see page 159.

In the second half of 2021, market concerns regarding China’s 
commercial real estate sector emerged. At 31 December 2021 we 
had no direct exposures to developers in the ‘red’ category under 
the Chinese government’s ‘three red lines’ framework used to 
govern the real estate sector. We continue to monitor the situation 
closely, including potential indirect impacts that may arise, and 
seek to take mitigating actions as required under our existing 
policy framework. 

During 2021, we adopted the EBA ‘Guidelines on the application 
of definition of default’ for our wholesale portfolios. This did not 
have a material impact on our wholesale portfolios. For our retail 
portfolios, these guidelines will be adopted in 2022 and this is not 
expected to have a material impact. 

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 actions, 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 and Compliance 
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

The IFRS 9 process comprises three main areas: modelling and 
data; implementation; and governance.

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 
relevant global business Chief Financial Officer and the Global 
Financial Controller.

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 
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 

HSBC Holdings plc Annual Report and Accounts 2021

137

Risk reviewRisk

wholesale and retail customers, 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.

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

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.

Credit quality classification

Retail lending credit quality is based on a 12-month point-in-time 
probability-weighted PD.

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

Quality classification1,2
Strong

Good

Satisfactory

Sub-standard

Credit impaired

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

Renegotiated loans and recognition of expected credit losses

(Audited)

(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 
under our existing disclosures. 

Loans that have been identified as renegotiated retain this 
designation until maturity or derecognition under our existing 
disclosures. 

For details of our policy on derecognised renegotiated loans, see Note 1.2(i) 
on the financial statements.

Credit quality of renegotiated loans

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 under our existing disclosures. 

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.

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 pandemic, 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 
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 159.

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.

138

HSBC Holdings plc Annual Report and Accounts 2021

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.

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 to achieve a fair customer outcome, 
and in line with regulatory expectations, they may be extended 
further.

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. Write-off, either partially or in full, may be earlier when there 
is no reasonable expectation of further recovery, for example, in 
the event of a bankruptcy or equivalent legal proceedings. 
Collection procedures may continue after write-off.

Credit risk in 2021

At 31 December 2021, gross loans and advances to customers 
and banks of $1,140bn increased by $6.3bn, compared with 
31 December 2020. This included adverse foreign exchange 
movements of $17.0bn and a $2.4bn decrease due to domestic 
mass market retail banking in the US being reclassified to assets 
held for sale. 

Excluding foreign exchange movements, the growth was driven by 
a $24.0bn increase in personal loans and advances to customers 
and a $3.0bn increase in loans and advances to banks. Wholesale 
loans and advances to customers decreased by $3.7bn.

The increase in personal loans and advances to customers was 
driven by mortgage growth of $22.8bn, mainly in the UK (up 
$10.1bn), Hong Kong (up $6.6bn), Canada (up $3.4bn) and 
Australia (up $2.1bn). Other personal lending increased by $1.2bn, 
mainly from unsecured personal lending in Hong Kong (up $1.0bn) 
and Latin America (up $0.7bn), as well as guaranteed loans in 
respect of residential property in France (up $0.8bn). These were 
offset by a decrease in credit cards mainly in the US (down 
$0.9bn).

At 31 December 2021, the allowance for ECL of $12.2bn 
decreased by $3.5bn compared with 31 December 2020, including 
favourable foreign exchange movements of $0.4bn. The $12.2bn 
allowance comprised $11.6bn in respect of assets held at 
amortised cost, $0.4bn 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 2021, the Group experienced a release in 
allowances for ECL, reflecting an improvement of the economic 
outlook. This trend continued during the second half of the year 
following better than expected levels of credit performance and 
lower levels of stage 3 charges. However, in the later part of the 

year the trend slowed down due to the emergence of the new 
Omicron variant and the recent developments in China’s 
commercial real estate sector.

Excluding foreign exchange movements, the allowance for ECL in 
relation to loans and advances to customers decreased by $2.7bn 
from 31 December 2020. This was attributable to:

• a $1.2bn decrease in wholesale loans and advances to 

customers, of which $1.0bn was driven by stages 1 and 2; and

• a $1.5bn decrease 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 2 to stage 1, reflecting an 
improvement of the economic outlook. This trend continued 
during the second half of 2021 as forecasts underpinning forward 
economic guidance stabilised.

Stage 3 balances at 31 December 2021 remained broadly stable 
compared with 31 December 2020.

The ECL release for 2021 was $0.9bn, inclusive of recoveries. This 
release comprised $0.6bn in respect of wholesale lending, of 
which the stage 3 and purchased or originated credit impaired 
(‘POCI‘) charge was $0.5bn, and $0.3bn in respect of personal 
lending, of which the stage 3 charge was $0.4bn. Uncertainty 
remains as countries recover from the pandemic at different 
speeds, government support measures unwind and the 
emergence of new strains of the virus continue to test the efficacy 
of vaccination programmes.

During 2021, we continued to provide Covid-19-related support to 
customers under the current policy framework. For further details 
of market-specific measures to support our personal and business 
customers, see page 159.

Income statement movements are analysed further on page 92.

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 144;
• measurement uncertainty and sensitivity analysis of ECL 

estimates, see page 144;

• 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 
152;

• credit quality, see page 155;
• customer relief programmes, see page 159;
• total wholesale lending for loans and advances to banks and 

customers by stage distribution, see page 163;

• wholesale lending collateral, see page 169;
• total personal lending for loans and advances to customers at 

amortised cost by stage distribution, see page 177; and

• personal lending collateral, see page 181.

HSBC Holdings plc Annual Report and Accounts 2021

139

Risk reviewRisk

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)

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

–  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 assets2
Total gross carrying amount on-balance sheet

Loans and other credit-related commitments

–  personal

–  corporate and commercial

–  financial

Financial guarantees

–  personal

–  corporate and commercial

–  financial
Total nominal amount off-balance sheet3

Debt instruments measured at fair value through other comprehensive income (‘FVOCI’)

31 Dec 2021

 At 31 Dec 2020

Gross carrying/
nominal amount

Allowance for
ECL1

Gross carrying/
nominal amount

Allowance for 
ECL1

$m

$m

$m

1,057,231   

(11,417)   

1,052,477   

478,337   

513,539   

65,355   

83,153   

880,351   

403,022   

4,136   

42,578   

241,648   

97,364   

91,603   

(3,103)   

(8,204)   

(110)   

(17)   

(193)   

(4)   

—   

—   

—   

(62)   

(127)   

460,809   

527,088   

64,580   

81,658   

772,408   

304,486   

4,094   

40,420   

230,628   

88,719   

104,061   

$m

(14,490) 

(4,731) 

(9,494) 

(265) 

(42) 

(175) 

(5) 

— 

— 

— 

(80) 

(90) 

2,020,735   

(11,627)   

1,906,543   

(14,707) 

627,637   

239,685   

283,625   

104,327   

27,795   

1,130   

22,355   

4,310   

(379)   

(39)   

(325)   

(15)   

(62)   

—   

(58)   

(4)   

659,783   

236,170   

299,802   

123,811   

18,384   

900   

12,946   

4,538   

655,432   

(441)   

678,167   

(734) 

(40) 

(650) 

(44) 

(125) 

(1) 

(114) 

(10) 

(859) 

2,676,167   

(12,068)   

2,584,710   

(15,566) 

Fair value

$m

347,203   

Memorandum 
allowance for 
ECL4

$m

(96)   

Fair value

$m

399,717   

Memorandum 
allowance for 
ECL4

$m

(141) 

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 310, includes both financial and non-financial assets. The 31 December 2021 
balances include $2,424m gross carrying amounts and $39m allowances for ECL related to assets held for sale due to the exit of domestic mass 
market retail banking in the US.

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 
significant increase in credit risk on which a 12-month 
allowance for ECL is recognised.

• POCI: Financial assets that are purchased or originated at a 

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.

140

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
–  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 
2021

Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at
31 December 2021
(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

  918,936   119,224   18,797    274   1,057,231    (1,367)    (3,119)    (6,867)   

(64)   (11,417) 

–  personal

  456,956    16,439    4,942    —    478,337   

(658)    (1,219)    (1,226)    —    (3,103) 

 0.1 

 0.1 

 2.6 

 7.4 

 36.5 

 23.4 

 24.8 

 — 

 1.1 

 0.6 

  400,894    98,911   13,460    274    513,539   

(665)    (1,874)    (5,601)   

(64)    (8,204) 

 0.2 

 1.9 

 41.6 

 23.4 

 1.6 

  61,086    3,874   

395    —   

65,355   

(44)   

(26)   

(40)    —   

(110) 

 0.1 

 0.7 

 10.1 

 — 

 0.2 

  81,636    1,517   

—    —   

83,153   

(14)   

(3)   

—    —   

(17) 

 — 

 0.2 

 — 

 — 

 — 

  875,016    4,988   

304    43    880,351   

(91)   

(54)   

(42)   

(6)   

(193) 

 — 

 1.1 

 13.8 

 14.0 

 — 

  594,473    32,389   

775    —    627,637   

(165)   

(174)   

(40)    —   

(379) 

–  personal

  237,770    1,747   

168    —    239,685   

(37)   

(2)   

—    —   

(39) 

  254,750    28,269   

606    —    283,625   

(120)   

(165)   

(40)    —   

(325) 

  101,953    2,373   

1    —    104,327   

(8)   

(7)   

—    —   

(15) 

  24,932    2,638   

225    —   

27,795   

(11)   

(30)   

(21)    —   

(62) 

1,114   

15   

1    —   

1,130   

—   

—   

—    —   

— 

  20,025    2,107   

223    —   

22,355   

(10)   

(28)   

(20)    —   

(58) 

3,793   

516   

1    —   

4,310   

(1)   

(2)   

(1)    —   

(4) 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.5 

 0.1 

 0.6 

 0.3 

 1.1 

 — 

 1.3 

 0.4 

 5.2 

 — 

 6.6 

 — 

 9.3 

 — 

 9.0 

 100.0 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.1 

 — 

 0.1 

 — 

 0.2 

 — 

 0.3 

 0.1 

 2,494,993   160,756   20,101    317   2,676,167    (1,648)    (3,380)    (6,970)   

(70)   (12,068) 

 0.1 

 2.1 

 34.7 

 22.1 

 0.5 

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 
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).

Stage 2 days past due analysis at 31 December 2021

(Audited)

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

 119,224   115,350    2,193    1,681   

(3,119)   

(2,732)   

(194)   

  16,439    14,124    1,387   

928   

(1,219)   

(884)   

(160)   

(193) 

(175) 

 2.6 

 7.4 

 2.4 

 6.3 

 8.8 

 11.5 

 11.5 

 18.9 

  98,911    97,388   

806   

717   

(1,874)   

(1,822)   

(34)   

(18) 

 1.9 

 1.9 

 4.2 

 2.5 

  3,874    3,838   

—   

36   

(26)   

(26)   

—   

  1,517    1,517   

—   

—   

(3)   

(3)   

—   

— 

— 

 0.7 

 0.7 

 0.2 

 0.2   

 — 

— 

 — 

 — 

  4,988    4,935   

22   

31   

(54)   

(47)   

(4)   

(3) 

 1.1 

 1.0 

 18.2 

 9.7 

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.

HSBC Holdings plc Annual Report and Accounts 2021

141

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

Risk

Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at 
31 December 2020 (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

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 

 26.8 

 40.4 

 — 

 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 

 — 

–  personal

234,337   

1,681   

152    —   

236,170   

(39)   

(1)   

—   

—   

(40) 

604,485    54,217    1,080   

1   

659,783   

(290)   

(365)   

(78)   

(1)   

(734) 

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)   

872   

26   

2    —   

900   

—   

(1)   

—   

9,536   

3,157   

252   

1   

12,946   

(35)   

(54)   

(25)   

—   

—   

(125) 

(1) 

—   

—   

(114) 

(10) 

–  financial

3,682   

841   

15    —   

4,538   

(2)   

(7)   

(1)   

At 31 Dec 2020

  2,336,365   227,405    20,621    319    2,584,710    (2,414)    (5,445)    (7,585)   

(122)   (15,566) 

1  Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
2  Purchased or originated credit-impaired (‘POCI’).

 — 

 — 

 0.1 

 — 

 0.3 

 — 

 0.4 

 0.1 

 0.1 

 0.7 

 0.1 

 0.7 

 0.4 

 1.5 

 3.8 

 1.7 

 0.8 

 2.4 

 7.2 

 100.0 

 — 

 — 

 8.4 

 7.5 

 9.7 

 — 

 9.9 

 6.7 

 100.0 

 — 

 — 

 — 

 — 

 — 

 36.8 

 38.2 

 0.1 

 — 

 0.2 

 — 

 0.7 

 0.1 

 0.9 

 0.2 

 0.6 

Stage 2 days past due analysis at 31 December 2020

(Audited)

Gross carrying amount

Allowance for ECL

ECL coverage %

Stage 2 Up-to-date

1 to 29 
DPD1,2

30 and > 

DPD1,2 Stage 2 Up-to-date

1 to 29 
DPD1,2

30 and > 
DPD1,2

 Stage 2 Up-to-date

$m

$m

$m

$m

$m

$m

$m

$m

%

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)   

  25,064    22,250   
  126,287    125,301   

1,554   
489   

1,260    (2,402)   
497    (2,444)   

(1,895)   
(2,344)   

(275)   

(227)   
(48)   

(332) 

(280) 
(52) 

  11,834    11,816   

9   

9   

(119)   

(119)   

—   

2,004   

2,004   

—   

—   

(9)   

(9)   

—   

3,975   

3,963   

3   

9   

(44)   

(44)   

—   

— 

— 

— 

 3.0 

 9.6 

 1.9 

 1.0 

 0.4 

 1.1 

%

 2.7 

 8.5 

 1.9 

 1.0 

 0.4 

 1.1 

1 to 29 
DPD1,2

30 and > 
DPD1,2

%

%

 13.4 

 14.6 

 9.8 

 — 

 — 

 — 

 18.8 

 22.2 

 10.5 

 — 

 — 

 — 

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.

142

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ECL 
coverage
 Total 

%

 3.0 

 1.8 

 2.0 

 2.6 

Stage 2 decomposition at 31 December 2021

The following disclosure presents the stage 2 decomposition of 
gross carrying amount and allowances for ECL for loans and 
advances to customers. 

The table below discloses the reasons why an exposure moved 
into stage 2 originally, and is therefore presented as a significant 
increase in credit risk since origination.

The quantitative classification shows when the relevant reporting 
date PD measure exceeds defined quantitative thresholds for retail 

Loans and advances to customers1

Gross carrying amount

Personal

Corporate and 
commercial

Non-bank 
financial 
institutions

$m

$m

and wholesale exposures, as set out in Note 1.2 ‘Summary of 
significant accounting policies’, on page 324.

The qualitative classification primarily accounts for CRR 
deterioration, watch and worry and retail management 
judgemental adjustments.

For further details on our approach to the assessment of 
significant increase in credit risk, see ‘Summary of significant 
accounting policies’ on page 324.

Allowance for ECL

Corporate and 
commercial

Non-bank 
financial 
institutions

$m

$m

Total

$m

Total

$m

Personal

$m

Quantitative

Qualitative
30 DPD backstop2
Total stage 2

68,000   

30,326   

585   

3,041   

80,948   

(1,076)   

(1,347)   

(19)   

(2,442) 

818   

15   

37,473   

803   

(134)   

(9)   

(520)   

(7)   

(7)   

—   

(661) 

(16) 

16,439   

98,911   

3,874   

119,224   

(1,219)   

(1,874)   

(26)   

(3,119) 

$m

9,907   

6,329   

203   

1   Where balances satisfy more than one of the above three criteria for determining a significant increase in credit risk, the corresponding gross 

exposure and ECL have been assigned in order of categories presented.

2   Days past due (‘DPD’).

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. 

‘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.

Commentary on consolidated balance sheet movements in 2021 
is provided on page 96.

The offset on derivatives remains in line with the movements 
in maximum exposure amounts.

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 322 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 169.

HSBC Holdings plc Annual Report and Accounts 2021

143

Risk review 
 
 
 
 
Risk

Maximum exposure to credit risk

(Audited)

Loans and advances to customers held at amortised cost

  1,045,814   

(22,838)    1,022,976   

1,037,987   

(27,221)   

1,010,766 

Maximum
exposure

$m

2021

Offset

$m

2020

Net

$m

Maximum
exposure

$m

Offset

$m

Net

$m

475,234   

(4,461)   

470,773   

456,078   

(4,287)   

505,335   

(16,824)   

488,511   

517,594   

(21,102)   

–  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 

65,245   

83,136   

(1,553)   

63,692   

—   

83,136   

882,708   

(12,231)   

870,477   

403,018   

4,136   

42,578   

—   

—   

—   

403,018   

4,136   

42,578   

241,648   

(12,231)   

229,417   

97,302   

94,026   

—   

—   

97,302   

94,026   

196,882   

(188,284)   

8,598   

64,315   
81,616   
774,116   
304,481   
4,094   
40,420   
230,628   
88,639   
105,854   
307,726   

2,201,445   
940,185   
96,147   
844,038   
3,141,630   

(1,832)   
—   
(14,668)   
—   
—   
—   
(14,668)   
—   
—   
(293,240)   

(335,129)   
—   
—   
—   
(335,129)   

451,791 

496,492 

62,483 

81,616 

759,448 

304,481 

4,094 

40,420 

215,960 

88,639 

105,854 

14,486 

1,866,316 

940,185 

96,147 

844,038 

2,806,501 

Total on-balance sheet exposure to credit risk

  2,208,540   

(223,353)    1,985,187   

Total off-balance sheet

–  financial and other guarantees

–  loan and other credit-related commitments

At 31 Dec 

928,183   

113,088   

815,095   

—   

—   

—   

928,183   

113,088   

815,095   

  3,136,723   

(223,353)    2,913,370   

Concentration of exposure

Methodology

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 17 on the financial statements;

• trading assets, see Note 11 on the financial statements;

• derivatives, see page 176 and Note 16 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 Limited, HSBC Bank plc, HSBC Bank Middle East 
Limited and HSBC Bank USA, by the location of the lending 
branch), see page 162 for wholesale lending and page 176 for 
personal lending.

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.

Measurement uncertainty and sensitivity analysis 
of ECL estimates

(Audited)

Despite a broad recovery in economic conditions during 2021, ECL 
estimates continued to be subject to a high degree of uncertainty, 
and management judgements and estimates continued to reflect a 
degree of caution, both in the selection of economic scenarios and 
their weightings, and through management judgemental 
adjustments. Releases of provisions were made progressively as 
economic conditions recovered and by 31 December 2021 the 
majority of the 2020 uplift in ECL provisions had been reversed. By 
the end of 2021, we retained $0.6bn (15%) of the $3.9bn uplift in 
stage 1 and stage 2 ECL provisions on loans made during 2020.

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.  

144

HSBC Holdings plc Annual Report and Accounts 2021

Four economic scenarios are used to capture 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. 

In the second quarter of 2020, to ensure that the severe risks 
associated with the pandemic were appropriately captured, 
management added a fourth, more severe, scenario to use in the 
measurement of ECL. Starting in the fourth quarter of 2021, 
HSBC’s methodology has been adjusted so that the use of four 
scenarios, of which two are Downside scenarios, is the standard 
approach to ECL calculation.

Three of the 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. 
Consensus Upside and Downside scenarios are created with 
reference to distributions for select markets that capture 
forecasters’ views of the entire range of outcomes. In the later 
years of the scenarios, projections revert to long-term consensus 
trend expectations. In the consensus outer scenarios, reversion to 
trend expectations is done mechanically with reference to 
historically observed quarterly changes in the values of 
macroeconomic variables.

The fourth scenario, Downside 2, is designed to represent 
management’s view of severe downside risks. It is a globally 
consistent narrative-driven scenario that explores more extreme 
economic outcomes than those captured by the consensus 
scenarios. In this scenario, variables do not, by design, revert to 
long-term trend expectations. They may instead explore alternative 
states of equilibrium, where economic activity moves permanently 
away from past trends. 

The consensus Downside and the consensus Upside scenarios are 
each constructed to be consistent with a 10% probability. The 
Downside 2 is constructed with a 5% probability. The Central 
scenario is assigned the remaining 75%. This weighting scheme is 
deemed appropriate for the unbiased estimation of ECL in most 
circumstances. However, management may depart from this 
probability-based scenario weighting approach when the 
economic outlook is determined to be particularly uncertain and 
risks are elevated.

In light of ongoing risks, related primarily to the Covid-19 
pandemic, management deviated from this probability weighting 
in most markets in the fourth quarter of 2021. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 global economy experienced a recovery in 2021, following an 
unprecedented contraction in 2020. Restrictions to mobility and 
travel eased across our key markets, aided by the successful roll-
out of vaccination programmes. The emergence of new variants 
that potentially reduce the efficacy of vaccines remains a risk. 

Economic forecasts remain subject to a high degree of 
uncertainty. Risks to the economic outlook are dominated by the 
progression of the pandemic, vaccine roll-out and the public policy 
response. Geopolitical risks also remain significant and include 
continued differences between the US and other countries with 
China over a range of economic and strategic defence issues. 
Continued uncertainty over the long-term economic relationship 
between the UK and EU also present downside risks. 

The scenarios used to calculate ECL in the Annual Report and 
Accounts 2021 are described below.

The consensus Central scenario

HSBC’s Central scenario features a continued recovery in 
economic growth in 2022 as activity and employment gradually 
return to the levels reached prior to the outbreak of Covid-19. 

Our Central scenario assumes that the stringent restrictions on 
activity, imposed across several countries and territories in 2020 
and 2021 are not repeated. The new viral strain that emerged late 
in 2021, Omicron, has only a limited impact on the recovery, 
according to this scenario. Consumer spending and business 
investment, supported by elevated levels of private sector savings, 
are expected to drive the economic recovery as fiscal and 
monetary policy support recedes.

Regional differences in the speed of economic recovery in the 
Central scenario reflect differences over the progression of the 
pandemic, roll-out of vaccination programmes, national level 
restrictions imposed and scale of support measures. Global GDP is 
expected to grow by 4.2% in 2022 in the Central scenario and the 
average rate of global GDP growth is 3.1% over the five-year 

forecast period. This exceeds the average growth rate over the 
five-year period prior to the onset of the pandemic. 

The key features of our Central scenario are:

• Economic activity in our top eight markets continues to 
recover. GDP grows at a moderate rate and exceeds pre-
pandemic levels across all our key markets in 2022. 

• Unemployment declines to levels only slightly higher than 

existed pre-pandemic, with the exception of France where the 
downward trend in unemployment, related to structural 
changes to the labour market, resumes. 

• Covid-19-related fiscal spending recedes in 2022 as fewer 

restrictions on activity allow fiscal support to be withdrawn. 
Deficits remain high in several countries as they embark on 
multi-year investment programmes to support recovery, 
productivity growth and climate transition. 

• Inflation across many of our key markets remains elevated 

through 2022. Supply-driven price pressures persist through 
the first half of 2022 before gradually easing. In subsequent 
years, inflation quickly converges back towards central bank 
target rates.

• Policy interest rates in key markets rise gradually over our 

projection period, in line with economic recovery.

• The West Texas Intermediate oil price is forecast to average 

$62 per barrel over the projection period.

In the longer term, growth reverts back towards similar rates that 
existed prior to the pandemic, suggesting that the damage to long-
term economic prospects is expected to be minimal. 

The Central scenario was first created with forecasts available in 
November, and subsequently updated in December. Probability 
weights assigned to the Central scenario vary from 60% to 80% 
and reflect relative differences in uncertainty across markets. 

The following table describes key macroeconomic variables and 
the probabilities assigned in the consensus Central scenario.

Central scenario 2022–2026

GDP growth rate

2022: Annual average growth rate

2023: Annual average growth rate

2024: Annual average growth rate

5-year average

Unemployment rate

2022: Annual average rate

2023: Annual average rate

2024: Annual average rate

5-year average

House price growth

2022: Annual average growth rate

2023: Annual average growth rate

2024: Annual average growth rate

5-year average 

Short-term interest rate

2022: Annual average rate

2023: Annual average rate

2024: Annual average rate

5-year average

Probability

UK

%

 5.0 

 2.1 

 1.9 

 2.5 

 4.5 

 4.3 

 4.2 

 4.3 

 5.5 

 3.3 

 3.3 

 3.5 

 1.0 

 1.3 

 1.2 

 1.2 

 60 

US

Hong Kong

Mainland China

Canada

France

%

 4.0 

 2.4 

 2.1 

 2.5 

 4.2 

 3.8 

 3.8 

 3.8 

 10.3 

 5.4 

 3.7 

 5.4 

 0.5 

 1.1 

 1.5 

 1.3 

 75 

%

 3.1 

 2.9 

 2.6 

 2.7 

 4.1 

 3.6 

 3.5 

 3.6 

 3.4 

 2.4 

 2.0 

 2.6 

 0.5 

 1.1 

 1.6 

 1.4 

 70 

%

 5.3 

 5.4 

 5.1 

 5.1 

 3.8 

 3.7 

 3.8 

 3.8 

 0.3 

 4.7 

 4.9 

 3.5 

 3.1 

 3.2 

 3.4 

 3.4 

 80 

%

 4.1 

 2.8 

 2.0 

 2.5 

 6.3 

 5.9 

 5.8 

 5.9 

 6.4 

 2.8 

 2.1 

 3.3 

 1.1 

 2.0 

 2.2 

 1.9 

 75 

%

 3.9 

 2.1 

 1.6 

 2.1 

 8.0 

 7.7 

 7.6 

 7.7 

 4.9 

 4.6 

 4.0 

 3.9 

 (0.5) 

 (0.3) 

 (0.1) 

 (0.2) 

 60 

UAE

%

 4.4 

 3.4 

 3.0 

 3.2 

 3.1 

 3.0 

 2.9 

 3.0 

 4.9 

 — 

 2.1 

 2.7 

 1.1 

 1.7 

 2.2 

 2.0 

 70 

Mexico

%

 2.9 

 2.3 

 2.2 

 2.3 

 4.0 

 3.9 

 3.8 

 3.8 

 5.8 

 5.0 

 4.4 

 4.7 

 7.2 

 8.1 

 8.0 

 7.9 

 65 

HSBC Holdings plc Annual Report and Accounts 2021

145

Risk review 
Risk

The graphs comparing the respective Central scenarios in the fourth quarters of 2020 and 2021 reveal the extent of economic dislocation 
that occurred in 2020 and compare current economic expectations with those held a year ago.

GDP growth: Comparison

UK

25

20

15

10

5

0

‐5

‐10

‐15

‐20

‐25

4Q20 Central 5Y Average: 2.8%
4Q21 Central 5Y Average: 2.5%

2019

2020

2021

2022

2023

2024

2025

2026

4Q20 Central

4Q21 Central

Note: Real GDP shown as year-on-year percentage change.

Hong Kong

10

8

6

4

2

0

‐2

‐4

‐6

‐8

‐10

4Q20 Central 5Y Average: 2.9%
4Q21 Central 5Y Average: 2.7%

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

US

15

10

5

0

‐5

‐10

100

90

80

70

60

50

40

30

20

10

0

4Q20 Central 5Y Average: 2.7%
4Q21 Central 5Y Average: 2.5%

2019

2020

2021

2022

2023

2024

2025

2026

4Q20 Central

4Q21 Central

Note: Real GDP shown as year-on-year percentage change.

Mainland China

20

15

10

5

0

‐5

‐10

100

90

80

70

60

50

40

30

20

10

0

4Q20 Central 5Y Average: 5.6%
4Q21 Central 5Y Average: 5.1%

2019

2020

2021

2022

2023

2024

2025

2026

2019

2020

2021

2022

2023

2024

2025

2026

Note: Real GDP shown as year-on-year percentage change.

4Q20 Central

4Q21 Central

Note: Real GDP shown as year-on-year percentage change.

4Q20 Central

4Q21 Central

The consensus Upside scenario

Compared with the Central scenario, the consensus Upside 
scenario features a faster recovery in economic activity during the 
first two years, before converging to long-run trend expectations.

The scenario is consistent with a number of key upside risk 
themes. These include the orderly and rapid global abatement of 

Consensus Upside scenario best outcome

Covid-19 via successful containment and ongoing vaccine 
efficacy; de-escalation of tensions between the US and China; 
continued fiscal and monetary support; and smooth relations 
between the UK and the EU.

The following table describes key macroeconomic variables and 
the probabilities assigned in the consensus Upside scenario.

UK

%

US

%

Hong Kong

Mainland China

Canada

%

%

%

France

%

UAE

%

Mexico

%

GDP growth rate

 9.9  (1Q22)

 7.3  (3Q22)

 10.3  (4Q22)

 11.8  (4Q22)

 9.1  (3Q22)

 7.0  (2Q22)

 10.8  (1Q22)

 7.6  (3Q22)

Unemployment rate

 3.0  (4Q23)

 2.7  (2Q23)

 2.7  (4Q23)

 3.5  (1Q23)

 5.0  (2Q23)

 6.6  (4Q23)

 2.3  (4Q23)

 3.3  (3Q22)

House price growth

 7.4  (2Q23)

 14.8  (1Q22)

 11.9  (4Q22)

 8.2  (4Q22)

 16.0  (4Q22)

 6.8  (2Q22)

 14.4  (2Q22)

 9.6  (1Q23)

Short-term interest rate

 0.7  (1Q22)

 0.4  (1Q22)

 0.6  (1Q22)

 3.2  (1Q22)

 0.9  (1Q22)

 (0.5)  (1Q22)

 0.9  (1Q22)

 8.7  (1Q22)

Probability

10

5

5

5

10

10

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.

Downside scenarios

The progress of the pandemic and the ongoing public policy 
response continue to be a key sources of risk. Downside scenarios 
assume that new strains of the virus result in an acceleration in 
infection rates and increased pressure on public health services, 
necessitating restrictions on activity. The reimposition of such 
restrictions could be assumed to have a damaging effect on 
consumer and business confidence. 

Government fiscal programmes in advanced economies in 2020 
and 2021 were supported by accommodative actions taken by 
central banks. These measures 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: 

• continued differences between the US and other countries with

China, which could affect sentiment and restrict global
economic activity;

• the re-emergence of social unrest in Hong Kong; and

• potential disagreements between the UK and the EU, which

may hinder the ability to reach a more comprehensive
agreement on trade and services, despite the Trade and
Cooperation Agreement averting a disorderly UK departure.

146

HSBC Holdings plc Annual Report and Accounts 2021

The consensus Downside scenario

In the consensus Downside scenario, economic recovery is 
weaker compared with the Central scenario as key global risks, 
including the Covid-19 pandemic, escalate. Compared with the 
Central scenario, GDP growth is expected to be lower, 
unemployment rates rise moderately and asset and commodity 

Consensus Downside scenario worst outcome

prices fall, before gradually recovering towards their long-run 
trend expectations. 

The following table describes key macroeconomic variables and 
the probabilities assigned in the consensus Downside scenario.

UK

%

US

%

Hong Kong

Mainland China

Canada

%

%

%

France

%

UAE

%

Mexico

%

GDP growth rate

 (0.5)  (3Q23)

 0.0  (4Q22)

 (1.0)  (4Q22)

 2.3  (4Q22)

 (0.5)  (4Q22)

 0.5  (4Q23)

 (2.0)  (4Q22)

 (0.7)  (4Q22)

Unemployment rate

 5.6  (4Q22)

 5.6  (3Q22)

 5.6  (2Q22)

 4.0  (2Q22)

 7.3  (3Q22)

 9.1  (3Q22)

 4.3  (3Q22)

 4.8  (3Q22)

House price growth

 (4.2)  (1Q23)

 3.0  (4Q23)

 (7.9)  (4Q22)

 (3.7)  (2Q22)

 (2.3)  (4Q22)

 2.0  (4Q22)

 (6.6)  (1Q23)

 2.5  (1Q23)

Short-term interest rate

 0.2  (4Q23)

 0.3  (1Q22)

 0.4  (1Q22)

 2.9  (1Q22)

 0.5  (3Q23)

 (0.5)  (1Q22)

 0.6  (4Q23)

 4.6  (1Q22)

Probability

15

10

20

10

10

15

20

20

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. 

Downside 2 scenario

The Downside 2 scenario features a deep global recession. In this 
scenario, new Covid-19 variants emerge that cause infections to 
rise sharply in 2022, resulting in setbacks to vaccination 
programmes and the rapid imposition of restrictions on mobility 

and travel across some countries. The scenario also assumes 
governments and central banks are unable to significantly increase 
fiscal and monetary support, which results in abrupt corrections in 
labour and asset markets. 

The following table describes key macroeconomic variables and 
the probabilities assigned in the Downside 2 scenario.

Downside 2 scenario worst outcome

UK

%

US

%

Hong Kong

Mainland China

Canada

%

%

%

France

%

UAE

%

Mexico

%

GDP growth rate

 (4.6)  (4Q22)

 (4.6)  (4Q22)

 (8.2)  (4Q22)

 (4.8)  (4Q22)

 (13.9)  (4Q22)

 (4.6)  (4Q22)

 (12.5)  (4Q22)

 (8.5)  (4Q22)

Unemployment rate

 7.5  (2Q23)

 10.6  (4Q23)

 6.1  (4Q22)

 5.4  (4Q23)

 11.5  (2Q23)

 10.0  (4Q23)

 4.7  (2Q22)

 5.9  (2Q23)

House price growth

 (14.2)  (2Q23)

 (6.2)  (4Q22)

 (17.7)  (4Q22)

 (24.8)  (4Q22)

 (23.8)  (1Q23)

 (6.0)  (2Q23)

 (16.2)  (4Q22)

 1.0  (2Q23)

Short-term interest rate

 1.6  (2Q22)

 1.3  (2Q22)

 1.3  (2Q22)

 4.0  (2Q22)

 0.5  (3Q23)

 0.4  (2Q22)

 1.5  (2Q22)

 9.6  (2Q22)

Probability

15

10

5

5

5

15

5

10

Note: Extreme point in the Downside 2 is 'worst outcome' in the scenario, for example lowest GDP growth and the highest unemployment rate, in the 
first two years of the scenario. 

Scenario weighting

In reviewing the economic conjuncture, the level of uncertainty 
and risk, management has considered both global and country-
specific factors. This has led management to assign scenario 
probabilities that are tailored to its view of uncertainty in individual 
markets.

To inform its view, management has considered the progression 
of the virus in individual countries, the speed of vaccine roll-outs, 
the degree of current and expected future government support 
and connectivity with other countries. Management has also been 
guided by the policy response and economic performance through 
the pandemic, as well as the evidence that economies have 
adapted as the virus has progressed.

A key consideration in the fourth quarter was the emergence of 
the new variant, Omicron. The virulence and severity of the new 
strain, in addition to the continued efficacy of vaccines against it, 
was unknown when the variant first emerged. Management 
therefore determined that uncertainty attached to forecasts had 
increased and sought to reflect this in scenario weightings. 

China’s significant capacity to extend policy support to the 
economy and manage through Covid-19-related disruptions, led 
management to conclude that the outlook for mainland China was 
the least uncertain of all our key markets. The Central scenario 
was given an 80% probability while a total of 15% has been 
assigned to the two Downside scenarios. 

In Hong Kong, the combination of recurrent outbreaks and the 
other risks outlined above led management to assign a 25% 
weight to the two Downside scenarios.

The UK and France faced the greatest economic uncertainties of 
our key markets. The emergence of Omicron exacerbated the rise 
in case rates and hospitalisations in both countries, necessitating 
the imposition of new restrictions. These increase uncertainties 
around economic growth and employment. Accordingly, the 
Central scenario was assigned a 60% weight in both countries. 
The two Downside scenarios were given a combined probability 
weighting of 30% for both the UK and France. 

For the US, Canada and Mexico, connectivity across the three 
North American economies has been considered. For the US and 
Mexico, management similarly sought to reflect the increase in 
uncertainty by raising the probability weighting of the Downside 2 
scenario. The two Downside scenarios combined have been given 
weights of between 20% and 30%. For Canada, the probability 
attached to the Downside 2 scenario was reduced. This follows 
from an adjustment to the methodology used for this scenario, 
which increased its overall severity. The change aligned the 
methodology to the global approach and weighting adjustments 
reflect the greater implied severity. 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 75% weight for these four markets and, with risks perceived 
as being weighted to the downside, the two Downside scenarios 
have been given weights of between 15% and 30%.

HSBC Holdings plc Annual Report and Accounts 2021

147

Risk review 
Risk

The following graphs show the historical and forecasted GDP 
growth rate for the various economic scenarios in our four largest 
markets.

2020

2021

2022

2023

2024

2025

2026

Central

Upside

Downside

Downside 2

US

15.0

10.0

5.0

0.0

‐5.0

‐10.0

2019

UK

25.0

20.0

15.0

10.0

5.0

0.0

‐5.0

‐10.0

‐15.0

‐20.0

‐25.0

Critical accounting estimates and judgements

The calculation of ECL under IFRS 9 involves significant 
judgements, assumptions and estimates. Despite a general 
recovery in economic conditions during 2021, the level of 
estimation uncertainty and judgement has remained high during 
2021 as a result of the ongoing economic effects of the Covid-19 
pandemic and other sources of economic instability, 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, and 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 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 pandemic and the recovery from those
conditions. Modelled assumptions and 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

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

2019

2020

2021

2022

2023

2024

2025

2026

Central

Upside

Downside

Downside 2

• the identification of customers experiencing significant

Hong Kong

15.0

10.0

5.0

0.0

‐5.0

‐10.0

‐15.0

2019

2020

2021

2022

2023

2024

2025

2026

Central

Upside

Downside

Downside 2

Mainland China

20.0

15.0

10.0

5.0

0.0

‐5.0

‐10.0

2019

2020

2021

2022

2023

2024

2025

2026

Central

Upside

Downside

Downside 2

148

HSBC Holdings plc Annual Report and Accounts 2021

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

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 conditions experienced in 2021, and management 
judgemental adjustments were still required to support modelled 
outcomes.   

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 2021.   

For our wholesale portfolios, 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 our retail portfolios, 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, segment 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.

At 31 December 2021, management judgements were applied to 
reflect credit risk dynamics not captured by our models. The 
drivers of the management judgemental adjustments reflect the 
changing economic outlook and evolving risks across our 
geographies.

Where the macroeconomic and portfolio risk outlook continues to 
improve, supported by low levels of observed defaults, 
adjustments initially taken to reflect increased risk expectations 
have been retired or reduced.

However, other adjustments have increased where modelled 
outcomes are overly sensitive and not aligned to observed 
changes in the risk of the underlying portfolios during the 
pandemic, or where sector-specific risks are not adequately 
captured.

The effects of management judgemental adjustments are 
considered for balances and ECL when determining whether or 
not a significant increase in credit risk has occurred and are 
attributed or allocated to a stage as appropriate. This is in 
accordance with the internal adjustments framework.

Management judgemental adjustments are reviewed under the 
governance process for IFRS 9 (as detailed in the section ‘Credit 
risk management’ on page 137). Review and challenge focuses on 
the rationale and quantum of the adjustments with a further 
review carried out by the second line of defence where significant. 
For some management judgemental adjustments, internal 
frameworks establish the conditions under which these 
adjustments should no longer be required and as such are 
considered as part of the governance process. This internal 
governance process allows management judgemental 
adjustments to be reviewed regularly and, where possible, to 
reduce the reliance on these through model recalibration or 
redevelopment, as appropriate.

Management judgemental adjustments made in estimating the 
scenario-weighted reported ECL at 31 December 2021 are set out 
in the following table. The table includes adjustments in relation to 
data and model limitations, including those driven by late-breaking 
events and sector-specific risks and as a result of the regular 
process of model development and implementation.

Management judgemental adjustments to ECL at 31 December 
20211

Retail

$bn

Wholesale

$bn

Total

$bn

Low-risk counterparties 
(banks, sovereigns and 
government entities)

Corporate lending 
adjustments

Retail lending probability 
of default adjustments

Retail model default 
timing adjustments

Macroeconomic-related 
adjustments

Pandemic-related 
economic recovery 
adjustments

Other retail lending 
adjustments

Total

(0.1)   

(0.1) 

1.3   

1.3 

— 

— 

— 

0.2 

0.3 

1.7 

0.2 

0.3 

0.5   

.

1.2   

Management judgemental adjustments to ECL at 31 December 
20201

Low-risk counterparties 
(banks, sovereigns and 
government entities)

Corporate lending 
adjustments

Retail lending probability 
of default adjustments

Retail model default 
timing adjustment

Macroeconomic-related 
adjustments

Pandemic-related 
economic recovery 
adjustments

Other retail lending 
adjustments

Total

Retail

$bn

Wholesale

$bn

(0.7)   

0.5   

(0.8) 

1.9 

0.1 

0.3 

1.5   

(0.2)   

Total

$bn

(0.7) 

0.5 

(0.8) 

1.9 

0.1 

— 

0.3 

1.3 

1  Management judgemental adjustments presented in the table reflect 

increases or (decreases) to ECL, respectively.

Management judgemental adjustments at 31 December 2021 
were an increase to ECL of $1.2bn for the wholesale portfolio and 
an increase to ECL of $0.5bn for the retail portfolio.

During 2021, management judgemental adjustments reflected an 
evolving macroeconomic outlook and the relationship of the 
modelled ECL to this outlook and to late-breaking and sector-
specific risks.

At 31 December 2021, wholesale management judgemental 
adjustments were an ECL increase of $1.2bn (31 December 2020: 
$0.2bn decrease). 

• Adjustments relating to low credit-risk exposures decreased 
ECL by $0.1bn at 31 December 2021 (31 December 2020: 
$0.7bn decrease). These were 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. The decrease in adjustment impact relative to 
31 December 2020 was mostly driven by increased alignment 
of modelled outcomes to management expectations following 
changes in systems and data.

• Adjustments to corporate exposures increased ECL by $1.3bn 
at 31 December 2021 (31 December 2020: $0.5bn increase). 
These principally reflected the outcome of management 
judgements for high-risk and vulnerable sectors in some of our 
key markets, supported by credit experts’ input, portfolio risk 
metrics, quantitative analyses and benchmarks. Considerations 
include risk of individual exposures under different 

HSBC Holdings plc Annual Report and Accounts 2021

149

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

macroeconomic scenarios and comparison of key risk metrics 
to pre-pandemic levels, resulting in either releases or increases 
to ECL in each geography. The increase in adjustment impact 
relative to 31 December 2020 was mostly driven by 
management judgements as a result of the effect of further 
improvement of macroeconomic scenarios on modelled 
outcomes and increased dislocation of modelled outcomes to 
management expectations for high-risk sectors and due to late-
breaking events not fully reflected in the underlying data. The 
highest increase was observed in the real estate sector, 
including an adjustment to reflect the uncertainty of the higher 
risk Chinese commercial real estate offshore exposures, booked 
in Hong Kong, on account of tightening liquidity and increased 
refinancing risks resulting in the downgrade of even some 
previously highly rated borrowers.

At 31 December 2021, retail management judgemental 
adjustments were an ECL increase of $0.5bn (31 December 2020: 
$1.5bn increase).

• Pandemic-related economic recovery adjustments increased 

ECL by $0.2bn (31 December 2020: $0) to adjust for the effects 
of the volatile pace of recovery from the pandemic. This is 
where in management’s judgement, supported by quantitative 
analyses of portfolio and economic metrics, modelled 
outcomes are overly sensitive given the limited observed 
deterioration in the underlying portfolio during the pandemic. 

• Other retail lending adjustments increased ECL by $0.3bn 

(31 December 2020: $0.3bn increase). These were primarily to 
address areas such as model recalibration and redevelopment, 
customer relief and data limitations.

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 

Wholesale analysis

IFRS 9 ECL sensitivity to future economic conditions1, 2, 3

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 at the balance sheet date. 

There is a particularly high degree of estimation uncertainty in 
numbers representing more severe risk scenarios when assigned a 
100% weighting. 

For wholesale credit risk exposures, the sensitivity analysis 
excludes ECL and financial instruments related to defaulted (stage 
3) obligors. It is generally impracticable to separate the effect of 
macroeconomic factors in individual assessments of obligors in 
default. The measurement of stage 3 ECL is relatively more 
sensitive to credit factors specific to the obligor than future 
economic scenarios, and loans to defaulted obligors are a small 
portion of the overall wholesale lending exposure, even if 
representing the majority of the allowance for ECL. Therefore, the 
sensitivity analysis to macroeconomic scenarios does not capture 
the residual estimation risk arising from wholesale stage 3 
exposures.

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 Downside 2 
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.

By geography at 31 Dec 2021

UK

US

Hong Kong

Mainland China

Canada

Mexico

UAE

France

By geography at 31 Dec 2020

UK

US

Hong Kong

Mainland China

Canada

Mexico

UAE

France

Gross carrying 
amount2

Reported ECL

Consensus 
Central scenario 
ECL

Consensus 
Upside scenario 
ECL

Consensus 
Downside 
scenario ECL

Downside 2 
scenario ECL

$m

483,273   

227,817   

434,608   

120,627   

85,117   

23,054   

44,767   

163,845   

430,555   

201,263   

452,983   

118,163   

85,720   

25,920   

44,777   

164,899   

$m

920   

227   

767   

149   

151   

118   

158   

133   

$m

727   

204   

652   

113   

98   

80   

122   

121   

$m

590   

155   

476   

36   

61   

61   

73   

106   

$m

944   

317   

984   

216   

150   

123   

214   

162   

2,077   

1,514   

1,026   

2,271   

369   

474   

116   

183   

246   

250   

117   

314   

388   

93   

140   

222   

241   

109   

219   

211   

28   

82   

177   

190   

97   

472   

672   

252   

253   

285   

330   

131   

$m

1,985 

391 

1,869 

806 

1,121 

358 

711 

187 

3,869 

723 

1,363 

1,158 

528 

437 

536 

238 

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  Excludes defaulted obligors. For a detailed breakdown of performing and non-performing wholesale portfolio exposures, see page 162. 

150

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
At 31 December 2021, the most significant level of ECL sensitivity 
was observed in Hong Kong, the UK and Canada. Real estate was 
the sector with higher sensitivity to a severe scenario, namely in 
Hong Kong and Canada. In the case of Hong Kong, the higher ECL 
sensitivity was mainly driven by increased uncertainty due to 
tightening liquidity and increased refinancing risks resulting in the 

Retail analysis

IFRS 9 ECL sensitivity to future economic conditions1

downgrade of even some previously highly rated borrowers. In the 
case of Canada, the higher ECL sensitivity was mainly driven by 
the adoption of a new Downside 2 scenario, which resulted in 
increased modelled ECL for this scenario relative to 31 December 
2020.

Gross carrying 
amount

Reported ECL

Consensus Central 
scenario ECL

Consensus Upside 
scenario ECL

Consensus 
Downside scenario 
ECL

Downside 2 
scenario ECL

ECL of loans and advances to 
customers at 31 December 2021

$m

$m

$m

$m

$m

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

155,084   

8,084   

7,902   

4,972   

1,167   

2,935   

96,697   

7,644   

5,628   

1,982   

429   

615   

23,159   

1,602   

15,379   

446   

26,097   

279   

1,598   

191   

439   

369   

123   

141   

366   

—   

218   

109   

45   

43   

19   

63   

61   

28   

80   

28   

9   

19   

182   

381   

298   

116   

134   

360   

—   

206   

101   

44   

41   

18   

62   

61   

27   

76   

27   

9   

18   

175   

330   

254   

106   

122   

350   

—   

154   

88   

42   

29   

13   

62   

60   

26   

70   

26   

9   

17   

197   

456   

388   

130   

150   

374   

—   

231   

128   

46   

54   

21   

63   

61   

29   

83   

29   

10   

19   

$m

231 

987 

830 

164 

176 

401 

— 

359 

180 

57 

82 

25 

64 

63 

41 

118 

48 

13 

27 

IFRS 9 ECL sensitivity to future economic conditions1 

Gross carrying 
amount

Reported ECL

ECL of loans and advances to customers 
at 31 December 2020

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

$m

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   

$m

197   

857   

897   

111   

260   

436   

—   

266   

112   

66   

92   

38   

68   

88   

41   

86   

31   

9   

22   

Central scenario   

Upside scenario   

ECL

$m

182   

774   

795   

101   

255   

428   

—   

259   

105   

63   

81   

37   

68   

87   

39   

84   

30   

9   

21   

ECL

$m

172   

589   

471   

79   

243   

411   

—   

247   

102   

53   

62   

33   

68   

85   

38   

81   

29   

8   

20   

Downside scenario 
ECL

Additional   

Downside scenario

$m

205   

904   

1,022   

136   

269   

451   

—   

277   

115   

73   

107   

41   

69   

88   

41   

88   

31   

9   

24   

$m

221 

1,084 

1,165 

167 

290 

491 

— 

405 

130 

78 

126 

46 

70 

91 

53 

119 

36 

9 

28 

1  ECL sensitivities exclude portfolios utilising less complex modelling approaches.

HSBC Holdings plc Annual Report and Accounts 2021

151

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.

Risk

At 31 December 2021, 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 remained 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 improved during 2021. 

Group ECL sensitivity results

The ECL impact of the scenarios and management judgemental 
adjustments are highly sensitive to movements in economic 
forecasts. Based upon the sensitivity tables presented above, if the 
Group ECL balance was estimated solely on the basis of the 
Central scenario, Downside scenario or the Downside 2 scenario 
at 31 December 2021, it would increase/(decrease) as presented in 
the below table.

Total Group ECL at 31 December 2021

Reported ECL

Scenarios

100% Consensus Central scenario

100% Consensus Upside scenario

100% Consensus Downside scenario

100% Downside 2 scenario 

Total Group ECL at 31 December 2020

Reported ECL

Scenarios

100% Consensus Central scenario

100% Consensus Upside scenario

100% Consensus Downside scenario

100% Downside 2 scenario

Retail1

Wholesale1

$bn 

3.0   

(0.2)   

(0.5)   

0.2   

2.0   

$bn

3.1 

(0.6) 

(1.2) 

0.6 

5.5 

Retail1

Wholesale

$bn

4.5   

(0.3)   

(1.0)   

0.3   

1.3   

$bn

4.5 

(0.9) 

(2.0) 

1.0 

5.9 

1  On the same basis as retail and wholesale sensitivity analysis.

For both retail and wholesale portfolios, the reported ECL 
decreased since 31 December 2020. The relative sensitivity of the 
Group total consensus Central scenario remained relatively stable, 
while the Group total consensus Upside and consensus Downside 
sensitivities both reduced since 31 December 2020. The Group 
total Downside 2 scenario continues to present the highest level of 
sensitivity. The Group results are reflective of the improvement in 
economic expectations, inclusive of the continuing pandemic-
related and sector-specific uncertainty.

152

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
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 2021

 1,506,451   

(2,331)    223,432   

(5,403)    20,424   

(7,544)   

279   

(113)   1,750,586   

(15,391) 

Transfers of financial instruments:

21,107   

(1,792)    (27,863)   

2,601   

6,756   

(809)   

–  transfers from stage 1 to stage 2

(159,633)   

527    159,633   

(527)   

–  transfers from stage 2 to stage 1

  182,432   

(2,279)   (182,432)   

2,279   

—   

—   

—   

—   

–  transfers to stage 3

–  transfers from stage 3

(2,345)   

653   

24   

(6,478)   

1,010   

8,823   

(1,034)   

(64)   

1,414   

(161)   

(2,067)   

225   

—   

—   

—   

—   

—   

—   

1,225   

—   

(596)   

—   

(34)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

— 

— 

— 

— 

— 

—   

595 

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
Others1
At 31 Dec 2021

ECL income statement change for 
the period

Recoveries

Others 

Total ECL income statement 
change for the period

  444,070   

(553)   

—   

—   

—   

—   

124   

—    444,194   

(553) 

(304,158)   

174    (31,393)   

489   

(2,750)   

458   

(10)   

6    (338,311)   

1,127 

(61,742)   

547   

(3,634)   

498   

(1,268)   

576   

(108)   

12   

(66,752)   

1,633 

—   

1,111   

—   

(1,012)   

—   

(2,354)   

—   

28   

—   

(2,227) 

—   

—   

—   

(17)   

—   

—   

—   

—   

—   

(25,231)   

(2,915)   

26   

(2,918)   

53   

(1,882)   

(33)   
—   

— 

45   

85   

—   

(2,610)   

1   
2,605   

(125)   

(479)   

(151)   

—   

157   

16   

—   

(7)   

—   

(4)   

—   

—   
7   

—   

(49) 

(2,617)   

2,612 

—   

(125)   

1   

(28,632)   

(5)   

(4,948)   

— 

229 

149 

 1,577,582   

(1,557)    155,742   

(3,326)    19,797   

(6,928)   

274   

(64)   1,753,395   

(11,875) 

2,487 

(654) 

(1,353) 

46 

526 

409 

(111) 

824 

1  Total includes $3.0bn of gross carrying loans and advances to customers, which were classified to assets held for sale and a corresponding 

allowance for ECL of $123m, reflecting our exit of the domestic mass market retail banking in the US.

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 2021

12 months ended 
31 Dec 2021

Gross carrying/nominal 
amount

Allowance for ECL

ECL charge

$m

1,753,395   

880,351   

42,421   

—   

2,676,167   

347,203   

n/a  

$m

(11,875)   

(193)   

—   

—   

(12,068)   

(96)   

(12,164)   

$m

824 

(19) 

— 

75 

880 

48 

928 

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 decreased $3,516m during 
the period from $15,391m at 31 December 2020 to $11,875m at 
31 December 2021.

This decrease was primarily driven by:

• $2,612m of assets written off;

• $2,207m relating to volume movements, which included the 
ECL allowance associated with new originations, assets 
derecognised and further lending/repayment;

• $595m relating to the net remeasurement impact of stage 

transfers; and

• foreign exchange and other movements of $378m.

These were partly offset by:

• $2,227m relating to underlying credit quality changes, including 
the credit quality impact of financial instruments transferring 
between stages; and

• $49m of changes to models used for ECL calculation.

The ECL release for the period of $526m presented in the previous 
table consisted of $2,207m relating to underlying net book volume 
movement and $595m relating to the net remeasurement impact 
of stage transfers. This was partly offset by $2,227m relating to 
underlying credit quality changes, including the credit quality 
impact of financial instruments transferring between stages and 
$49m in changes to models used for ECL calculation. 

Summary views of the movement in wholesale and personal 
lending are presented on pages 165 and 179.

HSBC Holdings plc Annual Report and Accounts 2021

153

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 
exposure

$m

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

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

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) 

Foreign exchange

Others

32,808   

(47)   

9,123   

(76)   

5   

292   

—   

—   

—   

(223)   

(1)   

(23)   

633   

(1)   

7   

(163)   

8   

134   

—   

—   

—   

294   

—   

5   

—   

(2,946)   

2,944   

—   

—   

—   

—   

(30)   

—   

4   

8   

—   

30   

—   

(3)   

(1)   

—   

(2,976)   

(23)   

42,568   

223   

433 

2,974 

7 

(436) 

11 

At 31 Dec 2020
ECL income statement change for 
the period

Recoveries

Others
Total ECL income statement change 
for the period

  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) 

154

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 138.

Distribution of financial instruments by credit quality at 31 December 2021

(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

544,695   

230,326   

233,739   

29,404   

19,067   

1,057,231   

(11,417)   

1,045,814 

–  personal

388,903   

52,080   

30,492   

1,920   

4,942   

478,337   

–  corporate and commercial

124,819   

158,938   

188,858   

27,194   

13,730   

513,539   

–  non-bank financial institutions

30,973   

19,308   

14,389   

290   

395   

65,355   

(3,103)   

(8,204)   

(110)   

475,234 

505,335 

65,245 

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

72,978   

4,037   

5,020   

1,118   

—   

83,153   

(17)   

83,136 

400,176   

1,675   

1,171   

4,122   

42,578   

10   

—   

4   

—   

175,576   

46,412   

18,881   

67,097   

12,109   

11,685   

1,742   

65,355   

5,240   

6,869   

4,038   

7,647   

—   

—   

—   

779   

1   

408   

199   

209   

—   

403,022   

(4)   

403,018 

—   

4,136   

—   

4,136 

—   

42,578   

—   

42,578 

—   

43   

241,648   

97,364   

—   

241,648 

(62)   

97,302 

304   

26   

278   

91,603   

11,245   

80,358   

(127)   

(17)   

(110)   

91,476 

11,228 

80,248 

320,161   

12,298   

11,677   

1,087   

46   

345,269   

(96)   

345,173 

Financial investments

84,477   

11,442   

1,401   

Trading assets

101,879   

16,254   

20,283   

678   

134   

139,228   

—   

139,228 

Other financial assets designated 
and otherwise mandatorily 
measured at fair value through 
profit or loss 

Derivatives

Total gross carrying amount 
on balance sheet

6,438   

723   

146,748   

42,717   

4,455   

6,691   

150   

719   

—   

7   

11,766   

196,882   

—   

—   

11,766 

196,882 

1,966,925   

378,003   

315,007   

34,344   

19,601   

2,713,880   

(11,723)   

2,702,157 

Percentage of total credit quality

72.5%

13.9%

11.6%

1.3%

0.7%

100%

Loan and other credit-related 
commitments

389,865   

136,297   

92,558   

Financial guarantees

16,511   

4,902   

5,166   

8,142   

991   

775   

225   

627,637   

27,795   

(379)   

627,258 

(62)   

27,733 

In-scope: Irrevocable loan 
commitments and financial 
guarantees

Loan and other credit-related 
commitments

406,376   

141,199   

97,724   

9,133   

1,000   

655,432   

(441)   

654,991 

Performance and other 

31,510   

32,193   

19,265   

62,701   

65,031   

56,446   

3,327   

2,027   

332   

539   

187,837   

85,534   

—   

187,837 

(179)   

85,355 

Out-of-scope: Revocable loan 
commitments and non-
financial guarantees

94,211   

97,224   

75,711   

5,354   

871   

273,371   

(179)   

273,192 

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 2021

155

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Distribution of financial instruments by credit quality at 31 December 2020 (continued)

(Audited)

Gross carrying/notional amount

Strong

$m

Good

Satisfactory Sub- standard

Credit impaired

$m

$m

$m

$m

Total

$m

Allowance for 
ECL/other 
credit 
provisions

$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

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

506,231   

233,320   

256,584   

357,821   

120,971   

27,439   

53,892   

38,520   

158,601   

203,560   

20,827   

14,504   

36,970   

4,965   

30,718   

1,287   

19,372   

1,052,477   

(14,490)   

1,037,987 

5,611   

13,238   

523   

460,809   

527,088   

64,580   

(4,731)   

(9,494)   

(265)   

456,078 

517,594 

64,315 

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   

1,458   

80,428   

10,129   

11,570   

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   

178   

20   

158   

230,628   

88,719   

104,061   

10,307   

93,754   

—   

(80)   

(90)   

(30)   

(60)   

230,628 

88,639 

103,971 

10,277 

93,694 

367,685   

12,678   

10,409   

825   

306   

391,903   

(141)   

391,762 

117,972   

14,694   

20,809   

829   

43   

154,347   

—   

154,347 

6,440   

243,005   

2,378   

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 

Financial investments

77,361   

9,781   

1,537   

Percentage of total credit quality

72.0%

13.9%

11.9%

1.5%

0.7%

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

400,911   

157,339   

90,784   

6,356   

5,194   

5,317   

9,668   

1,247   

1,081   

659,783   

270   

18,384   

(734)   

(125)   

659,049 

18,259 

407,267   

162,533   

96,101   

10,915   

1,351   

678,167   

(859)   

677,308 

59,392   

26,082   

62,664   

27,909   

59,666   

21,256   

2,837   

2,112   

430   

755   

184,989   

78,114   

—   

184,989 

(226)   

77,888 

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.

156

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
–  stage 1

–  stage 2

–  stage 3

–  POCI

–  stage 1

–  stage 2

–  stage 3

–  POCI

Financial guarantees

–  stage 1

–  stage 2

–  stage 3

–  POCI

At 31 Dec 2021
Debt instruments at FVOCI1
–  stage 1

–  stage 2

–  stage 3

–  POCI

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

Gross carrying/notional amount

Strong

$m

Good Satisfactory

Sub-
standard

Credit 
impaired

$m

$m

$m

$m

Total

$m

Allowance  

for ECL

$m

Net

$m

544,695   

230,326   

233,739   

29,404   

19,067    1,057,231   

(11,417)    1,045,814 

537,642   

206,645   

169,809   

4,840   

7,053   

23,681   

63,930   

24,560   

—   

—   

918,936   

(1,367)   

917,569 

119,224   

(3,119)   

116,105 

—   

—   

72,978   

72,903   

75   

—   

—   

—   

—   

4,037   

3,935   

102   

—   

—   

—   

—   

5,020   

4,788   

—   

4   

1,118   

10   

232   

1,108   

—   

—   

—   

—   

18,797   

18,797   

(6,867)   

11,930 

270   

274   

—   

—   

—   

—   

—   

83,153   

81,636   

1,517   

—   

—   

(64)   

(17)   

(14)   

(3)   

—   

—   

210 

83,136 

81,622 

1,514 

— 

— 

Other financial assets measured at amortised 
cost

774,026   

71,648   

33,142   

1,188   

347   

880,351   

(193)   

880,158 

Loan and other credit-related commitments 

389,865   

136,297   

92,558   

773,427   

70,508   

30,997   

84   

599   

1,140   

2,145   

1,104   

—   

—   

—   

—   

—   

—   

387,434   

129,455   

76,043   

2,431   

6,842   

16,515   

—   

—   

16,511   

16,351   

160   

—   

—   

—   

—   

4,902   

4,469   

433   

—   

—   

—   

—   

5,166   

3,929   

1,237   

—   

—   

—   

—   

304   

43   

875,016   

4,988   

304   

43   

(91)   

(54)   

(42)   

(6)   

874,925 

4,934 

262 

37 

775   

627,637   

(379)   

627,258 

—   

—   

594,473   

32,389   

(165)   

594,308 

(174)   

32,215 

775   

—   

775   

—   

225   

27,795   

—   

—   

225   

—   

24,932   

2,638   

225   

—   

(40)   

—   

(62)   

(11)   

(30)   

(21)   

—   

735 

— 

27,733 

24,921 

2,608 

204 

— 

—   

—   

8,142   

1,541   

6,601   

—   

—   

991   

183   

808   

—   

—   

  1,798,075   

447,210   

369,625   

40,843   

20,414    2,676,167   

(12,068)    2,664,099 

319,557   

12,196   

11,354   

—   

604   

102   

323   

1,087   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

46   

46   

343,107   

2,116   

—   

46   

(67)   

(22)   

—   

(7)   

343,040 

2,094 

— 

39 

345,269   

(96)   

345,173 

At 31 Dec 2021

320,161   

12,298   

11,677   

1,087   

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 2021

157

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

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

506,231   

233,320   

256,584   

36,970   

19,372   

1,052,477   

(14,490)   

1,037,987 

Gross carrying/notional amount

Strong

$m

Good

Satisfactory Sub-standard

$m

$m

$m

Credit 
impaired

$m

Allowance for 
ECL

$m

Total 

$m

 Net

$m

Loan and other credit-related commitments

400,911   

157,339   

–  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

–  stage 1

–  stage 2

–  stage 3

–  POCI

Financial guarantees

–  stage 1

–  stage 2

–  stage 3

–  POCI

At 31 Dec 2020
Debt instruments at FVOCI1
–  stage 1

–  stage 2

–  stage 3

–  POCI

At 31 Dec 2020

499,836   

199,138   

165,507   

5,439   

6,395   

34,182   

91,077   

31,531   

—   

—   

71,318   

71,126   

192   

—   

—   

—   

—   

5,496   

5,098   

398   

—   

—   

—   

—   

3,568   

3,357   

211   

—   

—   

683,231   

61,768   

26,581   

682,412   

61,218   

24,532   

550   

2,049   

819   

—   

—   

—   

—   

396,028   

143,600   

4,883   

13,739   

—   

—   

6,356   

6,286   

70   

—   

—   

—   

—   

5,194   

4,431   

763   

—   

—   

—   

—   

90,784   

63,592   

27,192   

—   

—   

5,317   

3,163   

2,154   

—   

—   

—   

—   

869,920   

163,185   

19,095   

19,095   

277   

—   

—   

—   

—   

—   

277   

81,658   

79,654   

2,004   

—   

—   

(1,974)   

(4,965)   

(7,439)   

(112)   

(42)   

(33)   

(9)   

—   

—   

867,946 

158,220 

11,656 

165 

81,616 

79,621 

1,995 

— 

— 

217   

772,408   

(175)   

772,233 

—   

—   

177   

40   

768,216   

3,975   

177   

40   

1,081   

659,783   

—   

—   

1,080   

1   

270   

—   

—   

269   

1   

604,485   

54,217   

1,080   

1   

18,384   

14,090   

4,024   

269   

1   

(80)   

(44)   

(42)   

(9)   

(734)   

(290)   

(365)   

(78)   

(1)   

(125)   

(37)   

(62)   

(26)   

—   

768,136 

3,931 

135 

31 

659,049 

604,195 

53,852 

1,002 

— 

18,259 

14,053 

3,962 

243 

1 

—   

—   

1,276   

73   

1,203   

—   

—   

611   

54   

557   

—   

—   

9,668   

1,265   

8,403   

—   

—   

1,247   

210   

1,037   

—   

—   

1,668,047   

463,117   

382,834   

49,772   

20,940   

2,584,710   

(15,566)   

2,569,144 

367,542   

12,585   

10,066   

143   

—   

—   

93   

—   

—   

343   

—   

—   

367,685   

12,678   

10,409   

—   

825   

—   

—   

825   

—   

—   

257   

49   

306   

390,193   

1,404   

257   

49   

(88)   

(20)   

(23)   

(10)   

390,105 

1,384 

234 

39 

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.

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 159. 

A summary of our current policies and practices for renegotiated loans and 
forbearance is set out in ‘Credit risk management’ on page 137.

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.

158

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Renegotiated loans and advances to customers at amortised cost by stage allocation

Stage 1

$m

Stage 2

$m

Stage 3

$m

POCI

$m

Gross carrying amount

Personal

–  first lien residential mortgages

–  other personal lending

Wholesale

–  corporate and commercial

–  non-bank financial institutions

At 31 Dec 2021

Allowance for ECL

Personal

–  first lien residential mortgages

–  other personal lending

Wholesale

–  corporate and commercial

–  non-bank financial institutions

At 31 Dec 2021

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

—   

—   

—   

366   

355   

11   

366   

—   

—   

—   

(7)   

(7)   

—   

(7)   

—   

—   

—   

328   

324   

4   

328   

—   

—   

—   

(10)   

(10)   

—   

(10)   

Renegotiated loans and advances to customers by geographical region

Europe

$m

Asia

$m

MENA

$m

—   

—   

—   

559   

550   

9   

559   

—   

—   

—   

(24)   

(24)   

—   

(24)   

—   

—   

—   

989   

972   

17   

989   

—   

—   

—   

(36)   

(36)   

—   

(36)   

2,256   

1,547   

709   

4,505   

4,491   

14   

6,761   

(400)   

(178)   

(222)   

(1,282)   

(1,274)   

(8)   

(1,682)   

2,429   

1,692   

737   

3,929   

3,903   

26   

6,358   

(452)   

(152)   

(300)   

(1,276)   

(1,263)   

(13)   

(1,728)   

North 
America

Latin 
America

$m

$m

480   

267   

Total

$m

2,256 

1,547 

709 

5,683 

5,649 

34 

7,939 

(400) 

(178) 

(222) 

(1,365) 

(1,357) 

(8) 

(1,765) 

2,429 

1,692 

737 

5,485 

5,438 

47 

7,914 

(452) 

(152) 

(300) 

(1,408) 

(1,395) 

(13) 

(1,860) 

—   

—   

—   

253   

253   

—   

253   

—   

—   

—   

(52)   

(52)   

—   

(52)   

—   

—   

—   

239   

239   

—   

239   

—   

—   

—   

(86)   

(86)   

—   

(86)   

Of which:

Total

$m

UK

$m

7,939   

3,469   

7,914   

3,483   

Hong 
Kong

$m

528 

220 

At 31 Dec 2021

At 31 Dec 2020

4,119   

1,322   

954   

1,064   

4,274   

745   

1,279   

1,349   

Customer relief programmes

In response to the Covid-19 pandemic, governments and 
regulators around the world 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 2021. When 
schemes expire, accounts and customers and their associated 
drawn balances are no longer reported under relief regardless of 
their repayment status. 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 2021, the gross carrying value of loans to 
personal customers under relief was $1.7bn (31 December 2020: 
$5.5bn). This comprised $1.0bn in relation to mortgages 
(31 December 2020: $4.7bn) and $0.7bn in relation to other 
personal lending (31 December 2020: $0.9bn). The decrease in 
personal customer relief during the year was driven by customers 
exiting relief measures. The gross carrying value of loans to 
wholesale customers under relief was $26.3bn (31 December 
2020: $35.3bn). 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 2021.

HSBC Holdings plc Annual Report and Accounts 2021

159

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
Risk

Personal lending

Extant at 31 December 2021

Market-wide schemes

Number of accounts granted mortgage customer relief

Drawn loan value of accounts granted mortgage customer relief
Number of accounts granted other personal lending customer relief

Drawn loan value of accounts granted other personal lending customer relief

HSBC-specific measures

Number of accounts granted mortgage customer relief

Drawn loan value of accounts granted mortgage customer relief

Number of accounts granted other personal lending customer relief

Drawn loan value of accounts granted other personal lending customer relief
Total personal lending to major markets under market-wide schemes and 
HSBC-specific measures

Number of accounts granted mortgage customer relief

Drawn loan value of accounts granted mortgage customer relief

Number of accounts granted other personal lending customer relief

Drawn loan value of accounts granted 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 2021

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

—  

—  
—  

—  

— 

— 

— 

— 

—   

—   

—   

—   

 — 

 — 

—   

—   
—   

—   

—

57

—

34

—   

57   

—   

34   

 0.1 

 0.1 

UK

227

Hong
Kong

1

12,468

2,907

—

82

5  

4,611

US

— 

— 
— 

— 

1

336

—

18

1   

336   

—   

18   

 2.0 

 2.3 

US

1

262

— 

42

Other major 
markets1,2

Total

8  

657  
34  

613  

—  

3  

1  

10  

8   

660   

35   

623   

 0.8 

 1.2 

8 

657 
34 

613 

1 

396 

1 

62 

9 

1,053 

35 

675 

 0.3 

 0.7 

Other major 
markets1

Total

5  

234 

4,501  

20,138 

—  

5 

1,420  

6,155 

227   

6   

12,550   

7,518   

1   

304   

5   

239 

5,921   

26,293 

Market-wide schemes and HSBC-specific measures as a proportion of total 
wholesale lending loans and advances

%

 9.9 

 4.1 

 0.9 

 2.9 

 4.8 

Personal lending (continued)

Extant at 31 December 2020

Market-wide schemes

UK Hong Kong

US

Other major 
markets1,2,3

Number of accounts granted mortgage customer relief

Drawn loan value of accounts granted mortgage customer relief

Number of accounts granted other personal lending customer relief

Drawn loan value of accounts granted other personal lending customer relief

HSBC-specific measures

Number of accounts granted mortgage customer relief

Drawn loan value of accounts granted mortgage customer relief

Number of accounts granted other personal lending customer relief

Drawn loan value of accounts granted other personal lending customer relief

Total personal lending to major markets under market-wide schemes and HSBC-
specific measures

Number of accounts granted mortgage customer relief

Drawn loan value of accounts granted mortgage customer relief

Number of accounts granted other personal lending customer relief

Drawn loan value of accounts granted 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

000s

$m

000s

$m

000s

$m

000s

$m

000s

$m

000s

$m

%

%

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 

— 

— 

— 

— 

2

864

6

67

2   

864   

6   

67   

 4.7 

 3.1 

5  

908  

28  

386  

3  

360  

18  

182  

8   

1,268   

46   

568   

 1.6 

 1.1 

Total

11 

2,320 

43 

526 

8 

2,355 

25 

324 

19 

4,675 

68 

850 

 1.4 

 0.8 

160

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale lending (continued)

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

UK Hong Kong

US

Other major 
markets1

Total

226

3

13,517

10,622

3

1,043

5  

237 

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, 

2 

3 

Switzerland, Taiwan and UAE.
In Malaysia, personal lending customers are granted an automatic moratorium programme for all eligible retail customers. As a result of further 
loosening of eligibility criteria and scope of relief measures, the country is now the major contributor to the figures reported under ‘Other major 
markets’. At 31 December 2021, the number of accounts under relief was 39,000 (31 December 2020: 26,000) with an associated drawn balance 
of $1,151m (31 December 2020: $452m).
In Mexico, at 31 December 2020, there were 16,000 personal lending accounts under customer relief with an associated drawn balance of 
$233m. 

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 pandemic 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 consisted of 
payment holidays or partial payment deferrals.

Relief was offered for an initial period of three months and could 
be extended for a further three months in certain circumstances. 
No payment was required from the customer during this period 
(though with a partial payment deferral the customer had 
expressed a desire to make a contribution) and interest continued 
to be charged as usual. The customer’s arrears status was not 
worsened from utilisation of these schemes. All UK personal 
lending schemes expired during 2021.

Other personal lending payment holidays

Customer relief was granted for an initial period of three months 
and could be extended for a further three months. The maximum 
relief value was up to the due payment amount during the period. 
All UK personal lending schemes expired during 2021.

UK wholesale lending 

The primary relief granted under government schemes consisted 
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 was extended to 31 March 
2021. The key features of these schemes were as follows:

• The Bounce Back Loan Scheme provided small and medium-
sized enterprises (‘SME’) with loans of up to £50,000 for a 

maximum period of six years. Interest was charged at 2.5% and 
the government paid the fees and interest for the first 12 
months. No capital repayment was required by the customer 
for the first 12 months of the scheme. A government guarantee 
of 100% was provided under the scheme. Before their first 
payment was due customers could extend the term of the loan 
to 10 years, move to interest-only repayments for a period of 
six months (customers could use this option up to three times) 
and/or pause repayments for a period of six months (customers 
could use this option once).

• The Coronavirus Business Interruption Loan Scheme provided 

SMEs that had a turnover of less than £45m with loans of up to 
£5m for a maximum period of six years. Interest was charged 
between 3.49% and 3.99% above the UK base rate and no 
capital repayment was required by the customer for the first 12 
months of the scheme. A government guarantee of up to 80% 
was provided under the scheme.

• The Coronavirus Large Business Interruption Loan Scheme 
provided medium and large-sized enterprises that had a 
turnover in excess of £45m with loans of up to £200m. The 
interest rate and tenor of the loan were negotiated on 
commercial terms. A government guarantee of 80% was 
provided under the scheme.

Until 31 December 2021, the Recovery Loan Scheme, launched on 
6 April 2021, provided businesses of any size financial support to 
recover from the Covid-19 pandemic with loans of £25,001 to 
£10m subject to eligibility and viability assessments. A 
government guarantee of 80% was provided under the scheme. 

For term loans and asset finance, businesses could borrow for 
three months up to six years and for overdrafts and invoice 
finance, three months up to three years. The scheme was 
extended until 30 June 2022, with the following changes coming 
into force from 1 January 2022: the scheme remains open to small 
and medium-sized enterprises and the maximum amount of 
finance available is £2m per business. A government guarantee of 
70% is provided on such loans.

Hong Kong wholesale lending

Pre-approved Principal Payment Holiday Scheme for Corporate 
Customers

The above scheme enabled 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 (‘HKMA’) announced 
that this scheme had been extended for a further six months to 
April 2021 and on 4 March 2021, it was extended for a further six 
months (or 90 days for trade finance) to October 2021.

HSBC Holdings plc Annual Report and Accounts 2021

161

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 2021 to 31 December 2021 
closing gross carrying/nominal amounts and the associated 
allowance for ECL.

At 31 December 2021, wholesale lending for loans and advances 
to banks and customers of $662bn decreased by $11.3bn since 
31 December 2020. This included adverse foreign exchange 
movements of $10.6bn. Excluding foreign exchange movements, 
the total wholesale lending decrease was driven by a $5.2bn 
decline in corporate and commercial balances. This was partly 
offset by a $3bn increase in loans and advances to banks and a 
$1.5bn increase in balances from non-bank financial institutions.

The primary driver of the decline in corporate and commercial 
balances was $11.2bn in Europe, notably $12.4bn in the UK and 
$1bn in Germany, partly offset by growth of $4.6bn in France.

In MENA and North America, balances declined $1.4bn and 
$0.9bn respectively, while they grew in Asia by $8.0bn, notably 
$4.3bn in mainland China, $1.6bn in Hong Kong and $1.1bn in 
India.

Loan commitments and financial guarantees declined $26.5bn 
since 31 December 2020 to $415bn at 31 December 2021, 
including a $19.3bn decrease related to unsettled reverse 
repurchase agreements. This also included adverse foreign 
exchange movements of $12.7bn.

The allowance for ECL attributable to wholesale loans and 
advances to banks and customers decreased $1.5bn to $8.3bn at 
31 December 2021 from $9.8bn at 31 December 2020. This 
included favourable foreign exchange movements of $0.2bn. 

Excluding foreign exchange movements, the total decrease in the 
wholesale ECL allowance for loans and advances to customers 
and banks was driven by a $1.1bn decline in corporate and 
commercial allowances. The primary driver of this decrease in 
corporate and commercial allowance for ECL was $1.1bn in 
Europe, notably $1.1bn in the UK. Additionally, there were 
decreases of $0.2bn, $0.2bn and $0.1bn in MENA, North America 
and Latin America, respectively. There was an increase of $0.6bn 
in Asia, notably $0.4bn in Hong Kong. 

The allowance for ECL attributable to loan commitments and 
financial guarantees of $0.4bn at 31 December 2021 decreased 
from $0.8bn at 31 December 2020.

Risk

Given the persistence of the Covid-19 pandemic around the world 
and the severity of the ensuing impact on the global and local 
economy, HKMA – together with the Banking Sector SME Lending 
Coordination Mechanism – announced on 21 September 2021 that 
the Pre-approved Principal Payment Holiday Scheme would be 
extended for another six months until April 2022. HKMA and the 
coordination mechanism agreed that all principal payments of 
loans falling due between November 2021 and April 2022 by 
eligible corporate customers would be deferred by another six 
months except for repayments of trade loans, which would be 
deferred by 90 days.

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 were fully guaranteed by the Small Business 
Administration, whose guarantee was backed by the full faith and 
credit of the US. PPP-covered loans also afforded customers 
forgiveness up to the principal amount of the PPP-covered loan, 
plus accrued interest, if the loan proceeds were used to retain 
workers and maintain payroll or to make certain mortgage 
interest, lease and utility payments, and certain other criteria were 
satisfied. The Small Business Administration would reimburse PPP 
lenders for any amount of a PPP-covered loan that was forgiven, 
and PPP lenders would not be liable for any representations made 
by PPP borrowers in connection with their requests for loan 
forgiveness. Lenders received pre-determined fees for processing 
and servicing PPP loans. The schemes have now been closed.

HSBC-specific measures

UK wholesale lending

HSBC offered capital repayment holidays to CMB customers. 
Relief was offered on a preferred term of six months. However, 
some were granted for three months with the option of an 
extension. Interest continued to be paid as usual. Schemes have 
now been closed for application.

Hong Kong personal lending

Mortgages 

Customer relief granted on Hong Kong mortgages consisted of 
deferred principal repayment of up to 12 months. This relief 
programme was available to existing HSBC mortgage loan 
customers who had a good repayment record during the six 
months prior to application. Schemes have now been closed for 
application.

Hong Kong wholesale lending

On 20 May 2021, the Group announced a new SME financing 
scheme in Hong Kong, with HK$40bn reserved to support SME 
customers as the economy started to recover. The scheme has 
now been closed for application.

US total personal lending

Customer relief granted on US mortgages and other personal 
lending consisted of deferrals of up to 12 months and up to nine 
months respectively. Schemes have now been closed for 
application.

162

HSBC Holdings plc Annual Report and Accounts 2021

–  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

–  accommodation and food

–  publishing, audiovisual and 

broadcasting

–  real estate

Total wholesale lending for loans and advances to banks and customers by stage distribution

Corporate and commercial

  400,894    98,911    13,460   

274    513,539   

(665)   

(1,874)   

(5,601)   

(64)   

(8,204) 

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

6,510   

1,026   

7,167   

2,055   

362   

447   

1   

7,899   

16   

9,685   

(10)   

(17)   

(23)   

(39)   

  75,193    16,443   

2,019   

88    93,743   

(110)   

(176)   

(104)   

(159)   

(931)   

(1)   

(12)   

(31)   

(138) 

(227) 

(1,248) 

  15,255   

1,285   

78   

—    16,618   

(16)   

(21)   

(31)   

—   

(68) 

–  transportation and storage

  21,199   

7,726   

658   

8,080    14,096   

1,199   

9    29,592   

1    23,376   

3,376   

468   

9,506   

3,605   

51   

842   

—   

3,895   

1    13,954   

  79,137    12,802   

3,003   

2    94,944   

(5)   

(24)   

(71)   

(56)   

(67)   

(4)   

(20)   

(44)   

(439)   

(99)   

(1,936)   

(116)   

(245)   

(191)   

(110)   

  16,417   

1,804   

222   

28    18,471   

(37)   

(47)   

(94)   

  93,633    25,154   

2,375   

98    121,260   

(132)   

(737)   

(775)   

–  professional, scientific and technical 

activities

  16,160   

2,888   

–  administrative and support services

  23,186   

4,740   

–  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

938   

1,455   

3,743   

1,620   

333   

273   

928   

826   

  10,123   

1,726   

860   

117   

2   

7,010   

324   

—   

602   

14   

Non-bank financial institutions

  61,086   

3,874   

Loans and advances to banks

  81,636   

1,517   

637   

719   

—   

65   

183   

152   

448   

—   

—   

—   

—   

395   

—   

—    19,685   

30    28,675   

—   

—   

—   

—   

1,271   

1,793   

4,854   

2,598   

—    12,297   

—   

977   

—   

—   

—   

2   

7,612   

338   

—    65,355   

—    83,153   

(26)   

(40)   

(5)   

(4)   

(11)   

(6)   

(26)   

—   

—   

(2)   

—   

(44)   

(14)   

(40)   

(84)   

(3)   

(15)   

(24)   

(44)   

—   

(18)   

(37)   

(42)   

(101)   

(246)   

—   

—   

—   

(2)   

(10)   

(26)   

(3)   

—   

—   

—   

(40)   

—   

—   

(1)   

(1)   

—   

(1)   

(29) 

(508) 

(2,107) 

(363) 

(423) 

(6)   

—   

(184) 

(1,644) 

(238) 

(431) 

(8) 

(37) 

(72) 

(92) 

(373) 

— 

— 

(4) 

(10) 

(110) 

(17) 

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(172)   

(296)   

—   

(11)   

At 31 Dec 2021

By geography

Europe

–  of which: UK

Asia

MENA

North America

Latin America

At 31 Dec 2021

  543,616    104,302    13,855   

274    662,047   

(723)   

(1,903)   

(5,641)   

(64)   

(8,331) 

  154,575    31,871   

6,741   

30    193,217   

  101,029    24,461   

5,126   

28    130,644   

  297,423    53,993   

3,997   

199    355,612   

  26,135   

5,295   

1,682   

22    33,134   

  53,513    10,397   

  11,970   

2,746   

652   

783   

—    64,562   

23    15,522   

(356)   

(306)   

(182)   

(85)   

(62)   

(57)   

(66)   

(654)   

(1,806)   

(518)   

(1,060)   

(830)   

(2,299)   

(650)   

(836)   

(108)   

(1,028)   

(215)   

(96)   

(169)   

(339)   

(9)   

(6)   

(43)   

(21)   

(11)   

—   

(1)   

(2,825) 

(1,890) 

(3,354) 

(1,592) 

(1,209) 

(441) 

(502) 

  543,616    104,302    13,855   

274    662,047   

(723)   

(1,903)   

(5,641)   

(64)   

(8,331) 

–  of which: Hong Kong

  165,437    30,305   

1,990   

159    197,891   

Total wholesale lending for loans and other credit-related commitments and financial guarantees by stage distribution1

Nominal amount

Allowance for ECL

Corporate and commercial

  274,775    30,376   

829   

—    305,980   

(130)   

(193)   

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

Total

Stage 1

Stage 2

Stage 3

$m

$m

$m

Financial 

At 31 Dec 2021

By geography

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2021

  105,746   

2,889   

2   

—    108,637   

(9)   

(9)   

  380,521    33,265   

831   

—    414,617   

(139)   

(202)   

  189,770    15,585   

  68,136   

8,430   

  72,179   

5,229   

  31,314   

1,517   

6,335   

1,017   

  109,851    11,350   

2,386   

84   

673   

389   

20   

10   

19   

91   

28   

—    206,028   

—    76,955   

—    77,428   

—    32,841   

—   

7,371   

—    121,292   

—   

2,498   

(67)   

(55)   

(35)   

(11)   

(10)   

(24)   

(3)   

(76)   

(49)   

(40)   

(17)   

(18)   

(66)   

(2)   

  380,521    33,265   

831   

—    414,617   

(139)   

(202)   

(61)   

$m

(60)   

(1)   

(61)   

(47)   

(28)   

(5)   

(2)   

(3)   

(1)   

(5)   

POCI

$m

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

Total

$m

(383) 

(19) 

(402) 

(190) 

(132) 

(80) 

(30) 

(31) 

(91) 

(10) 

(402) 

1 

Included in loans and other credit-related commitments and financial guarantees is $42bn relating to unsettled reverse repurchase agreements, 
which once drawn are classified as ‘Reverse repurchase agreements – non-trading’.

HSBC Holdings plc Annual Report and Accounts 2021

163

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Total wholesale lending for loans and advances to banks and customers by stage distribution

Corporate and commercial

  387,563    126,287   

12,961   

277    527,088   

(1,101)   

(2,444)   

(5,837)   

(112)   

(9,494) 

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

6,087   

7,429   

1,026   

3,705   

331   

797   

68,179   

23,564   

2,076   

1   

16   

87   

7,445   

11,947   

93,906   

(12)   

(33)   

(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   

4   

14,600   

(8)   

(42)   

(7)   

(118)   

(22)   

(426)   

–  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

65,937   

21,518   

3,196   

19,510   

9,143   

10,616   

14,918   

769   

536   

12   

11   

90,663   

29,433   

1   

26,071   

17,019   

2,796   

131   

33   

19,979   

  102,933   

22,186   

1,907   

1    127,027   

–  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

Non-bank financial institutions

Loans and advances to banks

1,530   

1,402   

4,049   

1,631   

11,380   

660   

10   

7,866   

596   

475   

691   

1,192   

1,570   

1,320   

142   

—   

671   

15   

52,223   

11,834   

79,654   

2,004   

498   

907   

3   

29   

261   

236   

410   

—   

—   

1   

—   

523   

—   

33   

70   

24,072   

26,423   

—   

—   

8   

—   

—   

—   

—   

—   

—   

—   

—   

2,008   

2,122   

5,510   

3,437   

13,110   

802   

10   

8,538   

611   

64,580   

81,658   

(174)   

(326)   

(2,029)   

(90)   

(76)   

(45)   

(169)   

(56)   

(66)   

(2)   

(12)   

(21)   

(9)   

(54)   

—   

—   

(6)   

—   

(46)   

(33)   

(163)   

(285)   

(85)   

(260)   

(149)   

(153)   

(11)   

(20)   

(45)   

(62)   

(105)   

(1)   

—   

(2)   

(13)   

(119)   

(9)   

(240)   

(129)   

(39)   

(738)   

(185)   

(291)   

(1)   

(9)   

(120)   

(87)   

(249)   

—   

—   

(1)   

—   

(100)   

—   

—   

(4)   

(3)   

—   

(1)   

(37) 

(590) 

(2,532) 

(493) 

(491) 

(20)   

(189) 

—   

(1,167) 

(8)   

(24)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(398) 

(534) 

(14) 

(41) 

(186) 

(158) 

(408) 

(1) 

— 

(9) 

(13) 

(265) 

(42) 

At 31 Dec 2020

By geography

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2020

  519,440    140,125   

13,484   

277    673,326   

(1,180)   

(2,572)   

(5,937)   

(112)   

(9,801) 

  156,474   

51,708   

  104,534   

40,454   

  279,985   

58,159   

  156,817   

39,257   

24,753   

7,893   

46,852   

18,220   

11,376   

4,145   

6,531   

4,712   

3,443   

1,637   

1,952   

913   

645   

109    214,822   

53    149,753   

106    341,693   

45    197,756   

30   

—   

32   

34,628   

65,985   

16,198   

(589)   

(536)   

(337)   

(162)   

(91)   

(77)   

(86)   

(1,400)   

(2,097)   

(1,234)   

(1,320)   

(383)   

(260)   

(216)   

(302)   

(271)   

(2,040)   

(751)   

(1,205)   

(281)   

(314)   

(51)   

(33)   

(43)   

(23)   

(12)   

—   

(6)   

(4,137) 

(3,123) 

(2,803) 

(1,196) 

(1,524) 

(660) 

(677) 

  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

Corporate and commercial

  262,598   

49,008   

1,140   

2    312,748   

Nominal amount

Stage 1

Stage 2

Stage 3

$m

$m

$m

POCI

$m

Total

$m

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

  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   

26,502   

4,975   

6,311   

3,639   

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   

Allowance for ECL

Stage 1

Stage 2

Stage 3

$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)   

POCI

$m

(1)   

—   

(1)   

(1)   

(1)   

—   

—   

—   

—   

—   

(1)   

Total

$m

(764) 

(54) 

(818) 

(444) 

(387) 

(122) 

(47) 

(60) 

(170) 

(22) 

(818) 

  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’.

164

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021

  841,105   

(1,465)    196,662   

(2,998)   

14,662   

(6,041)   

Transfers of financial instruments

19,285   

(638)   

(23,361)   

888   

4,076   

(250)   

$m

$m

$m

$m

$m

$m

$m

279   

—   

$m

$m

$m

(113)   1,052,708   

(10,617) 

—   

—   

—   

— 

—   

140 

—   

400   

—   

(233)   

—   

(27)   

—   

38,224   

20   

(32,150)   

454   

(2,501)   

764   

6   

18   

3,579   

1,256 

—   

793   

—   

(234)   

—   

(1,347)   

—   

28   

—   

(760) 

—   

—   

—   

(15)   

—   

—   

—   

—   

—   

(33)   

—   

—   

—   

(1,085)   

1,085   

—   

51   

(125)   

(341)   

—   

114   

—   

(7)   

—   

(4)   

—   

7   

—   

(48) 

(1,092)   

1,092 

—   

(125)   

(4)   

(20,827)   

— 

204 

Foreign exchange and other

(16,872)   

43   

(3,610)   

At 31 Dec 2021

  881,742   

(862)    137,541   

(2,105)   

14,686   

(5,702)   

274   

(64)   1,034,243   

(8,733) 

ECL income statement change for 
the period

Recoveries

Others

Total ECL income statement 
change for the period

1,198 

(46) 

(610) 

46 

588 

54 

(102) 

540 

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 decreased $1,884m during the period 
from $10,617m at 31 December 2020 to $8,733m at 31 December 
2021.

This decrease was primarily driven by:

• $1,256m relating to volume movements, which included the 
ECL allowance associated with new originations, assets 
derecognised and further lending/repayments;

• $1,092m of assets written off;

• $140m relating to the net remeasurement impact of stage 

transfers; and

• foreign exchange and other movements of $204m.

These were partly offset by:

• $760m relating to underlying credit quality changes, including 
the credit quality impact of financial instruments transferring 
between stages; and

• $48m of changes to models used for ECL calculation.

The ECL release for the period of $588m presented in the previous 
table consisted of $1,256m relating to underlying net book volume 
movement and $140m relating to the net remeasurement impact 
of stage transfers. This was partly offset by $760m relating to 
underlying credit quality changes, including the credit quality 
impact of financial instruments transferring between stages and 
$48m in changes to models used for ECL calculation.

The net transfer of gross carrying/nominal amounts to stage 1 of 
$19,285m reflects the overall improvement in the economic 
outlook as the effects of the Covid-19 outbreak subsided. It was 
primarily driven by $14,393m in Europe, $8,871m in North 
America, $3,674m in Middle East and North Africa, and was partly 
offset by a net transfer out of stage 1 of $8,285m in Asia mainly 
driven by an increase in Downside scenario weighting for China, 
reflecting management’s concern for potential deterioration on 
forward looking credit quality. 

HSBC Holdings plc Annual Report and Accounts 2021

165

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

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

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)   

Gross 
carrying/ 
nominal 
amount

$m

345   

—   

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

$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) 

Foreign exchange and other

18,219   

(20)   

7,990   

(157)   

—   

—   

—   

(23)   

479   

7   

(123)   

At 31 Dec 2020

841,105   

(1,465)    196,662   

(2,998)    14,662   

(6,041)   

137   

—   

—   

—   

303   

—   

—   

—   

(1,537)   

1,537   

—   

—   

—   

—   

(30)   

—   

12   

279   

—   

30   

—   

(4)   

—   

440 

(1,567)   

1,567 

(23)   

7 

26,700   

(304) 

(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) 

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 2021

Gross carrying/nominal amount

Strong

$m

Good Satisfactory

Sub-
standard

Credit 
impaired

$m

$m

$m

$m

Total

$m

Allowance 
for ECL

$m

Net

$m

48,758 

30,390 

  155,072 

74,440 

12,264 

11,683 

993 

49,254 

37,212 

95,626 

54,703 

7,004 

24,663 

5,736 

74,240 

48,694 

96,046 

63,301 

10,321 

22,022 

5,638 

14,196 

6,769 

  193,217 

(2,825)   

190,392 

9,192 

4,670 

3,297 

1,844 

5,543 

2,349 

5,156 

  130,644 

(1,890)   

128,754 

4,198 

  355,612 

(3,354)   

352,258 

2,150 

  197,891 

(1,592)   

196,299 

1,701 

651 

806 

33,134 

64,562 

15,522 

(1,209)   

(441)   

(502)   

31,925 

64,121 

15,020 

  228,770 

  182,283 

  208,267 

28,602 

14,125 

  662,047 

(8,331)   

653,716 

Percentage of total credit quality

 34.6 %

 27.5 %

 31.5 %

 4.3 %

 2.1 %

 100.0 %

By geography

Europe 

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2020

Percentage of total credit quality

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 

219,728 

184,924 

221,632 

 32.6 %

 27.5 %

 32.9 %

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 

13,761 

 2.0 %

214,822 

149,753 

341,693 

197,756 

34,628 

65,985 

16,198 

673,326 

 100.0 %

(4,137)   

(3,123)   

(2,803)   

(1,196)   

(1,524)   

(660)   

(677)   

210,685 

146,630 

338,890 

196,560 

33,104 

65,325 

15,521 

(9,801)   

663,525 

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 138.

166

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
–  CRR 9/10

100.000   

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

%

 400,894    98,911   13,460   274    513,539   

(665)   (1,874)   (5,601)   

(64)    (8,204) 

 1.6 

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 2021

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

0.000 to 0.053   40,583   

599   

—    —    41,182   

(7)   

(1)   

—    —   

0.054 to 0.169   78,794    4,843   

—    —    83,637   

(26)   

(43)   

—    —   

0.170 to 0.740  139,739    19,199   

—    —    158,938   

(165)   

(145)   

—    —   

0.741 to 1.927   91,268    23,365   

—    —    114,633   

(218)   

(258)   

—    —   

1.928 to 4.914   45,850    28,375   

—    —    74,225   

(185)   

(424)   

—    —   

4.915 to 8.860   3,280    11,197   

—    —    14,477   

(22)   

(242)   

—    —   

8.861 to 15.000   1,101    4,406   

—    —   

5,507   

(24)   

(167)   

—    —   

15.001 to 99.999  

279    6,927   

—   

4   

7,210   

(18)   

(594)   

—    —   

(8) 

(69) 

(310) 

(476) 

(609) 

(264) 

(191) 

(612) 

100.000   

—   

—   13,460   270    13,730   

—   

—   (5,601)   

(64)    (5,665) 

 41.3 

  61,086    3,874   

395    —    65,355   

(44)   

(26)   

(40)    —   

(110) 

 0.2 

0.000 to 0.053   14,370   

122   

—    —    14,492   

0.054 to 0.169   16,438   

43   

—    —    16,481   

0.170 to 0.740   18,282    1,026   

—    —    19,308   

0.741 to 1.927   6,835    1,204   

—    —   

8,039   

1.928 to 4.914   5,053    1,297   

—    —   

6,350   

4.915 to 8.860  

102   

8.861 to 15.000  

15.001 to 99.999  

5   

1   

—   

98   

25   

59   

—    —   

200   

—    —   

—    —   

30   

60   

—   

395    —   

395   

(2)   

(5)   

(11)   

(15)   

(11)   

—   

—   

—   

—   

  81,636    1,517   

—    —    83,153   

(14)   

0.000 to 0.053   61,275   

0.054 to 0.169   11,628   

0.170 to 0.740   3,935   

0.741 to 1.927   4,232   

1.928 to 4.914  

556   

4.915 to 8.860  

8.861 to 15.000  

15.001 to 99.999  

100.000   

9   

1   

—   

—   

10   

65   

102   

180   

52   

541   

564   

3   

—   

—    —    61,285   

—    —    11,693   

—    —   

4,037   

—    —   

4,412   

—    —   

—    —   

—    —   

—    —   

—    —   

608   

550   

565   

3   

—   

(4)   

(3)   

(2)   

(5)   

—   

—   

—   

—   

—   

(1)   

—   

(4)   

—    —   

—    —   

—    —   

(11)   

—    —   

(4)   

(5)   

(1)   

—   

—   

(3)   

—   

—   

—   

—   

(1)   

—   

—   

(2)   

—   

—    —   

—    —   

—    —   

—    —   

(40)    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

(3) 

(5) 

(15) 

(26) 

(15) 

(5) 

(1) 

— 

(40) 

(17) 

(4) 

(3) 

(2) 

(5) 

(1) 

— 

— 

(2) 

— 

 543,616   104,302   13,855   274    662,047   

(723)   (1,903)   (5,641)   

(64)    (8,331) 

 387,563   126,287   12,961    277   527,088    (1,101)   

(2,444)   

(5,837)    (112)   

(9,494) 

0.000 to 0.053   36,047   

486   

—    —    36,533   

0.054 to 0.169   81,298    3,140   

—    —    84,438   

(8)   

(42)   

0.170 to 0.740  131,540    27,061   

—    —   158,601   

(262)   

0.741 to 1.927   91,385    35,376   

—    —   126,761   

(390)   

1.928 to 4.914   42,214    34,585   

—    —    76,799   

(330)   

4.915 to 8.860   3,523    14,560   

—    —    18,083   

8.861 to 15.000   1,111    7,241   

—    —    8,352   

15.001 to 99.999  

445    3,838   

—    —    4,283   

100.000   

—   

—   12,961    277    13,238   

(35)   

(21)   

(13)   

—   

(5)   

(36)   

(197)   

(375)   

(686)   

(476)   

(322)   

(347)   

—    —   

—    —   

—    —   

—    —   

(13) 

(78) 

(459) 

(765) 

—    —   

(1,016) 

—    —   

—    —   

—    —   

(511) 

(343) 

(360) 

—   

(5,837)    (112)   

(5,949) 

 44.9 

  52,223    11,834   

523    —    64,580   

(46)   

(119)   

(100)    —   

(265) 

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)   

—   

(9)   

—   

—   

(2)   

(4)   

(1)   

—   

—   

(2)   

—   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

(3) 

(6) 

(21) 

(42) 

(44) 

(23) 

(9) 

(17) 

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

—    —   

(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) 

 —  AA- and above

 0.1 

 0.2 

 0.4 

 0.8 

 1.8 

 3.5 

 8.5 

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 

 0.3 

 0.2 

 2.5 

 3.3 

 — 

 10.1 

 — 

 —  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

AA- and above

A+ to A-

BBB+ to BBB-

BB+ to BB-

BB- to B

B-

CCC+

CCC to C

D

 — 

 — 

 0.1 

 0.2 

 — 

 — 

 66.7 

 — 

 1.3 

 1.8 

 — 

 0.1 

 0.3 

 0.6 

 1.3 

 2.8 

 4.1 

 8.4 

 0.4 

 — 

 — 

 0.1 

 0.5 

 0.8 

 3.8 

 2.2 

 6.5 

 0.1 

 — 

 0.1 

 0.1 

 0.3 

 0.2 

 6.6 

 — 

 0.2 

 — 

 1.5 

HSBC Holdings plc Annual Report and Accounts 2021

167

– CRR 9/10

100.000   

—   

—   

523    —   

(100)    —   

(100) 

 19.1 

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 real estate lending

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 $7.5bn, including adverse 
foreign exchange movements of $1.2bn, mainly in the UK and, to 
a lesser extent, within the US.

Gross loans and advances

Stage 1

Stage 2

Stage 3

POCI

Asia

$m

MENA

$m

North
 America

Latin 
America 

$m

$m

Total

$m

UK

$m

Hong Kong

$m

Of which:

56,734   

17,103   

543   

98   

781   

569   

206   

—   

8,328   

1,265   

9   

—   

1,073   

218   

249   

—   

87,233   

22,660   

2,069   

98   

14,235   

2,781   

905   

—   

42,951 

13,300 

435 

98 

Europe

$m

20,317   

3,505   

1,062   

—   

At 31 Dec 2021

–  of which: renegotiated loans

Allowance for ECL

24,884   

74,478   

1,556   

9,602   

1,540   

112,060   

17,921   

56,784 

440   

(450)   

251   

(693)   

145   

(158)   

—   

(26)   

—   

(130)   

836   

(1,457)   

436   

(366)   

170 

(604) 

Gross loans and advances

Stage 1

Stage 2

Stage 3

POCI

At 31 Dec 2020

–  of which: renegotiated loans

Allowance for ECL

22,639   

5,549   

1,114   

1   

63,276   

11,686   

37   

—   

1,147   

436   

250   

—   

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 

— 

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) 

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:

12,980   

26,736   

4,794   

5,352   

1,758   

18,192   

26,668   

2,882   

478   

159   

631   

288   

5,961   

1,098   

2,297   

246   

336   

280   

559   

365   

46,491   

10,546   

24,523   

35,507   

5,539   

3,921   

2,805   

649   

20,466 

14,399 

19,562 

2,357 

At 31 Dec 2021

24,884   

74,478   

1,556   

9,602   

1,540   

112,060   

17,921   

56,784 

On demand, overdrafts or revolving

< 1 year

1–2 years

2–5 years

> 5 years

13,728   

6,373   

6,241   

2,961   

25,075   

18,396   

27,699   

3,829   

750   

119   

668   

296   

5,793   

3,112   

2,288   

315   

263   

434   

927   

266   

45,609   

28,434   

37,823   

7,667   

12,131   

4,991   

3,135   

1,215   

At 31 Dec 2020

29,303   

74,999   

1,833   

11,508   

1,890   

119,533   

21,472   

19,998 

13,237 

21,694 

2,929 

57,858 

168

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table presents the Group’s total exposure to mainland China commercial real estate at 31 December 2021, by country/
territory and credit quality. Mainland China reported real estate exposures comprise exposures booked in mainland China and offshore 
where the ultimate parent and beneficial owner is based in mainland China, and all exposures booked on mainland China balance sheets.

Mainland China commercial real estate

Loans and advances to customers1
Guarantees issued and others2
Total mainland China commercial real estate exposure at 31 Dec 2021

Distribution of mainland China commercial real estate exposure by credit 
quality

– Strong

– Good

– Satisfactory

– Sub-standard

– Credit impaired

At 31 Dec 2021

Allowance for ECL

1   Amounts represent gross carrying amount.
2   Amounts represent nominal amount.

At 31 December 2021, the Group had no direct credit exposure to 
developers in the ‘red’ category of the Chinese government’s 
‘three red lines’ framework. The Group’s exposures related to 
companies whose primary activities are focused on residential, 
commercial and mixed-use real estate activities.  Lending is 
generally focused on tier 1 and 2 cities.

Booked in Hong Kong are higher risk exposures to a combination 
of state and privately owned enterprises. This portfolio had 89% of 
exposure booked with a credit quality of ‘satisfactory’ or above, 
but had a higher degree of uncertainty due to tightening liquidity 
and increased refinancing risks. In addition, offshore exposures 
are typically higher risk than onshore exposures. At 31 December 
2021, the Group had allowances for ECL of $560m held against 
mainland China commercial real estate exposures booked in Hong 
Kong. We will continue to monitor the prevailing situation closely. 

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 
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. 

Hong Kong

Mainland China Rest of the Group

$m

9,903   

1,747   

11,650   

3,543   

2,652   

3,383   

1,570   

502   

11,650   

560   

$m

6,811   

2,376   

9,187   

3,864   

2,354   

2,855   

12   

102   

9,187   

49   

$m

410   

79   

489   

155   

73   

106   

155   

—   

489   

2   

Total

$m

17,124 

4,202 

21,326 

7,562 

5,079 

6,344 

1,737 

604 

21,326 

611 

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 credit 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.

Certain credit mitigants are used strategically in portfolio 
management activities. While single name concentrations arise in 

For credit-impaired loans, the collateral values cannot be directly 
compared with impairment allowances recognised. The LTV 

HSBC Holdings plc Annual Report and Accounts 2021

169

Risk review 
 
 
 
 
 
 
 
 
 
Risk

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 324.

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 commercial real estate, where the 

facility exceeds regulatory threshold requirements, Group policy 
requires an independent review of the valuation at least every 
three years, or more frequently as the need arises.

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.

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:

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 2021

$m

%

$m

%

$m

50,603 

71,769 

35,984 

26,390 

5,284 

4,111 

5,429 

2,942 
127,801 

11,729 

12,741 

5,759 

4,804 

757 

1,421 

1,783 

930 

 0.1   

 0.1   

 0.1   

 0.1   

 0.2   

 0.1   

 0.1   

7,623 

13,139 

4,142 

6,460 

1,859 

678 

2,018 

874 

 0.4   

 0.2   

 0.2   

 0.2   

 0.2   

 —   

 0.1   

23,864 

32,951 

22,645 

8,082 

1,181 

1,043 

714 

447 

 0.1   

22,780 

 0.3   

57,529 

 4.3   

 1.1   

 1.0   

 1.1   

 1.5   

 1.5   

 2.7   

1,970 

1,131 

605 

471 

43 

12 

366 

223 

 0.9   

 2.3   

 3.1   

 1.3   

 —   

 —   

 0.3   

7,758 

6,385 

3,633 

2,389 

269 

94 

172 

70 

26,253 

 2.7   

3,467 

 1.3   

14,315 

%

 — 

 — 

 — 

 — 

 — 

 0.1 

 — 

 — 

 5.9 

 0.4 

 0.3 

 0.5 

 0.4 

 — 

 2.9 

 3.4 

828 

1,176 

645 

286 

62 

183 

265 

149 

 40.9   

 22.0   

 19.8   

 9.1   

 14.5   

 52.5   

 47.9   

2,269 

 32.0   

— 

98 

98 

— 

— 

— 

— 

— 

98 

156,421 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 1.0   

407 

346 

36 

250 

11 

49 

204 

97 

957 

— 

— 

— 

— 

— 

— 

— 

— 

— 

27,204 

 42.0   

 5.2   

 2.8   

 5.2   

 —   

 8.2   

 49.0   

198 

290 

 35.9 

 11.0 

284 

 10.9 

— 

2 

4 

— 

— 

 — 

 — 

 25.0 

 — 

 30.2   

488 

 21.1 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 1.5   

— 

98 

98 

— 

— 

— 

— 

— 

98 

72,430 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.8 

170

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale lending – commercial real estate 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:

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

$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   

 1.1   

 45.3   

 11.5   

 13.6   

 15.5   

 6.7   

 8.3   

 45.6   

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 

6,584 

 1.8   

9,999 

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 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

— 

— 

— 

— 

— 

— 

— 

— 

— 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

— 

20 

11 

3 

— 

6 

— 

— 

20 

— 

— 

— 

— 

— 

— 

— 

— 

— 

%

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.1 

 0.5 

 0.4 

 0.8 

 0.3 

 — 

 1.0 

 0.5 

 — 

 5.0 

 — 

 — 

 — 

 16.7 

 — 

 5.0 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

163,217 

 0.8   

30,483 

 2.0   

73,596 

 0.1 

HSBC Holdings plc Annual Report and Accounts 2021

171

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 2021

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

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:

61,279 

83,456 

7,059 

3,729 

 0.5   

 0.2   

 0.5   

151,794 

 0.3   

9,586 

14,218 

2,379 

1,092 

26,183 

 0.5   

 0.2   

 0.2   

30,917 

38,817 

886 

517 

 0.3   

70,620 

1,053 

1,054 

503 

447 

60 

44 

153 

143 

 26.5   

 3.8   

 4.8   

 3.1   

 1.7   

 2.3   

 15.0   

7 

52 

41 

8 

1 

2 

5 

5 

 42.9   

 38.5   

 41.5   

 25.0   

 —   

 —   

 20.0   

705 

519 

378 

137 

4 

— 

— 

— 

 0.6 

 0.1 

 0.6 

 0.3 

 38.6 

 2.1 

 0.8 

 5.8 

 — 

 — 

 — 

2,260 

 15.1   

64 

 37.5   

1,224 

 23.1 

828 

1,274 

743 

286 

62 

183 

265 

149 

2,367 

156,421 

64,046 

89,664 

6,728 

3,994 

 40.9   

 20.3   

 17.2   

 9.1   

 14.5   

 52.5   

 47.9   

 30.6   

 1.0   

 0.3   

 0.3   

 0.4   

160,438 

 0.3   

 22.5   

 8.2   

 7.1   

 9.0   

 21.4   

 —   

 11.1   

40 

634 

282 

321 

14 

17 

9 

9 

683 

1,038 

584 

178 

161 

149 

96 

474 

331 

2,096 

163,217 

407 

346 

36 

250 

11 

49 

204 

97 

957 

27,204 

10,527 

16,483 

2,174 

1,157 

29,184 

15 

104 

15 

75 

5 

9 

2 

1 

 42.0   

 5.2   

 2.8   

 5.2   

 —   

 8.2   

 49.0   

 30.2   

 1.5   

 1.1   

 0.4   

 0.3   

198 

388 

382 

— 

2 

4 

— 

— 

586 

72,430 

30,506 

41,861 

965 

741 

 0.6   

73,332 

 6.7   

 12.5   

 6.7   

 13.3   

 20.0   

 —   

 50.0   

— 

244 

102 

138 

4 

— 

— 

— 

 35.9 

 8.2 

 8.1 

 — 

 — 

 25.0 

 — 

 17.6 

 0.8 

 — 

 0.1 

 0.2 

 — 

 — 

 12.7 

 11.8 

 13.0 

 25.0 

 — 

 — 

 9.1   

121 

 12.4   

244 

 12.7 

 45.3   

 11.5   

 13.5   

 15.5   

 6.7   

 8.3   

 45.6   

 35.9   

 0.8   

635 

348 

56 

128 

139 

25 

195 

120 

1,178 

30,483 

 50.7   

 9.5   

 5.4   

 12.5   

 5.8   

 24.0   

 27.7   

 34.7   

 2.0   

— 

20 

11 

3 

— 

6 

— 

— 

20 

73,596 

 — 

 5.0 

 — 

 — 

 — 

 16.7 

 — 

 5.0 

 0.1 

172

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021

624,935 

112,905 

40,636 

38,709 

13,284 

20,276 

64,058 

30,890 

 0.1   

 0.1   

 0.1   

 0.1   

 0.1   

 0.1   

 0.1   

112,188 

22,971 

6,512 

9,431 

2,556 

4,472 

8,665 

4,826 

 0.2   

 0.2   

 0.2   

 0.2   

 0.1   

 —   

 0.1   

111,948 

45,479 

16,915 

16,533 

4,920 

7,111 

20,358 

9,322 

801,898 

 0.1   

143,824 

 0.2   

177,785 

85,394 

32,019 

10,892 

14,281 

2,752 

4,094 

12,484 

6,675 

 1.1   

 1.1   

 1.2   

 1.1   

 1.2   

 0.9   

 1.0   

129,897 

 1.1   

8,122 

2,278 

603 

1,110 

295 

270 

2,134 

1,200 

 47.3   

 12.7   

 20.9   

 5.0   

 11.5   

 27.4   

 38.7   

18,562 

8,231 

3,148 

4,161 

687 

235 

1,824 

937 

28,617 

2,979 

1,212 

249 

786 

115 

62 

318 

186 

 2.0   

 1.3   

 1.5   

 1.2   

 1.5   

 1.7   

 1.9   

8,310 

11,503 

3,378 

5,202 

1,148 

1,775 

1,788 

785 

 1.8   

21,601 

 21.6   

 3.4   

 4.8   

 1.4   

 9.6   

 9.7   

 35.5   

732 

240 

76 

110 

26 

28 

616 

358 

 — 

 0.1 

 — 

 0.1 

 0.1 

 0.1 

 — 

 — 

 1.1 

 0.7 

 0.5 

 0.9 

 0.9 

 0.2 

 0.4 

 0.8 

 74.7 

 2.1 

 — 

 3.6 

 — 

 3.6 

 28.9 

12,534 

 39.6   

4,509 

 17.7   

1,588 

 46.0 

114 

61 

 36.0   

 34.4   

 —   

 36.8   

 —   

 —   

 100.0   

— 

57 

— 

4 

2 

2 

177 

944,506 

 36.2   

 0.8   

28 

— 

— 

— 

— 

— 

— 

— 

28 

176,978 

 21.4   

 —   

 —   

 —   

 —   

 —   

 —   

 21.4   

 0.9   

4 

57 

— 

57 

— 

— 

— 

— 

61 

201,035 

 — 

 36.8 

 — 

 36.8 

 — 

 — 

 — 

 34.4 

 0.5 

HSBC Holdings plc Annual Report and Accounts 2021

173

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 

 0.2 

 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 

$m

%

$m

%

$m

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   

 50.0   

 17.3   

 24.0   

 19.0   

 9.2   

 11.6   

 35.5   

7,852 

1,939 

637 

526 

294 

482 

2,847 

1,619 

12,638 

211 

63 

6 

11 

34 

12 

4 

4 

278 

967,469 

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 

 41.7   

3,931 

 24.7   

1,799 

 41.6 

 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 

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

174

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021

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

4,790 

1,653 

803 

583 

116 

151 

1,253 

921 

7,696 

8,239 

2,335 

604 

1,166 

295 

270 

2,137 

1,203 

12,711 

20,407 

3,787 

1,107 

269 

480 

140 

218 

493 

352 

 47.1   

 13.3   

 20.9   

 6.7   

 11.5   

 27.4   

 38.7   

 39.5   

 26.1   

 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 

 49.7   

 18.1   

 24.2   

 18.8   

 15.0   

 11.3   

 35.6   

 41.7   

 31.4   

 3.9   

 3.9   

 3.5   

 3.8   

 5.2   

 5.3   

 3.7   

1,587 

259 

113 

110 

23 

13 

138 

40 

 3.1   

 6.6   

 6.2   

 8.2   

 4.3   

 —   

 8.0   

79 

32 

2 

1 

29 

— 

11 

6 

 30.4 

 — 

 — 

 — 

 — 

 — 

 — 

 3.9   

1,984 

 3.9   

122 

 20.5 

3,007 

1,212 

249 

786 

115 

62 

318 

186 

4,537 

6,521 

924 

171 

29 

87 

13 

42 

174 

83 

1,269 

2,847 

585 

151 

182 

211 

41 

553 

337 

3,985 

5,254 

 21.5   

 3.4   

 4.8   

 1.4   

 9.6   

 9.7   

 35.5   

 17.7   

 13.5   

 8.7   

 9.4   

 10.3   

 6.9   

 23.1   

 9.5   

 9.2   

736 

297 

75 

168 

26 

28 

616 

358 

1,649 

1,771 

103 

15 

1 

— 

14 

— 

27 

13 

 74.3 

 9.1 

 — 

 14.9 

 — 

 3.6 

 28.9 

 45.6 

 43.8 

 25.2 

 — 

 — 

 — 

 — 

 — 

 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   

865 

388 

84 

139 

83 

82 

592 

322 

1,845 

1,990 

 66.0 

 11.6 

 6.0 

 5.0 

 34.9 

 4.9 

 26.4 

 41.8 

 40.2 

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 358 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 2021

175

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

2021

Fair value

Assets

Liabilities

$m

$m

Notional

amount

$m

2020

Fair value

Assets

Liabilities

$m

$m

Total OTC derivatives

 21,964,665   

246,108   

241,136    22,749,280   

372,373   

368,010 

–  total OTC derivatives cleared by central counterparties

 10,086,344   

59,147   

60,686   

9,898,260   

74,054   

75,253 

–  total OTC derivatives not cleared by central counterparties

 11,878,321   

186,961   

180,450    12,851,020   

298,319   

292,757 

Total exchange traded derivatives

Gross

Offset

At 31 Dec

  1,359,692   

4,152   

3,306   

1,332,438   

4,456   

4,094 

 23,324,357   

250,260   

244,442    24,081,718   

376,829   

372,104 

(53,378)   

(53,378) 

196,882   

191,064 

(69,103)   

(69,103) 

307,726   

303,001 

The purposes for which HSBC uses derivatives are described in Note 15 on 
the financial statements.

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 378 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 2021 to 31 December 2021 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 2021, total personal lending for loans and 
advances to customers of $478bn increased by $17.5bn compared 
with 31 December 2020. This increase included adverse foreign 
exchange movements of $6.4bn. Excluding foreign exchange 
movements, there was growth of $24.0bn, primarily driven by 
$11.4bn in Asia and $10.2bn in Europe. The allowance for ECL 
attributable to personal lending, excluding off-balance sheet loan 
commitments and guarantees and foreign exchange movements, 
decreased $1.5bn to $3.1bn at 31 December 2021.

Excluding foreign exchange movements, total personal lending 
was primarily driven by mortgage growth, which grew by $22.8bn. 
Mortgages grew $10.1bn in the UK; $9.9bn in Asia, notably $6.6bn 
in Hong Kong and $2.1bn in Australia; and $3.4bn in Canada. This 
was partly offset by a decrease of $1.8bn due to domestic mass 
market retail banking in the US being reclassified to assets held for 
sale. The allowance for ECL, excluding foreign exchange, 
attributable to mortgages of $0.7bn decreased by $0.1bn 
compared with 31 December 2020.

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 
62%, compared with an estimated 47% for the overall mortgage 
portfolio. The average LTV ratio on new lending in the UK was 
67%, compared with an estimated 51% for the overall mortgage 
portfolio. 

Excluding foreign exchange movements, other personal lending 
balances at 31 December 2021 increased by $1.2bn compared 
with 31 December 2020, mainly from unsecured personal lending 
in Hong Kong (up $1.0bn) and in Latin America (up $0.7bn), as 
well as from guaranteed loans in respect of residential property in 
France (up $0.8bn). These were offset by a decrease in credit 
cards mainly in the US (down $0.9bn).

The allowance for ECL, excluding foreign exchange, attributable to 
other personal lending of $2.4bn decreased by $1.5bn compared 
with 31 December 2020. Excluding foreign exchange, the 
allowance for ECL attributable to credit cards decreased by $0.9bn 
while unsecured personal lending decreased by $0.6bn.

176

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
Total personal lending for loans and advances to customers at amortised cost by stage distribution

By portfolio

First lien residential mortgages

–  of which: interest only (including offset)

–  affordability (including US adjustable rate 

mortgages)

Other personal lending 

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

360,686   

28,506   

7,637   

1,795   

3,045   

371,368   

255   

30,556   

(128)   

(5)   

(131)   

(24)   

(416)   

(81)   

Total

$m

(675) 

(110) 

13,621   

712   

452   

14,785   

(6)   

(6)   

(5)   

(17) 

96,270   

8,802   

1,897   

106,969   

(530)   

(1,088)   

(810)   

(2,428) 

–  second lien residential mortgages

314   

44   

37   

395   

(1)   

(4)   

(9)   

(14) 

–  guaranteed loans in respect of residential 

property

–  other personal lending which is secured

–  credit cards

–  other personal lending which is unsecured

–  motor vehicle finance

–  IPO loans

At 31 Dec 2021

By geography

Europe 

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2021

20,643   

36,533   

18,623   

18,743   

1,414   

—   

731   

1,096   

3,897   

2,820   

214   

—   

236   

366   

338   

915   

5   

—   

21,610   

37,995   

22,858   

22,478   

1,633   

—   

(9)   

(21)   

(246)   

(240)   

(13)   

—   

(7)   

(15)   

(675)   

(378)   

(9)   

—   

(42)   

(120)   

(214)   

(421)   

(4)   

—   

(58) 

(156) 

(1,135) 

(1,039) 

(26) 

— 

456,956   

16,439   

4,942   

478,337   

(658)   

(1,219)   

(1,226)   

(3,103) 

212,284   

176,547   

187,391   

125,854   

4,965   

5,639   

4,668   

7,796   

4,959   

252   

2,148   

220,071   

1,488   

182,703   

1,303   

196,490   

202   

131,015   

202   

5,419   

43,489   

2,126   

1,005   

46,620   

8,827   

626   

284   

9,737   

456,956   

16,439   

4,942   

478,337   

(199)   

(167)   

(158)   

(65)   

(38)   

(43)   

(220)   

(658)   

(499)   

(480)   

(381)   

(231)   

(40)   

(67)   

(232)   

(637)   

(399)   

(226)   

(43)   

(94)   

(118)   

(151)   

(1,335) 

(1,046) 

(765) 

(339) 

(172) 

(228) 

(603) 

(1,219)   

(1,226)   

(3,103) 

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 2021

Stage 1

Stage 2

Stage 3

$m

57,109   

54,704   

160,248   

121,597   

2,568   

15,039   

3,920   

$m

558   

407   

894   

292   

30   

251   

29   

$m

107   

104   

21   

19   

16   

23   

2   

Total

$m

57,774   

55,215   

161,163   

121,908   

2,614   

15,313   

3,951   

238,884   

1,762   

169   

240,815   

$m

(11)   

(10)   

—   

—   

(5)   

(15)   

(6)   

(37)   

$m

$m

(1)   

(1)   

—   

—   

—   

(1)   

—   

(2)   

—   

—   

—   

—   

—   

—   

—   

—   

Stage 1

Stage 2

Stage 3

Total

Total personal lending for loans and advances to customers at amortised cost by stage distribution (continued)1

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

$m

(12) 

(11) 

— 

— 

(5) 

(16) 

(6) 

(39) 

Total

$m

(755) 

(116) 

By portfolio

First lien residential mortgages

336,666   

12,233   

3,383   

352,282   

–  of which: interest only (including offset) 

29,143   

3,074   

351   

32,568   

–  affordability (including US adjustable rate 

mortgages)

Other personal lending

13,265   

2,209   

606   

16,080   

93,468   

12,831   

2,228   

108,527   

–  second lien residential mortgages

593   

100   

51   

744   

(125)   

(9)   

(11)   

(702)   

(3)   

(4)   

(13)   

(386)   

(288)   

(8)   

—   

(188)   

(19)   

(442)   

(88)   

(11)   

(5)   

(27) 

(2,214)   

(1,060)   

(3,976) 

(9)   

(10)   

(22) 

(7)   

(19)   

(1,281)   

(888)   

(10)   

—   

(32)   

(127)   

(380)   

(506)   

(5)   

—   

(43) 

(159) 

(2,047) 

(1,682) 

(23) 

— 

21,558   

36,230   

17,327   

16,338   

1,374   

48   

835   

1,357   

5,292   

5,096   

151   

—   

159   

448   

680   

882   

8   

—   

22,552   

38,035   

23,299   

22,316   

1,533   

48   

430,134   

25,064   

5,611   

460,809   

(827)   

(2,402)   

(1,502)   

(4,731) 

200,120   

163,338   

178,175   

118,252   

4,879   

40,387   

6,573   

11,032   

9,476   

7,969   

5,133   

403   

4,613   

1,047   

2,511   

1,721   

1,169   

206   

251   

213,663   

174,535   

187,313   

123,591   

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) 

–  guaranteed loans in respect of residential 

property

–  other personal lending which is secured

–  credit cards

–  other personal lending which is unsecured

–  motor vehicle finance

–  IPO loans

At 31 Dec 2020

By geography

Europe

–  of which: UK

Asia

–  of which: Hong Kong

MENA

North America

Latin America

At 31 Dec 2020

1  During the period, the Group has re-presented the other personal lending with additional granularity.

HSBC Holdings plc Annual Report and Accounts 2021

177

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 2020

Stage 1

$m

56,920   

54,348   

156,057   

118,529   

2,935   

15,835   

3,462   

Nominal amount

Stage 2

Stage 3

$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   

Stage 1

$m

(22)   

(21)   

—   

—   

(1)   

(11)   

(5)   

(39)   

Allowance for ECL

Stage 2

$m

Stage 3

$m

(2)   

(2)   

—   

—   

—   

—   

—   

(2)   

—   

—   

—   

—   

—   

—   

—   

—   

Total

$m

(24) 

(23) 

— 

— 

(1) 

(11) 

(5) 

(41) 

Exposure to UK interest-only mortgage loans

The following information is presented for HSBC branded UK 
interest-only mortgage loans with balances of $15.2bn. This 
excludes offset mortgages in the first direct brand and Private 
Bank mortgages.

At the end of 2021, the average LTV ratio in the portfolio was 40% 
and 99% of mortgages had an LTV ratio of 75% or less. 

were repaid within 12 months of expiry with a total of 91% being 
repaid within 24 months of expiry. For those expiring during 2020, 
73% were repaid within 12 months of expiry. The drop in the 
amount fully repaid within the 12 months is explained by the 
extensions granted as part of the FCA guidance on helping 
borrowers with maturing interest-only mortgages during the 
pandemic that ended in October 2021. Excluding the extensions, 
only $3.9m remains outstanding.

Of the interest-only mortgage loans that expired in 2019, 89% 

The profile of maturing UK interest-only loans is as follows:

UK interest-only mortgage loans 

Expired interest-only mortgage loans

Interest-only mortgage loans by maturity

– 2022

– 2023

– 2024

– 2025

– 2026–2030

– post-2030

At 31 Dec 2021

Expired interest-only mortgage loans

Interest-only mortgage loans by maturity

– 2021

– 2022

– 2023

– 2024

– 2025–2029

–  post-2030

At 31 Dec 2020

$m

167 

267 

401 

330 

420 

3,288 

10,333 

15,206 

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 offset their credit and debit balances against their mortgage 
exposure.

At 31 December 2021, exposures were worth a total $7.0bn with 
an average LTV ratio of 35% (31 December 2020: $8.6bn exposure 
and 37% LTV ratio).

178

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
— 

455 

951 

(1,467) 

(1) 

1,520 

174 

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 2021

Transfers of financial instruments

  665,346   

(866)    26,770   

(2,405)   

1,822   

(1,154)   

(4,502)   

1,713   

Net remeasurement of ECL arising from transfer of stage

—   

825   

—   

(363)   

5,762   

2,680   

—   

(559)   

(7)   

—   

—   

(1,503)    697,878   

(4,774) 

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 other1
At 31 Dec 2021

39,946   

148   

(2,877)   

533   

(1,517)   

270   

35,552   

—   

—   

—   

318   

(2)   

—   

—   

—   

—   

(11,274)   

36   

(1,190)   

(778)   

—   

—   

79   

—   

—   

(1,007)   

1   

—   

—   

(1,525)   

1,520   

(1,525)   

(289)   

59   

(12,753)   

  695,840   

(695)    18,201   

(1,221)   

5,111   

(1,226)    719,152   

(3,142) 

ECL income statement change for the period

1,289 

(608) 

(743) 

Recoveries

Other

Total ECL income statement change for the period

(62) 

355 

(9) 

284 

1   Total includes $3.0bn of gross carrying loans and advances to customers, which were classified to assets held for sale and a corresponding 

allowance for ECL of $123m, reflecting our exit of the domestic mass market retail banking in the US.

As shown in the above table, the allowance for ECL for loans and 
advances to customers and relevant loan commitments and 
financial guarantees decreased $1,632m during the period from 
$4,774m at 31 December 2020 to $3,142m at 31 December 2021.

This decrease was primarily driven by:
• $1,520m of assets written off;

• $951m relating to volume movements, which included the ECL 

allowance associated with new originations, assets 
derecognised and further lending/repayment;

• $455m relating to the net remeasurement impact of stage 

transfers; and 

• foreign exchange and other movements of $174m.

These were partly offset by:

• $1,467m relating to underlying credit quality changes, including 

the credit quality impact of financial instruments transferring 
between stages.

The ECL charge for the period of $62m presented in the above 
table consisted of $1,467m relating to underlying credit quality 
changes, including the credit quality impact of financial 
instruments transferring between stages. This was partly offset by 
$951m relating to underlying net book volume movements and 
$455m relating to the net remeasurement impact of stage 
transfers.

The net transfer of gross carrying/nominal amounts to stage 1 of 
$1,822m reflects the overall improvement in the economic outlook 
as the effects of the Covid-19 outbreak subsided. It was primarily 
driven by $2,854m in Europe and $1,074m in North America, and 
was partly offset by a net transfer out of stage 1 of $2,346m in 
Asia, mainly driven by management judgemental adjustments 
primarily in Hong Kong during 1H21.

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)

Gross 
carrying/ 
nominal 
amount

$m

635,961   

(16,019)   

—   

30,891   

—   

—   

—   

14,513   

665,346   

At 1 Jan 2020

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 2020

ECL income statement change for the period

Recoveries

Other

Total ECL income statement change for the period

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

$m

$m

(1,215)   

658,389   

(3,150) 

(552)   

(8)   

—   

—   

150   

24,807   

(1,258)   

5   

—   

—   

$m

$m

17,382   

13,370   

(1,338)   

1,181   

—   

(5,407)   

—   

—   

—   

1,425   

(555)   

408   

(2,025)   

(9)   

—   

(67)   

$m

5,046   

2,649   

—   

(677)   

—   

—   

$m

(597)   

(629)   

431   

101   

(147)   

(3)   

—   

(22)   

(866)   

382 

(1,409)   

1,407   

(1,409)   

153   

(32)   

16,091   

26,770   

(2,405)   

5,762   

(1,503)   

697,878   

(2,181) 

(1,111) 

— 

(132) 

659 

(3,430) 

(7) 

1,407 

(121) 

(4,774) 

(2,910) 

280 

(25) 

(2,655) 

HSBC Holdings plc Annual Report and Accounts 2021

179

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

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

  360,686   

7,637   

3,045    371,368   

(128)   

(131)   

(416)   

(675) 

0.000 to 0.250   310,042   

0.251 to 0.500   19,741   

451   

203   

—    310,493   

—    19,944   

0.501 to 1.500   25,835   

1,936   

—    27,771   

1.501 to 5.000  

4,976   

2,657   

5.001 to 20.000  

88   

1,416   

20.001 to 99.999  

100.000  

4   

—   

974   

—   

—   

—   

7,633   

1,504   

978   

(30)   

(7)   

(79)   

(12)   

—   

—   

—   

(5)   

(2)   

(8)   

(30)   

(35)   

(51)   

—   

—   

—   

—   

—   

—   

—   

(35) 

(9) 

(87) 

(42) 

(35) 

(51) 

—   

3,045   

3,045   

(416)   

(416) 

 13.7 

ECL 
coverage

%

 0.2 

 — 

 — 

 0.3 

 0.6 

 2.3 

 5.2 

 2.3 

 0.1 

 0.2 

 0.5 

 2.1 

 11.6 

 40.0 

 42.7 

 0.6 

 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 

Other personal lending 

  96,270   

8,802   

1,897    106,969   

(530)   

(1,088)   

(810)   

(2,428) 

–  Band 1

–  Band 2

–  Band 3

–  Band 4

–  Band 5

–  Band 6

–  Band 7

0.000 to 0.250   45,049   

0.251 to 0.500   12,625   

187   

605   

—    45,236   

—    13,230   

0.501 to 1.500   22,791   

1,518   

—    24,309   

1.501 to 5.000   13,006   

2,360   

—    15,366   

5.001 to 20.000  

2,732   

3,257   

20.001 to 99.999  

100.000  

67   

—   

875   

—   

—   

5,989   

942   

—   

1,897   

1,897   

(50)   

(27)   

(102)   

(213)   

(138)   

—   

—   

(13)   

(6)   

(30)   

(108)   

(554)   

(377)   

—   

—   

—   

—   

—   

—   

—   

(810)   

(63) 

(33) 

(132) 

(321) 

(692) 

(377) 

(810) 

At 31 Dec 2021

  456,956    16,439   

4,942    478,337   

(658)   

(1,219)   

(1,226)   

(3,103) 

First lien residential 
mortgages

–  Band 1

–  Band 2

–  Band 3

–  Band 4

–  Band 5

–  Band 6

–  Band 7

  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   

0.501 to 1.500  

27,055   

1.501 to 5.000  

8,858   

5.001 to 20.000  

238   

20.001 to 99.999  

100.000  

4   

—   

302   

1,755   

5,134   

1,806   

1,953   

—   

—   

—   

—   

—   

—   

3,383   

16,561   

28,810   

13,992   

2,044   

1,957   

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   

0.501 to 1.500  

23,802   

1.501 to 5.000  

11,787   

5.001 to 20.000  

3,234   

20.001 to 99.999  

100.000  

27   

—   

589   

518   

1,280   

2,175   

5,288   

2,981   

—   

—   

—   

—   

—   

—   

—   

2,228   

42,154   

13,571   

25,082   

13,962   

8,522   

3,008   

2,228   

(96)   

(31)   

(108)   

(270)   

(197)   

—   

—   

(8)   

(63)   

(37)   

(112)   

(821)   

(1,173)   

—   

—   

—   

—   

—   

—   

—   

(1,060)   

At 31 Dec 2020

  430,134   

25,064   

5,611    460,809   

(827)   

(2,402)   

(1,502)   

1  12-month point in time adjusted for multiple economic scenarios.

(104) 

(94) 

(145) 

(382) 

(1,018) 

(1,173) 

(1,060) 

(4,731) 

180

HSBC Holdings plc Annual Report and Accounts 2021

 
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)

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 2021

$m

%

$m

%

$m

377,454 

 —   

168,737 

190,370   

64,217 

51,842 

46,932 

18,778 

5,315 

682 

254 

98 

330 

484 

—   

 —   

 —   

 0.1   

 0.1   

 0.1   

0.3  

0.6  

0.4  

0.1  

81,582 

28,555 

25,949 

24,114 

7,899 

638 

358 

104 

60 

194 

235 

378,136 

 —   

169,095 

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

 —   

98,020 

61,234 

12,070 

4,649 

8,360 

8,420 

3,287 

30 

26 

1 

3 

28 

98,050 

7,710 

1.7  

2,738 

2.1  

1,166 

4,380 

1,317 

1,016 

725 

208 

64 

24 

7 

8 

9 

20 

7,734 

1.5  

1.4  

1.6  

2.3  

4.3  

4.1  

13.6  

18.6  

16.6  

6.7  

1,846 

397 

282 

175 

32 

6 

3 

1 

— 

2 

2 

1.6  

2.4  

3.0  

4.7  

5.6  

1.9  

7.7  

1.0  

—  

11.1  

905 

106 

34 

50 

58 

13 

— 

— 

— 

— 

— 

1.7  

2,741 

2.1  

1,166 

2,853 

11.5  

954 

14.2  

1,490 

443 

371 

256 

171 

122 

220 

56 

29 

135 

143 

3,073 

388,943 

9.2  

8.6  

10.9  

15.4  

20.4  

32.2  

39.6  

27.5  

29.2  

46.9  

13.5  

0.2  

635 

129 

79 

67 

21 

23 

7 

4 

— 

3 

6 

961 

172,797 

13.0  

14.0  

16.2  

19.1  

25.2  

18.6  

30.8  

22.3  

—  

45.5  

14.4  

0.1  

68 

48 

10 

2 

3 

4 

1 

— 

— 

— 

— 

— 

68 

99,284 

%

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.3 

 0.5 

 0.1 

 0.1 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 0.3 

 — 

HSBC Holdings plc Annual Report and Accounts 2021

181

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

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 2020

$m

%

$m

%

$m

354,102 

 —   

159,562 

 —   

90,733 

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   

 —   

 —   

 —   

 —   

 —   

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 

%

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

182

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021

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

Corporate 
and 
commercial

Of which: 
real estate1

Non-bank 
financial 
institutions

$m

(2,770)   

(1,855)   

(654)   

(120)   

(8)   

(133)   

(108)   

(84)   

(246)   

(198)   

(172)   

(792)   

—   

(112)   

Corporate 
and 
commercial

Of which: 
real estate1

Non-bank 
financial 
institutions

$m

$m

$m

Total

$m

163,341   

115,386   

34,488   

6,746   

1,188   

5,533   

23,137   

16,233   

5,520   

306   

731   

347   

17,818   

181,159   

11,306   

126,692   

4,391   

38,879   

987   

688   

446   

7,733   

1,876   

5,979   

263,821   

162,684   

81,453   

62,792   

36,321   

300,142   

20,182   

182,866   

(3,297)   

(1,585)   

9,937   

8,221   

3,436   

33,555   

7,229   

16,401   

6,291   

16,067   

21,963   

1,788   

12,942   

7,233   

52,577   

27,002   

25,048   

527   

11,837   

9,561   

2,276   

2,596   

1,786   

86   

6,811   

1,741   

4,158   

31   

1,452   

1,555   

69   

1,370   

116   

717   

4,003   

226   

10,654   

12,224   

3,662   

9,359   

42,914   

7,426   

17,183   

6,338   

16,875   

197   

782   

47   

808   

376   

152   

190   

34   

13,639   

10,197   

5,895   

7,650   

94   

1,476   

1,475   

1   

8,511   

1,546   

140   

643   

618   

25   

22,339   

(1,207)   

1,940   

13,132   

7,267   

62,774   

35,513   

26,594   

667   

12,480   

10,179   

2,301   

(161)   

(811)   

(235)   

(427)   

(207)   

(198)   

(22)   

(503)   

(452)   

(51)   

$m

(546)   

(489)   

(47)   

—   

—   

(10)   

(731)   

(624)   

(3)   

(29)   

(2)   

(41)   

(21)   

(5)   

—   

(6)   

(158)   

(7)   

(149)   

(2)   

(87)   

(64)   

(15)   

(8)   

(122)   

(122)   

—   

$m

(41)   

(32)   

(2)   

(3)   

—   

(4)   

(44)   

(7)   

—   

(8)   

(1)   

(28)   

—   

—   

—   

—   

(3)   

—   

—   

(3)   

(18)   

(1)   

(6)   

(11)   

(4)   

(4)   

—   

Total

$m

(2,811) 

(1,887) 

(656) 

(123) 

(8) 

(137) 

(3,341) 

(1,592) 

(108) 

(92) 

(247) 

(226) 

(172) 

(792) 

— 

(112) 

(1,210) 

(161) 

(811) 

(238) 

(445) 

(208) 

(204) 

(33) 

(507) 

(456) 

(51) 

513,539   

121,260   

65,355   

578,894   

(8,204)   

(1,644)   

(110)   

(8,314) 

179,104   

128,933   

32,278   

8,309   

1,489   

8,095   

257,942   

162,039   

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   

26,505   

18,890   

5,740   

364   

576   

935   

82,359   

64,216   

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   

22,176   

16,165   

3,557   

1,156   

513   

785   

31,637   

18,406   

1,348   

3,075   

246   

7,128   

123   

362   

60   

889   

379   

13   

170   

196   

9,292   

7,708   

1,440   

144   

1,096   

1,083   

13   

201,280   

145,098   

35,835   

9,465   

2,002   

8,880   

289,579   

180,445   

11,117   

10,298   

3,945   

35,571   

7,351   

19,221   

6,175   

15,456   

25,004   

2,175   

13,655   

9,174   

62,678   

38,133   

23,801   

744   

13,127   

11,327   

1,800   

(3,918)   

(2,958)   

(645)   

(125)   

(14)   

(176)   

(2,766)   

(1,180)   

(95)   

(90)   

(229)   

(187)   

(86)   

(782)   

—   

(117)   

(1,512)   

(157)   

(1,019)   

(336)   

(637)   

(367)   

(243)   

(27)   

(661)   

(589)   

(72)   

(632)   

(574)   

(40)   

—   

—   

(18)   

(162)   

(83)   

(2)   

(18)   

(2)   

(23)   

(27)   

(2)   

—   

(5)   

(187)   

(7)   

(176)   

(4)   

(73)   

(38)   

(27)   

(8)   

(113)   

(113)   

—   

(185)   

(147)   

(26)   

(3)   

—   

(9)   

(38)   

(15)   

—   

(4)   

—   

(18)   

—   

—   

—   

(1)   

(9)   

(3)   

(2)   

(4)   

(23)   

(3)   

(9)   

(11)   

(10)   

(10)   

—   

(4,103) 

(3,105) 

(671) 

(128) 

(14) 

(185) 

(2,804) 

(1,195) 

(95) 

(94) 

(229) 

(205) 

(86) 

(782) 

— 

(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) 

1  Real estate lending within this disclosure corresponds solely to the industry of the borrower. Commercial real estate on page 168 includes 

borrowers in multiple industries investing in income-producing assets and to a lesser extent, their construction and development.

HSBC Holdings plc Annual Report and Accounts 2021

183

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Personal lending – loans and advances to customers at amortised cost by country/territory

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 2021

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

Gross carrying amount

Allowance for ECL

First lien 
residential 
mortgages

Other 
personal

Of which: 
credit 
cards

$m

$m

$m

Total

$m

  170,818   

49,253   

8,624   

220,071   

  163,549   

19,154   

8,213   

182,703   

3,124   

22,908   

366   

26,032   

—   

1,367   

2,778   

282   

6,615   

294   

—   

—   

45   

282   

7,982   

3,072   

  149,709   

46,781   

11,413   

196,490   

98,019   

32,996   

8,154   

131,015   

21,149   

981   

76   

10,525   

2,532   

7,811   

5,672   

2,944   

2,262   

—   

1,924   

338   

43,529   

16,642   

25,773   

1,114   

5,050   

4,882   

168   

504   

543   

272   

1,103   

2,657   

6,649   

1,188   

869   

3,157   

368   

1,232   

1,557   

3,091   

799   

2,123   

169   

4,687   

4,006   

681   

427   

181   

147   

563   

791   

367   

271   

512   

761   

98   

417   

246   

555   

232   

284   

39   

1,505   

1,172   

333   

21,653   

1,524   

348   

11,628   

5,189   

14,460   

6,860   

3,813   

5,419   

368   

3,156   

1,895   

46,620   

17,441   

27,896   

1,283   

9,737   

8,888   

849   

First lien 
residential 
mortgages

$m

(329)   

(223)   

(38)   

—   

—   

(68)   

(59)   

(1)   

(5)   

(10)   

(1)   

(4)   

(33)   

—   

—   

(5)   

(26)   

—   

(18)   

(8)   

(141)   

(12)   

(33)   

(96)   

(120)   

(119)   

(1)   

Other 
personal

$m

(1,006)   

(823)   

(91)   

—   

(75)   

(17)   

(706)   

(338)   

(33)   

(30)   

(20)   

(72)   

(122)   

(40)   

(17)   

(34)   

(146)   

(3)   

(88)   

(55)   

(87)   

(53)   

(27)   

(7)   

(483)   

(450)   

(33)   

Of which: 
credit 
cards

$m

(437)   

(434)   

(3)   

—   

—   

—   

(428)   

(217)   

(32)   

(20)   

(14)   

(66)   

(34)   

(13)   

(5)   

(27)   

(60)   

(1)   

(39)   

(20)   

(47)   

(36)   

(8)   

(3)   

(163)   

(148)   

(15)   

Total

$m

(1,335) 

(1,046) 

(129) 

— 

(75) 

(85) 

(765) 

(339) 

(38) 

(40) 

(21) 

(76) 

(155) 

(40) 

(17) 

(39) 

(172) 

(3) 

(106) 

(63) 

(228) 

(65) 

(60) 

(103) 

(603) 

(569) 

(34) 

  371,368    106,969   

22,858   

478,337   

(675)   

(2,428)   

(1,135)   

(3,103) 

162,630   

51,033   

154,839   

19,696   

8,471   

8,064   

213,663   

174,535   

3,623   

23,982   

358   

27,605   

(364)   

(236)   

(43)   

(1,980)   

(1,762)   

(120)   

—   

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   

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   

514   

215   

167   

644   

841   

375   

277   

580   

863   

89   

432   

342   

1,373   

1,091   

244   

38   

1,406   

1,119   

287   

20,922   

1,477   

359   

10,834   

5,761   

13,931   

6,476   

3,962   

5,533   

360   

2,999   

2,174   

46,378   

20,571   

24,471   

1,336   

7,922   

7,252   

670   

352,282   

108,527   

23,299   

460,809   

—   

—   

(85)   

(80)   

—   

(12)   

(9)   

—   

(6)   

(41)   

—   

—   

(12)   

(43)   

—   

(37)   

(6)   

(159)   

(26)   

(36)   

(97)   

(109)   

(107)   

(2)   

(755)   

—   

(79)   

(19)   

(841)   

(387)   

(47)   

(45)   

(37)   

(81)   

(102)   

(55)   

(15)   

(72)   

(275)   

(8)   

(163)   

(104)   

(266)   

(226)   

(31)   

(9)   

(614)   

(578)   

(36)   

(859)   

(852)   

(5)   

—   

—   

(2)   

(563)   

(265)   

(45)   

(34)   

(26)   

(73)   

(35)   

(17)   

(5)   

(63)   

(142)   

(3)   

(92)   

(47)   

(193)   

(182)   

(10)   

(1)   

(290)   

(268)   

(22)   

(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) 

(3,976)   

(2,047)   

(4,731) 

1 

Included in other personal lending at 31 December 2021 is $19,972m (31 December 2020: $20,625m) guaranteed by Crédit Logement.

184

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

  918,936   119,224    18,797   

274    1,057,231    (1,367)    (3,119)    (6,867)   

(64)    (11,417) 

–  WPB

–  CMB

–  GBM

  469,477    17,285    5,211   

—    491,973   

(664)    (1,247)    (1,276)   

—   

(3,187) 

  267,517    76,798    11,462   

245    356,022   

(571)    (1,369)    (4,904)   

(53)   

(6,897) 

  181,247    25,085    2,124   

29    208,485   

(132)   

(493)   

(687)   

(11)   

(1,323) 

–  Corporate Centre

695   

56   

Loans and advances to banks at amortised cost

81,636    1,517   

–  WPB

–  CMB

–  GBM

–  Corporate Centre

20,464   

15,269   

36,875   

9,028   

481   

352   

654   

30   

Other financial assets measured at amortised cost

  875,016    4,988   

–  WPB

–  CMB

–  GBM

–  Corporate Centre

  207,335    1,407   

  163,457    2,370   

  409,808    1,204   

94,416   

7   

—   

—   

—   

—   

—   

—   

304   

175   

61   

62   

6   

751   

—   

(10)   

—   

—   

—   

—   

—   

—   

83,153   

(14)   

20,945   

15,621   

(1)   

(1)   

37,529   

(10)   

9,058   

43    880,351   

43    208,960   

—    165,888   

—    411,074   

—   

94,429   

(2)   

(91)   

(51)   

(12)   

(28)   

—   

(3)   

(1)   

—   

(2)   

—   

(54)   

(44)   

(8)   

(2)   

—   

—   

—   

—   

—   

—   

—   

(42)   

(14)   

(20)   

(8)   

—   

—   

—   

—   

—   

—   

—   

(6)   

(6)   

—   

—   

—   

(10) 

(17) 

(2) 

(1) 

(12) 

(2) 

(193) 

(115) 

(40) 

(38) 

— 

Total gross carrying amount on-balance sheet at 
31 Dec 2021

 1,875,588   125,729    19,101   

317    2,020,735    (1,472)    (3,176)    (6,909)   

(70)    (11,627) 

Loans and other credit-related commitments

  594,473    32,389   

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Financial guarantees

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Total nominal amount off-balance sheet at 
31 Dec 2021

WPB

CMB

GBM

Corporate Centre

Debt instruments measured at FVOCI at 
31 Dec 2021

  235,722    2,111   

  126,728    17,490   

  231,890    12,788   

133   

—   

775   

153   

555   

67   

—   

—    627,637   

(165)   

(174)   

(40)   

—    237,986   

(37)   

(3)   

—   

—    144,773   

(80)   

(118)   

(37)   

—    244,745   

(48)   

(53)   

133   

—   

—   

(3)   

—   

24,932    2,638   

225   

1,295   

15   

1   

6,105    1,606   

126   

17,531    1,017   

1   

—   

98   

—   

—   

—   

—   

—   

—   

—   

27,795   

(11)   

(30)   

(21)   

1,311   

7,837   

18,646   

1   

—   

(7)   

(4)   

—   

(1)   

(16)   

(13)   

—   

—   

(17)   

(4)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(379) 

(40) 

(235) 

(104) 

— 

(62) 

(1) 

(40) 

(21) 

— 

  619,405    35,027    1,000   

—    655,432   

(176)   

(204)   

(61)   

—   

(441) 

  143,373   

86,247   

  111,473   

4,038   

718   

471   

526   

311   

—   

—   

—   

—   

35    144,126   

10   

86,728   

1    112,000   

—   

4,349   

(20)   

(11)   

(13)   

(25)   

(7)   

(1)   

(2)   

(11)   

—   

—   

—   

—   

(5)   

(1)   

—   

—   

(32) 

(13) 

(15) 

(36) 

  345,131    2,026   

—   

46    347,203   

(69)   

(21)   

—   

(6)   

(96) 

HSBC Holdings plc Annual Report and Accounts 2021

185

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Summary of financial instruments to which the impairment requirements in IFRS 9 are applied – by global business (continued)

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

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

1,198   

70   

79,654   

2,004   

16,837   

12,253   

519   

222   

33,361   

1,166   

–  Corporate Centre

17,203   

Other financial assets measured at amortised cost

  768,216   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

1,268   

81,658   

17,356   

12,475   

34,527   

17,300   

177   

40    772,408   

50   

65   

56   

6   

39    168,689   

1    113,081   

—    392,728   

—   

97,910   

—   

(33)   

(2)   

(2)   

(23)   

(6)   

(80)   

(41)   

(17)   

(22)   

—   

(13)   

(9)   

(2)   

—   

(7)   

—   

(44)   

(22)   

(19)   

(3)   

—   

—   

—   

—   

—   

—   

—   

(42)   

(7)   

(25)   

(10)   

—   

—   

—   

—   

—   

—   

—   

(9)   

(9)   

—   

—   

—   

(13) 

(42) 

(4) 

(2) 

(30) 

(6) 

(175) 

(79) 

(61) 

(35) 

— 

97   

3,975   

1,547   

1,716   

705   

7   

  167,053   

  111,299   

  391,967   

97,897   

Loans and other credit-related commitments

  604,485   

54,217   

1,080   

1    659,783   

(290)   

(365)   

–  WPB

–  CMB

–  GBM

–  Corporate Centre

Total gross carrying amount on-balance sheet at 
31 Dec 2020

–  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

  1,717,790    169,164    19,272   

317   1,906,543   

(2,087)   

(5,018)   

(7,481)   

(121)    (14,707) 

  232,027   

2,591   

  111,800   

29,150   

  260,527   

22,476   

131   

—   

136   

779   

165   

—   

—    234,754   

(41)   

1    141,730   

(157)   

—    283,168   

—   

131   

14,090   

4,024   

269   

1   

18,384   

1,048   

5,556   

7,482   

4   

23   

2,519   

1,482   

—   

2   

146   

121   

—   

—   

1   

—   

—   

1,073   

8,222   

9,085   

4   

(2)   

(203)   

(160)   

—   

(62)   

—   

(36)   

(26)   

—   

(92)   

—   

(37)   

—   

(19)   

(17)   

(1)   

(78)   

—   

(72)   

(6)   

—   

(26)   

—   

(12)   

(14)   

—   

(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) 

186

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Loans and advances to customers and banks metrics

First lien residential mortgages

–  second lien residential mortgages

–  guaranteed loans in respect of residential property

–  other personal lending which is secured

–  credit cards

–  other personal lending which is unsecured

–  motor vehicle finance

–  IPO loans

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 2021

Gross 
carrying 
amount

Of which: 
stage 3 and 
POCI

Allowance 
for ECL

Of which: 
stage 3 and 
POCI

$m

$m

$m

$m

371,368   

3,045   

(675)   

(416)   

Change in 

ECL Write-offs

Recoveries

(9)   

(42)   

(120)   

(214)   

(421)   

(4)   

—   

(810)   

(1,226)   

(105)   

(171)   

(962)   

(31)   

(20)   

(191)   

(111)   

(100)   

(775)   

(172)   

(307)   

—   

(18)   

(37)   

(42)   

395   

21,610   

37,995   

22,858   

22,478   

1,633   

—   

106,969   

478,337   

7,899   

9,685   

93,743   

16,618   

3,895   

13,954   

37   

236   

366   

338   

915   

5   

—   

1,897   

4,942   

363   

463   

(14)   

(58)   

(156)   

(1,135)   

(1,039)   

(26)   

—   

(2,428)   

(3,103)   

(138)   

(227)   

2,107   

(1,248)   

78   

51   

843   

(68)   

(29)   

(508)   

(440)   

94,944   

3,005   

(2,107)   

(1,937)   

29,592   

23,376   

18,471   

667   

1,200   

250   

(363)   

(423)   

(184)   

121,260   

2,473   

(1,644)   

19,685   

28,675   

1,271   

1,793   

4,854   

2,598   

12,297   

977   

2   

7,612   

338   

637   

749   

—   

65   

183   

152   

448   

—   

—   

—   

—   

(238)   

(431)   

(8)   

(37)   

(72)   

(92)   

(373)   

(246)   

—   

—   

(4)   

(10)   

—   

—   

—   

—   

513,539   

13,734   

(8,204)   

(5,665)   

65,355   

395   

(110)   

578,894   

14,129   

(8,314)   

  1,057,231   

19,071   

(11,417)   

83,153   

—   

(17)   

(40)   

(5,705)   

(6,931)   

—   

  1,140,384   

19,071   

(11,434)   

(6,931)   

$m

(70)   

(1)   

(8)   

(11)   

(751)   

(659)   

(20)   

—   

(1,450)   

(1,520)   

(5)   

(57)   

(222)   

—   

(7)   

(94)   

$m

31 

6 

2 

1 

153 

156 

6 

— 

324 

355 

— 

(1) 

7 

— 

— 

9 

(238)   

15 

$m

—   

12   

(5)   

(11)   

172   

135   

(22)   

—   

281   

281   

61   

72   

102   

5   

3   

(13)   

163   

100   

12   

(12)   

(10)   

(17)   

(4)   

(674)   

(152)   

97   

48   

6   

1   

44   

27   

(59)   

—   

1   

(6)   

3   

(19)   

129   

110   

391   

22   

413   

(39)   

(37)   

—   

(1)   

(69)   

(26)   

(109)   

—   

—   

—   

—   

(1,087)   

(5)   

(1,092)   

(2,612)   

—   

(2,612)   

2 

6 

1 

5 

1 

— 

1 

— 

1 

— 

6 

— 

1 

— 

— 

54 

— 

54 

409 

— 

409 

HSBC Holdings plc Annual Report and Accounts 2021

187

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Allowance for 
ECL

Of which: 
stage 3 and 
POCI

Change in 
ECL

Write-offs

Recoveries

$m

(755)   

(22)   

(43)   

(159)   

(2,047)   

(1,682)   

(23)   

—   

(3,976)   

(4,731)   

(207)   

(365)   

51   

159   

448   

680   

882   

8   

—   

2,228   

5,611   

332   

813   

2,163   

(1,588)   

53   

47   

777   

(73)   

(37)   

(590)   

780   

537   

164   

(493)   

(491)   

(189)   

744   

22,552   

38,035   

23,299   

22,316   

1,533   

48   

108,527   

460,809   

7,445   

11,947   

93,906   

16,200   

3,174   

14,600   

90,663   

29,433   

26,071   

19,979   

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)   

$m

(442)   

(10)   

(32)   

(127)   

(380)   

(506)   

(5)   

—   

(1,060)   

(1,502)   

(150)   

(220)   

(945)   

(8)   

(22)   

(430)   

$m

(259)   

(5)   

1   

(62)   

(1,194)   

(1,085)   

(18)   

—   

(2,363)   

(2,622)   

(28)   

(513)   

(652)   

(7)   

(8)   

(151)   

$m

(92)   

—   

(3)   

(5)   

(736)   

(543)   

(28)   

—   

(1,315)   

(1,407)   

(3)   

(311)   

(375)   

(14)   

—   

(135)   

(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)   

—   

3,208   

(2,532)   

(2,032)   

(1,560)   

(280)   

527,088   

13,238   

(9,494)   

(5,949)   

(5,311)   

(1,537)   

64,580   

591,668   

1,052,477   

81,658   

523   

13,761   

19,372   

(265)   

(9,759)   

(14,490)   

—   

(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)   

$m

35 

— 

— 

1 

131 

108 

5 

— 

245 

280 

— 

— 

7 

— 

— 

13 

11 

1 

— 

— 

4 

1 

— 

— 

1 

1 

— 

4 

— 

1 

— 

— 

44 

2 

46 

326 

— 

326 

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 $1.6bn at 
31 December 2021 (2020: $1.7bn).

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 (2020: 100%). For 
further details of credit quality classification, see page 138. 

Risk

Loans and advances to customers and banks metrics (continued)

Gross 
carrying 
amount

$m

Of which: 
stage 3 and 
POCI

$m

352,282   

3,383   

First lien residential mortgages

–  second lien residential mortgages

–  guaranteed loans in respect of residential property

–  other personal lending which is secured

–  credit cards

–  other personal lending which is unsecured

–  motor vehicle finance

–  IPO loans

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

HSBC Holdings

(Audited)

Risk in HSBC Holdings is overseen by the HSBC Holdings Asset 
and Liability Management Committee. 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 315); 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).

188

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Treasury risk

Overview

Treasury risk management

Other Group risks

Capital risk in 2021

Liquidity and funding risk in 2021

Structural foreign exchange risk in 2021

Interest rate risk in the banking book in 2021

Overview

Page

189

189

191

193

196

199

200

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 non-trading book 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, non-
trading book foreign exchange risk, and interest rate risk in the 
banking book.

For further details, refer to our Pillar 3 Disclosures at 31 December 2021.

Treasury risk management

Key developments in 2021

• Global Treasury initiated a new flagship programme to deliver a 
more resilient, effective and efficient Treasury function over the 
next four years with a focus on safeguarding and optimising 
financial resources. The programme will aim to deliver 
modernised infrastructure and upgraded modelling capabilities 
alongside a broad reorganisation of the Global Treasury 
function.

• As announced in February 2021, we intend to maintain a 

common equity tier 1 (‘CET1’) ratio above 14%, normalising 
within our target operating range of 14% to 14.5% by the end 
of 2022. For the financial year 2021, we were at the lower end 
of our target dividend payout ratio range of between 40% and 
55% of reported earnings per ordinary share (‘EPS’), driven by 
ECL releases and higher restructuring costs.

• We continued to build our recovery and resolution capabilities, 
including in relation to the Bank of England (‘BoE’) Resolvability 
Assessment Framework, which had an overall compliance 
deadline of 1 January 2022. We submitted a self-assessment 
report on our resolvability to the Prudential Regulation 
Authority (‘PRA’) and the BoE on 1 October 2021. This included 
an assessment of how we addressed resolvability outcomes 
that impact treasury risk, including valuations, and capital, 
liquidity and funding capabilities in resolution. We will publish a 

summary of our self-assessment report in June 2022. The BoE 
will similarly publish a statement relating to the resolvability of 
HSBC at the same time.

• The BoE’s Financial Policy Committee (‘FPC’) confirmed its 

guidance on the path for the UK countercyclical capital buffer 
rate. It has announced that it is increasing the rate from 0% to 
1%, effective December 2022 in line with the usual 12‑month 
implementation lag. Absent a material change in the outlook for 
the UK’s financial stability, the FPC would expect to further 
increase the rate to 2% in the second quarter of 2022, which 
would take effect 12 months later. The Hong Kong Monetary 
Authority (‘HKMA’) maintained the countercyclical capital 
buffer rate at 1% for Hong Kong, but it will continue to monitor 
credit and economic conditions closely.

• The PRA has confirmed that the capitalisation of structural 
foreign exchange risk should align to a Pillar 1 approach. In 
response, we adopted this approach from 31 December 2021. 
As a result, market risk RWAs increased by $8.4bn, offset by a 
reduction in Pillar 2 requirements. In advance of this change, 
we undertook incremental hedging transactions to reduce 
structural foreign exchange risk and RWAs.

• We revised the approach to calculate the Group liquidity 

coverage ratio (‘LCR’) better reflecting the free transferability of 
liquidity within the Group, in consideration with currency 
convertibility and regulatory intra-Group limits. A risk appetite 
has been set against the Group LCR. We first published the 
Group LCR as part of our 30 June 2021 disclosures. Based on 
the consolidation methodology, the Group LCR was 138.4% at 
31 December 2021. 

• As part of our continuing focus on enhancing the quality of our 
regulatory reporting, we are progressing with a comprehensive 
programme to strengthen our global processes, improve 
consistency and enhance control standards on various aspects 
of regulatory reporting. Further details can be found in the 
subsequent sub-section ‘Regulatory reporting processes and 
controls’.

• We worked with the fiduciaries of all our pension plans to 
ensure the measures taken in response to the Covid-19 
pandemic, including remote working for plan providers and 
dealing appropriately with affected plan members, were 
properly maintained and supported. Our de-risking 
programmes continued to provide protection against the 
volatility in financial markets that resulted from the pandemic’s 
economic impact.

• We created a new team within the Global Treasury function to 
be accountable for monitoring and managing the financial risk 
and capital implications of the Group’s employee defined 
benefit pension plans. This change creates clearer delineation 
of the roles and responsibilities of the first and second lines of 
defence.

The Group’s CET1 ratio was 15.8% at 31 December 2021 and the 
leverage ratio, calculated in accordance with the Capital 
Requirements Regulation, was 5.2%. The Group continues to 
maintain and plan for the appropriate resources required to 
manage its risk and deliver its strategic objectives while 
supporting local economies.

All of the Group’s material operating entities were above 
regulatory minimum levels of liquidity and funding at 31 December 
2021.

For quantitative disclosures on capital ratios, own funds and RWAs, see 
pages 193 to 194. For quantitative disclosures on liquidity and funding 
metrics, see pages 196 to 197. For quantitative disclosures on interest rate 
risk in the banking book, see pages 200 to 201.

Governance and structure

The Global Head of Traded and Treasury Risk Management and 
Risk Analytics is the accountable risk steward for all treasury risks. 
The Group Treasurer is the risk owner for all treasury risks, with 
the exception of pension risk, which is co-owned together with the 
Group Head of Performance, Reward and Employee Relations.

HSBC Holdings plc Annual Report and Accounts 2021

189

Risk review 
Risk

Capital risk, liquidity risk, interest rate risk in the banking book and 
non-trading book foreign exchange risk are the responsibility of 
the Group Executive Committee and the Group Risk Committee 
(‘GRC’). The Global Treasury function actively manages these risks 
on an ongoing basis, supported by the Holdings Asset and Liability 
Management Committee (‘ALCO’) and local ALCOs, overseen by 
Treasury Risk Management and the Risk Management Meeting 
(‘RMM’).

Pension risk is overseen by a network of local and regional 
pension risk management meetings. The Global Pensions Risk 
Management Meeting provides oversight of all pension plans 
sponsored by HSBC globally and is chaired by the accountable risk 
steward.

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 Group’s policies 
and controls.

Capital, liquidity and funding risk management 
processes

Assessment and risk appetite

Our capital management policy is underpinned by a global capital 
management framework and our ICAAP. The framework 
incorporates key capital risk appetites including CET1, total 
capital, minimum requirements for own funds and eligible 
liabilities (‘MREL’), leverage ratio 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, 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, interest rate risk in the banking book and Group risk 
driven by credit concentration risk in HSBC UK. Climate risk is also 
considered as part of the ICAAP, and we are continuing to develop 
our approach. The Group’s 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 in line with global 
guidance, while considering their local regulatory regimes to 
determine their own risk appetites and ratios.

HSBC Holdings is the provider of equity capital and MREL-eligible 
debt to its subsidiaries, and also provides them with non-equity 
capital where necessary. These investments are funded by HSBC 
Holdings’ own equity capital and MREL-eligible debt.

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. In 
2021, we updated the basis of preparation for the calculation of 
double leverage, to better reflect the economics of the risk and 
align with the Group accounting view. The Group recognises that 
double leverage can give rise to holding company cash flow risk, 
and the risk framework reflects the view that the holding company 
should be a source of support for its subsidiaries in times of stress. 
Double leverage is one of the constraints 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 holdings capital buffer comprising high-quality liquid 
assets (‘HQLA’), which at 31 December 2021 was in excess of 
$13bn. The portfolio of HQLA helps to mitigate the risks 
associated with double leverage. Further mitigation is provided by 
additional tier 1 (‘AT1’) securities issued in excess of the regulatory 
requirements of our subsidiaries.

We aim to ensure that management has oversight of our liquidity 
and funding risks at Group and entity level by maintaining 
comprehensive policies, metrics and controls. We manage 
liquidity and funding risk at an operating entity level to make sure 
that obligations can be met in the jurisdiction where they fall due, 
generally without reliance on other parts of the Group. Operating 

190

HSBC Holdings plc Annual Report and Accounts 2021

Planning and performance

Capital and risk-weighted asset (‘RWA’) plans form part of the 
annual financial resource 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 financial resource plan 
that is approved by the Board. The Board-level appetite measures 
are the LCR and net stable funding ratio (‘NSFR’), together with an 
internal liquidity metric which was introduced in January 2021 to 
supplement the LCR and NSFR. In addition, we use a wider set of 
measures to manage an appropriate funding and liquidity profile, 
including legal entity depositor concentration limits, intra-day 
liquidity, forward-looking funding assessments and other key 
measures.

Risks to capital and liquidity

Outside the stress testing framework, other risks may be identified 
that have the potential to affect our RWAs, capital and/or liquidity 
position. Downside and Upside scenarios are assessed against our 
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 and 
liquidity requirements. These include the UK’s implementation of 
amendments to the Capital Requirements Regulation (‘CRR II’), 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 internal ratings-based (‘IRB’) modelling 
requirements. 

Regulatory developments

The PRA has confirmed that software assets are deducted in full 
from CET1 capital, starting 1 January 2022. This reverses the 
beneficial changes to the treatment of software assets that were 
implemented as part of the EU’s response to the Covid-19 
pandemic. As a result, the CET1 capital ratio will reduce by 
approximately 25bps. 

Overall, we expect RWAs to increase by around 3% as a result of 
changes in regulations during 2022. These include the changes to 
the UK’s version of the CRR II, as well as other regulatory 
statements including changes to IRB modelling requirements and 
the expiry of transitional provisions in relation to the UK’s 
withdrawal from the EU. The CRR II changes, including the PRA’s 
new rules on NSFR, counterparty credit risk, equity investment in 
funds, and leverage ratio, will be reflected in disclosures starting in 
the first quarter of 2022.

Further changes will occur with the introduction of the remaining 
Basel III Reforms on which the PRA is expected to consult in the 
second half of 2022. We currently do not foresee a material net 
impact on initial implementation. The RWA output floor under the 
Basel III reforms will be subject to a five-year transitional 
provision. Any impact from the output floor would be towards the 
end of the transition period.

Regulatory reporting processes and controls

The quality of regulatory reporting remains a key priority for 
management and regulators. Notably, the PRA published a Dear 
CEO letter addressed to UK regulated banks, which highlighted 
areas of concern over the processes firms use to deliver regulatory 
returns. Recent sanctions issued by the PRA demonstrate their 
intent in this respect. We are progressing with a comprehensive 
programme to strengthen our processes, improve consistency, 
and enhance controls on various aspects of regulatory reporting. 
We have commissioned a number of independent external 
reviews, some at the request of our regulators, including one on 
our credit risk RWA reporting process, which is currently ongoing. 
As a result of these initiatives, there may be an impact on some of 
our regulatory ratios, such as the CET1 and LCR.

Stress testing and recovery planning

The Group uses stress testing to evaluate the robustness of plans 
and risk portfolios including the impact of ECL, and to meet the 
stress testing requirements 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 capital or 
liquidity buffers. 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. This is to help ensure that 
our capital and liquidity position can be recovered even in an 
extreme stress event.

Overall, recovery and resolution plans form part of the integral 
framework safeguarding the Group’s financial stability. The Group 
is committed to developing its recovery and resolution capabilities 
further, including in relation to the BoE’s Resolvability Assessment 
Framework.

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 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 Global Treasury function uses a number of measures to 
monitor and control interest rate risk in the banking book, 
including:

• net interest income sensitivity; and

• economic value of equity sensitivity

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 calculate both one-year and five-year NII sensitivities 
across a range of interest rate scenarios.

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.

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 holders 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.

Further details of HSBC’s risk management of interest rate risk in the banking 
book can be found in the Group’s Pillar 3 Disclosures at 31 December 2021. 

Other Group risks

Non-trading book foreign exchange exposures

Structural foreign exchange exposures

Structural foreign exchange exposures represent net assets or 
capital investments in subsidiaries, branches, joint arrangements 
or associates, together with any associated hedges, 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 positions where it is capital 
efficient to do so, and subject to approved limits. This is achieved 

HSBC Holdings plc Annual Report and Accounts 2021

191

Risk review 
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).

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 fiduciaries 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 60% of the 
plan’s pensioner liabilities.

Risk

through a combination of net investment hedges and economic 
hedges. Hedging positions are monitored and rebalanced 
periodically to manage RWA or downside risks associated with 
HSBC’s foreign currency investments.

For further details of our structural foreign exchange exposures, see page 
199.

Transactional foreign exchange exposures

Transactional 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 generated through profit 
and loss is periodically transferred to Markets and Securities 
Services and managed within limits with the exception of limited 
residual foreign exchange exposure arising from timing differences 
or for other reasons. Transactional foreign exchange exposure 
generated through OCI reserves is managed by the Markets 
Treasury business within a limit framework to be agreed in the first 
half of 2022.

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, financial liabilities including debt capital issued 
and structural foreign exchange hedges. 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 and forward 
foreign exchange contracts to manage its structural foreign 
exchange exposures.

For quantitative disclosures on interest rate risk in the banking book, see 
pages 200 to 201.

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. We will continue to review and 
enhance our risk appetite metrics to 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 

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HSBC Holdings plc Annual Report and Accounts 2021

Capital risk in 2021

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

2021

31 Dec

2020

680.6 

35.9 

32.9 

88.9 

838.3 

132.6 

156.3 

177.8 

 15.8 

 18.6 

 21.2 

132.6 

155.0 

167.5 

 15.8 

 18.5 

 20.0 

717.0

518.0

 138.4 

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 

References to EU regulations and directives (including technical 
standards) should, as applicable, be read as references to the UK’s 
version of such regulation or directive, as onshored into UK law 
under the European Union (Withdrawal) Act 2018, and as may be 
subsequently amended under UK law.

Own funds disclosure

(Audited)

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 pandemic.

At 31 December 2021, our common equity tier 1 (‘CET1’) capital 
ratio decreased to 15.8% from 15.9% at 31 December 2020. 
RWAs decreased due to RWA reductions under the transformation 
programme and favourable movements in asset quality. CET1 
capital fell due to higher regulatory deductions and fair value 
movements net of capital generation.

Own funds

The $3.5bn fall in CET1 capital was mainly as a result of:

• a $2.9bn net increase in deductions for excess expected loss,
investment in financial sector entities and defined benefit
pension assets surplus;

• $2.5bn unfavourable foreign currency translation differences;

and

• a $2.2bn decrease in fair value through other comprehensive

income reserve.

These decreases were partly offset by capital generation of $3.9bn 
through profits net of share buy-back, foreseeable dividend and 
dividends paid.

Our Pillar 2A requirement at 31 December 2021, as per the PRA’s 
Individual Capital Requirement based on a point-in-time 
assessment, was $22.5bn, equivalent to 2.7% of RWAs, of which 
1.5% was required to be met by CET1. With effect from 
31 December 2021, structural foreign exchange risk is capitalised 
in RWAs under Pillar 1, with a consequent reduction in Pillar 2A. 
Going forward, structural foreign exchange risk will be assessed 
for Pillar 2A in the same manner as other risks capitalised under 
Pillar 1.

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 earnings1
Accumulated other comprehensive income (and other reserves)

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 adjustments1
Total regulatory adjustments to common equity tier 11
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

2021

$m

23,513 

23,513 

121,059 

8,273 

4,186 

5,887 

162,918 

(30,353) 

132,565 

23,787 

(60) 

23,727 

156,292 

23,018 

(1,524) 

21,494 

31 Dec

2020

$m

23,219 

23,219 

126,314 

9,768 

4,079 

(252) 

163,128 

(27,078) 

136,050 

24,183 

(60) 

24,123 

160,173 

25,722 

(1,472) 

24,250 

177,786 

184,423 

* The references identify the lines prescribed in the European Banking Authority (‘EBA’) template, which are applicable and where there is a value.
1 The figures for 31 December 2020 have been restated to reflect the reclassification of the IFRS 9 transitional adjustment from retained earnings

(within row 6) to ‘Total regulatory adjustments to common equity tier 1’ (row 28).

HSBC Holdings plc Annual Report and Accounts 2021

193

Risk reviewRisk

Throughout 2021, we complied with the PRA’s regulatory capital 
adequacy requirements, including those relating to stress testing. 

• the expiry of transitional provisions in relation to the UK’s 

withdrawal from the EU.

Regulatory and other developments

During 2022, we expect our CET1 ratio to be affected by 
regulatory developments including:

•  the change in the treatment of software assets;

•  the implementation of the standardised approach for 

counterparty credit risk calculation, which came into effect on 
1 January 2022;

• measures to improve the comparability of internal ratings-

based (‘IRB’) models, including the introduction of a minimum 
risk weight for performing mortgage portfolios in the UK; and

Based on our capital position at 31 December 2021, we would 
expect that the proposed classification of our retail banking 
operations in France as being held for sale would reduce our CET1 
ratio by around 30bps. Separately, our recent strategic actions are 
likely to lead to a fall in our CET1 ratio of around 15bps, of which 
we expect approximately half will occur in the first quarter of 
2022. These actions include the acquisitions of AXA Singapore, 
L&T Investment Management and HSBC Life China, and the exit of 
mass market retail banking in the US.

Risk-weighted assets 

RWAs by global business

Credit risk

Counterparty credit risk

Market risk

Operational risk

At 31 Dec 2021

RWAs by geographical region

Credit risk

Counterparty credit risk
Market risk1
Operational risk

At 31 Dec 2021

WPB

$bn

CMB

$bn

143.0   

305.4   

1.1   

1.7   

32.5   

178.3   

0.7   

0.9   

25.9   

332.9   

GBM Corporate Centre

$bn

151.8   

33.5   

20.3   

30.6   

236.2   

$bn

80.4   

0.6   

10.0   

(0.1)   

90.9   

Europe

$bn

Asia

$bn

MENA

$bn

193.7   

318.1   

50.6   

19.4   

24.6   

23.4   

9.9   

25.3   

43.0   

1.3   

2.3   

6.0   

261.1   

396.3   

60.2   

North
America

Latin
America

$bn

90.6   

3.3   

5.3   

11.2   

110.4   

$bn

27.6   

2.0   

1.0   

5.3   

35.9   

838.3 

Total

$bn

680.6 

35.9 

32.9 

88.9 

838.3 

Total

$bn

680.6 

35.9 

32.9 

88.9 

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 2021

Asset size

Asset quality

Model updates

Methodology and policy

Acquisitions and disposals

Foreign exchange movements

Total RWA movement

RWAs at 31 Dec 2021

RWA movement by geographical region by key driver

RWAs at 1 Jan 2021

Asset size

Asset quality

Model updates

Methodology and policy

Acquisitions and disposals

Foreign exchange movements

Total RWA movement

RWAs at 31 Dec 2021

Credit risk, counterparty credit risk and operational risk

WPB

$bn

171.2   

5.5   

(2.2)   

2.0   

3.4   

(0.4)   

(2.9)   

5.4   

CMB

$bn

326.8   

12.5   

(4.9)   

(0.4)   

3.3   

—   

(5.3)   

5.2   

176.6   

332.0   

GBM

$bn

242.2   

(12.1)   

(0.4)   

—   

(9.8)   

—   

(4.0)   

(26.3)   

215.9   

Corporate 
Centre

Market
risk

$bn

88.8   

0.6   

(0.5)   

—   

(7.3)   

—   

(0.7)   

(7.9)   

80.9   

$bn

28.5   

(1.8)   

—   

(1.2)   

7.4   

—   

—   

4.4   

32.9   

Credit risk, counterparty credit risk and operational risk

Europe

$bn

Asia

$bn

MENA

$bn

North
America

Latin
America

$bn

$bn

260.8   

363.3   

57.8   

113.1   

34.0   

(15.9)   

17.2   

2.9   

—   

(5.5)   

—   

(5.8)   

(24.3)   

(4.9)   

1.7   

(3.2)   

—   

(3.1)   

7.7   

2.3   

(0.5)   

—   

0.6   

—   

(2.3)   

0.1   

0.8   

(6.2)   

(0.1)   

(2.3)   

(0.4)   

0.2   

(8.0)   

2.1   

0.7   

—   

—   

—   

(1.9)   

0.9   

236.5   

371.0   

57.9   

105.1   

34.9   

Market risk

$bn

28.5   

(1.8)   

—   

(1.2)   

7.4   

—   

—   

4.4   

32.9   

Total
RWAs

$bn

857.5 

4.7 

(8.0) 

0.4 

(3.0) 

(0.4) 

(12.9) 

(19.2) 

838.3 

Total
 RWAs

$bn

857.5 

4.7 

(8.0) 

0.4 

(3.0) 

(0.4) 

(12.9) 

(19.2) 

838.3 

Risk-weighted assets (‘RWAs’) fell by $19.2bn during the year, 
including a drop of $12.9bn due to foreign currency translation 
differences. The $6.3bn decrease (excluding foreign currency 
translation differences) resulted from RWA saves and favourable 
movements in asset quality, which more than offset increases due 

194

HSBC Holdings plc Annual Report and Accounts 2021

to lending growth and regulatory change. At 31 December 2021, 
our cumulative RWA saves as part of our transformation 
programme were $104bn, including accelerated reductions of 
$9.6bn from 31 December 2019.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Asset size

Model updates

The $12.5bn increase in CMB RWAs reflected corporate loan 
growth in mainland China, Hong Kong and North America, while 
lending in Europe reduced.

WPB RWAs rose by $5.5bn, primarily due to lending growth in 
Asia, largely in the mortgage portfolio. Sovereign exposures drove 
the $0.6bn rise in Corporate Centre RWAs.

The $12.1bn fall in GBM was mostly due to lower lending, 
management initiatives and mark-to-market movements in 
Europe, North America and Latin America, partly offset by growth 
in Asia.

Market risk RWAs decreased by $1.8bn, largely as a result of 
reduced exposures and risk mitigation actions.

Asset quality

The RWA decreases in CMB, WPB and Corporate Centre were 
mostly due to favourable portfolio mix changes in Asia and North 
America, and credit migration in Europe and North America.

In GBM, favourable portfolio mix changes in Asia and credit 
migration in North America were partly offset by increases in the 
UK due to portfolio changes, leading to an overall fall of $0.4bn.
Leverage ratio1

The $2.0bn increase in WPB was mostly due to changes to our 
Australian mortgages model. 

This was partly offset by the $1.2bn reduction in market risk 
RWAs, largely from the implementation of an options risk model. 
The fall in CMB RWAs was driven by corporate model updates.

Methodology and policy

Changes to Markets Treasury allocation methodologies decreased 
RWAs in Corporate Centre and increased RWAs in WPB, CMB and 
GBM. However, the increase in GBM was more than offset by 
parameter refinements across our major regions.

The $7.4bn rise in market risk included an $8.4bn increase on our 
adoption of a Pillar 1 approach to the capitalisation of structural 
foreign exchange risk, following confirmation from the PRA. This 
was partly offset by enhancements to foreign exchange risk 
calculations under the standardised approach.

Acquisitions and disposals

The sale of a US credit card portfolio led to a $0.4bn fall in WPB 
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 average2

UK leverage ratio – quarterly average2
UK leverage ratio – quarter end2

At

31 Dec

2021

$bn

155.0   

2,962.7   

%

 5.2 

31 Dec

2020

$bn

158.5 

2,897.1 

%

 5.5 

Fully phased-in Fully phased-in

2,545.6   

2,555.5 

%

 6.0 

 6.2 

%

 6.1 

 6.2 

*  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 from the 

calculation of exposure qualifying central bank balances and loans under the UK Bounce Back Loan Scheme.

Our leverage ratio calculated in accordance with the Capital 
Requirements Regulation was 5.2% at 31 December 2021, down 
from 5.5% at 31 December 2020, due to a decrease in tier 1 
capital and an increase in leverage exposure, primarily due to 
growth in central bank deposits and customer lending, offset by a 
decrease in financial investments.

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. 

At 31 December 2021, 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 $17.6bn and 
$2.5bn respectively. We exceeded these leverage requirements.

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 tables in this section, 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. 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.

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 
$1.0bn under the STD approach with a tax impact of $0.2bn. At 
31 December 2020, the add-back to the capital base under the 
STD approach was $1.6bn with a tax impact of $0.4bn. 

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 2021 is published on our website at www.hsbc.com/
investors.

HSBC Holdings plc Annual Report and Accounts 2021

195

Risk review 
 
 
Risk

Liquidity and funding risk in 2021

Liquidity metrics

At 31 December 2021, 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 assets for each entity is shown in the following table 
along with the individual LCR levels based on European 
Commission Delegated Regulation (EU) 2015/61. This basis may 
differ from local LCR measures due to differences in the way non-
EU regulators have implemented the Basel III standards. Each

Operating entities’ liquidity

 entity maintains sufficient stable funding relative to the required 
stable funding assessed using the NSFR or other appropriate 
metrics. From 1 January 2022, we started managing funding risk 
based on the PRA’s NSFR rules.

In addition to regulatory metrics, we enhanced our liquidity 
framework in 2021 to include an internal liquidity metric, which is 
being used to monitor and manage liquidity risk via a low-point 
measure across a 270-day horizon, taking into account recovery 
capacity. 

The Group liquidity and funding position at the end of 2021 is 
analysed in the following sections.

HSBC UK Bank plc (ring-fenced bank)1
HSBC Bank plc (non-ring-fenced bank)2
The Hongkong and Shanghai Banking Corporation – Hong Kong branch3
The Hongkong and Shanghai Banking Corporation – Singapore branch3
Hang Seng Bank

HSBC Bank China

HSBC Bank USA
HSBC Continental Europe4, 5
HSBC Bank Middle East Ltd – UAE branch
HSBC Canada4
HSBC Mexico

HSBC UK Bank plc (ring-fenced bank)1
HSBC Bank plc (non-ring-fenced bank)2
The Hongkong and Shanghai Banking Corporation – Hong Kong branch3
The Hongkong and Shanghai Banking Corporation – Singapore branch3
Hang Seng Bank

HSBC Bank China

HSBC Bank USA
HSBC Continental Europe4
HSBC Bank Middle East Ltd – UAE branch
HSBC Canada4
HSBC Mexico

LCR

%

241   

150   

154   

179   

169   

141   

119   

145   

210   

119   

200   

198   

136   

195   

162   

212   

232   

130   

143   

280   

165   

198   

At 31 December 2021

HQLA

Net outflows

NSFR

$bn

163   

135   

145   

18   

43   

17   

98   

54   

12   

22   

9   

At 31 December 2020

121   

138   

146   

16   

50   

24   

106   

48   

11   

30   

10   

$bn

68   

90   

94   

10   

25   

12   

83   

37   

6   

18   

5   

61   

102   

75   

10   

24   

10   

82   

34   

4   

18   

5   

%

178 

107 

135 

145 

144 

130 

140 

128 

146 

123 

141 

164 

124 

146 

135 

151 

158 

130 

130 

164 

136 

139 

1 HSBC UK Bank plc refers to the HSBC UK liquidity group, which comprises four legal entities: HSBC UK Bank plc, 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 Limited. 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.

5 The net stable funding ratio for HSBC Continental Europe is based on the EU’s CRR II rules.

At 31 December 2021, all of the Group’s principal operating 
entities were above regulatory minimum levels. 

liquidity ratio dropped to 154%, mainly due to growth in equity 
holding and loans.

The most significant movements in 2021 are explained below:

• Hang Seng Bank’s liquidity ratio dropped to 169%, mainly due 

• HSBC UK Bank plc retained a strong liquidity position, 

to growth in loans.

reflecting growth in its commercial surplus that was driven by 
customer deposits and the drawdown of a central bank term 
funding scheme. 

• HSBC Bank China’s liquidity ratio dropped to 141%, mainly 

driven by growth in loans coupled with lower deposits and debt 
issuances.

• HSBC Bank plc’s liquidity ratio increased to 150%, mainly due 

• HSBC Bank Middle East Ltd – UAE branch retained a strong 

to growth in customer deposits and a decline in loans.

liquidity position, with a liquidity ratio of 210%.

• HSBC Continental Europe maintained a strong liquidity 

position, reflecting growth in deposits.

• The Hongkong and Shanghai Banking Corporation – Hong 

Kong branch’s liquidity position remained strong, although its 

• HSBC Canada’s liquidity ratio dropped to 119%, mainly driven 
by the maturity of the short-term funding raised during the 
pandemic and growth in loans. 

196

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated liquidity metrics

Liquidity coverage ratio

At 31 December 2021, the total HQLA held at entity level 
amounted to $880bn (31 December 2020: $857bn), an increase of 
$23bn. In 2021, we implemented a revised approach to the 
application of the requirements under the European Commission 
Delegated Regulation (EU) 2015/61. This revised approach was 
used to assess the limitations in the transferability of entity 
liquidity around the Group and resulted in an adjustment of 
$163bn to LCR HQLA and $9bn to LCR inflows. This reflected an 
increase in the adjustment of $62bn compared with the approach 
used for the disclosure in the Annual Report and Accounts 2020. 
The change in methodology was designed to better incorporate 
local regulatory restrictions on the transferability of liquidity.

High-quality liquid assets (in entities)

EC Delegated Act adjustment for transfer
restrictions2

Group LCR HQLA

Net outflows

Liquidity coverage ratio

At

31 Dec

30 Jun

2021

$bn

880

(172)

717

518

2021

$bn

844

(189)

659

494

31 Dec 
 20201

$bn

857

(179)

678

487

138%

134%

139%

1   Group LCR numbers above for 31 December 2020 are based on the 

approach used before the methodology was revised. 

2   This includes adjustments made to high-quality liquid assets and 

inflows in entities to reflect liquidity transfer restrictions 

Liquid assets

After the $163bn adjustment, the Group LCR HQLA of $717bn 
(31 December 2020: $678bn) was held in a range of asset classes 
and currencies. Of these, 97% were eligible as level 1 
(31 December 2020: 90%).

The following tables reflect the composition of the liquidity pool by 
asset type and currency at 31 December 2021.

Liquidity pool by asset type

Cash and balance at central bank

Central and local government 
bonds

Regional government public 
sector entities

International organisation and 
multilateral developments banks

Covered bonds

Other

Total at 31 Dec 2021

Total at 31 Dec 2020

Liquidity 
pool

Cash

Level 11

Level 21

$bn

$bn

$bn

390   

390   

—   

$bn

— 

302   

—   

281   

21 

3   

—   

2   

1 

9   

4   

9   

—   

—   

—   

9   

2   

8   

717   

390   

302   

678

307

301

— 

2 

1 

25 

70

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.

Funding sources 

(Audited)

Customer accounts
Deposits by banks

Repurchase agreements – non-trading

Debt securities in issue

Cash collateral, margin and settlement accounts
Liabilities of disposal groups held for sale

Subordinated liabilities

Financial liabilities designated at fair value

Liabilities under insurance contracts

Trading liabilities
–  repos

–  stock lending

–  other trading liabilities

Total equity

Other balance sheet liabilities

At 31 Dec

Funding uses

(Audited)

2021

$m

  1,710,574   
101,152   
126,670   

78,557   

65,452   

9,005   

20,487   

145,502   

112,745   

84,904   

11,004   
2,332   

71,568   

2020

$m

1,642,780 

82,080 
111,901 

95,492 

78,565 

— 

21,951 

157,439 

107,191 

75,266 

11,728 
4,597 

58,941 

206,777   

296,114   

204,995 

406,504 

  2,957,939   

2,984,164 

2021

$m

2020

$m

Loans and advances to customers

  1,045,814   

1,037,987 

Loans and advances to banks
Reverse repurchase agreements – non-trading

Cash collateral, margin and settlement 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

83,136   

81,616 

241,648   

230,628 

59,884   

76,859 

3,411   

299 

248,842   

231,990 

14,994   
8,082   

225,766   

446,274   

403,018   

425,912   

13,990 
8,286 

209,714 

490,693 

304,481 

529,611 

1  As defined in EU regulations, level 1 assets means ‘assets of 

At 31 Dec

  2,957,939   

2,984,164 

extremely high liquidity and credit quality’, and level 2 assets means 
‘assets of high liquidity and credit quality’.

Liquidity pool by currency

$

£

€

HK$

Other

Total

$bn

$bn

$bn

$bn

$bn

$bn

Liquidity pool at 31 Dec 
2021

Liquidity pool at 31 Dec 
2020

  189    211    104   

56    157    717 

218   

176    117   

74   

93   

678 

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.

HSBC Holdings plc Annual Report and Accounts 2021

197

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

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

17,602   

14,593   

4,586   

8,542   

2,090   

—   

956   

1   

1,427   

—   

—   

—   

6,795   

4,140   

1,610   

1,137   

—   

133   

778   

—   

—   

—   

9,293   

4,281   

2,633   

1,017   

—   

—   

33   

9,249   

2,837   

2,078   

975   

997   

—   

31   

1,329   

2,331   

11   

11   

—   

—   

—   

—   

5,233   

25,058   

55,388    56,639    193,055 

1,189   

947   

834   

931    22,400 

2,074   

14,932   

45,063    45,259    124,721 

1,206   

—   

—   

193   

571   

—   

—   

—   

2,996   

2,417   

—   

3,382    8,604    21,880 

1,997   

—   

—   

—   

6,548 

956 

896   

1,696   

98   

3,081 

2,870   

2,416    1,747    13,469 

417   

417   

—   

7,023    21,274    28,725 

7,023    19,427    26,878 

—    1,847   

1,847 

17,602   

14,593   

9,304   

9,249   

5,233   

25,475   

62,411    77,913    221,780 

18,057   

16,848   

20,314   

15,208   

4,048   

9,625   

2,075   

—   

1,094   

19   

1,196   

618   

618   

—   

8,440   

3,363   

1,539   

—   

—   

119   

3,387   

—   

—   

—   

9,977   

3,915   

1,451   

28   

—   

171   

4,772   

237   

237   

—   

6,186   

4,684   

1,242   

—   

—   

45   

7,561   

2,945   

2,005   

1,241   

750   

—   

41   

20,768   

49,948    59,911    208,615 

1,474   

9,295   

3,702   

2,514   

—   

410   

1,454   

1,546   

36,070 

35,834    49,209    117,930 

4,979   

6,765   

22,994 

3,917   

—   

—   

—   

1,865   

646   

7,209 

1,094 

3,316 

3,051   

579   

3,373   

1,899   

1,745   

20,002 

—   

—   

—   

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 

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 2021

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 2020

198

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Structural foreign exchange risk in 2021

Structural foreign exchange exposures represent net assets or capital investments in subsidiaries, branches, joint arrangements or 
associates, together with any associated hedges, the functional currencies of which are currencies other than the US dollar. Exchange 
differences on structural exposures are usually recognised in ‘Other comprehensive income’.

Net structural foreign exchange exposures

20211

Net 
investment in 
foreign 
operations 
(excl non-
controlling 
interest)

Structural 
foreign 
exchange 
exposures (pre-
economic 
hedges)

Net 
investment 
hedges

Economic 
hedges – 
structural FX 
hedges2

Economic 
hedges – 
equity 
securities 
(AT1)3

Net structural 
foreign 
exchange 
exposures

Currency of structural exposure

$m

$m

Hong Kong dollars

Pounds 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

Qatari rial

Argentinian peso

Others, each less than $700m

At 31 Dec

Hong Kong dollars

Pounds 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

Qatari rial

Argentinian peso

Others, each less than $700m

At 31 Dec

44,714   

47,935   

35,879   

14,671   

5,147   

5,106   

3,598   

4,115   

4,155   

2,713   

2,339   

2,300   

2,105   

1,748   

1,107   

1,219   

859   

1,051   

725   

795   

(4,992)   

(15,717)   

—   

—   

(1,093)   

—   

—   

—   

(700)   

—   

(680)   

—   

(1,019)   

—   

(809)   

(696)   

—   

—   

—   

—   

5,242   

(200)   

$m

39,722   

32,218   

35,879   

14,671   

4,054   

5,106   

3,598   

4,115   

3,455   

2,713   

1,659   

2,300   

1,086   

1,748   

298   

523   

859   

1,051   

725   

795   

5,042   

$m

(7,935)   

$m

—   

—   

(1,353)   

(1,255)   

—   

—   

—   

—   

—   

(1,985)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(332)   

—   

(36)   

—   

(4,262)   

—   

—   

—   

—   

—   

—   

(1,298)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

$m

31,787 

30,865 

34,624 

10,409 

4,054 

5,106 

3,598 

4,115 

1,470 

2,713 

361 

2,300 

1,086 

1,748 

298 

523 

859 

1,051 

393 

795 

5,006 

187,523   

(25,906)   

161,617   

(11,543)   

(6,913)   

143,161 

47,623   

46,506   

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   

667   

614   

5,577   

—   

(11,221)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

186,733   

(11,221)   

20201

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   

667   

614   

5,577   

175,512   

(5,564)   

—   

—   

(1,365)   

(1,191)   

—   

—   

—   

—   

—   

(1,985)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(382)   

—   

(75)   

—   

(4,596)   

—   

—   

—   

—   

—   

—   

(1,324)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

42,059 

33,920 

30,974 

11,076 

5,123 

4,833 

4,139 

3,892 

1,882 

2,771 

1,149 

2,357 

2,036 

1,726 

1,444 

1,368 

991 

889 

285 

614 

5,502 

(9,197)   

(7,285)   

159,030 

1 

Incremental hedging transactions were undertaken in 2021 to reduce structural foreign exchange risk. The disclosure has therefore been 
expanded and comparatives re-presented.

2  Represents hedges that do not qualify as net investment hedges for accounting purposes.
3  Represents foreign currency denominated preference share and AT1 instruments. These are accounted for at historical cost under IFRSs and do 

not qualify as net investment hedges for accounting purposes. The gain or loss arising from changes in the US dollar value of these instruments is 
recognised on redemption in retained earnings.

Shareholders’ equity would decrease by $2,981m (2020: $2,427m) if euro and sterling foreign currency exchange rates weakened by 5% 
relative to the US dollar. 

HSBC Holdings plc Annual Report and Accounts 2021

199

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Interest rate risk in the banking book in 2021

Net interest income sensitivity

The following tables set out the assessed impact to a hypothetical 
base case projection of our banking book NII 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 2022 (effects over one year and five years); 

• an immediate shock of 100bps to the current market-implied 
path of interest rates across all currencies on 1 January 2022 
(effects over one year and five years).

The sensitivities shown represent a hypothetical simulation of the 
base case NII, assuming a static balance sheet, no management 
actions from the Markets Treasury business and a simplified 50% 
pass-on assumption applied for material entities as described 
below. This incorporates the effect of interest rate 
behaviouralisation, hypothetical managed rate product pricing 
assumptions and customer behaviour, including prepayment of 
mortgages under the specific interest rate scenarios. The scenarios 
represent interest rate shocks to the current market implied path 
of rates. The sensitivity calculations exclude pensions, insurance 
and investments in subsidiaries. 

The NII sensitivity analysis performed in the case of a down-shock 
does not include floors to market rates, and it does not include 
floors on some wholesale assets and liabilities. However, floors 
have been maintained for deposits and loans to customers where 
this is contractual or where negative rates would not be applied.

As market and policy rates move, the degree to which these 
changes are passed on to customers will vary based on a number 
of factors, including the absolute level of market rates, regulatory 
and contractual frameworks, and competitive dynamics in 
particular markets. Previously we disclosed NII sensitivity using a 
range of different pass-on assumptions, varying by currency, 
product and market. To aid comparability between markets, we 
have simplified the basis of preparation for our disclosure, and 
have used a 50% pass-on assumption for major entities on certain

interest bearing deposits. Our pass-through asset assumptions are 
largely in line with our contractual agreements or established 
market practice, which typically results in a significant portion of 
interest rate changes being passed on. Using this basis has 
resulted in a modest reduction in interest rate sensitivities in 
comparison with the previous basis of preparation. Comparatives 
have not been restated.

The one-year and five-year NII sensitivities in the down-shock 
scenarios increased at 31 December 2021 at Group level when 
compared with 31 December 2020. This was driven by the 
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 hypothetical and based on 
simplified scenarios. Immediate interest rate rises of 25bps and 
100bps would increase projected NII for the 12 months to 
31 December 2022 by $1,309m and $5,414m, respectively. 
Conversely, falls of 25bps and 100bps would decrease projected 
NII for the 12 months to 31 December 2022 by $1,952m and 
$5,761m, respectively. 

The sensitivity of NII for 12 months increased by $66m in the plus 
100bps parallel shock and increased by $907m in the minus 
100bps parallel shock, comparing 31 December 2021 with 
31 December 2020. The increase in the sensitivity of NII for 12 
months in the plus 100bps parallel shock was mainly driven by 
change in market sentiment, reflecting current market 
expectations of main policy rates and changes in pass-on 
assumptions referred to above.

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 Markets and Securities Services net trading income 
that may further limit the impact.

For further details on measurement of interest rate risk in the 
banking book, see page 191.  

NII sensitivity to an instantaneous change in yield curves (12 months) – 1 year NII sensitivity by currency

Change in Jan 2022 to Dec 2022 (based on balance sheet at 31 December 2021)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Change in Jan 2021 to Dec 2021 (based on balance sheet at 31 December 2020)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Currency

$

$m

HK$

$m

£

$m

€

$m

Other

$m

Total

$m

125   

(257)   

265   

(536)   

420   

(594)   

106   

(170)   

393   

1,309 

(395)   

(1,952) 

458   

1,054   

1,739   

632   

1,532   

5,414 

(466)   

(1,020)   

(2,070)   

(595)   

(1,610)   

(5,761) 

223   

(227)   

546   

(565)   

423   

(343)   

555   

(548)   

1,267   

1,811   

126   

(88)   

502   

320   

(302)   

1,647 

(1,508) 

1,222   

5,348 

(749)   

(1,906)   

(299)   

(1,335)   

(4,854) 

NII sensitivity to an instantaneous change in yield curves (5 years) – Cumulative 5 years NII sensitivity by currency

.

Change in Jan 2022 to Dec 2026 (based on balance sheet at 31 December 2021)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Change in Jan 2021 to Dec 2025 (based on balance sheet at 31 December 2020)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Currency

$

$m

HK$

$m

£

$m

€

$m

Other

$m

Total

$m

1,026   

1,410   

3,333   

827   

2,510   

9,106 

(1,701)   

(2,887)   

(4,216)   

(997)   

(2,600)   

(12,401) 

3,922   

4,870    13,389   

3,919   

9,841    35,941 

(5,060)   

(7,052)   

(14,893)   

(3,571)   

(10,481)   

(41,057) 

1,233   

1,732   

3,718   

(1,466)   

(1,968)   

(3,826)   

761   

(605)   

2,128   

9,571 

(2,094)   

(9,959) 

3,891   

6,465   

12,571   

3,020   

8,203   

34,149 

(4,650)   

(5,285)   

(13,469)   

(1,888)   

(8,808)   

(34,098) 

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.

200

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NII sensitivity to an instantaneous change in yield curves (5 years) – NII sensitivity by years

Change in Jan 2022 to Dec 2026 (based on balance sheet at 31 December 2021)

+25bps parallel

-25bps parallel

+100bps parallel

-100bps parallel

Change in Jan 2021 to Dec 2025 (based on balance sheet at 31 December 2020)

+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

1,309   

1,758   

1,896   

2,002   

2,141   

9,106 

(1,952)   

(2,324)   

(2,593)   

(2,687)   

(2,845)   

(12,401) 

5,414   

6,738   

7,492   

7,937   

8,359    35,941 

(5,761)   

(7,664)   

(8,675)   

(9,354)   

(9,603)   

(41,057) 

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) 

Sensitivity of capital and reserves

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 high-quality liquid assets held under a hold-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. 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 the end of 2021, the stressed VaR of 
the portfolio was $3.63bn (2020: $2.94bn). The increase was 
mainly driven by the extension in the duration of our mortgage- 
backed securities exposures in US dollars as well as increases to 
the hold-to-collect-and-sell portfolios in US dollars and pounds 
sterling, partially offset by a reduction of exposure in a variety of 
other currencies.

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. Due 
to increases in interest rates during 2021, the effect of this flooring 
has reduced significantly when compared with 2020.

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. These particular exposures form only a 
part of our overall interest rate exposure. 

Comparing 31 December 2021 with 31 December 2020, the 
sensitivity of the cash flow hedging reserve increased by $866m in 
the plus 100bps scenario and increased by $1.13bn in the minus 
100bps scenario. The increase in both scenarios was mainly driven 
by an increase in fixed rate pound sterling hedges transacted in 
HSBC UK Bank plc against a change in the interest rate risk 
behaviouralisation profile for non-interest-bearing current 
accounts. The increase in the down scenario is also driven by the 
reduced effect of flooring as interest rates increased over the year.

Sensitivity of cash flow hedging reported reserves to interest rate movements

At 31 Dec 2021

+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 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

$m

(1,531) 

(0.77)%

1,537 

0.78%

(665) 

(0.34)%

409 

0.21%

Third-party assets in Markets Treasury

Third-party assets in Markets Treasury increased by 8% compared 
with 31 December 2020. The net increase of $57bn is reflective of 
higher commercial surpluses during the year, with the increase of 
$115bn in ‘Cash and balances at central banks’ and decrease of 

Third-party assets in Markets Treasury 

$52bn in ‘Financial investments’ being largely attributed to the 
reduction of investments in high-quality liquid assets driven by the 
change in outlook for interest rate expectations across many 
markets, with the resulting cash deployed with central banks.

Cash and balances at central banks

Trading assets

Loans and advances:

–  to banks

–  to customers

Reverse repurchase agreements

Financial investments

Other

At 31 Dec

2021

$m

379,106   

329   

47,363   

371   

47,067   

338,692   

5,451   

818,379   

2020

$m

263,656 

392 

34,555 

1,167 

61,693 

391,017 

8,724 

761,204 

HSBC Holdings plc Annual Report and Accounts 2021

201

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Defined benefit pension plans

Market risk arises within our defined benefit pension plans to the 
extent that the obligations of the plans are not fully matched by 
assets with determinable cash flows.

For details of our defined benefit plans, including asset allocation, see Note 5 
on the financial statements, and for pension risk management, see page 192.
.
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 2021, HSBC Holdings issued approximately $19.3bn of 
debt, replacing $5.6bn of maturing or callable debt and generating 
$13.7bn of net new debt. A total $3.1bn of this new debt was left 
unhedged and the impact can be observed in the NII sensitivity 
tables where the 12 months sensitivity increased compared with 
last year.

Foreign exchange risk

HSBC Holdings’ foreign exchange exposures derive almost entirely 
from the execution of structural foreign exchange hedges on 
behalf of the Group as its business-as-usual foreign exchange 
exposures are managed within tight risk limits. At 31 December 
2021, HSBC Holdings had forward foreign exchange contracts of 

NII sensitivity to an instantaneous change in yield curves (12 months)

$25.9bn (2020: $11.2bn) to manage the Group’s structural foreign 
exchange exposures. 

For further details of our structural foreign exchange exposures, see page 
199.

Sensitivity of net interest income 

HSBC Holdings monitors NII sensitivity over 12-month and five-
year time horizons, 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 tables below set out the effect on 
HSBC Holdings’ future NII based on 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 2022; and

• an immediate shock of 100bps to the current market-implied 
path of interest rates across all currencies on 1 January 2022. 

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 
2022 by $29m and $113m, respectively. Conversely, falls of 25bps 
and 100bps would decrease projected NII for the 12 months to 
31 December 2022 by $28m and $109m, respectively. 

Change in Jan 2022 to Dec 2022 (based on balance sheet at 31 December 2021)

+25bps

-25bps

+100bps

-100bps

Change in Jan 2021 to Dec 2021 (based on balance sheet at 31 December 2020)

+25bps

-25bps

+100bps

-100bps

NII sensitivity to an instantaneous change in yield curves (5 years)

Change in Jan 2022 to Dec 2022 (based on balance sheet at 31 December 2021)

+25bps

-25bps

+100bps

-100bps

Change in Jan 2021 to Dec 2021 (based on balance sheet at 31 December 2020)

+25bps

-25bps

+100bps

-100bps

$

$m

HK$

$m

16   

(16)   

65   

(64)   

13   

(13)   

50   

(51)   

—   

—   

—   

—   

—   

—   

—   

—   

£

$m

8   

(8)   

31   

(31)   

8   

(8)   

33   

(32)   

€

$m

Other

$m

Total

$m

4   

(4)   

16   

(14)   

2   

(3)   

7   

(13)   

—   

—   

—   

—   

—   

—   

—   

—   

Year 1

Year 2

Year 3

Year 4

Year 5

$m

$m

$m

$m

$m

29   

(28)   

113   

(109)   

23   

(23)   

91   

(95)   

44   

(44)   

177   

(174)   

40   

(42)   

159   

(169)   

45   

(45)   

180   

(174)   

43   

(46)   

171   

(189)   

38   

(38)   

152   

(148)   

39   

(41)   

156   

(169)   

28   

(28)   

112   

(109)   

— 

31   

(32)   

126   

139   

29 

(28) 

113 

(109) 

23 

(23) 

91 

(95) 

Total

$m

184 

(183) 

733 

(715) 

176 

(184) 

702 

(761) 

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.

202

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021

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 20201
Cumulative interest rate gap 

Total

$m

2,590   

2,811 

76,516   

26,194   

163,211   

1,850 

Up to
1 year

$m

2,590 

22,545   

22,917   

5,425   

From over 
1 to 5 years

From over 
5 to 10 years

More than
10 years

Non-interest
 bearing

$m

$m

$m

$m

29,759   

20,347   

2,000   

3,268 

8,395   

600 

2,811 

1,865 

9 

148,791 

1,850 

273,172   

53,477   

41,422   

20,947   

2,000   

155,326 

(111) 

(32,418)   

(5,925)   

(10,801)   

(14,942)   

(750) 

(1,220) 

(67,483)   

(11,244)   

(34,917)   

(19,322)   

(2,000) 

(111) 

(1,220) 

(4,551) 

(1,131)   

(2,446)   

(20,746)   

(18,797)   

13,952   

13,952   

(3,705)   

(11,096)   

(60,519)   

(10,871)   

(8,226)   

5,726   

(1,780)   

(10,443) 

(8,721) 

(128,067) 

(44,765)   

(13,193)   

(133,949) 

1,434   

(22,384)   

(16,658)   

6,184   

(5,009)   

(21,667) 

308 

21,667 

2,913   

—   

25,610   

15,112   

5,381   

257   

49,273   

(330)   

(1,827)   

—   

—   

—   

—   

—   

—   

—   

22,190   

20,398   

2,000   

2,771   

7,660   

—   

—   

1,500   

—   

—   

—   

—   

— 

4,698 

5,498 

(398) 

141,944 

1,464 

32,621   

21,898   

2,000   

153,206 

—   

—   

(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)   

(9,198) 

—   

(10,463)   

(46,576)   

(13,213)   

2,492   

(22,186)   

(13,444)   

6,200   

(5,013)   

(18,457)   

— 

(3,019) 

(3,060) 

(1,008) 

(5,375) 

(1,834) 

(120,523) 

(134,819) 

70 

18,457 

— 

(4,551) 

(17,059)   

(150,330)   

(273,172)   

2,913   

4,698   

75,696   

17,485   

156,485   

1,721   

258,998   

(330)   

(25,664)   

(3,060)   

(64,029)   

(5,375)   

(17,916)   

(142,624)   

(258,998)   

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

Overview

Market risk management

Market risk in 2021

Trading portfolios 

Non-trading portfolios 

Market risk balance sheet linkages

Overview

Page

203

203

204

205

206

207

Market risk is the risk of adverse financial impact on trading 
activities arising from changes in market parameters such as 
interest rates, foreign exchange rates, asset prices, volatilities, 
correlations and credit spreads. Exposure to market risk is 
separated into two portfolios: trading portfolios and non-trading 
portfolios

Market risk management

Key developments in 2021

There were no material changes to our policies and practices for 
the management of market risk in 2021.

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.

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, Global Treasury, 
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 202.

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 and Compliance Officer for HSBC Holdings. 
These limits are allocated across business lines and to the Group’s 
legal entities. Each major operating entity has an independent 
market risk management and control sub-function, which is 

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203

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

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.

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HSBC Holdings plc Annual Report and Accounts 2021

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 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 necessarily indicative of the actual performance of the 
business. 

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 2021

Financial markets performed well in 2021. During the first half of 
the year, the roll-out of Covid-19 vaccination programmes, as well 
as continued monetary and fiscal support, contributed to a gradual 
recovery of major economies. Concerns of rising inflationary 
pressures were mainly interpreted as transitory. While the path of 
monetary policies remained uncertain, central banks continued to 
provide liquidity. This supported risk asset valuations, while 

volatility in most asset classes was subdued. In the second half of 
2021, amid the emergence of new Covid-19 variants, global 
equities reached further record highs, as investors focused on 
global economic resilience and strong corporate earnings. Bond 
yields followed a downward trend for most of the third quarter of 
2021, before reversing in the final weeks of the year, when 
markets began pricing in expectations of a faster pace of interest 
rate rises in some of the major economies, due to persistently 
elevated inflation. Credit markets remained strong, with credit 
benchmark indices for investment-grade and high-yield debt close 
to pre-pandemic levels.

We continued to manage market risk prudently during 2021. 
Sensitivity exposures and VaR remained within appetite as the 
business pursued its core market-making activity in support of our 
customers. Market risk was managed using a complementary set 
of risk measures and limits, including stress and scenario analysis.

Value at risk of the trading portfolios

Trading VaR was predominantly generated by the Markets and 
Securities Services business. 

Trading VaR at 31 December 2021 did not change materially 
compared with 31 December 2020 and it remained within a 
relatively narrow range for most of 2021. On a consolidated 
portfolio basis, larger contributions from credit spread risks and 
foreign exchange risks were offset by: 

• gains from exposures to equity risks and interest rate risks; and

• reduced equity risks captured in the RNIV framework.

On a stand-alone basis, credit spread risks and interest rate risks 
from fixed income market-making activities were the main drivers 
of VaR at the end of 2021, with larger contributions compared 
with the end of 2020.

Trading portfolios

The daily levels of total trading VaR during 2021 are set out in the graph below.

Daily VaR (trading portfolios), 99% 1 day ($m) 

The Group trading VaR for the year is shown in the table below.

Trading VaR, 99% 1 day1
(Audited)

Balance at 31 Dec 2021

Average

Maximum

Minimum

Balance at 31 Dec 2020

Average

Maximum

Minimum

Foreign
exchange and 
commodity

Interest
rate

$m

9.1   

12.9   

31.8   

6.7   

13.7   

11.0   

25.7   

5.6   

$m

25.9   

33.8   

51.7   

18.5   

20.3   

26.6   

43.5   

19.1   

Equity

$m

15.4   

16.7   

24.3   

12.1   

21.5   

27.3   

42.0   

13.6   

Portfolio 
diversification2

$m

(36.5)   

(45.5)   

(36.4)   

(38.3)   

Credit
spread

$m

24.8   

19.2   

29.4 

12.2 

24.3   

21.6   

44.1 

12.6 

Total3

$m

38.8 

37.1 

53.8 

27.7 

43.4 

48.1 

69.3 

33.6 

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.

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205

Trading totalInterest rate (‘IR’) tradingEquity (‘EQ’) tradingCredit spread (‘CS’) trading intentForeign exchange (‘FX’) tradingDiversificationDec-20Jan-21Feb-21Mar-21Apr-21May-21Jun-21Jul-21Aug-21Sep-21Oct-21Nov-21Dec-21-80-60-40-200204060Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

The table below shows trading VaR at a 99% confidence level 
compared with trading VaR at a 95% confidence level at 
31 December 2021. This comparison facilitates the benchmarking

Comparison of trading VaR, 99% 1 day vs trading VaR, 95% 1 day

of the trading VaR, which can be stated at different confidence 
levels, with financial institution peers. The 95% VaR is unaudited. 

Balance at 31 Dec 2021

Average

Maximum

Minimum

Balance at 31 Dec 2020

Average

Maximum

Minimum

Back-testing

During 2021, the Group experienced two loss back-testing 
exceptions against hypothetical profit and loss and two loss back-
testing exceptions against actual profit and loss.

These exceptions comprised:

• a loss back-testing exception against hypothetical profit and 

loss in March, mainly driven by the effect of lower volatility in 
the equity markets and by the increase in some emerging 
markets foreign exchange forward rates volatilities;

• a loss exception against actual profit and loss in September, 
attributable to the payment of novation fees under our RWA 
optimisation programme; and

• a loss back-testing exception against both hypothetical and 
actual profit and loss in late November, due to a number of 
relatively small losses spread across credit spread, equity and 
interest rates asset classes.

Non-trading portfolios

Non-trading portfolios comprise positions that primarily arise from 
the interest rate management of our retail and commercial 
banking assets and liabilities, financial investments measured at 

Daily VaR (non-trading portfolios), 99% 1 day ($m)

Trading VaR, 
99% 1 day

Trading VaR, 
95% 1 day

$m

38.8   

37.1   

53.8   

27.7   

43.4   

48.1   

69.3   

33.6   

$m

21.6 

24.0 

30.0 

18.9 

27.6 

32.7 

47.3 

22.4 

fair value through other comprehensive income, debt instruments 
measured at amortised cost, and exposures arising from our 
insurance operations.

Value at risk of the non-trading portfolios

The VaR for non-trading activity at 31 December 2021 was lower 
than at 31 December 2020. The decrease arose mainly from an 
increase in the diversification benefit across interest rate and 
credit exposures. On a stand-alone basis, interest rate VaR 
increased, mainly due to higher levels of market volatility observed 
in February 2021, while credit VaR reduced over the year driven by 
a reduction in credit spread exposure in the portfolio of non-
trading financial instruments managed by Markets Treasury.

Non-trading VaR includes the interest rate risk in the banking book 
transferred to and managed by Markets Treasury and the 
exposures generated by the portfolio of high-quality liquid assets 
held by Markets Treasury to meet liquidity requirements. 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 in 2021 are set out in the 
graph below.

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HSBC Holdings plc Annual Report and Accounts 2021

Non-trading totalIR non-tradingCS non-trading intentDiversificationDec-20Jan-21Feb-21Mar-21Apr-21May-21Jun-21Jul-21Aug-21Sep-21Oct-21Nov-21Dec-21-140-120-100-80-60-40-20020406080100120140160180200220240260280300320 
 
 
 
 
 
 
 
The Group non-trading VaR for 2021 is shown in the table below.

Non-trading VaR, 99% 1 day

(Audited)

Balance at 31 Dec 2021

Average

Maximum

Minimum

Balance at 31 Dec 2020

Average

Maximum

Minimum

Interest
rate

$m

216.4   

200.7   

248.7   

163.3   

166.6   

150.2   

196.4   

59.0   

Credit
spread

$m

70.3   

76.9   

99.3   

64.7   

87.0   

82.5   

133.4   

44.2   

Portfolio
diversification1

$m

(66.3)   

(40.3)   

—   

—   

(5.7)   

(42.0)   

—   

—   

Total2

$m

220.4 

237.3 

298.8 

193.5 

247.8 

190.7 

274.6 

79.7 

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 and credit spreads – 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.

Non-trading VaR excludes equity risk on securities held at fair 
value, non-trading book 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.

• We developed a more robust understanding of our risk and 

control environment, by updating our material risk taxonomy 
and control libraries, and refreshing material risk and control 
assessments.

• We further strengthened our non-financial risk governance and 

Market risk balance sheet linkages

senior leadership.

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.

• We created a consolidated view of all risk issues across the 
Group, enabling better senior management focus on non-
financial risk, and the ability to identify material control issues 
and intervention as required.

• We improved how we provide analysis and reporting of non-

financial risks, with more risk practitioners now having access 
to a wider range of management information on their risks and 
controls.

• We increased the capability of risk stewards to allow for 
effective stewardship to be in place across the Group.

• We strengthened our approach in the comparison of issues 
and near misses by implementing a Group-wide harmonised 
approach across businesses, functions and regions.

• We enhanced risk management oversight across our most 

material change initiatives to support growth in our strategic 
transformation.

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.

For information on the accounting policies applied to financial instruments at 
fair value, see Note 1 on the financial statements

Governance and structure

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 2021

The Operational and Resilience Risk sub-function provides robust 
non-financial risk steward oversight of the management of risk by 
the Group businesses, functions and legal entities. It also provides 
effective and timely independent challenge. During the year, we 
carried out a number of initiatives to strengthen the management 
of non-financial risks:

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 and Compliance 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 

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207

Risk review 
 
 
 
 
 
 
 
Risk

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

Business continuity, in response to the Covid-19 pandemic, 
remains in place across a number of locations where the Group 
operates, allowing the majority of service level agreements to be 
maintained. There were no significant impacts to service delivery 
in locations where the Group operates.

Regulatory compliance risk

Overview

Regulatory compliance risk is the risk associated with breaching 
our duty to clients and other counterparties, inappropriate market 
conduct and breaching related financial services regulatory 
standards. Regulatory compliance risk arises from the failure to 
observe relevant laws, codes, rules and regulations and can 
manifest itself in poor market or customer outcomes and lead to 
fines, penalties and reputational damage to our business.  
Regulatory compliance risk management

Key developments in 2021

We continued to embed the structural changes made in 2020 to 
our wider approach to compliance risk management. The 
integration of the Risk and Compliance functions in May 2021 has 
brought together two complementary functions, which will 
strengthen the regulatory compliance function’s mandate and our 
capability to drive the right standards with regard to the conduct 
of our business.

In June 2021, we also announced our new purpose-led approach 
to conduct. As part of this, we took the opportunity to align and 
simplify our approach, making conduct easier to understand and 
showing how it relates to and helps fulfil our value: ‘we take 
responsibility’.

Governance and structure

Following the integration of the Global Risk and Compliance 
functions, the Group Head of Compliance and the Group Head of 
Financial Crime – who is also the Group Money Laundering 
Reporting Officer – each report to the Group Chief Risk and 
Compliance Officer. They also each attend the Risk and 
Compliance Executive Committee, the Group RMM and the GRC. 
The structure of the Compliance function below this level is 
substantively unchanged and the Group Regulatory Conduct 
capability and Group Financial Crime capability both continue to 
work closely with the regional chief compliance officers and their 
respective teams to help them identify and manage regulatory and 
financial crime compliance risks across the Group. They also work 
together to ensure we achieve good conduct outcomes and 
provide enterprise-wide support on the Compliance risk agenda in 
collaboration with the Group’s Risk function.

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 risk. It also devises the 
required frameworks and support processes to protect against 
regulatory compliance risks. The Group 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 breaches, and 
relevant reportable events are escalated to the Group RMM and 
the GRC, as appropriate.

Conduct of business

Our new, simplified conduct approach, which was launched in 
2021, guides us to do the right thing and to recognise the real 

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HSBC Holdings plc Annual Report and Accounts 2021

impact we have for our customers and the financial markets in 
which we operate. It complements our purpose and values, setting 
outcomes to be achieved for our customers and markets. It 
recognises cultural and behavioural drivers of good conduct 
outcomes and applies across all risk disciplines, operational 
processes and technologies. During 2021:

• We understood and served our customers’ ongoing needs, and 
continued to champion a strong conduct and customer-focused 
culture. This was demonstrated through the continued 
provision of support to our customers facing financial 
difficulties as a result of the prolonged impacts of the pandemic 
and the resulting uncertainty in trading conditions.

• We began the integration of climate risk into the Group’s risk 

management approach to recognise the importance of 
strengthened controls and oversight for our related activities.

• We operated resiliently and securely to avoid harm to our 

customers and markets by continuing to embed conduct within 
our business line processes and through our non-financial and 
financial risk steward activities.

• We continued our focus on culture and behaviours as a driver 

of good conduct outcomes.

• We placed a particular focus on the importance of well-being 

and collaborative working as we continued to adapt to 
changing working practices as the pace of change resulting 
from the pandemic varied across our markets. 

• We continued to emphasise – and worked to create – an 

environment in which employees are encouraged and feel safe 
to speak up.

• We delivered our latest annual global mandatory training 

course on conduct to reinforce the importance of conduct for 
all colleagues.

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 2021

We continuously review the effectiveness of our financial crime 
risk management framework, which includes consideration of the 
complex and dynamic nature of sanctions risk, notably with 
respect to the array of new regulations and designations in 2021 
and in alignment with our policy, which is to comply with all 
applicable sanctions regulations in the jurisdictions in which we 
operate.

We also continued to make progress with several key financial 
crime risk management initiatives, including:

• We deployed a key component of our intelligence-led, dynamic 
risk assessment capabilities for customer account monitoring in 
the UK, and undertook important enhancements to our 
traditional transaction monitoring systems globally.

• We strengthened our anti-fraud capabilities, notably with 

respect to the early identification of first-party lending fraud 
and the development of new strategic detection tools.

• We continued the development of leading-edge surveillance 

technology and capabilities to identify potential market abuse, 
including testing machine learning capabilities to detect 
unauthorised trading. 

 
• We invested in the use of AI and advanced analytics techniques 

to manage financial crime risk, notably new automated 
capabilities in name and transaction screening (for further 
details, see page 120).

• We implemented a gifts and entertainment recording and 
approval system, which, in combination with an expenses 
reconciliation tool, allows us to better manage our gifts and 
entertainment risk. 

Governance and structure

We have continued to review the effectiveness of our governance 
framework to manage financial crime risk. The framework aims to 
enable us to comply with the letter and the spirit of applicable 
financial crime laws and regulations in the jurisdictions in which 
we operate, as well as our own policies, standards, and values 
relating to financial crime risks. 

In 2021, the Group Risk and Compliance functions were 
integrated, allowing us to make better use of a broader range of 
perspectives from other risk disciplines.

Key risk management processes

We will not tolerate knowingly conducting business with 
individuals or entities believed to be engaged in illicit activity. We 
require everybody in HSBC to play their role in maintaining 
effective systems and controls to prevent and detect financial 
crime. Where we believe we have identified suspected illicit 
activity or vulnerabilities in our control framework, we will take 
appropriate mitigating action.

We continue to assess the effectiveness of our end-to-end 
financial crime risk management framework on an ongoing basis, 
and invest in enhancing our operational control capabilities and 
technology solutions to deter and detect criminal activity. We have 
simplified our framework by streamlining and de-duplicating policy 
requirements. We also strengthened our financial crime risk 
taxonomy and control libraries and our investigative and 
monitoring capabilities through technology deployments. We 
developed more targeted metrics, and have also enhanced our 
governance and reporting.  

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 the 
communities we serve. We participate in numerous public-private 
partnerships and information-sharing initiatives around the world. 
In 2021, the UK, the EU, the US and Singapore, were particularly 
focused on anti-money laundering (‘AML’) reforms, to which we 
provided significant input. We played a key role in the industry 
responses to a number of consultation papers focused on the 
overall effectiveness of the global AML framework. We were also 
active participants in a key pilot undertaken by the Monetary 
Authority of Singapore, which establishes a framework to enable 
financial institutions to share information with each other when 
certain financial crime risk concerns have been identified. We took 
part in a number of roundtables organised by the Financial Action 
Task Force, supporting its strategic review. We also supported its 
work on digitisation and beneficial ownership registers. These 
align with our objectives of promoting a public policy and 
regulatory environment that embraces the use and harnessing of 
technology in building a financial crime framework for the future 
to ensure our organisation is more resilient and secure, while 
benefiting our customers.

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 
AML and sanctions-related obligations. Over the past several 
years, HSBC has retained a Skilled Person under section 166 of the 
Financial Services and Markets Act and an Independent 
Consultant under the FRB cease-and-desist order to produce 

periodic assessments of the Group’s AML and sanctions 
compliance programme.

The Skilled Person issued its final report in June 2021, which 
contained a number of limited recommendations. Following 
publication of the report, the FCA determined that no further 
Skilled Person work is required. The Group Risk Committee will 
continue to retain oversight of matters relating to AML, sanctions, 
terrorist financing and proliferation financing. Separately, the 
Independent Consultant carried out its eighth annual review for 
the FRB and, in November 2021, issued its report, which 
contained a limited number of recommendations. 

Model risk

Overview

Model risk is the risk of 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 arises in both financial and non-financial contexts 
whenever business decision making includes reliance on models. 

Key developments in 2021

In 2021, we continued to make improvements in our model risk 
management processes amid regulatory changes in model 
requirements.

Initiatives during the year included: 

• In response to regulatory capital charges, we redeveloped, 

validated and submitted to the PRA our models for the internal 
ratings-based (‘IRB’) approach for credit risk, internal model 
method (‘IMM’) for counterparty credit risk and internal model 
approach (‘IMA’) for market risk. These new models have been 
built to enhanced standards using improved data as a result of 
investment in processes and systems. 

• We redeveloped and validated models impacted by changes to 
alternative rate setting mechanisms due to the Ibor transition.

• We made further enhancements to our control framework for 

our Sarbanes-Oxley models to address the control weaknesses 
that emerged as a result of significant increases in adjustments 
and overlays that were applied to compensate for the impact of 
the Covid-19 pandemic on models. We also introduced a 
requirement for the model risk stewards to approve material 
models prior to use.

• Our businesses and functions were more involved in the 
development and management of models, and hiring 
colleagues who had strong model risk skills. They also put an 
enhanced focus on key model risk drivers such as data quality 
and model methodology.

• Our model owners in businesses and functions fully embedded 

the requirements included in the model risk policy and 
standards introduced in 2020. 

• We delivered a suite of training on model risk to front-line 
teams to improve their awareness of model risk and their 
adherence to the governance framework.

• We rolled out new model risk appetite measures, which are 
more forward looking and will help our businesses and 
functions manage model risk more effectively.

• We continued the transformation of the Model Risk 

Management team, with changes to the model validation 
processes, including new systems and processes. Key senior 
hires were made during the year to lead the business areas and 
regions to strengthen oversight and expertise within the 
function. We also made changes to the model inventory system 
to provide businesses and functions with improved 
functionality and more detailed information related to model 
risk.

• We initiated a programme of development related to climate 

risk and models using advanced analytics and machine 
learning, which have become critical areas of focus that will 

HSBC Holdings plc Annual Report and Accounts 2021

209

Risk reviewRisk

grow in importance in 2022 and beyond. We also added 
qualified specialist skills to the model risk teams to manage the 
increased model risk in these areas.

Governance and structure

The new governance structure implemented in 2020 is fully 
operational. Model Risk Governance committees at the Group, 
business and functional levels provide oversight of model risk. The 
committees include senior leaders from the three global 
businesses and the Global Risk and Compliance function, and 
focus on model-related concerns and are supported by key model 
risk metrics. The Group-level Model Risk Committee is chaired by 
the Group Chief Risk and Compliance Officer and the heads of key 
businesses participate in those meetings.

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 and Compliance 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. 

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

Insurance manufacturing operations risk in 2021

Measurement

Key risk types

–  Market risk

–  Credit risk

–  Liquidity risk 

–  Insurance underwriting risk

Overview

Page

210

210

212

212

214

214

215

215

216

The key risks for our insurance manufacturing operations are 
market risks, in particular interest rate and equity, credit risks and 
insurance underwriting and operational risks. These have a direct 
impact on the financial results and capital positions of the 
insurance operations. Liquidity risk, while significant in other parts 
of the Group, is relatively minor for our insurance operations.

HSBC’s insurance business

We sell insurance products worldwide through a range of 
channels including our branches, direct channels and third-party 
distributors. The majority of sales are through 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 customers, which we can identify from our point-of-sale 
contacts and customer knowledge. For the products we 
manufacture, the majority of sales are savings, universal life and 
protection 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 

210

HSBC Holdings plc Annual Report and Accounts 2021

part of the underwriting profit and investment income within the 
Group.

We have life insurance manufacturing subsidiaries in eight 
markets, which are Hong Kong, Singapore, mainland China, 
France, the UK, 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.

This section focuses only on the risks relating to the insurance 
products we manufacture.

Insurance manufacturing operations risk 
management

Key developments in 2021

The insurance manufacturing subsidiaries follow the Group’s risk 
management framework. In addition, there are specific policies 
and practices relating to the risk management of insurance 
contracts. There were no material changes to the policies and 
practices over 2021, although enhancements were made to the 
product pricing and profitability framework to allow for the 
transition to IFRS 17.

Governance and structure

(Audited)

Insurance manufacturing 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 122. 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. The Group’s risk stewardship 
functions support the 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.

The results of these stress tests and the adequacy of management 
action plans to mitigate these risks are considered in the Group’s 
ICAAP and the entities’ regulatory Own Risk and Solvency 
Assessments (‘ORSAs’).

Key risk management processes

Market risk

(Audited) 

All our insurance manufacturing subsidiaries have market risk 
mandates and limits 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. 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.

• 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.

Credit risk

(Audited)

Our insurance manufacturing subsidiaries also have credit risk 
mandates and limits within which they are permitted to operate, 
which consider the credit risk exposure, 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.

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.

Capital and liquidity risk

(Audited)

Capital risk for our insurance manufacturing subsidiaries is 
assessed in the Group’s ICAAP based on their financial capacity to 
support the risks to which they are exposed. Capital adequacy is 

assessed on both the Group’s economic capital basis, and the 
relevant local insurance regulatory basis. The Group’s economic 
capital basis is largely aligned to European Solvency II regulations, 
other than in Hong Kong where this is based on the emerging 
Hong Kong risk based capital regulations.

Risk appetite buffers are set to ensure that the operations are able 
to remain solvent on both bases, allowing for business-as-usual 
volatility and extreme but plausible stress events.

Liquidity 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.

Insurance underwriting risk 

Our insurance manufacturing subsidiaries primarily use the 
following frameworks and processes to manage and mitigate 
insurance underwriting risks:

• a formal approval process for launching new products or 

making changes to products;

• a product pricing and profitability framework, which requires 
initial and ongoing assessment of the adequacy of premiums 
charged on new insurance contracts to meet the risks 
associated with them;

• a framework for customer underwriting;

• reinsurance, which cedes risks above our appetite thresholds to 

a third-party reinsurer thereby limiting our exposure; and

• oversight of expense and reserve risks by entity Actuarial 

Control Committees.

HSBC Holdings plc Annual Report and Accounts 2021

211

Risk reviewRisk

Insurance manufacturing operations risk in 2021

Measurement

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

–  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 assets3
Reinsurance assets
PVIF4
Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts
Deferred tax5
Other liabilities

Total liabilities
Total equity
Total liabilities and equity at 31 Dec 2021

With
DPF

$m

Unit-linked

Other 
contracts2

Shareholder
assets and 
liabilities

$m

$m

$m

Total

$m

88,969   

8,881   

19,856   

9,951   

127,657 

30,669   

8,605   

3,581   

1,827   

44,682 

129   

42,001   

10,858   

5,312   

2,180   

—   

2,558   

93,707   

—   

89,492   

179   

—   

89,671   
—   
89,671   

1   

61   

—   

214   

72   

—   

1   

8,954   

2,297   

6,558   

9   

—   

8,864   
—   
8,864   

15   

14,622   

459   

1,179   

1,666   

—   

206   

2   

4,909   

1,951   

1,262   

3   

9,453   

820   

147 

61,593 

13,268 

7,967 

3,921 

9,453 

3,585 

21,728   

20,227   

144,616 

3,641   

16,757   

24   

—   

20,422   
—   
20,422   

—   

—   

5,938 

112,807 

1,418   

7,269   

8,687   
16,972   
25,659   

1,630 

7,269 

127,644 
16,972 
144,616 

Financial assets

84,478   

8,802   

18,932   

8,915   

121,127 

–  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 assets3
Reinsurance assets
PVIF4
Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts
Deferred tax5
Other liabilities

Total liabilities

Total equity

Total liabilities and equity at 31 Dec 2020

26,002   

262   

39,891   

12,531   

5,792   

2,256   

—   

2,628   

89,362   

—   

84,931   

145   

—   

8,558   

3   

30   

—   

211   

65   

—   

1   

8,868   

2,285   

6,503   

5   

—   

3,508   

13   

13,984   

459   

968   

1,447   

—   

227   

20,606   

4,100   

15,827   

25   

—   

85,076   

8,793   

19,952   

—   

—   

—   

85,076   

8,793   

19,952   

1,485   

3   

4,521   

1,931   

975   

2   

9,435   

721   

39,553 

281 

58,426 

14,921 

7,946 

3,770 

9,435 

3,577 

19,073   

137,909 

—   

—   

1,400   

7,244   

8,644   

15,444   

24,088   

6,385 

107,261 

1,575 

7,244 

122,465 

15,444 

137,909 

1 Balance sheet of insurance manufacturing operations is 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.

212

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Balance sheet of insurance manufacturing subsidiaries by geographical region1,2
(Audited)

Financial 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 assets3
Reinsurance assets
PVIF4
Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts
Deferred tax5
Other liabilities

Total liabilities

Total equity

Total liabilities and equity at 31 Dec 2021

Financial 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 assets3
Reinsurance assets
PVIF4
Other assets and investment properties

Total assets

Liabilities under investment contracts designated at fair value

Liabilities under insurance contracts
Deferred tax5
Other liabilities

Total liabilities

Total equity

Total liabilities and equity at 31 Dec 2020

Europe

$m

34,264   
19,030   

Asia

$m

92,535   
25,248   

65   

82   

1,161   

60,389   

12,073   

1,935   

213   

1,098   

1,091   

817   

5,999   

3,703   

8,177   

2,431   

Latin 
America

$m

858   
404   

—   

43   

378   

33   

5   

178   

63   

Total

$m

127,657 
44,682 

147 

61,593 

13,268 

7,967 

3,921 

9,453 

3,585 

36,666   

106,846   

1,104   

144,616 

1,396   

4,542   

—   

5,938 

30,131   

81,840   

836   

112,807 

250   

2,711   

34,488   

2,178   

1,357   

4,523   

92,262   

14,584   

23   

35   

894   

210   

1,630 

7,269 

127,644 

16,972 

36,666   

106,846   

1,104   

144,616 

34,768   
17,184   

107   

531   

13,894   

3,052   

245   

884   

1,189   

37,086   

1,288   

31,153   

204   

2,426   

35,071   

2,015   

37,086   

85,259   
22,099   

174   

57,420   

706   

4,860   

3,521   

8,390   

2,332   

99,502   

5,097   

74,994   

1,348   

4,800   

86,239   

13,263   

99,502   

1,100   
270   

—   

475   

321   

34   

4   

161   

56   

121,127 
39,553 

281 

58,426 

14,921 

7,946 

3,770 

9,435 

3,577 

1,321   

137,909 

—   

6,385 

1,114   

107,261 

23   

18   

1,155   

166   

1,321   

1,575 

7,244 

122,465 

15,444 

137,909 

1 HSBC has no insurance manufacturing subsidiaries in the Middle East and North Africa or North America.
2 Balance sheet of insurance manufacturing operations is 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.

HSBC Holdings plc Annual Report and Accounts 2021

213

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk

Key risk types

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’). 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 invested in 
fixed interest, 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.

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 decreased to $938m (2020: $1,105m) 
primarily due to the increase in swap rates and positive equity 
performance in France and Hong Kong.

For unit-linked contracts, market risk is substantially borne by the 
policyholder, but some market risk exposure typically remains, as 
fees earned are related to the market value of the linked assets.

Financial return guarantees

(Audited)

Capital

Nominal annual return

Nominal annual return

Nominal annual return

At 31 Dec

Sensitivities

2021

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

220 

423 

183 

112 

938 

%

 0.0 

0.1–1.9

2.0–3.9

4.0–5.0

2020

Long-term 
investment 
returns on 
relevant 
portfolios

%

0.7–3.2  

2.3–3.6  

2.0–4.5  

2.0–4.2  

Cost of 
guarantees

$m

277 

515 

180 

133 

1,105 

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 $516m (2020: $102m). 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

2021

2020

Effect on
profit after tax

Effect on
total equity

Effect on 
profit after tax

Effect on
total equity

$m

(2)   

(154)   

369   

(377)   

80   

(80)   

$m

(142)   

(9)   

369   

(377)   

80   

(80)   

$m

(67)   

(68)   

332   

(338)   

84   

(84)   

$m

(188) 

58 

332 

(338) 

84 

(84) 

214

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
Credit risk

(Audited)

Liquidity risk

(Audited)

Description and exposure

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 2021. 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 2021 remained comparable with 2020.
The remaining contractual maturity of investment contract 
liabilities is included in Note 29 on page 373.

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 212.

The credit quality of the reinsurers’ share of liabilities under 
insurance contracts is assessed as ‘satisfactory’ or higher (as 
defined on page 138), with 100% of the exposure being neither 
past due nor impaired (2020: 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 155. 
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.

Expected maturity of insurance contract liabilities

(Audited)

Unit-linked 

With DPF and Other contracts

At 31 Dec 2021

Unit-linked 

With DPF and Other contracts

At 31 Dec 2020

Within 1 year

1–5 years

5–15 years

Over 15 years

Expected cash flows (undiscounted)

$m

1,346   

8,803   

10,149   

1,407   

8,427   

9,834   

$m

2,605   

31,334   

33,939   

3,097   

30,156   

33,253   

$m

3,159   

51,891   

55,050   

2,976   

51,383   

54,359   

$m

2,293   

94,168   

96,461   

2,099   

75,839   

77,938   

Total

$m

9,403 

186,196 

195,599 

9,579 

165,805 

175,384 

HSBC Holdings plc Annual Report and Accounts 2021

215

Risk review 
 
 
 
 
 
 
Risk

Insurance underwriting risk

Description and exposure

Insurance underwriting 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, lapse and expense rates.

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 212 and 213 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 2020.

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. 

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.

Expense rate risk is the exposure to a change in the allocated 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. This risk is 
generally greatest for our smaller entities.

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)

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

2021

$m

(112)   

115   

(115)   

129   

(108)   

107   

2020

$m

(93) 

98 

(111) 

128 

(117) 

115 

216

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
Corporate 
governance 
report

The corporate governance report gives 
details of our Board of Directors, senior 
management, and Board committees. 
It outlines key aspects of our approach 
to corporate governance, including 
internal control.

It also includes the Directors’ 
remuneration report, which explains 
our policies on remuneration. 

218   Group Chairman's governance statement

220   The Board

224   Senior management

227   How we are governed

232   Board activities during 2021

234 

 Board and committee effectiveness, performance 
and accountability

237   Board committees

254   Directors' remuneration report

287   Share capital and other related disclosures

291  

Internal control

293   Employees

295   Statement of compliance

296   Directors' responsibility statement

We have a comprehensive range of policies and systems in 
place designed to help ensure that the Group is well managed, 
with effective oversight and control.

HSBC Holdings plc Annual Report and Accounts 2021

217217

Report of the Directors | Corporate governance report

Group Chairman's governance statement 
The Board and its committees continued to operate 
well in a challenging environment, and focused on 
enhancing governance practices.

There were a number of changes to the Board 
during 2021, with Laura Cha, Heidi Miller and 
Henri de Castries retiring following our 2021 
Annual General Meeting ('AGM') in May, and 
Rachel Duan and Dame Carolyn Fairbairn 
appointed with effect from 1 September. 

We also recently announced that, in line with 
our succession planning and having each 
served on the Board for six years, Irene Lee 
and Pauline van der Meer Mohr would step 
down from the Board at the conclusion of our 
2022 AGM in April. Irene’s existing roles on 
our subsidiary boards in Asia are not impacted 
by her retirement from the Holdings Board. On 
behalf of the Board, I wish to thank Irene and 
Pauline for their outstanding dedication and 
the enormous contributions they have made 
to the success of HSBC during their time on 
the Board. We wish them both well in their 
future endeavours.

Purpose, strategy and values
Following the launch of the Group’s refreshed 
purpose, strategy and values in March, we 
introduced a 'culture moment' at the beginning 
of each Board meeting. These discussions 
have allowed Board members to share their 
insights on the culture of the Group, and have 
raised awareness of employee and stakeholder 
perspectives in the Boardroom. This has 
supported the Board in helping to create 
greater alignment between culture and 
strategy, and in driving a tone from the top 
focused on the Group’s purpose of opening 
up a world of opportunity. 

Technology governance
Digitise at scale is one of our four strategic 
pillars and reflects the increasingly important 
role that technology plays in delivering for  
our customers. It is therefore critical that  
our governance helps enable the Board to 
effectively shape and oversee progress against 
our technology strategy. As such, we took  
the decision to establish the Technology 
Governance Working Group at the beginning 
of 2021 to determine the most effective 
approach for the Board to discharge its 
responsibilities in relation to technology 
strategy and oversight. 

The Co-Chairs of the Technology Governance 
Working Group presented to the Board in 
January 2022 on their work during 2021.  
In light of the significant role that technology 
will continue to play in the Group's strategy,  
it was recommended that the Technology 
Governance Working Group continues to  
meet throughout 2022. The Board agreed  
to continue with the Technology Governance 
Working Group in its current format through 

Mark E Tucker
Group Chairman

“ Following the launch of the Group’s refreshed 
purpose, strategy and values in March,  
we introduced a 'culture moment' at the 
beginning of each Board meeting.”

Dear Shareholder

The global health crisis continued into 2021 
as a result of the Covid-19 pandemic. Despite 
promising developments in relation to the 
efficacy of vaccines in combating the virus, 
there remained significant restrictions across 
our markets. It was therefore important that 
our governance framework and practices 
remained flexible to ensure that the Board 
could effectively discharge its duties. 

While the Board and its committees have 
operated well in a virtual environment, it was 
unfortunate that we were again unable to 
come together physically as a Board. It has 
been two years since the full Board was last 
together in person for a Board meeting,  
with five new Directors appointed in that time. 
I hope to hold in-person meetings as soon as 
it is safe to do so, particularly in our largest 
markets of Hong Kong and the UK. 

We continued our focus on enhancing our 
governance practices throughout the year, 
with key decisions and areas of focus set  
out in further detail below. 

Board changes
A key aspect of my role as Group Chairman 
is ensuring that collectively the Board has the 
skills, knowledge and experience it requires. 
The Nomination & Corporate Governance 
Committee retained a keen focus on 
succession planning during the year. For 
further details on its work, see page 237.  
We are currently in the process of completing 
a search for new non-executive Directors  
to join our Board, with knowledge and 
experience of banking and Asia a priority. The 
Committee is actively progressing this search 
and will provide an update in due course. 

218

HSBC Holdings plc Annual Report and Accounts 2021

2022, but with the scope extended to  
include a focus on business execution of the 
technology strategy. This will allow for a better 
understanding of the progress, challenges 
involved in implementing the strategy and  
the impact on key stakeholders. 

Environmental, social and governance
The Board recognises the growing importance 
of ESG and oversees the ESG agenda. It was a 
significant year for the Group in its efforts to 
support the transition to net zero – a key pillar 
of our overall Group strategy – with the 
passing of our climate resolution at our 2021 
AGM and the publication of our thermal coal 
phase-out policy, being two of the most 
notable achievements. Given its significance, 
the Board has decided to retain responsibility 
for development and oversight of our ESG 
strategy directly, rather than establishing  
a specific Board-level committee and we  
will include a dedicated item on our agenda  
for ESG matters. Within their existing 
responsibilities, the Group Risk Committee, 
Group Audit Committee and Group 
Remuneration Committee will also continue  
to have specific roles to play in overseeing and 
supporting the delivery of our ESG objectives. 

At the management level, we have asked our 
team to further enhance ESG governance, 
with the introduction of an ESG Committee, 
co-chaired by our Group Chief Sustainability 
Officer, Celine Herweijer, and our Group 
Company Secretary and Chief Governance 
Officer, Aileen Taylor. This committee will 
regularly report to the Board on progress 
against our ESG ambitions, climate strategy 
and related commitments. In February 2022, 
the Board also approved the proposal to 
develop and implement a sustainability target 
operating model for the Group. The new 
operating model will help ensure that our 
businesses have the technical expertise, 
specialist resources and training to equip and 
support them in assisting our clients in their 
transition to net zero.

For further information on our climate 
ambition and progress against our transition 
to net zero strategic pillar, see page 45.

Board evaluation
We again conducted a review of the 
effectiveness of the Board and Board 
committees, which helps to support the 
continuous improvement of the operation  
of our key governance practices. Following 
two successive externally facilitated 
evaluations, we took the decision that the 
2021 evaluations should be facilitated 
internally. The process was led by our Group 

Company Secretary and Chief Governance 
Officer and involved the completion of  
online surveys tailored for each Board and 
committee, complemented by individual 
interviews with Directors and attendees.

 Further details on the progress made against 
the 2020 findings, as well as the findings and 
recommendations from the 2021 review, can 
be found on page 235 and in each of the 
respective committee reports on pages 
237 to 267. 

Subsidiary governance
Subsidiary governance remained a key priority, 
as it has been since my appointment as Group 
Chairman, and we continued to build strong 
connectivity with our principal subsidiaries. 
In 2021, we sought to enhance the standard 
and consistency of governance across the 
Group, with the launch of our refreshed 
subsidiary accountability framework. The 
refreshed framework makes clear the Group's 
expectations of subsidiaries in relation to 
their governance approach and board 
practices through overarching principles 
and detailed provisions. 

A key aspect of the framework is focused  
on the composition of our subsidiary boards, 
with our most significant subsidiaries required 
to submit their succession plans to the 
Nomination & Corporate Governance 
Committee through the course of the year. 
This provided clarity on plans to refresh and 
enhance the calibre and diversity of boards 
across the Group. Further details are set out  
in the Nomination & Corporate Governance 
Committee report on page 237. 

Given the continued uncertainty externally, we 
looked to strengthen the connectivity between 
the Group and principal subsidiaries during  
the year through virtual forums held between  
the Board and committee chairs and our 
counterparts at subsidiary level. We further 
supplemented this connectivity with the 
introduction of a virtual Non-Executive 
Director Summit, which saw all subsidiary 
non-executive directors invited to come 
together to discuss areas of common interest. 
This was a valuable opportunity to share and 
discuss material topics, including strategy, 
risk, data, culture, diversity, climate and 
technology. Following the success of the 
summit, we have taken the decision to make 
these sessions a part of our annual 
governance calendar. 

Workforce engagement
Various opportunities for members of the 

Board to engage with employees have been 
provided during 2021, including through 
partnerships with our employee resource 
groups and sessions with members of our 
global graduate programme. The Board 
greatly values the opportunity to engage  
with employees from across the business  
and markets, and of different backgrounds 
and seniority. We will continue to prioritise 
this, along with interaction with all our key 
stakeholders, during 2022. 

For further details on the arrangements  
we have in place to facilitate workforce 
engagement, see page 233.

2021 Annual General Meeting
The pandemic has continued to pose many 
challenges for the Group, as it does for many 
of our stakeholders. However, the Group has 
benefited significantly from the speed at 
which digital tools have been adopted since 
the beginning of the pandemic. 

This has also been true of our AGM, where 
I was delighted to host our first hybrid AGM, 
which enabled shareholders globally to attend 
virtually, or in person. The use of technology 
enabled a broader range of shareholders to 
attend and participate than had been the 
case pre-pandemic. 

Further details of our plans for the 2022 AGM, 
which will be a hybrid meeting again, will be 
provided when our Notice of AGM is published 
on 25 March 2022.

Looking ahead
Despite the concerns of the Covid-19 
pandemic, I am hopeful that the success of 
vaccine roll-out will allow us to safely resume 
in-person engagement with each other and  
all stakeholders in the near future. 

On behalf of myself and the Board, many 
thanks for your continued commitment 
and support.

Mark E Tucker
Group Chairman

22 February 2022

HSBC Holdings plc Annual Report and Accounts 2021

219

Corporate governance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 (64) 
Group Chairman
Appointed to the Board: September 2017 
Group Chairman since: October 2017

Noel Quinn (60)
Group Chief Executive
Appointed to the Board: August 2019 
Group Chief Executive since: March 2020

Skills and experience: With over 35 years of 
experience in financial services in Asia, Africa,  
the US and the UK, including 25 years based in  
Hong Kong, Mark has a deep understanding of  
the industry and markets in which we operate. 

Career: Mark was most recently Group Chief 
Executive and President of AIA Group Limited (‘AIA’), 
having joined in July 2010. Prior to AIA he was Group 
Chief Executive of Prudential plc. He served on 
Prudential's Board for nearly 10 years.

Mark previously served as non-executive Director 
of the Court of the Bank of England and as an 
independent non-executive Director of Goldman 
Sachs Group.

Other appointments: 
 – Chair of TheCityUK
 – Non-executive Chairman of Discovery Limited
 – Supporting Chair of Chapter Zero
 – Member of the UK Investment Council
 – Co-Chair of the B20 Finance and Infrastructure 

Skills and experience: Having qualified as an 
accountant in 1987, Noel has more than 30 years  
of banking and financial services experience,  
both in the UK and Asia.

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 
roles across HSBC, or its constituent companies, 
since 1987. 

Prior to becoming Group Chief Executive, Noel was 
most recently CEO, Global Commercial Banking.  
He has also served as Regional Head of Commercial 
Banking for Asia-Pacific; Head of Commercial 
Banking UK; Head of Commercial Finance Europe; 
and Group Director of Strategy and Development  
at HSBC Insurance Services North America.

Other appointments: 
 – Chair of the Financial Services Task Force of HRH 
The Prince of Wales’ Sustainable Market Initiative
 – Member of the Principals Group of the Glasgow 

Task Force (Indonesia 2022)

Financial Alliance for Net Zero 

 – Director, Peterson Institute for International 

 – Member of the World Economic Forum’s 

Economics

International Business Council

 – Director, Institute of International Finance
 – International Adviser to the Hong Kong Academy 

of Finance

 – Asia Society Board of Trustees

Ewen Stevenson (55)
Group Chief Financial Officer
Appointed to the Board: January 2019

Skills and experience: Ewen has over 25 years  
of experience in the banking industry as an adviser 
and executive to major banks and 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 the Group’s corporate development activities  
in April 2021.

Career: Ewen was Chief Financial Officer at the 
Royal Bank of Scotland Group plc from 2014 to 2018. 
Before 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.

Other appointments:
 – Director of The Hongkong and Shanghai Banking 

Corporation Limited

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-and-governance.

220

HSBC Holdings plc Annual Report and Accounts 2021

 
Independent non-executive Directors

Rachel Duan (51) 
Independent non-executive Director
Appointed to the Board:  
September 2021 

Dame Carolyn Fairbairn (61) 
Independent non-executive Director
Appointed to the Board:  
September 2021

Skills and experience: Carolyn 
has significant experience across 
the media, government and 
finance sectors.

Career: An economist by training, 
Carolyn has served as a Partner  
at McKinsey & Company, Director-
General of the Confederation of British 
Industry, and Group Development and 
Strategy Director at ITV plc. She has 
extensive board experience, having 
previously served as non-executive 
Director of Lloyds Banking Group plc, 
the Vitec Group plc and Capita plc. 
She has also served as a non-
executive Director of the UK 
Competition and Markets Authority 
and the Financial Services Authority. 

Other appointments: 
 – Non-executive Director of BAE 

Systems plc

Skills and experience: Rachel is 
a business leader with exceptional 
international experience in the US, 
Japan, mainland China and 
Hong Kong.

Career: Rachel spent 24 years at 
General Electric (‘GE’), most recently 
as Senior Vice President of GE, and 
President and Chief Executive Officer 
of GE’s Global Markets, where she 
was responsible for driving GE’s 
growth in Asia-Pacific, the Middle 
East, Africa, Latin America, and  
Russia and the Commonwealth of 
Independent States. She has also 
previously served as President and 
Chief Executive Officer of GE 
Advanced Materials China and then  
of the Asia-Pacific, President and CEO 
of GE Healthcare China, and President 
and CEO of GE China.

Other appointments: 
 – Independent Director of Sanofi S.A.
 – Independent Director of AXA S.A.
 – Independent Director of the 

Adecco Group

James Forese (58) 
Independent non-executive Director
Appointed to the Board: May 2020

Steven Guggenheimer (56) 
Independent non-executive Director
Appointed to the Board: May 2020

Skills and experience: James has 
over 30 years of 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, he was Chief Executive 
Officer of Citigroup’s Institutional 
Clients Group. He has also been 
Chief Executive of its Securities and 
Banking division and head of its 
Global Markets business.

Skills and experience: Steven brings 
extensive insight into technologies 
ranging from artificial intelligence  
to Cloud computing, through his 
experience advising businesses  
on digital transformation.

Career: Steven has more than 
25 years of experience at Microsoft, 
where he held a variety of senior 
leadership roles. These included: 
Corporate Vice President, Artificial 
Intelligence and Independent Software 
Vendor Engagement; Corporate Vice 
President, Chief Evangelist; and 
Corporate Vice President, Original 
Equipment Manufacturer.

Other appointments: 
 – Chair of HSBC North America 

Holdings Inc

Other appointments: 
 – Non-executive Director of Forrit 

Technologies Limited

 – Non-executive Chairman of Global 

 – Independent Director of Software 

Bamboo Technologies
 – Trustee of Colby College

Acquisition Group

 – Adviser to Tensility Venture  

Partners LLC

 – Advisory Board Member of 5G  

Open Innovation Lab

HSBC Holdings plc Annual Report and Accounts 2021

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Report of the Directors | Corporate governance report

Independent non-executive Directors 

Irene Lee (68) 
Independent non-executive Director
Appointed to the Board: July 2015

Skills and experience: Irene has 
more than 40 years of experience in 
the finance industry, having worked 
in the UK, the US and Australia.

Career: Irene held senior investment 
banking and fund management roles 
at Citibank, the Commonwealth Bank 
of Australia and SealCorp Holdings 
Limited. She has served as a member 
of the Advisory Council for J.P. 
Morgan Australia, a member of the 
Australian Government Takeovers 
Panel and as a non-executive Director 
of QBE Insurance Group Limited, 
Keybridge Capital Limited, ING Bank 
(Australia) Limited, Noble Group 
Limited, CLP Holdings Limited and 
Cathay Pacific Airways Limited.

Other appointments: 
 – Chair of Hang Seng Bank Limited
 – Non-executive Director of the 

Hongkong and Shanghai Banking 
Corporation Limited

Dr José Antonio Meade Kuribreña 
(52) 
Independent non-executive Director
Appointed to the Board: March 2019

Skills and experience: José has 
extensive experience in public 
administration, banking, financial 
policy and foreign affairs.

Eileen Murray (63) 
Independent non-executive Director
Appointed to the Board: July 2020

Skills and experience: Eileen has 
extensive knowledge in financial 
technology and corporate strategy 
from a career spanning more than 
40 years.

Career: José has 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.

Career: Eileen most recently served 
as co-Chief Executive Officer of 
Bridgewater Associates, LP. Before 
this, she was Chief Executive Officer 
for Investment Risk Management LLC, 
and President and co-Chief Executive 
Officer of Duff Capital Advisors. Eileen 
started her professional career at 
Morgan Stanley, having held positions 
including Controller, Treasurer, and 
Global Head of Technology and 
Operations, as well as Chief Operating 
Officer for its Institutional Securities 
Group. At Credit Suisse, she was Head 
of Global Technology, Operations and 
Product Control.

Other appointments: 
 – Non-executive Director of Alfa 

S.A.B. de C.V.

Other appointments: 
 – Chair of the Financial Industry 

 – Executive Chair of Hysan 

 – Non-executive Director of Grupo 

Regulatory Authority

Development Company Limited
 – Member of the Exchange Fund 

Advisory Committee of the 
Hong Kong Monetary Authority

Comercial Chedraui, S.A.B. de C.V.
 – Board member of The Global Center 

on Adaptation

 – Member of the Independent Task 
Force on Creative Climate Action
 – Member of the UNICEF Mexico 

Advisory Board

 – Non-executive Director of Guardian 
Life Insurance Company of America
 – Adviser of Invisible Urban Charging
 – Adviser of ConsenSys, 
Aquarion Company

David Nish (61) 
Independent non-executive Director
Appointed to the Board: May 2016 
Senior Independent non-executive 
Director since: February 2020 

Skills and experience: David has 
international experience in financial 
services, corporate governance, 
financial accounting, and strategic 
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.

Other appointments: 
 – Non-executive Director of Vodafone 

Group plc

 – Honorary Professor of Dundee 
University Business School

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HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
Former Directors who  
served for part of the year 

Heidi Miller
Heidi Miller retired from the  
Board on 28 May 2021.

Henri de Castries
Henri de Castries retired from  
the Board on 28 May 2021.

Laura Cha, GBM
Laura Cha, GBM retired from  
the Board on 28 May 2021.

Aileen Taylor (49) 
Group Company Secretary and 
Chief Governance Officer
Appointed: November 2019

Skills and experience: Aileen 
is a solicitor with significant 
governance and regulatory 
experience across various roles  
in the banking industry. She is a 
member of the European Corporate 
Governance Council, the GC100 and 
the Financial Conduct Authority's 
Listing Authority Advisory Panel.

Career: Prior to joining HSBC, 
Aileen spent 19 years at the Royal 
Bank of Scotland Group, holding 
various legal, risk and compliance 
roles. She was appointed Group 
Secretary in 2010 and subsequently 
Chief Governance Officer and 
Board Counsel. 

Jackson Tai (71) 
Independent non-executive Director
Appointed to the Board: September 2016

Skills and experience: Jackson has 
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., having 
served as Chief Financial Officer and 
then as President and Chief Operating 
Officer. He worked for 25 years with 
J.P. Morgan & Co. Incorporated, 
holding roles as Chairman of 
Asia-Pacific Management Committee 
and Head of Japan Capital Markets. 
Other former appointments included 
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.

Pauline van der Meer Mohr (62) 

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 
also Deputy Chair of the Supervisory 
Board of Royal DSM N.V. from 2018  
to 2021, while also chairing its 
Sustainability Committee. Pauline  
was formerly President of Erasmus 
University Rotterdam, a member of 
the Dutch Banking Code Monitoring 
Commission, 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. Pauline also 
chaired the Group’s former Conduct 
and Values Committee.

Other appointments: 
 – Non-executive Director of Eli Lilly 

Other appointments:
 – Chair of the Dutch Corporate 

and Company

 – Non-executive Director of 
MasterCard Incorporated

Governance Code 
Monitoring Committee

 – Chair of the Supervisory Board of EY 

Netherlands LLP

 – 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.
 – Chair of the ASM International NV 

Supervisory Board

 For full biographical details of our Board members,  
see www.hsbc.com/who-we-are/leadership-and-governance.

HSBC Holdings plc Annual Report and Accounts 2021

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Report of the Directors | Corporate governance report

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 (53) 
Group Chief Human  
Resources Officer

Elaine joined HSBC as Group Chief 
Human Resources Officer in June 
2017. Prior to joining HSBC, she was 
Group Human Resources Director at 
Royal Bank of Scotland Group for six 
years. She has held a number of 
human resources and employee 
relations roles in financial services, 
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 Institute of Banking 
in Scotland.

Chira Barua (48) 
Global Head of Strategy

Chira joined HSBC in May 2020 as 
Global Head of Strategy and was 
appointed to the Group Executive 
Committee in April 2021. Before 
joining HSBC, he was a partner at 
McKinsey & Company in its financial 
services practice and a managing 
director at Sanford C. Bernstein 
between 2011 and 2017. Earlier in  
his career, Chira held a number of 
strategy, management and operational 
roles at Standard Chartered and 
Citigroup in India.

Colin Bell (54) 
Chief Executive Officer,  
HSBC Bank plc and HSBC Europe

Colin joined HSBC in July 2016 and 
was appointed Chief Executive Officer, 
HSBC Bank plc and HSBC Europe in 
February 2021. He previously held 
the role of Group Chief Compliance 
Officer. Before HSBC, Colin worked 
at UBS as Global Head of Compliance 
and Operational Risk Control. He 
served for 16 years in the British Army, 
having held a variety of command 
and staff positions, including within 
operational tours of Iraq and Northern 
Ireland, the Ministry of Defence 
and NATO.

Jonathan Calvert-Davies (53) 
Group Head of Internal Audit

Jonathan is a standing attendee of  
the Group Executive Committee, 
having joined HSBC as Group Head  
of Internal Audit in October 2019. 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. Jonathan's previous roles 
included leading KPMG UK’s financial 
services internal audit services 
practice and PwC's UK internal audit 
services practice. He has also served 
as interim Group Head of Internal 
Audit at the Royal Bank of 
Scotland Group.

Georges Elhedery (47) 
Co-Chief Executive Officer,  
Global Banking and Markets

Greg Guyett (58) 
Co-Chief Executive Officer, 
Global Banking and Markets

Georges joined HSBC in 2005 and was 
appointed 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, with 
responsibility for its strategic direction 
in more than 55 countries and 
territories. Georges previously served 
as Head of Global Markets; Chief 
Executive Officer for HSBC, Middle 
East, North Africa and Turkey; Head  
of Global Banking and Markets, 
MENA; and Regional Head of Global 
Markets, MENA. Georges will be on 
sabbatical leave between March and 
September 2022.

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. 
Greg will assume sole responsibility of 
the business while Georges Elhedery 
is on sabbatical leave between March 
and September 2022. Before 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.

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HSBC Holdings plc Annual Report and Accounts 2021

Dr Celine Herweijer (44) 
Group Chief Sustainability Officer

John Hinshaw (51) 
Group Chief Operating Officer

Bob Hoyt (57) 
Group Chief Legal Officer

Celine joined HSBC as Group Chief 
Sustainability Officer in July 2021, 
and is responsible for the Group’s 
sustainability agenda including its 
ambition to transition to net zero. She 
previously worked as a partner at PwC 
for over a decade, where she held 
global leadership roles including 
acting as its global innovation and 
sustainability leader. Before joining 
PwC, Celine worked as Director of 
Climate Change and Consulting for 
Risk Management Solutions. She is a 
World Economic Forum Young Global 
Leader, a co-chair of the We Mean 
Business Coalition, a PhD climate 
scientist and a NASA fellow by training.

John became Group Chief Operating 
Officer in February 2020, having joined 
HSBC in December 2019. He has an 
extensive background in transforming 
organisations across a range of 
industries. Most recently, John 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, DocuSign and the US 
National Academy Foundation.

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 and senior 
policy adviser 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.

Steve John (48) 
Group Chief Communications 
Officer

Pam Kaur (58) 
Group Chief Risk and 
Compliance Officer

Steve was appointed as Group Chief 
Communications Officer in December 
2019 and appointed to the Group 
Executive Committee in April 2021. He 
has a wealth of senior communications, 
public policy and leadership experience 
acquired across a number of 
multinational and charitable 
organisations. Prior to joining HSBC, 
Steve was a partner and Global Director 
of Communications at McKinsey & 
Company from 2014 to 2019. He has 
also held roles with Bupa as Global 
Director of Communications and 
PepsiCo as Director of Corporate Affairs 
for their UK and Ireland franchises.

Pam was appointed Group Chief Risk 
and Compliance Officer in July 2021, 
having held the role of Group Risk 
Officer since January 2020. She joined 
HSBC in 2013 and was previously 
Group Head of Internal Audit, Head of 
Wholesale Market and Credit Risk, 
and Chair of the enterprise-wide 
non-financial risk forum. Pam has also 
held a variety of audit and compliance 
roles in the banking industry, including 
with Deutsche Bank, Royal Bank of 
Scotland Group, Lloyds TSB and 
Citigroup. She serves as a non-
executive Director of Centrica plc.

David Liao (49) 
Co-Chief Executive Officer, 
Asia-Pacific – The Hongkong 
and Shanghai Banking 
Corporation Limited

David was appointed co-Chief 
Executive Officer of the Asia-Pacific 
region in June 2021. He is a Director  
of the Hongkong and Shanghai 
Banking Corporation Limited, Bank of 
Communications Co., Limited, Hang 
Seng Bank Limited and HSBC Global 
Asset Management Limited. David 
joined HSBC in 1997, with previous 
roles including: Head of Global 
Banking Coverage for Asia-Pacific; 
President and Chief Executive at 
HSBC China; Head of Global Banking 
and Markets at HSBC China; and 
Treasurer and Head of Global Markets 
at HSBC China.

HSBC Holdings plc Annual Report and Accounts 2021

225

Corporate governanceReport of the Directors | Corporate governance report

Nuno Matos (54) 
Chief Executive Officer,  
Wealth and Personal Banking 

Nuno joined HSBC in 2015 and was 
appointed Chief Executive Officer  
of Wealth and Personal Banking in 
February 2021. He is a Director of 
HSBC Global Asset Management 
Limited. He was previously the Chief 
Executive Officer of HSBC Bank plc 
and HSBC Europe, a role he held from 
March 2020. Nuno has also served  
as Chief Executive Officer of HSBC 
Mexico, and as regional head of 
Retail Banking and Wealth 
Management in Latin America.  
Before joining HSBC, he held senior 
positions at Santander Group.

Stephen Moss (55) 
Regional Chief Executive Officer –  
Middle East, North Africa 
and Turkey

Barry O’Byrne (46) 
Chief Executive Officer,  
Global Commercial Banking 

Stephen was appointed Regional Chief 
Executive Officer for the Middle East, 
North Africa and Turkey in April 2021. 
He has held a series of roles since 
joining HSBC in 1992, including as 
Chief of Staff to the Group Chief 
Executive and overseeing the Group’s 
mergers and acquisitions, and strategy 
and planning activities. Stephen is a 
Director of The Saudi British Bank, 
HSBC Bank Middle East Limited, 
HSBC Middle East Holdings B.V, 
HSBC Bank Egypt S.A.E and HSBC 
Saudi Arabia.

Barry joined HSBC in April 2017 and 
was appointed Chief Executive Officer 
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. Before joining 
HSBC, Barry worked at GE Capital  
for 19 years in a number of senior 
leadership roles, including as Chief 
Executive Officer and Chief Operating 
Officer for GE Capital International.

Michael Roberts (61) 
Chief Executive Officer,  
HSBC USA and Americas

Michael was appointed Chief 
Executive Officer for HSBC USA  
and the Americas with oversight 
responsibility for Canada and Latin 
America in April 2021. He joined HSBC 
in October 2019 and is a Director  
of HSBC Bank Canada; executive 
Director, President and Chief Executive 
Officer of HSBC North America 
Holdings Inc.; and Chairman of HSBC 
Bank USA, N.A. and HSBC USA Inc. 
Previously, Michael 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.

Surendra Rosha (53) 
Co-Chief Executive Officer, 
Asia-Pacific – The Hongkong 
and Shanghai Banking 
Corporation Limited

John David Stuart  
(known as Ian Stuart) (58) 
Chief Executive Officer,  
HSBC UK Bank plc

Surendra was appointed co-Chief 
Executive Officer of the Asia-Pacific 
region in June 2021. He is a Director of 
The Hongkong and Shanghai Banking 
Corporation Limited and HSBC Bank 
Australia Limited. Surendra joined 
HSBC in 1991 and has held several 
senior positions within Global Banking 
and Markets, including as Head of 
Global Markets in Indonesia and Head 
of Institutional Sales, Asia-Pacific.  
He was Chief Executive for HSBC  
India and Head of HSBC’s financial 
institutions group for Asia-Pacific.

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.

226

HSBC Holdings plc Annual Report and Accounts 2021

Additional members of the  
Group Executive Committee

Noel Quinn

Ewen Stevenson

Aileen Taylor

Biographies are provided  
on pages 220 and 223.

 
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 help ensure that it is well managed, with 
effective oversight and controls. We comply with the UK 
Corporate Governance Code and the applicable requirements of 
the Hong Kong Corporate Governance Code. 

Board’s role, Directors’ responsibilities and 
meeting 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;

• setting the Group’s risk appetite and monitoring the Group’s 

risk profile; 

• approving and monitoring capital and operating plans for 

achieving strategic objectives; 

• approving material transactions;

• approving the appointment of Directors, including Board roles; 

and

• reviewing the Group's overall corporate governance 

arrangements.

Board meetings. Other senior executives attend Board meetings as 
required.

In addition to formal Board meetings, the Board Oversight Sub-
Group, established by the Group Chairman in 2020, meets in 
advance of each Board meeting. Such meetings are an informal 
mechanism for a smaller group of Board members and 
management to discuss emerging issues and upcoming Board 
matters. Standing attendees comprise the Group Chairman, the 
Chair of the Group Audit Committee (who is also the Senior 
Independent Director), the Chair of the Group Risk Committee, the 
Group Chief Executive, the Group Chief Financial Officer, the 
Group Chief Risk and Compliance Officer, and the Group Company 
Secretary and Chief Governance Officer. Other non-executive 
Directors and management are invited on a rotational basis, 
depending on the subject to be discussed. The forum is not 
decision making but provides regular opportunities for Board 
members to communicate with senior management to deepen 
their understanding of, and provide input into, key issues facing 
the Group. For further details on how the Board engages with the 
wider workforce, see page 233.

Board governance enhancements due to Covid-19

The Board continued many of the governance changes 
introduced in 2020 in response to the Covid-19 pandemic, 
including meeting online during 2021. The Board was kept 
informed of the continuing challenges and priorities of the 
management team as part of the formal executive reporting 
received at these meetings. The following practices continued: 
• The Group Chairman prepared a weekly Board update note. 
• The Group Chief Risk and Compliance Officer produced a 

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.

weekly Board report on risk matters, including in relation to the 
Covid-19 pandemic, as well as market highlights, industry 
events and results. 

• Immunologists and pandemic experts updated the Board on 

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. Further details on the 
independence of the Board and the value independence brings can 
be found in the Nomination & Corporate Governance Committee 
report. 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 2021, the Board comprised the Group 
Chairman, 10 non-executive Directors, and two executive 
Directors who are the Group Chief Executive and the Group Chief 
Financial Officer. Two non-executive Directors will not stand for 
re-election at the AGM in April 2022.

For further details of the Board’s career background, skills, 
experience and external appointments, see pages 220 to 223.

Operation of the Board 

The Board is ordinarily scheduled to meet at least seven times a 
year. In 2021, the Board held 12 meetings. For further details on 
attendance at those meetings, see page 228. The Board agenda is 
agreed by the Group Chairman, working with both the Group Chief 
Executive and the Group Company Secretary and Chief 
Governance Officer. For more information, see 'Board activities 
during 2021' on page 232.

The Group Company Secretary and Chief Governance Officer, the 
Group Chief Risk and Compliance Officer, the Group Chief Legal 
Officer and the non-executive Chairman of The Hongkong and 
Shanghai Banking Corporation Limited are all regular attendees at 

emerging issues. 

• The Group Chairman's Forum was held monthly. It was 

attended by Board committee chairs, as well as chairs of 
principal subsidiaries.

Technology governance

A Technology Governance Working Group was established in 
2021, initially for a period of 12 months, to provide 
recommendations to enhance the Board's oversight of 
technology strategy, governance and emerging risks, and to 
enhance connectivity with the principal subsidiaries. Given their 
industry expertise and experience, the working group is jointly 
chaired by Eileen Murray and Steven Guggenheimer. Its 
members include Group Risk Committee chair Jackson Tai and 
other non-executive Directors representing each of our US, UK, 
European and Asian principal subsidiaries. Key technology and 
business stakeholders have attended the working group to 
provide insights on technology and information security issues 
across the Group. The working group has met formally eight 
times since its inception, and has held additional ad hoc sessions 
on priority strategic topics including data and cybersecurity. The 
Technology Governance Working Group's recommendations 
were presented to the Board in January 2022 when it was 
decided that the working group will remain an informal 
committee of the Board. For further details on the future of the 
working group, see the Group Chairman's governance statement 
on page 218.

HSBC Holdings plc Annual Report and Accounts 2021

227

Corporate governance 
Report of the Directors | Corporate governance report

Board engagement with shareholders

In 2021, the Group Chairman, Senior Independent Director and 
other non-executive Directors, often with the Group Company 
Secretary and Chief Governance Officer, engaged with a number 
of our large institutional investors in 15 meetings. The Group 
Chief Executive and the Group Chief Financial Officer attended 
over 30 meetings with investors in 2021. Key topics included our 
financial performance,  climate policies and progress in relation 
to the climate resolution passed at the 2021 AGM. Other topics 
discussed with investors 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, and the impact of the Covid-19 pandemic on the 
Group, its employees, customers and communities. 
The Group Remuneration Committee Chair met with 
representatives from key investors and proxy advisory firms 
numerous times during the fourth quarter of 2021, in preparation 
for its discussion and decision making on the 2021 executive 
Directors' performance outcomes and the renewal of the 2022 
Directors' remuneration policy. 

Board roles, responsibilities and meeting attendance

The table below sets out the Board members' respective roles, responsibilities and attendance at Board meetings and the AGM in 2021. 
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

Board 
attendance 
in 2021

Responsibilities

12/12

• 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 fosters open and 

constructive debate among Directors.

• Maintains external relationships with key stakeholders and communicates investors' views to the Board.
• Organises periodic monitoring and evaluation, including externally facilitated evaluation, of the 

performance of the Board, its committees and individual Directors.

Executive Director
Group Chief Executive
Noel Quinn2

Executive Director
Chief Financial Officer
Ewen Stevenson2

12/12

• 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 internal and external stakeholders including the Group Chairman, the 

Board, regulators, governments and investors.

12/12

• Supports the Group Chief Executive in developing and implementing the Group strategy and 

recommends the annual budget and long-term strategic and financial plan.

• 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.

Non-executive Directors
Senior Independent 
Director
David Nish2,3

12/12

• 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 

6/6
5/6
4/4
4/4
12/12
12/12
12/12
12/12

Laura Cha2,3,4
Henri de Castries2,3,4,6
Rachel Duan3,5
Dame Carolyn Fairbairn3,5
James Forese2,3
Steven Guggenheimer2,3
Irene Lee2,3
Dr José Antonio Meade 
Kuribreña2,3
Heidi Miller2,3,4
6/6
Eileen Murray2,3.6
9/12
Jackson Tai2,3
12/12
Pauline van der Meer Mohr2,3 12/12
Group Company Secretary 
and Chief Governance 
Officer
Aileen Taylor

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  Attended the AGM on 28 May 2021.
3 

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. 

4  Heidi Miller, Laura Cha and Henri de Castries retired from the Board on 28 May 2021.
5  Rachel Duan and Dame Carolyn Fairbairn joined the Board effective 1 September 2021.
6  Henri de Castries was unable to attend one Board meeting due to a conflict of interest. Eileen Murray was unable to attend meetings in the last 

few months of 2021 due to personal health reasons, but was kept informed of Board and relevant committee matters. She was fully briefed ahead 
of her return to regular meeting attendance in January 2022. Eileen continues to have sufficient time to dedicate to her role with HSBC.

228

HSBC Holdings plc Annual Report and Accounts 2021

Board induction and training

Q&A with Rachel Duan 

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 and 
comprehensive induction programmes to fit with their individual 
experiences and needs, including the process for dealing with 
conflicts.  

The induction programme is delivered through formal briefings 
and introductory sessions with Board members, senior 
management, legal counsel, auditors, tax advisers and regulators, 
as appropriate. Topics covered include, but are not limited to: 
purpose and values; culture and leadership; governance and 
stakeholder management; Directors' legal and regulatory duties; 
recovery and resolution risk; anti-money laundering and anti-
bribery; technical and business briefings; and strategy. 

An early focus on induction allows a new Board member to 
contribute meaningfully from appointment. The structure of the 
induction supports good information flows within the Board and 
its committees, as well as between senior management and non-
executive Directors, providing a clear understanding of our culture 
and way of operating. 

During 2021 we welcomed two new non-executive Directors, 
Rachel Duan and Dame Carolyn Fairbairn, to our Board. We gave 
careful consideration to creating relevant and bespoke induction 
programmes for each of the new non-executive Directors, 
particularly given their differing geographical locations and the 
continuing Covid-19-related challenges for meetings in person. For 
illustrations of the typical induction modules, see the 'Directors' 
induction and ongoing development in 2021' table on the 
following page.

Non-executive Directors continued to engage with each other 
through virtual meetings amid continuing Covid-19-related travel 
restrictions. We continue to plan and look forward to opportunities 
to facilitate safe and comprehensive person-to-person 
engagement, both in and out of Board meetings. These 
opportunities provide invaluable insight and understanding of our 
business, customers, culture and people. 

Directors undertook routine training during 2021. 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 training sessions included external 
consultants who provided insights into geopolitical matters, 
macroeconomics and investor sentiments. Other topics of focus 
included: operations and technology strategy; the resolvability 
assessment framework; and climate change and sustainability.

Non-executive Directors also 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.

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. During 2021, the Group Chairman hosted a Non-
Executive Director Summit where 200 independent non-executive 
directors from the Group's subsidiaries attended a virtual session 
along with Board Directors. They received updates and training on 
Group-wide matters including climate change, technology, culture 
and the launch of the newly developed Non-Executive Director 
Handbook. Following its success, further Non-Executive Director 
Summits will take place during 2022.

Q: What is your impression and experience of the onboarding 
process for HSBC?
From the very start of the process I was impressed at the level of 
attention given to my induction programme. Care was taken to tailor 
my meetings and the information provided so that it was relevant for 
me and thereby ensured a smooth, efficient and thoughtful process.
Q: How have you managed to get insight into the wider Group 
governance?
Before my joining date I was afforded many opportunities to meet 
colleagues, both virtually and physically. Shortly after joining, I visited 
our Hong Kong office to meet, among others, Peter Wong, non-
executive chairman of The Hongkong and Shanghai Banking 
Corporation Limited. This gave me the chance to gain insight into 
governance matters in Asia. In July 2021, I was invited to attend the 
Non-Executive Director Summit, which was a great introduction into 
the Group's and its subsidiaries' governance matters. These 
engagements highlighted key areas of focus for HSBC and provided 
clear insight into the Group's way of working.
Q: How prepared did you feel for the first Board meeting in 
September?
My tailored engagements and bespoke briefings started shortly after 
the announcement of my intention to join the HSBC Board in March, 
all of which helped me get my arms around this complex 
organisation and made me feel included and ready to execute my role 
in the boardroom with ease.

Q&A with Dame Carolyn Fairbairn

Q: How have you got an understanding of the Board's focus on 
culture?
The culture at HSBC is thoughtful and inclusive. I could see from the 
carefully planned induction meetings which were arranged well 
ahead of my joining. I have been introduced to two  employee 
resource groups: Ability, the disability and mental health network, 
and Embrace, an ethnicity network, and value the opportunity to 
support them. Also, the Board opens every meeting with a ‘culture 
moment’, which really demonstrates how it connects closely with the 
corporate values, and openly expresses how these are observed.
Q: What has been your experience of preparing for membership of 
the Group Remuneration Committee and the Group Risk Committee? 
Before I joined, I engaged closely with the committees' chairs, as well 
as senior management, to understand their priorities, including a new 
remuneration policy for the 2022 AGM and the climate agenda. I 
remain actively engaged with the members to ensure a smooth 
transition onto these committees.
Q: Did your attendance at the 2021 AGM give you a better 
understanding of the Group's business?
Attending the 2021 AGM, ahead of my official appointment to the 
Board, enabled me to witness HSBC’s first hybrid meeting with 
shareholders. I was pleased to see that the company’s planning 
enabled as many shareholders as possible to participate in this 
annual event, despite the persistent Covid-19 pandemic challenges, 
demonstrating HSBC's inclusive culture. The questions from 
shareholders were insightful and gave me a good sense of what was 
top of investors’ minds and how the company was responding to 
such concerns, particularly on the climate agenda.

HSBC Holdings plc Annual Report and Accounts 2021

229

Corporate governanceReport of the Directors | Corporate governance report

Directors’ induction and ongoing development in 2021

Director

Rachel Duan

Dame Carolyn Fairbairn

James Forese

Steven Guggenheimer

Irene Lee

José Antonio Meade Kuribreña

Eileen Murray

David Nish

Noel Quinn

Ewen Stevenson

Jackson Tai

Mark Tucker

Pauline van der Meer Mohr

Induction1
l
l
ô

ô

ô

ô

ô
ô
ô
ô
ô

ô

ô

Strategy and 
business 
briefings2
l
l
l
l
l
l
l
l
l
l
l
l
l

Risk and
control3
l
l
l
l
l
l
l
l
l
l
l
l
l

Corporate 
governance, ESG 
and other 
reporting 
matters4
l
l
l
l
l
l
l
l
l
l
l
l
l

Board and global 
mandatory 
training5
l
l
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l
l
l
l
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Chair and 
subsidiary non-
executive 
Director forums6
l
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l
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l
l

1  The induction programme was delivered through formal briefings and introductory sessions with Board members, senior management, legal 

counsel, auditors, tax advisers and regulators, as appropriate. Topics covered included, but were not limited to: purpose and values; culture and 
leadership; governance and stakeholder management; Directors’ legal and regulatory duties; recovery and resolution risk; 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 2021 included: 'US strategy: restructuring of the operating model' and 'Climate change: becoming net zero 
by 2050'.

3  Directors received risk and control training. Examples of specific sessions held in 2021 included: 'Stress testing' and 'ICAAP/ILAAP'.
4  All Directors received training on topics such as: 'Resolvability assessment framework', 'Climate and sustainable finance' and 'IFRS 17'.
5  Global mandatory training, issued to all Directors, mirrored training undertaken by all employees, including senior management. This included: 

management of risk under the enterprise risk management framework, with a focus on operational risk; cybersecurity risk; 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, fraud and bribery and corruption risks; and our values and conduct, including workplace harassment and speaking up.

6  Chairman's Forum, Remuneration Committee Chairs' Forum and the Non-Executive Director Summit.

Board committees and working groups

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 237.

In addition to the Board committees, working groups are 
established to enhance Board governance. The Technology 
Governance Working Group was first convened in March 2021 to 
enhance the Board's oversight of technology strategy, governance 

and emerging risks, and to enhance connectivity with the principal 
subsidiaries. The working group will continue in 2022 but will 
remain a working group, not a formal committee of the Board. For 
further details, see page 227. 

The Board Oversight Sub-Group is also part of the group operating 
rhythm ahead of Board meetings. As described on page 227, this 
group offers the Board and senior management an informal forum 
to discuss key matters before they are considered by the Board. 

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. All Board members 
are invited to attend all Chairman's Committees.

Board

Chairman’s
Committee

Group Audit 
Committee

Group Risk 
Committee

Group 
Remuneration 
Committee

Nomination & 
Corporate 
Governance 
Committee

230

HSBC Holdings plc Annual Report and Accounts 2021

Relationship between Board and senior management 

The designated principal subsidiaries are:

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 management of the 
Group by recommendations and advice from the Group Executive 
Committee ('GEC'), an executive forum comprising members of 
senior management that include chief executive officers of the 
global businesses, regional chief executive officers and functional 
heads.

The Directors are encouraged to have contact with management 
at all levels, and have 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 but only 
when it is safe to do so. While there were limited physical 
opportunities for Board members to meet in 2021, there were 
several virtual meetings with senior executives including induction 
meetings and subject matter 'deep dives', as well as regular 
working meetings.

Connectivity between management and the Board is further 
facilitated through informal discussion held as required on an ad 
hoc basis, and as part of the Board Oversight Sub-Group 
meetings.

Executive governance

The Group’s executive governance is underpinned by the Group 
operating rhythm, which helps facilitate end-to-end governance 
between senior leadership and the Board, and sets out the Board 
and executive engagement schedule. 
The Group operating rhythm is characterised by three pillars:
• The GEC normally meets every week to discuss current and 

emerging issues.

• On a monthly basis, the GEC reviews the performance of 
global businesses, principal geographical areas and legal 
entities. These performance reviews are supplemented by 
operating unit performance review meetings between 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. The Group Chief 
Executive and Group Risk and Compliance Officer have 
standing invitations to these meetings. 

• 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 
committees are dedicated sub-committees of the GEC, including 
the new ESG Committee, the Transformation Oversight Executive 
Committee and the Acquisitions and Disposals Committee, and 
all committees together support and facilitate collective decision 
taking and individual accountabilities. 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, ESG matters and talent and 
development. 
In addition to our regional company secretaries supporting our 
principal subsidiaries, we have corporate governance officers 
supporting our global businesses and our larger global functions 
to assist in effective end-to-end governance, consistency and 
connectivity.

Subsidiary governance

Certain subsidiaries are formally designated as principal 
subsidiaries by approval of the Board. In addition to their 
obligations under their respective local laws and regulation, 
principal subsidiaries have an important role in supporting 
effective and high standards of governance across the Group.

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 and North Africa

US

Mexico and Latin America

Canada

In general, principal subsidiaries are responsible for overseeing the 
implementation of the subsidiary accountability framework for 
Group companies in the region for which they are responsible. The 
subsidiary accountability framework, approved in 2020, and 
refreshed by the Board in 2021, set out to improve 
communications and connectivity between the Group and its 
subsidiaries. It is subject to regular review and is occasionally 
updated to improve how the respective roles of principal 
subsidiaries and other subsidiaries are articulated. This helps to 
provide the Group with a shared understanding and a consistent 
approach towards its strategic objectives, culture and values and 
furthers the efforts to streamline and align corporate governance.

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, the 
chairs of the Group's audit, risk and remuneration committees and 
the Group Chief Executive to discuss Group-wide and regional 
matters. The Group Chairman hosted 11 Chairman’s Forums in 
2021, which were also attended by relevant executive 
management, to cover sessions on strategy, financial performance 
and investor sentiment, geopolitics, culture, employee 
engagement, diversity and inclusion, technology and data, group 
recovery planning, corporate governance and implementation of 
the updated subsidiary accountability framework. The Non-
Executive Director Summit, hosted by the Group Chairman, was 
also an effective subsidiary directors' engagement event. For 
further details, see page 229.

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. 
While the Audit and Risk Committee Chairs' Forums did not take 
place in 2021, the chairs of the Group Audit Committee and Group 
Risk Committee continued to have regular dialogue with the 
respective committees of the principal subsidiaries to ensure an 
awareness and coordinated approach to key issues. The annual 
Remuneration Committee Chairs' Forum took place in October, 
and provided the principal subsidiary chairs with an opportunity to 
discuss performance, key considerations and positioning in 
advance of the pay review process. A follow-up forum was held in 
early December to provide transparency around pay outcomes and 
allocation, with feedback from the discussion used to shape the 
final pay proposals, which were considered and approved by the 
Group Remuneration Committee.

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, and in particular, when the Prudential Regulation 
Authority ('PRA') is in attendance. The chairs of the principal 
subsidiary risk committees are regular attendees at the Group Risk 
Committee.

HSBC Holdings plc Annual Report and Accounts 2021

231

Corporate governance 
 
Report of the Directors | Corporate governance report

Board activities during 2021

During 2021, the Board was focused on HSBC's strategic direction 
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 2021 are set out by theme 
below.

Strategy and business performance

Since the Group announced a new strategic focus and associated 
transformation programme in February 2020, it has set out to 
reshape underperforming businesses, simplify the organisation 
and reduce costs. The strategy aims to increase returns for 
investors, create capacity for future investment and build a 
sustainable platform for growth.

The Board, which held a dedicated strategy session in May 2021, 
assessed the delivery of strategic achievements throughout the 
year through both the perspectives of the global businesses and 
the regions. The Board took a holistic view by reviewing 
management’s strategic alignment to, and outcomes against, 
HSBC's four strategic pillars of: focus on our strengths, digitise at 
scale, energise for growth and transition to net zero. 

Environmental, social and governance

In 2020, the Group announced its new climate ambition to align 
financed emissions to net zero by 2050 and become net zero for 
its own operations and supply chain by 2030. The Group aims to 
achieve this by supporting clients on the road to a net zero carbon 
economy and a focus on sustainable finance opportunities. In 
2021, the Board considered more climate matters at its meetings, 
including participating in four climate 'deep-dives' and approving 
the climate-related resolution for the 2021 AGM. For further details 
on how the Board is meeting its climate agenda ambitions, see 
'Board decision making and engagement with stakeholders' on 
page 21 and the ESG review on page 43.

The Board has also considered other sustainability matters, 
including human rights, a new thermal coal phase-out policy, the 
operating model for sustainability and the methodology for 
climate-aligned financing.

The Board received regular reports on the continuing challenges 
presented by the ongoing Covid-19 pandemic, which supported 
the Group’s responses and measures to mitigate the effects, 
including, providing medical aid and assistance to our colleagues 
in India and other regions.

The Board takes overall responsibility for ESG strategy, overseeing 
executive management in developing the approach, execution and 
associated reporting. It has enhanced its oversight of ESG matters, 
with a dedicated agenda item on this topic introduced for 2022. 
Management has also enhanced its governance model with the 
introduction of a new ESG Committee and supporting forums, 
which will support senior management in the delivery of the 
Group’s ESG strategy, key policies and material commitments by 
providing holistic oversight over – and management and 
coordination of – ESG commitments and activities.

Financial decisions

The Board approved key financial decisions throughout the year 
and approved the Annual Report and Accounts 2020, the Interim 
Report 2021 and the first quarter and the third quarter Earnings 
Releases.

At the start of 2021, the Board approved the 2021 annual financial 
resourcing plan and in December 2021 approved the financial 
resourcing plan for 2022. The Board monitored the Group's 
performance against the approved 2021 financial resourcing plan, 

232

HSBC Holdings plc Annual Report and Accounts 2021

as well as the plans of each of the global businesses. The Board 
also approved the renewal of the debt issuance programme, and 
as announced on 26 October 2021 the buy-back programme.

Following the decision in 2020 to cancel the fourth interim 
dividend for 2019, on 23 February 2021, we announced that after 
considering the requirements set out in the PRA's temporary 
approach to shareholder distributions for 2020, an interim dividend 
for 2020 of $0.15 per ordinary share would be paid in cash on 
29 April 2021. On 2 August 2021, we announced an interim 
dividend of $0.07 for the 2021 half-year paid in cash on 
30 September 2021. For further details of dividend payments, see 
page 397 and 'Board decision making and engagement with 
stakeholders' on page 21.

The Board has adopted a policy designed to provide sustainable 
dividends going forward. For the financial year 2021, we are at the 
lower end of our target dividend payout ratio range of between 
40% and 55% of reported earnings per ordinary share (‘EPS’), 
driven by ECL releases and higher restructuring costs. The 
dividend policy has the flexibility to adjust EPS for non-cash 
significant items such as goodwill or intangible 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. 

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 and Human Trafficking 
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 impacts to trade following the UK's departure 
from the EU.

Technology

Throughout the year, the Board received regular updates on 
technology from the Group Chief Operating Officer, including 
updates on the refreshed technology strategy and restructuring of 
the technology leadership function.

In early 2021, the Technology Governance Working Group was 
established to oversee and enhance the Group's governance of 
technology. For further details on this group’s work and the future 
of the Board’s oversight of technology governance, see page 227.

People and culture

The Board continued to spend time discussing people and culture-
related topics. To set the right cultural tone, since March 2021, 
each Board meeting has begun with a Director or regular attendee 
describing a 'cultural moment' he or she had experienced, 
including observations of behaviours within the Group aligned to 
the purpose and values. Once a year the chairs from each of the 

principal subsidiaries present to the Chairman's Forum on their 
respective board engagement activities and learnings, including 
cultural insights. Twice a year the Group Chief Human Resources 
Officer attends the Board to provide insights into the Group’s 
employee Snapshot survey results measuring employee sentiment, 
talent plans, progress on the embedding of the new purpose and  
values, and the measurement of culture. This reporting includes a 
culture insights report, which allows the Board to monitor culture 
through receipt of data on culture perceptions and using the 
indicators of behaviours/sentiment and business outcomes/people 
data. These presentations help enable the Board to monitor and 
assess the organisation's culture.

Board engagement with management and the wider workforce 
continued to remain a strong area of attention.

Governance

The Board continued to oversee the governance, smooth operation 
and oversight of the Group and its principal and material 
subsidiaries. Following a review of subsidiary governance, the 
Board oversaw the implementation of the review findings, with the 
support of the Nomination & Corporate Governance Committee. 

The Board also supported new governance initiatives to encourage 
simplification and promote effective decision making in the 
business. Such initiatives included the refinement of Board and 
committee papers, and a review to reduce unnecessary committee 
meetings to free management time and encourage individual 
accountability and decision taking.

Succession planning was considered at the Nomination & 
Corporate Governance Committee. During the year, Laura Cha, 
Henri de Castries and Heidi Miller retired as independent non-
executive Directors. The Board appointed Rachel Duan and Dame 
Carolyn Fairbairn as independent non-executive Directors who 
joined the Board in September 2021. 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, diversity, experiences and 
competencies to discharge its responsibilities effectively.

For further details on the review, subsequent actions and changes 
to the Board, see the Nomination & Corporate Governance 
Committee report on page 237.

The Board monitored its compliance with the UK Corporate 
Governance Code, the Hong Kong Corporate Governance Code 
and the Companies Act 2006 throughout the year.

Workforce engagement

The Board continued to place great emphasis on the importance 
of engagement with the workforce, including colleagues affected 
by the continued impact of the Covid-19 pandemic and the 
return to offices in the UK and elsewhere. The Board also 
considered the impact of the launch of our new purpose and 
values and the ongoing transformation activity, including the 
announcement of the disposal of our retail businesses in the US 
and France.
In accordance with the UK Corporate Governance Code, the 
Board reaffirmed that it continued to believe that the 'alternative 
arrangements' approach remained most appropriate for the 
Group in engaging and understanding the views of the 
workforce. The programme of engagement covered a variety of 
interaction styles: more bespoke sessions with smaller groups; 
formal presentations; Q&A opportunities; and other sessions to 
facilitate engagement across a breadth of experience, 
geographical spread and seniority. This variety of engagements 
enabled open dialogue and two-way discussions between 
Directors and employees. These sessions allowed the Board to 
gain valuable insight on employee perspectives, which in turn 
informed their deliberations and decision making at Board and 
committee meetings. The Board receives updates on how the 
Group engages with stakeholders, including the workforce, by 
way of the Group Chief Executive's Board report and the Group 
Chairman's weekly Board note. In addition, the Board's agenda 
regularly includes non-executive Director workforce and other 
stakeholder engagement updates. These help to inform the 
Board of employee initiatives and sentiment and allow the Board 
to plan for future engagement activities. For further details of 
how the Board considered the views of employees and other 
stakeholders, see the 'Board decision making and engaging with 
stakeholders' on page 21.
The flexibility of this approach allowed all Board members the 
opportunity for direct engagement – albeit often virtually during 
2021 – with a broad cross-section of the workforce, spanning 
global businesses, functions and geographies. It also gave 
insights provided by management through our employee 
listening tools and surveys. 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 pandemic. The Chairman’s Forum meetings also 
discussed employee feedback from the Group's subsidiaries.
Specific engagement between the Board and the wider 
workforce included meetings and events with:
• representatives of the employee resource groups and each of 
the non-executive Directors who have been partnered to 
support the designated groups: Ability, Balance, Embrace, 
Faith, Generations, Nurture, Pride, and Communities;

• the Nurture employee resource group, which hosted online 

events on domestic abuse and working fathers, during which 
non-executive Directors discussed with a small group of 
employees how the Group had supported them during such 
challenging times and how the Board could promote further 
initiatives; 

• first and second year members of the HSBC graduate 

scheme, who discussed their experiences of hybrid working 
and HSBC's culture, purpose and values;

• US executive management, who held succession and 

emerging talent sessions, and who also discussed our net 
zero ambitions, career pathways, and the delivery of our 
strategy; and 

• African heritage employee resource group leaders, who held a 

roundtable event to discuss inclusivity at work.

HSBC Holdings plc Annual Report and Accounts 2021

233

Corporate governanceReport of the Directors | Corporate governance report

Board activities in 2021

Main topic

Sub-topic

Strategy

Group strategy

Regional strategy/global business strategy

Environmental, social, governance

Business and 
financial 
performance

Financial

Region/global business

Financial performance

Results and accounts

Dividends

Group financial resource planning

Risk

Risk function

Risk appetite

Regulatory

Regulatory and legal matters2 

Capital and liquidity adequacy

Regulatory matters with regulators in attendance3

External

Technology

People and 
culture

Governance

External insights

Strategic and operational

Purpose, values and engagement 

Subsidiary governance framework

Policies and terms of reference

Board/committee effectiveness

Appointment and succession

AGM and resolutions

Meetings at which topics were discussed1

Jan

Feb

Mar

Apr

May

Jun

Jul

Sep

Nov

Dec

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1  No formal Board meetings were held during August and October 2021. 
2 

Includes resolvability assessment framework, modern slavery and human trafficking, statement of business principles and code of conduct, 
regional updates and listing renewals.

3  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.

In 2020, the Nomination & Corporate Governance Committee 
invited Dr Tracy Long of Boardroom Review Limited to support the 
Board with its annual evaluation and to conduct a follow-up 
review on the Board's progress against the findings and 
recommendations from her 2019 report.

In 2021, the Nomination & Corporate Governance Committee 
approved the conducting of an internal evaluation of the Board 
and its committees, with the assistance of an externally facilitated 
questionnaire system managed by Lintstock, an independent 
service provider with no other connection to the Group or any 
individual Director. The questions were designed by the Group 
Company Secretary and Chief Governance Officer and included 
some of the themes addressed by Dr Long's previous reviews, 
namely: leadership, shared perspective, culture, end-to-end 
governance and future thinking. A summary of the effectiveness 
reviews of the Board and the Board committees can be found on 
page 235 and in the respective committee reports on pages 237 to 
267.

To gather qualitative feedback the Group Company Secretary and 
Chief Governance Officer, together with the Deputy Group 
Secretary, conducted one-to-one interviews with all questionnaire 
respondents, including all the Board Directors, regular attendees 
of the relevant meetings and key advisers. The Group Chairman 
and committee chairs also participated in additional discussion 
following the consolidation of feedback in respect of the individual 
committees.

In general, there were consistent findings across the Board and 
committee reviews. These included: a desire to be more forward 
looking; more discussion of contextual matters such as economic, 
social, and geopolitical issues; maintaining a supportive and 
challenging relationship between the Board, its committees and 
senior management; providing clear governance for our 
subsidiaries; and a more consistent approach in leading and living 
the Group purpose and values.

At its January 2022 meeting, the Board considered the findings 
and noted the following areas of focus:  in person Board and 
committee meetings; succession planning; diversity in Board 
composition including the need for more Asian and banking 
experience; prioritising digital opportunities; and more Board 
meeting time dedicated to customers. 

The Group Chairman led a discussion at which the Board agreed 
the actions and priorities to be implemented, which will be 
monitored and addressed on an ongoing basis. Similar discussions 
were carried out by each of the committee chairs in their 
respective January meetings. Progress against these actions will 
be included in the Annual Report and Accounts 2022.

During 2021, a review of the Group Chairman’s performance was 
led by the Senior Independent Director in consultation with the 
other independent non-executive Directors, management and key 
stakeholders. Non-executive Directors also undergo regular 
individual reviews with the Group Chairman. These reviews 
confirmed that the performance of the Group Chairman and each 
Director was effective and that each 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 268.

234

HSBC Holdings plc Annual Report and Accounts 2021

Summary of 2020 Board effectiveness recommendations and actions:

Recommendation from the evaluation

Progress against recommendations

Leadership

• 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.

• 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.

Shared 
perspective

Culture

• 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.

Significant time has been allocated at Nomination & Corporate Governance 
Committee meetings to discuss these items. An additional session was held in 
March to discuss Board and committee composition, and senior executive changes. 
Discussions have included succession candidates at the layer below the GEC, and 
plans to simplify the senior grade structure at managing director level and above.
Progress reports for the Asia talent programme were submitted to Nomination & 
Corporate Governance Committee meetings, with the first received at the May 
meeting.

The Board operating rhythm continues to be effective. Positive feedback from non-
executive and executive Directors confirmed that the Board Oversight Sub-Group is 
valuable for all stakeholders.

We have made use of the expertise and experience of our non-executive Directors 
by rotating attendance at our Board Oversight Sub-Group meetings, according to 
the topic to be discussed.

Regular feedback is sought from members of the GEC and the Board to ensure that 
the Board operating rhythm continues to support the Group's decision making.

The Board Oversight Sub-Group meetings supported both the executive Directors 
and the Board to take strategic decisions in a timely manner, and ensure effective 
use of time in Board meetings. The enhanced strategy was announced alongside the 
2021 interim results, including the Group's proposed disposal of the US retail 
banking franchise.
Cadence of reporting to the Board in support of its oversight of culture was  agreed. 
This takes place twice per year alongside updates on workforce engagement. The 
Board has adopted a 'culture moment' at the beginning of each meeting.

Future thinking

• Maintain and evolve good quality papers 

and presentations to the Board to continue 
providing insight and supporting informed 
decision making

The Group’s new Board paper template and guidance on the most effective writing 
approach has now been implemented across the Board and committee meetings. 
We also provided presenter and chair training to members of the Group Executive 
and wider management.

HSBC Holdings plc Annual Report and Accounts 2021

235

Corporate governanceReport of the Directors | Corporate governance report

Summary of 2021 Board effectiveness recommendations and actions

Findings from the evaluation

Recommendations for action

Composition and 
Board dynamics

Meetings, 
priorities and 
materials

Risk

• The Board's overall skills and capability, and 
diversity and inclusion representation, could 
be improved, particularly with Asian 
background and banking experience.

• Significant collective knowledge of existing 
chairs who are all extremely able and active 
in their roles must be considered as part of 
succession planning.

• Strong relationships exist among Board 

members and senior management with the 
Board providing appropriate challenge and 
support  as necessary. 

• The Board Oversight Sub-Group has been a 

useful forum for Directors and senior 
management to hold discussions in 
advance of Board meetings.

• There is a strong desire to return to in-

•

person meetings. The Group Chairman was 
complimented on his management of 
meetings and Board communication 
throughout the pandemic. 
Increased engagement outside of formal 
meetings with executives and employees to 
aid focused, informed and efficient 
discussion in formal meetings was 
welcomed.

• Board meetings were efficiently and 
effectively managed, in terms of the 
logistics and support, as well as the quality 
of materials which had improved during the 
year as a result of the introduction of the 
new templates. Continuation of that 
improvement would help the effort to 
reduce length, improve timelines and drive 
clarity.

• The Board should build on foundational 

work to date to provide greater clarity on 
climate matters, and more broadly ESG 
issues.

• The Board should increase its focus on 
understanding of – and attention to – 
customers, and also digital opportunities 
and threats.

• Strategic oversight was highly regarded 

overall, with a request for the development 
of Board materials to more easily track 
progress of the strategic priorities. Attention 
to execution, prioritisation, capability and 
capacity were recurring themes.

• The Board oversaw risk matters as part of 
its dedicated sessions but suggested more 
focus on emerging risks and consideration 
of 'what keeps management awake at 
night' with forward-looking discussion and 
debate at Board meetings in addition to at 
the Group Risk Committee.

The Board will support the Nomination & Corporate Governance Committee’s focus 
on identifying and securing additional Board members, reflecting on the 
membership of the committees, and with a particular focus on Hong Kong, 
mainland China and south-east Asian representation, as well as banking expertise 
and diversity. In addition, through the Nomination & Corporate Governance 
Committee, the Board should consider the tenure of the Chairs of the Board, the 
Group Audit Committee and the Group Risk Committee to ensure there is well 
planned succession so as not to lose their collective knowledge and experience 
within too short a space of time. 

The Board will explore different approaches to in-person meetings during 2022 to 
allow members to meet face to face in different locations, and to continue to 
facilitate communication between the Board and management. 

The Board will support an appropriate level of employee and customer engagement 
outside formal meetings while ensuring both receive adequate time on the Board 
agenda.

Senior management will clearly articulate progress against strategic objectives in 
Board materials, particularly in relation to relevant strategic levers and prioritisation. 
The forward agenda planner will capture the key areas of future focus, particularly 
ESG, digital and customer issues. 
The improvement in style and content of Board and committee papers will continue 
in 2022 with the Corporate Governance and Secretariat facilitating management’s 
commitment to improving information to the Board.
A 2022 Board meeting will include digital opportunities and threats as an agenda 
item.

The Board will hold two forward-looking strategic risk discussions per year focused 
on emerging areas of threat and/or opportunity, to ensure that the Board is 
considering how to maximise growth opportunities and appropriate mitigants.

Principal 
subsidiaries

• The Board should continue to evolve good 

quality papers and presentations at 
meetings to continue providing insight, and 
support for, informed decision making.

Through the subsidiary accountability framework, the Board will continue to monitor 
progress of governance of principal subsidiaries and maintain subsidiary director 
interactions through the annual virtual Non-Executive Director Summit.

Committee 
connectivity and 
collaboration

• The Board should look to improve 

coordination between Board committees 
and the Technology Governance Working 
Group to ensure minimal overlap in content 
and optimal coverage of relevant matters, 
and ensure appropriate reporting to the 
Board for discussion.

The Board will undertake a review of the Board committees’ and Technology 
Governance Working Group's terms of reference, with particular reference to 
technology, transformation, data, cyber-related matters and ESG matters. In each 
case, the Board will ensure that there is clarity as to the remit and responsibilities of 
each committee and the Technology Governance Working Group, with a view to 
reducing any duplication and ensuring optimal coverage of relevant matters. 
Enhanced planning will be implemented across Board and committee agendas to 
improve rhythm of topics for discussion by the Board.

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HSBC Holdings plc Annual Report and Accounts 2021

Board committees

Membership

Nomination & Corporate Governance Committee

Member since

Meeting attendance in 
2021

Mark Tucker (Chair)
Laura Cha1
Henri de Castries1
Rachel Duan2
Dame Carolyn Fairbairn2
James Forese

Steven Guggenheimer

Irene Lee

José Antonio Meade 
Kuribreña

Eileen Murray3
Heidi Miller1
David Nish

Jackson Tai

Pauline van der Meer Mohr

Oct 2017

May 2014

Apr 2018

Sep 2021

Sep 2021

May 2020

May 2020

Apr 2018

Apr 2019

Jul 2020

Apr 2018

Apr 2018

Apr 2018

Apr 2016

8/8

4/4

4/4

2/2

2/2

8/8

8/8

8/8

8/8

7/8

4/4

8/8

8/8

8/8

"The Committee has overseen another year of significant activity, 
with a number of changes to the Board and senior executive 
team, as well as to our subsidiary governance practices."

1  Laura Cha, Henri de Castries and Heidi Miller stepped down from the 

Board following the conclusion of the AGM on 28 May 2021.
2  Rachel Duan and Dame Carolyn Fairbairn were appointed to the 

Dear Shareholder

I am pleased to present the Nomination & Corporate Governance 
Committee report, which provides an overview of the work of the 
Committee and its activities during the year. 

The Committee has overseen another year of significant activity, 
with a number of changes to the Board and senior executive team, 
as well as to our subsidiary governance practices. 

Executive development and succession has continued to be a 
priority for the Committee, with various joiners approved 
throughout the year, improving the capability and depth of our 
senior leadership team. This included the approval of a new senior 
leadership structure with an expanded Group Executive 
Committee and a new General Manager cohort with enterprise-
wide responsibilities. The Committee has supported the 
establishment of a flagship development programme for senior 
executives and the first HSBC Bank Director Programme, which 
aims to prepare senior talent for roles on subsidiary boards. 

Significant progress has also been made in enhancing our 
subsidiary governance practices over recent years, with further 
improvements made during 2021. In accordance with the 
recommendation arising from the subsidiary governance review 
undertaken in 2020, we implemented a refreshed subsidiary 
accountability framework, which now applies to all HSBC 
subsidiaries on a proportionate basis and provides greater clarity 
on the Group’s expectations of subsidiary boards. A key element 
of this has been succession planning for our principal and material 
subsidiary boards, with the Committee overseeing all succession 
plans and considering requests for exceptions from the 
requirements of the framework. 

As we look ahead to the remainder of 2022, the Committee will 
continue to play an important role in overseeing our work in 
improving the standards of corporate governance across HSBC 
and achieving our ambition of world class governance. 

Mark E Tucker

Chair

Nomination & Corporate Governance Committee

22 February 2022

Board on 1 September 2021.

3  Eileen Murray was unable to attend the December committee 

meeting for personal health reasons.

Key responsibilities 

The Committee’s key responsibilities include:

• leading the process for identifying and nominating candidates

for appointment to the Board and its committees;

• overseeing succession planning and development for the Group

Executive Committee and other senior executives; and

• overseeing and monitoring the corporate governance

framework of the Group and ensuring that this is consistent
with best practice.

Committee governance

The Group Chief Executive, Group Chief Human Resources Officer 
and Group Company Secretary and Chief Governance Officer 
routinely attended Nomination & Corporate Governance 
Committee meetings.

Russell Reynolds Associates, which supported the Committee and 
the management team in relation to Board and senior executive 
succession planning, regularly attended meetings during the year. 
It has no other connection with the Group or members of the 
Board.

The Group Company Secretary and Chief Governance Officer 
ensured that the Committee fulfilled its governance 
responsibilities, considering input from various stakeholders when 
finalising meeting agendas and tracking progress on actions and 
Committee priorities.

Board composition and succession

The main focus of the Committee during 2021 was on succession 
planning for the Board and committees. The Committee keeps the 
composition of the Board and its committees under constant 
review and continually strives to ensure that the membership, both 
individually and collectively, has the skills, knowledge and 
experience necessary to oversee, challenge and support 
management in the achievement of the Group’s strategic and 
business objectives.

There were a number of retirements from the Board during the 
year, with Henri de Castries, Laura Cha and Heidi Miller retiring at 
the conclusion of the 2021 AGM. In addition, since the year-end, 
we announced that Irene Lee and Pauline van der Meer Mohr 
would retire from the Board at the conclusion of the 2022 AGM. 
The Committee is actively considering Pauline’s successor as 
Chair of the Group Remuneration Committee and will provide an 
update in due course.  

The Committee considered both the short-term and long-term 
succession needs to identify candidates for immediate 

HSBC Holdings plc Annual Report and Accounts 2021

237

Corporate governanceReport of the Directors | Corporate governance report

appointment, and to develop a pipeline for potential future 
appointments. This will ensure that the longer-term shape of the 
Board is well aligned to our purpose, strategy and values, and 
provides relevant skills, experience and knowledge of our priority 
markets. 

In late 2020, the Committee engaged Russell Reynolds Associates 
to conduct a thorough and robust search to identify prospective 
candidates for appointment to the Board. This identified a number 
of potential candidates who met our agreed search criteria, which 
reflected prior feedback from stakeholders including investors, 
regulators and the management team. This was initially reviewed 
by the Group Chairman, with potential candidates presented and 
discussed by the Committee at various meetings during 2021. 
Following consideration by the Committee, and meetings between 
various members of the Committee and priority candidates to 
understand their interest and capacity, the Board approved the 
appointments of Rachel Duan and Dame Carolyn Fairbairn with 
effect from 1 September 2021. 

A search for additional non-executive Director candidates, which 
looks to enhance the Board’s collective knowledge and experience 
of banking and Asia in particular, was initiated during 2021. The 
search will also look to further enhance diversity on the Board in 
line with its diversity and inclusion policy. The Committee’s search 
was again supported by Russell Reynolds. The Committee is 
actively progressing this search and will provide an update in due 
course. 

Board diversity

The Board recognises the importance of gender, social and ethnic 
diversity, and the strengths this brings to Board effectiveness. 
There was a significant focus on diversity at Board and senior 
executive levels in 2021, with consultations issued by our UK 
regulators and the UK Listing Authority. We are well positioned 
against the proposals outlined in those consultations and, in line 
with the Board diversity and inclusion policy, remain committed to 
increasing diversity at Board and senior levels to ensure we reflect 
the markets and societies we serve. The policy, which was 
updated in 2021 to incorporate new targets on female 
representation, details our approach to achieving our diversity 
ambitions, and helps to ensure that diversity and inclusion factors 
are taken into account in succession planning. The revised Board 
diversity and inclusion policy is available at www.hsbc.com/who-
we-are/leadership-and-governance/board-responsibilities.

At the end of 2021, we had a 38% female Board representation, 
with five female Board members out of 13. Our aspirational female 
representative target is at least 40% by the end of 2023, aligned to 
the recommendation in the final Hampton-Alexander Review. We 
continue to exceed the Parker Review target of at least one 
Director from an ethnic minority background by 2021, with four 
members of our Board self-identifying in line with the ethnicity/
ethnic definition set by Parker. Given the global and international 
nature of HSBC, including our strong presence and heritage in 
Asia, the Committee expects the composition of the Board to 
exceed the current Parker Review recommendations. In line with 
our purpose and values, the Board believes that a diverse and 
inclusive Board, reflective of the communities we serve, is key to 
effective decision making and to developing a sustainable and 
successful business for HSBC. 

Further details on activities to improve diversity across senior 
management and the wider workforce, together with 
representation statistics, can be found on page 72.

Independence

Independence is a critical component of good corporate 
governance, and is a principle that is applied consistently at both 
Holdings and subsidiary level. 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 

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HSBC Holdings plc Annual Report and Accounts 2021

after consideration of all relevant circumstances that are likely to 
impair, or could appear to impair, independence. 

Senior executive succession and development

The Group Executive Committee underwent a period of significant 
change during 2021 and engaged Russell Reynolds to identify the 
best talent for roles on the committee. The changes included the 
addition of three new roles, as well as the appointments of new 
Co-Chief Executives for our Asia-Pacific region. These 
appointments recognised the leadership and capabilities that the 
Group requires to deliver our strategic commitments. 

Succession plans for the Group Executive Committee members 
were approved at the Nomination & Corporate Governance 
Committee meeting in December. These reflected continued 
efforts to support the development and progression of diverse 
talent and promote the long-term success of the Group. 

The Committee also discussed progress under the Asia talent 
programme, which aims to support the development of potential 
future leaders from the Group’s key region. The initiative exceeded 
the target of appointing the top talent from the region into stretch 
roles as part of their development. As part of succession plans, we 
also identified at least one credible successor of Asia heritage for 
the region's key roles. Other regions across the Group have begun 
work to replicate the success in Asia, with updates on their efforts 
to be provided to the Committee during 2022. 

Committee evaluation

The annual review of the effectiveness of the Committee was 
internally facilitated in 2021. The review concluded that the 
Committee continued to operate effectively, with a number of 
positive aspects of the Committee’s operation and practices 
highlighted. Areas for improvement that were identified included 
the Committee’s succession planning practices, and the need to 
review the support and guidance provided in relation to executive 
succession activity, including the expectations of leaders in 
relation to succession preparedness. The Committee discussed the 
outcomes of the evaluation in January 2022, and endorsed the 
findings and actions to be taken. The outcomes of the evaluation 
have been reported to the Board and the Committee will track 
progress on the recommendations through the year.

Subsidiary governance

The importance of robust, effective and proportionate governance 
at all levels of the Group is critical, with the 2020 subsidiary 
governance review of principal subsidiaries identifying a number 
of areas of good practice and areas where further improvement 
would be beneficial. 

One of the recommended areas for improvement was a refresh of 
the existing subsidiary governance policy, and the subsidiary 
accountability framework, to provide greater clarity and guidance 
on the Group’s expectations of various subsidiaries. The refreshed 
framework, which included additional principles, underpinned by 
provisions and detailed guidance, took effect from 1 April 2021. 

Subsidiary board composition and ensuring effective succession 
planning practices were key objectives of the refreshed 
framework. The subsidiary governance review also recommended 
that guidance should be developed and enhanced with additional 
provisions to support effective board composition and succession 
planning. It also expected that boards should use a skills matrix. In 
connection with the revised expectations, all principal and material 
subsidiaries submitted their succession plans for the Committee’s 
review. The Committee approved a number of required exceptions 
from strict compliance with the framework to manage transition 
for a limited period, and to reflect varying market practices, laws 
and regulations across our markets. 

As part of efforts to make greater use of the skills, expertise and 
experience among our senior employees for roles on subsidiary 
boards, the Committee approved the development of the HSBC 
Bank Director Programme. This programme seeks to equip our 
internal talent with the appropriate skills and knowledge required 
to serve on a HSBC subsidiary board. The initiative was developed 
following consultation with our principal subsidiary chairs, who 

supported the greater use of an internal talent pool on subsidiary 
boards, where permitted by applicable laws and regulations. 

Business governance review

Following the success of the 2020 review, an equivalent review of 
the executive governance practices across our three global 
businesses, Wealth and Personal Banking, Commercial Banking 
and Global Banking and Markets, was conducted during the fourth 
quarter of 2021. This work had the strong support of the Group 
Executive Committee, and involved desktop reviews, meeting 
observations and interviews.

Overall, the review concluded that the governance of the three 
global businesses operated effectively, and had improved as a 

result of governance simplification initiatives sponsored by the 
Group Executive Committee. The main opportunities for 
improvement related to further simplification of governance 
structures. In particular, the role of the global business governance 
forums within regions and countries will be considered to avoid 
duplication by ensuring that their roles and responsibilities are 
clear and distinct. 

The findings and recommendations from the review were 
discussed and endorsed by the Committee in January 2022, with 
oversight of the actions and next steps to be overseen by the 
respective global business executive committees and the Group 
Executive Committee.

Matters considered during 2021

Board composition and succession

Board composition, including succession planning 
and skills matrices 

Approval of diversity and inclusion 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

Mar

Apr 

May

Jul

Sep

Dec

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HSBC Holdings plc Annual Report and Accounts 2021

239

Corporate governanceReport of the Directors | Corporate governance report

Group Audit Committee

Membership

David Nish (Chair)
James Forese2
Eileen Murray3
Jackson Tai
Pauline van der Meer Mohr4

Member since

Meeting attendance
 in 20211

May 2016

May 2020

Jul 2020

Dec 2018

Apr 2020

11/11

10/11

5/6

11/11

10/11

1  These included two joint meetings with the Group Risk Committee.
2  James Forese was unable to attend one meeting due to extreme 

weather conditions disrupting air travel.

3  Eileen Murray was unable to attend one meeting due to personal 

circumstances and stepped down from the Group Audit Committee 
on 28 May 2021.

4  Pauline van der Meer Mohr was unable to attend one meeting due to 
personal circumstances and another due to a prior commitment. 

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 overseeing its appointment, tenure, rotation,
remuneration, independence and engagement for non-audit
services;

• overseeing the Group’s policies, procedures and arrangements
for capturing and responding to whistleblower concerns and
ensuring they are operating effectively; 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. 

Committee meetings usually take place a couple of days before 
Board meetings 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. The Board also receives copies of the Committee 
agenda and minutes of meetings.

The Group Chief Executive, Group Chief Financial Officer, Group 
Head of Finance, Global Financial Controller, Group Head of 
Internal Audit, Group Chief Risk and Compliance Officer, Group 
Company Secretary and Chief Governance 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 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. 

"In 2021, the Group Audit Committee carried out significant 
development in our internal financial controls and regulatory 
reporting processes to meet a number of challenges."

Dear Shareholder

The Group Audit Committee (‘GAC’) had a busy agenda in 2021.

We carried out significant development in our internal financial 
controls and regulatory reporting processes to help meet the 
challenges of organisational transformation, the continued impact 
of the Covid-19 pandemic, a changing regulatory landscape and 
the growing demand for better and more ESG and climate 
reporting. 

To ensure alignment of priorities and understand local challenges, 
I attended a number of principal subsidiary audit committee 
meetings. These were supplemented with regular communications 
that we cascade through the Group, informal meetings with audit 
committee chairs and a breakout session on key areas for focus at 
the Non-Executive Director Summit in July 2021. 

I regularly met the whistleblowing team to discuss material 
whistleblowing cases and the effectiveness of whistleblowing 
arrangements. The GAC spent significant time considering 
enhancements to whistleblowing arrangements, management's 
responses to internal audit findings and the thematic and cultural 
insights that could be used to improve the speak-up culture.

The Committee received regular updates from the Group Chief 
Financial Officer and the Group Head of Internal Audit on 
functional transformation, its impact on the control environment 
and the capacity and capabilities of the functions. The Committee 
also invited the Global Finance Executive Committee for a private 
session, and I attended a session of the Global Internal Audit 
Executive Committee to discuss key topics and themes from a 
management perspective.   

Recognising the importance of providing enhanced trust in 
reporting to all stakeholders, the Committee provided a detailed 
response to the UK Government's consultation paper on 
‘Restoring Trust in Audit and Corporate Governance’. 

The Committee implemented all the actions from the 2020 
evaluation. The 2021 review determined that the GAC continued to 
operate effectively. 

Eileen Murray stepped down as a member at the 2021 AGM. The 
Committee continues to have a wide range of financial services 
experience and I would like to thank all the GAC members and 
management for their diligent contributions and support to the 
work of the Committee during the year. 

David Nish

Chair, Group Audit Committee, 22 February 2022

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HSBC Holdings plc Annual Report and Accounts 2021

Matters considered during 2021

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

ESG and climate reporting

Regulatory reporting-related matters

Certificates from principal subsidiary audit committees

Control environment

Control enhancement programmes

Group transformation

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

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 and Jackson Tai are 
‘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 GAC Chair had regular meetings with the regulators, including 
the UK’s PRA and the Financial Conduct Authority ('FCA'). These 
included trilateral meetings involving the Group’s external auditor 
PwC.

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. 

How the Committee discharged its 
responsibilities

Connectivity with principal subsidiary audit committees

The Committee maintains a close working relationship with the 
principal subsidiary audit committees through formal and informal 
channels. 

On a half-year basis, principal subsidiary audit committees provide 
certifications to the GAC regarding the preparation of their 
financial statements, adherence to Group policies and escalation 
of any issues that require the attention of the GAC. Recognising 
the additional focus on prudential regulatory reporting, the GAC 
sought additional information via these certifications regarding the 
governance, review and assurance activities undertaken by the 
principal subsidiary audit committees in relation to prudential 
regulatory reporting. 

The GAC Chair regularly met with the chairs of the principal 
subsidiary audit committees, and attended meetings to enable 
close links and deeper understanding on judgements around key 
issues. Certain chairs and audit committee members from the 
principal subsidiary audit committees were also invited to attend 
meetings of the GAC on relevant topics. 

At the Non-Executive Director Summit, the GAC Chair engaged 
with a number of subsidiary non-executive Directors in a breakout 
session to discuss key focus areas, including regulatory reporting, 
ESG and climate reporting and whistleblowing arrangements. 

Jan

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Regular post-meeting communications to principal subsidiary 
audit chairs were supplemented with informal quarterly catch-ups 
with a group of the audit committee chairs. These provided 
opportunities for the discussion of key matters impacting 
subsidiaries and the Group in between formal meetings. 

Internal controls 

In 2021, the GAC devoted significant time in overseeing 
management’s approach to enabling a sustainable transformation 
of the control environment that supports financial, prudential 
regulatory and other regulatory reporting to meet the evolving 
expectations of regulators and other stakeholders. The programme 
will drive end-to-end organisational alignment so that principles 
and control standards can be designed to deliver a more 
integrated, standardised and automated control environment. The 
Committee received regular updates on the mobilisation of the 
programme workstreams, resourcing and engagement throughout 
the Group and with regulators. The oversight and implementation 
of the programme and its component parts will be a key focus for 
the Committee in 2022. 

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. For further details 
on how the Board reviewed the effectiveness of key aspects of 
internal control, see page 291.

As required by the Sarbanes-Oxley Act, the GAC received updates 
on the Group's work on section 404 compliance and the Group's 
broader financial control environment during the year. This was to 
assess the effectiveness of the internal control system for financial 
reporting and any developments affecting it. Based on this work, 
the GAC recommended that the Board support the assessment of 
the internal controls over financial reporting.  

Financial reporting

The Committee is responsible for reviewing the Group’s financial 
reporting during the year, including the Annual Report and 
Accounts, Interim Report, quarterly earnings releases, analyst 
presentations and, where material, Pillar 3 disclosures and other 
items arising from the review of the Group Disclosure Committee. 
As part of its review, the GAC:

• evaluated management’s application of critical accounting
policies and material areas in which significant accounting
judgements were applied;

HSBC Holdings plc Annual Report and Accounts 2021

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Corporate governanceReport of the Directors | Corporate governance report

• focused on compliance with disclosure requirements to ensure
these were consistent, appropriate and acceptable under the
relevant financial and governance reporting requirements;

discussed the positions taken, and the risks associated with the 
policy, as well as the methodology for capturing and reporting the 
emissions data across the financing portfolio. 

• provided advice to the Board on the form and basis underlying

Regulatory reporting

the long-term viability statement; and

• 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.

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.

Fair, balanced and understandable 

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, including 
in relation to the increasingly important ESG considerations. 

The Committee reviewed the draft Annual Report and Accounts 
2021 and results announcements to enable input and comment. It 
was supported by the work of the Group Disclosure Committee, 
which also reviewed and assessed the Annual Report and 
Accounts 2021 and investor communications.

This work enabled the GAC to provide positive assurance to the 
Board to assist them in making the statement required in 
compliance with the 2018 UK Corporate Governance Code.

ESG and climate reporting

During the year, the GAC reviewed the strategy, scope and status 
of ESG and climate reporting, including the climate change 
resolution and scenario analysis disclosure. Management updates 
were also informed by an HSBC-specific stakeholder feedback 
survey, which highlighted the appetite for more detailed ESG 
disclosures on climate metrics, emissions targets and plans on 
how these would be achieved. The Committee considered the 
operational, disclosure and litigation risks, which could arise from 
making further external commitments related to ESG and climate 
reporting.  

The development of methodologies, tools and data to support our 
ESG strategy remained a key challenge. The GAC discussed 
management plans to enhance and assure internal and external 
ESG data sourcing across the Group to develop a common ESG 
data inventory. The Committee considered the approach to 
subsidiary reporting, in particular the availability of granular data 
to support the Group subsidiaries in fulfilling their mandatory 
disclosure requirements. 

Management updated the Committee on the verification and 
assurance framework to ensure that ESG and climate disclosures 
were materially accurate, consistent, fair and balanced. The GAC 
discussed the roles and work of the three lines of defence as part 
of this framework, as well as proposals for PwC to perform further 
limited assurance over specific ESG-related metrics.

The Committee oversaw and challenged management on the 
proposals to further expand the ESG review section of the Annual 
Report and Accounts to incorporate additional disclosures. These 
include the integration of TCFD disclosures, which were previously 
published in a stand-alone supplement, and net zero disclosures in 
relation to the special shareholder resolution on climate change.  

The GAC and the GRC held a joint meeting to review the progress 
made to deliver on the commitment – under the climate change 
special resolution – to publish a policy to phase out the financing 
of coal-fired power and thermal coal mining. The committees 

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HSBC Holdings plc Annual Report and Accounts 2021

The GAC focused on what improvements were required to 
regulatory reporting processes and controls, which were operating 
outside the Board’s risk tolerance. The Committee continued to 
focus heavily on the quality and reliability of regulatory reporting 
to strengthen the end-to-end processes to meet regulatory 
expectations. It also challenged management on the scope of the 
regulatory reporting enhancement programmes. This was in 
response to findings from HSBC-specific external reviews and 
other regulatory pronouncements including the PRA's ‘Dear CEO’ 
letter on thematic findings on the reliability of regulatory reporting 
across the industry. The Committee Chair invited certain principal 
subsidiary audit committee members to GAC meetings to 
participate in discussions to ensure alignment and understanding 
of key issues and ongoing regulatory engagement. 

Management discussed root cause themes, remediation of known 
issues and areas of increased risk identified from the risk-based 
read-across exercise. The Committee considered the near-term 
actions being taken by management, as well as the strategic 
remediation plan, including the costs, resources and time for 
implementation. It also challenged management on the delivery 
risks and the dependency on other ongoing programmes. 

Management also highlighted potential impacts on some of the 
Group's regulatory ratios, such as CET1 and LCR, and adjustments 
required to external disclosures.

UK audit reform

The Committee spent significant time in reviewing a UK 
Government consultation paper – from the Department of 
Business,  Energy and Industrial Strategy – on ‘Restoring Trust in 
Audit and Corporate Governance’. The GAC oversaw the 
development of the direct HSBC response to the consultation, as 
well as management’s engagement across a number of industry 
bodies to understand wider views. 

In addition, the Committee discussed the management activities 
being undertaken in preparation for future stages of the 
consultation. The GAC took steps to review its audit and 
assurance policy and expand assurance in certain areas, 
particularly regulatory reporting and ESG. The Committee also 
considered the impact on the future audit tender strategy, and will 
be looking to tender in advance of the 10-year rotation point. The 
Committee has proactively started engagement with the Big Four 
and challenger audit firms, as part of its preparations. 

The Committee will continue to monitor outcomes and next steps 
arising from the UK Government’s consultation. 

External auditor 

The GAC has the primary responsibility for overseeing the 
relationship with the Group’s external auditor, PwC.

PwC completed its seventh audit, providing robust challenge to 
management and sound independent advice to the Committee on 
specific financial reporting judgements and the control 
environment. 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 audit, including observations on 
the control environment. Key audit matters discussed with PwC 
are set out in its report on page 298.

External audit plan

The GAC reviewed the PwC external audit approach, including the 
materiality, risk assessment and scope of the audit. The 
Committee invited a number of the principal subsidiary audit 
partners to discuss their priorities as part of the review of the 
external audit plan. 

PwC highlighted the changes being made to their approach to 
enhance the quality and effectiveness of the audit. Changes for the 
2022 audit included more auditing being performed centrally 

across legal entities and the increased use of technology solutions, 
some of which are aligned to technology change and 
transformation activities across HSBC. 

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.

Effectiveness of external audit process

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. PwC 
highlighted the actions being taken in response to the HSBC 
effectiveness review, including the development of audit quality 
indicators, which would provide a balanced scorecard and 
transparent reporting to the GAC. These focused on the following 
areas:

• findings from inspections across the Group on PwC as a firm;

• the hours of audit work delivered by senior PwC audit team
members, the extent of specialist and expert involvement,
delivery against agreed timetable and milestones and the use of
technology;

• any new control deficiencies in Sarbanes-Oxley locations,

proportion of management identified deficiencies and delivery
of audit deliverables to agreed timelines; and

• outcomes and scores from annual audit surveys, independent

senior partner reviews and prior period errors.

The GAC will continue to receive regular updates from PwC and 
management on the progress of the external audit plan and PwC 
performance across the audit quality indicators. 

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.

Independence and objectivity

The Committee 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 and applicable rules and regulations, provided 
the GAC with written confirmation of its independence for the 
duration of 2021. 

The Committee confirms it has complied with the provisions of the 
The Statutory Audit Services for Large Companies Market 
Investigation (Mandatory Use of Competitive Tender Processes 
and Audit Committee Responsibilities) Order 2014 for the financial 
statements. The Committee acknowledges the provisions 
contained in the 2018 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 in 
2021 as a change in auditor would have a significant impact on 
the organisation, including on the Global Finance function and 
would increase operational risk. In 2021, the Committee's priority 
was to monitor closely the ongoing industry developments and 
proposals on reform of the UK external audit market and the 
impact this may have on any tender process. As a result, the 
Committee has commenced planning for the next tender process 
in advance of the 10-year re-tender period, likely to take place no 
later than early 2023. 

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 2022 will be proposed 
to shareholders at the 2022 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. The 
non-audit services are carried out in accordance with the external 
auditor independence policy to ensure that services do not create 

During the period, it was identified that PwC provided an 
impermissible training service via a publicly available seminar in 
respect of the implementation of a new Indonesian IT security 
regulation. The attendees at this seminar included six members of 
staff from HSBC Indonesia. The HSBC staff who attended the 
course were not from the Finance function and were not in roles 
relevant to the audit. In addition, HSBC Indonesia is not within the 
scope of the Group audit. In light of the nature and scope of the 
original service and the mitigating factors mentioned above, we do 
not believe that the provision of the service has affected PwC’s 
professional judgement or integrity in respect of the audit of the 
Group. Mitigating actions have been implemented by both PwC 
and HSBC to reinforce the controls around the provision of non-
audit services by PwC, including additional independence training 
and improved communication between relevant parties.

The non-audit services carried out by PwC included 69 
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.

Ten 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, including the provision of services by PwC relating 
to the Section 166 Financial Services and Markets Act 2000 Skilled 
Person report. The PRA instructed a Section 166 review of HSBC's 
credit risk RWAs as reported at 31 December 2020 and agreed for 
PwC to provide a reasonable assurance opinion on the accuracy of 
the regulatory reporting at that date. 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

2021

$m

129.4 

41.3 

2020

$m

130.2 

37.3 

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 Internal Audit reports to the Chair of the GAC 
and there are frequent and regular meetings held between them. 
Results of audit work, together with an assessment of the Group’s 

HSBC Holdings plc Annual Report and Accounts 2021

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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, and the output from 
continuous monitoring. This includes business and regulatory 
developments and an independent view of emerging and horizon 
risk, together with details of audit coverage and any required 
changes to the annual audit plan. 

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 2021 audit coverage were strategy, governance and 
culture, financial crime, conduct and compliance, financial 
resilience and operational resilience. In 2021, Global Internal Audit 
increased coverage on the Group’s transformation programme and 
performed project audit activity for selected complex and high-
priority business cases. Global Internal Audit also continued its 
'real-time audit' approach, notably to cover areas of strategic 
importance. 'Real-time audits' provide real-time, independent 
ongoing observations to management, with issues being raised for 
significant observations that are not addressed in a timely manner. 
In addition, in 2021, Global Internal Audit implemented its revised 
'culture audit' approach which assesses the impact of culture in 
supporting or inhibiting sustainable performance against strategic 
aspirations and managing risk within risk appetite. The approach 
combines internal audit and behavioural science principles, which 
align to regulator culture assessments and industry best practice.

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 2022 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 annual plan. Risk theme categories for the 2022 
audit work continue to be strategy, governance and culture, 
financial crime, conduct and compliance, financial resilience and 
operational resilience. In 2022, a quarterly assessment of key risk 
themes will form the basis of thematic reporting and plan updates 
and will ultimately drive the 2023 planning process. The annual 
audit plan and material plan updates made in response to changes 
in the Group’s structure and risk profile are approved by the GAC.

Based on regular internal audit reporting to the GAC, private 
sessions with the Group Head of Internal 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 2021

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. 

Areas of joint focus for the GAC and GRC during 2021 were:

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HSBC Holdings plc Annual Report and Accounts 2021

Sustainable control environment

As discussed in the ‘Internal controls’ section of this report, the 
GAC oversaw management’s approach to create a sustainable 
transformation of the control environment. The programme, and 
its impact on the internal control environment as a whole, was 
also discussed by the GRC. 

In conjunction with the GRC, the GAC monitored the remediation 
of significant deficiencies and weaknesses in 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 
framework as part of the sustainable control environment 
programme. The committees will also continue to monitor the 
regulatory reporting enhancements programmes to bring 
regulatory reporting processes within the risk appetite. 

In 2021, the GAC and GRC Chairs worked closely with the Group 
Chief Risk and Compliance Officer and the Group Head of Internal 
Audit to:

• ensure that risks and issues highlighted at the GAC from audit

reports were appropriately captured and reported as part of the
wider internal controls discussion at the GRC; and

• coordinate the approach and oversight required for the

remediation of very high risk and high risk issues identified by
Global Internal Audit, as well as the establishment of a single
repository of issues across HSBC.

The GAC and the GRC also held a joint meeting to consider data 
strategy and data management. Further details can be found in the 
GRC report on page 250.

Financial reporting

In addition to the GRC’s overall review of the Group’s risk appetite 
and risk management framework, the GAC gave particular focus 
to risk measures impacting financial reporting. This included the 
review of the financial reporting, tax and pension risk appetite 
statements. The GAC and the GRC also considered how the 
approach to financial reporting risk appetite could be evolved to 
drive a reduction in the exposure to this risk over the medium term 
and provide better visibility to financial and prudential regulatory 
reporting separately. 

The committees worked collaboratively in reviewing ESG and 
climate risks, as well as the financial and regulatory reporting 
impacts. For further details, see the 'ESG and climate reporting’ 
section of this report on page 80. 

Given the continued impact from the Covid-19 pandemic, the GAC 
and the GRC reviewed the risks arising from models used for the 
estimation of expected credit losses under IFRS 9. 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. 

Whistleblowing and speak-up culture

An important part of HSBC's values is ensuring that colleagues 
have the confidence to speak up when they observe unlawful or 
unethical behaviour. HSBC provides a variety of channels for 
colleagues to raise concerns, including through the Group’s 
whistleblowing channel, HSBC Confidential (see page 87 for 
further information). The GAC is responsible for the oversight of 
the effectiveness of the Group’s whistleblowing arrangements. 
The Group Head of Compliance 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 Conduct, Policy and Whistleblowing 

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 2021, including: enhancements made to the Group’s 
whistleblowing arrangements following an external benchmarking 
assessment in December 2020; completion of actions arising from 

Global Internal Audit reviews; and details of key emerging conduct 
themes across the arrangements. During 2022, the Committee will 
be provided with updates on how whistleblowing arrangements 
are actively supporting our purpose and values, and conduct 
approach.

Principal activities and significant issues considered during 2021

Areas of focus

Key issues

Conclusions and actions

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 
enhance ESG disclosures and associated 
verification and assurance activities. The GAC 
reviewed the 2021 ESG disclosure approach in line 
with our external commitments.

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.

Expected credit losses
The measurement of expected credit losses involves 
significant judgements, particularly under current 
economic conditions. Despite a general recovery in 
economic conditions in 2021, there remains an 
elevated degree of uncertainty over ECL estimation 
under current conditions, due to macroeconomic, 
political and epidemiological uncertainties.

Goodwill, other non-financial assets and 
investment in subsidiaries impairment
During the year, management tested for impairment 
goodwill, other non-financial assets and 
investments in subsidiaries. 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 $0.6bn impairment in relation to 
goodwill and an impairment reversal of $3.1bn in 
investments in subsidiaries.

Financial and 
regulatory 
reporting

Significant 
accounting 
judgements

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. 

In relation to our climate change resolution, particular attention was given to the 
disclosure of the financed emissions. The Committee reviewed the ESG reporting 
strategy, including the broadening of ESG coverage in the Annual Report and 
Accounts and management’s approach on integrated reporting, which will be 
further informed by feedback from external stakeholders.

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 GAC reviewed the economic scenarios for the key countries in which the 
Group operates, and challenged management's judgements as to the weightings 
assigned to these scenarios. The GAC also challenged management's approach to 
making management adjustments to account for the uncertainty in outcomes 
arising from Covid-19 and China commercial real estate,, including the rationale 
for such adjustments, the controls underpinning the adjustment processes, and 
under what conditions such adjustments could be reduced or removed. The GAC 
also challenged management on the overall levels of ECL across portfolios, 
including looking at historical performances of portfolios and peer group 
comparisons.

The GAC received reports on management's approach to goodwill, other non-
financial assets and investments in subsidiaries impairment testing and 
challenged the approach and methodologies used,with a key focus on the 
cashflows included within the forecasts and the discount rates 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.

Associates (Bank of Communications Co., 
Limited)
During the year, management performed the 
impairment review of HSBC’s investment in Bank of 
Communications Co., Ltd (‘BoCom’). The 
impairment reviews are complex and require 
significant judgements, such as projected future 
cash flows, discount rate, and regulatory capital 
assumptions.

The GAC reviewed the judgements in relation to the impairment review of HSBC’s 
investment in BoCom, 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 model’s sensitivity to long-term 
assumptions including the continued appropriateness of the discount rates. The 
GAC also challenged management to review all aspects of its approach to 
accounting for BoCom to ensure the approach remains the most appropriate in 
terms of accounting judgements including compliance with the relevant 
accounting requirements. 

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.

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 agrees with the conclusions reached by 
management.

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Principal activities and significant issues considered during 2021 (continued)

Areas of focus

Key issues

Conclusions and actions

Significant 
accounting 
judgements

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 ongoing volatile market conditions in 
2021, management continuously refined its 
approach to valuing the 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 IFRSs.

Long-term viability and going concern 
statement
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 pandemic continues to have 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.

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.

Impact of acquisitions and disposals
In 2021, HSBC engaged in a number of business 
acquisition and disposal activities, notably in the 
US, France, Singapore and India. There are a 
number of accounting impacts that need to be 
considered, including the timing of recognition of 
assets held-for-sale, gains or losses, and the 
measurement of assets and liabilities on acquisition 
or disposal.

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.

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 considered the recoverability of deferred tax assets, in particular in the 
US, France 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 the impacts of the planned exits of the French and US retail 
banking businesses and the timing of the accounting recognition of these 
transactions. The GAC also considered the financial and accounting impacts of 
other acquisitions and disposals.

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HSBC Holdings plc Annual Report and Accounts 2021

Principal activities and significant issues considered during 2021 (continued)

Areas of focus

Key issues

Conclusions and actions

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

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.

The Committee received regular updates on the Group transformation programme 
– and the broader change framework – to review the impact on the risk and
control environment and to oversee progress of the transformation programme. In
these updates, the Committee monitored the progress of the programme, and
focused on the implementation of the new change framework and the
management of the entire change portfolio. This oversight helped the Committee
to understand the key improvements being made to the management of the
change portfolio, and progress on the implementation.

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 2021, 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 make use of 
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 has received regular status updates on the progress of the Global 
Finance transformation, the outcomes achieved to date and challenges 
encountered. The Committee has continued to dedicate significant time to the 
review of the progress of the programme. 

A key objective of the programme is to improve the Group’s control environment 
and a particular focus of the Committee has been the interaction of the Global 
Finance transformation programme and the programmes to enhance the Group’s 
regulatory reporting control environment. The Committee has also considered the 
dependencies that key regulatory change programmes, such as the Basel III 
Reform programme, have on the Global Finance transformation. In addition, the 
Committee has specifically sought to understand the impact of new requirements 
and programme re-planning on the delivery and timing of programme outcomes. 
Sessions have been held with individual Committee members to support a more 
detailed understanding of the programme risks and challenges.

The results of Global Internal Audit reviews of the programme have been 
considered by the Committee and there have been frequent discussions with 
Global Internal Audit on its assessment of the progress and risks of the 
programme.

The Group Chief Financial Officer had private sessions with the Committee to 
share his perspectives on the progress of the Global Finance transformation and 
where additional focus was required. 

Earlier in 2021, management provided an update on the potential impact of IFRS 
17 on HSBC’s reported numbers in the financial statements, and conducted a 
walk-through of the relevant disclosure requirements applicable to HSBC, 
including an introduction to GAAP and potential non-GAAP metrics to support 
investor communications during and after the transitional period. In response to 
questions from GAC members, including from the Chair, relating to the overall 
financial management of the insurance business, a separate session was 
organised with the Chair of the GAC on 16 June 2021. The meeting covered 
different aspects of insurance financial management, with a particular focus on 
interest rate management and business strategy. Since then, HSBC released 
further information on the impact of IFRS 17 on HSBC’s reported numbers, as part 
of the third quarter 2021 earnings release statement, as well as providing a 
briefing to analysts on IFRS 17. Feedback from analysts so far has been positive, 
particularly given HSBC was the first to provide high-level indicative impact based 
on planning assumptions. In December 2021, management provided an update 
on the disclosure of performance metrics on adoption of IFRS 17, including its 
current intention to continue to provide Value of New Business and embedded 
value metrics for comparability. 

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 the Covid-19 pandemic.

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Principal activities and significant issues considered during 2021 (continued)

Areas of focus

Key issues

Conclusions and actions

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.

Regulatory 
change

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 we were ready to migrate and able to  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 2021. Led by the 
Group Company Secretary and Chief Governance Officer, the 
review concluded that the GAC continued to operate effectively. 
Management of meetings and reporting to the Board on 
discussions, in particular, were rated highly.

The review also made certain recommendations for continual 
improvement. The GAC was recommended to review the 
composition of the GAC to broaden the skillset, ensure clarity in 
roles and improve the coordination between the GAC and other 
Board committees and working groups relating to technology and 
ESG. Succession planning was also highlighted as a priority. The 
Committee considered the outcomes of the evaluation and 
accepts the findings. The evaluation outcomes were reported to 
the Board and the Committee will track progress against the 
recommendations during 2022. 

At the beginning of each year, the Committee discusses its key 
priorities for the year ahead. In 2022, the Committee will continue 
to focus strongly on the remediation of controls, particularly those 
supporting regulatory reporting. The Committee will continue to 
monitor the execution of the Group's transformation programme 
and its impact on the risk and control environment. It will also 
monitor the interdependencies between the transformation 
programme and the implementation of large-scale regulatory 
change programmes, such as the Basel III reforms, the Ibor 
transition and IFRS 17 'Insurance Contracts'. A key priority will be 
to further embed ESG and climate-related disclosures to meet 
increasing expectations of stakeholders, in particular the 
implementation of robust processes and controls to support these 
disclosures. The Committee will focus on the audit tender strategy 
in preparation for the next re-tender, and will consider the impact 
of potential changes to the UK external audit market on HSBC's 
approach to audit and assurance.

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HSBC Holdings plc Annual Report and Accounts 2021

Group Risk Committee 

Membership

Member since

Meeting attendance 
in 20211

Jackson Tai (Chair)
Dame Carolyn Fairbairn2
Steven Guggenheimer

José Antonio Meade Kuribreña
Heidi Miller3
Eileen Murray4
David Nish5
Pauline van der Meer Mohr6

Sep 2016

Sep 2021

May 2020

May 2019

Sep 2014

Jul 2020

Feb 2020

Apr 2018

11/11

3/3

11/11

11/11

6/6

9/11

10/11

5/6

1  These included two joint meetings with the Group Audit Committee.
2  Dame Carolyn Fairbairn joined the GRC on 1 September 2021.
3  Heidi Miller stepped down from the GRC on 28 May 2021.
4  Eileen Murray was unable to attend two meetings due to personal 

circumstances.

5  David Nish was unable to attend one meeting due to a prior 

commitment.

6  Pauline van der Meer Mohr was unable to attend one meeting due to 
personal circumstances, and stepped down from the GRC on 28 May 
2021.

"The GRC provided oversight on the management of Covid-19-
related financial risks, including the Group's release of expected 
credit loss reserves in response to the improving macroeconomic 
conditions."

Dear Shareholder

Key responsibilities

I am pleased to present the Group Risk Committee (‘GRC’) report.

The year commenced with a challenging risk outlook due to 
increasing Covid-19 infections and lockdowns across markets. The 
outlook began to stabilise by the second quarter, with the roll-out 
of global vaccine programmes, and the GRC monitored the impact 
of new strains, including the Omicron variant.

Against this backdrop, the GRC provided oversight on the 
management of Covid-19-related financial risks, including the 
Group’s release of expected credit loss reserves in response to the 
improving macroeconomic conditions. The Committee worked 
closely with the Group Chief Risk and Compliance Officer in 
strengthening the Group’s risk management framework to be even 
more forward looking, granular and risk connected. The GRC 
continued its oversight of people and operational challenges 
presented by the pandemic and market conditions.

Throughout the year, the GRC played a central role in reviewing 
and challenging management on the Group’s regulatory 
submissions and programmes, including the Bank of England's 
requirements for the resolvability assessment framework. The GRC 
had primary non-executive responsibility for reviewing the 
outcomes of regulatory stress tests, including the Bank of 
England's biennial exploratory scenario on the financial risk from 
climate risk, and the 2021 solvency stress test. The GRC reviewed 
and challenged the Group’s thermal coal phase-out policy and 
approach to climate-aligned finance in a joint meeting with the 
GAC. The Committee continued its oversight of the Group’s 
preparations to meet the PRA’s requirements on operational 
resilience. 

The GRC continued to strengthen its composition, skills and 
experience to ensure that it remains well positioned to promote 
proactive risk governance. On 1 September 2021, we welcomed 
Dame Carolyn Fairbairn, a seasoned macroeconomic and political 
environment expert. Heidi Miller and Pauline van der Meer Mohr 
left the GRC on 28 May 2021. I extended our gratitude to each for 
their valued commitments and support to the GRC.

The GRC convened 11 formal meetings, two of which were joint 
meetings with the GAC, and 13 education and special meetings to 
review and challenge some of our most important responsibilities.

The GRC has overall non-executive responsibility for the oversight 
of risk-related matters and the risks impacting the Group. The 
GRC’s key responsibilities are:

• 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;

• advising the Board on risk appetite-related matters, and key

regulatory submissions;

• reviewing the effectiveness of the Group’s enterprise risk

management framework and internal controls systems (other
than internal financial controls overseen by the GAC); and

• reviewing and challenging the Group's stress testing exercises.

Committee governance

The Group Chief Risk and Compliance Officer, Group Chief 
Financial Officer, Group Chief Operating Officer, Group Company 
Secretary and Chief Governance Officer, Group Chief Legal Officer, 
Group Head of Internal Audit, Group Head of Finance and Group 
Head of Risk Strategy are standing attendees and regularly attend 
GRC meetings to contribute their subject matter expertise and 
insight. The Chair and members of the GRC also hold private 
meetings with the Group Chief Risk and Compliance Officer, the 
Group Head of Internal Audit and external auditor, PwC, following 
scheduled GRC meetings.

The participation of our senior business leaders, including the 
Group Chief Executive who attended 9 GRC meetings in 2021, 
reaffirmed the ownership and accountability of risks in the first line 
of defence and strengthened our holistic three lines of defence 
review of our most pressing risks.

The Chair meets regularly with the Group Chief Risk and 
Compliance Officer to discuss priorities, track progress on key 
actions and plan GRC meeting agendas. 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 meets regularly with the GRC Secretary and other 
members of the Corporate Governance and Secretariat to ensure 
the GRC meets its governance responsibilities, and to consider 
input from stakeholders when finalising meeting agendas, tracking 
progress on actions and GRC priorities. A summary of coverage is 
set out in the 'Matters considered during 2021' table on page 250.

Jackson Tai

Chair

Group Risk Committee

22 February 2022

HSBC Holdings plc Annual Report and Accounts 2021

249

Corporate governanceReport of the Directors | Corporate governance report

Matters considered during 2021

Financial risk

Credit risk

Climate risk

IT and operational risk including outsourcing, 
third-party risk management, cyber risk      

Model risk  

People and conduct risk

Risk appetite

Financial crime risk

Regulatory compliance

Legal risk  

Jan

Feb

Mar

Apr

May

Jun

Jul

Sep

Nov

Dec

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How the Committee discharged its 
responsibilities

Activities outside formal meetings

The GRC held a number of meetings outside its regular schedule 
to facilitate more effective oversight of the risks impacting the 
Group. In particular, Directors’ education meetings and GRC 
Chair’s preview meetings strengthened the understanding of more 
technical topics and promoted constructive challenge. Areas 
covered included stress testing, ICAAP and ILAAP preparations, as 
well as recovery and resolution planning. Further details on these 
sessions are included in the 'Principal activities and significant 
issues considered during 2021' table starting on page 251.  

Connectivity with principal subsidiary risk committees 

During 2021 the GRC continued to actively engage with principal 
subsidiary risk committees through the scheduled participation of 
principal subsidiary risk committee chairs at GRC meetings, and 
through two connectivity meetings with the principal subsidiary 
risk committee chairs. This participation and connectivity 
promoted the sharing of information and best practices between 
the GRC and principal subsidiary risk committees.

The GRC also received reports on the key risks facing particular 
principal subsidiaries at its regular meetings and continued to 
review certifications from the principal subsidiary risk committees. 
The 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 and that the risk 
management and internal control systems have been operating 
effectively. 

The principal subsidiary risk committee chairs have attended 
regular GRC meetings, education meetings and special review 
meetings. The engagement facilitated the GRC’s holistic review of 
regulatory submissions including stress tests, the Group recovery 
plan and the resolution self-assessment. The interactions furthered 
the GRC’s understanding of the risk profile of the principal 
subsidiaries, leading to more comprehensive review and challenge 
by the GRC. 

Collaborative oversight by the GRC and the GAC

The GRC collaborated with the GAC to address any areas of 
significant overlap and to oversee risk more comprehensively, 
through inter-committee communication and joint meetings. The 
GRC and GAC Chairs are members of both committees to 
strengthen connectivity and the flow of information between the 
committees.

Joint meetings with the GAC

The GRC and the GAC convened a meeting on data strategy and 
data management in April 2021, with the attendance and support 
of the Group Chief Executive and the chief executive officers of the 
three global businesses. The committees reviewed the Group’s 
data strategy and the work required to embed its data policies, 
define its technology landscape and build a data-led culture. The 
committees challenged the first and second lines of defence on 

how they are pursuing a data-driven strategy across four key areas 
for the Group. In the process the committees reviewed the 
regulatory landscape in relation to the Group's use of data, and the 
roles of the first and second lines of defence as co-owners of the 
management of data risk. The committees also reviewed the 
Group's approach to harnessing and using data to better unlock 
value for our customers. 

The GRC and the GAC convened a joint meeting in November 
2021 to review HSBC's thermal coal phase-out policy and the 
Group's approach to climate-aligned finance. The committees 
reviewed the progress made to deliver on the commitment to 
publish a policy to phase out the financing of coal-fired power and 
thermal coal mining by 2030 in EU/OECD markets, and by 2040 in 
other markets. The committees recommended the thermal coal 
phase-out policy and the approach to climate-aligned finance to 
the Board for approval.

Sustainable control environment 

The GRC continued to review and challenge the Group’s internal 
controls to improve the control environment. The GRC reviewed 
entity level controls, which form the basis of HSBC’s control 
environment, as well as the results and remediation plans of a self-
assessment performed by entity level control owners. At the 
request of the GRC Chair, with support of the GAC Chair, the GRC 
received an update on the thematic analysis and remediation plans 
for any overdue very high risk and high risk issues identified by 
Global Internal Audit. 

Financial risk 

During 2021, the GRC and the GAC reviewed and challenged the 
Group’s risk appetite and risk management framework relating to 
financial risk. In the process the committees discussed risk 
tolerance for financial reporting risk and financial reporting and tax 
risk, as well as improvement and remediation plans to enhance the 
broad regulatory reporting control environment.

Collaborative oversight by the GRC and the Technology 
Governance Working Group

The GRC worked closely with the Technology Governance 
Working Group to ensure appropriate alignment in the review, 
discussion, challenge and conclusions on technology risk-related 
matters. The GRC organised a technology-specific session with the 
working group in advance of the broader discussion at the joint 
GRC and GAC meeting on data strategy and data management. 
This ensured that the GRC benefited from the working group’s 
expertise and challenge in advance of the GRC and GAC 
discussion. The GRC also arranged for the Technology Governance 
Working Group Co-Chairs to lead discussions on data, models and 
infrastructure at the GRC climate biennial exploratory scenario pre-
meetings.

Coordination and collaboration between the GRC and the 
Technology Working Group is supported by cross-membership. 
The GRC Chair is a member of the Technology Working Group and 
the Co-Chairs of the Technology Working Group are members of 
the GRC. 

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HSBC Holdings plc Annual Report and Accounts 2021

Principal activities and significant issues considered during 2021

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, the Group's 
capacity and capabilities to support customers, 
and the pursuit of strategic goals.

Risk appetite

The GRC maintained oversight of changes to the Group’s risk appetite statements, 
which in turn provided the basis for the Committee’s regular interactive review of 
financial and non-financial management information at each GRC meeting. The GRC 
continued to promote the development of more granular risk appetite statements 
that are more forward looking and risk responsive. The Committee continued to 
strengthen the linkage between risk appetite statements with the Group’s corporate 
strategy, stress testing, annual operating plan, as well as the Group's move towards 
stronger, sustainably higher returns for stakeholders, so that it may serve customers 
well. In January 2021, the GRC recommended the Group’s climate risk appetite 
statement to the Board for approval. It also recommended significant changes to the 
Group’s risk appetite statement, including in the areas of liquidity risk, wholesale 
credit risk metrics, climate risk, model risk, resilience risk, financial crime risk and 
regulatory compliance.    

Geopolitical 
developments 
and risks

Geopolitical developments and risks continue to 
present significant challenges for the Group’s 
customer franchise and for the resilience of our 
operations.

The GRC continued to monitor global geopolitical risks that could impact the 
Group’s strategy, business performance or operations, including trade tensions 
between the US and China and the related regulatory and reputational risks for 
operations globally. 

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 pandemic.

Managing 
through the 
Covid-19 
pandemic

Management’s operational resilience programme 
defines the Group’s policies and practices to 
strengthen its ability to protect customers. The 
programme identifies priority business services 
and their readiness to serve customers in the 
event of unforeseen disruptions in key markets. 

Operational 
resilience

The GRC continued to review the economic uncertainty stemming from the Covid-19 
pandemic and the impact to the Group’s own risk management and exposures, 
including those related to credit risk and models. The Committee received updates 
on the progress of economic recovery and how the Group continued to support 
customers and sustain operational resilience during the pandemic. The GRC closely 
monitored Covid-19-related lending and financial support packages, including 
forbearance and other support to customers following the closure of government 
lending schemes.  

The GRC continued its oversight of the Group’s operational resilience programme 
with a focus on 2021 and 2022 regulatory commitments to the PRA. The GRC 
reviewed and challenged the remediation plans for identified gaps, relevant controls, 
and the business ownership model and its supporting infrastructure. The GRC 
worked with management, including the Group Chief Control Officer to ensure 
ownership and the delivery of resilience outcomes is embedded with business and 
function leaders in the first line of defence. The Committee encouraged early 
adoption of operational resilience learnings across key markets and business, as well 
as the effective management of third-party risk.

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 reports on the state of the Group’s technology risk profile, as well 
as reports on cybersecurity. The GRC also maintained a strong focus on 
understanding the Group’s data risk landscape and its data strategy and data 
management programme.

Technology 
resilience 
including 
cybersecurity 
and Cloud 
strategy

People, conduct 
and culture

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 
not having the right people with the right skills 
doing the right thing, including risks associated 
with employment practices and relations.

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

Financial crime 
risk

The GRC convened a joint meeting with the Group Audit Committee in April to 
review and challenge the data strategy and data management programme, which 
had the strong support of the Group Chief Executive and the chief executives of the 
global businesses. The committees agreed that the Group’s data strategy and data 
management programme should be elevated to the highest level of prominence 
within the Group. Further details on the joint meeting are included in the 'Joint 
meetings with the GAC' section on page 250.

The GRC monitored people risk and employee conduct, with support from the Group 
Chief Human Resources Officer and Group Chief Risk and Compliance Officer. The 
Committee considered people risk issues, including those arising from the impact of 
Covid-19, the link between remuneration and talent retention and acquisition, and 
reviewed workplace harassment data and insights. The GRC reviewed and 
challenged the alignment of risk and reward, and the impact of risk and compliance 
objectives on the Group’s variable pay pool.

The GRC reviewed the Group’s new conduct approach, which was refreshed in 
2021, to reflect prevailing regulatory and industry standards and to align with the 
Group’s new purpose and values. The GRC monitored progress in remediating the 
market conduct issues underlying the 2017 Federal Reserve Bank Consent Order 
(which remains in force) arising from its investigation into HSBC’s historical foreign 
exchange activities, and to ensure the reforms are effective and sustainable in the 
long term.

The GRC continued to review the Group’s approach to managing its financial crime 
risk across a number of important areas. These included the Group’s progress in 
enhancing its transaction monitoring framework, the use of next generation 
technology, the fraud landscape (particularly against heightened Covid-19 
conditions), the Group’s fraud risk profile and the nature and scale of insider risk and 
the strategies for managing such 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.

HSBC Holdings plc Annual Report and Accounts 2021

251

Corporate governanceReport of the Directors | Corporate governance report

Principal activities and significant issues considered during 2021 (continued)

Areas of focus

Key issues

Conclusions and actions

The GRC oversees the Group’s management of its 
financial risk.

Capital and 
liquidity risk
including ICAAP 
and ILAAP

HSBC faces risk from the possibility of losses 
resulting from the failure of a counterparty to 
meet its agreed obligations to pay the Group

Credit risk

Successful delivery of our climate ambition will be 
determined by our ability to measure and manage 
all components of climate risk.

Climate 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 performs internal and regulatory stress 
tests to measure the Group’s resilience and 
performance against stress.

Stress testing

The GRC reviewed the Group’s ongoing capital and liquidity management activities, 
including early warning indicators, scenario stress testing and the Group’s capital 
and liquidity adequacy. 

The GRC conducted its annual review, challenge and recommendation of the Group 
ICAAP and ILAAP to the Board for approval. GRC members received both an 
education session and previewed the ICAAP and ILAAP submissions in depth, with 
input from the principal subsidiary risk committee chairs. In the process the 
Committee evaluated the Group’s capital and liquidity strategies, capabilities 
including progress on the Group liquidity remediation programme and internal 
liquidity metric.

The Committee reviewed updates from management on the strategy and approach 
to manage credit risk and credit risk capabilities. The Committee reviewed forward 
economic scenarios and received quarterly updates on the Group’s expected credit 
losses and provisions, loan impairment charges and the credit risk arising from the 
wholesale portfolio and mortgage books. The GRC also reviewed the potential 
impact for the Group from external and secondary market events and recommended 
a management-led comprehensive review of the learnings and actions to be taken to 
drive a stronger credit risk culture.

The GRC remained focused on climate risk, reviewed quarterly reports on climate 
risk management, and maintained oversight over delivery plans to ensure the Group 
develops robust climate risk management capabilities. The GRC reviewed the 
Group's approach to climate risk appetite.
The GRC approved the Group’s climate biennial exploratory scenario stress test 
submission to the PRA. In preparation, the GRC reviewed the scenario and convened 
an education session. The GRC challenged management on the results of the 
submission during three preparatory meetings on the key risks of climate change. 
During the sessions the GRC reviewed the engagement with clients, their transition 
plans and the importance of advancing risk appetite and management actions; the 
challenges in relation to data, modelling and infrastructure support; and the impact 
of climate change on our physical risks including through our residential and 
corporate real estate mortgage books. The GRC also reviewed new business and 
lending opportunities for our Wealth and Personal Banking business to support 
customers.
The GRC and the GAC convened a joint meeting in November to review HSBC's 
thermal coal phase-out policy and the Group's approach to climate-aligned finance 
and recommended the thermal coal phase-out policy and approach to climate-
aligned finance to the Board for approval. Further details on the joint meeting are 
included in the 'Joint meetings with the GAC' section on page 250.

The GRC continued to receive ongoing updates on the Group’s progress in 
managing model risk through the Group Chief Risk and Compliance Officer’s Group 
risk profile report and from the second line of defence. In January 2021, the 
Committee received an update on a number of material post-model adjustments to 
the Group’s wholesale portfolio, and on alternative modelling concepts being 
considered to recalibrate the idiosyncratic economic effects of the pandemic not 
captured by models. The update to the Committee in May 2021 reported on model 
risk deliverables against external review findings, improvements to enhance first line 
of defence engagement in the model lifecycle, and progress made to transform the 
model risk management function and implementation of new global model risk 
policy and standards.

The GRC reviewed and approved the outcomes of the initial submission of the 
impairments and RWA impact to the Bank of England's solvency stress test in April 
2021 and subsequently the final outcomes of the 2021 solvency stress test scenarios 
in May 2021. In advance of the review, the Committee convened a preview meeting 
with the principal subsidiary risk committee chairs to review the solvency stress test 
submissions and the key learnings for the principal subsidiaries, including early 
identification of adjustments that might strengthen resilience in advance of a stress 
event. The Committee also undertook significant review and challenge of the 
Group’s 2021 GRC climate biennial exploratory analysis and approved the 
submissions to the PRA.

The GRC undertook a technical review of the 2021 Group internal stress test 
outcomes at a GRC Chair’s preview meeting, which was followed by formal review 
and approval at the January 2021 GRC meeting. In the lead-up to the 2022 financial 
resource plan, the GRC reviewed and endorsed the economic scenarios 
underpinning the financial resource plan and Group internal stress test in July 2021. 
The GRC subsequently reviewed, challenged and approved the final Group internal 
stress test results in December 2021. 

The GRC also reviewed the implications of the results of the Federal Reserve’s 
Comprehensive Capital Analysis and Review severely adverse scenario stress test 
resubmission in relation to HSBC North America Holdings, and considered action 
being progressed by management in response.

252

HSBC Holdings plc Annual Report and Accounts 2021

Principal activities and significant issues considered during 2021 (continued)

Areas of focus

Key issues

Conclusions and actions

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.

Recovery and 
resolvability

The GRC continued its oversight of the Group’s progress in understanding its 
capabilities against the Bank of England’s requirements for recovery and 
resolvability. The GRC reviewed and challenged the governance pathway for the 
2021 Group recovery plan, including review of the recovery indicator framework and 
a special session to consider the key messages, the recovery playbook and strategic 
management actions. In advance of review by the Committee the GRC Chair met 
with senior management to consider the Group recovery plan, including principal 
subsidiary risk committee components.

The GRC was also heavily involved in the governance of the resolvability assessment 
framework, with updates on the valuation in resolution requirements, and the 
Group’s resolvability self-assessment and resolvability assessment framework 
testing approach. The GRC reviewed and recommended the resolvability assessment 
framework self-assessment to the Board for approval. The Board meeting was 
preceded by four Board sub-Group preview meetings jointly sponsored by the GRC 
and GAC Chairs to examine the Group’s submission.

Committee evaluation 

Focus of future activities

During 2021, the GRC implemented the recommendations of the 
internal committee evaluation conducted by the Group Company 
Secretary and Chief Governance Officer in November 2020. This 
included strengthening the focus of meeting agendas, and further 
increasing the GRC’s engagement with the Risk and Compliance 
functions and principal subsidiary risk committee chairs.

Continuing the commitment to regular evaluation, the Group 
Company Secretary and Chief Governance Officer performed an 
annual review of the effectiveness of the GRC in December 2021. 
The evaluation concluded that the GRC continued to operate 
effectively and in line with regulatory requirements, and identified 
enhancements, including a review of GRC composition, to help 
strengthen the GRC's ability to effectively review and challenge 
the Group's risk profile. Other recommendations included: 
strengthening the focus of agendas with an ongoing emphasis on 
emerging risks; continued enhancement to papers and 
presentations; optimising the use of member time spent outside of 
formal governance; and even stronger coordination of the roles of 
the Board committees. As with the GAC, succession planning will 
also remain a priority. The outcomes of the evaluation have been 
reported to the Board, and the GRC will track the progress in 
implementing recommendations during 2022.

The GRC’s focus for 2022 will include the following activities. It 
will:

• oversee the continued strengthening of the Group's risk 

appetite and risk management framework; 

• continue to review the Group’s work to enhance its credit risk 

capabilities and culture;

• continue to oversee financial crime and fraud;

• oversee the delivery against climate change commitments and 

enhancing climate risk capabilities;

• continue the oversight of the delivery of technology-related 
programmes including the adoption of Cloud platforms, and 
enhancement of the Group’s IT systems/platform; and

• oversee key regulatory actions, including the implementation of 
the Group’s operational resilience strategy on a global basis, 
recovery and resolution, and stress testing submissions and 
capabilities.

HSBC Holdings plc Annual Report and Accounts 2021

253

Corporate governance 
 
Report of the Directors | Corporate governance report

Directors’ remuneration report

Membership

Committee Chair's statement

Directors' remuneration policy

Annual report on Directors' remuneration

Our approach to workforce remuneration

Additional regulatory remuneration disclosures

Page

254

257

268

278

284

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 2021 reflect the improvement in the 
Group's financial performance, our strong cost controls and execution of 
our strategy at pace.'

Dear shareholder

I am pleased to present our 2021 Directors’ remuneration report 
on behalf of the members of the Group Remuneration Committee.

During 2021 the Group's financial performance improved against a 
backdrop of continuing challenging circumstances, including the 
emergence of new Covid-19 variants and ongoing low interest 
rates. We continued to execute our strategy at pace. The decisions 
the Committee has taken reflect the improvement in the Group's 
performance and progress towards its strategic targets. I have 
summarised our decisions in this statement.

At the 2022 Annual General Meeting ('AGM'), we will be seeking 
shareholder approval for a renewed Directors' remuneration 
policy. Our current policy received 97% of votes cast in favour at 
our 2019 AGM and its implementation received strong support 
with more than 96% of votes cast in favour in both 2020 and 2021. 
The Committee reviewed the remuneration policy, considering 
carefully whether it provides a fair and competitive remuneration 
opportunity to incentivise long-term performance. We also noted 
that the UK regulatory requirements currently restrict us from 
using a structure with a greater focus on variable pay and lower 
fixed pay. 

Based on this review, engagement with our largest shareholders, 
and the premise that the policy, within our regulatory framework, 
supports the execution of our strategy, we have decided to roll 
forward our current policy with no changes to the fixed or variable 
pay structure and approach.

254

HSBC Holdings plc Annual Report and Accounts 2021

Member since

Meeting attendance in 
2021

Pauline van der Meer Mohr (Chair)

Rachel Duan

Dame Carolyn Fairbairn

James Forese

José Antonio Meade Kuribreña
Henri de Castries1
Irene Lee1
David Nish1

Jan 2016

Sept 2021

Sept 2021

May 2020

May 2021

May 2017

Apr 2018

May 2017

6/6

2/2

2/2

6/6

4/4

2/3

3/3

2/2

1  David Nish stepped down from the Committee on 23 February 2021; 
Henri de Castries and Irene Lee stepped down from the Committee 
on 28 May 2021. 

Performance in 2021

Financial performance

The Group's financial performance improved in 2021 and all 
regions were profitable. Reported profit before tax of $18.9bn was 
up $10.1bn from 2020. Adjusted profit before tax of $21.9bn was 
up $9.6bn, with net ECL releases more than offsetting the impact 
of lower revenue, which reflected continuing external pressures 
during 2021. We continued to demonstrate strong cost control. 
Despite inflationary pressures and continued investment in 
technology, our adjusted costs were $32.1bn. Our return on 
tangible equity ('RoTE') improved from 3.1% in 2020 to 8.3%. We 
also achieved a $104bn RWA reduction in legacy assets and low-
return areas and we have now achieved 95% of the $110bn 
reduction targeted by the end of 2022. We were able to restart our 
dividend payments to shareholders and we remain well placed to 
fund growth and step up capital returns.

Workforce pay

Support for our colleagues

The well-being of our people remained a critical focus, specifically 
as the operating environment continued to be challenging for 
many colleagues and their families. The pandemic, which remains 
a presence in all of our lives, continued to impact our customers, 
colleagues and communities and we have continued to provide 
support to our colleagues. 

While we have sustained our employee engagement scores, which 
remain above pre-pandemic levels, we are monitoring carefully the 
well-being of our people. Our survey results showed that overall 
well-being has remained stable with 82% of our colleagues 
reporting positive mental health. We are moving to a hybrid 
working model wherever possible, giving people the flexibility to 
work in a way that balances the needs of our customers, their 
teams and their personal preferences.

To help people to develop skills for the changing world around us, 
we launched Future Skills in September 2021, supporting 
colleagues to explore new personal, digital, data and sustainability 
skills through a series of learning activities and events.

Group variable pay pool

2021 was characterised by a sharp economic rebound and an 
extraordinarily competitive labour market. Our financial 
performance was strong, and it is critical for our long-term 
performance that we continue to attract and retain the talent 
necessary to deliver our strategic priorities. As a Committee, we 
reflected on this throughout the year, and particularly when we 
reviewed and agreed the Group variable pay pool of $3,495m, a 
year-on-year increase of 31%. 

In deciding the Group variable pay pool, we reviewed performance 
against financial and non-financial metrics set out in the Group risk 
framework, including conduct. We took into account the 
improvement in the Group's financial performance with adjusted 
profit before tax up 79%, our strong capital position, the 
reinstatement of dividends and the capital return to shareholders 
through the up to $2bn buy-back announced in October 2021. 
Subsequently, the Group has announced that it intends to initiate a 
further up to $1bn share buy-back, to commence after the existing 

buy-back has concluded. We also took into account the operating 
environment and the challenges created by a very competitive 
market for talent manifesting through higher than normal 
voluntary attrition rates.

The pool was determined in line with our countercyclical funding 
methodology, whereby variable pay as a percentage of profits 
generally reduces as performance increase. In 2020, the variable 
pay pool was reduced by 20% when the adjusted profit before tax 
was down 45% to recognise the need to remain competitive in 
retaining talent even in challenging circumstances. In 2021, our 
countercyclical approach meant that while the adjusted profit 
before tax was up 79%, the pool increased by 31%.

As part of the year-end pay review, the Committee considered the 
remuneration outcomes. Overall, total compensation across all our 
businesses was up relative to 2020. For our junior colleagues, the 
increase is slightly lower, as their outcomes last year were broadly 
stable in order to protect their outcomes against material year-on-
year volatility. Outcomes correlated well with performance and 
behaviours, with the largest increase in variable pay for those who 
performed most strongly and who acted as role models for our 
values. Fixed pay increases were targeted towards junior 
colleagues to help address the impact of rising inflation in many of 
our locations. The outcomes were in line with our pay principles 
and the approach decided by the Committee for 2021. 

Key remuneration decisions for Directors 

Executive Directors' annual performance assessment

The financial measures in the executive Directors’ 2021 scorecards 
were growing revenue in Asia, meeting the Group's adjusted cost 
target and our strategic priority of reducing RWAs in legacy assets 
and low-return areas. Strategic performance measures were 
customer satisfaction, employee engagement and diversity and 
personal objectives aligned with delivery of our strategy. 

Overall, the Committee considered the executive Directors 
delivered a strong performance. The adjusted cost performance 
was above the minimum set for the year. As noted earlier, strong 
performance in RWA reduction, with 95% of our end-2022 target 
already achieved, led to a maximum payout against the RWA 
performance metrics. We did not meet the target for revenue 
growth in Asia, primarily due to the impact of low interest rates on 
certain business lines. 

We also made good progress on strategic measures, by improving 
customer satisfaction, maintaining the high level of employee 
engagement from 2020, exceeding our gender representation 
target in senior leadership roles and executing our strategy at pace 
(see page 268 for details). 

Executive Directors' annual incentive scorecard 
outcome

This resulted in an overall annual incentive outcome of 57.30% for 
Noel Quinn and 60.43% for Ewen Stevenson (further details are 
provided on page 262). These are slightly below the 2020 
scorecard outcomes and results in an annual incentive award of 
£1.59m for Noel Quinn (2020: £1.60m before voluntarily waiver of 
cash bonus) and £0.98m for Ewen Stevenson (2020: £0.90m 
before voluntary waiver of cash bonus).  

Long-term incentive ('LTI') for executive Directors

Noel Quinn and Ewen Stevenson will receive LTI awards of 
£4.13m and £2.41m respectively, in respect of their performance 
for 2021 and subject to a three-year forward-looking performance 
period from 1 January 2022 to 31 December 2024. The Committee 
decided to retain the RoTE, relative total shareholder return ('TSR'), 
capital reallocation to Asia and transition to net zero measures in 
the LTI scorecard given their strong alignment with the Group’s 
strategy. Details of the measures and targets are set out on page 
271. 

Executive Directors' fixed pay for 2022

We have increased the base salary of our executive Directors by 
3.5%, effective from 1 March 2022. The Committee considered the 
increase was necessary to ensure that the total remuneration 
opportunity of our executive Directors does not fall further behind 

desired levels based on the size, complexity and international peer 
group of the Group. This was discussed with shareholders during 
our engagement with them on the new Directors' remuneration 
policy. The increase is in line with the average salary increase for 
our wider workforce.

New Directors' remuneration policy

We are proposing to roll forward our current remuneration policy 
for shareholder approval at the 2022 AGM. During the year, we 
undertook a review of the policy based on the key principles that it 
should be easy to understand, align reward with stakeholder 
interests, incentivise long-term performance, be competitive and 
meet expectations of investors and regulators.

As part of the review, the Committee considered whether the 
current policy provides a remuneration opportunity that is 
appropriate given the size and complexity of the Group's 
operations and is commensurate with its aim of fairly 
remunerating executives for delivering its strategic priorities. The 
review clearly demonstrated that over time, HSBC’s overall 
remuneration opportunity has fallen significantly behind desired 
levels to reflect the calibre of the executives and positioning 
against international peers. The Committee also noted that the UK 
regulatory requirements currently restrict us from using a 
remuneration structure with a greater focus on variable pay for 
performance, which is typically used by our international peers. 

We engaged with our shareholders to take into account their 
views on our policy and remuneration structure. As ever, we found 
engagement with our shareholders to be very helpful and we were 
pleased with the level of feedback and support received. Noting 
the strong support from shareholders for our current policy and on 
the basis that it supports the execution of our strategy within our 
regulatory framework, we are proposing to roll forward our current 
policy for shareholders’ approval at the 2022 AGM. We will keep 
the issue on appropriate positioning of our executive Directors' 
total remuneration opportunity under review for the duration of the 
policy. Further details of the remuneration policy and how each 
element supports the Group’s strategy are set out on page 257.

On behalf of the Committee I would like to thank our shareholders 
for their engagement and feedback. The Committee looks forward 
to maintaining an open and transparent dialogue in 2022.

Our annual report on remuneration

The section on Directors' remuneration policy provides an 
overview of our remuneration policy for our Directors, for which 
we are seeking shareholder approval at the 2022 AGM. 

In the annual report section, we provide details of decisions made 
for executive Directors in respect of their 2021 remuneration for 
which, along with this statement, we will seek shareholder 
approval with an advisory vote at the 2022 AGM. 

We also provide details of our remuneration framework for our 
Group colleagues. In the additional remuneration disclosure 
section of this report, we provide other related disclosures. 

As Chair of the Committee, I hope you will support our 
remuneration policy and the 2021 Directors' remuneration report. 

Finally, as announced in January, I will step down as Chair of this 
Committee and from the Board at the conclusion of the 2022 
AGM. An update on my successor will be announced in due 
course.

Pauline van der Meer Mohr

Chair

Group Remuneration Committee

22 February 2022

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Summary 2021 remuneration outcomes for executive Directors

An overview of the 2021 remuneration outcomes and the release profile of remuneration for executive Directors is set out below. Further 
details are available on page 268.

Noel Quinn

Total remuneration (£000)

Ewen Stevenson
Total remuneration (£000)

Maximum opportunity

£10,193

2021 total remuneration

£4,895

Salary and fixed pay allowance
Annual incentive
Notional returns on deferred cash
awarded in respect of prior role

Pension and benefits
Long-term incentive

Annual incentive outcome

Shareholding (% of salary)1

1  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.

Illustration of release profile

The following chart provides an illustrative release profile of the remuneration awarded for executive Directors in respect of 2021.

• Received during 2021.

u u

2021

2022

2023

2024

2025

2026

2027

2028

2029

2030 u

Salary and 
benefits

Fixed pay 
allowance

Annual 
incentive

• Released in five equal annual instalments starting

from March 2022.

• 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.

• Award granted taking into consideration

performance over the prior year and subject to
three-year forward-looking performance
conditions.

• Subject to performance outcome, awards will vest
in five equal annual instalments starting from the
third anniversary of the grant date.

• 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.

u

u

u

u

u

Perform
-ance
period

Retained 
shares

u u u

u

Clawback

Performance 
period

Vesting period

u

u u

u

Retention period u

u

u

u

u

Malus

Clawback

u

u

u

u

u

u

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HSBC Holdings plc Annual Report and Accounts 2021

£5,987£3,665Salary and fixed pay allowancePension and benefitsAnnual incentiveLong-term incentiveReplacement awardMaximum opportunity2021 total remuneration57.30%42.70%AchievedLapsed60.43%39.57%AchievedLapsed400%380%Shareholding requirementCurrent shareholding300%483%Shareholding requirementCurrent shareholdingDirectors’ remuneration policy

This section sets outs the Directors' remuneration policy proposed 
for shareholders' approval at the AGM on 29 April 2022. We have 
made no changes to the remuneration structure or to the 
maximum opportunity payable for each element of remuneration 
and are seeking to roll forward our current policy. Minor changes 
have been made to provide the Committee with sufficient 
flexibility to implement the policy as intended over its term. 
Subject to receiving shareholder approval, the policy is intended to 
apply immediately for three years to the end of the AGM in 2025, 
although we may seek shareholders' approval for a new policy 
during the period depending on regulatory developments, changes 
to our strategy or competitive pressures.

Remuneration policy – key principles

The Committee is responsible for reviewing and recommending to 
the Board the Directors' remuneration policy to be put forward for 
approval by shareholders. 

The guiding principles that form the basis of our review of the 
remuneration policy for Directors are as follows:

• The rationale and operation of the policy should be easy to 

understand and transparent.

• There should be a strong alignment between reward 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 to deliver our strategic 
priorities.

• The structure should meet the expectations of investors and 

our regulators.

Setting the policy

The Committee undertook a detailed review of the Group's 
remuneration policy during 2021 to assess whether it continues to 
be appropriate based on the size and complexity of its operations, 
investor feedback, best practice and market developments. Input 
was received from the Group Chairman and management while 
ensuring that conflicts of interest were suitably mitigated. Input 
was also provided by the Committee’s appointed independent 
advisers throughout the process. 

As highlighted in the 2020 Directors' remuneration report, the 
Committee – while conscious of external sentiment – planned to 
focus the review on whether overall remuneration levels remain 
appropriate and support the delivery of our strategic priorities.

The Committee has become increasingly concerned that, over 
time, the remuneration opportunity of our executive Directors has 
fallen behind desired levels to reflect their calibre and positioning 
against our international peers. This is supported by benchmarked 
data for comparable roles in organisations similar in size, 
geographical presence and with whom we compete for talent.

The Committee noted that UK regulatory requirements restrict us 
from using a remuneration structure with a greater focus on 
variable pay for performance, which is typically used by our 
international peers. Our preference would be to use such a 
structure to improve the total compensation opportunity of our 
executive Directors. This view was supported by a number of our 
shareholders, who also expressed a preference for a structure with 
lower fixed pay and higher variable pay opportunity, but 
understood that UK regulatory rules impact our ability to use such 
a structure.

The Committee also noted that our current policy and its 
implementation have received strong support from shareholders 
over the last few years. This was reaffirmed during our 
engagement with shareholders on the new policy.

Based on the review and taking into account the feedback 
received during our discussions with shareholders, we are 
proposing to roll forward our current policy for shareholders’ 
approval at the 2022 AGM. We will keep the issues on appropriate 
positioning of our executive Directors' total remuneration 
opportunity under review throughout the duration of the policy. 

Other matters considered as part of policy review

We also reviewed the remuneration structure, fixed and variable 
pay mix, the deferral and post-vesting retention periods and our 
shareholding guidelines to ensure there is strong alignment 
between reward and interests of our stakeholders. We also 
considered whether a formal post-employment shareholding 
policy should be introduced. For this purpose, the Committee took 
into consideration the following features of our existing policy:

• Shares delivered to executive Directors as part of the fixed pay 
allowance ('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.

• LTI awards have a seven-year vesting period with a one-year 
post-vesting retention period, which is not accelerated on 
departure. The weighted average holding period of an LTI 
award within HSBC is therefore six years, in excess of the five-
year holding period typically implemented by FTSE-listed 
companies. When an executive Director ceases employment, if 
they are treated 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.

Reflecting on the above, and the in-employment shareholding 
requirement of up to 400% of salary for executive Directors, we 
agreed our existing policy structure achieves the objective of 
ensuring there is ongoing alignment of executive Directors' 
interests with shareholder experience post-cessation of their 
employment. We discussed this with major shareholders during 
our consultation on the new policy.

HSBC Holdings plc Annual Report and Accounts 2021

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Remuneration policy – executive Directors

Fixed pay

Elements

Base salary

Operation

Maximum opportunity

Details

To attract, retain and develop key talent by being market competitive and rewarding ongoing contribution to role.

The base salary for an executive Director is designed to reflect the individual’s role, experience and responsibility. 
Base salaries are normally benchmarked on an annual basis against relevant comparator groups and may be reviewed more 
frequently at the discretion of the Committee. The Committee reviews and approves changes, taking into consideration factors 
such as scope of the role, local requirements, employee increases and market competitiveness.

In normal 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 this policy. The Committee may determine larger increases in 
exceptional circumstances, such as a change in responsibility, where the overall remuneration opportunity has been set lower 
than the market and when it is justified based on skills, experience and performance in the role.

Fixed pay allowance 
(‘FPA’)

To deliver a level of fixed pay required to reflect the role, skills and experience of the executive Directors and to maintain a 
competitive total remuneration package for executive Directors.

Operation

FPAs are non-pensionable and will normally be granted in three instalments of immediately vested shares per year, or at any 
other frequency that the Committee deems appropriate.

Shares equivalent to the net number of shares delivered (after those sold to cover any income tax and social security) will be 
subject to a retention period and normally released on a pro-rata basis over five years, starting from the March immediately 
following the end of the financial year in respect of which the shares are granted.
Dividends will be paid on the vested shares held during the retention period.

The Committee retains the discretion to amend the retention period and/or pay the FPA in cash if required to do so to meet any 
regulatory requirements or for any other reason the Committee deems appropriate.

FPAs are determined based on the role, skills and responsibility of each individual and taking into account factors such as 
market competitiveness of the total remuneration opportunity and other elements of remuneration set out in this policy.
Other than in exceptional circumstances, the FPA for the duration of this policy will be capped at 150% of base salary levels at 
the start of this policy.

Maximum opportunity

Cash in lieu of pension To help executive Directors build retirement savings

Operation

Directors receive a cash allowance in lieu of a pension entitlement.

Maximum opportunity

The maximum opportunity will be aligned with the maximum contribution rate that HSBC could make for the majority of 
employees in the relevant jurisdiction. This is currently set at 10% of base salary in line with 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 in the UK.

Benefits and all employee share plans

Elements

Benefits

Operation

Details

To provide support for physical, mental and financial health in accordance with local market practice.

Benefits take account of local market practice and include, but are not restricted to:
• taxable benefits (gross value before payment of tax) including 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); and

• non-taxable benefits including the provision of a health assessment, life assurance and other insurance coverage.
The Group Chief Executive is also eligible to be provided with accommodation and car benefits in Hong Kong. Any tax and/or 
social security due on these benefits will be paid by HSBC.
Additional benefits may also be provided when an executive is relocated or spends a substantial proportion of their time in more 
than one jurisdiction for business needs, or in such other circumstances as the Committee may determine in its discretion. Such 
benefits could include, but are not restricted to, airfare, accommodation, shipment, storage, utilities, and any tax and social 
security that may be due in respect of such benefits.

Maximum opportunity

The maximum opportunity is determined by the nature of the benefit provided. The benefit amount will be disclosed in the single 
figure of remuneration table for the relevant year.

All employee share 
plans
Operation

To promote share ownership by all employees.

Executive Directors are entitled to participate in all employee share plans, such as the HSBC Sharesave, on the same basis as all 
other employees.
Under the Sharesave, executive Directors can make monthly savings over a period of three or five years towards the grant of an 
option over HSBC shares. The option price can be at a discount, currently up to 20%, on the share price at the time that the option 
is granted.

Maximum opportunity

The maximum number of options is determined by the maximum savings limit set by HM Revenue and Customs. This is currently 
£500 per month.

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HSBC Holdings plc Annual Report and Accounts 2021

 
Variable pay

Adhering to the values-aligned behaviours is a prerequisite to be considered for any variable pay. Executive Directors receive a 
performance and behaviour rating that is considered by the Committee in determining the variable pay awards.

Elements

Details

Annual incentive

Operation

To drive and reward performance against annual financial and non-financial objectives that are consistent with the strategy and 
align to shareholder interests.

Annual incentive awards are discretionary and can be delivered in any combination of cash and shares under the HSBC Share Plan 
2011 (‘HSBC Share Plan’). Shares will not represent less than 50% of any award and are normally immediately vested.
On vesting, shares equivalent to the net number of shares that vested (after those sold to cover any income tax and social security 
payable) must be held for a retention period up to one year, or such other period as required by regulators.
The awards will be subject to clawback (i.e. repayment or recoupment of paid/vested awards) on or after vesting for a period of 
seven years from the date of award. This may be extended to 10 years in the event of an ongoing internal/regulatory investigation 
at the end of the seven-year period. Details of the clawback provision are set out in the following section on LTI awards.
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 awards, subject to such conditions that the Committee may determine at its discretion 

(which may include continued employment). The deferred awards will be subject to malus (i.e. reduction and/or cancellation of 
unvested awards) provisions during any applicable deferral period.

Any deferred shares may be entitled to dividend equivalents during the vesting period, which will be paid on vesting. Where 
awards do not receive dividend equivalents during the vesting period (to meet regulatory requirements), the number of shares to 
be awarded will be determined using a share price discounted for the expected dividend yield.
Any deferred cash award may be entitled to notional returns during the deferral period, or any appropriate adjustment to reflect 
such notional returns, as determined by the Committee.
The Committee may adjust and amend awards in accordance with the relevant plan rules.

Maximum opportunity

The maximum opportunity for the annual incentive award, in respect of a financial year, is up to 215% of base salary.

Performance metrics

Performance is measured against an annual scorecard, based on targets set for financial and non-financial measures. The 
scorecards may vary by individual.
Measures with financial targets will generally have a weighting of 60% for the Group Chief Executive and 50% for the Group Chief 
Financial Officer. The Committee will review the scorecard annually and may vary the measures, weighting and targets each year. 
The overall payout of the annual incentive could be between 0% (for below threshold performance) and 100% of the maximum.
At threshold level of performance set in the scorecard for each measure, 25% of the award opportunity for that measure will pay 
out. An achievement of maximum performance set in the scorecard means a payout of 100% of the award. The Committee 
exercises its judgement to determine performance achieved and awards at the end of the performance period, which in normal 
circumstances will be one financial year, to ensure that the outcome is fair in the context of overall Group and individual 
performance. The Committee can adjust the payout based on the outcome of the performance measures, if it considers that the 
payout determined does not appropriately reflect the overall position and performance of the Group for the relevant performance 
period.
The scorecard outcome may also be subject to a risk and compliance modifier and/or a capital underpin under which the 
Committee will have the discretion to adjust down the overall scorecard outcome, taking into account performance against those 
factors. 
The Committee has the discretion to:
• change the overall weighting of the financial and non-financial measures;
• vary the measures and their respective weightings within each category. The specific performance measures will be disclosed 

in the ‘annual report on remuneration’ for the relevant year; and

• make adjustments to performance targets, measures, weighting and/or outcomes in exceptional circumstances. This may be to 
reflect significant one-off items that occur during the measurement period and/or where the Committee determines that original 
measures, targets or conditions are no longer appropriate or that amendment is required so that the measures, targets or 
conditions achieve their original purpose. Full and clear disclosure of any such adjustments will be made in the 'annual report 
on remuneration' for the relevant year, subject to commercial confidentiality.

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Report of the Directors | Corporate governance report

Elements

Details

Long-term 
incentives (‘LTI’)

Operation

To incentivise sustainable long-term performance and alignment with shareholder interests.

LTI awards are discretionary and are granted if the Committee considers that there has been satisfactory performance over the 
prior year. The awards are granted as rights to receive shares under the HSBC Share Plan, normally 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, the performance outcome will be used to assess the percentage of the awards that will vest. 
These shares will then normally 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, in accordance with the UK's Prudential 
Regulation Authority's ('PRA') remuneration rules.

On each vesting, shares equivalent to the net number of shares that vested (after those sold to cover any income tax and social 
security payable) must be held for a retention period up to one year (or such other period as required by regulators). 
Awards are subject to malus provisions prior to vesting. The awards will also be subject to clawback on or after vesting for a period 
of seven years from the date of award. This may be extended to 10 years in the event of an ongoing internal/regulatory 
investigation at the end of the seven-year period. Details of the malus and clawback provisions are set out in the bottom section of 
this table.

Awards may be entitled to dividend equivalents during the vesting period, which will be paid on vesting. Where awards do not 
receive dividend equivalents during the vesting period (to meet regulatory requirements), the number of shares to be awarded will 
be determined using a share price discounted for the expected dividend yield.

The Committee may adjust or amend awards in accordance with the rules of the HSBC Share Plan.

Maximum opportunity The maximum opportunity for the LTI award, in respect of a financial year, is up to 320% of base salary.

Performance metrics

Malus and clawback
(applicable to both 
annual incentive and 
LTI)

The Committee will take into consideration prior performance when assessing the value of the LTI grant. Forward-looking 
performance is measured against a long-term scorecard. Financial measures will generally have a weighting of 60% or more.
For each measure, the Committee will determine the extent of achievement based on actual performance against the target set and 
other relevant factors that the Committee considers appropriate to take account of in order to better reflect the Group's underlying 
performance. The overall payout level could be between 0% (for below threshold performance) and 100% of the maximum.
At threshold level of performance set in the scorecard for each measure, 25% of the award opportunity for that measure will vest. 
100% of the award will vest for achieving the maximum level of performance set for each measure. Where performance achieved 
is between the threshold, target and maximum level of performance set in the scorecard, the number of awards that will vest will 
be determined on a straight-line basis.
The Committee can adjust the LTI payout based on the outcome of the performance measures, if it considers that the payout 
determined does not appropriately reflect the overall position and performance of the Group during the performance period.
The scorecard outcome may also be subject to a risk and compliance modifier and/or a capital underpin under which the 
Committee will have the discretion to adjust down the overall scorecard outcome, taking into account performance against those 
factors. Performance targets will normally be set annually for each three-year cycle. The Committee has the discretion to:
• change the overall weighting of the financial and non-financial measures;
• vary the measures and their respective weightings within each category. The specific performance measures will be disclosed in 

the ‘annual report on remuneration’ for the relevant year;

• vary the risk and compliance and/or any underpin measures; and
• make adjustments to performance targets, measures, weighting and/or outcomes in exceptional circumstances. This may be to 
reflect significant one-off items that occur during the measurement period and/or where the Committee determines that original 
measures, targets or conditions are no longer appropriate or that an amendment is required so that the measures, targets or 
conditions achieve their original purpose. Revised targets/measures will be, in the opinion of the Committee, no less difficult to 
satisfy had they been set at the same time as the original targets. Full and clear disclosure of any such adjustments will be made 
within the 'annual report on remuneration' for the relevant year, subject to commercial confidentiality.

The Committee has the discretion to operate malus and clawback provisions.
Malus can be applied to unvested awards 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 for a period of seven years from the grant date. This may be extended to 10 
years 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;

• a material failure of risk management suffered by HSBC or a business unit in the context of Group risk management standards, 

policies and procedures; and

• any other circumstances required by local regulatory obligations to which any member of the HSBC Group or its subsidiary is 

subject.

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HSBC Holdings plc Annual Report and Accounts 2021

Other

Elements

Details

Shareholding guidelines

To ensure appropriate alignment with the interest of our shareholders.

Operation

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%
For this purpose, unvested shares which are not subject to forward-looking performance conditions (on a net of tax basis) 
will count towards the shareholding requirement. 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.

Maximum opportunity

Not applicable.

The Committee reserves the right to make any remuneration 
payments and payments for loss of office, notwithstanding that 
they are not in line with the policy set out above, where the terms 
of the payment were agreed:

• before the policy set out above or any previous policy came 

into effect;

• at a time where a previous policy, approved by shareholders, 
was in place provided the payment is in line with the terms of 
that policy; or

• at a time when the relevant individual was not a Director of the 

Group and the payment was not in consideration for the 
individual becoming a Director of the Group.

For these purposes, payments include the Committee satisfying 
awards of variable remuneration. This means making payments in 
line with the terms that were agreed at the time the award was 
granted.

In addition to the specific discretions expressly set out in the 
policy, the incentive plans include a number of operational 
discretions available to the Committee, including:

• the right to grant awards in the form of conditional share 

awards or options (including nil-cost options);

• the right to amend a performance condition in accordance with 

Performance measures

Measures and 
modifier/
underpin

Financial 
measures

Example measures for annual incentive scorecard

• Adjusted profit before tax
• Operating profit
• RoTE
• Revenue growth 
• Volume growth
• Adjusted costs

Strategic 
measures

• Customer satisfaction
• Employee engagement
• Succession planning and diversity
• Carbon reduction and sustainable finance

Risk and 
compliance 
measures, 
modifier and/
or underpin

• Sustained delivery of global conduct outcomes 
• Effective financial crime risk management
• Effective management of material operational risks in support of strategic 

priorities

• Risk metrics to identify when business activities are outside of tolerance level 

for a significant period of time

• Failures in risk management that have resulted in significant customer 

detriment, reputational damage and/or regulatory censure. 

• CET1 level

its terms, or if anything happens that causes the Committee to 
consider it appropriate to do so;

• the right to settle the award in cash, based on the relevant 

share price, or shares as appropriate; and

• the right to adjust the award on a variation of share capital or 

other corporate event that affects the current or future value of 
the award, or alternatively, the right to vest the award early in 
such circumstances.

Choice of performance measures and targets

The performance measures selected for the annual incentive and 
LTI awards will be set on an annual basis by the Committee, 
taking into account the Group’s strategic priorities and any 
feedback received from our shareholders. The following table sets 
out the performance measures we currently consider for inclusion 
in our scorecards. The Committee retains the discretion to choose 
other measures that are considered to be appropriate for achieving 
our strategic priorities and meeting any regulatory expectation.

The targets for the performance measures will be set taking into 
account a number of factors, including the targets set in our 
financial and resource plan, our strategic priorities, shareholder 
expectations, the economic environment and risk appetite.

Example measures for LTI 
scorecard

Rationale

• RoTE
• Total shareholder 

return

• Underpin to maintain a 
minimum CET1 ratio 

Measures are selected to 
incentivise the achievement 
of our financial targets as 
set out in our strategic 
priorities and financial and 
resource plan.

• Reduce carbon 

emissions

• Sustainable finance 
• Capital reallocation to 
areas of strategic focus

• Modifier linked to risk 

and compliance 
performance

Measures are selected to 
support the delivery of our 
strategic priorities.

Measures are chosen to 
ensure a high level of 
accountability of risk and 
conduct, to promote an 
effective risk management 
environment and to embed 
a robust governance 
system.

HSBC Holdings plc Annual Report and Accounts 2021

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Approach to recruitment remuneration –  
executive Directors

On the recruitment or appointment of a new executive Director, 
the Committee would adhere to the following principles:

• Remuneration packages should be in line with the approved 

policy for executive Directors.

• Remuneration packages must meet any applicable local 

regulatory requirements.

• Where necessary, compensation may be provided in respect of 
forfeiture of awards from an existing employer (for example, 
buy-out awards).

Components of remuneration package of a new executive Director

Component

Approach taken to each component of remuneration

Outlined in the following table are all components that would be 
considered for inclusion in the remuneration package of a new 
executive Director appointment and, for each, the approach that 
would be adopted.

In the case of an internal appointment, any existing commitments 
will be honoured and any variable element awarded in respect of 
the prior role will be allowed to be paid out according to its 
existing terms.

Fixed pay 

Benefits 

Variable pay 
awards

Buy-out 

The base salary and FPA will reflect the individual’s role, experience and responsibility, and will be set in the context of market practice.
The maximum cash in lieu of pension allowance will be no more than the maximum contribution, as a percentage of salary, that can be 
made for the majority of employees in the relevant jurisdiction.

Benefits to be provided will be dependent on circumstances while in line with Group policy and the remuneration policy table, including 
the global mobility policy (where applicable) and local regulations.

New appointments will be eligible to be considered for variable pay awards consisting of an annual incentive and/or LTI award (or any 
other element which the Committee considers appropriate given the particular circumstances but not exceeding the maximum level of 
variable remuneration set out below).
For the year in which the individual commences providing services as an executive Director, the Committee retains the discretion to 
determine the proportion of variable pay to be deferred, the deferral and retention period, whether any performance and/or continued 
employment conditions should be applied, and the period over which such performance should be assessed. In exercising this discretion, 
the Committee will take into account the circumstances in which the individual is appointed (for example, if it is promotion of an internal 
candidate or an external appointment), expectation of shareholders and any regulatory requirements.
Total variable pay awarded for the year in which the individual is newly appointed as an executive Director will be limited to 535% of 
base salary. This limit excludes buy-out awards and is in line with the aggregate maximum variable pay opportunity set out in the 
remuneration policy table.
Guaranteed bonuses are only permitted by exception and in very rare and limited circumstances (for example, where the individual loses 
a variable pay opportunity with the previous employer as a result of joining HSBC and such an award is considered essential to attract 
and hire the candidate). If such an award is provided then, in line with the PRA remuneration rules, it will be limited to the first year of 
service, subject to the Group deferral policy and performance requirements. 

The Committee may make an award to buy out remuneration terms forfeited on resignation from the previous employer.
The Group buy-out policy is in line with the PRA remuneration rules, which state that both the terms and amount of any replacement 
awards will not be more generous than the award forfeited on departure from the former employer.
In considering buy-out levels and conditions, the Committee will take into account the type of award, performance measures and 
likelihood of performance conditions being met in setting the quantum of the buy-out. Buy-out awards will match the terms of forfeited 
awards with the previous employer as closely as possible, subject to proof of forfeiture and other relevant documentation. Where the 
vesting time is fewer than 90 days, cash or deferred cash may be awarded for administrative purposes.
Where appropriate, the Committee retains the discretion to utilise the provisions provided in the UK Listing Rules for the purpose of 
making buy-out awards.

262

HSBC Holdings plc Annual Report and Accounts 2021

Policy on payments for loss of office – executive 
Directors

no further obligations that could give rise to remuneration 
payments or payments for loss of office:

The following table sets out the basis on which payments on loss 
of office may be made. Other than as set out in the table, there are 

Payments on loss of office

Component of remuneration

Approach taken

Fixed pay and benefits

Executive Directors may be entitled to payments in lieu of:
• notice, which may consist of base salary, FPA, cash in lieu of pension allowance, pension entitlements and other 

Annual incentive and 
LTI

Unvested awards

Post-departure benefits

Other

Legal claims

contractual benefits, or an amount in lieu of; and/or

• accrued but untaken holiday entitlement.
Payments may be made in instalments or a lump sum, and may be subject to mitigation, and subject to applicable tax 
and social security deductions.

In exceptional circumstances, as determined by the Committee, an executive Director may be eligible for the grant of 
annual and/or long-term incentives under the HSBC Share Plan, taking into account the time worked in the 
performance year and based on the individual’s contribution.

All unvested awards will be forfeited when an executive Director ceases employment voluntarily and is not deemed a 
good leaver. An executive Director may be considered a good leaver, under the HSBC Share Plan, if their employment 
ceases in specified circumstances, which include:
• ill heath, injury or disability, as established to the satisfaction of the Committee;
• retirement with the agreement and approval of the Committee;
• the employee's employer ceasing to be a member of the Group;
• redundancy with the agreement and approval of the Committee; or
• any other reason at the discretion of the Committee.
If an executive Director is considered a good leaver, unvested awards will normally continue to vest in line with the 
applicable vesting dates, subject to performance conditions, the share plan rules, and malus and clawback provisions. 
Unless the Committee determined otherwise, awards made subject to forward-looking performance conditions, 
including LTI awards, will normally be subject to time pro-rating for time in employment during the performance period.
In the event of death, unvested awards will vest and will be released to the executive Director’s estate as soon as 
practicable.
In respect of outstanding unvested awards, the Committee may determine that good leaver status is contingent upon 
the Committee being satisfied that the executive has no current or future intention at the date of leaving HSBC of being 
employed by any competitor financial services firm. The Committee determines the list of competitor firms from time to 
time, and the length of time for which this restriction applies. If the Committee becomes aware of any evidence to the 
contrary before vesting, the award will lapse.

Executive Directors can be provided certain benefits for up to a maximum of seven years from date of departure for 
those who depart under good leaver provisions under the HSBC Share Plan, in accordance with the terms of the policy. 
Benefits may include, but are not limited to, medical coverage, tax return preparation assistance and legal expenses.

Where an executive Director has been relocated as part of their employment, the Committee retains the discretion to 
pay the repatriation costs. This may include, but is not restricted to, airfare, accommodation, shipment, storage, 
utilities, and any tax and social security that may be due in respect of such benefits.
Except in the case of gross misconduct or resignation, an executive Director may also receive retirement gifts.

The Committee retains the discretion to make payments (including professional and outplacement fees) in connection 
with an executive Director’s cessation of office or employment. This may include payments that are made in good faith 
in discharge of an existing legal obligation (or by way of damages for breach of such an obligation) or by way of 
settlement of any claim arising in connection with the cessation of that executive Director’s office or employment.

Change of control

In the event of a change of control, outstanding awards will be treated in line with the provisions set out in the 
respective plan rules.

Other directorships

Executive Directors may accept appointments as non-executive 
Directors of companies that are not part of HSBC if so authorised 
by either the Board or the Nomination & Corporate Governance 
Committee. 

When considering a request to accept a non-executive 
appointment, the Board or the Nomination & Corporate 
Governance Committee will take into account, among other

 things, the expected time commitment associated with the 
proposed appointment. 

The time commitment for external appointments is also routinely 
reviewed to ensure that it will not compromise the Director's 
commitment to HSBC. Any remuneration receivable in respect of 
an external appointment of an executive Director is normally paid 
to the Group unless otherwise approved by the Nomination & 
Corporate Governance Committee or the Board.

HSBC Holdings plc Annual Report and Accounts 2021

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Remuneration scenarios

The following charts show how the total value of remuneration 
and its composition would vary under different performance 
scenarios for executive Directors under the proposed policy, which 
will be effective from the date of the 2022 AGM, subject to 
shareholders’ approval. Benefits in the charts below represents 
value of regular benefits as per the 2021 single figure table of 
remuneration. Additional benefits may arise but will always be 
provided in line with the shareholder approved policy.

The charts set out:

• the minimum level of remuneration receivable under the policy 

for each performance year;

Group Chief Executive (£000)

• the remuneration level for achieving target level of performance 
(which assumes 50% of maximum variable pay opportunity is 
realised); and

• the maximum level of remuneration (which assumes 100% of 

the variable pay opportunity is realised), as well as the 
maximum value assuming a 50% increase in share price for LTI 
awards.

The charts have been prepared using 2022 salaries and, therefore, 
the annual incentive and LTI opportunities have been computed as 
percentages of 2022 salaries.

£3,336

5%

95%

£6,909

31%

21%

46%

2%

Fixed pay

 Benefits

Annual incentive

LTI

£10,483

41%

27%

30%

2%

£12,621

51%

23%

25%

1%

Proposed policy

Minimum

Proposed policy

Target

Proposed policy

Proposed policy with 50% share price increase

Maximum

Group Chief Financial Officer (£000)

£1,987

2%

98%

£4,071

30%

21%

48%

1%

Fixed pay

 Benefits

Annual incentive

LTI

£6,155

40%

27%

32%

1%

£7,401

50%

23%

26%

1%

Proposed policy

Minimum

Proposed policy

Target

Proposed policy

Proposed policy with 50% share price increase

Maximum

Service contracts

The service contracts of executive Directors do not have a fixed 
term. The 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.

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.

Noel Quinn

Ewen Stevenson

Contract date (rolling)

18 March 2020

1 December 2018

Notice period
(Director and HSBC)

12 months

12 months

264

HSBC Holdings plc Annual Report and Accounts 2021

 
 
Remuneration policy – non-executive Directors

The Nomination & Corporate Governance Committee has reviewed 
and revised the time commitments required for all non-executive 
Directors as the Board supports HSBC through its ambitious 
agenda of governance reform, growth and organisational 

development in an environment of increasing regulatory, political 
and organisational complexity.

The following table sets out the framework that will be used to 
determine the fees for non-executive Directors during the term of 
this policy.

Elements and link to strategy  Operation

Fees
To reflect the time 
commitment and 
responsibilities of a non-
executive Director of HSBC 
Holdings. 

Expenses/benefits

Shareholding guidelines
To ensure appropriate 
alignment with the interests 
of our shareholders.

The policy for non-executive Directors is to pay:
• base fees;
• 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; and

• travel allowances.
Fees are paid in cash. The Board retains the discretion to pay in shares rather 
than cash where appropriate.
The non-executive Group Chairman will be paid a fixed annual fee for all 
Board responsibilities based on their experience and the time commitments 
expected for the role, together with such other benefits as the Group 
Remuneration Committee may in its absolute discretion determine.
A newly appointed non-executive Director would be paid in line with the 
policy on a time-apportioned basis in the first year as necessary. No sign-on 
payments are offered to non-executive Directors. 
The Board (excluding the non-executive Directors) has discretion to approve 
changes to the fees. The Board may also introduce any new component of 
fees for non-executive Directors, subject to the principles, parameters and 
other requirements set out in this remuneration policy. 
Certain non-executive Directors may be entitled to receive fees for their 
services as directors of subsidiary companies of HSBC Holdings plc. Such 
additional remuneration is determined by the Board of Directors of each 
relevant subsidiary within a framework set by the Committee. 

Any taxable or other expenses incurred in performing their role are 
reimbursed, as well as any related tax cost on such reimbursement.
Non-executive Directors may on occasion receive reimbursement for costs 
incurred in relation to the provision of professional advice. These payments, if 
made, are taxable benefits to the non-executive Directors and the tax arising 
is paid by the Group on the Directors’ behalf.

Non-executive Directors, individually or with their connected persons, are 
expected to satisfy a shareholding guideline of 15,000 shares within five years 
from their appointment.
The Committee reviews compliance with the guidelines annually. The 
Committee has full discretion in determining any consequences in cases of 
non-compliance.

Maximum opportunity

The Board will normally review the amount 
of each component of fees periodically to 
assess whether, individually and in 
aggregate, they remain competitive and 
appropriate in light of changes in roles, 
responsibilities and/or time commitment of 
the non-executive Directors, and to ensure 
that individuals of the appropriate calibre are 
retained or appointed. 
Other than in exceptional circumstances, 
during the term of this policy, fees will not 
increase by more than 20% above the 2022 
levels. 
Travel allowances are set at an appropriate 
level, taking into account the time 
requirement for non-executive Directors to 
travel to overseas meetings.  
Any new fees, allowance or component part 
(for example, for a new committee) would be 
set and then subject to a maximum of 20% 
increase for the duration of the policy, 
subject to the exceptional circumstances 
referred to above.

Not applicable

Not applicable

Service contracts

Remuneration arrangements for colleagues

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.

Policy on payments on loss of office – non-
executive Directors

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 are entitled to notice under their letter of 
appointment. Non-executive Directors' current terms of 
appointment will expire as follows:

2022 AGM
2023 AGM
José Antonio Meade Kuribreña David Nish
Rachel Duan1
Jackson Tai
Dame Carolyn Fairbairn1

2024 AGM
Mark Tucker 
James Forese
Steven Guggenheimer
Eileen Murray

1  Rachel Duan and Dame Carolyn Fairbairn were appointed following 
the 2021 AGM and therefore their initial three-year appointment 
terms are subject to approval of their election by shareholders at the 
2022 AGM. Their initial three-year term of appointment will end at 
the conclusion of the 2025 AGM, subject to annual re-election by 
shareholders' at the relevant AGMs.

Our remuneration arrangements for our colleagues, including the 
executive Directors, are driven by the Group reward strategy. The 
Committee reviews the Group reward strategy to ensure it 
continues to support HSBC's overall ability to attract, retain, 
develop and motivate the best people, who are aligned to HSBC’s 
values and committed to maintaining a long-term career within the 
Group. Full details of our remuneration framework for our 
colleagues are disclosed on page 279.

Our executive Directors' remuneration policy aligns with our 
remuneration policy for our colleagues as follows:

• Externally sourced market data is used to help guide pay 
decisions for colleagues, including executive Directors.

• The base salary increases for executive Directors take into 

consideration base salary increases of colleagues across the 
Group, and relevant market conditions.

• The cash in lieu of pension allowance for executive Directors 

will not exceed the maximum contribution (as a percentage of 
salary) that can be made for the majority of colleagues in the 
relevant jurisdiction.

• All colleagues are eligible to be considered for an annual 

incentive award based on their performance and behaviour 
ratings. The variable pay for all colleagues, including executive 
Directors, is funded from a Group variable pay pool that is 
determined by reference to Group performance. Colleagues 
who receive a variable pay award above a certain level have a 
portion of their award deferred over a period of three to seven 
years.

HSBC Holdings plc Annual Report and Accounts 2021

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• LTI awards are considered for senior management, given their 

ability to influence directly the long-term performance.

The Board gathers views from our colleagues through a number of 
engagement channels. Our management engages with colleagues, 
either on a Group-wide basis or in the context of smaller focus 
groups, to solicit feedback generally on a wide range of matters, 
including pay. Our annual survey on pay seeks the views of all 
colleagues on their performance and pay outcomes. The 
Committee reviews the outcomes of the survey and determines 
the key remuneration priorities for the forthcoming year. Many of 
our colleagues are also shareholders and therefore have the 
opportunity to vote on the policy at the 2022 AGM. 

As part of our annual calendar, the Committee Chair also hosts a 
forum attended by the chairs of our principal subsidiaries boards 
and remuneration committees. This event allows the Committee to 
understand local market factors and feedback gathered from 
employees, within the regions where we operate, on pay and 

performance matters. This helps both management and the 
Committee to determine the prioritisation of pay budgets, and 
allows the Committee to ensure that funding is directed to the 
areas of need in support of the Group’s strategic ambitions.

In 2022, the Committee has requested that a detailed review of the 
reward strategy be conducted to reflect the changes in the 
Group’s strategy, and our employee value proposition as a result 
of the Covid-19 pandemic, as well as to ensure that we are well 
positioned versus developments in the market, both within 
financial services and more broadly. This will include engagement 
with colleagues to ensure their feedback on the various elements 
of our reward strategy can be taken into account as part of the 
Committee’s decision making. An update will be provided as part 
of next year’s Directors’ remuneration report. 

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.

Provision

Approach

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. 

• 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. 
• 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 so that it is easy to understand and 

transparent, while complying with the provisions set out in the UK Corporate Governance Code and 
the remuneration rules of the UK's PRA and FCA, 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 281).

• The Group Chief Risk and Compliance Officer attends Committee meetings and updates the 

Committee on the overall risk profile of the Group. The Committee also seeks inputs from the Group 
Risk Committee when making remuneration decisions. 

• 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 incentive and LTI scorecards include a mix of financial and non-financial 
measures. Financial measures in the scorecards are subject to a CET1 capital underpin to ensure 
CET1 capital remains within risk tolerance levels while achieving financial targets. In addition, the 
overall scorecard outcome is subject to a risk and compliance modifier.

• 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 264 show how the total value of remuneration and its composition vary 

under different performance scenarios for executive Directors. 

• The annual incentive and LTI scorecards reward achievement of our financial and resource plan 

targets, as well as long-term financial and shareholder value creation targets.

• The Committee retains the discretion to adjust 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. 

• Annual incentive and LTI scorecards contain non-financial measures linked to our wider social 

obligations. These include measures related to reducing the environmental impact of our operations, 
improving customer satisfaction, diversity and employee engagement.

• Each year senior employees participate in a 360 degree survey, which gathers feedback on values-

aligned behaviours from peers, direct reports, skip level reports and managers.

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Group Remuneration Committee

The Group Remuneration Committee is responsible for setting the 
overarching principles, parameters and governance of the Group's 
remuneration framework for our colleagues, and the remuneration 
of executive Directors, the Group Chairman and other senior 
Group colleagues. The Committee regularly reviews the framework 
to ensure it supports the Group's purpose, values, culture and 
strategy, as well as promoting sound risk management. The 
Committee also reviews the framework to satisfy itself that it  
complies with the regulatory requirements of multiple 
jurisdictions.

All members of the Committee are independent non-executive 
Directors of HSBC Holdings. No Directors are involved in deciding 
their own remuneration.  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 six times during 2021. Rachel Duan, Dame 
Carolyn Fairbairn and José Antonio Meade Kuribreña were 
appointed as members of the Committee during 2021. David Nish, 
Henri de Castries and Irene Lee stepped down as members of the 
Committee during 2021. The following is a summary of the 
Committee’s key activities during 2021.

Matters considered during 2021

Remuneration framework and governance

Group variable pay pool, workforce performance and pay matters, gender pay gap report, and employee surveys

Directors' remuneration policy design

Executive Director remuneration policy implementation, scorecards and pay proposals

Remuneration for other senior executives of the Group

Directors’ remuneration report

Regulatory, risk and governance

Information on material risk and audit events, and performance and remuneration impacts for individuals involved

Regulatory updates, including approach and outcomes for the identification of Material Risk Takers

Jan

Feb

May

Jul

Sep

Dec

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l
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l

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Governance matters
Principal subsidiaries
Matters from subsidiary committees

Advisers

The Committee received input and advice from different advisers 
on specific topics during 2021. Deloitte LLP’s engagement with 
the Committee was extended during 2021. 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. 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.

The Committee also received advice from Willis Towers Watson 
on market data and remuneration trends. Willis Towers Watson 
was appointed 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. The Committee 
was satisfied the advice provided by Deloitte and Willis Towers 
Watson was objective and independent in 2021.

For 2021, total fees of £176,550 and £35,060 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; 

• Jenny Craik, Group Head of Performance Management, 

Reward and Employee Relations;

• Alexander Lowen, Former Group Head of Performance 

Management and Reward; 

• Pam Kaur, Group Chief Risk and Compliance Officer;

• Colin Bell, former Group Chief Compliance Officer;

• Bob Hoyt, Group Chief Legal Officer; 

• Shawn Chen, Group General Counsel for Litigation and 

Regulatory Enforcement; 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. 

Committee effectiveness

The annual review of the effectiveness of the Committee was 
internally facilitated for 2021. The review concluded that the 
Committee continued to operate effectively, with a number of 
positive aspects of the Committee’s operation and practices 
highlighted. Areas identified for focus during 2022 included:

• The Committee needs to receive suitable and relevant data and 
insight to support its discussion and decision making on pay, 
including for the wider workforce.

• It should facilitate the right level of preparation for its members. 

• The Committee should consider how best the Committee’s 

advisers and other external consultants could add value and 
insights on developing market context and stakeholder views to 
its discussions. 

The Committee discussed the outcomes of the evaluation in 
January 2022, and endorsed the findings and actions to be taken. 
The outcomes of the evaluation have been reported to the Board 
and the Committee will track progress on the recommendations 
through the year.

Voting results from Annual General Meeting

The table below shows the voting results from our last AGM.

2021 Annual General Meeting voting results

Remuneration report
(votes cast)

Remuneration policy 
(2019) (votes cast)

For

 97.30 %

Against

2.70%

Withheld

––

8,898,898,415

246,557,676

12,404,292

 97.36  %

2.64%

––

9,525,856,097

258,383,075

47,468,297

HSBC Holdings plc Annual Report and Accounts 2021

267

Corporate governance 
 
Report of the Directors | Corporate governance report

Annual report on Directors' remuneration

This section sets out how our approved Directors’ remuneration 
policy was implemented during 2021.

Determining executive Directors’ incentive 
outcomes

(Audited) 

The maximum 2021 annual incentive opportunity for our two 
executive Directors, Noel Quinn and Ewen Stevenson, was set at 
215% of salary.

In order for any annual incentive award to be made, each 
executive Director must achieve a minimum values-aligned 
behaviour rating. For 2021, both executive Directors met this 
requirement.

The level of award is determined by applying the outcome of their 
annual incentive scorecard to the maximum opportunity. The 
scorecard measures, weighting and targets were determined at 
the start of the financial year taking into account the Group's plan 
for 2021 and the Group's strategic priorities and commitments. 

The financial targets were set at the start of the financial year 
when there was significant uncertainty and challenging 
circumstances, including the emergence of new Covid-19 variants 
and ongoing low interest rates. For strategic measures, the 
performance assessment involved considering performance 
against targets set in line with our commitments, such as 
employee diversity, survey results for employee experience and 
customer satisfaction measures, as well as an assessment of the 
progress made and momentum generated to achieve our strategic 
priorities.

The Group's financial performance improved in 2021. In particular, 
the Committee noted:

• reported profit before tax was $18.9bn, which represented an 

increase of 115% compared with 2020 and an increase of 42% 
compared with 2019;

• strong cost controls were demonstrated, despite inflationary 
pressures and continued investment in technology, with 
adjusted costs at $32.15bn;

• RoTE was 8.3%; and 

Annual incentive assessment

• there was a more positive shareholder experience, including 
share price performance and shareholder returns through 
dividends and capital returns.

As set out in the scorecard assessment table below, while cost 
performance was towards the lower end of the target range, it 
was broadly in line with the Group’s revised adjusted cost 
guidance of $32bn, reflecting increases in technology investment 
and inflationary pressures. Adjusted revenue in Asia was down, 
due mainly to the impact of interest rate cuts. However, wealth 
and trade revenues grew, while loans and advances increased by 
$33bn for the year, indicating that demand remains high. We 
made strong progress towards our core objective of reducing 
RWAs in low-return franchises, achieving $104bn by the end of 
2021 and more than 95% of our cumulative target for the end of 
2022. We also made good progress on strategic measures, by 
improving customer satisfaction, maintaining the high level of 
employee engagement from 2020 and exceeding our gender 
representation target in senior leadership roles.

Overall, this level of performance resulted in a payout of 57.30% of 
the maximum for Noel Quinn and 60.43% for Ewen Stevenson. 

The annual incentive scorecard is subject to a risk and compliance 
modifier, which provides the Committee with the discretion to 
adjust down the overall scorecard outcome, taking into account 
information such as any risk metrics being 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. Taking into account the 
Group's performance against the risk metrics, inputs from the 
Group Risk Committee and overall performance of the executive 
Directors, the Committee determined that the application of the 
risk modifier was not required for 2021. 

The Committee also reviewed these outcomes in the context of a 
number of internal and external considerations to determine 
whether it should exercise its discretion to reduce the formulaic 
outcome. The Committee determined that the 2021 formulaic 
outcome appropriately rewards the executive Directors for their 
performance within the context of Group's financial performance 
and overall stakeholder experience. 

Adjusted cost ($bn)
Revenue growth in Asia (%)
RWA reduction in legacy assets/low-
return areas ($bn)1

Customer satisfaction

Employee experience

Personal objectives

Total

Maximum annual incentive 
opportunity (£000)

Annual incentive outcome
(£000)

Minimum 
(25% 
payout)

Maximum 
(100% 

payout) Performance

32.27

0.44%

31.47

0.89%

32.15

 -5.96 %

38.35

42.40

43.00

See following section for 
non-financial performance 
commentary

Noel Quinn

Ewen Stevenson

Weighting 
(%)

Assessment 
(%)

Outcome
(%)

Weighting 
(%)

Assessment 
(%)

Outcome 
(%)

 20.00 

 20.00 

 20.00 

 15.00 

 15.00 

 10.00 

 100.00 

 36.25 

 — 

 100.00 

 67.00 

 75.00 

 87.50 

 20.00 

 15.00 

 15.00 

 15.00 

 15.00 

 20.00 

 100.00 

 36.25 

 — 

 100.00 

 67.00 

 75.00 

 84.40 

 7.25 

 — 

 20.00 

 10.05 

 11.25 

 8.75 

 57.30 

£2,776

£1,590

 7.25 

 — 

 15.00 

 10.05 

 11.25 

 16.88 

 60.43 

£1,619

£978

1  As set out in our February 2020 business update, one of our objectives has been to reduce RWAs in low-return franchises and redeploy capital in 

areas of faster growth and higher returns, with a target of achieving a $100bn reduction in RWAs by the end of 2022. This target was 
subsequently amended during 2021, following a change to the methodology of capturing RWA saves. Following this amendment in methodology, 
the Committee adjusted the original target range of $28.35bn to $32.4bn and increased it to $38.35bn to $42.40bn.

268

HSBC Holdings plc Annual Report and Accounts 2021

Non-financial performance

Shared objectives for Noel Quinn and Ewen Stevenson

Objectives

Weighting Assessment Performance

15%

67%

15%

75%

Customer
satisfaction
Maintain and 
improve net 
promoter score 
('NPS') in the UK 
and Hong Kong

Employee
experience
Improve 
engagement, 
diversity and 
inclusion

•

•

In Wealth and Personal Banking, our NPS ranking in Hong Kong remained in third place, and in the 
UK our NPS increased and our overall rank improved by one place (assessed at 65%). 
In Commercial Banking, our overall NPS ranking was fourth in Hong Kong, and we ranked in the top 
three among our large corporate customers. In the UK, overall we declined one rank position in 2021. 
We continued to have a top placed NPS ranking for mid-market enterprises, and we maintained our 
NPS ranks for large corporates and small business banking clients, while our ranking fell for business 
banking customers (assessed at 57%). 

• For Global Banking and Markets, we improved our overall NPS ranking in Asia from third to first place, 

and our rank improved by one place in Europe among priority clients (assessed at 80%).

Employee engagement (assessed at 100%)
• We met our stretch target to sustain last year’s historically strong employee engagement score of 
72%. The result is four points above the global financial services benchmark and five points above 
2019 levels.

• The index comprises three areas: willingness to recommend HSBC as a great place to work, feeling 

proud to work for HSBC, and feeling valued by HSBC.

• Commentary from our survey suggests that focus on employee well-being, flexible work 

arrangements and our response to the Covid-19 pandemic have had a strong positive impact on 
employee engagement. 

Gender representation in leadership roles (assessed at 100%)
• At the end of 2021, we had 31.7% of our senior leadership roles held by female colleagues, exceeding 

our target of 31.0% for the year and on track to achieving our new goal of 35.0% by 2025.

• This has been achieved through a focus on the hiring, retention and career development of female 

colleagues. 

Black employees' representation in leadership roles (assessed at 100%)
• The number of Black heritage employees in senior leadership increased by 17.5%. 
• We are reliant on our colleagues’ choice to self-identify or not, noting that we have made good 

progress on this ethnicity data with 78.1% of UK colleagues and 95.2% of US colleagues having self-
identified. This improvement has enabled a much clearer picture of where to focus attention and we 
are using it as part of progress check-ins with executives.

Engagement among colleagues identifying as part of an ethnic minority and who identify as 
having a disability (assessed at 0%)
• At a global level, we have not closed the gap in employee engagement scores between ethnic 

minority and non-ethnic-minority colleagues, or between colleagues with disabilities versus those who 
do not have a disability. 

• While delivering meaningful change will take time, we are deepening our understanding of where 

differences arise – in particular looking at how engagement is shaped by the way diverse groups are 
represented differently across our businesses, geographies and job types.

• We have also introduced an inclusion index to help understand the sentiment of all colleagues, 

including diverse groups. This includes questions related to a sense of belonging, speak-up, trust, 
career, fair treatment and self-expression. 

HSBC Holdings plc Annual Report and Accounts 2021

269

Corporate governanceReport of the Directors | Corporate governance report

Personal objectives for Noel Quinn and Ewen Stevenson

Objectives

Weighting Assessment Performance

Noel Quinn
• Launch of refreshed 
purpose and values
• Delivery of strategy

10%

87.5%

Launch of refreshed purpose and values
• Our refreshed purpose and values were successfully deployed with strong leadership tone from the 

Group Chief Executive and Group Executives internally and externally. 

• Our employee survey to test awareness and understanding of our new purpose, values and strategy 
found that 82% of respondents said that HSBC has the right purpose, strategy and values to drive 
success, and 76% believed that the purpose and values will lead to meaningful changes in how we 
work. The strategy index is at 72%, two points ahead of the financial services benchmark that has 
trended downwards. 

• The purpose and values have been embedded into our onboarding and induction processes for 

26,500 new joiners, our recognition framework and performance management approach.

Delivery of strategy
• We are making progress across the four strategic pillars: Focus on our strengths, digitise at scale, 

energise for growth and transition to net zero.

• Focus on our strengths:

–

–

In Wealth and Personal Banking, we saw growth of 138% in net new invested assets for Asia 
wealth. In asset management, our funds under management rose 5% to $630bn. In insurance, 
the value of new business in Singapore, mainland China, and Hong Kong (including Hang Seng 
Bank) increased 40% from 2020, to reach $917m. 
In Commercial Banking, we saw strong growth in fee income in 2021, reaching $3.6bn, a 
growth of 9% compared with 2020. Our customer lending volume increased 3% to $349bn. We 
made progress on improving SME propositions in our key markets. Since the launch of Kinetic 
in the UK in 2020 we have reached 24,000 customers at the end of 2021.
In Global Banking and Markets, we reduced adjusted RWAs by 10% to $236bn at 31 December 
2021, driven by saves in our Western franchise, comprising of our Europe and Americas 
businesses. Overall, Global Banking and Markets revenue reached approximately $15bn, driven 
by strong performance in Equities, Capital Markets and Advisory, and Securities Services.
– We made progress on restructuring our US business and HSBC Bank plc, our non-ring-fenced 

–

bank in Europe and the UK. We announced three key acquisitions in 2021 to further strengthen 
our wealth franchise in Asia. We entered into an agreement to acquire AXA Singapore, pending 
regulatory approval, with the intention to merge the business with the operations of our existing 
HSBC Life Singapore franchise. We agreed to fully acquire L&T Investment Management, the 
12th largest mutual fund management company in India. We received regulatory approval to 
acquire the remaining 50% stake in HSBC Life China, bringing our shareholder ownership to 
100% upon completion. 

• Digitise at scale: We made good progress on automating our organisation at scale. Our Cloud 

adoption rate, which is the percentage of our technology services on the private or public Cloud, 
increased from approximately 20% in 2020 to 27% in 2021. At the end of 2021, 43% of our 
customers were 'mobile active' users, who are customers that had logged onto a mobile app at least 
once in the last 30 days. This is an improvement compared with 38% in 2020. 

• Energise for growth: We continue to help to energise our colleagues through initiatives that help 

develop their future skills and learning opportunities, in areas including data, digital and 
sustainability.  

• Transition to net zero: In 2021, we reduced our organisation’s absolute greenhouse gas emissions in 
our operations to 341,000 CO2 tonnes, a decrease of 50% using 2019 as the baseline. We provided 
and facilitated $82.6bn of sustainable finance and investment, taking the cumulative amount to 
$126.7bn since 1 January 2020, as part of our $750bn to $1tn by 2030 ambition.

Ewen Stevenson
• Finance on the Cloud 

deployment

• Climate stress test
• Resolvability 
assessment 
framework attestation

• Reduce Global 

Finance function 
costs and number of 
FTEs

20%

84.4%

• The Finance on the Cloud programme entered into the implementation phase in 2021. The RWA and 

liquidity Cloud migrations from the legacy Platfora solution was completed and the UK Cloud 
transformation was extended to liquidity. All regulatory obligations in relation to this were met. We 
also made progress with the global roll-out of the Cloud solution in Hong Kong and the US.

• We significantly developed our climate scenario capabilities, largely driven by the climate biennial 

exploratory scenario exercise and through developing a framework to incorporate client adaptation 
plans into climate scenario analysis to address insufficient client data issues. We developed 
reporting that includes the Group’s carbon reduction metrics, with reporting of high-risk sectors 
included in the quarterly Group Executive Committee update. We also enhanced disclosures to cover 
quantitative risk metrics aligned with the climate risk appetite statement. 

• We built capabilities to support the resolvability assessment framework and met all regulatory 

deadlines during 2021 in relation to this. 

• The Global Finance function costs were marginally above target due to market pay challenges and 

the target for full-time equivalent colleagues was largely met. 

270

HSBC Holdings plc Annual Report and Accounts 2021

Single figure of remuneration

(Audited)

The following table shows the single figure of total remuneration of each executive Director for 2021, together with comparative figures. 

Single figure of remuneration

(£000)
Base salary1
Fixed pay allowance ('FPA')1
Cash in lieu of pension
Taxable benefits2
Non-taxable benefits2
Total fixed
Annual incentive3
Notional returns4
Replacement award5
Total variable

Total fixed and variable

Noel Quinn

Ewen Stevenson

2021

1,288

1,700

129

95

71

3,283

1,590

22

— 

1,612

4,895

2020

1,266

1,700

127

186

59

3,338

799

17

—

816

4,154

2021

751

1,062

75

3

42

1,933

978

—

754

1,732

3,665

2020

738

950

74

12

32

1,806

450

—

1,431

1,881

3,687

1 Executive Directors made the personal decision to donate 100% of their base salary increases for 2021 to charity given the ongoing challenging 
external environment. Ewen Stevenson also donated his FPA increase for 2021 to charity. Figures shown in the table above are the gross figures 
before charitable donations. 

2  Taxable benefits include the provision of medical insurance, 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.

3  Noel Quinn and Ewen Stevenson both voluntarily waived the cash portion of their 2020 annual incentive. Without this voluntary waiver, the 2020 

annual incentive of Noel Quinn and Ewen Stevenson would have been £1,598,000 and £900,000, respectively. 

4  The deferred cash awards granted in prior years includes a right to receive notional returns for the period between the grant and vesting date. This 

5 

is determined by reference to a rate of return specified at the time of grant and paid annually, with the amount disclosed on a paid basis. 
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. The values included in the table for 
2020 relate to his 2017 LTI award granted by the Royal Bank of Scotland Group plc ('RBS'), now renamed as NatWest Group plc ('NatWest'), for 
performance year 2016, which was determined by applying the performance assessment outcome of 56.25% as disclosed in NatWest'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 NatWest 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. The value included in the table for 2021 relates to Ewen Stevenson's 2018 LTI 
replacement award granted by NatWest for performance year 2017 and was subject to a pre-vest performance test assessed and disclosed by 
NatWest in its Annual Report and Accounts 2020 (page 135). As no adjustment was proposed for Ewen Stevenson by NatWest, a total of 
177,883 shares granted in respect of his 2018 LTI replacement award ceased to be subject to performance conditions. These awards were 
granted at a share price of £6.643 and the HSBC share price was £4.240 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 table.1

(£000)

Insurance benefit (non-taxable)
Car and driver (UK and Hong Kong)2

Noel Quinn

2021

67

87

2020

51

139

1  The insurance and car benefits for Ewen Stevenson are not included in the above table as they were not deemed significant.
2  The 2021 car and driver benefit was lower than 2020 due to the impact of travel restrictions during the Covid-19 pandemic. 

Long-term incentive awards

(Audited)

Long-term incentive in respect of 2021

After taking into account performance for 2021, the Committee 
decided to grant Noel Quinn and Ewen Stevenson LTI awards of 
£4,131,000 and £2,410,000, respectively. 

The 2021 LTI awards will have a three-year performance period 
starting 1 January 2022. During this period, performance will be 
assessed based on 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'). This is consistent with the 
measures used for our last LTI award. 

RoTE is a key measure of our financial performance and how we 
generate returns that deliver value for our shareholders. The target 
range for this measure is aligned with our medium-term objective 
of achieving a RoTE of 10% or more.

Capital reallocation to Asia remains 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. The target range for 
this measure is aligned with our long-term strategic plan. 

The transition to net zero scorecard measures are aligned to our 
strategic priority of bringing carbon emissions in our own 
operations to net zero by 2030 and supporting our customers in 
the transition to a more sustainable future, by providing and 
facilitating $750bn to $1tn of sustainable finance and investment 
over the same time period. 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 rewards executive Directors based on comparison of 
the TSR performance of the Group and a relevant peer group. No 
changes were made to the peer group for this LTI award. The 
Committee will review the TSR peer group for future LTI awards to 
ensure the peer group remains appropriate, taking into account 
the progress in the execution of our strategic shifts in our 
geographical and business mix, notably future growth investment 
in Asia and wealth business. 

The LTI continues to be subject to a risk and compliance modifier, 
which gives the Committee the discretion to adjust down the 

HSBC Holdings plc Annual Report and Accounts 2021

271

Corporate governance 
Report of the Directors | Corporate governance report

overall 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.

The RoTE and capital reallocation to Asia measures are also 
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 these 
measures will be reduced to nil.

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.

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.

Performance conditions for LTI awards in respect of 2021 (performance period 1 January 2022 to 31 December 2024)

Measures1
RoTE (with CET1 underpin)2

Capital reallocation to Asia (with CET1 
underpin)3

Transition to net 
zero4

Carbon reduction

Sustainable finance 
and investment

Relative TSR5

Minimum
(25% payout)

Target
(50% payout)

Maximum
(100% payout)

Weighting
%

8.0%

46.0%

52.0%

9.5%

48.0%

56.0%

11.0%

50.0%

60.0%

$285.0bn

$340.0bn

$370.0bn

At the median of the peer 
group

Straight-line vesting between 
minimum and maximum

At the upper quartile of the 
peer group

25.0

25.0

25.0

25.0

1 Awards will vest on a straight-line basis for performance between the minimum, target and maximum levels of performance set in this table.
2 To be assessed based on RoTE at the end of the performance period. This metric will be subject to the CET1 underpin outlined above. 
3  To be assessed based on share of Group tangible equity (on a constant currency basis and excluding associates) allocated to Asia by 31 December 

2024. This metric will be subject to the CET1 underpin outlined above. 

4  Carbon reduction will be measured based on percentage reduction in total energy and travel emissions achieved by 31 December 2024 using 

2019 as the baseline. The sustainable finance and investment metric will assess cumulative financing provided over the period commencing on 
1 January 2020 and ending on 31 December 2024.

5  The peer group for the 2021 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. 

2018 long-term incentive performance

The 2018 LTI award was granted to John Flint (former Group Chief Executive) and Marc Moses (former Group Chief Risk Officer).

Based on the scorecard outcome, 78,071 shares will vest for John Flint and 54,932 shares will vest for Marc Moses (determined by pro-
rating their awards for time in employment during the performance period of 1 January 2019 to 31 December 2021). The awards will vest 
in five equal annual instalments commencing in March 2022. Using the average daily closing share prices over the three months to 31 
December 2021 of £4.339 the value of awards to vest to John Flint and Marc Moses is £338,750 and £238,350, respectively.

Assessment of the LTI award in respect of 2018 (performance period 1 January 2019 to 31 December 2021)

Minimum

Target

Maximum

Measures (with weighting)

(25% payout)

(50% payout)

(100% payout)

Actual

Assessment Outcome

Average RoTE (with CET1 underpin) 
(75%)

Employer advocacy1 (12.5%)

10.0%

65%

Environmental, social and 
governance rank2 (12.5%)

At median of the peer 
group

Total3

11.0%

70%

Straight-line vesting 
between minimum 
and maximum

12.0%

75%

6.6%

70%

0.0%

0.00%

50.0%

6.25%

At upper quartile of 
peer group

Above upper 
quartile

100.0%

12.50%

18.75%

1  Assessed based on results of the 2021 employee Snapshot survey question: 'I would recommend this company as a great place to work'.
2  Based on Sustainalytics ratings. Peer group for this measure included 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.

3  The award was subject to a risk and compliance underpin which gives the Committee the discretion to adjust down the overall scorecard 

outcome, taking into account performance against risk and compliance factors during the performance period for the award. Taking into account 
inputs received from Group Risk and Compliance and the Group Risk Committee, the Committee considered the application of the risk and 
compliance underpin was not required.

272

HSBC Holdings plc Annual Report and Accounts 2021

 
Scheme interests awarded during 2021

(Audited)

The table below sets out the scheme interests granted to executive Directors during 2021 in respect of performance year 2020, as 
disclosed in the 2020 Directors’ remuneration report. No non-executive Directors received scheme interests during the financial year.

Scheme awards in 2021

(Audited)

Ewen Stevenson

Noel Quinn 

Type of interest 
Basis on which 
awarded
award made
LTI deferred shares2 % of salary2
LTI deferred shares2 % of salary2

Date of award

Face value
awarded1
£000

Percentage receivable 
for minimum
performance

Number of
shares
awarded

End of
performance period

1 March 2021  

1 March 2021  

2,716 

4,767 

 25 

637,197

31 December 2023

 25  1,118,554

31 December 2023

1 The face value of the award has been computed using HSBC's closing share price of £4.262 taken on 26 February 2021. 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 2021 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 293% of salary for Noel Quinn and 286% of 
salary for Ewen Stevenson. The number of shares to be granted was determined by taking HSBC's closing share price of £4.262 taken on 
26 February 2021, and applying a discount based on HSBC’s expected dividend yield of 5% per annum for the vesting period (£3.324). 

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 2020 are set out below:

Performance conditions for LTI awards in respect of 2020 (performance period 1 January 2021 to 31 December 2023)

Measures1
RoTE (with CET1 underpin)2
Capital reallocation to Asia (with CET1 underpin)3

Environment and 
sustainability4

Relative TSR5

Carbon reduction

Sustainable finance and 
investment

Minimum
(25% payout)

Target
(50% payout)

Maximum
(100% payout)

Weighting
%

8.0%

45.0%

42.0%

9.0%

47.0%

48.0%

10.0%

50.0%

51.0%

$200.0bn

$240.0bn

$260.0bn

At median of the
peer group

Straight-line vesting between 
minimum and maximum

At upper quartile of 
peer group

25.0

25.0

25.0

25.0

1 Awards will vest on a straight-line basis for performance between the minimum, target and maximum levels of performance set in this table.
2  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.

3  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.

4  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. The sustainable finance and investment metric will assess cumulative financing provided over the period commencing on 
1 January 2020 and ending on 31 December 2023. 

5  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.

Executive Directors’ interests in shares

(Audited)

The shareholdings of executive Directors in 2021, including the 
shareholdings of their connected persons, at 31 December 2021 
(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 2021 to the date of this report.

Individuals have five years from their appointment date to build up 
the recommended levels of shareholding. In line with investor 
guidance, for executive Directors, unvested shares which are not 
subject to forward-looking performance conditions (on a net of tax 
basis) will count towards their shareholding requirement under the 
new policy proposed for shareholder approval at the 2022 AGM.

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 post-employment shareholding arrangements,

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 
employment due to the following features of the policy: 

• 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.

• LTI awards have a seven-year vesting period with a one-year 
post-vesting retention period, which is not accelerated on 
departure. The weighted average holding period of an LTI 
award within HSBC is therefore six years, in excess of the five-
year holding period typically implemented by FTSE-listed 
companies. 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.

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.

HSBC Holdings plc Annual Report and Accounts 2021

273

Corporate governanceReport of the Directors | Corporate governance report

Shares
(Audited)

Executive Directors
Noel Quinn6
Ewen Stevenson6

At 31 Dec 2021

Scheme interests

Shares awarded 
subject to deferral1

Shareholding 
guidelines
(% of salary)

Shareholding at 
31 Dec 20212 (% of 
salary)

Share interests
(number
of shares)

Share options3

without
 performance 
conditions4

with
performance
conditions5

400%

300%

380%  

483%  

1,131,278   

838,154   

—   

—   

481,634   

506,743   

1,118,554 

1,113,954 

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 2021 (£4.339).
3  At 31 December 2021, 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, now renamed as NatWest Group plc ('NatWest'), and is subject to any performance adjustments assessed and disclosed in the relevant 
NatWest Annual Report and Accounts.

5  LTI awards granted in February 2020 and 2021 are subject to the performance conditions as set out on page 273. 
6  All Group Executives 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). For Group Executives, their shareholding 
requirement is 250% of salary and unvested shares that are not subject to forward-looking performance conditions (on a net of tax basis) are 
counted towards their shareholding requirement. 

Total pension entitlements 

External appointments

(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 
colleagues is 65.

Payments to past Directors

(Audited)
Details of the 2018 LTI outcome, in which John Flint (former Group 
Chief Executive) and Marc Moses (former Group Chief Risk Officer) 
participated, are outlined on page 272. 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)
No payments for loss of office were made to, or in respect of, 
former or current Directors in the year.

During 2021, executive Directors did not receive any fees from 
external appointments.

Implementation of remuneration policy in 2022 
for executive Directors

The base salary of our executive Directors will increase by 3.5% 
with effect from 1 March 2022. The Committee determined the 
increase was necessary to ensure that the total remuneration 
opportunity of our executive Directors does not fall further behind 
desired levels based on the size, complexity and international peer 
group of the Group. This was discussed with shareholders during 
our engagement with them on the new Directors' remuneration 
policy.

The increase is in line with the average salary increase of our 
wider workforce. There is no other change to the remuneration 
elements of our executive Directors.

The following table summarises how the maximum opportunity for 
each element of our remuneration policy for executive Directors 
will be implemented in 2022.

Implementation of remuneration policy in 2022

Summary of operation

3.5% increase with effect from 1 March 2022 (in line 
with the increase for the wider workforce)
No change

Noel Quinn

£1,336,000

£1,700,000

Ewen Stevenson

£779,000

£1,085,000

Base salary 

Fixed pay allowance 

Cash in lieu of pension

Benefits

No change

No change

Annual incentive

No change in maximum opportunity

Long-term incentive

No change in maximum opportunity

2022 annual incentive scorecards

The 2022 annual incentive scorecard measures for our executive 
Directors have been set to deliver growth and business 
transformation. The targets for the measures have been set, 
reflecting on the Group's plan for 2022 and the macroeconomic 
uncertainty, including the interest rate environment and inflation.

The Committee will continue to retain discretion to adjust the 
formulaic outcomes of scorecards, taking into account factors 
such as Group profits, wider business performance and 
stakeholder experience, to ensure executive reward is aligned with 
underlying Group performance and the broader stakeholder 
experience.
The weightings and performance measures for the 2022 annual 
incentive award for executive Directors are disclosed below. The 
performance targets are commercially sensitive and it would be 

274

HSBC Holdings plc Annual Report and Accounts 2021

10% of base salary

Same benefit provisions will be made available

Maximum opportunity will be 215% of base salary

Maximum opportunity will be 320% of base salary

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 2022 annual incentive scorecards for members of our Group 
Executive Committee include similar measures as for the executive 
Directors to drive performance in each of our businesses, 
functions and regions that contribute to the overall success of the 
Group. The Group Executives' LTI awards in respect of 2021 will 
also be subject to the same three-year forward-looking scorecard 
measures and targets as set out on page 271.

2022 annual incentive scorecard measures and weightings

Measures

Group adjusted profit before tax

Growth in Group lending and net new invested assets

RoTE

Group adjusted costs

Customer satisfaction in the UK, Hong Kong and key growth markets

Employee experience through maintaining and improving engagement, increasing diversity and improving inclusion

Personal objectives
Group Chief Executive
• Technology transformation, growth initiatives, restructuring of the Group and driving innovation programmes. 
Group Chief Financial Officer
• Finance of the future, creating strong corporate development and Group transformation functions, Global Finance 

function employee experience and Global Finance function efficiency. 

Total

Noel Quinn

Ewen Stevenson

Weighting %

Weighting %

 20.0 

 15.0 

 15.0 

 10.0 

 15.0 

 15.0 

 15.0 

 10.0 

 15.0 

 10.0 

 15.0 

 15.0 

 10.0 

 20.0 

 100.0 

 100.0 

The Group adjusted profit before tax, Group lending and net new 
invested assets growth, RoTE and Group adjusted costs measures 
will be subject to a CET1 underpin. If the CET1 ratio on 31 
December 2022 is below the CET1 risk tolerance level set in the 
risk appetite statement, then the assessment for these measures 
will be reduced to nil. The 2022 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.

Non-executive Directors

(Audited)

The following table shows the total fees and benefits of non-executive Directors for 2021, together with comparative figures for 2020.

Fees and benefits
(Audited)
(£000)
Henri de Castries3
Laura Cha3, 4
Rachel Duan5
Dame Carolyn Fairbairn6
James Forese7
Steven Guggenheimer8
Irene Lee9
José Antonio Meade Kuribreña10
Heidi Miller3, 11
Eileen Murray12
David Nish13
Jackson Tai
Mark Tucker14
Pauline van der Meer Mohr15
Total (£000)

Total ($000)

Fees1

Benefits2

Total

2021

2020

2021

2020

2021

82   

242   

67   

80   

572   

250   

556   

223   

251   

266   

482   

350   

1,500   

291   

5,212   

7,169

202   

587   

—   

—   

160   

134   

546   

202   

632   

120   

480   

355   

1,500   

312   

5,230   

6,958

22   

18   

—   

—   

—   

—   

—   

—   

19   

—   

10   

—   

33   

—   

102   

140

1   

—   

—   

—   

—   

—   

—   

4   

7   

—   

8   

12   

52   

2   

79   

105

104   

260   

67   

80   

572   

250   

556   

223   

270   

266   

492   

350   

1,533   

291   

5,314   

7,309

2020

203 

587 

— 

— 

160 

134 

546 

206 

639 

120 

488 

367 

1,552 

314 

5,309 

7,063

1 Fees are in line with the Directors' remuneration policy that was approved at the 2019 AGM. 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, no travel allowance was paid to non-executive Directors during 2021. 

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  Retired from the Board on 28 May 2021.
4 

Includes fees of £177,000 (2020: £423,800) for her role as non-executive Chair and member of the Nomination Committee of The Hongkong and 
Shanghai Banking Corporation Limited.  

5  Appointed to the Board and as a member of the Group Remuneration Committee and Nomination & Corporate Governance Committee on 

1 September 2021.

6  Appointed to the Board and as a member of the Group Risk Committee, Group Remuneration Committee and Nomination & Corporate 

7 

Governance Committee on 1 September 2021.
Includes fees of £332,000 (2020: £nil) in relation to his role as a non-executive Director of HSBC North America Holdings, Inc. He was appointed 
as non-executive Chair on 28 May 2021.

8  Appointed as Co-Chair of the Technology Governance Working Group on 1 March 2021. 
9 

Includes fees of £380,000 (2020: £546,000) 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 and in relation to her role as non-executive Chair of Hang 
Seng Bank Limited. 

10  Appointed to the Group Remuneration Committee on 28 May 2021.
11 Includes fees of £169,000 (2020: £431,000) in relation to her role as non-executive Chair of HSBC North America Holdings, Inc.
12 Appointed as Co-Chair of the Technology Governance Working Group on 1 March 2021. Stepped down as a member of the Group Audit 

Committee on 28 May 2021. 

13 Stepped down as a member of Group Remuneration Committee on 23 February 2021.
14 As previously announced in 2020, a part of the fee for 2021 was donated to charity. The fee shown in the single figure of remuneration is the gross 

fee before charitable donations. 

15 Stepped down as a member of the Group Risk Committee on 28 May 2021.

HSBC Holdings plc Annual Report and Accounts 2021

275

Corporate governance 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Directors | Corporate governance report

Non-executive Directors’ interests in shares

set out below. 

(Audited)

The shareholdings of persons who were non-executive Directors in 
2021, including the shareholdings of their connected persons, at 
31 December 2021, or date of cessation as a Director if earlier, are 

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 2021 met the guidelines.

Shares

Laura Cha (retired on 28 May 2021)

Henri de Castries (retired on 28 May 2021)

Rachel Duan (appointed to the Board on 1 Sep 2021)

Dame Carolyn Fairbairn (appointed to the Board on 1 Sep 2021)

James Forese

Steven Guggenheimer

Irene Lee

José Antonio Meade Kuribreña

Heidi Miller (retired on 28 May 2021)

Eileen Murray

David Nish 

Jackson Tai 

Mark Tucker

Pauline van der Meer Mohr 

2022 fees for non-executive Directors

The table below sets out the 2022 fees for non-executive Directors.

Position
Non-executive Group Chairman1
Non-executive Director (base fee)

Senior Independent Director

Group Risk Committee

Group Audit Committee and Group Remuneration Committee

Nomination & Corporate Governance Committee

Technology Governance Working Group 

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  

Chair

Member

Chair

Member

Chair

Member

Co-Chair

16,200 

19,251 

— 

— 

115,000 

15,000 

15,000 

15,000 

15,700 

75,000 

50,000 

66,515 

307,352 

15,000 

2022 fees

£

1,500,000

127,000

200,000

150,000

40,000

75,000

40,000

––

33,000

60,000

1  The Group Chairman does not receive a base fee or any other fee in respect of chairing of the Nomination & Corporate Governance Committee.

276

HSBC Holdings plc Annual Report and Accounts 2021

 
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 2021.

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

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

Group Chief Executive

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Stuart 
Gulliver

Total single figure £000
Annual incentive1 (% of maximum)
Long-term incentive1,2,3 (% of maximum)

7,532

8,033

7,619

7,340

5,675

6,086

52%

40%

49%

49%

54%

44%

45%

41%

64%

–%

80%

–%

2,387

76%

100%

John 
Flint

4,582

76%

–%

John 
Flint

2,922

61%

–%

Noel 
Quinn

1,977

66%

–%

Noel 
Quinn

Noel 
Quinn

4,154

4,895

32%

57%

–%   — %

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 2012 to 2015 are therefore related to awards granted in 2013 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 2018 LTI award that had a 
performance period ended on 31 December 2021.

Relative importance of spend on pay

The following chart shows the change in:

• total staff pay between 2020 and 2021; and

• dividends and share buy-backs in respect of 2020 and 2021.

In 2021, total spend on pay was up from 2020, and the distribution 
to shareholders also increased from 2020 with the reinstatement 
of dividends (following the suspension of dividend payments 
during 2020) and the capital return to shareholders through the up 
to $2bn share buy-back announced in October 2021. In addition, 
the Group has announced the intention to initiate a further up to 
$1bn buy-back, to commence after the existing buy-back has 
concluded. Dividends include an approximation of the amount 
payable on 28 April 2022 in relation to the second interim dividend 
of $0.18 per ordinary share.

Relative importance of spend on pay

2021  —

$5,070m

$2,000m

$7,070m

Total return to 
shareholder

2020  —

$3,059m

2021  —

$18,742m

Employee pay

2020   —

$18,076m

ì
131.1%

ì
3.7%

Employee pay

Dividends

Share buy-back

HSBC Holdings plc Annual Report and Accounts 2021

277

HSBC TSRFTSE 100 Total Return IndexDec 2011Dec 2012Dec 2013Dec 2014Dec 2015Dec 2016Dec 2017Dec 2018Dec 2019Dec 2020Dec 2021100%200%Corporate governanceReport of the Directors | Corporate governance report

Our approach to workforce remuneration

Remuneration principles

Our performance and pay strategy aims to competitively reward 
long-term sustainable performance. Our goal is to attract, motivate 
and retain the very best people, regardless of gender, ethnicity,

Principle

Our approach in 2021

age, disability or any other factor unrelated to performance or 
experience. This supports the long-term interests of our 
stakeholders, including our customers and the communities we 
serve, our shareholders and our regulators.
Our approach to performance and pay in 2021 for the broader 
workforce was underpinned by our remuneration principles. 

Fair, 
appropriate 
and free from 
bias

• We help managers to make informed, consistent and fair pay decisions. Variable pay for 92% of our employees is either set centrally 

or based on a starting point recommendation from HR.

• Communications and reporting encourage our managers to: challenge their assessments; question whether they were objective; and 

use facts to make decisions.

A culture of 
continuous 
feedback 
through 
manager and 
employee 
empowerment

Reward and 
recognition of 
sustainable 
performance 
and values-
aligned 
behaviour

Balanced, 
simple and 
transparent 
total reward 
packages, 
which support 
employee well-
being  

• Managers in similar roles complete ‘fairness reviews’ where they discuss the performance and values-aligned behaviour ratings of 
their teams. They help each other to make objective decisions by providing a diverse range of examples, facts and viewpoints, and 
challenge each other to mitigate the risk of unconscious bias.

• During the annual review process, HR and management perform checks to ensure outcomes are in line with our principles and are 

equitable. We use data to identify employees whose pay is lower than their comparable peer group. If there is no objective reason for 
these variances, such as performance or skills and experience, we make 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 2021, we further improved our culture of continuous feedback, with 66% of our colleagues saying that conversations with their 

managers across the year had a positive impact on their performance and 62% reporting positive effects on their well-being.

• Our continuous feedback tool, including a mobile app, makes it easier for our colleagues to share feedback with each other in the 

moment, providing a structure so that they can share what went well and what they could do better in specific situations.
• We encourage colleagues to use our online career planning tools to help them with their thinking about future roles and the 

capabilities they require and to drive conversations.

• Individual performance is assessed against clear and relevant financial and non-financial objectives. These set out expectations for 

each colleague in terms of performance and development. 

• We recognise our colleagues not just for results, but also for demonstrating our values. As such, subject to local law, our colleagues 

receive a behaviour rating as well as a performance rating. 

• Group and business performance is used to determine the Group variable pay pool and that of each business. Where performance in 

a year is weak, as measured by both financial and non-financial metrics, this will impact the relevant pool. The final pool also 
considers the external operating environment and the expectations of our stakeholders. 

• We undertake analytical reviews to ensure there is clear pay differentiation across both performance and behaviour ratings. This is 

provided to senior management and the Committee as part of their oversight of the remuneration outcomes for the Group. 

• 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.

• We promote employee share ownership through variable pay deferrals and voluntary enrolment in an all-employee share plan.

• Paying our colleagues fairly and appropriately is critical to delivering on our strategic commitments. We work extensively with our 

external market benchmarking consultants to get the latest insights on market pay levels and areas of potential risk. That guides us 
as we make pay decisions, allowing us to focus on managing people risks and areas critical to our strategy.

• 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. Decisions are informed, but not driven, by market position and practice.
• We are committed to employee well-being and offer employee benefits that support the mental, physical and financial health of a 

diverse workforce.

• We review pay based on gender to uphold our commitment to inclusion and pay equity.
• 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’. In 
nine of our jurisdictions where a 'living wage' has been defined, our employees are paid at or above that level. We also undertake 
regular reviews of equal pay for gender.

• As part of our commitment to the World Economic Forum ('WEF') metrics on measuring stakeholder capitalism, we review entry 
level wages in key markets to compare both men and women against the local minimum wage. This provided an indication of 
fairness at point of career entry. We have included data from the UK, US and Mexico where we have sufficient entry-level colleagues 
and good quality gender disclosures to allow for meaningful analysis (see table below). In line with expectations, the data shows 
broad consistency between male and female outcomes.

Average standard entry level vs. minimum wage by gender as at 31 December 2021

Market

UK

US

Mexico

Male

115%

153%

259%

Female

114%

162%

250%

All

114%

158%

254%

To calculate the above, we have used an average of annualised fixed pay to allow for a like-for-like comparison to include colleagues who work part-
time. For colleagues based in the UK, we have compared the entry level wage against the UK national minimum wage. For the US, our comparison is 
against the respective state minimum wage, which is slightly higher than the federal minimum wage. In Mexico, we have used the minimum wage, 
which is regulated by the National Minimum Wage Commission.

278

HSBC Holdings plc Annual Report and Accounts 2021

 
Supporting colleagues in 2021

The well-being of our people remained a critical focus, in particular 
as the operating environment continued to be challenging for 
many colleagues and their families. The pandemic was a key 
influence on our activities during the year and our country-based 
approach allowed us to respond quickly and flexibly to specific 
situations in each of our markets. In India, we took urgent steps 
during the second wave of the pandemic to help our colleagues 
and their dependants with access to support via a Covid-19 
taskforce consisting of employee volunteers working in 
collaboration with partners. Our offices in India were set up to 
manage vaccination drives for employees and their families and 
we provided financial support to local non-profit organisations 
delivering the relief effort on the ground.

Our global well-being programme covered three pillars: mental, 
physical and financial well-being. Despite the immense challenges, 
sentiment remained high. A total of 82% of colleagues rated their 
mental well-being as positive, 75% rated their physical well-being 
positively and 64% of colleagues reported their financial well-
being as positive in our December survey.

Our survey suggests that work-life balance has improved, with 
76% of colleagues saying they can integrate their work and 
personal life positively, compared with 74% in 2020.

The pandemic offered us the opportunity to take the best of what 
we learnt and rethink the future of work. To support our approach, 
we created three guiding principles:

• Customer focus: We aim to make sure the way we work helps 

deliver the best commercial outcomes for our customers.

• Team commitment: We will connect with each other, build our 

from 56% in 2020. Our colleagues tell us that these have a positive 
impact on their performance, development and well-being, and are 
important in motivating them to perform at their best.

We also measure our colleagues’ sentiment on performance and 
pay matters through our annual pay review surveys. In the most 
recent survey, a significant proportion of the respondents’ 
comments indicated they believed they were paid fairly for what 
they do. It also highlighted challenges on market positions and 
potential retention issues in certain areas. Noting this sentiment of 
our colleagues, the extraordinarily competitive market for talent 
and material improvement in the Group's financial performance, 
we agreed a Group variable pay pool of $3,495m. This was 
determined using our countercyclical funding methodology under 
which a ceiling is used to limit the increase in variable pay pool at 
higher levels of performance. Therefore, while adjusted profit 
before tax rose 79%, the year-on-year increase in Group variable 
pay pool was 31%, following a reduction of 20% in 2020. In 
addition, fixed pay increases were targeted towards junior 
colleagues to help address the impact of rising inflation in many of 
our locations.

Throughout the year we also recognise our colleagues for 
demonstrating our values. The ‘At Our Best‘ recognition online 
platform allows for real-time recognition and communication of 
positive behaviours by colleagues, in line with our refreshed 
purpose and values. We ran a special ‘Spotlight on valuing 
difference’ campaign to recognise the exceptional actions of our 
colleagues in being empathetic, championing inclusivity, listening 
and seeking out different perspectives. An additional points 
budget was allocated and there were over 130,000 recognitions 
during the campaign.

community and collaborate.

Remuneration structure for Group employees

• Flexibility: We will provide our colleagues with more choice on 
how, when and where we work, suitable to the roles we do.

Considering the challenges colleagues faced, it was encouraging 
to see that check-ins happened regularly, with 60% of colleagues 
having frequent conversations with their managers, an increase

Total compensation, which comprises fixed and variable pay, is 
the key focus of our remuneration framework, with variable pay 
differentiated by performance and demonstration of values-aligned 
behaviours. 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:

Overview of remuneration structure for employees

Application for Group employees

Approach for executive 
Directors

• May include salary, fixed pay allowance, cash in lieu of pension and other cash allowances in 

• Consistent with approach 

accordance with local market practice. 

• Based on predetermined criteria, non-discretionary, transparent and not reduced based on 

performance.

• Represents a higher proportion of total compensation for more junior employees.
• May change to reflect an individual’s position, role or grade, cost of living in the country, 

individual skills, capabilities and experience.

• Fixed pay is generally delivered in cash on a monthly basis.

for Group colleagues 
except fixed pay 
allowance paid in shares. 

• Benefits may include, but are not limited to, the provision of a pension, medical insurance, life 

• Provision of medical 

insurance, health assessment and relocation support.

Remuneration components 
and objectives

Fixed pay
Attract and retain 
employees with market 
competitive pay for the 
role, skills and experience 
required.

Benefits
Support the physical, 
mental and financial health 
of a diverse workforce in 
accordance with local 
market practice.

Annual incentive
Incentivise and reward 
performance based on 
annual financial and non-
financial measures 
consistent with the 
medium- to long-term 
strategy, stakeholder 
interests and values-
aligned behaviours.

• All employees are eligible to be considered for a discretionary variable pay award. Individual 
awards are determined against objectives for performance set at the start of the year.    

• Represents 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 for Group employees identified as Material Risk Takers ('MRTs') under European 
Union Regulatory Technical Standard ('RTS') 2021/923 is limited to 200% of fixed pay, as 
approved by shareholders at the 2014 AGM held on 23 May 2014 (98% in favour).

• 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.

insurance, life insurance, 
car and tax return 
assistance. Group Chief 
Executive is eligible to 
receive accommodation 
and a car benefit in Hong 
Kong. 

• Annual incentive is 

determined based on the 
outcomes of annual 
scorecard of financial and 
non-financial measures.
• Executive Directors and 

Group Executives are also 
eligible to be considered 
for a long-term incentive 
award, which is subject 
to three-year forward-
looking performance 
measures. See details on 
page 257.

HSBC Holdings plc Annual Report and Accounts 2021

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Overview of remuneration structure for employees (continued)

Remuneration components 
and objectives

Deferral
Align employee interests 
with the medium- to long-
term strategy, stakeholder 
interests and values-
aligned behaviours.

Approach for executive 
Directors

• All of the LTI award, or at 
least 60% of the total 
variable award (including 
LTI), is deferred. The 
deferred awards will vest 
in five equal annual 
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.

• All deferred awards are in 
HSBC shares and subject 
to a post-vesting 
retention period of one 
year.

Application for Group employees

• 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.

• For MRTs awards are generally subject to a minimum 40% deferral (60% for awards of 

£500,000 or more) over a minimum period of four years. 

• A deferral period of five years is applied for senior management and individuals identified in 

specified roles with managerial responsibilities as prescribed under the PRA and FCA 
remuneration rules.

• A deferral period of seven years is applied for individuals in PRA-designated senior 

management functions.

• 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 variable pay is £44,000 or less and variable pay is not more than 
one-third of total compensation. For these individuals, the Group standard deferral applies.
• Individuals based outside the UK and identified as MRTs under local regulations, would be 

subject to local requirements where necessary.

• 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 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.

• 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. Local regulatory requirements would also apply where 
necessary.

• 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.

• 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. 

• 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.

• Where an employee is subject to more than one regulation, the requirement specific to the 

sector and/or country in which the individual is working is applied.

Buy-out awards
Support recruitment of key 
individuals.

Guaranteed variable 
remuneration
Support recruitment of key 
individuals.

Severance payments
Adhere to contractual 
agreements with 
involuntary leavers.

• Buy-out awards may be offered if an individual holds any outstanding unvested awards that 

• For new hires, the 

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.

approach is consistent 
with the approach taken 
for employees and policy 
approved by 
shareholders.

• Guaranteed variable remuneration is awarded in exceptional circumstances for new hires, 

• For new hires, the 

and is limited to the individual’s first year of employment only.

• The exceptional circumstances 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 and 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.

approach is consistent 
with the approach taken 
for employees and policy 
approved by 
shareholders.

• Any payments will be in 
line with the policy on 
loss of office as noted on 
page 274.

280

HSBC Holdings plc Annual Report and Accounts 2021

 
Link between risk, performance and reward

Our remuneration practices promote sound and effective risk 
management while supporting our business objectives and the 
delivery of our strategy. 

Alignment between risk and reward

We set out below the key features of our framework, which help 
enable us to achieve alignment between risk, performance and 
reward, subject to compliance with local laws and regulations:

Framework 
elements

Variable pay 
pool

Individual 
performance 
scorecard

Control 
function staff

Application

The Group variable pay pool is expected to move in line with Group performance, based on a range of financial, non-financial and 
contextual factors. 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, financial and resourcing plan and global 

conduct outcomes; and

• fines, penalties and provisions for customer redress, which are automatically included in the Committee’s definition of profit for 

determining the pool.

In the event that the Group was unable to distribute dividends to shareholders for reasons such as capital adequacy, then the Group may 
determine that as a year of weak performance. In such a year, the Group may withhold some, or all, variable pay for employees including 
unvested share awards, using the metrics outlined above as a basis for that determination.

• Assessment of individual performance is made with reference to clear and relevant financial and non-financial objectives. Objectives 
for 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.

• 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. 

• Their remuneration is determined independent of the performance of the business areas they oversee.
• The Committee is responsible for approving the remuneration for the Group Chief Risk and Compliance Officer and Group Head of 

Internal Audit.

• Group policy is for control functions staff to report into their respective function. Remuneration decisions for senior functional roles are 

made by 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 values-aligned behaviours 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 in PRA and FCA designated senior management functions 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 and using the following key 

principles that 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.

• 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.

HSBC Holdings plc Annual Report and Accounts 2021

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Report of the Directors | Corporate governance report

Comparison of Directors' and employees' pay

The following table compares the changes in each Director's 
salary, taxable benefits and annual incentive between 2020 and 
2021 with the percentage change in each of those elements of pay 
for UK-based employees of HSBC Group Management Services 
Limited, the employing entity of the executive Directors. 

There were no changes to the fees or benefits of the non-executive 
Directors between 2021 and 2020. The year-on-year percentage 
change in fees noted in the table below is primarily driven by any

Annual percentage change in remuneration

 pro-rated fees received by the non-executive Director for 2021 
and/or 2020 based on time served by them on the Board and the 
relevant Board committees and any additional responsibilities 
taken on by the non-executive Director during each year. The 
value of benefits received by the non-executive Directors reflect 
the taxable expense reimbursements claimed, and the associated 
gross-up tax, in relation to attending the Board meetings in each 
year. Non-executive Directors who joined after 1 January 2021 are 
not included. 

2020

2021

Director/employees

Base salary/fees

Benefits

Executive Directors
Noel Quinn1
Ewen Stevenson
Non-executive Directors3
Kathleen Casey (retired on 24 April 2020)
Laura Cha4
Henri de Castries4,5
James Forese6
Steven Guggenheimer7
Irene Lee
José Antonio Meade Kuribreña8
Heidi Miller4,5
Eileen Murray7
David Nish

Sir Jonathan Symonds (retired on 18 February 2020)
Jackson Tai8
Mark Tucker
Pauline van der Meer Mohr8
Employee group9

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%

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%

Base salary/fees

Benefits

1.7%
1.8%

-
-58.8%
-59.4%
257.5%
86.6%
1.8%
10.4%
-60.3%
121.7%
0.4%
-
-1.4%

—

-6.7%
1.0%

-48.9%
-75.0%

-
-
2,100.0%
-
-
-
-100.0%
171.4%
-
25.0%
-
-100.0%
-36.5%
-100.0%
1.3%

Annual 
incentive2

99.0%
117.3%

-
-
-
-
-
-
-
-
-
-
-
-
-
-
25.2%

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 in 2020 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 was 2.1%, 85.2% and -50.9%, respectively for 2020.

2  Noel Quinn and Ewen Stevenson both voluntarily waived the cash portion of their 2020 annual incentive. The year-on-year percentage change 

3 

between 2020 and 2021 would be -1% for Noel Quinn and 9% for Ewen Stevenson without this cash waiver.
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 275 provides the underlying single figure of remuneration for non-executive Directors used to calculate the figures above.

4  Retired from the Board during 2021 and therefore fees received during 2021 were lower than the fees received in 2020. 
5  There was no change to the benefit provided. The year-on-year change reflected the increase in taxable expense reimbursement claimed in 2021 

6 

for attending Board and other meetings at HSBC Holdings' registered offices. 
In 2021, James Forese was appointed as non-executive Chair of HSBC North America Holdings, Inc. Fees for 2021 included fees in relation to this 
role. 

7  Joined the Board during 2020 and therefore received fees for only part of 2020.
8   Received no taxable benefits in 2021, resulting in a 100% reduction from 2021. 
9  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.

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

2021

2020

2019

Method

A

A

A

Lower 
quartile

154:1

139:1

169:1

Median

90:1

85:1

105:1

Upper 
quartile

46:1

43:1

52:1

282

HSBC Holdings plc Annual Report and Accounts 2021

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

(£)

Method

2021

2020

2019

A

A

A

31,727

27,666

54,678

41,500

106,951

84,000

29,833

23,264

48,703

36,972

96,386

75,000

28,920

24,235

46,593

41,905

93,365

72,840

The increase in median ratio is primarily driven by a higher annual 
incentive payout than 2020 when the Group Chief Executive 
voluntarily decided to waive the cash portion of his annual 
incentive award and we protected the outcomes for junior 
colleagues against material year-on-year volatility when the Group 
variable pay pool was down 20%. The 2021 annual incentive 
award of the Group Chief Executive was higher than in 2020, 
reflecting the improvement in the financial performance of the 
Group and execution of our strategy at pace.

The total pay and benefits for the median employee for 2021 was 
£54,678, a 12.3% increase compared with 2020.

 
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 a framework for them 
to develop their career. To help people to develop skills for the 
changing world around us, we launched Future Skills in 
September 2021, supporting colleagues to explore new personal, 
digital, data and sustainability skills through a series of learning 
activities and events. 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.

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 calculated 
using full-time equivalent pay and benefits of all employees 
providing services in the UK at 31 December 2021. 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 37,000 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 2021;

• variable pay awards for 2021;

•

return on deferred cash awards granted 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; 

• 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 calculated by using each employee’s 
fixed pay and benefits at 31 December 2021. 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 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 2021. In a year in which the 
value of an LTI is included in the single figure table of 
remuneration, the 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 
may not be comparable to those reported by other listed peers on 
the FTSE 100 and our international peers. 

HSBC Holdings plc Annual Report and Accounts 2021

283

Corporate governanceReport of the Directors | Corporate governance report

Additional regulatory 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 

Remuneration awarded for the financial year (REM1)

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 2021 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.

Number of identified staff

Total fixed pay ($m)

Fixed 
remuneration

Of which: cash-based ($m)1
Of which: shares or equivalent ownership interests ($m)2
Of which: share-linked instruments or equivalent non-cash instruments ($m)

Of which: other instruments ($m)

Of which: other forms ($m)

Number of identified staff
Total variable remuneration ($m)4,5

Of which: cash-based ($m)

Of which: deferred ($m)

Variable 
remuneration3

Of which: shares or equivalent ownership interests ($m)2

Of which: deferred ($m)

Of which: share-linked instruments or equivalent non-cash instruments ($m)

Of which: deferred ($m)

Of which: other instruments ($m)

Of which: deferred ($m)

Of which: other forms ($m)

Of which: deferred ($m)

Supervisory 
function

Management 
function

Other senior 
management

Other identified 
staff

14.0

7.2

7.2

—

—

—

—
14.0

—

—

—

—

—

—

—

—

—

—

—

2.0

6.9

3.1

3.8

—

—

—
2.0

15.1

1.8

—

13.3

11.5

—

—

—

—

—

—

22.9

48.9

48.9

—

—

—

—
22.9

76.3

27.1

16.2

49.2

38.3

—

—

—

—

—

—

1,020.7

619.6

619.6

—

—

—

—
1,020.7

637.5

307.2

161.6

318.1

178.2

8.8

4.7

—

—

3.4

2.1

Total remuneration ($m)

7.2

22.0

125.2

1,257.1

1  Cash-based fixed remuneration is paid immediately.
2  Paid in HSBC shares. Vested shares are subject to a retention period of up to one year.
3  Variable pay awarded in respect of 2021. 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.

4  The Group has used the discount rate under PRA remuneration rule 15.13 for 15 individuals for the purpose of calculating the ratio between fixed 

and variable components of 2021 total remuneration. 

5  13 identified staff members were exempt from the application of the remuneration structure requirements for MRTs under the PRA and FCA 

remuneration rules. Their total remuneration is $4.2m, of which $3.6m is fixed pay and $0.6m is variable remuneration.

Special payments to staff whose professional activities have a material impact on institutions’ risk profile (REM2)

Supervisory 
function

Management 
function

Other senior 
management

Other 
identified staff

Guaranteed variable remuneration awards1
Number of identified staff

Total amount ($m)

Of which guaranteed variable remuneration awards paid during the financial year, that are not taken 
into account in the bonus cap ($m)

Severance payments awarded in previous periods, that have been paid out during the financial year2
Number of identified staff

Total amount ($m)
Severance payments awarded during the financial year2
Number of identified staff

Total amount ($m)

Of which paid during the financial year ($m)

Of which deferred ($m)

Of which severance payments paid during the financial year, that are not taken into account in the 
bonus cap ($m)

Of which highest payment that has been awarded to a single person ($m)

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

64.6

68.2

54.3

—

68.2

5.0

1  No guaranteed variable remuneration was awarded in 2021. HSBC would offer a guaranteed variable remuneration award in exceptional 

circumstances for new hires, and for the first year of employment only. It 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 

284

HSBC Holdings plc Annual Report and Accounts 2021

Deferred remuneration at 31 December1 (REM3)

Total amount 
of deferred 
remuneration 
awarded for 
previous 
performance 
periods

Of which:
due to vest in 
the financial 
year

Of which: 
vesting in 
subsequent 
financial years

Amount of 
performance 
adjustment 
made in the 
financial year 
to deferred 
remuneration 
that was due 
to vest in the 
financial year

Amount of 
performance 
adjustment 
made in the 
financial year 
to deferred 
remuneration 
that was due 
to vest in 
future 
performance 
years

Total amount 
of adjustment 
during the 
financial year 
due to ex post 
implicit 
adjustments

Total amount 
of deferred 
remuneration 
awarded 
before the 
financial year 
actually paid 
out in the 
financial year

Total of 
amount of  
deferred 
remuneration 
awarded for 
previous 
performance 
period that 
has vested 
but is subject 
to retention 
periods

—

—

—

—

—

—

24.7

3.5

21.2

—

—

—

82.5

40.2

40.6

1.7

—

—

717.9

349.9

350.4

11.8

—

5.8

825.1

—

—

—

—

—

—

1.9

0.3

1.6

—

—

—

13.2

7.2

4.9

1.1

—

—

173.0

94.3

70.4

5.4

—

2.9

—

—

—

—

—

—

22.8

3.2

19.6

—

—

—

69.3

33.0

35.7

0.6

—

—

544.9

255.6

280.0

6.4

—

2.9

188.1

637.0

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

2.0

—

2.0

—

—

—

4.6

—

4.3

0.2

—

0.1

39.8

—

38.5

1.0

—

0.3

46.4

—

—

—

—

—

—

1.9

0.3

1.6

—

—

—

13.3

7.2

5.0

1.1

—

—

175.4

95.3

71.6

5.5

—

3.0

190.6

—

—

—

—

—

—

0.2

—

0.2

—

—

—

1.8

—

1.3

0.5

—

—

35.6

—

31.8

2.0

—

1.8

37.6

$m

Supervisory function

Cash-based

Shares

Share-linked instruments

Other instruments

Other forms

Management function

Cash-based

Shares

Share-linked instruments

Other instruments

Other forms

Other senior management

Cash-based

Shares

Share-linked instruments

Other instruments

Other forms

Other identified staff

Cash-based

Shares

Share-linked instruments

Other instruments

Other forms

Total amount

1  This table provides details of balances and movements during performance year 2021. For details of variable pay awards granted for 2021, refer to 
the 'Remuneration awarded for the financial year' table. Deferred remuneration is made in cash and/or shares. Share-based awards are made in 
HSBC shares.

Identified staff - remuneration by band1 (REM4)

Identified staff that are high earners as set
 out in Article 450(i) CRR

€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

€10,000,000 – 11,000,000

€11,000,000 – 12,000,000

243 

85 

54 

25 

11 

8 

6 

5 

4 

4 

3 

— 

2 

— 

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.

HSBC Holdings plc Annual Report and Accounts 2021

285

Corporate governance 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Directors | Corporate governance report

Information on remuneration of staff whose professional activities have a material impact on institutions’ risk profile (REM5)

Management body

Business areas

Total number of identified staff

Of which members of the Board

14.0

2.0

16.0

Supervisory 
function

Management 
function

Total

Investment 
banking

Retail 
banking

Asset 
management

Corporate 
function

Independent 
internal 
control 
function

All 
other

Total

1,059.6

Of which senior management

Of which other identified staff

Total remuneration of identified staff 
($m)

Of which variable remuneration ($m)1
Of which fixed remuneration ($m)

2.0

3.0

504.5

162.0

—

30.0

7.9

110.6

4.0

142.6

6.0

71.0

7.2   

—   

7.2   

22.0    29.2   

741.3    186.3   

39.7   

167.3   

118.7    129.0 

15.1    15.1   

410.7    87.5   

6.9    14.1   

330.6    98.8   

21.0   

18.7   

82.8   

84.5   

48.5    63.3 

70.2    65.7 

1  Variable pay awarded in respect of 2021. 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.

Directors’ emoluments

The details of compensation paid to executive and non-executive Directors for the year ended 31 December 2021 are set out below.

Emoluments

Noel Quinn

Ewen Stevenson

Non-executive Directors

Directors' base salary, allowances and benefits in kind

3,283   

3,338   

1,933   

2021

£000

2020

£000

2021

£000

Non-executive Directors' fees 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)

—   

5,721   

—   

—   

22   

9,026   

12,414   

—   

4,517   

—   

—   

17   

7,872   

10,097   

—   

3,388   

754   

—   

—   

6,075   

8,356   

2020

£000

1,806 

—   

2,568   

1,431   

—   

—   

5,805   

7,446   

2021

£000

2020

£000

5,314   

5,309 

—   

—   

—   

—   

—   

— 

— 

— 

— 

— 

5,314   

7,309 

5,309 

7,063

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 2021 was $28,079,057. 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 £6,477 ($8,909), Stuart Gulliver valued at 
£6,477 ($8,909), John Flint valued at £10,303 ($14,171), and Marc 
Moses valued at £15,310 ($21,058). Tax return support was also 
provided to John Flint £8,292 ($11,405), and Marc Moses £2,500 
($3,439). The total aggregate value of benefits provided to former 
executive Directors was £49,359 ($67,891). 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 $435,131. The provision at 31 December 
2021 in respect of unfunded pension obligations to former 
Directors amounted to $8,162,646. This relates to unfunded 
unapproved retirement benefits schemes. 

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 2021, or for the period of appointment in 
2021 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 
Executives, for the year ended 31 December 2021, are also 
presented.

Five highest paid employees

Senior management

13,070   

22   

21,870   

6,388   

—   

41,350   

56,873   

37,816 

303 

54,033 

7,039 

— 

99,191 

136,428 

286

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Emoluments by bands

Hong Kong dollars

$0 – $1,000,000

$5,000,001 – $5,500,000

$6,000,001 – $6,500,000

$12,500,001 – $13,000,000

$14,000,001 – $14,500,000

$19,000,001 – $19,500,000

$24,500,001 – $25,000,000

$25,500,001 – $26,000,000

$26,500,001 – $27,000,000

$27,500,001 – $28,000,000

$38,000,001 – $38,500,000

$39,500,001 – $40,000,000

$40,000,001 – $40,500,000

$41,500,001 – $42,000,000

$42,000,001 – $42,500,000

$45,500,001 – $46,000,000

$56,500,001 – $57,000,000

$58,000,001 – $58,500,000

$65,500,001 – $66,000,000

$68,000,001 – $68,500,000

$76,500,001 – $77,000,000

$77,500,001 – $78,000,000

$96,000,001 – $96,500,000

$122,500,001 – $123,000,000

US dollars

$0 – $128,652

$643,262 – $707,588

$771,915 – $836,241

$1,608,156 – $1,672,482

$1,801,134 – $1,865,461

$2,444,397 – $2,508,723

$3,151,985 – $3,216,311

$3,280,638 – $3,344,964

$3,409,290 – $3,473,616

$3,537,943 – $3,602,269

$4,888,793 – $4,953,119

$5,081,772 – $5,146,098

$5,146,098 – $5,210,424

$5,339,077 – $5,403,403

$5,403,403 – $5,467,729

$5,853,687 – $5,918,013

$7,268,864 – $7,333,190

$7,461,842 – $7,526,168

$8,426,736 – $8,491,062

$8,748,367 – $8,812,693

$9,841,913 – $9,906,239

$9,970,565 – $10,034,891

$12,350,636 – $12,414,962

$15,759,926 – $15,824,252

Number of highest paid employees

Number of senior management

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

1   

1   

1   

1   

1   

1 

1 

1 

1 

1 

1 

1 

1 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

Share capital and other related disclosures

Share buy-back programme

On 26 October 2021, HSBC Holdings commenced a share buy-
back to purchase its ordinary shares of $0.50 each up to a 
maximum consideration of $2.0bn. This programme will end no 
later than 20 April 2022. The purpose of the programme is to 
reduce HSBC’s number of outstanding ordinary shares. As at 

31 December 2021, 120,366,714 ordinary shares had been 
purchased and cancelled representing a nominal value of 
$60,183,357 and an aggregate consideration paid by HSBC of 
£524,301,527. The shares cancelled represented 0.58% of the 
shares in issue and 0.59% of the shares in issue, excluding 
treasury shares.

The table that follows outlines details of the shares purchased and 
cancelled on a monthly basis during 2021.

Month

Share buy-back of 2021

Oct-21

Nov-21

Dec-21

Dividends

Dividends for 2021

An interim dividend of $0.07 for the 2021 half-year was paid on 
30 September 2021. For further details of the dividends approved 
in 2021, see Note 8 on the financial statements.

On 22 February 2022, the Directors approved a second interim 
dividend for 2021 of $0.18 per ordinary share, making a total of 
$0.25 for the 2021 full year. The second interim dividend for 2021 
will be payable on 28 April 2022 in cash in US dollars, or in sterling 
or Hong Kong dollars at exchange rates to be determined on 
19 April 2022. As the second interim dividend for 2021 was 
approved after 31 December 2021, it has not been included in the 
balance sheet of HSBC as a liability. The distributable reserves of 
HSBC Holdings at 31 December 2021 were $32.2bn.

A quarterly dividend of £0.01 per Series A sterling preference 
share was paid on 15 March, 15 June, 15 September and 
15 December 2021. The Series A dollar preference shares were 
redeemed on 13 January 2021.

Dividends for 2022

The Group has reviewed whether it will revert to paying quarterly 
dividends and is currently not intending to pay quarterly dividends 
during 2022. The Group will continue to review whether to revert 
to paying quarterly dividends in future years, and a further update 

Number
of shares

Highest price
paid per share 

Lowest price
paid per share

Average price 
paid per share

£

£

£

5,260,011 

67,010,270 

48,096,433 

120,366,714 

4.4800

4.4750

4.5280

4.4155

4.1525

4.0990

4.4553

4.3602

4.3390

Aggregate
price paid

£

23,435,159

292,178,124

208,688,243

524,301,527

will be given at or ahead of the 2022 results announcement in 
February 2023. 

A dividend of £0.01 per Series A sterling preference share was 
approved on 22 February 2022 for payment on 15 March 2022.

Share capital

Issued share capital

The nominal value of HSBC Holdings’ issued share capital paid 
up at 31 December 2021 was $10,315,760,219.50 divided into 
20,631,520,439 ordinary shares of $0.50 each and one non-
cumulative preference share of £0.01, representing approximately 
100.00% and 0.00% respectively of the nominal value of HSBC 
Holdings’ total issued share capital paid up at 31 December 2021. 
The 1,450,000 non-cumulative preference shares of $0.01 each 
were redeemed on 13 January 2021.

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.

HSBC Holdings plc Annual Report and Accounts 2021

287

Corporate governance 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Directors | Corporate governance report

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 397.

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. Shares 
held by custodians in connection with the vesting of employee 
share awards also lodged instructions to waive dividends. The 
total amount of dividends waived during 2021 was $6.8m.

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 

All-employee share plans

HSBC Holdings Savings-Related Share Option Plan (UK)

HSBC ordinary shares issued in £

Options over HSBC ordinary shares lapsed

Options over HSBC ordinary shares granted in response to approximately 
11,183 applications from HSBC employees in the UK on 22 September 2021

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 340.

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 2021

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.

Number

Aggregate
nominal value

$

Exercise price

from
£

to
£

3,197,834   

1,598,917   

2.627   

4.4037 

19,287,652   

9,643,826 

15,410,381   

7,705,191 

HSBC Holdings
ordinary shares issued

Aggregate
nominal value

$

Market value per share

from

£

to

£

HSBC International Employee Share Purchase Plan

283,004   

141,502   

3.5975   

4.4995 

HSBC share plans

HSBC Holdings
ordinary shares issued

Aggregate
nominal value

$

Market value per share

from

£

to

£

Vesting of awards under the HSBC Share Plan 2011

54,785,215   

27,392,608   

4.052   

4.555 

Authorities to allot and to purchase shares and 
pre-emption rights

At the AGM in 2021, shareholders renewed the general authority 
for the Directors to allot new shares up to 13,615,199,500 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 2,042,279,925 ordinary shares. The 
Directors exercised this authority during the year and purchased 
120,366,714 ordinary shares.

In addition, shareholders gave authority for the Directors to grant 
rights to subscribe for, or to convert any security into, no more 
than 4,084,559,850 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 2021’, the Directors did not allot any shares during 
2020.

Debt securities

In 2021, HSBC Holdings issued the equivalent of $19.34bn 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 
details of capital instruments and subordinated bail-inable debt, 
see Notes 28 and 31 on pages 370 and 379.

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 2021, 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 

288

HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
  
time during 2021, representing 1.58% of the shares in issue as at 
31 December 2021. The nominal value of shares held in treasury 
was $162,636,704. 

Notifiable interests in share capital

During 2021, HSBC Holdings did not receive any notification of 
major holdings of voting rights pursuant to the requirements of 
Rule 5 of the Disclosure, Guidance and Transparency Rules. No 
further notifications had been received between 31 December 
2021 and 11 February 2022. Previous notifications received are as 
follows:

• 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.

• Ping An Asset Management Co., Ltd. gave notice on 

6 December 2017 that on 4 December 2017 it had an indirect 
interest in HSBC Holdings ordinary shares of 1,007,946,172, 
representing 5.04% of the total voting rights at that date.

At 31 December 2021, 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.

On 8 February 2022, pursuant to section 324 of Part XV of the 

Directors’ interests – shares and debentures

Securities and Futures Ordinance of Hong Kong, BlackRock, Inc. 
gave notice that on 3 February 2022 it had the following interests 
in HSBC Holdings ordinary shares: a long position of 
1,638,892,657 shares and a short position of 13,731,141 shares, 
representing 7.96% and 0.07%, respectively, 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 2021 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 2021.

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 2021 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 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.

HSBC Holdings ordinary shares

Laura Cha (retired on 28 May 2021)

Henri de Castries (retired on 28 May 2021)

Rachel Duan (appointed to the Board on 1 Sep 2021)

Dame Carolyn Fairbairn (appointed to the Board on 1 Sep 2021)
James Forese1
Steven Guggenheimer1
Irene Lee
José Antonio Meade Kuribreña1
Heidi Miller1 (retired on 28 May 2021)
Eileen Murray1
David Nish 
Noel Quinn2
Ewen Stevenson2
Jackson Tai1,3
Mark Tucker

Pauline van der Meer Mohr

At 31 Dec 2021 or date of cessation, if earlier

At 1 Jan 2021, or
date of appointment,
if later

Beneficial
owner

Child
under 18
or spouse

Jointly with
another
person

Trustee

Total
interests

16,200   

16,200   

19,251   

19,251   

—   

—   

—   

—   

115,000   

115,000   

15,000   

—   

11,904   

15,000   

15,000   

15,000   

15,700   

15,700   

75,000   

75,000   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

50,000   

—   

50,000   

778,958    1,131,278   

545,731   

838,154   

—   

—   

—   

—   

—   

—   

—   

15,000   

—   

—   

—   

—   

—   

—   

—   

66,515   

32,800   

11,965   

21,750   

307,352   

307,352   

15,000   

15,000   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

16,200 

19,251 

— 

— 

115,000 

15,000 

15,000 

15,000 

15,700 

75,000 

50,000 

—    1,131,278 

—   

—   

—   

—   

838,154 

66,515 

307,352 

15,000 

1 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 American Depositary 
Shares ('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 254. At 31 December 2021, 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 – 2,731,466; and Ewen Stevenson – 2,458,851. Each Director’s total 
interests represents approximately 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.

HSBC Holdings plc Annual Report and Accounts 2021

289

Corporate governance 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Directors | Corporate governance report

There have been no changes in the shares or debentures of the 
current Directors from 31 December 2021 to the date of this 
report.
Listing Rule 9.8.4 and other disclosures

This section of the Annual Report and Accounts 2021 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.

Content

Long-term incentives

Dividend waivers

Dividends

Share buy-back

Emissions

Energy efficiency

Page references

271

287

287

24, 287

46

46, 53, 55

Principal activities of HSBC

13, 30, 97, 362

Business review and future developments

12–41, 43, 122, 135, 388

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 & 
Corporate Governance Committee report sets out further details of 
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. 

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 2021 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 2022 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.
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 anticipated time commitment for non-executive 
Directors serving on the Board and as a member of any 
committees is no more than 75 days per annum. Directors who in 
addition chair a large committee should expect to commit up to 
100 days per annum. Any additional time commitment connected 
with Board-related appointments will be confirmed separately. 

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 

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HSBC Holdings plc Annual Report and Accounts 2021

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. The Board agreed 
for 2022 onwards that the conflicts register be reviewed annually 
by the Board and quarterly by the Nomination & Corporate 
Governance Committee. 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. Directors 
are requested to review and confirm their own and their respective 
closely associated persons' outside interests and appointments 
twice a year. 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. All non-executive Directors are re-vetted by the 
compliance team every three years from appointment and as part 
of such process all conflicts checks are refreshed.
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, 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 2021, 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 2021, 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.
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 governance statement on page 218 and the 
Remuneration Committee Chair's letter on page 254.
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 2022 is planned to be held in London at 11:00am on 
Friday, 29 April 2022. Information on how to participate, both in 
advance and on the day, can be found in the Notice of the 2022 
AGM, which will be sent to shareholders on 25 March 2022 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 
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 37 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 $15,500 during 2021 
(2020: $100,750).

Charitable contributions

For details of charitable contributions, see page 77.

Internal control

The Board is responsible for maintaining and reviewing the 
effectiveness of risk management and internal control systems, 
and for determining the level and type 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 22 February 2022, the date 
of approval of the Annual Report and Accounts 2021.

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, 
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 supports our Global Principles. It 
outlines the key principles and practices that we employ in 
managing material risks. It applies to all categories of risk and 
supports a consistent approach in identifying, assessing, 
managing and reporting the risks we accept and incur in our 
activities. 
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 

HSBC Holdings plc Annual Report and Accounts 2021

291

Corporate governanceReport of the Directors | Corporate governance report

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 2021 due to the prolonged impact of the Covid-19 
pandemic on the  global economy, banks continued to play an 
expanded role to support society and customers. The pandemic  
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 
and these continue to be in place. We continue 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. Financial resource 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 GRC and 
the GAC. 

During 2021, 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 

292

HSBC Holdings plc Annual Report and Accounts 2021

remedy any failings or weaknesses identified through the 
operation of the Group's framework of controls. In response to the 
prolonged Covid-19 pandemic, 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 2021. 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. 
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 121. 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 and Compliance 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 the Annual Report 
and Accounts 2021.

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 2021, 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 2021, HSBC had a total workforce equivalent to 
220,000 full-time employees compared with 226,000 at the end of 
2020 and 235,000 at the end of 2019. Our main centres of 
employment were India with approximately 38,000 employees, the 
UK with 35,000, mainland China with 30,000, Hong Kong with 
28,000, Mexico with 16,000 and the US with 7,000.

Our business spans many cultures, communities and continents. 
We aim to provide an environment where our colleagues can fulfil 
their potential by building their skills and capabilities while 
focusing on the development of a diverse and inclusive culture. 
We use confidential employee surveys to assess progress and 
make changes. We want to provide an open culture, where our 
colleagues feel connected, supported to speak up and where our 
leaders encourage and use feedback. Where we make 
organisational changes, we support our people, in particular where 
there are job impacts. 
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 
law 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, colleagues and communities span many cultures 
and continents. We value difference, and believe that diversity 
makes us strong. 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. Every colleague at HSBC must treat 
each other with dignity and respect to ensure an inclusive 
environment. Our policies make it clear that we do not tolerate 
unlawful discrimination, bullying or harassment on any grounds. 

To align our approach to inclusion best practices, we participate in 
global diversity benchmarks that 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 72. 
Further details of our diversity and inclusion activity, together with our Gender 
and Ethnicity Pay Gap Report 2021, can be found at www.hsbc.com/
diversitycommitments.

Employment of people with a disability

We strongly believe in providing equal opportunities for all 
employees. The employment of people with a disability is included 
in this commitment. The recruitment, training, 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. Where necessary, we will provide appropriate 
training, facilities and reasonable equipment.

Employee development

We aim to build a dynamic, inclusive culture where the best want 
to develop the skills and experiences that help them fulfil their 
potential. This determines how we develop our people and recruit, 
identify and nurture talent. A range of resources bring this to life 
including:

• HSBC University, our platform for learning and development 

with specific business and technical academies;

• our My HSBC Career portal, which offers career development 

information and resources; and

• HSBC Talent Marketplace, our new online platform that uses AI 

to provide opportunities to learn as we work.

Each year, every employee is asked to complete global mandatory 
training. It plays a critical role in shaping our culture by ensuring 
everyone is focused on issues that are fundamental to working at 
HSBC, from sustainability, to financial crime risk, to our 
intolerance of bullying and harassment.

As the opportunities we face change, we provide development to 
key populations through business and technical academies. This 
includes our risk academy, which helps us to develop broad 
capabilities in traditional areas of risk like financial crime but also 
in emerging risk issues like climate risk and the ethics of AI and 
Big Data.

Our approach to learning is skills based. Our academies work with 
our businesses to identify the key skills and capabilities we need in 
the future. Alongside this, we help colleagues identify, assess and 
develop the skills that match their ambition and aspirations. In 
2021, as part of our Future Skills programme a ‘Focus 4’ campaign 
encouraged colleagues to identify four future skills they want to 
prioritise in their development plans. Over four themed weeks, 
various events introduced colleagues to areas such as data, digital 
and sustainability skills, as well as personal skills like critical 
thinking and resilience.
Our new platform for learning content is Degreed. This helps 
colleagues identify, assess and develop key skills through internal 
and external training materials in a way that suits them. Content 
can range from quick videos, articles or podcasts to packaged 
programmes or learning pathways.  

In 2021, we launched the HSBC Talent MarketPlace, an AI-based 
platform, which matches colleagues to projects and experiences 
based on their aspirations. By December, this had been rolled out 
to nearly 50,000 colleagues in the US, India, Singapore and the 
UK, and will be rolled out globally in 2022.

Effective people management and impactful leadership remain 
critical to our ability to energise for growth. In 2021, we launched 
a refreshed executive development curriculum for our most senior 
population. This combines internal programmes and business 
school activities with targeted technical programmes on key topics 
and skills.

HSBC Holdings plc Annual Report and Accounts 2021

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Health and safety

Remuneration 

We are committed to providing a safe and healthy working 
environment for everyone. We have adopted global policies, 
mandatory procedures, and incident and information reporting 
systems across the organisation that reflect our core values and 
are aligned to international standards. Our global health and safety 
performance is subject to ongoing monitoring and assurance.
Our chief operating officers have overall responsibility for 
engendering a positive health and safety culture and ensuring that 
global policies, procedures and systems are put into practice 
locally. They also have responsibility for ensuring all local legal 
requirements are met. 
We delivered a range of programmes in 2021 to help us 
understand and manage our health and safety risks:

• We continued to provide enhancements to our workplaces 

globally to minimise the risks of Covid-19, including enhanced 
cleaning, improved ventilation and social distancing measures.

• We updated our advice and risk assessment methodology on 
working from home, providing more awareness and best 
practices on good ergonomics and well-being to be adopted as 
we transitioned to new ways of working.

• We delivered health and safety training and awareness to 

220,000 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 2021 safety climate survey results showed a 
continued high level of positive safety culture, significantly 
above the industry average.

• We commenced a targeted guidance and training programme 

for our construction partners in our key markets globally to help 
them understand and deliver industry leading health and safety 
performance, with over 130 construction workers receiving 
safety passporting training.

• Our Eat Well Live Well programme continued 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 a key component 
of HSBC’s winning entry in the 2021 Global Healthy Workplace 
Awards.

• We put in place effective storm preparation controls and 
processes to ensure the protection of our people and 
operations. In 2021, there were 38 named storms that passed 
over 1,935 of our buildings, resulting in 0 injuries or material 
business impact. 

Employee health and safety

Rate of workplace fatalities per 100,000 employees
Number of major injuries to employees1
All injury rate per 100,000 employees

2021
  — 

2020
—

  14   

  64   

15 

88 

2019
—

29

189

1  Fractures, dislocation, concussion, loss of consciousness, overnight 

admission to hospital.

HSBC Holdings Savings-Related Share Option Plan (UK)

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 
unrelated to performance or experience with the Group, while 
performing their role in the long-term interests of our stakeholders.

For further details of the Group’s approach to remuneration, see page 278.

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 2021 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 273.

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 2021, 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 
21 September 2021, the day before the options were granted and 
as derived from the Daily Official List, was £3.5975.

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 
28 jurisdictions, although no options are granted under this plan.

During 2021, approximately 190,000 employees were offered 
participation in these plans.

Dates of awards

Exercise price

Usually exercisable

At

Granted

from

to

from

(£)

to

(£)

from

to

1 Jan 2021

during year

Exercised
during year1

Lapsed

At

during year

31 Dec 2021

20 Sep 2015 22 Sep 2021   2.6270    5.9640 

1 Nov 2019

30 Apr 2027   130,952,539   

15,410,381   

3,878,418    19,287,652   123,196,850 

1  The weighted average closing price of the shares immediately before the dates on which options were exercised was £4.3351.

HSBC Holdings ordinary shares

294

HSBC Holdings plc Annual Report and Accounts 2021

 
 
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.   
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

22 February 2022

Statement of compliance

The statement of corporate governance practices set out on pages 
217 to 296 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 2021, HSBC complied with the 
provisions and requirements of both the UK and Hong Kong 
Corporate Governance Codes. 

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 
oversight of internal control, other than internal control over 
financial reporting, and risk management systems. This is 
permitted under the UK Corporate Governance Code.

HSBC Holdings plc Annual Report and Accounts 2021

295

Corporate governance 
• 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 
240 sets out how the Group Audit Committee discharges its 
responsibilities.

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

HSBC Holdings plc

Registered number 617987

22 February 2022

Report of the Directors | Corporate governance report

Directors’ responsibility statement

The Directors are responsible for preparing the Annual Report and 
Accounts 2021, 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 UK-adopted international 
accounting standards. The company has also prepared financial 
statements in accordance with international financial reporting 
standards adopted pursuant to Regulation (EC) N0 1606/2002 as it 
applies in the European Union. In preparing these financial 
statements, the Directors have also elected to comply with 
International Financial Reporting Standards issued by the 
International Accounting Standards Board (IFRSs as issued by 
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 accounting estimates that are 

reasonable and prudent; 

• state whether applicable UK-adopted international accounting 
standards, international financial reporting standards adopted 
pursuant to Regulation (EC) No 1606/2002 as it applies in the 
European Union and IFRSs issued by IASB have been followed, 
subject to any material departures disclosed and explained in 
the financial statements; and

• 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 and enable 
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 2021 as they appear on the 
Company’s website. Legislation in the United Kingdom governing 
the preparation and dissemination of financial statements may 
differ from legislation in other jurisdictions.

The Directors consider that the Annual Report and Accounts 2021, 
taken as a whole, is fair, balanced and understandable, and 
provides the information necessary for shareholders to assess the 
Company’s position and 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 
220 to 223 of the Annual Report and Accounts 2021, confirms that, 
to the best of their knowledge:

• the Group financial statements, which have been prepared in 

accordance with UK-adopted international accounting 
standards, international financial reporting standards adopted 
pursuant to Regulation (EC) No 1606/2002 as it applies in the 
European Union and IFRSs issued by IASB, give a true and fair 
view of the assets, liabilities, financial position, and profit or 
loss of the Group; and

296

HSBC Holdings plc Annual Report and Accounts 2021

Financial  
statements

The financial statements provide detailed 
information and notes on our income, 
balance sheet, cash flows and changes 
in equity, alongside a report from our 
independent auditors.

298 

 Report of Independent Registered Public Accounting 
Firm to the Board of Directors and Shareholders  
of HSBC Holdings plc

308   Financial statements

318   Notes on the financial statements

Making our cards more  
sustainable and accessible

We are ending single-use plastic in our payment cards. By the 
end of 2026, the approximately 23 million cards we issue each 
year will be made from recycled PVC plastic. This action is 
expected to reduce CO2 emissions by 161 tonnes and save 73 
tonnes of plastic waste per year as part of our net zero strategy. 
We rolled out recycled PVC cards for 13 markets in 2021, issuing 
them for customers needing new or replacement cards.

Our UK cards also feature a range of accessibility features as 
standard for all customers. Working with charities such as 
Alzheimer’s Society, the new features include considerations for 
people with dementia, visual impairments, learning difficulties, 
dyslexia and colour blindness. These include tactile raised dots to 
differentiate credit cards from debit cards, and retail cards from 
commercial ones. 

HSBC Holdings plc Annual Report and Accounts 2021

297

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

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 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 2021 and of the group’s and 

company’s profit and the group’s and company’s cash flows for the year then ended;

• have been properly prepared in accordance with UK-adopted international accounting standards; and

• have been prepared in accordance with the requirements of the Companies Act 2006.

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 and company, in addition to applying UK-adopted international 
accounting standards, have 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 and company 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 and company, in addition to applying UK-adopted international 
accounting standards, have also applied international financial reporting standards (‘IFRSs’) as issued by the International Accounting 
Standards Board (‘IASB’).

In our opinion, the group and company 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)’), International Standards on Auditing 
issued by the International Auditing and Assurance Standards Board (‘ISAs’) and applicable law. Our responsibilities under ISAs (UK) and 
ISAs 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

During the period, we identified that PricewaterhouseCoopers provided an impermissible training service via a publicly available seminar 
in respect of the implementation of a new Indonesian IT security regulation. The attendees at this seminar included six members of staff 
from HSBC Indonesia. The HSBC staff who attended the course were not from the Finance function and were not in roles relevant to our 
audit. In addition, HSBC Indonesia is not within the scope of the group audit. We confirm that based on our assessment of the breach, 
nature and scope of the service and our communication with the GAC, that the provision of this service has not compromised  our 
professional judgement or integrity and as such believe that an objective, reasonable and informed third party in possession of these facts 
would conclude that our integrity and objectivity has not been impaired and accordingly we remain independent for the purposes of the 
audit. 

Other than the matter referred to above, to the best of our knowledge, we declare that no other non-audit services prohibited by the FRC’s 
Ethical Standard were provided to the company or its controlled undertakings in the period under audit. 

Other than those disclosed in Note 6, we have provided no non-audit services to the company or its controlled undertakings in the period 
under audit.

Our audit approach

Overview

Audit scope

• This was the third 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.  

1  We have audited the financial statements, included within the Annual Report and Accounts 2021 (the ‘Annual Report’), which comprise: the 

consolidated and company balance sheets as at 31 December 2021, 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, 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 127 to 216 and the 
Directors' remuneration report disclosures on pages 268 to 276.

298 HSBC Holdings plc Annual Report and Accounts 2021

Key audit matters
• Expected credit losses - Impairment of loans and advances (group)

• Investment in associate – Bank of Communications Co., Ltd (‘BoCom’) (group)

• Impairment of investments in subsidiaries (parent)

• Valuation of defined benefit pensions obligations (group)

Materiality

• Overall group materiality: US$970m (2020: US$900m) based on 5% of adjusted profit before tax.

• Overall company materiality: US$920m (2020: US$855m) based on 0.75% of total assets. This would result in an overall materiality of 

US$2bn and was therefore reduced below the group materiality.

• Performance materiality: US$725m (2020: US$675m) (group) and US$690m (2020: US$641m) (company).

The scope of our audit

As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial statements. 

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.

Compared to last year the number of key audit matters has reduced from eight to four. The following are no longer considered to be key 
audit matters.

• Impact of Covid-19 (group and company) - Given the impact of Covid-19 on working practices and international travel, the majority of 
our interactions continued to be undertaken virtually, including those with the partners and teams for Significant Subsidiaries and 
operations centres, and with HSBC Board members and management. Similarly, a substantial part of our audit testing was performed 
remotely. We used established practices throughout 2021 for interacting and undertaking our audit testing virtually, consistent with the 
hybrid working models at both PwC network teams and HSBC.

• IT access management (group) - Management has remediated a number of the control deficiencies in relation to IT access 

management.

• Valuation of financial instruments (group) - The financial instruments where significant pricing inputs are unobservable, the most 

material of which are the private equity investments held by Global Banking and Markets and the Insurance business, experienced 
reduced market volatility during the year that impacted the determination of the fair value.

• Impairment of goodwill and intangible assets (group) - The risk of impairment at the period end is reduced due to the significant 

surplus between the recoverable amounts and the carrying value for the goodwill and intangible asset balances at the year end, after 
the full impairment recognised for the WPB LatAm goodwill in 2021. 

The remaining four key audit matters are consistent with last year. 

HSBC Holdings plc Annual Report and Accounts 2021 299

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

Expected credit losses - Impairment of loans and advances (group)

Nature of the key audit matter

Determining expected credit losses (‘ECL’) involves management judgement and is subject to a high degree of estimation uncertainty.
Management makes various assumptions when estimating ECL. The significant assumptions that we focused on in our audit included those with greater 
levels of management judgement and for which variations had the most significant impact on ECL. These included assumptions made in determining 
forward looking economic scenarios and their probability weightings and estimating material management judgemental adjustments.
The impact of Covid-19, including the nature and extent of government support, supply chain constraints and increasing energy prices, and more recent 
factors, including developments in China’s commercial real estate sector, have resulted in unprecedented economic conditions that vary between 
territories and industries, leading to uncertainty around judgements made in determining the severity and probability weighting of macroeconomic 
variable (‘MEV’) forecasts across the different economic scenarios used in ECL models.
The modelling methodologies used to estimate ECL are developed using historical experience. The impact of the unprecedented economic conditions has 
also resulted in certain limitations in the reliability of these methodologies to forecast the extent and timing of future customer defaults and therefore 
estimate ECL. In addition, modelling methodologies do not incorporate all factors that are relevant to estimating ECL, such as differentiating the impact on 
industry sectors of economic conditions. These limitations are addressed with management judgemental adjustments, the measurement of which is 
inherently judgemental and subject to a high level of estimation uncertainty.
Management makes other assumptions which are less judgemental or for which variations have a less significant impact on ECL. These assumptions 
include:
• The methodologies used in quantitative scorecards for determining customer risk ratings (‘CRRs’);
• Estimating expected cash flows and collateral valuations for credit impaired wholesale exposures;
• Model methodologies themselves; and
• Quantitative and qualitative criteria used to assess significant increases in credit risk.

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  continuing impact of Covid-19 and other economic 
conditions, including recent developments in China’s commercial real estate sector. We discussed a number of areas, including:
• The severity of MEV forecasts in economic scenarios, and their related probability weightings, across territories;
• Management judgemental adjustments and the nature and extent of analysis used to support those adjustments;
• The criteria and conditions used to assess to what extent management judgemental adjustments continue to be needed;
• Management’s policies, governance and controls over model validation and monitoring; and
• The disclosures made in relation to ECL, in particular the impact of adjustments on determining ECL and the resulting estimation uncertainty.

How our audit addressed the Key Audit Matter

We assessed the design and effectiveness of governance and controls over the estimation of ECL. We observed management’s review and challenge in 
governance forums for (1) the determination of MEV forecasts and their probability weightings for different economic scenarios, and (2) the assessment of 
ECL for Retail and Wholesale portfolios, including the assessment of model limitations and any resulting management judgemental adjustments. 
We also tested controls over:
• Model validation and monitoring;
• Credit reviews that determine customer risk ratings for wholesale customers;
• The identification of credit impaired events;
• The input of critical data into source systems and the flow and transformation of critical data from source systems to impairment models and 

management judgemental adjustments; and

• The calculation and approval of management judgemental adjustments to modelled outcomes.
We involved our economic experts in assessing the significant assumptions made in determining the severity and probability weighting of MEV forecasts. 
These assessments considered the sensitivity of ECL to variations in the severity and probability weighting of MEVs for different economic scenarios. We 
involved our modelling experts in assessing the appropriateness of the significant assumptions and methodologies used for models and management 
judgemental adjustments. We independently reperformed the calculations for a sample of those models and management judgemental adjustments. We 
further considered whether the judgements made in selecting the significant assumptions would give rise to indicators of possible management bias.
In addition, we performed substantive testing over:
• The compliance of ECL methodologies and assumptions with the requirements of IFRS 9;
• The appropriateness and application of the quantitative and qualitative criteria used to assess significant increases in credit risk;
• A sample of critical data used in ECL models and to estimate management judgemental adjustments as at 31 December 2021;
• Assumptions and critical data for a sample of credit impaired wholesale exposures; and
• A sample of CRRs applied to wholesale exposures.
We evaluated and tested the Credit Risk disclosures made in the Annual Report. 

Relevant references in the Annual Report and Accounts 2021

• Credit risk disclosures, page 137.
• GAC Report, page 245.
• Note 1.2(d): Financial instruments measured at amortised cost, page 321.
• Note 1.2(i): Impairment of amortised cost and FVOCI financial assets, page 323.

300 HSBC Holdings plc Annual Report and Accounts 2021

 Impairment of investment in associate - Bank of Communications Co., Ltd (‘BoCom’) (group)

Nature of the key audit matter

At 31 December 2021, the fair value of the investment in BoCom, based on the share price, was US$15.1bn lower than the carrying value (‘CV’) of 
US$23.6bn.
This is an indicator of potential impairment. An impairment test was performed by management, with supporting sensitivity analysis, using the higher of 
fair value and value in use ('VIU'). The VIU was US$1.2bn in excess of the CV. On this basis, management concluded no impairment was required.

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:
• The discount rate;
• Short term assumptions for operating income growth rate, cost-income ratio, expected credit losses and effective tax rates;
• Long term assumptions for profit and asset growth rates, expected credit losses, and effective tax rates; and
• Capital related assumptions (risk-weighted assets, capital adequacy ratio and tier 1 capital adequacy ratio).

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, the outlook for the Chinese banking market and the fair value, which has been lower than the carrying value for approximately 10 years. We 
also discussed the disclosures made in relation to BoCom, including reasonably possible alternatives for the significant assumptions, the use of sensitivity 
analysis to explain estimation uncertainty and the changes in certain assumptions that would result in the VIU being equal to the CV.

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 appropriateness of the significant assumptions and, where relevant, their interrelationships;
• Obtaining evidence for data supporting significant assumptions including 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 certain significant assumptions, both individually and in aggregate;      
• 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; and

• Assessing whether the judgements made in deriving the significant assumptions give rise to indicators of possible management bias.
We observed the quarterly meetings in March, May, September, and November 2021 between management and BoCom management, held specifically to 
identify facts and circumstances impacting assumptions relevant to the determination of the VIU.
Representations were obtained from management that assumptions used were consistent with information currently available to the group.       .
We evaluated and tested the disclosures made in the Annual Report in relation to BoCom.

Relevant references in the Annual Report and Accounts 2021

• GAC Report, page 245.
• Note 1.2(a): Critical accounting estimates and judgements, page 320.
• Note 18 Interests in associates and joint ventures, page 359.

HSBC Holdings plc Annual Report and Accounts 2021 301

Financial statements 
Report of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

Impairment of investments in subsidiaries (company)

Nature of the key audit matter

The macroeconomic and geopolitical environment continues to be challenging, impacting both 2021 and the outlook into 2022 and beyond. These 
external factors, as well as HSBC’s strategy, impact the financial position and performance of subsidiaries within the group. These factors were 
considered by management in determining if there were potential indicators of impairment that required an impairment assessment for investment in 
subsidiaries.
Management compared the net assets to the carrying value of each direct subsidiary of HSBC Holdings plc. 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 a partial reversal of an impairment charge of US$3.1bn in relation to the 
investment in HSBC Overseas Holdings (UK) Limited (‘HOHU’). This resulted in investment in subsidiaries of US$163bn at 31 December 2021.

The methodology 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 strategic planning cycle for 2022 to 2026 
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 partial reversal of the impairment charge for HOHU, the appropriateness of methodologies used and significant assumptions with the 
GAC, giving consideration to the macroeconomic outlook and HSBC’s strategy. We considered reasonably possible alternatives for significant 
assumptions.

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 tested the mathematical accuracy of the calculations, to estimate the recoverable amounts. In respect of the significant 
assumptions, our testing included the following:
• Challenging the achievability of management’s strategic planning cycle  and the prospects for HSBC’s businesses, as well as considering the 

achievement of historic forecasts;

• Obtaining and evaluating evidence where available for critical data relating to significant assumptions, from a combination of historic experience and 

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 in relation to investment in subsidiaries.

Relevant references in the Annual Report and Accounts 2021

• Note 19: Investments in subsidiaries, page 362.

Valuation of defined benefit pensions obligations (group)

Nature of the key audit matter

The group has a defined benefit obligation of US$42.8bn, of which US$32.3bn relates to HSBC Bank (UK) pension scheme.

The valuation of the defined benefit obligation for HSBC Bank (UK) pension scheme is dependent on a number of actuarial assumptions. Management 
uses an actuarial expert to determine the valuation of the defined benefit obligation. The valuation methodology uses 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 governance and controls in place over the methodologies and the significant assumptions, including those in relation to the use of 
management's experts. 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, we used our actuarial experts to understand the judgements made by management and their actuarial expert in determining the 
significant assumptions and compared these assumptions to our independently compiled expected ranges based on market observable indices and the 
knowledge and opinions of our actuarial experts.
We evaluated and tested the disclosures made in the Annual Report in relation to the defined benefit pension obligation.

Relevant references in the Annual Report and Accounts 2021

• GAC Report, page 246.
• Note 1.2(k): Critical accounting estimates and judgements, page 327.
• Note 5: Employee compensation and benefits, page 331.

302 HSBC Holdings plc Annual Report and Accounts 2021

 
 
How we tailored the audit scope

We performed a risk assessment, giving consideration to relevant external and internal factors, including Covid-19, climate change, 
geopolitical and economic risks, relevant accounting and regulatory developments, HSBC’s strategy and the changes taking place across 
the group. We also considered our knowledge and experience obtained in prior year audits. As part of considering the impact of climate 
change in our risk assessment, we evaluated management's assessment of the impact of climate risk, which is set out on page 45, 
including their conclusion that there is no material impact on the financial statements. In particular, we considered management’s 
assessment of the impact on ECL on loans and advances to customers, the financial statement line item we determined to be most likely 
to be impacted by climate risk. Management’s assessment gave consideration to a number of matters, including the climate stress testing 
performed in 2021.

Using our risk assessment, we tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on 
the financial statements as a whole, taking into account the structure of the group and the company, the accounting processes and 
controls, and the industry in which they operate. We continually assessed risks and changed the scope of our audit where necessary. 

Our risk assessment and scoping identified certain entities (collectively the Significant Subsidiaries) for which we obtained audit opinions. 
We obtained full scope audit opinions for the consolidated financial position and performance of Hongkong and Shanghai Banking 
Corporation Limited, HSBC Bank plc, and HSBC North America Holdings Limited. We also obtained full scope audit opinions for the 
company financial position and performance of HSBC UK Bank plc, HSBC Bank Canada and HSBC Mexico S.A. We obtained audit 
opinions over specific balances for HSBC Bank Middle East Limited - UAE Operations. The audits for HSBC Bank plc and HSBC UK Bank 
plc were performed by other PwC teams in the UK. All other audits were performed by other PwC network firms.

We continued with our 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. HSBC Bank 
Malaysia was removed from the scope of The Hongkong and Shanghai Banking Corporation Limited audit for 2021 and India was 
included.

Group-wide audit approach

HSBC has entity level controls that have a pervasive influence across the group, as well as other global and regional governance and 
controls over aspects of financial reporting, such as those operated by the Global Risk function for expected credit losses. A significant 
amount of IT and operational processes and controls relevant to financial reporting are undertaken in operations centres run by Digital 
Business Services ('DBS') across different locations. Financial reporting processes and controls are performed centrally in HSBC’s Group 
Finance function and the four Finance operations centres, including the impairment assessment of goodwill and intangible assets, the 
consolidation of the group’s results, the preparation of the financial statements, and management’s oversight controls relevant to the 
group’s financial reporting.

For these areas, we either performed audit work ourselves, or directed and provided oversight of the audit work performed by PwC teams 
in the UK, Poland, China, Sri Lanka, Malaysia, India and the Philippines. A substantial part of our audit testing in these locations was 
performed remotely. Some of this work was relied upon by the PwC teams auditing the Significant Subsidiaries. This audit work, together 
with analytical review procedures and assessing the outcome of local external audits, also mitigated the risk of material misstatement for 
balances in entities that were not part of a Significant Subsidiary. 

Significant Subsidiaries audit approach

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 US$48m to US$690m. Certain Significant Subsidiaries 
were audited to a local statutory audit materiality that was less than our overall group materiality.   

We designed global audit approaches for the products and services that substantially make up HSBC’s global businesses, such as 
lending, deposits and derivatives. These approaches were provided to the partners and teams performing audit testing for the Significant 
Subsidiaries.

We were in active dialogue throughout the year with the partners and teams responsible for the audits of the Significant Subsidiaries, 
including consideration of how they planned and performed their work. We attended Audit Committee meetings for some of the 
Significant Subsidiaries. We also attended meetings with management in each of these Significant Subsidiaries at the year-end. Given the 
impact of Covid-19 on working practices and international travel, the majority of our interactions continued to be undertaken virtually.

The audit of The Hongkong and Shanghai Banking Corporation Limited in Hong Kong relied upon work performed by other teams in Hong 
Kong and the PwC network firms in India, mainland China and Singapore. Similarly, the audit of HSBC 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, Significant 
Subsidiaries covered 85% of total assets and 75% of total operating income.

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, economic experts for our work around 
the severity and probability weighting of macroeconomic variables used as part of the expected credit loss allowance 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 
obtained audit evidence from work that is scoped and provided by other auditors that are engaged by those third parties. For example, we 
obtained a report evidencing the testing of external systems and controls supporting HSBC’s payroll and HR processes.

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.

HSBC Holdings plc Annual Report and Accounts 2021 303

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

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

Financial statements – group

Overall materiality

US$970m (2020: US$900m).

How we determined it

5% 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 28, 
management believes it best reflects the performance of 
HSBC and how the group is run. We excluded the 
adjustments made by management on page 28 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.

Financial statements – company

US$920m (2020: US$855m).

0.75% of total assets. This would result in an overall 
materiality of US$2bn and was therefore reduced below the 
group materiality level.

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 US$725m for the group financial statements and US$690m for 
the company financial statements.

In determining the performance materiality, we considered a number of factors, including the history of misstatements, our risk 
assessment and aggregation risk, and the effectiveness of controls. We concluded that an amount at the upper end of our normal range 
was appropriate.

We agreed with the GAC that we would report to them misstatements identified during our audit above US$48m (group audit) (2020: 
US$45m) and US$48m (company audit) (2020: US$45m) as well as misstatements below those amounts that, in our view, warranted 
reporting for qualitative reasons.

 Conclusions relating to going concern

Our evaluation of the directors’ assessment of the group's and the 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 

external risks including geopolitical, Covid-19 and climate change 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. 

• Understanding and evaluating credit rating agency ratings and actions.

• 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.

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

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

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, which includes reporting based on the Task Force on Climate-related 
Financial Disclosures (‘TCFD’) recommendations. 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, including the TCFD reporting and other information related to climate change, 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.

304 HSBC Holdings plc Annual Report and Accounts 2021

 
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 2021 is consistent with the financial statements and has been prepared in accordance with 
applicable legal requirements.

In light of the knowledge and understanding of the group and 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 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.

Responsibilities for the financial statements and the audit

Responsibilities of the directors for the financial statements

As explained more fully in the Directors’ responsibility 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) and ISAs will always detect a material 
misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, 
they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

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

HSBC Holdings plc Annual Report and Accounts 2021 305

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

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 and regulations and regulatory compliance, including regulatory reporting requirements and 
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 financial statements such as the Companies Act 2006. 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 Significant Subsidiaries 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 from 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, insofar 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 programmes and the results of management’s investigation of such 

matters; insofar 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, the impairment assessments of the investment in BoCom, valuation of defined benefit 
pensions obligations and investment in subsidiaries (see related key audit matters);

• Obtaining confirmations from third parties to confirm the existence of a sample of transactions and balances; 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.

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 in accordance with ISAs (UK) is located on the FRC’s 
website at: www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditors’ report.

As part of an audit in accordance with ISAs, we exercise professional judgement and maintain professional scepticism throughout the 
audit. We also:

• Identify and assess the risks of material misstatement of the consolidated financial statements, whether due to fraud or error, design 
and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis 
for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as 
fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the 

circumstances, but not for the purpose of expressing an opinion on the effectiveness of the group’s and company’s internal control.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures 

made by management.

• Conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on the audit evidence 
obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the group’s and 
company’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention 
in our auditor’s report to the related disclosures in the consolidated financial statements or, if such disclosures are inadequate, to 
modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future 
events or conditions may cause the group to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the consolidated financial statements, including the disclosures, and 
whether the consolidated financial statements represent the underlying transactions and events in a manner that achieves fair 
presentation.

• Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities within the group 
and company to express an opinion on the consolidated financial statements. We are responsible for the direction, supervision and 
performance of the group and company audit. We remain solely responsible for our audit opinion.

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

We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding 
independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our 
independence, and where applicable, actions taken to eliminate threats or safeguards applied.

From the matters communicated with those charged with governance, we determine those matters that were of most significance in the 
audit of the consolidated financial statements of the current period and are therefore the key audit matters. We describe these matters in 
our auditor’s report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we 

306 HSBC Holdings plc Annual Report and Accounts 2021

determine that a matter should not be communicated in our report because the adverse consequences of doing so would reasonably be 
expected to outweigh the public interest benefits of such communication.

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 company 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 seven years, 
covering the years ended 31 December 2015 to 31 December 2021.

 Other matter

As required by the Financial Conduct Authority Disclosure Guidance and Transparency Rule 4.1.14R, these financial statements form part 
of the ESEF-prepared annual financial report filed on the National Storage Mechanism of the Financial Conduct Authority in accordance 
with the ESEF Regulatory Technical Standard (‘ESEF RTS’). This auditors’ report provides no assurance over whether the annual financial 
report has been prepared using the single electronic format specified in the ESEF RTS.

Scott Berryman (Senior Statutory Auditor)

for and on behalf of PricewaterhouseCoopers LLP

Chartered Accountants and Statutory Auditors

London

22 February 2022

HSBC Holdings plc Annual Report and Accounts 2021 307

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

308

308

310

311

312

314

314

315

316

317

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

19

7

9

9

2021

$m

26,489   

36,188   

(9,699)   

13,097   

16,788   
(3,691)   

7,744   

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 

4,053   

2,081   

3,478 

(182)   

798   

569   

231   

455   

653   

10,870   

10,093   

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) 

527   

63,074   

(12,645)   

50,429   

(8,817)   

41,612   

(18,076)   

(11,115)   

(2,681)   
(2,519)   

(41)   

(34,432)   

(42,349) 

7,180   

1,597   

8,777   

(2,678)   

6,099   

3,898   

90   

1,241   

870   

6,099   

$

0.19   

0.19   

10,993 

2,354 

13,347 

(4,639) 

8,708 

5,969 

90 

1,324 

1,325 

8,708 

$

0.30 

0.30 

502   

63,940   

(14,388)   

49,552   

928   

50,480   

(18,742)   

(11,592)   

(2,261)   
(1,438)   

(587)   

(34,620)   

15,860   

3,046   

18,906   

(4,213)   

14,693   

12,607   

7   

1,303   

776   

14,693   

$

0.62   

0.62   

*  For Notes on the financial statements, see page 318.
1 

Interest income includes $30,916m (2020: $35,293m) of interest recognised on financial assets measured at amortised cost and $4,337m (2020: 
$5,614m) 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 $8,227m (2020: $12,426m) 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 $878m (2020: $1,029m). 

308 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

2021

$m

2020

$m

14,693   

6,099   

(2,139)   

(2,270)   

(464)   

(49)   

644   

(664)   

595   

(1,514)   

255   

103   

103   

1,750   

2,947   

(668)   

48   

(577)   

471   

(157)   

769   

(141)   

(73)   

(73)   

2019

$m

8,708 

1,152 

1,793 

(365) 

109 

(385) 

206 

551 

(286) 

(59) 

21 

21 

(2,393)   

4,855   

1,044 

(274)   

(107)   

(167)   

531   

512   

19   

(446)   

(443)   

(3)   

315   

834   

1,223   

(389)   

167   

190   

(23)   

212   

212   

—   

193   

(4,967)   

9,726   

8,409   

14,508   

7,765   

12,146   

7   

1,303   

651   

9,726   

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 

HSBC Holdings plc Annual Report and Accounts 2021 309

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

2021

$m

31 Dec

2020

$m

Notes*

11

14

15

16

22

18

21

7

23

24

15

25

26

4

27

7

28

31

31

19

403,018   

304,481 

4,136   

42,578   

248,842   

49,804   

196,882   

83,136   

4,094 

40,420 

231,990 

45,553 

307,726 

81,616 

1,045,814   

1,037,987 

241,648   

446,274   

139,982   

970   

29,609   

20,622   

4,624   

230,628 

490,693 

156,412 

954 

26,684 

20,443 

4,483 

2,957,939   

2,984,164 

42,578   
101,152   

40,420 
82,080 

1,710,574   

1,642,780 

126,670   

111,901 

5,214   

84,904   

145,502   

191,064   

78,557   

123,778   

698   

4,343 

75,266 

157,439 

303,001 

95,492 

128,624 

690 

112,745   

107,191 

2,566   

4,673   

20,487   

3,678 

4,313 

21,951 

2,751,162   

2,779,169 

10,316   

14,602   
22,414   

6,460   

144,458   

198,250   

8,527   

10,347 

14,277 
22,414 

8,833 

140,572 

196,443 

8,552 

206,777   

204,995 

2,957,939   

2,984,164 

*  For Notes on the financial statements, see page 318.

The accompanying notes on pages 318 to 396 and the audited sections in ‘Risk’ on pages 120 to 216 (including ‘Measurement 
uncertainty and sensitivity analysis of ECL estimates’ on pages 144 to 152), and ‘Directors’ remuneration report’ on pages 254 to 287 form 
an integral part of these financial statements. 

These financial statements were approved by the Board of Directors on 22 February 2022 and signed on its behalf by:

Mark E Tucker
Group Chairman

Ewen Stevenson
Group Chief Financial Officer

310 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

2021

$m

2020

$m

2019

$m

18,906   

8,777   

13,347 

4,286   

(647)   

(3,046)   

—   

(519)   

1,063   

467   

510   

5,241   

(541)   

(1,597)   

—   

9,096   

1,164   

433   

(906)   

18,937   

(25,749)   

(9,226)   

(11,014)   

552   

(4,254)   

19,899   

95,703   

14,769   

(16,936)   

(11,425)   

(10,935)   

808   

(509)   

13,150   

(14,131)   

9,950   

(1,962)   

(19,610)   

226,723   

(28,443)   

(9,075)   

(6,630)   

20,323   

761   

(495)   

(3,077)   

(4,259)   

104,312   

182,220   

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 

(493,042)   

(496,669)   

(445,907) 

521,190   

476,990   

413,186 

(1,086)   

3,059   

(2,479)   

(106)   

(1,446)   

1,362   

(2,064)   

(603)   

(1,343) 

1,118 

(2,289) 

(83) 

27,536   

(22,430)   

(35,318) 

1,996   

(707)   

(1,386)   

(3,450)   

(864)   

(6,383)   

(10,794)   

121,054   

468,323   

(15,345)   

1,497   

—   

(181)   

(398)   

(3,538)   

(2,023)   

(4,643)   

155,147   

293,742   

19,434   

— 

(1,000) 

141 

— 

(4,210) 

(9,773) 

(14,842) 

(20,417) 

312,911 

1,248 

574,032   

468,323   

293,742 

403,018   

304,481   

154,099 

4,136   

55,705   

76,658   

28,488   

11,241   

(5,214)   

4,094   

51,788   

65,086   

30,023   

17,194   

(4,343)   

4,956 

41,626 

65,370 

20,132 

12,376 

(4,817) 

574,032   

468,323   

293,742 

Interest received was $40,175m (2020: $45,578m; 2019: $58,627m), interest paid was $12,695m (2020: $17,740m; 2019: $27,384m) and 
dividends received (excluding dividends received from associates, which are presented separately above) were $1,898m (2020: $1,158m; 
2019: $2,369m).

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 $(0.9)bn (2020: $(3.5)bn; 2019: $(4.2)bn) of securities. Non-cash 
changes during the year included foreign exchange gains/(losses) of $(0.3)bn (2020: $0.5bn; 2019: $0.6bn) and fair value gains/(losses) of $(1.0)bn 
(2020: $1.1bn; 2019: $1.4bn).

3 At 31 December 2021 $33,634m (2020: $41,912m; 2019: $35,735m) was not available for use by HSBC, of which $15,357m (2020: $16,935m; 

2019: $19,353m) related to mandatory deposits at central banks.

HSBC Holdings plc Annual Report and Accounts 2021 311

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

  24,624   22,414    140,572   

1,816   

457   

(20,375)   

26,935   196,443   

8,552   204,995 

—   

—   

—   

—   

13,917   

—   

—   

—   

—    13,917   

776    14,693 

661   

(2,455)   

(654)   

(2,394)   

—    (4,842)   

(125)   

(4,967) 

—   

—   

—   

(2,105)   

—   

—   

—    (2,105)   

(34)   

(2,139) 

—   

—   

—   

—   

—   

—   

(350)   

—   

—   

(654)   

—   

—   

—   

—   

(350)   

(654)   

(96)   

(446) 

(10)   

(664) 

—   

—   

531   

—   

—   

—   

—   

531   

—   

531 

At 1 Jan 2021

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

—   

—   

(288)   

—   

—   

—   

—   

(288)   

14   

(274) 

–  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

Cancellation of shares7
Other movements
At 31 Dec 2021

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/

—   

—   

—   

—   

—   

—   

103   

315   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

103   

315   

—   

—   

103 

315 

(2,394)   

—    (2,394)   

1   

(2,393) 

—   

—   

14,578   

(2,455)   

(654)   

(2,394)   

—    9,075   

651    9,726 

354   

—   

(336)   

—    2,000   

(4)   

—   

—   

(5,790)   

—    (2,000)   

—   

—   

—   

(60)   

—   

—   

—   

(3,065)   

467   

(2,004)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

18   

—    1,996   

—   

18 

—    1,996 

—    (5,790)   

(593)   

(6,383) 

—    (2,000)   

—   

(2,000) 

3,065   

—   

—   

467   

—   

—   

— 

467 

60    (2,004)   

—   

(2,004) 

—   

40   
  24,918   22,414    144,458   

—   

5   
(634)   

—   
(197)   

—   
(22,769)   

—   

45   
30,060   198,250   

(83)   

(38) 
8,527   206,777 

24,278    20,871   

136,679   

(108)   

(25,133)   

27,370    183,955   

8,713    192,668 

—   

—   

—   

—   

5,229   

1,118   

—   

—   

1,913   

459   

4,758   

—   

—   

5,229   

8,248   

870   

161   

6,099 

8,409 

(2)   

—   

—   

—   

—   

1,746   

—   

—   

—   

1,746   

4   

1,750 

—   

—   

—   

—   

—   

—   

167 

—   

459   

—   

—   

—   

—   

167   

459   

45   

12   

212 

471 

—   

—   

167   

—   

—   

—   

—   

167   

—   

167 

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

—   

—   

—   

—   

—   

—   

—   

—   

(73)   

193   

—   

—   

—   

—   

—   

—   

—   

6,347   

1,913   

459   

—   

—   

4,758   

4,758   

—   

—   

—   

(73)   

193   

4,758   

—   

—   

97   

(73) 

193 

4,855 

—    13,477   

1,031    14,508 

346   

—   

—    1,500   

—   

—   

—   

—   

—   

—   

—   

—   

—   

43   

(339)   

(3)   

(1,331)   

(1,450)   

435   

434   

(200)   

—   

—   

—   

—   

—   

—   

11   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

7   

—   

1,497   

—   

—   

7 

1,497 

—   

(1,331)   

(692)   

(2,023) 

—   

(1,450)   

(435)   

—   

—   

—   

434   

(146)   

—   

—   

—   

(1,450) 

— 

434 

(500)   

(646) 

24,624    22,414   

140,572   

1,816   

457   

(20,375)   

26,935    196,443   

8,552    204,995 

312 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of changes in equity (continued)

for the year ended 31 December

Other reserves

Called up
share
capital and
share
premium

$m

Other
equity
instru-
ments

$m

Financial
assets at
FVOCI
reserve

Cash
flow
hedging
reserve

Retained
earnings3,4

Foreign
exchange
reserve

Merger
and other
reserves4,5

Total
share-
holders’
equity

Non-
controlling
interests

$m

$m

$m

$m

$m

$m

$m

Total
equity

$m

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) 

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 due to movement 
in own credit risk

–  remeasurement of defined benefit asset/

liability

—   

—   

5   

—   

—   

—   

—   

5   

8   

–  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

13 

21 

217 
1,044 

—   

—   
—   

—   

—   

—   
—   

—   

21   

217   
—   

—   

—   
—   

—   

—   
—   

—   

—   
1,000   

—   

—   
—   

21   

217   
1,000   

—   

—   
44   

5,624   

1,424   

204   

1,000   

—   

8,252   

1,473   

9,725 

557   

—   

(495)   

—   

—   

—   

—   

62   

—   

62 

—   

—   

—   
—   
—   

(68)   

—   

—   

—   

2,687   

(11,683)   

(1,496)   
—   
—   

—   

—   

(12)   
2,475   
478   

(1,000)   

414   

—   

—   

—   
—   
—   

—   

—   

—   

—   

—   
—   
—   

—   

—   

(2)   

—   

—   

—   
—   
—   

—   

—   

—   

2,687   

—   

2,687 

—    (11,683)   

(777)    (12,460) 

—   
(2,475)   
—   

(1,508)   
—   
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)   

1  During 2021, HSBC Holdings issued $2,000m of additional tier 1 instruments on which there were $4m of external issue costs. In 2020, HSBC 

Holdings issued $1,500m of perpetual subordinated contingent convertible capital securities.

2  During 2021, HSBC Holdings redeemed $2,000m 6.875% perpetual subordinated contingent convertible capital securities. For further details, see 
Note 31 in the Annual Report and Accounts 2021. In 2020, HSBC Holdings called and later redeemed $1,450m 6.20% non-cumulative US dollar 
preference shares. In 2019, HSBC Holdings redeemed $1,500m 5.625% perpetual subordinated capital securities on which there were $12m of 
external issuance costs. Under IFRSs external issuance costs are classified as equity.

3  At 31 December 2021, retained earnings included 558,397,704 treasury shares (2020: 509,825,249; 2019: 432,108,782). 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 Markets and 
Security Services.

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 the comparative periods, impairments (2020: $435m; 2019: $2,475m) were recognised and a permitted transfer of these 
amounts was made from the merger reserve to retained earnings. During 2021, a part reversal of these impairments resulted in a transfer from 
retained earnings back to the merger reserve of $3,065m.

7 For further details, see Note 31 in the Annual Report and Accounts 2021. In October 2021, HSBC announced a share buy-back of up to $2.0bn, 

which will be completed no later than April 2022. At 31 December 2021, 120,366,714 ordinary shares had been purchased and cancelled 
representing a nominal value of $60m, which has been transferred from share capital to capital redemption reserve within merger and other 
reserves. In August 2019, HSBC announced a share buy-back of up to $1.0bn, which was completed in September 2019. 

HSBC Holdings plc Annual Report and Accounts 2021 313

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

Dividend income from subsidiaries

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

2021

$m

(2,367)   

380   

(2,747)   

(5)   

110   

349   

(420)   

11,404   

230   

9,301   

(30)   

(1,845)   

3,065   

1,190   

10,491   

343   

10,834   

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 

*  For Notes on the financial statements, see page 318.
1  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch.

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

2021

$m

2020

$m

10,834   

4,085   

2019

$m

9,041 

267   

259   

8   

267   

176   

176   

—   

176   

(396) 

(573) 

177 

(396) 

11,101   

4,261   

8,645 

314 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 318. 

31 Dec 2021

31 Dec 2020

Notes*

$m

$m

15

24

15

25

28

31

2,590   

51,408   

2,811   

25,108   

26,194   

1,513   

122   

2,913 

65,253 

4,698 

10,443 

17,485 

1,445 

— 

163,211   

160,660 

215   

276 

273,172   

263,173 

111   

32,418   

1,220   

67,483   

4,240   

17,059   

—   

311   

330 

25,664 

3,060 

64,029 

4,865 

17,916 

71 

438 

122,842   

116,373 

10,316   

14,602   

22,414   

37,882   

65,116   

150,330   

273,172   

10,347 

14,277 

22,414 

34,757 

65,005 

146,800 

263,173 

The accompanying notes on pages 318 to 396 and the audited sections in ‘Risk’ on pages 120 to 216 (including ‘Measurement 
uncertainty and sensitivity analysis of ECL estimates’ on pages 144 to 152), and ‘Directors’ remuneration report’ on pages 254 to 287 form 
an integral part of these financial statements.

These financial statements were approved by the Board of Directors on 22 February 2022 and signed on its behalf by:

Mark E Tucker
Group Chairman

Ewen Stevenson
Group Chief Financial Officer 

HSBC Holdings plc Annual Report and Accounts 2021 315

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 tax

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 preference shares and other equity instruments

Purchase of treasury shares

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

2021

$m

10,491   

(2,954)   

(2,976)   

2   

20   

3,364   

(4,409)   

47   

(226)   

20   

(2,833)   

(1,396)   

(691)   

32   

1,445   

2020

$m

4,250   

442   

87   

1   

354   

(327)   

(3,289)   

(1,657)   

(633)   
449   
3,063   

1,258   

1,366   

270   

5,192   

(16,966)   

(11,652)   

16,074   

(1,337)   

2,000   
(26)   

(255)   

2,334   

(3,450)   

(28)   

(707)   

—   

19,379   

(5,569)   

(4,480)   

(1,310)   

6,169   

7,359   

6,176   

13,535   

2,590   

93   
10,852   

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 

2,584 

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 

Interest received was $1,636m (2020: $1,952m; 2019: $2,216m), interest paid was $2,724m (2020: $3,166m; 2019: $3,819m) and 
dividends received were $11,404m (2020: $8,156m; 2019: $15,117m).

316 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings statement of changes in equity 

for the year ended 31 December

At 1 Jan 2021

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
Cancellation of shares2
Dividends to shareholders

Redemption of capital securities 
Transfers3
Other movements

At 31 Dec 2021

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
Transfers3
Other movements4
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 shares

Capital securities issued

Dividends to shareholders

Redemption of capital securities 
Transfers3
Other movements

At 31 Dec 2019

Called up
share
capital

Share
premium

Other
equity
instruments

Retained
earnings1

Merger 
and other
reserves

Total
shareholders’
equity

$m

$m

$m

$m

$m

$m

  10,347    14,277   

22,414   

65,005   

34,757   

146,800 

—   

—   

—   

—   

29   
—   

(60)   

—   
—   
—   

—   

—   

—   

—   

—   

325   
—   

—   

—   
—   
—   

—   

—   

—   

10,834   

267   

—   
—   
—   
2,000   

—   

—   
(2,000)   
—   

—   

267   

11,101   

(103)   
(20)   
(2,004)   
(5,790)   
—   
(3,065)   
(8)   
65,116   

—   

—   

—   

—   

—   

—   

60   

—   

—   

3,065   

—   

10,834 

267 

267 

11,101 

251 

1,980 

(2,004) 

(5,790) 

(2,000) 

— 

(8) 

37,882   

150,330 

  10,316    14,602   

22,414   

10,319    13,959   

20,743   

62,484   

37,539   

145,044 

—   

—   

—   

—   

28   

—   

—   

—   

—   

—   

—   

—   

—   

—   

318   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

1,500   

—   

—   

—   

4,085   

176   

176   

4,261   

2,540   

(15)   

(1,331)   

(1,450)   

435   

171   

(1,919)   

—   

—   

—   

—   

(2,347)   

—   

—   

—   

(435)   

—   

4,085 

176 

176 

4,261 

539 

1,485 

(1,331) 

(1,450) 

— 

(1,748) 

10,347    14,277   

22,414   

65,005   

34,757   

146,800 

10,180    13,609   

22,231   

61,434   

39,899   

147,353 

—   

—   

—   

—   

36   

171   

(68)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

521   

(171)   

—   

—   

—   

—   

—   

—   

—   
—   

—   

—   

—   

—   

—   

—   

—   

9,041   
(396)   

(396)   

8,645   

(56)   

2,687   

(1,000)   

—   

(11,683)   

(1,488)   

(20)   

—   

—   

—   

—   

—   

—   

68   

—   

—   

—   

—   

—   

2,475   

(2,475)   

2   

47   

9,041 

(396) 

(396) 

8,645 

501 

2,687 

(1,000) 

— 

(11,683) 

(1,508) 

— 

49 

10,319    13,959   

20,743   

62,484   

37,539   

145,044 

Dividends per ordinary share at 31 December 2021 were $0.22 (2020: nil; 2019: $0.51).

1  At 31 December 2021, retained earnings included 329,871,829 ($2,542m) treasury shares (2020: 326,766,253 ($2,521m); 2019: 326,191,804 

($2,543m)).

2  On 26 October 2021, HSBC announced a share buy-back of up to $2.0bn, which is to be completed no later than 20 April 2022.
3  Permitted transfers from the merger reserve to retained earnings were made when the investment in HSBC Overseas Holdings (UK) Limited was 

previously impaired. In 2021, a part reversal of this impairment resulted in a transfer from retained earnings back to the merger reserve of 
$3,065m. At 31 December 2020, an additional impairment of $435m (2019: $2,475m) was recognised and a permitted transfer of this amount was 
made from the merger reserve to retained earnings. 
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.

4 

HSBC Holdings plc Annual Report and Accounts 2021 317

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 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

38

Page

318

329

329

330

331

337

338

340

340

341

344

344

350

351

352

356

358

359

362

363

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

Business disposals

Events after the balance sheet date

HSBC Holdings’ subsidiaries, joint ventures and associates

Page

365

368

368
368
369

369

369

370

373

378

379

381

382

382

385

387

388

388

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 UK-adopted 
international accounting standards and 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. There were no unendorsed standards effective for the year ended 
31 December 2021 affecting these consolidated and separate financial statements. 

Standards adopted during the year ended 31 December 2021

There were no new accounting standards or interpretations that had a significant effect on HSBC in 2021. 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. 

(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 standard has been endorsed for use in the EU but has not yet been endorsed 
for use in the UK. The Group is in the process of implementing IFRS 17. Industry practice and interpretation of the standard are still 
developing. Therefore, the likely financial impact of its implementation remains uncertain. However, we have the following expectations 
as to the impact compared with our current accounting policy for insurance contracts, which is set out in policy 1.2(j) below:

• Under IFRS 17, there will be no present value of in-force business (‘PVIF’) asset recognised. Instead the estimated future profit will be 
included in the measurement of the insurance contract liability as the contractual service margin (‘CSM’), representing  unearned 
profit, and this will be gradually recognised in revenue as services are provided over the duration of the insurance contract. While the 
profit over the life of an individual contract will be unchanged, its emergence will be later under IFRS 17. The removal  of the PVIF 
asset and the recognition of  CSM, which is a liability, will reduce  equity. 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.

318 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
• IFRS 17 requires increased use of current market values in the measurement of insurance liabilities. Changes in market conditions for 
certain products measured under the general measurement approach are immediately recognised in profit or loss, while changes in 
market conditions for other products measured under the variable fee approach are included in the measurement of CSM.

• In accordance with IFRS 17, directly attributable costs will be incorporated in the CSM and recognised in the results of insurance 

services as a reduction in reported revenue, 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 reported operating expenses compared with the current 
accounting policy.

• We intend to provide an update on the likely financial impacts at or around our 2022 interim results announcement, when we expect 

that this will be reasonably estimable. 

(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 the Annual Report and Accounts 2021 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 120 to 216.

• The ‘Own funds disclosure’ is included in the ‘Risk review’ on page 193.

• Disclosures relating to HSBC’s securitisation activities and structured products are included in the ‘Risk review’ on pages 120 to 216.

HSBC follows the UK Finance Disclosure Code. The UK Finance 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 UK Finance 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, 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.

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 uncertainty that the global Covid-19 pandemic 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 plc Annual Report and Accounts 2021 319

Financial statementsNotes on the financial statements

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 equity assigned to individual CGUs. The cost of equity 
percentage is generally derived from a capital asset pricing model and market implied cost of 
equity, 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.

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 capital 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.

320 HSBC Holdings plc Annual Report and Accounts 2021

 
 
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, 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.

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.

HSBC Holdings plc Annual Report and Accounts 2021 321

Financial statements 
Notes on the financial statements

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.

• 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.

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.

322 HSBC Holdings plc Annual Report and Accounts 2021

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; 

• 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 

HSBC Holdings plc Annual Report and Accounts 2021 323

Financial statementsNotes on the financial statements

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. Changes made to these financial instruments 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 of the interest rate benchmark. 

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 PDs and through-the-cycle migration probabilities, consistent with the instrument’s 
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 138. 

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.

324 HSBC Holdings plc Annual Report and Accounts 2021

 
 
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 makes use of the Basel II IRB framework where possible, with recalibration to meet the differing IFRS 9 requirements as set out in 
the following table:

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 

HSBC Holdings plc Annual Report and Accounts 2021 325

Financial statements 
Notes on the financial statements

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 its 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 144. 

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 section ‘Measurement uncertainty and 

sensitivity analysis of ECL estimates’, marked as 
audited from page 144, sets out the assumptions 
used in determining ECL, and provides 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’.

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 

326 HSBC Holdings plc Annual Report and Accounts 2021

  
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.

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 and estimates.

Judgements

Estimates

•

In assessing the probability and sufficiency of future taxable profit, we 
consider the availability of evidence to support the recognition of deferred 
tax assets. taking into account the inherent risk in long-term forecasting 
and drivers of recent history of tax losses where applicable, taking into 
account the future reversal of existing taxable temporary differences and 
tax planning strategies including corporate reorganisations. Specific 
judgements supporting deferred tax assets are described in Note 7.

The recognition of deferred tax assets is sensitive to estimates of future 
cash flows projected for periods for which detailed forecasts are available 
and to assumptions regarding the long-term pattern of cash flows 
thereafter, on which forecasts of future taxable profit are based, and 
which affect the expected recovery periods and the pattern of utilisation 
of tax losses and tax credits. In particular there is estimation uncertainty 
relating to the recognition of deferred tax on the post-1 April 2017 tax 
losses of HSBC Holdings plc. See Note 7 for further detail. 

HSBC Holdings plc Annual Report and Accounts 2021 327

Financial statements 
 
Notes on the financial statements

(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.

Contingent liabilities, contractual commitments and guarantees 

Contingent liabilities

• 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.

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.

(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). 

328 HSBC Holdings plc Annual Report and Accounts 2021

 
2

Net fee income

Net fee income by global business

Funds under management

Cards

Credit facilities

Broking income

Account services

Unit trusts

Underwriting

Global custody

Remittances

Imports/exports

Insurance agency commission

Other

Fee income

Less: fee expense

Net fee income 

Funds under management

Cards

Credit facilities

Broking income

Account services

Unit trusts

Underwriting

Global custody

Remittances

Imports/exports

Insurance agency commission

Other

Fee income

Less: fee expense

Net fee income

Wealth and
Personal
Banking

Commercial
Banking

2021

Global
Banking and
Markets

$m

1,984   

1,949   

103   

863   

429   

1,065   

4   

167   

75   

1   

324   

1,305   

8,269   

(2,375)   

5,894   

$m

126   

240   

833   

69   

677   

23   

6   

24   

357   

474   

17   

1,077   

3,923   

(284)   

3,639   

Wealth and
Personal 
Banking

Commercial
Banking

2020

Global
Banking and
Markets

$m

1,686   

1,564   

93   

862   

431   

881   

5   

189   

77   

—   

307   

1,123   

7,218   

(1,810)   

5,408   

$m

126   

360   

740   

61   

598   

18   

9   

22   

313   

417   

17   

893   

3,574   

(349)   

3,225   

$m

477   

25   

626   

616   

264   

—   

1,002   

723   

288   

160   

1   

2,369   

6,551   

(3,284)   

3,267   

$m

546   

23   

690   

669   

340   

—   

1,009   

787   

343   

145   

—   

2,503   

7,055   

(3,452)   

3,603   

Corporate
Centre

$m

—   

—   

—   

—   

—   

—   

(1)   

—   

(1)   

—   

—   

(2,290)   

(2,292)   

2,266   

(26)   

Corporate
Centre

$m

—   

1   

1   

—   

6   

—   

(2)   

—   

—   

—   

—   

Total

$m

2,656 

2,213 

1,627 

1,601 

1,452 

1,088 

1,017 

978 

775 

620 

341 

(2,465)   

(2,459)   

2,420   

(39)   

2,420 

16,788 

(3,691) 

13,097 

2019

Total

$m

2,177 

1,975 

1,618 

1,057 

2,003 

1,035 

829 

717 

747 

662 

377 

2,242 

15,439 

(3,416) 

12,023 

Total

$m

2,289   

1,949   

1,459   

1,539   

1,293   

899   

1,015   

934   

677   

577   

325   

2,095   

15,051   

(3,177)   

11,874   

Net fee income included $6,742m of fees earned on financial assets that were not at fair value through profit or loss, other than amounts 
included in determining the effective interest rate (2020: $5,858m; 2019: $6,647m), $1,520m of fees payable on financial liabilities that 
were not at fair value through profit or loss, other than amounts included in determining the effective interest rate (2020: $1,260m; 
2019: $1,450m), $3,849m of fees earned on trust and other fiduciary activities (2020: $3,426m; 2019: $3,110m) and $305m of fees 
payable relating to trust and other fiduciary activities (2020: $267m; 2019: $237m).

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 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 derivatives1
Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss

2021

$m

6,668   

1,076   

7,744   

4,134   

(81)   

4,053   

(2,811)   

2,629   

(182)   

798   

2020

$m

11,074   

(1,492)   

9,582   

2,481   

(400)   

2,081   

2,619   

(2,388)   

231   

455   

2019

$m

16,121 

(5,890) 

10,231 

3,830 

(352) 

3,478 

2,561 

(2,471) 

90 

812 

Year ended 31 Dec

12,413   

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 plc Annual Report and Accounts 2021 329

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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

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 2021

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

1  Discretionary participation features.

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 2021

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

1 Discretionary participation features.

330 HSBC Holdings plc Annual Report and Accounts 2021

2021

$m

87   

23   

110   

(625)   

974   

349   

(420)   

39   

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 

Non-linked
insurance

 Linked life
insurance

$m

8,529   

(555)   

7,974   

8,321   

(362)   

7,959   

9,353   

(1,465)   

7,888   

$m

1,027   

(4)   

1,023   

579   

(8)   

571   

489   

(7)   

482   

Investment
contracts with
DPF1

$m

Total

$m

1,873   

11,429 

—   

(559) 

1,873   

10,870 

1,563   

—   

1,563   

2,266   

—   

2,266   

10,463 

(370) 

10,093 

12,108 

(1,472) 

10,636 

Non-linked
insurance

Linked life
insurance

Investment
contracts with
DPF1

$m

10,474   

2,929   

7,545   

(543)   

(343)   

(200)   

$m

1,134   

1,023   

111   

(9)   

(7)   

(2)   

$m

3,332   

2,142   

1,190   

—   

—   

—   

Total

$m

14,940 

6,094 

8,846 

(552) 

(350) 

(202) 

9,931   

1,125   

3,332   

14,388 

10,050   

3,695   

6,355   

(366)   

(430)   

64   

9,684   

11,305   

3,783   

7,522   

(1,402)   

(411)   

(991)   

9,903   

1,112   

900   

212   

(4)   

(10)   

6   

1,853   

2,083   

(230)   

—   

—   

—   

13,015 

6,678 

6,337 

(370) 

(440) 

70 

1,108   

1,853   

12,645 

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 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Liabilities under insurance contracts

Gross liabilities under insurance contracts at 1 Jan 2021

Claims and benefits paid

Increase in liabilities to policyholders
Exchange differences and other movements2
Gross liabilities under insurance contracts at 31 Dec 2021

Reinsurers’ share of liabilities under insurance contracts

Net liabilities under insurance contracts at 31 Dec 2021

Gross liabilities under insurance contracts at 1 Jan 2020

Claims and benefits paid

Increase in liabilities to policyholders
Exchange differences and other movements2
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

 Non-linked
insurance

 Linked life
insurance

$m

72,464   

(2,929)   

10,474   

(534)   

79,475   

(3,638)   

75,837   

65,324   

(3,695)   

10,050   

785   

72,464   

(3,434)   

69,030   

$m

6,449   

(1,023)   

1,134   

(47)   

6,513   

(30)   

6,483   

6,151   

(900)   

1,112   

86   

6,449   

(14)   

6,435   

Investment
contracts with
DPF1

$m

Total

$m

28,278   

107,191 

(2,142)   

3,332   

(2,711)   

(6,094) 

14,940 

(3,292) 

26,757   

112,745 

—   

(3,668) 

26,757   

109,077 

25,964   

(2,083)   

1,853   

2,544   

28,278   

—   

28,278   

97,439 

(6,678) 

13,015 

3,415 

107,191 

(3,448) 

103,743 

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

Employee compensation and benefits

Capitalised wages and salaries 

Gross employee compensation and benefits for the year ended 31 Dec

Consists of:

Wages and salaries

Social security costs

Post-employment benefits

Year ended 31 Dec

2021

$m

18,742   

870   

19,612   

17,072   

1,503   

1,037   

19,612   

2020

$m

18,076   

1,320   

19,396   

17,072   

1,378   

946   

19,396   

2019

$m

18,002 

1,475 

19,477 

17,056 

1,472 

949 

19,477 

Employee compensation and benefits are presented net of software capitalisation costs in the income statement. During 2021, the 
allocation methodology for internally capitalised software costs between ‘employee compensation and benefits’ and ‘general 
administrative expenses’ has been updated to better reflect the underlying costs being capitalised.

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

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

2021

2020

2019

138,026   

144,615   

148,680 

44,992   

48,179   

359   

45,631   

49,055   

411   

46,584 

51,313 

478 

231,556   

239,712   

247,055 

2021

60,919   

127,673   

9,329   

13,845   

19,790   

2020

64,886   

129,923   

9,550   

15,430   

19,923   

2019

66,392 

133,624 

9,798 

16,615 

20,626 

231,556   

239,712   

247,055 

HSBC Holdings plc Annual Report and Accounts 2021 331

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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

2021

$m

3,495   

(379)   

3,116   

270   

4   

3,390   

2020

$m

2,659   

(239)   

2,420   

286   

2   

2,708   

‘Wages and salaries’ includes the effect of share-based payments arrangements, of which $467m was equity settled (2020: $434m; 
2019: $478m), as follows:

Conditional share awards

Savings-related and other share award option plans

Year ended 31 Dec

HSBC share awards

Award

Policy

2021

$m

479

27

506

2020

$m

411

51

462

2019

$m

3,341 

(337) 

3,004 

327 

(55) 

3,276 

2019

$m

521

30

551

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. 
•  Awards are subject to malus and clawback provisions.

International Employee 
Share Purchase Plan 
(‘ShareMatch’)

The plan was first introduced in Hong Kong in 2013 and now includes employees based in 28 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 (in mainland China matching awards 

are settled in cash).

•  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 ($)

HSBC share option plans

Main plans

Policy

2021

Number

(000s)

103,473   

75,549   

(63,635)   

(6,023)   

109,364   

6.49   

2020

Number

(000s)

97,055 

72,443 

(60,673) 

(5,352) 

103,473 

7.28 

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% (2020: 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. 

332 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Movement on HSBC share option plans

Outstanding at 1 Jan 2021
Granted during the year2
Exercised during the year3
Expired during the year

Forfeited during the year

Outstanding at 31 Dec 2021

– of which exercisable
Weighted average remaining contractual life (years)

Outstanding at 1 Jan 2020
Granted during the year2
Exercised during the year3
Expired during the year

Forfeited during the year

Outstanding at 31 Dec 2020

– of which exercisable
Weighted average remaining contractual life (years)

Savings-related
share option plans

Number

(000s)

130,953   

15,410   

(3,878)   

(11,502)   

(7,786)   

123,197   

4,949   

3.02

65,060   

111,469   

(1,387)   

(43,032)   

(1,158)   

130,953   

8,170   

3.68

WAEP1

£

2.97 

3.15 

3.80 

3.53 

3.97 

2.85 

4.05 

4.81 

2.63 

4.48 

4.81 

4.88 

2.97 

4.50 

1  Weighted average exercise price.
2  The weighted average fair value of options granted during the year was $0.85 (2020: $0.47).
3  The weighted average share price at the date the options were exercised was $5.87 (2020: $7.08).

Post-employment benefit plans

The Group operates pension plans throughout the world for its employees. ‘Pension risk management processes’ on page 192 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, inflation swaps to reduce inflation risk and longevity swaps to reduce the 
impact of longer life expectancy.

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 continued to make separately committed lump sum contributions and the 
final such contribution of £160m ($218m) was 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 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.

HSBC Holdings plc Annual Report and Accounts 2021 333

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Income statement charge

Defined benefit pension plans

Defined contribution pension plans

Pension plans

Defined benefit and contribution healthcare plans

Year ended 31 Dec

2021

$m

243   

767   

1,010   

27   

1,037   

2020

$m

146   

775   

921   

25   

946   

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 2021

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 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’)

HSBC Holdings

Fair value of
plan assets

Present value of
defined benefit
obligations

Effect of
limit on plan
surpluses

$m

51,431   

103   

51,534   

$m

(42,277)   

(572)   

(42,849)   

52,990   

114   

53,104   

(43,995)   

(639)   

(44,634)   

$m

(23)   

—   

(23)   

(44)   

—   

(44)   

2019

$m

176 

758 

934 

15 

949 

Total

$m

9,131 

(469) 

8,662 

(1,607) 

10,269 

8,951 

(525) 

8,426 

(2,025) 

10,450 

Employee compensation and benefit expense in respect of HSBC Holdings’ employees in 2021 amounted to $30m (2020: $56m). The 
average number of persons employed during 2021 was 54 (2020: 59). A small number of employees  are members of defined benefit 
pension plans. These employees are members of the HSBC Bank (UK) Pension Scheme. HSBC Holdings pays contributions to such plan 
for its own employees in accordance with the schedules of contributions determined by the trustees of the plan and recognises these 
contributions as an expense as they fall due. 

334 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Defined benefit pension plans

Net asset/(liability) under defined benefit pension plans 

At 1 Jan 2021

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) financial assumptions

–  actuarial gains/(losses) demographic assumptions

–  actuarial gains/(losses) experience adjustments

–  other changes

Exchange differences

Benefits paid
Other movements2
At 31 Dec 2021

At 1 Jan 2020

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) financial assumptions

–  actuarial gains/(losses) demographic assumptions

–  actuarial gains/(losses) experience adjustments

–  other changes

Exchange differences

Benefits paid
Other movements2
At 31 Dec 2020

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

42,505   

10,485   

(33,005)   

(10,990)   

—   

—   

—   

—   

—   

—   

(55)   

(14)   

(41)   

(276)   

(206)   

(70)   

613   

172   

(473)   

(174)   

(377)   

(377)   

—   
—   

—   

—   

7   

7   

—   
—   
—   
—   

(361)   

(94)   

(271)   

—   

611   

(447)   

(435)   

—   

283   

(1,396)   

(645)   

1,396   

400   

122   

(130)   

471   

—   

315   

64   

92   

—   

138   

712   

97   

41,384   

10,047   

(32,255)   

(10,022)   

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   

692   

—   

—   

—   

187   

249   

(652)   

83   

(2,118)   

—   

(3,179)   

86   

975   

—   

(1,100)   

1,148   

(134)   

(547)   

—   

(564)   

49   

87   

(119)   

(387)   

727   

58   

42,505   

10,485   

(33,005)   

(10,990)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

Other
plans

$m

Principal1
plan

$m

(44)   

9,500   

—   

—   

—   

(55)   

(14)   

(41)   

Other
plans

$m

(549) 

(276) 

(206) 

(70) 

(1)   

140   

(3) 

22   

—   

—   

—   

—   

22   

—   

—   

—   

(648)   

(377)   

611   

(447)   

(435)   

—   

(78)   

—   

270   

(23)   

9,129   

(16)   

7,716   

—   

—   

—   

(68)   

(28)   

(40)   

500 

7 

315 

64 

92 

22 

44 

67 

219 

2 

(747) 

(172) 

(184) 

12 

—   

151   

(12) 

(26)   

1,055   

—   

—   

—   

—   

(26)   

(2)   

—   

—   

3,173   

(3,179)   

86   

975   

—   

346   

—   

300   

(44)   

9,500   

306 

692 

(564) 

49 

87 

42 

(140) 

75 

141 

(549) 

1  For further details of the principal plan, see page 333.
2  Other movements include contributions by HSBC, contributions by employees, administrative costs and taxes paid by plan.

HSBC expects to make $145m of contributions to defined benefit pension plans during 2022. 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

2022

$m

1,444   

474   

2023

$m

1,491   

473   

2024

$m

1,542   

460   

2025

$m

1,592   

459   

2026

$m

1,644   

453   

2027-2031

$m

9,070 

2,325 

1  The duration of the defined benefit obligation is 17.3 years for the principal plan under the disclosure assumptions adopted (2020: 17.4 years) and 

12.7 years for all other plans combined (2020: 13.5 years).

2  For further details of the principal plan, see page 333.

HSBC Holdings plc Annual Report and Accounts 2021 335

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Fair value of plan assets by asset classes

31 Dec 2021

Quoted
market price
in active
market

No quoted
market price
in active
market

$m

$m

Value

$m

Thereof
HSBC1

$m

Value

$m

31 Dec 2020

Quoted
market price
in active
market

No quoted
market price
in active
market

$m

$m

41,384   

36,270   

5,114   

1,037   

42,505   

37,689   

4,816   

197   

5   

36,295   

35,612   

1,864   
1,094   

1,934   

10,047   

892   

7,080   

7   

123   

1,945   

—   
—   

653   

8,248   

668   

6,490   

(13)   

119   

984   

192   

683   

1,864   
1,094   

1,281   

1,799   

224   

590   

20   

4   

961   

—   

—   

1,037   
—   

—   

52   

5   

5   

—   

—   

42   

268   

7   

36,198   

35,479   

1,973   
1,106   

2,960   

10,485   

1,484   

7,624   

(57)   

192   

—   
—   

2,203   

9,512   

1,069   

7,143   

—   

157   

1,242   

1,143   

261   

719   

1,973   
1,106   

757   

973   

415   

481   

(57)   

35   

99   

Thereof
HSBC1

$m

973 

— 

— 

973 
— 

— 

54 

3 

10 

— 

— 

41 

The principal plan2
Fair value of plan assets
–  equities3
–  bonds4
–  derivatives

–  property
–  other5
Other plans

Fair value of plan assets

–  equities

–  bonds

–  derivatives

–  property

–  other

1  The fair value of plan assets includes derivatives entered into with HSBC Bank plc as detailed in Note 35. 
2  For further details on the principal plan, see page 333.
3 
4  Principal plan bonds includes fixed income bonds of $18,315m (2020: $17,730m) and index-linked bonds of $18,160m (2020: $18,468m).
5  Other includes $0m (2020: $696m) of pooled investment vehicles with quoted underlying assets and $1,281m (2020: $757m) of pooled investment 

Includes $192m (2020: $261m) in relation to private equities. 

vehicles with unquoted underlying assets.

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 2021

At 31 Dec 2020

Discount rate

Inflation rate (RPI)2

Inflation rate (CPI)2

Rate of increase for 
pensions

Rate of pay increase

%

 1.90 

 1.45 

%

 3.45 

 3.05 

%

 3.20 

 2.50 

%

 3.30 

 3.00 

%

 3.45 

 2.75 

1  For further details on the principal plan, see page 333.
2  Due to the significant difference between short-term and long-term inflation expectations that has developed over 2021, HSBC UK has changed the 

methodology of setting inflation-related assumptions to fully and separately reflect how benefits are linked to RPI inflation and CPI inflation 
respectively. For example, the revaluation of deferred pensions is driven by CPI inflation expectations in the short to medium term, whereas 
increases to pensions in payment are driven by RPI inflation expectations over the long term.

Mortality tables and average life expectancy at age 60  for the principal plan1

UK

At 31 Dec 2021

At 31 Dec 2020

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 S32

27.3

27.0

28.8

28.5

28.5

28.1

30.1

29.7

1  For further details of the principal plan, see page 333.
2  Self-administered pension scheme (‘SAPS’) S3 table, with different tables and multipliers adopted based on gender, pension amount and member 

status, reflecting the Scheme’s actual mortality experience.  Improvements are projected in accordance with the Continuous Mortality 
Investigation’s CMI 2020 core projection model with an initial addition  to  improvement of 0.25% per annum and a long-term rate of improvement 
of 1.25% per annum. 

The effect of changes in key assumptions on the principal plan1

Discount rate – increase/decrease of 0.25%

Inflation rate (RPI and CPI) – 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

Impact on HBUK section of the 
HSBC Bank (UK) Pension Scheme obligation2

Financial impact of increase

Financial impact of decrease

2021

$m

(1,337)   

1,211   

1,267   

20   

1,387   

2020

$m

(1,383)   

871   

1,307   

60   

1,453 

2021

$m
1,425   
(980)   
(1,177)   
(20)   
N/A

2020

$m
1,475 

(830) 

(1,222) 

(59) 

N/A

1  For further details of the principal plan, see page 333.
2   Sensitivities allow for HSBC UK’s convention of rounding pension assumptions to the nearest 0.05%.

336 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.

Directors’ emoluments

Details of Directors’ emoluments, pensions and their interests are disclosed in the Directors’ remuneration report on page 254.

6

Auditor’s remuneration

Audit fees payable to PwC1
Other audit fees payable

Year ended 31 Dec

Fees payable by HSBC to PwC

Fees for HSBC Holdings’ statutory audit2
Fees for other services provided to HSBC

–  audit of HSBC’s subsidiaries
–  audit-related assurance services3
–  other assurance services4,5
–  taxation compliance services
–  other non-audit services4
Year ended 31 Dec

2021

$m

88.1

2.0

90.1

2021

$m

19.5   

109.9   

68.6   

18.7   

22.6   

—   

—   

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 

129.4   

130.2   

110.7 

1 Audit fees payable to PwC in the current year include adjustments made to the prior year audit fee after finalisation of the 2020 financial 

statements. 

2 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.

3 Including services for assurance and other services that relate to statutory and regulatory filings, including interim reviews.
4 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.

5   Includes reviews of PRA regulatory reporting returns.

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

2021

$000

382   

382   

2020

$000

316   

316   

2019

$000

250 

250 

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 $6.3m (2020: $12.3m; 
2019: $17.2m). 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.

HSBC Holdings plc Annual Report and Accounts 2021 337

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

7

Tax

Tax expense

Current tax1
–  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 Dec2

2021

$m

3,250   

3,182   

68   

963   

874   

132   

(43)   

2020

$m

2,700   

2,883   

(183)   

(22)   

(341)   

58   

261   

2019

$m

3,768 

3,689 

79 

871 

684 

(11) 

198 

4,213   

2,678   

4,639 

1  Current tax included Hong Kong profits tax of $813m (2020: $888m; 2019: $1,413m). The Hong Kong tax rate applying to the profits of subsidiaries 

assessable in Hong Kong was 16.5% (2020: 16.5%; 2019: 16.5%). 
In addition to amounts recorded in the income statement, a tax charge of $7m (2020: charge of $7m) 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:

Profit before tax

Tax expense

Taxation at UK corporation tax rate of 19.00%

Impact of differently taxed overseas profits in overseas locations

 UK banking surcharge

Items increasing tax charge in 2021:

–  impact of differences between French tax basis and IFRSs

–  local taxes and overseas withholding taxes

–  UK tax losses not recognised

–  other permanent disallowables

–  non-deductible goodwill write-down

–  impact of changes in tax rates

–  bank levy

–  impacts of hyperinflation

–  adjustments in respect of prior period liabilities

–  non-deductible regulatory settlements

Items reducing tax charge in 2021:

–  non-taxable income and gains

–  tax impact of planned sale of French retail banking business

–  effect of profits in associates and joint ventures

–  deductions for AT1 coupon payments

–  non-UK movements in unrecognised deferred tax

–  non-deductible UK customer compensation

–  non-taxable gain on dilution of shareholding in SABB

–  other items

Year ended 31 Dec

2021

$m

18,906 

3,592 

280 

332 

434 

360 

294 

254 

178 

132 

93 

68 

25 

2 

(641) 

(434) 

(414) 

(270) 

(67) 

(5) 

— 

— 

%

2020

$m

8,777 

 19.0   

1,668 

 1.5   

 1.8   

 2.3   

 1.9   

 1.6   

 1.3   

 0.9   

 0.7   

 0.5   

 0.4   

 0.1   

 —   

 (3.4)   

 (2.3)   

 (2.2)   

 (1.4)   

 (0.4)   

 —   

 —   

 —   

178 

(113) 

— 

228 

444 

322 

— 

58 

202 

65 

78 

33 

(515) 

— 

(250) 

(310) 

608 

(18) 

— 

— 

%

 19.0   

 2.0   

 (1.3)   

 —   

 2.6   

 5.1   

 3.6   

 —   

 0.6   

 2.3   

 0.7   

 0.9   

 0.4   

 (5.8)   

 —   

 (2.8)   

 (3.5)   

 6.9   

 (0.2)   

 —   

 —   

2019

$m

13,347 

2,536 

253 

29 

— 

484 

364 

481 

1,421 

(11) 

184 

29 

277 

5 

(844) 

— 

(467) 

(263) 

12 

382 

(181) 

(52) 

4,213 

 22.3   

2,678 

 30.5   

4,639 

%

 19.0 

 1.9 

 0.2 

 — 

 3.6 

 2.7 

 3.6 

 10.7 

 (0.1) 

 1.4 

 0.2 

 2.1 

 — 

 (6.3) 

 — 

 (3.5) 

 (2.0) 

 0.1 

 2.9 

 (1.3) 

 (0.4) 

 34.8 

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 2021 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 22.3% (2020: 19.7%). The effective tax rate for the year 
of 22.3% was lower than in the previous year (2020: 30.5%). The impact of non-recognition of deferred tax was smaller in 2021 than in 
2020, which decreased the effective tax rate by 10.8%. This was partly offset by changes in the geographical composition of profits, 
which resulted in tax at applicable local statutory rates being 2.5% greater for 2020 than for 2021. 

The signing of a framework agreement for the planned sale of the French retail banking business resulted in a tax deduction (tax value of 
$434m) for a provision for loss on disposal, which was recorded in the French tax return. A deferred tax liability of the same amount arises 
as a consequence of the temporary difference between the French tax basis and IFRSs in respect of this provision. 

During 2021, legislation to increase the main rate of UK corporation tax from 19% to 25% from 1 April 2023 was enacted, increasing the 
Group’s 2021 tax charge by $132m due to the remeasurement of deferred tax balances.   

Accounting for taxes involves some estimation because 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. 

338 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Movement of deferred tax assets and liabilities

Assets

Liabilities

At 1 Jan 2021

Income statement

Other comprehensive income

Foreign exchange and other adjustments

At 31 Dec 2021
Assets2
Liabilities2

Assets

Liabilities

At 1 Jan 2020

Income statement

Other comprehensive income

Foreign exchange and other adjustments

At 31 Dec 2020
Assets2
Liabilities2

Loan
impairment
provisions

Unused tax
losses and
tax credits

Derivatives, FVOD1
and other
investments

Insurance
business

Expense
provisions

Fixed 
assets

Retirement 
obligations

Other

Total

$m

$m

$m

$m

$m

$m

$m

$m

$m

1,242   

1,821   

548   

—   

565    901   

—    960   6,037 

—   

—   

(705)   

(1,622)   

—    —   

(2,306)   (1,234)   (5,867) 

1,242   

1,821   

(157)   

(1,622)   

565    901   

(2,306)   

(274)    170 

(89)   

(5)   

14   

1,162   

1,162   

—   

983   

—   

983   

295   

—   

(36)   

1,242   

1,242   

—   

161   

33   

(14)   

2,001   

2,001   

—   

1,414   

—   

1,414   

355   

—   

52   

1,821   

1,821   

—   

22   

149   

(5)   

9   

9   

(43)   

—   

25   

(333)   

(26)   

(336)   

(319)    (963) 

74   

25   

(205)    713    784 

(10)   

3   

28   

(81)   

(1,640)   

296    903   

(2,819)   

39   

—   

296    903   

109    742   5,222 

(40) 

(49) 

—   

(1,640)   

—    —   

(2,928)   

(703)   (5,271) 

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)   

(23)   

(281)   

(32)   

—   

31   

(81)   

(112)   

(190)   

61   

22 

—    —   

(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) 

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 $4,624m (2020: $4,483m) 

and deferred tax liabilities $4,673m (2020: $4,313m). 

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. Management’s assessment of the likely availability of future taxable 
profits against which to recover deferred tax assets is based on the most recent financial forecasts approved by management, which 
cover a five-year period and are extrapolated where necessary, and takes into consideration the reversal of existing taxable temporary 
differences and past business performance.

The Group’s net deferred tax asset of $4.6bn (2020: $4.5bn) included $2.6bn (2020: $2.4bn) of deferred tax assets relating to the US and a 
net deferred asset of $0.0bn (2020: $0.00) in France. 

The net US deferred tax asset of $2.6bn included $1.1bn 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.

The net deferred tax asset in France of $0.0bn included $0.4bn related to tax losses which are expected to be substantially recovered 
within 10 years.  

Following the signing of a framework agreement in 2021 for the planned sale of the French retail banking business, that business is now 
excluded from our deferred tax analysis as its sale is considered probable. Although the French consolidated tax group recorded a tax loss 
in both 2020 and 2021, this would have been taxable profit if the effects of the retail banking business and other non-recurring items, 
mainly related to the restructuring of the European business, were excluded. The French net deferred tax asset is supported by forecasts 
of taxable profit, also taking into consideration the history of profitability in the remaining businesses. No net deferred tax asset was 
recognised as at 31 December 2020 as management did not consider there to be convincing evidence of sufficient future taxable profits 
within the French consolidated tax group to support recognition. 

The Group’s net deferred tax liability of $4.7bn (2020: $4.3bn) included a net UK deferred tax asset of $0.8bn (2020: $0.6bn), of which 
$0.2bn related to UK banking tax losses which are expected to be substantially recovered within one year. The net UK deferred tax asset 
of $0.8bn excludes a $3.0bn 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 assets are supported by forecasts of taxable profit, also taking into 
consideration the history of profitability in the relevant businesses.     
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 $16.9bn (2020: $15.6bn). This amount included unused UK tax losses of $10.5bn (2020: $9.3bn), of which $5.8bn (2020: 
$4.3bn) arose after 1 April 2017 and can be recovered against the future taxable profits of any of the Group’s UK tax resident subsidiaries. 
The remaining balance can only be recovered against future taxable profits of HSBC Holdings plc. No deferred tax was recognised on any 
of these losses due to the absence of convincing evidence regarding the availability of sufficient future taxable profits against which to 
recover them, taking into account the recent history of taxable losses within the UK group. Deferred tax asset recognition is reassessed at 
each balance sheet date based on the available evidence. Of the total amounts unrecognised, $10.9bn (2020: $11.5bn) had no expiry date, 
$0.7bn (2020: $0.7bn) 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 $12.7bn 
(2020: $12.1bn) and the corresponding unrecognised deferred tax liability was $0.8bn (2020: $0.7bn).

HSBC Holdings plc Annual Report and Accounts 2021 339

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

8

Dividends

Dividends to shareholders of the parent company

2021

Per
share

$

Total

$m

Settled
in scrip

$m

Per
share

$

2020

Total

$m

Settled
in scrip

$m

Per
share

$

2019

Total

$m

Settled 
in scrip

$m

Dividends paid on ordinary shares

In respect of previous year:

–  fourth interim dividend / interim dividend

0.15   

3,059   

—   

—   

—   

—   

0.21   

4,206   

1,160 

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)1

Total coupons on capital securities classified as 
equity 

Dividends to shareholders 

0.07   

1,421   

—   

—   

—   

—   

0.22   

4,480   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

0.10   

0.10   

0.10   

0.51   

2,013   

2,021   

2,029   

375 

795 

357 

10,269   

2,687 

4.99   

7 

62.00   

90 

62.00   

90 

1,303 

5,790 

1,241 

1,331 

1,324 

11,683 

1   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.

Total coupons on capital securities classified as equity 

Perpetual subordinated contingent convertible securities,1,2
$1,500m issued at 5.625%2
$2,000m issued at 6.875%3
$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%4
$1,000m issued at 4.000%5
$1,000m issued at 4.700%6
€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

2021

First call date Per security

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   

Jun 2031  

$46.000   

Mar 2026  

$40.000   

Mar 2031  

$47.000   

Sep 2022  

€52.500   

Sep 2023  

€60.000   

July 2029  

€47.500   

Sep 2026  
£58.750   
Jun 2022   SGD47.000   

Sep 2023   SGD50.000   

Total

$m

—   

69   

143   

156   

180   

147   

117   
69   
20   
24   
93   

70   

72   

80   
35   

28   

2020

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 

1,303   

1,241   

1,324 

1 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.

2 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.

3 This security was called by HSBC Holdings on 15 April 2021 and was redeemed and cancelled on 1 June 2021.
4 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.

5 This security was issued by HSBC Holdings on 9 March 2021. The first call date commences six calendar months prior to the reset date of 

9 September 2026.

6 This security was issued by HSBC Holdings on 9 March 2021. The first call date commences six calendar months prior to the reset date of 

9 September 2031.

After the end of the year, the Directors approved a second interim dividend in respect of the financial year ended 31 December 2021 of 
$0.18 per ordinary share, a distribution of approximately $3,649m. The second interim dividend for 2021 will be payable on 28 April 2022 
to holders on the Principal Register in the UK, the Hong Kong Overseas Branch Register or the Bermuda Overseas Branch Register on 
11 March 2022. No liability was recorded in the financial statements in respect of the second interim dividend for 2021.

On 4 January 2022, HSBC paid a coupon on its €1,250m subordinated capital securities, representing a total distribution of €30m 
($34m). No liability was recorded in the balance sheet at 31 December 2021 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. 

340 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

2021

$m

13,917   

(7)   

(1,303)   

12,607   

2020

$m

5,229   

(90)   

(1,241)   

3,898   

2019

$m

7,383 

(90) 

(1,324) 

5,969 

Basic1
Effect of dilutive potential 
ordinary shares

Diluted1

2021

Number 
of shares

Profit

$m

(millions)

Per
 share

$

2020

Number
of shares

Profit

$m

(millions)

Per
share

$

Profit

$m

2019

Number
of shares

(millions)

12,607   

20,197   

0.62   

3,898   

20,169   

0.19   

5,969   

20,158   

Per
share

$

0.30 

105 

73 

75 

12,607   

20,302   

0.62   

3,898   

20,242   

0.19   

5,969   

20,233   

0.30 

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 
8.6 million (2020: 14.6 million; 2019: 1.1 million).

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 2020 and 2019 adjusted performance information is presented on 
a constant currency basis. The 2020 and 2019 income statements are converted at the average rates of exchange for 2021, and the 
balance sheets at 31 December 2020 and 31 December 2019 at the prevailing rates of exchange on 31 December 2021. 

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.

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 Holdings plc Annual Report and Accounts 2021 341

Financial statements 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC adjusted profit before tax and balance sheet data

Net operating income/(expense) before change in expected credit losses 
and other credit impairment charges1

–  external

–  inter-segment

of which: net interest income/(expense)

Change in expected credit losses and other credit impairment 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

Net operating income/(expense) before change in expected credit losses and other 
credit impairment charges1

–  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

Net operating income/(expense) before change in expected credit losses and other 
credit impairment charges1

–  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

2021

Global
Banking and
Markets

Corporate 
Centre

$m

$m

$m

$m

22,110   
21,753   
357   
14,198   

288   

22,398   

(15,384)   

7,014   

34   

13,415   

15,002   

13,294   

16,558   

121   

8,898   

300   

13,715   

(6,973)   

6,742   

1   

(1,556)   

4,122   

337   

15,339   

(10,006)   

5,333   

—   

7,048   

6,743   

5,333   

%

 32.2 

 69.6 

$m

%

 30.8 

 52.0 

$m

%

 24.3 

 66.7 

$m

Total

$m

50,090 

50,090 

— 

(437)   

(1,515)   

1,078   

(739)   

26,479 

3   

(434)   

215   

(219)   

3,011   

2,792   

%

 12.7 

 49.2 

$m

928 

51,018 

(32,148) 

18,870 

3,046 

21,916 

%

 100.0 

 64.2 

$m

488,786   

349,126   

207,162   

740   

1,045,814 

499   

13   

126   

28,971   

29,609 

932,582   

622,925   

1,229,820   

172,612   

2,957,939 

859,029   

506,688   

344,205   

652   

1,710,574 

2020

15,768   

18,651   

(2,883)   

4,580   

(1,289)   

14,479   

(9,640)   

4,839   

—   

4,839   

%

 39.4 

 61.1 
$m

13,718   

14,114   

(396)   

9,560   

(4,989)   

8,729   

(6,897)   

1,832   

(1)   

1,831   

%

 14.9 

 50.3 
$m

338,193   
13   

220,692   
141   

(287)   

(1,469)   

1,182   

(1,337)   

1   

(286)   

(429)   

(715)   

2,186   

1,471   

%

 12.0 

 (149.5) 
$m

1,231   
26,472   

51,770 

51,770 

— 

28,273 

(9,282) 

42,488 

(32,409) 

10,079 

2,192 

12,271 

%

 100.0 

 62.6 
$m

1,022,402 
27,070 

562,125   

1,319,389   

187,189   

2,938,627 

464,380   

331,164   

593   

1,620,128 

2019

15,282   

20,782   

(5,500)   

5,309   

(155)   

15,127   

(9,891)   

5,236   

1   

5,237   

%

 23.1 

 64.7 

$m

15,594   

16,522   

(928)   

11,242   

(1,194)   

14,400   

(7,028)   

7,372   

1   

7,373   

%

 32.5 

 45.1 

$m

(581)   

(2,646)   

2,065   

(3,338)   

38   

(543)   

(821)   

(1,364)   

2,440   

1,076   

%

 4.7 

 (141.3) 

$m

56,435 

56,435 

— 

31,033 

(2,687) 

53,748 

(33,563) 

20,185 

2,496 

22,681 

%

 100.0 

 59.5 

$m

22,571   

20,474   

2,097   

15,470   

(3,005)   

19,566   

(15,443)   

4,123   

7   

4,130   

%

 33.7 

 68.4 
$m

462,286   
444   

869,924   

823,991   

26,140   

21,777   

4,363   

17,820   

(1,376)   

24,764   

(15,823)   

8,941   

54   

8,995   

%

 39.7 

 60.5 

$m

448,880   

348,716   

248,062   

1,141   

1,046,799 

445   

780,456   

758,414   

14   

16   

25,305   

25,780 

515,962   

1,283,597   

161,055   

2,741,070 

392,133   

298,618   

760   

1,449,925 

1   Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

342 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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/territory1
–  UK

–  Hong Kong

–  US

–  France

–  other countries

2021

$m

49,552   

10,909   

14,245   

3,795   

2,179   

2020

$m

50,429   

9,163   

15,783   

4,474   

1,753   

18,424   

19,256   

2019

$m

56,098 

9,011 

18,449 

4,471 

1,942 

22,225 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

Adjusted results reconciliation

Revenue1
ECL

2021

Significant

Adjusted

items Reported Adjusted

2020

2019

Currency
translation

Significant

 items Reported Adjusted

Currency
translation

Significant
items

Reported

$m

$m

$m

$m

$m

$m

$m

$m

$m

$m

$m

  50,090   

(538)    49,552    51,770   

(1,393)   

52    50,429    56,435   

(1,010)   

673    56,098 

928   

—   

928   

(9,282)   

465   

—   

(8,817)   

(2,687)   

(69)   

981   

—   

(2,756) 

(9,767)    (42,349) 

Operating expenses

  (32,148)   

(2,472)    (34,620)    (32,409)   

1,072   

(3,095)    (34,432)    (33,563)   

Share of profit in associates and joint 
ventures 

  3,046   

—   

3,046    2,192   

(133)   

(462)   

1,597   

2,496   

(142)   

—   

2,354 

Profit/(loss) before tax

  21,916   

(3,010)    18,906    12,271   

11   

(3,505)   

8,777    22,681   

(240)   

(9,094)    13,347 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

Adjusted balance sheet reconciliation

2021

Reported and
adjusted

$m

Adjusted

$m

2020

Currency 
translation

Reported

Adjusted

2019

Currency 
translation

$m

$m

$m

$m

Reported

$m

Loans and advances to customers (net)

1,045,814   

1,022,402   

15,585   

1,037,987   

1,046,799   

(10,056)   

1,036,743 

Interests in associates and joint ventures

29,609   

27,070   

(386)   

26,684   

25,780   

(1,306)   

24,474 

Total external assets

Customer accounts

2,957,939   

2,938,627   

45,537   

2,984,164   

2,741,070   

(25,918)   

2,715,152 

1,710,574   

1,620,128   

22,652   

1,642,780   

1,449,925   

(10,810)   

1,439,115 

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 instruments1
–  restructuring and other related costs (revenue)2
–  costs of structural reform3
–  customer redress programmes (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)4
–  settlements and provisions in connection with legal and other regulatory matters
–  impairment of goodwill (share of profit in associates and joint ventures)5
–  currency translation on significant items

Currency translation

Reported profit before tax

2021

$m

2020

$m

21,916   

(3,010)   

12,271   

(3,505)   

11   

—   

(242)   

(307)   

—   

(49)   

(587)   

—   

(1,836)   

—   

—   

(21)   

(10)   

264   

(170)   

—   

54   

(1,090)   

(17)   

(1,908)   

(12)   

(462)   

(133)   

11   

2019

$m

22,681 

(9,094) 

(163) 

768 

84 

— 

(158) 

(1,281) 

(7,349) 

— 

(827) 

61 

— 

(229) 

(240) 

18,906   

8,777   

13,347 

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.
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 in 2020. 

5  During 2020, 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 2021 343

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

11 Trading assets

Treasury and other eligible bills

Debt securities

Equity securities

Trading securities
Loans and advances to banks1
Loans and advances to customers1
Year ended 31 Dec

2021

$m

23,110   

89,944   

109,614   

222,668   

7,767   

18,407   

2020

$m

24,035 

102,846 

77,643 

204,524 

8,242 

19,224 

248,842   

231,990 

1  Loans and advances to banks and customers include reverse repos, stock borrowing and other accounts.

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 an appropriate market 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.

344 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
Financial instruments carried at fair value and bases of valuation

2021

2020

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

  180,423   

65,757   

2,662    248,842   

167,980   

61,511   

2,499   

231,990 

17,937   

17,629   

14,238   

49,804   

19,711   

14,365   

11,477   

45,553 

2,783    191,621   

2,478    196,882   

2,602   

302,454   

2,670   

307,726 

  247,745   

97,838   

3,389    348,972   

303,654   

94,746   

3,654   

402,054 

63,437   

20,682   

785   

84,904   

53,290   

21,814   

162   

75,266 

Financial liabilities designated at fair value

1,379    136,243   

7,880    145,502   

1,267   

150,866   

5,306   

157,439 

Derivatives

1,686    186,290   

3,088    191,064   

1,788   

297,025   

4,188   

303,001 

Transfers between Level 1 and Level 2 fair values

At 31 Dec 2021

Transfers from Level 1 to Level 2

Transfers from Level 2 to Level 1

At 31 Dec 2020

Transfers from Level 1 to Level 2

Transfers from Level 2 to Level 1

Financial
investments

$m

Trading
assets

$m

8,477   

6,007   

6,553   

4,132   

4,514   

7,764   

3,891   

5,517   

Assets

Designated and otherwise
mandatorily measured at 
fair value

Liabilities

Derivatives

Trading
liabilities

Designated
at fair value

Derivatives

$m

$m

$m

$m

$m

1,277   

768   

245   

328   

103   

—   

—   

1   

181   

638   

155   

433   

—   

—   

7,414   

—   

212 

— 

— 

— 

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

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

2021

2020

GBM

$m

Corporate
Centre

$m

868   

412   

66   

228   

(92)   

254   

—   

57   

57   

—   

106   

1,031   

42   

—   

1   

35   

—   

6   

—   

—   

—   

—   

—   

42   

GBM

$m

1,170   

514   

106   

445   

(120)   

204   

21   

74   

70   

4   

104   

1,348   

Corporate
Centre

$m

28 

— 

1 

27 

— 

— 

— 

— 

— 

— 

— 

28 

We continue to observe losses on the disposals of certain uncollateralised over-the-counter (‘OTC’) derivatives as part of our 
commitments to reduce RWAs in GBM, as set out in our business update in February 2020. Based on our analysis, these losses are not 
considered to give rise to an adjustment within the IFRS 13 ‘Fair Value Measurement’ framework.

The reduction in fair value adjustments was driven by increased liquidity, lower volatility and an improved credit environment. Movement 
in funding fair value adjustment included a change in measurement from Libor to a Libor replacement risk-free rate.

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.

HSBC Holdings plc Annual Report and Accounts 2021 345

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Notes on the financial statements

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.

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 

Structured notes 

Derivatives with monolines 

Other derivatives 

Other portfolios 

At 31 Dec 2021

Private equity including strategic 
investments 

Asset-backed securities 

Structured notes 

Derivatives with monolines 

Other derivatives 

Other portfolios 

At 31 Dec 2020

1,837   

3,389   

2,528   

2,662   

14,238   

2,478   

22,767   

544   

1,008   

—   

—   

—   

930   

1,286   

—   

—   

—   

1,438   

3,654   

2   

13,732   

132   

—   

—   

—   

523   

—   

—   

—   

1,972   

2,499   

1   

—   

—   

—   

505   

25   

—   

—   

—   

481   

—   

—   

—   

—   

2,478   

—   

14,278   

1,141   

—   

—   

2,478   

4,870   

—   

—   

—   

68   

2,602   

—   

11,905   

1,834   

—   

68   

2,602   

3,891   

11,477   

2,670   

20,300   

4   

10,971   

9   

—   

—   

—   

—   

776   

785   

4   

—   

29   

—   

—   

129   

162   

346 HSBC Holdings plc Annual Report and Accounts 2021

Total

$m

9 

— 

7,879 

— 

3,088 

777 

—   

—   

7,879   

—   

—   

1   

—   

—   

—   

—   

3,088   

—   

7,880   

3,088   

11,753 

—   

—   

5,301   

—   

—   

5   

—   

—   

—   

—   

4,187   

1   

5,306   

4,188   

4 

— 

5,330 

— 

4,187 

135 

9,656 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 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 asset-backed securities 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 (‘NAV’) 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.

Reconciliation of fair value measurements in Level 3 of the fair value hierarchy

Movement in Level 3 financial instruments

Assets

Liabilities

Designated 
and otherwise 
mandatorily 
measured at 
fair value 
through profit 
or loss

Derivatives

Trading 
liabilities

Designated 
at fair value

Derivatives

$m

$m

2,499   

(378)   

11,477   

1,753   

2,670   

2,237   

$m

162   

16   

$m

5,306   

(836)   

$m

4,188 

2,583 

Trading 
assets

$m

Financial 
investments

$m

3,654   

(10)   

—   

(378)   

—   

2,237   

16   

—   

2,583 

At 1 Jan 2021

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

—   

—   

1,753   

–  gains less losses from financial investments at fair value 

through other comprehensive income

(10)   

—   

—   

Total gains/(losses) 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 2021

(521)   

(428)   

(93)   

(18)   

—   

(18)   

1,025   

1,988   

—   

(580)   

(336)   

(383)   

540   

—   

(473)   

(747)   

(1,027)   

818   

(285)   

—   

(285)   

3,692   

—   

(1,216)   

(1,049)   

(184)   

50   

—   

—   

(27)   

—   

(27)   

—   

—   

—   

—   

(836)   

—   

(8)   

—   

(8)   

1,014   

35   

(4)   

—   

(61)   

—   

(61)   

1   

5,969   

(27)   

— 

— 

(26) 

— 

(26) 

— 

— 

— 

(2,347)   

(681)   

(2,922)   

(3,962) 

(418)   

363   

(7)   

258   

785   

(704)   

1,154   

7,880   

(734) 

1,039 

3,088 

3,389   

2,662   

14,238   

2,478   

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 

—   

(309)   

1,509   

1,298   

—   

166   

(969) 

—   

(309)   

—   

1,298   

—   

—   

(969) 

mandatorily measured at fair value through profit or loss

—   

—   

1,509   

—   

—   

166   

— 

HSBC Holdings plc Annual Report and Accounts 2021 347

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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

$m

9,476   

504   

$m

2,136   

2,281   

$m

53   

307   

$m

5,016   

(59)   

$m

2,302 

3,398 

—   

2,281   

307   

—   

3,398 

At 1 Jan 2020

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

Total gains/(losses) 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

$m

3,218   

17   

—   

—   

17   

394   

270   

124   

671   

—   

(674)   

(530)   
(101)   

659   

3,654   

—   

—   

—   

$m

4,979   

(6)   

(6)   

—   

—   

115   

—   

115   

687   

—   

(1,579)   

(1,122)   
(1,790)   

1,215   

2,499   

504   

—   

286   

—   

286   

3,701   

1   

(2,042)   

(435)   
(140)   

126   

11,477   

—   

—   

143   

—   

143   

—   

—   

—   

(1,542)   
(565)   

217   

2,670   

(32)   

412   

707   

(32)   

—   

707   

—   

—   

17   

—   

17   

66   

6   

(260)   

(26)   
(9)   

8   

162   

1   

1   

(59)   

—   

204   

—   

204   

—   

1,876   

—   

(1,531)   
(777)   

577   

5,306   

— 

— 

169 

— 

169 

— 

— 

— 

(1,462) 
(528) 

309 

4,188 

(91)   

(1,621) 

—   

(1,621) 

—   

412   

—   

—   

(91)   

— 

1 

Included in ‘financial investments: fair value gains/(losses)’ in the current year and ‘exchange differences’ in the consolidated statement of 
comprehensive income.

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

2021

2020

Favourable
changes

Un-
favourable
changes

Favourable
changes

Un-
favourable
changes

Favourable
changes

$m

$m

$m

$m

$m

Un-
favourable
changes

$m

Favourable
changes

$m

143   

(146)   

—   

—   

229   

(244)   

—   

849   

20   

(868)   

(20)   

1,012   

(1,034)   

—   

113   

113   

—   

(112)   

(112)   

644   

35   

908   

(643)   

(35)   

(922)   

—   

110   

110   

Un-
favourable
changes

$m

— 

— 

(110) 

(110) 

Derivatives, trading assets and trading 
liabilities1 

Financial assets and liabilities designated and 
otherwise mandatorily measured at fair value 
through profit or loss

Financial investments

At 31 Dec

1 

‘Derivatives, trading assets and trading liabilities’ are presented as one category to reflect the manner in which these instruments are risk-
managed. 

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.

348 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 
2021.

Quantitative information about significant unobservable inputs in Level 3 valuations 

Fair value

Private equity including strategic 
investments 

  14,278   

9  See below

See below

Asset-backed securities 

  1,141   

— 

Assets Liabilities Valuation

$m

$m

techniques

Key unobservable
inputs

2021

Full range
of inputs

2020

Full range
of inputs

Lower Higher

Lower

Higher

–  collateralised loan/debt obligation

20  

— 

Market proxy 

Prepayment rate  

  1,121   

Market proxy 
—  Market proxy

Bid quotes 

Bid quotes

—

0

0

—

100

100

–  other ABSs 

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 

–  repurchase agreements
–  other1

At 31 Dec 2021

0%

0

0

6%

(4)%

0%

9%

100

101

115%

88%

36%

—    7,879 

—    6,565 

—   

—   

—   

Model – Option model 

Equity volatility 

6% 124%

Model – Option model 
629  Model – Option model 
685 

Equity correlation 

FX volatility 

22%

1%

99%

99%

—  Model – Discounted cash flow Credit spread 

—

—

2%

2%

  2,478    3,088   

797   

284   

36   

477   

379   

212   

167   

990   

595  Model – Discounted cash flow Prepayment rate 

73  Model – Option model 

IR volatility 

5%

15%

10%

35%

6%

6%

6%

28%

322 

403 

270  Model – Option model 

FX volatility

1%

99%

0%

43%

133 

  1,143    1,513 

590   

553   

159   

159   

  4,870   

895  Model – Option model 

Equity volatility

4% 138%

0%

120%

618 

182 

182 

777 

778   

—  Model – Discounted cash flow IR curve

1%

5%

0%

5%

  4,092   

777 

  22,767    11,753 

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. The key unobservable inputs would be price and correlation. The valuation approach includes using a range of inputs that include 
company specific financials, traded comparable companies multiples, published net asset values and qualitative assumptions, which are 
not directly comparable or quantifiable.

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.

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.

HSBC Holdings plc Annual Report and Accounts 2021 349

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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

2021

$m

2020

$m

2,811   

51,408   

32,418   

1,220   

4,698 

65,253 

25,664 

3,060 

At 31 Dec 2021

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 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

Carrying
amount

$m

83,136   

1,045,814   

241,648   

97,302   

101,152   

1,710,574   

126,670   

78,557   

20,487   

81,616   

1,037,987   

230,628   

88,639   

82,080   

1,642,780   

111,901   

95,492   

21,951   

Fair value

Quoted market
price Level 1

Observable
inputs Level 2

Significant
unobservable
inputs Level 3

$m

$m

$m

Total

$m

—   

—   

—   

38,722   

—   

—   

—   

—   

—   

—   

—   

—   

28,722   

—   

—   

3   

—   

—   

82,220   

10,287   

241,531   

63,022   

101,149   

1,710,733   

126,670   

78,754   

26,206   

80,457   

9,888   

230,330   

67,572   

81,996   

1,642,988   

111,898   

96,371   

28,552   

1,073   

83,293 

1,034,288   

1,044,575 

121   

523   

—   

—   

—   

489   

—   

1,339   

1,025,573   

272   

507   

—   

143   

—   

657   

—   

241,652 

102,267 

101,149 

1,710,733 

126,670 

79,243 

26,206 

81,796 

1,035,461 

230,602 

96,801 

81,996 

1,643,131 

111,901 

97,028 

28,552 

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.

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 

350 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

2021

2020

Carrying amount

Fair value1

Carrying amount

Fair value1

$m

$m

$m

$m

25,108   

26,194   

111   

67,483   

17,059   

25,671   

26,176   

111   

69,719   

21,066   

10,443   

17,485   

330   

64,029   

17,916   

10,702 

17,521 

330 

67,706 

22,431 

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

2021

Designated at 
fair value

Mandatorily 
measured at fair 
value

$m

2,251   

599   

1,652   

—   
—   

—   

2,251   

$m

42,062   

31   

5,177   

36,854   
4,307   

1,184   

47,553   

Designated at fair 
value

2020

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   

Total

$m

44,313   

630   

6,829   

36,854   
4,307   
1,184   

49,804   

Total

$m

41,580 

661 

7,107 

33,812 

2,988 

985 

45,553 

HSBC Holdings plc Annual Report and Accounts 2021 351

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

15 Derivatives

Notional contract amounts and fair values of derivatives by product contract type held by HSBC

Foreign exchange 

Interest rate 

Equities 

Credit 

Commodity and other 

Notional contract amount

Fair value – Assets

Trading

Hedging

Trading

Hedging

$m

$m

$m

7,723,034   

43,839   

79,801   

  14,470,539   

162,921   

151,631   

659,142   

190,724   

74,159   

—   

—   

—   

12,637   

2,175   

1,205   

$m

1,062   

1,749   

—   

—   

—   

Total

$m

$m

80,863   

77,670   

153,380   

146,808   

12,637   

14,379   

2,175   

1,205   

3,151   

1,261   

Fair value – Liabilities

Trading

Hedging

$m

207   

966   

—   

—   

—   

Total

$m

77,877 

147,774 

14,379 

3,151 

1,261 

Gross total fair values

  23,117,598   

206,760   

247,449   

2,811   

250,260   

243,269   

1,173   

244,442 

Offset (Note 30)

At 31 Dec 2021

Foreign exchange 

Interest rate 

Equities 

Credit 

Commodity and other 

Gross total fair values

Offset (Note 30)

At 31 Dec 2020

  23,117,598   

206,760   

247,449   

2,811   

196,882   

243,269   

1,173   

191,064 

(53,378) 

(53,378) 

7,606,446   

35,021   

15,240,867   

157,436   

652,288   

269,401   

120,259   

—   

—   

—   

106,696   

249,204   

14,043   

2,590   

2,073   

309   

1,914   

—   

—   

—   

107,005   

251,118   

14,043   

2,590   

2,073   

108,903   

236,594   

15,766   

3,682   

3,090   

1,182   

2,887   

—   

—   

—   

23,889,261   

192,457   

374,606   

2,223   

376,829   

368,035   

4,069   

(69,103) 

23,889,261   

192,457   

374,606   

2,223   

307,726   

368,035   

4,069   

110,085 

239,481 

15,766 

3,682 

3,090 

372,104 

(69,103) 

303,001 

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 decreased during 2021, 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

36,703   

35,970   

72,673   

23,413   

47,569   

70,982   

$m

—   

45,358   

45,358   

—   

34,006   

34,006   

$m

384   

712   

1,096   

506   

966   

1,472   

$m

—   

1,715   

1,715   

—   

3,221   

3,221   

Total

$m

384   

2,427   

2,811   

506   

4,187   

4,693   

Liabilities

Trading

Hedging

$m

377   

769   

1,146   

870   

2,176   

3,046   

$m

—   

74   

74   

—   

8   

8   

Total

$m

377 

843 

1,220 

870 

2,184 

3,054 

Foreign exchange 

Interest rate 

At 31 Dec 2021

Foreign exchange 

Interest rate 

At 31 Dec 2020

Use of derivatives

For details regarding the use of derivatives, see page 207 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.

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 Dec1

1 This amount is yet to be recognised in the consolidated income statement. 

352 HSBC Holdings plc Annual Report and Accounts 2021

2021

$m

104   

311   

(308)   

(177)   

(4)   

(127)   

(1)   

—   

106   

2020

$m

73 

232 

(205) 

(116) 

(4) 

(85) 

4 

— 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Hedge accounting derivatives

HSBC applies hedge accounting to manage the following risks: interest rate and foreign exchange risks. 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

Hedging instrument

Carrying amount

Hedged risk
Interest rate3
At 31 Dec 2021

Interest rate3
At 31 Dec 2020

Notional amount1

$m

90,556   

90,556   

121,573   

121,573   

Assets

$m

1,637   

1,637   

1,675   

1,675   

Liabilities

$m

1,410 

1,410 

3,761 

3,761 

Balance sheet 
presentation

Derivatives  

Derivatives  

Change in fair value2

$m

1,330 

1,330 

(1,894) 

(1,894) 

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, which uses 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

68,059 

1,199 

2 

3,066 

14,428 

86 

(3) 

9 

At 31 Dec 2021

71,127   

14,514   

1,205   

Financial assets designated 
and otherwise mandatorily 
measured at fair value 
through other 
comprehensive income  

Loans and advances to 

banks  

Loans and advances to 

customers  
Debt securities in issue  
Deposits by banks  

992 

1 

993 

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

(36) 

(1,932) 

(3) 

(41) 

609 
1 

(1,366)   

(36) 

Interest rate3

102,260 

6 

2,280 

3,392 

3 

56 

12,148 

89 

1,620 

3 

Financial assets designated and 
otherwise mandatorily 
measured at fair value through 

other comprehensive income  
Loans and advances to banks  

Loans and advances to 

customers  
Debt securities in issue  
Deposits by banks  

2,456 

1 

21 

(613) 

18 

(11) 

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) 

1 Used in effectiveness testing, which comprise an 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 $1,061m for FVOCI assets and assets of $15m for debt issued.

3 The hedged risk ‘interest rate’ includes inflation risk.

HSBC Holdings plc Annual Report and Accounts 2021 353

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings hedging instrument by hedged risk

Hedged risk
Interest rate3
At 31 Dec 2021

Interest rate3
At 31 Dec 2020

Notional amount1,4

$m

45,358   

45,358   

34,006   

34,006   

Hedging instrument

Carrying amount

Assets

$m

1,715   

1,715   

3,221   

3,221   

Liabilities

$m

74 

74 

8 

8 

Balance sheet 
presentation

Derivatives  

Derivatives  

Change in fair value2

$m

(1,515) 

(1,515) 

1,927 

1,927 

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 $45,358m, of which the weighted-average maturity date is January 2028 and the 

weighted-average swap rate is 1.30%. 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

Change in fair 
value1

Recognised in
profit and loss

$m

$m

Balance sheet 
presentation

Debt 
securities

Ineffectiveness

Profit and loss
presentation

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

Interest rate3

39,154 

1,408 

in issue  

1,599   

(21) 

At 31 Dec 2021

7,863   

39,154   

7,863 

(104) 

(104)   

1,408 

(104) 

1,495   

(21) 

Loans and 
Advances to 

banks  

Debt securities

Interest rate3

37,338 

3,027 

in issue  

(1,910)   

Loans and 
Advances to 
banks

17  Net income from financial 
instruments held for 
trading or managed on a 
fair value basis

At 31 Dec 2020

—   

37,338   

—   

3,027 

(1,910)   

17 

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 $54.4m 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.

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.

354 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Hedging instrument by hedged risk

Hedging instrument

Hedged item

Ineffectiveness

Hedged risk

Carrying amount

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

Foreign currency

17,930   

827   

207 

Derivatives  

987   

987   

Interest rate

At 31 Dec 2021

72,365   

90,295   

112   

939   

217 

424 

Derivatives  

(519)   

468   

(500)   

487   

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)   

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

$m

— 

(19) 

(19) 

— 

5 

5 

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 2021

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 2021

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

Net investment hedges

Interest rate Foreign currency

$m

495   

(500)   

(217)   

185   

45   

8   

204   

514   

(107)   

(79)   

(37)   

495   

$m

(37) 

987 

(1,177) 

25 

(3) 

(205) 

(205) 

(630) 

822 

(23) 

(1) 

(37) 

The Group applies hedge accounting in respect of certain net investments in non-US dollar functional currency foreign operations for 
changes in spot exchange rates only. Hedging could be undertaken for Group structural exposure to changes in the US dollar to foreign 
currency exchange rates using forward foreign exchange contracts or by financing with foreign currency borrowings. The aggregate 
positions at the reporting date and the performance indicators of both live and de-designated hedges are summarised below. There were 
no amounts reclassified to the profit and loss account during the accounting periods presented.

Hedges of net investment in foreign operations

Description of hedged risk

2021

Pound sterling-denominated structural foreign exchange

Swiss franc-denominated structural foreign exchange

Hong Kong dollar-denominated structural foreign exchange  
Other structural foreign exchange1
Total

2020

Pound sterling-denominated structural foreign exchange

Swiss franc-denominated structural foreign exchange

Hong Kong dollar-denominated structural foreign exchange  
Other structural foreign exchange1
Total

Carrying value

Derivative
 assets

$m

Derivative 
liabilities

$m

Nominal
 amount

Amounts 
recognised in OCI

Hedge ineffectiveness 
recognised in income 
statement

$m

$m

$m

229   

—   

7   

7   

243   

—   

—   

—   

—   

—   

—   

(8)   

—   

—   

(8)   

733   

—   

—   

—   

733   

15,717   

809   

4,992   

4,387   

25,905   

10,500   

—   

—   

—   

10,500   

(126)   

101   

5   

6   

(14)   

(167)   

111   

—   

—   

(56)   

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

 1   Other currencies include New Taiwan dollar, Singapore dollar, Canadian dollar, Omani rial, South Korean won and United Arab Emirates dirham.

HSBC Holdings plc Annual Report and Accounts 2021 355

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Interest rate benchmark reform: Amendments to IFRS 9 and IAS 39 ‘Financial Instruments’

HSBC has applied both the first set of amendments (‘Phase 1’) and the second set of amendments (‘Phase 2’) to IFRS 9 and IAS 39 
applicable to hedge accounting. 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 value of the derivatives 
impacted by the Ibor reform, including those designated in hedge accounting relationships, is disclosed on page 127 in the section 
‘Financial instruments impacted by the Ibor reform’. For further details on Ibor transition, see 'Top and emerging risks' on page 126.

During 2021, the Group transitioned all of its hedging instruments referencing sterling Libor, European Overnight Index Average rate 
(‘Eonia’) and Japanese yen Libor. The Group also transitioned some of the hedging instruments referencing US dollar Libor. There is no 
significant judgement applied for these benchmarks to determine whether and when the transition uncertainty has been resolved.

The most significant Ibor benchmark in which the Group continues to have hedging instruments is US dollar Libor. It is expected that the 
transition out of US dollar Libor hedging derivatives will be largely completed by the end of 2022. These transitions do not necessitate 
new approaches compared with any of the mechanisms used so far for transition and it will not be necessary to change the transition risk 
management strategy. 

For some of the Ibors included under the ‘Other’ header in the table below, judgement has been needed to establish whether a transition 
is required, since there are Ibor benchmarks that are subject to computation methodology improvements and insertion of fallback 
provisions without full clarity being provided by their administrators on whether these Ibor benchmarks will be demised.

The notional amounts of interest rate derivatives designated in hedge accounting relationships do not represent the extent of the risk 
exposure managed by the Group but they are expected to be directly affected by market-wide Ibor reform and in scope of Phase 1 
amendments and are shown in the table below. 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 2021

Fair value hedges

Cash flow hedges

At 31 Dec 2020

€2

$m

6,178   

7,954   

14,132   

17,792   

8,344   

26,136   

Impacted by Ibor reform

Hedging instrument

£

$m

—   

—   

—   

3,706   

2,522   

6,228   

$

$m

18,525   

100   

Other3

$m

6,615   

8,632   

18,625   

15,247   

32,789   

8,705   

41,494   

10,128   

6,797   

16,925   

Total

$m

31,318   

16,686   

48,004   

64,415   

26,368   

90,783   

Not impacted 
by Ibor reform

$m

59,238   

55,679   

Notional
amount1

$m

90,556 

72,365 

114,917   

162,921 

57,157   

9,495   

66,652   

121,572 

35,863 

157,435 

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 and they do not represent amounts at risk.

2 The notional contract amounts of euro interest rate derivatives impacted by Ibor reform mainly comprise hedges with a Euribor benchmark, which 

are ‘Fair value hedges’ of $6,178m (31 December 2020: $6,000m) and ‘Cash flow hedges’ of $7,954m (31 December 2020: $8,344m).

3 Other benchmarks impacted by Ibor reform comprise mainly of Canadian dollar offered rate (‘CDOR’), Hong Kong interbank offered rate (‘HIBOR’) 

and Mexican interbank equilibrium interest rate (‘TIIE’) related derivatives.

Hedging instrument impacted by Ibor reform held by HSBC Holdings

Hedging instrument

Impacted by Ibor reform

£

$m

—   

—   

$

$m

20,035   

20,035   

5,393   

5,393   

21,081   

21,081   

Other

$m

1,458   

1,458   

3,242   

3,242   

Total

$m

31,437   

31,437   

34,006   

34,006   

Not impacted 
by Ibor reform

$m

13,921   

13,921   

Notional 
amount

$m

45,358 

45,358 

—   

—   

34,006 

34,006 

€

$m

9,944   

9,944   

4,290   

4,290   

Fair value hedges

At 31 Dec 2021

Fair value hedges

At 31 Dec 2020

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

356 HSBC Holdings plc Annual Report and Accounts 2021

2021

$m

348,972   

100,158   

246,998   

1,770   

46   

97,302   

21,634   

75,668   

2020

$m

402,054 

118,163 

281,467 

2,337 

87 

88,639 

11,757 

76,882 

446,274   

490,693 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021

Investments required by central institutions

Business facilitation

Others

At 31 Dec 2020

Weighted average yields of investment debt securities

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 

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 

Fair value

Dividends 
recognised

$m

766   

954   

50   

1,770   

904   

1,387   

46   

2,337   

$m

17 

24 

3 

44 

22 

22 

3 

47 

Up to 1
 year

Yield

%

1 to 5 
years

Yield

%

5 to 10 
years

Over 10 
years

Yield

%

Yield

%

 1.2 

 0.2 

 1.0 

 2.5 

 0.4 

 2.0 

 9.3 

 2.3 

 0.7 

 3.8 

 2.7 

 2.0 

 3.0 

 — 

 3.4 

 1.5 

 1.2 

 1.6 

 0.5 

 0.9 

 2.5 

 0.7 

 1.3 

 1.3 

 8.2 

 2.8 

 3.8 

 3.9 

 — 

 3.3 

 1.3 

 2.8 

 2.3 

 0.7 

 2.2 

 2.2 

 1.1 

 2.4 

 5.9 

 5.4 

 2.3 

 2.1 

 3.3 

 — 

 3.7 

 2.1 

 1.9 

 1.6 

 2.6 

 — 

 3.7 

 0.5 

 3.1 

 2.9 

 2.5 

 3.3 

 4.8 

 3.9 

 7.5 

 3.3 

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 2021 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

Weighted average yields of investment debt securities

Debt securities measured at amortised cost

US Treasury 

2021

$m

2020

$m

19,508   

6,686   

26,194   

10,941 

6,544 

17,485 

Up to 1
 year

Yield

%

1 to 5 
years

Yield

%

5 to 10 
years

Yield

%

Over 10 
years

Yield

%

 0.3 

 0.3 

 — 

 — 

The weighted average yield for each range of maturities is calculated by dividing the annualised interest income for the year ended 
31 December 2021 by the book amount of debt securities at that date. The yields do not include the effect of related derivatives.

HSBC Holdings plc Annual Report and Accounts 2021 357

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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

2021

$m

2020

$m

9,613   

12,774 

412   

55,370   

66,629   

34,472   

45,396   

236 

43,168 

67,312 

26,101 

60,810 

211,892   

210,401 

Assets pledged as collateral include all assets categorised as encumbered in the disclosure on page 79 of the Pillar 3 Disclosures at 31 December 2021.

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

2021

$m

69,719   

12,416   

82,135   

2020

$m

64,225 

16,915 

81,140 

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 $476,455m 
(2020: $447,101m). The fair value of any such collateral sold or repledged was $271,582m (2020: $246,520m).

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 2021

Repurchase agreements

Securities lending agreements

Other sales (recourse to transferred assets only)

At 31 Dec 2020

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

51,135   

43,644   

3,826   

52,413   

38,364   

3,564   

48,180 

2,918 

3,826   

3,830   

3,842   

(12) 

51,092 

124 

3,478   

3,619   

3,564   

55 

358 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

2021

$m

29,515   

94   

29,609   

2020

$m
26,594 

90 

26,684 

2021

Carrying amount

$m

23,616   

4,426   

Fair value1
$m

8,537   

5,599   

2020

Carrying amount

Fair value1

$m

21,248   

4,215   

$m

7,457 

4,197 

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

A list of all associates and joint ventures is set out in Note 38. 

Bank of Communications Co., Limited 

Country of incorporation
and principal place of
business

People’s Republic of 
China

At 31 Dec 2021

Principal
activity

Banking services

Saudi Arabia

Banking services

HSBC’s
interest
%

 19.03 

 31.00 

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 agreement (‘RES’). 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 2021, the fair value of the Group’s investment in BoCom had been below the carrying amount for approximately 10 
years. As a result, the Group performed an impairment test on the carrying amount, which confirmed that there was no impairment at 
31 December 2021 as the recoverable amount as determined by a value-in-use (‘VIU’) calculation was higher than the carrying value. 

BoCom

At 31 Dec 2021

VIU

$bn

24.8   

Carrying value

Fair value

$bn

23.6   

$bn

8.5   

VIU

$bn

21.8   

At 31 Dec 2020

Carrying value

Fair value

$bn

21.2   

$bn

7.5 

Compared with 31 December 2020, the extent to which the VIU exceeds the carrying value (‘headroom’) increased by $0.6bn. The 
increase in headroom was principally due to the impact on the VIU from BoCom's actual performance, which was better than earlier 
estimates, 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.

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 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. Reflecting management's intent to continue to 
retain its investment, 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 that need to be withheld in order for BoCom to meet 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 capital requirements. An increase in the CMC as a result of a change to these principal inputs would reduce VIU. 
Additionally, management considers other qualitative factors, to ensure that the inputs to the VIU calculation remain appropriate.

HSBC Holdings plc Annual Report and Accounts 2021 359

Financial statements 
 
 
 
 
 
 
 
Notes on the financial statements

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% (2020: 3%) for periods after 2025, which does not exceed forecast GDP growth in mainland China 

and is consistent with forecasts by external analysts.

• Long-term asset growth rate: 3% (2020: 3%) for periods after 2025, which is the rate that assets are expected to grow to achieve long-

term profit growth of 3%.

• Discount rate: 10.03% (2020: 11.37%) based on a capital asset pricing model (‘CAPM’), using market data. The discount rate used is 

within the range of 8.7% to 10.1% (2020 equivalent range: 10.9% to 11.9%) indicated by the CAPM. The lower rate reflects the impact 
of a relative reduction in the volatility of Chinese banks’ equity prices and a decrease in mainland China’s credit risk due to its relatively 
quick recovery from the impact of the Covid-19 outbreak. While the CAPM range sits at the lower end of the range adopted by selected 
external analysts of 9.9% to 13.5% (2020: 10.3% to 15.0%), we continue to regard the CAPM range as the most appropriate basis for 
determining this assumption.

• Expected credit losses as a percentage of customer advances (‘ECL’): ranges from 0.98% to 1.12% (2020: 0.98% to 1.22%) in the short 

to medium term, reflecting reported credit experience through the ongoing Covid-19 pandemic in mainland China followed by an 
expected reversion to recent historical levels. For periods after 2025, the ratio is 0.97% (2020: 0.88%), which is higher than BoCom’s 
average ECL in recent years prior to the Covid-19 outbreak.

• Risk-weighted assets as a percentage of total assets: ranges from 61.0% to 62.4% (2020: 61.0% to 62.0%) in the short to medium 
term, reflecting reductions that may arise from a subsequent lowering of ECL and a continuation of the trend of strong retail loan 
growth. For periods after 2025, the ratio is 61.0% (2020: 61.0%). These rates are similar to BoCom’s actual results in recent years and 
forecasts disclosed by external analysts.

• Operating income growth rate: ranges from 5.1% to 6.2% (2020: 3.5% to 6.7%) 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 BoCom’s most recent actual results, 
global trade tensions and industry developments in mainland China.

• Cost-income ratio: ranges from 35.5% to 36.1% (2020: 36.3% to 36.8%) in the short to medium term. These ratios are similar to 

BoCom's actual results in recent years and forecasts disclosed by external analysts.

• Effective tax rate (‘ETR’): ranges from 6.8% to 15.0% (2020: 7.8% to 16.5%) 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 2025, the rate is 
15.0% (2020: 16.8%), which is higher than the recent historical average, and aligned to the minimum tax rate as proposed by the 
OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting.

• Capital requirements: capital adequacy ratio ('CAR') of 12.5% (2020: 11.5%) and tier 1 capital adequacy ratio of 9.5% (2020: 9.5%), 

based on BoCom’s capital risk appetite and capital requirements respectively. The CAR assumption was updated to 12.5% from 11.5% 
following the approval of BoCom's capital management plan in March 2021.

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 28 basis points

• Increase by 23 basis points

• Increase by 36 basis points

• Expected credit losses as a percentage of customer advances

• Increase by 4 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 194 basis points

• Decrease by 39 basis points

• Increase by 109 basis points

• Increase by 322 basis points

• Increase by 40 basis points

• Increase by 195 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.

360 HSBC Holdings plc Annual Report and Accounts 2021

 
Sensitivity of VIU to reasonably possible changes in key assumptions

At 31 Dec 2021
Long-term profit growth rate1
Long-term asset growth rate1
Discount rate2
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 2020
Long-term profit growth rate1
Long-term asset growth rate1
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

Favourable change

Unfavourable change

Increase in VIU

bps

$bn

VIU

$bn

Decrease in VIU

bps

$bn

VIU

$bn

87   

(69)   

(133)   

4.2    29.0   

2.9    27.7   

5.4    30.2   

(69)   

87   

207   

2021 to 2025: 103
2026 onwards: 91  

1.5    26.3 

2021 to 2025: 121
2026 onwards: 105  

(111)   

37   

(152)   

(104)   

—   

—   

—   

(50)   

(47)   

2020 to 2024: 96
2025 onwards: 76  

(40)   

2   

(149)   

(316)   

—   

—   

0.2    25.0   

1.0    25.8   

1.7    26.5   

0.3    25.1   

—    24.8   

—    24.8   

—   

21.8   

1.4   

1.2   

23.2   

23.0   

2.3   

24.1 

0.1   

0.2   

1.3   

0.9   

—   

—   

21.9   

22.0   

23.1   

22.7   

21.8   

21.8   

280   

(58)   

174   

1,000   

325   

364   

(50)   

—   

53   

2020 to 2024: 122
2025 onwards: 95  

166   

(69)   

120   

820   

297   

263   

(2.7)    22.1 

(4.7)    20.1 

(5.3)    19.5 

(2.7)    22.1 

(2.1)    22.7 

(1.8)    23.0 

(1.7)    23.1 

(3.6)    21.2 

(10.0)    14.8 

(6.5)    18.3 

(1.3)   

—   

(1.2)   

20.5 

21.8 

20.6 

(2.1)   

19.7 

(0.8)   

(1.5)   

(1.2)   

(2.2)   

(7.8)   

(5.3)   

21.0 

20.3 

20.6 

19.6 

14.0 

16.5 

1   The reasonably possible ranges of the long-term profit growth rate and long-term asset growth rate assumptions reflect the close relationship 

between these assumptions, which would result in offsetting changes to each assumption.

2   The unfavourable change in the reasonably possible ranges of the discount rate assumption reflects the impact of adopting the average of the rates 

adopted by selected external analysts.

Considering the interrelationship of the changes set out in the table above, management estimates that the reasonably possible range of 
VIU is $19.0bn to $29.3bn (2020 equivalent range: $17.2bn to $25.7bn). The range is based on impacts set out in the table above arising 
from the favourable/unfavourable change in the earnings in the short to medium term, the long-term expected credit losses as a 
percentage of customer advances, and a 50bps increase/decrease in the discount rate. The discount rate has been included this year, 
reflecting the relative materiality of movements in this assumption. All other long-term assumptions 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 2021, HSBC included the associate’s 
results on the basis of the financial statements for the 12 months ended 30 September 2021, taking into account changes in the 
subsequent period from 1 October 2021 to 31 December 2021 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

2021

$m

123,194   

98,932   

993,956   

541,577   

47,679   

2020

$m

121,987 

107,334 

870,728 

508,328 

44,622 

1,805,338   

1,652,999 

287,057   

273,708 

1,099,266   

1,012,732 

228,135   

40,070   

207,110 

31,105 

1,654,528   

1,524,655 

150,810   

128,344 

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 31 Dec

2021

$m

23,097   

519   

23,616   

2020

$m

20,743 

505 

21,248 

HSBC Holdings plc Annual Report and Accounts 2021 361

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

2021

$m

24,582   

7,170   

(9,701)   

(2,297)   

(1,045)   

14,199   

(368)   

13,831   

692   

2020

$m
21,994 

6,398 

(9,698) 

(2,072) 

(858) 

10,261 

(769) 

9,492 

633 

The Group’s investment in The Saudi British Bank (‘SABB’) is classified as an associate. HSBC is the largest shareholder in SABB with a 
shareholding of 31%. 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

There were no indicators of impairment at 31 December 2021. The fair value of the Group’s investment in SABB of $5.6bn was above the 
carrying amount of $4.4bn.

19 Investments in subsidiaries

Main subsidiaries of HSBC Holdings

Place of incorporation 
or registration

HSBC’s 
interest %

Share class

At 31 Dec 2021

Europe

HSBC Bank plc 

HSBC UK Bank plc

HSBC Continental Europe

HSBC Trinkaus & Burkhardt AG

Asia

Hang Seng Bank Limited 

England and Wales

England and Wales

France

Germany

 100 

 100 

 99.99 

 100 

Hong Kong

 62.14 

HSBC Bank (China) Company Limited 

HSBC Bank Malaysia Berhad 

HSBC Life (International) Limited 

The Hongkong and Shanghai Banking Corporation Limited 

Middle East and North Africa

People’s Republic of 
China

Malaysia

Bermuda

Hong Kong

HSBC Bank Middle East Limited 

United Arab Emirates

North America

HSBC Bank Canada 

HSBC Bank USA, N.A. 

Latin America

Canada

US

 100 

 100 

 100 

 100 

 100 

 100 

 100 

£1 Ordinary, $0.01 Non-Cumulative Third Dollar 
Preference

£1 Ordinary

€5 Actions

Stückaktien no par value

HK$5 Ordinary

CNY1 Ordinary

RM0.5 Ordinary

HK$1 Ordinary

Ordinary no par value

$1 Ordinary and $1 Cumulative Redeemable 
Preference shares 

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

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 38. 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 increase in investments in subsidiaries was partly due to the reversal of impairment of HSBC Overseas Holdings (UK) 
Limited of $3.1bn. The cumulative impairment for HSBC Overseas Holdings (UK) Limited as at 31 December 2021 is $7.2bn. It is 
reasonably possible that outcomes in the future may be different from the assumptions made as at December 2021 that could require a 
material change to the carrying amount of HSBC Overseas Holdings (UK) Limited. The carrying value is $33.1bn as at 31 December 2021 
(2020:$30.7bn).

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 2021, 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 

362 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
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 

20 Structured entities

2021

2020

 37.86 %

Hong Kong
$m

708  

7,597  

568  

230,866  

209,315  

4,280  

1,872  

1,686  

37.86%

Hong Kong

$m

843 

7,604 

625 

224,483 

202,907 

4,568 

2,230 

2,535 

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 2021

At 31 Dec 2020

Conduits

Conduits

Securitisations

HSBC
managed funds

$bn

4.4   

6.9   

$bn

10.0   

11.7   

$bn

6.3   

5.3   

Other

$bn

8.4   

10.8   

Total

$bn

29.1 

34.7 

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 2021, Solitaire, HSBC’s principal SIC, held $1.6bn of ABSs (2020: $1.9bn). It is currently funded entirely by commercial 

paper (‘CP’) issued to HSBC. At 31 December 2021, HSBC held $1.8bn of CP (2020: $2.1bn).

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 $6.7bn at 31 December 2021 
(2020: $9.6bn). 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.

HSBC Holdings plc Annual Report and Accounts 2021 363

Financial statements 
 
 
 
Notes on the financial statements

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 2021

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 2021

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 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

96   

11   

—   

—   

—   

107   
$bn

4.8   

—   

—   

4.8   

—   

—   

—   

—   

0.1   

4.9   

86   

9   

—   

—   

—   

95   

$bn

4.4   

—   

—   

4.4   

—   

—   

—   

—   

0.1   
4.5   

294   

116   

33   

14   

4   

461   
$bn

10.8   

0.2   

10.0   

—   

0.6   

—   

—   

—   

0.9   

11.7   

292   

94   

32   

14   

5   

437   

$bn

9.9   

0.3   

8.6   

—   

1   

—   

—   

—   

0.5   
10.4   

1,408   

911   

435   

197   

11   

2,962   
$bn

18.6   

2.4   

15.5   

0.1   

0.6   

—   

—   

—   

4.6   

23.2   

1,430   

733   

389   

311   

41   

2,904   

$bn

17.5   

3.2   

13.8   

—   

0.5   

—   

—   

—   

4.9   
22.4   

37   

3   

—   

—   

—   

40   
$bn

3.8   

0.1   

—   

3.0   

—   

0.7   

0.4   

0.4   

1.2   

4.6   

47   

2   

—   

—   

—   

49   

$bn

2.1   

—   

—   

1.5   

—   

0.6   

0.3   

0.3   

1.2   
3.6   

Total

1,835 

1,041 

468 

211 

15 

3,570 
$bn

38.0 

2.7 

25.5 

7.9 

1.2 

0.7 

0.4 

0.4 

6.8 

44.4 

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 

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 104.

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.

364 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2021 and 2020 were not 
significant.

21 Goodwill and intangible assets

Goodwill

Present value of in-force long-term insurance business
Other intangible assets1
At 31 Dec

2021

$m

5,033   

9,453   

6,136   

2020

$m

5,881 

9,435 

5,127 

20,622   

20,443 

1 Included within other intangible assets is internally generated software with a net carrying value of $5,430m (2020: $4,452m). During the year, 
capitalisation of internally generated software was $2,373m (2020: $1,934m), impairment was $137m (2020: $1,322m) and amortisation was 
$1,183m (2020: $1,085m).

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

2021

$m

2020

$m

23,135   

22,084 

(905)   

(15)   

967 

84 

22,215   

23,135 

(17,254)   

(16,494) 

(587)   

659   

(17,182)   

5,033   

(41) 

(719) 

(17,254) 

5,881 

The Group’s impairment test in respect of goodwill allocated to each cash-generating unit (‘CGU’) is performed at 1 October each year. A 
review for indicators of impairment is undertaken at each subsequent quarter-end and at 31 December 2021. 

As a result of the 1 October 2021 annual impairment test, we recognised $0.6bn of goodwill impairment related to the Latin America – 
WPB CGU. Impairment resulted from a combination of factors, including our macroeconomic outlook and the impact of inflationary 
pressure on judgements made to estimate value in use (‘VIU’). Significant inputs to the VIU calculation are discussed in more detail within 
‘Basis of the recoverable amount’ below. Management considered the sensitivity of certain assumptions, in particular the discount rate, 
and the outcome of reasonably possible alternative scenarios. This resulted in full impairment of goodwill allocated to Latin America – 
WPB.

Impairment results and key assumptions in VIU calculations – impaired CGU at 1 October 2021

Carrying amount

$bn

2.3   

of which 
goodwill

$bn

0.6   

Value in use

Impairment

$bn

1.7   

$bn

0.6 

Discount
rate

%

 14.5 

Growth rate 
beyond initial 
cash flow 
projections

%

 4.8 

Latin America – WPB

Basis of the recoverable amount

The recoverable amount of all CGUs to which goodwill has been allocated was equal to its value in use at each respective testing date. 
The VIU is calculated by discounting management’s cash flow projections for the CGU. 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 2021

Europe – WPB

Goodwill at
1 Oct 2021

$m

3,556 

Discount rate

%

 9.2 

Growth rate
beyond initial
cash flow

%

 1.8   

Goodwill at 
1 Oct 2020

$m

3,582 

Discount
rate

Growth rate 
beyond initial cash 
flow projections

%

 9.6 

%

 1.9 

At 1 October 2021, aggregate goodwill of $2,108m (1 October 2020: $2,059m) 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.

HSBC Holdings plc Annual Report and Accounts 2021 365

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Management’s judgement in estimating the cash flows of a CGU

The cash flow projections for each CGU are based on forecast profitability plans approved by the Board and minimum capital levels 
required to support the business operations of a CGU. 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 including climate risk. For 
the 1 October 2021 impairment test, cash flow projections until the end of 2026 were considered, in line with our internal planning 
horizon. 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.

Discount rate

The rate used to discount the cash flows is based on the cost of equity assigned to each CGU, which is derived using a capital asset 
pricing model (‘CAPM’) and market implied cost of equity. 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 equity 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 1 October 2021, 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 VIU calculation, 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 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 CGU’s carrying amount.

Input

Key assumptions

Associated risks

Reasonably possible change

Cash-generating unit
Europe – WPB

Forecast 
profitability

Discount rate

• Level of interest rates and yield 

• Uncertain regulatory 

• Forecast profitability projections 

curves.

• Competitors’ position within the 

market.

• Level and change in unemployment 

rates.

Discount rate used is a reasonable 
estimate of a suitable market rate for 
the profile of the business.

environment.

• Customer remediation 
and regulatory actions.

decrease by 30%. This does not result in 
an impairment.

• External evidence 

• Discount rate increases by 100bps. This 

suggests that the rate 
used is not appropriate to 
the business.

does not 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 1 October 2021

Carrying amount

VIU

Impact on VIU

100bps increase in the discount rate – single variable

30% decrease in forecast profitability – single variable

Cumulative impact of all changes

Changes to key assumption to reduce headroom to nil – single variable

Discount rate – bps

Profit cash flows – %

Other intangible assets

Impairment testing

Europe – WPB

18.8 

29.8 

(3.7) 

(9.2) 

(11.7) 

 409 

 36 

Impairment of other intangible assets is assessed in accordance with our policy explained in Note 1.2(n) by comparing the net carrying 
amount of CGUs containing intangible assets with their recoverable amounts. Recoverable amounts are determined by calculating an 
estimated VIU or fair value, as appropriate, for each CGU. No significant impairment was recognised during the year.

In 2020, having considered the pervasive macroeconomic deterioration caused by the outbreak of Covid-19, along with the impact of 
forecast profitability in some businesses, 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, 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 

366 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
the plan, and would therefore have recognised a provision for restructuring costs. For some businesses, this means that the benefit of 
certain strategic actions may not be included in the 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 combination of CAPM and market-implied calculations considering market data for the 

businesses and geographies in which the Group operates. 

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 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. 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 31 December 2021 none of the CGUs were 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 VIU calculation, such as the external range of discount rates observable, 
historical performance against forecast and risks attaching to the key assumptions underlying cash flow projections.

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 return1
–  assumption changes and experience variances (see below)

–  other adjustments

Exchange differences and other movements

At 31 Dec

2021

$m

9,435   

130   

1,090   

(903)   

(105)   

48   

(112)   

9,453   

2020

$m

8,945 

382 

776 

(1,003) 

604 

5 

108 

9,435 

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:

• $59m (2020: $132m), directly offsetting interest rate-driven changes to the valuation of liabilities under insurance contracts;

• $(324)m (2020: $247m), 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

• $160m (2020: $225m), 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

2021

2020

Hong Kong

France1

Hong Kong

France1

%

 1.40 

 5.20 

 3.00 

%

 0.69 

 1.55 

 1.80 

%

 0.71 

 4.96 

 3.00 

%

 0.34 

 1.34 

 1.60 

1 For 2021, the calculation of France’s PVIF assumes a risk discount rate of 1.55% (2020: 1.34%) plus a risk margin of $215m (2020: $213m).

HSBC Holdings plc Annual Report and Accounts 2021 367

Financial statements 
 
 
 
 
 
 
 
Notes on the financial statements

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 214.

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 216.

22 Prepayments, accrued income and other assets

Prepayments and accrued income

Settlement accounts

Cash collateral and margin receivables
Assets held for sale1
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

2021

$m

8,233   

17,713   

42,171   

3,411   

15,283   

11,229   

3,668   

10,269   

2,985   

10,255   

14,765   

2020

$m

8,114 

17,316 

59,543 

299 

20,151 

10,278 

3,448 

10,450 

4,002 

10,412 

12,399 

139,982   

156,412 

1   ‘Assets held for sale’ includes $2.6bn of loans and advances to customers that were classified as assets held for sale, reflecting our exit of mass 

market retail banking in the US.

Prepayments, accrued income and other assets include $91,045m (2020: $105,469m) of financial assets, the majority of which are 
measured at amortised cost.

23 Trading liabilities

Deposits by banks1
Customer accounts1
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 accounts1
Liabilities to customers under investment contracts

Debt securities in issue (Note 25)

Subordinated liabilities (Note 28)

At 31 Dec

2021

$m

4,243   

9,424   

1,792   

69,445   

84,904   

2020

$m

6,689 

10,681 

1,582 

56,314 

75,266 

2021

$m

16,703   

5,938   

2020

$m

19,176 

6,385 

112,761   

121,034 

10,100   

10,844 

145,502   

157,439 

1  Structured deposits placed at HSBC Bank USA are insured by the Federal Deposit Insurance Corporation, a US government agency, up to 

$250,000 per depositor.

The carrying amount of financial liabilities designated at fair value was $827m more than the contractual amount at maturity. The 
cumulative amount of change in fair value attributable to changes in credit risk was a loss of $2,084m (2020: loss of $2,542m). 

HSBC Holdings

Debt securities in issue (Note 25)

Subordinated liabilities (Note 28)

At 31 Dec

368 HSBC Holdings plc Annual Report and Accounts 2021

2021

$m

26,818   

5,600   

32,418   

2020

$m

19,624 

6,040 

25,664 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The carrying amount of financial liabilities designated at fair value was $1,766m more than the contractual amount at maturity
(2020: $3,019m more). The cumulative amount of change in fair value attributable to changes in credit risk was a loss of $951m 
(2020: $1,210m).

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)
Liabilities of disposal groups held for sale1
Lease liabilities

Other liabilities

At 31 Dec

2021

$m

166,537   

26,573   

193,110   

(1,792)   

(112,761)   

78,557   

2021

$m

94,301   

(26,818)   
67,483   

2021

$m

10,466   

15,226   

50,226   

11,232   

1,607   

9,005   

3,586   

22,430   

123,778   

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 

 1   Includes $8.8bn of customer accounts that were classified as liabilities of disposal groups held for sale, reflecting our exit of mass market retail 

banking in the US.

Accruals, deferred income and other liabilities include $111,887m (2020: $120,229m) of financial liabilities, the majority of which are 
measured at amortised cost.

27 Provisions

Provisions (excluding contractual commitments)

At 1 Jan 2021

Additions

Amounts utilised

Unused amounts reversed

Exchange and other movements

At 31 Dec 2021
Contractual commitments1
At 1 Jan 2021

Net change in expected credit loss provision and other movements

At 31 Dec 2021

Total provisions

At 31 Dec 2020

At 31 Dec 2021

Restructuring
costs

Legal proceedings
and regulatory
matters

Customer
remediation

Other
provisions

$m

$m

$m

$m

671   

347   

(499)   

(170)   

34   

383   

756   

249   

(316)   

(59)   

(11)   

619   

858   

192   

(548)   

(113)   

(3)   

386   

305   

471   

(58)   

(124)   

(36)   

558   

Total

$m

2,590 

1,259 

(1,421) 

(466) 

(16) 

1,946 

1,088 

(468) 

620 

3,678 

2,566 

HSBC Holdings plc Annual Report and Accounts 2021 369

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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

Restructuring
costs

$m

Legal proceedings
and regulatory
matters

Customer
remediation

$m

$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   

Total

$m

2,887 

1,456 

(1,363) 

(469) 

79 

2,590 

511 

577 

1,088 

3,398 

3,678 

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 2021, $173m (2020: $328m) 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 $328m balance at 31 December 2020, 
$192m was utilised during 2021 and the provision was increased by $37m.

At 31 December 2021, a provision of $87m (2020: $302m) was held relating to the estimated liability for redress payable to customers 
following a review of historical collections and recoveries practices in the UK. During 2021, redress payments and incurred operating 
costs totalled $197m, in addition to the net release of $18m of provision. This release reflect the actual number of customers impacted 
and cost of redress paid, which were lower than has been previously estimated.

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 153.

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

2021

$m

20,487   

18,640   

1,847   

10,100   

10,100   

—   

30,587   

9,112   

21,475   

2020

$m

21,951 

20,095 

1,856 

10,844 

10,844 

— 

32,795 

10,223 

22,572 

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 relevant market 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.

370 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC’s subsidiaries subordinated liabilities in issue

Additional tier 1 capital securities guaranteed by HSBC Holdings1
$900m

10.176% non-cumulative step-up perpetual preferred securities, series 22 

Additional tier 1 capital securities guaranteed by HSBC Bank plc1
£700m

5.844% non-cumulative step-up perpetual preferred securities3 

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 notes4
5.375% subordinated notes 

6.25% subordinated notes 

4.75% subordinated notes 

First call date Maturity date

Jun 2030

Nov 2031

Jun 1990

Sep 1990

Jun 1992

— 

May 2025  

— 

Jul 2023  

Nov 2025

Nov 2030  

— 

— 

— 

Aug 2033  

Jan 2041  

Mar 2046  

Tier 2 securities issued by The Hongkong and Shanghai Banking Corporation Limited

$400m

Primary capital undated floating rate notes (third series)

Jul 1991

Tier 2 securities issued by HSBC Bank Malaysia Berhad

MYR500m

5.05% subordinated bonds5,6

Tier 2 securities issued by HSBC USA Inc.

$250m

7.20% subordinated debentures5 
Other subordinated liabilities each less than $150m7

Tier 2 securities issued by HSBC Bank USA, N.A.

$1,000m

$750m

$700m

5.875% subordinated notes8
5.625% subordinated notes8
7.00% subordinated notes 

Tier 2 securities issued by HSBC Finance Corporation

$2,939m

6.676% senior subordinated notes5,9

Tier 2 securities issued by HSBC Bank Canada

Nov 2022

Nov 2027  

— 

Jul 2097  

— 

— 

— 

Nov 2034  

Aug 2035  

Jan 2039  

— 

Jan 2021  

Other subordinated liabilities each less than $150m5

Oct 1996

Nov 2083  

Securities issued by other HSBC subsidiaries
Other subordinated liabilities each less than $200m10
Subordinated liabilities issued by HSBC subsidiaries at 31 Dec

2021

$m

900   

900   

947   

947   

750   

500   

300   

300   

2020

$m

900 

900 

956 

956 

750 

500 

300 

300 

1,850   

1,850 

406   

539   

900   

303   

805   

2,953   

4,803   

400   

400   

120   

120   

222   

—   

222   

456   

489   

697   

409 

583 

981 

306 

812 

3,091 

4,941 

400 

400 

124 

124 

222 

200 

422 

497 

533 

700 

1,642   

1,730 

—   
—   

9   

9   

509 
509 

9 

9 

69   

232 

9,112   

10,223 

1 See paragraph below, ‘Guaranteed by HSBC Holdings or HSBC Bank plc’.
2 The interest rate payable after June 2030 is the sum of the three-month Libor plus 4.98%.
3   The interest rate payable after November 2031 is the sum of the compounded daily Sonia rate plus 2.0366%.
4  The interest rate payable after November 2025 is the sum of the compounded daily Sonia rate plus 1.6193%.
5  These securities are ineligible for inclusion in the capital base of HSBC.
6  The interest rate payable after November 2022 is 6.05%.
7  These securities matured in 2021 and were redeemed.
8   HSBC tendered for these securities in November 2019. The principal balance is $357m and $383m respectively. The original notional values of 

these securities are $1,000m and $750m respectively.

9  HSBC tendered for these securities in 2017. In January 2018, a further tender was conducted. The principal balance is $509m. The original 

notional of these securities is $2,939m. This instrument matured and settled in January 2021. 

10 These securities are included in the capital base of HSBC, in accordance with the grandfathering provisions under CRR II. In 2021, securities of 

$49m matured and were redeemed, and in addition approximately $109m were redeemed in June 2021 in relation to securities that matured at 
31 December 2020. The latter were no longer eligible for inclusion in the capital base of HSBC at the end of 2020. 

HSBC Holdings’ subordinated liabilities

At amortised cost 

Designated at fair value (Note 24)

At 31 Dec

2021

$m

17,059   

5,600   

22,659   

2020

$m

17,916 

6,040 

23,956 

HSBC Holdings plc Annual Report and Accounts 2021 371

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 notes2,3
4.25% subordinated notes2
4.375% subordinated notes2
7.625% subordinated notes1
7.35% subordinated notes1
6.50% subordinated notes1
6.50% subordinated notes1
6.80% subordinated notes1
5.25% subordinated notes2

5.75% subordinated notes2
6.75% subordinated notes2
7.00% subordinated notes2
6.00% subordinated notes2

€1,500m

€1,000m

3.0% subordinated notes2
3.125% subordinated notes2

First call

date

Maturity

date

2021

$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  

2,072   

1,615   

1,641   

536   

241   

2,032   

2,825   

1,491   

1,946   

1,040   

877   

1,082   

1,320   

1,737   

1,304   

21,759   

900   
900   

2020

$m

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 

Amounts owed to HSBC undertakings
$900m

10.176% subordinated step-up cumulative notes

Jun 2030

Jun 2040  

At 31 Dec

22,659   

23,956 

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. 

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.

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 qualified as additional tier 1 
capital for HSBC under CRR II until 31 December 2021 by virtue of the application of grandfathering provisions. The capital security 
guaranteed by HSBC Bank plc also qualified as additional tier 1 capital for HSBC Bank plc (on a solo and a consolidated basis) under 
CRR II until 31 December 2021 by virtue of the same grandfathering process. Since 31 December 2021, these securities have no longer 
qualified as regulatory capital for HSBC or HSBC Bank plc. 

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.

372 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
29 Maturity analysis of assets, liabilities and off-balance sheet commitments

The table on page 374 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 irrespective of contractual maturity included in the ‘Due over 5 years’ time bucket in the 

maturity table provided below. An analysis of the expected maturity of liabilities under insurance contracts based on undiscounted 
cash flows is provided on page 215. 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 2021 373

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

  403,018   

Items in the course of collection from other banks  

4,136   

Hong Kong Government certificates of 
indebtedness

42,578   

—   

—   

—   

Trading assets

  244,422   

2,403   

Financial assets designated or otherwise 
mandatorily measured at fair value

Derivatives

4,968   

  195,701   

89   

164   

—   

—   

—   

440   

585   

85   

—   

—   

—   

194   

515   

110   

—   

—   

—   

468   

224   

233   

—   

—   

—   

—   

—    403,018 

—   

4,136 

—   

621   

—   

294   

—   

42,578 

—    248,842 

855   

1,852   

40,716   

49,804 

91   

310   

188    196,882 

Loans and advances to banks

55,572   

10,889   

5,469   

1,078   

1,512   

5,321   

3,134   

161   

83,136 

Loans and advances to customers

  160,583   

82,531   

69,380   

42,459   

42,651    107,393    220,746    320,071   1,045,814 

–  personal

50,573   

11,373   

8,934   

8,022   

7,766   

25,271   

78,373    284,922    475,234 

–  corporate and commercial

97,554   

64,511   

52,548   

29,341   

28,749   

72,441    127,527   

32,664    505,335 

–  financial
Reverse repurchase agreements – non-trading

12,456   

6,647   

7,898   

5,096   

6,136   

9,681   

14,846   

2,485   

65,245 

  155,997   

49,392   

18,697   

9,386   

3,661   

2,672   

1,843   

—    241,648 

Financial investments

47,084   

68,034   

33,233   

20,638   

21,779   

49,903   

80,367    125,236    446,274 

Accrued income and other financial assets

79,077   

5,932   

2,935   

536   

537   

265   

812   

3,722   

93,816 

Financial assets at 31 Dec 2021

 1,393,136    219,434    130,824   

74,916   

71,065    167,121    309,358    490,094   2,855,948 

Non-financial assets

—   

—   

—   

—   

—   

—   

—    101,991    101,991 

Total assets at 31 Dec 2021

 1,393,136    219,434    130,824   

74,916   

71,065    167,121    309,358    592,085   2,957,939 

Off-balance sheet commitments received

Loan and other credit-related commitments

49,061   

—   

—   

—   

—   

—   

—   

—   

49,061 

Financial liabilities

Hong Kong currency notes in circulation

42,578   

—   

—   

Deposits by banks

Customer accounts

–  personal

63,660   

2,695   

2,419   

—   

238   

—   

—   

—   

—   

42,578 

125   

14,653   

16,734   

628    101,152 

 1,615,025   

51,835   

19,167   

8,007   

9,710   

3,143   

3,585   

102   1,710,574 

  802,777   

24,725   

12,038   

5,961   

5,255   

2,304   

2,242   

26    855,328 

–  corporate and commercial

  623,459   

22,980   

5,654   

1,762   

3,402   

–  financial

  188,789   

4,130   

1,475   

Repurchase agreements – non-trading

  117,625   

4,613   

1,716   

284   

292   

1,053   

142   

Items in the course of transmission to other 
banks

Trading liabilities

Financial liabilities designated at 
fair value

5,214   

—   

79,789   

3,810   

—   

346   

—   

218   

—   

223   

18,080   

9,437   

4,514   

3,287   

4,485   

17,422   

42,116   

46,161    145,502 

–  debt securities in issue: covered bonds

—   

1,137   

—   

—   

—   

1,481   

1,160   

—   

3,778 

–  debt securities in issue: unsecured

9,916   

5,967   

2,823   

2,259   

3,462   

14,758   

34,515   

35,282    108,982 

–  subordinated liabilities and preferred securities

—   

—   

—   

—   

—   

—   

5,371   

4,729   

10,100 

–  other

Derivatives

Debt securities in issue

–  covered bonds

–  otherwise secured

–  unsecured

8,164   

2,333   

1,691   

1,028   

1,023   

1,183   

1,070   

6,150   

22,642 

  190,233   

46   

11   

30   

25   

100   

288   

331    191,064 

7,053   

7,777   

5,664   

6,880   

1,703   

9,045   

20,254   

20,181   

78,557 

—   

957   

—   

164   

—   

42   

997   

31   

—   

193   

996   

896   

860   

—   

1,696   

1,207   

2,853 

5,186 

6,096   

7,613   

5,622   

5,852   

1,510   

7,153   

17,698   

18,974   

70,518 

Accruals and other financial liabilities

91,749   

10,317   

5,630   

1,103   

1,072   

1,948   

2,407   

2,829    117,055 

Subordinated liabilities

—   

1   

11   

—   

—   

417   

2,055   

18,003   

20,487 

Total financial liabilities at 31 Dec 2021

 2,231,006   

90,531   

39,478   

20,055   

17,485   

48,148   

87,889   

89,165   2,623,757 

Non-financial liabilities

—   

—   

—   

—   

—   

—   

—    127,405    127,405 

Total liabilities at 31 Dec 2021

 2,231,006   

90,531   

39,478   

20,055   

17,485   

48,148   

87,889    216,570   2,751,162 

Off-balance sheet commitments given

Loan and other credit-related commitments

  813,491   

121   

133   

–  personal

–  corporate and commercial 

–  financial 

  239,207   

  456,498   

  117,786   

34   

76   

11   

34   

91   

8   

228   

54   

168   

6   

254   

108   

143   

3   

78   

32   

46   

—   

931   

688   

243   

—   

238    815,474 

238    240,395 

—    457,265 

—    117,814 

374 HSBC Holdings plc Annual Report and Accounts 2021

706   

133   

975   

—   

445   

1,167   

33    659,163 

176   

377   

—   

73   

43    196,083 

930    126,670 

—   

5,214 

—   

84,904 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

  304,481   

Items in the course of collection from other banks  

4,094   

Hong Kong Government certificates of 
indebtedness 

Trading assets 

Financial assets designated at fair value 

Derivatives 

—   

—   

—   

—   

—   

—   

458   

466   

12   

—   

—   

—   

135   

262   

14   

—   

—   

—   

67   

454   

14   

—   

—   

—   

644   

—   

—   

—   

474   

—   

—   

304,481 

4,094 

—   

40,420 

—   

231,990 

1,424   

1,992   

37,654   

45,553 

441   

424   

245   

307,726 

40,420   

  228,434   

1,778   

3,061   

  306,561   

240   

15   

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 

–  corporate and commercial

–  financial 
Reverse repurchase agreements 
– non-trading

Financial investments 

51,711   

9,645   

7,918   

7,270   

7,033   

26,318   

70,447   

275,736   

456,078 

  101,684   

55,009   

51,755   

31,529   

28,553   

76,225   

125,393   

47,446   

517,594 

18,911   

6,092   

6,165   

5,593   

3,020   

9,897   

10,608   

4,029   

64,315 

  157,234   

44,658   

16,655   

5,113   

1,324   

3,058   

2,586   

—   

230,628 

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 

Total assets at 31 Dec 2020

Off-balance sheet commitments received

—   

—   

—   

—   

—   

—   

—   

103,413   

103,413 

  1,408,631    212,121    136,067   

67,982   

67,319   

171,074   

315,734   

605,236    2,984,164 

Loan and other credit-related commitments

60,849   

—   

—   

—   

—   

—   

—   

—   

60,849 

Financial liabilities

Hong Kong currency notes in circulation 

Deposits by banks

Customer accounts

–  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 

–  debt securities in issue: covered bonds 

40,420   

60,973   

—   

1,396   

—   

714   

  1,533,595   

61,376   

22,568   

  766,631   

32,429   

15,511   

  588,887   

22,856   

  178,077   

  102,633   

6,091   

3,979   

4,343   

70,799   

18,434   

—   

—   

3,377   

7,333   

—   

5,963   

1,094   

2,165   

—   

400   

—   

695   

9,375   

6,276   

2,966   

133   

386   

—   

143   

—   

197   

8,418   

5,825   

2,058   

535   

675   

—   

185   

—   

—   

718   

16,757   

2,859   

1,976   

777   

106   

4,467   

3,591   

627   

249   

16   

—   

289   

—   

630   

40,420 

82,080 

122    1,642,780 

39   

37   

46   

832,278 

624,171 

186,331 

1,035   

1,012   

111,901 

—   

72   

—   

1   

4,343 

75,266 

6,973   

6,775   

6,593   

14,182   

40,510   

56,639   

157,439 

—   

—   

—   

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

—   

—   

—   

—   

—   

—   

7,672   

2,863   

1,451   

1,171   

1,063   

2,488   

  300,902   

264   

198   

38   

55   

237   

3,912   

1,970   

726   

6,932   

6,882   

10,844 

25,560 

581   

303,001 

–  other 

Derivatives 

Debt securities in issue 

–  covered bonds 

–  otherwise secured 

–  unsecured 

Accruals and other financial liabilities
Subordinated liabilities 

6,552   

12,329   

14,964   

9,764   

3,878   

9,215   

16,618   

22,172   

95,492 

—   

—   

28   

1,094   

1,585   

1,001   

5,458   

10,744   

13,935   

96,821   
619   

9,794   
—   

3,886   
237   

—   

1,000   

8,764   

692   
—   

750   

—   

3,128   

1,174   
12   

1,275   

999   

—   

274   

1,640   

1,590   

7,666   

13,979   

1,742   
12   

3,179   
2,658   

20,582   
3,053   
18,413   

3,052 

8,184 

84,256 
120,341 

21,951 

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 

HSBC Holdings plc Annual Report and Accounts 2021 375

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 

2,590   

1,101   

—   

—   

—   

—   

Loans and advances to HSBC undertakings 

120   

750   

341   

—   

—   

—   

—   

—   

—   

23   

—   

—   

585   

1,102   

2,590 

2,811 

3,017   

5,608   

13,333   

1,939   

25,108 

Financial assets with HSBC undertakings 
designated and otherwise mandatorily measured 
at fair value

—   

1,759   

250   

1,019   

—   

5,987   

19,455   

22,938   

51,408 

Financial investments

8,377   

7,166   

3,014   

1,346   

3,026   

3,265   

Accrued income and other financial assets

129   

874   

108   

58   

4   

—   

—   

—   

—   

—   

26,194 

1,173 

Total financial assets at 31 Dec 2021

12,317   

10,549   

3,713   

2,423   

6,047   

14,883   

33,373   

25,979    109,284 

Non-financial assets 

—   

—   

—   

—   

—   

—   

—    163,888    163,888 

Total assets at 31 Dec 2021

12,317   

10,549   

3,713   

2,423   

6,047   

14,883   

33,373    189,867    273,172 

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 

—   

397   

397   

—   

1,167   

1,051   

1,778   

111   

2,484   

2,484   

—   

—   

—   

—   

—   

—   

—   

—   

—   

730   

1,612   

—   

—   

—   

Total financial liabilities 31 Dec 2021

4,393   

3,325   

1,612   

Non-financial liabilities 

Total liabilities at 31 Dec 2021

—   

—   

—   

4,393   

3,325   

1,612   

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

Financial investments in HSBC undertakings

Accrued income and other financial assets

Total financial assets at 31 Dec 2020

Non-financial assets 

Total assets at 31 Dec 2020

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 

2,913   

1,473   

—   

—   

—   

600   

—   

5   

120   

—   

451   

—   

3,701   

1,015   

9,102   

—   

3,769   

2,924   

275   

100   

5,095   

3,149   

—   

—   

9,102   

5,095   

3,149   

—   

—   

—   

—   

3,052   

—   

3,769   

—   

330   

984   

984   

—   

—   

503   

689   

—   

—   

859   

859   

—   

—   

1,621   

301   

—   

Total financial liabilities at 31 Dec 2020

6,821   

2,506   

2,781   

Non-financial liabilities 

Total liabilities at 31 Dec 2020

—   

—   

—   

6,821   

2,506   

2,781   

Contractual maturity of financial liabilities

—   

—   

—   

—   

—   

—   

68   

—   

68   

—   

68   

—   

—   

—   

—   

799   

33   

832   

—   

832   

—   

—   

—   

—   

—   

563   

57   

—   

620   

—   

620   

—   

—   

—   

—   

—   

—   

12   

—   

12   

—   

12   

—   

—   

—   

111 

1,364   

11,276   

16,897   

32,418 

1,364   

8,020   

14,553   

26,818 

—   

5   

3,256   

2,344   

1   

47   

5,600 

1,220 

8,525   

29,889   

28,018   

67,483 

—   

—   

—   

40   

4,240 

3,809   

13,250   

17,059 

9,894   

44,975   

58,252    122,531 

—   

—   

311   

311 

9,894   

44,975   

58,563    122,842 

—   

—   

—   

—   

9   

312   

—   

1,131   

6,027   

—   

2,080   

2,913 

4,698 

3,384   

10,443 

—   

4,320   

23,203   

37,279   

65,253 

3,528   

2,764   

22   

—   

—   

—   

—   

—   

17,485 

1,445 

3,550   

7,405   

30,361   

42,743   

102,237 

—   

—   

—   

160,936   

160,936 

3,550   

7,405   

30,361   

203,679   

263,173 

—   

—   

—   

—   

—   

—   

12   

—   

12   

—   

12   

—   

3,088   

3,088   

—   

—   

—   

—   

3,810   

16,923   

2,108   

12,585   

1,702   

4,338   

—   

8   

330 

25,664 

19,624 

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 

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.

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.

376 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 value

Derivatives

Debt securities in issue

Subordinated liabilities

Other financial liabilities

Loan and other credit-related commitments
Financial guarantees1
At 31 Dec 2021

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 guarantees1
At 31 Dec 2020

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

63,684   

2,712   

2,800   

31,294   

643   

101,133 

1,613,065   

54,092   

37,219   

117,643   

4,615   

2,157   

—   

—   

7,093   

1,359   

—   

9,760   

13,606   

63,834   

50,953   

192   

190   

1,792   

7,958   

15,142   

32,651   

168   

9,842   

848   

7,664   

6,741   

4,577   

138   

1,711,607 

935   

126,709 

—   

1,332   

21,911   

28,347   

84,904 

156,488 

193,860 

84,811 

36,223 

2,697   

154,486 

84,904   

18,335   

190,354   

7,149   

119   

129,706   

2,224,959   

89,339   

79,626   

149,341   

106,956   

2,650,221 

813,471   

27,774   

121   

6   

615   

9   

1,029   

6   

238   

815,474 

—   

27,795 

3,066,204   

89,466   

80,250   

150,376   

107,194   

3,493,490 

88%

3%

2%

4%

3%

61,001   

1,530,584   

102,664   

75,266   

18,815   

300,158   

6,551   

739   

140,094   

1,442   

64,809   

3,984   

—   

7,556   

356   

1,639   

40,755   

3,257   

—   

19,243   

579   

12,709   

29,520   

170   

9,120   

1,102   

5,113   

17,352   

7,720   

1,058   

—   

59,835   

1,830   

28,787   

7,024   

5,030   

632   

153   

82,066 

1,644,021 

1,017   

—   

55,475   

2,128   

24,075   

28,812   

2,887   

111,980 

75,266 

160,924 

305,051 

101,642 

37,847 

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%

1  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 2021, 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 2021 377

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

Derivatives 

Debt securities in issue 

Subordinated liabilities 

Other financial liabilities 

Loan commitments 
Financial guarantees1
At 31 Dec 2021

Amounts owed to HSBC undertakings 

Financial liabilities designated at fair value 

Derivatives 

Debt securities in issue 

Subordinated liabilities 

Other financial liabilities 

Loan commitments 
Financial guarantees1
At 31 Dec 2020

$m

—   

473   

1,223   

1,196   

81   

1,778   

4,751   

—   

13,746   

18,497   

—   

70   

3,085   

135   

82   

3,769   

7,141   

—   
13,787   

20,928   

$m

111   

2,611   

9   

276   

155   

730   

3,892   

—   

—   

$m

—   

621   

51   

722   

1,692   

4,372   

—   

—   

15,017   

17,557   

Due over
5 years

$m

—   

585   

30,800   

20,777   

40   

$m

—   

414   

7,222   

—   

Total

$m

111 

36,279 

2,282 

76,918 

28,957 

4,240 

66,013   

69,759   

148,787 

—   

—   

—   

—   

— 

13,746 

1,286   

43,360   

3,892   

4,372   

66,013   

69,759   

162,533 

330   

1,109   

—   

760   

156   

690   

—   

1,412   

2   

3,354   

726   

370   

—   

—   

9,110   

16,104   

—   

31,567   

7,513   

—   

—   

37,103   

21,552   

36   

330 

27,805 

3,087 

72,919 

30,029 

4,865 

3,045   

5,864   

48,190   

74,795   

139,035 

—   
—   

—   
—   

—   
—   

—   
—   

— 
13,787 

3,045   

5,864   

48,190   

74,795   

152,822 

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.

378 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
–  non-trading assets 
Loans and advances to customers3
At 31 Dec 2021

Derivatives (Note 15)1
Reverse repos, stock borrowing 
and similar agreements classified 
as:2

–  non-trading assets
Loans and advances to customers3
At 31 Dec 2020

Financial liabilities
Derivatives (Note 15)1
Repos, stock lending and similar 
agreements classified as:2

–  trading liabilities

–  non-trading liabilities 
Customer accounts4
At 31 Dec 2021

Derivatives (Note 15)1
Repos, stock lending and similar 
agreements classified as:2

–  trading liabilities 

–  non-trading liabilities
Customer accounts4
At 31 Dec 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

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

  244,694   

(53,378)   

191,316   

(139,945)   

(11,359)   

(36,581)   

3,431   

5,566    196,882 

Financial assets
Derivatives (Note 15)1
Reverse repos, stock borrowing 
and similar agreements classified 
as:2

–  trading assets

21,568   

(222)   

21,346   

(359)   

(20,913)   

  353,066   

(136,932)   

216,134   

(12,226)   

(203,543)   

(71)   

(165)   

3   

200   

1,729    23,075 

25,731    241,865 

27,045   

(10,919)   

16,126   

(13,065)   

—   

—   

3,061   

327    16,453 

  646,373   

(201,451)   

444,922   

(165,595)   

(235,815)   

(36,817)   

6,695   

33,353    478,275 

368,057   

(69,103)   

298,954   

(230,758)   

(13,766)   

(48,154)   

6,276   

8,772    307,726 

–  trading assets 

21,204   

(461)   

20,743   

(709)   

(20,030)   

318,424   

(115,678)   

202,746   

(13,936)   

(188,646)   

30,983   

(10,882)   

20,101   

(17,031)   

—   

738,668   

(196,124)   

542,544   

(262,434)   

(222,442)   

(48,227)   

—   

(73)   

—   

4   

91   

3,070   

9,441   

1,534   

22,277 

28,258    231,004 

428   

20,529 

38,992    581,536 

  239,597   

(53,378)   

186,219   

(139,945)   

(23,414)   

(18,225)   

4,635   

4,845    191,064 

13,540   

(222)   

13,318   

(359)   

(12,959)   

—   

  235,042   

(136,932)   

98,110   

(12,226)   

(85,590)   

(203)   

—   

91   

17    13,335 

28,560    126,670 

40,875   

(10,919)   

29,956   

(13,065)   

—   

—   

16,891   

17    29,973 

  529,054   

(201,451)   

327,603   

(165,595)   

(121,963)   

(18,428)   

21,617   

33,439    361,042 

364,121   

(69,103)   

295,018   

(230,758)   

(21,387)   

(37,343)   

5,530   

7,983    303,001 

16,626   

(461)   

200,999   

(115,678)   

41,177   

(10,882)   

16,165   

85,321   

30,295   

(709)   

(15,456)   

(13,936)   

(71,142)   

—   

(215)   

—   

28   

159   

16,324 

26,580    111,901 

(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 

1  At 31 December 2021, the amount of cash margin received that had been offset against the gross derivatives assets was $4,469m 

(2020: $7,899m). The amount of cash margin paid that had been offset against the gross derivatives liabilities was $9,479m (2020: $17,955m).
2  For the amount of repos, reverse repos, stock lending, stock borrowing and similar agreements recognised on the balance sheet within ‘Trading 
assets’ $23,075m (2020: $22,277m) and ‘Trading liabilities’ $13,335m (2020: $16,324m), see the ‘Funding sources and uses’ table on page 197.
3  At 31 December 2021, the total amount of ‘Loans and advances to customers’ was $1,045,814m (2020: $1,037,987m), of which $16,126m (2020: 

$20,101m) was subject to offsetting.

4  At 31 December 2021, the total amount of ‘Customer accounts’ was $1,710,574m (2020: $1,642,780m), of which $29,956m (2020: $30,295m) 

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 Dec1

2021

Number

$m

Number

2020

  20,693,621,100   

10,347   

20,638,524,545   

58,266,053   

—   

120,366,714   

29   

—   

60   

55,096,555   

—   

—   

$m

10,319 

28 

— 

— 

  20,631,520,439   

10,316   

20,693,621,100   

10,347 

HSBC Holdings plc Annual Report and Accounts 2021 379

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings 6.2% non-cumulative US dollar preference shares, Series A 

At 1 Jan and 31 Dec2

HSBC Holdings share premium

At 31 Dec

Total called up share capital and share premium

At 31 Dec

2021

Number

—   

$m

—   

2020

Number

1,450,000   

2021

$m

14,602   

2021

$m

24,918   

$m

— 

2020

$m

14,277 

2020

$m

24,624 

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 has included 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 US dollar non-cumulative preference shares outlined above (which were redeemed in January 2021) 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, subject to anti-
dilution adjustments.

380 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
HSBC’s additional tier 1 capital – contingent convertible securities in issue which are accounted for in equity

$2,000m

$2,250m

$2,450m

$3,000m

$2,350m

$1,800m

$1,500m

$1,000m

$1,000m

€1,500m

€1,000m

€1,250m

£1,000

6.875% perpetual subordinated contingent convertible securities1
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 securities2
4.000% perpetual subordinated contingent convertible securities3
4.700% perpetual subordinated contingent convertible securities4
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

SGD750m

5.000% perpetual subordinated contingent convertible securities

At 31 Dec

First call
date

Jun 2021  

Sep 2024  

Mar 2025  

May 2027  

Mar 2023  

Mar 2028  

Dec 2030  
Mar 2026  

Mar 2031  

Sep 2022  

Sep 2023  

Jul 2029  

Sep 2026   

Jun 2022  
Sep 2023  

2021

$m

—   

2,250   

2,450   

3,000   

2,350   

1,800   

1,500   
1,000   

1,000   

1,945   

1,123   

1,422   

1,301   

723   
550   

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   

22,414 

1  This security was called by HSBC Holdings on 15 April 2021 and was redeemed and cancelled on 1 June 2021. 
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.

3  This security was issued by HSBC Holdings on 9 March 2021. The first call date commences six calendar months prior to the reset date of 

9 September 2026.

4  This security was issued by HSBC Holdings on 9 March 2021. The first call date commences six calendar months prior to the reset date of 

9 September 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 2021

31 Dec 2020

Number of
HSBC Holdings
ordinary shares Usual period of exercise

Exercise price 

123,196,850 

2020 to 2027

£2.6270–£5.9640  

Number of
HSBC Holdings
ordinary shares

130,952,539 

Usual period of exercise

Exercise price

2019 to 2026

£2.6270–£5.9640

Maximum obligation to deliver HSBC Holdings ordinary shares

At 31 December 2021, 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 long-term incentive awards and deferred share awards granted 
under the HSBC Share Plan 2011, was 224,974,433 (2020: 238,278,952). The total number of shares at 31 December 2021 held by 
employee benefit trusts that may be used to satisfy such obligations to deliver HSBC Holdings ordinary shares was 9,297,415 (2020: 
5,179,531).

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:2
–  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

HSBC

2021

$m

HSBC Holdings1

2020

$m

2021

$m

2020

$m

27,795   
85,534   
858   
114,187   

8,827   
47,184   
759,463   
815,474   

18,384   
78,114   
1,219   
97,717   

7,178   
66,506   
771,086   
844,770   

13,746 

13,787

— 

133   

—

119 

13,879 

13,906

—   

—   

—   

—   

— 

— 

— 

— 

1  Guarantees by HSBC Holdings are all in favour of other Group entities.
2 

Includes $627,637m of commitments at 31 December 2021 (31 December 2020: $659,783m), 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.

HSBC Holdings plc Annual Report and Accounts 2021 381

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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.

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 HSBC UK 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 be estimated reliably. It is dependent on various uncertain factors
including the potential recovery 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 $63.5bn at 31 December 2021 
(2020: $53.1bn). 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

2021

Unearned
finance
income

$m

$m

Present
value

$m

Total future
minimum
payments

$m

2020

Unearned
finance
income

$m

3,298   

2,303   

1,645   

1,225   

795   

5,968   

4,044   

(303)   

(242)   

(192)   

(146)   

(113)   

(693)   

(528)   

2,995   

2,061   

1,453   

1,079   

682   

5,275   

3,516   

3,108   

2,476   

2,055   

1,380   

787   

6,698   

4,221   

(257)   

(196)   

(143)   

(109)   

(80)   

(528)   

(451)   

Present
value

$m

2,851 

2,280 

1,912 

1,271 

707 

6,170 

3,770 

13,310   

(1,524)   

11,786   

14,027   

(1,236)   

12,791 

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 2021 (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

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 Bernard L. Madoff Investment Securities LLC (‘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 Madoff Securities 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. Following an initial dismissal of certain claims, which was later reversed on appeal, 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 dismissed certain claims by the Fairfield liquidators and granted a 
motion by the liquidators to file amended complaints. 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 these appeals remain pending.

In January 2020, the Fairfield liquidators filed amended complaints on the claims remaining in the US Bankruptcy Court. In December 
2020, the US Bankruptcy Court dismissed the majority of those claims. In March 2021, the liquidators and defendants appealed the US 
Bankruptcy Court’s decision to the New York District Court, and these appeals are currently pending. Meanwhile, proceedings before the 
US Bankruptcy Court with respect to the remaining claims that were not dismissed are ongoing.

UK litigation: The Madoff Securities 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 2022 for UK-based defendants and November 2022 for all other defendants.

382 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
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. Two hearings before the UK Privy Council took place during 2021. Judgment was given against 
HSBC in respect of the first hearing and judgment is pending in respect of the second hearing.

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 
and money damages claims. 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.

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 around $600m, 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. Over the past several years, HSBC has retained a Skilled Person under section 166 of the 
Financial Services and Markets Act and an Independent Consultant under the FRB cease-and-desist order to produce periodic 
assessments of the Group’s AML and sanctions compliance programme. The Skilled Person completed its engagement in the second 
quarter of 2021, and the FCA has determined that no further Skilled Person work is required. Separately, the Independent Consultant 
continues to work pursuant to the FRB cease-and-desist order. The roles of each of the FCA Skilled Person and the FRB Independent 
Consultant are discussed on page 209.

In December 2021, the FCA concluded its investigation into HSBC’s compliance with UK money laundering regulations and financial 
crime systems and control requirements. The FCA imposed a fine on HSBC Bank plc, which has been paid.

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. 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, nine actions 
remain pending in federal courts in New York or the District of Columbia. The courts have granted HSBC’s motions to dismiss in five of 
these cases; appeals remain pending in two cases, and the remaining three dismissals are also subject to appeal. The four remaining 
actions are at an early stage.

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. 

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 (‘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. 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 both appealed the General 
Court’s decision to the European Court of Justice (the ‘Court of Justice’). In June 2021, the EC adopted a new fining decision for an 
amount that was 5% less than the previously annulled fine, and it subsequently withdrew its appeal to the Court of Justice. HSBC has 
appealed the EC’s June 2021 fining decision to the General Court, and its appeal to the Court of Justice on liability also remains pending.

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. HSBC has reached 
class settlements with five groups of plaintiffs, and the court has approved these settlements. HSBC has also resolved several of the 
individual actions, although a number of other US dollar Libor-related actions remain pending against HSBC in the New York District 
Court.

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’ motion to 
dismiss in its entirety and, in February 2022, the US Court of Appeals for the Second Circuit dismissed the plaintiffs’ appeal.

HSBC Holdings plc Annual Report and Accounts 2021 383

Financial statementsNotes on the financial statements

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, in October 2021, The Hongkong and Shanghai Banking Corporation Limited reached a settlement in principle 
with the plaintiffs to resolve this action. The settlement remains subject to court approval.

In the BBSW litigation, in November 2018, the court dismissed all foreign defendants, including all 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 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 

In December 2021, the EC issued a settlement decision finding that a number of banks, including HSBC, had engaged in anti-competitive 
practices in an online chatroom between 2011 and 2012 in the foreign exchange spot market. The EC imposed a €174.3m fine on HSBC in 
connection with this matter, which is fully provisioned.

In January 2018, following the conclusion of the US Department of Justice’s (‘DoJ’) investigation into HSBC’s historical foreign exchange 
activities, HSBC Holdings entered into a 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. In January 2021, the FX DPA expired and, 
in August 2021, the charges deferred by the FX DPA were dismissed.

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 December 2021, a hearing on HSBC 
Bank plc’s and HSBC Bank USA’s applications to dismiss the revised complaint took place before the South African Competition Tribunal, 
where a decision remains pending.

Beginning in 2013, various HSBC companies and other banks have been named as defendants in a number of putative class actions filed 
in, or transferred to, the New York District Court arising from allegations that the defendants conspired to manipulate foreign exchange 
rates. HSBC has reached class settlements with two groups of plaintiffs, including direct and indirect purchasers of foreign exchange 
products, and the court has granted final approval of these settlements. A putative class action by a group of retail customers of foreign 
exchange products remains 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 direct purchaser class 
action settlement in the US. These matters remain pending. Additionally, lawsuits alleging foreign exchange-related misconduct remain 
pending against HSBC and other banks in courts in Brazil and Israel. 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, which were consolidated in the New York District Court, 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. 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 and remain pending, following the 
conclusion of pre-class certification discovery.

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 2020, the court granted the 
defendants' motion to dismiss the plaintiffs’ 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.

384 HSBC Holdings plc Annual Report and Accounts 2021

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. In December 2018 and June 2019, two further actions were brought against PBGB 
in the High Court of England and Wales by multiple claimants in connection with lending provided by PBGB to third parties in respect of 
certain Ingenious film finance schemes in which the claimants participated. In January 2022, HSBC UK Bank plc (as successor to PBGB) 
reached a settlement in principle with the claimant group to resolve these actions. The settlement remains subject to the negotiation of 
definitive documentation.

In June 2020, two separate claims were issued against HSBC UK Bank plc (as successor to PBGB) in the High Court of England and Wales 
by two separate groups of investors in Eclipse film finance schemes in connection with PBGB’s role in the development of such schemes. 
These actions are ongoing.

In April 2021, HSBC UK Bank plc (as successor to PBGB) was served with a claim issued in the High Court of England and Wales in 
connection with PBGB’s role in the development of the Zeus film finance schemes. This action is at an early stage.

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.

There are many factors that may affect the range of outcomes, and the resulting financial impact, of these matters, which could be 
significant.

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, among other things, as well as the use of non-HSBC approved messaging platforms for business communications;

• an investigation by the PRA in connection with depositor protection arrangements in the UK;

• an investigation by the FCA in connection with collections and recoveries operations in the UK;

• an investigation by 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 220 to 226 except for the roles of Group Chief Legal Officer, Group 
Head of Internal Audit, Group Chief Human Resources Officer, Group Chief Sustainability Officer, Group Head of Strategy, Group Chief 
Communications Officer and Group Company Secretary and Chief Governance Officer who do 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.

HSBC Holdings plc Annual Report and Accounts 2021 385

Financial statements 
Notes on the financial statements

Key Management Personnel

Details of Directors’ remuneration and interests in shares are disclosed in the ‘Directors’ remuneration report’ on pages 254 to 287. 
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 
Number of other HSBC securities held1
At 31 Dec

2021

$m

50   

6   

27   

83   

2020

$m

39   

5   

20   

64   

2021

(000s)

35   

13,529   

228   

13,792   

2019

$m

64 

8 

27 

99 

2020

(000s)

27 

11,916 

228 

12,171 

1   The disclosure includes other HSBC securities held by Key Management Personnel and comparatives for 2020 have now been presented.

Advances and credits, guarantees and deposit balances during the year with Key Management Personnel

Key Management Personnel
Advances and credits1
Guarantees

Deposits

2021

2020

Balance at
31 Dec

$m

Highest amounts
outstanding
during year

$m

373   

25   

284   

401   

45   

3,190   

Balance at
31 Dec

$m

221   

30   

281   

Highest amounts
outstanding
during year

$m

357 

55 

874 

1  Advances and credits entered into by subsidiaries of HSBC Holdings plc during 2021 with Directors and former Directors, disclosed pursuant to 

section 413 of the Companies Act 2006, totalled $2.8m (2020: $4.7m).

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 19.

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

2021

2020

Highest balance 
during the year

Balance at
31 Dec

Highest balance
during the year

Balance at
31 Dec

$m

160   

4,527   

3,397   

102   

1,016   

$m

96   

4,188   

1,070   

44   

347   

$m

147   

4,330   

5,466   

102   

433   

$m

147 

2,942 

2,226 

102 

283 

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 2021, $3.4bn (2020: $3.5bn) of HSBC post-employment benefit plan assets were under management by HSBC 
companies, earning management fees of $14m in 2021 (2020: $13m). At 31 December 2021, HSBC’s post-employment benefit plans had 
placed deposits of $476m (2020: $452m) with its banking subsidiaries, earning interest payable to the schemes of nil (2020: nil). 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 2021, the gross notional value of the swaps was $7.4bn (2020: $7.7bn). These swaps 
had a positive fair value to the scheme of $1.0bn (2020: $1.0bn); and HSBC had delivered collateral of $1.0bn (2020: $1.0bn) to the 
scheme in respect of these arrangements. All swaps were executed at prevailing market rates and within standard market bid/offer 
spreads.

386 HSBC Holdings plc Annual Report and Accounts 2021

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings

Details of HSBC Holdings’ subsidiaries are shown in Note 38.

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

2021

2020

Highest balance
during the year

Balance at
31 Dec

Highest balance
during the year

$m

$m

$m

Balance at
31 Dec

$m

3,397   

2,590   

5,476   

2,913 

64,686   

4,187   

27,142   

1,555   

163,211   

264,178   

340   

2,872   

2,036   

900   

6,148   

51,408   

2,811   

25,108   

1,135   

163,211   

246,263   

111   

1,220   

1,732   

900   

3,963   

65,253   

5,784   

10,785   

1,838   

161,546   

250,682   

581   

3,376   

2,737   

892   

7,586   

16,477   

13,746   

15,661   

65,253 

4,698 

10,443 

1,363 

160,660 

245,330 

330 

3,060 

1,936 

892 

6,218 

13,787 

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.

36 Business disposals

In 2021, we accelerated the pace of execution on our strategic ambition to be the preferred international financial partner for our clients 
with the announcements of the planned sale of our retail banking businesses in France, as well as the exit of domestic mass market retail 
banking in the US.

Planned sale of the retail banking business in France

On 25 November 2021, HSBC Continental Europe signed a framework agreement with Promontoria MMB SAS (‘My Money Group’) and 
its subsidiary Banque des Caraïbes SA, regarding the planned sale of HSBC Continental Europe’s retail banking business in France. This 
followed the signing of a Memorandum of Understanding on 18 June 2021 and the conclusion of the information and consultation 
processes of the parties with their respective works councils. 

In parallel, several other agreements have been entered into aiming to ensure continuity of service for HSBC Continental Europe's retail 
banking customers who hold asset management products with HSBC Global Asset Management (France) and HSBC REIM (France), and 
protection and/or life-wrapped insurance products with HSBC Assurances Vie (France).

The sale, which is subject to regulatory approvals and the satisfaction of other relevant conditions, includes: HSBC Continental Europe’s 
French retail banking business; the Crédit Commercial de France (‘CCF’) brand; and HSBC Continental Europe’s 100% ownership interest 
in HSBC SFH (France) and its 3% ownership interest in Crédit Logement. The sale would generate an estimated loss before tax including 
related transaction costs for the Group of $2.3bn, together with an additional $0.7bn impairment of goodwill.

The signing of the framework agreement for the planned sale of the French retail banking business resulted in a tax deduction (tax value 
of $0.4bn) for a provision for loss on disposal, which was recorded in the French tax return. A deferred tax liability of the same amount 
arises as a consequence of the temporary difference between the French tax return and IFRS in respect of this provision. There was no tax 
impact in respect of goodwill impairment recognised in the Group financial statements for the year ended 31 December 2021. The vast 
majority of the estimated loss for the write-down of the disposal group to fair value less costs to sell will be recognised when it is 
classified as held for sale in accordance with IFRS 5, which is currently anticipated to be in 2022. Subsequently, the disposal group 
classified as held for sale will be remeasured at the lower of carrying amount and fair value less costs to sell at each reporting period. Any 
remaining gain or loss not previously recognised will be recognised at the date of derecognition, which is currently anticipated to be in 
2023. 

At 31 December 2021, the value of the total assets of the business to be sold was $27.4bn, including $24.9bn of loans and advances to 
customers, and the value of customer accounts was $22.6bn.

US retail banking business

On 26 May 2021, we announced that we will exit our US mass market retail banking business, including our Personal and Advance 
propositions, as well as retail business banking, and will rebrand approximately 20 to 25 of our retail branches into international wealth 
centres to serve our Premier and Jade customers. In conjunction with the execution of this strategy, HSBC Bank USA, N.A. entered into 
definitive sale agreements with Citizens Bank and Cathay Bank to sell approximately 90 of our retail branches along with substantially all 
residential mortgage, unsecured and retail business banking loans and all deposits in our branch network not associated with our Premier, 
Jade and Private Banking customers. Certain assets under management associated with our mass market retail banking business were 
also transferred. The sale agreement with Cathay Bank completed on 4 February 2022 and the sale agreement with Citizens Bank 
completed on 18 February 2022. The remaining branches not sold or rebranded will be closed.

At 31 December 2021, loans and advances to customers of $2.4bn and customer accounts of $8.8bn related to these transactions met the 
criteria to be classified as held for sale.

HSBC Holdings plc Annual Report and Accounts 2021 387

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

37 Events after the balance sheet date

The following recently announced acquisitions form part of our strategy to grow our insurance business, helping to deliver on our 
strategic priority to become a market leader in Asian wealth management. 

• On 11 February 2022, following the completion of all regulatory approvals, HSBC Insurance (Asia-Pacific) Holdings Limited, a wholly-

owned subsidiary of the Group, acquired 100% of the issued share capital of AXA Insurance Pte Limited for $529m, subject to 
adjustment for closing items. This will be reflected in our 2022 results by which time determination of the initial acquisition accounting 
will have been completed.

• On 30 December 2021, approval was received from the China Banking and Insurance Regulatory Commission for HSBC Insurance 

(Asia) Limited, a wholly-owned subsidiary of the Group, to acquire the remaining 50% equity interest in HSBC Life Insurance Company 
Limited (HSBC Life China). Completion is expected to occur during the first half of 2022. Headquartered in Shanghai, HSBC Life China 
offers a comprehensive range of insurance solutions covering annuity, whole life, critical illness and unit-linked insurance products and 
in 2021 reported gross written premiums of approximately $0.4bn (2020: $0.3bn).

• On 28 January 2022, HSBC Insurance (Asia-Pacific) Holdings Limited notified the shareholders of Canara HSBC Oriental Bank of 
Commerce Life Insurance Company Limited (‘CHOICe’) of its intention to increase its shareholding in CHOICe up to 49%. HSBC 
currently has a 26% shareholding which is accounted for as an associate. Any increase in shareholding is subject to agreement with 
other shareholders in CHOICe, as well as internal and regulatory approvals. Established in 2008, CHOICe is a life insurance company 
based in India with reported gross written premiums of approximately $0.7bn for the year to 31 March 2021 (31 March 2020: $0.5bn).

In 2021 HSBC Bank USA, N.A. entered into definitive sale agreements with Citizens Bank and Cathay Bank to sell approximately 90 of our 
retail branches along with substantially all residential mortgage, unsecured and retail business banking loans and all deposits in our 
branch network not associated with our Premier, Jade and Private Banking customers. The sale agreement with Cathay Bank completed 
on 4 February 2022 and the sale agreement with Citizens Bank completed on 18 February 2022. For further information on the 
transactions refer to Note 36: Business disposals on page 387.

A second interim dividend for 2021 of $0.18 per ordinary share (a distribution of approximately $3,649m) was approved by the Directors 
after 31 December 2021. HSBC Holdings called $2,500m 3.262% Fixed to Floating Rate Senior Unsecured Notes due March 2023 on 
8 February 2022. The security will be redeemed and cancelled on 13 March 2022. These accounts were approved by the Board of 
Directors on 22 February 2022 and authorised for issue.

38 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 2021 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.

388 HSBC Holdings plc Annual Report and Accounts 2021

 
 
Subsidiaries 

Subsidiaries

452 TALF Plus ABS Opportunities SPV LLC

452 TALF SPV LLC

Almacenadora Banpacifico S.A. (In Liquidation)
Arcadia Financial Services (Asia) Limited

Assetfinance December (F) Limited

Assetfinance December (H) Limited

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

BentallGreenOak China Real Estate 
Investments LP

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)

CCF & Partners Asset Management Limited

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

N/A

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

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.

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

Griffin International Limited

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

N/A

100.00

% 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)

15

15

16

17

18

19

19

19

19

18

19

20

18

19

19

18

19

21

22

22

21

0, 24

12, 25

0, 145

26

19

19

27

15

15

28

29

19

19

19

19

12, 30

12, 30

12, 32

0, 19

33

0, 34

12, 35

0, 36

4, 37

4, 37

16

16

22

38

37

37

12, 39

40

11, 16

27

0, 15

19

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(62.14)

(99.99)

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

Hang Seng Qianhai Fund Management 
Company Limited

Hang Seng Real Estate Management Limited

Hang Seng Securities Limited

Hang Seng Security Management Limited

HASE Wealth Limited

Haseba Investment Company Limited

HFC Bank Limited (In Liquidation)
High Time Investments Limited

Honey Blue Enterprises 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 (Fund Services UK) 
Limited

HSBC Asset Management (Japan) 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

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

70.00

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

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)

(43.49)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(62.14)

(99.99)

Footnotes

0, 41

16

12, 42

12, 43

40

44

40

40

40

40

40

40

40

45

40

40

40

40

40

1, 12, 46

40

40

40

40

40

26

40

47

48

49

49

50

51

0, 52

19

2, 53

22

54

55

56

57

0, 58

19

54

15

59

19

2, 49

19

19

19

19

61

60

62

63

64

12, 65

53

66

HSBC Holdings plc Annual Report and Accounts 2021 389

Financial statementsNotes on the financial statements

Subsidiaries

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.

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) GP 
Inc.

HSBC Canadian Covered Bond (Legislative) 
Guarantor Limited Partnership

HSBC Capital (USA), Inc.

HSBC Capital Funding (Dollar 1) L.P.

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 Secretary (UK) 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.

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

N/A

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

100.00

100.00

N/A

N/A

94.54

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

100.00

N/A

100.00

N/A

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

N/A

100.00

100.00

99.99

100.00

100.00

100.00

 (99.99) 

Footnotes

0, 13, 67

56

68

69

70

71

59

72

63

23

73

0, 53

0, 53

74

54

75

5, 76

77

78

19

2, 19

3, 79

18

21

49

49

49

49

49

49

80

0, 80

15

0, 53

15

16

81

81

19

19

82

0, 15

37

54

49

2, 83

19

63

22

84

0, 85

12, 86

87

88

89

90

91

390 HSBC Holdings plc Annual Report and Accounts 2021

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

Footnotes

62

18

19

19

18

37

2, 19

15

19

92

19

56

93

94

95

41

3, 23

73

41

62

24

96

97

16

Subsidiaries

HSBC Epargne Entreprise (France)

HSBC Equipment Finance (UK) Limited

HSBC Equity (UK) Limited

HSBC Europe B.V.

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 Advisors Singapore Pte. Ltd.

HSBC Financial Services (Lebanon) s.a.l.

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)

 (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

99.65

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

100.00

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)

HSBC Global Asset Management (Oesterreich) 
GmbH (In Liquidation)

100.00

(99.33)

6, 98

HSBC Global Asset Management (Singapore) 
Limited

100.00

56

HSBC Global Asset Management (Switzerland) 
AG

100.00

(99.66)

4, 99

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

HSBC Global Services (China) Holdings Limited

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 Institutional Trust Services (Asia) Limited

HSBC Institutional Trust Services (Bermuda) 
Limited

100.00

100.00

100.00

100

19

101

100.00

(99.99)

102

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

103

2, 19

19

1, 19

92

19

49

19

2, 19

1, 57

19

2, 19

19

19

0, 58

0, 58

19

(99.33)

14, 41

49

23

% 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)

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.
HSBC InvestDirect (India) Private Limited
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 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) Limited

HSBC Life (Tsing Yi Industrial) Limited
HSBC Life (UK) Limited

HSBC Life Assurance (Malta) Limited

HSBC Life Insurance Company 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 Asset Co. LLC

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)

HSBC Nominees (Asing) Sdn Bhd

HSBC Nominees (Hong Kong) Limited

HSBC Nominees (New Zealand) Limited

HSBC Nominees (Tempatan) Sdn Bhd

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

100.00
100.00

(99.98)

99.99

(99.98)

98.99

(98.98)

(99.99)

(70.03)

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

50.00

100.00

100.00

100.00

100.00

100.00

99.99

100.00

100.00

N/A

100.00

100.00

100.00

100.00

100.00

100.00

100.00

66

56

104

105

23

56

101

106

2, 19

23

23

107

19

108

109

56

110

64

60

60

57

60

19

19

2, 19

111

24

58

112

19

19

19

2, 19

49

37

104

104

23

104

104

19

97

113

19

114

15

19

19

16

115

2, 116

0, 117

118

119

15

54

49

120

54

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 Investment Counsel  (Canada) 
Inc.

100.00

80.00

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

HSBC Private Markets Management SARL

N/A

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 Saudi Arabia, a Saudi closed Joint Stock 
Company
HSBC Savings Bank (Philippines) Inc.

HSBC Securities (Canada) Inc.

HSBC Securities (Egypt) S.A.E. (In Liquidation)

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 Brokers (Asia) Limited

HSBC Securities Investments (Asia) Limited

HSBC Securities Preparatory (Japan) Co., Ltd.

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

HSBC Services USA Inc.

HSBC Servicios Financieros, S.A. de C.V

100.00

100.00

100.00

100.00

51.00

100.00

100.00

100.00

100.00

100.00

100.00

66.19

99.99

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

100.00

100.00

Footnotes

3, 15

41

2, 19

121

19

59

122

123

124

16

66

125

19

58

126

19

123

127

19

49

111

0, 128

129

19

19

49

12, 130

37

15

58

62

1, 2, 19

1, 19

131

132

92

74

19

56

133

134

15

57

49

49

61

23

22

124

58

124

49

59

59

(99.99)

(99.99)

(99.99)

(99.99)

(94.65)

(99.99)

(99.99)

(99.99)

3, 16

41

135

37

136

137

16

(99.99)

(99.99)

HSBC Holdings plc Annual Report and Accounts 2021 391

Financial statementsNotes on the financial statements

Subsidiaries

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 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

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 (In Liquidation)

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

Lion International Management Limited

Lion Management (Hong Kong) Limited

Lyndholme Limited

Marks and Spencer Financial Services plc

% 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

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

99.98

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)

(99.99)

(62.14)

(62.14)

(99.68)

(99.99)

(99.99)

(99.99)

16

4, 62

22

138

187

87

19

139

15

6, 41

58

41

41

41

6, 41

6, 41

119

108

19

33

127

140

22

49

56

2, 18

18

2, 19

121

15

84

1, 18

125

15

40

19

141

12, 142

143

12, 144

40

41

16

16

16

16

19

19

19

19

19

49

1, 110

110

1, 49

49

146

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
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 Oliviers D'Antibes

SNCB/M6 - 2008 A

SNCB/M6-2007 A

SNCB/M6-2007 B

Société Française et Suisse

Somers Dublin DAC

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

Trinkaus Europa Immobilien-Fonds Nr.3 Objekt 
Utrecht Verwaltungs-GmbH

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

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

99.99

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

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)

(99.99)

146

59

16

19

18

18

81

59

16

19

147

148

15

15

22

101

1, 19

1, 19

37

4, 37

4, 37

62

1, 49

12, 149

37

133

12, 150

12, 151

152

1, 11, 153

62

37

4, 37

4, 37

37

124

23

37

19

18

12, 154

19

71

49

19

2, 19

155

41

6, 41

41

6, 41

6, 41

41

6, 41

81

18

37

49

392 HSBC Holdings plc Annual Report and Accounts 2021

The undertakings below are joint ventures and equity accounted.

Canara HSBC Oriental Bank of Commerce Life 
Insurance Company Limited

Subsidiaries

Wayfoong Nominees Limited

Wayhong (Bahamas) Limited (In Liquidation)

Westminster House, LLC

Woodex Limited

Yan Nin Development Company Limited

Joint ventures

% of share class held 
by immediate parent 
company (or by the 
Group where this 
varies)

100.00

100.00

N/A

100.00

100.00

(62.14)

Footnotes

49

103

0, 15

23

40

% of share class 
held by immediate 
parent company (or 
by the Group where 
this varies)

Footnotes

Joint ventures

Global Payments Technology Mexico S.A. De 
C.V.

HCM Holdings Limited (In Liquidation)

House Network Sdn Bhd (In Liquidation)

HSBC Pollination Climate Asset Management 
Limited

ProServe Bermuda Limited

The London Silver Market Fixing Limited

Vaultex UK Limited

50.00

50.99

25.00

40.00

50.00

N/A

50.00

Associates

The undertakings below are associates and equity accounted.

Associates

Bank of Communications Co., Ltd.

Barrowgate Limited

BGF Group PLC

Bud Financial Limited

CFAC Payment Scheme Limited (In 
Liquidation)

Contour Pte Ltd
Divido Financial Services Limited

Episode Six Limited

EPS Company (Hong Kong) Limited

EURO Secured Notes Issuer

GZHS Research Co Ltd

HSBC Jintrust Fund Management Company 
Limited

HSBC UK Covered Bonds (LM) Limited

16

28

156

157

158

0, 1, 159

160

HSBC UK Covered Bonds LLP

Icon Brickell LLC (In Liquidation)

Liquidity Match LLC

London Precious Metals Clearing Limited

MENA Infrastructure Fund (GP) Ltd

Quantexa Ltd

Services Epargne Entreprise

Simon Group LLC

sino AG

The London Gold Market Fixing Limited

The Saudi British Bank

Trade Information Network Limited

Trinkaus Europa Immobilien-Fonds Nr. 7 
Frankfurt Mertonviertel KG

Vizolution Limited

We Trade Innovation Designated Activity 
Company

Threadneedle Software Holdings Limited

% of share class 
held by immediate 
parent company (or 
by the Group where 
this varies)

19.03

15.31

24.61

10.89

26.00

33.33

12.60
5.60

8.09

38.66

16.66

20.50

49.00

20.00

N/A

N/A

N/A

25.00

33.33

10.10

14.18

N/A

24.94

25.00

31.00

16.67

N/A

17.95

9.88

6.60

Footnotes

161

162

163

1, 164

165

166

167

168

169

49

170

171

172

173

0, 18

0, 174

0, 175

176

177

178

179

0, 180

181

159

182

183

0, 41

1, 184

1, 185

186

HSBC Holdings plc Annual Report and Accounts 2021 393

Financial statements 
Notes on the financial statements

Footnotes for Note 38

Description of Shares

0

1

2

3

4

5

6

7

8

9

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

Liquidating Share Class

Nominal Shares

10 Non-Participating Voting Shares

11
12

13

14

Parts

Registered Capital Shares

Russian Limited Liability Company Shares

Stückaktien

Registered offices

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

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

Unit 232 & 233, Solo Offices, 343-347 King’s Road, North 
Point, Hong Kong

1 Centenary Square, Birmingham, United Kingdom, B1 1HQ

8 Canada Square, London, United Kingdom, E14 5HQ

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

156 Great Charles Street, Queensway, Birmingham, West 
Midlands, United Kingdom, B3 3HN

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

c/o Walkers Corporate Services Limited Walker House, 87 
Mary Street, George Town, Grand Cayman, Cayman Islands, 
KY1-9005

First & Second Floor, No.3 Nanshan Road, Pulandian , Dalian, 
Liaoning, China

394 HSBC Holdings plc Annual Report and Accounts 2021

Registered offices

36

37

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

160 Mine Lake CT, Ste 200, Raleigh, North Carolina, United 
States Of America, 27615-6417

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

Hansaallee 3, Düsseldorf, Germany, 40549

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

Claude Debussylaan 10 Office Suite 20, 1082MD, Amsterdam, 
Netherlands

1001, T2 Office Building, Qianhai Kerry Business Center, 
Qianhai Avenue, Nanshan Street, Qianhai Shenzhen-Hong 
Kong Cooperation Zone,, Shenzhen, Guangdong, China

Commerce House, Wickhams Cay 1, P.O. Box 3140, Road 
Town, Tortola, British Virgin Islands, VG1110

1 Queen's Road Central, Hong Kong

Hill House 1 Little New Street, London, United Kingdom, EC4A 
3TR

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

Level 21 Menara IQ, Lingkaran TRX, Tun Razak Exchange, 
Kuala Lumpur, Malaysia, 55188

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

9-11 Floors, NESCO IT Park Building No. 3 Western Express
Highway, Goregaon (East), Mumbai, India, 400063

Level 21 Menara IQ, Lingkaran TRX, Tun Razak Exchange, 
Kuala Lumpur, Malaysia, 55188

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
Rincón 391 Montevideo, CP 11.000, 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

Registered offices

Registered offices

73

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

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

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

8 Canada Square, London, United Kingdom, E14 5HQ

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

16 York Street, 6th Floor, Toronto, Ontario, Canada, M5J 0E6

Centre Ville 1341 Building - 4th Floor Patriarche Howayek 
Street (facing Beirut Souks), PO Box Riad El Solh, Lebanon, 
9597

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

80 Mill Street, Qormi, Malta, QRM 3101

Herrengasse 1-3, Wien, Austria, 1010

26 Gartenstrasse, Zurich, Switzerland, 8002

100

101

102

24th Fl. 97-99, Sec.2, Tunhwa S. Rd., Taipei, Taiwan, R.O.C., 
Taiwan

452 Fifth Avenue, New York, United States of America, 
NY10018

Bouchard 557, Piso 18°, Cdad. Autónoma de Buenos Aires, 
Argentina, 1106

103 Mareva House 4 George Street, Nassau, Bahamas
104

18th Floor, Tower 1, HSBC Centre 1 Sham Mong Road, 
Kowloon, Hong Kong

105

106

107

108

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

109 Woodbourne Hall, Road Town, Tortola, British Virgin Islands, 

P.O. Box 916

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

125

126

127

128

129

130

131

132

133

134

135

Craigmuir Chambers, PO Box 71, Road Town, Tortola, British 
Virgin Islands

300-885 West Georgia Street, Vancouver, British Columbia,
Canada, V6C 3E9

21 Farncombe Road Worthing, United Kingdom, BN11 2BW

Unit 1602 of 16/F,18/F, Unit 2101, 2113, 2113A, 2115 and 
2116 of 21/F, HSBC Building, 8 Century Avenue, China 
(Shanghai) Pilot Free Trade Zone, China

Arnold House St Julians Avenue, St Peter Port, Guernsey, GY1 
1WA

Plot No.312-878 Mezzanine Floor, Bldg. of Sheikh Hamdan Bin 
Rashid, Dubai Creek, Dubai, United Arab Emirates

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

The Corporation Trust Incorporated, 2405 York Road, Suite 
201, Lutherville Timonium, Maryland, United States of America

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

Büyükdere Caddesi No.128, Istanbul, Turkey, 34394

Quai des Bergues 9-17, Geneva, Switzerland, 1201

HSBC House Esplanade, St Helier, Jersey, JE1 1GT

5 rue Heienhaff, Senningerberg, Luxembourg, 1736

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

HSBC Building 7267 Olaya - Al Murrooj , Riyadh, Saudi Arabia, 
12283 - 2255

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

Kapelanka 42A, Krakow, Poland, 30-347

136 MB&H Corporate Services Ltd Mareva House, 4 George Street, 

Nassau, Bahamas

137

138

139

140

141

142

143

144

145

146

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

Level 19, HSBC Building, Shanghai ifc 8 Century Avenue 
Pudong, Shanghai, China

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

Oak House Hirzel Street, St Peter Port, Guernsey, GY1 2NP

Kings Meadow Chester Business Park, Chester, United 
Kingdom, CH99 9FB

HSBC Holdings plc Annual Report and Accounts 2021 395

Financial statementsNotes on the financial statements

Registered offices

Registered offices

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

185

186

187

Office 7, 35-37 Ludgate Hill, London, United Kingdom, EC4M 
7JN

9/F Amtel Bldg, 148 des Voeux Rd Central, Central, Hong Kong

3 avenue de l'Opera, Paris, France, 75001

Room 1303, 106 Feng Ze Dong Road, Nansha District, 
Guangzhou, Guangdong, China

17F, HSBC Building, Shanghai ifc 8 Century Avenue, Pudong, 
Shanghai, China

10th Floor 5 Churchill Place, London, England, London, United 
Kingdom, E14 5HU

C T Corporation System 1200 South Pine Island Road 
Plantation, Florida, United States of America, 33324

100 Town Square Place, Suite 201, Jersey City, NJ , United 
States of America, 07310

1-2 Royal Exchange Buildings Royal Exchange, London, United
Kingdom, EC3V 3LF

Precinct Building 4, Level 3, Dubai International Financial 
Centre, Dubai, United Arab Emirates, P.O. BOX 506553

75 Park Lane, Croydon, Surrey, United Kingdom, CR9 1XS

32 rue du Champ de Tir, Nantes, France, 44300

125 W 25th St. New York, New York, United States of 
America, 10001

Ernst-Schneider-Platz 1, Duesseldorf, Germany, 40212

Al Amir Abdulaziz Ibn Mossaad Ibn Jalawi Street, Riyadh, 
Saudi Arabia

3 More London Riverside, London, United Kingdom, SE1 2AQ

Office Block A, Bay Studios Business Park, Fabian Way, 
Swansea, Wales, United Kingdom, SA1 8QB

10 Earlsfort Terrace, Dublin, Ireland, D02 T380

34 Copse Wood Way, Northwood, Middlesex, United 
Kingdom, HA6 2UA

Business Bay, Wing 2, Tower B, Survey no 103, Hissa no. 2, 
Airport road, Yerwada Pune India 411006

147 World Trade Center 1, Floor 8-9 Jalan Jenderal Sudirman 

Kavling 29 - 31, Jakarta, Indonesia, 12920

148

149

150

151

5th Floor, World Trade Center 1, Jl. Jend. Sudirman Kav. 
29-31, Jakarta, Indonesia, 12920

Unit B02 20/F No. 168 Yin Cheng Zhong Road, Pilot Free Trade 
Zone, Shanghai, China, 200120

No.198-2 Chengshan Avenue (E), Rongcheng, China, 264300

Room 1303-13062 Marine Center Main Tower, 59 Linhai Rd, 
Nanshan District, Shenzhen, China

152 Woodbourne Hall, Road Town, Tortola, British Virgin Islands, 

P.O. Box 3162

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

25 Main St. P.O. Box 69, Grand Cayman, Cayman Islands, 
KY1-1107

No 5 Jalan Prof Khoo Kay Kim, Seksyen 13, Petaling Jaya, 
Selangor, Malaysia, 46200

Office 1.01 21 Gloucester Place, London, United Kingdom, 

157
158 o MUFG Fund Services (Bermuda) Limited The Belvedere 

c/

159

160

161

162

163

164

165

166

167

Building, 69 Pitts Bay Road, Pembroke, Bermuda, HM

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

Ground Floor, 25b Vyner Street, London, United Kingdom, E2 
9DG

Unit No. 208, 2nd Floor, Kanchenjunga Building 18, 
Barakhamba Road, New Delhi, India, 110001

65 Gresham Street 6th Floor, London, United Kingdom, EC2V 
7NQ

50 Raffles Place, #32-01 Singapore Land Tower, Singapore, 
048623

396 HSBC Holdings plc Annual Report and Accounts 2021

Shareholder information

Second Interim dividend for 2021

Interim dividends for 2022

Other equity instruments

2021 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

397

397

397

397

398

398

399

399

399

400

401

402

404

405

This section gives important information for our shareholders, including contact information. It also includes an overview of key 
abbreviations and terminology used throughout the Annual Report and Accounts.

A glossary of terms used in the Annual Report and Accounts can be found in the Investors section of www.hsbc.com.

Second interim dividend for 2021

The Directors have approved a second interim dividend for 2021 of $0.18 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 25 March 2022. The interim dividend will 
be paid in cash. 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, Bermuda1
Mailing of Annual Report and Accounts 2021 and/or Strategic Report 2021 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

22 February 2022

10 March 2022
11 March 2022

25 March 2022

13 April 2022

19 April 2022

28 April 2022

1 Removals to and from the Overseas Branch register of shareholders in Hong Kong will not be permitted on this date.

Interim dividends for 2022

The Group has reviewed whether it will revert to paying quarterly dividends and is currently not intending to pay quarterly dividends 
during 2022. The Group will continue to review whether to revert to paying quarterly dividends in future years, and a further update will 
be given at or ahead of the 2022 results announcement in February 2023. 

For the financial year 2021, we are at the lower end of our target dividend payout ratio range of between 40% and 55% of reported 
earnings per ordinary share (‘EPS’), driven by ECL releases and higher restructure costs. The dividend policy has the flexibility to adjust 
EPS for non-cash significant items such as goodwill or intangibles impairments and may be supplemented from time to time by buy-
backs or special dividends, 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.  

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. 

HSBC issued $1,000m 4.000% and $1,000m 4.700% Perpetual Contingent Convertible Securities on 9 March 2021.  

2021 Annual General Meeting

With the exception of the shareholder requisitioned Resolution 16, which the Board recommended that shareholders vote against, all 
resolutions considered at the 2021 Annual General Meeting held at 11:00am on 28 May 2021 at Queen Elizabeth Hall, Southbank Centre, 
Belvedere Road, London SE1 8XX, UK were passed on a poll.

HSBC Holdings plc Annual Report and Accounts 2021 397

Additional information 
 
Additional information

Earnings releases and interim results

First and third quarter results for 2022 will be released on 26 April 2022 and 25 October 2022 respectively. The interim results for the six 
months to 30 June 2022 will be issued on 1 August 2022.  

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 the Annual Report and Accounts 2021 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.

398 HSBC Holdings plc Annual Report and Accounts 2021

Chinese translation

A Chinese translation of the Annual Report and Accounts 2021 will be available upon request after 25 March 2022 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.

《2021年報及賬⽬》備有中譯本,各界⼈⼠可於2022年3⽉25⽇之後,向上列股份登記處索閱。

閣下如欲於⽇後收取相關文件的中譯本,或已收到本文件的中譯本但不希望繼續收取有關譯本,均請聯絡
股份登記處。

Stock symbols

HSBC Holdings ordinary shares trade under the following stock symbols:

London Stock Exchange

Hong Kong Stock Exchange

*HSBC’s Primary market

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 2021 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 
2021 by 31 December 2022. This information will be available on HSBC’s website: www.hsbc.com/tax.

HSBC Holdings plc Annual Report and Accounts 2021 399

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 2021 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. From 6 April 2022, these rates 
will each be increased by 1.25% to 8.75%, 33.75% and 39.35% 
respectively.

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

There were no scrip dividends issued during the year. As 
announced on 23 February 2021, the Group has decided to 
discontinue the scrip dividend option.    

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 be applied to a disposal of those shares in 
December 2017. If in doubt, shareholders are recommended to 
consult their professional advisers.

400 HSBC Holdings plc Annual Report and Accounts 2021

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 
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 the Annual Report and 
Accounts 2021 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 information reporting and backup withholding tax

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 US 
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 US 
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 US 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 88, 
taken together with other information relating to ESG issues 
included in this Annual Report and Accounts 2021, aims to provide 
key ESG information and data relevant to our operations for the 
year ended 31 December 2021. The data is compiled for the 
financial year 1 January to 31 December 2021 unless otherwise 
specified. Measurement techniques and calculations are explained 
next to data tables where necessary. There are no significant 
changes from the previous reporting period in terms of scope, 
boundary or measurement of our reporting of ESG matters. Where 
relevant, rationale is provided for any restatement of information 
or data that has been previously published. 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’) and under LR9.8.6R(8) of the 
Financial Conduct Authority’s (‘FCA’) Listing Rules. We will 
continue to develop and refine our reporting and disclosures on 
ESG matters in line with feedback received from our investors and 
other stakeholders, and in view of our obligations under the ESG 
Guide and the FCA’s Listing Rules.

ESG Guide

We comply with the ‘comply or explain’ provisions in the ESG 
Guide, save for certain items, which we describe in more detail 
below:
• A1(b) on relevant laws/regulations relating to air and 

greenhouse gas emissions, discharges into water and land, and 
generation of hazardous and non-hazardous waste: Taking into 
account the nature of our business, we do not believe that 
there are relevant laws and regulations in these areas that have 
significant impacts on HSBC.

• A1.3 on total hazardous waste produced, A1.4 on total non-

hazardous waste produced: Taking into account the nature of 
our business, we do not consider hazardous waste to be a 
material issue for our stakeholders. As such, we report only on 
total waste produced, which includes hazardous and non-
hazardous waste.

• A1.6 on handling hazardous and non-hazardous waste: Taking 

into account the nature of our business, we do not consider this 
to be a material issue for our stakeholders. Notwithstanding 
this, we continue to focus on the reduction and recycling of all 
waste. Building on the success of our previous operational 
environmental strategy, we are identifying key opportunities 
where we can lessen our wider environmental impact, 
including waste management. For further details, please see 
our ESG review on page 51.

• A2.4 on sourcing water issue: Taking into account the nature of 
our business, we do not consider this to be a material issue for 

HSBC Holdings plc Annual Report and Accounts 2021 401

Additional informationAdditional information

our stakeholders. Notwithstanding this, we have implemented 
measures to further reduce water consumption through the 
installation of flow restrictors, auto-taps and low or zero flush 
sanitary fittings and continue to track our water consumption.

• A2.5 on packaging material, B2.2 on lost days due to work 

injury, B6(b) on issues related to health and safety and labelling 
relating to products and services provided, B6.1 on percentage 
of total products sold or shipped subject to recalls for safety 
and health reasons and B6.4 in recall procedures: Taking into 
account the nature of our business, we do not consider these to 
be material issues for our stakeholders.

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 44 for further information on how we determine what 
matters are material to our stakeholders.

TCFD recommendations and recommended 
disclosures

As noted on page 19, we have considered our ‘comply or explain’ 
obligation under the FCA’s Listing Rules, and confirm that we have 
made disclosures consistent with the TCFD Recommendations 
and Recommended Disclosures in this Annual Report and 
Accounts 2021 save for certain items, which we describe below:

Targets setting 

Metrics and targets (c) relating to short-term targets: Given that 
climate scenarios are mainly focused on medium- to long-term 
horizons, rather than short term, we have set interim 2030 targets 
for on-balance sheet financed emissions for the oil and gas, and 
power and utilities sectors. HSBC intends to review the financed 
emissions baseline and targets annually, where relevant, to help 
ensure that they are aligned with market practice and current 
climate science.

Impacts on financial planning and performance

Strategy (b) relating to financial planning and performance: We do 
not currently fully disclose the impacts of climate-related issues on 
financial planning, how these serve as an input to the financial 
planning process, the impact of climate-related issues on our 
financial performance (for example, revenues and costs) and 
financial position (for example, assets and liabilities), in each case 
due to transitional challenges including data and system 
limitations.

Metrics and targets (a) relating to internal carbon prices and 
climate-related opportunities metrics: We do not currently fully 
disclose the proportion of revenue or proportion of assets, or other 
business activities aligned with climate-related opportunities, 
including revenue from products and services, forward-looking 
metrics consistent with our business or strategic planning time 
horizons, or internal carbon prices, in each case due to transitional 
challenges including data and system limitations.

We expect the data and system limitations related to financial 
planning and performance, internal carbon prices and climate-
related opportunities metrics to be addressed in the medium term 
as more reliable data becomes available and technology solutions 
are implemented. 

Impacts of transition and physical risk

Strategy (c) relating to quantitative scenario analysis: We do not 
currently fully disclose the impacts of transition and physical risk 
quantitatively, due to transitional challenges including data 
limitations and evolving science and methodologies.

Metrics and targets (a) relating to detailed climate-related risk 
exposure metrics for retail and wholesale: We do not fully disclose 
metrics used to assess the impact of climate-related risks on retail 
lending, parts of wholesale lending and other financial 
intermediary business activities (specifically credit exposure, 
equity and debt holdings, or trading positions, each broken down 
by industry, geography, credit quality, average tenor). This is due 
to transitional challenges including data limitations.

Metrics and targets (c) on targets related to physical risk: We do 
not currently disclose targets used to measure and manage 

402 HSBC Holdings plc Annual Report and Accounts 2021

physical risk. This is due to transitional challenges including data 
limitations.

We expect the data limitations related to quantitative scenario 
analysis, specific risk metrics and physical risk targets to be 
addressed in the medium term as more reliable data becomes 
available and technology solutions are implemented.

 Scope 3 emissions disclosure

Metrics and targets (b) relating to scope 3 emissions metrics: We 
currently disclose partial scope 3 greenhouse gas emissions 
including business travel and financed emissions. In relation to 
financed emissions, we are disclosing scope 3 greenhouse gas 
emissions for the oil and gas, and the power and utilities sectors. 
Future disclosure on scope 3 financed emissions (customers) and 
supply chain emissions (suppliers), and related risks is reliant on 
both our customers and suppliers publicly disclosing their carbon 
emissions and related risks. We aim to disclose financed 
emissions for additional sectors by 2023. 

Our approach to disclosure of financed emissions for additional 
sectors can be found on: www.hsbc.com/who-we-are/esg-and-
responsible-business/esg-reporting-centre.

Other matters

Strategy (b) relating to acquisitions/divestments and access to 
capital: We have considered the impact of climate-related issues 
on our businesses, strategy, and financial planning, but not 
specifically in relation to acquisitions/divestments or access to 
capital. Due to transitional challenges such as process limitations, 
we do not disclose the climate-related impact in these areas. We 
will aim to further enhance our processes in relation to 
acquisitions/divestments and access to capital in the medium 
term. 

Metrics and targets (c) relating to water usage target: We have 
described the targets used by the organisation to manage climate-
related risks and opportunities and performance against targets. 
However, taking into account the nature of our business, we do 
not consider water usage to be a material target for our business 
and, therefore, we have not included a target in this year’s 
disclosure.

With respect to our obligations under LR9.8.6R(8) of the FCA’s 
Listing Rules, as part of considering what to measure and publicly 
report, we perform an assessment to ascertain the appropriate 
level of detail to be included in the climate-related financial 
disclosures that are set out in our Annual Report and Accounts. 
Our assessment takes into account factors such as the level of our 
exposure to climate-related risks and opportunities, the scope and 
objectives of our climate-related strategy, transitional challenges, 
and the nature, size and complexity of our business. See ‘How we 
decide what to measure’ on page 44 for further information.

Cautionary statement regarding forward-
looking statements

The Annual Report and Accounts 2021 contains certain forward-
looking statements with respect to HSBC’s financial condition; 
results of operations and business, including the strategic 
priorities; financial, investment and capital targets; and ESG 
targets, commitments and ambitions described herein. 

Statements that are not historical facts, including statements 
about HSBC’s beliefs and expectations, are forward-looking 
statements. Words such as ‘may’, ‘will’, ‘should’, ‘expects’, 
‘targets’, ‘anticipates’, ‘intends’, ‘plans’, ‘believes’, ‘seeks’, 
‘estimates’, ‘potential’ and ‘reasonably possible’, or the negative 
thereof, other variations thereon or 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 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 new 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 may continue to have adverse impacts on our income 
due to lower lending and transaction volumes, lower wealth 
and insurance manufacturing revenue, and volatile 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); potential changes in HSBC’s 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 
diplomatic tensions, including between China and the US, the 
UK, the EU, India and other countries, and developments in 
Hong Kong and Taiwan, alongside other potential areas of 
tension, which may affect the Group by creating regulatory, 
reputational and market risks; the efficacy of government, 
customer, and HSBC's actions in managing and mitigating ESG 
risks, in particular climate risk, nature-related risks and human 
rights risks, each of which can impact HSBC both directly and 
indirectly through our customers and which may result 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 
discontinuation of certain key Ibors and the development of 
near risk-free benchmark rates, as well as the transition of 
legacy Ibor contracts to near risk free benchmark rates, which 
exposes HSBC to material execution risks, and increases some 
financial and non-financial risks; 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; changes to tax laws and tax rates 
applicable to HSBC, including the 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 of assets and changes in legislation relating to 
foreign ownership; the UK’s relationship with the EU following 
the UK’s withdrawal from the EU, which may continue to be 
characterised by uncertainty, particularly with respect to the 
regulation of financial services,  despite the signing of the 
Trade and Cooperation Agreement between the UK and the EU; 
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 and ambitions (including with respect to 
the commitments set forth in our thermal coal phase-out policy 
and our targets to reduce our on-balance sheet financed 
emissions in the oil and gas and power and utilities sectors), 
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 judgemental post model adjustments, 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, including the 
implementation of IFRS 17 ‘Insurance Contracts’, which may 
have a material impact on the way we prepare our financial 
statements and (with respect to IFRS 17) may negatively affect 
the profitability of HSBC’s insurance business; 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 and 
climate-related products consistent with the evolving 
expectations of our regulators, and our capacity to measure the 
climate impact from our financing activity (including as a result 
of data limitations and changes in methodologies), which may 
affect our ability to achieve our climate ambition, our targets to 
reduce financed emissions in our oil and gas and power and 
utilities portfolio and the commitments set forth in our thermal 
coal phase-out policy, and increase the risk of greenwashing. 
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; 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 
124 to 131. 

HSBC Holdings plc Annual Report and Accounts 2021 403

Additional informationAdditional information

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.

404 HSBC Holdings plc Annual Report and Accounts 2021

Abbreviations

Currencies

£

CA$

€

HK$

MXN

RMB

SGD

$

A

ABS¹

ADR

ADS

AGM

AI

AIEA

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 and Liability Management Committee

Anti-money laundering

E

EAD¹

EBA

EC

ECB

ECL

EEA

Eonia

EPC

EPS

ESG

EU

Euribor

EVE

F

Exposure at default

European Banking Authority

European Commission

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

Energy performance certificate

Earnings per ordinary share

Environmental, social and governance

European Union

Euro interbank offered rate

Economic value of equity

AML DPA

Five-year deferred prosecution agreement with the US 
Department of Justice, entered into in December 2012

FAST-Infra

Finance to Accelerate the Sustainable Transition-
Infrastructure

ASEAN

Association of Southeast Asian Nations

AT1

B

Additional tier 1

Basel Committee Basel Committee on Banking Supervision

Basel II¹

Basel III¹

BGF

BoCom

BoE

Bps¹

BVI

C

CAPM

CDS¹

CEA

CET1¹

CGUs

CMB

CMC

CODM

COSO

CP¹

CRD IV¹

CRR¹

CRR II¹

CSA

CSM

CVA¹

D

2006 Basel Capital Accord

Basel Committee’s reforms to strengthen global capital and 
liquidity rules

Business Growth Fund, an investment firm that provides 
growth capital for small and mid-sized businesses in the UK 
and Ireland

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

Capital Requirements Regulation and Directive

Customer risk rating

Revised Capital Requirements Regulation and Directive, as 
implemented

Credit support annex

Contractual service margin

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

US Department of Justice

Days past due

Discretionary participation feature of insurance and 
investment contracts

Debt valuation adjustment

FCA

FFVA

FPA

FRB

FRC

FSB

FSCS

FTE

FTSE

FVOCI¹

FVPL¹

FX

FX DPA

G

GAAP

GAC

GBM

GDP

GEC

GLCM

GMP

GPSP

GRC

Group

GTRF

H

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

Foreign exchange

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

Group Executive Committee

Global Liquidity and Cash Management

Guaranteed minimum pension

Group Performance Share Plan

Group Risk Committee

HSBC Holdings together with its subsidiary undertakings

Global Trade and Receivables Finance

Hang Seng Bank Hang Seng Bank Limited, one of Hong Kong’s largest banks

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

HSBC Bank Middle East Limited

HSBC Bank USA HSBC Bank USA, N.A., HSBC’s retail bank in the US

HSBC Canada

HSBC 
Continental 
Europe

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 Holdings plc Annual Report and Accounts 2021 405

Additional informationInternal capital adequacy assessment process

Reverse repo

Security purchased under commitments to sell

Additional information

HSBC Finance

HSBC Finance Corporation, the US consumer finance 
company (formerly Household International, Inc.)

HSBC Holdings

HSBC Holdings plc, the parent company of HSBC

HSBC Private 
Bank (Suisse)

HSBC Private Bank (Suisse) SA, HSBC’s private bank in 
Switzerland

HSBC UK

HSBC USA

HSI

HSSL

HTIE

I

IAS

IASB

IBA

Ibor

ICAAP

IEA

IFRSs

ILAAP

IMA

IMM

IRB¹

ISDA

J

JV

K

KMP

L

LCR

LGBT+

LGD¹

Libor

Long term

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

International Energy Agency

International Financial Reporting Standards

Internal liquidity adequacy assessment process

Internal model approach

Internal model method

Internal ratings-based

International Swaps and Derivatives Association

Joint venture

Key Management Personnel

Liquidity coverage ratio

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

For our strategic goals, we define long term as five to six 
years, commencing 1 January 2020

Long-term incentive

Loan to value

Mainland China

People’s Republic of China excluding Hong Kong and Macau

Medium term

For our strategic goals, we define medium term as three to 
five years, commencing 1 January 2020

MENA

MREL

MRT¹

MSS

N

Middle East and North Africa

Minimum requirement for own funds and eligible liabilities

Material Risk Taker

Markets and Securities Services, HSBC’s capital markets and 
securities services businesses in Global Banking and Markets

Net operating 
income

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

NGO

NII

NIM

NPS

NSFR

NYSE

NZBA

O

OCI

OECD

OTC¹

P

PACTA

PBT

PCAF

PD¹

Non-governmental organisation

Net interest income

Net interest margin

Net promoter score

Net stable funding ratio

New York Stock Exchange

Net-Zero Banking Alliance

Other comprehensive income

Organisation of Economic Co-operation and Development

Over-the-counter

Paris Agreement Capital Transition Assessment

Profit before tax

Partnership for Carbon Accounting Financials

Probability of default

406 HSBC Holdings plc Annual Report and Accounts 2021

Performance 
shares¹

Ping An

POCI

PPI

PRA

PRC

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

Repo¹

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

Sale and repurchase transaction

RFR

RMM

RNIV

RoE

RoTE

RWA¹

S

SABB

SAPS

SASB

SBTi

SDG

SEC

Risk-free rate

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

Sustainability Accounting Standards Board

Science Based Targets initiative

United Nation’s Sustainable Development Goals

Securities and Exchange Commission (US)

ServCo group

Separately incorporated group of service companies 
established in response to UK ring-fencing requirements

Sibor

SIC

SME

SOFR

Solitaire

Sonia

SPE¹

T

TCFD¹

THBFIX

TNFD

TSR¹

U

UAE

UK

UN

US

V

VaR¹

VIU

W

WEF

WPB

Singapore interbank offered rate

Securities investment conduit

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

Task Force on Climate-related Financial Disclosures

Thai Baht Interest Rate Fixing

Taskforce on Nature-related Financial Disclosures

Total shareholder return

United Arab Emirates

United Kingdom

United Nations

United States of America

Value at risk

Value in use

World Economic Forum

Wealth and Personal Banking, a global business

1  A full definition is included in the glossary to the Annual Report and 
Accounts 2021 which is available at www.hsbc.com/investors.

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 2022

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)

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waste. Pulps used are totally chlorine-free.  

The FSC® recycled logo identifies a paper that contains 100% post-
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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