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HSBC

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FY2022 Annual Report · HSBC
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HSBC Holdings plcAnnual Report and  Accounts 2022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 and strategy  
on pages 4 and 11.

Contents

Strategic report

Highlights

Group Chairman’s statement 
Group Chief Executive’s review

2 
4  Who we are
6 
8 
11  Our strategy
14 
20  Board decision making and 

ESG overview

engagement with stakeholders 
(Section 172 (1) statement) 

24  Remuneration
Financial overview
26 
31  Global businesses
38  Risk overview
42 

Long-term viability and going 
concern statement

Environmental, social and 
governance (‘ESG’) review

44  Our approach to ESG
46  Environmental
73  Social
85  Governance

Financial review

98   Financial summary
109   Global businesses and 

geographical regions
128   Reconciliation of alternative 
performance measures

Risk review

132   Our approach to risk
135   Top and emerging risks
142   Areas of special interest
142   Our material banking risks

Corporate governance report

240   Biographies of Directors and 

senior management

259   Board committees
276   Directors’ remuneration report

Financial statements

313   Independent auditors’ report
324   Financial statements
335   Notes on the financial statements

Additional information

418   Shareholder information
427   Abbreviations

Our approach to ESG reporting
We embed our ESG reporting and Task Force 
on Climate-related Financial Disclosures 
(‘TCFD’) within our Annual Report and 
Accounts. Our TCFD disclosures are 
highlighted with the following symbol:  TCFD  

This Strategic Report was approved by the 
Board on 21 February 2023. 

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 29.

None of the websites referred to in this  
Annual Report and Accounts 2022 for the year 
ended 31 December 2022 (including where a 
link is provided), and none of the information 
contained on such websites, are incorporated 
by reference in this report.

Cover image: Opening up a world of opportunity
Our cover features Stitt, one of HSBC’s two bronze lions. Touching the lion’s  
paw was said to bring good luck, and that tradition continues today. The lions, 
Stephen and Stitt, designed by British sculptor Henry Poole, were commissioned 
to celebrate the opening of the newly-rebuilt HSBC building on the Bund in 
Shanghai in 1923. Stephen and Stitt represent the strength and endurance that  
is part of our heritage. Loyal and proud, they stand guard outside our offices in 
Hong Kong, London and Shanghai, and symbolise good fortune and stability. 

  @HSBC

linkedin.com/company/hsbc
facebook.com/HSBC

HSBC Holdings plc Annual Report and Accounts 2022

HSBC Holdings plcAnnual Report and  Accounts 2022 
Performance in 2022 

HSBC is one of the world’s leading 
international banks. 

We have a clear strategy to deliver revenue  
and profit growth, enhance customer service 
and improve returns to shareholders.

Delivery against our 
financial targets

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

 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 can be found on page 26.

Return on average tangible equity

Common equity tier 1 capital ratio

9.9%

Target: ≥12% from 2023 onwards.
(2021: 8.3%)

Adjusted operating expenses

$30.5bn

Target: 2022 adjusted operating expenses 
broadly stable compared with 2021.
(2021: $30.1bn)

Gross risk-weighted asset reduction

$128bn

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

14.2%

Target: >14%, managing in the range of  
14% to 14.5% in the medium term; and 
manage the range down further long term.
(2021: 15.8%)

Dividend per share

$0.32

2022 payout ratio: 44%
Updated target: dividend payout ratio  
of 50% for 2023 and 2024, excluding  
material significant items.
Previous target: sustainable cash dividends 
with a payout ratio of 40% to 55% from  
2022 onwards.

Strategic performance 
indicators 

Our strategy supports our ambition of being 
the preferred international financial partner  
for our clients. 

We are committed to building a business  
for the long term, developing relationships  
that last. 

 Read more on our strategic progress on page 11.
 Read more on how we set and define our 
environmental, social and governance metrics  
on page 16.
 Read more on our financed emissions scope, 
methodology and terminology on page 50,  
and our definition of sustainable finance and 
investment on page 57.

Capital allocation to Asia 

Sustainable finance and investment

47%

Tangible equity as a percentage of the  
Group’s (excluding associates, holding 
companies, and consolidation adjustments).
(2021: 42%) 

Net new invested assets

$80bn

Generated in 2022, of which $59bn were in Asia.

Gross cost saves 

$5.6bn

Delivered from our cost-reduction programme, 
with an expected additional $1bn in 2023, and 
a total programme cost of $6.5bn.

$210.7bn 

Cumulative total provided and facilitated  
since January 2020.
(2021: $126.7bn)

Net zero in our own operations

58.5%

Cumulative reduction in absolute greenhouse 
gas emissions from 2019 baseline. 
(2021: 50.3%)

Financed emissions targets 

8 sectors

Number of sectors where we have set 
on-balance sheet financed emissions targets.

Gender diversity

33.3%

Women in senior leadership roles.
(2021: 31.7%)

HSBC Holdings plc Annual Report and Accounts 2022

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Strategic reportStrategic report

Highlights

Financial performance reflected net interest income growth and cost discipline, 
and we continued to make progress against our four strategic pillars. 

Financial performance (vs 2021)

 – Reported profit before tax fell

 – Reported expected credit losses and

by $1.4bn to $17.5bn, including an
impairment on the planned sale of our retail
banking operations in France of $2.4bn.
Adjusted profit before tax increased
by $3.4bn to $24.0bn. Reported profit
after tax increased by $2.0bn to
$16.7bn, including a $2.2bn credit arising
from the recognition of a deferred tax asset.

 – Reported revenue increased by 4% to
$51.7bn, driven by strong growth in net
interest income, with increases in all of our
global businesses, and higher revenue from
Global Foreign Exchange in Global Banking
and Markets (‘GBM’). This was in part
offset by a $3.1bn adverse impact of foreign
currency translation differences, the
impairment on the planned sale of our retail
banking operations in France and adverse
movements in market impacts in insurance
manufacturing in Wealth and Personal
Banking (‘WPB‘). In addition, fee income
fell in both WPB and GBM. Adjusted
revenue increased by 18% to $55.3bn.

 – Net interest margin (‘NIM’) of

1.48% increased by 28 basis points
(‘bps’), reflecting interest rate rises.

other credit impairment charges (‘ECL’)
were $3.6bn, including allowances to
reflect increased economic uncertainty, 
inflation, rising interest rates and supply chain
risks, as well as the ongoing developments
in mainland China‘s commercial real estate
sector. These factors were in part offset
by the release of most of our remaining
Covid-19-related reserves. This compared 
with releases of $0.9bn in 2021. ECL charges
were 36bps of average gross loans and
advances to customers.

 – Reported operating expenses decreased
by $1.3bn or 4% to $33.3bn, reflecting
the favourable impact of foreign currency
translation differences of $2.2bn and ongoing
cost discipline, which were in part offset by 
higher restructuring and other related costs,
increased investment in technology and
inflation. Adjusted operating expenses
increased by $0.4bn or 1.2% to
$30.5bn, including a $0.2bn adverse
impact from retranslating the 2022 results
of hyperinflationary economies at
constant currency.

 – Customer lending balances fell by
$121bn on a reported basis. On an
adjusted basis, lending balances fell by
$66bn, reflecting an $81bn reclassification
of loans, primarily relating to the planned
sale of our retail banking operations in
France and the planned sale of our banking
business in Canada, to assets held for sale.
Growth in mortgage balances in the UK and
Hong Kong mitigated a reduction in term
lending in Commercial Banking (‘CMB’)
in Hong Kong.

 – Common equity tier 1 (‘CET1’) capital

ratio of 14.2% reduced by 1.6
percentage points, primarily driven by a
decrease of a 0.8 percentage point from
new regulatory requirements, a reduction
of a 0.7 percentage point from the fall in the
fair value through other comprehensive
income (‘FVOCI’) and a 0.3 percentage
point fall from the impairment following
the reclassification of our retail banking
operations in France to held for sale. Capital
generation was mostly offset by an increase
in risk-weighted assets (‘RWAs’) net of
foreign exchange translation movements.

 – The Board has approved a second interim

dividend of $0.23 per share, making a
total for 2022 of $0.32 per share.

Outlook

 – The impact of our growth and

transformation programmes, as well
as higher global interest rates, give us
confidence in achieving our return on
average tangible equity (‘RoTE‘) target
of at least 12% for 2023 onwards.

 – Our revenue outlook remains positive.

Based on the current market consensus
for global central bank rates, we expect
net interest income of at least $36bn in
2023 (on an IFRS 4 basis and retranslated for
foreign exchange movements). We intend to
update our net interest income guidance at or
before our first quarter results to incorporate
the expected impact of IFRS 17 ‘Insurance
Contracts’.

 – While we continue to use a range of 30bps
to 40bps of average loans for planning our
ECL charge over the medium to long term,
given current macroeconomic headwinds,
we expect ECL charges to be around
40bps in 2023 (including lending balances
transferred to held for sale). We note recent

favourable policy developments in 
mainland China’s commercial real  
estate sector and continue to monitor 
events closely. 

 – We retain our focus on cost discipline and 

will target 2023 adjusted cost growth of
approximately 3% on an IFRS 4 basis. This
includes up to $300m of severance costs in 
2023, which we expect to generate further 
efficiencies into 2024. There may also be an 
incremental adverse impact from retranslating
the 2022 results of hyperinflationary 
economies at constant currency. 

 – We expect to manage the CET1 ratio
within our medium-term target range
of 14% to 14.5%. We intend to continue to
manage capital efficiently, returning excess
capital to shareholders where appropriate.

 – Given our current returns trajectory, we

are establishing a dividend payout ratio
of 50% for 2023 and 2024, excluding
material significant items, with consideration 
of buy-backs brought forward to our first

quarter results in May 2023, subject to 
appropriate capital levels. We also intend  
to revert to paying quarterly dividends from 
the first quarter of 2023.

 – Subject to the completion of the sale of our
banking business in Canada, the Board’s
intention is to consider the payment
of a special dividend of $0.21 per share
as a priority use of the proceeds
generated by completion of the
transaction. A decision in relation to any
potential dividend would be made following
the completion of the transaction, currently
expected in late 2023, with payment
following in early 2024. Further details in
relation to record date and other relevant
information will be published at that time.
Any remaining additional surplus capital
is expected to be allocated towards
opportunities for organic growth and
investment alongside potential share
buy-backs, which would be in addition to
any existing share buy-back programme.

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HSBC Holdings plc Annual Report and Accounts 2022

Highlights

Strategic progress

 – We have made progress in implementing

 – As part of our efforts to improve the

our transformation programme,
establishing a platform for future
growth.

 – During 2022, we took further actions to

reshape the Group. In November 2022,
we announced the planned sale of
our banking business in Canada, which
is expected to be completed in late
2023, subject to regulatory and
governmental approvals. In addition,
we are in the process of disposing of
our retail banking operations in France, as
well as exiting our businesses in Greece
and Russia, subject to regulatory and
governmental approvals.

returns profile of the Group, we surpassed
our gross RWA reduction target,
generating cumulative gross RWA
reductions of $128bn since the start
of the programme in 2020.

 – Our cost-reduction programme continued
to make progress, with a further $2.3bn
of gross cost savings recognised in 2022.
Since the start of the programme in
2020, we have realised gross savings
of $5.6bn, with cost to achieve spend
of $6.5bn. While our three-year cost to
achieve programme has now concluded,
the Group-wide focus on cost discipline
remains resolute.

 – We have continued to invest and grow
in the areas in which we are strongest.
In our Wealth business in Asia, we
attracted net new invested assets
of $59bn in 2022.

ESG highlights

Transition to net zero
 – We have set interim 2030 targets for

on-balance sheet financed emissions
for eight sectors. These include six
sectors for which we have reported
2019 and 2020 emissions: oil and gas;
power and utilities; cement; iron, steel and
aluminium; aviation; and automotive. We
have also set targets for thermal coal power
and thermal coal mining. We recognise that
methodologies and data for measuring
emissions will continue to evolve.

 – We published an updated energy policy,

which is an important mechanism to help
phase down the financed emissions of
our energy portfolio in line with a 1.5ºC
pathway. We also updated our thermal
coal phase-out policy with new targets
to reduce absolute on-balance sheet
financed emissions from thermal
coal mining and coal-fired power,
and extended the policy to exclude
finance for the specific purposes of
new metallurgical coal mines.

 – Since 2020, we have provided and

facilitated $210.7bn of sustainable
finance and investment, an increase
of $84.2bn in the past year.

 – Within our own operations, we have made
a 58.5% cumulative reduction in our
absolute greenhouse gas emissions
from a 2019 baseline. We also published
supply chain emissions as part of our
scope 3 disclosures for the first time.

Act responsibly
 – We conducted a review of our salient

human rights issues, including
stakeholder consultation with non-
governmental organisations (‘NGOs’)
and potentially affected groups.

 – We aim to be a top-three bank for customer
satisfaction. While our net promoter scores
have improved in many of our key markets,
we have more work to do to improve our
position relative to peers, as some have
improved their performance more quickly.

 – We have launched a sustainable

procurement mandatory procedure for
our employees and a new supplier code
of conduct to help ensure our sustainability
objectives are embedded in the way we
operate and do business with suppliers.

Build inclusion and resilience
 – Having surpassed our 2020 target to reach
30% women in senior leadership roles, we
have made progress towards our goal
to achieve 35% by 2025, with 33.3%
achieved in 2022. We continue to make
progress towards the target we set in 2020
to at least double the number of Black senior
leaders within five years.

 – We have stepped up efforts to support
customers in the face of inflation and
the rising cost of living, particularly in the
UK. We have focused on early intervention,
using data analysis to identify potentially
impacted customers in our WPB and CMB
businesses, signpost to relevant resources,
and provide tailored support.

 – We are working to make the banking

experience more accessible in both physical
and digital spaces. We are committed to
ensuring that our digital channels are
usable by everyone, regardless of
ability. The introduction of features such
as safe spaces, quiet hours and talking
ATMs are helping to make our physical
spaces more accessible as well.

HSBC Holdings plc Annual Report and Accounts 2022

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Strategic reportStrategic report

Who we are

HSBC is one of the largest banking and financial services organisations in the world. 
We aim to create long-term value for our shareholders and capture opportunity. 

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

Our strategy

Our strategy supports our ambition of being the preferred international financial 
partner for our clients, centred around four key areas.

Focus on our 
strengths 
In each of our global 
businesses, we continue 
to focus on areas where 
we are strongest and 
have opportunities  
to grow.

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. 

For further details on our strategy, see pages 11 to 13.

Energise for growth
We are building  
a dynamic and  
inclusive culture,  
and empowering our 
people by helping them 
develop future skills.

Transition to net zero
We are helping the 
transition to a net  
zero economy by 
transforming ourselves, 
and supporting our 
customers to make  
their own transitions.

Our global reach

Our global businesses serve around 39 million customers worldwide 
through a network that covers 62 countries and territories.

Our customers range from individual savers  
and investors to some of the world’s biggest 
companies, governments and international 
organisations. We aim to connect them  
to opportunities and help them to achieve  
their ambitions.

Assets of

$3.0tn

Approximately

39m

Customers bank with us1

Operations in

We employ approximately

62

219,000

Countries and territories

Full-time equivalent staff

 For further details of our customers and approach to 
geographical information, see page 108. 

1  Our customer numbers exclude those acquired through 

our purchase of L&T Investment Management.

4

HSBC Holdings plc Annual Report and Accounts 2022

 
 
Who we are

Our global 
businesses

We serve our customers through three global businesses.

On pages 31 to 37 we provide  
an overview of our performance 
in 2022 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. 

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. 

For further details, see page 31.

For further details, see page 33.

For further details, see page 35.

Adjusted revenue by 
global business1

Wealth and Personal Banking

Commercial Banking

Global Banking and Markets

44%

29%

27%

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 $596m in 2022.

Our stakeholders

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.

Customers

Employees

Investors

Communities Regulators and 

Suppliers

governments

For further details of how we are engaging with our stakeholders, see page 15.
Our section 172 statement, detailing our Directors’ responsibility to stakeholders, can be found on page 20.

HSBC Holdings plc Annual Report and Accounts 2022

5

Strategic reportStrategic report

Group Chairman’s statement

As we signalled at our interim results, we are 
committed to ensuring our shareholders share 
the benefits of our improved performance. The 
Board approved a second interim dividend for 
2022 of $0.23 per share, bringing the full year 
dividend for 2022 to $0.32 per share. We are 
establishing a dividend payout ratio of 50%  
of reported earnings per share for 2023 and 
2024, excluding material significant items, and 
we aim to restore the dividend to pre-Covid-19 
levels as soon as possible. We also intend to 
return to paying quarterly dividends from the 
start of 2023.

Subject to completion of the planned sale  
of our banking business in Canada, the 
Board’s intention is to consider the payment  
of a special dividend of $0.21 per share as  
a priority use of the proceeds generated.  
A decision in relation to any potential dividend 
would be made following the completion  
of the transaction, currently expected in  
late 2023, with payment following in early 
2024. Any remaining additional surplus  
capital is expected to be allocated towards 
opportunities for organic growth and 
investment alongside share buy-backs,  
which would be in addition to any existing 
share buy-back programme. 

Board operations
In 2022, the Board met in person in London, 
Hong Kong, New York and Riyadh – on each 
occasion also undertaking a wide range of 
engagements with clients, colleagues, 
government officials and regulators. The 
importance of engaging with our teams was 
also underlined by the appointment of José 
(Pepe) Meade as Board member with specific 
responsibility for employee liaison. At the 
same time as holding some in-person 
meetings, the continued use of virtual 
meetings enabled us to retain the benefits  
of greater efficiency and reduced costs.

At the 2022 Annual General Meeting, Irene 
Lee and Pauline van der Meer Mohr stepped 
down from the Board. I am enormously 
grateful to them for their important and 
valuable contributions to the Board, the 
committees and the subsidiary entities on 
which they have served. Irene remains an 
independent non-executive Director of The 
Hongkong and Shanghai Banking Corporation 
Limited and independent non-executive  
chair of Hang Seng Bank Limited. Geraldine 
Buckingham joined the Board as an 
independent non-executive Director on 1 May.

Following Ewen Stevenson’s departure, 
Georges Elhedery became Group Chief 
Financial Officer and joined the Board on  
1 January 2023. On behalf of the Board, I 
would like to again thank Ewen for all that  
he has done for the bank. His leadership, 
financial expertise and operational rigour  
have been invaluable to HSBC, and he  
leaves with our very best wishes.

Mark E Tucker
Group Chairman

The global economy remains volatile, but our strategy is 
delivering improved returns for shareholders and HSBC  
is well placed to compete as the economy recovers.

At the start of 2022, the ongoing impact 
of Covid-19 was the most dominant 
factor within the external environment. 
While further outbreaks in Hong Kong 
and mainland China significantly 
impacted economic growth, the Russia-
Ukraine war and rising inflation and 
interest rates had an even greater impact 
on the global economy in 2022. They are 
also likely to continue to have a greater 
economic impact than the pandemic in 
2023, as we are already seeing with a 
cost of living crisis affecting many of  
our customers and colleagues.

Strong financial performance and higher 
capital distributions
We supported our customers through the 
challenges that they faced at the same time as 
executing our strategic plan. The first phase of 
our transformation is now complete. The work 
that we have done has enabled us to emerge 
from the pandemic a stronger bank, better 
aligned to the international needs of our 
customers. 

The reshaping of our portfolio continued with 
the announcement of the planned sale of our 
banking business in Canada. We continued to 
develop our Wealth capabilities, especially in 
Asia, and this strategy gained traction in 2022. 
Our increased investment in technology has 
improved the customer experience and made 
our processes more efficient. Meanwhile, we 
continued to support our clients to transition 
to net zero, and also took further important 
steps towards our ambition of aligning our 
financed emissions to net zero by 2050. Given 
the urgency of today’s global energy crisis, it is 
now even more important that we continue to 
actively engage our clients on how they intend 
to prepare their businesses for a low-carbon 
future.

In 2022, reported profit before tax was 
$17.5bn, a decrease of $1.4bn compared with 
2021 due to the $2.4bn impairment on the 
planned sale of our French retail banking 
operations. Adjusted profit before tax was 
$24.0bn, an increase of $3.4bn on last year. All 
of our businesses grew profits in 2022, and we 
maintained our strong capital, funding and 
liquidity positions.

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HSBC Holdings plc Annual Report and Accounts 2022

Group Chairman’s statement

” Given the urgency of 
today’s global energy 
crisis, it is now even  
more important that  
we continue to actively 
engage our clients on  
how they intend to 
prepare their businesses 
for a low-carbon future.”

We also recently announced some changes  
to the Board. Kalpana Morparia will join the 
Board as an independent non-executive 
Director on 1 March. Jack Tai will retire from 
the Board at the conclusion of the 2023 AGM, 
and will be succeeded as Chair of the Group 
Risk Committee by Jamie Forese. Jack has 
made a significant and important contribution 
during his time on the Board, particularly  
in the strengthening of risk and conduct 
governance and oversight through a period  
of major change. We wish him very well in  
his future endeavours. 

Noel and I were delighted to meet face-to-face 
with our loyal Hong Kong shareholders at our 
Informal Shareholders Meeting in August. We 
have always greatly valued their feedback and 
engagement, and this meeting was as well 
attended as ever. We were pleased to discuss 
how our business has performed, our 
continued support of Hong Kong, and our 
commitment to growing shareholder value. 
We look forward to continuing these 
discussions in person in 2023.

Our strategy is working 
There were reports over the course of last  
year about ideas for alternative structures for 
HSBC. The Board has been fully engaged in 
examining these alternatives in depth, with the 
benefit of independent third-party financial 
and legal advice. It has been, and remains,  
our judgement that alternative structural 
options would not deliver increased value for 
shareholders. Rather, they would have a 
material negative impact on value.

For 157 years, we have followed trade and 
investment flows to support our customers  
as they fulfil their financial ambitions. We  
have used our experience, expertise and 
relationships to help our customers to  
navigate the world. 

to individuals and companies of all sizes 
whose financial ambitions span multiple 
countries and regions. Very few, if any, other 
banks can rival our ability to connect capital, 
ideas and people through a global network 
that facilitates the international access and 
collaboration required to succeed in today’s 
world.

Our performance in 2022 demonstrates  
that our current strategy is working and 
improving returns. We are also confident  
that it will deliver good returns for our 
shareholders over the coming years. The 
Board and management team are fully 
focused on delivering it.

An uneven macroeconomic outlook 
We will need to maintain this focus against  
an uneven macroeconomic outlook. The 
pandemic, high inflation and interest rates, 
and the Russia-Ukraine war all have 
implications for the global economy, including 
volatility in markets, supply chain disruption, 
pressure on small and medium-sized business 
and squeezes on the cost of living. Different 
economies also now face different challenges 
and have different opportunities in 2023.

China’s reopening and package of measures 
to stabilise the property market should provide 
a significant boost for its economy and the 
global economy, albeit with some near-term 
volatility. Our economists forecast China’s 
GDP will grow 5% in 2023. The reopening of 
the border means that Hong Kong, and the 
entire Greater Bay Area, are likely to be major 
beneficiaries, and I expect to see a strong 
recovery.

More broadly, Asia as a whole has proven 
resilient and there is the prospect of a  
strong rebound later in the year. Virtually  
all economies in the region have now 
recovered the output losses incurred during 
the pandemic and are above 2019 levels.

The Middle East economies enjoyed a strong 
2022, and we expect this momentum to 
continue in 2023 on the back of the important 
reforms underway to transform, diversify and 
grow the region’s economies. We see strong 
and growing demand to connect clients in the 
Middle East with Asia’s economies, and  
vice versa.

In contrast, Europe, including the UK, face 
challenges from higher energy prices fuelling 
inflation and necessitating higher interest 
rates, driven in part by the Russia-Ukraine  
war. All of these factors are contributing to  
a cost of living crisis and more economic 
uncertainty. We expect that any recession,  
if there is one at all, will be relatively shallow.

have peaked in the US, and there is consensus 
that the US will avoid recession. I expect the 
US to make an important contribution to 
global GDP growth in 2023.

Overall, I am optimistic about the global 
economy in the second half of 2023, but there 
is still a high level of uncertainty due to the 
Russia-Ukraine war and recessionary fears 
may yet dominate much of the year ahead. 

Navigating geopolitics remains 
challenging
The geopolitical environment remains 
challenging for our clients to navigate. There is 
sadly no end in sight to the Russia-Ukraine 
war. However, the West’s relationship with 
China appears to be relatively stable. The 
renewed, constructive dialogue between 
President Xi and President Biden at the G20  
in November was clearly important. While 
further US sanctions are expected this year, 
capital flows between China and the West 
increased during the pandemic, even with 
reciprocal tariffs in place. China is also taking 
an active approach to diplomatic engagement 
with European nations, including the UK. 
China’s reopening will also allow for the 
resumption of face-to-face visits, which will 
support greater dialogue between China and 
important partners such as Germany, France 
and the UK. We also naturally continue to 
engage with governments around the world.

One of the key trends of the past three years 
has been supply chain disruption, due largely 
to a combination of geopolitics, pandemic and 
war-related factors. Businesses are seeking to 
build greater resilience into their supply chains, 
reduce their dependence on sole suppliers or 
regions, and take the opportunity to digitise. I 
expect these trends all to continue throughout 
2023. HSBC’s global network means we are 
well placed to adapt to regional diversification 
that takes place within supply chains.

Thank you to my colleagues
Finally, my colleagues have once again shown 
great dedication, energy and care in serving 
our customers and working together over the 
past year. They have exemplified our purpose 
of ‘opening up a world of opportunity’ and our 
core values. While we want to achieve even 
more in 2023 and beyond, I am very proud of 
what they achieved in 2022 – and I am 
extremely grateful to each of them.

Mark E Tucker
Group Chairman

21 February 2023

Today, we remain steadfastly focused on  
our core purpose of ‘opening up a world of 
opportunity’. Our model is particularly relevant 

The US economy is proving resilient and  
a hard landing appears unlikely. Some 
economists believe that inflation may now 

HSBC Holdings plc Annual Report and Accounts 2022

7

Strategic reportStrategic report 

Group Chief Executive’s review

The most significant changes to our portfolio 
have been the exit and wind-down of 
non-strategic assets and clients in the 
Americas and Europe, and the investment  
in technology and in organic and inorganic 
growth in Asia, especially in Wealth and 
Personal Banking. We have completed the 
sale of our US mass market retail business, 
and announced the planned exit of our French 
retail banking operations and the planned sale 
of our banking business in Canada. We have 
also announced exits in other smaller 
businesses, including Greece and Russia.  
A key factor in assessing the strategic value  
of our businesses has been whether they 
capitalise on the distinct advantages that  
we have, especially those derived from our  
global network.

Our work to increase capital efficiency 
resulted in cumulative risk-weighted asset 
savings of $128bn by the end of 2022, in 
excess of our original target as we accelerated 
restructuring in the US and Europe. This 
enabled us to reallocate capital towards  
Asia and the Middle East.

Finally, we have transformed our cost base 
and restored tight cost discipline across the 
organisation. Our cost to achieve programme 
concluded at the end of 2022, but it enabled 
us to take multiple layers of inefficiency out  
of the business and embed changes that we 
expect to provide flow-through benefits for 
years to come.

Building a good platform for future 
growth
At the same time, we have invested in new 
sources of value creation that provide a good 
platform for future growth. Developing our 
capabilities in Wealth, particularly in Asia, has 
been a strategic priority as we have sought  
to diversify our revenues. We have done  
this organically through the build-out of our 
Pinnacle business in mainland China, and 
inorganically through the purchases of AXA 
Singapore and L&T Investment Management 
in India, by increasing our stake to 90% in 
HSBC Qianhai Securities, and by taking full 
ownership of our HSBC Life China insurance 
business. The traction that we are gaining in 
Wealth is reflected by the $80bn of net new 
invested assets that we attracted in 2022, 
$59bn of which were in Asia.

Noel Quinn
Group Chief Executive 

The progress that we have made over the past three years 
means that HSBC is well positioned to deliver higher returns  
and has a good platform for future growth.

Return on average tangible 
equity 

9.9%

(2021: 8.3%)

Adjusted revenue 

$55.3bn

(2021: $47.0bn)

We have completed the first phase of  
our transformation. Our international 
connectivity is now underpinned by good, 
broad-based profit generation around  
the world. Our focus is now on continuing 
to grow our core business, while also 
capitalising on the new sources of  
value creation that we have built. 

When we embarked on our transformation 
programme in February 2020, our aim was  
to address the fundamental issues that had 
contributed to a decade of low returns. It was 
clear to me that too much of our capital was 
being used inefficiently, too many of our 
businesses were loss-making and sub-scale, 
and too many of our clients were low returning 
and purely domestic in nature. Over the  
last three years, while responding to the 
challenges of the pandemic, we have 
structurally repositioned our businesses and 
operating model to achieve higher returns.

8

HSBC Holdings plc Annual Report and Accounts 2022

Group Chief Executive’s review

” The difference  
compared with three  
years ago is that  
our international 
connectivity is now 
underpinned by good 
broad-based profit 
generation around  
the world.”

Our core purpose is ‘opening up a world of 
opportunity’ and that, in essence, is what we 
do by helping our personal and corporate 
customers to move money between countries 
and do business across borders. This is still  
the best way for us to create value, and what 
makes us a world leading bank for international 
and mid-market customers. We are the 
number one trade finance bank, and trade 
revenue was up 13% in 2022, surpassing the 
good level of growth in the previous year.  
Trade also increased in all regions. 

We are also one of the leading global foreign 
exchange houses and a leading payments 
company globally, with over $600tn of 
payments processed in 2022. Our global 
connectivity has made international our 
fastest-growing revenue segment in Wealth 
and Personal Banking. Products like Global 
Money and our Wealth platforms are 
specifically designed to meet the international 
needs of our retail and wealth customers. 
These customers also provide around double 
the average revenue of domestic-only 
customers.

The difference compared with three years ago  
is that our international connectivity is now 
underpinned by good broad-based profit 
generation around the world. Already the 
leading bank in Hong Kong, we gained market 
share last year in key products including 
customer deposits, insurance and trade 
finance. We are also the leading foreign bank 
in mainland China by revenue and are pleased 
to have received seven main licence approvals 
since 2020. Our business in India delivered 
$0.9bn of profit before tax last year and 
facilitated the equivalent of around 9% of 
India’s exports. In the Middle East, we 
delivered $1.8bn of profits and were the 
number one bank in capital markets league 
tables. HSBC UK delivered $5bn of profits and 
was the number one bank for trade finance, 
while our non-ring-fenced bank in Europe 
delivered $2.1bn of profits and around 35%  
of its client business was booked outside the 
region. Our US business has now had nine 
consecutive quarters of profitability after its 
turnaround, while our business in Mexico 
delivered a return on tangible equity of 18%.

The cost savings that we have made have 
been reinvested in technology, which has in 
turn enabled us to change the way we operate 
as a business. Technology spending was 19% 
higher in 2022 than in 2019. Much of this 
investment has been used to rebuild and 
upgrade platforms, which we have then rolled 
out globally. Our upgraded mobile banking 
app is available in 24 markets and has around 
13 million active users, while our upgraded 
digital trade finance platform has been rolled 
out in the UK and Hong Kong, ensuring that 
market-leading businesses are well positioned 
for the next 10 years. In 2022, we launched 
HSBC Orion, our new proprietary tokenisation 
platform using blockchain technology for bond 
issuances. We’re also partnering with fintechs 
around the world to use their capabilities in 
our products. Finally, we are investing in 
greater automation, which we expect to  
reap the benefits from for years to come.

Empowering our people has underpinned 
everything that we have achieved over the 
past three years – and it will underpin the  
next phase of our strategy too. Reducing 
management layers has helped to increase  
our speed and agility. In our last staff survey, 
the number of colleagues who report that 
work processes allow them to work efficiently 
was 6 percentage points above the sector 
benchmark. Confidence within the 
organisation has also increased. 77% of 
colleagues told us they are confident about 
our future, which is 3 percentage points up  
on 2021. We have continued to make steady 
progress against our medium-term targets on 
gender and ethnicity representation, while  
the number of hours that colleagues spent 

learning about digital and data, and 
sustainability also increased by 13% last  
year, underlining the importance of these 
critical future skills.

The transition to net zero will offer increasingly 
significant commercial opportunities in the 
future. We have continued to make good 
progress towards our ambition of providing 
and facilitating $750bn to $1tn of sustainable 
financing and investment by 2030. At the end 
of 2022, the cumulative total for sustainable 
financing and investment since 2020 had 
reached more than $210bn. We published an 
updated energy policy, which commits us to 
no longer provide new finance or advisory 
services for the specific purpose of projects 
pertaining to new oil and gas fields and related 
infrastructure whose primary use is in 
conjunction with new fields. As per our policy, 
we will continue to provide finance to maintain 
supplies of oil and gas in line with declining 
current and future global demand, while 
accelerating our activities in support  
of clean energy. We have also set interim  
2030 targets for on-balance sheet financed 
emissions for eight sectors. These include  
six sectors for which we have reported 2019 
and 2020 emissions. We recognise that 
methodologies and data for measuring 
emissions will continue to evolve, and our  
own disclosures will therefore continue to 
develop as a result. In 2023, we will publish  
our first bank-wide climate transition plan.

Strong overall financial performance  
in 2022
The progress that we have made transforming 
HSBC and investing in growth has helped  
to drive an improved financial performance  
in 2022. A strong net interest income 
performance reflected higher global interest 
rates, but there was also good underlying 
growth across the business in key areas, 
particularly those linked to our international 
network.

Overall, the Group delivered $17.5bn of 
reported profit before tax, which was  
$1.4bn lower than in 2021. This was due to  
a net expected credit loss charge of $3.6bn 
compared with a net release of $0.9bn last 
year, as well as the impairment of $2.4bn 
relating to the planned sale of our retail 
banking operations in France. Adjusted  
profit before tax was $24bn, up $3.4bn.

Adjusted revenue was 18% higher than the 
same period last year, as net interest income 
grew strongly in all of our global businesses. 
There was also a strong performance in Global 
Foreign Exchange. Our reported return on 
tangible equity for 2022 was 9.9%. Excluding 
significant items, we delivered a return on 
tangible equity of 11.6%.

HSBC Holdings plc Annual Report and Accounts 2022

9

Strategic reportStrategic report | Group Chief Executive’s review

Future growth levers

In 2022, we continued to build new 
sources of value creation.

We brought in 

$80bn 

of net new invested assets in Wealth.

We provided and facilitated cumulatively

$210.7bn 

of sustainable finance and investment since 
January 2020.

There was a good performance across our 
global businesses. In Commercial Banking, 
adjusted profit before tax was up by 24% to 
$7.7bn, driven by revenue increases across all 
products and in all regions, most notably Asia 
and the UK. Within this, Global Payments 
Solutions revenue grew by 104% on the back 
of higher interest rates, while trade revenue 
was up 14% with growth in all regions. 

Global Banking and Markets delivered 
adjusted profit before tax of $5.4bn, up  
8% compared with 2021. Global Payments 
Solutions was again the main driver, with 
119% growth in net interest income from 
higher interest rates, and a strong 
performance in Global Foreign Exchange.  
In Wealth and Personal Banking, adjusted 
profit before tax of $8.5bn was 27% higher 
than 2021. Net interest income growth drove a 
good performance in Personal Banking, while 
there was also balance sheet growth in the 
UK, Asia outside Hong Kong, and Mexico.

We restricted adjusted cost growth to 1% in 
2022 as a result of the significant cost-saving 
actions that we have taken. This represents  
a good outcome given the high inflation 
environment. After good capital generation in 
the fourth quarter, our CET1 ratio at the end of 
2022 was 14.2% and back within our target 
range of 14% to 14.5%. We are able to pay a 
second interim dividend of $0.23 per share, 
bringing the total 2022 dividend to $0.32  
per share.

Improved returns and substantial 
distribution capacity
We are firmly on track to achieve our target  
of a return on tangible equity of at least 12% 
from 2023 onwards. We have built up a good 
level of expected credit loss provisions, and 
we also expect the headwinds associated with 
macroeconomic uncertainty and the ongoing 
challenges within the China commercial real 
estate sector to subside, enabling expected 
credit losses to start to normalise. 

There will be no easing off at all on costs.  
Our cost to achieve programme has now 
ended, but we will continue to seek and  
find opportunities to create efficiencies  
that will deliver sustainable cost savings  
in future years. We are now considering up  
to $300m of additional costs for severance  
in 2023. These costs will need to be reported 
in our costs line. Taking this into account, we 
will aim for approximately 3% cost growth  
in 2023. Tight cost discipline will remain a 
priority for the whole Group.

As a result of the improving quality of our 
returns, we are establishing a dividend payout 
ratio of 50% of reported earnings per share for 
2023 and 2024, excluding material significant 
items. We will aim to restore the dividend to 
pre-Covid-19 levels as soon as possible. We 
also intend to revert to paying quarterly 
dividends from the start of 2023. Given the 
capital generation at the end of 2022, we will 
bring forward the consideration of buy-backs 
to the announcement of our results for the  
first quarter of 2023.

Finally, subject to the completion of the  
sale of our banking business in Canada, I am 
pleased that the Board will consider payment 
of a special dividend of $0.21 per share in  
early 2024 as a priority use of the surplus 
capital generated by the transaction. We 
understand the importance of dividends to  
our shareholders and expect them to benefit 
from improved capital distributions ahead.

My colleagues are getting it done
I would like to end by thanking my colleagues 
around the world. Over the last three years, 
they have managed a period of substantial 
change, embraced the opportunities that our 
transformation has presented and gone the 
extra mile to support our customers – all while 
living through a global pandemic. More 
recently, there have also been the Russia-
Ukraine war, the real-life financial strains 
caused by high inflation and the devastating 
earthquakes in Türkiye for them to deal with. 
We have only made the progress that we have 
because of their efforts. They are exemplifying 
our value of getting it done, and I am proud to 
lead them.

Overall, 2022 was another good year for 
HSBC. We completed the first phase of  
our transformation and our international 
connectivity is now underpinned by good, 
broad-based profit generation around the 
world. This contributed to a strong overall 
financial performance. We are on track to 
deliver higher returns in 2023 and have built  
a platform for further value creation. With  
the delivery of higher returns, we will have 
increased distribution capacity, and we will 
also consider a special dividend once the  
sale of HSBC Canada is completed.

Noel Quinn
Group Chief Executive

21 February 2023

10

HSBC Holdings plc Annual Report and Accounts 2022

Our strategy

Our strategy

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

Transformation journey

We have made progress in our transformation 
in six key areas, as we start to improve 
financial performance and build a strong 
foundation for future growth. 

Capital allocation 
Asia
(as a % of Group tangible equity)1

Firstly, we have retained a market leading 
position in international connectivity. We  
are the number one trade finance bank and 
number three bank in foreign exchange 
globally, based on peer analysis undertaken  
by Coalition Greenwich. Across our global 
businesses, international connectivity is core 
to who we serve, with approximately 45% of 
our wholesale client business coming from 
cross-border relationships and approximately 
6 million international customers banking with 
Wealth and Personal Banking. International 
clients remain our most attractive client base 
in Wealth and Personal Banking, with revenue 
around double that of domestic customers. In 
addition, global transaction banking revenue,  
a cornerstone of our international connectivity, 
has grown 7% each year since 2019.

Secondly, we have also reshaped our portfolio 
through strategic exits in continental Europe 
and the Americas. We have exited our 
domestic mass market retail business in the 
US, and are in the process of selling our retail 
banking operations in France, our banking 
business in Canada, our business in Russia 
and our branch operations in Greece, subject 
to regulatory and governmental approvals.  
We have taken actions to improve the returns 
profile of the Group, including generating 
cumulative gross RWA reductions of $128bn 
since the start of our programme, exceeding 
our target of more than $110bn. We have 
continued to reallocate capital to Asia, with 
the proportion of our tangible equity allocated 
to Asia increasing to 47% at the end of 2022, 
and we remain on track with our medium- to 
long-term aspiration to increase this to 50%. 
We have also invested through a series of 
bolt-on acquisitions in Asia, including AXA’s 
business in Singapore and L&T Investment 
Management in India, and we have increased 
our stakes in HSBC Life China and  
HSBC Qianhai. 

47%

2021

2022

Medium- to long-term aspiration

42%

47%

c.50%

1  Based on tangible equity of the Group’s major 
legal entities excluding associates, holding 
companies, and consolidation adjustments.

Gross RWA reduction

$128bn

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

Technology investment

$6.1bn

(2019: $5.1bn) 

Thirdly, over the last three years we have built 
a broad and geographically diverse base of 
profit generation. We remain the leading bank 
in Hong Kong across key areas including 
deposits, lending and trade finance, while in 
mainland China, our business contributed 
$1.0bn of adjusted profit before tax in 2022, 
excluding the share of profit from our 
associate, Bank of Communications Co., 
Limited. We have also grown our businesses 
in the rest of Asia, with adjusted profit before 
tax of $4.2bn, up 24% compared with 2019. 
Outside of Asia, HSBC UK Bank plc delivered 
$5.0bn of adjusted profit before tax in 2022, 
while our HSBC Bank plc and US businesses 
have transformed into being leaner and more 
internationally focused. In the Middle East  
and North Africa, we are the leading bank in 
capital markets, while in Mexico, the return on 
average tangible equity was 18.0% in 2022. 

Fourthly, we have retained our strong focus  
on cost discipline. Within the past year, 
notwithstanding inflationary pressures, we 
contained adjusted cost growth compared 
with 2021. As a result, excluding the benefit of 
a reduced UK bank levy, adjusted costs have 
remained flat since 2019, with a 19% increase 
in technology spend offset by gross saves 
within our global businesses, operations and 
other costs. Since 2019, we have taken actions 
to become a more efficient organisation, 
reducing our office real estate footprint by 
37%, branches by 21% and operations 
headcount by approximately 11%. 

As we transformed, we have also built a 
platform for growth and returns upon which 
we will build new value creation opportunities. 
We have continued to grow our balance sheet, 
with our deposits growing by 4% and assets 
growing by 5% each year since 2019. 
Increasing fee-based revenue and growing our 
Wealth and Personal Banking franchise remain 
important priorities for the Group, and we have 
gained traction, with Wealth revenue up 3% 
and transaction banking revenue up 7% since 
2019. However, given the changes to the 
macroeconomic environment, together with 
the implementation of IFRS 17, the metrics 
‘Insurance and fees as a percentage of Group 
adjusted revenue’ and ‘WPB as a percentage 
of Group tangible equity’ are no longer 
appropriate to measure our progress in  
these areas. 

We continue to view technology as a key 
enabler of our growth ambitions, and  
have also increased our investment from 
approximately $5.1bn in 2019 to $6.1bn in 
2022. During the year, we have scaled up 
existing digital propositions and launched 
others. Details of these can be found on the 
following pages. 

Fifthly, we have supported a sustainable 
dividend policy with strong capital and 
liquidity. Finally, the above five themes have 
resulted in a strong platform for growth and 
returns, upon which we will build new value 
creation opportunities.

HSBC Holdings plc Annual Report and Accounts 2022

11

Strategic reportStrategic report | Our strategy

Delivery in 2022

Our strategy centres on four key pillars: 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
Adjusted revenue for our Wealth and Personal 
Banking business was $24.4bn in 2022, up 
16% compared with 2021. This was driven by 
growth in Personal Banking, where adjusted 
revenue was $15.9bn, up 37%. We continued 
to make progress in executing our Wealth, 
Asset Management and Insurance strategy, 
attracting net new invested assets of $80bn, 
compared with $64bn in 2021, with $59bn 
coming from Asia. Our Asia Insurance value  
of new business reached $1.1bn, up 24%.

We continued to grow our digital propositions 
during the year. We launched Global Money in 
the UK and Australia, with the proposition now 
live in eight markets. This new proposition 
recorded approximately $11bn of transactions 
in 2022, enabling customers to make cheaper 
and faster international payments. We also 
signed up more than 900,000 users to our 
Pinnacle financial planning app to bring the 
total user base to over 1 million. 

Within our Wealth business, in partnership 
with BlackRock, we launched Prism, a hybrid 
advisory service to help investors make more 
informed investment decisions. 

$80bn

Net new invested assets in 2022.

Commercial Banking
Adjusted revenue for our Commercial Banking 
business reached $16.2bn in 2022, up 29% 
compared with 2021. Adjusted revenue rose in 
all regions, and notably in Hong Kong, which 
grew by 36%. Fee income increased by 8% to 
$3.7bn, reflecting growth in Global Payments 
Solutions and Global Trade and Receivables 
Finance.

Our digital propositions have gained 
significant traction, with payments processed 
on HSBCnet mobile increasing by nearly 62% 
during the year. Kinetic, our digital business 
banking account for SMEs in the UK, gained 
approximately 29,000 customers, taking its 
overall customer base to approximately 
53,000. Business Go, our new global digital 
platform for SMEs, has gone live and has 
grown to over 95,000 users as of 2022.  

In 2022, we launched our first Banking-as-a-
Service proposition in the US with Oracle 
Netsuite, embedding HSBC’s banking 
products within Oracle’s Cloud enterprise 
resource planning platform. 

We continue to actively help our clients with 
their climate transition goals, and have 
completed the global roll-out of our core 
sustainable product suite covering loans, trade 
finance and bonds. We also launched our 
enhanced HSBC Sustainability Tracker for 
Business Banking customers. 

Global Banking and Markets
Adjusted revenue for our Global Banking  
and Markets business was $15.4bn in 2022, 
up 10% compared with 2021, driven by  
strong performances in Global Payments 
Solutions and Markets and Securities 
Services, primarily from our Global Foreign 
Exchange business. During the year, we 
continued to drive efforts for cross-business 
line collaboration through referrals and 
cross-sell of products, with adjusted 
collaboration revenue of approximately 
$3.7bn in 2022, compared with approximately 
$3.5bn in 2021. Our Global Banking and 
Markets franchise remains an internationally 
connected one, with our clients doing 
business with us in multiple markets. In 2022, 
our clients in Europe and the Americas drove 
approximately $2.6bn of client business into 
Asia and the Middle East, an increase of 
approximately 30%.

We continued to develop our digital 
propositions with the launch of HSBC Orion,  
a new proprietary tokenisation platform to 
issue digital bonds based on distributed  
ledger technology.

We also extended our sustainable investment 
product range, launching a biodiversity 
screened equity index created in partnership 
with biodiversity data specialist Iceberg data 
lab and Euronext. 

$3.7bn

Fee income in 2022.

c.$2.6bn

Client business1 booked in the  
East from clients managed in  
the Americas and Europe. 

1  Client business differs from reported revenue as it relates to certain client-specific income, and excludes certain products (including Principal Investments,  

GBM ’other’ and asset management), Group allocations, recoveries and other non-client-related and portfolio level revenue. It also excludes Hang Seng. GBM 
client business includes an estimation of client-specific day-one-trade-specific revenue from Markets and Securities Services products, which excludes ongoing 
mark-to-market revenue and portfolio level revenue such as hedging. Cross-border client business represents the income earned from a client’s entity domiciled  
in a different geography than where the client group’s global relationship is managed. ‘Booking location’ represents the geography of the client’s entity or 
transaction booking location where this is different from where the client group’s global relationship is managed. 

12

HSBC Holdings plc Annual Report and Accounts 2022

Our strategy

Digitise at scale

We continued to invest in our technology and 
operational capabilities to drive productivity 
across businesses and geographies, and to 
improve customer experience. In 2022, $6.1bn, 
or 20%, of our overall adjusted operating 
expenses were dedicated to technology,  
up from $5.6bn in 2021.

Enhancing our digital propositions to improve 
customer engagement and journeys remains a 

significant priority. During the year, just under 
half of our Wealth and Personal Banking 
customers were active users of our mobile 
applications, an increase from 42.7% in 2021, 
and over 75% of our Commercial Banking 
customers were active on our digital 
applications, an increase from 71.0%. 
Furthermore, in Wealth and Personal Banking, 
nearly half of sales were generated digitally. 
Our customer journeys continue to be 

transformed, for example, in Singapore, our 
Wealth and Personal Banking customers can 
now open an account even before they arrive 
in their new country via their mobile phones. 

To improve our operational efficiency, we 
continue to deploy technologies at scale in our 
organisation. Our Cloud adoption rate, which 
is the percentage of our technology services 
on the private or public Cloud, increased from 
27% to 35%.

Energise for growth 

Empowering and energising our colleagues  
is crucial for inspiring a dynamic culture. Our 
Employee engagement index, our headline 
measure of employee satisfaction, rose to 73% 
in 2022 from 67% in 2019, our baseline year. 
The participation rate of the survey also rose 
from 50% to 78%.

We remained focused on creating a diverse 
and inclusive environment, especially in senior 
leadership roles, which are those classified as 
band 3 and above in our global career band 

structure. We achieved 33.3% female 
representation in senior leadership positions 
by the end of 2022, and are on track to achieve 
our target of 35% by 2025. In 2022, we also 
set a Group-wide ethnicity strategy to better 
represent the communities we serve. We are 
on track to meet this, with 2.5% of leadership 
roles held by colleagues of Black heritage  
in 2022. 

We continued to help our colleagues develop 
future-ready skills. In 2022, the total learning 

hours spent on these future-ready skills 
(digital, data, and sustainability) increased  
to approximately 375,777 hours, up from 
334,651 hours in 2021. 

We outline how we put our purpose and 
values into practice in the following ‘ESG 
overview‘ section. 

 For further details on how we plan to energise  
for growth, see the Social section in the ESG 
review on page 73.

Transition to net zero

In November, we participated in COP27 to  
play our part in bringing together the public 
and private sector to mobilise the transition  
to a net zero global economy. We also made 
good progress on our ambitions, including 
expanding our financed emissions targets to 
eight sectors in total, reducing our greenhouse 
gas emissions, and supporting our customers 
in their transition to a net zero future including 
the launch of new climate solutions. 

Becoming a net zero bank
We continue to pursue our 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 2022, we reduced our 
absolute greenhouse emissions in our 
operations to 285,000 tonnes CO2e, which 
represents a 58.5% reduction from our  
2019 baseline. 

Growth and returns

So far, we have set interim 2030 targets for 
on-balance sheet financed emissions for eight 
sectors. We also published updated energy 
and thermal coal phase-out policies during the 
year, which are important mechanisms to help 
phase down our financed emissions in these 
areas while supporting our customers in their 
own transition plans. We plan to extend our 
financed emissions analysis to new sectors – 
shipping, agriculture, commercial real estate 
and residential real estate – in future 
disclosures. We remain committed to setting 
facilitated emissions targets, and aim to 
continue to engage with industry initiatives  
to produce a consistent and comparable 
cross-industry approach. 

a total of $84.2bn of sustainable finance and 
investments, bringing our cumulative amount 
since 1 January 2020 to $210.7bn of our 
$750bn to $1tn ambition by 2030. 

Unlocking new climate solutions 
In 2022, Climate Asset Management, the 
dedicated natural capital investment manager 
formed as a joint venture with climate change 
investment and advisory firm Pollination, 
achieved commitments of more than $650m 
across its two natural capital strategies. We 
also officially launched Pentagreen, a joint 
venture with Temasek, to finance the 
development of sustainable infrastructure  
in south-east Asia. 

Supporting customers through transition
We have made progress in our ambition to 
support our customers through their transition 
to net zero. In 2022, we provided and facilitated 

 For further details on our climate ambition,  
see the Environmental section in the ESG  
review on page 46.

Looking ahead, we will continue to build on our areas of strength, using our international connectivity and strong geographical diversity 
spanning every region. We will also continue to drive our transaction banking, wealth and digital platforms in order to grow fee income. Cost 
discipline remains a priority for us, while we drive investment in technology to increase productivity and growth. As a result, we expect to 
achieve more than 12% RoTE from 2023 onwards – the highest in a decade – and have substantial distribution capacity in 2023 and 2024. 

HSBC Holdings plc Annual Report and Accounts 2022

13

Strategic reportStrategic report 

ESG overview

We conduct our business to support the sustained success 
of our customers, people and other stakeholders.

Our approach

We are guided by our purpose: to open up  
a world of opportunity for our colleagues, 
customers and communities. Our purpose is 
underpinned by our values: we value difference; 
we succeed together; we take responsibility; 
and we get it done. Our purpose and values 
help us to deliver our strategy and unlock 
long-term value for our stakeholders. 

Our approach to ESG is shaped by our purpose 
and values and a desire to create sustainable 
long-term value for our stakeholders. As an 
international bank with significant breadth  
and scale, we understand that our climate, 
economies, societies, supply chains and 
people’s lives are interconnected. We recognise 
we can play an important role in tackling ESG 
challenges. We focus our efforts on three 
areas: the transition to net zero, building 
inclusion and resilience, and acting responsibly.  

Transition to net zero
The transition to net zero is one of the biggest 
challenges for our generation. Success will 
require governments, customers and finance 
providers to work together. Our global footprint 
means that many of our clients operate in 
high-emitting sectors and regions that face the 
greatest challenge in reducing emissions. This 
means that our transition will be challenging 
but is an opportunity to make an impact. 

We recognise that to achieve our climate 
ambition we need to be transparent on the 

opportunities, challenges, related risks and 
progress we make. To deliver on our ambition, 
we require enhanced processes, systems, 
controls, governance and new sources of data. 
We continue to invest in our climate resources 
and skills, and develop our business 
management process to integrate climate 
impacts. As we enhance our systems, 
processes, controls and governance, certain 
aspects of our reporting will rely on manual 
sourcing and categorisation of data. Given the 
challenges on data sourcing as well as the 
evolution of our processes as mentioned 
above, this has had an impact on certain 
climate disclosures including thermal coal. In 
2023, we will continue to review our approach 
to our disclosures, with our reporting needing 
to evolve to keep pace with market 
developments.

We set out in more detail the steps we are 
taking on our climate ambitions in the ESG 
review on page 47.

Build inclusion and resilience
Building inclusion and resilience helps us to 
create long-term value. By removing barriers 
and being a fair and equitable bank, we can 
attract the best talent, serve a wider customer 
base and support our communities.

diversity, and we focus on employee sentiment, 
and support our colleagues’ resilience through 
well-being and learning resources. 

We strive to provide inclusive and accessible 
banking for our customers. We help our 
customers to build financial resilience by 
providing resources that help them manage 
their finances, and services that help them 
protect what they value. This is critical in 
challenging times, as we continue to support 
our stakeholders in the wake of Covid-19 and 
in the face of a rising cost of living.  

Finally, we give back to our communities 
through philanthropic giving, disaster relief 
and volunteering.  

Act responsibly
We are focused on running a strong and 
sustainable business that puts the customer 
first, values good governance, and gives our 
stakeholders confidence in how we do what 
we do. 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. Customer 
experience is at the heart of how we operate. 
We aim to act responsibly and with integrity 
across the value chain.

An inclusive, healthy and stimulating 
environment for our people helps us to succeed. 
We have set goals for gender and ethnic 

On page 16, we have set out ways that we 
have supported our stakeholders through a 
challenging year.

ESG disclosure map and directory

Transition to  
net zero

Our climate ambition

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

Diversity and inclusion disclosures 

Pay gap disclosures

How we govern ESG 

Build 
inclusion 
and 
resilience

Act 
responsibly

Human rights and modern slavery disclosures

Read more on our approach to the transition to net zero

Read more on our progress made against our ambition 
to achieve net zero in our financed emissions by 2050

Read more on our progress made against our $750bn 
to $1tn sustainable finance and investment ambition

Read more on our ambition to achieve net zero in our 
own operations by 2030

We make disclosures consistent with Task Force  
on Climate-related Financial Disclosures (‘TCFD’) 
recommendations, highlighted with the symbol:  TCFD

Read more on how we are building an inclusive 
environment that reflects our customers and 
communities, and our latest pay gap statistics

Read more on our ESG governance approach and 
human rights 

 Page 46

 Page 50

 Page 57

 Page 62

 Page 68

 Page 74

 Page 75

 Page 86

 Page 87

How our ESG targets link to executive 
remuneration

Read more on our ESG targets embedded in executive 
remuneration

 Page 16; 
Pages 282 to 287

Our ESG Data Pack

Our ESG Data Pack provides more granular ESG 
information, including the breakdown of our sustainable 
finance and investment progress, and complaints volumes

www.hsbc.com/esg

14

HSBC Holdings plc Annual Report and Accounts 2022

ESG overview

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

Customers

Employees

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

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

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

Regulators and 
governments

We proactively engage with regulators and governments to facilitate strong 
relationships through virtual and in-person meetings and by responding to 
consultations individually and jointly via industry bodies

Material topics highlighted by 
the engagement1

 – Customer advocacy

 – Cybersecurity

 – Employee training

 – Diversity and inclusion

 – Employee engagement 

 – Thermal coal policies

 – Energy policies

 – Becoming a net zero bank  
in our own operations and 
financed emissions

 – Financial inclusion and 
community investment

 – Anti-bribery and corruption

 – Conduct and product 

responsibility

Suppliers

Our 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

 – Human rights

1  These 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 customers facing a rising 
cost of living
We know that many of our customers around 
the world are facing increasing cost of living 
pressures from higher inflation, and we are 
committed to helping them.

Colleagues across our global businesses have 
been reaching out to customers to provide 
them with increased access to support, such 
as free financial health checks, as well as 
proactively contacting those who we believe 
could benefit from additional assistance.

Proactive support
We have focused our support on our 
customers in the UK, which is our largest 
market to be affected by rising cost of  
living pressures, using our guidelines  
and procedures to help provide the right 
outcomes. We also engage closely and 
regularly with our key regulators to help 
ensure we meet their expectations of financial 
institutions’ activities more generally during 
volatile markets.

For our personal customers in financial 
difficulty, we enhanced our range of digital 
resources, with the launch of a new ‘Rising 

cost of living hub’ on our public website. The 
hub provides useful articles and tools to help 
budget, manage money and gain access to 
the range of support we are providing. Other 
measures in 2022 included:

 – conducting a review of our existing tools 
and services, helping to ensure requests  
for borrowing remained affordable; 

 – helping those most in need with temporary 

support, such as reducing overdraft 
borrowing costs in eligible accounts; 

and offering extensions to collection periods. 
Other measures in 2022 included:

 – improving our customer support and 

education, including through webinars and 
our financial well-being website, to guide 
how best to improve financial resilience and 
forecast cash flows;

 – enhancing the identification of customers 

exhibiting signs of financial vulnerability, by 
using data and front-line insights provided 
from relationship management teams; 

 – providing the opportunity to mortgage 

 – increasing the education provided to our 

customers coming to the end of an existing 
fixed rate to secure a new rate earlier; and

colleagues on the various forms of financial 
support available to clients; and

 – removing the payments of penalties for 
customers in need of funds having to  
close fixed-rate savers accounts early. 

In our CMB business, our focus has been 
towards helping Business Banking clients 
exhibiting signs of financial vulnerability, as well 
as participating in local government-backed 
initiatives targeted at extending financial 
support to SMEs. When a customer is in need 
of assistance, we review on a case-by-case 
basis, with potential solutions including 
repayment holidays, extending loan repayments 

 – proactively getting in touch with customers 

to help ensure awareness of available 
support, including communicating with over 
40,000 SMEs, and increasing the number of 
outbound calls in the fourth quarter of 2022 
by 190%, when compared with the previous 
quarter, to those displaying signs of lower 
financial resilience.

 For further details on our conduct and product 
responsibilities, see the ESG review on page 94. 
For further details of how we are supporting our 
colleagues amid rising inflation, see page 25.

HSBC Holdings plc Annual Report and Accounts 2022

15

Strategic reportStrategic report | ESG overview

Our ESG ambitions, metrics and targets  TCFD

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 achieve our 
environment and social sustainability goals. They 
also help us to improve employee advocacy, the 
diversity of senior leadership and strengthen our 
market conduct. The targets for these measures 
are linked to the pillars of our ESG strategy: 
transitioning to net zero, building inclusion  
and resilience, and acting responsibly. 

To help us achieve our ESG ambitions, a 
number of measures are included in the 
annual incentive and long-term incentive 
scorecards of the Group Chief Executive, 
Group Chief Financial Officer and Group 
Executives that underpin the ESG metrics  
in the table below. 

We have developed a forward-looking 
roadmap to consider greater use of ESG 
measures in executive performance 

assessment. For a summary of how all 
financial and non-financial metrics link to 
executive remuneration, see pages 282 to  
287 of the Directors’ remuneration report.

The table below sets out some of our key  
ESG metrics that we use to measure our 
progress against our ambitions. For further 
details of how well we are doing, see the  
ESG review on page 43.

Environmental:

Transition to  
net zero1 

Financed  
emissions2

8 sectors 

Number of sectors where we have 
set on-balance sheet financed 
emissions targets.
Ambition: Achieve net zero in our 
financed emissions by 2050.

Gender diversity5

33.3%

Women in senior leadership roles.
(2021: 31.7%)
Target: Achieve 35% women in 
senior leadership roles by 2025.

Sustainable finance and 
investment3 

$210.7bn 

Cumulative total provided and 
facilitated since January 2020.
(2021: $126.7bn) 
Ambition: Provide and facilitate 
$750bn to $1tn of sustainable 
finance and investment by 2030.

Ethnic diversity5

37% increase

Of Black colleagues in senior 
leadership roles from 2020 baseline.
(2021: 17.5% increase)
Target: Double the number of Black 
colleagues in senior leadership roles 
between 2020 and 2025.

Net zero in our own  
operations4

58.5% 

Cumulative reduction in absolute 
operational greenhouse gas 
emissions from 2019 baseline.
(2021: 50.3%)
Ambition: Achieve net zero in our own 
operations and supply chain by 2030.

Employee engagement6

73%

Employee engagement score.
(2021: 72%)
Target: Maintain 72% in the Snapshot 
Employee engagement index.

Conduct training7

98%

Customer satisfaction8 

4 out of 6

5 out of 6

Employees who completed conduct 
training in 2022.
(2021: 99%)
Target: At least 98% of employees 
complete conduct and financial 
crime training each year.

WPB markets that sustained 
top-three rank and/or improved  
in customer satisfaction.
(2021: 5 out of 6)
Target: To be ranked top three and/or 
improve customer satisfaction rank.

CMB markets that sustained 
top-three rank and/or improved  
in customer satisfaction.
(2021: 2 out of 6)
Target: To be ranked top three and/or 
improve customer satisfaction rank

Social: 

Build inclusion 
and resilience

Governance: 

Acting 
responsibly

1  For further details of our approach to transition to net zero, methodology and PwC’s limited assurance reports, see www.hsbc.com/who-we-are/esg-and-

responsible-business/esg-reporting-centre. 

2  See page 52 for further details on our targets for six of these sectors, which include oil and gas; power and utilities; cement; iron, steel and aluminium; aviation;  

and automotive. See page 66 for further details about our thermal coal mining and coal fired power targets, as well as our thermal coal phase-out policy. 

3  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 58. For details on how this target links with the scorecards, see page 282. 

4   This absolute greenhouse gas emission figure covers scope 1, scope 2 and scope 3 business travel emissions. For further details of how this target links with the 

scorecards, see page 282. 

5  Senior leadership is classified as those at band 3 and above in our global career band structure. The progress for the ethnicity target is tracked from a 31 December 
2020 baseline against our 2020 commitment to double the number of Black senior leaders. We have since refined our approach to ethnicity by focusing on targets 
by market. For further details, see the ESG review on page 75. For details on how this target links with the scorecards, see page 282.

6 For further details, see the ESG review on page 77. For details on how this target links with the scorecards, see page 282.
7  The completion rate shown relates to the financial crime ‘Take another look’ training module and conduct ‘Taking responsibility’ training module in 2022.
8  The markets where we report rank positions for WPB and CMB – the UK, Hong Kong, mainland China, India, Mexico and Singapore – are in line with the annual 
executive scorecards. This represents a change from 2021, when the metric was based on all markets where benchmarking studies were run. For further details  
of customer satisfaction, see the ESG review on page 89. For further details of how this target links with the scorecards, see page 282.

16

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
ESG overview

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

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 have set out our key climate-related 
financial disclosures throughout the Annual 
Report and Accounts 2022 and related 
disclosures. In 2022, while recognising that 
further work lies ahead as we develop our 
management and reporting capabilities,  
we made certain enhancements to our 
disclosures. These include reporting relevant 
quantitative results from our first internal 
climate-related scenario analysis, including  
the carbon prices that we used. We also 
began to incorporate climate-related 
considerations into our annual financial 
planning cycle, and disclosed how 
management has considered the impact  
of climate-related risks on our financial 
position and forward-looking performance. 

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 11 
TCFD Recommendations and Recommended 
Disclosures save for certain items, which we 
summarise below.

 – For financed emissions we do not plan  

 – We do not fully disclose impacts from 

to set 2025 targets. We set targets in line 
with the Net-Zero Banking Alliance (‘NZBA‘) 
guidelines by setting 2030 targets. While  
the NZBA define 2030 as intermediate, we 
use different time horizons for climate risk 
management. We define short term as time 
periods up to 2025; medium term is between 
2026 and 2035; and long term is between 
2036 and 2050. These time periods align  
to the Climate Action 100+ disclosure 
framework. In 2022, we disclose interim 
2030 targets for on-balance sheet financed 
emissions for eight sectors as we outline  
on page 18. For the shipping sector, we 
chose to defer setting a baseline and target 
until there is sufficient reliable data to 
support our work, allowing us to more 
accurately track progress towards net zero. 
In March 2022, we said we would set capital 
markets emissions targets for the oil and 
gas, and power and utilities sectors based 
on the industry reporting standard from  
the Partnership for Carbon Accounting 
Financials (’PCAF’) once published. We 
remain committed to setting facilitated 
emissions targets, and aim to continue to 
engage with industry initiatives to produce  
a consistent and comparable cross-industry 
approach. We intend to review the financed 
emissions baselines and targets annually, 
where relevant, to help ensure that they are  
aligned with market practice and current 
climate science. 

climate-related opportunities on financial 
planning and performance including on 
revenue, costs and the balance sheet, 
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 including 
business travel, supply chain and financed 
emissions. In relation to financed emissions, 
we published on-balance sheet financed 
emissions for six sectors as detailed on page 
18. Future disclosure on financed emissions, 
and related risks is reliant on our customers 
publicly disclosing their carbon emissions 
and related risks. We aim to disclose 
financed emissions for additional sectors  
in our Annual Report and Accounts 2023 
and related disclosures. Our approach  
to disclosure of financed emissions for 
additional sectors can be found at:  
www.hsbc.com/who-we-are/esg-and-
responsible-business/esg-reporting-centre.

  For a full summary of our TCFD disclosures, 
including detailed disclosure locations for 
additional information, see pages 68 to 72.  
The additional information section on  
page 423 provides further detail.

Connecting international investors to sustainable solutions 

We are connecting investors around the world with governments to support the transition to 
net zero. In May, we helped the Indonesian government raise $3.25bn in an Islamic bond, 
known as a sukuk, with $1.5bn of the proceeds dedicated to be used exclusively for eligible 
spending that delivers on the UN’s Sustainable Development Goals, with guidance and 
support from the UNDP. We were joint lead manager and joint bookrunner, and were also 
mandated as joint green structuring adviser. The order book topped $10bn, with most of the 
buyers from Asia and the Middle East. 

The deal demonstrated how our specialist expertise can build trusted relationships. We have 
been discussing green financing solutions with the Indonesian government since 2018 and 
were previously appointed to structure both its green and sustainability financing 
programmes.

HSBC Holdings plc Annual Report and Accounts 2022

17

Strategic reportStrategic report | ESG overview

How we measure our net zero progress  TCFD

One of our strategic pillars is to support the 
transition to a net zero global economy. Our 
ambition is 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.

We have set interim 2030 targets for on-
balance sheet financed emissions for eight 
sectors. These include six sectors for which we 
have reported 2019 and 2020 emissions: oil 
and gas; power and utilities; cement; iron, steel 
and aluminium; aviation; and automotive. We 
have also set targets for thermal coal power 
and thermal coal mining. We remain 
committed to setting facilitated emissions 
targets, and aim to continue to engage with 
industry initiatives to produce a consistent  
and comparable cross-industry approach.  

We also recognise that we require enhanced 
capabilities and new sources of data, as set  
out on page 47.    

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 ambition to achieve net zero in our 
own operations and supply chain by 2030. We 
also recognise that green finance taxonomies 
are not consistent globally, and evolving 
taxonomies and practices could result in 
revisions in our sustainable finance reporting 
going forward.  

In the year ahead we plan to set interim targets 
for financed emissions across additional 
sectors and will continue our transformation 
programme to embed the climate transition 
into our core business and risk processes. We 
will continue to work on our climate transition 
plan, which will bring together – in one place 
– our financed emissions targets and climate 

strategy, with how we plan to embed this into 
our processes, infrastructure, governance and 
engagement. We plan to publish this in 2023, 
and update on progress annually thereafter.

We acknowledge this is a journey and 
recognise that regular reassessment will be 
needed to take into account climate scenarios, 
better data and revisions in reporting 
standards, as well as to reflect real world 
developments and trends. Our modelling 
inputs and assumptions will be impacted over 
time by the evolution of external parameters, 
such as policy and regulatory changes across 
our markets, technology innovation uptake, 
and macroeconomic events beyond our 
control. As a result of this, certain metrics and 
targets may need to be revised. In the following 
table, we set out our metrics and indicators 
and assess our progress against them.

  For further details of our approach to  
measuring financed emissions, including  
scope, methodology, assumptions and 
limitations, see page 50.

Climate strategic pillars  
and ambition

Metrics and indicators

Progress to date

Becoming a  
net zero bank

Number of sectors analysed  
for financed emissions1 

We have published on-balance sheet financed emissions for six 
sectors including cement; iron, steel and aluminium; aviation; and 
automotive. We also continue to disclose our financed emissions for 
the oil and gas and power and utilities sectors2 (see pages 50 to 56).

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

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

Absolute operational greenhouse gas 
emissions (tonnes CO2e)3

58.5% cumulative reduction in absolute greenhouse gas emissions 
from 2019 baseline (see page 62)

Percentage of renewable electricity 
sourced across our operations

Increase from 37.5% in 2021 to 48.3% (see page 62)

Percentage of energy consumption 
reduced

24.0% cumulative reduction in energy consumption from 2019  
baseline (see page 62)

Supporting our 
customers 

Sustainable finance and investment 
provided and facilitated ($bn)4

$210.7bn cumulative progress since 2020 (for further breakdown  
see page 58)

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 

Natural capital investment

Climate technology investment

Philanthropic investment to climate 
innovation ventures, renewable energy, 
and nature-based solutions

Climate Asset Management, which forms part of our goal to unlock 
new climate solutions, received commitments of over $650m for its 
two strategies: the Natural Capital Strategy and the Nature Based 
Carbon Strategy (for further details of our approach to responsible 
investment, see page 60)

Achieved our initial goal to fund $100m to climate technology 
companies, and subsequently raised our target to $250m (see page 60)

Committed $95.8m to our NGO partners since 2020, as part of the 
Climate Solutions Partnership (see page 84)

1  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.

2 Our disclosures for our 2019 emissions for our oil and gas, and power and utilities sectors have been revised. For further details, see page 55.
3  Our reported scope 3 greenhouse gas emissions of our own operations in 2022 are related to business travel. For further details on scope 1, 2 and 3, and our progress 
on greenhouse gas emissions and renewable energy targets, see page 63 and our ESG Data Pack at www.hsbc.com/esg. For further details of our methodology and 
PwC’s limited assurance report, see www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre.

4  The detailed definitions of the contributing activities for sustainable finance are available in our revised Sustainable Finance and Investment Data Dictionary 2022. For 

this, together with our ESG Data Pack and PwC’s limited assurance report, see www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre.

18

HSBC Holdings plc Annual Report and Accounts 2022

ESG overview

Responsible business culture

We have the responsibility to help 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.

At times our colleagues may need to speak  
up about behaviours in the workplace. We 
encourage colleagues to speak to their line 
manager in the first instance, and our annual 
employee Snapshot survey showed that  
84% of colleagues have trust in their direct 
manager. 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). 

We promote an environment where our 
colleagues can expect to be treated with 
dignity and respect. We are an organisation 
that acts where we find behaviours that fall 
short. Our index measuring colleagues’ 
confidence in speaking up increased by  
1 percentage point to 76% in 2022, 
significantly above the industry benchmark.

We aspire to be an organisation that is 
representative of the communities which  
we serve. To help achieve this, we have set 
commitments on the gender and ethnic 
diversity of our senior leadership.

We have committed to achieving a target of 
35% of senior leadership roles held by women 
(classified as those at band 3 and above in our 
global career band structure) by 2025. We 
remain on track, having achieved 33.3%  
in 2022.

In July 2020, we set out our early global 
ethnicity commitments to double the number 

of Black employees in senior leadership roles. 
To date we have achieved a 37% increase 
through leadership development, inclusive 
hiring practices and developing the next 
generation of high-performing talent. We have 
made good progress, but we know there is 
more to be done. 

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. 
As our self-disclosures improve, we can use 
this data to develop market-specific goals that 
are connected to the communities we serve. 

The table below outlines high-level 
diversity metrics. 

All employees

Male

Female

Senior leadership1

Male

Female

Holdings Board

Male

Female

48%

52%

67%

33%

67%

33%

1  Senior leadership is classified as those at band 3 
and above in our global career band structure.

 For further details of 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 74.

Social matters
We have a responsibility to invest in the 
long-term prosperity of the communities 
where we operate. We aim to provide people 
with the skills and knowledge needed to thrive 
in the post-pandemic environment, and 
through the transition to a sustainable future. 

For this reason, we focus our support on 
programmes that help develop employability 
and financial capability. We also support 
climate solutions and innovation, and 
contribute to disaster relief when needed.  
For further details of our programmes,  
see the ‘Communities’ section of the ESG 
review on page 83.

Human rights 
Our commitment to respecting human rights, 
principally as they apply to our employees, our 
suppliers and through our financial services 
lending and investment, 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. For further 
details, see the ‘Human rights’ section of the 
ESG review on page 87.

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. We  
set a high standard globally in our global 
anti-bribery and corruption policy, which  
also focuses on the spirit of relevant laws  
and regulations to help 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 46.

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 of our key performance 
indicators, see page 1. 
 For further details of our business model,  
see page 4.
 For further details of our principal risks and 
how they are managed, see pages 38 to 41.

Equipping our colleagues with sustainability skills

We are developing a range of sustainability-related resources and initiatives to help equip our 
colleagues with the skills to be able to support our net zero ambition. We expanded mandatory 
training that educates all colleagues on our approach to sustainability. In October, we launched 
the Sustainability Academy to equip specific colleagues with key skills to improve their 
understanding of topics ranging from climate change to biodiversity. We launched an ESG-
themed recognition campaign through the ‘At Our Best’ platform that encouraged colleagues to 
recognise each other’s ESG contributions. The campaign was well supported with nearly 200,000 
unique recognitions made, an increase of 50% on the previous year’s Spotlight campaign. 

For further details on the Sustainability Academy, see page 82.

HSBC Holdings plc Annual Report and Accounts 2022

19

Strategic reportStrategic report 

Board decision making and 
engagement with stakeholders 

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

Section 172 (1) statement

This section, from pages 20 to 23 forms  
our section 172(1) 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.

The Board understands its fundamental  
role in formulating and overseeing the Group’s 
strategy to achieve long-term success and  
fulfil its purpose of opening up a world of 
opportunity. Every scheduled Board meeting 
features the Group’s strategy as an item of 
discussion. When taking principal decisions, 
the Directors remain mindful that the matter 
for consideration should be aligned to one of 
the four strategic pillars. For further details  
of our purpose, values and strategy, see  
pages 4 and 11 to 13.

The Board, together with senior management, 
have given high priority to the format and 
content of papers presented to the Board and 
its committees for their consideration. The 

Group Chief Executive and the Group 
Chairman promote best governance practice 
by requiring that materials contain appropriate 
information to allow Directors to take informed 
decisions in keeping with their duties. The 
Corporate Governance and Secretariat team 
supports the provision of relevant information 
by providing governance guidance and 
direction regarding the key areas for 
consideration in relation to section 172 factors 
in order to help the Directors to understand the 
likely consequences of their decisions  
long term.

The Group Chief Executive’s regular report  
to the Board provides insights into key 
stakeholder sentiments by highlighting the 
interactions he has held with customers, 
regulators, employees and other stakeholders, 
and the importance of – and learnings from 
– these engagements. This informs the Board as 
to how the Group fosters its relationships with 
stakeholders and how the Group’s business 
affects the environment and the communities  
it serves. Directors also participate in a variety  
of stakeholder engagement events, which 
support their understanding of key issues and 

challenges, which can then be factored into 
future decision making.

The Board recognises that to promote the 
Group’s success, the right culture must exist 
throughout the organisation, be clearly 
understood and be consistently applied. This is 
supported by HSBC’s values, which help us 
succeed together by connecting, collaborating 
and acting with a shared purpose. Each Board 
meeting begins with a ‘cultural moment’, 
which includes observations of behaviours 
within the Group aligned to our purpose and 
values. The Board and its committees also 
receive updates on conduct issues and any 
consequences for stakeholders at its meetings, 
in particular from the Group Chief Risk and 
Compliance Officer and Group Human 
Resources Officer. The Group’s refreshed 
conduct approach, approved in 2021, also 
helps to support the consistent application of 
conduct principles across the organisation, 
acknowledging the importance of maintaining 
a good reputation for high standards of 
business conduct. For further details on  
the Board’s oversight of culture, see the 
‘Corporate governance report’ on page 255.

Stakeholder engagement and key considerations for the Board

The Board continued to focus on its 
engagement with our key stakeholders, 
acknowledging that this engagement is core  
to being a responsible business and furthers  
the fulfilment of our strategy. In discharging  
their responsibilities, the Directors sought to 
understand, and have regard to, the interests 
and priorities of the Group’s key stakeholders, 
including in relation to material decisions that 
were taken by the Board during the course of 
the year.

Virtual and physical meetings 
During 2022, the Board was able to resume  
its active engagement with stakeholders in 
person following two years of Covid-19-related 
restrictions. The Board met physically in 
several international locations, where it was 
able to carry out engagements with a wide 
range of stakeholders. For further details of 
how we engaged with our stakeholders,  
see pages 21 and 253.

We hosted our second hybrid AGM and 
engaged directly with our investors leading  
up to and during the event. The Informal 
Shareholders’ Meeting in Hong Kong also 
resumed for the first time since 2019 and 

attracted hundreds of shareholders to attend in 
person to receive an update on the Group’s 
strategy and discuss the latest financial 
performance with the Group Chairman, the 
Group Chief Executive and the Group Chief 
Financial Officer. We are focused on treating 
our shareholders fairly, by having a consistent 
approach to engagement and communication 
with them, and this approach is demonstrated 
by our refreshed shareholder communication 
policy. Such a policy helps to support the 
Board to act fairly between members of the 
company.

Doing business responsibly
Maintaining a transparent and trusting 
relationship with our regulators remains key  
to helping us ensure that we do business 
responsibly and that we are able to respond  
to challenges appropriately. In addition to 
continuous assessment meetings with the UK 
regulator (including with Board committee 
chairs), the Group Chairman, the Group Chief 
Executive and the Group Chief Financial Officer 
met with our regulators in the UK and Hong 
Kong on a regular basis. These included 
meetings in connection with our recovery and 
resolution planning, which involved several 

Board members engaging directly with the UK 
regulator. The Group Chairman and the Group 
Chief Executive also met regularly with 
government officials globally to continue to 
foster strong international relations. In addition, 
certain Board members also continued to be 
actively involved in climate initiatives and 
attend global events such as the Group Chief 
Executive’s attendance at the COP27 Summit 
in Egypt.

During Board meetings, the Directors  
continued to balance discussions on the 
Group’s performance, emerging risks and 
duties to shareholders, while remaining 
conscious of responsibilities to support 
communities and help customers. Feedback 
from – and engagement with – stakeholders 
helps inform the Board on the execution of its 
responsibilities.

On pages 22 and 23, we set out four 
examples that demonstrate how the Board 
made certain decisions while considering 
stakeholders, in accordance with the 
Directors’ section 172 duties, and how the 
decisions support or accelerate the delivery  
of the Group’s strategy.

20

HSBC Holdings plc Annual Report and Accounts 2022

Board decision making and engagement with stakeholders

Stakeholder engagement key events in 2022

Stakeholders

Engagement

Impact

Customers
We recognise that the greater 
our understanding of our 
customers’ needs, the better  
we can help support them to 
achieve their financial aims  
and succeed in our purpose  
and strategy.

 – Engagement events with customers ranging from small 
businesses to multinational companies, in key markets. 

 – Meetings with business customers in key industries to 

discuss plans regarding the transition to net zero.

 – Board reporting on retail customer surveys including  
net promoter scores and millennial retail customers’ 
satisfaction.

 – By formally and informally engaging with customers  

and potential customers, the Board can form a deeper 
understanding of why clients do business with us and 
how they contribute to achieving our purpose  
and ambition. 

 – Meetings with clients help the Board to understand how 

the Group can work to achieve its commitment to 
transition to net zero. 

 – Customer surveys provide insights into how our 

customers perceive our services and inform how  
we can drive meaningful improvements.

Employees
We want to continue to be a 
positive place to work and build 
careers, with the success of the 
Group’s strategy dependent 
upon having motivated people 
with the expertise and skills 
required to deliver it.

 – Employee events, including leadership forums, 
webcasts, townhalls, global jams, off-sites and  
employee Exchanges. 

 – Meeting with colleagues across jurisdictions allowed  

the Board to hear directly the employee voice on 
important issues. 

 – Extensive interaction with employee resource groups 

 – These interactions helped inform the Board when it 

across multiple events in many jurisdictions.

 – Several dedicated talent sessions, including with women 

and other diverse talent pools.

 – Next Gen gatherings for graduates, including dedicated 

focus group interactive sessions.

considers people matters such as career development, 
policies and business operations, including technology 
needs. Engagement also helps the Board to 
contextualise employee Snapshot survey results. 

 – The appointment of a dedicated workforce engagement 
non-executive Director has created a different way for 
the employee voice to be heard and demonstrates the 
Board’s commitment to understanding what matters to 
our people.

 – Regular and ad hoc interactions with institutional and 
retail investors allow for updates on strategy delivery, 
including the transition to net zero. This in turn helps the 
Board understand investor sentiment on material matters 
throughout the year. 

 – Such engagements also serve to inform investors of key 
developments so that they are well informed and able  
to respond appropriately when significant events are 
communicated. 

 – The Board recognises that the Group can influence 
meaningful change in many ways, including by 
educating, encouraging broader thinking, helping to 
shape policy and formulating worldwide solutions, 
creating safe environments and achieving net  
zero ambitions.

 – Frequent and varied engagement between the Board 
and government officials and regulators provides an 
opportunity for an open, two-way communication. It is 
also critical in ensuring that the Board understands and 
meets its regulatory obligations.

 – Meeting with international officials allows the Board to 
communicate the Group’s strategy, perspectives and 
insights while ensuring that Directors remain abreast of 
political and regulatory trends. It also allows the Board to 
share perspectives on standards of best practice across 
industries and regions.

Investors
We seek to understand investor 
needs and sentiment through 
ongoing dialogue and a variety 
of engagements with both retail 
and institutional investors.

 – Numerous meetings with analysts and several 

roadshows to discuss interim and year-end results.

 – Remuneration Committee Chair investor meetings with 

top investors and proxy advisers.

 – Annual retail investor events such as the AGM in the UK 
and the Informal Shareholders’ Meeting in Hong Kong.

Communities
We seek to play an important 
role in supporting the 
communities in which we 
operate through our corporate 
social responsibility and broader 
engagement activities.

 – Forums and summits supporting ESG causes, such as 

the Glasgow Financial Alliance for Net Zero, the Financial 
Services Task Force of the Sustainable Markets Initiative 
and the World Economic Forum.

 – The Directors’ participation at a range of community 
initiatives helps them to experience first-hand the 
positive effect the Group has on local communities  
as an employer, sponsor, collaborator and supporter. 

 – Visits to local community education facilities in the  

UK and Dubai to promote initiatives and collaboration, 
including a ‘future coders’ event and a local  
sustainability project.

Regulators and 
governments
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. 

 – Various meetings across our key markets with 

governmental officials, including leaders, ministers  
and ambassadors.

 – Regular meetings with our many regulators, including  

in the UK and Hong Kong, and elsewhere.

 – Meetings with non-government bodies and 

organisations including the European Central Bank,  
Bank of England, Monetary Authority of Singapore,  
State Bank of India, Public Investment Fund and the  
Bank for International Settlements.

Suppliers
We engage with suppliers, 
which helps us operate our 
business effectively and  
execute our strategy.

 – Regular reports and updates from the Group Chief 

 – Meeting with our suppliers helps Directors understand 

Operating Officer on supplier matters.

 – Meetings with existing and prospective auditors  

as part of the audit tender process.

 – A meeting with customers (who are also our suppliers)  

in the Middle East.

 – Interactive sessions with catering and real estate 

suppliers including on their net zero plans.

our suppliers’ challenges and how we can work 
collaboratively to succeed, particularly in achieving our 
net zero ambitions.

 – It is key for the Board to understand the Group’s supply 
chain and how suppliers’ operations are aligned to our 
purpose and values.

 – This supports the Board when approving its Modern 

Slavery Act Statement.

HSBC Holdings plc Annual Report and Accounts 2022

21

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

Principal decisions

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. The following examples demonstrate 
how these Board decisions, taken in 2022, align to each of our four strategic pillars.

Focus on our strengths 

The Board undertook a 
strategic review of the 
Group’s Canada business 
in support of the Group’s 
strategic aims. 

Energise for growth 

The Board approved  
a review of its 
headquarters’ office 
location in London to 
support its employees  
in creating a more 
dynamic and agile 
environment in which  
to work.

The Board, together with senior management, 
keep under review potential inorganic 
opportunities to help accelerate the delivery of 
our strategy and deliver value for shareholders. 
In 2022, to further the Group’s strategy and 
ambition, and following a strategic review, the 
Board took the decision for the Group to sell its 
Canadian business to Royal Bank of Canada.

The review considered HSBC Canada’s 
relatively low market share and whether it  
was in the Group’s best interests to invest  
in HSBC Canada’s expansion and growth in 
the context of opportunities in other markets. 
It was concluded that the best course of 
strategic action was for the Group to sell HSBC 
Canada. The Board’s decision to approve the 
sale was aligned to the Group’s strategic pillar 
of focus on our strengths.

The implications of the transaction for several 
key stakeholders were considered and many 
stakeholders were engaged with, including 
Canadian government officials and regulators 
in both the UK and Canada. Financial and  
legal advisers were engaged throughout the 
process to provide specialist advice to help 
inform the Board’s understanding and allow  

it to take a decision. Transaction terms were 
carefully negotiated to provide certainty for  
the Group’s employees in Canada. The Board 
also acknowledged that completion of the 
transaction would require engagement with 
additional key stakeholders, including 
employees, customers and suppliers. 

The Board considered there to be a number of 
benefits to the disposal, including simplifying 
the Group structure and helping to further the 
aim of becoming a market leader in wealth 
management, with a particular focus on Asia. 
In addition, the transaction would unlock 
significant value for the Group and realise a 
good return for our shareholders.

For the reasons set out above, in taking this 
decision, the 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 long-term 
success of the company for the benefit of its 
members as a whole.

Our strategic pillar, energise for growth, 
includes a commitment to inspire a dynamic 
culture where the best talent want to work. 
Throughout the Covid-19 pandemic, we saw 
how we could continue to deliver our work 
commitments through a hybrid working model 
and the value that hybrid working brings for 
our clients and colleagues. Our workstyle 
approach is helping us to attract and retain 
diverse talent, while enabling us to reduce  
our office footprint.

We want our head office to connect  
people, drive collaboration, foster alternative 
workstyles and promote well-being. With  
this in mind, in September 2022, the Board 
considered a proposal to review the location  
of our global headquarters. While we are 
committed to remain in London, the success 
of hybrid working has meant our workspace 
requirements are changing, creating the 
opportunity to drive a new real estate model  
fit for a modern bank.

The views from several stakeholders helped  
to shape this key decision. Employee surveys 
provided evidence to support hybrid working, 
which informed the decision to review the 

global headquarters location. The Board 
recognised the importance of taking this 
decision early enough to provide sufficient 
notice to relevant suppliers, including the 
affected landlords, to best prepare for any 
changes. Our UK regulators were also 
engaged with in good time to ensure that  
they were informed of our intentions to  
stay in London. 

An important Board consideration factored 
into the new office environment review 
included that it should be more digitally 
enabled, so as to help us work smarter  
and develop future-ready skills. The Board  
also acknowledged that the new office 
environment should be designed in a 
sustainable way to help meet our net zero 
commitments. In taking this decision, the 
Board focused on its strategic aspiration to 
have a more flexible and dynamic workspace 
that meets the needs of everyone. The Board 
took into account the section 172 factors along 
with the relevant stakeholder engagement, 
which informed its decision to commence the 
review with a view to best promote the 
success of the company for the long term.

22

HSBC Holdings plc Annual Report and Accounts 2022

 
Board decision making and engagement with stakeholders

Transition to net zero 

The Board remained 
active and directly 
engaged on the Group’s 
response to the climate 
change agenda, 
agreeing an updated 
energy policy aligned to 
our ambition to support 
the transition to a net 
zero global economy.

Digitise at scale 

The Group is committed 
to creating and delivering 
on fast, easy, digital 
customer experiences.

The Board has remained focused on  
its commitments, following the climate 
change resolution passed at the 2021 AGM,  
to support our customers on their transitions 
to a low-carbon future.

need to balance the responsibility of 
facilitating a just transition, helping to ensure 
continued access to affordable energy sources 
in the markets we serve, and supporting an 
accelerated transition. 

In 2022, the Board approved an update to the 
thermal coal phase-out policy. It also approved 
the publication of an updated energy policy, 
which was considered well aligned to our 
strategic approach to transition to net zero. 
The energy policy seeks to balance three 
objectives: driving down global greenhouse 
gas emissions; the need to enable an orderly 
transition that builds resilience in the longer 
term; and the need to support a just and 
affordable transition. In developing this policy, 
the Board was informed of the engagement 
undertaken with several internal and external 
stakeholders including: governments, major 
clients, large institutional investors and leading 
scientific and international bodies and industry 
participants. The Board took into consideration 
the active role we are seeking to play in 
supporting and accelerating the energy 
transition in the markets we serve and the 
crucial importance of engaging with our 
customers on their own transition plans. The 
Board also considered the long-term impacts 
of the policy on its stakeholders including the 

The Group’s digital strategy aims to ensure 
that ways of working for colleagues, as  
well as the experience of our customers,  
are technologically advanced and efficient. 
Digitise at scale means we are focused on 
creating and delivering fast, easy, digital 
customer experiences by partnering with 
technology innovators and working together 
to enable new customer benefits. The Board’s 
oversight of our digital strategies and policies 
is important given that these are critical in 
helping to ensure the Group’s resiliency and 
customer security. 

The Group Chief Executive regularly reports  
to the Board on his engagements with – and 
feedback from – customers on the Group’s 
digital strategy progress. The Board has 
engaged with many customers over the past 
year, and is focused on ensuring that  
our customers’ experiences meet their 
expectations. Customer survey insights 
throughout 2022 have been used to deepen 
understanding of the digital landscape 
challenges customers face, and to help drive 
solutions. Consequently, the Group has led 
several key digital customer deliveries in 2022, 
with approximately 49% of customers being 
mobile active and around 48% of retail sales 
being performed through digital channels. 
Delivery of these new initiatives improved 
customer experiences across our global 
markets in 2022, and supported the Group’s 
efforts to execute at speed and automate at 
scale – a cornerstone of our strategy. 

Since publication of the energy policy, 
stakeholder engagement has continued, 
including with key institutional investors to 
discuss 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 begin the 
implementation of the policy.

In taking the decision to approve the energy 
policy and in overseeing the Group’s climate 
commitments, the Board gave due regard  
to the section 172 factors, in particular the 
impact of the decision on the environment  
and communities the company serves,  
our continuing valuable relationships with 
customers and investors, and the long-term 
success of the company.

The Board also receives updates from the 
Group Chief Operating Officer on the various 
ways the Group is furthering its digital 
strategy. Vision 27, which is our long-term 
technology strategy, featured regularly on  
the Board agenda and was launched at the 
beginning of 2022. Its aim is to help transform 
HSBC into a digital-first bank over the next five 
years. One of the Vision 27 initiatives is the 
development of a digital technology map, 
which is a bespoke tool developed to capture 
all of the Group’s applications and systems 
and provide insight and data points on these 
including usage by businesses, regions and 
entities. The Board and the Technology 
Governance Working Group have also 
challenged management on the prioritisation 
of digital initiatives, as well as the demise of 
legacy and non-strategic applications, as part 
of efforts to streamline the large and complex 
technology architecture. This is a key focus  
in helping to improve the resiliency and 
efficiency of our systems for colleagues  
and customers.

In taking these decisions, whether by the 
Board directly, or the business through its 
delegated authority, the digital needs of 
customers and employees are taken into 
account in order to create long-term success 
of the company and become a truly data-led 
organisation.

HSBC Holdings plc Annual Report and Accounts 2022

23

Strategic reportStrategic report 

Remuneration

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

Our remuneration 
approach

We have refreshed our reward strategy and 
proposition for the workforce in response to 
the new or elevated challenges we are facing 
as we move beyond the Covid-19 pandemic, 
including the cost of living pressures many  
of our colleagues are experiencing. The 
commitments we make to colleagues are 
critical to support us in energising for growth 
and delivering sustainable performance.

 For further details of what we did during 2022  
to help ensure remuneration outcomes were 
consistent with this approach, see page 292. 

Remuneration for our 
executive Directors

Our current remuneration policy for executive 
Directors was approved by 96% of our 
shareholders at our AGM in 2022 and will 
apply for a maximum of three years until the 
AGM in 2025. We made no changes to the 
remuneration structure or to the maximum 
opportunity payable for each element of 
remuneration. Details of the policy can be 

found on pages 257 to 265 of our previous 
Annual Report and Accounts 2021.

The table below shows the amount our 
executive Directors earned in 2022. For details 
of Directors’ pay and performance for 2022, see 
the Directors’ remuneration report on page 282.

Single figure of remuneration

(£000)

Base salary

Fixed pay allowance

Cash in lieu of pension

Taxable benefits

Non-taxable benefits

Total fixed
Annual incentive

Notional returns

Replacement award

Long-term incentive

Total variable

Total fixed and variable

Noel Quinn

Ewen Stevenson

2022

1,329

1,700

133

119

86

3,367

2,164

31

—

—

2,195

5,562

2021

1,288

1,700

129

95

71

3,283

1,590

22

—

—

1,612

4,895

2022

775

1,085

77

7

50

1,994

1,091

—

1,180

436

2,707

4,701

2021

751

1,062

75

3

42

1,933

978

—

754

—

1,732

3,665

Notes and commentary related to this table are provided in the Directors’ remuneration report on page 284.

24

HSBC Holdings plc Annual Report and Accounts 2022

Remuneration

Remuneration for our executive Directors continued

Variable pay for our executive Directors is 
driven primarily by achievement against 
performance scorecards, with measures  
and targets set by the Group Remuneration 
Committee at the start of the year to align pay 
outcomes with the delivery of our strategy and 
plan. After the formulaic scorecard outcome 
was determined, the Group Remuneration 

Committee applied a downward adjustment  
of 5% and 15% to Noel Quinn’s and Ewen 
Stevenson’s 2022 annual incentive outcomes, 
respectively, to take into account specific risk 
matters around capital management in the 
year. Further details are provided in the 
Directors’ remuneration report.

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

Group Chief Executive

Group Chief Financial Officer

75.35%

65.15%

Remuneration for our colleagues

Variable pay pool 

($m)

2022

2021

3,359

3,495

The Group Remuneration Committee 
determined an overall variable pay  
pool for Group employees of $3,359m  
2019
(2021: $3,495m). This followed a review  
of our performance against financial and 
non-financial metrics set out in the Group  
risk framework. The Group Remuneration 
Committee considered our 2022 financial 
performance, with a 17% increase in adjusted 
profit before tax, return on average tangible 

equity of 9.9% and costs slightly up year on 
year. The Group Remuneration Committee 
also considered the external environment, the 
challenging economic outlook and projected 
outcomes across the market to ensure we 
remain competitive to attract and retain talent.

The distribution of the pool was differentiated 
by business performance. Overall year-on-year 
variable pay outcomes were strongest in  
CMB, followed by WPB but down in GBM  
to reflect relative performance. There  
was robust differentiation for individual 
performance so that our highest performers 
received meaningful variable pay increases 
compared with the previous year. We have 
protected variable pay for junior colleagues, 
which is up on average, recognising the 

inflationary and cost of living challenges 
experienced across most of our markets.

In determining 2023 fixed pay increases, we 
considered the impact of inflation in each 
country where we operate. Increases were 
targeted towards more junior and middle 
management colleagues as fixed pay is a 
larger proportion of their overall pay. Across 
the Group, there was an overall increase of 
5.5% in fixed pay, compared with 3.6% for 
2022. The level of increases varies by country, 
depending on the economic situation and 
individual roles. There were no fixed pay 
increases for most of our senior leaders, 
including our executive Directors.

 For details of how the Group Remuneration 
Committee sets the pool, see page 276.

Supporting our colleagues during 2022

We know that many colleagues around the world are facing different pressures, and we are 
committed to supporting them, adapting our approach according to the market. 

For colleagues who are still significantly impacted by the pandemic, for example in mainland 
China and Hong Kong, we provided care packages and increased well-being sessions. In 
mainland China, we also delivered food essentials and provided inconvenience allowances. 
Separately, in Argentina and Türkiye, we made regular adjustments to fixed pay given the 
continuing inflationary pressures. In Sri Lanka, we made one-off payments and fixed pay 
increases during the year to address high inflation. In the UK, we provided almost 17,000 
junior colleagues with a one-off payment of £1,500 to help with energy cost pressures. We 
have continued to provide a wide range of resources to all our colleagues globally, including 
wider support on financial guidance, employee assistance programmes and access to 
hardship funds.

For further details of how we are supporting colleague well-being, see page 80. 

HSBC Holdings plc Annual Report and Accounts 2022

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

Group financial targets

Financial performance in 2022 was 
supported by a rise in global interest rates, 
which materially improved our net interest 
income, and we maintained our strong 
focus on cost discipline, despite inflationary 
pressures and continued investment. While 
our revenue outlook remains positive, there 
are continued risks around inflation and 
increasing macroeconomic uncertainty in 
many of the markets in which we operate.

Reported profit after tax for 2022 of  
$16.7bn was 13% higher, which included  
an effective tax rate charge of 4.9% due  
to the benefit of credits related to the 
recognition of deferred tax assets. Our 
return on average tangible equity (‘RoTE’) 
improved by 1.6 percentage points to  
9.9%. Reported profit before tax of  
$17.5bn decreased by 7%, which included 
an impairment of $2.4bn following the 
reclassification of our retail banking 
operations in France to held for sale, as  
well as a more normalised charge for 
expected credit losses (‘ECL’), compared 
with a net release in 2021. These reductions 
were mitigated by the favourable impact of 
higher interest rates on reported revenue 
and a reduction in reported operating 
expenses, primarily due to the favourable 
impact of foreign currency translation 
differences.

The Group CET1 capital ratio fell  
1.6 percentage points to 14.2% at  
31 December 2022. In addition, customer 
deposit and lending balances both fell 
compared with 31 December 2021, 
reflecting the reclassification to held for  
sale of balances, notably from our retail 
banking operations in France and our 
banking business in Canada, as well  
as from the adverse impact of foreign 
currency translation differences. 
Notwithstanding these impacts, there  
was mortgage growth in the UK and  
Hong Kong, which mitigated a reduction  
in term lending in CMB in Hong Kong.

Return on average tangible equity

9.9%

(2021: 8.3%)

In 2022, RoTE was 9.9%, an increase of  
1.6 percentage points from 2021. 

Despite increasing macroeconomic uncertainty, 
the impact of our growth and transformation 
programmes, together with the positive revenue 
outlook, give us confidence in achieving our  
RoTE target of at least 12% for 2023 onwards.

Adjusted operating expenses

$30.5bn

(2021: $30.1bn)

During 2022, we continued to demonstrate  
strong cost discipline, despite inflationary 
pressures. We achieved 1% growth in adjusted 
operating expenses compared with 2021,  
relative to our target of broadly stable adjusted 
operating expenses.

Our cost to achieve programme concluded on  
31 December 2022. Cumulatively, since the start 
of the programme in 2020, we have realised gross 
savings of $5.6bn, with cost to achieve spend  
of $6.5bn. We expect approximately $1bn of 
additional gross cost saves from this programme 
in 2023, due to actions taken in 2022.

We retain our focus on cost discipline and will 
target 2023 adjusted cost growth of approximately 
3% on an IFRS 4 basis. This includes up to $300m 
of additional severance costs in 2023, which we 
expect to generate further efficiencies into 2024. 
There may also be an incremental adverse  
impact from retranslating the 2022 results of 
hyperinflationary economies at constant currency.

Gross risk-weighted asset reductions

$128bn

Since the start of the programme.

At 31 December 2022, the Group had delivered 
cumulative gross RWA reductions of $128bn, 
relative to our target to achieve gross RWA 
reductions of $110bn or more by the end of  
2022. This included accelerated saves of  
$9.6bn made in 2019. This programme  
concluded on 31 December 2022.

Capital and dividend policy
CET1 ratio

Dividend payout ratio

14.2%

44%

At 31 December 2022, our common equity  
tier 1 (‘CET1’) capital ratio was 14.2%, down 
1.6 percentage points from 31 December 2021. 
Having fallen below 14% during 2022, we are 
back within our medium-term CET1 target 
range of 14% to 14.5%. We intend to continue 
to manage capital efficiently, returning excess 
capital to shareholders where appropriate.

The Board has approved a second interim 
dividend for 2022 of $0.23 per ordinary share. 
The total dividend per share in 2022 of $0.32 
results in a dividend payout ratio of 44%, 
relative to our 2022 target range of between 
40% and 55% from 2022 onwards. In 
determining our dividend payout ratio for 2022, 
the impairment on the planned sale of our retail 
banking operations in France, the $1.8bn 
impact from the recognition of a deferred tax 
asset for the UK tax group and HSBC Canada’s 
financial results from the 30 June 2022 net 
asset reference date are excluded from the 
reported earnings per share.

We are establishing a dividend payout ratio of 
50% for 2023 and 2024, excluding material 
significant items (including the planned sale  
of our retail banking operations in France and 
the planned sale of our banking business in 
Canada), with consideration of buy-backs 
brought forward to our first quarter results in 
May 2023, subject to appropriate capital levels. 
We also intend to revert to paying quarterly 
dividends from the first quarter of 2023. 

Subject to the completion of the sale of our 
banking business in Canada, the Board’s 
intention is to consider the payment of a 
special dividend of $0.21 per share as a priority 
use of the proceeds generated by completion 
of the transaction. A decision in relation to any 
potential dividend would be made following 
the completion of the transaction, currently 
expected in late 2023, with payment following 
in early 2024. Further details in relation to 
record date and other relevant information  
will be published at that time. Any remaining 
additional surplus capital is expected to be 
allocated towards opportunities for organic 
growth and investment alongside potential 
share buy-backs, which would be in addition  
to any existing share buy-back programme.

26

HSBC Holdings plc Annual Report and Accounts 2022

 
 
Financial overview

Key financial metrics

Reported results

Reported profit before tax ($m)

Reported profit after tax ($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 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 (%)

Expected credit losses and other credit impairment charges (‘ECL’) as % of average 
gross loans and advances to customers, including held for sale (%)2

Return on average ordinary shareholders’ equity (%)

Return on average tangible equity (%)

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)3,4

Total capital ratio (%)3,4

Leverage ratio (%)3,4

High-quality liquid assets (liquidity value) ($bn)4,5

Liquidity coverage ratio (%)4,5

Net stable funding ratio (%)4,5

Share count

For the year ended

2022

17,528

16,670

64.4

1.48

0.75

0.74

0.32

44

2021

18,906

14,693

69.9

1.20

0.62

0.62

0.25

40

2020

8,777

6,099

68.3

1.32

0.19

0.19

0.15

79

24,010

20,603

11,695

55.0

0.36

0.35

8.7

9.9

64.0

(0.08)

(0.08)

7.1

8.3

62.3

0.87

0.87

2.3

3.1

At 31 December

2022

2021

2020

2,966,530

924,854

1,570,303

2,203,639

58.9

187,484

149,355

8.50

7.57

2,957,939

1,045,814

1,710,574

2,209,513

61.1

198,250

158,193

8.76

7.88

2,984,164

1,037,987

1,642,780

2,092,900

63.2

196,443

156,423

8.62

7.75

14.2

15.8

839,720

838,263

15.9

857,520

19.3

5.8

647

132

136

21.2

5.2

688

139

N/A

21.5

5.5

678

139

N/A

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)

19,739

19,876

20,073

20,189

20,184

20,272

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

19,849

20,197

20,169

For reconciliations of our reported results to an adjusted basis, including lists of significant items, see page 109. Definitions and calculations of other alternative 
performance measures are included in our ‘Reconciliation of alternative performance measures’ on page 128.
1  Dividend per share, in respect of the period, as a percentage of earnings per share adjusted for certain items (recognition of certain deferred tax assets: $0.11 reduction 

in EPS; planned sales of the retail banking operations in France and banking business in Canada: $0.09 increase in EPS). No items were adjusted in 2021 or 2020.

2 Includes average gross loans and advances to customers reported within ‘assets held for sale’. 
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 208. Leverage ratios are reported 
based on the disclosure rules in force at that time, and include claims on central banks. Current period leverage metrics exclude central bank claims in accordance with 
the UK leverage rules that were implemented on 1 January 2022. 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.

4  Regulatory numbers and ratios are as presented at the date of reporting. Small changes may exist between these numbers and ratios and those subsequently 

submitted in regulatory filings. Where differences are significant, we will restate in subsequent periods.

5  The liquidity coverage ratio is based on the average value of the preceding 12 months. The net stable funding ratio is based on the average value of four preceding 

quarters. The LCR in December 2021 has been restated for consistency. We have not restated the prior periods for NSFR as no comparatives are available.

HSBC Holdings plc Annual Report and Accounts 2022

27

Strategic reportStrategic report | Financial overview

Reported results

Reported profit
Reported profit after tax of $16.7bn was 
$2.0bn or 13% higher than in 2021, and 
included a $2.2bn credit arising from the 
recognition of a deferred tax asset from 
historical tax losses in HSBC Holdings. It  
also benefited from other deferred tax asset 
and uncertain tax position reassessments, 
resulting in an effective tax rate of 5%. 

Reported profit before tax of $17.5bn was 
$1.4bn or 7% lower than in 2021. The decrease 
reflected a net ECL charge of $3.6bn in 2022, 
which included stage 3 charges of $2.2bn,  
in part relating to the commercial real estate 
sector in mainland China, as well as from  
the impact of heightened economic 
uncertainty, inflation and rising interest rates. 
This compared with a net release of $0.9bn in 
2021. This adverse movement in reported ECL 
was partly offset by higher reported revenue 
and lower reported operating expenses.

The increase in reported revenue primarily 
reflected higher net interest income from the 
positive impact of interest rate rises on all of 
our global businesses. This was partly offset 
by an impairment of $2.4bn recognised 
following the reclassification of our retail 
banking operations in France as held for sale 
on 30 September 2022, an adverse impact of 
foreign currency translation differences and 
unfavourable market impacts in life insurance 
manufacturing in WPB. Lower reported 
operating expenses primarily reflected  
the favourable impact of foreign currency 
translation differences, while restructuring  
and other related costs increased. 

Effective 1 January 2023, 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 replaces IFRS 4 and could have 
a significant adverse impact on the profitability 
of our insurance business on transition. For 
further details of the impact of IFRS 17 on  
the results of our insurance operations,  
see page 335.

Reported revenue
Reported revenue of $51.7bn was $2.2bn  
or 4% higher than in 2021, primarily due to  
an increase in net interest income from the 
positive impact of interest rate rises, mainly  
in Global Payments Solutions (‘GPS’) in CMB 
and GBM, and in Personal Banking in WPB.  
In GBM, Global Foreign Exchange revenue 
benefited from increased client activity due to 
elevated levels of market volatility. In addition, 
there were strong sales in our life insurance 
manufacturing business in WPB, with growth 
in the value of new business, while insurance 
revenue also included a gain following a 
pricing update for our policyholders‘ funds 
held on deposit with us in Hong Kong to 
reflect the cost to provide this service.

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 increases were partly offset by an 
impairment of $2.4bn recognised following the 
reclassification of our retail banking operations 
in France as held for sale on 30 September 
2022, as well as losses of $0.4bn associated 
with the planned sales of our branch 
operations in Greece and our business in 
Russia. Reported revenue included an adverse 
impact of foreign currency translation 
differences of $3.1bn, and unfavourable market 
impacts in life insurance manufacturing in 
WPB of $1.0bn, compared with favourable 
movements in 2021 of $504m. There was also 
a decrease in Markets Treasury revenue, which 
is allocated to our global businesses, due to 
lower net interest income from the impact of 
rising interest rates on our funding costs and 
flattening yield curves across all regions, as 
well as from lower disposal gains related to  
risk management activities. 

Lower net fee income reflected a reduction  
in investment distribution income in WPB  
due to muted customer sentiment resulting  
in reduced activity in equity markets, and 
Covid-19-related restrictions in Hong Kong in 
early 2022, which resulted in the temporary 
closure of parts of our branch network. Since 
then, restrictions have substantially been 
eased. Additionally in GBM, there were lower 
fees in Capital Markets and Advisory, in line 
with the reduced global fee pool. In Principal 
Investments, lower revaluation gains resulted 
in a reduction in revenue relative to 2021. 

Reported ECL
Reported ECL were a net charge of $3.6bn, 
which included stage 3 charges of $2.2bn,  
in part relating to the commercial real estate 
sector in mainland China. We also recognised 
additional stage 1 and stage 2 allowances  
to reflect heightened levels of economic 
uncertainty, inflation, supply chain risks and 
rising interest rates, in part offset by the release 
of most of our remaining Covid-19-related 
allowances. This compared with a net release 
of $0.9bn in 2021 relating to Covid-19-related 
allowances previously built up in 2020.

 For further details of the calculation of ECL,  
see pages 153 to 162.

2022

$m

2021

$m

2020

$m

51,727

49,552

50,429

(3,592)

928

(8,817)

48,135

(33,330)

14,805

2,723

17,528

(858)

16,670

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

Reported operating expenses
Reported operating expenses of $33.3bn  
were $1.3bn or 4% lower than in 2021, 
primarily as foreign currency translation 
differences resulted in a favourable impact of 
$2.2bn, as well as from the non-recurrence of 
a 2021 goodwill impairment of $0.6bn related 
to our WPB business in Latin America. 

Reported operating expenses also reflected 
the impact of ongoing cost discipline across 
the Group. This helped mitigate the cost  
of increased investment in technology of 
$0.5bn, which included investments in our 
digital capabilities, as well as the impact of 
business volume growth and inflation. 
Restructuring and other related costs 
increased by $1.0bn.

Reported share of profit from associates 
and joint ventures
Reported share of profit from associates  
and joint ventures of $2.7bn was $0.3bn or 
11% lower than in 2021, primarily as 2021 
included a higher share of profit from Business 
Growth Fund (‘BGF’) due to the recovery in 
asset valuations. This was partly offset by  
an increase in the share of profit from  
The Saudi British Bank (‘SABB’).

Tax expense
Tax in 2022 was a charge of $0.9bn and 
included a $2.2bn credit arising from the 
recognition of a deferred tax asset from 
historical tax losses in HSBC Holdings.  
This was a result of improved profit forecasts 
for the UK tax group, which accelerated  
the expected utilisation of these losses  
and reduced uncertainty regarding their 
recoverability. We also benefited from other 
deferred tax asset and uncertain tax position 
reassessments during 2022. Excluding these, 
the effective tax rate for 2022 was 19.2%, 
which was 3.1 percentage points lower than  
in 2021. The effective tax rate for 2022 was 
decreased by the remeasurement of deferred 
tax balances following the substantive 
enactment in the first quarter of 2022 of 
legislation to reduce the rate of the UK banking 
surcharge from 8% to 3% from 1 April 2023.

28

HSBC Holdings plc Annual Report and Accounts 2022

Financial overview

Adjusted performance

Our reported results are prepared in 
accordance with IFRSs, as detailed in  
the financial statements on page 335.

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.

 For reconciliations of our reported results to an 
adjusted basis, including lists of significant items, 
see page 109. Definitions and calculations of 
other alternative performance measures are 
included in our ‘Reconciliation of alternative 
performance measures’ on page 128.

Adjusted results

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

2022

$m

2021

$m

2020

$m

55,345

47,020

48,848

2022 vs 2021

$m

8,325

%

18

Change in expected credit losses and other credit impairment charges 

(3,592)

754

(8,815)

(4,346)

>(200)

Total operating expenses

Operating profit

Share of profit in associates and joint ventures

Profit before tax

Tax

Profit after tax

Adjusted profit before tax
Adjusted profit after tax of $19.7bn was $3.4bn 
or 21% higher than in 2021.

Adjusted profit before tax of $24.0bn was 
$3.4bn or 17% higher than in 2021, reflecting 
higher adjusted revenue, mainly from net 
interest income growth following global 
interest rate rises. This increase was partly 
offset by an ECL charge in 2022, compared 
with a net release in 2021. The ECL charge in 
2022 reflected stage 3 charges, as well as the 
impact of heightened economic uncertainty, 
inflation, supply chain risks and rising interest 
rates. Adjusted profit from associates and joint 
ventures decreased, while adjusted operating 
expenses increased by 1% compared with 
2021, reflecting investment in technology 
mitigated by continued cost discipline. 

Adjusted revenue
Adjusted revenue of $55.3bn was $8.3bn or 
18% higher than in 2021. The increase was 
driven by net interest income growth of $7.7bn 
following global interest rate rises, mainly in 
GPS in CMB and GBM, and Personal Banking 
in WPB. Global Foreign Exchange in GBM 
benefited from increased client activity due to 
elevated levels of market volatility, and there 
were strong sales in our insurance business in 
WPB, with the value of new business up by 
$0.2bn or 23%. In addition, insurance revenue 
included a $0.3bn gain following a pricing 
update for our policyholders‘ funds held on 
deposit with us in Hong Kong to reflect the 
cost to provide this service.

(30,466)

(30,104)

(30,445)

21,287

2,723

24,010

17,670

2,933

20,603

(4,287)

(4,241)

19,723

16,362

9,588

2,107

11,695

(3,274)

8,421

(362)

3,617

(210)

3,407

(46)

3,361

Reconciliation of reported profit before tax to adjusted profit after tax

Reported profit before tax

Currency translation

Significant items:

 – customer redress programmes

 – 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

2022

$m

2021

$m

17,528

18,906

—

6,482

(39)

2,817

579

(4)

—

(1,180)

2,877

38

—

242

587

—

 – restructuring and other related costs

3,129

2,143

 – 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

—

—

—

—

—

(1)

20

(7)

17

(1)

21

2020

$m

8,777

(303)

3,221

(33)

10

(264)

1,090

17

2,078

12

 462 

(133)

(151)

Adjusted profit before tax

Adjusted tax charge1

Adjusted profit after tax

24,010

20,603

11,695

(4,287)

(4,241)

19,723

16,362

(3,274)

8,421

1 For a reconciliation of reported to adjusted tax charge, see page 109. 

HSBC Holdings plc Annual Report and Accounts 2022

29

Strategic report 
Strategic report | Financial overview

Adjusted performance continued

These increases in adjusted revenue  
were partly offset by a net unfavourable 
movement in market impacts in life insurance 
manufacturing in WPB of $1.4bn. In addition, 
lower net fee income reflected a reduction  
in investment distribution income, as muted 
customer sentiment led to reduced activity  
in equity markets, and Covid-19-related 
restrictions in Hong Kong in early 2022 
resulted in the temporary closure of parts of 
our branch network. Since then, restrictions 
have substantially been eased. In GBM, there 
were lower fees in Capital Markets and 
Advisory revenue, in line with the reduced 
global fee pool. In Principal Investments, 
revenue fell due to lower revaluation gains 
relative to 2021.

Revenue relating to Markets Treasury 
decreased by $0.7bn due to lower net interest 
income from the impact of rising interest  
rates on our funding costs and flattening  
yield curves across all regions, as well as  
from lower disposal gains related to risk 
management activities. This revenue is 
allocated to our global businesses.

Adjusted ECL
Adjusted ECL were a net charge of $3.6bn, 
which included stage 3 charges of $2.2bn,  
in part relating to the commercial real estate 
sector in mainland China. The charge also 
included stage 1 and stage 2 allowances to 
reflect heightened economic uncertainty, 
inflation, supply chain risks and rising interest 
rates, in part offset by the release of most of 
our remaining Covid-19-related allowances. 
The net ECL release of $0.8bn in 2021 related 
to Covid-19 allowances previously built up  
in 2020.

Adjusted operating expenses
Adjusted operating expenses of $30.5bn were 
1% higher compared with 2021, as we actively 
managed the impact of inflation on our cost 
base through ongoing cost discipline. These 
reductions helped mitigate an increase from 
continued investment in technology of $0.5bn, 
which included investments in our digital 
capabilities, as well as growth due to  
business volume-related cost growth and  
the impact of inflation. Adjusted operating 
expenses also included the adverse impact  

of retranslating the prior year results of our 
operations in hyperinflationary economies  
at 2022 average rates of foreign exchange. 

The number of employees expressed 
in full-time equivalent staff (‘FTE’) at  
31 December 2022 was 219,199, a decrease  
of 498 compared with 31 December 2021.  
The number of contractors at 31 December 
2022 was 6,047, a decrease of 145.

Adjusted share of profit from associates 
and JVs
Adjusted share of profit from associates and 
joint ventures of $2.7bn was 7% lower than  
in 2021, primarily as 2021 included a higher 
share of profit from BGF due to the recovery in 
asset valuations. This was partly offset by an 
increase in the share of profit from SABB.

Balance sheet and capital

Balance sheet strength
At 31 December 2022, our total assets  
of $3.0tn were broadly unchanged from  
31 December 2021 on a reported basis,  
which included adverse effects of foreign 
currency translation differences of $152bn.  
On a constant currency basis, total assets 
increased $161bn, primarily from a growth  
in derivative asset balances. 

Reported loans and advances to customers 
decreased by $121bn. On a constant currency 
basis, loans and advances fell by $66bn, 
primarily due to the reclassification of $81bn of 
balances to held for sale, notably associated 
with our retail banking operations in France 
and our banking business in Canada. While 
our near-term outlook on lending growth 
remains cautious, we expect mid-single-digit 
percentage annual loan growth in the medium 
to long term. 

Reported customer accounts of $1.6tn 
decreased by $140bn, and by $52bn on  
a constant currency basis, mainly due to  
the reclassification to held for sale.

Reported loans and advances to customers  
as a percentage of customer accounts was 
58.9%, which was lower compared with 
61.1% at 31 December 2021.

Distributable reserves
The distributable reserves of HSBC Holdings 
at 31 December 2022 were $35.2bn, 

compared with $32.2bn at 31 December 2021. 
The increase was primarily driven by profits 
generated of $12.4bn and a foreign exchange 
gain on the redemption of additional tier 1 
securities of $0.4bn, offset by ordinary 
dividend payments and additional tier 1 
coupon distributions of $6.5bn, other reserves 
movements of $2.3bn and $1bn 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 and the impact 
on our capital ratios as a result of stress.

Our CET1 ratio at 31 December 2022 was 
14.2%, down 1.6 percentage points from 
2021. Capital generation was more than offset 
by new regulatory requirements, a fall in the 
fair value through other comprehensive 
income (‘FVOCI’), dividends, share buy-backs 
and foreign exchange movements. RWAs 
were relatively stable with growth broadly 
offset by foreign exchange movements.

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. During 2022, 
the average high-quality liquid assets we held 
was $647bn. This excludes high-quality liquid 
assets in legal entities which are not 
transferable due to local restrictions. 

For further details, see page 205.

Total assets
($bn)

$2,967bn

2022

2021

2020

2019
Common equity tier 1 ratio
(%)

14.2%

2022

2021

2020

2019

2,967

2,958

2,984

14.2

15.8

15.9

30

HSBC Holdings plc Annual Report and Accounts 2022

Global businesses 

Wealth and Personal Banking

We serve around 38 million customers globally, including  
6 million of whom are international, from retail customers  
to ultra high net worth individuals and their families.

Contribution to Group adjusted profit 
before tax   

$8.5bn
(36%)

Creating a seamless  
digital journey for our 
international customers

To deliver on our strategic focus on  
better serving and growing our 6 million 
international customers, we have enhanced 
our proposition for customers with 
international needs.

In 2022, we launched digital international 
account opening in Singapore, the UK  
and Australia, and made enhancements to 
the existing onboarding journeys in Hong 
Kong, the US, Canada, mainland China and 
the Channel Islands, allowing customers  
to open their accounts even before they 
arrive in their new country. Global Money 
Transfers offers customers an easy, quick, 
and competitively priced way for foreign 
currency payments, and is now live in eight 
markets. In addition, a partnership-enabled 
innovation allows customers in Singapore 
to access their credit history from other 
markets, using this information to expedite 
credit card limit decisions. 

To meet our customers’ needs, we  
offer a full suite of products and services 
across transactional banking, lending  
and wealth.

WPB continued to invest in our key strategic 
priorities of expanding our Wealth franchise in 
Asia, developing our transactional banking 
and lending capabilities, and addressing our 
customers’ international needs. Performance 

benefited from our product diversification in 
the context of rising interest rates mitigating 
adverse movements in market impacts in 
insurance and lower customer activity in 
equity markets. The results included a more 
normalised level of adjusted ECL charges in 
2022, compared with releases in 2021. 

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

2022

$m

2021

$m

24,367

20,963

(1,137)

213

2020

$m

21,481

(2,878)

2022 vs 2021

$m

3,404

%

16

(1,350) >(200)

(14,726)

(14,489)

(14,536)

29

34

6

8,533

18.5

6,721

15.2

4,073

9.1

(237)

(5)

(2)

(15)

1,812

27

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.

Divisional highlights

$80bn

WPB net new invested assets in 2022,  
up 25% compared with 2021. 

6 million

International customers at 31 December 2022, 
an increase of 7% compared with 2021.

Adjusted profit before tax
($bn)

$8.5bn

Net operating income
($bn)

$24.4bn

2022

2021

2020

2019

8.5

2022

6.7

4.1

2021

2020

2019

24.4

21.0

21.5

 International customers are those who bank in more than one market, those whose address is different 
from the market we bank them in and customers whose nationality, or country of birth for non-resident 
Indians and overseas Chinese, is different to the market we bank them in. Customers may be counted 
more than once when banked in multiple countries. Customer numbers exclude those acquired through 
our purchase of L&T Investment Management.

HSBC Holdings plc Annual Report and Accounts 2022

31

Strategic report 
Strategic report | Global businesses | Wealth and Personal Banking 

Management view of adjusted revenue

Wealth

 – investment distribution

 – Global Private Banking

net interest income

non-interest income

 – life insurance manufacturing

 – asset management

Personal Banking

 – net interest 

 – non-interest income

Other1

Net operating income2

2022

$m

8,091

3,066

1,978

946

1,032

1,914

1,133

15,911

14,610

1,301

365

24,367

2021

$m

8,783

3,377

1,746

620

1,126

2,508

1,152

11,587

10,258

1,329

593

20,963

2020

$m

7,737

3,177

1,712

661

1,051

1,838

1,010

12,683

11,472

1,211

1,061

21,481

2022 vs 2021

$m

(692)

(311)

232

326

(94)

(594)

(19)

4,324

4,352

(28)

(228)

3,404

%

(8)

(9)

13

53

(8)

(24)

(2)

37

42

(2)

(38)

16

1  ‘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 (2022: $494m, 2021: $807m, 2020: $1,048m), HSBC Holdings interest expense and 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’).

Financial performance
Adjusted profit before tax of $8.5bn was 
$1.8bn or 27% higher than in 2021. Despite  
an adverse movement of $1.4bn in market 
impacts in life insurance manufacturing, 
adjusted revenue increased primarily from 
rising interest rates. There was also a net 
adjusted ECL charge in 2022 of $1.1bn, 
compared with a net release of $0.2bn in 2021.

Adjusted revenue of $24.4bn was $3.4bn  
or 16% higher. Net interest income grew in 
Personal Banking by $4.4bn due to rising 
interest rates and balance sheet growth in  
the UK, Asia, Mexico and the Middle East.  
This was partly offset by lower Wealth revenue 
due to adverse market impacts of $1.4bn in  
life insurance manufacturing, despite strong 
insurance sales and an increase in net interest 
income of $0.3bn in Global Private Banking.

In Personal Banking, revenue of $15.9bn was 
up $4.3bn or 37%.

 – Net interest income was $4.4bn or 42% 

higher due to the positive impact of rising 
interest rates. This was supported by strong 
balance sheet growth in the UK, Asia, 
Mexico and the Middle East. Compared with 
2021, deposit balances in Asia increased by 
$6bn. Mortgage lending increased in the UK 
by $9bn and in Hong Kong by $3bn. In 
addition, unsecured lending increased in 
Asia by 5% and Mexico by 18%.

In Wealth, revenue of $8.1bn was down 
$0.7bn or 8%, notably from lower life 
insurance manufacturing as described above. 
However, our investments in Asia contributed 
to the generation of net new invested assets  
of $80bn during 2022.

 – Life insurance manufacturing revenue was 
$0.6bn or 24% lower due to a net adverse 
movement in market impacts of $1.4bn.  
In 2022, an adverse movement of $1.0bn 
compared with favourable impacts of 
$0.5bn in 2021, reflecting a weaker 
performance in equity markets. However, 
the value of new business written increased 
by $0.2bn or 23%, reflecting the launch  
of new products. In addition, there was a 
$0.3bn gain following a pricing update for 
our policyholders’ funds held on deposit 
with us in Hong Kong to reflect the cost to 
provide this service. We also recognised  
a $0.1bn gain on the completion of our 
acquisition of AXA Singapore.

 – Investment distribution revenue was  

$0.3bn or 9% lower, as muted customer 
sentiment led to lower activity in equity 
markets, which compared with a strong 
2021, and as Covid-19-related restrictions  
in Hong Kong in early 2022 resulted in the 
temporary closure of parts of our branch 
network. Since then, restrictions have 
substantially been eased.

 – Global Private Banking revenue was $0.2bn 
or 13% higher due to the positive impact of 
rising interest rates on net interest income. 
This increase was partly offset by a decline 
in brokerage and trading revenue, reflecting 
reduced client activity compared with a 
strong 2021.

 – Asset management revenue was $19m or 

2% lower, as adverse market conditions led 
to unfavourable valuation movements.  
This was in part mitigated by growth in 
management fees from net new invested 
assets of $45bn in 2022 and improved 
performance fees.

32

HSBC Holdings plc Annual Report and Accounts 2022

Other revenue fell by $0.2bn or 38%, notably 
from a lower allocation of revenue from 
Markets Treasury.

Adjusted ECL were a net charge of $1.1bn, 
reflecting a more normalised level of ECL 
charges, including provisions relating to a 
deterioration in the forward economic outlook 
from heightened levels of uncertainty and 
inflationary pressures. This compared with a 
net release of $0.2bn in 2021 from Covid-19-
related allowances previously built up in 2020.

Adjusted operating expenses of $14.7bn were 
$0.2bn or 2% higher, mainly due to continued 
investments, notably in wealth in Asia 
including the costs related to our AXA 
Singapore acquisition, and from the impact of 
higher inflation. These increases were partly 
offset by the benefits of our cost-saving 
initiatives.

The reported results of our WPB business 
included an impairment of $2.4bn recognised 
following the reclassification of our retail 
banking operations in France as held for  
sale on 30 September 2022. This impairment  
is excluded from our adjusted results. At  
31 December 2022, loans and advances  
to customers of $52.4bn and customer 
accounts of $56.6bn were classified as  
held for sale, notably relating to our retail 
banking operations in France and our  
banking business in Canada.

Global businesses

Commercial Banking

We support businesses in 54 countries and territories, ranging from small 
enterprises to large companies operating globally.

Contribution to Group adjusted profit 
before tax   

$7.7bn
(32%)

Funding digital growth 
and innovation 

We are helping technology companies  
to grow in Asia by providing them with 
specialist financing solutions. These 
include Grab, a leading south-east Asian 
platform, which has been on a journey  
of growth over the last decade. 

Based in Singapore, the company started 
as a ride-hailing app in 2012, and has 
since expanded to provide transport, 
food delivery and digital payments 
services. It has become an everyday, 
multi-use platform for more than  
33 million consumers every month.

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

We continued our investment in technology, 
launching new products to support customers 

and make banking with us easier. With our 
clients and partners we have made progress in 
delivering our sustainability strategy. We act as 
a trusted transition partner, seeking to provide 
sustainable supply chain solutions, and aim to 
capture growth opportunities as we transition 
into a new low-carbon economy. Strong 
performance in Global Payments Solutions 
(‘GPS’) continued due to interest rate rises and 
19% growth in fee income. This was partly 
offset by an adjusted ECL charge in 2022 
relative to a net release in 2021. 

Adjusted results 

2022

$m

2021

$m

2020

$m

Net operating income

16,215

12,538

12,889

2022 vs 2021

$m

3,677

%

29

Change in expected credit  
losses and other credit 
impairment charges

(1,858)

225

(4,710)

(2,083) >(200)

Operating expenses

(6,642)

(6,554)

(6,475)

Share of profit in associates  
and JVs

Profit before tax

RoTE excluding significant  
items (%)1

1

1

(1)

7,716

14.2

6,210

10.8

1,703

1.3

(88)

—

(1)

—

1,506

24

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.

Divisional highlights

19%

Growth in adjusted net fee income  
in GPS, supported by repricing and  
strategic initiatives.

Adjusted profit before tax
($bn)

$7.7bn

43%

Growth in adjusted net interest income  
across all CMB products, notably in  
GPS (up 149%) and GTRF (up 24%).

Net operating income
($bn)

$16.2bn

2022

2021

2020

2019

7.7

2022

6.2

1.7

2021

2020

2019

16.2

12.5

12.9

HSBC Holdings plc Annual Report and Accounts 2022

33

Strategic report 
Strategic report | Global businesses | Commercial Banking

Management view of adjusted revenue

Global Trade and Receivables Finance 

Credit and Lending 

Global Payments Solutions

Markets products, Insurance and Investments and Other1

 – of which: share of revenue for Markets and Securities 

Services and Banking products

2022

$m

2,084

5,722

6,839

1,570

1,185

2021

$m

1,829

5,667

3,354

1,688

1,005

2020

$m

1,687

5,465

4,040

1,697

898

2022 vs 2021

$m

255

55

%

14

1

3,485

>100

(118)

180

(7)

18

29

Net operating income2

16,215

12,538

12,889

3,677

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 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’).

 – In Markets products, Insurance and 

Investments and Other, revenue decreased 
by $0.1bn or 7%, reflecting the adverse 
effects of hyperinflation accounting in 
Türkiye and Argentina, as well as lower 
Markets Treasury and insurance revenue. 
This was partly offset by an 18% increase in 
collaboration revenue from GBM products, 
notably Foreign Exchange.

Adjusted ECL were a net charge of $1.9bn, 
compared with a net release of $0.2bn in 2021. 
The charge in 2022 primarily related to stage 3 
charges in Asia, mainly in the commercial real 
estate sector in mainland China, and higher 
charges in the UK reflecting heightened levels 
of uncertainty and inflationary pressures.  
This compared with a net release in 2021 of 
Covid-19-related allowances previously built 
up in 2020.

Adjusted operating expenses of $6.6bn 
remained broadly stable (up 1%). The 
continued investment in technology and  
the impact of higher inflation were mitigated 
by continued cost discipline on discretionary 
spend and through hiring efficiencies, as  
well as from the impact of our cost-saving 
initiatives.

At 31 December 2022, loans and advances to 
customers of $25.1bn and customer accounts 
of $22.1bn relating to our banking business in 
Canada were reclassified as held for sale.

Financial performance 
Adjusted profit before tax of $7.7bn was 
$1.5bn or 24% higher than in 2021. This was 
driven by an increase in adjusted revenue 
across all CMB products and in all regions, 
notably in Asia and the UK, and included a 
149% increase in GPS net interest income. 
This was partly offset by a net adjusted ECL 
charge compared with a net release of 
adjusted ECL in 2021. Adjusted operating 
expenses remained stable, as increased 
investment spend was mitigated by continued 
cost discipline.

Adjusted revenue of $16.2bn was $3.7bn or 
29% higher:

 – In GPS, revenue increased by $3.5bn, with 

growth in all regions, particularly in Asia and 
the UK, driven by higher margins, reflecting 
interest rate rises and business repricing 
actions. Revenue also benefited from a 6% 
increase in average deposit balances. There 
was a 19% increase in fee income, notably 
in cards and payments, with growth in all 
regions, notably in the UK, supported by  
the delivery of our strategic fee initiatives.

 – In Global Trade and Receivables Finance 
(‘GTRF‘), revenue increased by $0.3bn or 
14%, with growth in all regions, notably in 
the UK and Asia, driven by an increase in 
average balances, which rose by 17% 
compared with 2021 at improved margins. 
In addition, fee income grew by 4% 
compared with 2021.

 – In Credit and Lending, revenue increased  
by $0.1bn or 1%, notably in Canada and 
Latin America, driven by a 3% growth in 
average balances. In addition, fee income 
grew by 1%.

34

HSBC Holdings plc Annual Report and Accounts 2022

Global businesses

Global Banking and Markets

We support multinational corporates, financial institutions and institutional 
clients, as well as public sector and government bodies. 

Contribution to Group adjusted profit 
before tax   

$5.4bn
(23%)

Connecting the world to 
the biggest IPO in UAE

In April 2022, the initial public offering 
(‘IPO’) of Dubai Electricity and Water 
Authority raised $6.1bn for the 
Government of Dubai, which sold shares 
in the largest IPO ever to be carried out  
in the UAE, and the largest IPO focused 
on the utility sector in 2022. As joint 
global coordinator and joint bookrunner, 
we supported the state-owned utility 
company through the transaction,  
which attracted $85.7bn of demand.  
This demonstrated the depth of interest 
from international, regional and local 
investors, and the capacity for growth 
opportunities in the Middle East. We 
supported the company to articulate  
its energy transition plans to investors.  
The company is a supporter of the Dubai 
Clean Energy Strategy 2050, which aims 
to provide 100% of Dubai’s energy 
production capacity from clean energy 
sources by 2050.

We are leaders in facilitating global  
trade and payments, particularly into  
and within Asia and the Middle East, 
enabling our clients in the East and West 
to achieve their objectives by accessing 
our expertise and geographical reach. 
Our product specialists deliver a 
comprehensive range of transaction 
banking, financing, capital markets and 
advisory, and risk management services.

GBM adjusted profit before tax increased in 
2022, reflecting a strong revenue performance 
due to higher client activity related to volatility 
and rising interest rates. This was partly offset 
by adjusted ECL charges, which included a 
build-up of reserves, reflecting heightened 
levels of economic uncertainty, compared with 
releases in 2021. We continued to invest in 
technology to modernise our infrastructure, 
innovate product capabilities and to support 
our clients.

Adjusted results 

2022

$m

2021

$m

2020

$m

Net operating income

15,359

13,982

14,696

2022 vs 2021

$m

1,377

%

10

Change in expected credit  
losses and other credit 
impairment charges

(587)

313

(1,227)

(900) >(200)

Operating expenses

(9,325)

(9,250)

(8,895)

Share of profit in associates  
and JVs

(2)

—

—

(75)

(2)

(1)

 — 

Profit before tax

5,445

5,045

4,574

400

8

RoTE excluding significant  
items (%)1

10.7

8.6

6.7

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.

Divisional highlights

50%

Adjusted revenue generated in Asia in 2022. 

$94bn

Cumulative gross RWA reductions since the start 
of our RWA programme in 2020. This included 
accelerated saves of $9.6bn made in 2019.

Adjusted profit before tax
($bn)

$5.4bn

Net operating income
($bn)

$15.4bn

2022

2021

2020

2019

5.4

2022

5.0

4.6

2021

2020

2019

15.4

14.0

14.7

HSBC Holdings plc Annual Report and Accounts 2022

35

Strategic report 
Strategic report | Global businesses | Global Banking and Markets 

Management view of adjusted revenue 

Markets and Securities Services

 – Securities Services1

 – Global Debt Markets

 – Global Foreign Exchange

 – Equities

 – Securities Financing

 – Credit and funding valuation adjustments

Banking

 – Global Trade and Receivables Finance

 – Global Payments Solutions

 – Credit and Lending

 – Capital Markets and Advisory1

 – Other2

GBM Other

 – Principal Investments

 – Other3

Net operating income4

2022

$m

8,926

2,072

706

4,215

1,007

920

6

7,282

742

3,131

2,363

748

298

(849)

57

(906)

2021

$m

7,810

1,799

838

3,158

1,156

827

32

6,244

675

1,727

2,465

1,188

189

(72)

371

(443)

2020

$m

8,489

1,724

1,399

3,917

790

929

(270)

6,392

668

1,932

2,550

1,002

240

(185)

112

(297)

2022 vs 2021

$m

1,116

273

(132)

1,057

(149)

93

(26)

1,038

67

1,404

(102)

(440)

109

(777)

(314)

(463)

15,359

13,982

14,696

1,377

%

14

15

(16)

33

(13)

11

(81)

17

10

81

(4)

(37)

58

>(100)

(85)

>(100)

10

1 From 1 June 2020, Issuer Services was transferred to Global Banking. This resulted in revenue of $80m being recorded in Securities Services in 2020. 
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 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’).

Financial performance 
Adjusted profit before tax of $5.4bn was 
$0.4bn or 8% higher than in 2021. Growth in 
adjusted revenue of $1.4bn or 10% was partly 
offset by a net adjusted ECL charge in 2022 of 
$0.6bn, compared with a net release in 2021 
of $0.3bn, and from an increase of $0.1bn in 
adjusted operating expenses.

Adjusted revenue of $15.4bn was $1.4bn or 
10% higher, reflecting a more than 100% 
growth in GPS net interest income from higher 
interest rates, and a strong Markets and 
Securities Services performance driven by 
increased client activity and disciplined risk 
management.

In Markets and Securities Services, revenue 
increased by $1.1bn or 14%.

 – In Securities Services, revenue grew by 
$0.3bn or 15% from higher net interest 
income as global interest rates rose, partly 
offset by reduced fee income from lower 
market levels.

 – In Global Debt Markets, revenue fell by 
$0.1bn or 16%, reflecting lower primary 
issuances and challenging market 
conditions.

 – In Global Foreign Exchange, revenue 
growth of $1.1bn or 33% reflected 
increased client activity due to elevated 

market volatility and the combined 
macroeconomic impacts of rising inflation, 
higher interest rates and a strengthening of 
the US dollar, as well as a strong trading 
performance.

 – In Equities, revenue fell by $0.1bn or 13% in 
the context of a strong prior year and lower 
client activity in 2022.

 – In Securities Financing, revenue increased 
by $0.1bn or 11%, driven by client franchise 
growth and a strong trading performance.

In Banking, revenue increased by $1.0bn  
or 17%.

 – In GPS, revenue increased by $1.4bn or 

81%, driven by margin growth as a result of 
the rising global interest-rate environment 
and business pricing actions, together with 
active portfolio management and average 
balance growth. Fee income grew in all 
regions from the continued delivery of our 
strategic initiatives.

 – Capital Markets and Advisory revenue 

decreased $0.4bn or 37%, primarily from 
lower fees in line with the reduced global fee 
pool and adverse valuation movements on 
leveraged loans, net of hedging. 

In GBM Other, Principal Investments revenue 
declined by $0.3bn or 85%, as 2022 included 
lower valuation gains compared with 2021. 
There was also a reduction in revenue  
from Markets Treasury and the impact of 
hyperinflationary accounting, which are 
allocated to the global businesses. GBM  
Other also included a loss of $0.1bn from  
a buy-back of legacy securities.

Adjusted ECL were a net charge of $0.6bn. 
This included stage 3 charges predominantly 
in the commercial real estate sector in 
mainland China, and in Europe, which also 
reflected allowances due to a deterioration  
in the forward economic outlook given  
the heightened levels of uncertainty and 
inflationary pressures. This compared with  
the net release of $0.3bn in 2021 of Covid-19-
related allowances previously built up in 2020.

Adjusted operating expenses of $9.3bn 
increased by $0.1bn or 1% as the impact  
of higher inflation and strategic investments 
were in part mitigated by our ongoing cost 
discipline. 

36

HSBC Holdings plc Annual Report and Accounts 2022

Global businesses

Corporate Centre

Contribution to Group adjusted profit 
before tax   

$2.3bn
(9%)

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 in 2022 
reflected a lower share of profit from our 
associates, an increase in hedging costs and 
revaluation losses on investment properties. 
These reductions were in part mitigated by  
a favourable allocation of the UK bank levy 
and related prior year credits.

Financial performance
Adjusted profit before tax of $2.3bn was 
$0.3bn or 12% lower than in 2021 due to  
a reduction in adjusted share of profit in 
associates and joint ventures, and lower 
adjusted revenue.

Adjusted revenue was $0.1bn or 29% lower, 
primarily reflecting revaluation losses on 
investment properties, compared with gains  
in 2021, and an increase in costs associated 
with hedging foreign exchange exposure.  
The reduction also included the consideration 
paid in respect of an exchange offer for 
subordinated notes undertaken by  
HSBC Holdings plc.

Adjusted operating expenses decreased  
by $38m or 20%, reflecting a favourable 
allocation of the UK bank levy and related prior 
year credits. Since 2021, the UK bank levy and 
any related credits have been allocated across 
our global businesses and Corporate Centre, 
primarily to GBM.

Adjusted share of profit from associates  
and joint ventures of $2.7bn decreased by 
$0.2bn or 7%, primarily as 2021 included a 
higher share of profit from BGF in the UK, due 
to a recovery in asset valuations. This was 
partly offset by an increase in the share of 
profit from SABB.

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

2022

$m

(596)

(10)

227

2,695

2,316

5.4

2021

$m

(463)

3

189

2,898

2,627

5.6

2020

$m

(218)

–

(539)

2,102

1,345

3.1

2022 vs 2021

$m

(133)

(13)

38

(203)

(311)

%

(29)

>(200)

20

(7)

(12)

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

Other2,3

Net operating income4

2022

$m

(77)

(17)

(502)

(596)

2021

$m

(99)

(31)

(333)

(463)

2020

$m

151

(19)

(350)

(218)

2022 vs 2021

$m

22

14

(169)

(133)

%

22

45

(51)

(29)

1  Central Treasury includes adverse valuation differences on issued long-term debt and associated swaps of $77m (2021: losses of $99m; 2020: gains of $151m).
2  Other comprises consolidation adjustments, funding charges on property and technology assets, revaluation gains and losses on investment properties and 

property disposals and other revenue items not allocated to global businesses. The reduction in 2022 related primarily to adverse revaluation gains and losses on 
investment properties.

3  Revenue from Markets Treasury, HSBC Holdings net interest expense and hyperinflation impacts 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 2022 was $1,549m (2021: $2,202m; 2020: $2,699m).

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

HSBC Holdings plc Annual Report and Accounts 2022

37

Strategic reportStrategic report 

Risk overview

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

Managing risk

Geopolitical tensions have resulted in an 
increasingly fragmented macroeconomic, 
trade and regulatory environment. The global 
economic slowdown and high inflationary 
pressures are exacerbating the risks linked to 
this fragmentation. 

Global commodity markets have been 
significantly impacted by the Russia-Ukraine 
war, leading to supply chain disruptions and 
increased prices for both energy and non-
energy commodities. This, combined with 
extensive monetary policy loosening at the 
height of the Covid-19 pandemic, contributed 
to a sharp increase in inflation, creating  
further challenges for central banks and our 
customers. The continuation of – or any further 
escalation in – the Russia-Ukraine war could 
have additional economic, social and political 
consequences. These include further sanctions 
and trade restrictions, longer-term changes in 
the macroeconomic environment, and the risk 
of higher and sustained inflation, including 
continued increases in energy and non-energy 
prices. Interest rates have increased in reaction 
to inflationary pressures and we have adapted 
our interest rate risk management strategy  
in response.

China’s policy measures issued at the end of 
2022 have increased liquidity and the supply  
of credit to the mainland China commercial  
real estate sector. Recovery in the underlying 
domestic residential demand and improved 
customer sentiment will be necessary to 
support the ongoing health of the sector. We 
will continue to monitor the sector closely, 
notably the risk of further idiosyncratic real 
estate defaults and the potential associated 
impact on wider market, investor and 
consumer sentiment. Given that parts of the 
global economy are in, or close to, recession, 
the demand for Chinese exports may  
also diminish. 

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 management of our risk 
appetite, and ensuring regular communication 
with our Board and key stakeholders.

While the financial performance of our 
operations varied in different geographies, our 
balance sheet and liquidity remained strong.

Key risk appetite metrics 

Component

Measure

Capital

CET1 ratio – end point basis

Change in 
expected credit 
losses and  
other credit 
impairment 
charges1

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

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

Risk 
appetite

≥13.0%

≤0.50%

2022

14.2%

0.24%

≤0.45%

0.40%

1  Includes change in expected credit losses and other impairment charges and advances related to assets 

that are held for sale.

Our risk appetite
Our risk appetite defines our desired forward-
looking risk profile, and informs the strategic 
and financial planning process. It provides an 
objective baseline to guide strategic decision 
making, helping to ensure that planned 
business activities provide an appropriate 
balance of return for the risk assumed, while 
remaining within acceptable risk levels. Risk 
appetite supports senior management in 
allocating capital, funding and liquidity 
optimally to finance growth, while monitoring 
exposure to non-financial risks. 

Capital and liquidity remain at the core of our 
risk appetite framework, with forward-looking 
statements informed by stress testing. We 
continue to develop our climate risk appetite as 
we engage with businesses on including climate 
risk in decision making and starting to embed 
climate risk appetite into business planning.

At 31 December 2022, our CET1 ratio and ECL 
charges were within their defined risk appetite 
thresholds. Wholesale ECL charges increased 
towards the end of 2022, with additional stage 
1 and 2 allowances recorded, as a result of the 
uncertain macroeconomic environment. 
Monitoring of measures against our risk 
appetite remains a key focus. During 2022,  
we enhanced the monitoring and forecasting 
of our CET1 ratio through regular reviews in 
periods of high volatility.

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 a crisis. 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. The results 
from the stress tests also drive 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 risks, emerging risks and our risk 
appetite. During 2022, assessments were made 
of the impact on the Group of the Russia-
Ukraine war and the consequences from  
the deteriorating global economic outlook.

The results of the most recent stress test, 
referred to as the solvency stress test, 
published by the Bank of England (‘BoE’) in 
December 2021 confirmed the Group was 
sufficiently capitalised.

The BoE’s 2022 annual cyclical scenario stress 
test, originally due for submission in June 
2022, was rescheduled to commence in 
September 2022 in light of the uncertainty 
related to the Russia-Ukraine war, and was 
submitted in January 2023. 

As a result of this postponement, our own 
internal stress test will now be conducted in  
the first quarter of 2023, and will explore the 
potential impacts of key vulnerabilities to which 
we are exposed across certain key regions, 
including a lower interest-rate environment, 
additional macroeconomic headwinds including 
lower oil prices and the introduction of foreign 
exchange shocks. This focused internal stress 
test will consider the impacts of the various risk 
scenarios on those specific regions across all 
risk types and on capital resources.

38

HSBC Holdings plc Annual Report and Accounts 2022

Risk overview

Managing risk continued

Climate risk
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 help improve our 
understanding of our risk exposures for risk 
management and business decision making. 
In 2021, the Prudential Regulation Authority 
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 
policy action scenario. This was followed in 
the first half of 2022 with a second round to 
explore our strategic responses to such 
scenarios. We also conducted climate change 
stress testing exercises for the European 
Central Bank and the Monetary Authority of 
Singapore, and in the second half of 2022 we 
ran an internal climate scenario analysis to 
identify challenges and opportunities to our 
net zero strategy, as well as to inform capital 
planning and risk appetite.

 For further details of our approach to climate  
risk stress testing, see ‘Insights from scenario 
analysis’ on page 67.

Climate risk relates to the financial and 
non-financial impacts that may arise as a 
result of climate change and the move to a 
greener economy. Climate risk can impact us 
either directly or through our relationships with 
our clients. This includes potential climate risk 
arising as a result of our net zero ambition, 
which could lead to reputational concerns, 
and potential legal and/or regulatory action if 
we are perceived to mislead stakeholders on 
our business activities or if we fail to achieve 
our stated net zero targets. Our most material 
exposure to climate risk relates to corporate 
and retail client financing activity within our 
banking portfolio. We also have significant 
responsibilities in relation to asset ownership 
by our insurance business, employee pension 
plans, and asset management business.

We seek to manage climate risk across all  
our businesses in line with our Group-wide  
risk management framework, and are 
incorporating climate considerations within 
our existing risk types to reflect our strategic 
ambition to align to net zero. 

  For further details of our approach to climate risk 
management, see ‘Climate risk‘ on page 221. 

 For further details of our TCFD disclosures, see 
the ‘ESG review‘ on page 43.

Our operations
We remain committed to investing in the 
reliability and resilience of our IT systems  
and critical services, including those provided 
by third parties, 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, legal 
and regulatory consequences. In our approach 
to defending against these threats, we invest in 
business and technical controls to help us 
detect, manage and recover from issues, 
including data loss, in a timely manner.

We have made progress with the 
implementation of our business transformation 
plans. We seek to manage change execution 
risk so we can prioritise, manage and deliver 
change initiatives effectively and safely, and  
at the scale, complexity and pace required. 

 For further details on our risk management 
framework and risks associated with our banking 
and insurance manufacturing operations, see 
pages 142 to 144.

Geopolitical and macroeconomic risks 

The Russia-Ukraine war has continued to 
elevate geopolitical instability and has resulted 
in the use of significant sanctions and trade 
restrictions against Russia by the UK, the  
US and the EU, as well as other countries.  
In response to such sanctions and trade 
restrictions, Russia has implemented  
certain countermeasures.

The Russia-Ukraine war, alongside the 
economic impacts that continue to result from 
the Covid-19 pandemic, has contributed to 
increased commodity prices, which, combined 
with extensive monetary policy loosening 
during the height of the Covid-19 pandemic, 
has led to a sharp increase in inflation. In 
response, central banks both in developed and 
emerging markets tightened monetary policy 
sharply in 2022. Inflation is expected to abate 
in the coming months, albeit only gradually as 
the ongoing Russia-Ukraine war is likely to 
keep energy and food prices at high levels. 

Fiscal deficits are likely to remain high in  
both developed and emerging markets as 
further public spending is rolled out to help the 
private sector manage rising prices, against a 
backdrop of slower growth and higher interest 
rates. This could increase the strains on highly 
leveraged sovereigns, corporates and 
households. While the average maturity of 
sovereign debt in developed markets has 
lengthened, rising interest rates could reduce 

the affordability of debt and may eventually 
bring into question its sustainability in some 
countries. Among emerging markets, countries 
that need to refinance maturing US dollar-
denominated debt in the context of a strong 
dollar may face increasing difficulties. 

Our businesses also continue to consider the 
impact of the increasing cost of living on our 
customers. We are engaging closely with our 
key regulators to help ensure we continue to 
meet their expectations of financial institutions’ 
activities at a time of market volatility.

Higher inflation and interest rate expectations 
around the world – and the resulting economic 
uncertainty – have had an impact on ECL.  
The combined pressure of higher inflation and 
interest rates may impact the ability of our 
customers to repay debt. We have continued 
to carry out enhanced monitoring of model 
outputs and the use of model overlays. This 
includes management adjustments based  
on the expert judgement of senior credit  
risk managers to reflect the uncertainty in 
current market inflation and interest rate 
conditions in the forecasts from the underlying 
macroeconomic scenarios. Inflation and rising 
interest rates have been considered both 
directly in certain models, and assessed via 
adjustments where not directly considered. 
While many of the government programmes 
implemented during the Covid-19 pandemic  

to support businesses and individuals have 
ceased, this has impacted the level of credit 
losses, which in turn may have impacted  
the longer-term reliability of loss and  
capital models. 

The relationship between China and several 
countries, including the UK and the US, 
remains complex. The UK, the US, the EU  
and other countries have imposed various 
sanctions and trade restrictions on Chinese 
persons and companies, and may continue  
to impose further measures. In response to 
foreign sanctions and trade restrictions, China 
has imposed sanctions and introduced new 
laws and trade restrictions that could impact 
the Group and its customers. Further 
sanctions and counter-sanctions, whether in 
connection with Russia or China, may affect 
the Group and its customers by creating 
regulatory, reputational and market risks.

Negotiations between the UK and the EU over 
the operation of the Northern Ireland Protocol 
are continuing. While there are signs that 
differences may be diminishing, failure to 
reach agreement could have implications for 
the future operation of the EU-UK Trade and 
Cooperation Agreement.

HSBC Holdings plc Annual Report and Accounts 2022

39

Strategic reportStrategic report | Risk overview

Geopolitical and macroeconomic risks continued

In August 2022, the US Inflation Reduction  
Act introduced a minimum tax of 15% with 
effect from 1 January 2023. It is possible that  
a minimum tax could result in an additional  
US tax liability over our regular US federal 
corporate tax liabilities in a given year, based on 
differences between the US book and taxable 
income (including as a result of temporary 
differences). Given its recent pronouncement, 

it is unclear at this time what, if any, impact 
the US Inflation Reduction Act will have on 
HSBC’s US tax rate and US financial results, 
and HSBC will continue to evaluate its impact 
as further information becomes available. In 
addition, potential changes to tax legislation 
and tax rates in the countries and territories in 
which we operate could increase our effective 
tax rate in the future.

We continue to monitor, and seek to manage, 
the potential implications of all the above 
developments on our customers and our 
business. 

 For further details on our approach to 
geopolitical and macroeconomic risks,  
see ‘Top and emerging risks’ on page 135.

We continue to monitor the situation closely 
and, given the remaining uncertainties related 
to the post-pandemic landscape, additional 
mitigating actions may be required.

 For further details on our approach to the risks 
related to Covid-19, see ‘Areas of special interest’ 
on page 142.

Risks related to Covid-19

While the immediate impact of the Covid-19 
pandemic on the global economy has largely 
abated in most markets, it continues to disrupt 
economic activity in mainland China and Hong 
Kong despite the easing in December 2022 of 
the domestic Covid-19 restrictions that have 
adversely impacted China’s economy, Asia 
tourism and global supply chains. The return  
to pre-pandemic levels of social interaction 
across all our key markets continues to vary  
as governments respond differently to new 
waves of infection. 

Ibor transition 

The publication of sterling, Swiss franc,  
euro and Japanese yen Libor interest rate 
benchmarks, as well as Euro Overnight Index 
Average (‘Eonia’), ceased from the end of 
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 – has continued to support the 
transition of the limited number of remaining 
contracts in sterling and Japanese yen Libor, 
which were published using a ‘synthetic’ 
interest rate methodology during 2022. We are 
prepared for the cessation of the publication of 

these ‘synthetic’ interest rates from March 
2023 and March 2024. 

Additionally, prior to the cessation of the 
publication of US dollar Libor from 30 June 
2023, we have implemented the majority of 
required processes, technology and RFR 
product capabilities throughout the Group, in 
preparation for upcoming market events and 
the continued transition of legacy US dollar 
Libor and other demising Ibor contracts. 

We continue to be exposed to risks associated 
with Ibor transition, which include regulatory 

compliance risk, resilience risk, financial 
reporting risk, legal risk, model risk and market 
risk. The level of these key risks is diminishing 
in line with our process implementation and 
the transition of our legacy contracts. We have 
sought to implement mitigating controls, 
where required, and continue to actively 
manage and monitor these risks.

 For further details on our approach to Ibor 
transition, see ‘Top and emerging risks’ on 
page 135.

Top and emerging risks 

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

Top risks are those that have the potential  
to have a material adverse impact on the 
financial results, reputation or business model 
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 not under active management.

Our suite of top and emerging risks is subject 
to regular review by senior governance 
forums. We continue to monitor closely the 
identified risks and ensure management 
actions are in place, as required. 

40

HSBC Holdings plc Annual Report and Accounts 2022

Risk overview

Risk

Trend Description

Externally driven

Geopolitical and 
macroeconomic 
risks  

Technology and 
cybersecurity risk

Evolving regulatory 
environment risk

Financial crime risk 

Ibor transition risk

Environmental, 
social and 
governance (‘ESG’) 
risks

Digitalisation and 
technological 
advances 

Internally driven

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

Data risk

Change execution 
risk

Our operations and portfolios are subject 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. Heightened geopolitical tensions, alongside other factors, have also disrupted supply chains globally. 
Inflation, rising interest rates and slower Chinese economic activity may prompt a global recession that would 
affect our credit portfolio.

We face a risk of service disruption resulting from technology failures or malicious activities by internal or 
external threats. We continue to monitor ongoing geopolitical events and changes to the threat landscape.  
We operate a continuous improvement programme to protect our technology operations and to counter a 
fast-evolving cyber threat environment.

The regulatory and compliance risk environment has become more complex, in part due to heightened geopolitical 
tensions. There has been increased regulatory focus on operational and cyber resilience, crypto-asset-related risks 
and sanctions. These, alongside other regulatory priorities, may result in change requirements across the Group in 
the short to medium term. We continue to monitor regulatory and wider industry developments closely, and 
engage with regulators as appropriate.

We continue to support our customers against a backdrop of increasingly complex geopolitical, socio-economic 
and technological challenges, including the Russia-Ukraine war. HSBC is monitoring the impacts of the war on the 
Group, and using its sanctions compliance capabilities to respond to evolving sanctions regulations, noting the 
challenges that arise in implementing the unprecedented volume and diverse set of sanctions and trade restrictions.

We remain exposed to regulatory compliance, legal and resilience risks as contracts transition away from the 
remaining demising Ibor benchmarks to new reference rates. We continue to consider the fairness of client 
outcomes, our compliance with regulatory expectations and the operation of our systems and processes. The 
key risks are diminishing in line with our process implementation and we are progressing well in transitioning 
contracts in the remaining demising Ibors, specifically US dollar Libor.

We are subject to ESG risks relating to climate change, nature and human rights. These risks have increased 
owing to the pace and volume of regulatory developments globally, and due to stakeholders placing more 
emphasis on financial institutions’ actions and investment decisions in respect of ESG matters. Failure to meet 
these evolving expectations may result in financial and non-financial costs, including adverse reputational 
consequences. 

Developments in technology and changes in regulations have enabled new entrants to the banking industry and 
new products and services offered by competitors. Along with opportunities, new technology can introduce new 
risks. This challenges us to continue to innovate to take advantage of new digital capabilities to best serve our 
customers by adapting our products, and to attract and retain customers and employee talent, while ensuring 
that the risks are understood and managed with appropriate controls.

Our businesses, functions and geographies are exposed to risks associated with employee retention and talent 
availability, and compliance with employment laws and regulations. Heightened demand for talent in key labour 
markets and continuing Covid-19-related challenges have led to increased attrition and attraction challenges,  
and continuing pressure on employees. We monitor hiring activities and levels of employee attrition, and each 
business and function has workforce plans in place to aim to ensure effective workforce forecasting to meet 
business demands.

We procure goods and services from a range of third parties. It is critical that we have appropriate risk 
management policies and processes to select and govern third parties, including third parties’ supply  
networks, 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.

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 selections, 
product pricing, financial crime transaction monitoring, creditworthiness evaluation and financial reporting. 
Evolving regulatory requirements are driving material changes to the way model risk is managed across the 
banking industry, with particular focus on capital models. New technologies such as machine learning are 
driving changes to the model landscape.

We use data to serve our customers and run our operations, often in real-time within digital experiences and 
processes. If our data is not accurate and timely, our ability to serve customers, operate with resilience or meet 
regulatory requirements could be impacted. We need to ensure that non-public data is kept confidential, and that 
we comply with the growing number of regulations that govern data privacy and cross-border movement of data.

Failure to effectively prioritise, manage and/or deliver transformation across the organisation impacts our ability 
to achieve our strategic objectives. We aim to monitor, manage and oversee change execution risk to ensure our 
change portfolios and initiatives continue to deliver the right outcomes for our customers, people, investors and 
communities.

 Risk heightened during 2022 

Risk remained at the same level as 2021 

 Risk decreased during 2022

HSBC Holdings plc Annual Report and Accounts 2022

41

Strategic report 
Strategic report 

Long-term viability and going  
concern statement 

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

The Directors have specified a period of three 
years to 31 December 2025. 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 (see page 135):

 – 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 

2023–2027.

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 geopolitical and macroeconomic risks, 
including rising global inflationary pressures, 
the Russia-Ukraine war and its impact on 
sanctions and trade restrictions, disrupted 
supply chains globally and slower Chinese 
economic activity, all of which have  
increased to a heightened level during 2022. 
Digitalisation and technological advances and 
environmental, social and governance risks 
remained at a heightened level during 2022.

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 (see 
page 12);

 – 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 132) 
and top and emerging risks (see page 135); 

 – the impact on the Group due to the 

Russia-Ukraine war; instability in China’s 
commercial real estate sector; structural 
changes from the Covid-19 pandemic and 
strained economic and diplomatic tensions 
between China and the US, the UK, the  
EU and other countries;

 – reports and updates regarding regulatory 
and internal stress testing. The Group 
internal stress test has been delayed from 
the fourth quarter of 2022 to the first quarter 
of 2023 and will include overlays applied  
to the 2022 annual cyclical scenario for 
HSBC-specific vulnerabilities, including 
geopolitical issues (and related 
macroeconomic headwinds) along with  
the continued impact of Covid-19. It will  
also consider the impacts of various risk 
scenarios across all risk types and on capital 
resources. The 2022 Bank of England annual 
cyclical scenario, originally due in June 
2022, was also postponed in light of the 
uncertainty related to the Russia-Ukraine 
war. The exercise commenced on 26 
September 2022, with the submission  
made to the Bank of England in early 
January 2023 and the results due to be 
published mid-2023. The initial results of this 
exercise indicated the Group is sufficiently 
capitalised to withstand a severe but 
plausible adverse stress; 

 – the results of our 2022 internal climate 
scenario analysis exercise. In 2022, the 
Group delivered its first internal climate 
scenario analysis exercise with internal 
scenarios being formed with reference to 
external publicly available climate scenarios. 
Using these external scenarios as a 
template, the Group adapted them by 
incorporating unique climate risks and 
vulnerabilities to which the organisation is 
exposed. No issues were identified around 
the going concern status of the Group. 
Further details of the insights from the 2022 
climate scenario analysis are explained from 
page 67;

 – 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 35 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

21 February 2023

42

HSBC Holdings plc Annual Report and Accounts 2022

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.

44 

46 

73 

85 

Our approach to ESG

Environmental 

Social

Governance

How we present our TCFD disclosures
Our overall approach to TCFD can be found on page 17 
and additional information is included on pages 68 and 
423. Further details have been embedded in this section 
and the Risk review section on pages 221 to 230. Our 
TCFD disclosures are highlighted with the following 
symbol: TCFD

HSBC Holdings plc Annual Report and Accounts 2022

43

ESG review 

Our approach to ESG

We are on a journey to incorporate environmental, social and  
governance principles throughout the organisation, and are taking  
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 on the planet we all inhabit. 

Transition to net zero
We have continued to take steps to implement 
our climate ambition to become net zero in our 
operations and our supply chain by 2030, and 
align our financed emissions to net zero by 
2050. We have expanded our coverage  
of sectors for on-balance sheet financed 
emissions targets, noting the challenge of 
evolving methodologies and data limitations.  
In addition, our operating environment for 
climate analysis and portfolio alignment is 
developing. We continue work to improve our 
data management processes and are setting 
targets to align our provision of finance with 
the goals and timelines of the Paris Agreement.

In March 2022, we announced plans to  
turn our net zero ambition for our portfolio  
of clients into business transformation across 
the Group. The plan involves the publication of 
a Group-wide climate transition plan in 2023. 
We continued our work to review and update 
our wider financing and investment policies 
critical to achieving net zero by 2050, which 
included publishing an updated energy policy 
and thermal coal phase-out policy in 
December 2022. 

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

Building inclusion and resilience
Our social pillar is centred around building 
inclusion and resilience for our colleagues  
and customers, as well as in the communities 
we serve. 

Environmental – Transition to net zero

 – Since 2020, we have provided and facilitated $210.7bn of sustainable finance and investment 
towards our ambition of $750bn to $1tn by 2030. We monitor developments in taxonomies 
and changing market guidelines in this space.

 – In December, we updated our energy policy as an important mechanism to help deliver our 
financed emissions targets and phase down fossil fuel financing in line with our net zero 
ambition, and introduced further restrictions for thermal and metallurgical coal.

 – We have introduced on-balance sheet financed emissions targets for eight sectors, noting  

the limitations of evolving methodologies and data quality. 

Read more in the Environmental section on page 46.

Social – Building inclusion and resilience

 – In 2022, 33.3% senior leadership roles were occupied by women, 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, increased to 73% in 2022 following  

a five-point increase from 2019, and was three points above benchmark.

Read more in the Employees section on page 74.

Governance – Acting responsibly

 – We conducted a review of our salient human rights issues, including stakeholder consultation 

with non-governmental organisations (‘NGOs’) and potentially affected groups.

 – Our customer satisfaction performance, using the net promoter score, improved in many 

markets in which we operate. However, 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 Governance section on page 85.

We are committed to ensuring our  
people – and particularly our leadership –  
are representative of the communities that  
we serve, and that we support their well-being 
and development so they can learn and grow 
in their careers. We are equally committed  
to ensuring there are no unnecessary barriers 
to finance for our customers. We have an 
ambition to create a welcoming, inclusive  
and accessible banking experience. 

Inclusion goes hand-in-hand with resilience. 
We build resilience for our colleagues by 
supporting their physical, mental and financial 
well-being, and by ensuring they are equipped 
with the skills and knowledge to further their 
careers during a period of significant economic 
transformation. For our customers, we build 
resilience primarily through education – by 
helping them to understand their finances and 
how to manage them effectively.

Acting responsibly
Our governance pillar focuses on  
our approach to acting responsibly  
and recognises topics such as human  
rights, conduct and data integrity. 

Our policies and procedures help us provide 
the right outcomes for customers, including 
those with enhanced care needs, which in 
2022 took into account the current cost of 
living crisis. Customer experience is at the 
heart of how we operate and is measured 
through customer satisfaction and customer 
complaints.

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

44

HSBC Holdings plc Annual Report and Accounts 2022

Our approach to ESG

How we decide what to measure

We listen to our stakeholders in a number of 
different ways, which we set out in more detail 
within the ‘ESG overview’ on page 14. We use 
the information they provide us to identify the 
issues that are most important to them and 
consequently also matter to our own business.

Our ESG 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 the LR9.8.6R(8)  
of the Financial Conduct Authority’s (‘FCA’) 
Listing Rules, and other applicable laws and 

regulations to choose what we measure and 
publicly report in this ESG review.

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 help ensure we remain relevant  
in what we measure and publicly report.

Recognising the need for a consistent  
and global set of ESG metrics, we monitor  
the developments related to International 
Sustainability Standard Board (‘ISSB’) and 
other standard setters. In the absence of a 

globally consistent set of sustainability 
standards, we continued to report against  
the core World Economic Forum (‘WEF’) 
‘Stakeholder Capitalism Metrics’ and 
Sustainability Accounting Standards  
Board (‘SASB’) metrics this year.

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 ESG-related data and methodologies in 
general, we are on a journey towards 
improving completeness and robustness.

 For further information on our approach to 
reporting, see the ‘Additional information’ 
section of page 422.

Our reporting around ESG

We report on ESG matters throughout our Annual Report and Accounts, including the ’ESG overview’ section of the Strategic Report (pages 14 to 19), 
this ESG review (pages 44 to 96), and the ‘Climate risk’ and ‘Insights from climate scenario analysis’ sections of the Risk review (pages 221 to 230).  
In addition, we have other supplementary materials, including our ESG Data Pack, which provides a more granular breakdown of ESG information.

Detailed data

Additional reports

ESG Data Pack 2022

UK Pay Gap Report 2022

Modern Slavery and Human Trafficking Statement 2022

Green Bond Report 2022

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

HSBC UN Sustainable Development Goals Bond and Sukuk Report 2022

Indices

SASB Index 2022

WEF Index 2022

Assurance relating to ESG data 

TCFD

HSBC Holdings plc is responsible for 
preparation of the ESG information and  
all the supporting records, including selecting 
appropriate measurement and reporting 
criteria, in our Annual Report and Accounts, 
ESG Data Pack and the additional reports 
published on our website. 

We recognise the importance of ESG 
disclosures and the quality of data underpinning 
it. We also acknowledge that our internal 
processes to support ESG are in the process  
of being developed and currently rely on manual 
sourcing and categorisation of data. Certain 
aspects of our ESG disclosures are subject  
to enhanced verification and assurance 
procedures including the first and second line  
of defence. We aim to continue to enhance our 
approach in line with external expectations. 

For 2022, ESG data is subject to stand-alone 
independent limited assurance reports  
by PwC 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 disclosures and metrics:

 – our Green Bond Report 2022 (published  

in December 2022);

 – our financed emissions for 2019 and 2020 

for six sectors (see page 50);

 – our progress towards our ambition to provide 
and facilitate $750bn to $1tn of sustainable 
finance and investment (see page 57);

 – our own operations’ scope 1, 2 and 3 

(business travel) greenhouse gas emissions 
data (see page 63); and supply chain 
emissions data; and

 – our 2019 baseline for financed emissions 

covering 38% of assets under management 
for our asset management business (see 
page 56).

The work performed by external parties to 
support their limited assurance report is 
substantially less than the work performed for 
a reasonable assurance opinion, like those 
provided over financial statements. 

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

HSBC Holdings plc Annual Report and Accounts 2022

45

ESG reviewESG review | Environmental 

Environmental 
Transition to net zero

TCFD

We are developing new solutions to the climate crisis 
and supporting the transition of our customers, 
industries and markets to a net zero future, while  
moving to net zero ourselves.

At a glance

Transition to net zero
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 have made good progress on our 
net zero ambition, including publishing an 
updated energy policy as an important 
mechanism to meeting our financed emissions 
targets, and expanding our financed emissions 
targets to eight sectors in total. 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. We continue 
to engage with our clients on their transition 
plans and to provide them with financing 
solutions to support their sustainability goals.

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

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 139, ‘Climate risk’ on 
page 221 and ‘Insights from scenario analysis’ on 
page 226.

Impact on reporting and 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 
2022. We considered the impact on a number 
of areas of our balance sheet including 
expected credit losses, classification and 
measurement of financial instruments, 
goodwill and other intangible assets, our 
owned properties, as well as our long-term 
viability and going concern. As part of 
assessing the impact on our financial 
statements we conducted scenario analysis to 
understand the impact of climate risk on our 
business (see page 67). For further details on 
our climate risk exposures, see page 145.

 For further details of how management has 
considered the impact of climate-related risks  
on its financial position and performance see  
our ‘Critical accounting estimates and 
judgements’ in Note 1 ‘Basis of preparation and 
significant accounting policies’ from page 335.

In this section

Transition  
to net zero

Understanding our climate 
reporting

To achieve our climate ambition we need to be transparent on the 
opportunities, challenges, related risks and progress we make.

Our approach to the 
transition

Financed emissions

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

Supporting customers 
through transition

Our ability to help 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 help 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 help accelerate the transition to net zero.

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.

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.

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.

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 
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.

46

HSBC Holdings plc Annual Report and Accounts 2022

 Page 47

 Page 49

 Page 50

 Page 57

 Page 60

 Page 61

 Page 62

 Page 64

 Page 65

 Page 67

 Page 68

Environmental 

Transition to net zero  TCFD

Understanding our climate reporting 

Need for enhanced governance, 
processes, systems, controls and data
Our climate ambition requires enhanced 
capabilities including governance, processes, 
systems and controls. We also need new 
sources of data, some of which may be 
difficult to assure using traditional verification 
techniques. We continue to invest in our 
climate resources and skills, and develop  
our business management process to 
integrate climate impacts. Our activities are 
underpinned by efforts and investment to 
develop our data and analytics capabilities and 
to help ensure that we have the appropriate 
processes, systems, controls and governance 
in place to support our transition. 

We are taking steps to establish an ESG data 
utility tool to help streamline and support  
data needs across the organisation. We are 
enhancing our processes, systems, controls 
and governance to help achieve the required 
scale to meet the demands of future ESG 
reporting. Certain aspects of our reporting rely 
on manual sourcing and categorisation of 
data. This categorisation of data is not always 
aligned with how our businesses are currently 
managed. We also have a dependency on 
emissions data from our clients. Given the 
manual nature, enhanced verification and 
assurance procedures are performed on a 
sample basis over this reporting including the 
first and second line of defence. Our models 
undergo independent review by an internal 
model review group, and we obtain limited 
assurance on our financed emissions and 
sustainable finance disclosures from external 
parties including our external auditors.

Limited international alignment on green 
taxonomies
Green finance taxonomies are not consistent 
globally, and evolving taxonomies and 
practices could result in revisions in our 
sustainable finance reporting going forward. 
We recognise that there can be differing views 
of external stakeholders in relation to these 
evolving taxonomies, and we will seek to align 
to enhanced industry standards as they  
are further developed. We aim to increase 
transparency across the different types of 
green and transition finance and investment 
categories going forward, and plan to engage 
with standard setters to help evolve 
sustainable finance product standards to best 
incentivise science-based decarbonisation, 
particularly in high transition risk sectors.

Engagement with clients on their 
transition at an early stage
Success will require governments, clients  
and finance providers to work together. Stable 
and strong policy environments are critical  
to accelerating the energy transition. Active 
engagement between public and private 
stakeholders is fundamental to de-risk new 
technologies and markets and establish new 
business structures.

We established a new process to assess client 
transition plans for our largest energy sector 
clients and those involved in thermal coal to 
help inform areas for further engagement and 
guide business decisions. We acknowledge 
that our assessment of client transition plans is 
in the initial stages and our engagement with 
clients on their plans and progress will need  
to continue to be embedded. 

In December 2022, following extensive 
consultation with scientific and industry 
bodies, we published our updated energy 
policy and an update to our thermal coal 
phase-out policy. These policies acknowledge 
a need to phase down financing of fossil fuels 
while also investing at scale in climate 
solutions to enable a transition to net zero.

The transition to net zero is one of the 
biggest challenges for our generation
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.

Our ability to meet our net zero ambition –  
to align the financed emissions of our portfolio 
to net zero by 2050, and to become net zero  
in our operations and supply chain by 2030 
– relies on the pace of change taking place in 
the real economy and action among a broad 
set of stakeholders, including policymakers. 
This will include responsible actions from  
both HSBC and our clients to address  
climate change.

We acknowledge that to achieve our climate 
ambition we need to be transparent on the 
opportunities, challenges, related risks  
and progress we make. Our reporting will 
need to evolve to keep pace with market 
developments and we will aim to overcome 
challenges with regard to consistency across 
different markets in which we operate. The 
role of standard setters and regulators will be 
important in achieving standardisation. We 
have highlighted below some of the limitations 
and challenges that our organisation, and the 
wider industry, face with regard to climate 
reporting.

Our transition will be challenging but we 
have an opportunity to make an impact
Our global footprint means that many of our 
clients operate in high-emitting sectors and 
regions that face the greatest challenge in 
reducing emissions in the critical decades 
ahead to 2050. Their ability to transition 
effectively will be key to reaching a global  
net zero economy in time, but they are often 
faced with increasingly high energy demand, 
relatively new carbon-intensive assets, and 
lower level of investments into clean 
technologies.

Our approach is rooted in engagement  
with our clients to provide them with the 
capital and tools to help them transform  
their business models and decarbonise. It  
is also rooted in the reality that a just and 
inclusive transition requires us to consider 
region-specific challenges and opportunities. 
Additionally, countries are moving at different 
speeds and, given our geographical and 
sectoral spread, we will naturally have one  
of the most complex transitions.

HSBC Holdings plc Annual Report and Accounts 2022

47

ESG reviewESG review | Environmental 

Understanding our climate reporting continued

Capturing the full-scope of our emissions
Having set on-balance sheet 2030 emissions 
targets for the oil and gas, and power and 
utilities sectors, we have now expanded  
our coverage to include heavy industry and 
transport sectors, which are key drivers of 
energy demand. These sectors cover the most 
emissions-intensive parts of our portfolio.  
We plan to extend our analysis to four 
additional sectors – shipping, agriculture, 
commercial real estate and residential real 
estate – in our Annual Report and Accounts 
2023 and related disclosures.

Our initial focus has been on on-balance sheet 
financing, including project finance and direct 
lending. We also have facilitated emissions 
from our capital markets activities, through our 
underwriting in debt and equity capital markets 
and syndicated lending. We aim to update  
our targets and baselines to include both 
on-balance sheet and off-balance sheet 
activities following the publication of the 
industry standard for capital markets 
methodology by the Partnership for Carbon 
Accounting Financials (‘PCAF’). This should 
give guidance on how to apportion the 
emissions responsibility between a facilitator 
and an investor within capital markets activities.

Our Asset Management business released  
a coal phase-out policy in September 2022, 
and made its initial emissions disclosure  
in November 2022 with a portfolio 
decarbonisation target for 2030 to align 
investments with the goals of the Paris 
Agreement. The commitment covers listed 
equity and corporate fixed income where  
data and methodologies are most mature. 
We will also consider the inclusion of 
emissions on our insurance business.

Disclosure challenges for year-end 
reporting
Given the challenges on data sourcing, as well 
as the evolution of our processes and industry 
standards as mentioned above, there has 
been an impact on certain climate disclosures:

 – Thermal coal exposures: We acknowledge 
that our processes, systems, controls and 
governance are not yet designed to fully 
identify and disclose thermal coal 
exposures, particularly for exposures within 
broader conglomerates. We are reassessing 
the reliability of our data and reviewing  
our basis of preparation to help ensure that 
we are reporting all relevant thermal coal 
exposures aligned to our thermal coal policy. 
As a result, we have not reported thermal 
coal exposures in this Annual Report and 
Accounts 2022. We expect that our updated 
thermal coal exposure dating back to  
31 December 2020 will be made available 
for reporting as soon as practicable in 2023, 
although this is dependent on availability 
and quality of data.

 – Facilitated emissions: In March 2022,  
we said we would set capital markets 
emissions targets for the oil and gas, and 
power and utilities sectors based on the 
industry reporting standard from the PCAF 
once published. We have chosen to defer 
setting targets for facilitated emissions  
until the PCAF standard for capital markets 
is published, which is expected in 2023.  
We had intended to disclose facilitated 
emissions for 2019 and 2020 for the oil  
and gas, and power and utilities sectors  
for transparency, as we did last year. 
However, following internal and external 
assurance reviews performed during the 
year, we identified certain data and process 
limitations and have deferred the publication 
of our facilitated emissions for 2019 and 
2020 for these two sectors while additional 
verification procedures are performed. We 
aim to provide these disclosures as soon as 
practicable in 2023. We continue to monitor 

the developments in industry standards  
for the publication of such emissions and 
associated targets, and, as mentioned 
above, we will seek to align to the PCAF 
standard when published. However, we will 
aim to provide transparency on our 2019 
and 2020 facilitated emissions for the oil and 
gas, and power and utilities sectors as they 
become available, which may be in advance 
of the PCAF standard being available.

 – Shipping financed emissions targets: For  

the shipping sector, we have chosen to defer 
setting a baseline and target until there is 
sufficient reliable data to support our work, 
allowing us to more accurately track 
progress towards net zero.

Continuing to evolve our climate 
disclosures
In 2023, we plan to publish our first Group-
wide climate transition plan to provide further 
details of our strategic approach to net zero 
and how we plan to transform our organisation 
to execute our ambition. We also aim to 
publish an updated deforestation policy and 
build out our financed emissions portfolio 
coverage to include agriculture, residential real 
estate, commercial real estate and shipping, 
and plan to update our targets for certain 
sectors to include facilitated emissions once 
the PCAF standard is launched. 

In 2023, we will continue to review our 
approach to disclosures, with our reporting 
needing to evolve to keep pace with market 
developments.

 For details of assurance around ESG data,  
see page 45.
 For details of our approach to calculating 
financed emissions and the relevant data and 
methodology limitations, see page 52.
 For details of our sustainable finance and 
investment ambition, see page 57.
 For details of our approach to thermal coal,  
see page 66.

Awarded as a green lease leader

We are carrying out a programme to promote green lease clauses across our global  
portfolio of leased buildings, which commit our landlords to helping us reduce our impact  
on the environment. As part of this programme, in May 2022, we agreed to move our US 
headquarters to The Spiral office tower at 66 Hudson Boulevard in Manhattan, New York, 
which we expect to reduce our total energy consumption by 60% compared with 2021.  
The Spiral is on track to achieve industry leading LEED Gold and Fitwel certifications for 
sustainability and building health. Alongside our real estate broker JLL, and our landlord 
Tishman Speyer, we were recognised by the Green Lease Leaders Organisation with a Green 
Lease Leaders Team Transaction Award – Platinum Level, for our collaboration to improve  
the energy efficiency and sustainability of buildings.

48

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

Our approach to the transition

We are committed to a net zero future. Our 
global footprint means we play a significant 
role in the sectors and regions most critical to 
the transition to net zero. Many of our clients 
operate in the high-emitting sectors and 
regions that face the greatest challenge in 
reducing emissions. This means we can have 
a significant impact in helping to drive down 
emissions in the real economy, but this is  
a challenging process that will take time.

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. We are committed to a 
science-aligned phase-down of fossil fuel 
finance in line with the Paris Agreement. 

We have committed to publish our own 
Group-wide climate transition plan in 2023. 
This plan will bring together our climate 
strategy, science-based targets, and how  
we plan to embed this into our processes, 
policies, governance and capabilities. It  
will outline, in one place, not only our 
commitments, targets and approach to  
net zero across the sectors and markets we 
serve, but also how we are transforming our 
organisation to embed net zero and help 
finance the transition. Our approach to nature 
and enabling a just and resilient transition  
will also be incorporated into our climate 
transition plan. 

Our net zero policies
In December 2022, we published our updated 
policy covering the broader energy system, 
including upstream oil and gas, oil and gas 
power generation, coal, hydrogen, renewables 
and hydropower, nuclear, biomass and energy 
from waste. The policy seeks to balance three 
related objectives: driving down global 
greenhouse gas emissions; enabling an 
orderly transition that builds resilience in  
the longer term; and supporting a just and 
affordable transition. In December, we also 
expanded our thermal coal phase-out policy, 
in which we committed to not providing new 
finance or advisory services for the specific 
purposes of the conversion of existing 
coal-to-gas-fired power plants, or new 
metallurgical coal mines. Our updated  
energy and thermal coal phase-out policies 
were drafted in consultation with leading 
independent scientific and international bodies 
and investors. Details on the policies can be 
found in ‘Our approach to sustainability 
policies’ on page 65. 

Working with our customers and suppliers
We believe we can make the most significant 
impact by working with our customers  
to support their transition to a net zero  
global economy. 

We aim to align our financed emissions to net 
zero by 2050 or sooner. We are setting 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 we consider 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. 

We have set interim 2030 targets for on-
balance sheet financed emissions for eight 
sectors. These include six sectors for which we 
have reported 2019 and 2020 emissions: oil 
and gas; power and utilities; cement; iron, steel 
and aluminium; aviation; and automotive. We 
have also set targets for thermal coal power 
and thermal coal mining.

In 2022, we established a process to assess 
client transition plans to help inform areas  
for further engagement and guide business 
decisions. We expect engagement with  

our customers on their transition plans to form 
a core part of our approach as we pursue  
our targets. We acknowledge that our 
assessment of client transition plans is in the 
initial stages and our engagement with clients 
on their plans and progress will need to 
continue to be embedded.

We aim to become net zero in our operations 
and supply chain by 2030. 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, we are asking our 
suppliers to do the same.

The next section provides further details on 
how we are measuring our progress on our 
financed emissions ambition. For further details 
of the progress made to date on our own 
operations and supply chain, see page 62. The 
diagram below shows how these ambitions 
map to our scope 1, 2 and 3 emissions.

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.

Under the protocol, scope 3 emissions are also broken down into 15 categories, of which we 
provide reporting emissions data for three related to upstream activities, which are: purchased 
goods and services (category 1); capital goods (category 2); and business travel (category 6). 
We also provide reporting data for one category related to downstream activities, which is 
investments and financed emissions (category 15)

For further breakdown of our scope 1, 2 and 3 emissions, see our ESG Data Pack at www.hsbc.com/esg.

Our own
operations and 
supply chain

See page 63

Scope 2
Indirect

Scope 3
Indirect

Scope 1
Direct

Scope 3
Indirect

Our financed 
emissions

See page 51

Electricity, 
steam 
heating and 
cooling 

  Purchased 
goods and 
services
(category 1)

Company
facilities

Company
vehicles

  Business 
travel
(category 6)

  Capital 
goods
(category 2) 

Investments and 
financed emissions
(category 15) 

Upstream activities

HSBC Holdings

Downstream activities

1 HSBC-sponsored shuttles only

HSBC Holdings plc Annual Report and Accounts 2022

49

ESG reviewESG review | Environmental 

Financed emissions  

TCFD

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. We plan to publish initial 
financed emissions targets for 2030, and in 
five-year increments thereafter. We remain 
committed to working with our customers  
to support their journey towards a net zero 
future, and deploying capital towards 
decarbonisation solutions for the most 
emissions-intensive sectors.

Our analysis of financed emissions considers 
on-balance sheet financing, including project 
finance and direct lending. We distinguish 
between ‘on-balance sheet financed’ and 
‘facilitated’ emissions where necessary. 
Financed emissions link the financing we 
provide to our customers and their activities in 
the real economy, and 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. We also recognise that we have more 
to do to embed these targets in our business, 
including enhanced capabilities and new 
sources of data as set out on page 47.

In 2021, we started measuring our financed 
emissions for two emissions-intensive sectors: 
oil and gas, and power and utilities. On the 
following pages, we present the progress for 
both sectors against the on-balance sheet 
financed emissions baseline that we now 
measure ourselves against. We have also 
begun measuring the financed emissions  
and setting targets for four additional sectors: 
cement; iron, steel and aluminium; aviation; 
and automotive. During our analysis of the 

shipping sector, we noted significant data 
gaps. We have therefore chosen to defer 
setting a baseline and target for this sector 
until there is sufficient reliable data to support 
our work.

We plan to measure and report progress on an 
annual basis, and plan to extend our analysis 
to four new sectors – shipping, agriculture, 
commercial real estate and residential real 
estate – in our Annual Report and Accounts 
2023 and related disclosures. For the new 
sectors, we plan to set production intensity 
targets. We believe these targets are robust as 
they are linked to real world production, and 
allow us to deploy capital towards solutions for 
progressive decarbonisation, supporting our 
clients’ transition plans.

Our approach to financed emissions

In our approach to assessing our financed 
emissions, our key methodological decisions 
were shaped in line with industry practices 
and standards. We recognise these are  
still developing.

Coverage of our analysis
For each sector, we focused our analysis on 
the parts of the value chain where we believe 
the majority of emissions are produced based 
upon industry benchmarks, and to help 
reduce double counting of emissions.  
For aviation, we have focused on scope 1 
emissions from airlines and scope 3 from 
aircraft lessors as we believe the use of  
lower emissions aviation fuels and different 

propulsion systems for new aircraft is where 
attention needs to be prioritised to meet net 
zero targets. By estimating emissions and 
setting targets for customers that directly 
account for, or indirectly control the majority 
of emissions in each industry, we can focus 
our engagement and resources where we 
believe the potential for change is highest.

With regards to the different types of 
greenhouse gases measured, we include  
CO2 and methane (measured in CO2e) for  
the oil and gas sectors, and CO2 only for  
the remaining sectors due to data availability 
and greenhouse gas emissions materiality 
within each sector. 

To calculate annual on-balance sheet financed 
emissions, we used drawn balances as at  
31 December in the year of analysis 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. We excluded products 
that were short term by design, which are 
typically less than 12 months in duration, 
following guidance from the Partnership for 
Carbon Accounting Financials (‘PCAF’), and  
to reduce volatility. 

The chart below shows the scope of our financed emissions analysis of the six sectors, including upstream, midstream and downstream 
activities within each sector.

Sector

Scope of emissions

Value chain in scope

Coverage of 
greenhouse gases

Oil and gas

1, 2 and 3

Upstream 
(e.g. extraction)

Midstream
(e.g. transport)

Downstream
(e.g. fuel use)

Integrated/ 
diversified

CO2/methane

Power and utilities 1 and 2

Cement

Iron, steel and 
aluminium

Aviation

1 and 2

1 and 2

Upstream  
(e.g. generation)

Midstream
(e.g. transmission 
and distribution)

Upstream (e.g. raw  
materials, extraction) 

Midstream (e.g clinker 
and cement manufacturing)

Upstream (e.g. raw  
materials, extraction)

Midstream
(e.g. ore to steel)

Downstream

(e.g. retail)

Downstream
(e.g. construction) 

Downstream
(e.g. construction)

1 for airlines,  
3 for aircraft lessors

Upstream
(e.g. parts manufacturers) 

Midstream 
(e.g. aircraft manufacturing)

Downstream
(e.g. airlines and air lessors)

Automotive

1, 2 and 3

Key: 

Included in analysis

Upstream
(e.g. suppliers)

Midstream 
(e.g. motor vehicle 
manufacture)

Downstream
(e.g. retail)

50

HSBC Holdings plc Annual Report and Accounts 2022

CO2

CO2

CO2

CO2

CO2

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Environmental 

Financed emissions continued

An evolving approach 
We believe methodologies for calculating 
financed emissions and setting targets should 
be transparent and comparable, and should 
provide science-based insights that focus 
engagement efforts, inform capital allocation 
and develop solutions that are both timely  
and impactful. We continue to engage with 
regulators, standard setters and industry 
bodies to shape our approach to measuring 
financed emissions and managing portfolio 
alignment to net zero. We also work with  
data providers and our clients to help us 
gather data from the real economy to improve 
our analysis.

Scenarios used in our analysis are modelled 
upon allocation assumptions of the available 
carbon budget and actions that need to be 
taken to drive the global transition to 1.5°C 
outcomes. Assumptions include technology 
development and/or adoption, shifts in  
the energy mix, the retirement of assets, 
behavioural changes and implementation of 
policy levers, among others. We expect that 
scenario developers will be continually working 
to improve the usability, accuracy and 
granularity of pathways.

Setting our targets 
We set targets for sectors based on 
decarbonisation pathways that are 
constructed using the Net Zero Emissions  
by 2050 scenario produced by the 
International Energy Agency (‘IEA’).

Following guidance from the Net-Zero Banking 
Alliance (‘NZBA’) and the Science Based 
Targets Initiative (‘SBTi’) this scenario  
has low reliance on negative emissions 
technologies, or the possibility for the rise  
in global temperatures to exceed 1.5°C before 
cooling again. The scenario makes reasonable 
assumptions about the potential for carbon 
sequestration through nature-based solutions 
and land use change. 

Our approach for financed emissions 
accounting does not rely on purchasing 
offsets to achieve any financed emissions 
targets we set.

Meeting our targets for 2030 is dependent  
on immediate and significant deployment of 
available clean technology solutions, as shown 
by the IEA’s Net Zero by 2050 roadmap for the 
global energy sector. Innovation in this decade 
needs to be accompanied by large‐scale 
construction of infrastructure to enable the 
implementation of cleaner technologies. This 
will require strong policy support and public 
and private capital to be deployed at scale. 

We also recognise that the supply and 
demand side of the market need to move 
concurrently. The reduction of fossil fuels in 
favour of clean energy supply needs to be 
matched by an increase in demand from 
industry, buildings and transport to consume 
clean energy. Both the supply and demand  
still require significant policy support to  
enable this transition economically.

Connecting the offshore 
energy industry 

The global transition to a net zero 
economy provides opportunities for 
companies looking to create new 
connections to renewable energy 
sources. UK-based JDR Cable Systems, 
which is part of TFK Group, links global 
offshore energy sources to the land 
using its subsea cable technology. As it 
looks to expand its production, and with 
the backing of UK Export Finance, we 
helped to provide a £100m investment 
loan to finance the building of a new 
facility in Cambois, near Blyth, 
Northumberland. The new facility, 
which occupies the site of a former 
coal-fired power station, will help JDR 
expand its product portfolio. It is 
expected to complete in 2024.

Leading the electric battery charge in Indonesia 

We are supporting Hyundai in its journey to produce only electrical vehicles by 2040. We 
acted as a mandated lead arranger and lender towards a $711m loan to a joint venture 
company between Hyundai Motor, Kia, Hyundai Mobis and LG Energy Solution. The 
financing will help fund the construction of an electric vehicle battery manufacturing plant in 
Karawang, Indonesia, which would be the first in south-east Asia. The facility will have an 
annual production capacity of 10 gigawatt hours (‘GWh’)-worth of lithium-ion battery cells.

As the electric vehicle battery sector continues to grow, the facility will help establish 
Indonesia as an electric vehicle supply chain hub in Asia and be a crucial contributor to 
Hyundai’s net zero ambitions in the region.

HSBC Holdings plc Annual Report and Accounts 2022

51

ESG reviewESG review | Environmental 

Financed emissions continued

Data and methodology limitations

Our financed emissions estimates and 
methodological choices are shaped by the 
availability of data for the sectors we analyse. 

 – We are members of Partnership for Carbon 

Accounting Financials (‘PCAF’), which 
seeks to define and develop greenhouse 
gas accounting standards for financial 
institutions. PCAF developed the Global 
GHG Accounting and Reporting Standard 
for the Financial Industry, which focuses  
on measuring and reporting financed 
emissions. The PCAF Standard provides 
guidance on assigning data quality scoring 
per asset class, creating data transparency 
and encouraging improvements to data 
quality in the medium and long term. 

 – We found that data quality scores varied 

across the different sectors and years of our 
analysis, although not significantly. While 
we expect our data quality scores to 
improve over time, as companies continue 
to expand their disclosures to meet growing 
regulatory and stakeholder expectations, 
there may be fluctuations within sectors 
year on year, and/or differences between 
the data quality scores between sectors  
due to changes in data availability.

 – 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 estimate them using proxies 
based on company production and revenue 
figures, and validated key data inputs with 
our global relationship managers. 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. As data 
improves, estimates will be replaced with 
reported figures. Our 2019 emissions for our 
oil and gas, and power and utilities sectors 
have been revised as a result of changes to 
data sources. 

 – Third-party data sets that feed into our 

analysis may have up to a two-year lag in 
reported emissions figures, and we are 
working with data providers to help  
reduce this.

 – The methodology and data used to assess 
financed emissions and set targets are new 
and evolving, and we expect industry 
guidance, market practice, and regulations 
to continue to change. We plan to refine our 
analysis using appropriate data sources and 
current methodologies available for the 
sectors we analyse. 

 – In line with the PCAF Standard, to calculate 
sector-level baselines and annual updates, 

our portfolio-level financed emissions  
are weighted by the ratio of our financing  
in relation to the value of the financed 
company. We believe this introduces 
volatility and are assessing if portfolio 
weight is more appropriate. We remain 
conscious that the economic value used  
in the financed emissions calculation is 
sensitive to changes in drawn amounts or 
market fluctuations, and we plan to be 
transparent around drivers for change to 
portfolio financed emissions where possible.

 – The classification of our clients into sectors 

is performed with inputs from subject 
matter experts and will also continue to 
evolve with improvements to data and  
our sector classification approach. 

 – The operating environment for climate 
analysis and portfolio alignment is also 
maturing. We continue to work to improve 
our data management processes, and are 
implementing steering mechanisms to align 
our provision of finance with the goals and 
timelines of the Paris Agreement. 

 Our methodology for financed emissions 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.

Targets and progress

We have set out in the table below our defined targets for the on-balance sheet financed emissions for the following sectors: oil and gas; power 
and utilities; cement; iron, steel and aluminium; aviation; and automotive. On the following pages, we provide more granular details on our financed 
emissions within these sectors. 

Sector

Oil and gas

Power and utilities2

Cement

Iron, steel and aluminium3

Aviation

Automotive

2019 baseline

2020 progress

2030 target

Unit1

Target type

33.0

589.9

0.64

1.8

84.0

191.5

30.1

509.6

0.64

2.0

103.9

176.2

(34)%

138

0.46

1.05 (1.43)

63

66

Mt CO2e 
tCO2/GWh
tCO2/t cement
tCO2/t metal
tCO2/million rpk
tCO2/million vkm

Absolute 

Intensity

Intensity

Intensity

Intensity

Intensity

Target scenario

IEA NZE 2050

IEA NZE 2050

IEA NZE 2050

IEA NZE 2050

IEA NZE 2050

IEA NZE 2050

1  Our absolute and intensity emission metrics and targets are measured based on the drawn exposures of the counterparties in scope for each sector, which is a 

subset of our total loans and advances. For the oil and gas sector, absolute emissions are measured in million tonnes of carbon dioxide (‘Mt CO2e’) and intensity  
is measured in million tonnes of carbon dioxide per exajoule (‘Mt CO2e/Ej’); for the power and utilities sector, it is measured in tonnes of carbon dioxide equivalent 
per gigawatt hour (‘tCO2/GWh’); for the cement sector, it is measured in tonnes of carbon dioxide per tonne of cement (‘tCO2/t cement’); for the iron, steel and 
aluminium sector, it is measured in tonnes of carbon dioxide per tonne of metal (‘tCO2/t metal’); for the aviation sector, it is measured in tonnes of carbon dioxide 
per million revenue passenger kilometres (‘tCO2/million rpk’); and for the automotive sector, it is measured in tonnes of carbon dioxide per million vehicle kilometres 
('tCO2/million vkm’).

2  Our power and utilities target units have been revised from our 2021 analysis, and the target has been revised from 0.14 Mt CO2e/TWh to 138 tCO2/GWh due to 

rounding. The target value remains unchanged.

3  While the iron, steel and aluminium 2030 target is aligned with the IEA Net Zero Emissions by 2050 scenario, we also reference the Mission Possible Partnership 

Technology Moratorium scenario, whose 2030 reference range is shown in parentheses.

52

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

Financed emissions continued

When assessing the changes from 2019  
to 2020, it is important to emphasise the 
long-term commitment that is needed to meet 
our 2030 interim targets and how changes  
to exposure and market fluctuations impact 
yearly updates. Movement from one year to 
the next may not reflect future trends for the 
financed emissions of our portfolio, and as we 
are at the beginning of our journey to track 
and measure progress, we believe it would be 
premature to infer future trends from the 2019 
to 2020 progress at this stage. In addition, the 

Oil and gas
For the oil and gas sector, we cover all scopes 
for upstream as well as integrated companies  
to help ensure we include the vast majority of 
CO2 and methane emissions created by crude 
oil and natural gas extraction and consumption. 
In line with the IEA Net Zero Emissions by 2050 
scenario, we target an absolute reduction of 
34% in on-balance sheet financed emissions  
by 2030, using 2019 as our baseline. We believe 
decarbonising the energy system, and therefore 
our ability to meet our targets, requires 
electrification of the economy, combined with a 
shift from consuming fossil fuels towards the 
use of more renewable electricity and 
alternative fuels.

Due to data quality and modelling 
improvements, we have revised our 2019 
baseline to 33.0 million tonnes of carbon dioxide 
(‘Mt CO2e’). The sector’s PCAF data quality 
score is 2.7 for scope 1 and 2, and 2.9 for scope 
3 in 2019, indicating that we need to find better 
data sources, such as reported and verified 
emissions. Many clients report scope 1 and 2, 
but for scope 3 we have had to estimate many 
data points using production and revenue 
proxies, in line with PCAF guidance. In 2020, 
absolute financed emissions decreased 9%, 
mostly as a result of changes in our portfolio 
during the first year of the Covid-19 pandemic.

Covid-19 pandemic led to anomalies in our 
portfolio’s financed emissions for 2020. 

global average, the baselines may be  
the same.

For some sectors, our financed emissions 
baseline will be different from the Net Zero 
Emissions by 2050 reference scenario 
baseline. Where we have applied an absolute 
reduction target such as for the oil and gas 
sector, and the target is defined as a 
percentage reduction from the baseline they 
will be the same. Similarly, when the sector 
portfolio intensity is very similar to that of the 

We plan to report financed emissions and 
progress against our targets annually and 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 recalibration as data, methodologies 
and reference scenarios develop. 

Power and utilities
For the power and utilities sector, we include 
scope 1 and 2, and focus on power generation 
only. We also follow the IEA Net Zero Emissions 
by 2050 scenario and target an on-balance 
sheet financed emissions intensity of 138 
tonnes of carbon dioxide equivalent per 
gigawatt hour (‘tCO2/GWh’) by 2030, using 2019 
as our baseline. The power and utilities sector  
is expected to expand significantly as the 
electrification of transport, heating and other 
activities will drive an increase in electricity 
demand. To enable this growth through 
low-emission sources of electricity, we have 
chosen an intensity target. We believe financing 
for renewable electricity will need to increase 
significantly to help us meet our targets, 
alongside smart grids and energy storage.

Due to data quality and modelling 
improvements, we have revised our 2019 
baseline to 589.9 tCO2/GWh, which is higher 
than the IEA global average. The PCAF score is 
3.3, for scope 1 and 2 in 2019, as many of our 
smaller clients are not disclosing their scope 1 to 
2 emissions. These have mostly been estimated 
using production or revenue, which will be 
replaced when we have reported and verified 
emissions from clients. In 2020, the emissions 
intensity of our portfolio decreased by 14% as a 
result of clients moving their generation mix to 
lower emission sources and portfolio shifts.

Cement
We cover scope 1 and 2 for all companies with 
clinker and cement manufacturing facilities. In 
line with the IEA Net Zero Emissions by 2050 
scenario, we target an on-balance sheet 
financed emissions intensity of 0.46 tonnes of 
carbon dioxide per tonne of cement (‘tCO2/t 
cement’) by 2030, using 2019 as our baseline. 
Some emission reductions can be achieved 
through energy efficiency. However, we believe 
that to significantly reduce fuel and process 
emissions from cement manufacturing, and  
our ability to meet our targets, large-scale 
investments are required in new technologies, 
such as clinker substitution, alternative fuel use 
such as bioenergy, and carbon capture use and 
storage. Our 2020 emission intensity stayed 
level with 2019, as there were no significant 
changes to the emission intensity of our clients. 
The PCAF score for the cement sector is 2.2  
for scope 1 and 2 in 2019, which is higher 
compared with other sectors, as we have 
reported emissions data for a large portion of 
our clients, and have only needed to estimate 
emissions through production or revenue 
proxies for the smaller clients in our portfolio.

Oil and gas 
Mt CO2e 

2020 progress 
from baseline
(9)%

Power and utilities2 
tCO2/GWh

2020 progress 
from baseline
(14)%

Cement 
tCO2/t cement

2020 progress 
from baseline
0

h
W
G

/
2

O
C
t

700

600

500

400

300

200

100

0

t
n
e
m
e
c

t
/
2

O
C
t

0.7

0.6

0.5

0.4

0.3

0.2

0.1

0

2019 2020

2025

2030

2019 2020

2025

2030

2019 2020

2025

2030

45

40

35

30

25

20

15

10

5

0

e
2
O
C
t
M

Key:

Net Zero Emissions by 2050 Scenario

On-balance sheet financed emissions intensity

HSBC Holdings plc Annual Report and Accounts 2022

53

ESG review 
ESG review | Environmental 

Financed emissions continued

Iron, steel and aluminium
We cover scope 1 and 2 for midstream iron, 
steel and aluminium production. Due to the low 
materiality of the aluminium sector’s financed 
emissions within our portfolio, we have 
combined them with our iron and steel financed 
emissions. For the iron, steel and aluminium 
sector, we target an on-balance sheet financed 
emissions intensity of 1.05 (1.43) tonnes of 
carbon dioxide per tonne of metal (‘tCO2/t 
metal’) by 2030, using 2019 as our baseline.  
We use the IEA Net Zero Emissions by 2050 
scenario as our core target scenario, and have 
included the net zero-aligned Mission Possible 
Partnership Technology Moratorium as an 
alternative scenario. We recognise that our 
ability to meet our targets in so-called ‘hard-to-
abate’ sectors is dependent on strong policy 
support to unlock widespread investment and 
the scaling up of crucial nascent technologies. 
We will continue to monitor the progress in the 
uptake of low-carbon technologies, and assess 
real economy progress against the IEA and 
Mission Possible Partnership scenarios.  
The emissions intensity in 2020 rose due to 
increased financing to the aluminium sector, 
which has a higher carbon intensity than that  
of steel. The PCAF score is 2.5 in 2019, as only  
a small number of clients have reported 
emissions, and for many we have had to  
make estimates based on their revenue.

Aviation
In the aviation sector, we included airlines’ 
scope 1 emissions and aircraft lessors’ scope 3 
emissions, as we believe this captures direct 
emissions from aircraft as the main source of 
emissions. We exclude military and dedicated 
cargo flights. As per the IEA Net Zero Emissions 
by 2050 scenario, we target an on-balance 
sheet financed emissions intensity of 63 tonnes 
of carbon dioxide per revenue passenger 
kilometre (‘tCO2/rpk’) by 2030, using 2019 as our 
baseline. To reach these intensity levels, and 
help meet our targets, we believe the sector 
needs significant policy support investments 
into alternative fuels, such as sustainable 
aviation fuel, and new aircraft to reduce 
emissions. Sustainable aviation fuel is currently 
too costly and in limited supply, so the industry’s 
decarbonisation efforts are highly dependent on 
partnerships between energy companies, 
airlines and aircraft manufacturers. Due to  
the travel disruption caused by the Covid-19 
pandemic in 2020, emissions intensity figures 
increased significantly as aeroplanes carried 
fewer passengers on average. This can be  
seen in the IEA numbers as well as our client 
portfolio. For the aviation sector, the PCAF  
score is 2.8 for scope 1 and 2, and 2.8 for scope 
3 in 2019, as emissions or production data is 
available for most clients, although we continue 
to have a challenge with finding reported 
emissions from smaller firms.

Automotive
For the automotive sector, we look at scope 1, 2 
and 3 emissions from the manufacturing of 
vehicles, and tank-to-wheel exhaust pipe 
emissions for light-duty vehicles. We excluded 
heavy-duty vehicles from our analysis, following 
industry practice. We will consider including 
them at a later stage of our analysis as data and 
methodologies develop. We target an on-
balance sheet financed emissions intensity of 66 
tonnes of carbon dioxide per vehicle kilometre 
(‘tCO2/vkm’) by 2030, using 2019 as our baseline. 
This is in line with the IEA Net Zero Emissions by 
2050 scenario, modified to match the share of 
new in-year vehicle sales for light-duty vehicles. 
We believe decarbonisation of the automotive 
sector, and therefore our ability to meet our 
targets, needs large-scale investments in new 
electric vehicle and battery manufacturing 
plants, widespread charging infrastructure, and 
government policies to support electric vehicles. 
Our 2020 intensity reduced by 8% as a result of 
clients manufacturing more efficient vehicles, 
and the increased sales of electric vehicles. The 
PCAF score for the automotive sector is only  
3.3 for scope 1 and 2, and 3.4 for scope 3 in 
2019, as most companies only report their  
scope 1 and 2 emissions. We had to estimate 
scope 3 emissions using vehicle production 
numbers. Increased self-reporting of  
scope 3 emissions from clients would 
significantly improve data quality.

Iron, steel and aluminium3 
tCO2/t metal

2020 progress 
from baseline
11%

Aviation 
tCO2/million rpk

2020 progress 
from baseline
24%

Automotive 
tCO2/million vkm

2020 progress 
from baseline
(8)%

k
p
r

n
o

i
l
l
i

m

/
2

O
C
t

200

180

160

140

120

100

80

60

40

20

0

m
k
v

n
o

i
l
l
i

m

/
2

O
C
t

200

180

160

140

120

100

80

60

40

20

0

2019 2020

2025

2030

2019 2020

2025

2030

2019 2020

2025

2030

2.5

2.0

1.5

1.0

0.5

0

l

a
t
e
m

t
/
2

O
C
t

Key:

Net Zero Emissions by 2050 Scenario

On-balance sheet financed emissions intensity

MPP Tech Moratorium

Our analysis of shipping emissions

As part of our work in 2022, we analysed financed emissions for the shipping sector to establish a baseline. During our analysis we noted 
significant data gaps in reported emissions and data from external vendors at the company level. For scope 1 emissions, which are typically  
the easiest to source, we would have needed to have made estimates using outstanding amounts rather than production or revenue indicators, 
which would have resulted in the least accurate data quality scoring. We have therefore chosen to defer setting a baseline and target for this 
sector until there is sufficient reliable data to support our work, allowing us to more accurately set a baseline and track progress towards net 
zero. We will continue to engage with strategic clients within the sector to encourage disclosure and discuss their transition plans. We believe 
the shipping industry will require significant policy support and innovation to allow for the use of lower emissions fuels in existing as well as  
new ships. On the supply side, the provision of low-carbon fuels will need to increase sufficiently to meet this new demand.

54

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
Environmental 

Financed emissions continued

Financed emissions
The table below summarises the results of our assessment of financed emissions using 2019 and 2020 data. 

Sector

Oil and gas4, 5

Power and utilities4,5

Cement

Iron, steel and aluminium

Aviation

Automotive

On-balance sheet financed emissions – wholesale credit lending and project finance1,2

Scope 1–2  
(Mt CO2)†

Scope 3  
(Mt CO2)†

Emissions 
intensity

Scope 1  
and 2

Scope 3

PCAF data quality score3,†

3.7

3.3

12.1

11.8

2.2

1.3

3.2

2.7

6.2

4.9

0.11

0.14

29.3

26.8

N/A

N/A

N/A

N/A

N/A

N/A

0.11

0.08

4.0

4.9

72.2

71

589.9

509.6

0.64

0.64

1.8

2

84

103.9

191.5

176.2

2.7

2.7

3.3

3.2

2.2

2.3

2.5

2.8

2.8

2.6

3.3

3.2

2.9

2.9

N/A

N/A

N/A

N/A

N/A

N/A

2.8

3

3.4

3.3

Year

2019

2020

2019

2020

2019

2020

2019

2020

2019

2020

2019

2020

1 Total amount of short-term finance excluded for all sectors listed is $9.3bn in 2019 and $7.6bn in 2020
2  Total loans and advances analysed in 2019 were $38.3bn representing 1.7% of wholesale credit and lending and project finance at 31 December 2019, and in 2020 

were $34.7bn representing 1.7% of wholesale credit and lending and project finance at 31 December 2020.

3 PCAF scores where 1 is high and 5 is low. This is a weighted average score based financing for on-balance sheet financed emissions.
4   In the Annual Report and Accounts 2021 the units for power and utilities were reported last year as MtCO2e, and are now read Mt CO2. Oil and gas absolute 

emissions are measured in MtCO2e. This year we amended the units for the power and utilities sector from Mt CO2e/TWh’ to tCO2/GWh to align to market practice. 
While the target value remains unchanged this has led to a revision in the figure reported from 0.14 Mt CO2e/TWh’ to 138 tCO2/GWh.

5   Our 2019 emissions for our oil and gas, and power and utilities sectors have been revised due to changes in data impacting drawn amounts of client lending, and 

amendments to the assumptions governing the in-scope client population.

†  Data is subject to independent limited assurance by PwC in accordance with ISAE 3000/ ISAE 3410. For further details, see our Financed Emissions Methodology 

and PwC's limited assurance report, which are available at www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre. 

Our analysis of facilitated emissions 

In March 2022, we said we would set capital markets emissions targets for the oil and gas, and power and utilities sectors based on the industry 
reporting standard from the PCAF once published. We have chosen to defer setting targets for facilitated emissions until the PCAF standard for 
capital markets is published, which is expected in 2023. We had intended to disclose facilitated emissions for 2019 and 2020 for the oil and gas, 
and power and utilities sectors for transparency, as we did last year. However, following internal and external assurance reviews performed 
during the year, we identified certain data and process limitations and have deferred the publication of our facilitated emissions for 2019 and 
2020 for these two sectors while additional verification procedures are performed. We aim to provide these disclosures as soon as practicable 
in 2023. 

We continue to monitor the developments in industry standards for the publication of such emissions and associated targets, and, as 
mentioned above, we will seek to align to the PCAF standard when published. However, we will aim to provide transparency on our 2019  
and 2020 facilitated emissions for the oil and gas, and power and utilities sectors as they become available, which may be in advance of  
the PCAF standard being available.

HSBC Holdings plc Annual Report and Accounts 2022

55

ESG reviewESG review | Environmental 

Financed emissions continued
Embedding financed emissions 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.

In 2022, we developed an operating model 
across our Global Sustainability teams to 
strengthen our processes, systems, controls 
and governance. The Global Sustainability 
function also established a Sustainability 
Centre of Excellence, a team of sustainability 
specialists with deep subject matter expertise 
on new climate technologies, climate analytics 
and transition planning and assessment, to 
help us fulfil our net zero commitments and 
serve our customers.

The Global Sustainability Centre of Excellence, 
together with the Group Risk and Compliance, 
and Global Finance functions, have continued 
to develop our approach, including working to 
embed financed emissions into our business 
activities and culture. We have strengthened 
our climate data and analytics capability to 
help inform decision making and portfolio 
management, as well as expanded the 
resources to support business engagement. 

We are placing climate and sustainability at the 
heart of our engagement with customers, and 
in particular those customers with the greatest 
potential to effect change. In 2022, we 
requested and assessed transition plans for EU 
and OECD managed clients in scope of our 
thermal coal phase-out policy. We have also 
requested and are assessing transition plans 
for our major oil and gas clients (see page 49). 

We aim to provide and facilitate $750bn to 
$1tn of sustainable finance and investment  
by 2030 to support our customers in their 
transition to net zero and a sustainable future. 
In 2022, we also started to develop an 
approach for allocating financing to scale 
technologies critical to reach net zero.

Our own climate transition plan will bring 
together our financed emissions targets and 
climate strategy, with how we plan to embed 
this into our processes, infrastructure, 
governance and engagement.

The next section provides further detail on how 
we are embedding net zero considerations into 
our customer engagement and unlocking 
finance to support our customers on their 
transition to net zero and a sustainable future.

Backing green SMEs in 
the UK 

Panthera Group, a family-run 
construction company, launched 
EnviroHoard, the UK’s first construction 
hoarding system to be verified as net 
zero carbon. In March, we supported 
the firm with the first ever loan through 
our $500m Green SME Fund, which we 
announced at COP26 as part of our 
commitment to supporting small and 
medium-sized businesses in their 
transition to net zero. Panthera will use 
the loan to grow its business in the UK. 
In 2022, Panthera reduced 446 tonnes 
of carbon emissions through its 
installations, and set up a partnership 
with Circular Ecology and Trees for 
Cities to help offset the carbon impact 
of its installations.

Reducing emissions in our assets under management 

In July 2021, our asset management 
business, HSBC Asset Management, signed 
up to the Net Zero Asset Managers initiative, 
which encourages investment firms to 
commit to manage assets in line with the 
attainment of net zero emissions by 2050. 

In November 2022, HSBC Asset Management 
announced its ambition of reducing scope 1 
and 2 carbon emissions by 58% by 2030 for 
38% of its total assets under management, 
consisting of listed equity and corporate fixed 
income, which amounted to $193.9bn at  
31 December 2019.

A baseline year of 2019 was chosen for our 
calculations as it offered a more realistic 
picture of the level of carbon emissions 
intensity than the period after the pandemic. 
Our baseline for the emission intensity of our 
portfolio in 2019 was 131tCo2e/M$ invested, 
which includes scope 1 and 2 emissions of 
companies in our portfolio. 

Our baseline represents the emissions 
associated with our investing activities  
in terms of emissions per dollar invested 
relevant of the assets under management in 
scope for this assessment. We will review 
our interim target at least every five years, 
with a view to increasing the proportion  
of assets under management covered until 
100% of assets are included. Implementation 
of our net zero targets remains subject to 
consultation with our key stakeholders. We 
plan to stay actively engaged to help support 
our investors on their own decarbonisation 
goals, and continue to apply resources in  
the development of climate solutions. 

To support the development of HSBC Asset 
Management’s climate strategy and goal to 
deliver on its target, it has chosen to align to 
the Institutional Investors Group on Climate 
Change’s net zero investment framework, 
which was created for investors to provide  
a common approach around the actions, 

metrics and methodologies required to align 
portfolios to net zero. 

The PCAF data quality score for our baseline 
emissions was 2.63. 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’, and with 
respect of the greenhouse 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.  
For the methodology, PwC’s limited 
assurance report, and details on HSBC Asset 
Management’s net zero ambition, see www.
assetmanagement.hsbc.com/net-zero.

56

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

Supporting customers through transition  TCFD

We understand that financial institutions have 
a critical role to play in achieving the transition 
to a net zero global economy. We believe the 
most significant contribution we can make is 
by mobilising finance to support our portfolio 
of customers in their transition to decarbonise. 

Mobilising sustainable finance for our 
customers
Given our global presence and relationships 
with our customers across industries, we 
recognise the role we can play in catalysing 
the global transition to net zero. We are well 
positioned to help finance the transition  
in developing and emerging economies, 
mobilising capital to help enable sustainable 
business models and an inclusive, just and 
resilient transition. 

In 2022, we continued to expand the horizons 
of sustainable finance through our products, 
services and partnerships to help enable 
emissions reduction in the real economy:

 – We launched a $5bn sustainable finance
scheme to support businesses of all sizes
to transition to low-carbon operations in
China’s Greater Bay Area, with successful
loan applicants entitled to a range of
additional services including training,
subsidised third-party assessments and
assistance from a newly formed team
with sustainable financing expertise.

 – We created a sustainable supply

chain finance programme for apparel
company PVH Corp in the US to finance
environmentally and socially friendly
production at its manufacturing facilities
(see page 97).

 – We supported Panthera Group, a family-run
construction company, to finance and grow
the UK’s first construction hoarding system
to be verified as zero carbon, (see page 56).

 – We expanded our green mortgage offering

to our retail customers in Hong Kong,
mainland China, India and Türkiye, as well
as electric vehicle and energy efficiency
loans to customers in Hong Kong, Egypt
and Argentina.

 – We committed to working collaboratively
with the government of Egypt in its Nexus
of Food, Water and Energy programme to
identify ways to use scarce public finances
effectively and efficiently, and help raise
private finance to support priority projects
from its national climate change strategy.

As part of the Just Energy Transition 
Partnership, which aims to mobilise capital 
towards emerging and developing economies 
to support their national climate strategies, we 
agreed to support the facilitation of at least 
$10bn of private sector financing for projects 
in Indonesia and $7.8bn for projects in 
Vietnam over the next three to five years.

In addition, we were also mandated to act on 
12 ESG-related government bonds, including 
inaugural issuances for the governments of 
Singapore, Canada and Uruguay. In 2022,  
we secured six awards at the Environmental 
Finance Bond Awards, revealing the high 
regard in the market for our structuring and 
engagement work across green, social and 
sustainability bonds during 2021. In the IFR 
Awards 2022, we were named ESG Financing 
House of the Year. We were also recognised 
by Euromoney as the Best Bank for 
Sustainable Finance in Asia for the fifth 
consecutive year, and in the Middle East  
for the fourth.

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. This includes 
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, achieve gender equality, reduce 
inequality, 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. 

$210.7bn

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

Embedding net zero transition into our client engagement

In 2022, we requested and assessed transition plans for EU and OECD managed clients in 
scope of our thermal coal phase-out policy. We also requested and are assessing transition 
plans for our major oil and gas clients. In 2023, we expect to complete assessments for 
remaining clients in scope of our thermal coal phase-out policy. Similarly, we expect to 
complete assessments for major oil and gas and power and utilities clients globally as well  
as other clients in EU and OECD markets in scope of our energy policy. 

Our assessments consider historical emissions and disclosures, emissions reduction targets,  
details of transition plans to achieve targets, and evidence of activities in line with these plans.  
Our assessment framework helps us to understand our clients’ transition plans, develop an 
engagement strategy to help support them on their transition journey and help us achieve our 
net zero ambition. We acknowledge that our assessment of client transition plans is in the 
initial stages and our engagement with clients on their plans and progress will need to 
continue to be embedded.

HSBC Holdings plc Annual Report and Accounts 2022

57

ESG reviewESG review | Environmental 

Supporting customers through transition continued

Financing the transition 
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 promoted green, sustainable 
and socially-focused business alongside 
sustainable infrastructure and energy 
systems, and enhanced investor capital 
through sustainable investment. 

Since 1 January 2020, we have provided and 
facilitated $185.3bn of sustainable finance, 
$19.0bn of sustainable investment and $6.4bn 
of sustainable infrastructure, as defined in our 
Sustainable Finance and Investment Data 
Dictionary 2022. This included 36% where  
the use of proceeds were dedicated to green 
financing, 13% to social financing, and 15% to 
other sustainable financing. It also included 
27% of sustainability-linked financing and 9% 
of net new investments flows managed and 
distributed on behalf of investors. 

In 2022, our underwriting of green, social, 
sustainability and sustainability-linked bonds 
for clients decreased in line with the overall 
market, although remained at 15% of our 
total bond issuances. On-balance sheet 
sustainable lending transactions increased 
by 53%, compared with 2021. The 
outstanding sustainable finance on-balance 
sheet position was in excess of $24bn at  
31 December 2022.

Sustainability-linked bonds are a recent 
innovation in the debt capital markets, which 
allow investors to manage their sustainability 
strategies by linking targets, and progress 
towards them, to the issuers’ financing costs. 
These products do not require definitions of 
use-of-proceeds as they are linked to issuers’ 
broader sustainability commitments.

Issuer commitments and strategies continue 
to develop and be included in medium- to 
long-term sustainability plans. We expect  
that sustainability-linked bonds will become 
increasingly meaningful for transparency in 
issuer performance against science-based 
transition pathways and other sustainability 
goals. We have supported customers within 
the high transition risk sectors to issue 
sustainability-linked bonds which support  
the transition to the net zero economy and  
a sustainable future.

We are working closely with industry bodies, 
such as the International Capital Markets 
Association (‘ICMA’), to establish a robust  
set of standards for the market. The ICMA 
Sustainability-Linked Bond Principles provide 
guidelines on what is core, material and 
relevant in terms of key performance 
indicators, and provides advice on how  
targets should be assessed.

2022 
($bn)

2021 
($bn)

2020 
($bn)

Cumulative progress 
since 2020
($bn)

Sustainable finance summary1

Balance sheet-related transactions provided

Capital markets/advisory (facilitated)

Investments (assets under management – flows)

Total contribution2

Sustainable finance classification by theme

Green use of proceeds3

Social use of proceeds3

Other sustainable use of proceeds3,4

Sustainability-linked5

Sustainable investments – Asset Management6

42.1

34.6

7.5

26.0

48.7

7.7

84.2

82.4

29.0

6.7

12.6

28.4

7.5

27.1

11.3

11.7

24.6

7.7

10.3

30.0

3.7

44.1

18.8

9.7

8.3

3.5

3.7

78.4

113.3

19.0

210.7

74.9

27.8

32.7

56.5

19.0

210.7

Total contribution2,7

84.2

82.4

44.1

1  This table has been prepared in accordance with our Sustainable Finance and Investment Data Dictionary 2022, 
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. In 2022, 
green liabilities were removed from the data dictionary, which resulted in $0.3bn removed from the published 
2021 cumulative total.

2  The $210.7bn cumulative progress since 2020 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 and Investment Data Dictionary 
2022 and PwC’s limited assurance report, see www.hsbc.com/who-we-are/esg-and-responsible-business/
esg-reporting-centre.

3  For green, social and other sustainable use of proceeds, our capital markets products are aligned to either 

ICMA’s Green Bond Principles, Social Bond Principles or Sustainability Bond Guidelines. Our lending labelled 
products are aligned to the LMA’s Green Loan Principles, the LMA’s Social Loan Principles or our sustainable 
trade instruments, which align the use of proceeds to the UN SDGs.

4   Sustainability use of proceeds can be used for green, social or a combination of green and social purposes.
5  Our sustainability-linked-labelled products are aligned to either the ICMA Sustainability-Linked Bond Principles 

or LMA Sustainability-Linked Loan Principles. The coupon or interest rate is linked to sustainability key 
performance indicators and the funds can be used for general purposes. Of the cumulative total of $56.5bn, 
$10.1bn relates to sustainability linked bonds and $46.4bn relates to sustainability linked loans. Within the 
sustainability linked loans, $13.1bn relates to lending to customers within the six high transition risk sectors  
(i.e. automobiles, chemicals, construction and building materials, Metals and mining, oil and gas, and power 
and utilities) as described on page 223. 

6  Net flows of HSBC-owned sustainable investment funds that have been assessed against the Sustainable 

Finance and Investment Data Dictionary 2022.

7  Additional detailed information in relation to our sustainable finance and investment progress can be found in 

the ESG Data Pack.

Our approach to financing net zero 
In 2022, we started developing a strategy to 
help us orient how we allocate our financing 
solutions and capital to support our clients’ 
transition to net zero and help deliver a 
significant decarbonisation impact to the 
global economy. The approach, based on the 
IEA’s Net Zero by 2050 scenario, identifies the 
infrastructure, technologies and new business 
models critical for industries to transition to net 
zero. We recognise that we will need to adapt 
our capabilities in specific products and 
sectors to capture business opportunities and 
help finance the transition. In 2022, we made 
several investments to play a catalytic role, 
including through Pentagreen Capital, an 
innovative financing vehicle set up in 
partnership with Temasek, to accelerate 
sustainable infrastructure in south-east Asia, 
and with Breakthrough Energy Catalyst to gain 
expertise in nascent, ‘new-economy, sectors 
aligned with our clients’ net zero ambitions. 

 Our data dictionary defining our sustainable 
finance and investments continues to evolve,  
and is reviewed annually to take into account the 
evolving standards, taxonomies and practices we 
deem appropriate. Our review involves reviewing 
and strengthening our product definitions, where 
appropriate adding and deleting qualifying 
products, making enhancements to our internal 
standards, and evolving reporting and 
governance. Our progress will be published each 
year, and we will seek to continue for it to be 
independently assured.
 The detailed definitions of the contributing 
activities for sustainable finance and investment 
are available in our revised Sustainable Finance 
and Investment Data Dictionary 2022. For our 
ESG Data Pack, Sustainable Finance and 
Investment Data Dictionary and third-party  
limited assurance report, see www.hsbc.com/
who-we-are/esg-and-responsible-business/
esg-reporting-centre.

58

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

Supporting customers through transition continued

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

Our Asset Management business seeks  
to drive innovation at scale, and bring new 
propositions to the market for investors, 
including sustainable exchange-traded funds 
and lower-carbon investment solutions. We  
are committed to further developing our 
sustainable product range across asset classes 
and strategies, as well as enhancing our 
existing product set for ESG criteria where it is 
in the investors’ interests to do so. In 2022, we 
launched 24 funds with a sustainable focus. 

In our aim to support the transition to more 
sustainable ways of dealing with resources 
and waste, through the circular economy, 
HSBC Asset Management launched the HSBC 
Global Investment Fund (’HGIF’) Global Equity 
Circular Economy fund. 

To support its net zero ambition, HSBC Asset 
Management continued to add to the range of 
products aligned to Paris-aligned benchmarks, 
launching two exchange-traded funds in 2022 
that invest in emerging markets and Asia-
Pacific. These benchmarks’ underlying assets 
are selected in such a manner that the 
resulting benchmark portfolio's greenhouse 
gas emissions are aligned with the long-term 
global warming target of the Paris Agreement. 

In 2022, HSBC Asset Management’s fixed 
income, equity and stewardship teams held 
over 1,000 meetings with companies in our 
portfolios. These included discussions on 
climate-related matters, with more than 60  
of these having specific, targeted outcomes 
with climate objectives. We continue to 
engage with issuers, encouraging the 
reporting of emissions data, the setting of 
emissions reduction targets, the assessment 
of climate risk, and the development of robust 
transition strategies.

We expanded our investment offering for 
private banking and wealth clients with the 
launch of 22 sustainable investing mutual 
funds and exchange-traded funds in 2022.  
We offer a range of sustainable investment 
products across other asset classes, including 
equities, fixed income, discretionary and 
alternatives. We enhanced our ESG thematic 
products offering linked to indices. For 
example, we collaborated with Euronext and 
Iceberg Datalab to design the first broad-based 
biodiversity screened equity index family. 

At HSBC Life, our insurance business, we are 
focused on ensuring our customers have more 
access to ESG investment fund options 
aligned to their ESG preferences. ESG funds 
invest only in companies with strong ESG 
credentials or in key ESG-related areas. We 
increased the availability of ESG investment 
fund options within our investment-linked 
products. During 2022, we launched in Hong 
Kong a new protection-linked plan with three 
ESG fund choices now available, and we 
launched our first ESG fund in Mexico. 

First ESG underwriting 
guide for life and health 
insurance 

Our insurance business, HSBC Life, 
co-sponsored and co-led the first  
ESG underwriting guide for the life  
and health insurance sector. The guide 
was published by the United Nations 
Environment Programme Finance 
Initiative (‘UNEP FI’) Principles for 
Sustainable Insurance, a set of 
principles endorsed by the United 
Nations and the insurance industry.

This guide, which was published in June 
2022, provides a framework for life and 
health insurers to evaluate a range of 
ESG risks and factors on the mortality, 
morbidity, longevity and hospitalisation 
risks when underwriting.

These include risk mitigation strategies 
alongside best practices for insurers  
to consider.

The guide was put together in 
collaboration with a global team of 
sustainability experts from 11 other 
member companies of the UNEP FI 
Principles for Sustainable Insurance.  
Its purpose is to reinforce the key role 
insurers need to play in helping to solve 
the major ESG challenges of our time, 
such as the spread of infectious 
diseases, biodiversity and nature loss, 
social inequality, and mental health  
and well-being.

Accelerating growth in geothermal and recovered energy

Ormat Technologies Inc., which has been operating in renewable energy production for more 
than 50 years, has developed expertise and global experience in the supply and development of 
geothermal, recovered energy and energy storage solutions. We supported Ormat in June 2022 
with the issuance of a $431m green convertible bond, the proceeds of which will support Ormat 
grow its business and develop its renewable green energy projects.

Ormat now has a total generating portfolio of approximately 1.1 gigawatts, including a 
geothermal and solar generation portfolio across the US, Kenya, Guatemala, Indonesia, 
Honduras and Guadeloupe, as well as holding an energy storage portfolio in the US.

HSBC Holdings plc Annual Report and Accounts 2022

59

ESG reviewESG review | Environmental 

Unlocking climate solutions and innovations  

TCFD

We understand the need to find new solutions 
to increase the pace of change if the world is 
to achieve the Paris Agreement’s goal of being 
net zero by 2050. 

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

Sustainable infrastructure
Addressing climate change requires the  
rapid development of a new generation of 
sustainable infrastructure, particularly for 
emerging markets. 

During 2022, we demonstrated our 
commitment to catalysing financing for 
sustainable infrastructure projects, with the 
launch of Pentagreen Capital, a debt financing 
vehicle we set up in partnership with Temasek 
(see below).

We continue to take a leading role in the 
FAST-Infra initiative, which we helped 
conceive, 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. Through the FAST-Infra 
initiative, we helped launch in 2021 the 
Sustainable Infrastructure (SI) Label – a 
consistent, globally applicable labelling  
system designed to identify and evaluate 
sustainable infrastructure assets. The initiative 
continues to grow, with the appointment in 
November 2022 of a consortium with global 
expertise in sustainability standards, global 
finance, software and data platforms, to 
manage the secretariat of the SI Label, so  
the label becomes an enduring and widely 
adopted standard.

Natural capital as an emerging  
asset class
Climate Asset Management, a joint venture we 
launched with Pollination in 2020, forms part 
of our goal to unlock new climate solutions. 
Combining expertise in investment 
management and natural capital, Climate 

Asset Management offers investment 
solutions that generate competitive risk-
adjusted returns for investors, and nature-
enhancing ecosystems to help protect 
biodiversity and accelerate the transition  
to net zero. 

In December 2022, Climate Asset Management 
announced it had received commitments of 
over $650m for its two strategies: 

 – the Natural Capital Strategy, which invests  
in agriculture, forestry and environmental 
assets, with the aim to deliver impact at 
scale alongside long-term financial returns; 
and

 – the Nature Based Carbon Strategy, which 

targets nature restoration and conservation 
projects in developing economies, 
prioritising community benefits while 
generating high-quality carbon credits. 

One of Climate Asset Management’s  
first investments was the Restore Africa 
Programme, in partnership with the Global 
EverGreening Alliance, announced in 
November 2021. The programme, which  
is the world’s largest community-based 
land-restoration project, aims to benefit  
1.5 million smallholder farmers and their 
communities through the restoration of up to  
2 million hectares of degraded land across six 
sub-Saharan countries. The programme has 
started being implemented in Kenya, Uganda 
and Malawi, with plans for Zambia, Tanzania 
and Ethiopia to follow in 2023.

Climate Asset Management is a founding 
member of the Natural Capital Investment 
Alliance, whose 15-strong membership of 
investment firms aims to have mobilised $10bn 
towards nature-based economic themes. 

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

We continue to unlock new climate solutions, 
focusing on supporting innovation in critical 
areas such as green technologies. In January 
2022, we announced our investment of $100m 
as an anchor partner in Breakthrough Energy 
Catalyst, a programme that uses private-public 
capital to accelerate the development of four 
critical climate technologies: direct air capture, 
clean hydrogen, long-duration energy storage 
and sustainable aviation fuel.

Our philanthropic programme, 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 84).

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. We 
expanded our venture debt platform to 
support climate technology hardware and 
software companies that are growing rapidly. 
In 2022, we achieved our initial goal to fund 
$100m to climate technology companies 
through this platform, and consequently 
increased our commitment to $250m. In 
2022, we committed an additional $100m  
to fund women and minority entrepreneurs 
through our venture debt platform. 

HSBC Asset Management also launched  
a venture capital strategy that invests in 
transformative early stage companies enabling 
decarbonisation and de-pollution of industries. 
The strategy invests across four investment 
themes: power transformation, transport 
electrification, supply chain sustainability  
and climate risk mitigation. We seeded the 
strategy with capital in November 2021,  
and it has since invested in three start-up 
companies. HSBC Asset Management 
continues to actively fundraise for this 
strategy, aiming to raise additional funds  
from institutional and private wealth clients 
over the course of 2023.

Accelerating sustainable infrastructure in Asia 

In August 2022, we officially launched Pentagreen Capital, a sustainable infrastructure debt 
financing vehicle set up in partnership with Temasek. Pentagreen’s goal is to accelerate the 
development of sustainable infrastructure in Asia by removing the barriers that can prevent 
marginally bankable projects from accessing capital. With a combined $150m of seed 
capital committed by the founding partners, the Singapore-based company aims to provide 
more than $1bn of loans over the next five years, targeting opportunities initially in south-
east Asia. Its primary focus will be on clean transport, renewable energy and energy storage, 
and water and waste management.

60

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

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. According to The 
Nature Conservancy, natural climate solutions 
can provide up to 37% of the emission 
reductions needed by 2030. At the same time 
climate change is accelerating nature loss, and 
consequently the ability for nature to mitigate 
climate change impacts. 

 – We participated in a pilot test of a draft

version of the Taskforce on Nature-related
Financial Disclosures (‘TNFD’) framework
for risk and opportunity management and
disclosure, which helped us understand its
implications and provide feedback ahead
of its release in September 2023.

 – We intend to publish a new deforestation

policy, informed by scientific and
international guidance, in 2023. For further
details of our biodiversity and natural
capital-related policies, see ‘Our approach
to sustainability policies’ on page 65.

Reducing nature loss
We are making progress with the investment 
and financing of biodiversity and nature-based 
solutions through client products and services 
and partnerships. In 2022, these included:

 – In August 2022, our asset management
business, HSBC Asset Management,
launched a biodiversity exchange-traded
fund that enables investors to incorporate
sustainable considerations within their
portfolios (see below).

 – Our Global Private Banking business

launched a biodiversity strategy for our
private bank clients in Hong Kong and
Singapore, which focuses on investing
in companies that are well positioned
to harness, regenerate and protect
biodiversity through the circular and
bio-based economy.

We understand we need to do more to embed 
nature-related issues into our sustainability 
policies and climate transition plan, and we  
are committed to strengthening our risk 
management approach and engaging with  
our customers. 

Understanding our exposure 
In 2022, we made progress with 
understanding how to assess and monitor 
nature-related risks, as well as how to create 
effective transition plans with the aim of 
halting our contribution to nature loss from  
our business activities: 

 – We conducted analysis on how reliant our
large corporate clients were on ecosystem
services, including the nature-related
benefits crucial for the provision of food and
drinking water, which demonstrated that our
clients were highly dependent on water
availability.

 – To improve our understanding of the

potential credit risks that nature-related risks
pose to our customers, we worked with the
Cambridge Institute on Sustainability
Leadership, by evaluating the impact of
three months of water shortage on a sample
of our customer portfolio comprising heavy
industry companies in east Asia.

 – Through the Climate Solutions Partnership,
our philanthropic collaboration with the
World Resources Institute and WWF, we
issued two reports on the hurdles and
success factors for scaling up nature-based
solutions.

 For further details of our approach to nature and 
related initiatives, see our Statement on Nature in 
the ESG reporting centre at www.hsbc.com/
who-we-are/esg-and-responsible-business/
esg-reporting-centre.

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 58.5% 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 39.7% 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, 1.6% 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. 

Building biodiversity risk awareness into ETFs 

Asset owners and managers have a role to play in addressing potential transition and physical 
risks. Our asset management business, HSBC Asset Management, launched the first of its 
kind biodiversity screened exchange-traded fund, which provides investors with the 
opportunity to consider biodiversity risk factors in their portfolios. This exchange-traded fund 
tracks the Euronext ESG Biodiversity Screened Index series, which was jointly developed by 
HSBC, Euronext and Iceberg Data Lab. The Biodiversity Footprint Score excludes companies 
from the index that do not sufficiently consider biodiversity impacts as well as those with poor 
ESG credentials and/or business activities deemed harmful towards biodiversity.

HSBC Holdings plc Annual Report and Accounts 2022

61

ESG reviewESG review | Environmental 

Our approach to our own operations  TCFD

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, and in 2022 
we achieved 24%. We plan to do this by 
optimising the use of our real estate portfolio, 
and carrying out a strategic reduction in our 
office space and data centres. We are using 
new technology and emerging products to 
make our spaces more energy efficient, such 
as in the UK, where an additive to our boiler 
systems helped make heating in our branches 
13% more efficient. 

As part of our ambition to achieve 100% 
renewable power across our operations by 
2030, we continue to look for opportunities to 
procure green energy in each of our markets. 
A key challenge remains the limited 
opportunity to pursue power purchase 
agreements or green tariffs in key markets  
due to regulations. 

We are tracking the impact on our emissions 
from our colleagues working from home, as 
they continue to embrace more flexible ways 
of working. We calculated the electricity used 
by our colleagues working from home was 5% 
of our total electricity consumption in 2022. 
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
In 2022, our travel emissions remained below 
50% of pre-pandemic levels in 2019, with 
international travel restrictions remaining for 
much of the year in key Asia markets, slowing 
the return to business travel. We are closely 
managing the gradual resumption of travel 
through internal reporting and review of 
emissions, and through the introduction of 
internal carbon budgets, in line with our aim  
to halve travel emissions by 2030, compared 
with pre-pandemic levels. With hybrid working 
embedded across the organisation, the use  
of virtual working practices has reduced the 
need for our colleagues to travel to meet with 
other colleagues and customers. We continue 
to focus on reducing the environmental impact 
from the vehicles we use in our global 
markets, and accelerate the use of electric 
vehicles. In 2022, we reduced the company 
car fleet size by 24%. We are now aiming to 
ensure that all new vehicles ordered are fully 
electric or hybrid vehicles where possible.

Engaging with our supply chain 
Our supply chain is critical to achieving our net 
zero ambitions, and we are partnering with our 
suppliers on this 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 (formerly the Carbon Disclosure 
Project) supply chain programme. The target 
for 2022 was for suppliers representing 60%  
of total supplier spend to have completed  
the CDP questionnaire. In total, suppliers 
representing 63.5% of total supplier spend 
completed the CDP questionnaire. 

We will continue to engage with our supply 
chain through CDP, and through direct 
discussions with our suppliers on how they 
can further support our transition to net zero.

In 2022, we also formalised our supply  
chain sustainability strategy through the 
update of our supplier code of conduct  
and the development of our sustainable 
procurement procedures. The new procedures 
set out the minimum requirements and 
operational information required to help 
ensure our sustainability objectives relating to 
climate change, the environment, human 
rights, and diversity and inclusion are clearly 
addressed in the way that we operate and 
conduct business with suppliers.

Focus on natural resources
Alongside our net zero operations ambition, 
our aim is to be a responsible consumer  
of natural resources. Through design, 
construction and operational standards,  
we strive to ensure that, wherever possible,  
our premises do not adversely affect the 
environment or natural resources. We have 
identified specific focus areas including waste, 
paper and sustainable diets, and are exploring 
key opportunities to reduce our wider 
environmental impact over the coming decade. 

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.

62

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

Our approach to our own operations continued

Emissions from our energy and travel  
in 2022
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 2022, we continued to decrease our 
emissions from our energy consumption and 
travel, achieving a 58.5% 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 400 energy conservation measures that 
amounted to an estimated energy avoidance in 
excess of 11.9 million kWh and increased our 
consumption of renewable electricity to 48.3%.

In 2022, we collected data on energy use  
and business travel for our operations in 28 
countries and territories, which accounted for 
approximately 92.4% of our FTEs. To estimate 
the emissions of our operations in entities 
where we have operational control and a small 
presence, we scale up the emissions data from 
92.4% to 100%. We then apply emission uplift 
rates to reflect uncertainty concerning the 
quality and coverage of emission measurement 
and estimation. This is consistent with both 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. 

Energy and travel greenhouse gas 
emissions in tonnes CO2e

Scope 11

Scope 21

Scope 3 (category 6) 
business travel1

2022

2021

19,000

22,000

224,000

307,000

42,000

12,000

Total

285,000

341,000

Included energy UK 

9,000

10,000

Greenhouse gas emissions in tonnes 
CO2e per FTE

 For further details on our methodology and 
relevant environmental key facts, see the ESG 
Data Pack at www.hsbc.com/esg. 

Total

2022

1.30

2021

1.52

Energy consumption in kWh in 000s 

2022

2021

Total Group

797,000

833,000

UK only

222,000

227,000

1  Data in 2022 is subject to PwC’s limited assurance 
report in accordance with International Standard  
on Assurance engagements 3410 (Assurance 
Engagements on Greenhouse Gas Statements). For 
further details, see GHG Reporting Guideline 2022 
and third-party limited assurance report at www.
hsbc.com/our-approach/esg-information/
esg-reporting-and-policies. 

Emissions from our supply chain in 2022

Emissions (tonnes CO2e)

Data quality score1

Scope 3 categories

Year

Scope 1–2

Scope 3

Total

Scope 1–2

Scope 3

Category 1 – Purchased goods and services 2, 3

Category 2 – Capital goods 2, 3

2022

2021

2022

2021

218,000

648,000

866,000

252,000

617,000

869,000

30,000

114,000

144,000

31,000

96,000

127,000

3.1

3.0

3.1

3.1

3.3

3.3

3.4

3.3

The data we receive through our engagement 
with CDP has enabled us to report our supply 
chain emissions for the first time. Our 
methodology uses supplier emissions data 
where we have it from 500 of our largest 
suppliers, through CDP. Where we do not 
have emissions data for suppliers, we use 
industry average carbon intensities and spend 
data to define the contribution to our supply 
chain emissions. As more of our suppliers 
report their emissions, we should be able  
to include more accurate data and fewer 
industry averages in the calculation. We  

have applied a data quality score to the 
sources of data we used to determine 
counterparty emissions. Our initial supply 
chain emission figures may require updating 
as data availability changes over time and 
methodology and climate science evolve.  
For further details, see our GHG Reporting 
Guidance.

In 2022, emissions from our supply chain 
increased by 16% compared with 2019, as  
a result of an increase in spend – particularly in 
IT services – and a rise in the average carbon 

intensity of our suppliers. The CDP-provided 
industry averages rose, increasing the 
emissions for our suppliers where we do not 
have emissions data. However, in 2022 there 
was a decrease in carbon intensity of suppliers 
who disclose their emissions compared with 
2021, particularly in servers and data centres. 
While the carbon intensity of our supply chain 
decreased, a rise in spend on services in 2022 
led to a 1% increase in emissions compared 
with 2021.

1  Data quality scores where 1 is high and 5 is low, based on the quality of emissions data. This is a weighted average score based on HSBC supplier spend and is in line 

with HSBC’s financed emissions reporting methodology

2 Supply chain emissions calculated using a combination of supplier emissions data and industry averages.
3  Data in 2019, 2020, 2021 and 2022 for scope 3 (purchased goods and service) and scope 3 (capital goods) is subject to PwC’s limited assurance report in accordance 

with International Standard on Assurance engagements 3410 (Assurance Engagements on Greenhouse Gas Statements). For further details, see GHG Reporting 
Guideline 2022 and third-party limited assurance report at www.hsbc.com/our-approach/esg-information/esg-reporting-and-policies. 

HSBC Holdings plc Annual Report and Accounts 2022

63

ESG reviewESG review | Environmental 

Our approach to climate risk  TCFD

Managing risk for our stakeholders

Climate risk relates to the financial and 
non-financial impacts that may arise as a 
result of climate change and the move to  
a greener economy. We manage climate  
risk across all our businesses and are 
incorporating climate considerations within 
our traditional risk types in line with our 

Group-wide risk management framework. Our 
most material exposure to climate risk relates 
to corporate and retail client financing activity 
within our banking portfolio. We also have 
significant responsibilities in relation to asset 
ownership by our insurance business, 
employee pension plans and asset 

management business. In the table below, we 
set out our duties to our stakeholders in our 
four most material roles.

 For further details of our approach to climate risk, 
see ‘ESG risk’ on page 139 and ‘Climate risk’ on 
page 221.

Banking
We manage the climate risk in our 
banking portfolios through our risk 
appetite and policies for financial 
and non-financial risks. 

Employee pensions
Our pension plans manage climate 
risk in line with their fiduciary 
duties towards members and local 
regulatory requirements.

Asset management 
Climate risk management is a key 
feature of our investment decision 
making and portfolio management 
approach. 

Insurance
We consider climate risk in our 
portfolio of assets.

Climate risk

This helps enable us to identify 
opportunities to support our 
customers, while continuing to 
meet stakeholder expectations.

We monitor climate risk exposure 
internally for our largest plans 
based on asset sector allocation 
and carbon emissions data where 
available. 

We also engage with companies 
on topics related to climate 
change.

We have established an evolving 
ESG programme to meet changing 
external expectations and 
customer demands. 

Customers

Employees

Customers

Investors

Customers

Employees

Communities

Customers

Employees

Investors

Investors

Communities

Customers
Suppliers

Investors

Regulators and 
Employees
governments

Communities
Customers

Regulators and 
governments

Employees

Communities

Regulators and 
Suppliers
Employees
governments

Investors

Customers

Regulators and 
Suppliers
governments

Investors

Communities
Employees

Customers
Suppliers

Communities

Customers

Customers

Suppliers

Communities

Investors

Suppliers

Investors

Employees

Regulators and 
Investors
governments

Employees

Regulators and 
Employees
governments

Regulators and 
governments

Communities

Customers

Investors
Communities

Suppliers

Regulators and 
Employees
governments

Regulators and 
Communities
governments

Suppliers

Investors

Suppliers

Regulators and 
governments

Communities

Suppliers

Regulators and 

governments

Suppliers

Banking
Our banking business is well positioned  
to support our customers managing their  
own climate risk through financing. For our 
wholesale customers, we use our transition 
and physical risk questionnaire as part of our 
risk framework to understand their climate 
strategies and risk. We have set out a suite of 
policies to guide our management of climate 
risk, including our recently updated energy 
policy and thermal coal phase-out policy (see 
page 65). We continue to develop our climate 
risk appetite and utilise metrics to help 
manage climate exposures in our wholesale 
and retail portfolios. Climate scenario analysis 
is used as a risk assessment tool to provide 
insights on the long-term effects of transition 
and physical risks across our corporate and 
retail banking portfolios, as well as our own 
operations (for further details, see page 67). 

Asset management
HSBC Asset Management managed  
over $608bn assets at the end of 2022,  
of which more than $55bn were held in 
sustainable investments. The majority of  
the remaining assets were invested in 
ESG-integrated strategies.

When assessing the impact of climate-related 
risk to our portfolios, we are increasingly 
considering both physical and transition risks. 
As a result, we have integrated ESG and 
climate analysis to help ensure that risks faced 

by companies are considered throughout  
the investment decision-making process. 
Investment teams through portfolio 
management tools assess, examine and 
determine the level of potential ESG risks that 
could impact the current and future value  
of issuers.

One of our key approaches to manage climate 
risk is through engaging with the companies 
we invest in. Our HSBC Asset Management 
Stewardship Plan outlines our approach to 
engaging with issuers, including on the topic 
of climate change. 

Employee pensions 
The Trustee of the HSBC Bank (UK) Pension 
Scheme, our largest plan with $33bn assets 
under management, aims to achieve net zero 
greenhouse gas emissions across its defined 
benefit and defined contribution assets by 
2050. To help achieve this, it is targeting an 
interim emissions reduction of 50% by 2030, 
from 2019 levels, for its equity and corporate 
bond mandates. This commitment was made 
in the context of wider efforts to manage the 
impact of climate change on the Scheme’s 
investments and the consequent impact on 
the financial interests of members.

During 2022, a framework was put in place to 
assess progress towards the 2030 targets. The 
Scheme, which has reported emission 
reductions for the equity and corporate bond 

mandates between 2019 and 2021, will 
continue to report against the 2030 targets, 
and aim to widen the coverage of its 
assessment and reporting over time. 

 For further details of the HSBC Bank (UK) 
Pension Scheme’s annual TCFD statements and 
climate action plan, see https://futurefocus.staff.
hsbc.co.uk/active-dc/information-centre/
other-information.

Insurance 
In 2022, our Insurance business, which has life 
insurance manufacturing subsidiaries in eight 
markets and total assets under management 
of approximately $126bn, updated its 
sustainability policy to align with the Group’s 
new thermal coal phase-out policy. An ESG 
policy on corporate underwriting was also 
introduced.

Risk appetite was reviewed relating to key ESG 
aspects. ESG standards were embedded into 
insurance product development processes 
and operational capabilities.

In response to multiple and differing ESG 
regulatory initiatives and developments, HSBC’s 
insurance entities in the EU have implemented 
key disclosure-related regulatory requirements. 
These requirements mainly impact insurance-
based investment products manufactured by 
HSBC entities in the EU. Related requirements 
for the UK and other jurisdictions are expected 
to be introduced in the near future.

64

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

Our approach to sustainability policies  TCFD

We recognise that businesses can have an 
impact on the environment, individuals and 
communities around them. We continue to 
develop, implement and refine 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 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. We also apply the 
Equator Principles when financing projects.

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 are 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, we updated our thermal coal 
phase-out policy, which we explain further  
on the following page, as well as our energy 
policy, which we set out below.

Governance and implementation
HSBC’s relationship managers are the primary 
point of contact for our customers and are 
responsible for checking whether our 
customers meet applicable policies. Within 
our Group 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 is 
supported by regional reputational risk 
managers across the Group who have 
additional oversight responsibilities for 
sustainability risk.

The Wholesale Reputational and Sustainability 
Risk team also became part of Risk Strategy, 
with expanded Group-wide responsibilities, to 
strengthen the governance and oversight of 
sustainability risk policies, and to reflect the 
evolution of the sustainability agenda.

The Sustainability Risk Oversight Forum, made 
up of senior members of the Group Risk and 
Compliance function and global businesses, 
continued to oversee the development and 
implementation of policies that seek to 
identify, manage and mitigate the Group’s 
sustainability risk. 

As part of our oversight of sustainability risk 
policies, we operate an assurance framework 
that is designed to take a more holistic view of 
risks, including by:

 – ESG news screening, taking a risk-based 
approach, across the sustainability risk 
policies;

 – overseeing clients considered to be of 

higher risk;

 – reviewing client files across the 
sustainability risk policies; and

 – monitoring of the sustainability risk client 

portfolio against a defined set of key control 
indicators overseen by the Sustainability 
Risk Oversight Forum.

The framework is used to monitor the  
in-scope portfolio and keep track if there  
is a deterioration in the risk ratings. With  
the respective risk rating assigned, our 
sustainability risk specialists will agree  
the necessary actions to help mitigate 
unacceptable risks with the business.

Where considered appropriate, a submission 
can be made to the Reputational Risk and 
Client Selection Committee to agree an 
appropriate course of action. 

Our energy policy 

In December 2022, we published our 
updated policy covering the broader energy 
system, including upstream oil and gas,  
oil and gas power generation, hydrogen, 
renewables and hydropower, nuclear, 
biomass and energy from waste. The  
policy seeks to balance three related 
objectives: supporting the reduction of 
global greenhouse gas emissions; enabling 
an orderly transition that builds resilience in 
the longer term; and supporting a just and 
affordable transition. Central to our approach 
is our commitment to supporting clients who 
are taking an active role in the transition.

In line with the policy, we will no longer 
provide new finance or advisory services for 

the specific purpose of projects pertaining  
to new oil and gas fields and related 
infrastructure whose primary use is in 
conjunction with new fields. Engagement on 
transition plans is a key part of our approach. 
We will continue to provide finance or 
advisory services to energy sector clients at 
the corporate level, where clients’ transition 
plans are consistent with our 2030 portfolio-
level financed emissions targets and net zero 
by 2050 commitment. If a client’s transition 
plan is not produced, or if, after repeated 
engagement, is not consistent with our 
targets and commitments, we will not 
provide new finance and may withdraw 
existing financing. 

The IEA’s 2021 Net Zero by 2050 report 
highlights that an orderly transition requires 
continued financing and investment in 
existing oil and gas fields to maintain the 
necessary output. We will therefore continue 
to provide finance to maintain supplies of  
oil and gas in line with current and future 
declining global oil and gas demand, while 
accelerating our activities to support clean 
energy deployment. 

As part of our previously announced ambition 
to provide $750bn to $1tn in sustainable 
finance and investment by 2030 to support 
our customers in all sectors, we will support 
critical areas such as renewable energy and 
clean infrastructure. 

HSBC Holdings plc Annual Report and Accounts 2022

65

ESG reviewESG review | Environmental 

Our approach to sustainability policies continued

Our thermal coal phase-out policy
In December 2021, we published a policy to 
phase out thermal coal financing in EU and 
OECD markets by 2030, and globally by 2040. 
This incorporated project finance, direct 
lending, and arranging or underwriting of 
capital markets transactions to in-scope 
clients, as well as the refinancing of existing 
finance facilities.

In line with our commitment to review our 
policy and targets each year, taking into 
account evolving science and internationally 
recognised guidance, we expanded the policy 
in 2022. We committed to not provide new 
finance or advisory services for the specific 
purposes of the conversion of existing 
coal-to-gas-fired power plants, unless  
the client demonstrates to us its intention  
to transition to abated power generation, 
consistent with our targets and commitments; 
and the plants do not operate in 
environmentally or socially critical areas. We 
also committed to not provide new finance or 
advisory services for new metallurgical coal 
mines. With the updated policy, we 
additionally committed to: 

 – reduce absolute on-balance sheet finance 
emissions by 70% in both the thermal coal 
power and thermal coal mining sectors  
by 2030; 

 – apply an amended definition of thermal  
coal expansion as it pertains to mergers  
and acquisitions activity; and 

 – decline new relationships with companies 

that operate thermal coal assets in 
environmentally and socially critical areas.

Biodiversity and natural capital-related 
policies 
Our sustainability risk policies restrict 
financing activities that have material  
negative impacts on nature. While a number 
of our sectoral policies have such restrictions, 
our forestry and agricultural commodities 
policies focus specifically on a key impact: 
deforestation. These policies require 
customers involved with major deforestation-
risk commodities to operate in accordance 
with sustainable business principles, as well  
as require palm oil customers to obtain 
certification and commit to ‘No Deforestation, 
No Peat and No Exploitation’ (see ‘Our respect 
for human rights’ on page 87). While we seek 
to work with our clients to help ensure their 
alignment with our policies, we have 
withdrawn banking services to customers 
who have not engaged, for example, in 
meeting our certification requirements. 

As part of our net zero commitment, we  
are reviewing our current policy protections in 
this area, and aim to release a revised policy, 
informed by scientific and international 
guidance, in 2023. 

 For further details of our approach to biodiversity 
and natural capital-related activities, see 
‘Biodiversity and natural capital strategy’  
on page 61. 

Exposure to thermal coal 
In our thermal coal policy published in 
December 2021, we disclosed our intention to 
reduce thermal coal financing exposure by at 
least 25% by 2025, and by 50% by 2030, using 
our 2020 Task Force on Climate-related 
Financial Disclosures (‘TCFD’) as our baseline. 
Using the same methodology and data used  

in our baseline reporting as at 31 December 
2020, we are making progress against  
these targets. 

Our 2020 baseline comprised thermal coal 
power generation and mining exposures 
within the power and utilities, and metals  
and mining sectors, as defined in our TCFD 
disclosures. We are in the process of expanding 
the on-balance sheet exposures that are 
in-scope for our thermal coal policy to include 
those outside of these two TCFD sectors.

Our processes, systems, controls and 
governance are not yet designed to fully 
identify and disclose thermal coal exposures, 
particularly for exposures within broader 
conglomerates. Until our systems, processes, 
controls and governance are enhanced, 
certain aspects of our reporting will rely on 
manual sourcing and categorisation of data. 
We are reassessing the reliability of our data 
and reviewing our basis of preparation to help 
ensure that we are reporting all relevant 
thermal coal exposures aligned to our thermal 
coal policy. As a result, we have not reported 
thermal coal exposures in this Annual Report 
and Accounts 2022. We expect that our 
updated thermal coal exposures dating back 
to 31 December 2020 will be made available 
for reporting as soon as practicable in 2023, 
although this is dependent on availability and 
quality of data.

Thermal coal financed emissions targets
As mentioned earlier, our financed emissions 
target is a reduction of 70% in both the 
thermal coal power and thermal coal mining 
sectors by 2030, using a 2020 baseline. We 
now intend to publish our baseline financed 
emissions alongside our updated thermal coal 
exposures as mentioned above.

Asset management policy

In September 2022, our asset management 
business, HSBC Asset Management, 
published its own policy on how a phase-out 
of thermal coal would impact on investments 
it makes on behalf of clients. 

The policy aligns with the commitment made 
by HSBC Asset Management under the Net 
Zero Asset Managers initiative to support 
investing aligned with net zero greenhouse 
gas emissions by 2050, or sooner. 

Under its policy, HSBC Asset Management 
will not hold listed securities of issuers with 
more than de minimis revenue exposure  
to thermal coal in its actively managed 

portfolios beyond 2030 for EU and OECD 
markets, and 2040 for all other markets.  
The policy includes some restrictions on 
investment exposure to thermal coal ahead 
of these deadlines, as well as commitments 
to undertake enhanced due diligence on the 
transition plans of investee companies with 
thermal coal exposure. Companies held in 
investment portfolios that do not develop 
credible plans to transition away from 
thermal coal could face voting sanctions, 
and ultimately a divestment of holdings.

 For further details of the policy, see www.
assetmanagement.hsbc.co.uk/-/media/files/
attachments/common/coal-policy-b2b-
en-09162022.pdf.

66

HSBC Holdings plc Annual Report and Accounts 2022

Environmental 

Insights from scenario analysis  TCFD

Scenario analysis supports our strategy by 
assessing our position under a range of climate 
scenarios. It helps to build our awareness of 
climate change, plan for the future and meet 
our growing regulatory requirements. 

Having run our first Group-wide climate 
change scenario analysis exercise in 2021, we 
produced several climate stress tests for global 
regulators in 2022, including the Monetary 
Authority of Singapore and the European 
Central Bank. We also conducted our first 
internal climate scenario analysis.

We continue to develop how we produce  
our climate scenario analysis exercises so  
that we can have a more comprehensive 
understanding of climate headwinds, risks 
and opportunities that will support our 
strategic planning and actions.

In climate scenario analysis, we consider, 
jointly:

 – transition risk arising from the process of 
moving to a net zero economy, including 
changes in policy, technology, consumer 
behaviour and stakeholder perception, which 
could 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 could each 
impact property values, repair costs and lead 
to business interruptions. 

We also analyse how these climate risks 
impact how we manage other risks within our 
organisation, including credit and market risks, 
and on an exploratory basis, operational, 
liquidity, insurance, and pension risks. 

Our climate scenarios
In our 2022 internal climate scenario analysis 
exercise, we used four scenarios that were 
designed to articulate our view of the range of 
potential outcomes for global climate change.

These scenarios, which reflect different levels  
of physical and transition risk and are varied  
by severity and probability, were: the Net Zero 
scenario, which aligns with our net zero strategy 
and is consistent with the Paris Agreement; the 
Current Commitments scenario, which assumes 
that climate action is limited to the current 
governmental commitments and pledges; the 
Downside Transition Risk scenario, which 
assumes that climate action is delayed until 
2030; and the Downside Physical Risk scenario, 
which assumes climate action is limited to 
current governmental policies. 

 For further details of these scenarios, and how 
they were designed to identify, measure and 
assess our material climate vulnerabilities, see 
‘Insights from scenario analysis’ in the ‘Climate 
risk’ section on page 226.

Analysing the outputs
Climate scenario analysis allows us to model 
how different potential climate pathways may 
affect our customers and portfolios, particularly 
in respect of credit losses. As the chart below 
shows, losses are influenced by their exposure 
to a variety of climate risks under different 
climate scenarios. 

Under the Current Commitments scenario, we 
expect moderate levels of losses relating to 
transition risks. However, the rise in global 
warming will lead to increasing levels of 
physical risk losses in later years. A gradual 
transition towards net zero, as shown in the 
Net Zero scenario, still requires fundamental 
shifts in our customers’ business models, and 

significant investments. This will have an 
impact on profitability, leading to higher  
credit risk in the transition period. A delayed 
transition will be even more disruptive due to 
lower levels of innovation that limits the ability 
to decarbonise effectively, and rising carbon 
prices that squeeze profit margins. 

Overall, our scenario analysis shows that the 
level of credit losses can be mitigated if we 
support our customers in enhancing their 
climate transition plans.

 For the full internal climate scenario analysis, 
including our assessment of the impacts of climate 
change on our corporate lending, retail mortgage 
and commercial real estate portfolios, see Insights 
from scenario analysis on page 226. 

Modelled climate losses 
How credit losses from climate risks have been modelled under different scenarios.1

)
n
b
$
(

s
t
n
e
m

r
i
a
p
m

i
e
v
i
t
a
l
u
m
u
C

<1.5x

>1.5x

2021

2025

2030

2035

2040

2045

2050

Net Zero
Current Commitments

Downside Transition Risk
Counterfactual1 

Net Zero2 
Downside Transition Risk2 

1  The counterfactual scenario is modelled on a scenario where there will be no losses due to climate change.
2  The dotted lines in the chart show the impact of modelled expected credit losses following our strategic 

responses to reduce the effect of climate risks under the Net Zero and Downside Transition Risk scenarios.

Use of climate scenario outputs
We are starting to consider climate scenario 
analysis in core decision-making processes, 
including strategic and financial planning, risk 
management, capital assessment, business 
decision making, client engagement, and 
Group reporting. It helps to inform our strategy 
and supports how we capture opportunities 
while minimising risks, and enabling HSBC  
to navigate through the climate transition. 

We use the analysis to anticipate climate-
related impacts for our customers by 
identifying new opportunities where possible, 
including targeted financing to support their 
transition journey.

We have considered climate risk in our annual 
financial planning cycle. In order to do this, we 
reviewed the inclusion of ECL outcomes from 
our internal climate scenario analysis using the 
Current Commitments scenario because we 
deem it the most likely to transpire over the 
planning horizon. 

Next steps
We plan to continue to enhance our 
capabilities for climate scenario analysis  
and use the results for decision making, 
particularly in respect of:

 – our risk appetite, by identifying business-

critical metrics and using scenario analysis 
to test, calibrate, and monitor against 
thresholds;

 – client engagement, by identifying the 

climate opportunities – such as supporting 
the growth of renewables, biomass, electric 
vehicles – and vulnerabilities by engaging 
with and supporting our customers; and

 – strategy, by using the range of scenario 
analysis outcomes to shape our strategy 
across business and regions.

HSBC Holdings plc Annual Report and Accounts 2022

67

ESG review 
 
ESG review | Environmental 

Our approach to climate reporting  TCFD

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.

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, save for certain items, which we summarise below and 
in the additional information section on page 423. 

Recommendation

Governance

Response

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

Process, frequency and training 

 – The Board takes overall responsibility for ESG strategy, overseeing executive management in 

Sub-committee accountability, processes 
and frequency 

Examples of the Board and relevant Board 
committees taking climate into account

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. It considered ESG 
at seven meetings during the year.

 – Board members receive ESG-related training as part of their induction and ongoing development, 

and seek out further opportunities to build their skills and experience in this area.

 – The Group Risk Committee (‘GRC’) maintains oversight of delivery plans to ensure that the  

Group develops robust climate risk management capabilities. The GRC also has oversight over 
ESG-related initiatives and reviews these to assess the risk profile. It considered ESG risk at four 
meetings in 2022. 

 – The Group Audit Committee (‘GAC’) reviews and challenges ESG and climate-related reporting, 
processes, systems and controls and considered these matters in detail at five meetings during 
the year. The GAC, supported by the executive-level ESG Committee and Group Disclosure and 
Controls Committee, provided close oversight of the disclosure risks in relation to ESG and 
climate reporting, amid rising stakeholder expectations.

 – The Board considered whether to establish a Board committee dedicated to ESG issues, but 

instead decided that the best way to support the oversight and delivery of the Group’s climate 
ambition and ESG strategy was to retain governance at Board level.

 – In 2022, the Board oversaw the implementation of ESG strategy through regular dashboard 

reports and detailed updates including: reviews of net zero policies, financed emissions target 
setting and climate-aligned financing initiatives.

 – The Group Chairman and the Group Chief Executive met regularly with government officials 

globally to continue to foster strong international relations. In addition, certain Board members 
also continued to be actively involved in climate initiatives and attend global events such as the 
Group Chief Executive’s attendance at the COP27 Summit in Egypt.

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

Who manages climate-related risks and 
opportunities

How management reports to the Board

 – The Group Executive Committee enhanced its governance model of ESG matters with the  
ESG Committee and supporting forums. These support senior management in the delivery  
of the Group’s ESG strategy, key policies and material commitments by providing oversight  
over – and management and coordination of – ESG commitments and activities. 

 – The Group Company Secretary and Chief Governance Officer, and Group Chief Sustainability 
Officer hold joint responsibility for the ESG Committee. It oversees all areas of environmental, 
social and governance issues, with support from accountable senior management in relation  
to their particular areas of responsibilities. Key representatives from the functions and global 
businesses attend to provide insights on the implementation of the ESG strategy across the 
Group, allowing the ESG Committee to make recommendations to the Board in respect of  
ESG matters.

 – 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.

 – 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. 

 – Key representatives from the functions and global businesses attend the ESG Committee  
to provide insights on the implementation of the ESG strategy across the Group, allowing  
the ESG Committee to make recommendations to the Board in respect of ESG matters.

Disclosure 
location

 Page 86 
and 256

 Page 86 
and 252 

 Page 272 
and 275

 Page 263 
and 268

 Page 255 
and 256

Page 255

Page 20

 Page 86 
and 255

 Page 86 
and 251 

Page 86

 Page 248 
and 249

Page 251

68

HSBC Holdings plc Annual Report and Accounts 2022

 
 
Environmental 

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

Recommendation

Response

Processes used to inform management

 – The ESG 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. We also recognise that we require enhanced capabilities and 
new sources of data.

 – The Climate Risk Oversight Forum oversees all global risk activities relating to climate risk 

management, including physical and transition risks. Equivalent forums have been established  
at regional level.

 – The Sustainability Target Operating Model Steering Committee oversees the implementation  
of the Group’s organisational plan for the internal infrastructure, both within the Sustainability 
function and the wider Group, to help deliver our climate ambitions.

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 

Risks and opportunities by sector and/or 
geography

 – 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. Given the 
challenges on data sourcing and processes, there has been an impact on certain climate disclosures. 

 – Climate scenario analysis was used as a risk assessment tool to provide insights on the long-term 
effects of transition and physical risks across our corporate and retail banking portfolios, as well as 
our own operations.

 – 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. 

 – 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.

 – We have taken these time horizons into our consideration. Our assessment of climate risks 
covers three distinct time periods: short term is up to 2025, medium term is 2026 to 2035;  
and long term is 2036 to 2050.

 – We enhanced our transition and physical risk questionnaire and scoring tool, which helps us to assess 

and improve our understanding of the impact of transition and physical risk on our customers’ 
business models, and used it for our corporate clients in high climate transition risk sectors.

 – 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.

 – In the UK, in line with our retail portfolio, the main perils that drive potential credit losses relate to 

coastal, river and surface water flooding, although the impacts from these perils are not expected  
to cause significant damages. Around 20% of our financed properties are in London, and most are 
protected by the Thames Barrier. 

 – We identified six key sectors where our wholesale credit customers have the highest exposure  
to climate transition risk, based on their carbon emissions. These are automotive, chemicals, 
construction and building materials, metals and mining, oil and gas, and power and utilities.

 – We continued to improve our identification and assessment of climate risk within our retail 

mortgage portfolio, with increased investments in physical risk data and enhancements to our 
internal risk assessment capabilities and models. We completed detailed analysis for the UK,  
Hong Kong, Singapore and Australia, which together represent 73.8% of balances of the global 
mortgage portfolio. 

Disclosure 
location

 Page 86 
and 251

 Page 222

 Page 86

 Page 38 
and 47 

Page 64

Page 58

Page 49 

Page 57 

Page 139

Page 222 

Page 58

Page 229

Page 223 

Page 224

Concentrations of credit exposure to 
carbon-related assets (supplemental 
guidance for banks)

Climate-related risks (transition and 
physical) in lending and other financial 
intermediary business activities 
(supplemental guidance for banks)

 – Opportunities include sustainable finance, sustainable investment and sustainable infrastructure. For 

Page 58

a detailed breakdown of our sustainable finance progress by geography, see the ESG Data Pack.

 – We report our exposure to the six high transition risk sectors in the wholesale portfolio. For 

details, see the ESG Data Pack.

 – Since 2020, we have rolled out the questionnaire so that it included our largest customers in the 

next highest climate transition risk sectors: agriculture, industrials, real estate, and transportation. 
This was done across a larger geographical scope. 

 – As a result of our climate scenario analysis, our largest and most impacted sectors – power and 
utilities, construction and building materials, and chemicals – are subject to increased levels of 
transition risks due to their ongoing exposure to higher carbon-emitting activities.   

 – HSBC Asset Management is increasingly considering both physical and transition risks. As a result, 
it integrated ESG and climate analysis to help ensure that risks faced by companies are considered 
throughout the investment decision-making process. 

Page 223 

Page 227

Page 64 

HSBC Holdings plc Annual Report and Accounts 2022

69

ESG review 
 
 
 
 
 
 
ESG review | Environmental 

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

Recommendation

Response

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.

 – Scenario analysis supports our strategy by assessing our position under a range of climate scenarios.  
It helps to build our awareness of climate change, plan for the future and meet our growing regulatory 
requirements. We acknowledge that our systems, processes, controls and governance are developing.

 – We continue to develop how we produce our climate scenario analysis exercises so that we can have a 
more comprehensive understanding of climate headwinds, risks and opportunities that will support our 
strategic planning and actions. 

Disclosure 
location

Page 49

 Page 48 
and 67

Page 67

 – We do not currently fully disclose the impacts of climate-related issues on financial planning, and 

Page 423

particularly the impact of climate-related issues on our financial performance and financial position.  
In addition, we have considered the impact of climate-related issues on our businesses, strategy,  
and financial planning, but not specifically in relation to acquisitions/divestments. Due to transitional 
challenges such as process limitations, we do not disclose the climate-related impact in these areas.  
We expect to further enhance our disclosure and processes in relation to acquisitions/divestments in  
the medium term.

 – We have considered the impact of climate-related issues on our businesses, strategy, and financial 

planning. Our access to capital may be impacted by reputational concerns as a result of climate action 
or inaction. In addition, if we are perceived to mislead stakeholders on our business activities or if we  
fail to achieve our stated net zero ambitions, we could face greenwashing risk resulting in significant 
reputational damage, impacting our revenue generating ability and potentially our 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

 – We will continue to engage with our supply chain through CDP, and through direct discussions 

Impact on adaptation and mitigation 
activities

with our suppliers on how they can further support our transition to net zero. 

 – We also have significant responsibilities in relation to asset ownership by our insurance business, 

employee pension plans and asset management business. 

 – In October 2020, we announced our ambition to reduce our energy consumption by 50% by 

2030, against a 2019 baseline. As part of our ambition to achieve 100% renewable power across 
our operations by 2030, we continue to look for opportunities to procure green energy in each of 
our markets. A key challenge remains the limited opportunity to pursue power purchase 
agreements or green tariffs in key markets due to regulations. 

Impact on operations 

 – Climate change poses a physical risk to the buildings that we occupy as an organisation, 

Impact on investment in research and 
development

including our offices, retail branches and data centres.

 – We use stress testing to evaluate the potential for impact to our owned or leased premises. Our 
scenario stress test, conducted in 2022, 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 500 of our 
critical and important buildings.

 – Our Climate Solutions Partnership is a five-year $100m philanthropic initiative that aims to 
identify and remove barriers to scale for climate change solutions. Working with the World 
Resources Institute, WWF and over 50 local partners, our support focuses on start-up 
companies developing carbon-cutting technologies, nature-based solutions, renewable energy 
initiatives in Asia and the WWF-led Asia Sustainable Palm Oil Links programme. 

How we are striving to meet investor 
expectations

 – During Board meetings, the Directors continued to balance discussions on the Group’s 
performance, emerging risks and duties to shareholders, while remaining conscious of 
responsibilities to support communities and help customers.

Transition plan to a low-carbon economy

 – In 2022, the Board approved an update to the thermal coal phase-out policy. It also approved the 

publication of an updated energy policy.

 – We have committed to publish our own climate transition plan in 2023. This plan will outline, in 
one place, not only our commitments, targets and approach to net zero across the sectors and 
markets we serve, but how we are transforming our organisation to embed net zero and finance 
the transition.

Page 423

Page 58

Page 62

Page 64

Page 62

Page 229

Page 84

Page 20

Page 23

Page 49

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

 – Scenario analysis supports our strategy by assessing our position under a range of climate 

scenarios. It helps to build our awareness of climate change, plan for the future and meet our 
growing regulatory requirements. 

 – In 2022, we delivered our first internal climate scenario analysis exercise where we used four 

scenarios that were designed to articulate our view of the range of potential outcomes for global 
climate change. The analysis considered the key regions in which we operate, and assessed the 
impact on our balance sheet between the 2022 and 2050 time period.

 Page 67 
and 226

Key drivers of performance and how these 
have been taken into account

 – Climate scenario analysis allows us to model how different potential climate pathways may  

affect our customers and portfolios, particularly in respect of credit losses. Under the Current 
Commitments scenario, we expect moderate levels of losses relating to transition risks. However, 
the rise in global warming will lead to increasing levels of physical risk losses in later years. 

 Page 67 
and 226

70

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
Environmental 

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

Recommendation

Response

Scenarios used and how they factored in 
government policies

 – The scenario assumptions used for our climate stress testing exercise include varying levels of 

governmental climate policy changes, macroeconomic factors and technological developments. 
However, these scenarios rely on the development of technologies that are still unproven, such 
as global hydrogen production to decarbonise aviation and shipping. For details of the 
assumptions, see the ESG Data Pack.

Disclosure 
location

Page 226

How our strategies may change and adapt 

 – The nature of the scenarios, our developing capabilities, and limitations of the analysis lead  
to outcomes that are indicative of climate change headwinds, although 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.

 – We plan to continue to enhance our capabilities for climate scenario analysis and use the results 
for decision making, particularly in respect of strategy, by using the range of scenario analysis 
outcomes to shape our strategy across business and regions.

 Page 67 
and 226 

Page 226 

Page 67

 – 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. 

Page 423

Risk management

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

Traditional banking risk types considered

Process

 – Our initial approach to managing climate risk was focused on understanding physical and 
transition impacts across five priority risk types: wholesale credit risk, retail credit risk, 
reputational risk, resilience risk and regulatory compliance risk.

 – We have integrated climate risk into our existing risk taxonomy, and incorporated it within the  
risk management framework through the policies and controls for the existing risks where 
appropriate. We also recognise that we require enhanced capabilities and new sources of data. 

 – We consider greenwashing to be an important emerging risk that is likely to increase over time, 
as we look to develop capabilities and products to achieve our net zero commitments, and work 
with our clients to help them transition to a low-carbon economy. We also recognise that green 
finance taxonomies are not consistent globally, and evolving taxonomies and practices could 
result in revisions in our sustainable finance reporting going forward.

 – We also use stress testing and scenario analysis to assess how these climate risks will impact our 

customers, business and infrastructure.

Integration into policies and procedures

 – In 2022, we incorporated climate considerations into our UK mortgage origination process for 

our retail mortgage business and new money request process for our key wholesale businesses. 
We also continued to enhance our climate risk scoring tool, which will enable us to assess our 
customers’ exposures to climate risk. We also published our updated energy policy, covering the 
oil and gas, power and utilities, hydrogen, renewables, nuclear and biomass sectors, as well as 
updated our thermal coal phase-out policy after its initial publication in 2021. 

 – We are integrating climate risk into the policies, processes and controls across many areas of our 
organisation, and we will continue to update these as our climate risk management capabilities 
mature over time.

 – In 2022, we expanded our scope to consider climate risk impacts on our other risk types 

(including treasury risk and traded risk) in our risk taxonomy. 

 – We also analysed in our internal scenario analysis exercise how climate risks impact how we 
manage other risks within our organisation, including credit risk, and on an exploratory basis: 
market, operational, liquidity, insurance, and pension risks. 

Consider climate-related risks in traditional 
banking industry risk categories 
(supplementary guidance for banks)

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

Process and how we make decisions 

 – The Group Risk Management Meeting and the Group Risk Committee receive regular updates on our 

climate risk profile, top and emerging climate risks, and progress of our climate risk programme.

 – Our climate risk appetite supports the oversight and management of the financial and non-financial 
risks from climate change, and supports the business to deliver our climate ambition in a safe and 
sustainable way. We recognise that we require enhanced systems, processes, controls, governance 
and new sources of data.

 Page 221

 Page 47 
and 221

 Page 47 
and 221

Page 46

Page 223

Page 223

 Page 221 
and 226

Page 67

Page 222 

 Page 47 
and 223

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 

 – Our climate risk approach 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. 

How we take into account interconnections 
between entities and functions

 – In February 2022, we refreshed a high-level assessment of how climate risk may impact risk 

types within the HSBC taxonomy over a 12-month horizon, and how the level of risk may increase 
over longer time horizons. 

 – We developed our first internal climate scenario exercise, where we used four bespoke scenarios that 
were designed to articulate our view of the range of potential outcomes for global climate change.

 – Through our dedicated climate risk programme, we continued to embed climate considerations 
throughout the organisation, including updating the scope of our programme to cover all risk 
types, expanding the scope of climate-related training, developing new climate risk metrics to 
monitor and manage exposures, and the development of our internal climate scenario exercise.

 – We updated our climate risk management approach to cover all risk types in our risk taxonomy.

 – We expanded the scope of climate-related training for employees to cover additional topics, such 

as greenwashing risk, and increased the availability of training to the broader workforce.

Page 221

Page 222

Page 222

Page 135

Page 222

Page 222

HSBC Holdings plc Annual Report and Accounts 2022

71

ESG review 
 
 
 
 
ESG review | Environmental 

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

Recommendation

Metrics and targets

Response

Disclosure 
location

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

Board or senior management incentives

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

are automotive, chemicals, construction and building materials, metals and mining, oil and gas, and 
power and utilities. The wholesale loan exposure is used as a metric to assess impact of climate risk 
and help inform risk management, together with our transition risk questionnaire results. 

 – We continue to measure climate risk in our most material mortgage market, which is the UK, 
where the primary physical risk facing properties is flooding. We also continue to identify the 
current and potential EPC ratings for individual properties within the UK mortgage portfolio.  
For further details, see our ESG Data Pack. 

 – 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 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. The breakdown 
of our sustainable finance and investment progress is included in our ESG Data Pack.

 – We do not currently fully disclose the proportion of revenue or proportion of assets, capital 

deployment or other business activities aligned with climate-related opportunities, including revenue 
from products and services designed for a low-carbon economy, forward-looking metrics consistent 
with our business or strategic planning time horizons. In addition, we do not currently disclose internal 
carbon prices due to transitional challenges such as data challenges. We recognise that we require 
enhanced systems, processes, controls, governance and new sources of data.

 – To help us achieve our ESG ambitions, a number of measures are included in the annual incentive 
and long-term incentive scorecards of the Group Chief Executive, Group Chief Financial Officer 
and Group Executives.

Metrics used to assess the impact of 
climate risk on lending and financial 
intermediary business (supplemental 
guidance for banks) 

 – As part of our internal climate scenario analysis, we carried out a detailed physical risk assessment of 
four of our most material retail mortgage markets – the UK, Hong Kong, Singapore and Australia – 
which represent 73.8% of balances in our retail mortgage portfolio. In 2022, we disclose our loan 
maturity within the UK mortgage portfolio.

 – 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).

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

Our own operations

 – We reported our scope 1, 2 and part of scope 3 greenhouse gas emissions resulting from the 

energy used in our buildings and employees’ business travel. In 2022, we started to disclose our 
scope 3 supply chain emissions. 

Greenhouse gas emissions for lending and 
financial intermediary business 
(supplemental guidance for banks)

 – We expanded our coverage of sectors for on-balance sheet financed emissions. We also set out 
the data and methodology limitations related to the calculation of scope 3 financed emissions.

 – In 2022, HSBC Asset Management started to measure scope 1 and 2 emissions of companies  

in its portfolio.

 – Future disclosure on financed emissions, and related risks is reliant on our customers publicly 
disclosing their carbon emissions and related risks. We aim to disclose financed emissions for 
additional sectors in our Annual Report and Accounts 2023 and related disclosures.

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 
interim 2030 targets for on-balance sheet financed emissions for eight sectors. 

 – For financed emissions we do not plan to set 2025 targets. We set targets in line with the Net-Zero 
Banking Alliance (‘NZBA‘) guidelines by setting 2030 targets. In 2022, we disclose interim 2030 
targets for on-balance sheet financed emissions for eight sectors. 

 – We do not currently disclose targets used to measure and manage physical risk, or internal carbon 

price targets. This is due to transitional challenges and data limitations. But we considered 
physical risk and carbon prices as an input in the climate scenario analysis exercise. We expect to 
further enhance the disclosure in the medium term as more data becomes available. In addition, 
we do not currently disclose a target for capital deployment. In 2022, we are internally reviewing 
and enhancing the green bond framework, with further refinement to be undertaken in 2023. Our 
continued monitoring of evolving taxonomies and practices over time could result in revisions in 
our reporting going forward and lead to differences year-on-year as compared with prior years. 
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. 

Page 223 

Page 224 

Page 423

 Page 18 
and 57

 Page 47 
and 423

 Page 16 
and 286

Page 224

Page 423

 Page 18 
and 63 

 Page 18 
and 50

Page 56

Page 423

Page 18 

Page 423

Other key performance indicators used

 – We also use other indicators to assess our progress including energy consumption and 

percentage of renewable electricity sourced.

Page 62

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Social 

Social
Building inclusion and resilience

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, colleagues  
and the communities in which we operate.

Inclusion is key to opening up a world of 
opportunity. It involves a commitment to 
remove unnecessary barriers to our people, 
our customers and our communities in 
realising their potential. Creating an inclusive 
environment for our colleagues enables them 
to flourish, and supports the strong and 
purposeful delivery of our strategy. 

We are committed to ensuring our colleagues 
– and particularly our leadership – are 
representative of the communities that we 
serve, and that we support their well-being 
and development so they can learn and grow 
in their careers. We do this because we know 
that when we build an inclusive, healthy and 
stimulating workplace for our people, the 
whole Group succeeds.

We are equally committed to ensuring there 
are no unnecessary barriers to finance for our 
customers. Customers should not find it more 
difficult to access finance because of their 
gender, their sexual orientation, their 
neurodiversity or their disability. We have an 
ambition to create a welcoming, inclusive and 
accessible banking experience that opens up  
a world of opportunity for our customers.

Building inclusion and resilience can also 
mean working to address gaps where we 
think we can make a difference. From working 
for fair pay and representation for our 
colleagues, to opening up access to finance  
to underserved customer groups, to ensuring 
HSBC branches and offices are safe spaces  
for everyone, we are committed to fairness 
and inclusivity. 

Inclusion goes hand-in-hand with resilience. 
We build resilience for our colleagues by 
supporting their physical, mental and financial 
well-being, and by ensuring they are equipped 
with the skills and knowledge to further their 
careers during a period of significant 
economic transformation. 

For our customers, we build resilience through 
education: by helping them to understand their 
finances and how to manage them effectively, 
and by creating propositions that simplify the 
banking experience while helping wealth  
to grow. We also build resilience through 
products and services that protect what our 
customers value – their health, their families, 
their homes and their belongings.

Finally, we aim to give back by engaging with 
our communities through philanthropic giving, 
disaster relief and volunteering. We are 
focusing these efforts on our priorities: the just 
transition to net zero and building inclusion 
and resilience.

We believe building inclusion and resilience 
helps us to create long-term value and growth. 
By removing unnecessary barriers and striving 
to be a fair and equitable bank, we can attract 
and retain the best talent, support a wider 
customer base to achieve their goals over  
the long term, and stimulate growth in our 
communities. This is how we open up a  
world of opportunity for our colleagues, our 
customers and our communities.

In this section

Promoting diversity 
and fostering 
inclusion

Our approach to diversity 
and inclusion

We value diversity of thought and we are building an inclusive 
environment that reflects our customers and communities. 

 Page 74

Creating a diverse 
environment

Fostering an inclusive 
culture

Building a healthy 
workplace

Listening to our colleagues We run a Snapshot survey and report insights to our Group 

Executive Committee and the Board.

Being a great place to work As the Covid-19 pandemic tested our colleagues, we expect the 
way we work to change as the workforce meets new demands.

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.

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.

Energising our colleagues 
for growth 

We are committed to offering colleagues the chance to develop 
their skills while building pipelines of talented colleagues to 
support the achievement of our strategic priorities.

Our approach to customer 
inclusion and resilience 

We aim to support financial well-being and remove barriers 
people can face in accessing financial services.

Developing skills, 
careers and 
opportunities

Building customer 
inclusion and 
resilience

Engaging with our 
communities

Building a more inclusive 
world

We focus on a number of priorities where we can make a 
difference to the community and support sustainable growth.

 Page 77

 Page 79

 Page 80

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73

ESG reviewESG review | Social 

Promoting diversity and fostering inclusion 

Our approach to diversity and inclusion

Our purpose, ‘Opening up a world of 
opportunity’, explains why we exist as an 
organisation and is the foundation of our 
diversity and inclusion strategy. Promoting 
diversity and fostering inclusion contributes to 
our ‘energise for growth’ priority. By valuing 
difference, we can make use of the unique 
expertise, capabilities, breadth and 
perspectives of our colleagues for the  
benefit of our customers. 

To achieve progress, we are focused on 
specific Group-wide priorities for which we 
hold senior executives accountable. Alongside 
Group targets, some executives have local 
priorities, such as combating social inequality 
in the UK, and the promotion of Hispanic 
representation in the US, to allow flexibility for 
a broader diversity and inclusion agenda that 
is contextually relevant.

Our approach extends beyond our colleagues 
and opens up a world of opportunity to our 
customers and the communities in which we 
operate. As we set out on the following pages, 
we are pleased to report progress in 2022, 
although we acknowledge there is more work 
to be done. 

How we hold ourselves to account

  We set meaningful goals 

Our executive Directors and Group 
Executives have goals within their annual 
performance scorecards that are tied to 
remuneration plans. In 2022, we continued 
to make progress against our three goals to: 

 – achieve a 35% representation of women 

in senior leadership roles by 2025; 

 – achieve a 3.4% representation of Black 
heritage colleagues in senior leadership 
roles in the UK and US combined by 
2025, aligned to our commitment to 
double the number of Black colleagues  
in leadership positions globally; and

We report and track progress
Data is critical and gives our Group Executive 
Committee regular progress checks against  
its goals. Our measures to track progress 
consist of:

 – a quarterly inclusion dashboard, which 

tracks progress against goals with specific 
data on hiring, promotion and exit ratios; 

 – a formal assessment of the Group Executive 
Committee’s performance against its three 
goals, run by our executive compensation 
team, at the half-year, third quarter and the 
end of the year, which is then reported to  
the Group Remuneration Committee; and

 – achieve a satisfaction score of at least 

 – semi-annual inclusion review meetings 

75% in our Inclusion index, which looks 
at the inclusivity of our culture by 
measuring our colleagues’ feelings of 
belonging, trust and psychological 
safety, as recorded within our employee 
Snapshot survey.

where our Head of Inclusion meets each 
Group Executive to review data and their 
progress against their goals, and to discuss 
actions and provide recommendations to 
support further progress.

We benchmark our performance
We use external disclosures and 
benchmarks to measure the progress  
we are making, and to provide us with 
insight into what actions to prioritise.  
In 2022, we achieved: 

 – the Parker Review target of having at 

least one Director from a minority ethnic 
group on its Board, with three Board 
members;

 – Stonewall’s Gold standard and rank as a 
top global LGBTQ+ inclusion employer; 

 – a score of 87.2 in the Bloomberg  

Gender Equality Index, which tracks  
the performance of public companies 
committed to transparency in gender 
data reporting. This was 13.1 percentage 
points above the financial sector average.

A data driven approach to inclusion
Our approach to collecting ethnicity data through colleagues’ self-identification underpins our ethnicity strategy to better reflect the 
communities we serve. Allowing colleagues to self-identify helps us to set market representation goals. We have enabled 91% of our  
workforce to be able to share their ethnic heritage with us. A total of 55% of our colleagues have now made disclosures on their ethnic 
background, where legally permissible. 

Strong self-declaration rates in the UK and US have enabled us to develop our ethnicity strategy with market-specific Black heritage 
representation goals. We define Black heritage to include all colleagues in the UK who identify as Black or mixed race where one of the 
ethnicities is stated as Black, and in the US for all colleagues who identify as Black or African-American. 

Employees can also share their disability, gender identity and sexual orientation data where legally and culturally acceptable to do so.  
These self-identification options are enabled for 90%, 81% and 70% of our workforce, respectively.

Engaging with diversity at the Board level

We have a designated non-executive Director 
responsible for workforce engagement, 
whose role is to bring the voice of the 
employee into the boardroom. Our employee 
resource group leadership community is an 
important contributor and communicator 
related to workforce engagement. 
Additionally, non-executive Directors are 
aligned to each of our employee resource 
groups.

In 2022, we continued our Bank Director 
Programme that invites a diverse group of 
senior leaders from across the Group to gain 
exposure to boards and develop board skills. 
This programme is building an internal pool 
of diverse talent that we will be able to assign 
to roles with our subsidiary boards. 

 For further details of Board diversity, see our 
Corporate governance report on page 247.

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Social 

Creating a diverse environment

Women in senior leadership 
After achieving our ambition of having 30% of 
senior leadership positions held by women in 
2020, we set a new goal to reach 35% by 2025. 
We remain on track, with 33.3% of senior 
leadership roles held by women at the end of 
2022, an increase of 1.6 percentage points since 
2021. A total 35.7% of all external appointments 
into senior positions were female, down from 
37.8% in 2021, and 38.1% of all promotions into 
senior leadership roles were female. 

Talent programmes, including Accelerating 
Female Leaders, helped increase the visibility, 
sponsorship and network of our high-
performing senior women. Since starting the 
programme in 2017, 38% of participants have 
either been promoted or taken a lateral move 
to develop their careers. We have also retained 
87% of colleagues who have completed  
the programme. 

In our Accelerating into Leadership 
programme, which prepares high potential, 
mid-level colleagues for future leadership roles, 
44% of participants in 2022 were women. 

We also had more than 2,600 women 
participating in our Coaching Circles 
programme, which involves senior leaders 
advising and supporting colleagues to develop 
their leadership skills and build their networks.

Our succession planning for key leadership 
roles includes an assessment of the diversity  
of our succession plans. We are improving the 
gender diversity of those in roles deemed most 
critical to the organisation, and successors to 
those roles. In 2022, 36% of the succession 
pool for these roles were women. 

In our support of our people throughout the 
different stages of their lives and careers, and 
in our aim to enable equal participation at 
work, we introduced gender neutral parental 
leave in the US and Australia, and improved 
paid maternity and paternity leave in Mexico 
and Argentina. 

Black colleagues in senior leadership 
We are on track to double the number of Black 
colleagues in senior leadership roles globally 
by 2025, having increased the number of 
Black senior leaders by 37% since 2020.

During 2022 we set a new Group-wide 
ethnicity strategy with the principle of better 
reflecting the communities we serve. We test 
this principle by comparing our workforce  
to national census data and setting goals to 
narrow material representation gaps over  
time. Our analysis highlighted Black heritage 
representation gaps in the UK and the US. We 
therefore set a goal of having 3.4% of Black 
heritage colleagues in senior leadership roles 
in the UK and US combined by 2025. While 
we are on track to meet this, with 2.5% of 
leadership roles held by Black heritage 
colleagues in 2022, we know there is more to 
be done to be representative of the societies 
we serve.

Our ethnicity strategy is overseen by a 
committee of senior leaders, led by our  
Group Chief Risk and Compliance Officer.  
The committee provides strategic direction  
to the Global Ethnicity Inclusion Programme.

In 2022, we continued to focus on inclusive 
hiring, investing in talent and growing 
leadership effectiveness. We have launched 
programmes to provide sponsorship and 
mentoring such as Solaris in the UK, which 
supports talented Black female colleagues, and 
a Black heritage programme in Global Banking 
and Markets, where 25% of participants at 
Director level secured promotion within 12 
months of commencing the programme. In 
2023, we will extend the programme to 
Commercial Banking colleagues and to 
colleagues in the US, with an additional focus 
on Hispanic colleagues. To help us attract 
diverse talent, we partner with specialist 
recruitment organisations that engage 
ethnically diverse talent. We also introduced 
reverse mentoring, which pairs Group 
Executives with Black heritage colleagues.

Gender diversity statistics 
Gender diversity data 

Holdings 
Board

Group 
Executives 

Combined 
Group 
Executives and 
direct reports1

Subsidiary 
directors2

Senior 
leadership3

Middle
management3

Junior
management3

All employees

8

4

17

4

170

89

616

315

6,226

3,103

18,897

11,257 

53,363

51,541

107,863

115,907 

Male 

Female

67%

33%

81%

19%

66%

34%

66%

34%

67%

33%

63%

37%

51%

49%

48%

52%

1  Combined Group Executives and direct reports 
includes HSBC Group Executives and their  
direct reports (excluding administrative staff)  
as at 31 December 2022. 

2  Directors (or equivalent) of subsidiary companies 

that are included in the Group’s consolidated 
financial statements, excluding corporate 
directors.

3  In our leadership structure, we classify: senior 

leadership as those at career band 3 and above; 
middle management as those at global career 
band 4; and junior management as those at global 
career bands 5 and 6. 

Representation and pay gaps 
We have reported gender representation and 
pay gap data since 2017 for the UK, and 
extended this to include gender data for the 
UK, the US, mainland China, Hong Kong, 
India and Mexico, alongside ethnicity data for 
the UK and US. In 2022, we extended this to 
include gender data for Singapore and the 
UAE. This covers over 70% of our workforce.

In 2022, our mean aggregate UK-wide 
gender pay gap was 45.2%, compared with 
44.9% in 2021, and the ethnicity pay gap 
was 0.4%, compared with -0.8% in 2021. 
Our UK gender pay gap is driven by the 

shape of our workforce. There are more men 
than women in senior, higher-paid roles and 
more women than men in junior roles. Given 
differences in variable pay levels across 
these roles, the increase in the 2021 variable 
pay pool contributed to the slight widening 
of our pay gap for 2022. 

While we are confident in our approach  
to pay equity, until women and ethnically 
diverse colleagues are proportionately 
represented across all areas and levels of the 
organisation we will continue to see gaps in 
average pay. We are committed to paying 
colleagues fairly regardless of their gender  

or ethnic heritage and have processes to 
ensure that remuneration is free from bias. 
We review our pay practices and undertake 
a pay equity review annually, including an 
independent third-party review of equal pay 
in major markets. If pay differences are 
identified that are not due to objective, 
tangible reasons such as performance, skills 
or experience, we make adjustments.

 For further details on our representation data, 
pay gap data, and actions, see www.hsbc.
com/diversitycommitments and the ESG Data 
Pack at www.hsbc.com/esg.

HSBC Holdings plc Annual Report and Accounts 2022

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Fostering an inclusive culture

In our annual Snapshot survey’s Inclusion 
index, which measures our colleagues’ sense 
of belonging, psychological safety, perception 
of fairness and trust, we achieved a 
favourability score of 76% in 2022, one point 
higher than our goal, and four points above 
the financial services industry benchmark. 

Looking to the future on disability
Our ambition is to become a leading disability 
confident employer and a digitally accessible 
financial services provider. In 2022, we 
continued to focus on driving our digital 
accessibility programme so that our products 
and service can be accessible for all. 

There was a three-point increase in colleagues 
feeling able to speak up without fear of 
negative consequences. This was a positive 
indicator of our strengthening culture of 
inclusion, which is a critical component of  
our ‘energise for growth’ strategy.

To educate our leaders and colleagues on 
driving an inclusive culture, we provided  
a number of inclusive leadership training 
programmes, and enhanced our ‘Making 
HSBC more inclusive’ training. More than 
10,500 colleagues also completed inclusive 
hiring training, which is aimed at enabling fair 
and inclusive hiring decisions that are in line 
with our hiring principles.

Employee resource groups 
Our employee resource groups foster an 
inclusive culture, and contribute significant 
value to tens of thousands of colleagues,  
with networks focused on a range of issues, 
including: age, disability, parents and careers, 
ethnicity, gender and LGBTQ+. 

Our employee resource groups celebrate key 
dates in the diversity calendar and hold events 
for colleagues to raise awareness, and build 
empathy and allyship. These included Pride, 
our network for LGBTQ+ colleagues and allies, 
holding a global ‘24 hours of Pride’ campaign 
that engaged our workforce to collectively 
celebrate our LGBTQ+ colleagues. Our 
Embrace network for ethnicity hosted its  
first global summit, attended by over 1,300 
colleagues, including senior leaders across 
three regions.

For our customers and colleagues, we 
improved the accessibility of our public 
websites, mobile applications and internal 
systems. AbilityNet, the digital accessibility 
charity, benchmarked HSBC as having the 
most accessible website compared with other 
local competitor banks in 10 of 13 of our key 
Wealth and Personal Banking markets.

We are transforming our internal systems to 
be digitally accessible. In 2022, we engaged 
over 2,000 colleagues in digital accessibility 
awareness and training, supported by the 
launch of a digital accessibility hub, which 
provides training and knowledge resources. 
The hub achieved the best digital accessibility 
award at the 2022 Digital Impact Awards. 

We are looking to extend our UK workplace 
adjustments process to other key markets, 
ensuring our colleagues have the right tools 
and technologies to perform their roles. The 
programme will help colleagues with a 
physical or sensory disability, long-term 
mental health conditions or neurodiversity 
needs to get advice and request additional 
equipment or software to enable them to do 
their work. 

In 2022, HSBC UK was recognised as a Gold 
Standard employer, following an assessment 
by the Business Disability Forum, with a score 
of 95.8%, the highest score awarded. We 
were praised on our commitment, drive and 
innovation with regards to disability inclusion. 
In 2023, we will continue to progress the 
execution of our disability confidence strategy 
with a particular focus on improving the 
experiences of colleagues with a disability 
across the key stages of their career journeys.

Empowering diverse customers
Aligned to our purpose of opening up a  
world of opportunity, we are committed  
to identifying and removing the different 
barriers customers face in accessing financial 
services. In 2022, we contributed to this 
through several initiatives, including the 
launch of a $1bn lending fund to invest in 
female-owned businesses. We introduced 
new processes to support refugees fleeing  
the conflict in Ukraine so they can access the 
financial services they need to set up a new 
life in the UK. We also sponsor the Hong Kong 
Lutheran Social Service to develop the ‘Health 
dollar fun’ app to boost digital literacy among 
the elderly. 

 For further details of how we are making 
financial services more accessible and fair,  
see ‘Our approach to customer inclusion and 
resilience’ on page 83.

Creating more equal communities
We partner with external organisations to 
open up opportunities for those groups who 
have historically been disadvantaged. In 2022, 
initiatives included: 

 – working with the Indian Academy for 

Self-Employed Women to provide business 
training and support to access digital 
marketplaces; 

 – partnering with Rural Education and 

Development India to train 500 youths  
from migrant and rural families to equip 
them with skills for the healthcare and 
apparel sector; and 

 – supporting the National Council of  

Social Service in Singapore to support 
employability services for persons who  
have recovered from mental health issues. 

Starting our journey on social mobility

We believe in the principle that the 
circumstances of someone’s birth  
should not define their future.

In 2022, we began to collect the socio-
economic diversity data of our colleagues 
within the UK, with the aim to improve social 
mobility. We will use this data to help us 
understand the representation and 
progression of colleagues from lower 
socio-economic backgrounds. 

We also joined ProgressTogether, a 
membership body of firms aimed at 
addressing career progression and retention 
for those identifying with a lower socio-
economic background. We established our 
‘Strive’ employee resource group, which will 
support and advocate for colleagues from 
lower socio-economic backgrounds. We 
plan to expand Strive to other markets as  
our work matures.

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Social 

Building a healthy workplace

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 2022, as we looked to 
continue defining the future of work and 
driving change in how we work.

In 2022, we also held a global ‘employee jam’, 
where over 18,000 colleagues across 63 
markets came together for a live online 
conversation (see panel below). The Snapshot 
survey is also a key source of insight to inform 
our approaches to well-being. For further 
details of our approach to well-being, see 
page 80. 

Employee conduct and harassment 
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. 

Our global anti-bullying and harassment code 
helps us to maintain consistent high standards 
of conduct across the Group, while 
accommodating local cultural requirements. In 
2022, we 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, which we improved throughout 
2022. We monitor bullying and harassment 
cases to inform our response and the data is 
reported to management committees. 

Listening to colleague sentiment 
In 2022, we changed how we run our 
all-employee Snapshot survey, reducing  
the frequency from once every six months  
to once a year, with a focus on increasing 
participation to enable more granular 
reporting throughout the organisation. We 
received a record 167,668 responses to the 
survey in September, with 78% of employees 
participating, surpassing the previous year’s 
record of 64%. 

This increase has enabled us to put more data 
directly in the hands of our people managers 
to understand how their teams feel about life 
at HSBC, with 5,000 managers given access 
to results, discussion guides and learning 
resources to help them engage with the 
feedback at a team level. We continue to 
report insights to our Group Executive 
Committee and the Board, and local results 
are shared across the Group to provide senior 
leaders across business areas with detailed 
insight to help plan and make decisions. 

We complement this all-colleague survey with 
targeted listening activities throughout the 
year, with employee lifecycle surveys aimed  
at new joiners, internal movers and voluntary 
leavers. 

In May and June, we received more than 
13,000 responses to our ‘Future of work’ 
survey, which explored how colleagues feel 
towards hybrid working. For further details  
of the findings and our approach to hybrid 
working, see ‘Being a great place to work’  
on page 79. 

In 2022, 1,159 concerns were raised related  
to bullying, harassment, discrimination and 
retaliation. Of the 811 cases where an 
investigation has concluded, 47% were 
substantiated. We take action where we see 
standards fall short of our expectation. In 
2022, 591 colleagues were dismissed in 
relation to misconduct, including 27 as a result 
of bullying, harassment or discrimination. We 
are not complacent and know that there is 
more we can do. Our refreshed values will 
guide and inform our plans to continue 
creating and promoting an inclusive working 
environment 

Employee engagement 

73%

Employee engagement score  
(2021: 72%) 

68% 

Of colleagues feel able to achieve their career 
objectives at this company 
(2021: 67%) 

77%

Of colleagues who feel confident about this 
company’s future 
(2021: 74%) 

Holding a live global online conversation 

In April, we held a global ‘employee jam’, 
where over 18,000 colleagues came 
together digitally for a live conversation 
around three key themes: embedding our 
purpose, values and strategy; enhancing the 
colleague experience; and enhancing the 
customer experience. 

Mirroring what we have heard in Snapshot 
surveys, colleagues told us that they believe in 
our purpose, strategy and values, but want to 
have a better understanding of their tangible 

impacts – both inside and outside HSBC – as 
well as their direct role in driving these. 

Colleagues said that we have made progress 
in areas such as diversity, future skills and 
trust, but that the focus should now be 
placed on building a culture of inclusion  
and empowerment, and on a more 
consistent approach to well-being. They also 
said the Group should focus on simplifying 
internal processes. 

HSBC Holdings plc Annual Report and Accounts 2022

77

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Listening to our colleagues continued

Employee engagement
We use eight Snapshot indices to measure key areas of focus and compare against peer institutions, including a new index focused on inclusion 
that we introduced in 2022. The table below sets out how we performed. 

Index

Score1

vs 
2021

HSBC vs 

benchmark2 Questions that make up the index

Employee 
engagement

73% +1

+3

Employee 
focus

72% +1

+2

Strategy

75% +3

+4

Change 
leadership

76% +2

+2

Speak-up

76% +1

+8

Trust

77% +1

+3

Career

68% +1

+4

Inclusion 
(new)3

76% +1

+4

I am proud to say I work for this company.
I feel valued at this company.
I would recommend this company as a great place to work.
I generally look forward to going to work. 
My work gives me a feeling of personal accomplishment. 
My work is challenging and interesting.
I have a clear understanding of this company’s strategic objectives. 
I am seeing the positive impact of our strategy. 
I feel confident about this company’s future.

Leaders in my area set a positive example. 
My line manager does a good job of communicating reasons behind important changes that are made. 
Senior leaders in my area communicate openly and honestly about changes to the business.
My company is genuine in its commitment to encourage colleagues to speak up.
I feel able to speak up when I see behaviour which I consider to be wrong.
Where I work, people can state their opinion without the fear of negative consequences.
I trust my direct manager. 
I trust senior leadership in my area. 
Where I work, people are treated fairly.
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.
I feel a genuine sense of belonging to my team.  
I feel able to achieve my career objectives at this company.  
I feel able to be myself at work.  
I trust my direct manager.  
Where I work, people are treated fairly.  
Where I work, people can state their opinion without the fear of negative consequences. 

1 Each index comprises 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 Inclusion index was introduced in 2022. It comprises questions that were asked in earlier surveys, so we are able to report a comparison with 2021. 

For further details of well-being, see page 80, and for further details of inclusion, see page 76. 

What we learned 
All eight of our Snapshot indices improved 
slightly in 2022. Employee engagement, which 
is our headline measure, was three points 
above benchmark and one point above 2021 
levels, and exceeded our target to maintain 
engagement levels during the year. The 
Strategy index continued to improve in relation 
to the financial services’ benchmark. 

Our colleagues continued to cite our 
approach to hybrid and flexible working as a 
reason to recommend HSBC, a theme that 
has been consistent since 2020. A greater 
proportion of colleagues also said they 
experienced a positive environment  
and culture, as well as saw training and 
progression opportunities, helping to  
drive our Employee engagement score. 

One of the other top five factors identified to 
influence the Employee engagement score is 
colleagues’ confidence in the company’s 
future. Within the Strategy index, employees 
recorded feeling increasingly confident about 
the future of the company and understanding 
of our strategic objectives. 

With inflationary pressures and the rising cost 
of living around the world, pay and financial 
well-being are growing concerns among 
colleagues. We saw an increase in comments 
relating to pay in the Snapshot survey, and 
self-reported financial well-being declined by 
four points, despite a four-point increase in 
employees reporting that they know how to 
get support about their financial capability. For 
further details of our approach to financial 
well-being, see page 80.

Our Snapshot survey showed 65% of 
colleagues reported they intend to stay with 
HSBC for five or more years, a one-point 
increase, while 19% said they intend to leave 
in the next two years, a two-point decrease. 
Despite this, involuntary turnover decreased  
to 3.3% and voluntary turnover increased to 
14.1%, as labour markets picked up globally. 
Both our Snapshot and voluntary leaver 
surveys tell us that career development  
and pay and benefits continue to be key 
influencing factors for voluntary attrition,  
and they remain central to our people strategy. 
For further details of how we help our people 
develop their careers, see ‘Developing skills, 
careers and opportunities’ on page 81.

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Being a great place to work 

We continued to support our colleagues 
during the Covid-19 pandemic, and ensured 
their safe return to the office. In 2022, we 
made it a priority to support even more 
colleagues to work flexibly, while ensuring we 
are there for our customers when and where 
they need us. 

Hybrid working is a key part of our flexible 
working proposition and requires trust. We 
have empowered our people to find the right 
balance, guided by the three principles of: 

 – customer focus, by delivering excellent 

outcomes for our customers;

 – team commitment, by connecting with  
each other, building our community and 
collaborating; and 

 – two-way flexibility, by providing more 

choice on how, when and where we work, 
suitable for the roles we perform. 

Our flexible working approach 
Colleagues consistently tell us that our 
approach to flexible and hybrid working is  
a key reason to recommend HSBC as an 
employer. In June 2022, our ‘Future of work’ 
survey showed 81% of colleagues speak 
positively about our approach to flexible and 
hybrid working, and 80% feel it improves their 
work-life balance. 

In 2022, we refreshed our flexible working 
policies to provide more choice and make it 
easier to request a flexible working 
arrangement. Choices include flexible and 
staggered hours, job sharing, reduced hours 
and hybrid working. These new policies are 
available to more than 90% of colleagues, 
including our branch network and non-
permanent employees. We have encouraged 
teams to have open conversations about 
flexible working opportunities. 

More colleagues than ever are working in  
a hybrid way, where working time is split 
between the office and home or another 
location. According to our Snapshot survey  
in September, 59% of our colleagues work  
in a hybrid way, compared with 37% in 2021. 

Different markets are at different stages of 
embedding hybrid working, and in 2022 some 
continued to operate under Covid-19 conditions. 

Getting the balance right 
While working at home eliminates  
commuting time and provides more 
opportunities to balance work and life,  
some benefits of being together in person 
cannot be recreated remotely. 

Overall, we have seen that colleagues  
in hybrid roles feel more productive and 
engaged than those who are unable to  
work remotely. However, nearly half of  
our colleagues told us that the networks  
of people they regularly interacted with 
decreased during the pandemic, and they 
missed social connections. 

As a result, we have equipped leaders to 
achieve the right balance of remote and 
in-person working for their teams. Our people 
managers have access to in-person and 
on-demand learning to develop the skills 
needed to lead hybrid teams effectively. 
Nearly 8,000 hybrid working learning 
curriculums were completed by our people 
leaders in 2022. In addition, we ran targeted 
events to stimulate a successful return to the 
office and create new hybrid working habits. 

With more colleagues adopting balanced hybrid 
working patterns, the Snapshot survey showed 
77% of colleagues said they have enough 
opportunities to connect and collaborate with 
people outside their immediate teams. 

Our offices will continue to evolve to support 
increased collaboration. We are rolling out a 
digital app in several locations that will offer 
greater visibility of who is in the office to 
support teams coming together.

86% 

Of people managers are confident their  
teams have the right balance of remote and 
in-person working to meet customer and 
stakeholder needs. 

Our approach to fair 
pay and performance 

As part of our approach to performance 
management, we ask colleagues to  
set goals with the support of their line 
managers, which are regularly reviewed. 
We encourage people managers to hold 
regular performance and development 
conversations, incorporating feedback, 
and discussing well-being and progress. 
In the Snapshot survey, 76% of 
colleagues indicated they were happy 
with the support their manager provided 
for career development. 

While our overall Career index, which 
measures employee sentiment towards 
career development, improved by  
one point, results from our employee 
listening channels indicated that 
sentiment around pay and career 
opportunities were key factors in 
colleagues’ decisions to leave HSBC.  
In 2023, we will review our approach to 
pay and performance to ensure we are 
able to motivate colleagues in a way that 
is authentic to our culture and values. 
Our approach will help colleagues have 
clarity on performance expectations, 
awareness of development 
opportunities and access to resources. 

As part of this programme, we are 
proposing to simplify assessments  
of colleagues and shift the focus to 
conversations about performance and 
growth, while improving transparency 
and structure in our fixed and variable 
pay design.

 For further details of our approach to 
colleague remuneration see page 281, and 
for details of our average standard entry 
level wages compared with local minimum 
wage, see our ESG Data Pack at www.
hsbc.com/esg.

Greater front-line flexibility with far reaching benefits

Colleagues have embraced hybrid working across our eight global service centres that 
support our customer operations and services. Through a ‘Hello hybrid’ campaign, over 
38,000 employees completed hybrid skills e-learning and nearly 850 colleagues took part in 
team dialogue sessions. The campaign helped our colleagues identify the best of remote and 
office working for their differing customer needs, cultures and regulatory requirements. As a 
result of the campaign, employee sentiment improved by 6% for the question ‘I generally look 
forward to my work day.’ In our main contact centres, colleagues now spend up to 67% of 
their working time on customer-facing activities. 

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Well-being

We want our colleagues to be at their best  
at work, so we invest significantly in their 
well-being and will continue to seek new  
ways to provide support. Guided by data  
and colleague feedback, the pillars of our 
well-being programme are mental, physical, 
financial and social well-being. In our 
employee Snapshot survey carried out in 
September, 70% of our colleagues said they 
believe HSBC cares about their well-being. 

Mental well-being 
Supporting our colleagues’ mental health 
remains a top priority, with the Covid-19 
pandemic still presenting mental health 
challenges in many countries. Our Snapshot 
survey revealed an increase in mental 
well-being, with 84% of colleagues rating  
their mental health as positive, compared with 
82% in 2021. It also revealed that 73% of 
colleagues felt comfortable talking to their 
manager about their mental health, a slight 
increase from 72% in 2021. 

We have continued to make telephone 
counselling services and Headspace, a 
meditation app, available to all colleagues 
globally. Use of these services increased  
by 3% and 28% in 2022, respectively.

More than 240,000 colleagues and contractors 
took part in mental health awareness training 
as part of global mandatory training. Our 
voluntary mental health e-learning has now 
been completed by 30,000 employees, with 
people managers making up 17% of the 
completions. We also provide an in-depth 
classroom course designed for line managers 
and those wanting to be mental health 
champions, which has been completed by  
800 colleagues.

To celebrate World Mental Health Day, we ran 
a global awareness campaign on alleviating 
stigma and encouraging colleagues to feel 
able to speak up if they need help. Throughout 
October, we held over 100 virtual events, 
featuring internal and external experts 
providing advice on mental health and 
well-being related topics. 

Physical well-being
The Snapshot survey revealed a decrease in 
physical well-being, with 71% of colleagues 
rating their physical health as positive, 
compared with 75% in 2021.

In February, we ran a survey about our 
employee benefits, which showed 37% of 
colleagues wanted more support with physical 
activity and exercise. In response, we ran a 
five-month pilot with 2,000 colleagues to test 
mobile apps that incentivise physical activity. 
The pilot showed that the use of apps and 
community challenges helped up to 70% of 
users increase their physical activity, to 
varying degrees. As a result, we are looking  
at expanding the initiative to more countries  
in 2023.

We have continued to provide access to 
private medical insurance in the majority of 
our countries and territories, covering 98% of 
permanent employees. In certain countries we 
provide on-site medical centres that the 
majority of colleagues can access.

We have enhanced fertility, adoption, and 
surrogacy benefits for our colleagues in the 
US and Canada. We are also expanding our 
gender dysphoria benefits for LGBTQ+ 
colleagues in the UK and Philippines  
from 2023. 

Financial well-being
Our Snapshot survey revealed a decrease in 
financial well-being, with 60% of colleagues 
reporting positively, compared with 64% in 
2021. We believe this is an impact of rising 
inflation and cost of living in many countries.

However, colleagues felt more supported to 
manage their financial well-being, at 62%, an 
increase of four points from 2021. The same 
survey revealed that 81% of colleagues felt 
they had the right skills and knowledge to 
manage their day-to-day finances, and 77% 
said they are well prepared to meet their 
financial goals.

programmes on healthy financial habits  
and saving strategies. Since their launch,  
over 2,400 colleagues have used these 
programmes.

We review our approach to employee share 
ownership plans in line with country demand, 
operational capacity and local legislation. In 2022, 
we expanded our global share plan to colleagues 
in Bahrain, Qatar and Kuwait, meaning that 90% 
of our people globally now have access to share 
ownership plans. We continue to look to offer the 
plan in new locations. 

In the UK, we introduced a green car scheme 
to encourage colleagues to transition to 
electric vehicles and benefit from reduced 
running costs and CO2 emissions.

Social well-being 
We introduced social well-being as a new 
pillar of our programme in 2022, to focus on 
social connections and work-life balance. 

Snapshot surveys showed 75% of colleagues 
say they can integrate their work and personal 
life positively, a slight decrease compared with 
76% in 2021. We will continue to facilitate this 
by enabling flexible working arrangements, 
including hybrid working, in line with our 
future of work initiative (see page 76). 
Colleagues feel more confident talking to their 
manager about work-life balance, with 80% 
saying they do, compared with 77% in 2021.

In 2021, we upgraded our At Our Best 
recognition online platform, which allows  
for real-time recognition and appreciation 
between colleagues. The upgrade enables 
colleagues to record and send video messages 
to accompany recognitions. In 2022, there 
were more than 1.2 million recognitions made, 
an 11% increase on 2021. We also enabled 
colleagues globally to donate their points 
directly to humanitarian relief agencies 
supporting those impacted by the war in 
Ukraine. To date more than 1,100 colleagues 
have made personal donations to this cause.

Our benefits survey showed that 31% of 
colleagues want more support around 
financial education. In response, we have 
continued to promote our financial education 

Awards 

CCLA Global 100 Mental Health 
Benchmark 
 – Ranked #1 global employer 

Promoting a culture of well-being

In July 2022, we became a founding member of the World Wellbeing Movement, a coalition 
of global leaders from business, civil society and academia. A key objective of the movement 
is to develop a simple and universally acceptable standard for measuring well-being that 
leads to meaningful action. We believe that having a standard ESG indicator on well-being 
will improve transparency and enable organisations to better target actions to create positive 
change.

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Developing skills, careers and opportunities 

Learning and skills development 

We aim to build a dynamic environment 
where our colleagues can develop skills and 
undertake experiences that help them fulfil 
their potential. Our approach helps us to  
meet our strategic priorities and support  
our colleagues’ career goals. 

Our resources 
The way we work and the way we learn has 
changed, driven by the adoption of hybrid 
working styles and digital capabilities. We use 
a range of resources to help colleagues take 
ownership of their development and career, 
including: 

 – HSBC University, which is our home for 
learning and skills accessed online and 
through a network of training centres. 
Learning is organised through technical 
academies aligned to businesses and 
functions, complemented with enterprise-
wide academies on topics of strategic 
importance; 

 – My HSBC Career Portal, which offers career 
development information and resources to 
help colleagues manage the various stages 
of their career, from joining through to 
career progression; and 

 – HSBC Talent Marketplace, which is our 

online platform that uses artificial 
intelligence (‘AI’) to match colleagues 
interested in developing specific skills with 
opportunities that exist throughout our 
global network.

Learning foundations 
We expect all colleagues, regardless of their 
contract type, to complete global mandatory 
training each year. This training plays a critical 
role in shaping our culture, ensuring a focus on 
the issues that are fundamental to our work 
– such as sustainability, financial crime risk, and 
our intolerance of bullying and harassment. 
New joiners attend our Global Discovery 
programme, which is designed to build their 
knowledge of the organisation and engage 
them with our purpose, values and strategy. 

As the risks and opportunities our business 
faces change, our technical academies adapt 
to offer general and targeted development. 
Our Risk Academy provides learning for  
every employee in traditional areas of risk 
management such as financial crime risk,  
but also offers more specific development  
for those in high-risk roles and for emerging 
issues, such as climate risk, or the ethics and 
conduct of AI and big data.

Preparing for the future 
Our approach to learning is skills based.  
Our academy teams work with businesses and 
functions to identify the key skills and 
capabilities they need now, and in the future. 

We use people analytics, strategic workforce 
planning, and learning needs analysis to identify 
current and future skills demand, and to help 
colleagues develop in new areas that match 
their aspirations and support career growth.

Throughout 2022 we continued to run  
skills campaigns to create the impetus for 
individual-led learning, and have used our 
skills influencer network of more than  
1,800 colleagues to build engagement and 
enthusiasm around the Talent Marketplace, 
and opportunities for development. 

Evolving how we learn 
During the Covid-19 pandemic, we 
strengthened our digital offering to enable 
colleagues to develop their skills in a hybrid 
environment. Our colleagues can access 
HSBC University online via our Degreed 
learning platform, using it to identify, assess 
and develop skills through internal and 
external courses and resources in a way  
which suits them. 

Degreed materials range from short videos, 
articles or podcasts to packaged programmes 
or curated learning pathways that link content 
in a logical structure. By December, more than 
187,000 colleagues were registered on the 
platform. In 2022, overall training volumes 
were 28.8 hours per FTE, up from 26.7 hours 
per FTE in 2021. 

However, we recognise that most 
development happens while our colleagues 
work, through regular coaching, feedback and 
performance management. To enable even 
more opportunities for colleagues to grow in 
this way, our Talent Marketplace matches 
colleagues to projects and new experiences 
based on their aspirations and career goals.  
In 2022, we rolled the platform out to an 
additional 83,000 colleagues across 18 
countries and territories. Over 150,000 
colleagues now have access to the platform, 
and to date over 3,000 projects and 
networking requests have been facilitated, and 
over 70,000 hours of activity have taken place. 

Training at HSBC 

6.3 million 

Training hours carried out by our  
colleagues in 2022.  
(2021: 5.9 million) 

28.8 hours

Training hours carried out per FTE in 2022. 
(2021: 26.7 hours) 

Identifying and retaining 
future talent 

The starting point to identifying talent is 
having a fair and inclusive recruitment 
process. To help managers hire in line 
with our principles, we have launched 
compulsory inclusive hiring training. In 
2022, over 5,000 managers received the 
certification, in addition to 13,500 in 2021. 

Our talent programmes have been 
designed to enable talented employees 
to make the successful transition into 
more complex roles and to support 
participants in planning for a long-term 
career at HSBC. Our key programmes 
include: 

 – Accelerating Female Leaders, which 
increases the visibility, sponsorship 
and network of female participants. 
Colleagues are supported with 
development plans to help them 
prepare for the next level of 
leadership, and matched with 
sponsors from our senior leadership 
and external executive coaches; 

 – Accelerating into Leadership, which 
prepares participants for leadership 
roles through peer-based development 
activities, senior sponsorship and 
executive coaches. Topics of focus 
include network building, developing 
resilience and navigating the 
organisation. We measure the 
retention of colleagues post-
programme to assess the success; and 

 – ‘UGrow’, which is our programme 
that supports the retention and 
development of colleagues while 
strengthening our leadership pipeline. 
The programme offers masterclasses 
focused on career planning, driving 
results and adaptability for aspiring 
colleagues. 

Our global emerging talent programmes 
welcomed over 800 graduates and 600 
interns to the organisation in 2022. Our 
programmes are a key enabler of our 
broader diversity goals (see page 74). In 
2022, our graduate intake was 48% 
female, and comprised graduates from 
46 nationalities and over 30 ethnicities. 
We welcomed our graduates with a 
three-day induction programme, which 
introduced them to key topics such as 
our purpose, values and strategy, as 
well as our role in delivering a 
sustainable future.

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Energising our colleagues for growth

We are committed to offering colleagues the 
chance to develop their skills while building 
pipelines of talented colleagues to support  
the achievement of our strategic priorities.

It remains critical to our ability to energise  
for growth that we demonstrate the right 
leadership, and create the optimal conditions 
for our people to perform. Our leadership and 
culture is guided by our purpose, values and 
delivering our strategy. 

The Sustainability Academy 
To support our ambitions to become net zero 
in our own operations by 2030, and to align 
our financed emissions to the Paris Agreement 
goal of net zero by 2050, we launched the 
Sustainability Academy in 2022. The academy 
is available to all colleagues across the Group 
and serves as a central point for colleagues to 
access learning plans and resources, and 
develop practical skills. 

The academy has resources to help all 
colleagues understand broad topics such  
as climate change or biodiversity, and is 
supplemented with more advanced content 
for key groups of colleagues who are 
supporting customers through their transition. 
We intend to align content to support business 
outcomes by educating our colleagues on 
topics such as energy efficiency, renewable 
energy, sustainability and ESG reporting. 

 As part of our strategy to align the provision 
of finance to the Paris Agreement, the 
Sustainability Academy is supporting our 
colleagues to build their knowledge and 
capability in the sectors in which we have 
begun to measure and set financed emissions 
targets, including the oil and gas, and power 
and utilities sectors. 

We will continue to update the academy with 
new research and content related to ESG 
issues, including those related to social and 
governance issues. 

Supporting our Asia wealth strategy 
At the heart of our ambition to offer best-in 
class international wealth management 
services to our customers is the accelerated 
expansion of our offering in Asia. To achieve 
this, we are providing opportunities for our 
colleagues to reskill and build career resilience 
through our Accelerating Wealth Programme. 
The programme offers a skills-based 
development plan for colleagues who  
are looking to pursue a career in wealth 
management. Participants on the programme 
are allocated 20% of their working week to 
focus on learning and skills development.  
They are then regularly assessed to ensure 
they are making progress with developing  
the right skills to meet our client needs.

We recognise the role that diverse experiences 
can bring to our customers, and have 
therefore ensured that the programme is open 
to colleagues from all global businesses and 
functions based in Asia. 

Building leadership capabilities 
We have strengthened the training we give to 
leaders at all levels of the Group to ensure they 
are equipped with the skills and knowledge  
to energise and develop our colleagues. 

We have continued the executive leadership 
programme for our most senior leaders, 
creating a programme of high-quality modules 
that draws on internal and external expertise. 
The programme focuses on the shifting 
expectations of leaders, embedding the clarity 
and alignment to achieve our goals and 
tackling strategic change. We complemented 
this with educational resources focused on the 
opportunities presented by Cloud, artificial 
intelligence, and blockchain technology. 

Our Country Leadership Programme aims  
to prepare and develop future country CEOs 
and executives for highly complex roles.  
The programme builds the confidence and 
competence of leaders across themes such  
as managing cyber risk, building regulatory 
relationships, representing HSBC’s net zero 
ambitions and upholding customer-centricity. 
Participants learn through simulation exercises 
and coaching from seasoned executives, 
subject matter experts and Board members.

Leadership development for our colleagues  
at managing director level includes new 
programmes that have been created in 
partnership with business schools and 
industry practitioners. Topics focus on a range 
of issues, including critical skills areas such as 
influence, inclusion, and Agile methodologies.

We recognise the importance of people 
managers in shaping the experience of our 
colleagues. We have revised our training for 
people managers to better support living our 
purpose, values and strategy, and to reflect 
the challenges of retaining talent. Our core 
leadership development programme is made 
up of four modules that are available in 
face-to-face and virtual formats. The 
programme is focused on the role and 
expectations of managers, how to design and 
organise work, how to handle relationships 
with employees and how to nurture a 
productive team environment.

Supporting UK emerging talent 

In the UK, we have continued to broaden our emerging talent programmes beyond 
traditional graduate and internship schemes. Our programmes support those from non-
traditional education backgrounds, and are supportive of our social mobility ambitions, 
outlined on page 75. In 2022, we provided over 180 apprenticeship opportunities for external 
and internal applicants. We have also provided over 600 structured work placements for 
secondary school students, and developed partnerships with Brampton Manor, Generating 
Genius and the #merky foundation to provide financial literacy support to over 6,400 14 to  
16 year olds. We have recently launched a career accelerator programme, in partnership 
with Zero Gravity, which involves over 120 of our graduates providing career coaching and 
mentorship to university students. HSBC UK also uses its apprenticeship levy to support 
work opportunities at small and medium-sized business through a partnership with West 
Midlands Combined Authority. 

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Building customer inclusion and resilience 

Our approach to customer inclusion and resilience

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 
supporting their financial well-being, and 
removing the different barriers that people  
can face in accessing financial services.

Access to products and services
We aim to provide innovative solutions  
that address the barriers people can face in 
accessing products and services. In 2022, we 
introduced a new process to help refugees 
fleeing the conflict in Ukraine to access the 
financial services they need to set up a new 
life in the UK. Over 9,000 Ukrainian refugees 
have now opened a bank account with us. 

As part of our efforts to help vulnerable 
customers access digital services, since 2021, 
HSBC UK has given over 1,500 vulnerable 
customers a free tablet device. This allows 
customers who previously had no way of 
accessing our online or mobile banking 
services the ability to do so.

Making banking accessible
Number of no-cost accounts held for 
customers who do not qualify for a standard 
account or who might need additional support 
due to social or financial vulnerability.1

2022

2021

2020

716,957

692,655

678,554

1 The scope of this disclosure has expanded from 2021, 
where we only reported the number of accounts opened 
for homeless, refugees and survivors of human trafficking.

Supporting financial knowledge  
and 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. 

Between the beginning of 2020 and the end  
of 2022, we received over 4 million unique 
visitors to our global digital financial education 
content, achieving our 2019 goal. We will 
continue to engage customers with financial 
education content and build their financial 
capabilities through the introduction of 
personal financial management tools. Since 
launching a financial fitness score in the UK, 
74,325 customers have used the tool to 
understand the healthiness of their finances 
based on details about their spending, 
borrowing and saving habits. 

We support programmes that deliver financial 
education to our local communities. HSBC Life 
is sponsoring the Hong Kong Lutheran Social 
Service to develop the Health Dollar Fun App, 
to boost digital literacy among the elderly, 
enhance their physical well-being and 
encourage social interaction. Throughout 2021 
and 2022, we also partnered with Injaz 
Al-Arab, member of JA Worldwide, to deliver 
our ‘Saving for good’ programme, which 
focuses on building the financial capability of 
low-income workers in Bahrain, Egypt, Kuwait, 
Qatar and the UAE. We have now supported 
over 1,700 individuals to grasp basic financial 
concepts such as budgeting, saving and 
investing through a combination of 
customised training courses and mentorship. 

We also understand the importance of 
building financial capability in young people 
to ensure future resilience. In Mexico, we 
offer a podcast that covers a relevant 
financial educational theme in each episode. 

To date, the podcast has been downloaded 
more than 73,000 times.

In collaboration with BBC Children in Need, 
HSBC UK has worked with financial education 
charity Young Enterprise to adapt its award-
winning Money Heroes programme for 
children and young people experiencing a 
range of issues and challenges in their lives. 
The education resources have been adapted 
to ensure they are accessible, with books 
available in braille and large-print, as well  
as British Sign Language signed videos, 
audiobooks and a new early-reader e-book. 

Creating an inclusive banking experience
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. 

We are committed to becoming a digitally 
accessible bank so that our digital channels 
are usable by everyone, regardless of ability. 
We have been recognised by the charity 
AbilityNet as having the most accessible 
website compared with other local competitor 
banks in 10 out of 13 of our key Wealth and 
Personal Banking markets. 

Support for customers extends beyond our 
digital channels. In recognition of the fact that 
not all disabilities are visible or immediately 
obvious to others, we have now joined the 
Hidden Disabilities Sunflower Lanyard 
Scheme in the UK and Hong Kong. The 
lanyard indicates that an individual may need 
additional support, help or a little more time. 
We also launched ‘quiet hours’ across all of 
our UK branches and ‘quiet corners’ at 
designated branches in Hong Kong, to provide 
a calmer and more inclusive environment. 

Supporting women and minority-led businesses

We aim to support our diverse customers 
by opening up a world of opportunity for 
women and minorities.

In May 2022, we launched a Female 
Entrepreneur Fund that aims to provide $1bn 
in lending to female-owned businesses.

Other programmes include our Mujeres Al 
Mundo (Women of the World) programme 
in Mexico, which supports the personal 
and professional development of women 
as customers. Mujeres Al Mundo offers 

women exclusive benefits across financial 
products and services, discounts on 
workshops and programmes taught by  
the University Anahuac Mexico.

We have also begun lending from the 
$100m that we allocated in 2021 for 
companies founded and led by women  
and minorities through HSBC Ventures.

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Engaging with our communities 

Building a more inclusive world

We have a long-standing commitment to 
support the communities in which we operate. 
We aim to provide people with the skills and 
knowledge needed to thrive in the post-
pandemic environment, and through the 
transition to a sustainable future. 

We are empowering our people and those  
in our communities to develop skills for the 
future. Through our charitable partnerships 
and volunteering opportunities, our people 
share their skills and create a positive impact 
in society.

Our global reach is our unique strength. 
Bringing together diverse people, ideas and 
perspectives helps us open up opportunities 
and build a more inclusive world.

Building community and future skills
Our Future Skills strategy, launched in 2018, 
has supported over 6.6 million people through 
more than $197m in charitable donations. 
Current projections from our charity partners 
indicate our support during 2022 reached 
more than 1.45 million people through 
donations of $41m. 

In anticipation of global economies 
transitioning towards a low-carbon future,  
our colleagues and charity partners initiated 
programmes that help people and 
communities respond to opportunities and 
challenges through building relevant skills: 

 – In the Middle East, we partner with the 
Posterity Institute and the Arab Youth 
Council for Climate Change to develop  
an open-source curriculum for teaching 
sustainability skills in higher education 
institutions in the region. 

 – In Argentina, the Academia Solar 

programme aims to train students in  
design, installation and commissioning  
of photovoltaic solar energy systems.

 – In India, the Babuji Rural Enlightenment and 
Development Society teaches rural farmers 
sustainable farming practices, including soil 
and water management, helping them to 
increase their income.

We also work with our charity partners  
around the world to promote employability 
and financial capabilities in disadvantaged 
communities, and to respond to local needs:

 – We support The Prince’s Trust Group to  

help marginalised young people in Australia, 
Canada, India, Malaysia, Malta and the  
UK to develop employable skills. 

 – Our award-winning partnership with the 
Scouts has led to the creation of the first 
ever Money Skills Activity Badge for  
Beaver and Cub groups in the UK.

 – We support Feeding America to help users 
of food banks in the US get on-site job skill 
training. 

 – We work with the China Volunteer Service 

Foundation to improve the financial 
capability of elderly people in Beijing, 
Shanghai, and Guangzhou.

Our support for Covid-19 relief efforts also 
continued in 2022, with a door-to-door 
vaccination programme in Hong Kong aiming 
to help 10,000 elderly or people with 
disabilities. 

Community engagement and 
volunteering
We offer paid volunteering days, and 
encourage our people to give time, skills  
and knowledge to causes within their 
communities. In 2022, our colleagues gave 
over 67,000 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.

Charitable giving in 2022

Social, including Future Skills: 50%
Environment, including the Climate 
Solutions Partnership: 20%
Local priorities: 16%
Disaster relief and other giving: 14%

Total cash giving towards charitable 
programmes

$116.8m

Hours volunteered during work time

>67,000

People reached through our Future Skills 
programme

1.45m 

Awards

Investor and Financial Education 
Awards 2022 Hong Kong
 – IFEA (Corporate) Gold Award 

Climate Solutions Partnership 

Our Climate Solutions Partnership is a five-year $100m philanthropic initiative that aims to 
identify and remove barriers to scale for climate change solutions. Working with the World 
Resources Institute, WWF and over 50 local partners, our support focuses on start-up 
companies developing carbon-cutting technologies, nature-based solutions, renewable 
energy initiatives in Asia and the WWF-led Asia Sustainable Palm Oil Links programme. 

Since 2020, we have committed $95.8m of our $100m funding target to non-governmental 
organisation (‘NGO’) partners, supporting projects with the potential to make significant 
impacts in the mission to achieve a net zero, resilient and sustainable future.

84

HSBC Holdings plc Annual Report and Accounts 2022

Governance 

Governance
Acting responsibly

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. 

Customer experience is at the heart of how  
we operate. It is imperative that we treat our 
customers well, that we listen, and that we act 
to resolve complaints quickly and fairly. We 
measure customer satisfaction through net 
promoter scores across each of our business 

lines, listen carefully to customer feedback so 
we know where we need to improve, and take 
steps to do this. 

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. 

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.

 For further details of our corporate  
governance, see our corporate  
governance report on page 239.

In this section

Setting high 
standards of 
governance 

Human rights

Customer 
experience

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.

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 transparent in how we track, record and 
manage complaints.

Integrity, conduct 
and fairness

Safeguarding the 
financial system

We have continued our efforts to combat financial crime and  
reduce its impact on our organisation, customers and communities 
that we serve.

Whistleblowing

Our global whistleblowing channel, HSBC Confidential, allows our 
colleagues and other stakeholders to raise concerns confidentially.

A responsible approach 
to tax

We seek to pay our fair share of tax in all jurisdictions in which  
we operate.

Acting with integrity

We aim to act with courageous integrity and learn from past events 
to prevent their recurrence.

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.

Our approach with 
our suppliers

We require suppliers to meet our compliance and financial stability 
requirements, as well as to comply with our supplier code of 
conduct.

Safeguarding data

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.

Cybersecurity

We invest in our business and technical controls to help prevent, 
detect and mitigate cyber threats.

 Page 86

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HSBC Holdings plc Annual Report and Accounts 2022

85

ESG reviewESG review | Governance 

Setting high standards of governance  TCFD

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  
our climate ambition and transition, customer 
experience and employee sentiment. The Board 
is regularly provided with specific updates on 
ESG matters, including the energy policy, human 
rights and employee well-being. Board members 
receive ESG-related training as part of their 
induction and ongoing development, and seek 
out further opportunities to build their skills and 
experience in this area. For further details of 
Board members’ ESG skills and experience, see 
page 240. For further details of their induction 
and training in 2022, see page 252. 

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 Group Disclosure and Controls Committee 
and Group Audit Committee, which provide 
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 PRA-regulated 
businesses are the senior managers responsible 
for climate financial risks under the UK Senior 
Managers Regime. Climate risks are 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 diagram on the right provides an illustration 
of our ESG governance process, including how 
the Board’s strategy on climate is cascaded and 
implemented throughout the organisation. It 
identifies examples of forums that manage both 
climate-related opportunities and risks, along 
with their responsibilities and the responsible 
chair. The structure of the process is similar for 
the escalation of problems, with issues either 
resolved in a given forum or raised to the 
appropriate level of governance with appropriate 
scope and authority.

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. 

Opportunities

Risks

How HSBC’s climate 
strategy is cascaded

Board level governance

HSBC Holdings Board

Group Executive Committee

Group Audit Committee

Group Risk Committee

Management level governance

ESG Committee

Group Risk Management Meeting

Supports the development and delivery 
of the Group’s ESG strategy, key 
policies and material commitments by 
providing oversight, coordination and 
management of ESG commitments 
and initiatives.

Co-Chairs: Group Company Secretary 
and Chief Governance Officer, and 
Group Chief Sustainability Officer

Receives updates on climate risk, 
and reviews climate risk appetite 
and top and emerging climate risks.

Chair: Group Chief Risk and 
Compliance Officer

Supporting governance

Sustainability Execution 
Review Group

Oversees the delivery of our ambition 
to provide and facilitate $750bn to 
$1tn of sustainable finance and 
investment, and realisation of 
commercial opportunities.

Chair: Group Chief Executive

Climate Risk Oversight Forum

Oversees global risk activities relating 
to climate risk management, including 
physical and transition risks. Equivalent 
forums have been established at 
regional level.

Chair: Group Head of Risk Strategy 
and Macroeconomic Risk

Regional, global business and global functions

Examples of ESG-related management governance
The following governance bodies support management in its delivery of ESG activities.

Digital Business 
Services Executive 
Committee
Oversees the global 
delivery of ESG 
activities within our 
own operations, 
services and 
technology 
elements of our 
strategy.

Chair: Group Chief 
Operating Officer

Group Reputational 
Risk Committee
Oversees global 
executive support 
for identification, 
management and 
ongoing monitoring 
of reputational risks.

Chair: Group 
Chief Risk and 
Compliance Officer

Human Rights 
Steering 
Committee
Oversees the 
Group’s evolving 
approach to human 
rights and provides 
enhanced 
governance.

Chair: Group 
Chief Risk and 
Compliance Officer

Sustainability 
Target Operating 
Model Steering 
Committee
Oversees the 
implementation 
of the Group’s 
organisational plan 
for the internal 
infrastructure, 
both within the 
Sustainability 
function and the 
wider Group, 
to deliver our 
climate ambitions.
Chair: Group Chief 
Sustainability 
Officer

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HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
Governance 

Human rights

Our respect for human rights

As set out in our Human Rights Statement, we 
recognise the role of business in respecting 
human rights. Our approach covers all aspects 
of internationally recognised human rights and 
is guided by the UN Guiding Principles on 
Business and Human Rights (‘UNGPs’) and the 
OECD Guidelines for Multinational Enterprises. 

Refreshing our salient human rights issues
In 2022, building on an earlier human rights 
review that had identified modern slavery and 
discrimination as priority issues, we reviewed 
our salient human rights issues following the 
methodology set out in the UNGPs. These are 
the human rights at risk of the most severe 
potential negative impact through our business 
activities and relationships. It is important to 
understand these as inherent risks, based on 
the nature of our business. Identifying and 
regularly reviewing these risks helps us to 
validate and evolve our overall approach to 
human rights.

Through this review, we identified the following 
five human rights risks (salient human rights 
issues) inherent to HSBC’s business globally: 

 – Right to decent work: This covers freedom 
from forced labour including freedom from 
slavery and child labour and protection from 
inhumane, harsh or degrading treatment or 
punishment. It also includes the right to just 
and favourable conditions of work including 
the right to reasonable working hours, fair 
working conditions and pay. It also covers the 
right to health and safety at work, including 
appropriate living conditions for workers as 
well as protection of their mental and 
physical health and safety while at work.

 – Right to equality and freedom from 

discrimination: This covers the right to equal 
opportunity and freedom from discrimination 
on the basis of protected characteristics.

 – Right to privacy: This includes the right to 

protection against interference with privacy.

 – Cultural and land rights: This includes 

Stakeholder engagement

As part of the process of validating our 
assessment of our salient human rights 
issues, we engaged with a range of internal 
and external stakeholders. These included:

 – drawing on the experience of our 

employee groups, which gave us valuable 
feedback on human rights challenges in 
the workplace;

 – working with civil society groups with 
expertise in one or more of our salient 
human rights issues, who could represent 
the views of potentially impacted people;

Our salient human rights issues
Illustration of HSBC Group’s inherent human rights risks mapped to business activities.

Inherent human rights risks 

Employer

Buyer

Right to 
decent 
work

Freedom from forced 
labour

Just and favourable 
conditions of work

Right to health and safety 
at work

Right to equality and freedom from 
discrimination

Right to privacy

Cultural and land rights

Right to dignity and justice

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

1 Investor includes our activities in HSBC Asset Management.

HSBC activities

Provider of products and 
services

Personal 
customers

Business 
customers

Investor1 

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

◆

self-determination and the enjoyment of 
culture, religion and language, and the rights 
of indigenous people.

 – Right to dignity and justice: This includes 
freedom of opinion and expression and 
freedom from arbitrary arrest, detention  
or exile.

The assessment also considered our business 
activities and relationships in the context of 
our roles: as an employer; as a buyer of goods 
and services; as a provider of financial 
products and services to personal customers 
and, separately, to business customers; and as 
an investor, including all investment activities.

We assessed how each of these five roles 
might intersect with our five salient human 
rights issues. The table above shows the areas 
where we assessed severe negative impacts 
on human rights would be most likely to arise, 
in the absence of action to mitigate them. This 

additional analysis allows us to focus our 
efforts as we review the range of measures 
already in place to manage risks, and consider 
enhancements.

Managing risks to human rights
In 2022, we began the process of adapting our 
risk management procedures to reflect what 
we learned from the work on salient human 
rights issues described above. This included 
the development of Group guidance on human 
rights, which incorporates the salient human 
rights issues assessment and provides 
colleagues with practical advice, including 
case studies, on how to identify, prevent, 
mitigate and account for how we address our 
impacts on human rights.

We incorporated additional human rights 
elements into our existing procurement 
processes and supplier code of conduct,  
and we extended existing human rights due 

 – interviewing of our largest investors to hear 
their assessments of the potential human 
rights impacts associated with the financial 
services industry, and we listened to their 
expectations of us in responding to the 
risks; and 

 – discussing our salient human rights issues 
with some of our key suppliers, our large 
business customers and the companies in 
which we invest, to understand their views 
of human rights impacts in different parts of 
the world and to develop collaborative 
approaches to addressing those impacts.

These stakeholder engagements and input 
from external human rights experts led us to 
alter or extend our initial assessments in 
several ways. For example, our discussions 
with civil society groups helped us 
understand the potential impact of our 
investments on all five of our salient human 
rights issues. Engagement with investors in 
HSBC informed our assessment of the way 
in which our salient human rights issues 
overlap with our approach to climate change 
and our commitment to a just transition (see 
next page).

HSBC Holdings plc Annual Report and Accounts 2022

87

ESG reviewESG review | Governance 

Our respect for human rights continued

diligence processes for suppliers and business 
customers. We continued to develop our 
in-house capability on human rights, including 
by launching online resources for all staff and 
delivering bespoke human rights training for 
520 employees across our network.

Financial crime controls 
The risk of us causing, contributing or being 
linked to adverse human rights impacts is  
also mitigated by our financial crime risk 
management framework, which includes our 
global policies and associated controls.

 For further details of how we fight financial crime, 
see www.hsbc.com/who-we-are/esg-and-
responsible-business/fighting-financial-crime.

Other policies
HSBC’s Principles for the Ethical Use of Data 
and Artificial Intelligence describe how we 
seek to respect rights to privacy while making 
use of these technologies.

Driving change
We continued to be active participants in 
industry forums, including the Thun Group of 
Banks, which is an informal group that seeks to 
promote understanding of the UNGPs within 
the sector.

HSBC has been an active member of the 
Mekong Club since 2016. We are a regular 
participant in its monthly financial services 
working group and use its informative 
typological toolkits, infographics, and other 
multimedia resources covering current and 
emerging human trafficking and modern 
slavery issues. Our Compliance teams 
regularly collaborate and engage with the 
Mekong Club in designing bank-wide 
knowledge sharing and training sessions.

Supporting those impacted and those 
potentially at risk
We continued to expand our Survivor Bank 
programme, which has now benefited over 
2,000 survivors of modern slavery and human 
trafficking in the UK, and is a model for 
making financial services more accessible to 
vulnerable communities worldwide. 

The actions we are taking to address these 
salient human rights issues are consistent  
with our values, and will help us to meet our 
commitments on diversity and inclusion, and 
those we have made under the UN Global 
Compact and the World Economic Forum 
metrics on risk for incidents of child, forced  
or compulsory labour. 

 For further details of the actions we have taken to 
respect the right to decent work, see our Annual 
Statement under the UK Modern Slavery Act at 
www.hsbc.com/modernslaveryact.
 For further details of the actions taken to  
respect the right to equality and freedom from 
discrimination, see ’Our approach to diversity  
and inclusion’ on page 74.

Sector policies
Some of our business customers operate in 
sectors in which the risk of adverse human 
rights impact is greater. Our sector policies for 
agricultural commodities, energy, forestry, 
mining and metals cover human rights issues 
such as forced labour, harmful or exploitative 
child labour, land rights, the rights of 
indigenous peoples, including ‘free prior and 
informed consent’, workers’ rights, and the 
health and safety of communities. 

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. 

Our sector policies are reviewed periodically to 
ensure they reflect our priorities. 

 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.

We built on this experience in developing 
access to banking services for customers  
in the UK and in Hong Kong with no fixed 
abode, providing over 4,000 accounts under 
these programmes.

We also responded to the devastating effects 
of the conflict in Ukraine by introducing a  
new process to help refugees to access the 
financial services they need to set up a new 
life in the UK. Over 9,000 people fleeing the 
conflict have opened a bank account with us.

 For further details of our work to support 
vulnerable communities, see page 83.

Effectiveness
The table below includes indicative metrics we 
use to measure year-on-year continual 
improvement to our human rights processes.

Contracted suppliers who had 
either confirmed adherence to the 
code of conduct or provided their 
own alternative that was accepted 
by our Global Procurement 
function (%)

93% 

No-cost accounts held for 
customers who do not qualify for 
a standard account or who might 
need additional support due to 
social or financial vulnerability

Employees who have received 
bespoke training on human rights

Votes against management for 
reasons including human rights1 

Concerns raised related to 
bullying, harassment, 
discrimination and retaliation

716,957

520

87

1,159

1  The figure represents the number of resolutions at 
investee company shareholder meetings (including 
AGMs) where votes were cast against management 
for reasons related to human rights.

Working for a just transition 

We aim to play a leading role in mobilising the transition to a global net zero economy, not just by 
financing it, but by helping to shape and influence the global policy agenda. When designing and 
implementing low-carbon pathways it is important to consider the communities and areas of the 
economy that will be facing the greatest challenges. This aligns closely with our commitments on 
human rights more broadly. This was demonstrated in June 2022 when HSBC and US fashion 
group PVH Corp. announced the first sustainable supply chain finance programme that includes 
human rights performance standards.

  For further details on this programme, see page 58. See also our paper on Just and Inclusive Climate 
Transition for investors at www.assetmanagement.hsbc.co.uk/-/media/files/attachments/common/
news-and-articles/articles/campaign-2022-11-02-hsbc-responsible-investment-insights-q4-2022.pdf.

88

HSBC Holdings plc Annual Report and Accounts 2022

Governance 

Customer experience

We remain committed to improving 
customers’ experiences. In 2022, we gathered 
feedback from over one million customers 
across our three global businesses to help us 
understand our strengths and the areas of 
focus. Our recommendation scores improved 
in more than 66% of our markets, although  
we still have work to do to improve our rank 
position against competitors.

Customer satisfaction

Listening to drive continual improvement
In 2022, we continued to embed our feedback 
system so we can better listen, learn and act 
on our customers’ feedback. We use the net 
promoter score (‘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’. 

We run studies that allow us to benchmark 
ourselves against other banks. In 2022, we 
expanded our surveys to 14 markets to cover 
India, France and Germany. We try to make it 
as easy as possible for customers to give us 
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 WPB ‘Customer in the room’ programme 
launched in 2022 to bring our senior 
leadership closer to customers by providing 
them with direct access to customer 
feedback. The programme helps to 
demonstrate the impact of our decisions on 

our customers, and helps ensure we use 
customer feedback in all aspects of how we 
run our business. 

How we fared
In WPB, our NPS increased in four of our six 
key markets, which were the UK, Hong Kong, 
mainland China and Singapore. Our NPS in 
Mexico remained unchanged, while our NPS 
in India saw a small decline. In Hong Kong,  
we were ranked in first place, with improved 
scores in wealth advisory, life insurance and 
investment products. Our PayMe payments 
app was also ranked in second place for  
digital wallets. 

Our ranks in mainland China and India 
remained in the top three, while our rank in 
India declined to third place. Our NPS in India 
declined across the mobile app, branch and 
call centre channels. Our overall rank in 
Singapore improved, and we remained in the 
top three among our mass affluent and high 
net worth customers. Our rank in the UK 
remained unchanged, with improvements in 
our loan products and wealth advisory scores. 
However, customers told us we needed to 
focus more 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 improvements in these areas. 

In our private bank, our global NPS decreased 
to 25, compared with 31 in 2021. This was 
largely due to a decrease in our scores in Hong 
Kong, the US and Luxembourg, with mainland 
China and Taiwan now included in the  
overall score.

In CMB, our NPS increased in four of our  
six key markets, which were Hong Kong, 
mainland China, Singapore and Mexico. Our 
NPS declined in the UK and India. Our rank 
positions in Hong Kong, India, mainland China, 

Singapore and Mexico either improved 
compared with 2021, or were in the top three 
against competitors. However, our rank in 
India declined to third place. This was driven 
by a decline in NPS among our Business 
Banking customers. In the UK, our overall rank 
remained unchanged. We were ranked in the 
top three among our large corporate and 
mid-market enterprise customers in the UK, 
and we saw a small decline in NPS among  
our Business Banking customers. We continue 
to see some challenges in service delivery, 
particularly for our Business Banking customers. 
Among other initiatives, we have been working 
hard to resolve telephony resourcing, which has 
impacted our responsiveness.

In GBM, our global NPS improved from 13 to 
17 points. Our global rank position remained in 
fifth place. We continued to be ranked in the 
top three against competitors in MENA, while 
our US rank improved. Our digital satisfaction 
score fell marginally by one point. We 
remained ranked first for the quality of our 
digital trade finance platforms.

Number of markets in top three 
or improving rank1

WPB

CMB

2022

4 out of 6

5 out of 6

1  In 2022, we updated the markets we measure  
our rank positions for both our WPB and CMB 
businesses to align with executive incentive 
scorecards. They comprise: the UK, Hong Kong, 
Mexico, mainland China, India and Singapore. 
Rank positions are provided using data gathered 
through third-party research agencies

Acting on feedback 

We continued to focus on improving our 
products and services to enable better 
customer experiences. 

Across WPB, we launched our Global 
Money proposition, initially in the UK, which 
allows customers to open a multi-currency 
account and be able to use it within 
minutes. We also introduced a new mobile 
account opening journey in Singapore in 
response to preferences for mobile-first 
experiences.

In CMB, we deployed digital onboarding 
solutions to 12 markets in 2022, using 
external data sourcing to streamline client 
and colleague journeys. These deliveries 
increased our digital penetration by 14% 
from 2021, extending our digital products 
and services to more customers globally. 
Through using technology to digitise our 
operations, there was close to a 6% increase 
in 2022 in trade transactions initiated digitally 
by our customers, and nearly a 62% increase 
in payments completed using the HSBCnet 
mobile app.

In response to client feedback, we made a 
number of changes to our client coverage 
model in GBM during 2022. We reshaped 
our Institutional Client Group, particularly our 
approach to financial sponsors, sovereign 
wealth funds and global investors. We 
enhanced our corporate multinational model 
to focus on our largest relationships through 
regional account managers. We also 
launched a series of transaction banking 
solutions to improve the experience for  
our clients, and created a new digital 
collaboration layer to drive clearer 
accountability and coordination of global 
teams when delivering these solutions.

HSBC Holdings plc Annual Report and Accounts 2022

89

ESG reviewESG review | Governance 

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

Keeping the 
customer up to 
date

Ensuring fair 
resolution

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. 

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. 

Providing available 
rights

We provide customers with information on their rights and the 
appeal process if they are not satisfied with the outcome of the 
complaint. 

Undertaking root 
cause analysis

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 2022, we received approximately 1.2 million 
complaints from customers. The ratio of 
complaints per 1,000 customers per month  
in our large markets decreased slightly from 
2.4 to 2.3.

accessing and using our digital platforms. We 
are addressing these by seeking to improve our 
digital capabilities, timely staff reinforcement, 
enhanced guidance of how to use our digital 
platforms and improved customer journeys.

In the UK, complaints fell 8% partly due to a 
decline in transaction disputes, which had 
risen during the Covid-19 pandemic. The 
reduction in these complaint volumes can also 
be attributed to journey improvements we 
made to deal with these disputes more quickly. 
We continue to be focused on improving the 
customer experience to reduce complaint 
volumes further during 2023. 

The increase in complaints in Hong Kong was 
mainly related to reduced operations in our 
branches during Covid-19-related restrictions, 
an increase in fraudulent activities, and the 
migration by customers towards new ways of 

The decrease in complaints in Mexico was 
driven by improvements in fraud detection,  
as our fraud teams took actions to protect 
customers, including carrying out an upgrade 
to a monitoring tool for credit and debit cards 
and making adjustments to fraud rules.

In our private bank in 2022, we received 331 
complaints, a 23% decrease on 2021, largely 
due to the reduction in administration and 
service issues. Within this category a high 
proportion were attributable to processing or 
client reporting delays/errors. In 2022, the 
private bank resolved 344 complaints.

WPB complaint volumes1
(per 1,000 customers per month)

Total2

UK3

Hong Kong3

Mexico3

2022

2021

2.3

2.4

1.4

1.4

1.0

0.7

5.1

5.5

1  A complaint is any expression of dissatisfaction 
about WPB’s activities, products or services 
where a response or resolution is explicitly or 
implicitly expected.

2  Markets included: Hong Kong, mainland China, 

France, the UK, UAE, Mexico, Canada and the US. 

3  The UK, Mexico and Hong Kong make up 86% of 

total complaints.

Acting on feedback 

In 2022, we launched a Group-wide plan to 
deliver an improved experience for our 
customers around the world. The plan will 
strengthen our capabilities to hear, understand 
and act on what our customers are telling  
us on a regular basis. Across markets we 
enhanced our measurement and tracking 
capabilities, and developed the skills and tools 
our colleagues need to improve their customer 
experience each day. We also sought to 

standardise our customer-focused approach 
in our processes. 

This allows us to have a structured approach 
to manage feedback. 

For our colleagues focused on improving our 
customers’ experiences, we enhanced and 
launched regular forums in 15 of our key 
markets to ensure systematic reviews are 
carried out to prioritise feedback and 
implement improvements quickly regarding 
our customers’ online and offline experiences. 

In Hong Kong, we analyse customer feedback 
and detect their pain points at an early stage 
through a feedback mechanism. Our 
colleagues are now able to reach out to  
our customers with unhappy experiences 
proactively to resolve their outstanding issues.

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Governance 

How we listen continued
Commercial Banking (‘CMB’)

In 2022, we received 62,995 customer 
complaints, a decrease of 23.4% from 2021. 
Of the overall volumes, 78.1% came from the 
UK and 12.9% from Hong Kong. The most 
common complaint related to operations, 
namely payment processing errors and delays.

The reduced volume of received complaints in 
the UK was largely as a result of a reduction in 
Covid-19-related complaints. This was mainly 
due to the fact we received fewer complaints 
related to the Bounce Back Loan scheme, and 
we also resolved the under-resourcing in UK 
servicing centres, which had led to delays in 
customer support in 2021 and into the first 
half of 2022.

Acting on feedback 

In Hong Kong, volumes were higher in the first 
half of the year due to the consequences of 
Covid-19-related restrictions that placed stress 
on servicing centre capacity. Additional 
recruiting of servicing staff, improvements  
in the customer due diligence policy and the 
payment investigations process helped to 
reduce complaints volumes in the second half 
of the year, resulting in annual volumes that 
were in line with 2021. 

We resolved 65,018 complaints globally  
in 2022. The average resolution time for 
complaints reduced by 23% to an average  
of 5.7 days, which is within our global target  
of 20 days.

CMB complaint volumes1
(000s)

Total

UK

2022

2021

63.0

82.2

49.2

67.1

Hong Kong

8.1

8.2

In 2022, we continued to invest in our client 
feedback tool, moving our products and local 
operations onto the platform. The Global 
Payments Solutions business adopted the 
tool during the year, and CMB staff in Hong 
Kong and India are due to begin logging and 
managing complaints in early 2023.

In late 2022, we also introduced new 
reporting functionality for complaints logged 
on the tool, which will update complaints  
on a daily basis, and enable colleagues 
responsible for managing complaints within 
markets and product teams to more closely 
manage volumes and operations.

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 2022, we 
reported 865 complaints associated with such 
customers and have managed these closely to 
ensure fair outcomes for the customer.

Global Banking and Markets (‘GBM’)

In 2022, we received 2,127 customer 
complaints in Global Banking, a decrease  
of 8% from 2021.

Of the overall Global Banking complaints 
volumes, 45.6% were from complaints in 
Europe and 28.0% came from the MENA 
region. With regard to the types of complaint, 
82% for Global Banking related to servicing 
and payment processing, which is in line with 
previous years.

In the Markets and Securities Services 
business, complaint volumes decreased by 
6% from 2021. Of the overall Markets and 
Securities Services complaint volumes, 48% 
were in Asia and 43% in Europe. Our Markets 
and Securities Services business remains 
focused on providing a high standard of client 
service and commitment to resolving issues in 
a timely manner, with 93% closed within our 
service standards.

GBM complaint volumes1

Total

2022

2021

2,419 2,619

Global Banking2

2,127 2,310

Global Markets and 
Securities Services

292

309

Acting on feedback 

We have continued to invest in our client 
feedback tool to create a consistent and 
streamlined experience for front-line staff in 
Global Banking and Markets and the 
wholesale businesses globally. In the fourth 

quarter, we launched a new reporting 
module driven from our client feedback tool, 
which will provide real-time complaints 
volumes, complaint details and operational 
metrics for our complaints users. This 

additional information will enable 
management to respond to complaints 
volumes. 

1  Globally, 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. Within the UK, a complaint is any expression of dissatisfaction – whether justified or not – about our products, services or activities which suggests 
we have caused (or might cause) financial loss, or material distress or material inconvenience.

2  Global Banking also includes Global Payments Solutions (previously known as Global Liquidity and Cash Management) and complaints relating to payment 

operations, which is part of Digital Business Services.

HSBC Holdings plc Annual Report and Accounts 2022

91

ESG reviewESG review | Governance 

Integrity, conduct and fairness

Safeguarding the financial system

We have continued our efforts to combat 
financial crime and reduce its impact on our 
organisation, customers and the communities 
that we serve. Financial crime includes fraud, 
bribery and corruption, tax evasion, sanctions 
and export control violations, money 
laundering, terrorist financing and  
proliferation financing. 

We are committed to acting with integrity,  
and have a financial crime risk management 
framework that is applicable across all global 
businesses and functions, and all countries 
and territories in which we operate. The 
financial crime risk framework, which is 
overseen by the Board, is supported by our 
financial crime policies that are designed to 
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 monitoring and testing our financial 
crime risk management programme.

We continue to invest in new technology, 
including through the deployment of a 
capability to monitor correspondent banking 
activity, the enhancements to our fraud 
monitoring capability and our trade screening 

controls, and the application of machine 
learning to improve the accuracy and 
timeliness of our detection capabilities. These 
new technologies should enhance our ability 
to respond effectively to unusual activity and 
be more granular in our risk assessments.  
This helps us to protect our customers, the 
organisation and the integrity of the global 
financial system against financial crime.

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. 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. Among other controls, 
we use customer due diligence and 
transaction monitoring to identify and help 
mitigate the risk that our customers are 
involved in bribery or corruption. We perform 
anti-bribery and corruption risk assessments 
on third parties that expose us to this risk.

The scale of our work

Each month, on average, we monitor 
over 1.2 billion transactions for signs of 
financial crime. During 2022, we filed 
over 73,000 suspicious activity reports 
to law enforcement and regulatory 
authorities where we identified potential 
financial crime. In addition, we screen 
approximately 117 million customer 
records monthly for sanctions exposure.

99% 

Total percentage of employees who have 
received financial crime training, including  
on anti-bribery and corruption.

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 the 
concerns of individuals and have a zero 
tolerance for acts of retaliation. 

Listening through whistleblowing 
channels
Our global whistleblowing channel, HSBC 
Confidential, is one of our speak-up channels, 
which allows our colleagues and other 
stakeholders to raise concerns confidentially 
and, if preferred, anonymously (subject to  
local laws). In most of our markets, HSBC 
Confidential concerns are raised through an 
independent third party, offering 24/7 hotlines 
and a web portal in multiple languages. We 
also provide and monitor an external email 
address for concerns about accounting, 
internal financial controls or auditing matters 
(accountingdisclosures@hsbc.com). Concerns 
are investigated proportionately and 
independently, with action taken where 
appropriate. This can include disciplinary 

action, dismissal, and adjustments to variable 
pay and performance ratings.

We promote our full range of speak-up 
channels to colleagues to help ensure their 
concerns are handled through the most 
effective route. In 2022, 18% fewer concerns 
were raised through HSBC Confidential 
compared with 2021. Of the concerns 
investigated through the HSBC Confidential 
channel in 2022, 83% related to behaviour  
and conduct, 11% to security and fraud risks, 
6% to compliance risks and less than 1% to 
other categories.

The Group Audit Committee has overall 
oversight of the Group’s whistleblowing 
arrangements, and 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 the 
organisation’s policies and procedures. 

Compliance sets the whistleblowing policy 
and procedures, and provides the Group  
Audit Committee with periodic updates on 
their effectiveness. Specialist Compliance 
teams and investigation functions own 
whistleblowing controls, with monitoring in 
place to determine control effectiveness. 

 For further details of the role of the Group Audit 
Committee in relation to whistleblowing, see 
page 266.

HSBC Confidential concerns raised  
in 2022: 

1,817

(2021: 2,224)

Substantiation rate of concerns 
investigated through HSBC Confidential 
in 2022:

41%

(2021: 42%)

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HSBC Holdings plc Annual Report and Accounts 2022

 
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 seek to ensure 
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. 

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 seven such jurisdictions in which 
we operated during 2022 that may be 
impacted by adjustments required under the 
Pillar 2 Framework. We continually monitor 
the number of active subsidiaries within each 
jurisdiction as part of our ongoing entity 
rationalisation programme. We seek to 
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 investments 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 of 4.9%  
was reduced by 14.3% by the recognition of 
previously unrecognised deferred tax assets in 
the UK and France in light of improvements in 
forecast profits in these jurisdictions. Further 
details are provided on page 357. The UK bank 
levy charge for 2022 of $13m is lower than the 
charge of $116m for 2021 as it includes 
adjustments made to prior period UK bank 
levy charges recognised in the current year.

As highlighted below, in addition to paying 
$5.5bn of our own tax liabilities during 2022, 
we collected taxes of $10.2bn on behalf of 
governments around the world. A more 
detailed geographical breakdown of the taxes 
paid in 2022 is provided in the ESG Data Pack. 

Taxes paid – by type of tax

Taxes paid – by region

Taxes collected – by region

Tax on profits $2,429m (2021: $2,711m)
Withholding taxes $361m (2021: $366m)
Employer taxes $1,041m (2021: $1,125m)
Bank levy $314m (2021: $479m)
Irrecoverable VAT $1,152m (2021: $1,315m)
Other duties and levies1 $232m (2021: $278m)

Europe $2,745m (2021: $3,170m)
Asia-Pacific $1,894m (2021: $2,077m)
Middle East and North Africa $259m 
(2021: $236m)
North America $207m (2021: $469m)
Latin America $424m (2021: $322m)

Europe $4,197m (2021: $3,177m)
Asia-Pacific $3,274m (2021: $3,584m)
Middle East and North Africa $67m 
(2021: $78m)
North America $1,129m (2021: $1,081m)
Latin America $1,493m (2021: $1,343m)

1 Other duties and levies includes property taxes of $94m (2021: $126m).

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, but it is a challenge we must 
continue to pursue. 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. 

HSBC Holdings plc Annual Report and Accounts 2022

93

ESG reviewESG review | Governance 

Conduct: Our product responsibilities

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 is embedded into the way 
we design, approve, market and manage 
products and services, with a focus on five 
clear outcomes:

 – We understand our customers’ needs.

 – We provide products and services that  

offer a fair exchange of value.

 – We service customers’ ongoing needs,  
and put it right if we make a mistake.

 – We act with integrity in the financial markets 

we operate in.

 – We operate resiliently and securely to avoid 

harm to customers and markets.

We train all our staff on our approach to 
conduct, helping to ensure our conduct 
outcomes are part of everything we do.

Designing products and services 
Our approach to product development is set 
out in our policies, and provides a clear basis 
on which informed decisions can be made. 
Our policies require that products must be 
fit-for-purpose throughout their existence, 
meeting regulatory requirements and 
associated conduct outcomes.

Our approach includes:

 – designing products to meet identified 

customer needs;

 – managing products through governance 
processes, helping to ensure they meet 
customers’ needs and deliver a fair 
exchange of value;

 – periodically reviewing products to help 

ensure they remain relevant and perform  
in line with expectations we have set; and

 – improving, or withdrawing from sale, 

products which do not meet our customers’ 
needs or no longer meet our high standards.

Meeting our customers’ needs 
Our policies and procedures set standards to 
ensure that we consider and meet customer 
needs. These include: 

 – enabling customers to understand the key 

features of products and services;

 – enabling customers to make informed 

decisions before purchasing a product or 
service; and

 – ensuring processes are in place for the 

provision of advice to customers. 

They help us provide the right outcomes for 
customers, including those with enhanced 
care needs. This helps us to support 
customers who are more vulnerable to 
external impacts, including the current cost of 
living crisis (see ‘Supporting our customers 
facing a rising cost of living’ on page 15).

Financial promotion
Our policies help to ensure that in the sale of 
products and services, we use marketing and 
product materials that support customer 
understanding and fair customer outcomes. 
This includes providing information on 
products and services that is clear, fair and not 
misleading. We also have controls in place to 
ensure our cross-border marketing complies 
with relevant regulatory requirements.

Product governance 
Our product governance arrangements 
cover the entire lifecycle of the product. 
This helps ensure that our products meet 
our policy requirements before we sell 
them. It also allows continued risk-based 
oversight of product performance against 
the intended customer outcomes.

When we decide to withdraw a product 
from sale, we aim to consider the 
implications for our existing customers, 
and agree actions to help them achieve a 
fair outcome where appropriate.

Our approach with our suppliers

We maintain global standards and procedures 
for the onboarding and use of third-party 
suppliers. We require suppliers to meet  
our compliance and financial stability 
requirements, and to comply with our  
supplier code of conduct. 

Supplier code of conduct 
We have a supplier code of conduct, revised in 
2022, which sets out our commitments to the 
environment, diversity and human rights, and 
which outlines the minimum commitments  
we expect of our suppliers on these issues.

Sustainable procurement
In October 2022, we introduced an internal 
sustainable procurement procedure to set out 
the minimum sustainability requirements for 
procurement activity. This helps us to manage 
the risks related to sustainability in our supply 
chain, and balance the social, environmental 
and economic considerations in procurement 
decisions.

We formalise commitment to the code with 
clauses in our supplier contracts, which 
support the right to audit and act if a breach  
is discovered.

At the end of 2022, 93% of approximately 
9,600 contracted suppliers had either 
confirmed adherence to the supplier code of 
conduct or provided their own alternative that 
was accepted by our Global Procurement 
function. 

Managing environmental and social risk
In 2022, we updated our ESG reputational risk 
assessment tool to identify the environmental 
and social risks for suppliers that are 
considered to be in sectors with high ESG risk. 
Previously, the assessment was applied to 
suppliers with higher value contracts only. The 
tool provides an ESG reputational risk score for 
the supplier. A high-risk score results in a 
further review to establish whether we are 
able to mitigate the risk and onboard  
the supplier. 

 For further details of the number of suppliers by 
geographical region, see the ESG Data Pack at 
www.hsbc.com/esg.

94

HSBC Holdings plc Annual Report and Accounts 2022

Governance 

Safeguarding data

Data privacy

We are committed to protecting and 
respecting the data we hold and process,  
in accordance with the laws and regulations  
of the markets 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. This 
includes global mandatory training for all our 
colleagues, with additional training sessions, 
where needed, to keep up to date with 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 
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 concerns on 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 
appropriate challenge and visibility for senior 
executives. Data privacy laws and regulations 
continue to evolve globally. We continually 
monitor the regulatory environment to ensure 
we respond appropriately to any changes. 

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 our data protection 
officers, 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. 

We continue to enhance our internal data 
privacy tools 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 help 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.

Data Privacy Day

In January 2022, we hosted an internal 
global data privacy event for our 
colleagues to mark International Data 
Privacy Day. The event, which was 
broadcast online, was hosted by our 
Global Head of Data Privacy Legal and 
the Global Data Risk Steward. The 
President and CEO of the International 
Association of Privacy Professionals  
was a guest speaker at the event. 

Key themes included an exploration of 
developments in US state and federal 
data privacy legislation and regulations, 
developments in the implementation and 
embedding of existing data privacy laws, 
key challenges to organisations such as 
cross-border data transfers and data 
localisation requirements, and the 
evolving enforcement environment 
within which we operate.

The ethical use of data and AI

Artificial intelligence and other emerging technologies give us the ability to process and 
analyse data at a depth and breadth not previously possible. While these technologies offer 
significant potential benefits for our customers, they also pose 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 Data and Artificial Intelligence are available at www.hsbc.com/who-we-are/
esg-and-responsible-business/our-conduct.

HSBC Holdings plc Annual Report and Accounts 2022

95

ESG reviewESG review | Governance 

Cybersecurity

The threat of cyber-attacks remains a concern 
for our organisation, as it does across the 
financial sector. As cyber-attacks continue  
to evolve, failure to protect our operations  
may result in disruption for customers, 
manipulation of data or financial loss.  
This could have a negative impact on  
our customers and our reputation. 

We continue to monitor ongoing geopolitical 
events and changes to the cyber threat 
landscape, and take necessary proactive 
measures with the aim to reduce any impact 
to our 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 ability  
to detect and respond to attacks through 
round-the-clock security operations centre 
capabilities helps to reduce the impact  
of attacks. 

We continually evaluate threat levels for the 
most prevalent attack types and their potential 
outcomes. We have a 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. 

In 2022, we further strengthened our cyber 
defences and enhanced our cybersecurity 
capabilities to help reduce the likelihood and 
impact of unauthorised access, security 
vulnerabilities being exploited, data leakage, 
third-party security exposure and advanced 
malware. These defences 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 and managing the cyber risk.  
They work with control owners to apply the 
appropriate risk treatment in line with our risk 
appetite. Our controls are executed in line with 
policies produced by our Resilience Risk 
teams, and are reviewed and challenged by 
the second line of defence. 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, including to the Board and across 
global businesses, functions and regions.  
In addition, we work with our third parties  
to help reduce the threat of cyber-attacks 
impacting our business processes. We have 
an assessment capability 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 appropriate tools and behaviours they need 
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.

Over 92% of our IT developers hold at least one 
of our enhanced security certifications to help 
ensure we build secure systems and products. 

We host an annual cyber awareness month  
for all colleagues, covering topics such as 
online safety at home, social media safety, 
safe hybrid working and cyber incidents  
and response. Our dedicated cybersecurity 
training and awareness team provides regular 
programmes to our colleagues and customers. 
We provide a wide range of education  
and guidance to both customers and our 
colleagues about how to spot and prevent 
online fraud.

Over 97%

Employees completed mandatory 
cybersecurity training on time.

Over 92%

IT developers who hold at least one of our 
internal secure developer certifications.

Over 140

Cybersecurity education events held globally.

Over 97%

Survey respondents to cybersecurity 
education events who said they have  
a better understanding of cybersecurity 
following these events.

Educating customers online 

Our Fraud and Cyber Awareness app, which launched in the UK in May 2021, has been 
enhanced and extended to eight markets in the Middle East and North Africa as a pilot to 
improve the financial education of our customers. The app is available free of charge for both 
personal and business customers, and is designed to keep customers and non-customers up 
to date with the latest trends concerning fraud, scams and cyber-attacks. It enables users to 
subscribe to real-time notifications about emerging fraud and cybercrime trends. Since May 
2021, the app has been downloaded approximately 28,000 times and has a 4.8 rating on 
Google Play and iOS app store. We plan to roll out the app to further markets in 2023.

96

HSBC Holdings plc Annual Report and Accounts 2022

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.

98  

Financial summary

109 

 Global businesses and geographical regions

128 

 Reconciliation of alternative performance measures

Pioneering a sustainable supply 
chain finance programme

In June 2022, we worked closely with US-based fashion group 
PVH Corp. to launch the first sustainable supply chain finance 
programme tied to environmental and social objectives, and 
based on suppliers’ sustainability ratings. 

The programme provides the company’s global suppliers  
with access to critical funding based on a set of science-based 
environmental targets, as well as a series of social elements, 
including a healthy and safe working environment, 
compensation and benefits, and employment issues, such  
as forced labour, child labour, and harassment and abuse. 

Sustainable supply chain finance supports leading companies 
and key sectors like the apparel industry to help ensure progress 
is made towards their targets and commitments.

HSBC Holdings plc Annual Report and Accounts 2022

97

Financial reviewFinancial summary

Financial summary
Contents

98

98

98

99

99

100

101

105

Use of alternative performance measures 

Changes to presentation from 1 January 2022

Changes to presentation from 1 January 2023

Future accounting developments

Critical accounting estimates and judgements

Consolidated income statement 

Income statement commentary 

Consolidated balance sheet 

Use of alternative performance 
measures
Our reported results are prepared in accordance with IFRSs 
as detailed in the financial statements starting on page 324.

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 128. 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 360.
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 that 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.

Management does not assess forward-looking reported operating 
expenses as a target of the business, and therefore a reconciliation of 
the adjusted operating expenses target to an equivalent IFRS 
measure is not available without unreasonable efforts.
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 109 to 112 and pages 119 to 124 detail the 
effects of significant items on each of our global business segments, 
geographical regions and selected countries/territories in 2022, 2021 
and 2020.
Foreign currency translation differences

Foreign currency translation differences reflect the movements of the 
US dollar against most major currencies during 2022. 

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 to better understand the underlying trends in the 
business.

98

HSBC Holdings plc Annual Report and Accounts 2022

Foreign currency translation differences
Foreign currency translation differences for 2022 are computed by 
retranslating into US dollars for non-US dollar branches, subsidiaries, joint 
ventures and associates:
•

the income statements for 2021 and 2020 at the average rates of 
exchange for 2022; and
the balance sheets at 31 December 2021 and 31 December 2020 at 
the prevailing rates of exchange on 31 December 2022.

•

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 Argentina subsidiaries 
has not been adjusted further for the impacts of hyperinflation. Since 
1 June 2022, Türkiye has been deemed a hyperinflationary economy for 
accounting purposes. HSBC has an operating entity in Türkiye and the 
constant currency data has not been adjusted further for the impacts of 
hyperinflation.
When reference is made to foreign currency translation differences in 
tables or commentaries, comparative data reported in the functional 
currencies of HSBC’s operations have been translated at the appropriate 
exchange rates applied in the current period on the basis described 
above.

Changes to presentation from 
1 January 2022
Application of IAS 29 ‘Financial Reporting in 
Hyperinflationary Economies’ 

Since 1 June 2022, Türkiye has been deemed a hyperinflationary 
economy for accounting purposes. The results of HSBC’s operations 
with a functional currency of the Turkish lira have been prepared in 
accordance with IAS 29 ‘Financial Reporting in Hyperinflationary 
Economies’ as if the economy had always been hyperinflationary. The 
results of those operations for the 12-month period ended 
31 December 2022 are stated in terms of current purchasing power 
using the Türkiye Consumer Price Index (’CPI’) at 31 December 2022 
with the corresponding adjustment presented in the consolidated 
statement of comprehensive income. In accordance with IAS 21 ‘The 
Effects of Changes in Foreign Exchange Rates’, the results have been 
translated and presented in US dollars at the prevailing rates of 
exchange on 31 December 2022. The Group’s comparative 
information presented in US dollars with respect to the 12-month 
periods ended 31 December 2021 and 31 December 2020 has not 
been restated. Argentina remains a hyperinflationary economy for 
accounting purposes. The impact of applying IAS 29 and the 
hyperinflation provisions of IAS 21 in the current period for both 
Türkiye and Argentina was a decrease in the Group’s profit before tax 
of $548m, comprising a decrease in revenue of $541m (including a 
loss of net monetary position of $543m) and an increase in ECL and 
operating expenses of $7m. The CPI at 31 December 2022 for Türkiye 
was 1,047 (movement 2022: 359.94) and for Argentina was 1,147 
(movement 2022: 563.92, 2021: 197.47).
Changes to presentation from 
1 January 2023
Foreign currency and notable items

From 1 January 2023, ‘adjusted performance’ will no longer exclude 
the impact of significant items. Rather it will be computed by 
adjusting reported results only for the effects of foreign currency 
translation differences between periods to enable users to 
understand the impact this has had on the Group’s performance. We 
will separately disclose ‘notable items‘, which are components of our 
income statement which management and investors would consider 
as outside the normal course of business and generally non-recurring 
in nature. We will recalibrate applicable targets and guidance to reflect 
the impact of these changes, as well as the impact on our targets 
following the implementation of IFRS 17 ‘Insurance Contracts’, and 

 
intend to communicate these as part of our first quarter results in 
May 2023.
Reporting by legal entity

From 1 January 2023, the Group will no longer present results by 
geographical regions. We will instead report performance by our main 
legal entities to better reflect the Group’s structure.
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 and December 
2021. Following the amendments, IFRS 17 is effective for annual 
reporting periods beginning on or after 1 January 2023 and is applied 
retrospectively, with comparatives restated from 1 January 2022.

On the basis of the implementation work performed to date, our 
current assumption remains that the accounting changes will result in 
a reduction in the earnings of our insurance business by 
approximately two thirds on transition to IFRS 17, albeit within a 
range of expected outcomes and before the effect of market impacts 
in specific periods. Unlike current accounting where market impacts 
and changes in assumptions are reported immediately in profit or 
loss, under IFRS 17 these are primarily accumulated with the 
contractual service margin (‘CSM’) and recognised in profit or loss 
over the remaining life of the contracts. While IFRS 17 changes the 
timing of profit recognition, there is no impact to the underlying 
economics of the insurance business, including solvency, capital and 
cash generation.

Results of work performed to date on the half-year to 30 June 2022 
IFRS17 comparatives indicate there would be a likely reduction to 
reported profit before tax for our insurance manufacturing operations 
from $0.6bn under IFRS 4, to approximately $0.3bn under IFRS 17. 
IFRS 4 based profit before tax included negative market impacts of 
$0.7bn and a $0.3bn specific pricing update for policyholder funds 
held on deposit with us in Hong Kong. The consolidated Group 
insurance accounting considers the effect of eliminating intra-group 
distribution fees between insurance manufacturing and non-insurance 
Group entities, and instead includes the costs of selling insurance 
contracts incurred by such entities within the Group CSM. These 
factors generate a further impact on the 30 June 2022 Group IFRS 17 
profit before tax of negative $0.1bn, in addition to the impact on 
insurance manufacturing operations. 

We also anticipate some impact on selected key Group metrics. We 
expect an estimated reduction of approximately $1.1bn to the first 
half of 2022 Group net interest income due to the reclassification of 
assets supporting policyholder liabilities from amortised cost to fair 
value through profit and loss classification, following which the 
associated interest income will be included within the ‘net income/
(expense) from assets and liabilities of insurance businesses, 
including related derivatives, measured at fair value through profit or 
loss’ line item. Group operating expenses are expected to reduce by 
approximately $0.3bn as a result of the IFRS 17 requirement for 
directly attributable costs to be included in the CSM and recognised 
within the insurance service result line, within revenue.

These estimates are based on accounting policies, assumptions, 
judgements and estimation techniques that remain subject to change.
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, 
selecting and calibrating the probability of default (‘PD’), the loss 
given default (‘LGD’) and the exposure at default (‘EAD’) models, 
as well as selecting model inputs and economic forecasts, and 
making assumptions and estimates to incorporate relevant 
information about late-breaking and 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 341.

• Deferred tax assets: The most significant judgements relate to 
those made in respect of recoverability, which is based on 
expected future profitability. See Note 1.2(l) on page 346.

• 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 339.

• Impairment of investment in subsidiaries: 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 HSBC Holdings’ 
investment in HSBC North America Holdings Limited and HSBC 
Bank Bermuda Limited. See Note 1.2(a) on page 337.

• 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 337.

• 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 337.

• 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 346.

• 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 345.

• Non-current assets and disposal groups held for sale: 

Management judgement is required on determining the likelihood 
of the sale to occur, and the anticipated timing in assessing 
whether the held for sale criteria have been met. See Note 1.2(o) 
on page 347. 

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.

HSBC Holdings plc Annual Report and Accounts 2022

99

Financial reviewFinancial summary

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 
Impairment loss relating to the planned sale of our retail banking operations in France2
Other operating income/(loss)
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
Change in expected credit losses and other credit impairment charges
Net operating income 
Total operating expenses excluding impairment of goodwill and other intangible assets
Impairment of goodwill and other intangible assets
Operating profit
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)4

Dividend payout ratio5
Post-tax return on average total assets
Return on average ordinary shareholders’ equity
Return on average tangible equity
Effective tax rate

2022
$m
32,610   
11,451   
10,469   

2021
$m
26,489   
13,097   
7,744   

2020
$m
27,578   
11,874   
9,582   

2019
$m
30,462   
12,023   
10,231   

2018
$m
30,489 
12,620 
9,531 

(3,394)   

4,053   

2,081   

3,478   

(1,488) 

(77)   

(182)   

231   

90   

(97) 

226   

(3)   
12,825   
(2,378)   
(133)   
61,596   
(9,869)   

798   

455   

812   

695 

569   
10,870   
—   
502   
63,940   
(14,388)   

653   
10,093   
—   
527   
63,074   
(12,645)   

335   
10,636   
—   
2,957   
71,024   
(14,926)   

218 
10,659 
— 
960 
63,587 
(9,807) 

51,727   

49,552   

50,429   

56,098   

53,780 

(3,592)   
48,135   
(33,183)   
(147)   
14,805   
2,723   
17,528   
(858)   
16,670   

14,822   
—   
1,213   
635   
16,670   

2022
$
0.75   
0.74   
0.27   
%
 44 
 0.6   
 8.7 
 9.9 
 4.9   

928   
50,480   
(33,887)   
(733)   
15,860   
3,046   
18,906   
(4,213)   
14,693   

12,607   
7   
1,303   
776   
14,693   

2021
$
0.62   
0.62   
0.22   
%
 40 
0.5   
 7.1 
 8.3 
22.3   

(8,817)   
41,612   
(33,044)   
(1,388)   
7,180   
1,597   
8,777   
(2,678)   
6,099   

3,898   
90   
1,241   
870   
6,099   

2020
$
0.19   
0.19   
—   
%
 79 
0.2   
 2.3 
 3.1 
30.5   

(2,756)   
53,342   
(34,955)   
(7,394)   
10,993   
2,354   
13,347   
(4,639)   
8,708   

5,969   
90   
1,324   
1,325   
8,708   

2019
$
0.30   
0.30   
0.51   
%
 100 
0.3   
 3.6 
 8.4 
34.8   

(1,767) 
52,013 
(34,622) 
(37) 
17,354 
2,536 
19,890 
(4,865) 
15,025 

12,608 
90 
1,029 
1,298 
15,025 

2018
$
0.63 
0.63 
0.51 
%
 81 
0.6 
 7.7 
 8.6 
24.5 

1  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch.
2   Includes impairment of goodwill of $425m. 
3  Net operating income before change in expected credit losses and other credit impairment charges also referred to as revenue. 
4 

Includes an interim dividend of $0.09 per ordinary share in respect of the financial year ending 31 December 2022, paid in September 2022, and an 
interim dividend of $0.18 per ordinary share in respect of the financial year ending 31 December 2021, paid in April 2022.

5  Dividend per share, in respect of the period, as a percentage of earnings per share adjusted for certain items (recognition of certain deferred tax 

assets: $0.11 reduction in EPS; planned sales of the retail banking operations in France and banking business in Canada: $0.09 increase in EPS). No 
items were adjusted in 2021, 2020, 2019 or 2018.

Unless stated otherwise, all tables in the Annual Report and Accounts 2022 are presented on a reported basis.

For a summary of our financial performance in 2022, see page 28.

For further financial performance data for each global business and geographical region, see pages 109 to 112 and 117 to 127 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 360.

100

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Income statement commentary
The following commentary compares Group financial performance for the year ended 2022 with 2021.
Net interest income

Interest income
Interest expense 
Net interest income
Average interest-earning assets 

Gross interest yield1
Less: gross interest payable1
Net interest spread2
Net interest margin3

31 Dec
2022
$m
55,059   
(22,449)   
32,610   
2,203,639   

Year ended
31 Dec
2021
$m
36,188   
(9,699)   
26,489   
2,209,513   

%
 2.50 
 (1.24) 
 1.26 
 1.48 

%
 1.64 
 (0.53) 
 1.11 
 1.20 

31 Dec
2020
$m
41,756   
(14,178)   
27,578   
2,092,900   

%
 2.00 
 (0.81) 
 1.19 
 1.32 

31 Dec
2022
$m
19,548   
(9,970)   
9,578   
2,178,281   

Quarter ended
30 Sep
2022
$m
14,656   
(6,075)   
8,581   
2,170,599   

%
 3.56 
 (2.21) 
 1.35 
 1.74 

%
 2.68 
 (1.36) 
 1.32 
 1.57 

31 Dec
2021
$m
9,219 
(2,438) 
6,781 
2,251,433 
%
 1.62 
 (0.52) 
 1.10 
 1.19 

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

2022

2021

Average
balance

Interest
income Yield

Average
balance

Interest
income

Short-term funds and loans and advances to banks
Loans and advances to customers
Reverse repurchase agreements – non-trading
Financial investments 
Other interest-earning assets 
Total interest-earning assets 

Summary of interest expense by type of liability

$m
446,178   
  1,023,606   
231,052   
430,327   
72,476   
  2,203,639   

$m
5,596 
32,607 
4,886 
9,836 
2,134 
55,059 

%
 1.25   
 3.19   
 2.11   
 2.29   
 2.94   
 2.50   

$m
450,678   

$m
1,105 
1,060,658    26,071 
1,019 
6,729 
1,264 
2,209,513    36,188 

206,246   
438,840   
53,091   

Deposits by banks1
Customer accounts2
Repurchase agreements – non-trading
Debt securities in issue – non-trading
Other interest-bearing liabilities
Total interest-bearing liabilities

2022

Average
balance

Interest
expense

$m
75,739   
  1,342,342   
118,309   
179,814   
87,719   
  1,803,923   

$m
770 
10,903 
3,085 
5,608 
2,083 
22,449 

2021

Average
balance

Interest
expense

$m
75,671   
1,362,580   
114,201   
193,137   
70,929   
1,816,518   

$m
198 
4,099 
363 
3,603 
1,436 
9,699 

Cost

%
 1.02   
 0.81   
 2.61   
 3.12   
 2.37   
 1.24   

2020

Average
balance

Interest
income

$m
298,255   

$m
1,264 
1,046,795    29,391 
1,819 
8,143 
1,139 
2,092,900    41,756 

221,901   
463,542   
62,407   

2020

Average
balance

Interest
expense

$m
65,536   
1,254,249   
125,376   
219,610   
76,395   

$m
330 
6,478 
963 
4,944 
1,463 
1,741,166    14,178 

Yield

%
 0.42 
 2.81 
 0.82 
 1.76 
 1.83 
 2.00 

Cost

%
 0.50 
 0.52 
 0.77 
 2.25 
 1.92 
 0.81 

Yield

%
 0.25   
 2.46   
 0.49   
 1.53   
 2.38   
 1.64   

Cost

%
 0.26   
 0.30   
 0.32   
 1.87   
 2.02   
 0.53   

1 
2 

Including interest-bearing bank deposits only. 
Including interest-bearing customer accounts only.

Net interest income (‘NII’) for 2022 was $32.6bn, an increase of 
$6.1bn or 23% compared with 2021. The increase reflected the 
benefit of rising global interest rates, while actively managing our 
pricing strategy and funding requirements, with growth in all regions, 
notably in Asia and the UK.

Excluding the unfavourable impact of foreign currency translation 
differences, net interest income increased by $7.7bn or 31%.

NII for the fourth quarter was $9.6bn, up 41% compared with the 
previous year, and 12% compared with the previous quarter. This was 
driven by higher interest rates and management of our funding costs, 
with growth in all regions, notably in Asia and the UK.

Net interest margin (‘NIM’) for 2022 of 1.48% was up 28 basis 
points (‘bps’) compared with 2021, as the gross yield on AIEA 
improved by 86bps in the high interest rate environment. This was 
partly offset by the rise in the funding cost of average interest-bearing 
liabilities of 71bps. Excluding the adverse impact of foreign currency 
translation differences, net interest income increased by 29bps.

NIM for the fourth quarter of 2022 was 1.74%, up 55bps year on 
year, and up 17bps compared with the previous quarter, 
predominantly driven by the impact of higher market interest rates. 

Interest income for 2022 of $55.1bn increased by $18.9bn or 52%, 
primarily due to higher average interest rates compared with 2021, as 
the yield on AIEA rose by 86bps, mainly driven by loans and advances 
to customers, short-term funds, loans and advances to banks, and 
reverse repurchase agreements. However, mortgage yields rose 
more modestly due to competitive pressures and market factors in 
the UK and Hong Kong. The increase in interest income included 
adverse effects of foreign currency translation differences of $2.2bn. 
Excluding this, interest income increased by $21.1bn.

Interest income of $19.5bn in the fourth quarter was up $10.3bn year 
on year, and up $4.9bn from the previous quarter. The increase was 
driven by the impact of higher interest rates, resulting in improved 
yields on loans and advances to customers and reverse repurchase 
agreements.

HSBC Holdings plc Annual Report and Accounts 2022

101

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial summary

Interest expense for 2022 of $22.4bn increased by $12.8bn or 131% 
compared with 2021. This reflected the increase in funding cost of 
71bps, mainly arising from higher interest rates paid on interest-
bearing customer accounts, repurchase agreements and debt 
securities in issue. The increase in interest expense included the 
favourable effects of foreign currency translation differences of 
$0.6bn. Excluding this, interest expense increased by $13.4bn.

Included within net interest income in 2022 is a $2.5bn interest 
expense representing a component of centrally allocated funding 
costs associated with generating ‘net income from financial 
instruments held for trading or managed on a fair value basis’. This 
compared with an interest expense of $0.4bn in 2021. 

Interest expense of $10.0bn in the fourth quarter of 2022 was up 
$7.5bn year on year, and up $3.9bn compared with the previous 
quarter. The steep rise in interest expense was mainly driven by 
higher funding cost on customer accounts as interest rates increased, 
particularly in Asia and Europe.

Net fee income of $11.5bn was $1.6bn lower than in 2021, and 
included an adverse impact from foreign currency translation 
differences of $0.6bn. Net fee income fell in WPB and GBM, although 
it increased in CMB.

In WPB, net fee income decreased by $0.9bn. The reduction was 
mainly in Wealth, as adverse market sentiment resulted in lower 
customer demand, mainly in Hong Kong. Fee income fell due to lower 
sales of unit trusts and from subdued customer demand in funds 
under management, as well as from lower broking income. Cards 
income grew as spending increased compared with 2021. This also 
resulted in higher fee expense.

In GBM, net fee income decreased by $0.8bn. This was driven by 
lower fee income from underwriting, in line with the reduction in the 
global fee pool. Fee income also decreased in credit facilities and in 
corporate finance, reflecting subdued client demand.

In CMB, net fee income increased by $0.1bn. Fee income grew in 
cards, as spending increased compared with 2021, and in account 
services, reflecting greater client activity in transaction banking, 
notably Global Payments Solutions (‘GPS’).

Net income from financial instruments held for trading or 
managed on a fair value basis of $10.5bn was $2.7bn higher 
compared with 2021. This primarily reflected a strong trading 
performance in Global Foreign Exchange due to increased client 
activity, driven by elevated levels of market volatility.

This was partly offset by adverse fair value movements on non-
qualifying hedges of $0.5bn. 

Net expense from assets and liabilities of insurance businesses, 
including related derivatives, measured at fair value through 
profit or loss of $3.4bn compared with a net income of $4.1bn in 
2021. This reduction primarily reflected unfavourable equity market 
performances in Hong Kong and France. This compared with 2021, 
which benefited from favourable equity markets.

This adverse movement resulted in a corresponding movement in 
liabilities to policyholders and the present value of in-force long-term 
insurance business (‘PVIF’) (see ‘Other operating income/expense’). 
This reflected the extent to which the policyholders and shareholders 
respectively participate in the investment performance of the 
associated assets.

Changes in fair value of other financial instruments mandatorily 
measured at fair value through profit or loss of $0.2bn was $0.6bn 
lower compared with 2021. This primarily reflected lower revaluation 
gains in our Principal Investments business in GBM.

Gains less losses from financial investments of $3m were $0.6bn 
lower compared with 2021, reflecting lower gains on the disposal of 
debt securities.

102

HSBC Holdings plc Annual Report and Accounts 2022

Net insurance premium income of $12.8bn was $2.0bn higher than 
in 2021, primarily reflecting higher sales volumes, particularly in Hong 
Kong, which had a higher proportion of single premium products in its 
product mix, as well as in Singapore following our acquisition of AXA 
Insurance Pte Limited.

Impairment loss relating to the sale of the retail banking 
operations in France was $2.4bn. In accordance with IFRS 5 ‘Non-
current Assets Held for Sale and Discontinued Operations’, the 
disposal group was classified as held for sale on 30 September 2022, 
at which point the Group recognised the estimated impairment of 
$2.4bn, which included impairment of goodwill of $0.4bn and related 
transaction costs.

Other operating income/expense was an expense of $0.1bn 
compared with an income of $0.5bn in 2021, and included an adverse 
impact from foreign currency translation differences of $0.4 bn. The 
reduction also reflected losses of $0.4bn related to the planned sales 
of our branch operations in Greece and our business in Russia, as well 
as the non-recurrence of a prior year gain on the sale of a property in 
Germany. These reductions were partly offset by a gain of $0.1bn on 
the completion of our acquisition of AXA Singapore and a favourable 
change in PVIF of $0.2bn. 

The favourable change in PVIF included a $0.2bn increase in the value 
of new business, notably in Hong Kong, a $0.5bn favourable impact 
from sharing lower investment returns with policyholders, and a 
$0.3bn gain following a pricing update for our policyholders’ funds 
held on deposit with us in Hong Kong to reflect the cost to provide 
this service. These factors were partly offset by a $0.7bn reduction 
from assumption changes, primarily reflecting the impact of higher 
interest rates in Hong Kong.

PVIF is presented in accordance with IFRS 4 ‘Insurance Contracts’. As 
set out on page 335, 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 $4.5bn lower, primarily in France and 
Hong Kong due to a reduction in returns on financial assets 
supporting contracts where the policyholder is subject to part or all of 
the investment risk. This was in part mitigated by higher sales 
volumes in Hong Kong.

Change in expected credit losses and other credit impairment 
charges (‘ECL’) were a charge of $3.6bn, compared with a net 
release of $0.9bn in 2021. 

The charges in 2022 reflected stage 3 charges of $2.2bn, in part 
relating to exposures to the commercial real estate sector in mainland 
China. We also recognised stage 1 and stage 2 charges in all global 
businesses, reflecting a deterioration in the macroeconomic 
environment, with many markets experiencing increased interest 
rates, continued inflation, supply chain risks and heightened 
recessionary risks. These economic conditions also contributed to the 
increase in stage 3 charges, mainly in CMB and GBM. These 
increases were in part mitigated by the release of most of our 
remaining Covid-19-related allowances.

The charge in 2022 compared with a net release in 2021, primarily 
relating to Covid-19-related allowances previously built up in 2020.

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 153 to 162.

Operating expenses – currency translation and significant items

Significant items
–  customer redress programmes
–  disposals, acquisitions and investment in new businesses
–  impairment of goodwill and other intangibles
–  restructuring and other related costs
–  currency translation on significant items
Currency translation
Year ended 31 Dec

Operating expenses

Gross employee compensation and benefits
Capitalised wages and salaries 
Goodwill impairment
Property and equipment
Amortisation and impairment of intangibles
UK bank levy1
Legal proceedings and regulatory matters
Other operating expenses2
Total operating expenses (reported)
Total significant items (including currency translation on significant items)
Currency translation
Total operating expenses (adjusted)

Year ended
2022
$m
2,864   
(31)   
18   
(4)   
2,881   

2,864   

Year ended
2022
$m
19,288 

(922)   
— 
5,005 
1,716 
13 
246 
7,984 
33,330 
(2,864)   

30,466 

2021
$m
2,335 
49 
— 
587 
1,836 
(137) 
2,181 
4,516 

2021
$m
19,612

(870) 
587
5,145
1,438
116
106
8,486
34,620
(2,335) 
(2,181) 
30,104

1   The UK bank levy charge for the year ended 2022 includes adjustments made to prior period UK bank levy charges recognised in the current year.
2   Other operating expenses includes professional fees, contractor costs, transaction taxes, marketing and travel. The decrease was driven by favourable 

currency translation movements, partly offset by higher costs related to our cost reduction programme. 

Staff numbers (full-time equivalents)1

Global businesses
Wealth and Personal Banking
Commercial Banking
Global Banking and Markets
Corporate Centre
At 31 Dec

2022

2021

2020

128,764   
43,640   
46,435   
360   
219,199   

130,185   
42,969   
46,166   
377   
219,697   

135,727 
43,221 
46,729 
382 
226,059 

1  Represents the number of full-time equivalent people with contracts of service with the Group who are being paid at the reporting date.

HSBC Holdings plc Annual Report and Accounts 2022

103

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial summary

Operating expenses of $33.3bn were $1.3bn or 4% lower than in 
2021, primarily as foreign currency translation differences resulted in 
a favourable impact of $2.2bn, and due to the non-recurrence of a 
2021 goodwill impairment of $0.6bn related to our WPB business in 
Latin America. 

Reported operating expenses also reflected the impact of ongoing 
cost discipline across the Group. This helped mitigate growth from 
increased investment in technology of $0.5bn, which included 
investments in our digital capabilities, the impact of business volume 
growth, and inflation. Restructuring and other related costs increased 
by $1.0bn. 

In 2022, cost to achieve spend, included within restructuring and 
other related costs, was $2.9bn. This three-year programme ended on 
31 December 2022 with a total spend of $6.5bn and cumulative gross 
saves realised of $5.6bn. We expect additional gross cost savings of 
approximately $1bn to be delivered in 2023 due to actions taken in 
2022. 

The number of employees expressed in full-time equivalent staff 
(‘FTE’) at 31 December 2022 was 219,199, a decrease of 498 
compared with 31 December 2021. The number of contractors at    
31 December 2022 was 6,047, a decrease of 145.

Share of profit in associates and joint ventures of $2.7bn was 
$0.3bn lower, primarily as 2021 included a higher share of profit from 
Business Growth Fund in the UK due to the recovery in asset 
valuations. This was partly offset by an increase in the share of profit 
from The Saudi British Bank.

In relation to Bank of Communications Co., Limited (‘BoCom’), we 
continue to be subject to a risk of impairment in the carrying value of 
our investment. We have performed an impairment test on the 
carrying amount of our investment and confirmed there was no 
impairment at 31 December 2022.

For more information, see Note 18: Interests in associates and joint 
ventures on page 379.

Tax expense

Reported tax charge
Currency translation 
Tax significant items
–  tax credit on significant items
–  recognition of losses
–  uncertain tax positions
–  currency translation
Adjusted tax charge

Year ended
2022
$m
858   

3,429   
1,118   
2,330   
(19)   

4,287   

2021
$m
4,213 
(279) 
307 
328 
(4) 
— 
(17) 
4,241 

Tax expense

The effective tax rate for 2022 of 4.9% was lower than the 22.3% in 
2021. Tax in 2022 included a $2.2bn credit arising from the 
recognition of a deferred tax asset from historical tax losses in HSBC 
Holdings, which was recognised as a significant item. This was a 
result of improved profit forecasts for the UK tax group, which 
accelerated the expected utilisation of these losses and reduced 
uncertainty regarding their recoverability. We also benefited from 
other deferred tax asset reassessments during 2022. Excluding these, 
the effective tax rate for 2022 was 19.2%, which was 3.1 percentage 
points lower than in 2021. The effective tax rate for 2022 was also 
decreased by the remeasurement of deferred tax balances following 
the substantive enactment in the first quarter of 2022 of legislation to 
reduce the rate of the UK banking surcharge from 8% to 3% from 
1 April 2023.
Supplementary table for planned 
disposals
The income statements and selected balance sheet metrics for the 
year ended 31 December 2022 of our banking business in Canada and 
our retail banking operations in France are shown below.

The asset and liability balances relating to these planned disposals are 
reported on the Group balance sheet within ‘Assets held for sale’ and 
‘Liabilities of disposal groups held for sale’, respectively, as at 
31 December 2022.

Income statement and selected balance sheet metrics of disposal 
groups held for sale

Year ended 2022

Revenue
ECL
Operating expenses3
Profit before tax

Loans and advances to customers
Customer accounts
RWA4

Canada1
$bn
1.9   
(0.1)   
(1.0)   
0.8   

55.2   
60.6   
31.9   

France 
retail2

$bn
0.6 
— 
(0.5) 
0.1 

25.0 
22.3 
5.0 

1   Under the terms of the sale agreement, the pre-tax profit on the sale 

will be recognised through a combination of the consolidation of HSBC 
Canada’s results into the Group’s financial statements from 30 June 
2022 until completion, and the remaining gain on sale recognised at 
completion.

2   France retail includes the transferring retail banking business, HSBC 
SFH and associated supporting services. For more information, see 
Note 23: Assets held for sale and liabilities of disposal groups held for 
sale on page 389.

3   Includes $0.3bn in Canada and $0.1bn in France retail in respect of 

Group recharges and other costs not transferring as part of the planned 
transactions.

4   Includes $3.0bn in Canada and $0.9bn in France retail in respect of 

operational risk RWAs.

104

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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
Derivatives
Loans and advances to banks
Loans and advances to customers
Reverse repurchase agreements – non-trading
Financial investments
Assets held for sale1
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 of disposal groups held for sale1
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

2022
$m

2021
$m

2020
$m

2019
$m

2018
$m

327,002   
218,093   

403,018   
248,842   

304,481   
231,990   

154,099   
254,271   

162,843 
238,130 

45,063   

49,804   

45,553   

43,627   

41,111 

284,146   
104,882   
924,854   
253,754   
425,564   
115,919   
267,253   
2,966,530   

66,722   
1,570,303   
127,747   
72,353   
127,327   
285,764   
78,149   
114,597   
114,844   
212,696   
2,770,502   

196,882   
83,136   
1,045,814   
241,648   
446,274   
3,411   
239,110   
2,957,939   

101,152   
1,710,574   
126,670   
84,904   
145,502   
191,064   
78,557   
9,005   
112,745   
190,989   
2,751,162   

307,726   
81,616   
1,037,987   
230,628   
490,693   
299   
253,191   
2,984,164   

82,080   
1,642,780   
111,901   
75,266   
157,439   
303,001   
95,492   
—   
107,191   
204,019   
2,779,169   

242,995   
69,203   
1,036,743   
240,862   
443,312   
123   
229,917   
2,715,152   

59,022   
1,439,115   
140,344   
83,170   
164,466   
239,497   
104,555   
—   
97,439   
194,876   
2,522,484   

187,484   
8,544   
196,028   
2,966,530   

198,250   
8,527   
206,777   
2,957,939   

196,443   
8,552   
204,995   
2,984,164   

183,955   
8,713   
192,668   
2,715,152   

207,825 
72,167 
981,696 
242,804 
407,433 
735 
203,380 
2,558,124 

56,331 
1,362,643 
165,884 
84,431 
148,505 
205,835 
85,342 
313 
87,330 
167,261 
2,363,875 

186,253 
7,996 
194,249 
2,558,124 

1   ‘Assets held for sale’ in 2021, including $2.4bn of loans and advances to customers in relation to our exit of mass market retail banking business in the 
US, were reported within ‘Other assets’ in the Annual Report and Accounts 2021. Similarly, $8.8bn of customer accounts classified as ‘Liabilities of 
disposal groups’ were previously presented within ‘Other liabilities’.

A more detailed consolidated balance sheet is contained in the financial statements on page 326.

HSBC Holdings plc Annual Report and Accounts 2022

105

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial summary

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: € 

2022
$m
10,147   
162,423   
1,967   
29,921   
839,720   
187,484   
(19,746)   
167,738   
(18,383)   
149,355   

58.9%
6.34%

8.50   
7.57   
7.51   
20,294   
19,739   

2021
$m
10,316   
177,786   
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   

2020
$m
10,347   
184,423   
1,970   
30,721   
857,520   
196,443   
(22,414)   
174,029   
(17,606)   
156,423   

63.2%
6.46%

8.62   
7.75   
7.72   
20,694   
20,184   

2019
$m
10,319   
172,150   
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   

2018
$m
10,180 
173,238 
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 

19,876   

20,189   

20,272   

20,280   

20,059 

0.830   
0.937   

0.739   
0.880   

0.732   
0.816   

0.756   
0.890   

0.783 
0.873 

1   Capital resources are regulatory total capital, the calculation of which is set out on page 205.
2   Including perpetual preferred securities, details of which can be found in Note 29: Subordinated liabilities on page 393.
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 shareholders’ 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. 

Combined view of customer lending and customer deposits

31 December 2021. The movement in this ratio reflected the 
reclassifications to held for sale mentioned above.

2022
$m

2021
$m

Assets

Combined customer lending
Loans and advances to customers
Loans and advances to customers of 
disposal groups reported in ‘Assets held 
for sale’
– Canada
– France retail banking operations
– other1
At 31 Dec
Combined customer deposits
Customer accounts
Customer accounts reported in ‘Liabilities 
of disposal groups held for sale’

– Canada
– France retail banking operations
– other1
At 31 Dec

924,854   

1,045,814 

80,576   

2,385 

55,197 
25,029 

350   
1,005,430   

2,385 
1,048,199 

1,570,303   

1,710,574 

85,274   

8,750 

60,606 
22,348 

2,320   
1,655,577   

8,750 
1,719,324 

1    At 31 December 2021, ‘other’ included loans and advances and 

customer accounts relating to the disposal of the US mass market 
retail banking business. This sale completed in February 2022.

Balance sheet commentary compared with 
31 December 2021

At 31 December 2022, total assets of $3.0tn, were broadly 
unchanged on a reported basis and increased by $161bn or 6% on a 
constant currency basis.

During the period, asset and liability balances mainly relating to the 
planned sales of our retail banking operations in France and our 
banking business in Canada were reclassified to ‘Assets held for sale’ 
and ‘Liabilities of disposal groups held for sale’. 

Reported loans and advances to customers as a percentage of 
customer accounts was 58.9%, compared with 61.1% at 

106

HSBC Holdings plc Annual Report and Accounts 2022

Cash and balances at central banks decreased by $76bn or 19%, 
which included a $32bn adverse impact of foreign currency translation 
differences. The decrease was mainly in the US, reflecting the 
redeployment of liquidity into reverse repurchase agreements, and 
also due to a reduction in customer accounts. In addition, lower 
balances in the UK primarily reflected growth in lending to customers 
and banks, on a constant currency basis.

Trading assets decreased by $31bn or 12%, reflecting a reduction in 
equity and debt securities held, particularly in Hong Kong and the UK, 
reflecting weaker client demand.

Derivative assets increased by $87bn or 44%, mainly in Europe, 
reflecting favourable revaluation movements on interest rate 
contracts due to movements in long-term yield curve rates in most 
major markets. Foreign exchange contracts also increased, primarily 
in the UK, as a result of foreign exchange rate movements. The 
increase in derivative assets was consistent with the increase in 
derivative liabilities, as the underlying risk is broadly matched.

Loans and advances to banks increased by $22bn or 26%, primarily 
reflecting increases in the UK and Hong Kong.

Loans and advances to customers of $925bn decreased by $121bn 
or 12% on a reported basis. This included the following items:

• adverse impacts of foreign currency translation differences of 

$55bn; and

• the reclassification of $81bn to ‘Assets held for sale’ primarily 
relating to the planned sales of our retail banking operations in 
France and our banking business in Canada in 2022, and $2bn in 
2021 primarily associated with the US mass market retail banking 
business sales which were disposed of during 2022.

On a constant currency basis and including balances classified as held 
for sale, loans and advances to customers increased by $12bn. This 
included the impact of the subsequent sale of US mass market retail 
balances that were held for sale at 31 December 2021 of $2bn with 
the remaining growth of $14bn reflecting the following movements.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In WPB, customer lending increased by $15bn, reflecting growth in 
mortgage balances, notably in the UK (up $9bn), Hong Kong (up $3bn) 
and Australia (up $2bn).

Derivative liabilities increased by $95bn or 50%, which is consistent 
with the increase in derivative assets, since the underlying risk is 
broadly matched.

In CMB, customer lending was $3bn higher from term lending 
increases in India, Australia and the US. Lending also increased in the 
UK, primarily in trade lending. This was partly offset by a reduction in 
term lending of $8bn in Hong Kong as customer demand for lending 
softened in the second half of 2022.

In GBM, lending fell by $3bn due to a reduction in Global Banking 
term lending in the fourth quarter of 2022, primarily in Hong Kong, 
partly offset by a growth in overdrafts balances in the UK.

Financial investments decreased by $21bn or 5%, mainly in Europe 
from the adverse impact of foreign currency translation differences 
since 31 December 2021. The reduction included adverse fair value 
movements recorded in ‘other comprehensive income’ in equity on 
debt securities, treasury and other eligible bills as a result of higher 
yield curves and wider macroeconomic pressures. It also included 
reductions due to disposals and maturity of these securities. The 
reductions were partly offset by increases in debt instruments 
measured at amortised cost, as we repositioned our portfolio to 
reduce capital volatility.

Assets held for sale of $116bn primarily comprised the assets 
relating to the planned sales of our retail banking operations in France 
and our banking business in Canada.

Other assets increased by $28bn, reflecting growth in cash collateral 
of $21bn due to an increase in the fair value of derivative liabilities. 

Liabilities

Deposits by banks decreased by $34bn or 34%, primarily in Europe, 
Hong Kong and the US.

Customer accounts of $1.6tn decreased by $140bn or 8% on a 
reported basis. This included the following items: 

• adverse impacts of foreign currency translation differences of 

$88bn; and

• the reclassification of $85bn to ‘Liabilities of disposal groups held 

for sale’ primarily relating to the planned sales of our retail banking 
operations in France and our banking business in Canada in 2022, 
and $9bn in 2021 primarily associated with the US mass market 
retail banking business which was disposed of during 2022.

On a constant currency basis and including balances classified as held 
for sale, customer accounts increased by $24bn. This included the 
impact of the subsequent sale of US mass market retail balances that 
were held for sale at 31 December 2021 of $9bn with the remaining 
growth of $33bn reflecting the following movements.

In GBM, customer accounts rose by $16bn. This was driven by 
growth in interest-bearing and term deposit balances as customers 
demonstrated a preference for higher yielding accounts as interest 
rates rose, notably in Europe.

In WPB, customer accounts grew by $17bn, reflecting higher interest-
bearing and term deposit balances, as interest rates rose, primarily in 
the UK and Asia. 

In CMB, customer accounts remained broadly stable, with reductions 
in Hong Kong, the US, and the UK, mitigated by growth in other Asia 
markets. 

Liabilities of disposal groups held for sale of $115bn primarily 
comprised the liabilities relating to the planned sales of our retail 
banking operations in France and our banking business in Canada.

Other liabilities increased by $22bn, notably from growth in cash 
collateral of $20bn, mainly due to the increase in fair value of 
derivative assets.

Equity

Total shareholders’ equity, including non-controlling interests, 
decreased by $11bn or 5% compared with 31 December 2021.

Profits generated of $17bn were offset by net losses through other 
comprehensive income (‘OCI’) of $17bn. In addition, shareholders’ 
equity fell as a result of dividends paid of $7bn, the redemption of 
perpetual subordinated contingent convertible capital securities of 
$3bn and the impact of our $1bn share buy-back announced at our 
2021 results in February 2022. 

The net losses in OCI of $17bn included adverse movements of $5bn 
on financial instruments designated as hold-to-collect-and-sell, which 
are held as hedges to our exposure to interest rate movements, as a 
result of the increase in term market yield curves in 2022. The net 
loss also included an adverse impact from foreign exchange 
differences of $10bn and losses of $4bn on cash flow hedges. These 
losses were partly offset by fair value gains on liabilities related to 
changes in own credit risk of $2bn.

In the earlier stages of a rising interest rate environment, the Group is 
positively exposed to rising interest rates through net interest income, 
although there is an impact on our capital base due to the fair value of 
hold-to-collect-and-sell instruments. These instruments are reported 
within ‘financial investments’. There is an initial negative effect 
materialising through reserves, after which the net interest income is 
expected to result in a net benefit for the Group over time, provided 
policy rates follow market implied rates.

Over time, these adverse OCI movements will unwind as the 
instruments reach maturity, although not all will necessarily be held to 
maturity.

Risk-weighted assets

Risk-weighted assets (‘RWAs’) totalled $839.7bn at 31 December 
2022, a $1.4bn increase since 2021. Excluding foreign currency 
translation differences of $41.9bn, RWAs rose by $43.3bn in 2022. 
This was mainly due to the following movements:

• a $20.9bn asset size increase, mostly caused by CMB and WPB 
lending growth in Europe and Asia, offset by reduced lending in 
GBM; and

• a $24.2bn increase in RWAs due to changes in methodology and 

policy. This was mostly due to regulatory changes, data 
enhancements driven by internal and external reviews of our 
regulatory reporting processes and the reversal of the beneficial 
changes to the treatment of software assets.

HSBC Holdings plc Annual Report and Accounts 2022

107

Financial reviewFinancial summary

Customer accounts by country/territory

Europe
–  UK
–  France1
–  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
–  Türkiye
–  Egypt
–  other
North America
–  US
–  Canada1
–  other
Latin America
–  Mexico
–  other
At 31 Dec

2022
$m
601,473   
493,028   
33,726   
28,949   
5,167   
40,603   
784,236   
542,543   
61,475   
56,948   
28,506   
22,636   
16,008   
15,316   
5,840   
34,964   
43,933   
23,331   
3,497   
6,045   
11,060   
109,093   
100,404   
—   
8,689   
31,568   
25,531   
6,037   
1,570,303   

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 
5,930 
1,710,574 

1   At 31 December 2022, customer accounts of $85bn met the criteria to be classified as held for sale and are reported within ‘Liabilities of disposal 
groups held for sale’ on the balance sheet, of which $61bn and $22bn belongs to the planned sales of the banking business in Canada and retail 
banking operations in France, respectively. Refer to Note 23 on page 389 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

USD
34,495   
182,719   
217,214   
23,133   
430,866   
453,999   

USD
21,474   
169,055   
190,529   
37,962   
453,864   
491,826   

GBP
12,292   
265,988   
278,280   
16,963   
422,087   
439,050   

GBP
3,991   
280,909   
284,900   
20,909   
463,232   
484,141   

At
31 Dec 2022
EUR
6,328   
57,077   
63,405   
8,830   
112,399   
121,229   

HKD
5,188   
221,150   
226,338   
4,002   
312,052   
316,054   

At
31 Dec 2021
EUR
3,970   
83,457   
87,427   
24,393   
133,604   
157,997   

HKD
524   
223,714   
224,238   
2,757   
318,702   
321,459   

CNY
7,833   
49,036   
56,869   
4,707   
63,032   
67,739   

CNY
6,545   
44,093   
50,638   
5,049   
65,052   
70,101   

Others1

38,746   
148,884   
187,630   
9,087   
229,867   
238,954   

Total
104,882 
924,854 
1,029,736 
66,722 
1,570,303 
1,637,025 

Others1
46,632   
244,586   
291,218   
10,082   
276,120   
286,202   

Total
83,136 
1,045,814 
1,128,950 
101,152 
1,710,574 
1,811,726 

1   ‘Others’ includes items with no currency information available ($1,519m for loans to banks (2021: $11,028m), $3,405m for loans to customers (2021: 

$64,491m), $13m for deposits by banks (2021: $23m) and $6m for customer accounts (2021: $5m)).

RWAs by currency

$m
RWAs1

$m
RWAs

USD
223,657   

GBP
143,474   

USD
216,664   

GBP
150,130   

At
31 Dec 2022
EUR
60,843   

HKD
152,804   

At
31 Dec 2021
EUR
67,934   

HKD
145,851   

CNY
49,867   

Others
209,075   

Total
839,720 

CNY
55,343   

Others
202,341   

Total
838,263 

1   RWAs of $840bn includes credit risk, market risk and operational risk RWAs.

108

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses and geographical regions
Contents

109

109

112

112

117

119

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

125

Analysis by country

.

Summary
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, Commercial 

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 360. 

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 117 and an adjusted basis on page 119.

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
–  disposals, acquisitions and investment in new businesses2
–  fair value movements on financial instruments3
–  restructuring and other related costs4
Adjusted 
ECL
Reported 
Adjusted
Operating expenses
Reported 
Significant items
–  customer redress programmes
–  disposals, acquisitions and investment in new businesses
–  impairment of goodwill and other intangibles
–  restructuring and other related costs
Adjusted 
Share of profit/(loss) in associates and joint ventures
Reported 
Adjusted
Profit/(loss) 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

2022

Global
Banking and
Markets

Corporate 
Centre

$m

$m

$m

$m

22,197   
2,170   
(10)   
2,274   
5   
(99)   
24,367   

(1,137)   
(1,137)   

(15,049)   
323   
(37)   
2   
—   
358   
(14,726)   

29   
29   

6,040   
2,493   
2,170   
323   
8,533   

16,197   
18   
2   
—   
2   
14   
16,215   

(1,858)   
(1,858)   

(6,893)   
251   
—   
—   
(13)   
264   
(6,642)   

1   
1   

7,447   
269   
18   
251   
7,716   

423,553   
423,553   

308,094   
308,094   

779,310   
779,310   

458,714   
458,714   

15,267   
92   
—   
—   
(93)   
185   
15,359   

(587)   
(587)   

(9,579)   
254   
—   
—   
—   
254   
(9,325)   

(1,934)   
1,338   
—   
525   
665   
148   
(596)   

(10)   
(10)   

(1,809)   
2,036   
6   
16   
9   
2,005   
227   

(2)   
(2)   

2,695   
2,695   

5,099   
346   
92   
254   
5,445   

192,852   
192,852   

331,844   
331,844   

(1,058)   
3,374   
1,338   
2,036   
2,316   

355   
355   

435   
435   

Total

$m

51,727 
3,618 
(8) 
2,799 
579 
248 
55,345 

(3,592) 
(3,592) 

(33,330) 
2,864 
(31) 
18 
(4) 
2,881 
(30,466) 

2,723 
2,723 

17,528 
6,482 
3,618 
2,864 
24,010 

924,854 
924,854 

1,570,303 
1,570,303 

1   Net operating income/(expense) before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2   Includes losses from classifying businesses as held for sale as part of a broader restructuring of our European business, of which $2.4bn relates to the 

planned sale of our retail banking operations in France.
Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives. 

3 
4  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.

HSBC Holdings plc Annual Report and Accounts 2022

109

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses

Reconciliation of reported and adjusted items (continued)

Revenue1
Reported 
Currency translation
Significant items
–  customer redress programmes
–  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
–  restructuring and other related costs
–  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 

Wealth and 
Personal 
Banking

Commercial
Banking

2021

Global
Banking and
Markets

$m

$m

$m

Corporate 
Centre

$m

22,117   
(1,152)   
(2)   
7   
—   
(14)   
5   
20,963   

288   
(75)   
213   

(16,306)   
914   
903   
39   
587   
296   
(19)   
(14,489)   

34   
—   
34   

6,133   
(313)   
901   
(2)   
903   
6,721   

488,786   
(27,739)   
461,047   

859,029   
(39,710)   
819,319   

13,431   
(885)   
(8)   
(18)   
(1)   
3   
8   
12,538   

300   
(75)   
225   

(7,055)   
429   
72   
1   
—   
81   
(10)   
(6,554)   

1   
—   
1   

6,677   
(531)   
64   
(8)   
72   
6,210   

349,126   
(18,443)   
330,683   

506,688   
(26,487)   
480,201   

14,588   
(987)   
381   
—   
19   
395   
(33)   
13,982   

337   
(24)   
313   

(10,203)   
781   
172   
—   
—   
197   
(25)   
(9,250)   

—   
—   
—   

4,722   
(230)   
553   
381   
172   
5,045   

207,162   
(8,383)   
198,779   

344,205   
(21,770)   
322,435   

(584)   
(50)   
171   
—   
224   
(77)   
24   
(463)   

3   
—   
3   

(1,056)   
57   
1,188   
9   
—   
1,262   
(83)   
189   

3,011   
(113)   
2,898   

1,374   
(106)   
1,359   
171   
1,188   
2,627   

740   
(52)   
688   

652   
(60)   
592   

Total

$m

49,552 
(3,074) 
542 
(11) 
242 
307 
4 
47,020 

928 
(174) 
754 

(34,620) 
2,181 
2,335 
49 
587 
1,836 
(137) 
(30,104) 

3,046 
(113) 
2,933 

18,906 
(1,180) 
2,877 
542 
2,335 
20,603 

1,045,814 
(54,617) 
991,197 

1,710,574 
(88,027) 
1,622,547 

1  Net operating income/(expense) before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.

Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives.

110

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 costs4
–  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
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 

Wealth and 
Personal 
Banking

Commercial
Banking

2020

Global
Banking and
Markets

Corporate 
Centre

$m

$m

$m

$m

21,999   
(532)   
14   
5   
9   
—   
—   
—   
21,481   

(2,855)   
(23)   
(2,878)   

(15,446)   
498   
412   
(64)   
294   
—   
192   

—   

(10)   
(14,536)   

6   
—   
—   
—   
—   
6   

3,704   
(57)   
426   
14   
412   
—   
4,073   

469,186   
(33,081)   
436,105   

834,759   
(46,716)   
788,043   

13,294   
(423)   
18   
16   
—   
1   
1   
—   
12,889   

(4,754)   
44   
(4,710)   

(6,900)   
230   
195   
1   
45   
—   
165   

—   

(16)   
(6,475)   

(1)   
—   
—   
—   
—   
(1)   

1,639   
(149)   
213   
18   
195   
—   
1,703   

343,182   
(23,098)   
320,084   

470,428   
(30,539)   
439,889   

14,994   
(581)   
283   
—   
—   
2   
307   
(26)   
14,696   

(1,209)   
(18)   
(1,227)   

(10,169)   
400   
874   
—   
577   
—   
326   

2   

(31)   
(8,895)   

—   
—   
—   
—   
—   
—   

3,616   
(199)   
1,157   
283   
874   
—   
4,574   

224,364   
(12,854)   
211,510   

336,983   
(26,226)   
310,757   

Total

$m

50,429 
(1,523) 
(58) 
21 
10 
(264) 
170 
5 
48,848 

(8,817) 
2 
(8,815) 

(34,432) 
1,170 
2,817 
(54) 
1,090 
17 
1,908 

12 

(156) 
(30,445) 

1,597 
48 
462 
462 
— 
2,107 

8,777 
(303) 
3,221 
(58) 
2,817 
462 
11,695 

1,037,987 
(69,137) 
968,850 

142   
13   
(373)   
—   
1   
(267)   
(138)   
31   
(218)   

1   
(1)   
—   

(1,917)   
42   
1,336   
9   
174   
17   
1,225   

10   

(99)   
(539)   

1,592   
48   
462   
462   
—   
2,102   

(182)   
102   
1,425   
(373)   
1,336   
462   
1,345   

1,255   
(104)   
1,151   

610   
(70)   
540   

1,642,780 
(103,551) 
1,539,229 

Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives.

1  Net operating income/(expense) before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3   Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.
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 2022

111

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses

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 2022

Global
Banking and
Markets

Corporate 
Centre

$bn

$bn

$bn

$bn

182.9   
182.9   

334.8   
334.8   

233.5   
233.5   

88.5   
88.5   

At 31 Dec 2021

178.3   
(8.2)   
170.1   

332.9   
(19.6)   
313.3   

236.2   
(9.3)   
226.9   

At 31 Dec 2020

172.8   
(10.2)   
162.6   

327.7   
(24.2)   
303.5   

265.1   
(13.5)   
251.6   

90.9   
(1.6)   
89.3   

91.9   
(2.7)   
89.2   

Total

$bn

839.7 
839.7 

838.3 
(38.7) 
799.6 

857.5 
(50.6) 
806.9 

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)

2022
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

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 expenses
Operating profit
Share of profit in associates and joint ventures
Profit before tax

Consists of1

Total 
WPB

$m

Banking 
operations

Insurance 
manufacturing

$m

$m

Global 
Private 
Banking

$m

Asset 
management

$m

24,367   

18,137   
5,030   
1,200   
(1,137)   
23,230   
(14,726)   
8,504   
29   
8,533   

20,963   

13,458   
5,649   
1,856   
213   
21,176   
(14,489)   
6,687   
34   
6,721   

19,342   

14,791   
3,848   
703   
(1,114)   
18,228   
(11,624)   
6,604   
11   
6,615   

15,519   

10,585   
4,236   
698   
219   
15,738   
(11,660)   
4,078   
17   
4,095   

1,914   

2,406   
(701)   
209   
(17)   
1,897   
(879)   
1,018   
18   
1,036   

2,547   

2,255   
(599)   
891   
(18)   
2,529   
(564)   
1,965   
17   
1,982   

1,978   

946   
776   
256   
(5)   
1,973   
(1,399)   
574   
—   
574   

1,746   

620   
901   
225   
13   
1,759   
(1,491)   
268   
—   
268   

1,133 

(6) 
1,107 
32 
(1) 
1,132 
(824) 
308 
— 
308 

1,151 

(2) 
1,111 
42 
(1) 
1,150 
(774) 
376 
— 
376 

112

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
WPB – summary (adjusted basis) (continued)

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
$m

Insurance 
manufacturing
$m

Global Private 
Banking

Asset 
management

$m

$m

21,481   

14,752   
5,306   
1,423   
(2,878)   
18,603   
(14,536)   
4,067   
6   
4,073   

16,925   

11,904   
4,027   
994   
(2,746)   
14,179   
(12,010)   
2,169   
6   
2,175   

1,834   

2,189   
(505)   
150   
(63)   
1,771   
(463)   
1,308   
—   
1,308   

1,712   

661   
813   
238   
(68)   
1,644   
(1,359)   
285   
—   
285   

1,010 

(2) 
971 
41 
(1) 
1,009 
(704) 
305 
— 
305 

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 may differ from 
the WPB Life insurance manufacturing revenue shown in the managed view of adjusted revenue on page 32, which excludes the impact of Argentina 
hyperinflation.

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 the adoption of IFRS 17 ‘Insurance Contracts’, 
effective from 1 January 2023. Further information about the adoption 
of IFRS 17 is provided on page 99.

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
Change in expected credit losses and other credit impairment charges
Net operating income
Total operating expenses
Operating profit
Share of profit in associates and joint ventures
Profit before tax of insurance manufacturing operations4
Annualised new business premiums of insurance manufacturing operations
Insurance distribution income earned by HSBC bank channels

2022

2021

2020

All global 
businesses

WPB

All global 
businesses

WPB

$m  
2,406   
(701)   
140   
(841)   

$m
2,595   
(724)   
159   
(883)   

$m
2,255   
(599)   
100   
(699)   

$m
2,430   
(629)   
123   
(752)   

WPB

$m
2,189   
(505)   
108   
(613)   

All global 
businesses

$m
2,352 
(541) 
129 
(670) 

95   

94   

(4)   

(12)   

60   

76 

(3,411)   

(12)   
12,413   
504   
369   
11,294   

(3,413)   

3,867   

3,903   

1,903   

(12)   
12,942   
453   
324   
11,935   

85   
10,145   
164   
76   
15,913   

89   
10,617   
148   
69   
16,546   

12   
9,522   
329   
365   
13,510   

1,853 

12 
10,005 
342 
377 
14,100 

(9,380)   

(9,929)   

(13,366)   

(13,863)   

(11,676)   

(12,166) 

1,914   

(17)   
1,897   
(879)   
1,018   
18   
1,036   
2,295   
764   

2,006   

(18)   
1,988   
(918)   
1,070   
18   
1,088   
2,354   
823   

2,547   

(18)   
2,529   
(564)   
1,965   
17   
1,982   
2,777   
726   

2,683   

(22)   
2,661   
(590)   
2,071   
17   
2,088   
2,830   
795   

1,834   

(63)   
1,771   
(463)   
1,308   
—   
1,308   
2,272   
718   

1,934 

(72) 
1,862 
(492) 
1,370 
— 
1,370 
2,333 
781 

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 2021: $53m unfavourable (reported: $2,141m), 2020: $7m unfavourable (reported: $1,377m).
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 a decrease in adjusted revenue in 

2022 of $3m (2021: increase of $6m, 2020: increase of $1m) and a decrease in profit before tax in 2022 of $2m (2021: increase of $5m, 2020: 
increase of $13m). These effects are recorded within ‘All global businesses’.

HSBC Holdings plc Annual Report and Accounts 2022

113

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses

Insurance manufacturing

The following commentary, unless otherwise specified, relates to the 
‘All global businesses’ results.

HSBC recognises the present value of long-term in-force insurance 
contracts and investment contracts with discretionary participation 
features (‘PVIF’) as an asset on the balance sheet. The overall balance 
sheet equity, including PVIF, is therefore a measure of the embedded 
value in the insurance manufacturing entities, and the movement in 
this embedded value in the period drives the overall income 
statement result.

Adjusted profit before tax of $1.1bn decreased by $1.0bn or 48% 
compared with 2021.

Adjusted net operating income before change in expected credit 
losses and other credit impairment changes was $2.0bn or 25% 
lower than in 2021. This reflected the following: 

•

‘Net expense from assets and liabilities of insurance businesses, 
including related derivatives, measured at fair value through profit 
or loss’ of $3.4bn in 2022 compared with a net income of $3.9bn 
in 2021. This decrease primarily reflected unfavourable equity 
market performance impacting our Hong Kong and France 
businesses in 2022, compared with favourable market 
performances in 2021.

• This unfavourable 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 $12.9bn was $2.3bn higher 

than in 2021, primarily reflecting higher sales volumes, particularly 
in Hong Kong which had a higher proportion of single premium 
products in its product mix, and in Singapore following the 
acquisition of AXA Insurance Pte Limited (‘AXA Singapore‘) during 
2022.

WPB: Wealth adjusted revenue by geography

• Other operating income of $0.5bn increased by $0.3bn compared 
with 2021. This reflected increases in Hong Kong of $0.2bn from 
the value of new business, a $0.5bn favourable impact from 
sharing lower investment returns with policyholders, a $0.3bn one-
off gain from a pricing update for policyholder funds held on 
deposit with us in Hong Kong to reflect the cost of provision of 
these services, and a $0.1bn gain on completion of our acquisition 
of AXA Singapore in 2022. These were partly offset by a $0.7bn 
reduction from PVIF assumption changes primarily in Hong Kong, 
reflecting the impact of higher interest rates.

• Net insurance claims and benefits paid and movement in liabilities 
to policyholders of $9.9bn were $3.9bn lower, primarily due to a 
decline in returns on financial assets supporting contracts where 
the policyholder is subject to part or all of the investment risk, 
mainly in France and Hong Kong. It also reflected higher sales 
volumes in Hong Kong.

Total operating expenses of $0.9bn increased by $0.3bn compared 
with 2021, reflecting the incorporation of the results of AXA 
Singapore in 2022 and investment in our Pinnacle proposition in 
mainland China.

Annualised new business premiums (‘ANP’) is used to assess new 
insurance premium generation by the business. It is calculated as 
100% of annualised first year regular premiums and 10% of single 
premiums, before reinsurance ceded. Lower ANP in the year mainly 
reflect a change in product mix in Hong Kong towards single premium 
new business, partially offset by higher ANP from business growth in 
mainland China and the inclusion of the results of AXA Singapore.

Insurance distribution income from HSBC channels included $503m 
(2021: $469m; 2020: $460m) from HSBC manufactured products, for 
which a corresponding fee expense is recognised within insurance 
manufacturing, and $320m (2021: $326m; 2020: $321m) from 
products manufactured by third-party providers. The WPB component 
of this distribution income was $461m (2021: $417m; 2020: $413m) 
from HSBC manufactured products and $303m (2021: $309m; 2020: 
$305m) from third-party products.

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

2022
$m
2,456   
4,549   
198   
581   
307   
8,091   

2021
$m
2,152   
5,701   
165   
522   
243   
8,783   

2020
$m
1,666 
5,199 
148 
513 
211 
7,737 

114

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
WPB: Wealth balances

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. 

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

2022
$bn
312   
57   
255   
364   
198   
166   
340   
1,016   
503   
1,519   

2021
$bn
351 
67 
284 
434 
229 
205 
334 
1,119 
551 
1,670 

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. At 31 December 2022, $31bn of invested assets were classified as held for sale and are not included in the table above.

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 $779bn (2021: $859bn) on page 109. At 31 December 2022, $42bn of wealth deposits were classified as held for sale and are not included 
in the table above.

Asset Management: funds under management

The following table shows the funds under management of our Asset 
Management business. Funds under management represents assets 
managed, either actively or passively, on behalf of our customers. 

Asset Management – reported funds under management1

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

2022
$bn
630   
45   
(36)   
(44)   
595   

2022
$bn
327   
196   
2   
60   
10   
595   

2021
$bn
602 
27 
18 
(17) 
630 

2021
$bn
367 
180 
5 
69 
9 
630 

1    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.

At 31 December 2022, Asset Management funds under management 
amounted to $595bn, a decrease of $35bn or 6%. The decrease 
reflected adverse market performance and foreign exchange 
translation, which more than offset strong net new invested assets of 
$45bn received in 2022. Within ‘foreign exchange and others’ is a 
$14bn reduction related to the reclassification to held for sale of our 
banking operations in Canada, which we continue to manage but are 
no longer considered part of our core funds under management. This 
was partly offset by an increase of $9bn due to the acquisition of L&T 
Investment Management. Net new invested assets were notably 
from additions in passive, private equity and money market products.

Global Private Banking – reported client assets2

Opening balance
Net new invested assets
Increase/(decrease) in deposits
Net market movements
Foreign exchange and others
Closing Balance

Global Private Banking: client assets1

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.

2022
$bn
423   
18   
(1)   
(53)   
(4)   
383   

2021
$bn
394 
19 
4 
17 
(11) 
423 

HSBC Holdings plc Annual Report and Accounts 2022

115

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global businesses

Global Private Banking – reported client assets by geography

Europe 
Asia 
North America
Closing balance

2022
$bn
153   
174   
56   
383   

2021
$bn
174 
178 
71 
423 

1    Client assets are translated at the rates of exchange applicable for their respective period-ends, with the effects of currency translation reported 

separately.

2  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. 

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

2022
$bn
434   
26   
(46)   
(50)   
364   

2022
$bn

54   
285   
5   
12   
8   
364   

2021
$bn
407 
26 
5 
(4) 
434 

2021
$bn
81 
293 
4 
47 
9 
434 

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 are 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

116

HSBC Holdings plc Annual Report and Accounts 2022

2022
$bn
1,119   
80   
(116)   
(67)   
1,016   

2022
$bn

13   
59   
—   
7   
1   
80   

2021
$bn
1,050 
64 
33 
(28) 
1,119 

2021
$bn
17 
36 
— 
10 
1 
64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
GBM: Securities Services and Issuer 
Services

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 2022, we held $9.1tn of assets 
as custodian, a reduction of 15% compared with 31 December 2021. 
The balance comprised $8.4tn of assets in Securities Services, which 
were recorded at market value, and $0.8tn of assets in Issuer 
Services, recorded at book value. 

Assets under administration

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 2022, the value of assets held under 
administration by the Group amounted to $4.5tn, which was 9% 
lower than at 31 December 2021. The balance comprised $2.6tn of 
assets in Securities Services, which were recorded at market value, 
and $1.8tn of assets in Issuer Services, recorded at book value. 

The decrease was mainly driven by Securities Services balances due 
to an adverse impact of currency translation differences in Europe, a 
net outflow of assets, mainly in Asia and Europe, and adverse market 
movements in Europe and Asia. These decreases were partly offset 
by an inflow of assets from new customers in Europe.

The reduction was mainly in Securities Services balances. This was 
driven by an adverse impact of currency translation differences in 
Europe and Asia, and adverse market movements, notably impacting 
Asia and the US. In addition, there was a net outflow of assets in Asia 
and Europe.
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

Net operating income 
Total operating expenses excluding impairment of goodwill and 
other intangible assets
Impairment of goodwill and other intangible assets
Operating profit/(loss)
Share of profit/(loss) in associates and joint ventures
Profit/(loss) before tax

Share of HSBC’s profit before tax
Cost efficiency ratio 
Balance sheet data
Loans and advances to customers (net)
Total assets 
Customer accounts
Risk-weighted assets3

Europe

Asia

MENA

2022

North 
America

Latin 

America Intra-HSBC

$m
7,185   
3,554   

$m
16,157   
4,695   

$m
1,665   
830   

$m
3,395   
1,824   

$m
2,754   
547   

$m
1,454   
1   

Total

$m
32,610 
11,451 

3,242   

5,329   

578   

587   

756   

(23)   

10,469 

(1,760)   

(1,683)   

1,639   

3,046   

4   

4,297   

(138)   

—   

2   

—   

48   

1   

(3,394) 

(8)   

630   

20   

(317)   

(1,431)   

(7,153)   

226 

365 

16,906   

28,799   

2,937   

6,428   

3,808   

(7,151)   

51,727 

(857)   

(2,089)   

8   

(93)   

(561)   

—   

(3,592) 

16,049   

26,710   

2,945   

6,335   

3,247   

(7,151)   

48,135 

(16,370)   

(15,343)   

(1,582)   

(4,639)   

(2,401)   

7,152   

(33,183) 

(52)   
11,315   
2,409   
13,724   

(54)   
(375)   
(40)   
(415)   
%
(2.4)
97.1
$m
343,670   

%
78.3
53.5
$m
475,278   
  1,345,971    1,316,876   
784,236   
409,320   

601,473   
251,195   

(5)   
1,358   
342   
1,700   
%
9.7
54.0
$m
26,475   
70,755   
43,933   
60,946   

(30)   
1,666   
—   
1,666   
%
9.5
72.6
$m
55,790   
341,125   
109,093   
106,546   

(5)   
841   
12   
853   
%
4.9
63.2
$m
23,641   
51,708   
31,568   
38,904 

(1)   
—   
—   
—   

(147) 
14,805 
2,723 
17,528 
%
100.0
64.4
$m
924,854 
(159,905)    2,966,530 
—    1,570,303 
839,720 

—   

$m

HSBC Holdings plc Annual Report and Accounts 2022

117

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

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 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
Net operating income 
Total operating expenses excluding impairment of goodwill and 
other intangible assets
Impairment of goodwill and other intangible assets
Operating profit/(loss)
Share of profit/(loss) in associates and joint ventures
Profit/(loss) before tax

Share of HSBC’s profit before tax
Cost efficiency ratio 
Balance sheet data
Loans and advances to customers (net)
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/(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
Net operating income 
Total operating expenses excluding impairment of goodwill and 
other intangible assets
Impairment of goodwill and other intangible assets
Operating profit/(loss)
Share of profit in associates and joint ventures
Profit/(loss) before tax

Share of HSBC’s profit before tax
Cost efficiency ratio 
Balance sheet data
Loans and advances to customers (net)
Total assets 
Customer accounts
Risk-weighted assets3

Europe
$m

Asia
$m

MENA
$m

2021

North 
America
$m

Latin 
America
$m

Intra-HSBC 
items
$m

6,454   
3,882   

12,596   
5,871   

1,299   
774   

2,845   
2,056   

2,195   
514   

1,100   
—   

Total
$m

26,489 
13,097 

2,602   

3,643   

431   

426   

476   

166   

7,744 

1,670   

2,340   

1,973   

3,523   

(3)   

1,316   

—   

(3)   

59   

—   

45   

(2)   

4,053 

54   

673   

40   

(212)   

(1,263)   

798 

(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 

21,705   

24,923   

2,692   

6,292   

2,855   

(7,987)   

50,480 

(18,099)   

(15,136)   

(1,536)   

(4,905)   

(2,198)   

7,987   

(33,887) 

(95)   
3,511   
268   
3,779   
%
20.0
90.5
$m

(24)   
9,763   
2,486   
12,249   
%
64.8
58.8
$m

397,090   

492,525   
  1,354,483    1,261,707   
792,098   
396,206   

667,769   
261,115   

(8)   
1,148   
275   
1,423   
%
7.5
60.3
$m
26,375   
70,974   
42,629   
60,223   

(13)   
1,374   
—   
1,374   
%
7.3
81.2
$m

108,717   
362,150   
178,565   
110,412   

2020

(593)   
64   
17   
81   
%
0.4
91.3
$m
21,107   
46,602   
29,513   
35,915   

—   
—   
—   
—   

(733) 
15,860 
3,046 
18,906 
%
100.0
69.9
$m
$m
—    1,045,814 
(137,977)    2,957,939 
—    1,710,574 
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 

3,266   

4,273   

402   

997   

593   

51   

9,582 

327   

1,699   

1,747   

3,885   

17   

1,197   

—   

3   

63   

—   

55   

—   

2,081 

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) 

14,668   

24,638   

1,870   

5,475   

1,896   

(6,935)   

41,612 

(17,860)   

(13,584)   

(1,521)   

(5,081)   

(1,933)   

6,935   

(33,044) 

(1,014)   
(4,206)   
1   
(4,205)   
%
 (47.9) 
 102.5 
$m

(78)   
10,976   
1,856   
12,832   

%
 146.2 
 50.7 
$m

408,495   

473,165   
  1,416,111    1,206,404   
762,406   
384,228   

629,647   
284,322   

(65)   
284   
(265)   
19   
%
 0.2 
 60.4 
$m
28,700   
68,860   
41,221   
60,181   

(226)   
168   
—   
168   
%
 1.9 
 83.2 
$m

107,969   
373,167   
182,028   
117,755   

(5)   
(42)   
5   
(37)   
%
 (0.4) 
 64.2 
$m
19,658   
49,703   
27,478   
35,240   

—   
—   
—   
—   

(1,388) 
7,180 
1,597 
8,777 
%
 100.0 
 68.3 
$m
$m
—    1,037,987 
(130,081)    2,984,164 
—    1,642,780 
857,520 
—   

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.

118

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items – geographical regions

Reconciliation of reported and adjusted items

Revenue1
Reported2
Significant items2
–  customer redress programmes
–  disposals, acquisitions and investment in new businesses3
–  fair value movements on financial instruments4
–  restructuring and other related costs2,5
Adjusted2
ECL
Reported 
Adjusted
Operating expenses
Reported2
Significant items2
–  customer redress programmes
–  disposals, acquisitions and investment in new businesses
–  impairment of goodwill and other intangibles
–  restructuring and other related costs2
Adjusted2
Share of profit/(loss) in associates and joint ventures
Reported 
Adjusted
Profit/(loss) before tax
Reported
Significant items
–  revenue2
–  operating expenses2
Adjusted
Loans and advances to customers (net)
Reported
Adjusted 
Customer accounts
Reported
Adjusted 

2022

Europe

$m

Asia

$m

MENA

$m

North
America

Latin
America

$m

$m

16,906   
3,065   
(8)   
2,799   
562   
(288)   
19,971   

28,799   
(223)   
—   
—   
22   
(245)   
28,576   

2,937   
9   
—   
—   
(3)   
12   
2,946   

6,428   
(108)   
—   
—   
(3)   
(105)   
6,320   

3,808   
15   
—   
—   
1   
14   
3,823   

Total

$m

51,727 
3,618 
(8) 
2,799 
579 
248 
55,345 

(857)   
(857)   

(2,089)   
(2,089)   

8   
8   

(93)   
(93)   

(561)   
(561)   

(3,592) 
(3,592) 

(16,424)   
2,119   
(31)   
18   
(4)   
2,136   
(14,305)   

(15,395)   
833   
—   
—   
—   
833   
(14,562)   

(1,587)   
73   
—   
—   
—   
73   
(1,514)   

(4,669)   
544   
—   
—   
—   
544   
(4,125)   

(2,406)   
155   
—   
—   
—   
155   
(2,251)   

(33,330) 
2,864 
(31) 
18 
(4) 
2,881 
(30,466) 

(40)   
(40)   

2,409   
2,409   

342   
342   

—   
—   

12   
12   

2,723 
2,723 

(415)   
5,184   
3,065   
2,119   
4,769   

13,724   
610   
(223)   
833   
14,334   

1,700   
82   
9   
73   
1,782   

1,666   
436   
(108)   
544   
2,102   

853   
170   
15   
155   
1,023   

17,528 
6,482 
3,618 
2,864 
24,010 

  343,670    475,278   
  343,670    475,278   

26,475   
26,475   

55,790   
55,790   

23,641   
23,641   

924,854 
924,854 

  601,473    784,236   
  601,473    784,236   

43,933    109,093   
43,933    109,093   

31,568    1,570,303 
31,568    1,570,303 

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 losses from classifying businesses as held for sale as part of a broader restructuring of our European business, of which $2.4bn relates to the 

planned sale of our retail banking operations in France.
Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives.

4 
5  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.

HSBC Holdings plc Annual Report and Accounts 2022

119

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items (continued)

Revenue1
Reported
Significant items
–  customer redress programmes
–  disposals, acquisitions and investment in new businesses
–  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/(loss) 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 

2022
Mainland 
China

$m

Hong 
Kong

$m

US

$m

Mexico

$m

16,155   
163   
—   
—   
39   
124   
16,318   

4,246   
(73)   
—   
—   
(1)   
(72)   
4,173   

4,107   
(99)   
—   
—   
(1)   
(98)   
4,008   

2,749 
19 
— 
— 
1 
18 
2,768 

UK

$m

17,353   
215   
(8)   
60   
571   
(408)   
17,568   

(712)   
(712)   

(1,680)   
(1,680)   

(328)   
(328)   

(20)   
(20)   

(507) 
(507) 

(13,224)   
1,710   
(31)   
1,741   
(11,514)   

(8,275)   
393   
—   
393   
(7,882)   

(2,906)   
70   
—   
70   
(2,836)   

(3,438)   
423   
—   
423   
(3,015)   

(1,642) 
115 
— 
115 
(1,527) 

(41)   
(41)   

3,376   
1,925   
215   
1,710   
5,301   

5   
5   

2,386   
2,386   

6,205   
556   
163   
393   
6,761   

3,398   
(3)   
(73)   
70   
3,395   

—   
—   

649   
324   
(99)   
423   
973   

12 
12 

612 
134 
19 
115 
746 

286,032   
286,032   

295,873   
295,873   

50,481   
50,481   

54,159   
54,159   

20,446 
20,446 

493,028   
493,028   

542,543   
542,543   

56,948   
56,948   

100,404   
100,404   

25,531 
25,531 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2   Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives.
3   Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.

120

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of reported and adjusted items (continued)

Revenue1
Reported2
Currency translation2
Significant items2
–  customer redress programmes
–  fair value movements on financial instruments3
–  restructuring and other related costs2,4
–  currency translation on significant items2
Adjusted2 
ECL
Reported 
Currency translation
Adjusted
Operating expenses
Reported 2
Currency translation2
Significant items2
–  customer redress programmes
–  impairment of goodwill and other intangibles
–  restructuring and other related costs2
–  currency translation on significant items2
Adjusted2 
Share of profit in associates and joint ventures
Reported 
Currency translation
Adjusted
Profit before tax
Reported
Currency translation
Significant items
–  revenue2 
–  operating expenses2
Adjusted
Loans and advances to customers (net)
Reported
Currency translation
Adjusted 
Customer accounts
Reported
Currency translation
Adjusted 

2021

Europe

$m

Asia

$m

MENA

$m

North
America

Latin
America

$m

$m

20,104   
(2,096)   
138   
(11)   
226   
(90)   
13   
18,146   

1,601   
(177)   
1,424   

(18,194)   
1,645   
1,234   
49   
—   
1,318   
(133)   
(15,315)   

25,763   
(769)   
(154)   
—   
11   
(175)   
10   
24,840   

(840)   
19   
(821)   

(15,160)   
490   
492   
—   
—   
509   
(17)   
(14,178)   

268   
(23)   
245   

2,486   
(90)   
2,396   

3,779   
(651)   
1,372   
138   
1,234   
4,500   

12,249   
(350)   
338   
(154)   
492   
12,237   

2,560   
(224)   
(1)   
—   
—   
—   
(1)   
2,335   

132   
(1)   
131   

(1,544)   
109   
51   
—   
—   
56   
(5)   
(1,384)   

275   
—   
275   

1,423   
(116)   
50   
(1)   
51   
1,357   

6,054   
(70)   
10   
—   
5   
5   
—   
5,994   

238   
(1)   
237   

(4,918)   
43   
429   
—   
—   
432   
(3)   
(4,446)   

—   
—   
—   

1,374   
(28)   
439   
10   
429   
1,785   

3,058   
(148)   
5   
—   
—   
5   
—   
2,915   

(203)   
(14)   
(217)   

(2,791)   
127   
673   
—   
587   
83   
3   
(1,991)   

17   
—   
17   

81   
(35)   
678   
5   
673   
724   

Total

$m

49,552 
(3,074) 
542 
(11) 
242 
307 
4 
47,020 

928 
(174) 
754 

(34,620) 
2,181 
2,335 
49 
587 
1,836 
(137) 
(30,104) 

3,046 
(113) 
2,933 

18,906 
(1,180) 
2,877 
542 
2,335 
20,603 

  397,090    492,525   
(11,301)   
  358,391    481,224   

(38,699)   

26,375    108,717   
(3,572)   
(1,395)   
24,980    105,145   

21,107    1,045,814 
(54,617) 
21,457    991,197 

350   

  667,769    792,098   
(13,859)   
  601,469    778,239   

(66,300)   

42,629    178,565   
(3,686)   
(3,826)   
38,943    174,739   

29,513    1,710,574 
(88,027) 
29,157    1,622,547 

(356)   

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 debit valuation adjustments on derivatives.
4  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.

HSBC Holdings plc Annual Report and Accounts 2022

121

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Reconciliation of reported and adjusted items (continued)

Revenue1
Reported
Currency translation
Significant items
–  customer redress programmes
–  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
–  restructuring and other related costs 
–  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 

2021
Mainland 
China

$m

Hong
Kong

$m

US

$m

Mexico

$m

14,463   
(103)   
60   
—   
7   
54   
(1)   
14,420   

(608)   
3   
(605)   

(7,955)   
53   
226   
—   
227   
(1)   
(7,676)   

16   
—   
16   

5,916   
(47)   
286   
60   
226   
6,155   

3,734   
(159)   
(39)   
—   
—   
(41)   
2   
3,536   

(89)   
9   
(80)   

(2,773)   
121   
30   
—   
32   
(2)   
(2,622)   

2,461   
(89)   
2,372   

3,333   
(118)   
(9)   
(39)   
30   
3,206   

4,006   
(1)   
14   
—   
5   
9   
—   
4,019   

205   
—   
205   

(3,683)   
—   
355   
—   
355   
—   
(3,328)   

—   
—   
—   

528   
(1)   
369   
14   
355   
896   

2,341 
19 
15 
— 
— 
15 
— 
2,375 

(224) 
(7) 
(231) 

(1,565) 
(20) 
66 
— 
59 
7 
(1,519) 

17 
— 
17 

569 
(8) 
81 
15 
66 
642 

UK

$m

16,415   
(1,664)   
7   
(11)   
220   
(227)   
25   
14,758   

1,645   
(182)   
1,463   

(14,808)   
1,292   
1,079   
49   
1,144   
(114)   
(12,437)   

267   
(23)   
244   

3,519   
(577)   
1,086   
7   
1,079   
4,028   

  306,464    311,947   
111   
  272,781    312,058   

(33,683)   

54,239   
(4,228)   
50,011   

52,678   
—   
52,678   

18,043 
924 
18,967 

  535,797    549,429   
193   
  476,908    549,622   

(58,889)   

59,266    111,921   
—   
(4,620)   
54,646    111,921   

23,583 
1,208 
24,791 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.

Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives.

122

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 investments3
–  restructuring and other related costs2,4
–  currency translation on significant items2
Adjusted2
ECL
Reported 
Currency translation
Adjusted
Operating expenses
Reported2
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 items2
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

Latin
America

$m

$m

18,419   
(819)   
(234)   
21   
—   
(254)   
(9)   
8   
17,366   

26,922   
(412)   
(34)   
—   
—   
(5)   
(32)   
3   
26,476   

(3,751)   
45   
(3,706)   

(2,284)   
2   
(2,282)   

(18,874)   
756   
2,074   
(54)   
803   
17   
1,425   
12   
(129)   
(16,044)   

1   
(11)   
—   
—   
—   
(10)   

(4,205)   
(29)   
1,840   
(234)   
2,074   
—   
(2,394)   

(13,662)   
250   
164   
—   
—   
—   
171   
—   
(7)   
(13,248)   

1,856   
59   
—   
—   
—   
1,915   

12,832   
(101)   
130   
(34)   
164   
—   
12,861   

2,628   
(252)   
—   
—   
—   
—   
—   
—   
2,376   

(758)   
20   
(738)   

(1,586)   
146   
75   
—   
64   
—   
19   
—   
(8)   
(1,365)   

(265)   
—   
462   
462   
—   
197   

19   
(86)   
537   
—   
75   
462   
470   

6,375   
49   
41   
—   
10   
(2)   
35   
(2)   
6,465   

(900)   
(18)   
(918)   

(5,307)   
(28)   
600   
—   
223   
—   
378   
—   
(1)   
(4,735)   

—   
—   
—   
—   
—   
—   

168   
3   
641   
41   
600   
—   
812   

3,020   
(195)   
—   
—   
—   
(3)   
—   
3   
2,825   

(1,124)   
(47)   
(1,171)   

(1,938)   
152   
73   
—   
—   
—   
91   
—   
(18)   
(1,713)   

5   
—   
—   
—   
—   
5   

(37)   
(90)   
73   
—   
73   
—   
(54)   

Total

$m

50,429 
(1,523) 
(58) 
21 
10 
(264) 
170 
5 
48,848 

(8,817) 
2 
(8,815) 

(34,432) 
1,170 
2,817 
(54) 
1,090 
17 
1,908 
12 
(156) 
(30,445) 

1,597 
48 
462 
462 
— 
2,107 

8,777 
(303) 
3,221 
(58) 
2,817 
462 
11,695 

  408,495    473,165   
(14,753)   
  360,196    458,412   

(48,299)   

28,700    107,969   
(2,814)   
(2,974)   
25,886    104,995   

19,658    1,037,987 
(69,137) 
19,361    968,850 

(297)   

  629,647    762,406   
(19,820)   
  555,299    742,586   

(74,348)   

41,221    182,028   
(4,466)   
(3,505)   
36,755    178,523   

27,478    1,642,780 
(1,412)   
(103,551) 
26,066    1,539,229 

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 debit valuation adjustments on derivatives.
3 
4  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.
5 

Includes impairment of software intangible assets of $189m (of total software intangible asset impairment of $1,347m) and impairment of tangible 
assets of $197m.

6   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.

HSBC Holdings plc Annual Report and Accounts 2022

123

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

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 

Hong
Kong

$m

2020
Mainland 
China

$m

US

$m

Mexico

$m

UK

$m

13,886   
(540)   
(187)   
21   
—   
(256)   
48   
—   
13,159   

(3,256)   
30   
(3,226)   

(14,855)   
438   
1,275   
(54)   
650   
17   
693   
12   
(43)   
(13,142)   

1   
(10)   
(9)   

(4,224)   
(82)   
1,088   
(187)   
1,275   
(3,218)   

16,345   
(145)   
14   
—   
—   
—   
15   
(1)   
16,214   

(824)   
9   
(815)   

(7,312)   
62   
98   
—   
—   
—   
100   
—   
(2)   
(7,152)   

(2)   
—   
(2)   

8,207   
(74)   
112   
14   
98   
8,245   

3,088   
90   
(5)   
—   
—   
(1)   
(4)   
—   
3,173   

(114)   
(10)   
(124)   

(2,211)   
(49)   
18   
—   
—   
—   
19   
—   
(1)   
(2,242)   

1,849   
58   
1,907   

2,612   
89   
13   
(5)   
18   
2,714   

4,590   
(1)   
40   
—   
10   
(2)   
33   
(1)   
4,629   

(622)   
—   
(622)   

(4,194)   
—   
556   
—   
223   
—   
333   
—   
—   
(3,638)   

—   
—   
—   

(226)   
(1)   
596   
40   
556   
369   

314,530   
(37,030)   
277,500   

302,454   
(1,635)   
300,819   

46,113   
(2,417)   
43,696   

58,082   
—   
58,082   

504,275   
(59,369)   
444,906   

531,489   
(2,873)   
528,616   

56,826   
(2,978)   
53,848   

117,485   
—   
117,485   

2,234 
141 
(12) 
— 
— 
(1) 
(12) 
1 
2,363 

(1,050) 
(77) 
(1,127) 

(1,376) 
(89) 
44 
— 
— 
— 
42 
— 
2 
(1,421) 

5 
— 
5 

(187) 
(25) 
32 
(12) 
44 
(180) 

17,296 
391 
17,687 

22,220 
503 
22,723 

1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
2 
3  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.

Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives.

124

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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
–  France2
–  Germany
–  Switzerland
–  other3
Asia
–  Hong Kong
–  Australia
–  India
–  Indonesia
–  mainland China
–  Malaysia
–  Singapore
–  Taiwan
–  other
Middle East and North Africa
–  Egypt
–  UAE
–  Saudi Arabia4
–  other
North America
–  US
–  Canada
–  other
Latin America
–  Mexico
–  other
Year ended 31 Dec 2022

Wealth and
Personal
Banking

Commercial 
Banking

2022

Global 
Banking and 
Markets

Corporate
Centre

$m
(95)   
1,853   
2,112   
386   
(645)   
(2,016)   
17   
25   
26   
4,995   
4,521   
147   
45   
4   
(109)   
110   
244   
36   
(3)   
313   
101   
128   
30   
54   
541   
209   
243   
89   
286   
269   
17   
6,040   

$m
2,652   
2,094   
2,662   
315   
(883)   
210   
8   
17   
323   
2,981   
1,309   
180   
304   
71   
303   
89   
255   
43   
427   
290   
76   
107   
—   
107   
1,169   
557   
548   
64   
355   
273   
82   
7,447   

$m
(77)   
(534)   
143   
141   
(818)   
81   
133   
13   
230   
3,529   
955   
157   
622   
100   
526   
219   
351   
137   
462   
861   
194   
320   
94   
253   
461   
270   
140   
51   
325   
180   
145   
5,099   

$m
(2,895)   
(37)   
(430)   
(474)   
867   
(268)   
(147)   
(30)   
(2,413)   
2,219   
(580)   
(37)   
306   
(9)   
2,678   
(35)   
(78)   
(17)   
(9)   
236   
(5)   
(86)   
345   
(18)   
(505)   
(387)   
(89)   
(29)   
(113)   
(110)   
(3)   
(1,058)   

Total

$m
(415) 
3,376 
4,487 
368 
(1,479) 
(1,993) 
11 
25 
(1,834) 
13,724 
6,205 
447 
1,277 
166 
3,398 
383 
772 
199 
877 
1,700 
366 
469 
469 
396 
1,666 
649 
842 
175 
853 
612 
241 
17,528 

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 $425m as a result of the reclassification of our retail banking operations in France to held for sale. As 
per Group accounting policy, HSBC’s cash-generating units are based on geographical regions, sub-divided by global businesses.

3   Corporate Centre includes inter-company debt eliminations of $1,850m.
4   Includes the results of HSBC Saudi Arabia and our share of the profits of our associate, The Saudi British Bank.

HSBC Holdings plc Annual Report and Accounts 2022

125

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Geographical regions

Profit/(loss) before tax by country/territory within global businesses (continued)

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 Arabia2
–  other
North America
–  US
–  Canada
–  other
Latin America
–  Mexico
–  other3
Year ended 31 Dec 2021

Wealth and
Personal
Banking

Commercial
 Banking

2021

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)   
6,133   

$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   
6,677   

$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   
4,722   

$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)   
1,374   

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) 
18,906 

1  UK includes results from the ultimate holding company, HSBC Holdings plc, and the separately incorporated group of service companies (‘ServCo 

Group’).

2   Includes the results of HSBC Saudi Arabia and our share of the profits of our associate, The Saudi British Bank.
3 

Includes the impact of goodwill impairment of $587m. As per Group accounting policy, HSBC’s cash-generating units are based on geographical 
regions, sub-divided by global businesses.

126

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Profit/(loss) before tax by country/territory within global businesses (continued)

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 Arabia2
–  other
North America
–  US
–  Canada
–  other
Latin America
–  Mexico
–  other
Year ended 31 Dec 2020

Wealth and 
Personal 
Banking

Commercial
 Banking

2020

Global
Banking
and Markets

Corporate
Centre

$m
(680)   
(357)   
113   
109   
(579)   
(340)   
17   
(2)   
2   
5,031   
4,927   
108   
16   
(6)   
(34)   
8   
45   
9   
(42)   
(15)   
68   
(21)   
21   
(83)   
(449)   
(547)   
52   
46   
(183)   
(115)   
(68)   
3,704   

$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   
1,639   

$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   
3,616   

$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)   
(182)   

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 
8,777 

1  UK includes results from the ultimate holding company, HSBC Holdings plc, and the separately incorporated group of service companies (‘ServCo 

Group’).

2   Includes the results of HSBC Saudi Arabia and our share of the profits of our associate, The Saudi British Bank.

HSBC Holdings plc Annual Report and Accounts 2022

127

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of alternative performance measures

Reconciliation of alternative performance measures

Contents

128

128

129

130

130

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

Use of alternative performance 
measures
Our reported results are prepared in accordance with IFRSs 
as detailed in our financial statements starting on page 324.

As described on page 98, 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 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, debit 
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 adjustments1,2
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

2022
$m

2021
$m

14,822   
531   
(264)   

15,089   

2,561   
17,650   

191,998   
(21,202)   
170,796   
(17,935)   
152,861   
(1,125)   
151,736   

%

 8.7 
 9.9 
 11.6 

12,607   
608   
(58)   

13,157   

2,086   
15,243   

199,295   
(22,814)   
176,481   
(17,705)   
158,776   
1,278   
160,054   

%

 7.1 
 8.3 
 9.5 

2020
$m

3,898 
1,036 
(253) 

4,681 

2,402 
7,083 

189,719 
(22,326) 
167,393 
(17,292) 
150,101 
422 
150,523 
%

 2.3 
 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 

represented.

2   Other adjustments includes entries relating to the timing of payments on additional tier 1 coupons.

128

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table details the adjustments made to reported results by global business:

Return on average tangible equity by global business

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)
Other adjustments
Profit attributable to ordinary shareholders, excluding PVIF, significant 
items
Average tangible shareholders’ equity excluding fair value of own debt, DVA and 
other adjustments
Return on average tangible equity excluding significant items (%)

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)
Other adjustments
Profit attributable to ordinary shareholders, excluding PVIF, significant items
Average tangible shareholders’ equity excluding fair value of own debt, DVA and 
other adjustments
Return on average tangible equity excluding significant items (%)

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

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

Year ended 31 Dec 2022

Wealth and
Personal
Banking

Commercial
Banking

Global
Banking and
Markets

Corporate
Centre

$m
6,040   
(1,218)   
4,822   

(696)   

4,126   
(251)   
1,960   
6   

$m
7,447   
(1,737)   
5,710   

(493)   

5,217   
36   
197   
(15)   

$m
5,099   
(823)   
4,276   

(603)   

3,673   
—   
300   
(24)   

$m
(1,058)   
2,920   
1,862   

(56)   

1,806   
(49)   
581   
87   

Total

$m
17,528 
(858) 
16,670 

(1,848) 

14,822 
(264) 
3,038 
54 

5,841   

5,435   

3,949   

2,425   

17,650 

31,519   

38,373   

36,944   

44,900   

151,736 

 18.5 

 14.2 

 10.7 

 5.4 

 11.6 

Year ended 31 Dec 2021

6,133   
(1,540)   
4,593   

(735)   

3,858   
(65)   
850   
3   
4,646   

6,677   
(1,783)   
4,894   

(665)   

4,229   
4   
51   
(4)   
4,280   

4,722   
(1,020)   
3,702   

(618)   

3,084   
—   
517   
(3)   
3,598   

1,374   
130   
1,504   

(68)   

1,436   
3   
1,269   
11   
2,719   

18,906 
(4,213) 
14,693 

(2,086) 

12,607 
(58) 
2,687 
7 
15,243 

30,587   

39,487   

41,816   

48,164   

160,054 

 15.2 

 10.8 

 8.6 

 5.6 

 9.5 

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.

2022
$m
187,484   
(19,746)   
167,738   
(18,383)   
149,355   
19,739   

$

2021
$m
198,250   
(22,414)   
175,836   
(17,643)   
158,193   
20,073   

$

2020
$m
196,443 
(22,414) 
174,029 
(17,606) 
156,423 
20,184 
$

8.50   
7.57   

8.76   
7.88   

8.62 
7.75 

HSBC Holdings plc Annual Report and Accounts 2022

129

Financial review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of alternative performance measures

Post-tax return and average total shareholders’ equity on average total assets
Post-tax return on average total assets is profit after tax divided by average total assets for the period. Average total shareholders’ equity to 
average total assets is average total shareholders’ equity divided by average total assets for the period.

Post-tax return and average total shareholders’ equity on average total assets

Profit after tax
Average total shareholders’ equity
Average total assets

Ratio
Post-tax return on average total assets
Average total shareholders’ equity to average total assets

2022
$m
16,670   
191,998   

2020
$m
6,099 
189,719 
  3,030,574    3,012,437    2,936,939 

2021
$m
14,693   
199,295   

%
 0.6 
 6.34 

%
 0.5 
 6.62 

%
 0.2 
 6.46 

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
Average gross loans and advances to customers – at most recent balance sheet foreign exchange rates
Average gross loans and advances to customers, including held for sale
Currency translation
Average gross loans and advances to customers, including held for sale – at most recent balance sheet foreign 
exchange rates

(3,592)   

2022
$m
(3,592)   

2021
$m
928   
(174)   
754   

2020
$m
(8,817) 
2 
(8,815) 
  1,015,445    1,057,412    1,047,114 
(63,174)   
(34,883) 
(13,325)   
  1,002,120   
994,238    1,012,231 
  1,036,974    1,058,947    1,047,114 
(34,883) 

(12,846)   

(63,012)   

  1,024,128   

995,935    1,012,231 

Ratio
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 as % of average gross loans and advances to customers, 
including held for sale

%
 0.36 

 0.35 

%
 (0.08) 

 (0.08) 

%
 0.87 

 0.87 

130

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
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.

132  Our approach to risk

132  Our risk appetite

132  Risk management

135  Key developments in 2022

135  Top and emerging risks

135  Externally driven

140 

Internally driven

142  Areas of special interest

142  Risks related to Covid-19

142  Our material banking risks

145  Credit risk 

202  Treasury risk

218  Market risk 

221  Climate risk

230  Resilience risk 

231  Regulatory compliance risk

231  Financial crime risk

232  Model risk

233 

Insurance manufacturing operations risk

Identifying suspicious activities 
through our award-winning AI tool 

We are using the latest artificial intelligence technology to help 
identify suspicious activities to help prevent financial crime. Our 
dynamic risk assessment solution brings data together on the 
Cloud, and uses machine learning to analyse and identify criminal 
activity by making use of relevant data, with the ability to identify 
patterns that humans are unlikely to spot.

The tool, which we first developed in November 2021 and is active 
in several markets including the UK, enables suspicious activity to 
be identified twice as fast than the previous process and reduces 
case volumes by 60%.   

The solution was recognised at the 2022 Banking Tech Awards, 
winning ‘Best Use of Cloud’ and ‘Best Use of AI’. We plan to roll  
it out to other markets throughout 2023.

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131

Risk review

Our approach to risk

Our risk appetite
We recognise the importance of a strong culture, which refers to our 
shared attitudes, beliefs, values and standards that shape behaviours 
including those 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 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. 

• We consider and, where appropriate, mitigate reputational risk that 

may arise from our business activities and decisions.

• We monitor non-financial risk exposure against risk appetite, 
including exposure related to inadequate or failed internal 
processes, people and systems, or events that impact our 
customers or can lead to sub-optimal returns to shareholders, 
censure, or reputational damage.

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 Group 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 2021 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.

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The Board reviews and approves the Group’s risk appetite regularly 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 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 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 material operating entity 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 134.

The implementation of our business strategy 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 actively review and 
enhance our risk management framework and 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. 

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/return 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

Non-executive risk governance

Risk governance

Executive risk governance

Roles and 
responsibilities

Three lines of defence model

Processes and tools

Risk appetite

Enterprise-wide risk management tools

Active risk management: identification/assessment, 
monitoring, management and reporting 

Policies and procedures

Internal controls

Control activities

Systems and infrastructure

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 255).

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 
134 and 142). 

Our ‘three lines of defence’ model defines roles and responsibilities for 
risk management. An independent Group Risk and Compliance 
function helps ensure the necessary balance in risk/return decisions 
(see page 134).

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 define the minimum requirements for the 
controls required to manage our risks. 

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 
Group Risk Management Meeting, 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. 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 Risk Management 
Meeting. This structure is summarised in the following table.

HSBC Holdings plc Annual Report and Accounts 2022

133

Risk reviewRisk review

Governance structure for the management of risk and compliance

Authority

Membership

Responsibilities include:

Group Risk Management 
Meeting 

Group Risk and 
Compliance Executive 
Committee

Global business/regional 
risk management 
meetings

Group Chief Risk and Compliance 
Officer
Group Chief Legal Officer
Group Chief Executive
Group Chief Financial Officer
Group Head of Financial Crime and 
Group Money Laundering Reporting 
Officer
Group Head of Compliance
All other Group Executive Committee 
members

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 Group 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 assessment of the risk environment
• Implementation of risk appetite and the risk management framework
• Monitoring all categories of risk and overseeing 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 258.

Treasury risks are the responsibility of the Group Executive Committee and the Group Risk Committee. Global Treasury actively manages these 
risks, supported by the Holdings Asset and Liability Management Committee (‘ALCO’) and local ALCOs, overseen by Treasury Risk 
Management and the Group Risk Management Meeting. Further details on treasury risk management are set out on page 202.

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.

Group Risk and Compliance function

Our Group 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. Group Risk and Compliance is made 
up of sub-functions covering all risks to our business. Forming part of 
the second line of defence, the Group Risk and Compliance function 
is independent from the global businesses, including sales and trading 

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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 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 as well as 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 scenario 
analysis specific to its region. They also participate, as required, in the 
regulatory stress testing programmes of the jurisdictions in which 
they operate, such as stress tests required by the Bank of England 
(‘BoE’) in the UK, the Federal Reserve Board (‘FRB’) in the US, and 
the Hong Kong Monetary Authority (‘HKMA’) in Hong Kong. Global 
functions and businesses also perform bespoke stress testing to 
inform their assessment of risks to potential scenarios.

We also conduct reverse stress tests each year at Group level and, 
where required, at subsidiary entity level to understand potential 
extreme conditions that would make our business model non-viable. 
Reverse stress testing identifies potential stresses and vulnerabilities 
we might face, and helps inform early warning triggers, management 
actions and contingency plans designed to mitigate risks.

Recovery and resolution plans 

Recovery and resolution plans form part of the integral framework 
safeguarding the Group’s financial stability. The Group recovery plan, 
together with stress testing, help us understand the likely outcomes 
of adverse business or economic conditions and in the identification 
of appropriate risk mitigating actions. The Group is committed to 
further developing its recovery and resolution capabilities in line with 
the BoE’s Resolvability Assessment Framework requirements.

Key developments in 2022
We actively managed the risks related to macroeconomic 
uncertainties including inflation, fiscal and monetary policy, the 
Russia-Ukraine war, broader geopolitical uncertainties and continued 
risks resulting from the Covid-19 pandemic, as well as other key risks 
described in this section. In addition, we sought to enhance our risk 
management in the following areas:

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

The Russia-Ukraine war has had far-reaching geopolitical and 
economic implications. HSBC is monitoring the impacts of the war 
and continues to respond to the further economic sanctions and trade 
restrictions that have been imposed on Russia in response. In 
particular, significant sanctions and trade restrictions imposed against 
Russia have been put in place by the UK, the US and the EU, as well 
as other countries. Such sanctions and restrictions have specifically 
targeted certain Russian government officials, politically exposed 

• We continued to improve our risk governance decision making, 

particularly with regard to the governance of treasury risk, to help 
ensure senior executives have appropriate oversight and visibility 
of macroeconomic trends around inflation and interest rates.

• We adapted our interest rate risk management strategy as market 

and official interest rates increased in reaction to inflationary 
pressures. This included the Board approving in September a new 
interest rate risk in the banking book strategy, a managed 
reduction in the duration risk of our hold-to-collect-and-sell asset 
portfolio and an increase in net interest income stabilisation.

• We began a process of enhancement of our country credit risk 

management framework to strengthen our control of risk tolerance 
and appetite at a country level. 

• We continued to develop our approach to emerging risk 

identification and management, including the use of forward-
looking indicators to support our analysis. 

• We enhanced our enterprise risk reporting processes to place a 
greater focus on our emerging risks, including by capturing the 
materiality, oversight and individual monitoring of these risks.

• We sought to further strengthen our third-party risk policy and 

processes to improve control and oversight of our material third 
parties to maintain our operational resilience, and to meet new and 
evolving regulatory requirements. 

• We made progress with our comprehensive regulatory reporting 

programme to strengthen our global processes, improve 
consistency and enhance controls.

• We continued to embed the governance and oversight around 

model adjustments and related processes for IFRS 9 models and 
Sarbanes-Oxley controls.

• We commenced a programme to enhance our framework for 

managing the risks associated with machine learning and artificial 
intelligence (‘AI’).

• Through our climate risk programme, we continued to embed 
climate considerations throughout the organisation, including 
updating the scope of our programme to cover all risk types, 
expanding the scope of climate-related training, developing new 
climate risk metrics to monitor and manage exposures, and 
developing our internal climate scenario exercise.

• We sought to improve the effectiveness of our financial crime 
controls, deploying advanced analytics capabilities into new 
markets. We refreshed our financial crime policies to help ensure 
they remain up to date and address changing and emerging risks. 
We continue to monitor regulatory changes.

persons, business people, Russian oil imports, energy products, 
financial institutions and other major Russian companies. In addition, 
there have been put in place more generally applicable investment, 
export, and import bans and restrictions. In response to such 
sanctions and trade restrictions, as well as asset flight, Russia has 
implemented certain countermeasures. 

Further sanctions, trade restrictions and Russian countermeasures 
may adversely impact the Group, its customers and the markets in 
which the Group operates by creating regulatory, reputational and 
market risks. Our business in Russia principally serves multinational 
corporate clients headquartered in other countries, is not accepting 
new business or customers and is consequently on a declining trend. 
Following a strategic review, HSBC Europe BV (a wholly-owned 
subsidiary of HSBC Bank plc) has entered into an agreement to sell its 
wholly-owned subsidiary HSBC Bank (RR) (Limited Liability Company), 
subject to regulatory and governmental approvals. 

Global commodity markets have been significantly impacted by the 
Russia-Ukraine war and localised Covid-19 outbreaks, leading to 
continued supply chain disruptions. This has resulted in product 
shortages appearing across several regions, and increased prices for 
both energy and non-energy commodities, such as food. We do not 

HSBC Holdings plc Annual Report and Accounts 2022

135

Risk reviewRisk review

expect these to ease significantly in the near term. In turn, this has 
had a significant impact on global inflation. Relatively mild weather, 
until recently, and diversification of fuel sources have nevertheless 
helped regions most dependent on Russian supply to substantially 
reduce risks of rationing over the winter months.

China’s policy measures issued at the end of 2022 have increased 
liquidity and the supply of credit to the mainland China commercial 
real estate sector. Recovery in the underlying domestic residential 
demand and improved customer sentiment will be necessary to 
support the ongoing health of the sector. We will continue to monitor 
the sector closely, notably the risk of further idiosyncratic real estate 
defaults and the potential associated impact on wider market, 
investor and consumer sentiment. Given that parts of the global 
economy are in, or close to, recession, the demand for Chinese 
exports may also diminish.

Rising global inflation has prompted central banks to tighten monetary 
policy. Since the beginning of 2022, the US Federal Reserve Board 
(‘FRB’) has delivered a cumulative 450 basis point (‘bps’) increase in 
the Federal Funds rate. The European Central Bank lagged the FRB 
initially, but its benchmark rate has subsequently been increased by 
300bps since July 2022. As of mid-February 2023, interest-rate 
futures suggested market uncertainty as to whether the FRB would 
begin to ease monetary policy over the 12-month horizon. Should 
monetary policy rates move materially higher than current 
expectations, a realignment of market expectations could cause 
turbulence in financial asset prices.

Financial markets have also shown reduced appetite for expansionary 
fiscal policies in the context of high debt ratios. Following the fiscal 
statement of 23 September 2022 by the UK government, there was a 
fall in the value of sterling and a sharp rise in the yields of UK 
government securities, known as gilts. Following this, the Bank of 
England reversed its plan to begin selling its gilt holdings from 
September 2022, and the UK government reversed most of the 
previously announced fiscal measures. We continue to monitor our 
risk profile closely in the context of uncertainty over global 
macroeconomic policies. 

Higher inflation and interest rate expectations around the world – and 
the resulting economic uncertainty – have had an impact on expected 
credit losses and other credit impairment charges (‘ECL’). The 
combined pressure of higher inflation and interest rates may impact 
the ability of our customers to repay debt. Our Central scenario, 
which has the highest probability weighting in our IFRS 9 ‘Financial 
Instruments’ calculations of ECL, assumes low growth and a higher 
inflation environment across many of our key markets. However, due 
to the rapidly changing economic conditions, the potential for forecast 
dispersion and volatility remain high, impacting the degree of accuracy 
and certainty of our Central scenario forecast. The level of volatility 
varies by market, depending on exposure to commodity price 
increases, supply chain constraints, the monetary policy response to 
inflation and the public health policy response to the Covid-19 
pandemic. As a result, our Central scenario for impairment has not 
been assigned the same likelihood of occurrence across our key 
markets. There is also uncertainty with respect to the relationship 
between the economic drivers and the historical loss experience, 
which has required adjustments to modelled ECL in cases where we 
determined that the model was unable to capture the material 
underlying risks.

For further details of our Central and other scenarios, see 
‘Measurement uncertainty and sensitivity analysis of ECL estimates’ 
on page 153.

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 US-China relationship remains complex. To date, the UK, the US, 
the EU and other countries have imposed various sanctions and trade 
restrictions on Chinese persons and companies. Although sanctions 
and trade restrictions are difficult to predict, increases in diplomatic 
tensions between China and the US and other countries could result 
in sanctions that could negatively impact the Group, its customers 
and the markets in which the Group operates. There is a continued 
risk of additional sanctions and trade restrictions being imposed by 

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HSBC Holdings plc Annual Report and Accounts 2022

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. 

China has in turn announced a number of its own sanctions and trade 
restrictions that target, or provide authority to target, foreign 
individuals and companies. 

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.

Negotiations between the UK and the EU over the operation of the 
Northern Ireland Protocol are continuing. While there are signs that 
differences may be diminishing, failure to reach agreement could 
have implications for the future operation of the EU-UK Trade and 
Cooperation Agreement.

In June 2022, the UK government published proposed legislation that 
seeks to amend the Protocol in a number of respects. In response, 
the EU launched infringement procedures against the UK, and is 
evaluating the UK response, received in September 2022. If the 
proposed legislation were to pass, and infringement procedures 
progressed, it could further complicate the terms of trade between 
the UK and the EU and potentially prevent progress in other areas 
such as financial services. 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. We are 
monitoring the situation closely, including the potential impacts on our 
customers.  

In August 2022, the US Inflation Reduction Act introduced a minimum 
tax of 15% with effect from 1 January 2023. It is possible that the 
minimum tax could result in an additional US tax liability over our 
regular US federal corporate tax liability in a given year, based on the 
differences between US book and taxable income (including as a 
result of temporary differences). Given its recent pronouncement, it is 
unclear at this time what, if any, impact the US Inflation Reduction 
Act will have on HSBC’s US tax rate and US financial results. HSBC 
will continue to evaluate its impact as further information becomes 
available. In addition, potential changes to tax legislation and tax rates 
in the countries and territories in which we operate could increase our 
effective tax rate in the future.

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.

The financial impact on the Group of geopolitical risks in Asia is 
heightened due to the region’s relatively high contribution to the 
Group’s profitability, particularly in Hong Kong.

While it is the Group's policy to comply with all applicable laws and 
regulations of all jurisdictions in which it operates, geopolitical risks 
and tensions, and potential ambiguities in the Group’s compliance 
obligations, will continue to present challenges and risks for the 
Group and could have a material adverse impact on the Group‘s 
business, financial condition, results of operations, prospects and 
strategy, as well as on the Group’s customers.

Expanding data privacy, national security and cybersecurity laws in a 
number of markets could pose potential challenges to intra-group data 
sharing. These developments could increase financial institutions’ 
compliance obligations in respect of cross-border transfers of 
personal information, which may affect our ability to manage financial 
crime risks across markets.

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 through 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 that our ability to 
manage the level of facilities offered through any downturn is 
appropriate.

• We continue to manage sanctions and trade restrictions through 

the use of, and enhancements to, our existing controls.

• 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.

Technology and cybersecurity risk

Together with other organisations, we operate in an extensive and 
complex technology landscape, which needs to remain resilient in 
order to support customers, our organisation and financial markets 
globally. Risks arise where technology is not understood, maintained, 
or developed appropriately. We also continue to operate in an 
increasingly hostile cyber threat environment globally. These threats 
include potential unauthorised access to customer accounts, attacks 
on our systems or those of our third-party suppliers, and require 
ongoing investment in business and technical controls to defend 
against.

Mitigating actions

• We continue to invest in transforming how software solutions are 
developed, delivered and maintained to improve system resilience. 
We continue to build security into our software development 
lifecycle 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 2022 for both our 
customers and colleagues.

• We continually evaluate threat levels for the most prevalent cyber-

attack types and their potential outcomes. To further protect HSBC 
and our customers and help ensure the safe expansion of our 
global businesses, we continue to 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 it across 
our global businesses, functions and regions to help ensure there 
is appropriate visibility and governance of the risk and its mitigating 
actions.

• We participate globally in industry bodies and working groups to 
collaborate on tactics employed by cyber-crime groups and to 
work together preventing, detecting and defending against cyber-
attacks on financial organisations globally.

Evolving regulatory environment risk

We aim to keep abreast of the emerging regulatory compliance and 
conduct agenda, which currently includes, but is not limited to: ESG 
matters; ensuring good customer outcomes; addressing customer 
vulnerabilities due to cost of living pressures; regulatory compliance; 
regulatory reporting; employee compliance, including the use of e-
communication channels; and the proposed reforms to the UK 
financial services sector, known as the Edinburgh Reforms. 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.

Mitigating actions

• We monitor for regulatory developments to understand the 

evolving regulatory landscape and seek to respond with changes in 
a timely manner.

• We engage with governments and regulators, responding to 

consultations with a view to help shaping regulations that can be 
implemented effectively. We hold regular meetings with relevant 
authorities to discuss strategic contingency plans, including those 
arising from geopolitical issues.  

• Our simplified conduct approach aligns to our purpose and values, 

in particular the value ‘we take responsibility’.

Financial crime risk 

Financial institutions remain under considerable regulatory scrutiny 
regarding their ability to detect and prevent financial crime. These 
evolving challenges include managing conflicting laws and approaches 
to legal and regulatory regimes, and implementing an unprecedented 
volume and diverse set of sanctions, notably as a result of the Russia-
Ukraine war.

Amid rising inflation and increasing cost of living pressures, we face 
increasing regulatory expectations with respect to managing internal 
and external fraud, and protecting vulnerable customers.

The digitisation of financial services continues to have an impact on 
the payments ecosystem, with an increasing number of new market 
entrants and payment mechanisms, not all of which are subject to the 
same level of regulatory scrutiny or regulations as banks. 
Developments around digital assets and 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, continue to increase. These are particularly focused on 
potential ‘greenwashing’, human rights issues and environmental 
crimes. In addition, climate change itself could heighten risks linked to 
vulnerable migrant populations in countries where financial crime is 
already more prevalent.

We also continue to face increasing challenges presented by national 
data privacy requirements, which may affect our ability to manage 
financial crime risks across markets. 

Mitigating actions  

• We continue to manage sanctions and trade restrictions through 

the use of, and enhancements to, our existing controls.

• We continue to develop our fraud controls and invest in 

capabilities to fight financial crime through the application of 
advanced analytics and artificial intelligence.

• We are looking at the impact of a rapidly changing payments 

ecosystem, as well as risks associated with direct and indirect 
exposure to digital assets and currencies, in an effort to maintain 
appropriate financial crime controls.

• We are assessing our existing policies and control framework so 
that developments relating to ESG are considered and the risks 
mitigated.

• We engage with regulators, policymakers and relevant 

international bodies, seeking to address data privacy challenges 
through international standards, guidance and legislation.

Ibor transition risk

Interbank offered rates (‘Ibors’) have previously 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 

HSBC Holdings plc Annual Report and Accounts 2022

137

Risk reviewRisk review

contracts from Ibors to products linked to near risk-free replacement 
rates (‘RFRs’) or alternative reference rates.

methodologies, and the transition of large volumes of Ibor 
contracts may lead to operational issues;

The publication of sterling, Swiss franc, euro and Japanese yen Libor 
interest rate benchmarks, as well as Euro Overnight Index Average 
(‘Eonia’), ceased from the end of 2021. Our Ibor transition programme 
– which is tasked with the development of RFR products and the 
transition of legacy Ibor products – has continued to support the 
transition of a limited number of remaining contracts in sterling and 
Japanese yen Libor, which were published using a ‘synthetic’ interest 
rate methodology during 2022. The remaining ‘tough legacy’ sterling 
contracts have required protracted client discussions where contracts 
are complex or restructuring of facilities is required. The publication of 
‘synthetic’ Japanese yen Libor ceased after 31 December 2022. In 
addition the FCA announced, in September and November 2022, that 
one month and six-month ‘synthetic’ sterling Libor rates will cease to 
be published from 31 March 2023, and three-month ‘synthetic’ 
sterling Libor will cease to be published after 31 March 2024. We 
have or are prepared to transition or remediate the remaining few 
contracts relying on ‘synthetic’ sterling settings, outstanding as at 
31 December 2022, in advance of those cessation dates.

For the cessation of the publication of US dollar Libor from 30 June 
2023, we have implemented the majority of required processes, 
technology and RFR product capabilities throughout the Group in 
preparation for upcoming market events. We will continue to 
transition outstanding legacy contracts through the first half of 2023. 
We have completed the transition of the majority of our uncommitted 
lending facilities, and continue to make steady progress with the 
transition of the outstanding legacy committed lending facilities. 
Transition of our derivatives portfolio is progressing well with most 
clients reliant on industry mechanisms to transition to RFRs. For the 
limited number of bilateral derivatives trades where an alternative 
transition path is required, client engagement is continuing. For 
certain products and contracts, including bonds and syndicated loans, 
we remain reliant on the continued support of agents and third 
parties, but we continue to progress those contracts requiring 
transition. We continue to monitor contracts that may be potentially 
more challenging to transition, and may need to rely upon legislative 
solutions. Additionally, following the FCA’s consultation in November 
2022 proposing that US dollar Libor is to be published using a 
‘synthetic’ methodology for a defined period, we will continue to work 
with our clients to support them through the transition of their 
products if transition is not completed by 30 June 2023.

For the Group’s own debt securities issuances, we continue to have 
instruments in US dollars, sterling, Japanese yen and Singapore 
dollars where the terms provide for an Ibor benchmark to be used to 
reset the coupon rate if HSBC chooses not to redeem them on their 
call dates. We remain mindful of the various factors that have an 
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, the potential relevance of legislative 
solutions and industry best practice guidance. We remain committed 
to 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.

For US dollar Libor and other demising Ibors, we continue to be 
exposed to, and actively monitor, risks including: 

• regulatory compliance and conduct risks, as the transition of 

legacy contracts to RFRs or alternative rates, or sales of products 
referencing RFRs, may not deliver fair client outcomes;

• resilience and operational risks, as changes to manual and 

automated processes, made in support of new RFR 

• legal risk, as issues arising from the use of legislative solutions and 
from legacy contracts that the Group is unable to transition may 
result in unintended or unfavourable outcomes for clients and 
market participants, which could potentially increase the risk of 
disputes;

• model risk, as there is a risk that changes to our models to replace 
Ibor-related data adversely affect the accuracy of model outputs; 
and

• market risk, because as a result of differences in Libor and RFR 
interest rates, we are exposed to basis risk resulting from the 
asymmetric adoption of rates across assets, liabilities and 
products. Additionally the current stage of the Term Secured 
Overnight Financing Rate (‘SOFR’) market presents challenges for 
certain hedge accounting strategies.

While the level of risk is diminishing in line with our process 
implementation and continued transition of contracts, we will monitor 
these risks through the remainder of the transition of legacy 
contracts. Throughout 2023, we plan to continue to engage with our 
clients and investors to complete an orderly transition of contracts 
that reference the remaining demising Ibors. 

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 have actively transitioned legacy contracts and ceased 

entering into new contracts based on demised or demising Ibors, 
other than those allowed under regulatory exemptions, and 
implemented 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.

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HSBC Holdings plc Annual Report and Accounts 2022

At 31 Dec 2022
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
Total derivative notional contract amount

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
Total derivative notional contract amount

Financial instruments yet to transition to alternative 
benchmarks, by main benchmark

USD Libor
$m

GBP Libor
$m

JPY Libor
$m

Others1
$m

49,632   
4,716   
54,348   

17,224   
5,352   
2,988   
25,564   

140,223   
2,208,189   
2,348,412   

262   
42   
304   

1,804   
—   
—   
1,804   

—   
68   
68   

—   
—   
—   

7,912 
1,562 
9,474 

1,179   
—   
—   
1,179   

— 
— 
176 
176 

—   
—   
—   

7,337 
186,952 
194,289 

Financial instruments yet to transition to alternative 
benchmarks, by main benchmark

USD Libor
$m

GBP Libor
$m

JPY Libor
$m

70,932   
5,131   
76,063   

18,307   
1,098   
19,405   

20,219   
5,255   
2,998   
28,472   

4,019   
—   
78   
4,097   

370   
—   
370   

1,399   
—   
—   
1,399   

Others1
$m

8,259 
2 
8,261 

1 
— 
— 
1 

137,188   
2,318,613   
2,455,801   

5,157   
284,898   
290,055   

31,470   
72,229   
103,699   

9,652 
133,667 
143,319 

1  Comprises financial instruments referencing other significant benchmark rates yet to transition to alternative benchmarks (euro Libor, Swiss franc 

Libor, Eonia, SOR, THBFIX, MIFOR and Sibor). Announcements were made by regulators during 2022 on the cessation of the Canadian dollar offered 
rate (‘CDOR’) and Mexican Interbank equilibrium interest rate (‘TIIE’), which will eventually transition to the Canadian overnight repo rate average 
(‘CORRA’) and a new Mexican overnight fall-back rate, respectively. Therefore, CDOR and TIIE are also included in Others during the current period.

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, Thailand, 
India and Japan. 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.
Environmental, social and governance 
(’ESG’) risk

We are subject to financial and non-financial risks associated with 
ESG-related matters. Our current areas of focus include climate risk, 
nature-related risks and human rights risks. These can impact us both 
directly and indirectly through our business activities and 
relationships. For details of how we govern ESG, see page 86.

Our assessment of climate risks covers three distinct time periods, 
comprising: short term, which is up to 2025; medium term, which is 
between 2026 and 2035; and long term, which is between 2036 and 
2050. Focus on climate-related risk continued to increase over 2022, 
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 could face direct impacts, owing to the increase in frequency and 
severity of weather events and chronic shifts in weather patterns, 
which could affect our ability to conduct our day-to-day operations.

Our customers may find that their business models fail to align to a 
net zero economy or face disruption to their operations or 
deterioration to their assets as a result of extreme weather.

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. Climate 
risk may also impact on model risk, as the uncertain impacts of 
climate change and data and methodology limitations present 
challenges to creating reliable and accurate model outputs. 

We also face reporting risk in relation to our climate disclosures, as 
any data, methodologies and standards we have used may evolve 
over time in line with market practice, regulation or owing to 
developments in climate science. While emissions reporting has 
improved over time, data remains of limited quality and consistency. 
The use of inconsistent or incomplete data and models could result in 
sub-optimal decision making. Any changes could result in revisions to 
our internal frameworks and reported data, and could mean that 

HSBC Holdings plc Annual Report and Accounts 2022

139

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

reported figures are not reconcilable or comparable year on year. We 
may also have to re-evaluate our progress towards our climate-related 
targets in future and this could result in reputational, legal and 
regulatory risks. 

There is increasing evidence that a number of nature-related risks 
beyond climate change, which include risks that can be represented 
more broadly by impact and 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, ecosystem degradation arising from 
economic activity 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. 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 be transparent about their efforts to identify and respond 
to the risk of negative human rights impacts arising from their 
business activities and relationships. 

Mitigating actions

Digitalisation and technological advances 
risk 

Developments in technology and changes to regulations are enabling 
new entrants to the industry, particularly with respect to payments. 
This challenges us to continue innovating and taking advantage of 
new digital capabilities so that we improve how we serve our 
customers, drive efficiency and adapt our products to attract and 
retain customers. As a result, we may need to increase our 
investment in our business to adapt or develop products and services 
to respond to our customers’ evolving needs. We also need to ensure 
that new digital capabilities do not weaken our resilience or wider risk 
management capabilities.

New technologies such as blockchain and quantum computing offer 
both business opportunities and potential risks for HSBC. As with all 
use of technologies, we aim to maximise their potential while seeking 
to ensure a robust control environment is in place to help manage the 
inherent risks, such as the impact on encryption algorithms.

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 assess new technologies to help develop appropriate controls 

• We aim to deepen our understanding of the drivers of climate risk. 

and maintain resilience.

• We closely monitor and assess financial crime risk and the impact 

on payment transparency and architecture.

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

Our global businesses and functions in all of our markets are exposed 
to risks associated with workforce capacity challenges, including 
challenges to retain, develop and attract high-performing employees 
in key labour markets, and compliance with employment laws and 
regulations. Changed working arrangements, and the residual impact 
of local Covid-19-related restrictions and health concerns during the 
pandemic, have also affected employee mental health and well-being.

Mitigating actions

• We seek to promote a diverse and inclusive workforce and provide 
health and well-being support. We continue to build our speak-up 
culture through active campaigns.

• We monitor hiring activities and levels of employee attrition, with 
each business and function putting in place plans to help ensure 
they have effective workforce forecasting to meet business 
demands. 

• 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 provides skills that will help to 
enable employees and HSBC to be successful in the future.

• We develop succession plans for key management roles, with 

oversight from the Group Executive Committee.

A dedicated Climate Risk Oversight Forum is responsible for 
shaping and overseeing our approach and providing support in 
managing climate risk. For further details of the Group’s ESG 
governance structure, see page 86.

• Our climate risk programme continues to support 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 also aim to enhance our 
approach to greenwashing risk management. 

• In December 2022, we published our updated policy covering the 
broader energy system including upstream oil and gas, oil and gas 
power generation, coal, hydrogen, renewables and hydropower, 
nuclear, biomass and energy from waste. We also expanded our 
thermal coal phase-out policy, in which we committed to not 
provide new finance or advisory services for the specific purposes 
of the conversion of existing coal-to-gas fired power plants, or new 
metallurgical coal mines (see page 65).

• 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.

• In 2022, we reviewed our salient human rights issues following 
the methodology set out in the UNGPs. These are the human 
rights at risk of the most severe potential negative impact through 
our business activities and relationships. This review built on an 
earlier review that had identified modern slavery and discrimination 
as priority human rights issues. For further details, see page 87 of 
the ESG review.

• 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 Disclosures (‘TNFD’). In 2022 
our asset management business 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, Task Force on Climate-related Financial 
Disclosures and CDP (formerly the Carbon Disclosure Project) to 
help drive best practice for climate risk management.

For further details of our approach to climate risk management, see 
‘Climate risk’ on page 221.

For further details of ESG risk management, see ‘Financial crime risk‘ 
on page 231 and ‘Regulatory compliance risk environment including 
conduct’ on page 225.

Our ESG review can be found on page 44.

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HSBC Holdings plc Annual Report and Accounts 2022

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.

Mitigating actions

• We continue to monitor the effectiveness of the controls operated 
by our third-party providers and request third-party control reports, 
where required. We have made further enhancements to our 
framework to help ensure risks associated with these 
arrangements are understood and managed effectively by our 
global businesses, global functions and regions.   

• We continue to enhance the effective management of our intra-

Group arrangements using the same control standards as we have 
for external third-party arrangements.

• We are implementing the changes required by new regulations as 

set by our regulators.

Model risk 

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. Significant 
increases in global inflation and interest rates have impacted the 
reliability and accuracy of both credit and market risk models.

We continued to prioritise 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. A number of these models have been submitted 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 ESG has become 
a key part of the Group’s strategy.

Model risk remains a key area of focus given the regulatory scrutiny in 
this area, with local regulatory exams taking place in many 
jurisdictions and further developments in policy expected from many 
regulators, including the PRA.

Mitigating actions

• 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 help ensure that risks that are determined by the 
algorithms have adequate oversight and review. A framework to 
manage the range of risks that are generated by these advanced 
techniques, and to recognise the multidisciplinary nature of these 
risks, is being developed.

Data risk

We use multiple 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 the 

quality, availability and security of data that supports our 
customers and internal processes. We work towards resolving any 
identified data issues in a timely manner.

• We have made improvements to our data policies. We are 

implementing an updated control framework (which includes 
trusted sources, data flows and data quality) in order to enhance 
the end-to-end management of data risk.

• We have established a global data management utility, and 

continue to simplify and unify data management activities across 
the Group.

• We seek to protect customer data through 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 artificial intelligence.

• We continue to educate our employees on data risk and data 
management. We have delivered regular mandatory training 
globally on how to protect and manage data appropriately.

Change execution risk

We have continued investment in strategic change to support the 
delivery of our strategic priorities and regulatory commitments. This 
requires change to be executed safely and efficiently. 

• We have continued to embed the enhanced monitoring, review 

Mitigating actions

and challenge of expected credit 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 effective review and challenge 
of any future redevelopment of these models.

• Model Risk Governance committees at the Group, business and 
functional levels continue to provide oversight of model risk.

• In 2022, we added change execution risk to our risk taxonomy and 
control library, so that it could be defined, assessed, managed, 
reported and overseen in the same way as our other material risks.

• The Transformation Oversight Executive Committee oversees the 
prioritisation, strategic alignment and management of execution 
risk for all change portfolios and initiatives.

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141

Risk reviewRisk review

Areas of special interest 

During 2022, 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.

Risks related to Covid-19 
The impact from the Covid-19 pandemic remains a continuing risk to 
our customers and organisation. However, the appetite for public 
health restrictions has reduced following the successful roll-out of 
vaccine programmes, and as societies have adapted. Countries 
continue to differ in their approach, although China has recently 
reversed restrictions on activity and mobility.   

In most countries, high vaccination rates and acquired population 
immunity have minimised the public health risks and the need for 
restrictions. However, in mainland China and Hong Kong, adherence 

Our material banking risks

to public health restrictions had adverse economic implications 
throughout much of 2022. Government-imposed restrictions on 

activity in major Chinese cities, and restrictions on travel, adversely 
affected global tourism and supply chains. 

While the recovery in China resulting from the relaxation of Covid-19 
related restrictions on movement, international travel and tourism in 
China that commenced in December 2022, raises the prospect of 
global growth, it could also lead to renewed inflationary pressures as 
demand for commodities and other goods rises. However, there are 
still short-term risks, as any surge in Covid-19 infections in China may 
dampen confidence and activity, and lead to the emergence of new 
vaccine-resistant variants of the virus.

We continue to monitor the situation closely, and given the continuing 
uncertainties related to the post-pandemic landscape, additional 
mitigating actions may be required.

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 145)

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 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 (see page 202)

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 and 
transactional foreign exchange 
exposures and changes in 
market interest rates, together 
with pension and insurance 
risk.

Market risk (see page 218)

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.

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 for non-trading 
portfolios is discussed in the 
Treasury risk section on page 214.
Market risk exposures arising from 
our insurance operations are 
discussed on page 237.

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 Group Risk Management Meeting 

and the risk management meetings in various global businesses. 

142

HSBC Holdings plc Annual Report and Accounts 2022

Description of risks – banking operations (continued)

Risks

Arising from

Measurement, monitoring and management of risk

Climate risk is:
• measured using a variety of risk appetite metrics and key management 

indicators, which assess the impact of climate risk across the risk taxonomy;

• monitored using stress testing; and
• managed through adherence to risk appetite thresholds and via specific 

policies.

Climate risk (see page 221)

Climate risk relates to the 
financial and non-financial 
impacts that may arise as a 
result of climate change and 
the move to a greener 
economy.

Climate risk can materialise 
through: 
• physical risk, which arises from 
the increased frequency and 
severity of weather events;

• transition risk, which arises from 
the process of moving to a low-
carbon economy; and

• greenwashing risk, which arises 
from the act of knowingly or 
unknowingly misleading 
stakeholders regarding our 
strategy relating to climate, the 
climate impact/benefits of a 
product or service, or the climate 
commitments or performance of 
our customers.

Resilience risk arises from failures 
or inadequacies in processes, 
people, systems or external events.

Resilience risk (see page 230)
Resilience risk is the risk of 
sustained and significant 
business disruption from  
execution, delivery, physical 
security or safety events, 
causing the inability to provide 
critical services to our 
customers, affiliates, and 
counterparties.

Regulatory compliance risk (see page 231)

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 (see page 231)

Financial crime risk is the risk 
that HSBC’s products and 
services will be exploited for 
criminal activity. This includes 
fraud, bribery and corruption, 
tax evasion, sanctions and 
export control violations, 
money laundering, terrorist 
financing and proliferation 
financing.

Model risk (see page 232)

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.

Financial crime risk arises from day-
to-day banking operations involving 
customers, third parties and 
employees. 

Model risk arises in both financial 
and non-financial contexts 
whenever business decision 
making includes reliance on 
models. 

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 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.

HSBC Holdings plc Annual Report and Accounts 2022

143

Risk review 
Risk review

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 237)

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 for credit risk, in terms of economic capital and the amount that could 
be lost if a counterparty fails to make repayments; for market risk, in terms of 
economic capital, internal metrics and fluctuations in key financial variables; and 
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 238)

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.

144

HSBC Holdings plc Annual Report and Accounts 2022

 
Credit risk 

Contents

145

145

147

148

151

Overview

Credit risk management

Credit risk in 2022

Summary of credit risk

Stage 2 decomposition as at December 2022

Credit exposure 

152
153 Measurement uncertainty and sensitivity analysis of ECL 
162

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
165
170 Wholesale lending
187

Personal lending

196

201

Supplementary information

HSBC Holdings 

Overview
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 derivatives. 
Credit risk management
Key developments in 2022

There were no material changes to the policies and practices for the 
management of credit risk in 2022. We continued to apply the 
requirements of IFRS 9 ‘Financial Instruments’ within the Credit Risk 
sub-function. For certain retail portfolios, we enhanced the significant 
increase in credit risk (‘SICR’) approach in relation to capturing relative 
movements in probability of default (‘PD’) since origination.

For our retail portfolios, we adopted the EBA ‘Guidelines on the 
application of definition of default’ during 2022 and, for our wholesale 
portfolios, these guidelines were adopted during 2021. Adoption of 
these guidelines did not have a material impact on our portfolios and 
comparative disclosures have not been restated.

We actively managed the risks related to macroeconomic 
uncertainties, including inflation, fiscal and monetary policy, the 
Russia-Ukraine war, broader geopolitical uncertainties, and the 
continued risks resulting from the Covid-19 pandemic.

For further details, see ‘Top and emerging risks’ on page 135.
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 Group 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, data and forward economic guidance

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.

We have a centralised process for generating unbiased and 
independent global economic scenarios. Scenarios are subject to a 
process of review and challenge by a dedicated team, as well as 
regional groupings. Each quarter, the scenarios and probability 
weights are reviewed and checked for consistency with the economic 
conjuncture and current economic and financial risks. These are 
subject to final review and approval by senior management in a 
Forward Economic Guidance Global Business Impairment Committee.

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 relevant global business impairment committee for 
final approval of the Group’s ECL for the period. Required members of 
the committee are the Wholesale Global Chief Corporate Credit 
Officer and Chief Risk Officer for 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 wholesale and retail 

HSBC Holdings plc Annual Report and Accounts 2022

145

Risk reviewRisk review

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.

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

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

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
BBB- to BB
BB- to B and 
unrated
B- to C
Default

A- and above
BBB+ to BBB-
BB+ to B and 
unrated
B- to C
Default

CRR 1 to CRR 2
CRR 3

0–0.169
0.170–0.740

Band 1 and 2
Band 3

0.000–0.500
0.501–1.500

CRR 4 to CRR 5

0.741–4.914

Band 4 and 5

1.501–20.000

CRR 6 to CRR 8
CRR 9 to CRR 10

4.915–99.999
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.

Forborne loans and advances

(Audited)

Forbearance measures consist of concessions towards an obligor that 
is experiencing or about to experience difficulties in meeting its 
financial commitments.

We continue to class loans as forborne when we modify the 
contractual payment terms due to having significant concerns about 
the borrowers’ ability to meet contractual payments when they were 
due.

In 2022, we expanded our definition of forborne to capture non-
payment-related concessions, such as covenant waivers. For our 
wholesale portfolio, we began identifying non-payment-related 
concessions in 2021 when our internal policies were changed. For our 
retail portfolios, we began identifying them during 2022. 

The comparative disclosures have been presented under the prior 
definition of forborne for the wholesale and retail portfolios.

For details of our policy on forbearance, see Note 1.2(i) in the financial 
statements.

Credit quality of forborne loans

For wholesale lending, where payment-related forbearance measures 
result in a diminished financial obligation, or if there are other 
indicators of impairment, the loan will be classified as credit impaired 
if it is not already so classified. All facilities with a customer, including 
loans that have not been modified, are considered credit impaired 
following the identification of a payment-related forborne loan. For 

retail lending, where a material payment-related concession has been 
granted, the loan will be classified as credit impaired. In isolation, non-
payment forbearance measures may not result in the loan being 
classified as credit impaired unless combined with other indicators of 
credit impairment. These are classed as performing forborne loans for 
both wholesale and retail lending.

Wholesale and retail lending forborne 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. Any forborne loans not considered credit impaired will 
remain forborne for a minimum of two years from the date that credit 
impairment no longer applies. For wholesale and retail lending, any 
forbearance measures granted on a loan already classed as forborne 
results in the customer being classed as credit impaired. 

Forborne loans and recognition of expected credit losses

(Audited)

Forborne loans expected credit loss assessments reflect the higher 
rates of losses typically experienced with these types of loans such 
that they are in stage 2 and stage 3. The higher rates are more 
pronounced in unsecured retail lending requiring further 
segmentation. For wholesale lending, forborne 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 forborne loans.

146

HSBC Holdings plc Annual Report and Accounts 2022

Impairment assessment

(Audited)

For details of our impairment policies on loans and advances and 
financial investments, see Note 1.2(i) on the financial statements.

Write-off of loans and advances

(Audited)

For details of our policy on the write-off of loans and advances, see 
Note 1.2(i) on the financial statements.

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 2022
At 31 December 2022, gross loans and advances to customers and 
banks of $1,041bn decreased by $99.1bn, compared with 
31 December 2021. This included adverse foreign exchange 
movements of $59.2bn and an $81.2bn decrease due to a 
reclassification of businesses to assets held for sale, including our 
banking business in Canada and our retail banking operations in 
France. 

Excluding foreign exchange movements, the underlying decrease of 
$39.9bn was driven by a $36.1bn decrease in personal loans and 
advances to customers and by a $29.9bn decrease in wholesale loans 
and advances to customers. These were partly offset by a $25.9bn 
increase in loans and advances to banks.

The underlying decrease in personal loans and advances to customers 
was driven by the $50.1bn reclassification of businesses to assets 
held for sale, and by a decrease in other personal lending, mainly in 
Hong Kong (down $1.5bn). This was offset by mortgage growth of 
$15.4bn, mainly in the UK (up $8.9bn), Hong Kong (up $3.4bn) and 
Australia (up $1.6bn).

The underlying increase in loans and advances to banks was driven by 
growth in the UK (up $10.6bn), Hong Kong (up $7.9bn) and Egypt (up 
$1.9bn), driven mainly by higher central bank placements.

At 31 December 2022, the allowance for ECL of $12.6bn increased by 
$0.5bn compared with 31 December 2021, including favourable 
foreign exchange movements of $0.6bn and the effect of 
reclassifications to assets held for sale of $0.4bn. The $12.6bn 
allowance comprised $12.1bn 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’).

Excluding foreign exchange movements, the allowance for ECL in 
relation to loans and advances to customers increased by $0.6bn from 
31 December 2021. This was attributable to:

• a $0.7bn increase in wholesale loans and advances to customers, 

of which $0.7bn was driven by stage 3; and

• a $0.1bn decrease in personal loans and advances to customers, 

of which $0.4bn was driven by stage 3, partly offset by an increase 
of $0.3bn in stages 1 and 2.

Stage 3 balances at 31 December 2022 increased by $1.9bn from 
31 December 2021. This was driven by a $3.2bn increase in 
wholesale loans and advances to customers, mainly in corporate real 
estate portfolios in Hong Kong. This was partly offset by a decrease 
of $1.3bn in personal loans and advances to customers.

At 31 December 2022, for certain retail lending portfolios, we 
introduced enhancements in the significant increase in credit risk 
(‘SICR’) approach in relation to capturing relative movements in 
probability of default (‘PD’). The enhanced approach captured relative 
movements in PD since origination, which resulted in a significant 
migration to stage 2 from loans to customers gross carrying amounts 
in stage 1.

The volume of stage 1 customer accounts with lower absolute levels 
of credit risk who have exhibited some amount of relative increase in 
PD since origination have migrated into stage 2, and accounts 
originated with higher absolute levels of credit risk with no or 
insignificant increases in PD since origination have been transferred to 
stage 1, with no material overall change in risk.

The impact on ECL is immaterial due to the offsetting ECL impacts of 
stage migrations and due to the low loan-to-value (‘LTV‘) profiles. This 
is particularly applicable to UK customers. 

The enhancement of the SICR approach constitutes an improvement 
towards more responsive models that better reflect the SICR since 
origination. This includes consideration of the current cost of living 
pressures, as markets adjust to the higher interest-rate environment.

In wholesale lending, China’s commercial real estate sector continued 
to deteriorate in 2022, resulting in further stage 2 allowances on 
downgrades and new and additional stage 3 charges.

The ECL charge for 2022 was $3.6bn, inclusive of recoveries. This 
was driven by higher ECL charges relating to increasing inflationary 
pressures, rising interest rates, China commercial real estate 
exposures and economic uncertainty, partly offset by a release in 
Covid-19-related allowances at the beginning of the year.

The ECL charge comprised: $2.4bn in respect of wholesale lending, of 
which $1.7bn were in stage 3 and purchased or originated credit 
impaired (‘POCI‘); $1.1bn in respect of personal lending, of which 
$0.5bn were in stage 3; and $0.1bn in respect of debt instruments 
measured at FVOCI.

Income statement movements are analysed further on page 101.

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 153;
• measurement uncertainty and sensitivity analysis of ECL 

estimates, see page 153;

• 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 162;

• credit quality, see page 165;
• total wholesale lending for loans and advances to banks and 

customers by stage distribution, see page 171;

• wholesale lending collateral, see page 180;
• total personal lending for loans and advances to customers at 

amortised cost by stage distribution, see page 188; and

• personal lending collateral, see page 193.

HSBC Holdings plc Annual Report and Accounts 2022

147

Risk reviewRisk review

Summary of credit risk
The following disclosure presents the gross carrying/nominal amount of financial instruments to which the impairment requirements in IFRS 9 
are applied and the associated allowance for ECL.

Summary of financial instruments to which the impairment requirements in IFRS 9 are applied

(Audited)

31 Dec 2022

 At 31 Dec 2021

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 
–  assets held for sale2
–  prepayments, accrued income and other assets3
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 sheet4

Gross carrying/
nominal amount

$m
936,307   
415,012   
454,356   
66,939   
104,951   
1,014,498   
327,005   
7,297   
43,787   
253,754   
168,827   
102,556   
111,272   
2,055,756   
618,788   
244,006   
269,187   
105,595   
18,783   
1,135   
13,587   
4,061   
637,571   
2,693,327   

Allowance for
ECL1
$m
(11,453)   
(2,872)   
(8,324)   
(257)   
(69)   
(553)   
(3)   
—   
—   
—   
(80)   
(415)   
(55)   
(12,075)   
(386)   
(27)   
(340)   
(19)   
(52)   
—   
(50)   
(2)   
(438)   
(12,513)   

Gross carrying/
nominal amount

Allowance for 
ECL1
$m

(11,417) 
(3,103) 
(8,204) 
(110) 
(17) 
(193) 
(4) 
— 
— 
— 
(62) 
(43) 
(84) 
(11,627) 
(379) 
(39) 
(325) 
(15) 
(62) 
— 
(58) 
(4) 
(441) 
(12,068) 

$m

1,057,231   
478,337   
513,539   
65,355   
83,153   
880,351   
403,022   
4,136   
42,578   
241,648   
97,364   
2,859   
88,744   
2,020,735   
627,637   
239,685   
283,625   
104,327   
27,795   
1,130   
22,355   
4,310   
655,432   
2,676,167   

Debt instruments measured at fair value through other comprehensive income 
(‘FVOCI’)

Memorandum 
allowance for 
ECL5
$m

Fair value

$m

Memorandum 
allowance for 
ECL5
$m

Fair value

$m

266,303   

(145)   

347,203   

(96) 

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 asset, 

in which case the ECL is recognised as a provision.

2  For further details on gross carrying amounts and allowances for ECL related to assets held for sale, see ‘Assets held for sale’ on page 151.
3 

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 326 comprises both financial and non-financial assets, including cash collateral and 
settlement accounts.

4  Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
5  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.

148

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at
31 December 2022
(Audited)

Gross carrying/nominal amount1

Allowance for ECL

ECL coverage %

Stage 
1

Stage 
2

$m

$m

Stage 

3 POCI2
$m

$m

Total

$m

Stage 
1

Stage 
2

Stage 
3

POCI
2

$m

$m

$m $m

Total

$m

Stage 
1

Stage 
2

%

%

Stage 

3 POCI2 Total
%
%
%

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
Loan and other 
credit-related 
commitments

–  personal
–  corporate and 
commercial

–  financial
Financial 
guarantees

–  personal
–  corporate and 
commercial

  777,543    139,130    19,505    129    936,307    (1,095)    (3,491)    (6,829)   

(38)   (11,453) 

  362,781    48,891   

3,340    —    415,012   

(562)    (1,505)   

(805)    —    (2,872) 

 0.1 

 0.2 

 2.5 

 3.1 

 35.0 

 24.1 

 29.5 

 — 

 1.2 

 0.7 

  353,010    85,521    15,696    129    454,356   

(490)    (1,909)    (5,887)   

(38)    (8,324) 

 0.1 

 2.2 

 37.5 

 29.5 

 1.8 

  61,752   

4,718   

469    —    66,939   

(43)   

(77)   

(137)    —   

(257) 

 0.1 

 1.6 

 29.2 

 — 

 0.4 

  103,042   

1,827   

82    —    104,951   

(18)   

(29)   

(22)    —   

(69) 

 — 

 1.6 

 26.8 

 — 

 0.1 

  996,489    17,166   

797   

46   1,014,498   

(124)   

(188)   

(234)   

(7)   

(553) 

 — 

 1.1 

 29.4 

 15.2 

 0.1 

  583,383    34,033   

1,372    —    618,788   

(141)   

(180)   

(65)    —   

(386) 

  239,521   

3,686   

799    —    244,006   

(26)   

(1)   

—    —   

(27) 

  241,313    27,323   
3,024   
  102,549   

551    —    269,187   
22    —    105,595   

(111)   
(4)   

(166)   
(13)   

(63)    —   
(2)    —   

(340) 
(19) 

  16,071   

2,463   

249    —    18,783   

1,123   

11   

1    —   

1,135   

(6)   

—   

(13)   

(33)    —   

(52) 

—   

—    —   

— 

  11,547   

1,793   

247    —    13,587   

(5)   

(12)   

(33)    —   

(50) 

 — 

 — 

 — 
 — 

 — 

 — 

 — 

 — 
 0.1 

 0.5 

 — 

 0.6 
 0.4 

 0.5 

 — 

 0.7 

 0.2 
 2.0 

 4.7 

 — 

 11.4 
 9.1 

 13.3 

 — 

 13.4 

 — 
 32.6 

 — 

 — 

 — 
 — 

 — 

 — 

 — 

 — 
 25.7 

 0.1 

 — 

 0.1 
 — 

 0.3 

 — 

 0.4 

 — 
 0.5 

–  financial
At 31 Dec 2022  2,476,528    194,619    22,005    175   2,693,327    (1,384)    (3,901)    (7,183)   

1    —   

4,061   

3,401   

659   

(1)   

(1)   

—    —   

(2) 
(45)   (12,513) 

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 2022

(Audited)

Gross carrying amount

Allowance for ECL

ECL coverage %

Stage 2

Up-to-
date

$m

$m

1 to 29 
DPD1,2
$m

30 and 

> DPD1,2 Stage 2
$m

$m

Up-to-
date

$m

1 to 29 
DPD1,2
$m

30 and 
> DPD1,2
$m

Stage 
2

Up-to-
date

%

%

1 to 29 
DPD1,2
%

30 and > 
DPD1,2
%

  139,130    134,733   

2,411   

1,986   

(3,491)   

(3,019)   

  48,891    46,402   

1,683   

806   

(1,505)   

(1,080)   

(234)   

(214)   

(238) 

(211) 

 2.5 

 3.1 

  85,521    84,005   

712   

804   

(1,909)   

(1,862)   

(20)   

(27) 

 2.2 

4,718   

4,326   

16   

376   

(77)   

(77)   

—   

1,827   

1,817   

—   

10   

(29)   

(29)   

—   

— 

— 

 1.6 

 1.6 

 2.2 

 2.3 

 2.2 

 1.8 

 1.6 

 9.7 

 12.7 

 2.8 

 — 

 — 

 12.0 

 26.2 

 3.4 

 — 

 — 

  17,166    16,930   

140   

96   

(188)   

(164)   

(8)   

(16) 

 1.1 

 1.0 

 5.7 

 16.7 

Loans and advances to 
customers at amortised 
cost
–  personal
–  corporate and 
commercial

–  non-bank financial 

institutions

Loans and advances to 
banks at amortised cost
Other financial assets 
measured at amortised 
cost

1  Days past due (‘DPD’).
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 2022

149

Risk review 
 
 
 
 
Risk review

Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at 
31 December 2021 (continued)
(Audited)

Gross carrying/nominal amount1
Stage 

Stage 
1

Stage 
2

$m

$m

3 POCI2
$m

$m

Allowance for ECL

ECL coverage %

Total

$m

Stage 
1

Stage 
2

$m

$m

Stage 

3 POCI2
$m

$m

Total

$m

Stage 
1

Stage 
2

%

%

Stage 

3 POCI2 Total
%
%
%

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
Loan and other 
credit-related 
commitments

–  personal
–  corporate and 
commercial

–  financial
Financial 
guarantees

–  personal
–  corporate and 
commercial

–  financial
At 31 Dec 2021

  918,936   119,224    18,797   

274    1,057,231    (1,367)    (3,119)    (6,867)   

(64)   (11,417) 

  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 

 24.8 

 23.4 

 — 

 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) 

  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   

1,114   

15   

1    —   

1,130   

(11)   

—   

(30)   

—   

(21)    —   

(62) 

—    —   

— 

20,025    2,107   

223    —   

22,355   

(10)   

(28)   

(20)    —   

(58) 

3,793   

516   

1    —   

4,310   

(1)   

(2)   

 2,494,993   160,756    20,101   

317    2,676,167    (1,648)    (3,380)    (6,970)   

(1)    —   

(4) 
(70)   (12,068) 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 — 
 0.1 

 0.5 

 0.1 

 0.6 

 0.3 

 1.1 

 — 

 1.3 

 0.4 
 2.1 

 5.2 

 — 

 6.6 

 — 

 9.3 

 — 

 9.0 

 — 

 — 

 — 

 — 

 — 

 — 

 — 

 100.0 
 34.7 

 — 
 22.1 

 0.1 

 — 

 0.1 

 — 

 0.2 

 — 

 0.3 

 0.1 
 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’).

Stage 2 days past due analysis at 31 December 2021 (continued)

(Audited)

Gross carrying amount

Allowance for ECL

ECL coverage %

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

Stage 2

$m

Up-to-
date

$m

1 to 29 
DPD1,2
$m

30 and > 
DPD1,2
$m

Stage 
2

$m

Up-to-
date

$m

1 to 29 
DPD1,2
$m

30 and > 
DPD1,2
$m

  119,224    115,350   

2,193   

1,681    (3,119)   

(2,732)   

  16,439    14,124   
  98,911    97,388   

1,387   
806   

928    (1,219)   
717    (1,874)   

(884)   
(1,822)   

(194)   

(160)   
(34)   

(193) 

(175) 
(18) 

3,874   

3,838   

—   

36   

(26)   

(26)   

—   

1,517   

1,517   

—   

—   

(3)   

(3)   

—   

— 

— 

%

 2.6 

 7.4 
 1.9 

 0.7 

 0.2 

 Stage 
2

Up-to-
date

4,988   

4,935   

22   

31   

(54)   

(47)   

(4)   

(3) 

 1.1 

1 to 29 
DPD1,2
%

30 and > 
DPD1,2
%

 8.8 

 11.5 
 4.2 

 — 

 — 

 11.5 

 18.9 
 2.5 

 — 

 — 

 18.2 

 9.7 

%

 2.4 

 6.3 
 1.9 

 0.7 

 0.2 

 1.0 

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.

150

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
Stage 2 decomposition
The following table presents the stage 2 decomposition of gross 
carrying amount and allowances for ECL for loans and advances to 
customers. It also sets out the reasons why an exposure is classified 
as stage 2 and therefore presented as a significant increase in credit 
risk at 31 December 2022.

The quantitative classification shows gross carrying values and 
allowances for ECL for which the applicable reporting date probability 

Loans and advances to customers1

of default (‘PD’) measure exceeds defined quantitative thresholds for 
retail and wholesale exposures, as set out in Note 1.2 ‘Summary of 
significant accounting policies’, on page 342.

The qualitative classification primarily accounts for CRR deterioration, 
watch-and-worry and retail management judgemental adjustments.

A summary of our current policies and practices for the significant 
increase in credit risk is set out in ‘Summary of significant accounting 
policies’ on page 342.

Quantitative
Qualitative
30 DPD backstop2
Total stage 2

Personal

$m
41,611   
7,233   
47   
48,891   

Quantitative
Qualitative
30 DPD backstop2
Total stage 2

9,907   
6,329   
203   
16,439   

Gross carrying amount
Corporate 
and 
commercial

Non-bank 
financial 
institutions

$m
66,450   
18,555   
516   
85,521   

68,000   
30,326   
585   
98,911   

$m
3,679   
878   
161   
4,718   

3,041   
818   
15   
3,874   

At 31 Dec 2022

Total

Personal

$m
111,740   
26,666   
724   
139,130   

$m
(1,301)   
(201)   
(3)   
(1,505)   

At 31 Dec 2021
(1,076)   
(134)   
(9)   
(1,219)   

80,948   
37,473   
803   
119,224   

Allowance for ECL

Corporate 
and 
commercial

Non-bank 
financial 
institutions

$m
(1,644)   
(262)   
(3)   
(1,909)   

(1,347)   
(520)   
(7)   
(1,874)   

$m
(66)   
(11)   
—   
(77)   

(19)   
(7)   
—   
(26)   

ECL coverage

Total

$m
(3,011) 
(474) 
(6) 
(3,491) 

(2,442) 
(661) 
(16) 
(3,119) 

Total

%
 2.7 
 1.8 
 0.8 
 2.5 

 3.0 
 1.8 
 2.0 
 2.6 

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’).

Assets held for sale
(Audited)

During 2022, gross loans and advances and related impairment 
allowances were reclassified from ‘loans and advances to customers’ 
and ‘loans and advances to banks’ to ‘assets held for sale’ in the 
balance sheet.

At 31 December 2022, the most material balances held for sale came 
from our banking business in Canada and from our retail banking 
operations in France.

Disclosures relating to assets held for sale are provided in the 
following credit risk tables, primarily where the disclosure is relevant 
to the measurement of these financial assets:

Loans and advances to customers and banks measured at amortised cost

(Audited)

• ‘Maximum exposure to credit risk’ (page 153);

• ‘Distribution of financial instruments by credit quality at 

31 December’ (page 165);

Although there was a reclassification on the balance sheet, there was 
no separate income statement reclassification. As a result, charges 
for changes in expected credit losses and other credit impairment 
charges shown in the credit risk disclosures include charges relating 
to financial assets classified as ‘assets held for sale’.

‘Loans and other credit-related commitments’ and ‘financial 
guarantees’, as reported in credit disclosures, also include exposures 
and allowances relating to financial assets classified as ‘assets held 
for sale’.

As reported
Reported in ‘Assets held for sale’
At 31 December

2022

Total gross loans and 
advances
$m

1,041,258   
81,221   
1,122,479   

Allowance for ECL

$m
(11,522)   
(392)   
(11,914)   

2021

Total gross loans and 
advances
$m

1,140,384   
2,424   
1,142,808   

Allowance for ECL

$m

(11,434) 
(39) 
(11,473) 

At 31 December 2022, gross loans and advances of our banking 
business in Canada were $55.5bn, and the related allowance for ECL 
were $0.2bn. Gross loans of our retail banking operations in France 
were $25.1bn, and the related allowance for ECL were $0.1bn. 

Lending balances held for sale continue to be measured at amortised 
cost less allowances for impairment and, therefore, such carrying 
amounts may differ from fair value. 

These lending balances are part of associated disposal groups that are 
measured in their entirety at the lower of carrying amount and fair 
value less costs to sell. Any difference between the carrying amount 
of these assets and their sales price is part of the overall gain or loss 
on the associated disposal group as a whole.

For further details of the carrying amount and the fair value at 
31 December 2022 of loans and advances to banks and customers 
classified as held for sale, see Note 23 on the financial statements.

HSBC Holdings plc Annual Report and Accounts 2022

151

Risk review 
 
 
 
 
 
 
 
 
 
 
Risk review

Gross loans and allowance for ECL on loans and advances to customers and banks reported in ‘Assets held for sale’

(Audited)

Banking business in 
Canada

Retail banking operations 
in France

Other1

Total

Loans and advances to customers 
at amortised cost
–  personal
–  corporate and commercial
–  non-bank financial institutions
Loans and advances to banks at 
amortised cost

At 31 December 2022

Gross 
carrying 
value

$m

55,431   

26,637   
27,128   
1,666   

100   

55,531   

Allowance 
for ECL

$m

(234)   

(75)   
(154)   
(5)   

—   

(234)   

Gross 
carrying 
value

$m

25,121   

22,691   
2,379   
51   

—   

25,121   

Allowance 
for ECL

Gross 
carrying 
value

Allowance 
for ECL

$m

(92)   

(88)   
(4)   
—   

—   

(92)   

$m

412   

305   
107   
—   

157   

569   

$m

(62)   

(47)   
(15)   
—   

(4)   

(66)   

Banking business in Canada

Retail banking operations in 
France

Gross 
carrying 
value

$m

Allowance 
for ECL

$m

Gross 
carrying 
value

$m

Allowance 
for ECL

$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
At 31 December 2021

—   

—   
—   
—   

—   

—   

—   

—   
—   
—   

—   

—   

—   

—   
—   
—   

—   

—   

—   

—   
—   
—   

—   

—   

Other2

Gross 
carrying 
value

$m

2,424   

2,424   
—   
—   

—   

2,424   

Allowance 
for ECL

$m

(39)   

(39)   
—   
—   

—   

(39)   

Gross 
carrying 
value

$m

80,964   

49,633   
29,614   
1,717   

257   

81,221   

Total

Gross 
carrying 
value

$m

2,424   

2,424   
—   
—   

—   

2,424   

Allowance 
for ECL

$m

(388) 

(210) 
(173) 
(5) 

(4) 

(392) 

Allowance 
for ECL

$m

(39) 

(39) 
— 
— 

— 

(39) 

1  Comprising assets held for sale relating to the planned sale of our branch operations in Greece and of our business in Russia.
2  Comprising assets held for sale relating to our mass market retail banking business in the US.

The table below analyses the amount of ECL (charges)/releases arising from assets held for sale. The charges during the period primarily relate 
to our retail banking operations in France.

Changes in expected credit losses and other credit impairment

(Audited)

ECL (charges)/releases arising from:
–  assets held for sale
– assets not held for sale
Year ended 31 December

Credit exposure
Maximum exposure to credit risk

(Audited)

This section provides information on balance sheet items and their 
offsets as well as loan and other credit-related commitments. 

Commentary on consolidated balance sheet movements in 2022 
is provided on page 106.

The offset on derivatives remains in line with the movements 
in maximum exposure amounts.

2022
$m

(5)   
(3,587)   
(3,592)   

2021
$m

— 
928 
928 

‘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.

152

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 credit risk is predominantly borne by the policyholder. See page 
341 and Note 31 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 180.

Maximum exposure to credit risk

(Audited)

Loans and advances to customers held at amortised cost
–  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 
–  assets held for sale
–  prepayments, accrued income and other assets
Derivatives 
Total on-balance sheet exposure to credit risk
Total off-balance sheet
–  financial and other guarantees
–  loan and other credit-related commitments
At 31 Dec 

Maximum
exposure

$m
924,854   
412,140   
446,032   
66,682   
104,882   
  1,029,618   
327,002   
7,297   
43,787   
253,754   
168,747   
115,919   
113,112   
284,146   
  2,343,500   
934,326   
106,861   
827,465   
  3,277,826   

2022

Offset

Maximum
exposure

$m

Net

$m

$m
(20,315)   
(2,575)   
(16,262)   
(1,478)   
—   

904,539    1,045,814   
475,234   
409,565   
505,335   
429,770   
65,245   
65,204   
83,136   
104,882   
882,708   
(8,969)    1,020,649   
403,018   
327,002   
—   
4,136   
7,297   
—   
42,578   
43,787   
—   
241,648   
244,785   
(8,969)   
97,302   
168,747   
—   
3,411   
115,919   
—   
90,615   
113,112   
—   
196,882   
10,649   
(273,497)   
(302,781)    2,040,719    2,208,540   
928,183   
934,326   
113,088   
106,861   
815,095   
827,465   
(302,781)    2,975,045    3,136,723   

—   
—   
—   

2021

Offset

Net

$m

$m
(22,838)    1,022,976 
470,773 
(4,461)   
488,511 
(16,824)   
63,692 
(1,553)   
—   
83,136 
870,477 
(12,231)   
—   
403,018 
—   
4,136 
—   
42,578 
229,417 
(12,231)   
—   
97,302 
—   
3,411 
—   
90,615 
(188,284)   
8,598 
(223,353)    1,985,187 
928,183 
113,088 
815,095 
(223,353)    2,913,370 

—   
—   
—   

Concentration of exposure

We have a number of global businesses with a broad range of 
products. We operate in a number of geographical markets with the 
majority of our exposures in Asia and Europe.

For an analysis of:

• financial investments, see Note 16 on the financial statements;

• trading assets, see Note 11 on the financial statements;

• derivatives, see page 187 and Note 15 on the financial statements; 

and

• loans and advances by industry sector and by the location of the 

principal operations of the lending subsidiary (or, in the case of the 
operations of The Hongkong and Shanghai Banking Corporation 
Limited, HSBC Bank plc, HSBC Bank Middle East Limited and 
HSBC Bank USA, by the location of the lending branch), see page 
170 for wholesale lending and page 187 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)

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.

Amid a deterioration in the economic and geopolitical environment, 
management judgements and estimates continued to be subject to a 
high degree of uncertainty in relation to assessing economic 
scenarios for impairment allowances in 2022. 

Inflation, economic contraction and high interest rates, combined with 
an unstable geopolitical environment and the effects of global supply 
chain disruption, contributed to elevated levels of uncertainty during 
the year. 

At 31 December 2022, as a result of this uncertainty, additional stage 
1 and 2 impairment allowances were recognised. Management 
continued to reflect a degree of caution both in the selection of 
economic scenarios and their weightings, and in the use of 
management judgemental adjustments, described in more detail 
below.

At 31 December 2022, there was a reduction in management 
judgemental adjustments compared with 31 December 2021. 
Adjustments related to Covid-19 and for sector-specific risks were 
reduced as scenarios and modelled outcomes better reflected the key 
risks at 31 December 2022.

HSBC Holdings plc Annual Report and Accounts 2022

153

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Methodology

Four global 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. 

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, management deviated from this probability 
weighting in the fourth quarter of 2022, and assigned additional 
weight to outer scenarios. 

Description of economic scenarios

The economic assumptions presented in this section have been 
formed by HSBC with reference to external forecasts and estimates, 
specifically for the purpose of calculating ECL. 

Economic forecasts in the Central scenario remain subject to a high 
degree of uncertainty. Upside and Downside scenarios are 
constructed so that they encompass the potential crystallisation of a 
number of key macro-financial risks. 

At the end of 2022, risks to the economic outlook included the 
persistence of high inflation and its consequences on monetary 
policy. Rapid changes to public policy also increased forecast 
uncertainty.

In Asia, the removal of Chinese Covid-19-related public health 
restrictions presents a key source of potential upside risk, but with 
significant near-term uncertainty relating to a subsequent surge of 
infections. This policy change could also have global implications. 

In Europe, risks relating to energy pricing and supply security remain 
significant. Geopolitical risks also remain significant and include the 
possibility of a prolonged and escalating Russia-Ukraine war, 
continued differences between the US and other countries with China 
over a range of economic and strategic issues, and the evolution of 
the UK’s relationship with the EU.

Economic forecasts for our main markets deteriorated in the fourth 
quarter as GDP growth slowed. In North America and Europe, high 
inflation and rising interest rates have reduced real household 
incomes and raised business costs, dampening consumption and 
investment and lowering growth expectations. The effects of higher 
interest rate expectations and lower growth are evident in asset price 
expectations, with house prices forecasts, in particular, significantly 
lower.

154

HSBC Holdings plc Annual Report and Accounts 2022

In Asia, forecasts for Hong Kong and mainland China were cut 
following weaker than expected third-quarter GDP growth, and due to 
China’s adherence to a stringent pandemic-related public health policy 
response for the majority of the year. While China made an abrupt 
reversal of the policy in December and GDP is expected to recover in 
2023, there remains a very high degree of uncertainty to both the 
upside and downside, and consensus forecasts have been slow to 
adjust. The increased uncertainty over China’s lifting of the 
restrictions has been reflected in management’s assessment of 
scenario probabilities.

The scenarios used to calculate ECL in the Annual Report and 
Accounts 2022 are described below.

The consensus Central scenario

HSBC’s Central scenario reflects a low-growth and higher-inflation 
environment across many of our key markets. The scenario features 
an initial period of below-trend GDP growth in most of our main 
markets as higher inflation and tighter monetary policy causes a 
squeeze on business margins and households’ real disposable 
income. Growth returns to its long-term expected trend in later years 
as central banks bring inflation back to target. 

However, three of our markets are forecast to experience increased 
GDP growth. In Hong Kong and mainland China, GDP growth is 
expected to be stronger in 2023 relative to 2022, following several 
quarters of negative GDP growth and the suspension of Covid-19-
related restrictions. In the UAE, high oil prices and the continued 
recovery of international travel and tourism are expected to ensure 
growth remains above trend in the short term.  

Our Central scenario assumes that inflation peaked in most of our key 
markets at the end of 2022, but remains high through 2023, before 
moderating as energy prices stabilise and supply chain disruptions 
abate. Central banks are expected to keep raising interest rates until 
the middle of 2023. Inflation is forecast to revert to target in most 
markets by early 2024. 

Global GDP is expected to grow by 1.6% in 2023 in the Central 
scenario, and the average rate of global GDP growth is forecast to be 
2.5% over the five-year forecast period. This is below 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 European and North American markets 

continues to weaken. Most major economies are forecast to grow 
in 2023, but at very low rates. Hong Kong and mainland China are 
expected to see a recovery in activity from 2023 as Covid-19-
related restrictions are lifted. 

• In most markets, unemployment rises moderately from historical 
lows as economic activity slows. Labour markets remain fairly 
tight across our key markets.

• Inflation is expected to remain elevated across many of our key 

markets, driven by energy and food prices. Inflation is 
subsequently expected to converge back towards central banks’ 
target rates over the next two years of the forecast. 

• Policy interest rates in key markets will continue to rise in the near 
term but at a slower pace. Interest rates will stay elevated but 
start to ease as inflation in each of the markets return to target.

• The West Texas Intermediate oil price is forecast to average $72 

per barrel over the projection period.

The Central scenario was first created with forecasts available in 
November, and reviewed continually until late December. Probability 
weights assigned to the Central scenario vary from 55% to 70% and 
reflect relative differences in risk and uncertainty across markets. 

The following table describes key macroeconomic variables and the probabilities assigned in the consensus Central scenario.

Central scenario 2023–2027

GDP growth rate
2023: Annual average growth rate
2024: Annual average growth rate
2025: Annual average growth rate
5-year average
Unemployment rate
2023: Annual average rate
2024: Annual average rate
2025: Annual average rate
5-year average
House price growth
2023: Annual average growth rate
2024: Annual average growth rate
2025: Annual average growth rate
5-year average
Inflation rate
2023: Annual average rate
2024: Annual average rate
2025: Annual average rate
5-year average
Probability

UK
%

 (0.8) 
 1.3 
 1.7 
 1.1 

 4.4 
 4.6 
 4.3 
 4.3 

 0.2 
 (3.8) 
 0.7 
 0.4 

 6.9 
 2.5 
 2.1 
 3.1 
 60 

US
%

Hong Kong Mainland China
%

%

Canada
%

France
%

UAE
%

Mexico
%

 0.2 
 1.5 
 2.0 
 1.5 

 4.3 
 4.5 
 4.2 
 4.2 

 (2.5) 
 (3.2) 
 (1.0) 
 (0.7) 

 4.1 
 2.5 
 2.2 
 2.7 
 70 

 2.7 
 3.0 
 2.7 
 2.7 

 3.7 
 3.5 
 3.4 
 3.4 

 (10.0) 
 (3.0) 
 1.7 
 (1.0) 

 2.1 
 2.1 
 2.0 
 2.1 
 55 

 4.6 
 4.8 
 4.7 
 4.6 

 5.2 
 5.1 
 5.0 
 5.0 

 (0.1) 
 2.9 
 3.5 
 2.9 

 2.4 
 2.2 
 2.2 
 2.2 
 55 

 0.6 
 1.9 
 2.0 
 1.6 

 6.1 
 5.9 
 6.0 
 5.9 

 (15.6) 
 (1.2) 
 4.0 
 (1.1) 

 3.5 
 2.2 
 2.1 
 2.4 
 70 

 0.2 
 1.6 
 1.5 
 1.2 

 7.6 
 7.5 
 7.3 
 7.3 

 1.8 
 2.0 
 3.1 
 2.8 

 4.6 
 2.0 
 1.8 
 2.4 
 60 

 3.7 
 3.7 
 3.1 
 3.2 

 2.9 
 2.8 
 2.8 
 2.8 

 5.9 
 5.2 
 4.5 
 4.4 

 3.2 
 2.2 
 2.1 
 2.3 
 70 

 1.2 
 2.0 
 2.3 
 1.9 

 3.7 
 3.7 
 3.5 
 3.6 

 7.9 
 5.2 
 4.2 
 5.1 

 5.7 
 4.1 
 3.7 
 4.2 
 70 

The graphs compare the respective Central scenario at the year end 2021 with economic expectations at the end of 2022.

GDP growth: Comparison of Central scenarios

UK
25

20

15

10

5

0

‐5

‐10

4Q21 Central 5Y Average: 2.5%
4Q22 Central 5Y Average: 1.1%

US

14

12

10

8

6

4

2

0

‐2

100

90

80

70

60

50

40

30

20

10

0

4Q21 Central 5Y Average: 2.5%
4Q22 Central 5Y Average: 1.5%

2021

2022

2023

2024

2025

2026

2027

2021

2022

2023

2024

2025

2026

2027

4Q21 Central

4Q22 Central

4Q21 Central

4Q22 Central

Note: Real GDP shown as year-on-year percentage change.

Note: Real GDP shown as year-on-year percentage change.

Hong Kong

Mainland China

10

8

6

4

2

0

‐2

‐4

‐6

4Q21 Central 5Y Average: 2.7%
4Q22 Central 5Y Average: 2.7%

100

90

80

70

60

50

40

30

20

10

0

20

18

16

14

12

10

8

6

4

2

0

4Q21 Central 5Y Average: 5.1%
4Q22 Central 5Y Average: 4.6%

2021

2022

2023

2024

2025

2026

2027

2021

2022

2023

2024

2025

2026

2027

4Q21 Central

4Q22 Central

4Q21 Central

4Q22 Central

Note: Real GDP shown as year-on-year percentage change.

Note: Real GDP shown as year-on-year percentage change.

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

HSBC Holdings plc Annual Report and Accounts 2022

155

Risk reviewRisk review

The consensus Upside scenario

Compared with the Central scenario, the consensus Upside scenario 
features stronger economic activity in the near term, before 
converging to long-run trend expectations. It also incorporates a faster 
fall in the rate of inflation than incorporated in the Central scenario. 

The scenario is consistent with a number of key upside risk themes. 
These include faster resolution of supply chain issues; a rapid 

Consensus Upside scenario ‘best outcome’

conclusion to the Russia-Ukraine war; de-escalation of tensions 
between the US and China; relaxation of Covid-19 policies in Asia; and 
improved relations between the UK and the EU.

The following table describes key macroeconomic variables and the 
probabilities assigned in the consensus Upside scenario.

GDP growth rate
Unemployment rate
House price growth
Inflation rate
Probability

UK

%
 4.4  (4Q24)
 3.5  (4Q23)
 4.2  (1Q23)
 0.7  (1Q24)
5

US

Hong Kong Mainland China

Canada

%
 3.6  (4Q24)
 3.1  (3Q23)
 3.6  (1Q23)
 1.6  (1Q24)
5

%
 9.0  (3Q23)
 3.0  (4Q23)
 1.4  (4Q24)
 (0.1)  (4Q23)
20

%

 10.3  (2Q23)
 4.7  (3Q24)
 6.9  (4Q24)
 0.8  (4Q23)

20

%
 4.3  (3Q24)
 5.2  (3Q24)
 4.9  (2Q24)
 1.0  (1Q24)

5

France
%
 3.1  (1Q24)
 6.5  (4Q24)
 3.7  (1Q23)
 0.8  (4Q23)

5

UAE
%
 7.8  (4Q23)
 2.2  (3Q24)
 9.5  (2Q24)
 1.5  (3Q24)
5

Mexico

%
 4.7  (4Q23)
 3.1  (3Q23)
 10.3  (4Q23)
 3.2  (1Q24)

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. The date on which the extreme is reached is indicated in parenthesis. For inflation, lower inflation is interpreted as 
the ‘best’ outcome.

Downside scenarios

Downside scenarios explore the intensification and crystallisation of a 
number of key economic and financial risks. 

High inflation and a stronger monetary policy response have become 
key concerns for global growth. In the Downside scenarios, supply 
chain disruptions intensify, exacerbated by an escalation in the spread 
of Covid-19, and rising geopolitical tensions drive inflation higher. 

There also remains a risk that energy and food prices rise further due 
to the Russia-Ukraine war, increasing pressure on household budgets 
and firms’ costs. 

The possibility of inflation expectations becoming detached from 
central bank targets also remains a risk. A wage-price spiral triggered 
by higher inflation and pandemic-related labour supply shortages 
could put sustained upward pressure on wages, aggravating cost 
pressures and increasing the squeeze on household real incomes and 
corporate margins. In turn, it raises the risk of a more forceful policy 
response from central banks, a steeper trajectory for interest rates 
and, ultimately, a deep economic recession. 

The risks relating to Covid-19 are centred on the emergence of a new 
variant with greater vaccine resistance that necessitates the 
imposition of stringent public health policies. In Asia, with the 
reopening of China in December, management of Covid-19 remains a

key source of uncertainty, with the rapid spread of the virus posing a 
heightened risk of new vaccine-resistant variants emerging.

The geopolitical environment also present risks, including: 

• a prolonged Russia-Ukraine war with escalation beyond Ukraine’s

borders;

• the deterioration of the trading relationship between the UK and

the EU over the Northern Ireland Protocol; and

• continued differences between the US and other countries with
China, which could affect sentiment and restrict global economic
activity.

The consensus Downside scenario

In the consensus Downside scenario, economic activity is 
considerably weaker compared with the Central scenario. In this 
scenario, GDP growth weakens below the Central scenario, 
unemployment rates rise and asset prices fall. The scenario features a 
temporary supply side shock that keeps inflation higher than the 
baseline, before the effects of weaker demand begin to dominate, 
leading to a fall in commodity prices and to lower inflation. 

The following table describes key macroeconomic variables and the 
probabilities assigned in the consensus Downside scenario.

Consensus Downside scenario ‘worst outcome’

GDP growth rate
Unemployment rate
House price growth
Inflation rate (min)
Inflation rate (max)
Probability

UK

%

 (3.5)  (3Q23)
 5.8  (2Q24)
 (10.1)  (2Q24)
 (0.4)  (4Q24)
 10.8  (1Q23)
25

US

%

 (3.7)  (4Q23)
 5.9  (1Q24)
 (7.8)  (4Q23)
 0.6  (4Q24)
 6.2  (1Q23)
20

Hong Kong Mainland China

Canada

%

 (2.2)  (4Q23)
 5.2  (3Q24)
 (14.9)  (2Q23)
 0.3  (4Q24)
 3.7  (4Q23)
20

%

 (1.2)  (4Q23)
 5.9  (4Q23)
 (1.9)  (1Q23)
 0.7  (4Q24)
 4.0  (4Q23)

20

%

 (3.9)  (4Q23)
 7.6  (3Q23)
 (23.8)  (2Q23)
 0.4  (4Q24)
 6.0  (1Q23)

France
%

 (1.4)  (3Q23)
 8.8  (4Q23)
 (0.6)  (4Q23)
 0.3  (4Q24)
 7.2  (1Q23)

UAE
%
 1.0  (4Q23)
 4.1  (3Q23)
 (3.0)  (4Q23)
 1.8  (2Q23)
 4.5  (1Q23)
20

Mexico

%

 (2.7)  (4Q23)
 4.4  (1Q23)
 2.2  (3Q24)
 2.2  (4Q24)
 7.9  (1Q23)

20

15

25

Note: Extreme point in the consensus Downside is ‘worst outcome‘ in the scenario, for example lowest GDP growth and the highest unemployment rate, 
in the first two years of the scenario. The date on which the extreme is reached is indicated in parenthesis. Due to the nature of the shock to inflation in 
the Downside scenarios, both the lowest and the highest point is shown in the tables.

Downside 2 scenario

The Downside 2 scenario features a deep global recession and 
reflects management’s view of the tail of the economic distribution. It 
incorporates the crystallisation of a number of risks simultaneously, 
including further escalation of the Russia-Ukraine war, worsening of 
supply chain disruptions and the emergence of a vaccine-resistant 
Covid-19 variant that necessitates a stringent public health policy 
response globally. 

This scenario features an initial supply-side shock that pushes up 
inflation and interest rates higher. This impulse is expected to prove 
short lived as a large downside demand pressure causes commodity 
prices to correct sharply and global price inflation to fall as a severe 
and prolonged recession takes hold.

156

HSBC Holdings plc Annual Report and Accounts 2022

The following table describes key macroeconomic variables and the probabilities assigned in the Downside 2 scenario.

Downside 2 scenario ‘worst outcome’

GDP growth rate
Unemployment rate
House price growth
Inflation rate (min)
Inflation rate (max)
Probability

UK

%

US

%

 (6.9)  (3Q23)
 8.7  (2Q24)
 (22.9)  (2Q24)
 (2.3)  (2Q24)
 13.5  (2Q23)
10

 (5.0)  (4Q23)
 9.5  (4Q24)
 (21.5)  (4Q23)
 0.3  (4Q24)
 6.3  (1Q23)
5

Hong Kong Mainland China

Canada

%

 (9.2)  (4Q23)
 5.8  (1Q24)
 (18.2)  (1Q24)
 0.6  (4Q24)
 4.3  (4Q23)
5

%

%

 (6.9)  (4Q23)
 6.8  (4Q24)
 (18.5)  (4Q23)
 1.0  (4Q24)
 4.6  (4Q23)

5

 (5.9)  (4Q23)
 11.6  (2Q24)
 (36.3)  (4Q23)
 1.1  (4Q24)
 6.5  (1Q23)

10

France
%

 (6.8)  (4Q23)
 10.3  (4Q24)
 (6.4)  (2Q24)
 (2.5)  (2Q24)
 10.4  (2Q23)
10

UAE
%

 (3.7)  (2Q24)
 4.6  (2Q24)
 (3.6)  (4Q23)
 1.7  (4Q24)
 4.8  (1Q23)
5

Mexico

%

 (7.4)  (4Q23)
 5.6  (2Q24)
 0.9  (3Q24)
 2.0  (4Q24)
 7.9  (1Q23)

5

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. The date on which the extreme is reached is indicated in parenthesis. Due to the nature of the shock to inflation in the 
Downside scenarios, both the lowest and the highest point is shown in the tables.

Scenario weighting

In reviewing the economic conjuncture, the level of risk and 
uncertainty, 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.

Key consideration around uncertainty attached to the Central scenario 
projections focused on: 

• the progression of the Covid-19 pandemic in Asian countries, and
the announcement of the removal of Covid-19-related measures
and travel restrictions in mainland China and Hong Kong;

• further tightening of monetary policy, and the impact on borrowing

costs in interest-rate sensitive sectors, such as housing;

• the risks to gas supply security in Europe, and the subsequent
impact on inflation and commodity prices and growth; and

• the ongoing risks to global supply chains.

In mainland China and Hong Kong, the announcement of the 
relaxation of Covid-19-related measures and travel restrictions has led 
to increased uncertainty around the Central scenario projection. It was 
management’s view that the easing of the policy could increase risks 
to the upside in the form of increased spending and travel. However, 
the continuing risks to the downside were also acknowledged, given 
the surge in Covid-19 infections and the potential for a new vaccine-
resistant variant. This led management to assign a combined 
weighting of 75% to the consensus Upside and Central scenarios in 
both markets.

In the UK and US, the surge in price inflation and a squeeze on 
household real incomes have led to strong monetary policy responses 
from both central banks. Higher interest rates have increased 
recession risks and the prospects for outright decline in house prices. 
The UK faces additional challenges from the rise in energy prices and 
accompanying deterioration in the terms of trade. For Canada and 
Mexico, similar risk themes dominate, and the connectivity to the US 
has also been a key consideration. For the UK, the consensus Upside 
and Central scenarios had a combined weighting of 65%. In each of 
the other three markets, the combined weightings of the consensus 
Upside and Central scenarios were 75%. 

In France, uncertainties around the outlook remain elevated due to 
high inflation and Europe’s exposure to the Russia-Ukraine war 
through the economic costs incurred from the imposition of 
sanctions, trade disruption and energy dependence on Russia. The 
consensus Upside and Central scenarios had a combined weighting of 
65%. 

Management concluded that the outlook for the UAE was the least 
uncertain of all our key markets. It is benefiting from higher 
commodity prices and the revival in tourism and travel. The 
consensus Upside and Central scenarios had a combined weighting of 
75%.

The following graphs show the historical and forecasted GDP growth 
rate for the various economic scenarios in our four largest markets.

US

14.0

12.0

10.0

8.0

6.0

4.0

2.0

0.0

‐2.0

‐4.0

‐6.0

UK

2021

2022

2023

2024

2025

2026

2027

Central

Upside

Downside

Downside 2

25.0

20.0

15.0

10.0

5.0

0.0

‐5.0

‐10.0

2021

2022

2023

2024

2025

2026

2027

Central

Upside

Downside

Downside 2

Hong Kong

10.0

8.0

6.0

4.0

2.0

0.0

‐2.0

‐4.0

‐6.0

‐8.0

‐10.0

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

100

90

80

70

60

50

40

30

20

10

0

2021

2022

2023

2024

2025

2026

2027

Central

Upside

Downside

Downside 2

HSBC Holdings plc Annual Report and Accounts 2022

157

Risk reviewRisk review

Mainland China

20.0

15.0

10.0

5.0

0.0

‐5.0

‐10.0

100

90

80

70

60

50

40

30

20

10

0

2021

2022

2023

2024

2025

2026

2027

Central

Upside

Downside

Downside 2

Critical estimates and judgements

The calculation of ECL under IFRS 9 involves significant judgements, 
assumptions and estimates. The level of estimation uncertainty and 
judgement has remained elevated since 31 December 2021, including 
judgements relating to:

• the selection and weighting of economic scenarios, given rapidly
changing economic conditions and a wide dispersion of economic
forecasts. There is judgement in making assumptions about the
effects of inflation and interest rates, global growth, supply chain
disruption; and

• estimating the economic effects of those scenarios on ECL,

particularly as the historical relationship between macroeconomic
variables and defaults might not reflect the dynamics of current
macroeconomic conditions.

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 2022, 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 2022.

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 the forward economic guidance proportionate to the 
probability-weighted outcome and the Central scenario outcome of 
the performing population.

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. 

158

HSBC Holdings plc Annual Report and Accounts 2022

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 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 
typically 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.

This includes refining model inputs and outputs and using 
adjustments to ECL based on management judgement and higher-
level quantitative analysis for impacts that are difficult to model.

The effects of management judgemental adjustments are considered 
for both balances and ECL when determining whether or not a 
significant increase in credit risk has occurred and is allocated to a 
stage where 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 145). 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.

The drivers of management judgemental adjustments continue to 
evolve with the economic environment and as new risks emerge.

At 31 December 2022, there was a $0.9bn reduction in management 
judgemental adjustments compared with 31 December 2021. 
Adjustments related to Covid-19 and for sector-specific risks were 
reduced as scenarios and modelled outcomes better reflected the key 
risks at 31 December 2022.

Management judgemental adjustments made in estimating the 
scenario-weighted reported ECL at 31 December 2022 are set out in 
the following table. 

Management judgemental adjustments to ECL at 31 December 
20221

Retail
$bn

Wholesale
$bn

Total
$bn

Banks, sovereigns, 
government entities and 
low-risk counterparties
Corporate lending 
adjustments
Retail lending inflation-
related adjustments
Other macroeconomic-
related adjustments
Pandemic-related 
economic recovery 
adjustments
Other retail lending 
adjustments

Total

— 

0.1 

0.1 

— 

0.2 

0.3 

.

— 

0.5 

0.5 

— 

0.5 

0.1 

0.1 

— 

0.2 

0.8 

Economic scenarios sensitivity analysis of 
ECL estimates

Management considered the sensitivity of the ECL outcome against 
the economic forecasts as part of the ECL governance process by 
recalculating the ECL under each scenario described above for 
selected portfolios, applying a 100% weighting to each scenario in 
turn. The weighting is reflected in both the determination of a 
significant increase in credit risk and the measurement of the 
resulting ECL.

The ECL calculated for the Upside and Downside scenarios should 
not be taken to represent the upper and lower limits of possible ECL 
outcomes. The impact of defaults that might occur in the future under 
different economic scenarios is captured by recalculating ECL for 
loans 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. Due to the range and specificity of the 
credit factors to which the ECL is sensitive, it is not possible to 
provide a meaningful alternative sensitivity analysis for a consistent 
set of risks across all defaulted obligors.

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 tables present the 100% 
weighted results. These exclude portfolios held by the insurance 
business and small portfolios, and as such cannot be directly 
compared with personal and wholesale lending presented in other 
credit risk tables. 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 risks relative to the consensus scenarios for the period end.

The wholesale and retail sensitivity analysis is stated inclusive of 
management judgemental adjustments, as appropriate to each 
scenario.

Management judgemental adjustments to ECL at 31 December 
20211

Retail
$bn

Wholesale
$bn

Banks, sovereigns, 
government entities and 
low-risk counterparties
Corporate lending 
adjustments
Retail lending inflation-
related adjustments
Other macroeconomic-
related adjustments
Pandemic-related 
economic recovery 
adjustments
Other retail lending 
adjustments
Total

(0.1)   

1.3   

1.2   

0.2 

0.3 

0.5   

Total
$bn

(0.1) 

1.3 

— 

— 

0.2 

0.3 

1.7 

1  Management judgemental adjustments presented in the table reflect 

increases or (decreases) to ECL, respectively.

Management judgemental adjustments at 31 December 2022 were 
an increase to ECL of $0.5bn for the wholesale portfolio and an 
increase to ECL of $0.3bn for the retail portfolio.

At 31 December 2022, wholesale management judgemental 
adjustments were an ECL increase of $0.5bn (31 December 2021: 
$1.2bn increase). 

• Adjustments to corporate exposures increased ECL by $0.5bn at 
31 December 2022 (31 December 2021: $1.3bn increase). These 
principally reflected the outcome of management judgements for 
high-risk and vulnerable sectors in some of our key markets. This 
was supported by credit experts’ input, portfolio risk metrics, 
short- to medium-term risks under each scenario, model 
performance, quantitative analyses and benchmarks. 
Considerations include risk of individual exposures under different 
macroeconomic scenarios and sub-sector analyses.
The largest increase in ECL was observed in the real estate sector, 
including material adjustments to reflect the uncertainty of the 
higher-risk Chinese commercial real estate exposures, booked in 
Hong Kong.

At 31 December 2022, retail management judgemental adjustments 
were an ECL increase of $0.3bn (31 December 2021: $0.5bn 
increase).

• Retail lending inflation-related adjustments increased ECL by 
$0.1bn (31 December 2021: $0.0bn). These adjustments 
addressed where increasing inflation and interest rates result in 
affordability risks that were not fully captured by the modelled 
output.

• Other macroeconomic-related adjustments increased ECL by 

$0.1bn (31 December 2021: $0.0bn). These adjustments were 
primarily in relation to country-specific risks related to future 
macroeconomic conditions. 

• Other retail lending adjustments increased ECL by $0.2bn 

(31 December 2021: $0.3bn increase), reflecting all other data, 
model and management judgemental adjustments. 

• Pandemic-related economic recovery adjustments were removed 

during 2022 as scenarios stabilised.

HSBC Holdings plc Annual Report and Accounts 2022

159

Risk review 
 
 
 
 
 
 
 
 
Risk review

Wholesale analysis

IFRS 9 ECL sensitivity to future economic conditions1,2,3

By geography at 31 Dec 2022
UK
US
Hong Kong
Mainland China
Canada4
Mexico
UAE
France

By geography at 31 Dec 2021
UK
US
Hong Kong
Mainland China
Canada4
Mexico
UAE
France

Gross carrying 
amount2
$m
421,685   
190,858   
415,875   
125,466   
83,274   
26,096   
45,064   
173,146   

483,273   
227,817   
434,608   
120,627   
85,117   
23,054   
44,767   
163,845   

Reported ECL

Consensus 
Central 
scenario ECL

Consensus 
Upside 
scenario ECL

Consensus 
Downside 
scenario ECL

Downside 2 
scenario ECL

$m
769   
277   
925   
295   
126   
88   
45   
110   

920   
227   
767   
149   
151   
118   
158   
133   

$m
624   
241   
819   
242   
80   
80   
41   
102   

727   
204   
652   
113   
98   
80   
122   
121   

$m
484   
227   
592   
144   
60   
67   
30   
90   

590   
155   
476   
36   
61   
61   
73   
106   

$m
833   
337   
1,315   
415   
148   
116   
55   
121   

944   
317   
984   
216   
150   
123   
214   
162   

$m
2,240 
801 
2,161 
1,227 
579 
313 
93 
145 

1,985 
391 
1,869 
806 
1,121 
358 
711 
187 

1  ECL sensitivity includes off-balance sheet financial instruments. These 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 170. 
4  Classified as held for sale at 31 December 2022.

At 31 December 2021, the most significant level of ECL sensitivity 
was observed in the UK, Hong Kong and mainland China. 

Real estate was the sector with higher sensitivity to a severe 
Downside scenario, namely in Hong Kong and mainland China due to 
higher risk of some material exposures.

In the UK, the real estate and services sectors accounted for the 
majority of ECL sensitivity due to higher exposure to these sectors in 
this market.

160

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Retail analysis

IFRS 9 ECL sensitivity to future economic conditions1

Gross carrying 
amount

Reported ECL

Consensus 
Central scenario 
ECL

Consensus 
Upside scenario 
ECL

Consensus 
Downside 
scenario ECL

Downside 2 
scenario ECL

By geography at 31 December 
2022

UK
Mortgages
Credit cards
Other
Mexico
Mortgages
Credit cards
Other
Hong Kong
Mortgages
Credit cards
Other
UAE
Mortgages
Credit cards
Other
France3
Mortgages
Other
US
Mortgages
Credit cards
Canada2
Mortgages
Credit cards
Other

$m

147,306   
6,518   
7,486   

6,319   
1,616   
3,447   

100,107   
8,003   
5,899   

2,170   
441   
718   

21,440   
1,433   

13,489   
219   

25,163   
299   
1,399   

$m

204   
455   
368   

152   
198   
438   

1   
261   
85   

37   
41   
17   

51   
54   

7   
26   

45   
10   
16   

$m

188   
434   
333   

127   
162   
400   

1   
227   
81   

37   
37   
17   

50   
53   

6   
25   

44   
9   
14   

$m

183   
396   
274   

102   
97   
318   

—   
180   
74   

36   
21   
15   

50   
52   

6   
23   

43   
8   
13   

IFRS 9 ECL sensitivity to future economic conditions1 

Gross carrying 
amount

Reported ECL

By geography at 31 December 
2021
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

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   

$m

191   
439   
369   

123   
141   
366   

—   
218   
109   

45   
43   
19   

63   
61   

28   
80   

28   
9   
19   

Consensus 

Consensus 

Central scenario   

Upside scenario   

ECL

$m

182   
381   
298   

116   
134   
360   

—   
206   
101   

44   
41   
18   

62   
61   

27   
76   

27   
9   
18   

ECL

$m

175   
330   
254   

106   
122   
350   

—   
154   
88   

42   
29   
13   

62   
60   

26   
70   

26   
9   
17   

$m

189   
442   
383   

183   
233   
503   

1   
417   
100   

38   
68   
19   

51   
55   

8   
27   

46   
11   
17   

$m

399 
719 
605 

270 
289 
618 

1 
648 
123 

38 
86 
22 

52 
59 

15 
36 

58 
11 
36 

Consensus 
Downside 
scenario ECL

Downside 2 
scenario ECL

$m

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 

1   ECL sensitivities exclude portfolios utilising less complex modelling approaches.
2   Classified as ‘assets held for sale’ at 31 December 2022.
3  Includes balances and ECL, which have been reclassified from ‘loans and advances to customers’ to ‘assets held for sale’ in the balance sheet. This 
also includes any balances and ECL which continue to be reported as personal lending in ‘loans and advances to customers’ that are in accordance 
with the basis of inclusion for retail sensitivity analysis.

HSBC Holdings plc Annual Report and Accounts 2022

161

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

At 31 December 2022, 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. Credit cards 
and other unsecured lending are more sensitive to economic 
forecasts, and therefore reflected the highest level of ECL sensitivity 
during 2022.
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 2022, it would increase/(decrease) as presented in the 
below table.

Total Group ECL at 31 December 2022
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 2021
Reported ECL
Scenarios
100% Consensus Central scenario
100% Consensus Upside scenario
100% Consensus Downside scenario
100% Downside 2 scenario

Retail1 Wholesale1
$bn
3.1 

$bn 
3.0   

(0.2)   
(0.6)   
0.4   
1.8   

(0.5) 
(1.1) 
0.8 
5.5 

Retail1
$bn
3.0   

Wholesale
$bn
3.1 

(0.2)   
(0.5)   
0.2   
2.0   

(0.6) 
(1.2) 
0.6 
5.5 

1  On the same basis as retail and wholesale sensitivity analysis.

At Group level for both the retail and wholesale portfolios, the 
reported ECL in scope of this analysis remained stable since 
31 December 2021. The Group total Downside 2 scenario ECL 
continues to present the highest level of sensitivity.

The ECL sensitivity for the Central scenario remained flat for the 
wholesale and retail portfolios from the previous year. For the 
remaining scenarios, the changes in ECL sensitivity from the previous 
year were reflective of geographical and sector risks, which increased 
or reduced accordingly with macroeconomic conditions.

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.

162

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
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

$m

  1,577,582   

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
(1,557)   

$m
155,742   

$m
(3,326)   

$m
19,797   

$m
(6,928)   

$m
274   

$m
(64)    1,753,395   

$m

$m

(11,875) 

(99,022)   

(798)   

89,052   

1,620   

9,970   

(822)   

(225,616)   

470   

225,616   

(470)   

128,246   

(1,216)   

(128,246)   

(2,392)   
740   

9   
(61)   

(10,087)   
1,769   

1,216   

1,132   
(258)   

—   

—   

—   

—   

12,479   
(2,509)   

(1,141)   
319   

—   

—   

—   

—   
—   

—   

—   

—   

—   
—   

—   

—   

—   

—   
—   

— 

— 

— 

— 
— 

—   

739   

—   

(953)   

—   

(152)   

—   

—   

—   

(366) 

483,617   

(548)   

—   

—   

—   

—   

26   

(2)   

483,643   

(550) 

(318,659)   

148   

(37,941)   

343   

(2,806)   

416   

(97)   

—   

(359,503)   

(65,778)   

226   

(6,963)   

93   

(594)   

259   

(61)   

5   

(73,396)   

907 

583 

—   

403   

—   

(1,670)   

—   

(3,019)   

—   

—   
—   

4   
—   

—   
—   

(151)   
—   

—   

13   

(2,794)   

2,794   

—   

(10)   

32   

—   

10   

—   

(4,254) 

—   

(134) 

(2,804)   

2,804 

—   

—   

—   

—   

(32)   

9   

(81,975)   
(60,557)   
  1,435,208   

59   
64   
(1,260)   

(8,811)   
(13,716)   
177,363   

972 

(1,395)   
(938)   
21,208   

170   
161   
(3,713)   

(2,338) 

323   
158   
(6,949)   

(2,483) 

—   

(3)   
—   
129   

—   

(32)   

9 

(92,184)   
1   
(20)   
(75,211)   
(38)    1,633,908   

553 
363 
(11,960) 

35 

(3,814) 

316 
(26) 

(3,524) 

At 1 Jan 2022
Transfers of financial 
instruments:
–  transfers from stage 1 to

stage 2

–  transfers from stage 2 to

stage 1

–  transfers to stage 3
–  transfers from stage 3
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 2022
ECL income statement 
change for the period
Recoveries
Others 
Total ECL income 
statement change for the 
period

1  Total includes $82.7bn of gross carrying loans and advances to customers and banks, which were classified to assets held for sale, and a 

corresponding allowance for ECL of $426m, reflecting business disposals as disclosed in Note 23 ‘Assets held for sale and liabilities of disposal groups 
held for sale’ on page 389.

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 2022

12 months ended 
31 Dec 2022

Gross carrying/
nominal amount

Allowance for ECL

ECL charge

$m

1,633,908   
1,014,498   
44,921   
—   

2,693,327   

266,303   
n/a  

$m
(11,960)   
(553)   
—   
—   

(12,513)   

(145)   
(12,658)   

$m
(3,524) 
(41) 
— 
41 

(3,524) 

(68) 
(3,592) 

As shown in the previous table, the allowance for ECL for loans and 
advances to customers and banks and relevant loan commitments 
and financial guarantees increased $85m during the period from 
$11,875m at 31 December 2021 to $11,960m at 31 December 2022.

This increase was primarily driven by:

• $4,254m relating to underlying credit quality changes, including the 
credit quality impact of financial instruments transferring between 
stages;

HSBC Holdings plc Annual Report and Accounts 2022

163

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

• $366m relating to the net remeasurement impact of stage 

transfers; and

• $134m of changes to models used for ECL calculation.

These were partly offset by:

• $2,804m of assets written off; 

• $940m relating to volume movements, which included the ECL 

allowance associated with new originations, assets derecognised 
and further lending/repayment; and

• foreign exchange and other movements of $916m.

The ECL charge for the period of $3,814m presented in the previous 
table consisted of $4,254m relating to underlying credit quality 
changes, including the credit quality impact of financial instruments 
transferring between stages, $366m relating to the net 
remeasurement impact of stage transfers, and $134m in changes to 
models used for ECL calculation. This was partly offset by $940m 
relating to underlying net book volume movement. 

Summary views of the movement in wholesale and personal lending 
are presented on pages 173 and 191.

Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including 
loan commitments and financial guarantees
(Audited)

Non-credit impaired

Credit impaired

Stage 1

Stage 2

Stage 3

POCI

Total

Gross 
exposure

Allowance
/ provision 
for ECL

Gross 
exposure

Allowance
/ provision 
for ECL

Gross 
exposure

Allowance/ 
provision 
for ECL

Gross 
exposure

Allowance
/ provision 
for ECL

Gross 
exposure

Allowance/ 
provision 
for ECL

At 1 Jan 2021
Transfers of financial instruments:
–  transfers from stage 1 to 

stage 2

–  transfers from stage 2 to 

stage 1

–  transfers to stage 3
–  transfers from stage 3
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

$m

$m

$m

 1,506,451   
21,107   

(2,331)    223,432   
(27,863)   
(1,792)   

$m
(5,403)   
2,601   

$m
20,424   
6,756   

$m
(7,544)   
(809)   

$m
279   
—   

  (159,633)   

527    159,633   

(527)   

—   

—   

—   

  182,432   

(2,279)    (182,432)   

(2,345)   
653   

24   
(64)   

(6,478)   
1,414   

2,279   

1,010   
(161)   

—   

8,823   
(2,067)   

—   

(1,034)   
225   

—   

1,225   

—   

(596)   

—   

(34)   

—   

—   
—   

—   

$m

$m
(113)   1,750,586   
—   

—   

—   

—   

—   
—   

—   

—   

—   

—   
—   

—   

$m

(15,391) 
— 

— 

— 

— 
— 

595 

  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)   
 1,577,582   

26   
53   

(2,918)   
(1,882)   
(1,557)    155,742   

(33)   

—   

1   

—   

(2,610)   

2,605   

—   

(125)   

45   
85   
(3,326)   

(479)   
(151)   
19,797   

—   

157   
16   
(6,928)   

(1,353) 

2,487 

(654) 

—   

(7)   

—   

(4)   
—   
274   

—   

7   

—   

(49) 

(2,617)   

2,612 

—   

(125)   

— 

1   
(5)   

(28,632)   
(4,948)   
(64)   1,753,395   

229 
149 
(11,875) 

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.

At 31 Dec 2021

Gross carrying/
nominal amount

Allowance for 
ECL

12 months ended 31 Dec 
2021

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 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

164

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 for the majority of portfolios. 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 provided below 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 146.

Distribution of financial instruments by credit quality at 31 December 2022

(Audited)

Gross carrying/notional amount

Strong

$m

Good Satisfactory

$m

$m

Sub-
standard

$m

Credit 
impaired

$m

Allowance 
for ECL/
other credit 
provisions

$m

Total

$m

Net

$m

492,848   

197,560   

196,819   

333,838   
126,659   
32,351   

45,696   
132,847   
19,017   

28,942   
154,135   
13,742   

29,446   

3,196   
24,890   
1,360   

19,634   

3,340   
15,825   
469   

936,307   

(11,453)   

415,012   
454,356   
66,939   

(2,872)   
(8,324)   
(257)   

924,854 

412,140 
446,032 
66,682 

93,025   

4,890   

5,643   

1,311   

82   

104,951   

(69)   

104,882 

325,119   

1,296   

590   

7,280   

43,787   

170,386   

151,385   
67,617   
91,114   

2,350   

88,764   

12   

—   

41,659   

14,113   
17,993   
10,911   

3,059   

7,852   

5   

—   

41,686   

3,121   
13,972   
8,821   

2,815   

6,006   

—   

—   

—   

20   

161   
2,333   
274   

175   

99   

—   

327,005   

(3)   

327,002 

—   

7,297   

—   

7,297 

—   

43,787   

—   

43,787 

3   

253,754   

47   
641   
152   

25   

127   

168,827   
102,556   
111,272   

8,424   

102,848   

—   

(80)   
(415)   
(55)   

(17)   

(38)   

253,754 

168,747 
102,141 
111,217 

8,407 

102,810 

261,247   

10,132   

5,981   

1,949   

42   

279,351   

(145)   

279,206 

91,330   

14,371   

23,415   

820   

133   

130,069   

—   

130,069 

6,281   

241,905   
15,254   

809   

34,181   
—   

1,785   

7,843   
—   

110   

181   
—   

—   

36   
—   

8,985   

284,146   
15,254   

—   

—   
—   

8,985 

284,146 
15,254 

2,058,578   

347,927   

309,681   

36,605   

20,770   

2,773,561   

(12,220)   

2,761,341 

74.2%

12.5%

11.2%

1.3%

0.8%

100%

402,972   

132,402   

8,281   

4,669   

74,410   

4,571   

7,632   

1,013   

1,372   

618,788   

249   

18,783   

(386)   

(52)   

618,402 

18,731 

411,253   

137,071   

78,981   

8,645   

1,621   

637,571   

(438)   

637,133 

76,095   

69,667   

59,452   

3,360   

489   

209,063   

—   

209,063 

37,943   

30,029   

17,732   

2,137   

399   

88,240   

(110)   

88,130 

114,038   

99,696   

77,184   

5,497   

888   

297,303   

(110)   

297,193 

In-scope for IFRS 9 ECL
Loans and advances to 
customers held at amortised cost
–  personal
–  corporate and commercial
–  non-bank financial institutions
Loans and advances to banks 
held at amortised cost 
Cash and balances at central 
banks 
Items in the course of collection 
from other banks
Hong Kong Government 
certificates of indebtedness 
Reverse repurchase agreements 
– non-trading
Financial investments
Assets held for sale
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
Assets held for sale
Total gross carrying amount on 
balance sheet
Percentage of total credit quality
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

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 2022

165

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Distribution of financial instruments by credit quality at 31 December 2021 (continued)

(Audited)

Gross carrying/notional amount

Strong

$m

Good

Satisfactory

$m

$m

Sub- 
standard

$m

Credit 
impaired

$m

Allowance 
for ECL/other 
credit 
provisions

$m

Total

$m

Net

$m

544,695   

230,326   

233,739   

388,903   
124,819   
30,973   

52,080   
158,938   
19,308   

30,492   
188,858   
14,389   

29,404   

1,920   
27,194   
290   

19,067   

1,057,231   

(11,417)   

1,045,814 

4,942   
13,730   
395   

478,337   
513,539   
65,355   

(3,103)   
(8,204)   
(110)   

475,234 
505,335 
65,245 

72,978   

4,037   

5,020   

1,118   

—   

83,153   

(17)   

83,136 

400,176   

1,675   

1,171   

4,122   

42,578   

175,576   

84,477   
560   
66,537   

1,742   

64,795   

10   

—   

46,412   

11,442   
1,112   
10,997   

5,240   

5,757   

4   

—   

18,881   

1,401   
936   
10,749   

4,038   

6,711   

—   

—   

—   

779   

1   
110   
298   

199   

99   

—   

403,022   

(4)   

403,018 

—   

4,136   

—   

4,136 

—   

42,578   

—   

42,578 

—   

43   
141   
163   

26   

137   

241,648   

97,364   
2,859   
88,744   

11,245   

77,499   

—   

(62)   
(43)   
(84)   

(17)   

(67)   

241,648 

97,302 
2,816 
88,660 

11,228 

77,432 

320,161   

12,298   

11,677   

1,087   

46   

345,269   

(96)   

345,173 

101,879   

16,254   

20,283   

678   

134   

139,228   

—   

139,228 

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 

72.5%

13.9%

11.6%

1.3%

0.7%

100%

389,865   

136,297   

92,558   

16,511   

4,902   

5,166   

8,142   

991   

775   

225   

627,637   

27,795   

(379)   

(62)   

627,258 

27,733 

406,376   

141,199   

97,724   

9,133   

1,000   

655,432   

(441)   

654,991 

62,701   

65,031   

56,446   

3,327   

332   

187,837   

—   

187,837 

31,510   

32,193   

19,265   

2,027   

539   

85,534   

(179)   

85,355 

94,211   

97,224   

75,711   

5,354   

871   

273,371   

(179)   

273,192 

In-scope for IFRS 9 ECL
Loans and advances to customers 
held at amortised cost
–  personal
–  corporate and commercial
–  non-bank financial institutions
Loans and advances to banks 
held at amortised cost 
Cash and balances at central 
banks 
Items in the course of collection 
from other banks
Hong Kong Government 
certificates of indebtedness 
Reverse repurchase agreements 
–  non-trading
Financial investments
Assets held for sale
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
Percentage of total credit quality
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

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.

166

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage allocation

(Audited)

Loans and advances to customers at 
amortised cost
–  stage 1
–  stage 2
–  stage 3
–  POCI
Loans and advances to banks at amortised 
cost
–  stage 1
–  stage 2
–  stage 3
–  POCI
Other financial assets measured at amortised 
cost
–  stage 1
–  stage 2
–  stage 3
–  POCI
Loan and other credit-related commitments 
–  stage 1
–  stage 2
–  stage 3
–  POCI
Financial guarantees
–  stage 1
–  stage 2
–  stage 3
–  POCI
At 31 Dec 2022
Debt instruments at FVOCI1
–  stage 1
–  stage 2
–  stage 3
–  POCI
At 31 Dec 2022

Gross carrying/notional amount

Strong

Good Satisfactory

Sub-
standard

Credit 
impaired

$m

$m

$m

$m

$m

Allowance  
for ECL

$m

Total

$m

Net

$m

492,848   

197,560   

196,819   

29,446   

19,634   

936,307   

(11,453)   

924,854 

458,843   
34,005   
—   
—   

170,875   
26,685   
—   
—   

142,695   
54,124   
—   
—   

93,025   

92,696   
329   
—   
—   

4,890   

4,465   
425   
—   
—   

5,643   

5,466   
177   
—   
—   

5,130   
24,316   
—   
—   

1,311   

415   
896   
—   
—   

—   
—   
19,505   
129   

82   

—   
—   
82   
—   

777,543   
139,130   
19,505   
129   

104,951   

103,042   
1,827   
82   
—   

(1,095)   
(3,491)   
(6,829)   
(38)   

(69)   

(18)   
(29)   
(22)   
—   

776,448 
135,639 
12,676 
91 

104,882 

103,024 
1,798 
60 
— 

856,688   

85,984   

68,195   

2,788   

843    1,014,498   

(553)    1,013,945 

855,523   
1,165   
—   
—   
402,972   
398,120   
4,852   
—   
—   
8,281   
8,189   
92   
—   
—   
  1,853,814   

260,941   
306   
—   
—   
261,247   

80,175   
5,809   
—   
—   
132,402   
121,581   
10,821   
—   
—   
4,669   
4,245   
424   
—   
—   
425,505   

10,000   
132   
—   
—   
10,132   

60,583   
7,612   
—   
—   
74,410   
60,990   
13,420   
—   
—   
4,571   
3,488   
1,083   
—   
—   
349,638   

5,690   
291   
—   
—   
5,981   

208   
2,580   
—   
—   
7,632   
2,692   
4,940   
—   
—   
1,013   
149   
864   
—   
—   
42,190   

—   
1,949   
—   
—   
1,949   

—   
—   
797   
46   
1,372   
—   
—   
1,372   
—   
249   
—   
—   
249   
—   

996,489   
17,166   
797   
46   
618,788   
583,383   
34,033   
1,372   
—   
18,783   
16,071   
2,463   
249   
—   
22,180    2,693,327   

(124)   
(188)   
(234)   
(7)   
(386)   
(141)   
(180)   
(65)   
—   
(52)   
(6)   
(13)   
(33)   
—   

996,365 
16,978 
563 
39 
618,402 
583,242 
33,853 
1,307 
— 
18,731 
16,065 
2,450 
216 
— 
(12,513)    2,680,814 

—   
—   
5   
37   
42   

276,631   
2,678   
5   
37   
279,351   

(68)   
(69)   
(1)   
(7)   
(145)   

276,563 
2,609 
4 
30 
279,206 

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 2022

167

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage allocation 
(continued)
(Audited)

Loans and advances to customers at amortised 
cost

–  stage 1
–  stage 2
–  stage 3
–  POCI
Loans and advances to banks at amortised 
cost
–  stage 1
–  stage 2
–  stage 3
–  POCI
Other financial assets measured at amortised 
cost

–  stage 1
–  stage 2
–  stage 3
–  POCI
Loan and other credit-related commitments
–  stage 1
–  stage 2
–  stage 3
–  POCI
Financial guarantees
–  stage 1
–  stage 2
–  stage 3
–  POCI
At 31 Dec 2021
Debt instruments at FVOCI1
–  stage 1
–  stage 2
–  stage 3
–  POCI
At 31 Dec 2021

Gross carrying/notional amount

Strong

$m

Good Satisfactory

$m

$m

Sub-
standard

$m

Credit 
impaired

$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   
7,053   
—   
—   

206,645   
23,681   
—   
—   

169,809   
63,930   
—   
—   

72,978   

72,903   
75   
—   
—   

4,037   

3,935   
102   
—   
—   

5,020   

4,788   
232   
—   
—   

4,840   
24,560   
—   
4   

1,118   

10   
1,108   
—   
—   

—   
—   
18,797   
270   

918,936   
119,224   
18,797   
274   

(1,367)   
(3,119)   
(6,867)   
(64)   

917,569 
116,105 
11,930 
210 

—   

—   
—   
—   
—   

83,153   

81,636   
1,517   
—   
—   

(17)   

(14)   
(3)   
—   
—   

83,136 

81,622 
1,514 
— 
— 

774,026   

71,648   

33,142   

1,188   

347   

880,351   

(193)   

880,158 

773,427   
599   
—   
—   
389,865   
387,434   
2,431   
—   
—   
16,511   
16,351   
160   
—   
—   
  1,798,075   

319,557   
604   
—   
—   
320,161   

70,508   
1,140   
—   
—   
136,297   
129,455   
6,842   
—   
—   
4,902   
4,469   
433   
—   
—   
447,210   

12,196   
102   
—   
—   
12,298   

30,997   
2,145   
—   
—   
92,558   
76,043   
16,515   
—   
—   
5,166   
3,929   
1,237   
—   
—   
369,625   

11,354   
323   
—   
—   
11,677   

84   
1,104   
—   
—   
8,142   
1,541   
6,601   
—   
—   
991   
183   
808   
—   
—   
40,843   

—   
1,087   
—   
—   
1,087   

—   
—   
304   
43   
775   
—   
—   
775   
—   
225   
—   
—   
225   
—   

875,016   
4,988   
304   
43   
627,637   
594,473   
32,389   
775   
—   
27,795   
24,932   
2,638   
225   
—   
20,414    2,676,167   

(91)   
(54)   
(42)   
(6)   
(379)   
(165)   
(174)   
(40)   
—   
(62)   
(11)   
(30)   
(21)   
—   

874,925 
4,934 
262 
37 
627,258 
594,308 
32,215 
735 
— 
27,733 
24,921 
2,608 
204 
— 
(12,068)    2,664,099 

—   
—   
—   
46   
46   

343,107   
2,116   
—   
46   
345,269   

(67)   
(22)   
—   
(7)   
(96)   

343,040 
2,094 
— 
39 
345,173 

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.

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.

168

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Forbearance

The following table shows the gross carrying amounts and allowances for ECL of the Group’s holdings of forborne loans and advances to 
customers by industry sector and by stages. 

A summary of our current policies and practices for forbearance is set out in ‘Credit risk management’ on page 145. 

Forborne loans and advances to customers at amortised cost by stage allocation

Gross carrying amount
Personal
–  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
Wholesale
–  corporate and commercial
–  non-bank financial institutions
At 31 Dec 2022
Allowance for ECL
Personal
–  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
Wholesale
–  corporate and commercial
–  non-bank financial institutions
At 31 Dec 2022

Gross carrying amount
Personal
–  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
Wholesale
–  corporate and commercial
–  non-bank financial institutions
At 31 Dec 20211
Allowance for ECL
Personal
–  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
Wholesale
–  corporate and commercial
–  non-bank financial institutions
At 31 Dec 20211

Performing – forborne 

Non-performing – forborne

Stage 1
$m

Stage 2
$m

Stage 3
$m

POCI
$m

—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   

—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   

—   
—   
—   
—   
—   
—   
—   
—   
366   
355   
11   
366   

—   
—   
—   
—   
—   
—   
—   
—   
(7)   
(7)   
—   
(7)   

651   
369   
—   
—   
5   
93   
179   
5   
4,873   
4,859   
14   
5,524   

(124)   
(49)   
—   
—   
—   
(19)   
(54)   
(2)   
(152)   
(151)   
(1)   
(276)   

—   
—   
—   
—   
—   
—   
—   
—   
559   
550   
9   
559   

—   
—   
—   
—   
—   
—   
—   
—   
(24)   
(24)   
—   
(24)   

1,171   
738   
7   
4   
13   
75   
334   
—   
4,576   
4,562   
14   
5,747   

(302)   
(118)   
(3)   
(3)   
(2)   
(44)   
(132)   
—   
(1,497)   
(1,490)   
(7)   
(1,799)   

2,256   
1,547   
22   
23   
39   
168   
456   
1   
4,505   
4,491   
14   
6,761   

(400)   
(178)   
(6)   
(7)   
(5)   
(53)   
(151)   
—   
(1,282)   
(1,274)   
(8)   
(1,682)   

—   
—   
—   
—   
—   
—   
—   
—   
107   
107   
—   
107   

—   
—   
—   
—   
—   
—   
—   
—   
(25)   
(25)   
—   
(25)   

—   
—   
—   
—   
—   
—   
—   
—   
253   
253   
—   
253   

—   
—   
—   
—   
—   
—   
—   
—   
(52)   
(52)   
—   
(52)   

Total – 
forborne

Total
$m

1,822 
1,107 
7 
4 
18 
168 
513 
5 
9,556 
9,528 
28 
11,378 

(426) 
(167) 
(3) 
(3) 
(2) 
(63) 
(186) 
(2) 
(1,674) 
(1,666) 
(8) 
(2,100) 

2,256 
1,547 
22 
23 
39 
168 
456 
1 
5,683 
5,649 
34 
7,939 

(400) 
(178) 
(6) 
(7) 
(5) 
(53) 
(151) 
— 
(1,365) 
(1,357) 
(8) 
(1,765) 

1    Forborne exposures and allowances for ECL at 31 December 2021 have not been restated and agreed with the policies and disclosures presented in 

the Annual Report and Accounts 2021.

Following the adoption of the EBA ‘Guidelines on the application of definition of default’, retail and wholesale loans are identified as forborne 
and classified as either performing or non-performing when we modify the contractual terms due to financial difficulty of the borrower. At 
31 December 2022, we reported $5,524m (31 December 2021: $925m) of performing forborne loans. The increase of $4,599m was mainly 
driven by the inclusion of non-payment-related concessions in the forbearance assessment since 1 January 2022.

HSBC Holdings plc Annual Report and Accounts 2022

169

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Forborne loans and advances to customers by geographical region

Gross carrying amount 
Performing forborne
Non-performing forborne
At 31 Dec 2022
Allowances for ECL
Performing forborne
Non-performing forborne
At 31 Dec 2022

Gross carrying amount
Performing forborne
Non-performing forborne
At 31 Dec 20211
Allowances for ECL
Performing forborne
Non-performing forborne
At 31 Dec 20211

Europe

$m

Asia

$m

MENA

$m

North 
America

Latin 
America

$m

$m

Total

$m

UK

$m

of which:

3,121   
2,636   
5,757   

276   
1,562   
1,838   

482   
1,076   
1,558   

1,100   
368   
1,468   

545   
212   
757   

5,524   
5,854   
11,378   

1,028   
2,126   
3,154   

Hong 
Kong

$m

134 
879 
1,013 

(95)   
(566)   
(661)   

(21)   
(525)   
(546)   

(19)   
(536)   
(555)   

(62)   
(83)   
(145)   

(79)   
(114)   
(193)   

(276)   
(1,824)   
(2,100)   

(64)   
(441)   
(505)   

(17) 
(355) 
(372) 

698   
3,421   
4,119   

5   
1,317   
1,322   

(13)   
(615)   
(628)   

—   
(306)   
(306)   

105   
849   
954   

(9)   
(475)   
(484)   

89   
975   
1,064   

(8)   
(138)   
(146)   

28   
452   
480   

(1)   
(200)   
(201)   

925   
7,014   
7,939   

(31)   
(1,734)   
(1,765)   

640   
2,829   
3,469   

(10)   
(459)   
(469)   

— 
528 
528 

— 
(89) 
(89) 

1  Forborne exposures and allowances for ECL at 31 December 2021 have not been restated and agreed with the policies and disclosures presented in 

the Annual Report and Accounts 2021.

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 2022 to 31 December 2022 
closing gross carrying/nominal amounts and the associated allowance 
for ECL.

At 31 December 2022, wholesale lending for loans and advances to 
banks and customers of $626.2bn decreased by $35.8bn since 
31 December 2021. This included adverse foreign exchange 
movements of $31.9bn. Excluding foreign exchange movements, the 
total wholesale lending decrease of $3.9bn was driven by a $34.3bn 
decline in corporate and commercial balances. This was partly offset 
by a $25.9bn increase in loans and advances to banks and a $4.5bn 
increase in balances from non-bank financial institutions.

The primary driver of the decline in corporate and commercial 
balances was the $23.4bn reclassification of our banking business in 
Canada to held for sale, and a decline of $11.3bn in Asia. In Asia, the 
decline was driven from a $17.3bn decrease in Hong Kong, partly 
offset by growth of $2.4bn in Australia, $1.9b in Japan and $1.7bn in 
India.

Growth in loans and advances to banks was mainly driven by a 
$13.0bn increase in Asia, a $10.1bn increase in Europe, and a $2.6bn 
increase in MENA. In Asia, the increase can be largely attributed to 
$7.9bn in Hong Kong and $1.5bn in Malaysia. In Europe, the growth 
was mainly from the UK with an increase of $10.6bn.

The increase in balances from non-bank financial institutions was 
driven from an increase of $3.7bn in Asia and $2.0bn in Europe. This 
growth was partly offset by a decline of $1.3bn in North America, of 
which $1.4bn was due to the reclassification of our banking business 
in Canada to held for sale, and a $0.1bn increase in the US.

Loan commitments and financial guarantees decreased by $22.2bn 
since 31 December 2021 to $392.4bn at 31 December 2022, 
including a $3.0bn increase related to unsettled reverse repurchase 
agreements. This also included adverse foreign exchange movements 
of $21.8bn.

The allowance for ECL attributable to wholesale loans and advances 
to banks and customers increased by $0.3bn to $8.7bn at 
31 December 2022. This included favourable foreign exchange 
movements of $0.4bn. 

Excluding foreign exchange movements, the total increase in the 
wholesale ECL allowance for loans and advances to customers and 
banks was driven by a $0.5bn growth in corporate and commercial 
allowances. The primary driver of this increase in corporate and 
commercial allowance for ECL was $1.1bn in Asia, notably $1.4bn in 
Hong Kong, which was partly offset by a decline of $0.4bn in 
Singapore. Allowances for ECL decreased by $0.2bn in North 
America, and by $0.1bn in both Europe and Latin America. 

The allowance for ECL attributable to loan commitments and financial 
guarantees at 31 December 2022 remained at $0.4bn from 
31 December 2021.

170

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
Total wholesale lending for loans and advances to banks and customers by stage distribution

Stage 1
$m

  353,010   
4,805   
6,498   
70,187   

Gross carrying amount
Stage 3
$m
15,696   
261   
232   
2,016   

Stage 2
$m
85,521   
1,505   
1,463   
15,251   

Total
$m

POCI
$m
129    454,356   
6,571   
8,194   
87,503   

—   
1   
49   

Stage 1
$m
(490)   
(10)   
(5)   
(93)   

Allowance for ECL
Stage 3
$m
(5,887)   
(68)   
(145)   
(867)   

Stage 2
$m
(1,909)   
(44)   
(21)   
(164)   

POCI
$m
(38)   
—   
(1)   
(29)   

Total
$m
(8,324) 
(122) 
(172) 
(1,153) 

15,006   

1,799   

277   

—   

17,082   

(11)   

(31)   

(67)   

—   

(109) 

Corporate and commercial
–  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
Non-bank financial institutions
Loans and advances to banks
At 31 Dec 2022
By geography
Europe
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2022

2,690   

277   

9,692   

2,742   

26   

791   

—   

2,993   

7   

13,232   

63,755   

15,872   

2,805   

5   

82,437   

19,227   
9,873   

5,062   
6,523   

556   
787   

—   
2   

24,845   
17,185   

16,609   

1,537   

249   

28   

18,423   

72,195   

24,386   

4,834   

19    101,434   

15,164   

2,229   

20,592   

3,505   

1,166   

1,346   
3,055   
1,264   
10,391   
730   

14   

181   
643   
452   
1,547   
14   

542   

962   

—   

87   
266   
146   
589   
—   

47   

—   

—   

8,699   
19   
61,752   
  103,042   
  517,804   

  150,592   
  104,595   
  293,503   
  155,513   
29,512   
31,372   
12,825   
  517,804   

506   
13   
4,718   
1,827   
92,066   

28,060   
21,489   
50,826   
28,275   
3,254   
6,950   
2,976   
92,066   

270   
—   
469   
82   
16,247   

7,070   
5,432   
6,938   
5,338   
1,530   
245   
464   
16,247   

—   

17,935   

18   

25,077   

—   

—   
—   
—   
—   
—   

—   

1,180   

1,614   
3,964   
1,862   
12,527   
744   

47   

9,475   
—   
32   
—   
—   
66,939   
—    104,951   
129    626,246   

31    185,753   
28    131,544   
81    351,348   
57    189,183   
34,313   
17   
38,567   
—   
16,265   
—   
129    626,246   

(3)   

(21)   

(96)   

(31)   
(23)   

(22)   

(86)   

(21)   

(25)   

—   

(4)   
(6)   
(4)   
(26)   
—   

—   

(3)   
—   
(43)   
(18)   
(551)   

(223)   
(186)   
(220)   
(104)   
(22)   
(25)   
(61)   
(551)   

(5)   

(51)   

(13)   

(368)   

(226)   

(1,341)   

(65)   
(139)   

(153)   
(81)   

(36)   

(58)   

(904)   

(1,861)   

(51)   

(90)   

(1)   

(5)   
(17)   
(16)   
(30)   
—   

(200)   

(293)   

—   

(22)   
(67)   
(57)   
(219)   
—   

—   

—   

—   
(13)   
(77)   
(29)   
(2,015)   

(628)   
(501)   
(1,077)   
(775)   
(49)   
(197)   
(64)   
(2,015)   

(7)   
—   
(137)   
(22)   
(6,046)   

(1,718)   
(1,015)   
(3,125)   
(2,136)   
(909)   
(44)   
(250)   
(6,046)   

Total wholesale lending for loans and other credit-related commitments and financial guarantees by stage distribution1

Corporate and commercial
Financial 
At 31 Dec 2022
By geography
Europe
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2022

Stage 1
$m

  252,860   
  105,950   
  358,810   

  168,179   
60,532   
67,473   
27,102   
7,500   
  112,695   
2,963   
  358,810   

Nominal amount
Stage 3
$m
798   
23   
821   

Stage 2
$m
29,116   
3,683   
32,799   

POCI
$m

Total
$m

—    282,774   
—    109,656   
—    392,430   

Stage 1
$m
(116)   
(5)   
(121)   

Allowance for ECL
Stage 3
$m
(96)   
(2)   
(98)   

Stage 2
$m
(178)   
(14)   
(192)   

17,235   
9,941   
6,081   
2,448   
565   
8,642   
276   
32,799   

498   
278   
114   
46   
21   
185   
3   
821   

—    185,912   
70,751   
—   
73,668   
—   
29,596   
—   
—   
8,086   
—    121,522   
—   
3,242   
—    392,430   

(41)   
(34)   
(54)   
(14)   
(4)   
(21)   
(1)   
(121)   

(87)   
(64)   
(53)   
(27)   
(5)   
(47)   
—   
(192)   

(85)   
(46)   
(9)   
(2)   
(2)   
(2)   
—   
(98)   

1 

Included in loans and other credit-related commitments and financial guarantees is $45bn relating to unsettled reverse repurchase agreements, which 
once drawn are classified as ‘Reverse repurchase agreements – non-trading’.

HSBC Holdings plc Annual Report and Accounts 2022

171

—   

(3)   

(3)   

—   
(1)   

(1)   

—   

—   

—   

—   

—   
—   
—   
—   
—   

—   

—   
—   
—   
—   
(38)   

(1)   
(1)   
(25)   
(22)   
(12)   
—   
—   
(38)   

POCI
$m

—   
—   
—   

—   
—   
—   
—   
—   
—   
—   
—   

(21) 

(443) 

(1,666) 

(249) 
(244) 

(117) 

(2,851) 

(272) 

(408) 

(1) 

(31) 
(90) 
(77) 
(275) 
— 

— 

(10) 
(13) 
(257) 
(69) 
(8,650) 

(2,570) 
(1,703) 
(4,447) 
(3,037) 
(992) 
(266) 
(375) 
(8,650) 

Total
$m
(390) 
(21) 
(411) 

(213) 
(144) 
(116) 
(43) 
(11) 
(70) 
(1) 
(411) 

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Total wholesale lending for loans and advances to banks and customers by stage distribution

Gross carrying amount

Allowance for ECL

Stage 1
$m

  400,894   
6,510   
7,167   
75,193   

Stage 2
$m
98,911   
1,026   
2,055   
16,443   

Stage 3
$m
13,460   
362   
447   
2,019   

Total
$m

POCI
$m
274    513,539   
7,899   
9,685   
93,743   

1   
16   
88   

Stage 1
$m
(665)   
(10)   
(17)   
(110)   

Stage 2
$m
(1,874)   
(23)   
(39)   
(176)   

Stage 3
$m
(5,601)   
(104)   
(159)   
(931)   

POCI
$m
(64)   
(1)   
(12)   
(31)   

Total
$m
(8,204) 
(138) 
(227) 
(1,248) 

15,255   

1,285   

78   

—   

16,618   

(16)   

(21)   

(31)   

—   

(68) 

Corporate and commercial
–  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
Non-bank financial institutions
Loans and advances to banks
At 31 Dec 2021
By geography
Europe
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2021

3,376   

468   

9,506   

3,605   

51   

842   

—   

3,895   

1   

13,954   

79,137   

12,802   

3,003   

21,199   
8,080   

7,726   
14,096   

658   
1,199   

2   

9   
1   

94,944   

29,592   
23,376   

16,417   

1,804   

222   

28   

18,471   

93,633   

25,154   

2,375   

98    121,260   

16,160   

2,888   

23,186   

4,740   

938   

333   

1,455   
3,743   
1,620   
10,123   
860   

273   
928   
826   
1,726   
117   

637   

719   

—   

65   
183   
152   
448   
—   

2   

—   

—   

7,010   
324   
61,086   
81,636   

602   
14   
3,874   
1,517   
  543,616    104,302   

  154,575   
  101,029   
  297,423   
  165,437   
26,135   
53,513   
11,970   

31,871   
24,461   
53,993   
30,305   
5,295   
10,397   
2,746   
  543,616    104,302   

—   
—   
395   
—   
13,855   

6,741   
5,126   
3,997   
1,990   
1,682   
652   
783   
13,855   

—   

19,685   

30   

28,675   

—   

—   
—   
—   
—   
—   

—   

1,271   

1,793   
4,854   
2,598   
12,297   
977   

2   

—   
—   
—   
—   

7,612   
338   
65,355   
83,153   
274    662,047   

30    193,217   
28    130,644   
199    355,612   
159    197,891   
33,134   
64,562   
15,522   
274    662,047   

22   
—   
23   

(5)   

(24)   

(71)   

(56)   
(67)   

(37)   

(132)   

(26)   

(40)   

(5)   

(4)   
(11)   
(6)   
(26)   
—   

—   

(2)   
—   
(44)   
(14)   
(723)   

(356)   
(306)   
(182)   
(85)   
(62)   
(57)   
(66)   
(723)   

(4)   

(44)   

(20)   

(439)   

(99)   

(1,936)   

(116)   
(245)   

(47)   

(737)   

(40)   

(84)   

(3)   

(15)   
(24)   
(44)   
(101)   
—   

(191)   
(110)   

(94)   

(775)   

(172)   

(296)   

—   

(18)   
(37)   
(42)   
(246)   
—   

—   

—   

(2)   
(10)   
(26)   
(3)   
(1,903)   

(654)   
(518)   
(830)   
(650)   
(108)   
(215)   
(96)   
(1,903)   

—   
—   
(40)   
—   
(5,641)   

(1,806)   
(1,060)   
(2,299)   
(836)   
(1,028)   
(169)   
(339)   
(5,641)   

Total wholesale lending for loans and other credit-related commitments and financial guarantees by stage distribution1

Corporate and commercial
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

Nominal amount

Allowance for ECL

Stage 1
$m

  274,775   
  105,746   
  380,521   

Stage 2
$m
30,376   
2,889   
33,265   

Stage 3
$m
829   
2   
831   

POCI
$m

Total
$m

—    305,980   
—    108,637   
—    414,617   

Stage 1
$m
(130)   
(9)   
(139)   

Stage 2
$m
(193)   
(9)   
(202)   

Stage 3
$m
(60)   
(1)   
(61)   

  189,770   
68,136   
72,179   
31,314   
6,335   
  109,851   
2,386   
  380,521   

15,585   
8,430   
5,229   
1,517   
1,017   
11,350   
84   
33,265   

673   
389   
20   
10   
19   
91   
28   
831   

—    206,028   
76,955   
—   
77,428   
—   
32,841   
—   
—   
7,371   
—    121,292   
—   
2,498   
—    414,617   

(67)   
(55)   
(35)   
(11)   
(10)   
(24)   
(3)   
(139)   

(76)   
(49)   
(40)   
(17)   
(18)   
(66)   
(2)   
(202)   

(47)   
(28)   
(5)   
(2)   
(3)   
(1)   
(5)   
(61)   

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’.

172

HSBC Holdings plc Annual Report and Accounts 2022

—   

(1)   

(1)   

—   
(1)   

(6)   

—   

—   

(11)   

—   

—   
—   
—   
—   
—   

—   

—   
—   
—   
—   
(64)   

(9)   
(6)   
(43)   
(21)   
(11)   
—   
(1)   
(64)   

POCI
$m

—   
—   
—   

—   
—   
—   
—   
—   
—   
—   
—   

(29) 

(508) 

(2,107) 

(363) 
(423) 

(184) 

(1,644) 

(238) 

(431) 

(8) 

(37) 
(72) 
(92) 
(373) 
— 

— 

(4) 
(10) 
(110) 
(17) 
(8,331) 

(2,825) 
(1,890) 
(3,354) 
(1,592) 
(1,209) 
(441) 
(502) 
(8,331) 

Total
$m
(383) 
(19) 
(402) 

(190) 
(132) 
(80) 
(30) 
(31) 
(91) 
(10) 
(402) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
At 1 Jan 2022
Transfers of financial 
instruments
–  transfers from stage 1 to 

stage 2

–  transfers from stage 2 to 

–  transfers to stage 3
–  transfers from stage 3
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/repayments
Change in risk parameters 
– credit quality 
Changes to models used 
for ECL calculation

Assets written off
Credit-related 
modifications that resulted 
in derecognition

Foreign exchange and 
other1
At 31 Dec 2022
ECL income statement 
change for the period

Recoveries
Others
Total ECL income 
statement change for the 
period

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

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

Allowance 
for ECL

Allowance 
for ECL

$m

  881,742   

$m
(862)    137,541   

$m

$m
(2,105)   

$m
14,686   

$m
(5,702)   

$m
274   

$m
(64)    1,034,243   

$m

$m
(8,733) 

(58,188)   

(299)   

49,569   

943   

8,619   

(644)   

  (157,553)   

201    157,553   

(201)   

stage 1

  100,839   

(482)    (100,839)   

(1,831)   
357   

7   
(25)   

(8,100)   
955   

482   

771   
(109)   

—   

241   

—   

(370)   

  352,985   

(277)   

—   

—   

—   

—   

(778) 
134   

(64)   

—   

—   

9,931   
(1,312)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   
—   

—   

— 

— 

— 

— 
— 

(193) 

—   

26   

(2)   

353,011   

(279) 

  (250,014)   

54   

(33,850)   

73   

(1,763)   

292   

(97)   

—   

(285,724)   

419 

(34,321)   

64   

(11,501)   

128   

(1,491)   

292   

(61)   

5   

(47,374)   

489 

—   

—   

—   

321   

—   

(994)   

—   

(2,197)   

—   

6   

—   

—   

—   

(57)   

—   

—   

—   

(1,579)   

1,579   

—   

(10)   

32   

—   

10   

—   

(2,838) 

—   

(51) 

(1,589)   

1,589 

—   

—   

—   

—   

(32)   

9   

—   

—   

(32)   

9 

(60,421)   

80   

(16,984)   

175   

(1,372)   

291   

  831,783   

(672)    124,775   

(2,207)   

17,068   

(6,144)   

(3)   

129   

(19)   

(78,780)   

527 

(38)   

973,755   

(9,061) 

409 

(1,220) 

(1,677) 

35 

(2,453) 

33 
(23) 

(2,443) 

1   Total includes $33.1bn of gross carrying loans and advances to customers and banks, which were classified to assets held for sale, and a 

corresponding allowance for ECL of $204m, reflecting business disposals as disclosed in Note 23 ‘Assets held for sale and liabilities of disposal groups 
held for sale’ on page 389.

As shown in the above table, the allowance for ECL for loans and 
advances to customers and banks and relevant loan commitments 
and financial guarantees increased by $328m during the period from 
$8,733m at 31 December 2021 to $9,061m at 31 December 2022.

This increase was primarily driven by:

• $2,838m relating to underlying credit quality changes, including the 
credit quality impact of financial instruments transferring between 
stages;

• $193m relating to the net remeasurement impact of stage 

transfers; and

• $51m of changes to models used for ECL calculation.

These were partly offset by:

• $1,589m of assets written off;

• $629m relating to volume movements, which included the ECL 

allowance associated with new originations, assets derecognised 
and further lending/repayments; and

• foreign exchange and other movements of $527m.

The ECL charge for the period of $2,453m presented in the previous 
table consisted of $2,838m relating to underlying credit quality 
changes, including the credit quality impact of financial instruments 
transferring between stages, $193m relating to the net 
remeasurement impact of stage transfers and $51m in changes to 
models used for ECL calculation. This was partly offset by $629m 
relating to underlying net book volume movement.

During the period, there was a net transfer to stage 2 of $56,714m 
gross carrying/nominal amounts. The movement reflected the 
increased level of uncertainty around the macroeconomic outlook 
during the period. It was primarily driven by $29,049m in Asia, due to 
deterioration in the macroeconomic outlook affecting real estate 
portfolios booked in Hong Kong, and $20,860m in Europe, mainly 
driven by deterioration in the macroeconomic outlook affecting 
corporate and commercial portfolios in France.

HSBC Holdings plc Annual Report and Accounts 2022

173

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

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

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Allowance 
for ECL

At 1 Jan 2021
Transfers of financial instruments
–  transfers from stage 1 to 

stage 2

–  transfers from stage 2 to 

stage 1

–  transfers to stage 3
–  transfers from stage 3
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/repayments
Changes to risk parameters – 
credit quality
Changes to models used for ECL 
calculation

Assets written off
Credit-related modifications that 
resulted in derecognition

Foreign exchange
Others
At 31 Dec 2021
ECL income statement change 
for the period

Recoveries
Others 
Total ECL income statement 
change for the period

$m
841,105   
19,285   

$m

$m

$m

$m

(1,465)    196,662   
(23,361)   

(638)   

(2,998)    14,662   
4,076   

888   

$m
(6,041)   
(250)   

(135,932)   

238    135,932   

(238)   

—   

—   

156,346   

(875)    (156,346)   

(1,363)   
234   

17   
(18)   

(3,410)   
463   

875   

276   
(25)   

—   

4,773   
(697)   

—   

(293)   
43   

—   

400   

—   

(233)   

—   

(27)   

$m
279   
—   

—   

—   

—   
—   

—   

$m

$m
(113)    1,052,708   
—   

—   

—   

—   

—   
—   

—   

—   

—   

—   
—   

—   

$m

(10,617) 
— 

— 

— 

— 
— 

140 

307,150   

(342)   

—   

—   

—   

—   

124   

—   

307,274   

(342) 

(221,160)   

55   

(26,136)   

70   

(1,514)   

239   

(10)   

6   

(248,820)   

370 

(47,766)   

307   

(6,014)   

384   

(987)   

525   

(108)   

12   

(54,875)   

1,228 

—   

793   

—   

(234)   

—   

(1,347)   

—   

—   

—   

(15)   

—   

—   

—   

—   

—   

(33)   

—   

—   

—   

(1,085)   

1,085   

—   

(125)   

—   

(16,157)   
(715)   
881,742   

9   
34   

(2,560)   
(1,050)   
(862)    137,541   

26   
25   

(341)   
—   
(2,105)    14,686   

1,198 

(46) 

112   
2   
(5,702)   

(610) 

—   

—   

(7)   

—   

(4)   
—   
274   

28   

—   

7   

—   

(760) 

—   

(48) 

(1,092)   

1,092 

—   

(125)   

— 

1   
(5)   

(19,062)   
(1,765)   
(64)    1,034,243   

148 
56 
(8,733) 

46 

588 

54 
(102) 

540 

Wholesale lending – distribution of financial instruments to which the impairment requirements of IFRS 9 are applied by credit quality 

Gross carrying/nominal amount

Strong

Good Satisfactory

Sub-
standard

Credit 
impaired

$m

$m

$m

$m

$m

Allowance 
for ECL

$m

Total

$m

Net

$m

By geography
Europe 
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2022
Percentage of total credit quality

By geography
Europe 
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2021
Percentage of total credit quality

        185,753 
        60,016 
        131,544 
        44,515 
        351,348 
      167,720 
        189,183 
        77,227 
          34,313 
        15,132 
          38,567 
          7,445 
          16,265 
          1,722 
      252,035 
        626,246 
         40.3 %          25.0 %             27.7 %             4.4 %             2.6 %          100.0 %

         49,831               58,580 
         38,521               36,934 
         81,907               84,973 
         44,479               54,500 
           5,349               11,170 
         13,390               12,856 
           6,277               5,941 
       156,754             173,520 

          10,224 
            6,115 
            9,735 
            7,581 
            1,113 
            4,630 
            1,859 
          27,561 

            7,102 
            5,459 
            7,013 
            5,396 
            1,549 
            246 
              466 
          16,376 

        193,217 
          48,758 
        130,644 
          30,390 
        355,612 
        155,072 
        197,891 
          74,440 
          33,134 
          12,264 
          64,562 
          11,683 
          15,522 
               993 
        228,770 
        662,047 
            34.6 %             27.5 %             31.5 %               4.3 %               2.1 %           100.0 %

          74,240 
         49,254 
          48,694 
         37,212 
          96,046 
         95,626 
          63,301 
          54,703 
          10,321 
            7,004 
          22,022 
          24,663 
            5,736 
            5,638 
         182,283          208,267 

          14,196 
            9,192 
            4,670 
            3,297 
            1,844 
            5,543 
            2,349 
          28,602 

            6,769 
            5,156 
            4,198 
            2,150 
            1,701 
               651 
               806 
          14,125 

(2,570)           183,183 
(1,703)           129,841 
(4,447)           346,901 
(3,037)           186,146 
(992)           33,321 
(266)           38,301 
(375)           15,890 
(8,650)           617,596 

(2,825)   
(1,890)   
(3,354)   
(1,592)   
(1,209)   
(441)   
(502)   
(8,331)   

190,392 
128,754 
352,258 
196,299 
31,925 
64,121 
15,020 
653,716 

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 146.

174

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate and 
commercial
–  CRR 1
–  CRR 2
–  CRR 3
–  CRR 4
–  CRR 5
–  CRR 6
–  CRR 7
–  CRR 8
–  CRR 9/10
Non-bank 
financial 
institutions
–  CRR 1
–  CRR 2
–  CRR 3
–  CRR 4
–  CRR 5
–  CRR 6
–  CRR 7
–  CRR 8
–  CRR 9/10
Banks
–  CRR 1
–  CRR 2
–  CRR 3
–  CRR 4
–  CRR 5
–  CRR 6
–  CRR 7
–  CRR 8
–  CRR 9/10
At 31 Dec 2022

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

POC
I

%

$m

$m

$m $m

Total

$m

Stage 
1

Stage 
2

Stage 

3 POCI

Total

ECL 
coverage

Mapped 
external 
rating

$m

$m

$m $m

$m

  353,010    85,521   15,696    129    454,356   

(490)    (1,909)    (5,887)   

(38)   

(8,324) 

330   
0.000 to 0.053   35,630   
3,234   
0.054 to 0.169   87,465   
0.170 to 0.740   115,116    17,731   
0.741 to 1.927   74,229    21,550   
1.928 to 4.914   36,707    21,649   
9,171   
4.915 to 8.860  
5,476   
8.861 to 15.000  
15.001 to 99.999  
6,380   
100.000   

—    —    35,960   
—    —    90,699   
—    —    132,847   
—    —    95,779   
—    —    58,356   
—    —    11,684   
6,640   
—    —   
6,566   
—    —   
—   15,696    129    15,825   

2,513   
1,164   
186   
—   

(6)   
(28)   
(129)   
(155)   
(146)   
(16)   
(8)   
(2)   
—   

(1)   
(15)   
(122)   
(210)   
(361)   
(237)   
(337)   
(626)   

—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
(38)   

(7) 
(43) 
(251) 
(365) 
(507) 
(253) 
(345) 
(628) 
(5,925) 

—    (5,887)   

%

 1.8 

 —  AA- and above
A+ to A-
 — 
BBB+ to BBB-
 0.2 
BB+ to BB-
 0.4 
BB- to B
 0.9 
B-
 2.2 
CCC+
 5.2 
CCC to C
 9.6 
D
 37.4 

  61,752   

4,718   

469    —    66,939   

(43)   

(77)   

(137)    —   

(257) 

 0.4 

0.000 to 0.053   15,082   
0.054 to 0.169   16,350   
0.170 to 0.740   17,254   
7,074   
0.741 to 1.927  
5,215   
1.928 to 4.914  
716   
4.915 to 8.860  
46   
8.861 to 15.000  
15   
15.001 to 99.999  
—   
100.000   
  103,042   
0.000 to 0.053   79,188   
0.054 to 0.169   13,508   
4,465   
0.170 to 0.740  
2,154   
0.741 to 1.927  
3,312   
1.928 to 4.914  
—   
4.915 to 8.860  
1   
8.861 to 15.000  
414   
15.001 to 99.999  
—   
100.000   

—    —    15,503   
—    —    16,848   
—    —    19,017   
7,791   
—    —   
5,951   
—    —   
806   
—    —   
78   
—    —   
476   
—    —   
469   
469    —   
82    —    104,951   
—    —    79,308   
—    —    13,717   
4,890   
—    —   
2,159   
—    —   
3,484   
—    —   
5   
—    —   
863   
—    —   
443   
—    —   
82   
82    —   
  517,804    92,066   16,247    129    626,246   

421   
498   
1,763   
717   
736   
90   
32   
461   
—   
1,827   
120   
209   
425   
5   
172   
5   
862   
29   
—   

(2)   
(3)   
(9)   
(19)   
(10)   
—   
—   
—   
—   
(18)   
(8)   
(2)   
(3)   
(1)   
(4)   
—   
—   
—   
—   

(1)   
(1)   
(13)   
(4)   
(10)   
(4)   
(3)   
(41)   
—   
(29)   
—   
—   
—   
—   
(1)   
—   
(27)   
(1)   
—   
(551)    (2,015)    (6,046)   

—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
(137)    —   
(22)    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
(22)    —   
(38)   

(3) 
(4) 
(22) 
(23) 
(20) 
(4) 
(3) 
(41) 
(137) 
(69) 
(8) 
(2) 
(3) 
(1) 
(5) 
— 
(27) 
(1) 
(22) 
(8,650) 

 —  AA- and above
A+ to A-
 — 
BBB+ to BBB-
 0.1 
BB+ to BB-
 0.3 
BB- to B
 0.3 
B-
 0.5 
CCC+
 3.8 
CCC to C
 8.6 
 29.2 
D
 0.1 
 —  AA- and above
A+ to A-
 — 
BBB+ to BBB-
 0.1 
BB+ to BB-
 — 
BB- to B
 0.1 
B-
 — 
CCC+
 3.1 
CCC to C
 0.2 
 26.8 
D
 1.4 

HSBC Holdings plc Annual Report and Accounts 2022

175

Risk review 
 
 
ECL 
coverage

Mapped 
external rating

%

 1.6 

 — 
 0.1 
 0.2 
 0.4 
 0.8 
 1.8 
 3.5 
 8.5 
 41.3 

 0.2 

 — 
 — 
 0.1 
 0.3 
 0.2 
 2.5 
 3.3 
 — 
 10.1 
 — 
 — 
 — 
 — 
 0.1 
 0.2 
 — 
 — 
 66.7 
 — 
 1.3 

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

Risk review

Wholesale lending – credit risk profile by obligor grade for loans and advances at amortised cost (continued)

Basel one-year 
PD range

Stage 1 Stage 2

%

$m

Gross carrying amount
POC
I
$m $m

Stage 
3

$m

Allowance for ECL

Total 

$m

Stage 

1 Stage 2 Stage 3 POCI
$m $m

$m

$m

Total 

$m

Corporate and
commercial
–  CRR 1
–  CRR 2
–  CRR 3
–  CRR 4
–  CRR 5
–  CRR 6
–  CRR 7
–  CRR 8
–  CRR 9/10
Non-bank financial 
institutions
–  CRR 1
–  CRR 2
–  CRR 3
–  CRR 4
–  CRR 5
–  CRR 6
–  CRR 7
–  CRR 8
–  CRR 9/10
Banks
–  CRR 1
–  CRR 2
–  CRR 3
–  CRR 4
–  CRR 5
–  CRR 6
–  CRR 7
–  CRR 8
–  CRR 9/10
At 31 Dec 2021

 400,894    98,911   13,460    274   513,539   

(665)   

(1,874)   

(5,601)   

(64)   

(8,204) 

0.000 to 0.053   40,583   
599    —    —    41,182   
0.054 to 0.169   78,794    4,843    —    —    83,637   
0.170 to 0.740  139,739    19,199    —    —   158,938   
0.741 to 1.927   91,268    23,365    —    —   114,633   
1.928 to 4.914   45,850    28,375    —    —    74,225   
4.915 to 8.860   3,280    11,197    —    —    14,477   
8.861 to 15.000   1,101    4,406    —    —    5,507   
4    7,210   
—   13,460    270    13,730   

15.001 to 99.999  
100.000   

279    6,927    —   

—   

(7)   
(26)   
(165)   
(218)   
(185)   
(22)   
(24)   
(18)   
—   

(1)   
(43)   
(145)   
(258)   
(424)   
(242)   
(167)   
(594)   
—   

—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
(64)   

(5,601)   

(8) 
(69) 
(310) 
(476) 
(609) 
(264) 
(191) 
(612) 
(5,665) 

  61,086    3,874   

395    —    65,355   

(44)   

(26)   

(40)    —   

(110) 

102   
5   
1   
—   

98    —    —   
25    —    —   
59    —    —   
395    —   
—   

122    —    —    14,492   
0.000 to 0.053   14,370   
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   
200   
4.915 to 8.860  
30   
8.861 to 15.000  
60   
15.001 to 99.999  
395   
100.000   
  81,636    1,517    —    —    83,153   
10    —    —    61,285   
65    —    —    11,693   
102    —    —    4,037   
180    —    —    4,412   
608   
550   
565   
3   
—   
 543,616   104,302   13,855    274   662,047   

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   
556   
1.928 to 4.914  
9   
4.915 to 8.860  
1   
8.861 to 15.000  
—   
15.001 to 99.999  
—   
100.000   

52    —    —   
541    —    —   
564    —    —   
3    —    —   
—    —    —   

(2)   
(5)   
(11)   
(15)   
(11)   
—   
—   
—   
—   
(14)   
(4)   
(3)   
(2)   
(5)   
—   
—   
—   
—   
—   
(723)   

(1)   
—   
(4)   
(11)   
(4)   
(5)   
(1)   
—   
—   
(3)   
—   
—   
—   
—   
(1)   
—   
—   
(2)   
—   
(1,903)   

—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
(40)    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
—    —   
(64)   

(5,641)   

(3) 
(5) 
(15) 
(26) 
(15) 
(5) 
(1) 
— 
(40) 
(17) 
(4) 
(3) 
(2) 
(5) 
(1) 
— 
— 
(2) 
— 
(8,331) 

176

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
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, mainland China 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 to customers

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.

Excluding adverse foreign exchange movements of $3.8bn, 
commercial real estate lending decreased by $14.9bn, mainly due to 
the reclassification of assets held for sale of our banking operations in 
Canada of $7.1bn, compounded by loan repayments in Hong Kong of 
$6.7bn and France of $0.7bn.

Gross loans and advances
Stage 1
Stage 2
Stage 3
POCI
At 31 Dec 2022
–  of which: forborne loans
Allowance for ECL

Gross loans and advances
Stage 1
Stage 2
Stage 3
POCI
At 31 Dec 2021
–  of which: forborne loans1
Allowance for ECL

Europe

$m

Asia

$m

MENA

$m

North
 America

Latin 
America 

$m

$m

17,318   
3,590   
980   
—   
21,888   
359   
(369)   

20,317   
3,505   
1,062   
—   
24,884   
440   
(450)   

46,757   
16,337   
3,320   
19   
66,433   
763   
(2,095)   

56,734   
17,103   
543   
98   
74,478   
251   
(693)   

1,115   
364   
286   
—   
1,765   
472   
(159)   

781   
569   
206   
—   
1,556   
145   
(158)   

1,534   
798   
8   
—   
2,340   
173   
(12)   

8,328   
1,265   
9   
—   
9,602   
—   
(26)   

880   
44   
54   
—   
978   
47   
(31)   

1,073   
218   
249   
—   
1,540   
—   
(130)   

Total

$m

67,604   
21,133   
4,648   
19   
93,404   
1,814   
(2,666)   

87,233   
22,660   
2,069   
98   
112,060   
836   
(1,457)   

of which:

UK Hong Kong

$m

$m

12,209   
3,008   
827   
—   
16,044   
336   
(323)   

14,235   
2,781   
905   
—   
17,921   
436   
(366)   

35,963 
11,092 
3,029 
19 
50,103 
654 
(1,879) 

42,951 
13,300 
435 
98 
56,784 
170 
(604) 

1  Forborne gross loans and advances at 31 December 2021 have not been restated, and agreed with the policies and disclosures presented in the 

Annual Report and Accounts 2021.

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 customer, being 

unable to repay the debt on maturity, fails to refinance it at 
commercial terms. We monitor our commercial real estate portfolio 
closely, assessing indicators for signs of potential issues with 
refinancing.

Commercial real estate gross loans and advances to customers maturity analysis

Europe

$m

Asia

$m

MENA

$m

North 
America

Latin 
America

$m

$m

On demand, overdrafts or revolving
< 1 year
1–2 years
2–5 years
> 5 years
At 31 Dec 2022

On demand, overdrafts or revolving
< 1 year
1–2 years
2–5 years
> 5 years
At 31 Dec 2021

10,996   
5,197   
4,031   
1,664   
21,888   

12,980   
4,794   
5,352   
1,758   
24,884   

23,492   
18,052   
21,818   
3,071   
66,433   

26,736   
18,192   
26,668   
2,882   
74,478   

434   
255   
694   
382   
1,765   

478   
159   
631   
288   
1,556   

196   
280   
1,832   
32   
2,340   

5,961   
1,098   
2,297   
246   
9,602   

Total

$m

35,417   
23,901   
28,837   
5,249   
93,404   

299   
117   
462   
100   
978   

336   
280   
559   
365   
1,540   

46,491   
24,523   
35,507   
5,539   
112,060   

of which:

UK 

$m

9,211   
3,678   
2,472   
683   
16,044   

10,546   
3,921   
2,805   
649   
17,921   

Hong 
Kong

$m

18,698 
13,917 
14,978 
2,510 
50,103 

20,466 
14,399 
19,562 
2,357 
56,784 

HSBC Holdings plc Annual Report and Accounts 2022

177

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

The following table presents the Group’s exposure to borrowers 
classified in the commercial real estate sector where the ultimate 
parent is based in mainland China, as well as all commercial real 

estate exposures booked on mainland China balance sheets. The 
exposures at 31 December 2022 are split by country/territory and 
credit quality including allowances for ECL by stage.

Mainland China commercial real estate

Loans and advances to customers2
Guarantees issued and others3
Total mainland China commercial real estate exposure at 31 Dec 2022
Distribution of mainland China commercial real estate exposure by 
credit quality
–  Strong
–  Good
–  Satisfactory
–  Sub-standard
–  Credit impaired
At 31 Dec 2022

Allowance for ECL by credit quality
–  Strong
–  Good
–  Satisfactory
–  Sub-standard
–  Credit impaired
At 31 Dec 2022

Allowance for ECL by stage distribution
– Stage 1
– Stage 2
– Stage 3
– POCI
At 31 Dec 2022

ECL coverage %

Hong Kong Mainland China Rest of the Group
(unaudited)1
(audited)1
$m
$m
860   
5,752   
18   
755   
878   
6,507   

(audited)1
$m
9,129   
249   
9,378   

Total
(unaudited)1
$m
15,741 
1,022 
16,763 

1,425   
697   
1,269   
2,887   
3,100   
9,378   

—   
—   
(20)   
(458)   
(1,268)   
(1,746)   

(1)   
(477)   
(1,268)   
—   
(1,746)   

18.6   

2,118   
1,087   
2,248   
779   
275   
6,507   

(5)   
(8)   
(81)   
(42)   
(105)   
(241)   

(9)   
(127)   
(105)   
—   
(241)   

3.7   

220   
370   
77   
193   
18   
878   

—   
(1)   
—   
(3)   
—   
(4)   

(1)   
(3)   
—   
—   
(4)   

3,763 
2,154 
3,594 
3,859 
3,393 
16,763 

(5) 
(9) 
(101) 
(503) 
(1,373) 
(1,991) 

(11) 
(607) 
(1,373) 
— 
(1,991) 

0.5   

11.9 

1   Disclosures in respect of mainland China commercial real estate exposures in Hong Kong and mainland China form part of the scope of the audit of 

the Group’s Annual Report and Accounts 2022. Amounts disclosed for mainland China commercial real estate exposures elsewhere in the Group have 
not been audited but are provided for completeness.

2   Amounts represent gross carrying amount.
3   Amounts represent nominal amount for guarantees and other contingent liabilities.

178

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Mainland China commercial real estate

Loans and advances to customers3
Guarantees issued and others4
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 by credit quality
–  Strong
–  Good
–  Satisfactory
–  Sub-standard
–  Credit impaired

At 31 Dec 2021

Allowance for ECL by stage distribution
–  Stage 1

–  Stage 2

–  Stage 3
–  POCI
At 31 Dec 2021

ECL coverage %

Hong Kong1 Mainland China
(audited)2
$m
6,811   
2,376   
9,187   

(audited)2
$m
11,484   
166   
11,650   

Rest of the Group
(unaudited)2
$m
410   
79   
489   

Total
(unaudited)2
$m
18,705 
2,621 
21,326 

3,543   
2,652   
3,383   
1,570   
502   
11,650   

(15)   
(37)   
(382)   
(24)   
(102)   

(560)   

(2)   

(456)   

(102)   
—   
(560)   

4.8   

3,864   
2,354   
2,855   
12   
102   
9,187   

(7)   
(10)   
(20)   
(1)   
(11)   

(49)   

(11)   

(27)   

(11)   
—   
(49)   

0.5   

155   
73   
106   
155   
—   
489   

—   
—   
(2)   
—   
—   

(2)   

(1)   

(1)   

—   
—   
(2)   

0.4 

7,562 
5,079 
6,344 
1,737 
604 
21,326 

(22) 
(47) 
(404) 
(25) 
(113) 

(611) 

(14) 

(484) 

(113) 
— 
(611) 

2.9

1   Comparatives have been restated to reflect an exposure reclassification from ‘guarantees and others‘ to ‘loans and advances to customers‘, which 

better reflects the nature of product.

2   Disclosures in respect of mainland China commercial real estate exposures in Hong Kong and mainland China form part of the scope of the audit of 

the Group’s Annual Report and Accounts 2022. Amounts disclosed for mainland China commercial real estate exposures elsewhere in the Group have 
not been audited but are provided for completeness.

3   Amounts represent gross carrying amount.
4   Amounts represent nominal amount for guarantees and other contingent liabilities.

Commercial real estate financing refers to lending that focuses on 
commercial development and investment in real estate and covers 
commercial, residential and industrial assets. Commercial real estate 
financing can also be provided to a corporate or financial entity for the 
purchase or financing of a property which supports the overall 
operations of the business.

The exposures in the table are 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.

The exposures in the table above had 57% (31 December 2021: 89%) 
of exposure booked with a credit quality of ‘satisfactory’ or above. 
This deterioration reflects increased funding risks and weaker sales 
performance for a number of our customers over the period.

Facilities booked in Hong Kong are exposures which represent 
relatively higher risk within the mainland China commercial real estate 
portfolio. This portfolio had 36% (31 December 2021: 82%) of 
exposure booked with a credit quality of ‘satisfactory’ or above, 
reflecting sustained credit deterioration in this book over the course of 
the year. At 31 December 2022, the Group had allowances for ECL of 
$1.7bn (31 December 2021: $0.6bn) held against mainland China 
commercial real estate exposures booked in Hong Kong .

Over one third of the unimpaired exposure in the Hong Kong portfolio 
reflects lending to state owned enterprises, and much of the 
remaining is to relatively strong privately owned enterprises. This is 
reflected in the relatively low ECL allowance in this part of the 
portfolio.

Regulatory and policy developments in the latter part of 2022 appear 
to have stabilised the sector. Sustained liquidity support and improved 
domestic residential demand will be necessary to support a recovery.

The Group has additional exposures to mainland China commercial 
real estate as a result of lending to multinational corporates, which is 
not incorporated in the table above.

HSBC Holdings plc Annual Report and Accounts 2022

179

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Collateral and other credit enhancements

Collateral on loans and advances

Collateral held is analysed separately for commercial real estate and 
for other corporate, commercial and financial (non-bank) lending. The 
following tables include off-balance sheet loan commitments, 
primarily undrawn credit lines.

The collateral measured in the following tables consists of fixed first 
charges on real estate, and charges over cash and marketable 
financial instruments. The values in the tables represent the expected 
market value on an open market basis. No adjustment has been made 
to the collateral for any expected costs of recovery. Marketable 
securities are measured at their fair value.

Other types of collateral such as unsupported guarantees and floating 
charges over the assets of a customer’s business are not measured 
in the following tables. While such mitigants have value, often 
providing rights in insolvency, their assignable value is not sufficiently 
certain and they are therefore assigned no value for disclosure 
purposes.

The LTV ratios presented are calculated by directly associating loans 
and advances with the collateral that individually and uniquely 
supports each facility. When collateral assets are shared by multiple 
loans and advances, whether specifically or, more generally, by way 
of an all monies charge, the collateral value is pro-rated across the 
loans and advances protected by the collateral.

For credit-impaired loans, the collateral values cannot be directly 
compared with impairment allowances recognised. The LTV figures 
use open market values with no adjustments. Impairment allowances 
are calculated on a different basis, by considering other cash flows 
and adjusting collateral values for costs of realising collateral as 
explained further on page 342.

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.

(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. 

Certain credit mitigants are used strategically in portfolio management 
activities. While single name concentrations arise in portfolios 
managed by Global Banking and Corporate Banking, it is only in Global 
Banking that their size requires the use of portfolio level credit 
mitigants. Across Global Banking, risk limits and utilisations, maturity 
profiles and risk quality are monitored and managed proactively. This 
process is key to the setting of risk appetite for these larger, more 
complex, geographically distributed customer groups. While the 
principal form of risk management continues to be at the point of 
exposure origination, through the lending decision-making process, 
Global Banking also utilises loan sales and credit default swap (‘CDS’) 
hedges to manage concentrations and reduce risk. 

These transactions are the responsibility of a dedicated Global 
Banking portfolio management team. Hedging activity is carried out 
within agreed credit parameters, and is subject to market risk limits 
and a robust governance structure. Where applicable, CDSs are 
entered into directly with a central clearing house counterparty. 
Otherwise, the Group’s exposure to CDS protection providers is 
diversified among mainly banking counterparties with strong credit 
ratings.

CDS mitigants are held at portfolio level and are not included in the 
expected credit loss calculations. CDS mitigants are not reported in 
the following tables.

180

HSBC Holdings plc Annual Report and Accounts 2022

Wholesale lending – commercial real estate loans and advances to customers including loan commitments by level of collateral for key 
countries/territories (by stage)
(Audited)

Total
Gross carrying/
nominal amount

ECL 
coverage

UK
Gross carrying/
nominal amount

of which:

Hong Kong

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

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 2022

$m

%

$m

%

44,052 
53,475 

29,486 
18,530 
2,941 
2,518 
4,923 
2,800 
102,450 

9,804 
15,423 

5,945 
6,821 
908 
1,749 
1,624 
997 
26,851 

2,612 
1,617 

544 
594 
315 
164 
513 
293 
4,742 

— 
— 

— 
— 
— 
— 
19 
8 
19 
134,062 

 0.1   
 0.1   

 0.1   
 0.1   
 0.1   
 0.2   
 0.1   

 0.1   

 5.7   
 1.6   

 1.6   
 1.1   
 2.1   
 3.6   
 1.6   

 3.1   

 53.7   
 10.8   

 16.5   
 4.4   
 4.1   
 28.7   
 54.2   

 39.1   

 —   
 —   

 —   
 —   
 —   
 —   
 —   

 —   
 2.1   

5,960 
10,293 

2,900 
6,361 
556 
476 
1,920 
1,113 
18,173 

2,511 
2,025 

664 
1,197 
140 
24 
179 
144 
4,715 

295 
372 

53 
291 
11 
17 
176 
72 
843 

— 
— 

— 
— 
— 
— 
— 
— 
— 
23,731 

 0.3   
 0.1   

 0.2   
 0.1   
 0.2   
 0.2   
 0.2   

 0.2   

 1.5   
 0.9   

 0.9   
 0.9   
 1.4   
 0.4   
 1.1   

 1.3   

 35.3   
 6.5   

 3.8   
 2.1   
 18.2   
 76.5   
 68.8   

 29.5   

 —   
 —   

 —   
 —   
 —   
 —   
 —   

 —   
 1.4   

$m

20,286 
27,926 

21,185 
5,365 
995 
381 
804 
584 
49,016 

4,673 
7,457 

3,539 
3,536 
134 
248 
390 
249 
12,520 

2,123 
864 

318 
205 
264 
77 
73 
39 
3,060 

— 
— 

— 
— 
— 
— 
19 
8 
19 
64,615 

%

 — 
 — 

 — 
 0.1 
 — 
 — 
 — 

 — 

 10.5 
 1.1 

 1.4 
 1.0 
 0.1 
 0.2 
 2.8 

 4.7 

 56.9 
 5.2 

 2.2 
 3.4 
 1.9 
 32.5 
 61.6 

 42.5 

 — 
 — 

 — 
 — 
 — 
 — 
 — 

 — 
 2.9 

HSBC Holdings plc Annual Report and Accounts 2022

181

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Wholesale lending – commercial real estate loans and advances to customers including loan commitments by level of collateral for key 
countries/territories (by stage) (continued)

(Audited)

Total
Gross carrying/
nominal amount

Of which:

UK

Hong Kong

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

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

%

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 
26,253 

828 
1,176 

645 
286 
62 
183 
265 
149 
2,269 

— 
98 

98 
— 
— 
— 
— 
— 
98 
156,421 

 0.1   
 0.1   

 0.1   
 0.1   
 0.2   
 0.1   
 0.1   

 0.1   

 4.3   
 1.1   

 1.0   
 1.1   
 1.5   
 1.5   
 2.7   

 2.7   

 40.9   
 22.0   

 19.8   
 9.1   
 14.5   
 52.5   
 47.9   

 32.0   

 —   
 —   

 —   
 —   
 —   
 —   
 —   

 —   
 1.0   

7,623 
13,139 

4,142 
6,460 
1,859 
678 
2,018 
874 
22,780 

1,970 
1,131 

605 
471 
43 
12 
366 
223 
3,467 

407 
346 

36 
250 
11 
49 
204 
97 
957 

— 
— 

— 
— 
— 
— 
— 
— 
— 
27,204 

 0.4   
 0.2   

 0.2   
 0.2   
 0.2   
 —   
 0.1   

 0.3   

 0.9   
 2.3   

 3.1   
 1.3   
 —   
 —   
 0.3   

 1.3   

 42.0   
 5.2   

 2.8   
 5.2   
 —   
 8.2   
 49.0   

 30.2   

 —   
 —   

 —   
 —   
 —   
 —   
 —   

 —   
 1.5   

$m

23,864 
32,951 

22,645 
8,082 
1,181 
1,043 
714 
447 
57,529 

7,758 
6,385 

3,633 
2,389 
269 
94 
172 
70 
14,315 

198 
290 

284 
— 
2 
4 
— 
— 
488 

— 
98 

98 
— 
— 
— 
— 
— 
98 
72,430 

%

 — 
 — 

 — 
 — 
 — 
 0.1 
 — 

 — 

 5.9 
 0.4 

 0.3 
 0.5 
 0.4 
 — 
 2.9 

 3.4 

 35.9 
 11.0 

 10.9 
 — 
 — 
 25.0 
 — 

 21.1 

 — 
 — 

 — 
 — 
 — 
 — 
 — 

 — 
 0.8 

182

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale lending – commercial real estate loans and advances including loan commitments by level of collateral for key 
countries/territories
(Audited)

Total
Gross carrying/
nominal amount

of which:

UK

Hong Kong

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

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 2022

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

$m

%

$m

%

52,373 
68,020 
6,479 
3,754 
126,872 

1,483 
878 

236 
594 
45 
3 
68 
43 
2,429 

2,612 
1,617 

544 
594 
315 
164 
532 
301 
4,761 
134,062 

61,279 
83,456 
7,059 
3,729 
151,794 

1,053 
1,054 

503 
447 
60 
44 
153 
143 
2,260 

828 
1,274 

743 
286 
62 
183 
265 
149 
2,367 
156,421 

 0.6   
 0.3   
 0.4   

 0.4   

 19.8   
 9.2   

 21.6   
 5.1   
 0.4   
 3.3   
 2.9   

 15.5   

 53.7   
 10.8   

 16.5   
 4.4   
 4.1   
 28.7   
 52.3   

 39.0   
 2.1   

 0.5   
 0.2   
 0.5   

 0.3   

 26.5   
 3.8   

 4.8   
 3.1   
 1.7   
 2.3   
 15.0   

 15.1   

 40.9   
 20.3   

 17.2   
 9.1   
 14.5   
 52.5   
 47.9   

 30.6   
 1.0   

8,457 
12,309 
2,098 
1,257 
22,864 

14 
9 

4 
3 
— 
2 
1 
— 
24 

295 
372 

53 
291 
11 
17 
176 
72 
843 
23,731 

9,586 
14,218 
2,379 
1,092 
26,183 

7 
52 

41 
8 
1 
2 
5 
5 
64 

407 
346 

36 
250 
11 
49 
204 
97 
957 
27,204 

 0.7   
 0.3   
 0.2   

 0.4   

 3.6   
 11.1   

 7.5   
 13.3   
 —   
 3.5   
 8.0   

 6.6   

 35.3   
 6.5   

 3.8   
 2.1   
 18.2   
 76.5   
 68.8   

 29.5   
 1.4   

 0.5   
 0.2   
 0.2   

 0.3   

 42.9   
 38.5   

 41.5   
 25.0   
 —   
 —   
 20.0   

 37.5   

 42.0   
 5.2   

 2.8   
 5.2   
 —   
 8.2   
 49.0   

 30.2   
 1.5   

$m

23,861 
34,779 
1,194 
833 
59,834 

1,098 
604 

167 
393 
44 
— 
— 
— 
1,702 

2,123 
864 

318 
205 
264 
77 
92 
47 
3,079 
64,615 

30,917 
38,817 
886 
517 
70,620 

705 
519 

378 
137 
4 
— 
— 
— 
1,224 

198 
388 

382 
— 
2 
4 
— 
— 
586 
72,430 

%

 0.9 
 0.1 
 0.9 

 0.5 

 26.0 
 7.1 

 15.0 
 4.6 
 0.2 
 — 
 — 

 19.3 

 56.9 
 5.2 

 2.2 
 3.4 
 1.9 
 32.5 
 48.9 

 42.2 
 2.9 

 0.6 
 0.1 
 0.6 

 0.3 

 38.6 
 2.1 

 0.8 
 5.8 
 — 
 — 
 — 

 23.1 

 35.9 
 8.2 

 8.1 
 — 
 — 
 25.0 
 — 

 17.6 
 0.8 

HSBC Holdings plc Annual Report and Accounts 2022

183

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

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)

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 2022

of which:

Total
Gross 
carrying/
nominal 
amount

ECL 
coverage

UK
Gross 
carrying/
nominal 
amount

ECL 
coverage

Hong Kong
Gross 
carrying/
nominal 
amount

ECL 
coverage

$m

%

$m

%

$m

632,847 
96,434 

36,896 
29,242 
9,922 
20,374 
54,836 
27,779 
784,117 

79,013 
29,618 

11,221 
11,948 
2,990 
3,459 
13,130 
6,484 
121,761 

8,278 
1,948 

678 
503 
402 
365 
2,120 
1,133 
12,346 

64 
24 

— 
1 
23 
— 
22 
16 
110 
918,334 

 0.1   
 0.1   

 0.1   
 0.1   
 0.1   
 0.1   
 0.1   

 0.1   

 1.0   
 1.2   

 1.3   
 1.4   
 1.0   
 0.8   
 1.0   

 1.1   

 38.4   
 13.7   

 18.7   
 11.3   
 4.7   
 17.5   
 37.3   

 34.3   

 18.8   
 91.7   

 —   
 —   
 95.7   
 —   
 18.2   

 34.5   
 0.7   

105,126 
21,192 

6,928 
7,611 
1,889 
4,764 
6,480 
3,470 
132,798 

16,886 
6,511 

2,872 
2,656 
578 
405 
2,288 
1,197 
25,685 

3,783 
699 

175 
336 
102 
86 
308 
158 
4,790 

28 
— 

— 
— 
— 
— 
— 
— 
28 
163,301 

 0.1   
 0.1   

 0.1   
 0.1   
 0.1   
 —   
 0.1   

 0.1   

 2.2   
 1.3   

 1.0   
 1.5   
 1.9   
 1.2   
 1.2   

 1.9   

 17.8   
 4.6   

 3.4   
 6.5   
 1.0   
 3.5   
 25.6   

 16.4   

 3.6   
 —   

 —   
 —   
 —   
 —   
 —   

 3.6   
 0.9   

109,919 
39,165 

15,695 
13,893 
4,964 
4,613 
17,704 
7,737 
166,788 

9,906 
12,693 

4,577 
5,413 
1,479 
1,224 
3,379 
1,524 
25,978 

939 
665 

175 
115 
268 
107 
777 
397 
2,381 

— 
24 

— 
1 
23 
— 
14 
13 
38 
195,185 

%

 — 
 0.1 

 0.1 
 0.1 
 0.1 
 0.1 
 0.1 

 0.1 

 0.7 
 1.0 

 0.9 
 1.2 
 0.7 
 0.3 
 0.6 

 0.8 

 56.0 
 3.8 

 1.7 
 7.8 
 0.4 
 10.3 
 30.9 

 33.2 

 — 
 91.7 

 — 
 — 
 95.7 
 — 
 — 

 57.9 
 0.6 

184

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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)

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

Total

UK

Hong Kong

Gross carrying/
nominal 
amount

ECL 
coverage

Gross carrying/
nominal 
amount

ECL 
coverage

Gross carrying/
nominal 
amount

ECL 
coverage

of which:

$m

%

$m

%

$m

624,935 
112,905 

40,636 
38,709 
13,284 
20,276 
64,058 
30,890 
801,898 

85,394 
32,019 

10,892 
14,281 
2,752 
4,094 
12,484 
6,675 
129,897 

8,122 
2,278 

603 
1,110 
295 
270 
2,134 
1,200 
12,534 

114 
61 

— 
57 
— 
4 
2 
2 
177 
944,506 

 0.1   
 0.1   

 0.1   
 0.1   
 0.1   
 0.1   
 0.1   

 0.1   

 1.1   
 1.1   

 1.2   
 1.1   
 1.2   
 0.9   
 1.0   

 1.1   

 47.3   
 12.7   

 20.9   
 5.0   
 11.5   
 27.4   
 38.7   

 39.6   

 36.0   
 34.4   

 —   
 36.8   
 —   
 —   
 100.0   

 36.2   
 0.8   

112,188 
22,971 

6,512 
9,431 
2,556 
4,472 
8,665 
4,826 
143,824 

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 
4,509 

28 
— 

— 
— 
— 
— 
— 
— 
28 
176,978 

 0.2   
 0.2   

 0.2   
 0.2   
 0.1   
 —   
 0.1   

 0.2   

 2.0   
 1.3   

 1.5   
 1.2   
 1.5   
 1.7   
 1.9   

 1.8   

 21.6   
 3.4   

 4.8   
 1.4   
 9.6   
 9.7   
 35.5   

 17.7   

 21.4   
 —   

 —   
 —   
 —   
 —   
 —   

 21.4   
 0.9   

111,948 
45,479 

16,915 
16,533 
4,920 
7,111 
20,358 
9,322 
177,785 

8,310 
11,503 

3,378 
5,202 
1,148 
1,775 
1,788 
785 
21,601 

732 
240 

76 
110 
26 
28 
616 
358 
1,588 

4 
57 

— 
57 
— 
— 
— 
— 
61 
201,035 

%

 — 
 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 

 46.0 

 — 
 36.8 

 — 
 36.8 
 — 
 — 
 — 

 34.4 
 0.5 

HSBC Holdings plc Annual Report and Accounts 2022

185

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Wholesale lending – other corporate, commercial and financial (non-bank) loans and advances including loan commitments by level 
of collateral for key countries/territories
(Audited)

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 2022

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

of which:

Total
Gross 
carrying/
nominal 
amount

ECL 
coverage

UK
Gross 
carrying/
nominal 
amount

ECL 
coverage

$m

%

$m

%

4,209 
2,208 

1,104 
933 
44 
127 
1,298 
1,212 
7,715 

8,342 
1,971 

677 
504 
425 
365 
2,143 
1,149 
12,456 
20,171 

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 

 3.5   
 3.8   

 4.3   
 3.5   
 6.8   
 0.8   
 2.9   

 3.5   

 38.2   
 14.6   

 18.8   
 11.3   
 9.6   
 17.5   
 37.1   

 34.3   
 22.5   

 3.9   
 3.9   

 3.5   
 3.8   
 5.2   
 5.3   
 3.7   

 3.9   

 47.1   
 13.3   

 20.9   
 6.7   
 11.5   
 27.4   
 38.7   

 39.5   
 26.1   

1,071 
303 

184 
95 
22 
2 
24 
4 
1,398 

3,810 
699 

175 
336 
102 
86 
309 
158 
4,818 
6,216 

1,587 
259 

113 
110 
23 
13 
138 
40 
1,984 

3,007 
1,212 

249 
786 
115 
62 
318 
186 
4,537 
6,521 

 1.6   
 3.3   

 0.5   
 5.3   
 13.6   
 10.0   
 4.2   

 2.0   

 17.7   
 4.6   

 3.4   
 6.5   
 1.0   
 3.5   
 25.6   

 16.3   
 13.1   

 3.1   
 6.6   

 6.2   
 8.2   
 4.3   
 —   
 8.0   

 3.9   

 21.5   
 3.4   

 4.8   
 1.4   
 9.6   
 9.7   
 35.5   

 17.7   
 13.5   

Hong Kong
Gross 
carrying/
nominal 
amount

ECL 
coverage

$m

62 
171 

84 
84 
— 
3 
9 
5 
242 

939 
688 

175 
116 
290 
107 
792 
410 
2,419 
2,661 

79 
32 

2 
1 
29 
— 
11 
6 
122 

736 
297 

75 
168 
26 
28 
616 
358 
1,649 
1,771 

%

 38.7 
 12.3 

 14.3 
 10.7 
 — 
 6.7 
 11.1 

 19.0 

 56.0 
 6.7 

 1.7 
 7.8 
 7.9 
 10.3 
 30.3 

 33.6 
 32.2 

 30.4 
 — 

 — 
 — 
 — 
 — 
 — 

 20.5 

 74.3 
 9.1 

 — 
 14.9 
 — 
 3.6 
 28.9 

 45.6 
 43.8 

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.

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 378 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.

• Trading loans and advances mainly pledged against cash collateral 
are posted to satisfy margin requirements. There is limited credit 

For further information on these arrangements, see Note 33 on the 
financial statements.

186

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

Total OTC derivatives
–  total OTC derivatives cleared by central counterparties
–  total OTC derivatives not cleared by central counterparties
Total exchange traded derivatives
Gross
Offset
At 31 Dec

Notional
amount
$m

  23,649,591   
  11,360,729   
  12,288,862   
  1,146,426   
  24,796,017   

2022

Fair value

Assets
$m
421,309   
149,190   
272,119   
3,824   
425,133   
(140,987)   
284,146   

Liabilities
$m

Notional
amount
$m

423,911    21,964,665   
154,167    10,086,344   
269,744    11,878,321   
2,840    1,359,692   
426,751    23,324,357   
(140,987) 
285,764 

2021

Fair value

Assets
$m
246,108   
59,147   
186,961   
4,152   
250,260   
(53,378)   
196,882   

Liabilities
$m
241,136 
60,686 
180,450 
3,306 
244,442 
(53,378) 
191,064 

The purposes for which HSBC uses derivatives are described 
in Note 15 on the financial statements.

The reduction was partly mitigated by growth of $8.7bn in the UK, 
$2.8bn in Asia and $2.0bn in Latin America. 

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 Note 31 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 
2022 to 31 December 2022 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 2022, total personal lending for loans and advances 
to customers of $415bn decreased by $63.3bn compared with 
31 December 2021. This decrease included adverse foreign exchange 
movements of $27.3bn. Excluding foreign exchange movements, 
there was a decrease of $36bn. This decrease was due to the 
reclassification to assets held for sale of our banking business in 
Canada of $26.1bn and our retail banking operations in France of 
$23.7bn.

The allowance for ECL attributable to personal lending, excluding off-
balance sheet loan commitments and guarantees, decreased by 
$0.2bn to $2.9bn at 31 December 2022. This included favourable 
foreign exchange movements of $0.1bn.

Excluding foreign exchange movements and reclassifications to held 
for sale, mortgage lending balances increased by $15.4bn to $336.8bn 
at 31 December 2022. The majority of the growth was in the UK by 
$8.9bn; Asia by $4.4bn, notably $3.4bn in Hong Kong and $1.6bn in 
Australia; and in Latin America by $1.0bn. The allowance for ECL, 
excluding foreign exchange, attributable to mortgages of $0.6bn 
decreased by $0.1bn compared with 31 December 2021.

At 31 December 2022, for certain retail lending portfolios, we 
introduced enhancements in the significant increase in credit risk 
(‘SICR’) approach in relation to capturing relative movements in 
probability of default (‘PD’). The enhanced approach captured relative 
movements in PD since origination, which resulted in a significant 
migration to stage 2 from loans to customers gross carrying amounts 
in stage 1.

The volume of stage 1 customer accounts with lower absolute levels 
of credit risk who have exhibited some amount of relative increase in 
PD since origination have migrated into stage 2, and accounts 
originated with higher absolute levels of credit risk with no or 
insignificant increases in PD since origination have been transferred to 
stage 1, with no material overall change in risk.

The impact on ECL is immaterial due to the offsetting ECL impacts of 
stage migrations and due to the LTV profiles. This is particularly 
applicable to UK customers. 

The enhancement of the SICR approach constitutes an improvement 
towards more responsive models that better reflect the SICR since 
origination. This includes consideration of the current cost of living 
pressures, as markets adjust to the higher interest-rate environment.

The quality of both our Hong Kong and UK mortgage books remained 
strong, with low levels of impairment allowances. The average LTV 
ratio on new mortgage lending in Hong Kong was 59%, compared 
with an estimated 57% for the overall mortgage portfolio. The 
average LTV ratio on new lending in the UK was 67%, compared with 
an estimated 50% for the overall mortgage portfolio. 

Excluding foreign exchange movements and reclassifications to held 
for sale, other personal lending balances at 31 December 2022 
decreased by $1.4bn compared with 31 December 2021. This was 
mainly from a decline of $2.0bn from Hong Kong in secured personal 
lending, partly offset by an increase of $0.5bn from Latin America in 
credit cards.

HSBC Holdings plc Annual Report and Accounts 2022

187

Risk review 
 
 
 
 
Risk review

The allowance for ECL, excluding foreign exchange, attributable to 
other personal lending of $2.3bn remained unchanged from 
31 December 2021. Excluding foreign exchange, the allowance for 

ECL attributable to credit cards increased by $0.1bn, offset by a 
decrease of $0.1bn in unsecured personal lending.

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 
–  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
At 31 Dec 2022
By geography
Europe 
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2022

Stage 1
$m

Gross carrying amount
Stage 3
$m

Stage 2
$m

Total
$m

Stage 1
$m

Allowance for ECL
Stage 2
$m

Stage 3
$m

294,918   
19,636   

39,860   
4,485   

2,043   
169   

336,821   
24,290   

14,773   

67,863   
353   

369   

9,031   
20   

240   

15,382   

1,297   
6   

78,191   
379   

1,121   

121   

125   

1,367   

31,306   
16,705   
16,617   
1,761   
362,781   

143,438   
132,312   
185,828   
128,218   
5,347   
17,772   
10,396   
362,781   

594   
4,423   
3,706   
167   
48,891   

38,186   
37,974   
8,723   
4,563   
237   
562   
1,183   
48,891   

206   
260   
687   
13   
3,340   

1,269   
1,027   
1,117   
236   
132   
439   
383   
3,340   

32,106   
21,388   
21,010   
1,941   
415,012   

182,893   
171,313   
195,668   
133,017   
5,716   
18,773   
11,962   
415,012   

(74)   
(3)   

(5)   

(488)   
(1)   

(1)   

(15)   
(225)   
(235)   
(11)   
(562)   

(151)   
(137)   
(139)   
(59)   
(33)   
(15)   
(224)   
(562)   

(230)   
(46)   

(3)   

(1,275)   
(2)   

(3)   

(10)   
(777)   
(470)   
(13)   
(1,505)   

(706)   
(696)   
(363)   
(255)   
(42)   
(44)   
(350)   
(1,505)   

(270)   
(41)   

(4)   

(535)   
(3)   

(30)   

(30)   
(160)   
(305)   
(7)   
(805)   

(282)   
(230)   
(188)   
(39)   
(70)   
(67)   
(198)   
(805)   

Total
$m

(574) 
(90) 

(12) 

(2,298) 
(6) 

(34) 

(55) 
(1,162) 
(1,010) 
(31) 
(2,872) 

(1,139) 
(1,063) 
(690) 
(353) 
(145) 
(126) 
(772) 
(2,872) 

At 31 December 2022, the stage 2 personal lending balances in the 
UK of $38.0bn increased by $33.3bn compared with 31 December 
2021. This increase was largely due to the enhancement in the SICR 
approach in relation to capturing relative movements in PD since 

origination, and also, to a lesser extent, it considered cost of living 
pressures. The impact on ECL was immaterial due to the offsetting 
ECL impacts of stage migrations due to the low LTV profiles 
applicable to these UK customers.

Total personal lending for loans and other credit-related commitments and financial guarantees by stage distribution

Europe
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2022

Stage 1
$m
53,299   
51,589   
170,103   
128,990   
2,328   
10,418   
4,496   
240,644   

Nominal amount
Stage 2
$m
592   
454   
2,914   
2,176   
20   
140   
31   
3,697   

Stage 3
$m
114   
107   
633   
624   
2   
48   
3   
800   

Total
$m
54,005   
52,150   
173,650   
131,790   
2,350   
10,606   
4,530   
245,141   

Stage 1
$m
(11)   
(11)   
(2)   
(2)   
(1)   
(1)   
(11)   
(26)   

Allowance for ECL
Stage 2
$m

Stage 3
$m

(1)   
(1)   
—   
—   
—   
—   
—   
(1)   

—   
—   
—   
—   
—   
—   
—   
—   

Total
$m
(12) 
(12) 
(2) 
(2) 
(1) 
(1) 
(11) 
(27) 

188

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total personal lending for loans and advances to customers at amortised cost by stage distribution (continued)

By portfolio
First lien residential mortgages
–  of which: interest only (including offset) 
–  affordability (including US adjustable rate 

mortgages)

Other personal lending
–  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
At 31 Dec 2021
By geography
Europe
–  of which: UK
Asia
–  of which: Hong Kong
MENA
North America
Latin America
At 31 Dec 2021

Stage 1
$m

Gross carrying amount
Stage 3
$m

Stage 2
$m

Total
$m

Stage 1
$m

Allowance for ECL
Stage 2
$m

Stage 3
$m

360,686   
28,506   

13,621   

96,270   
314   

20,643   

36,533   
18,623   
18,743   
1,414   
456,956   

212,284   
176,547   
187,391   
125,854   
4,965   
43,489   
8,827   
456,956   

7,637   
1,795   

712   

8,802   
44   

3,045   
255   

371,368   
30,556   

452   

14,785   

1,897   
37   

106,969   
395   

731   

236   

21,610   

1,096   
3,897   
2,820   
214   
16,439   

5,639   
4,668   
7,796   
4,959   
252   
2,126   
626   
16,439   

366   
338   
915   
5   
4,942   

2,148   
1,488   
1,303   
202   
202   
1,005   
284   
4,942   

37,995   
22,858   
22,478   
1,633   
478,337   

220,071   
182,703   
196,490   
131,015   
5,419   
46,620   
9,737   
478,337   

(128)   
(5)   

(6)   

(530)   
(1)   

(9)   

(21)   
(246)   
(240)   
(13)   
(658)   

(199)   
(167)   
(158)   
(65)   
(38)   
(43)   
(220)   
(658)   

(131)   
(24)   

(6)   

(1,088)   
(4)   

(7)   

(15)   
(675)   
(378)   
(9)   
(1,219)   

(499)   
(480)   
(381)   
(231)   
(40)   
(67)   
(232)   
(1,219)   

(416)   
(81)   

(5)   

(810)   
(9)   

(42)   

(120)   
(214)   
(421)   
(4)   
(1,226)   

(637)   
(399)   
(226)   
(43)   
(94)   
(118)   
(151)   
(1,226)   

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 2021

Stage 1
$m
57,109   
54,704   
160,248   
121,597   
2,568   
15,039   
3,920   
238,884   

Nominal amount
Stage 2
$m
558   
407   
894   
292   
30   
251   
29   
1,762   

Stage 3
$m
107   
104   
21   
19   
16   
23   
2   
169   

Total
$m
57,774   
55,215   
161,163   
121,908   
2,614   
15,313   
3,951   
240,815   

Stage 1
$m
(11)   
(10)   
—   
—   
(5)   
(15)   
(6)   
(37)   

Allowance for ECL
Stage 2
$m

Stage 3
$m

(1)   
(1)   
—   
—   
—   
(1)   
—   
(2)   

—   
—   
—   
—   
—   
—   
—   
—   

Total
$m

(675) 
(110) 

(17) 

(2,428) 
(14) 

(58) 

(156) 
(1,135) 
(1,039) 
(26) 
(3,103) 

(1,335) 
(1,046) 
(765) 
(339) 
(172) 
(228) 
(603) 
(3,103) 

Total
$m
(12) 
(11) 
— 
— 
(5) 
(16) 
(6) 
(39) 

HSBC Holdings plc Annual Report and Accounts 2022

189

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Exposure to UK interest-only mortgage 
loans

The following information is presented for HSBC branded interest-
only mortgage loans. This excludes offset mortgages in first direct 
and private banking mortgages.

At the end of 2022, the average LTV ratio of the interest-only 
mortgage loans was 41% (2021: 40%) and 99% (2021: 99%) had a 
LTV ratio of 75% or less. 

Of the interest-only mortgage loans that expired in 2020, 83% were 
repaid within 12 months of expiry with a total of 96% being repaid 
within 24 months of expiry. For those expiring during 2021, 95% 
were repaid within 12 months of expiry. The increase of 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, which 
reduced the repayment rates within 12 months for cases maturing in 
2022. Following the end of these extension in October 2021, 
repayment rates have now returned to levels similar to 2019.

At 31 December 2022, interest-only mortgage loans exposures were 
$14.4bn and the maturity profile is as follows:

UK interest-only mortgage loans 

Expired interest-only mortgage loans
Interest-only mortgage loans by maturity
–  2023
–  2024
–  2025
–  2026
–  2027–2031
–  post-2031
At 31 Dec 2022

Expired interest-only mortgage loans
Interest-only mortgage loans by maturity
–  2022
–  2023
–  2024
–  2025
–  2026–2030
–  post-2030
At 31 Dec 2021

$m

134 

219 
215 
300 
383 
2,951 
10,248 
14,450 

167 

267 
401 
330 
420 
3,288 
10,333 
15,206 

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 2022, exposures were worth a total $5.5bn with an 
average LTV ratio of 32% (2021: $7.0bn exposure and 35% LTV ratio).

190

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Allowance 
for ECL

At 1 Jan 2022
Transfers of financial instruments
–  transfers from stage 1 to stage 2
–  transfers from stage 2 to stage 1
–  transfers to stage 3
–  transfers from stage 3
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/
repayments
Change in risk parameters – credit quality 
Changes to models used for ECL calculation
Assets written off
Foreign exchange and other1
At 31 Dec 2022
ECL income statement change for the period
Recoveries
Other
Total ECL income statement change for the 
period

$m
695,840   
(40,834)   
(68,063)   
27,407   
(561)   
383   

—   

130,632   
(68,645)   

(31,457)   

—   
—   
—   
(82,111)   
603,425   

$m
(695)   
(499)   
269   
(734)   
2   
(36)   

498   

(271)   
94   

162   

82   
(2)   
—   
43   
(588)   
563 

$m
18,201   
39,483   
68,063   
(27,407)   
(1,987)   
814   

—   

—   
(4,091)   

4,538   

—   
—   
—   
(5,543)   
52,588   

$m
(1,221)   
677   
(269)   
734   
361   
(149)   

(583)   

—   
270   

$m
5,111   
1,351   
—   
—   
2,548   
(1,197)   

—   

—   
(1,043)   

$m
(1,226)   
(178)   
—   
—   
(363)   
185   

$m
719,152   
—   
—   
—   
—   
—   

(88)   

—   
124   

—   

130,632   
(73,779)   

(35)   

897   

(33)   

(26,022)   

(676)   
(94)   
—   
156   
(1,506)   
(1,118) 

—   
—   
(1,215)   
(961)   
4,140   

(822)   
13   
1,215   
190   
(805)   
(806) 

—   
—   
(1,215)   
(88,615)   
660,153   

$m
(3,142) 
— 
— 
— 
— 
— 

(173) 

(271) 
488 

94 

(1,416) 
(83) 
1,215 
389 
(2,899) 
(1,361) 
283 
(3) 

(1,081) 

1   Total includes $49.6bn of gross carrying loans and advances to customers, which were classified to assets held for sale, and a corresponding 

allowance for ECL of $221m, reflecting business disposals as disclosed in Note 23 ‘Assets held for sale and liabilities of disposal groups held for sale’ 
on page 389.

As shown in the above table, the allowance for ECL for loans and 
advances to customers and relevant loan commitments and financial 
guarantees decreased by $243m during the period from $3,142m at 
31 December 2021 to $2,899m at 31 December 2022.

This decrease was primarily driven by:

• $1,215m of assets written off;

• foreign exchange and other movements of $389m; and

• $311m relating to volume movements, which included the ECL 

allowance associated with new originations, assets derecognised 
and further lending/repayment.

These were partly offset by:

• $1,416m relating to underlying credit quality changes, including the 
credit quality impact of financial instruments transferring between 
stages;

• $173m relating to the net remeasurement impact of stage 

transfers; and

• $83m of changes to models used for ECL calculation.

The ECL charge for the period of $1,361m presented in the above 
table consisted of $1,416m relating to underlying credit quality 
changes, including the credit quality impact of financial instruments 
transferring between stages, $83m in changes to models used for 
ECL calculation and $173m relating to the net remeasurement impact 
of stage transfers. This was partly offset by $311m relating to 
underlying net book volume movements.

During the period, there was a net transfer to stage 2 of $40,656m 
gross carrying/nominal amounts. This increase was primarily driven by 
$36,816m in Europe, of which $34,278m was from the UK, largely 
due to enhancements in the SICR approach in relation to capturing 
relative movements in PD since origination and taking into 
consideration cost of living pressures. Further details are presented 
on page 187.

HSBC Holdings plc Annual Report and Accounts 2022

191

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

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

$m
665,346   
1,822   
(23,701)   
26,086   
(982)   
419   

—   

136,920   
(82,998)   

(13,976)   

—   
—   
—   
(9,074)   
(2,200)   
695,840   

At 1 Jan 2021
Transfers of financial instruments
–  transfers from stage 1 to stage 2
–  transfers from stage 2 to stage 1
–  transfers to stage 3
–  transfers from stage 3
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/
repayments

Change in risk parameters – credit quality
Changes to models used for ECL calculation
Assets written off
Foreign exchange
Others1
At 31 Dec 2021
ECL income statement change for the period
Recoveries
Other
Total ECL income statement change for the period

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Gross 
carrying/ 
nominal 
amount

Allowance 
for ECL

Allowance 
for ECL

$m
(866)   
(1,154)   
289   
(1,404)   
7   
(46)   

825   

(211)   
119   

240   

318   
(2)   
—   
17   
19   
(695)   

1,289 

$m
26,770   
(4,502)   
23,701   
(26,086)   
(3,068)   
951   

—   

—   
(5,257)   

2,380   

—   
—   
—   
(358)   
(832)   
18,201   

Gross 
carrying/ 
nominal 
amount

$m
697,878   
—   
—   
—   
—   
—   

$m
(1,503)   
(559)   
—   
—   
(741)   
182   

(7)   

—   
219   

—   

136,920   
(89,491)   

Allowance 
for ECL

$m
(4,774) 
— 
— 
— 
— 
— 

455 

(211) 
757 

$m
(2,405)   
1,713   
(289)   
1,404   
734   
(136)   

(363)   

—   
419   

$m
5,762   
2,680   
—   
—   
4,050   
(1,370)   

—   

—   
(1,236)   

114   

(281)   

51   

(11,877)   

405 

(778)   
—   
—   
19   
60   
(1,221)   
(608) 

—   
—   
(1,525)   
(138)   
(151)   
5,111   

(1,007)   
1   
1,520   
45   
14   
(1,226)   
(743) 

—   
—   
(1,525)   
(9,570)   
(3,183)   
719,152   

(1,467) 
(1) 
1,520 
81 
93 
(3,142) 
(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.

Personal lending – credit risk profile by internal PD band for loans and advances to customers at amortised cost 

Gross carrying amount

Allowance for ECL

PD range1
%

Stage 1

Stage 2

Stage 3

Total

Stage 1

Stage 2

Stage 3

$m

$m

$m

$m

$m

$m

$m

  294,918   

39,860   

2,043    336,821   

0.000 to 0.250   247,330   
19,614   
0.251 to 0.500  
21,323   
0.501 to 1.500  
6,594   
1.501 to 5.000  
34   
5.001 to 20.000  
23   
20.001 to 99.999  
—   
100.000  
67,863   
30,151   
7,219   
17,183   
10,342   
2,501   
467   
—   
  362,781   

0.000 to 0.250  
0.251 to 0.500  
0.501 to 1.500  
1.501 to 5.000  
5.001 to 20.000  
20.001 to 99.999  
100.000  

21,220   
7,900   
5,691   
2,694   
1,024   
1,331   
—   
9,031   
153   
251   
1,499   
2,061   
3,692   
1,375   
—   
48,891   

—    268,550   
27,514   
—   
27,014   
—   
9,288   
—   
1,058   
—   
1,354   
—   
2,043   
2,043   
78,191   
1,297   
30,304   
—   
7,470   
—   
18,682   
—   
12,403   
—   
6,193   
—   
1,842   
—   
1,297   
1,297   
3,340    415,012   

(74)   

(13)   
(4)   
(18)   
(39)   
—   
—   
—   
(488)   
(54)   
(26)   
(82)   
(171)   
(154)   
(1)   
—   
(562)   

(230)   

(4)   
(3)   
(7)   
(24)   
(40)   
(152)   
—   
(1,275)   
(13)   
(1)   
(44)   
(104)   
(520)   
(593)   
—   
(1,505)   

(270)   

—   
—   
—   
—   
—   
—   
(270)   
(535)   
—   
—   
—   
—   
—   
—   
(535)   
(805)   

ECL 
coverage

%

 0.2 

 — 
 — 
 0.1 
 0.7 
 3.8 
 11.2 
 13.2 
 2.9 
 0.2 
 0.4 
 0.7 
 2.2 
 10.9 
 32.2 
 41.2 
 0.7 

Total

$m

(574) 

(17) 
(7) 
(25) 
(63) 
(40) 
(152) 
(270) 
(2,298) 
(67) 
(27) 
(126) 
(275) 
(674) 
(594) 
(535) 
(2,872) 

First lien residential 
mortgages

–  Band 1
–  Band 2
–  Band 3
–  Band 4
–  Band 5
–  Band 6
–  Band 7
Other personal lending 
–  Band 1
–  Band 2
–  Band 3
–  Band 4
–  Band 5
–  Band 6
–  Band 7
At 31 Dec 2022

1  12-month point in time adjusted for multiple economic scenarios.

192

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Personal lending – credit risk profile by internal PD band for loans and advances to customers at amortised cost (continued)

Gross carrying amount

Allowance for ECL

First lien residential 
mortgages

–  Band 1
–  Band 2
–  Band 3
–  Band 4
–  Band 5
–  Band 6
–  Band 7
Other personal lending
–  Band 1
–  Band 2
–  Band 3
–  Band 4
–  Band 5
–  Band 6
–  Band 7
At 31 Dec 2021

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   

0.000 to 0.250   310,042   
19,741   
0.251 to 0.500  
25,835   
0.501 to 1.500  
4,976   
1.501 to 5.000  
88   
5.001 to 20.000  
4   
20.001 to 99.999  
—   
100.000  
96,270   
45,049   
12,625   
22,791   
13,006   
2,732   
67   
—   
  456,956   

0.000 to 0.250  
0.251 to 0.500  
0.501 to 1.500  
1.501 to 5.000  
5.001 to 20.000  
20.001 to 99.999  
100.000  

451   
203   
1,936   
2,657   
1,416   
974   
—   
8,802   
187   
605   
1,518   
2,360   
3,257   
875   
—   
16,439   

—    310,493   
19,944   
—   
27,771   
—   
7,633   
—   
1,504   
—   
978   
—   
3,045   
3,045   
1,897    106,969   
45,236   
—   
13,230   
—   
24,309   
—   
15,366   
—   
5,989   
—   
942   
—   
1,897   
1,897   
4,942    478,337   

(128)   

(30)   
(7)   
(79)   
(12)   
—   
—   
—   
(530)   
(50)   
(27)   
(102)   
(213)   
(138)   
—   
—   
(658)   

(131)   

(416)   

(675) 

(5)   
(2)   
(8)   
(30)   
(35)   
(51)   
—   
(1,088)   
(13)   
(6)   
(30)   
(108)   
(554)   
(377)   
—   
(1,219)   

—   
—   
—   
—   
—   
—   
(416)   
(810)   
—   
—   
—   
—   
—   
—   
(810)   
(1,226)   

(35) 
(9) 
(87) 
(42) 
(35) 
(51) 
(416) 
(2,428) 
(63) 
(33) 
(132) 
(321) 
(692) 
(377) 
(810) 
(3,103) 

ECL 
coverage

%

 0.2 

 — 
 — 
 0.3 
 0.6 
 2.3 
 5.2 
 13.7 
 2.3 
 0.1 
 0.2 
 0.5 
 2.1 
 11.6 
 40.0 
 42.7 
 0.6 

1  12-month point in time adjusted for multiple economic scenarios.

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.

HSBC Holdings plc Annual Report and Accounts 2022

193

Risk review 
Risk review

Personal lending – residential mortgage loans including loan commitments by level of collateral for key countries/territories by stage
(Audited)

Total
Gross carrying/
nominal amount

of which:

UK

Hong Kong

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

Gross carrying/
nominal amount

ECL 
coverage

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 2022

$m

310,705 

154,337   
57,386 
44,805 
25,458 
17,106 
11,613 
6,964 

6,127 
570 
267 
6,521 
317,669 

%

 —   

—   
 —   
 —   
 —   
 —   
 —   
—  

—  
—  
0.4  

 —   

$m

134,044 

70,936 
23,226 
20,391 
12,849 
5,922 
720 
329 

73 
61 
195 
237 
134,373 

%

 —   

 —   
 —   
 —   
 —   
 —   
 —   
 —   

 —   
 —   
 —   

 —   

39,906 

0.6  

34,541 

0.4  

12,250 
7,372 
9,617 
6,770 
3,388 
509 
143 

73 
24 
46 
123 
40,049 

0.7  
0.5  
0.4  
0.5  
0.5  
1.1  
6.9  

3.6  
12.5  
9.1  

0.6  

2,097 

9.9  

1,077 
330 
207 
212 
147 
124 
133 

37 
17 
79 
79 
2,230 
359,948 

7.2  
7.6  
12.6  
14.7  
17.8  
18.1  
46.9  

24.3  
32.7  
60.5  

12.1  
0.2  

10,387 
6,402 
8,541 
5,922 
2,918 
371 
49 

10 
10 
29 
38 
34,590 

676 

448 
110 
48 
33 
10 
27 
12 

10 
— 
2 
4 
688 
169,651 

0.6  
0.4  
0.3  
0.3  
0.2  
0.2  
0.3  

1.2  
—  
0.1  

0.4  

11.1  

9.4  
9.7  
15.9  
19.7  
24.5  
22.5  
9.8  

3.7  
64.9  
36.2  

11.1  
0.1  

$m

94,949 

44,740 
18,027 
10,096 
4,167 
7,883 
10,036 
6,441 

5,953 
482 
6 
6,146 
101,390 

981 

577 
171 
85 
37 
51 
60 
47 

45 
2 
— 
44 
1,028 

237 

105 
26 
11 
25 
27 
43 
1 

1 
— 
— 
1 
238 
102,656 

%

 — 

 — 
 — 
 — 
 — 
 — 
 — 
 — 

 — 
 — 
 — 

 — 

 — 

 — 
 — 
 — 
 — 
 0.1 
 0.2 
 0.2 

 0.2 
 — 
 — 

 — 

 0.1 

 — 
 0.1 
 0.7 
 0.1 
 — 
 — 
 0.3 

 0.4 
 — 
 — 

 0.1 
 — 

194

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

$m

%

$m

%

$m

%

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

377,454 

 —   

168,737 

190,370 
64,217 
51,842 
46,932 
18,778 
5,315 
682 

254 
98 
330 
484 
378,136 

 —   
 —   
 —   
 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 
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   

 1.7   

1,846 
397 
282 
175 
32 
6 
3 

1 
— 
2 
2 
2,741 

 1.6   
 2.4   
 3.0   
 4.7   
 5.6   
 1.9   
 7.7   

 1.0   
 —   
 11.1   

 2.1   

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   

905 
106 
34 
50 
58 
13 
— 

— 
— 
— 
— 
1,166 

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 2022

195

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

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
–  Canada2
–  other
Latin America
–  Mexico
–  other
At 31 Dec 2022

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

Non-bank 
financial 
institutions

Corporate 
and 
commercial

Total

Corporate 
and 
commercial

$m
146,236   
104,775   
27,571   
6,603   
988   
6,299   
245,872   
145,411   
11,641   
9,052   
3,214   
31,790   
5,986   
15,904   
4,700   
18,174   

Of which: 
real estate1
$m
19,814   
14,309   
4,216   
252   
635   
402   
73,164   
56,161   
3,106   
1,711   
85   
5,752   
1,081   
3,812   
20   
1,436   

$m
18,198   
12,663   
4,152   
713   
298   
372   
38,863   
20,812   
1,157   
4,267   
226   
8,908   
180   
1,192   
65   
2,056   

$m
164,434   
117,438   
31,723   
7,316   
1,286   
6,671   
284,735   
166,223   
12,798   
13,319   
3,440   
40,698   
6,166   
17,096   
4,765   
20,230   

21,565   

1,766   

324   

21,889   

1,261   
13,503   
6,801   
28,619   
28,249   
—   
370   
12,064   
9,784   
2,280   
454,356   

163,341   
115,386   
34,488   
6,746   
1,188   
5,533   
263,821   
162,684   
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   
513,539   

77   
1,569   
120   
5,783   
5,714   
—   
69   
907   
903   
4   
101,434   

23,137   
16,233   
5,520   
306   
731   
347   
81,453   
62,792   
2,596   
1,786   
86   
6,811   
1,741   
4,158   
31   
1,452   

1,555   

69   
1,370   
116   
13,639   
5,895   
7,650   
94   
1,476   
1,475   
1   
121,260   

101   
149   
74   
8,791   
8,640   
—   
151   
763   
717   
46   
66,939   

17,818   
11,306   
4,391   
987   
688   
446   
36,321   
20,182   
717   
4,003   
226   
9,359   
197   
782   
47   
808   

1,362   
13,652   
6,875   
37,410   
36,889   
—   
521   
12,827   
10,501   
2,326   
521,295   

181,159   
126,692   
38,879   
7,733   
1,876   
5,979   
300,142   
182,866   
10,654   
12,224   
3,662   
42,914   
7,426   
17,183   
6,338   
16,875   

376   

22,339   

152   
190   
34   
10,197   
8,511   
1,546   
140   
643   
618   
25   
65,355   

1,940   
13,132   
7,267   
62,774   
35,513   
26,594   
667   
12,480   
10,179   
2,301   
578,894   

Of which: 
real estate1
$m
(370)   
(329)   
(36)   
—   
—   
(5)   
(2,197)   
(1,966)   
(1)   
(22)   
(1)   
(167)   
(15)   
(12)   
—   
(13)   

(158)   

(5)   
(152)   
(1)   
(102)   
(94)   
—   
(8)   
(24)   
(24)   
—   
(2,851)   

(546)   
(489)   
(47)   
—   
—   
(10)   
(731)   
(624)   
(3)   
(29)   
(2)   
(41)   
(21)   
(5)   
—   
(6)   

(158)   

(7)   
(149)   
(2)   
(87)   
(64)   
(15)   
(8)   
(122)   
(122)   
—   
(1,644)   

Non-bank 
financial 
institutions

$m
(139)   
(130)   
(4)   
(3)   
—   
(2)   
(77)   
(36)   
—   
(10)   
—   
(30)   
—   
(1)   
—   
—   

(3)   

(1)   
—   
(2)   
(37)   
(26)   
—   
(11)   
(1)   
(1)   
—   
(257)   

(41)   
(32)   
(2)   
(3)   
—   
(4)   
(44)   
(7)   
—   
(8)   
(1)   
(28)   
—   
—   
—   
—   

(3)   

—   
—   
(3)   
(18)   
(1)   
(6)   
(11)   
(4)   
(4)   
—   
(110)   

Total

$m
(2,515) 
(1,652) 
(626) 
(157) 
(8) 
(72) 
(4,438) 
(3,037) 
(97) 
(90) 
(187) 
(358) 
(133) 
(389) 
(1) 
(146) 

(986) 

(118) 
(673) 
(195) 
(267) 
(240) 
— 
(27) 
(375) 
(336) 
(39) 
(8,581) 

(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) 
(8,314) 

$m
(2,376)   
(1,522)   
(622)   
(154)   
(8)   
(70)   
(4,361)   
(3,001)   
(97)   
(80)   
(187)   
(328)   
(133)   
(388)   
(1)   
(146)   

(983)   

(117)   
(673)   
(193)   
(230)   
(214)   
—   
(16)   
(374)   
(335)   
(39)   
(8,324)   

(2,770)   
(1,855)   
(654)   
(120)   
(8)   
(133)   
(3,297)   
(1,585)   
(108)   
(84)   
(246)   
(198)   
(172)   
(792)   
—   
(112)   

(1,207)   

(161)   
(811)   
(235)   
(427)   
(207)   
(198)   
(22)   
(503)   
(452)   
(51)   
(8,204)   

1  Real estate lending within this disclosure corresponds solely to the industry of the borrower. Commercial real estate on page 177 includes borrowers 

in multiple industries investing in income-producing assets and to a lesser extent, their construction and development.

2  Classified as held for sale at 31 December 2022.

196

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Personal lending – loans and advances to customers at amortised cost by country/territory

Gross carrying amount

Allowance for ECL

Europe
–  UK 
–  France1
–  Germany
–  Switzerland
–  other
Asia
–  Hong Kong
–  Australia
–  India
–  Indonesia
–  mainland China
–  Malaysia
–  Singapore
–  Taiwan
–  other
Middle East and North Africa (excluding 
Saudi Arabia)
–  Egypt
–  UAE
–  other
North America
–  US
–  Canada2
–  other
Latin America
–  Mexico
–  other
At 31 Dec 2022

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

First lien 
residential 
mortgages
$m
159,063   
154,519   
30   
—   
1,378   
3,136   
151,058   
101,478   
21,372   
1,078   
70   
9,305   
2,292   
7,501   
5,428   
2,534   

Other 
personal

$m
23,830   
16,794   
76   
234   
5,094   
1,632   
44,610   
31,539   
456   
590   
278   
921   
2,437   
6,264   
1,189   
936   

Of which: 
credit 
cards
$m
6,665   
6,622   
9   
—   
—   
34   
11,805   
8,645   
396   
162   
141   
378   
843   
422   
284   
534   

First lien 
residential 
mortgages
$m
(265)   
(226)   
(14)   
—   
—   
(25)   
(50)   
(1)   
(11)   
(4)   
(1)   
(3)   
(27)   
—   
—   
(3)   

Total

$m
182,893   
171,313   
106   
234   
6,472   
4,768   
195,668   
133,017   
21,828   
1,668   
348   
10,226   
4,729   
13,765   
6,617   
3,470   

2,450   

3,266   

735   

5,716   

—   
2,104   
346   
17,907   
16,847   
—   
1,060   
6,343   
6,124   
219   
336,821   

170,818   
163,549   
3,124   
—   
1,367   
2,778   
149,709   
98,019   
21,149   
981   
76   
10,525   
2,532   
7,811   
5,672   
2,944   

310   
1,340   
1,616   
866   
704   
—   
162   
5,619   
4,894   
725   
78,191   

49,253   
19,154   
22,908   
282   
6,615   
294   
46,781   
32,996   
504   
543   
272   
1,103   
2,657   
6,649   
1,188   
869   

83   
426   
226   
256   
213   
—   
43   
1,927   
1,615   
312   
21,388   

8,624   
8,213   
366   
—   
—   
45   
11,413   
8,154   
427   
181   
147   
563   
791   
367   
271   
512   

310   
3,444   
1,962   
18,773   
17,551   
—   
1,222   
11,962   
11,018   
944   
415,012   

220,071   
182,703   
26,032   
282   
7,982   
3,072   
196,490   
131,015   
21,653   
1,524   
348   
11,628   
5,189   
14,460   
6,860   
3,813   

2,262   

3,157   

761   

5,419   

—   
1,924   
338   
43,529   
16,642   
25,773   
1,114   
5,050   
4,882   
168   
371,368   

368   
1,232   
1,557   
3,091   
799   
2,123   
169   
4,687   
4,006   
681   
106,969   

98   
417   
246   
555   
232   
284   
39   
1,505   
1,172   
333   
22,858   

368   
3,156   
1,895   
46,620   
17,441   
27,896   
1,283   
9,737   
8,888   
849   
478,337   

(22)   

—   
(14)   
(8)   
(91)   
(10)   
—   
(81)   
(146)   
(145)   
(1)   
(574)   

(329)   
(223)   
(38)   
—   
—   
(68)   
(59)   
(1)   
(5)   
(10)   
(1)   
(4)   
(33)   
—   
—   
(5)   

(26)   

—   
(18)   
(8)   
(141)   
(12)   
(33)   
(96)   
(120)   
(119)   
(1)   
(675)   

Other 
personal

$m
(874)   
(837)   
(8)   
—   
(22)   
(7)   
(640)   
(352)   
(19)   
(18)   
(17)   
(62)   
(93)   
(36)   
(18)   
(25)   

(123)   

(2)   
(83)   
(38)   
(35)   
(30)   
—   
(5)   
(626)   
(593)   
(33)   
(2,298)   

(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)   
(2,428)   

Of which: 
credit 
cards
$m
(451)   
(449)   
—   
—   
—   
(2)   
(423)   
(258)   
(18)   
(13)   
(12)   
(49)   
(31)   
(14)   
(5)   
(23)   

(52)   

(1)   
(41)   
(10)   
(24)   
(23)   
—   
(1)   
(212)   
(196)   
(16)   
(1,162)   

(437)   
(434)   
(3)   
—   
—   
—   
(428)   
(217)   
(32)   
(20)   
(14)   
(66)   
(34)   
(13)   
(5)   
(27)   

(60)   

(1)   
(39)   
(20)   
(47)   
(36)   
(8)   
(3)   
(163)   
(148)   
(15)   
(1,135)   

Total

$m
(1,139) 
(1,063) 
(22) 
— 
(22) 
(32) 
(690) 
(353) 
(30) 
(22) 
(18) 
(65) 
(120) 
(36) 
(18) 
(28) 

(145) 

(2) 
(97) 
(46) 
(126) 
(40) 
— 
(86) 
(772) 
(738) 
(34) 
(2,872) 

(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) 
(3,103) 

1 

Included in other personal lending at 31 December 2022 is nil (31 December 2021: $19,972m) guaranteed by Crédit Logement as our retail banking 
business in France has been classified as held for sale.

2  Classified as held for sale at 31 December 2022.

HSBC Holdings plc Annual Report and Accounts 2022

197

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Summary of financial instruments to which the impairment requirements in IFRS 9 are applied – by global business

Loans and advances to customers at amortised cost
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Loans and advances to banks at amortised cost
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Other financial assets measured at amortised cost
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Total gross carrying amount on-balance sheet at 
31 Dec 2022
Loans and other credit-related commitments
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Financial guarantees
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Total nominal amount off-balance sheet at 
31 Dec 2022

Gross carrying/nominal amount

Allowance for ECL

Stage 1 Stage 2 Stage 3

POCI

Total Stage 1 Stage 2 Stage 3

POCI

Total

$m

$m

$m

325   
  103,042   
26,111   
23,735   
47,128   
6,068   

  777,543    139,130    19,505   
  373,889    49,096   
3,502   
  232,296    69,784    12,794   
3,209   
  171,033    20,207   
—   
43   
82   
1,827   
—   
377   
4   
257   
78   
1,050   
—   
143   
797   
  996,489    17,166   
458   
  248,708   
5,644   
253   
  184,459    10,883   
78   
637   
  486,224   
8   
2   
77,098   

$m

$m
129    936,307   
—    426,487   
112    314,986   
17    194,466   
368   
—   
—    104,951   
26,488   
—   
23,996   
—   
48,256   
—   
6,211   
—   
46    1,014,498   
46    254,856   
—    195,595   
—    486,939   
77,108   
—   

$m
(1,095)   
(572)   
(435)   
(88)   
—   
(18)   
(3)   
(5)   
(9)   
(1)   
(124)   
(57)   
(37)   
(28)   
(2)   

$m
(3,491)   
(1,512)   
(1,529)   
(437)   
(13)   
(29)   
(1)   
—   
(28)   
—   
(188)   
(96)   
(84)   
(8)   
—   

$m
(6,829)   
(850)   
(4,891)   
(1,088)   
—   
(22)   
—   
(2)   
(20)   
—   
(234)   
(130)   
(91)   
(13)   
—   

$m

$m
(38)    (11,453) 
(2,934) 
—   
(6,893) 
(38)   
(1,613) 
—   
(13) 
—   
(69) 
—   
(4) 
—   
(7) 
—   
(57) 
—   
(1) 
—   
(553) 
(7)   
(290) 
(7)   
(212) 
—   
(49) 
—   
(2) 
—   

 1,877,074    158,123    20,384   

175    2,055,756   

(1,237)   

(3,708)   

(7,085)   

(45)    (12,075) 

  583,383    34,033   
  238,161   
4,377   
  121,909    18,376   
  223,065    11,279   
1   
2,463   
11   
1,524   
928   
—   

248   
16,071   
1,196   
6,665   
8,210   
—   

1,372   
769   
512   
91   
—   
249   
1   
128   
120   
—   

—    618,788   
—    243,307   
—    140,797   
—    234,435   
249   
—   
18,783   
—   
1,208   
—   
8,317   
—   
9,258   
—   
—   
—   

(141)   
(25)   
(78)   
(38)   
—   
(6)   
—   
(5)   
(1)   
—   

(180)   
(1)   
(128)   
(51)   
—   
(13)   
—   
(8)   
(5)   
—   

(65)   
—   
(55)   
(10)   
—   
(33)   
—   
(26)   
(7)   
—   

—   
—   
—   
—   
—   
—   
—   
—   
—   
—   

(386) 
(26) 
(261) 
(99) 
— 
(52) 
— 
(39) 
(13) 
— 

  599,454    36,496   

1,621   

—    637,571   

(147)   

(193)   

(98)   

—   

(438) 

WPB
CMB
GBM
Corporate Centre
Debt instruments measured at FVOCI at 
31 Dec 2022

  113,557   
70,728   
75,951   
3,347   

1,213   
736   
434   
299   

—   
—   
—   
—   

33    114,803   
71,468   
76,386   
3,646   

4   
1   
—   

(18)   
(9)   
(11)   
(31)   

(26)   
(15)   
(8)   
(19)   

—   
—   
—   
(1)   

(6)   
(1)   
—   
—   

(50) 
(25) 
(19) 
(51) 

  263,583   

2,682   

—   

38    266,303   

(69)   

(68)   

(1)   

(7)   

(145) 

198

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Summary of financial instruments to which the impairment requirements in IFRS 9 are applied – by global business (continued)

Loans and advances to customers at amortised cost
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Loans and advances to banks at amortised cost
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Other financial assets measured at amortised cost
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Total gross carrying amount on-balance sheet at 
31 Dec 2021
Loans and other credit-related commitments
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Financial guarantees
–  WPB
–  CMB
–  GBM
–  Corporate Centre
Total nominal amount off-balance sheet at 
31 Dec 2021

Allowance for ECL

$m

$m

Stage 1
$m

Stage 2 Stage 3
$m

Gross carrying/nominal amount
POCI
$m
274   1,057,231   
—    491,973   
245    356,022   
29    208,485   
—   
751   
—    83,153   
—    20,945   
—    15,621   
—    37,529   
—   
9,058   
43    880,351   
43    208,960   
—    165,888   
—    411,074   
—    94,429   

  918,936    119,224    18,797   
17,285    5,211   
  469,477   
76,798    11,462   
  267,517   
25,085    2,124   
  181,247   
—   
695   
—   
81,636   
—   
20,464   
—   
15,269   
—   
36,875   
—   
9,028   
304   
  875,016   
175   
  207,335   
61   
  163,457   
62   
  409,808   
6   
94,416   

Total Stage 1 Stage 2 Stage 3
$m
(6,867)   
(1,276)   
(4,904)   
(687)   
—   
—   
—   
—   
—   
—   
(42)   
(14)   
(20)   
(8)   
—   

$m
(3,119)   
(1,247)   
(1,369)   
(493)   
(10)   
(3)   
(1)   
—   
(2)   
—   
(54)   
(44)   
(8)   
(2)   
—   

$m
(1,367)   
(664)   
(571)   
(132)   
—   
(14)   
(1)   
(1)   
(10)   
(2)   
(91)   
(51)   
(12)   
(28)   
—   

56   
1,517   
481   
352   
654   
30   
4,988   
1,407   
2,370   
1,204   
7   

Total
$m

POCI
$m
(64)    (11,417) 
(3,187) 
—   
(6,897) 
(53)   
(1,323) 
(11)   
(10) 
—   
(17) 
—   
(2) 
—   
(1) 
—   
(12) 
—   
(2) 
—   
(193) 
(6)   
(115) 
(6)   
(40) 
—   
(38) 
—   
— 
—   

 1,875,588    125,729    19,101   

317   2,020,735   

(1,472)   

(3,176)   

(6,909)   

(70)    (11,627) 

  594,473   
  235,722   
  126,728   
  231,890   
133   
24,932   
1,295   
6,105   
17,531   
1   

32,389   
2,111   
17,490   
12,788   
—   
2,638   
15   
1,606   
1,017   
—   

775   
153   
555   
67   
—   
225   
1   
126   
98   
—   

—    627,637   
—    237,986   
—    144,773   
—    244,745   
—   
133   
—    27,795   
1,311   
—   
—   
7,837   
—    18,646   
1   
—   

(165)   
(37)   
(80)   
(48)   
—   
(11)   
—   
(7)   
(4)   
—   

(174)   
(3)   
(118)   
(53)   
—   
(30)   
(1)   
(16)   
(13)   
—   

(40)   
—   
(37)   
(3)   
—   
(21)   
—   
(17)   
(4)   
—   

—   
—   
—   
—   
—   
—   
—   
—   
—   
—   

(379) 
(40) 
(235) 
(104) 
— 
(62) 
(1) 
(40) 
(21) 
— 

  619,405   

35,027    1,000   

—    655,432   

(176)   

(204)   

(61)   

—   

(441) 

WPB
CMB
GBM
Corporate Centre
Debt instruments measured at FVOCI at 
31 Dec 2021

  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 2022

199

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Loans and advances to customers and banks metrics

Gross 
carrying 
amount

of which: 
stage 3 
and POCI

Allowance 
for ECL

of which: 
stage 3 
and POCI

Change in 

ECL Write-offs

Recoveries

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
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 2022

$m
336,821   
379   
1,367   
32,106   
21,388   
21,010   
1,941   
78,191   
415,012   
6,571   
8,194   
87,503   
17,082   

2,993   

13,232   

82,437   

24,845   
17,185   
18,423   
101,434   
17,935   
25,077   

$m
2,043   
6   
125   
206   
260   
687   
13   
1,297   
3,340   
261   
233   
2,065   
277   

26   

798   

2,810   

556   
789   
277   
4,853   
542   
980   

$m
(574)   
(6)   
(34)   
(55)   
(1,162)   
(1,010)   
(31)   
(2,298)   
(2,872)   
(122)   
(172)   
(1,153)   
(109)   

(21)   

(443)   

(1,666)   

(249)   
(244)   
(117)   
(2,851)   
(272)   
(408)   

1,180   

—   

(1)   

1,614   
3,964   
1,862   
12,527   
744   
47   
9,475   
32   
454,356   
66,939   
521,295   
936,307   
104,951   
  1,041,258   

87   
266   
146   
589   
—   
—   
270   
—   
15,825   
469   
16,294   
19,634   
82   
19,716   

(31)   
(90)   
(77)   
(275)   
—   
—   
(10)   
(13)   
(8,324)   
(257)   
(8,581)   
(11,453)   
(69)   
(11,522)   

$m
(270)   
(3)   
(30)   
(30)   
(160)   
(305)   
(7)   
(535)   
(805)   
(68)   
(146)   
(896)   
(67)   

(13)   

(371)   

(1,344)   

(153)   
(82)   
(59)   
(1,861)   
(200)   
(293)   

—   

(22)   
(67)   
(57)   
(219)   
—   
—   
(7)   
—   
(5,925)   
(137)   
(6,062)   
(6,867)   
(22)   
(6,889)   

$m
180   
9   
(11)   
(16)   
(638)   
(655)   
39   
(1,272)   
(1,092)   
(32)   
(24)   
(191)   
(75)   

3   

(93)   

(344)   

(13)   
103   
9   
(1,537)   
(81)   
(27)   

5   

1   
(30)   
1   
120   
—   
1   
(5)   
(4)   
(2,213)   
(165)   
(2,378)   
(3,470)   
(53)   
(3,523)   

$m
(48)   
(1)   
(9)   
(8)   
(471)   
(660)   
(18)   
(1,167)   
(1,215)   
(42)   
(46)   
(171)   
(16)   

(1)   

(136)   

(667)   

(82)   
(29)   
(47)   
(174)   
(31)   
(27)   

—   

(3)   
(7)   
(17)   
(92)   
—   
—   
—   
—   
(1,588)   
(1)   
(1,589)   
(2,804)   
—   
(2,804)   

$m
26 
4 
2 
1 
126 
119 
5 
257 
283 
— 
— 
3 
— 

— 

6 

8 

1 
— 
1 
2 
1 
1 

— 

— 
1 
— 
7 
— 
1 
— 
— 
32 
1 
33 
316 
— 
316 

200

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Loans and advances to customers and banks metrics (continued)

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
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

Change in 

ECL Write-offs Recoveries

$m
371,368   
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   

94,944   

29,592   
23,376   
18,471   
121,260   
19,685   
28,675   

$m
3,045   
37   
236   
366   
338   
915   
5   
1,897   
4,942   
363   
463   
2,107   
78   

51   

843   

3,005   

667   
1,200   
250   
2,473   
637   
749   

$m
(675)   
(14)   
(58)   
(156)   
(1,135)   
(1,039)   
(26)   
(2,428)   
(3,103)   
(138)   
(227)   
(1,248)   
(68)   

(29)   

(508)   

(2,107)   

(363)   
(423)   
(184)   
(1,644)   
(238)   
(431)   

1,271   

—   

(8)   

1,793   
4,854   
2,598   
12,297   
977   
2   
7,612   
338   
513,539   
65,355   
578,894   
  1,057,231   
83,153   
  1,140,384   

65   
183   
152   
448   
—   
—   
—   
—   
13,734   
395   
14,129   
19,071   
—   
19,071   

(37)   
(72)   
(92)   
(373)   
—   
—   
(4)   
(10)   
(8,204)   
(110)   
(8,314)   
(11,417)   
(17)   
(11,434)   

$m
(416)   
(9)   
(42)   
(120)   
(214)   
(421)   
(4)   
(810)   
(1,226)   
(105)   
(171)   
(962)   
(31)   

(20)   

(440)   

(1,937)   

(191)   
(111)   
(100)   
(775)   
(172)   
(307)   

—   

(18)   
(37)   
(42)   
(246)   
—   
—   
—   
—   
(5,665)   
(40)   
(5,705)   
(6,931)   
—   
(6,931)   

$m

—   
12   
(5)   
(11)   
172   
135   
(22)   
281   
281   
61   
72   
102   
5   

3   

(13)   

163   

100   
12   
(12)   
(674)   
97   
48   

6   

1   
44   
27   
(59)   
—   
1   
(6)   
3   
(19)   
129   
110   
391   
22   
413   

$m
(70)   
(1)   
(8)   
(11)   
(751)   
(659)   
(20)   
(1,450)   
(1,520)   
(5)   
(57)   
(222)   
—   

(7)   

(94)   

(238)   

(10)   
(17)   
(4)   
(152)   
(39)   
(37)   

—   

(1)   
(69)   
(26)   
(109)   
—   
—   
—   
—   
(1,087)   
(5)   
(1,092)   
(2,612)   
—   
(2,612)   

$m
31 
6 
2 
1 
153 
156 
6 
324 
355 
— 
(1) 
7 
— 

— 

9 

15 

2 
6 
1 
5 
1 
— 

1 

— 
1 
— 
6 
— 
1 
— 
— 
54 
— 
54 
409 
— 
409 

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 332); 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 33).

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 $3.1bn at 
31 December 2022 (2021: $1.6bn).

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 (2021: 100%). For further details of 
credit quality classification, see page 146. 

HSBC Holdings plc Annual Report and Accounts 2022

201

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Treasury risk

Contents

202

202

204

205

209

212

213

Overview

Treasury risk management

Other Group risks

Capital risk in 2022

Liquidity and funding risk in 2022

Structural foreign exchange risk in 2022

Interest rate risk in the banking book in 2022

Overview
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 or transactional foreign exchange exposures 
and changes in market interest rates, together with pension and 
insurance risk.

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. The 
risk management framework incorporates a number of measures 
aligned to our assessment of risks for both internal and regulatory 
purposes. These risks include credit, market, operational, pensions, 
structural and transactional foreign exchange risk, and interest rate 
risk in the banking book.

For further details, refer to our Pillar 3 Disclosures at 31 December 
2022.
Treasury risk management
Key developments in 2022

• All of the Group’s material operating entities were above 

regulatory minimum levels of capital, liquidity and funding at 
31 December 2022. 

• Our CET1 position decreased from 15.8% at 31 December 2021 to 
14.2% at 31 December 2022. This included a 0.8 percentage point 
impact from new regulatory requirements and a 0.7 percentage 
point decrease from the fall in the fair value of securities.

• The Board approved a new interest rate risk in the banking book 
(‘IRRBB’) strategy in September, with the objective of increasing 
our stabilisation of net interest income (‘NII’), with consideration 
given to any capital or other constraints, and then adopting a 
managed approach based on interest rates and outlook.

• We took steps to reduce the duration risk of the Global Treasury 
hold-to-collect-and-sell portfolio, which is accounted for at fair 
value through other comprehensive income (‘FVOCI‘), primarily to 
dampen the capital impact from rising interest rates. This risk 
reduction lowered the hold-to-collect-and-sell stressed value at risk 
(‘VaR’) exposure of this portfolio from $3.63bn at the end of 2021 
to $2.15bn at the end of 2022. For further details of the calculation 

202

HSBC Holdings plc Annual Report and Accounts 2022

of this exposure and the use of this metric in our interest rate risk 
management framework, see page 215.

• We implemented a new hold-to-collect business model to better 
reflect our management strategy to stabilise NII. This portfolio of 
high-quality liquid assets will form a material part of our liquid 
asset buffer going forward, as well as being a hedge to our 
structural interest rate risk.

• We enhanced monitoring and forecasting as a result of the Russia-
Ukraine war, although there were no direct material capital or 
liquidity impacts.

• The HBUK section of the HSBC Bank (UK) Pension Scheme’s 

trustee funding level remained stable during the volatility in the UK 
gilt markets in September and October, as a result of its proactive 
pension scheme management, low-risk investment strategy and 
limited leverage in its liability-driven investment funds. 
Refinements relating to the scheme‘s inflation hedging strategy 
ensured continued effectiveness in the high-inflation environment.

• HSBC Overseas Holdings (UK) Limited entered into an agreement 
to sell its banking business in Canada to Royal Bank of Canada, 
subject to regulatory and governmental approvals. The transaction 
is expected to complete in late 2023. As a consequence of the 
gain on the sale and disposal of risk-weighted assets (‘RWAs‘) 
from our banking business in Canada, we expect an increase of 
approximately 1.3 percentage points in CET1 capital before any 
distribution. In addition, the hedging activity in respect to this 
transaction reduced the full-year 2022 ratio by 0.06 percentage 
point. This impact will revert on completion of sale.

• HSBC Continental Europe signed a framework agreement with 
Promontoria MMB SAS (‘My Money Group’) and its subsidiary 
Banque des Caraïbes SA for the sale of its retail banking business 
in France. The sale, which is subject to regulatory and 
governmental approvals, is anticipated to complete in the second 
half of 2023. The impact of classifying the disposal as held for sale 
resulted in a 0.3 percentage point reduction in the Group‘s CET1 
ratio, which will be partly offset by the reduction in RWAs upon 
closing.

• We identified an error in the RWA calculations of the European 

resolution group whereby $35bn of non-capital MREL instruments 
issued by the Asian and US resolution groups and held by the 
European resolution group were excluded from these calculations 
and were only deducted from MREL, whereas the relevant UK 
legislation requires these instruments to be both risk-weighted and 
deducted from MREL. In rectifying this error, we changed our 
treatment of $35bn of non-capital MREL investments held by the 
European resolution group from entities outside its group to 
deduct them from the European resolution group’s own funds 
rather than from solely its MREL, allowing us to exclude them 
from RWAs. The change in treatment significantly reduced the 
European resolution group’s total capital and increased its leverage 
ratio at 31 December 2022, although the European resolution 
group has no capital requirements. For further details regarding 
MREL, see ‘Assessment and risk appetite’ on page 203.

• We performed our inaugural resolvability self-assessment to meet 
the Bank of England requirements, which came into effect on 
1 January 2022. This was incorporated into the Bank of England’s 
publication of its findings on its first assessment of the 
resolvability of the eight major UK firms, as part of the 
Resolvability Assessment Framework.

For quantitative disclosures on capital ratios, own funds and RWAs, 
see pages 205 to 207. For quantitative disclosures on liquidity and 
funding metrics, see pages 209 to 210. For quantitative disclosures 
on interest rate risk in the banking book, see pages 213 to 215.

 
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 and insurance risk. The Group Treasurer co-
owns pension risk with the Group Head of Performance, Reward and 
Employee Relations. Insurance risk is owned by the Chief Executive 
Officer for Global Insurance.

Capital risk, liquidity risk, interest rate risk in the banking book, 
structural foreign exchange risk and transactional foreign exchange 
risk are the responsibility of the Group Executive Committee and the 
Group Risk Committee (‘GRC’). Global Treasury 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 Risk Management Meetings.

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. Insurance risk 
is overseen by the Global Insurance Risk Management Meeting, 
chaired by the Chief Risk Officer for Global Insurance.
Capital, liquidity and funding risk 
management processes

Assessment and risk appetite

Our capital management policy is supported by a global capital 
management framework. The framework sets out our approach to 
determining key capital risk appetites including CET1, total capital, 
minimum requirements for own funds and eligible liabilities (‘MREL’), 
the leverage ratio and double leverage. Our internal capital adequacy 
assessment process (‘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. 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. MREL includes own funds 
and liabilities that can be written down or converted into capital 
resources in order to absorb losses or recapitalise a bank in the event 
of its failure. In line with our existing structure and business model, 
HSBC has three resolution groups – the European resolution group, 
the Asian resolution group and the US resolution group. There are 
some smaller entities that fall outside these resolution groups.

HSBC Holdings seeks to maintain a prudent balance between the 
composition of its capital and its investments in subsidiaries. 

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 2022 was in excess of $24bn. 

We aim to ensure that management has oversight of our liquidity and 
funding risks at Group and entity level through robust governance, in 
line with our risk management framework. We manage liquidity and 
funding risk at an operating entity level in accordance with globally 
consistent policies, procedures and reporting standards. This ensures 
that obligations can be met in a timely manner, in the jurisdiction 
where they fall due.

Operating entities are required to meet internal minimum 
requirements and any applicable regulatory requirements at all times. 

These requirements are assessed through our internal liquidity 
adequacy assessment process (‘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.

Planning and performance

Capital and 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 also form part of the financial resource 
plan that is approved by the Board. The Board-level appetite measures 
are the liquidity coverage ratio (‘LCR’) and net stable funding ratio 
(‘NSFR’), together with an internal liquidity metric. 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, particularly those related to the UK’s implementation of 
the outstanding measures to be implemented from the Basel III 
reforms (‘Basel 3.1‘). 

Regulatory developments

Our capital adequacy ratios were affected by regulatory developments 
in 2022, including changes to internal-ratings based (’IRB’) modelling 
requirements and the UK’s implementation of the revisions to the 
Capital Requirements Regulation and Directive (’CRR II’). The PRA’s 
final rules on NSFR were implemented and have been reflected in 
disclosures since the first quarter of 2022. 

Future changes to our ratios will occur with the implementation of 
Basel 3.1. The PRA has published its consultation paper on the UK’s 
implementation, with a proposed implementation date of 1 January 
2025. We currently do not foresee a material net impact on our ratios 
from the initial implementation. The RWA output floor under Basel 3.1 
is proposed to 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. We are progressing with a 
comprehensive programme to strengthen our processes, improve 
consistency and enhance controls across our prudential regulatory 
reporting, focusing on PRA requirements initially. We commissioned a 
number of independent external reviews, some at the request of our 
regulators, including one on our credit risk RWA reporting process, 
which concluded in December 2022. These reviews have so far 

HSBC Holdings plc Annual Report and Accounts 2022

203

Risk reviewRisk review

resulted in enhancements to our RWAs and the LCR through 
improvements in reporting accuracy, which have been reflected in our 
year-end regulatory reported ratios. Our prudential regulatory 
reporting programme is being phased over a number of years, 
prioritising RWA, capital and liquidity reporting in the early stages of 
the programme. While this programme continues, there may be 
further impacts on some of our regulatory ratios, such as the CET1, 
LCR and NSFR, as we implement recommended changes and 
continue to enhance our controls across the process.

Stress testing and recovery and resolution planning

The Group uses stress testing to inform management of the capital 
and liquidity needed to withstand internal and external shocks, 
including a global economic downturn or a systems failure. Stress 
testing results are also used to inform risk mitigation actions, 
allocation of financial resources, and recovery and resolution planning, 
as well as 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. The results of regulatory stress 
testing and our internal stress tests are used when assessing our 
internal capital and liquidity requirements through the ICAAP and 
ILAAP. The outcomes of stress testing exercises carried out by the 
PRA and other regulators feed into the setting of regulatory minimum 
ratios and buffers.

We maintain recovery plans for the Group and material entities, 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. 
The Group recovery plan sets out the framework and governance 
arrangements to support restoring HSBC to a stable and viable 
position, and so lowering the probability of failure from either 
idiosyncratic company-specific stress or systemic market-wide issues. 
Our material entities’ recovery plans provide 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 HSBC entities 
can stabilise their financial position and recover from financial losses 
in a stress environment.

The Group also has capabilities, resources and arrangements in place 
to address the unlikely event that HSBC might not be recoverable and 
would therefore need to be resolved by regulators. The Group 
performed the inaugural Resolvability Assessment Framework self-
assessment during 2021 to meet the Bank of England’s 
requirements, which came into effect on 1 January 2022.

Overall, HSBC’s recovery and resolution planning helps safeguard the 
Group’s financial and operational stability. The Group is committed to 
further developing its recovery and resolution capabilities, including in 
relation to the Bank of England’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 Global 
Treasury. Hedging is generally executed through interest rate 
derivatives or fixed-rate government bonds. Any interest rate risk that 
Global Treasury cannot economically hedge is not transferred and will 
remain within the global business where the risks originate.

Global Treasury 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.

204

HSBC Holdings plc Annual Report and Accounts 2022

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, 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, except for certain mortgage products where balances are 
impacted by interest-rate sensitive prepayments. These sensitivity 
calculations do not incorporate actions that would be taken by Global 
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 2022.

Other Group risks
Non-trading book foreign exchange 
exposures

Structural foreign exchange exposures

Structural foreign exchange exposures arise from net assets or capital 
investments in foreign operations, together with any associated 
hedging. A foreign operation is defined as a subsidiary, associate, joint 
arrangement or branch where the activities are conducted in a 
currency other than that of the reporting entity. An entity’s functional 
reporting 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 foreign operations.

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 
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 212.

  
Transactional foreign exchange exposures

Transactional foreign exchange risk arises primarily from day-to-day 
transactions in the banking book generating profit and loss or fair 
value through other comprehensive income (‘FVOCI’) 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 Global Treasury within agreed appetite.
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. It also uses forward foreign 
exchange contracts to manage its structural foreign exchange 
exposures.

For quantitative disclosures on interest rate risk in the banking book, 
see pages 213 to 215.
Pension risk management processes

Our global pensions strategy is to move from defined benefit to 
defined contribution plans, where local law allows and it is considered 
competitive to do so.

In defined contribution pension plans, the contributions that HSBC is 
required to make are known, while the ultimate pension benefit will 
vary, typically with investment returns achieved by investment 
choices made by the employee. While the market risk to HSBC of 
defined contribution plans is low, the Group is still exposed to 
operational and reputational risk.

In defined benefit pension plans, the level of pension benefit is 
known. Therefore, the level of contributions required by HSBC will 
vary due to a number of risks, including:

• investments delivering a return below that required to provide the 

projected plan benefits;

• the prevailing economic environment leading to corporate failures, 
thus triggering write-downs in asset values (both equity and debt);

• a change in either interest rates or inflation expectations, causing 

an increase in the value of plan liabilities; and

• plan members living longer than expected (known as longevity 

risk).

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, including 
the review of de-risking opportunities. 

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.
Capital risk in 2022
Capital overview

Capital adequacy metrics

At

31 Dec
2022

31 Dec
2021

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 ($bn)
Common equity tier 1 (‘CET1’) capital
Tier 1 capital
Total capital
Capital ratios on an end point basis (%)
Common equity tier 1 ratio
Tier 1 ratio
Total capital ratio
Liquidity coverage ratio (‘LCR’)1
Total high-quality liquid assets ($bn)
Total net cash outflow ($bn)
LCR ratio (%)
Net stable funding ratio (‘NSFR’)1
Total available stable funding ($bn)
Total required stable funding ($bn)
NSFR ratio (%)

679.1   
37.1   
37.6   
85.9   
839.7   

119.3   
139.1   
162.4   

 14.2 
 16.6 
 19.3 

119.3   
139.1   
157.2   

 14.2 
 16.6 
 18.7 

647.0
490.8
 131.8 

1,552.0
1,138.4
 136.3 

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 

688.2
495.1
 139.0 

N/A
N/A
N/A

1   The LCR and NSFR ratios presented in the above table are based on 
average value. The LCR is the average of the preceding 12 months. 
The NSFR is the average of the preceding four quarters. The prior 
periods for LCR have been restated for consistency. We have not 
restated the prior periods for NSFR as no comparatives are available.

HSBC Holdings plc Annual Report and Accounts 2022

205

Risk review 
 
 
 
 
 
 
 
 
 
 
Risk review

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.

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 2022, our common equity tier 1 (‘CET1’) capital ratio 
decreased to 14.2% from 15.8% at 31 December 2021. This primarily 
reflected a decrease of $13.3bn in our CET1 capital. The key drivers of 
the fall in our CET1 ratio were:

• a 0.8 percentage point impact from new regulatory requirements, 

which reduced CET1 capital by $3.5bn and increased risk-weighted 
assets (‘RWAs’) by $27.1bn at implementation;

• a 0.7 percentage point decrease from a $5.6bn fall in the fair value 

through other comprehensive income (‘FVOCI’);

• a 0.4 percentage point impact from RWA growth, offset by 

favourable foreign currency translations; and

• a 0.3 percentage point impact from the $2.0bn impairment on the 
reclassification of our French retail operations to held for sale.

Profits and other movements added $4.4bn to CET1 capital and a 
0.7 percentage point to the CET1 ratio. This included capital 
deductions for deferred tax, dividends and the share buy-back.

Our Pillar 2A requirement at 31 December 2022, as per the PRA’s 
Individual Capital Requirement based on a point-in-time assessment, 
was 2.6% of RWAs, of which 1.5% was required to be met by CET1. 
Structural foreign exchange risk is now capitalised in RWAs under 
Pillar 1 and assessed for Pillar 2A in the same manner as other risks.

Own funds disclosure

(Audited)

Ref*

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)1
Minority interests (amount allowed in consolidated CET1)
Independently reviewed net profits net of any foreseeable charge or dividend
Common equity tier 1 capital before regulatory adjustments2
Total regulatory adjustments to common equity tier2
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

1

2
3
5
5a
6
28
29
36
43
44
45
51
57
58
59

At

31 Dec
2022
$m

23,406   
23,406   
127,155   
4,105   
4,444   
8,633   
167,743   
(48,452)   
119,291   
19,836   
(60)   
19,776   
139,067   
24,779   
(1,423)   
23,356   
162,423   

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 
177,786 

*  The references identify lines prescribed in the Prudential Regulatory Authority (‘PRA’) template, which are applicable and where there is a value.

1    To comply with new disclosures guidance from the PRA, with effect from 1 January 2022 we report changes in ‘Retained earnings’ during 2022 
separately in ‘Accumulated other comprehensive income’. As this change has no impact on CET1 capital, we have not restated prior periods.

2   From 30 September 2022, investments in non-financial institution subsidiaries or participations have been measured on an equity accounting basis in 

compliance with UK regulatory requirements. This change increased ‘Common equity tier 1 capital before regulatory adjustments’ and ‘Total 
regulatory adjustments to common equity tier’ by $13.2bn, with no impact on CET1 capital as at 31 December 2022. As this change has immaterial 
impact on CET1 capital as at 31 December 2021, we have not restated the comparatives.

Throughout 2022, we complied with the PRA’s regulatory capital 
adequacy requirements, including those relating to stress testing. 

Regulatory and other developments

We expect the recently announced reduction of the Hong Kong 
Monetary Authority’s risk weight floor for residential mortgages from 
25% to 15% to improve our CET1 ratio by 0.1 percentage points with 
effect from 1 January 2023. This reduction will be partly offset by a 
change to the sourcing and risk-weighting of balances we 
proportionally consolidate for our associates.

During 2023, our CET1 ratio will continue to be affected by strategic 
decisions we have taken. 

Based on our capital position on 31 December 2022, we would 
expect that on completing the planned sale of our banking operations 
in Canada, branch operations in Greece, and our retail banking 
operations in France, we would improve our CET1 ratio by around 
1.4 percentage points, net of the impact from foreign exchange 
hedges related to the proceeds from the planned sale of our Canada 
business. The exact timing and impact on our capital position of these 
transactions may change as the balance sheets being disposed evolve 
in 2023.

206

HSBC Holdings plc Annual Report and Accounts 2022

        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk-weighted assets 

RWAs by global business

Credit risk
Counterparty credit risk
Market risk
Operational risk
At 31 Dec 2022

At 31 Dec 2021

RWAs by geographical region

Credit risk
Counterparty credit risk
Market risk1
Operational risk
At 31 Dec 2022

At 31 Dec 2021

WPB

$bn
149.3   
0.9   
1.6   
31.1   
182.9   

178.3   

CMB

$bn
307.4   
0.7   
1.1   
25.6   
334.8   

332.9   

GBM

$bn
146.2   
33.8   
23.6   
29.9   
233.5   

236.2   

Corporate 
Centre

$bn
76.2   
1.7   
11.3   
(0.7)   
88.5   

90.9   

Europe

$bn
180.3   
18.9   
28.2   
23.8   
251.2   

261.1   

Asia

$bn
330.2   
10.4   
28.6   
40.1   
409.3   

396.3   

MENA

North
America

Latin
America

$bn
49.8   
2.7   
2.6   
5.9   
61.0   

60.2   

$bn
87.4   
4.2   
4.2   
10.7   
106.5   

110.4   

$bn
31.4   
0.9   
1.2   
5.4   
38.9   

35.9   

Total

$bn
679.1 
37.1 
37.6 
85.9 
839.7 

838.3 

Total

$bn
679.1 
37.1 
37.6 
85.9 
839.7 

838.3 

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

Credit risk, counterparty credit risk and operational 
risk

Corporate 
Centre

Market
risk

Total
RWAs

RWAs at 1 Jan 2022
Asset size
Asset quality
Model updates
Methodology and policy
Acquisitions and disposals
Foreign exchange movements1
Total RWA movement
RWAs at 31 Dec 2022

WPB

$bn
176.6   
6.5   
1.6   
(3.1)   
11.6   
(2.0)   
(9.9)   
4.7   
181.3   

CMB

$bn
332.0   
13.7   
(1.1)   
1.0   
8.9   
—   
(20.8)   
1.7   
333.7   

GBM

$bn
215.9   
(3.5)   
3.4   
(0.7)   
4.7   
—   
(9.9)   
(6.0)   
209.9   

$bn
80.9   
(0.6)   
(0.8)   
(0.1)   
(0.9)   
—   
(1.3)   
(3.7)   
77.2   

$bn
32.9   
4.8   
—   
—   
(0.1)   
—   
—   
4.7   
37.6   

RWA movement by geographical region by key driver

Credit risk, counterparty credit risk and 
operational risk

Europe

Asia MENA

North
America

Latin

RWAs at 1 Jan 2022
Asset size
Asset quality
Model updates
Methodology and policy
Acquisitions and disposals
Foreign exchange movements1
Total RWA movement
RWAs at 31 Dec 2022

$bn
236.5   
1.5   
(2.6)   
(3.0)   
11.2   
—   
(20.6)   
(13.5)   
223.0   

$bn
371.0   
3.9   
7.1   
0.2   
10.5   
—   
(12.0)   
9.7   
380.7   

$bn
57.9   
3.6   
—   
0.1   
1.4   
(0.2)   
(4.4)   
0.5   
58.4   

America Market risk
$bn
32.9   
4.8   
—   
—   
(0.1)   
—   
—   
4.7   
37.6   

$bn
34.9   
5.2   
0.3   
—   
0.2   
—   
(2.9)   
2.8   
37.7   

$bn
105.1   
1.9   
(1.7)   
(0.2)   
1.0   
(1.8)   
(2.0)   
(2.8)   
102.3   

$bn
838.3 
20.9 
3.1 
(2.9) 
24.2 
(2.0) 
(41.9) 
1.4 
839.7 

Total
 RWAs

$bn
838.3 
20.9 
3.1 
(2.9) 
24.2 
(2.0) 
(41.9) 
1.4 
839.7 

1    Foreign exchange movements in this disclosure are computed by retranslating the RWAs into US dollars for non-US dollar branches, subsidiaries, joint 

ventures and associates.

Risk-weighted assets (‘RWAs’) rose by $1.4bn during the year. An 
increase of $43.3bn, driven by regulatory change and lending growth, 
was partly offset by a decrease of $41.9bn due to favourable foreign 
currency translation differences. At 31 December 2022, our 
cumulative RWA saves as part of our transformation programme 
were $128bn.

Asset size

The $20.9bn increase in RWAs due to asset size movement included 
an increase of $4.8bn in market risk RWAs, mostly attributable to 
heightened market risk volatility, and an increase in transactional and 
structural foreign exchange exposures. The $13.7bn increase in CMB 
RWAs reflected corporate loan growth in Europe, Asia and North 
America.

HSBC Holdings plc Annual Report and Accounts 2022

207

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

GBM RWAs fell by $3.5bn due to a reduction in counterparty credit 
risk of $2.8bn, driven by mark-to-market movements and 
management initiatives. Lower lending in Europe further reduced 
RWAs, which was partly offset by growth in Asia and Latin America.

WPB RWAs increased by $6.5bn, primarily due to lending growth in 
Asia and Latin America, largely in term lending and the mortgage 
portfolio.

Asset quality

The increase of $3.1bn RWAs was mostly driven by credit migration, 
primarily in Europe and Asia and partly offset against portfolio mix 
changes.

the introduction of a counterparty credit risk equity model in Europe. 
This was mostly offset by a $2.1bn increase in RWAs in GBM and 
CMB due to a commercial property loan model in Asia.

Methodology and policy

The $24.2bn increase in RWAs was driven by the regulatory changes 
of $27.1bn for revised IRB modelling requirements and the UK‘s 
implementation of the CRR II rules.

These increases were partly offset by reductions predominantly due 
to data enhancements driven by internal and external reviews of our 
regulatory reporting processes, and the reversal of the beneficial 
changes to the treatment of software assets in Corporate Centre.

Model updates

Acquisitions and disposals

The $3.1bn RWA decrease in WPB was mostly due to the 
implementation of a credit card model in Hong Kong and a retail 
model in France. A reduction of $1.6bn RWAs in GBM was driven by 
Leverage ratio1

The $2.0bn RWA decrease was mainly due to the $1.8bn sale of WPB 
retail branches in US.

Tier 1 capital
Total leverage ratio exposure

Leverage ratio

At
31 Dec
2022
$bn
139.1   
2,417.2   

%
 5.8 

31 Dec
2021
$bn
155.0 
2,962.7 
%
 5.2 

1  The CRR II regulatory transitional arrangements for IFRS 9 are applied in the leverage ratio calculation. This calculation is in line with the UK leverage 
rules that were implemented on 1 January 2022, and excludes central bank claims. Comparatives for 2021 are reported based on the disclosure rules 
in force at that time, and include claims on central banks.

Our leverage ratio was 5.8% at 31 December 2022, up from 5.2% at 
31 December 2021. The improvement was mainly due to the 
exclusion of central bank claims following the implementation of the 
UK leverage ratio framework from 1 January 2022, and foreign 
exchange translation movement. This was partly offset by a decline in 
tier 1 capital.

Any add-back must be tax affected and accompanied by a 
recalculation of deferred tax, 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 2022, our UK minimum leverage ratio requirement of 
3.25% was supplemented by a leverage ratio buffer of 0.8%, which 
consists of an additional leverage ratio buffer of 0.7% and a 
countercyclical leverage ratio buffer of 0.1%. These buffers translated 
into capital values of $16.9bn and $2.4bn 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 14.2%.

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 ‘Quick Fix’ relief package increased the 2022 scalar 
from 25% to 75% 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 
$0.4bn under the STD approach with a tax impact of $0.1bn. At 
31 December 2021, the add-back to the capital base under the STD 
approach was $1.0bn with a tax impact of $0.2bn. 
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 
2022 is published on our website at www.hsbc.com/investors.

208

HSBC Holdings plc Annual Report and Accounts 2022

 
 
Liquidity and funding risk in 2022
Liquidity metrics

At 31 December 2022, 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 ratio on a local regulatory requirements basis 
wherever applicable. Where local regulatory requirements are not 

Operating entities’ liquidity1

applicable, the PRA LCR is shown. The local basis may differ from 
PRA measures due to differences in the way regulators have 
implemented the Basel III standards. 

Each entity maintains a sufficient stable funding profile and is 
assessed using the NSFR or other appropriate metrics. 

In addition to regulatory metrics, we use a wide set of measures to 
manage our liquidity and funding profile. 

The Group liquidity and funding position on an average basis is 
analysed in the following sections.

At 31 December 2022

HSBC UK Bank plc (ring-fenced bank)2
HSBC Bank plc (non-ring-fenced bank)3,4
The Hongkong and Shanghai Banking Corporation – Hong Kong branch5
HSBC Singapore6
Hang Seng Bank
HSBC Bank China
HSBC Bank USA
HSBC Continental Europe 7,8
HSBC Bank Middle East Ltd – UAE branch
HSBC Canada7
HSBC Mexico

HSBC UK Bank plc (ring-fenced bank)2
HSBC Bank plc (non-ring-fenced bank)3,4
The Hongkong and Shanghai Banking Corporation – Hong Kong branch5
HSBC Singapore6
Hang Seng Bank
HSBC Bank China
HSBC Bank USA
HSBC Continental Europe7
HSBC Bank Middle East Ltd – UAE branch
HSBC Canada7
HSBC Mexico

%
226   
143   
179   
247   
228   
183   
164   
151   
239   
149   
155   

222   
142   
190   
277   
200   
155   
169   
142   
203   
154   
210   

LCR

HQLA

Net 
outflows

$bn

$bn
136   
128   
147   
21   
50   
23   
85   
55   
12   
22   
8   

At 31 December 2021

143   
118   
139   
19   
48   
23   
104   
56   
12   
25   
9   

NSFR

%
164 
115 
130 
173 
156 
132 
131 
132 
158 
122 
129 

176 
115 
136 
165 
145 
143 
145 
131 
154 
125 
138 

60   
90   
82   
9   
22   
13   
52   
37   
5   
15   
5   

64   
84   
74   
7   
24   
15   
62   
39   
6   
16   
4   

1 The LCR and NSFR ratios presented in the above table are based on average values. The LCR is the average of the preceding 12 months. The NSFR is 

the average of the preceding four quarters. Prior period numbers have been restated for consistency. 

2 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.

3 HSBC Bank plc includes overseas branches and special purpose entities consolidated by HSBC for financial statements purposes.
4 HSBC Bank plc implemented a strategic data enhancement that resulted in a reclassification of some securities. This reclassification drove a reduction 

in total HQLA and corresponding LCR as of 31 December 2022. Prior period numbers have been restated for consistency.

5 The Hongkong and Shanghai Banking Corporation – Hong Kong branch represents the material activities of The Hongkong and Shanghai Banking 

Corporation Limited. 

6 HSBC Singapore includes HSBC Bank Singapore Limited and The Hongkong and Shanghai Banking Corporation – Singapore branch. Liquidity and 
funding risk is monitored and controlled at country level in line with the local regulator’s approval. Prior period numbers have been restated for 
consistency.

7 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.

8 In response to the requirement for an intermediate parent undertaking in line with EU Capital Requirements Directive (’CRD V’), HSBC Continental 

Europe acquired control of HSBC Germany and HSBC Bank Malta on 30 November 2022. The averages for LCR and NSFR includes the impact of the 
inclusion of two entities for November 2022 and December 2022.

HSBC Holdings plc Annual Report and Accounts 2022

209

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Consolidated liquidity metrics

Liquidity pool by currency1

Net stable funding ratio

From 1 January 2022, we started managing funding risk based on the 
PRA’s NSFR rules. The Group’s NSFR at 31 December 22, calculated 
from the average of the four preceding quarters average, was 136%.

Total available stable funding ($bn)
Total required stable funding ($bn)
NSFR ratio (%)

31 Dec
2022
$bn
1,552  
1,138  
136

At1
30 Jun
2022
$bn
1,567 
1,139 
138

31 Dec 
 2021
$bn
N/A
N/A
N/A

1  Group NSFR numbers above are based on average values. The NSFR 

number is the average of the preceding quarters.

Liquidity coverage ratio

At 31 December 2022, the average HQLA held at entity level 
amounted to $812bn (31 December 2021: $861bn). Since 2021, we 
have implemented a revised approach to the application of the 
requirements under the European Commission Delegated Regulation 
(EU) 2015/61 and PRA rule book. This revised approach was used to 
reflect the impact of limitations in the transferability of entity liquidity 
around the Group, and resulted in an adjustment of $165bn to LCR 
HQLA and $9bn to LCR inflows on an average basis. 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

31 Dec
2022
$bn
812

(174)

647
491
132%

At1
30 Jun
2022
$bn
848

(181)

676
500
135%

31 Dec 
 2021
$bn
861

(176)

688
495
139%

1   Group LCR numbers above are based on average values. The LCR is 

the average of the preceding 12 months.

2   This includes adjustments made to high-quality liquid assets and 

inflows in entities to reflect liquidity transfer restrictions. 

Liquid assets

After the $165bn adjustment, the average Group LCR HQLA of 
$647bn (31 December 2021: $688bn) was held in a range of asset 
classes and currencies. Of these, 97% were eligible as level 1 
(31 December 2021: 93%).

The following tables reflect the composition of the average liquidity 
pool by asset type and currency at 31 December 2022.

Liquidity pool by asset type1

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 2022
Total at 31 Dec 2021

Liquidity 
pool

$bn

Cash Level 12 Level 22
$bn
$bn

$bn

344   

344   

—   

288   

—   

272   

2   

—   

2   

9   

2   
2   
647   
688

—   

—   
—   
344   
390

9   

—   
1   
284   
251

— 

16 

— 

— 

2 
1 
19 
47

1  Group liquid assets numbers are based on average values.
2  As defined in EU regulations, level 1 assets means ‘assets of 

extremely high liquidity and credit quality’, and level 2 assets means 
‘assets of high liquidity and credit quality’.

210

HSBC Holdings plc Annual Report and Accounts 2022

Liquidity pool at 31 Dec 
2022

Liquidity pool at 31 Dec 
2021

$
$bn

£
$bn

€
$bn

HK$ Other Total
$bn
$bn
$bn

  167    191   

98   

54   

137    647 

  176    206    117   

67   

122    688 

1  Group liquid assets numbers are based on average values. 

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 sale1
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)

2022
$m

2021
$m
  1,570,303    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 
206,777 
296,114 
  2,966,530    2,957,939 

66,722   
127,747   
78,149   
88,468   
114,597   
22,290   
127,327   
114,844   
72,353   
16,254   
3,541   
52,558   
196,028   
387,702   

Loans and advances to customers
Loans and advances to banks
Reverse repurchase agreements – non-trading
Cash collateral, margin and settlement accounts 
Assets held for sale1
Trading assets
–  reverse repos
–  stock borrowing
–  other trading assets
Financial investments
Cash and balances with central banks
Other balance sheet assets
At 31 Dec

2022
$m

2021
$m
924,854    1,045,814 
83,136 
104,882   
241,648 
253,754   
59,884 
82,986   
3,411 
115,919   
248,842 
218,093   
14,994 
14,797   
8,082 
10,706   
225,766 
192,590   
446,274 
425,564   
403,018 
327,002   
425,912 
513,476   
  2,966,530    2,957,939 

1   ‘Liabilities of disposal groups held for sale’ includes $85bn and $27bn 
and ‘Assets held for sale’ includes $90bn and $23bn, in respect of 
planned sale of our banking business in Canada and planned sale of our 
retail banking operations in France respectively, that were classified as 
assets held for sale during 2022.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wholesale term debt maturity profile

The maturity profile of our wholesale term debt obligations is set out 
in the following table. The balances in the table are not directly 
comparable with those in the consolidated balance sheet because the 

table presents gross cash flows relating to principal payments and not 
the balance sheet carrying value, which includes debt securities and 
subordinated liabilities measured at fair value. 

Wholesale funding cash flows payable by HSBC under financial liabilities by remaining contractual maturities1

Due not
more 
than
1 month

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

Total

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 2022

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

$m
11,959   
3,821   
5,973   
1,264   
—   
690   
15   
196   
—   
—   
—   
11,959   

17,602   
4,586   
8,542   
2,090   
—   
956   
1   
1,427   
—   
—   
—   
17,602   

$m
11,266   
6,017   
2,351   
1,421   
—   
—   
28   
1,449   
—   
—   
—   
11,266   

14,593   
6,795   
4,140   
1,610   
1,137   
—   
133   
778   
—   
—   
—   
14,593   

$m
12,532   
7,088   
3,534   
1,247   
—   
—   
40   
623   
11   
11   
—   
12,543   

9,293   
4,281   
2,633   
1,017   
—   
—   
33   
1,329   
11   
11   
—   
9,304   

$m
8,225   
4,137   
1,363   
1,850   
—   
—   
38   
837   
160   
160   
—   
8,385   

9,249   
2,837   
2,078   
975   
997   
—   
31   
2,331   
—   
—   
—   
9,249   

$m
8,212   
3,123   
3,238   
1,627   
—   
—   
36   
188   
—   
—   
—   
8,212   

5,233   
1,189   
2,074   
1,206   
—   
—   
193   
571   
—   
—   
—   
5,233   

$m
26,669   
1,264   
19,229   
4,463   
—   
—   
123   
1,590   
2,000   
2,000   
—   
28,669   

25,058   
947   
14,932   
2,996   
2,417   
—   
896   
2,870   
417   
417   
—   
25,475   

1  Excludes financial liabilities of disposal groups.

$m

$m

707   

$m
52,435    52,952    184,250 
1,004    27,161 
44,023    44,021    123,732 
5,990    20,471 
2,609   
602 
602   
690 
—   
1,156 
656   
3,838   
1,717    10,438 
5,581    25,189    32,941 
5,581    23,446    31,198 
1,743 
1,743   
58,016    78,141    217,191 

—   
—   
220   

—   

834   

55,388    56,639    193,055 
931    22,400 
45,063    45,259    124,721 
8,604    21,880 
3,382   
6,548 
1,997   
956 
—   
3,081 
1,696   
2,416   
1,747    13,469 
7,023    21,274    28,725 
7,023    19,427    26,878 
1,847 
1,847   
62,411    77,913    221,780 

—   
—   
98   

—   

HSBC Holdings plc Annual Report and Accounts 2022

211

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Structural foreign exchange risk in 2022
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

Net 
investment 
in foreign 
operations 
(excl non-
controlling 
interest)

Net 
investment 
hedges

2022

Structural 
foreign 
exchange 
exposures 
(pre-
economic 
hedges)

$m
47,204   
39,535   
35,801   
15,182   
4,402   
4,967   
3,989   
4,182   
4,534   
2,715   
3,108   
2,264   
2,058   
1,453   
1,233   
1,283   
908   
746   
785   
968   
5,135   
182,452   

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   
5,242   
187,523   

$m
(4,597)   
(14,000)   
(3,532)   
(777)   
(811)   
(1,380)   
—   
(109)   
(731)   
—   
(358)   
—   
(1,140)   
(469)   
(727)   
(817)   
—   
—   
(200)   
—   
(495)   
(30,143)   

(4,992)   
(15,717)   
—   
—   
(1,093)   
—   
—   
—   
(700)   
—   
(680)   
—   
(1,019)   
—   
(809)   
(696)   
—   
—   
—   
—   
(200)   
(25,906)   

$m
42,607   
25,535   
32,269   
14,405   
3,591   
3,587   
3,989   
4,073   
3,803   
2,715   
2,750   
2,264   
918   
984   
506   
466   
908   
746   
585   
968   
4,640   
152,309   

2021
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   
161,617   

Economic 
hedges – 
structural 
FX hedges1
$m
(8,363)   
—   
(994)   
—   
—   
—   
—   
—   
(2,285)   
—   
—   
—   
—   
—   
—   
—   
—   
—   
(277)   
—   
(36)   
(11,955)   

(7,935)   
—   
(1,255)   
—   
—   
—   
—   
—   
(1,985)   
—   
—   
—   
—   
—   
—   
—   
—   
—   
(332)   
—   
(36)   
(11,543)   

Economic 
hedges – 
equity 
securities 
(AT1)2
$m

—   
(1,205)   
—   
(2,402)   
—   
—   
—   
—   
—   
—   
(559)   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
(4,166)   

—   
(1,353)   
—   
(4,262)   
—   
—   
—   
—   
—   
—   
(1,298)   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
(6,913)   

Net 
structural 
foreign 
exchange 
exposures

$m
34,244 
24,330 
31,275 
12,003 
3,591 
3,587 
3,989 
4,073 
1,518 
2,715 
2,191 
2,264 
918 
984 
506 
466 
908 
746 
308 
968 
4,604 
136,188 

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 
143,161 

Currency of structural exposure

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

1  Represents hedges that do not qualify as net investment hedges for accounting purposes.
2  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.

For definition of structural foreign exchange exposures, see page 205.

212

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interest rate risk in the banking book 
in 2022

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 2023 (effects over one year and five years); and

• an immediate shock of 100bps to the current market-implied path 
of interest rates across all currencies on 1 January 2023 (effects 
over one year and five years).

The sensitivities shown represent a hypothetical simulation of the 
base case NII, assuming a static balance sheet (specifically no 
assumed migration from current account to term deposits), no 
management actions from Global Treasury and a simplified 50% pass-
on assumption applied for material entities. This also incorporates the 
effect of interest rate behaviouralisation, hypothetical managed rate 
product pricing assumptions, prepayment of mortgages and deposit 
stability. 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.

including the absolute level of market rates, regulatory and contractual 
frameworks, and competitive dynamics. 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. 

The one-year and five-year NII sensitivities in the down-shock 
scenarios decreased at 31 December 2022 at Group level when 
compared with 31 December 2021. This was driven by changes in the 
forecasted yield curves and changes in balance sheet composition. 

Immediate interest rate rises of 25bps and 100bps would increase 
projected NII for the 12 months to 31 December 2023 by $884m and 
$3,535m, respectively. Immediate interest rate falls of 25bps and 
100bps would decrease projected NII for the 12 months to 
31 December 2023 by $973m and $3,969m, respectively.

The sensitivity of NII for 12 months decreased by $1,879m in the plus 
100bps parallel shock and by $1,792m in the minus 100bps parallel 
shock, comparing 31 December 2022 with 31 December 2021. The 
decrease in the sensitivity of NII for 12 months in the plus 100bps 
parallel shock was mainly driven by changes in market pricing, 
reflecting current market expectations of main policy rates. The key 
drivers of the reduction in NII sensitivity are the reduced effects of 
flooring as rates have moved higher, deposit migration, and 
management actions.

The sensitivities broken down by currency in the tables below do not 
include the impact of vanilla foreign exchange swaps to optimise cash 
management across the Group.

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, 

For further details of measurement of interest rate risk in the banking 
book, see page 204.  

NII sensitivity to an instantaneous change in yield curves (12 months) – 1 year NII sensitivity by currency

Change in Jan 2023 to Dec 2023 (based on balance sheet at 31 December 2022)
+25bps parallel
-25bps parallel
+100bps parallel
-100bps parallel
Change in Jan 2022 to Dec 2022 (based on balance sheet at 31 December 2021)
+25bps parallel
-25bps parallel
+100bps parallel
-100bps parallel

.

$
$m

(66)   
64   
(267)   
236   

125   
(257)   
458   
(466)   

Currency
£
$m

HK$
$m

107   
(115)   
413   
(476)   

265   
(536)   
1,054   
(1,020)   

245   
(289)   
1,026   
(1,177)   

420   
(594)   
1,739   
(2,070)   

€
$m

Other
$m

Total
$m

167   
(194)   
674   
(765)   

106   
(170)   
632   
(595)   

431   
(439)   
1,689   
(1,787)   

393   
(395)   
1,532   
(1,610)   

884 
(973) 
3,535 
(3,969) 

1,309 
(1,952) 
5,414 
(5,761) 

NII sensitivity to an instantaneous change in yield curves (5 years) – Cumulative 5 years NII sensitivity by currency

Change in Jan 2023 to Dec 2027 (based on balance sheet at 31 December 2022)
+25bps parallel
-25bps parallel
+100bps parallel
-100bps parallel
Change in Jan 2022 to Dec 2026 (based on balance sheet at 31 December 2021)
+25bps parallel
-25bps parallel
+100bps parallel
-100bps parallel

$
$m

192   
(282)   
673   
(1,522)   

1,026   
(1,701)   
3,922   
(5,060)   

Currency
£
$m

HK$
$m

€
$m

Other
$m

Total
$m

668   
(688)   
2,401   
(3,004)   

2,315   
(2,336)   
9,254   
(9,454)   

924   
(1,044)   
3,764   
(4,173)   

2,500   
(2,498)   
9,765   
(10,317)   

6,599 
(6,848) 
25,857 
(28,470) 

1,410   
(2,887)   
4,870   
(7,052)   

3,333   
(4,216)   
13,389   
(14,893)   

827   
(997)   
3,919   
(3,571)   

2,510   
(2,600)   
9,841   
(10,481)   

9,106 
(12,401) 
35,941 
(41,057) 

The net interest income sensitivities arising from the scenarios presented in the tables above are not directly comparable. This is due to timing 
differences relating to interest rate changes and the repricing of assets and liabilities.

HSBC Holdings plc Annual Report and Accounts 2022

213

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

NII sensitivity to an instantaneous change in yield curves (5 years) – NII sensitivity by years

Change in Jan 2023 to Dec 2027 (based on balance sheet at 31 December 2022)
+25bps parallel
-25bps parallel
+100bps parallel
-100bps parallel
Change in Jan 2022 to Dec 2026 (based on balance sheet at 31 December 2021)
+25bps parallel
-25bps parallel
+100bps parallel
-100bps parallel

Year 1
$m

Year 2
$m

Year 3
$m

Year 4
$m

Year 5
$m

Total
$m

884   
(973)   
3,535   
(3,969)   

1,309   
(1,952)   
5,414   
(5,761)   

1,145   
(1,178)   
4,565   
(4,944)   

1,758   
(2,324)   
6,738   
(7,664)   

1,378   
(1,420)   
5,367   
(5,925)   

1,896   
(2,593)   
7,492   
(8,675)   

1,550   
(1,579)   
5,962   
(6,565)   

2,002   
(2,687)   
7,937   
(9,354)   

1,642   
(1,699)   
6,429   
(7,067)   

6,599 
(6,848) 
25,857 
(28,470) 

2,141   
(2,845)   
8,359   
(9,603)   

9,106 
(12,401) 
35,941 
(41,057) 

Non-trading value at risk

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 fair value through 
other comprehensive income, debt instruments measured at 
amortised cost, and exposures arising from our insurance operations.

Value at risk of non-trading portfolios

Value at risk (‘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 the market risk management of non-
trading portfolios to have a complete picture of risk, complementing 
risk sensitivity analysis. 

Our models are predominantly based on historical simulation that 
incorporates the following features:

• historical market rates and prices, which are calculated with 

reference to interest rates, credit spreads and the associated 
volatilities;

• potential market movements that are calculated with reference to 

data from the past two years; and

• calculations to a 99% confidence level and using a one-day holding 

period.

Daily VaR (non-trading portfolios), 99% 1 day ($m)

Although a valuable guide to risk, VaR is used for non-trading 
portfolios 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. As the model is calibrated on the 
last 500 business days, it does not adjust instantaneously to a 
change in the market regime.

• The use of a one-day holding period for risk management purposes 

of non-trading books is only an indication of exposure and not 
indicative of the time period required to hedge or liquidate 
positions.

• The use of a 99% confidence level by definition does not take into 
account losses that might occur beyond this level of confidence.

The interest rate risk on the fixed-rate securities issued by HSBC 
Holdings is not included in the Group non-trading VaR. The 
management of this risk is described on page 217. Non-trading VaR 
also excludes the equity risk on securities held at fair value and non-
trading book foreign exchange risk.

The VaR for non-trading activity at 31 December 2022 was lower than 
at 31 December 2021.

The daily levels of total non-trading VaR in 2022 are set out in the 
graph below.

214

HSBC Holdings plc Annual Report and Accounts 2022

 Non-trading total IR non-trading CS non-trading intent DiversificationDec-21Jan-22Feb-22Mar-22Apr-22May-22Jun-22Jul-22Aug-22Sep-22Oct-22Nov-22Dec-22-100-80-60-40-20020406080100120140160180200220240260280300 
 
 
 
 
 
 
 
The Group non-trading VaR for 2022 is shown in the table below.

Non-trading VaR, 99% 1 day

(Audited)

Balance at 31 Dec 2022
Average
Maximum
Minimum

Balance at 31 Dec 2021
Average
Maximum
Minimum

Interest
rate
$m
159.8   
134.6   
225.5   
98.3   

216.4   
200.7   
248.7   
163.3   

Credit
spread
$m
56.6   
56.9   
84.7 
43.4 

70.3   
76.9   
99.3   
64.7   

Portfolio
diversification1
$m
(45.3)   
(35.9)   

(66.3)   
(40.3)   
—   
—   

Total2
$m
171.1 
155.6 
265.3 
106.3 

220.4 
237.3 
298.8 
193.5 

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.

The decrease at the end of February was primarily driven by Covid-19 
scenarios moving out of the two-year historical scenario window used 
to calculate VaR. Non-trading VaR remained at relatively low levels 
throughout the next two quarters, with an increase in duration risk 
exposure in Global Treasury during November driving an increase in 
both interest rate and total VaR. The average portfolio diversification 
effect between interest rate and credit spread exposure remained 
relatively stable between 2021 and 2022.

Sensitivity of capital and reserves

Hold-to-collect-and-sell stressed VaR is a quantification of the 
potential losses to a 99% confidence level of the portfolio of high-
quality liquid assets held under a hold-to-collect-and-sell business 
model in Global Treasury. 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 December 2022, the stressed VaR of 
the portfolio was $2.15bn (2021: $3.63bn). The decrease was 
primarily due to actions taken to reduce the overall duration risk of the 
portfolio in order to dampen the capital impact from higher interest 
rates.

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.

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. We apply flooring on negative rates in the 
minus 100bps scenario in this assessment. However, due to 
increases in interest rates in most major markets, the effect of this 
flooring is immaterial at the end of 2022.

Comparing 31 December 2022 with 31 December 2021, the 
sensitivity of the cash flow hedging reserve increased by $368m in 
the plus 100bps scenario and increased by $375m in the minus 
100bps scenario. Although our largest exposure by currency remained 
fixed rate pound sterling hedges transacted in HSBC UK Bank plc, the 
increase in sensitivity during 2022 was driven by increases in hedge 
exposure in a variety of other currencies including US dollars and 
Hong Kong dollars.

Sensitivity of cash flow hedging reported reserves to interest rate movements

At 31 Dec 2022
+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 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

$m

(1,899) 

(1.01)%
1,912 
1.02%

(1,531) 
(0.77)%
1,537 
0.78%

Third-party assets in Markets Treasury

Third-party assets in Markets Treasury decreased by 3% compared 
with 31 December 2021. The net decrease of $22bn was partly 
reflective of a reduction in our commercial surplus during the year, as 

well as the impact of foreign exchange rates and interest rates, as 
central banks tightened monetary policy during 2022. The increase of 
$31bn in ‘Other’ was largely driven by the reclassification of our 
banking business in Canada to held for sale.

HSBC Holdings plc Annual Report and Accounts 2022

215

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Third-party assets in Markets Treasury 

Cash and balances at central banks
Trading assets
Loans and advances:
–  to banks
–  to customers
Reverse repurchase agreements
Financial investments
Other
At 31 Dec

2022
$m
317,479   
498   

67,612   
2,102   
53,016   
319,852   
36,192   
796,751   

2021
$m
379,106 
329 

47,363 
371 
47,067 
338,692 
5,451 
818,379 

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 205.

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 2022, HSBC Holdings hedged $22.7bn of previously unhedged 
issuances. The impact can be observed in the NII sensitivity tables 
with a change from positive to negative sensitivities due to increases 
in interest rates.

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 2022, HSBC 
Holdings had forward foreign exchange contracts of 

NII sensitivity to an instantaneous change in yield curves (12 months)

$30.1bn (2021: $25.9bn) to manage the Group’s structural foreign 
exchange exposures. 

For further details of our structural foreign exchange exposures, see 
page 212.

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 of 
the following scenarios:

• an immediate shock of 25bps to the current market-implied path of 

interest rates across all currencies on 1 January 2023; and

• an immediate shock of 100bps to the current market-implied path 

of interest rates across all currencies on 1 January 2023. 

The NII sensitivities shown are indicative and based on simplified 
scenarios. Immediate interest rate rises of 25bps and 100bps would 
decrease projected NII for the 12 months to 31 December 2023 by 
$60m and $240m respectively. Conversely, falls of 25bps and 100bps 
would increase projected NII for the 12 months to 31 December 2023 
by $60m and $240m respectively. 

Change in Jan 2023 to Dec 2023 (based on balance sheet at 31 December 2022)
+25bps
-25bps
+100bps
-100bps
Change in Jan 2022 to Dec 2022 (based on balance sheet at 31 December 2021)
+25bps
-25bps
+100bps
-100bps

NII sensitivity to an instantaneous change in yield curves (5 years)

Change in Jan 2023 to Dec 2023 (based on balance sheet at 31 December 2022)
+25bps
-25bps
+100bps
-100bps
Change in Jan 2022 to Dec 2022 (based on balance sheet at 31 December 2021)
+25bps
-25bps
+100bps
-100bps

216

HSBC Holdings plc Annual Report and Accounts 2022

$
$m

HK$
$m

(66)   
66   
(265)   
265   

16   
(16)   
65   
(64)   

—   
—   
—   
—   

—   
—   
—   
—   

£
$m

4   
(4)   
16   
(16)   

8   
(8)   
31   
(31)   

€
$m

Other
$m

Total
$m

2   
(2)   
9   
(9)   

4   
(4)   
16   
(14)   

—   
—   
—   
—   

—   
—   
—   
—   

(60) 
60 
(240) 
240 

29 
(28) 
113 
(109) 

Year 1
$m

Year 2
$m

Year 3
$m

Year 4
$m

Year 5
$m

Total
$m

(60)   
60   
(240)   
240   

29   
(28)   
113   
(109)   

(41)   
41   
(162)   
162   

44   
(44)   
177   
(174)   

(36)   
36   
(143)   
143   

45   
(45)   
180   
(174)   

(37)   
37   
(148)   
148   

38   
(38)   
152   
(148)   

(38)   
38   
(154)   
154   
— 

28   
(28)   
112   
(109)   

(212) 
212 
(847) 
847 

184 
(183) 
733 
(715) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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 2022
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 20211
Cumulative interest rate gap 

Total

$m

2,590   
2,811 
76,516   
26,194   
163,211   
1,850 
273,172   
(111) 
(32,418)   
(1,220) 
(67,483)   
(4,551) 
(17,059)   
(150,330)   
(273,172)   

2,590   
2,811 
76,516   
26,194   
163,211   
1,850 
273,172   

(111) 
(32,418)   
(1,220) 
(67,483)   
(4,551) 
(17,059)   
(150,330)   
(273,172)   

Up to
1 year

From over 
1 to 5 years

From over 
5 to 10 
years

More than
10 years

Non-interest
 bearing

$m

$m

$m

$m

$m

2,590 

22,545   
22,917   
5,425   

29,759   
3,268 
8,395   

20,347   

2,000   

600 

53,477   

41,422   

20,947   

2,000   

(5,925)   

(10,801)   

(14,942)   

(750) 

(11,244)   

(34,917)   

(19,322)   

(2,000) 

(1,131)   
(2,446)   
(20,746)   
(18,797)   
13,952   
13,952   

2,590 

22,545   
22,917   
5,425   

(3,705)   
(11,096)   
(60,519)   
(10,871)   
(8,226)   
5,726   

(1,780)   
(8,721) 
(44,765)   
1,434   
(22,384)   
(16,658)   

(10,443) 

(13,193)   
6,184   
(5,009)   
(21,667) 

29,759   
3,268 
8,395   

20,347   

2,000   

600 

53,477   

41,422   

20,947   

2,000   

(5,925)   

(10,801)   

(14,942)   

(750) 

(11,244)   

(34,917)   

(19,322)   

(2,000) 

(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)   
(8,721) 
(44,765)   
1,434   
(22,384)   
(16,658)   

(10,443) 

(13,193)   
6,184   
(5,009)   

(21,667) 

2,811 
1,865 
9 
148,791 
1,850 
155,326 
(111) 

(1,220) 

(4,551) 

(128,067) 
(133,949) 
308 
21,667 

2,811 
1,865 
9 
148,791 
1,850 
155,326 
(111) 

(1,220) 

(4,551) 

(128,067) 
(133,949) 
308 
21,667 

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.

HSBC Holdings plc Annual Report and Accounts 2022

217

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

Market risk

Contents

Overview

218
218 Market risk management
219 Market risk in 2022
219
220 Market risk balance sheet linkages

Trading portfolios 

Overview
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. Exposure to market risk is separated into two 
portfolios: trading portfolios and non-trading portfolios.

For further details of market risk in non-trading portfolios, page 214, of 
the Annual Report and Accounts 2022.
Market risk management

Key developments in 2022

There were no material changes to our policies and practices for the 
management of market risk in 2022.
Governance and structure

The following diagram summarises the main business areas where 
trading market risks reside and the market risk measures used to 
monitor and limit exposures.

Trading risk

• Foreign exchange and commodities
• Interest rates
• Credit spreads
• Equities

GBM

Risk types

Global business
Risk measure

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. 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;

• potential market movements that are calculated with reference 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:

Value at risk | Sensitivity | Stress testing

• The use of historical data as a proxy for estimating future market 

The objective of our risk management policies and measurement 
techniques 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 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.

218

HSBC Holdings plc Annual Report and Accounts 2022

moves may not encompass all potential market events, particularly 
those that are extreme in nature. As the model is calibrated on the 
last 500 business days, it does not adjust instantaneously to a 
change in the market regime.

• The use of a one-day holding period for risk management purposes 
of 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.

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.
Back-testing

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 hypothetical loss back-testing exceptions, together 
with a number of other indicators, is used to assess model 
performance and to consider whether enhanced internal monitoring of 
a VaR model is required. We back-test our VaR at set levels of our 
Group entity hierarchy.

Market risk in 2022
During 2022, financial markets were driven by concerns over high 
inflation and recession risks, against the backdrop of the Russia-
Ukraine war and continued Covid-19-related pandemic restrictions in 
some countries. Throughout the year, several major central banks 
tightened their monetary policies at a faster pace than previously 
anticipated in order to counter rising inflation. As a result, bond 
markets sold off sharply and bond yields rose to multi-year highs. In 
addition, a change in the UK fiscal stance in late September led to the 
pound reaching record lows and to significant turmoil in the market 
for long-dated UK government bonds, which was exacerbated by 
rapid deleveraging of liability-driven investment funds used by pension 
schemes. There was pronounced volatility in equity valuations, with 
declines across most market sectors due to recession risks and 
tighter liquidity conditions. Foreign exchange markets were largely 
dominated by a strong US dollar, as a result of global geopolitical 
instability and the relatively fast pace of monetary tightening by the 
US Federal Reserve. Investor sentiment remained fragile in credit 
markets, with credit spreads in both investment-grade and high-yield 
debt benchmarks reaching their widest levels since the start of the 
Covid-19 pandemic.

We continued to manage market risk prudently during 2022. 
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 testing and scenario 
analysis.

Trading portfolios

Value at risk of the trading portfolios

Trading VaR was predominantly generated by the Markets and 
Securities Services business. 

Trading VaR as at 31 December 2022 increased compared with 
31 December 2021. The increase, which peaked in September 2022, 
was mainly driven by interest rate risk factors across business lines, 
although lower loss contributions from credit spread risks provided a 
partial offset. VaR returned to normal operating range in the fourth 
quarter of 2022.

The daily levels of total trading VaR during 2022 are set out in the graph below.

Daily VaR (trading portfolios), 99% 1 day ($m)

HSBC Holdings plc Annual Report and Accounts 2022

219

 Trading totalInterest rate (‘IR’) trading Equity (‘EQ’) tradingCredit spread (‘CS’) trading intentForeign exchange (‘FX’) trading DiversificationDec-21Jan-22Feb-22Mar-22Apr-22May-22Jun-22Jul-22Aug-22Sep-22Oct-22Nov-22Dec-22-60-40-20020406080100Risk reviewRisk review

The Group trading VaR for the year is shown in the table below.

Trading VaR, 99% 1 day1

(Audited)

Balance at 31 Dec 2022
Average
Maximum
Minimum

Balance at 31 Dec 2021
Average
Maximum
Minimum

Foreign
exchange and 
commodity

Interest
rate

Equity

Credit
spread

$m
15.4   
13.6   
29.2   
5.7   

9.1   
12.9   
31.8   
6.7   

$m
40.0   
29.6   
73.3   
20.2   

25.9   
33.8   
51.7   
18.5   

$m
18.6   
16.1   
24.8   
11.5   

15.4   
16.7   
24.3   
12.1   

$m
11.9   
16.8   
27.9 
9.1 

24.8   
19.2   
29.4 
12.2 

Portfolio 
diversification2
$m
(36.4)   
(34.0)   

(36.5)   
(45.5)   

Total3
$m
49.5 
42.1 
78.3 
29.1 

38.8 
37.1 
53.8 
27.7 

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.

The table below shows trading VaR at a 99% confidence level 
compared with trading VaR at a 95% confidence level at 
31 December 2022. 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. 

Trading VaR, 
99% 1 day
$m
49.5   
42.1   
78.3   
29.1   

Trading VaR, 
95% 1 day
$m
31.7 
24.6 
49.0 
17.5 

38.8   
37.1   
53.8   
27.7   

21.6 
24.0 
30.0 
18.9 

Market risk balance sheet linkages

The following balance sheet lines in the Group’s consolidated position 
are subject to market risk:

Trading assets and liabilities

The Group’s trading assets and liabilities are in almost all cases 
originated by GBM. These assets and liabilities are treated as traded 
risk for the purposes of market risk management, other than a limited 
number of exceptions, primarily in Global Banking where the short-
term acquisition and disposal of the assets are linked to other non-
trading-related activities such as loan origination.

Derivative assets and liabilities

We undertake derivative activity for three primary purposes: to create 
risk management solutions for clients, to manage the portfolio risks 
arising from client business, and to manage and hedge our own risks. 
Most of our derivative exposures arise from sales and trading 
activities within GBM. The assets and liabilities included in trading 
VaR give rise to a large proportion of the income included in net 
income from financial instruments held for trading or managed on a 
fair value basis. Adjustments to trading income such as valuation 
adjustments are not measured by the trading VaR model.

For information on the accounting policies applied to financial 
instruments at fair value, see Note 1 on the financial statements.

Balance at 31 Dec 2022
Average
Maximum
Minimum

Balance at 31 Dec 2021
Average
Maximum
Minimum

Back-testing

During 2022, the Group experienced 10 loss back-testing exceptions 
against hypothetical profit and losses, of which seven exceptions 
occurred in the second half of the year. The high number of 
hypothetical back-testing exceptions was primarily driven by the 
volatile market environment and a rapid shift in the global interest rate 
regime in 2022.

The hypothetical profit and loss reflects the profit and loss that would 
be realised if positions were held constant from the end of one 
trading day to the end of the next. This measure of profit and loss 
does not align with how risk is dynamically hedged, and is not 
therefore indicative of the actual performance of the business. 
Accordingly, of the 10 loss back-testing exceptions against 
hypothetical profit and loss, only one corresponded to an actual profit 
and loss exception.

The Group experienced four loss back-testing exceptions against 
actual profit and losses during 2022. Losses were attributable to fair 
value adjustments that were adopted for factors not incorporated 
within valuation models, and from the impacts of restructuring of 
derivative exposures under our RWA optimisation programme. 

Given the heightened number of hypothetical loss back-testing 
exceptions in the second half of 2022, we have undertaken a review 
of our VaR model assumptions and updated the risk parameters 
within the model.

220

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Climate risk TCFD 

Contents 

221

Overview

Climate risk management

222
223 Wholesale credit risk
224

Retail credit risk

Overview
Climate risk relates to the financial and non-financial impacts that may 
arise as a result of climate change and the move to a greener 
economy. Climate risk can materialise through:

• physical risk, which arises from the increased frequency and 
severity of weather events, such as hurricanes and floods, or 
chronic shifts in weather patterns;

• transition risk, which arises from the process of moving to a low-
carbon economy, including changes in government or public 
policy, technology and end-demand; and

• greenwashing risk, which arises from the act of knowingly or 
unknowingly misleading stakeholders regarding our strategy 
relating to climate, the climate impact/benefit of a product or 
service, or the climate commitments or performance of our 
customers.

Approach and policy

We are affected by climate risks either directly or indirectly through 
our relationships with our customers, resulting in both financial and 
non-financial impacts.

We may face direct exposure to the physical impacts of climate 
change, which could negatively affect our day-to-day operations. Any 
detrimental impact to our customers from climate risk could 
negatively impact us either through credit losses on our loan book or 
losses on trading assets. We may also be impacted by reputational 
concerns related to the climate action or inaction of our customers. In 
addition, if we are perceived to mislead stakeholders on our business 
activities or if we fail to achieve our stated net zero ambitions, we 
could face greenwashing risk resulting in significant reputational 
damage and potential regulatory fines, impacting our revenue 
generating ability. 

We have integrated climate risk into our existing risk taxonomy, and 
incorporated it within the risk management framework through the 
policies and controls for the existing risks where appropriate.

Our climate risk approach 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 (for further 

225

225

225

226

Resilience risk

Regulatory compliance risk

Reputational risk

Insights from climate scenario analysis

details of our three lines of defence framework, see page 134). This 
approach provides the Board and senior management with visibility 
and oversight of our key climate risks. 

Our initial approach to managing climate risk was focused on 
understanding physical and transition impacts across five priority risk 
types: wholesale credit risk, retail credit risk, reputational risk, 
resilience risk and regulatory compliance risk. In 2022, we expanded 
our scope to consider climate risk impacts on our other risk types in 
our risk taxonomy.   

We consider greenwashing to be an important emerging risk that is 
likely to increase over time as we look to develop capabilities and 
products to achieve our net zero commitments, and work with our 
clients to help them transition to a low-carbon economy. To reflect 
this, our climate risk approach has been updated to include 
greenwashing risk, and guidance has been provided to the first and 
second lines of defence on the key risk factors, and how it should be 
managed. 

Our ambition to achieve net zero in our financed emissions also 
exposes us to potential reputational, compliance and legal risks if we 
fail to effectively deliver on our ambition. Achieving this ambition is 
dependent on a number of known and unknown factors including the 
accuracy and reliability of data, emerging methodologies and the need 
to develop new tools to accurately assess emissions reductions. We 
have taken initial steps to develop our capabilities to monitor our 
exposures and set risk appetites, although, operationalising our 
ambition is dependent on data and methodologies maturing over 
time, and requires us to continue developing our internal processes 
and tools to help achieve our ambition. 

The tables below provide an overview of the climate risk drivers 
considered within HSBC’s climate risk framework. Primary risk drivers 
refer to risk drivers aligned to the Financial Stability Board’s Task 
Force on Climate-related Financial Disclosures (‘TCFD’), which sets a 
framework to help public companies and other organisations disclose 
climate-related risks and opportunities. Thematic risk drivers are 
bespoke to our internal climate risk framework.

The following table provides an overview of the physical and transition climate risk drivers.

Climate risk – primary risk drivers

Details

Potential Impacts

Physical

Acute

Increased frequency and severity of weather events causing 
disruption to business operations

• Decreased real estate values or stranded 

assets

Chronic

Longer-term shifts in climate patterns (e.g. sustained higher 
temperatures, sea level rise, shifting monsoons or chronic heat 
waves)

Transition

Policy and legal Mandates on, and regulation of products and services and/or 

Technology

End-demand 
(market)

Reputational

policy support for low carbon alternatives. Litigation from parties 
who have suffered loss and damage from climate impacts

Replacement of existing products with lower emissions options

Changing consumer demand from individuals and corporates

Increased scrutiny following a change in stakeholder perceptions 
of climate-related action or inaction

• Decreased household income and wealth 
• Increased costs of legal and compliance 
• Increased public scrutiny 
• Decreased profitability 
• Lower asset performance

HSBC Holdings plc Annual Report and Accounts 2022

221

Risk review 
Risk review

The table below provides an overview of the drivers of greenwashing risk, which is considered to be a thematic risk driver within HSBC’s 
framework.

Climate risk – thematic risk drivers Details

Greenwashing

Firm
Product

Client

Failure to be accurate and transparent in communicating our progress against our net zero ambition

Not taking steps to ensure our ‘green’ and ‘sustainable’ products are developed and marketed appropriately

Failing to check our products are being used for ‘green’ and ‘sustainable’ business activity and assessing the 
credibility of our customers’ climate commitments and/or progress against key performance indicators

In February 2022, we refreshed a high-level assessment of how 
climate risk may impact HSBC taxonomy risk types over a 12-month 
horizon, and we conducted an assessment to understand which parts 
of our risk taxonomy could be impacted by greenwashing risk. The 
table below summarises the results of these exercises. Assessments 
were completed prior to year-end 2022 and do not take into account 
all of the factors that were considered in our assessment of climate 
risk impacts on the financial statements for the year ended 31 

December 2022. The assessments will be refreshed annually, and, 
results may change as our understanding of climate risk and how it 
impacts HSBC evolves (for further details, see ‘Impact on reporting 
and financial statements’ on page 46). In addition to these 
assessments, we also consider climate risk in our emerging risk 
process, which considers potential impacts across longer time 
horizons (for further details, see ‘Top and emerging risks’ on 
page 135).

Financial risk

Non-financial risk

Risk type

Wholesale credit risk

Retail credit risk

Treasury risk – insurance risk

Treasury risk – pension risk
Traded risk

Strategic business risk

Reputational risk

Regulatory compliance risk

Resilience risk

Model risk

Financial crime risk

Financial reporting risk

Legal risk

l Relevant risk driver
Climate risk management
Key developments in 2022
Our climate risk programme continues to support the development of 
our climate risk management capabilities. The following outlines key 
developments in 2022.
• We updated our climate risk management approach to cover all 

risk types in our risk taxonomy.

• We expanded the scope of climate-related training for employees 

to cover additional topics, such as greenwashing risk, and 
increased the availability of training to the broader workforce.
• We developed new metrics to monitor physical climate risk 

exposure in our mortgage portfolio in all our markets, based on 
locally available data.

• We enhanced our transition and physical risk questionnaire and 

scoring tool, which will help us improve our understanding of the 
impact of transition and physical risk on corporate clients in high 
climate transition risk sectors. 

• We assessed transition plans for EU and OECD managed clients in 

scope of our thermal coal phase-out policy.

• We developed our first internal climate scenario exercise, where 
we used four scenarios that were designed to articulate our view 
of the range of potential outcomes for global climate change. For 
further details of our internal climate scenario analysis, see 
page 226.

While we have made progress in developing our climate risk 
framework, there remains significant work to fully integrate climate 
risk, including the need to provide additional skills for our colleagues 
and clients on climate risk topics, and develop further metrics to 
understand how climate risk can impact our risk taxonomy. We also 
need to continue to enhance our stress testing capabilities and 
expand our greenwashing risk framework. We have a dependency on 

222

HSBC Holdings plc Annual Report and Accounts 2022

Relevant risk drivers

Primary risk drivers

Thematic risk drivers

Physical

Transition

Greenwashing

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

●

data and systems in order to achieve these aims, which continue to 
be enhanced.
Governance and structure
The Board takes overall responsibility for our ESG strategy, 
overseeing executive management in developing the approach, 
execution and associated reporting. 

The Group ESG Committee supports the development and delivery of 
our ESG strategy, key policies and material commitments by providing 
oversight, coordination and management of ESG commitments and 
initiatives. It is co-chaired by the Group Company Secretary and Chief 
Governance Officer, and Group Chief Sustainability Officer.

The Group Chief Risk and Compliance Officer is responsible for the 
management of climate-related financial risks under the UK Senior 
Managers Regime, which involves holding overall accountability for 
the Group’s climate risk programme. The Climate Risk Oversight 
Forum oversees risk activities relating to climate risk management 
and the escalation of climate risks. It is supported by equivalent 
forums at regional level.  

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. 

The Group Risk Management Meeting and the Group Risk Committee 
receive regular updates on our climate risk profile and progress of our 
climate risk programme.

For further details on the Group’s ESG governance structure, see 
page 86.

Risk appetite

Management

In 2022, we updated our credit risk policy to require that relationship 
managers comment on climate risk factors in credit applications for 
new money requests. We continued using a climate risk scoring tool, 
which provides a climate risk score for each customer based on 
questionnaire responses. The climate risk score is used to inform 
portfolio level management discussions, and are made available to 
relationship management teams and credit risk management teams. 
The scoring tool will be enhanced and refined over time as more data 
becomes available. 
In 2023, we aim to further embed climate risk considerations in our 
credit risk management processes. 
Aggregation and reporting
We report our exposure to the six high transition risk sectors in the 
wholesale portfolio, as well as our related RWAs internally. 

We also report the proportion of questionnaire responses that have 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 
the Wholesale Credit Risk Management function attends the Global 
Climate Risk Oversight Forum to ensure there is consideration of this 
risk type, and we report our exposure through the climate risk 
management information dashboard at this meeting.

Since 2019, we have received responses from customers within the 
six high transition risk sectors, which represent 59% of our exposure, 
an increase in coverage of 7% since last year. The table below 
presents a breakdown of our customer responses by sector.

The table below also captures 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 decreased to 17.7% (2021: 18.2%). We have 
restated the 2021 comparatives to reflect the new 2022 sector 
allocations and to remove certain off-balance sheet exposures that 
were previously included following improvements in our data and 
processes. For further details of how we designate counterparties as 
high transition risk, see footnote 2.

Our climate risk appetite supports the oversight and management of 
the financial and non-financial risks from climate change, and supports 
the business to deliver our climate ambition in a safe and sustainable 
way. Our initial risk appetite focused on the oversight and 
management of climate risks in five priority areas, including exposure 
to high transition risk sectors in our wholesale portfolio and physical 
risk exposures in our retail portfolio. We have created metrics both at 
global and regional levels, where appropriate, to help manage our risk 
appetite. We continue to review our risk appetite regularly to capture 
the most material climate risks and will enhance our metrics over 
time, including to monitor risk exposures associated with our financed 
emissions reduction targets.

Policies, processes and controls

We are integrating climate risk into the policies, processes and 
controls across many areas of our organisation, and we will continue 
to update these as our climate risk management capabilities mature 
over time. In 2022, we incorporated climate considerations into our 
UK mortgage origination process for our retail business, and new 
money request process for our key wholesale businesses. We also 
continued to enhance our climate risk scoring tool, which will enable 
us to assess our customers’ exposures to climate risk. We also 
published our updated energy policy, covering the broader energy 
system, including upstream oil and gas, oil and gas power generation, 
coal, hydrogen, renewables and hydropower, nuclear, biomass and 
energy from waste, and we updated our thermal coal phase-out policy 
after its initial publication in 2021. For further details of how we 
manage climate risk across our global businesses, see page 64.

Wholesale credit risk
Identification and assessment
In 2019, we initially identified six key sectors where our wholesale 
credit customers had the highest exposure to climate transition risk, 
based on their carbon emissions, which were: automotive; chemicals; 
construction and building materials; metals and mining; oil and gas; 
and power and utilities. For a majority of customers in these sectors, 
we use a transition and physical risk questionnaire to help assess and 
improve our understanding of the impact of climate change on our 
customers’ business models and any related transition strategies. 
Relationship managers work with these customers to record 
questionnaire responses and also help identify potential business 
opportunities to support the transition. Since 2020, we have rolled out 
the questionnaire so that it includes the majority of our largest 
customers in the next highest climate transition risk sectors: 
agriculture; industrials; real estate; and transportation. In 2022, we 
continued to roll out the physical and transition risk questionnaire in 
these sectors by adding new countries to the scope of the 
questionnaire. Due to ongoing data and methodology challenges 
across the industry, our risk appetite metrics remained limited in their 
ability to monitor our risk profile. 

In 2023, we intend to roll out the questionnaire to additional 
customers and enhance our scoring model. We will also continue 
engaging with peers and regulators to explore approaches for further 
integration of climate in credit risk models. We continue to develop 
processes and training to improve the quality and accuracy of the 
questionnaire responses.

HSBC Holdings plc Annual Report and Accounts 2022

223

Risk reviewRisk review

Wholesale loan exposure to transition risk sectors and customer questionnaire responses at 31 December 20221

Wholesale loan exposure as % of total wholesale loans and 
advances to customers and banks2,3,4
Proportion of sector for which questionnaires were completed5
Proportion of questionnaire responses that reported either having 
a board policy or a management plan5
Sector weight as proportion of high transition risk sector5

Automotive Chemicals

%

≤ 3.0

63

69

16

%

≤ 3.3

49

81

19

Construction 
and building 
materials 

Metals 
and 
mining

Oil and 
gas

Power 
and 
utilities

%

%

%

%

Total

%

≤ 3.2

≤ 2.1

≤ 2.6

≤ 3.5

≤ 17.7

55

74

18

56

71

12

67

77

15

66

94

20

59

79

100

1   The 2022 numbers reflect the new 2022 sector allocations and remove certain off-balance sheet exposures that were previously included following 

improvements in our data and processes. See the ESG Data Pack for comparative 2020 and 2021 data. 

2  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.

3  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 in one high transition risk sector 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. From 2022, for Global Banking and Markets clients and Commercial 
Banking clients, the main business of a group of connected counterparties is identified by the industry that generates the majority of revenue within a 
group. Customer revenue data utilised during this allocation process is the most recent readily available and will not align to our own reporting period. 
In prior periods for Global Banking and Markets clients, the main business of a group of connected counterparties was identified by the relationship 
manager for the group. For Commercial Banking clients, the main business of a group of connected counterparties was identified based on the largest 
industry of HSBC’s total lending limits to the group. 

4  Total wholesale loans and advances to customers and banks amount to $658bn (2021: $662bn). Amounts include loans and advances that are held for 

sale.

5   All percentages are weighted by exposure.

Retail credit risk
Identification and assessment

We continued to improve our identification and assessment of climate 
risk within our retail mortgage portfolio. We increased our 
investments in centrally available physical risk data and enhanced our 
internal risk assessment capabilities and models, in order to 
understand our physical risk exposure across a larger proportion of 
our global portfolio. We have also started to identify and monitor 
potential physical risk in the remainder of our global mortgage 
markets, using locally available data. 

In 2022, we undertook an internal climate scenario analysis exercise 
to further our understanding and assessment of the potential impacts 
that physical risk could have on our mortgage portfolios. We 
completed detailed analysis for the UK, Hong Kong, Singapore and 
Australia, which together represent 73.8% of balances of the global 
mortgage portfolio. We also undertook a stress test for our portfolio in 
Singapore at the behest of the Monetary Authority of Singapore, and 
participated in the second round of the Bank of England’s climate 
biennial exploratory scenario exercise, focusing on management 
actions. For further details of our approach and results of our scenario 
analysis, see the ‘Insights on climate scenario analysis’ section on 
page 226.
Management 

We continued to review and update our retail credit risk management 
policies and processes to further embed climate risk, while 
monitoring local regulatory developments to ensure compliance. 

In the UK, which has our largest retail mortgage portfolio, we 
integrated climate risk data into our decision-making framework as 
part of the mortgage origination process. We are actively managing 
our UK mortgage portfolio with a climate risk perspective, and in line 
with our risk appetite, taking conduct considerations into account in 
the lending decision-making process.

Our UK team is also proactively supporting customers by providing 
information on our public website relating to how physical risk and 
home energy efficiency ratings may impact their mortgage 
applications. This gives customers more insight when considering 
purchasing a property that may be susceptible to physical climate risk 
or which may not be energy efficient.

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HSBC Holdings plc Annual Report and Accounts 2022

Aggregation and reporting

We manage and monitor the integration of climate risk in Wealth and 
Personal Banking through the WPB Risk Management Meeting and 
other senior leadership forums.

We assess the progress of the implementation of our strategic 
climate risk plans, and ensure that we update operational processes 
and risk management frameworks as our data and understanding of 
climate risk evolves. A senior representative from WPB Risk attends 
the Group Climate Risk Oversight Forum to ensure we maintain 
alignment with the Group strategy. 
Monitoring climate risk 

In 2022, each of our retail mortgage businesses defined metrics and 
began reporting on their potential balance sheet exposure to physical 
climate risk. Locally relevant data sources were used to identify 
properties or areas with potentially heightened climate risk. These 
climate risk exposure metrics are in the early stages of development 
and the underlying data and methodologies may require refinement in 
the future, although they provide an indicative view.

We continue to measure climate risk using third-party data in our 
most material mortgage market, which is the UK, where the primary 
physical 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 
value basis, and at present day risk levels, 3.5% of the UK retail 
mortgage portfolio is at high risk of flooding, and 0.2% is at a very 
high risk. This is based on approximately 93% coverage by value of 
our portfolio at the end of September 2022, and is reliant on flood 
data provided by Ambiental Risk Analytics.

In line with the UK government ambition to improve the energy 
performance certificate (‘EPC’) ratings of housing stock, we continue 
to identify the current and potential EPC ratings for individual 
properties within the UK mortgage portfolio. 

At the end of September, we had approximately 62% of properties by 
value in our UK residential mortgage portfolio with a valid EPC 
certificate dated within the last 10 years. While 37.7% of these, with 
balances of $31.5bn, had a ‘current’ rating of A to C, 96.8% of them, 
with balances of $81.1bn, had the potential to improve to that level. 
We are working on improving the EPC data coverage, we currently do 
not have EPC data for properties in Northern Ireland.

For both flood risk and EPC data, we disclose the end of September 
position. This is due to the time required for the data to be processed 
by a third party and our reliance on the government’s public EPC data.

Beyond the UK, we have strengthened our focus on the development 
of initiatives to support customers with their transition to more energy 
efficient homes.

The table below shows the maturity level of the UK retail mortgage 
portfolio at the end of December 2022, split by tenor.

Tenor
<1 years
1–5 years
>5 years

Loan by residual maturity ($bn) 
0.45
3.38
143.90

For further details of flood risk and the EPC breakdown of our UK 
retail mortgage portfolio, see our ESG Data Pack at www.hsbc.com/
esg.
Resilience risk
Identification and assessment

Our Operational and Resilience Risk function is responsible for 
overseeing the identification and assessment of physical and 
transition climate risks that may impact on the organisation’s 
operational and resilience capabilities.

We are developing a deeper understanding of the risks to which our 
properties are subject, and assess the mitigants to ensure ongoing 
operational resilience.  
Management

Operational and Resilience Risk policies are reviewed and enhanced 
periodically so they remain relevant to evolving risks, including those 
linked to climate change. The capability of our colleagues is enhanced 
through training, periodic communications and dedicated guidance. 
Aggregation and reporting

With our ambition to achieve net zero in our own operations, we are 
particularly focused on developing measures to facilitate proactive risk 
management and assess progress against this strategic target.

Operational and Resilience Risk is represented at the Group’s Climate 
Risk Oversight Forum.

Regulatory compliance risk
Identification and assessment

Compliance continues to prioritise the identification and assessment 
of compliance risks that may arise from climate risk. 

Throughout 2022, our focus remained on greenwashing risk, 
particularly with regard to the development and ongoing governance 
of new, changed or withdrawn climate and ESG products and 
services, and ensuring sales practices and marketing materials were 
clear, fair and not misleading.

To support the ongoing management and mitigation of greenwashing 
risk, Regulatory Compliance worked across all business lines to 
enhance our product controls. This improved our ability to identify, 
assess and manage product-related greenwashing risks throughout 
the product governance lifecycle. Examples of ongoing 
enhancements include:

• integrating the consideration and mitigation of climate and ESG 

risks within our existing product governance framework;

• enhancing our product templates and forms to ensure climate risk 
is actively considered and documented by the business within 
product review and creation; and  

• clarifying and improving product governance policies, associated 
guidance and key governance terms of reference to ensure new 
climate and ESG products, as well as climate- and ESG-related 
amendments to existing products, comply with both internal and 
external standards, and are subject to robust governance.

Management

Our policies continue to set the Group-wide 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. Our product and customer lifecycle 
policies have been enhanced to ensure they take climate into 
consideration. They are reviewed on a periodic basis to ensure they 
remain relevant and up to date. 

The Compliance function continues to focus on improving the 
capability of colleagues through training, communications and 
dedicated guidance, with a particular focus on ensuring colleagues 
remain up to date with changes in the evolving regulatory landscape. 
Aggregation and reporting

The Compliance function continues to operate an ESG and Climate 
Risk Working Group to track and monitor the integration and 
embedding of climate risk within the management of regulatory 
compliance risks. The working group also continues to monitor 
ongoing regulatory and legislative changes across the ESG and 
climate risk agenda. 

We have continued to develop our key climate risk-related metrics 
and indicators, aligned to the broader focus on regulatory compliance 
risks, to continually improve our risk monitoring capability. This has 
included the development of a climate-specific risk profile, alongside 
the introduction and improvement of existing metrics and indicators. 

The Compliance function continues to be represented at the Group’s 
Climate Risk Oversight Forums. 

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. In 2022, we published our updated energy 
policy, covering the broader energy system, including upstream oil 
and gas, oil and gas power generation, hydrogen, renewables and 
hydropower, nuclear, biomass and energy from waste. We also 
updated our thermal coal phase-out policy after its initial publication in 
2021.
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. Risk Strategy 
includes a team of reputational and sustainability risk specialists 
that provides a higher level of guidance and is responsible for the 
oversight of policy compliance and implementation over wholesale 
banking activities.

For further details on our sustainability risk policies, see our ESG 
review on page 65.
Aggregation and reporting

Our Sustainability Risk Oversight Forum provides a Group-wide forum 
for senior members of our Group 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. For the 
latest report, see: www.hsbc.com/who-we-are/esg-and-responsible-
business/esg-reporting-centre. A representative from Reputational 

HSBC Holdings plc Annual Report and Accounts 2022

225

Risk review 
Risk review

Risk attends the Group Climate Risk Forum to ensure consideration of 
this risk type. 
Other risks
The following section outlines key developments that we made to 
embed climate considerations within other risk types in our risk 
taxonomy. All risk functions, including those not referenced below, 
performed a materiality assessment to determine the impact of 
climate risk on their risk framework.
Treasury risk

We established a treasury risk-specific climate risk governance forum 
to provide oversight over climate-related topics that may impact 
Global Treasury. We updated relevant treasury risk policies to 
strengthen our climate risk guidance and requirements pertaining to 
treasury risk. We undertook an initial assessment to understand the 
exposure of high transition risk sectors within our pension plans.
Traded risk

We established a climate stress testing-focused working group to 
coordinate the implementation of climate stress testing, and support 
the delivery of internal climate scenario analysis. As part of the annual 
limit review in 2022, we developed a set of climate metrics for 
Markets and Securities Services, which we plan to implement in 
2023. 

Insights from climate scenario 
analysis
Scenario analysis supports our strategy by assessing our position 
under a range of climate scenarios. It helps to build our awareness of 
climate change, plan for the future and meet our growing regulatory 
requirements. 

Having run our first Group-wide climate change scenario analysis 
exercise in 2021, we produced several climate stress tests for global 
regulators in 2022, including the Monetary Authority of Singapore and 
the European Central Bank. We also conducted our first internal 
climate scenario analysis.

We continue to develop how we produce our climate scenario 
analysis exercises so that we can have a more comprehensive 
understanding of climate headwinds, risks and opportunities that will 
support our strategic planning and actions. 

In climate scenario analysis, we consider, jointly:

• transition risk arising from the process of moving to a net zero 
economy, including changes in policy, technology, consumer 
behaviour and stakeholder perception, which could 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 could each impact property values, repair 
costs and lead to business interruptions. 

We also analyse how these climate risks impact how we manage 
other risks within our organisation, including credit and market risks, 
and on an exploratory basis, operational, liquidity, insurance and 
pension risks. 
Our climate scenarios

In our 2022 internal climate scenario analysis exercise, we used four 
scenarios that were designed to articulate our view of the range of 
potential outcomes for global climate change. The analysis considered 
the key regions in which we operate, and assessed the impact on our 
balance sheet between the 2022 and 2050 time period. In the 
following sections, the time horizons are considered to cover three 
distinct time periods: short term is up to 2025; medium term is 2026 
to 2035; and long term is 2036 to 2050. The timeframes chosen are 
aligned to the Climate Action 100+ disclosure framework.

These internal scenarios were formed with reference to external 
publicly available climate scenarios, including those produced by the 

226

HSBC Holdings plc Annual Report and Accounts 2022

Network for Greening the Financial System (‘NGFS’), the 
Intergovernmental Panel on Climate Change and the International 
Energy Agency. Using these external scenarios as a template, we 
adapted them by incorporating our unique climate risks and 
vulnerabilities to which our organisation and customers across 
different business sectors and regions are exposed. This helped us 
produce the scenarios, which varied by severity and probability, to 
analyse how climate risks will impact our portfolios. Our scenarios 
were:

• the Net Zero scenario, which aligns with our net zero strategy and 
is consistent with the Paris Agreement, and which assumes that 
there will be rapid and considerable climate action, limiting global 
warming to no more than 1.5°C by 2100, when compared with 
pre-industrial levels;

• the Current Commitments scenario, which assumes that climate 
action is limited to the current governmental commitments and 
pledges, leading to global temperature rises of 2.4°C by 2100;

• the Downside Transition Risk scenario, which assumes that 

climate action is delayed until 2030, but will be rapid enough to 
limit global temperature rises to 1.5°C by 2100; and

• the Downside Physical Risk scenario, which assumes climate 
action is limited to current governmental policies, leading to 
extreme global warming with global temperatures increasing by 
3.1°C by 2100.

We have chosen these scenarios as they are designed to identify, 
measure and assess our most material climate vulnerabilities through 
considering our global presence, business activities and exposures. 
Our scenarios reflect inputs from our businesses and experts, and 
have been reviewed and approved through internal governance.

Our four scenarios reflect different levels of physical and transition 
risks. The scenario assumptions include varying levels of 
governmental climate policy changes, macroeconomic factors and 
technological developments. However, these scenarios rely on the 
development of technologies that are still unproven, such as global 
hydrogen production to decarbonise aviation and shipping.

The nature of the scenarios, our developing capabilities, and 
limitations of the analysis lead to outcomes that are indicative of 
climate change headwinds, although 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 to change over time.

For further details of our four internal climate scenarios, including a 
table including their key underlying assumptions, see our ESG Data 
Pack at www.hsbc.com/esg.
Our modelling approach

For our scenario analysis, we used models to assess how transition 
and physical risks may impact our portfolios under different scenarios. 
Our models incorporate a range of climate-specific metrics that will 
have an impact on our customers, including expected production 
volumes, revenue, unit costs and capital expenditure. 

We also assess how these metrics interplay with economic factors 
such as carbon prices, which represent the cost effect of climate-
related policies that aim to discourage carbon-emitting activities and 
encourage low-carbon solutions. The expected result of higher carbon 
prices is a reduction in emissions as high-emission activities become 
uneconomical. We also assume carbon prices will vary from country 
to country.

The models for our wholesale corporate lending portfolio consider 
metrics across each climate scenario, and from 2022 also 
incorporated our customers’ individual climate transition plans as part 
of our climate scenario analysis. These results in turn feed into the 
calculation of our risk-weighted assets and expected credit loss 
projections. For our residential real estate portfolio models, we focus 
on physical risk factors, including property locations, perils and 
insurance coverage when assessing the overall credit risk impact to 
the portfolio. The results were reviewed by our sector specialists 
who, subject to our governance procedures, make bespoke 
adjustments to our results based on their expert judgement when 
relevant.

We continue to enhance our capabilities by incorporating lessons 
learnt from previous exercises and feedback from key stakeholders, 
including regulators.

For a broad overview of the models that we use for our climate 
scenario analysis, as well as graphs that show how global carbon 
prices and carbon emissions will differ under our climate scenarios, 
see our ESG Data Pack at www.hsbc.com/esg.
Analysing the outputs of the climate 
scenario analysis

Climate scenario analysis allows us to model how different potential 
climate pathways may affect our customers and portfolios, particularly 
in respect of credit losses. As the chart below shows, losses are 
influenced by their exposure to a variety of climate risks under 
different climate scenarios. Under the Current Commitments 
scenario, we expect moderate levels of losses relating to transition 
risks. However, the rise in global warming will lead to increasing 
levels of physical risk losses in later years. 

Modelled climate losses 
How credit losses from climate risks have 
been modelled under different scenarios.

)
n
b
$
(

s
t
n
e
m

r
i
a
p
m

i

<1.5x

>1.5x

e
v
i
t
a
l
u
m
u
C

2021

2025

2030

2035

2040

2045

2050

Net Zero
Current Commitments
Downside Transition Risk

Counterfactual
Net Zero2 
Downside Transition Risk2 

1   The counterfactual scenario is modelled on a scenario where there will 

be no losses due to climate change.

2   The dotted lines in the chart show the impact of modelled expected 

credit losses following our strategic responses to reduce the effect of 
climate risks under the Net Zero and Downside Transition Risk 
scenarios.

A gradual transition towards net zero, as shown in the Net Zero 
scenario, still requires fundamental shifts in our customers’ business 
models, and significant investments. This will have an impact on 
profitability, leading to higher credit risk in the transition period. A 
delayed transition will be even more disruptive due to lower levels of 
innovation that limits the ability to decarbonise effectively, and rising 
carbon prices that squeeze profit margins. 

Overall, our scenario analysis shows that the level of potential credit 
losses can be mitigated if we support our customers in enhancing 
their climate transition plans.

In the following sections, we assess the impacts to our banking 
portfolios under different climate scenarios.  
How climate change is impacting our 
wholesale lending portfolio

In our scenario analysis, we assessed the impact of climate-related 
risks on our corporate counterparties under different climate 
scenarios, which we measured by reviewing the modelled effect on 
our expected credit losses (‘ECL’).

We focused our analysis on the 11 wholesale sectors that we expect 
to be most impacted by climate risks. As at December 2021, these 
portfolios represented 27% of our wholesale lending portfolio. 

For each sector in each scenario, we calculated a peak ECL increase, 
a metric showing the highest level of ECL modelled to be 
experienced during the 2022 to 2050 period. The peak ECL increase 
metric compares the multiplied levels of exposure in the scenario 
against a counterfactual scenario that incorporates no climate change. 

We use the sector’s exposure at default (‘EAD’), which represents 
the relative size of our exposure to potential losses from customer 
defaults. This helps to demonstrate which sectors are the most 
material to us in terms of the impact of climate change.

Due to current limitations, we are unable to fully model the impact of 
physical risks on our corporate customers’ supply chain. As a result, 
we have not included the Downside Physical Risk scenario in the 
following analysis, although we continue to develop our modelling 
capabilities. 

Impact of climate risk on wholesale lending portfolios under modelled 
climate solutions 

Relative size of exposures at default and increase in peak ECL under 
each scenario compared with the counterfactual scenario (expressed 
as a multiple).

Downside 
Transition 
Risk
>5x

Current 
Commitments

<1.5x

Sector level

Exposure 
at default

Conglomerates 

Power and 
utilities

Construction 
and building 
materials

and industrials ♦
♦
♦
♦
♦
♦

Automotive

Oil and gas

Chemicals

Land transport 
and logistics

Aviation

Agriculture and 
soft 
commodities

Marine

Metals and 
mining

♦

♦

♦

♦

♦

Net 
Zero

<5x

<3x

<3x

<3x

<3x

<1.5x

<1.5x

<4x

<3x

<5x

<2x

<5x

<2x

<5x

<4x

<3x

>5x

<3x

<4x

<3x

>5x

<1.5x

<1.25x

<1.25x

<1.5x

<1.25x

<1.5x

<1.25x

<1.5x

<1.25x

<1.5x

As the table above illustrates, we expect our ECL to rise most under 
the Net Zero or Downside Transition Risk scenarios. This is reflective 
of the high transition risks to which these sectors are exposed, and 
the potential impact of not having clear transition plans to mitigate 
these risks. 

For many sectors, the impact of rising carbon prices will lead to 
increased credit losses. However, this will depend on individual 
companies to determine how much of the additional costs associated 
with carbon pricing will be absorbed by their suppliers or customers 
and demand for more economically viable substitute products that 
emerge.

The conglomerates and industrials sector, which includes large 
companies with business activities in multiple business segments, is 
the most impacted by climate change in each scenario. It also 
represents our largest climate-related exposure, and would potentially 
experience the highest increases in credit losses, largely due to the 
transition risks predominantly within the high-emitting and lower-
profitability manufacturing segments. 

Of our other largest and most impacted sectors, the power and 
utilities, construction and building materials, and chemicals sectors 
are subject to increased levels of transition risks due to their ongoing 
exposure to higher carbon emitting activities.

HSBC Holdings plc Annual Report and Accounts 2022

227

Risk review 
 
 
Risk review

Within the analysis, there is a range of geographical outcomes, 
dictated by the varied pace of change in the transition to net zero, 
such as in Asia, where the quality of our customers’ climate transition 
plans within our high-risk sectors lags behind other regions.

We use the results of our climate scenario analysis, including how 
different scenarios will impact on different sectors, to assess the 
impact of climate change risk mitigation on our clients, including our 
customers’ creditworthiness. It informs us about climate risks in our 
wholesale portfolio, allowing us to identify and prioritise the sectors 
and sub-sectors that require the greatest support to transition. This 
also allow us to test the impact of actions that can support our 
customers’ transition and our net zero ambition.

Our net zero ambition represents one of our four strategic pillars. For 
further details of our net zero ambition, see the ‘Transition to net zero’ 
section of the ESG review on page 47, including how we are 
supporting our customers transition to net zero on page 57.
How climate change is impacting our retail 
mortgage portfolio

As part of our internal climate scenario analysis, we carried out a 
detailed physical risk assessment of four of our retail mortgage 
markets – the UK, Hong Kong, Singapore and Australia – which 
represent 73.8% of balances in our retail mortgage portfolio. 

We modelled defaults and losses under three physical risk scenarios. 
Under the Net Zero and Current Commitments scenarios, we project 
minimal losses over the modelled time horizon. However, under the 
Downside Physical Risk scenario, the mortgage book is expected to 
experience a moderate increase in defaults and losses, as the severity 
of perils is expected to worsen, although overall losses are still low.

The modelling, data and methodology in relation to climate scenario 
analysis is still evolving, so the results are not expected to be stable 
or consistent in the short to medium term, and are meant to give an 
indicative, directional assessment for strategic awareness only. 

In our analysis of our retail mortgage portfolio, we assessed several 
physical perils that could impact the value of properties, including 
flooding, wildfire and windstorms. We also assessed the ability and 
willingness of borrowers to service their debts. 

In 2022, we enhanced the methodology to factor in the negative 
impact on property valuations, as well as the impact of affordability 
due to repair costs, following physical risk events. We also considered 
the retail mortgage portfolio with and without insurance. The scenario 
assumptions reflected whether or not properties within the portfolio 
had buildings insurance coverage to pay for damage incurred from 
physical events. In addition, we addressed geolocation data 
deficiencies, implemented new models and incorporated more data, 
although the data and models used to estimate defaults and losses 
are still evolving.

228

HSBC Holdings plc Annual Report and Accounts 2022

Losses as a proportion of global retail 
mortgage book under tested scenarios1

5x

2020

2030

2040

2050

RCP2.6 Net Zero (with insurance)

RCP4.5 Current Commitments (with insurance)

RCP 8.5 Downside Physical Risk (with insurance)

1    Our internal climate scenarios are supported by the Intergovernmental 
Panel on Climate Change’s Representative Concentration Pathways 
(‘RCP’) and are used as inputs into physical risk modelling. The Net 
Zero scenario is mostly aligned to the RCP 2.6 scenario; the Current 
Commitments scenario is mostly aligned to the RCP 4.5 scenario; and 
the Downside Physical Risk scenario is mostly aligned to the RCP 8.5 
scenario.

The modelled impact on our portfolio projects losses will remain 
negligible under the Net Zero and Current Commitments scenarios by 
2050. Under the Downside Physical Risk (with insurance) scenario, 
although losses are five times larger than under the Net Zero and 
Current Commitments scenario, they remain at low levels. This 
moderate increase is largely driven by the expected demise of Flood 
Re in the UK in 2039. Flood Re is a UK government-backed insurance 
scheme that ensures that properties at the highest risk of flooding 
can obtain buildings insurance. Under this scenario, properties ceded 
to the scheme become uninsurable post-2039. The proportion of our 
properties that were reinsured by Flood Re was less than 4% of the 
UK portfolio at December 2021. While overall modelled losses were 
low, a large proportion of these were driven by such properties. 

One of the outcomes from the exercise was that the non-availability 
of insurance for impacted properties was a key contributor to losses. 
It was assumed that properties that are insurable, or where insurance 
is affordable, will largely maintain their insurance. We also assessed 
the impact of enhanced EPC legislation, although it was deemed to 
be immaterial.

In addition, we assessed the risk of tropical cyclones and related 
storm surges as they were deemed material in Hong Kong. However, 
defaults are expected to remain low through to 2050 due to buildings 
being designed to withstand high wind speeds and investment into 
sea defences. We also looked at wildfire in Australia, although the risk 
and severity is limited given our mortgage portfolio is predominantly 
located in metropolitan areas. Similarly, losses in Singapore were low 
in all the scenarios due to its geographical location and strong sea 
defences.

Projected peril risk

Flooding is usually localised to specific areas that are close to water 
sources such as rivers or the coast, areas that are located in particular 
valleys where surface water can ‘pool’, or urban areas with poor 
drainage following flash floods.

As the ‘Exposure to flooding’ table below shows, the majority of 
properties located in the four markets are predicted to experience 
zero to low risk of flooding, with flood depths of less than 0.5 metres, 
under a 1-in-100-year event in each of the scenarios, demonstrating 
the resilience of our portfolio. 

Exposure to flooding

Peak multiplier increase in ECL 

Proportion of properties with projected  flood depths in a 1-in-100-
year severity flood event (%)1

Relative size of exposures at default (‘EAD’) and increase in peak ECL 
under each scenario compared with the counterfactual scenario 
(expressed as a multiple) 

Markets

UK

Hong Kong

Singapore

Australia

Scenarios

Flood depth 
(metres)

Baseline 
flood risk

Net Zero

Downside 
Physical Risk

>1.5

0.5–1.5

0–0.5

>1.5

0.5–1.5

0–0.5

>1.5

0.5–1.5

0–0.5

>1.5

0.5–1.5

0–0.5

2022

0.2

0.7

99.1

0.7

1.2

98.1

0

2.8

97.2

0.6

1.2

98.2

2050

0.2

2.5

97.3

0.8

1.3

97.9

0

2.9

97.1

0.6

1.2

98.2

2050

0.4

3.7

95.9

1.2

30.4

68.4

0.1

7.4

92.5

0.7

2.6

96.7

1   Severe flood events include river and surface flooding and coastal 

inundation. The table compares 2050 snapshots under the Net Zero 
and Downside Physical Risk scenarios with a baseline view in 2022.

The most impacted market is Hong Kong, where over 30% of the 
locations would be susceptible to flood depths greater than 
0.5 metres under the Downside Physical Risk scenario in 2050. This is 
primarily driven by higher coastal and storm surges. However, this did 
not take into account building type and property floor level, which we 
expect would reduce the impact of flooding for a large number of 
individual properties, given the majority of buildings in Hong Kong are 
high-rise apartments.

For the remainder of the markets, more than 90% of mortgage 
locations within each market are expected to experience flood depths 
of less than 0.5 metres in all scenarios, which would not be material.
How climate change is impacting our 
commercial real estate portfolios

We assessed the impact of various perils to which our commercial 
real estate customers could be vulnerable, including flooding and 
windstorms. Our commercial real estate portfolio is globally 
diversified with larger concentrations in Hong Kong, the UK and the 
US. 

The impact of exposures to these perils can lead to increased ECL, 
largely due to the cost of repairs following damages caused by 
physical risk events or property valuation impacts caused by the 
increasing frequency of physical risk events.

The ‘Exposure to peril’ table below shows exposure of our 
commercial real estate portfolio within our largest markets to specific 
physical risk events. The ‘peak multiplier increase in ECL’ table shows 
for our largest markets the peak ECL increase modelled to be 
experienced during the 2022 to 2050 period. This is a metric which 
compares the multiplied levels of exposure in the scenario against a 
counterfactual scenario that incorporates no climate change. We use 
the sector’s exposure at default, which represents the relative size of 
our exposure to potential losses from customer defaults within each 
jurisdiction.

Exposure to peril

Proportion of our portfolio exposed to main perils in key markets.

Coastal 
inundation

Cyclone 
wind

Surface water 
flooding

Riverine 
flooding

%

2

15
16

%

94

0
83

%

18

12
15

%

11

8
28

Hong 
Kong
UK
US

Downside 
Physical 
Risk (with 
insurance)

Downside
 Physical 
Risk 
(without 
insurance
)

Exposure 
at default 
in 2021

Current 
Commit-
ments

Downside 
Transition 
Risk

Net 
Zero

Hong 

Kong ♦ <1.25x

UK

♦

<1.25x

<1.25x

US

♦

<1.25x

<1.25x

<1.25x

<1.25x

<1.25x

<1.25x

<1.25x

<1.25x

<1.5x

<1.25x

<1.5x

<1.5x

The tables show that despite a varying degree of exposure to perils 
across our most significant markets, our portfolio continues to 
maintain a strong level of resilience to physical climate risks out to the 
long term. In addition, the impact of insurance coverage mitigates 
some of the risks under the most severe Downside Physical Risk 
climate scenario.

Our largest credit exposure is in Hong Kong, where our portfolio has 
material exposure to tropical cyclone winds. However, the resulting 
impact on prospective credit losses remains low in the medium to 
long term due to high building standards.

In the UK, in line with our retail portfolio, the main perils that drive 
potential credit losses relate to coastal, river and surface water 
flooding, although the impacts from these perils are not expected to 
cause significant damages. Around 20% of our financed properties 
are in London, and most are protected by the Thames Barrier. Under 
the Net Zero scenario, transition risks materialise from 2025 due to 
the costs of retrofitting requirements, and these are expected to lead 
to increased impairments. 

In the US, the major perils are from coastal flooding, largely in the 
north-east of the country and in Florida, and from hurricane impact, 
including gust damage, heavy rainfall and storm surges. The intensity 
of these events are expected to increase in the future with a greater 
proportion of tropical cyclones falling within the highest categories. 
These will not only affect the regions that are currently exposed, but 
also new areas due to the projected poleward shift of future tropical 
cyclones. Building resilience and the future availability and affordability 
of insurance cover in these regions will be the key determinants of 
climate risks.
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, both in terms of loss and damage, and business interruption. 
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 2022, there were 38 major storms 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 
2022, 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 500 of our critical and important 
buildings.

The 2022 stress test covered all 500 buildings and modelled climate 
change with the NGFS’s 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.

HSBC Holdings plc Annual Report and Accounts 2022

229

Risk review 
Risk review

Key findings from the 4°C or greater Hot house scenario included:

A key finding from the 2°C, less severe scenario showed:

• The total number of buildings at risk reduces from 146 to 98, with 
the same 62 key facilities still at risk by 2050 from the same perils.

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 historical 
claims data to help ensure our building selection and design standards 
reflect the potential impacts of climate change.

• By 2050, 62 of the 500 critical and important 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.

• These included 40 locations that face the risk of coastal flooding 

due to sea levels rising and storm surges associated with 
typhoons and hurricanes. In addition, five locations face the risk of 
fluvial flooding due to surface water run-off caused by heavy rain. 
The remaining 17 locations are data centres where the 
predominant risk emanate from a mixture of temperature 
extremes and water stress, which could impact the mechanical 
cooling equipment or drought for which the specific direct physical 
impacts could be soil movement.

• A further 84 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. The principal risks are coastal flooding, drought, 
temperature extremes, and water stress.

Resilience risk

Overview
Resilience risk is the risk of sustained and significant business 
disruption from execution, delivery, physical security or safety events, 
causing the inability to provide critical services to our customers, 
affiliates, and counterparties. Resilience risk arises from failures or 
inadequacies in processes, people, systems or external events.
Resilience risk management
Key developments in 2022

The Operational and Resilience Risk sub-function provides robust risk 
steward oversight of the management of resilience risk by the Group 
businesses, functions and legal entities. This includes effective and 
timely independent challenge and expert advice. During the year, we 
carried out a number of initiatives to keep pace with geopolitical, 
regulatory and technology changes and to strengthen the 
management of resilience risk:

• We focused on enhancing our understanding of our risk and 

control environment, by updating our risk taxonomy and control 
libraries, and refreshing risk and control assessments.

• We implemented heightened monitoring and reporting of cyber, 
third-party, business continuity and payment/sanctions risks 
resulting from the Russia-Ukraine war, and enhanced controls and 
key processes where needed.

management oversight while operating effectively as part of a 
simplified non-financial risk structure. We view resilience risk across 
nine sub-risk types related to: failure to manage third parties; 
technology and cybersecurity; transaction processing; failure to 
protect people and places from physical malevolent acts; business 
interruption and incident risk; data risk; change execution risk; building 
unavailability; and workplace safety.

Risk appetite and key escalations for resilience risk are reported to 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 and Group Risk Committee.

Key risk management processes

Operational resilience is our ability to anticipate, prevent, adapt, 
respond to, recover and learn from operational disruption while 
minimising customer and market impact. Resilience is determined by 
assessing whether we are able to continue to provide our most 
important services, within an agreed level. This is achieved via day-to-
day oversight and periodic and ongoing assurance, such as deep dive 
reviews and controls testing, which may result in challenges being 
raised to the business by risk stewards. Further challenge is also 
raised in the form of quarterly risk steward opinion papers to formal 
governance. 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.

• We provided analysis and easy-to-access risk and control 

Business operations continuity

information and metrics to enable management to focus on non-
financial risks in their decision making and appetite setting.

• We further strengthened our non-financial risk governance and 
senior leadership, and improved our coverage and risk steward 
oversight for data privacy and change execution.

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.

Governance and structure

The Operational and Resilience Risk target operating model provides a 
globally consistent view across resilience risks, strengthening our risk

We continue to monitor the situation in Russia and Ukraine, and 
remain ready to take measures to help ensure business continuity, 
should the situation require. There has been no significant impact to 
our services in nearby markets where the Group operates. 
Publications from the UK government, EU Commission and energy 
company National Grid, among others, advised on potential plans for 
power cuts and energy restrictions across the UK and continental 
Europe during the winter period. In light of potential disruption, 
businesses and functions in these markets are reviewing existing 
plans and responses to minimise the impact.

230

HSBC Holdings plc Annual Report and Accounts 2022

 
 
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 2022

The dedicated programme to embed our updated purpose-led 
conduct approach has concluded. Work to map applicable regulations 
to our risks and controls continues in 2023 alongside the adoption of 
new tooling to support enterprise-wide horizon scanning for new 
regulatory obligations and manage our regulatory reporting 
inventories. Climate risk has been integrated into regulatory 
compliance policies and processes, with enhancements made to the 
product governance framework and controls in order to ensure the 
effective consideration of climate – and in particular greenwashing – 
risks. 

Governance and structure

The structure of the Compliance function is substantively unchanged 
and the Group Regulatory Conduct capability and Group Financial 

Financial crime risk

Overview
Financial crime risk is the risk that HSBC’s products and services will 
be exploited for criminal activity. This includes fraud, bribery and 
corruption, tax evasion, sanctions and export control violations, 
money laundering, terrorist financing 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 2022

We regularly review the effectiveness of our financial crime risk 
management framework, which includes consideration of the 
complex and dynamic nature of sanctions compliance risk. In 2022, 
we adapted our policies, procedures and controls to respond to the 
unprecedented volume and diverse set of sanctions and trade 
restrictions imposed against Russia following its invasion of Ukraine.  

We also continued to make progress with several key financial crime 
risk management initiatives, including:

• We enhanced our screening and non-screening controls to aid the 
identification of potential sanctions risk related to Russia, as well 
as risk arising from export control restrictions.

• We deployed a key component of our intelligence-led, dynamic 
risk assessment capability for customer account monitoring in 
additional UK entities, Mexico and Singapore, and have expanded 
coverage to include monitoring of customer credit card activity in 
the UK. Furthermore we have deployed a next generation 
capability for the monitoring of correspondent banking activity in 
Hong Kong and the UK. 

• We reconfigured our transaction screening capability to be ready 
for the global change to payment systems formatting under 
ISO20022 requirements, and enhanced transaction screening 
capabilities by implementing automated alert discounting.

• We strengthened the first-party lending fraud framework, 

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 and with all relevant stakeholders to 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, support processes and tooling 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 identification and escalation of any actual or 
potential regulatory breaches, and relevant reportable events are 
escalated to the Group’s Non-Financial Risk Management Board, the 
Group Risk Management Meeting and Group Risk Committee, as 
appropriate. The Group Head of Compliance reports to the Group 
Chief Risk and Compliance Officer and attends the Risk and 
Compliance Executive Committee, the Group Risk Management 
Meeting and the Group Risk Committee.  

Governance and structure

The structure of the Financial Crime function remained substantively 
unchanged in 2022, although we continued to review the 
effectiveness of our governance framework to manage financial crime 
risk. The Group Head of Financial Crime and Group Money Laundering 
Reporting Officer continues to report to the Group Chief Risk and 
Compliance Officer, while the Group Risk Committee retains 
oversight of matters relating to fraud, bribery and corruption, tax 
evasion, sanctions and export control breaches, money laundering, 
terrorist financing and proliferation financing.

Key risk management processes

We will not tolerate knowingly conducting business with individuals or 
entities believed to be engaged in criminal 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 criminal activity or vulnerabilities in our 
control framework, we will take appropriate mitigating action. 

We manage financial crime risk because it is the right thing to do to 
protect our customers, shareholders, staff, the communities in which 
we operate, as well as the integrity of the financial system on which 
we all rely. We operate in a highly regulated industry in which these 
same policy goals are codified in law and regulation. 

We are committed to complying with the laws and regulations of all 
the markets in which we operate and applying a consistently high 
financial crime standard globally.

We continue to assess the effectiveness of our end-to-end financial 
crime risk management framework, 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.

reviewed and published an updated fraud policy and associated 
control library, and continued to develop fraud detection tools.

We are committed to working in partnership with the wider industry 
and the public sector in managing financial crime risk and we 

HSBC Holdings plc Annual Report and Accounts 2022

231

Risk reviewIndependent Reviews

In August 2022, the Board of Governors of the Federal Reserve 
System terminated its 2012 cease-and-desist order, with immediate 
effect. This order was the final remaining regulatory enforcement 
action that HSBC had entered into in 2012. In June 2021, the UK 
Financial Conduct Authority had already determined that no further 
skilled person work was required under section 166 of the Financial 
Services and Markets Act. The Group Risk Committee retains 
oversight of matters relating to financial crime, including any 
remaining remedial activity not yet completed as part of previous 
recommendations.  

• We have completed independent validations of a suite of newly 

developed models for the forthcoming IFRS17 accounting 
standards for insurance.

• We have enhanced our model risk teams with specialist skills to 

manage the increased model risk in areas such as climate risk and 
models using advanced analytics and machine learning, as they 
become critical areas of focus that will grow in importance in 2023 
and beyond. 

Governance and structure

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 Group 
Risk and Compliance function, and focus on model-related concerns 
and are supported by key model risk metrics. We also have Model 
Risk Committees in our geographical regions focused on local delivery 
and requirements. The Group-level Model Risk Committee is chaired 
by the Group Chief Risk and Compliance Officer, and the heads of key 
businesses participate in these 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 Board to 
the Group Chief Risk and Compliance Officer, who authorises the 
Group Model Risk Committee. 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 and the Group Risk Committee 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.

Risk review

participate in numerous public-private partnerships and information 
sharing initiatives around the world. In 2022, our focus remained on 
measures to improve the overall effectiveness of the global financial 
crime framework, notably by providing input into legislative and 
regulatory reform activities. We did this by contributing to the 
development of responses to consultation papers focused on how 
financial crime risk management frameworks can deliver more 
effective outcomes in detecting and deterring criminal activity, 
including tackling evolving criminal behaviours such as fraud. Through 
our work with the Wolfsberg Group and the Institute of International 
Finance, we supported the efforts of the global standard setter, the 
Financial Action Task Force. In addition, we participated in a number 
of public events related to tackling forestry crimes, wildlife trafficking 
and human trafficking.

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 2022

In 2022, 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 changes, we redeveloped, 

independently validated and submitted to the PRA and other local 
regulators 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 the changes to 
the alternative rate setting mechanisms due to the Ibor transition.

• We embedded changes to address gaps in the control framework 
that emerged as a result of increases in adjustments and overlays 
that were applied to compensate for the impact of the Covid-19 
pandemic, and the subsequent volatility due to the effects of the 
rise in global interest rates on the ECL models. 

• We have increased the involvement of first line colleagues in 

businesses and functions in the development and management of 
models. We also put an enhanced focus on key model risk drivers 
such as data quality and model methodology.

• We have sought to enhance the reporting that supports the model 
risk appetite measures, to support our businesses and functions in 
managing model risk more effectively.

• We continued the transformation of the Model Risk Management 
team, with further enhancements to the independent model 
validation processes, including new systems and working 
practices. Key senior hires were made during the year to lead the 
business areas and regions to strengthen oversight and expertise 
within the function. 

232

HSBC Holdings plc Annual Report and Accounts 2022

Insurance manufacturing operations risk

Contents

233

233

Overview

Insurance manufacturing operations risk management

Insurance manufacturing operations risk in 2022

235
235 Measurement
Key risk types
237

237

238

238

238

–  Market risk

–  Credit risk

–  Liquidity risk 

–  Insurance underwriting risk

Overview
The key risks for our insurance manufacturing operations are market 
risk, in particular interest rate and equity, credit risk and insurance 
underwriting risk. 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 through a range of channels including our 
branches, insurance salesforces, 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, although the 
proportion of sales through other sources such as independent 
financial advisers, tied agents and digital is increasing.

For the insurance 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 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. 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 2022

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, 
which have not changed materially over 2022. During the year, there 
was continued market volatility observed across interest rates, equity 
markets and foreign exchange rates. This was predominantly driven 

by geopolitical factors and wider inflationary concerns. One area of 
key risk management focus was the implementation of the new 
accounting standard, IFRS17 ‘Insurance Contracts’. Given the 
fundamental nature of the impact of the accounting standard on 
insurance accounting, this presents additional financial reporting and 
model risks for the Group. Another area of focus was the acquisition 
early in 2022 of an insurance business in Singapore and the 
subsequent integration of that business into the Group’s risk 
management framework.
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 133. 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’), which are produced by all material entities.

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 proportion 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 proportion between policyholders 
and the shareholder.

HSBC Holdings plc Annual Report and Accounts 2022

233

Risk reviewRisk review

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. 

Risk appetite buffers are set to ensure that the operations are able to 
remain solvent, allowing for business-as-usual volatility and extreme 
but plausible stress events. In certain cases, entities use reinsurance 
to manage capital risk.

Liquidity risk is relatively minor for the insurance business. It 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 to third-party reinsurers to keep 
risks within risk appetite, reduce volatility and improve capital 
efficiency; and

• oversight of expense and reserve risks by entity Financial 

Reporting Committees.

234

HSBC Holdings plc Annual Report and Accounts 2022

Insurance manufacturing operations risk in 2022
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 2022

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 Unit-linked

$m
89,907   

30,950   

418   
46,142   
8,349   
4,048   
2,945   
—   
2,521   
95,373   
—   
91,948   
227   
—   
92,175   
—   
92,175   

$m
8,144   

7,992   

—   
43   
—   
109   
50   
—   
2   
8,196   
2,084   
5,438   
6   
—   
7,528   
—   
7,528   

Other 
contracts2
$m
21,467   

Shareholder
assets and 
liabilities

$m
9,086   

Total

$m
128,604 

3,899   

30   
16,114   
486   
938   
1,724   
—   
225   
23,416   
3,296   
17,521   
22   
—   
20,839   
—   
20,839   

1,543   

44,384 

15   
4,805   
1,920   
803   
2   
9,900   
957   
19,945   
—   
—   
1,495   
7,212   
8,707   
17,681   
26,388   

463 
67,104 
10,755 
5,898 
4,721 
9,900 
3,705 
146,930 
5,380 
114,907 
1,750 
7,212 
129,249 
17,681 
146,930 

88,969   

8,881   

19,856   

9,951   

127,657 

30,669   

129   
42,001   
10,858   
5,312   
2,180   
—   
2,558   
93,707   
—   
89,492   
179   
—   
89,671   
—   
89,671   

8,605   

1   
61   
—   
214   
72   
—   
1   
8,954   
2,297   
6,558   
9   
—   
8,864   
—   
8,864   

3,581   

15   
14,622   
459   
1,179   
1,666   
—   
206   
21,728   
3,641   
16,757   
24   
—   
20,422   
—   
20,422   

1,827   

2   
4,909   
1,951   
1,262   
3   
9,453   
820   
20,227   
—   
—   
1,418   
7,269   
8,687   
16,972   
25,659   

44,682 

147 
61,593 
13,268 
7,967 
3,921 
9,453 
3,585 
144,616 
5,938 
112,807 
1,630 
7,269 
127,644 
16,972 
144,616 

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.

HSBC Holdings plc Annual Report and Accounts 2022

235

Risk review 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Risk review

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 2022

Europe

$m
27,407   

15,858   

292   
383   
9,505   
1,369   
183   
1,296   
958   
29,844   
1,143   
24,076   
288   
2,166   
27,673   
2,171   
29,844   

Asia

$m
100,224   

28,030   

171   
66,674   
861   
4,488   
4,533   
8,407   
2,687   
115,851   
4,237   
89,904   
1,440   
4,992   
100,573   
15,278   
115,851   

Latin 
America

$m
973   

496   

—   
47   
389   
41   
5   
197   
60   
1,235   
—   
927   
22   
54   
1,003   
232   
1,235   

Total

$m
128,604 

44,384 

463 
67,104 
10,755 
5,898 
4,721 
9,900 
3,705 
146,930 
5,380 
114,907 
1,750 
7,212 
129,249 
17,681 
146,930 

Financial assets
–  financial assets designated and otherwise mandatorily measured at fair value through profit or 

34,264   

92,535   

858   

127,657 

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

19,030   

65   
1,161   
12,073   
1,935   
213   
1,098   
1,091   
36,666   
1,396   
30,131   
250   
2,711   
34,488   
2,178   
36,666   

25,248   

82   
60,389   
817   
5,999   
3,703   
8,177   
2,431   
106,846   
4,542   
81,840   
1,357   
4,523   
92,262   
14,584   
106,846   

404   

—   
43   
378   
33   
5   
178   
63   
1,104   
—   
836   
23   
35   
894   
210   
1,104   

44,682 

147 
61,593 
13,268 
7,967 
3,921 
9,453 
3,585 
144,616 
5,938 
112,807 
1,630 
7,269 
127,644 
16,972 
144,616 

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.

236

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

Financial return guarantees

(Audited)

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 in the 
larger entities.

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 $745m (2021: $938m), primarily 
due increases in interest rates during 2022.

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.

2022

Long-term  
investment 
returns on 
relevant 
portfolios

%

1.6-5.1  
3.6-6.8  
2.0-5.5  
2.0-4.2  

Investment 
returns 
implied by 
guarantee

%
—
0.1-1.9
2.0-3.9
4.0-5.0

Cost of 
guarantees

$m
47 
548 
109 
41 
745 

2021

Long-term 
investment 
returns on 
relevant 
portfolios

%
0.7-2.3  
2.7-6.4  
2.2-4.1  
2.2-4.2  

Investment 
returns 
implied by 
guarantee

%
—
0.1-1.9
2.0-3.9
4.0-5.0

Cost of 
guarantees

$m
220 
423 
183 
112 
938 

Capital
Nominal annual return
Nominal annual return
Nominal annual return
At 31 Dec

Sensitivities

Changes in financial market factors, from the economic assumptions 
in place at the start of the year, had a negative impact on reported 
profit before tax of $988m (2021: $516m). 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. These sensitivities 
are prepared in accordance with current IFRSs, which will change 
following the adoption of IFRS 17 ‘Insurance Contracts’, effective 
from 1 January 2023. Further information about the adoption of 
IFRS 17 is provided on page 335.

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. The 
increased upward sensitivity and reduced downward sensitivity of 
profit after tax to a parallel shift in yield curves is driven by rising 
interest rates having reduced the sensitivity impact associated with 
the cost of guarantees in France.

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

2022

Effect on
profit after 
tax

$m
(100)   
35   
391   
(419)   
98   
(98)   

2021

Effect on
total equity

Effect on 
profit after tax

Effect on
total equity

$m
(236)   
177   
391   
(419)   
98   
(98)   

$m

(2)   
(154)   
369   
(377)   
80   
(80)   

$m
(142) 
(9) 
369 
(377) 
80 
(80) 

HSBC Holdings plc Annual Report and Accounts 2022

237

Risk review 
 
 
 
 
 
 
 
 
 
Risk review

Credit risk

(Audited)

Description and exposure

Credit risk is the risk of financial loss if a customer or counterparty 
fails to meet their obligation under a contract. It arises in two main 
areas for our insurance manufacturers:

• risk associated with credit spread volatility and default by debt 
security counterparties after investing premiums to generate a 
return for policyholders and shareholders; and

• risk of default by reinsurance counterparties and non-

reimbursement for claims made after ceding insurance risk.

The amounts outstanding at the balance sheet date in respect 
of these items are shown in the table on page 235.

The credit quality of the reinsurers’ share of liabilities under insurance 
contracts is assessed as ‘satisfactory’ or higher (as defined on 
page 146), with 100% of the exposure being neither past due nor 
impaired (2021: 100%). 

Credit risk on assets supporting unit-linked liabilities is predominantly 
borne by the policyholders. Therefore, our exposure is primarily 
related to liabilities under non-linked insurance and investment 

Expected maturity of insurance contract liabilities

(Audited)

contracts and shareholders’ funds. The credit quality of insurance 
financial assets is included in the table on page 165. 

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.

Liquidity risk

(Audited)

Description and exposure

Liquidity risk is the risk that an insurance operation, though solvent, 
either does not have sufficient financial resources available to meet 
its obligations when they fall due, or can secure them only at 
excessive cost. Liquidity risk may be able to be shared with 
policyholders for products with DPF.

The following table shows the expected undiscounted cash flows for 
insurance liabilities at 31 December 2022.

The profile of the expected maturity of insurance contracts at 
31 December 2022 remained comparable with 2021.
The remaining contractual maturity of investment contract liabilities is 
included in Note 30 on page 396.

Unit-linked 
With DPF and Other contracts
At 31 Dec 2022

Unit-linked 
With DPF and Other contracts
At 31 Dec 2021

Insurance underwriting risk

Description and exposure

Within 1 year
$m
801   
8,637   
9,438   

Expected cash flows (undiscounted)
1–5 years
$m
1,732   
31,290   
33,022   

5–15 years Over 15 years
$m
2,355   
135,002   
137,357   

$m
2,522   
55,157   
57,679   

1,346   
8,803   
10,149   

2,605   
31,334   
33,939   

3,159   
51,891   
55,050   

2,293   
94,168   
96,461   

Sensitivities 

(Audited)

Total
$m
7,410 
230,086 
237,496 

9,403 
186,196 
195,599 

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. Lapse risk 
exposure on products with premium financing increased over the year 
as rising interest rates led to an increase in the cost of financing for 
customers.

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. These sensitivities are 
prepared in accordance with current IFRSs, which will change 
following the adoption of IFRS 17 ‘Insurance Contracts’, effective 
from 1 January 2023. Further information about the adoption of 
IFRS 17 is provided on page 335.

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. 

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. 

The tables on pages 235 and 236 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 2021.

Sensitivity to lapse rates depends on the type of contracts 
being written. 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. 

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.

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

238

HSBC Holdings plc Annual Report and Accounts 2022

2022
$m

(105)   
109   
(121)   
124   
(89)   
89   

2021
$m

(112) 
115 
(115) 
129 
(108) 
107 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate 
governance 
report

HSBC continues to enhance its corporate 
governance practices and procedures to 
support the Board's ambition of world-class 
governance.

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 and their application.

240   The Board

244  Senior management

248   How we are governed

255   Board activities during 2022

257   Board and committee effectiveness,  
performance and accountability

259   Board committees

276  Directors' remuneration report

301  Share capital and other related disclosures

306 

Internal control

308  Employees

310  Statement of compliance

311  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 2022

239

 
Report of the Directors | Corporate governance report

The Board
The Board, which seeks to promote the Group’s long-term 
success, deliver sustainable value to shareholders and  
promote a culture of openness and debate, comprises  
diverse, high-calibre members who have experience in  
our global markets.

Chairman and executive Directors

Mark E Tucker (65) 
Group Chairman
Appointed to the Board: September 2017 
Group Chairman since: October 2017

Noel Quinn (61)
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, the EU and the UK, including 30 years  
living and working in Hong Kong, Mark has a  
deep understanding of the industry and markets  
in which we operate. 

Career: Mark was previously Chairman, Group 
Chief Executive and President of AIA Group Limited 
(‘AIA’), and prior to AIA he was Group Chief 
Executive of Prudential plc.

Mark previously served as a non-executive Director 
of the Court of the Bank of England and as an 
independent non-executive Director of Goldman 
Sachs Group.

Other appointments: 
 – Non-executive Chairman of Discovery Limited
 – Supporting Chair of Chapter Zero
 – Member of the UK Investment Council
 – Member of the Advisory Group on Trade Finance 

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 appointed Group Chief Executive 
in March 2020, having held the role on an interim 
basis since August 2019. Since joining HSBC and its 
constituent companies in 1987, Noel has held a 
variety of roles including Chief Executive Officer, 
Global Commercial Banking; Regional Head of 
Commercial Banking for Asia-Pacific; Head of 
Commercial Banking UK; and Head of Commercial 
Finance Europe.

Other appointments: 
 – Chair of the Financial Services Task Force of the 

Sustainable Markets Initiative

 – Member of the Advisory Council of the Sustainable 

Markets Initiative 

 – Founding member of CNBC ESG Council
 – Member of the Advisory Board of the China 

to the International Chamber of Commerce 

Children Development Fund

Georges Elhedery (48)
Group Chief Financial Officer
Appointed to the Board: January 2023

Skills and experience: Georges has 25 years of 
experience in the banking industry across Europe, 
the Middle East and Asia, and has held a number of 
executive roles at both a regional and global 
business level.

Career: Georges was appointed Group Chief 
Financial Officer and executive Director with effect 
from 1 January 2023. He is also responsible for the 
oversight of the Group’s transformation programme 
and corporate development activities. Georges was 
previously co-Chief Executive Officer, Global 
Banking and Markets and also Head of the Markets 
and Securities Services division of the business. 
Georges joined HSBC in 2005 with extensive trading 
experience in London, Paris and Tokyo. He has since 
held a number of senior leadership roles, including 
Head of Global Banking and Markets, Middle East 
and North Africa; Chief Executive Officer for HSBC, 
Middle East, North Africa and Türkiye; and Global 
Head of Markets based in London.

 – Principal member of the Glasgow Financial 

Alliance for Net Zero 

 – Member of the World Economic Forum’s 

International Business Council

 – Member of the Trade Advisory Group on Financial 
Services to the UK Government’s Department for 
International Trade 

 – Member of the Asia Business Council 
 – Chairman of the Multinational Chairman’s Group 
 – Co-Chair of the Indian B20 Taskforce on Financial 

Inclusion for Economic Empowerment 

 – Director, Peterson Institute for International 

Economics

 – Director, Institute of International Finance
 – Asia Society Board of Trustees

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.

240

HSBC Holdings plc Annual Report and Accounts 2022

 
Independent non-executive Directors

Geraldine Buckingham (45) 
Independent non-executive 
Director
Appointed to the Board: May 2022 

Skills and experience: Geraldine is 
an experienced executive within the 
global financial services industry,  
with significant leadership experience 
in Asia. 

Career: Geraldine is the former Chair 
and Head of Asia-Pacific at BlackRock, 
where she was responsible for all 
business activities across Hong Kong, 
mainland China, Japan, Australia, 
Singapore, India and Korea. After 
stepping down from this role, she 
acted as senior adviser to the 
Chairman and Chief Executive Officer 
of BlackRock. She earlier served as 
BlackRock’s Global Head of Corporate 
Strategy, and previously was a partner 
within McKinsey & Company’s 
financial services practice. 

Other appointments: 
 – Independent non-executive Director 
of Brunswick Group Partnership Ltd

Rachel Duan (52)    
Independent non-executive 
Director
Appointed to the Board:  
September 2021 

Dame Carolyn Fairbairn (62) 
Independent non-executive 
Director
Appointed to the Board:  
September 2021

Skills and experience: Rachel is  
an experienced business leader with 
exceptional international experience in 
the US, Japan, mainland China and 
Hong Kong.

Career: Rachel spent 24 years at 
General Electric (‘GE’), where she  
held positions including 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, 
Russia and the Commonwealth  
of Independent States. She 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.

Skills and experience: Carolyn has 
significant experience across the 
media, government and finance 
sectors, and a deep understanding  
of the macroeconomic, regulatory, 
and political environment.

Career: An economist by training, 
Carolyn has served as a partner at 
McKinsey & Company, Director-
General of the Confederation of British 
Industry, and held senior executive 
positions at BBC and ITV plc. She has 
extensive board experience, having 
previously served as non-executive 
Director of Lloyds Banking Group plc, 
The Vitec Group plc, Capita plc and 
BAE Systems plc. She has also served 
as a non-executive Director of the UK 
Competition and Markets Authority 
and the Financial Services Authority. 

Other appointments: 
 – Honorary Fellow of Gonville and 

Caius College, Cambridge
 – Honorary Fellow of Nuffield  

 – Member of the Advisory Board of 
ClimateWorks Centre Australia

Other appointments: 
 – Independent non-executive Director 

of Sanofi S.A.

 – Independent non-executive Director 

College, Oxford

of AXA S.A.

 – Chair of Trustees at Royal Mencap 

 – Independent non-executive Director 

Society

of the Adecco Group AG

HSBC Holdings plc Annual Report and Accounts 2022

241

Corporate governance 
 
 
 
 
  
Report of the Directors | Corporate governance report

James Forese (59) 
Independent non-executive Director
Appointed to the Board: May 2020

Steven Guggenheimer (57) 
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 working in areas 
including global markets, investment 
and private banking.

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: 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 Citigroup’s President, he was  
Chief Executive Officer of Citigroup’s 
Institutional Clients Group. He has held 
the positions of Chief Executive of its 
Securities and Banking division and 
Head of its Global Markets business.

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; and Corporate 
Vice President, Original Equipment 
Manufacturer.

Other appointments: 
 – Independent non-executive Director 

of BT Group plc

Other appointments: 
 – Non-executive Chair of HSBC North 

 – Independent non-executive Director 

of Leupold & Stevens, Inc

America Holdings Inc

 – Independent non-executive Director 

 – Non-executive Chairman of Global 

of Forrit Holdings Limited

Dr José Antonio Meade Kuribreña 
(53) 
Independent non-executive Director
Appointed to the Board: March 2019 
Workforce engagement non-executive 
Director since: June 2022

Skills and experience: José has 
extensive experience in public 
administration, banking and  
financial policy.

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.

Bamboo Technologies
 – Trustee of Colby College

 – Independent non-executive Director 

of Software Acquisition Group

Other appointments: 
 – Independent non-executive Director 

of Alfa S.A.B. de C.V.

 – Independent non-executive Director 
of Grupo Comercial Chedraui, S.A.B. 
de C.V.

 – Board member of The Global Center 

on Adaptation

 – Member of the Advisory Board of 
the University of California, Centre 
for US Mexican Studies

 – Member of the UNICEF Mexico 

Advisory Board

242

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
Aileen Taylor (50) 
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. 

David Nish (62) 
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, 
strategy, financial reporting, 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, 
Thus plc, London Stock Exchange 
Group plc, the UK Green Investment 
Bank plc and Zurich Insurance Group.

Other appointments: 
 – Independent non-executive Director 

of Vodafone Group plc

 – Honorary Professor of University  

of Dundee Business School

Eileen Murray (64) 
Independent non-executive Director
Appointed to the Board: July 2020

Skills and experience: Eileen has 
extensive knowledge in financial 
services, technology and corporate 
strategy from a career spanning  
more than 40 years.

Career: Eileen previously 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, where she held 
positions including Controller, 
Treasurer, and Global Head of 
Technology and Operations, as  
well as Chief Operating Officer for  
its Institutional Securities Group. She 
was also Head of Global Technology, 
Operations and Product Control at 
Credit Suisse.

Other appointments: 
 – Independent non-executive Director 
of Guardian Life Insurance Company 
of America

 – Independent non-executive Director 
of Broadridge Financial Solutions, Inc
 – Independent non-executive Director 

and Chair of Carbon Arc

 – Strategic Adviser of Invisible Urban 

Charging

 – Adviser of ConsenSys

Jackson Tai (72) 
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 
previously served as Chief Financial 
Officer and President and Chief 
Operating Officer. He worked for  
25 years in the investment banking 
division of J.P. Morgan & Co. 
Incorporated, holding roles as 
Chairman of the Asia-Pacific 
Management Committee and Head  
of Japan Capital Markets. Former 
non-executive Director appointments 
included 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.

Other appointments: 
 – Independent non-executive Director 

of Eli Lilly and Company

 – Independent non-executive Director 

of MasterCard Incorporated

 – Member of the Advisory Panel of the 
Russell Reynolds Associates Board 
and CEO Advisory Group

 – Member of the Board of Trustees of 
the Rensselaer Polytechnic Institute 

 – Member of the Association of the 

Metropolitan Opera Board

Former Directors who served during the year
Irene Lee
Irene Lee retired from the Board on 29 April 2022

Pauline van der Meer Mohr
Pauline van der Meer Mohr retired from the Board 
on 29 April 2022

Ewen Stevenson
Ewen Stevenson resigned from the Board on  
31 December 2022

 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 2022

243

Corporate governance 
 
 
 
 
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. 

244

HSBC Holdings plc Annual Report and Accounts 2022

Elaine Arden (54) 
Group Chief Human  
Resources Officer

Colin Bell (55) 
Chief Executive Officer,  
HSBC Bank plc and HSBC Europe

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 
throughout her career in financial 
services, including with 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.

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, 
where he held a variety of command 
and staff positions, including within 
operational tours of Iraq and Northern 
Ireland, and roles in the Ministry of 
Defence and NATO.

Jonathan Calvert-Davies (54) 
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 also previously 
served as interim Group Head of 
Internal Audit at the Royal Bank of 
Scotland Group.

Greg Guyett (59) 
Chief Executive Officer,  
Global Banking and Markets

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, 
before assuming sole responsibility in 
October 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 for Asia-Pacific.

 
Dr Celine Herweijer (45) 
Group Chief Sustainability Officer

John Hinshaw (52) 
Group Chief Operating Officer

Bob Hoyt (58) 
Group Chief Legal Officer

Celine joined HSBC as Group Chief 
Sustainability Officer in July 2021, and  
is responsible for the Group’s execution 
of its sustainability strategy. She is also 
co-chair of the Group’s ESG Committee. 
She was previously 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 in 2009, 
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 
NASA Fellow.

John became Group Chief Operating 
Officer in February 2020, having joined 
HSBC in December 2019. He has 
extensive background in transforming 
and digitising organisations across a 
range of industries. John was previously 
Executive Vice President of Technology 
and Operations and Chief Customer 
Officer at Hewlett Packard and Hewlett 
Packard Enterprise, and has held senior 
executive positions at Verizon and 
Boeing. John serves on the boards of 
Sysco Corporation and Illumio, Inc., and 
has previously served on the boards of 
BNY Mellon, DocuSign and the National 
Academy Foundation. 

Bob joined HSBC as Group Chief  
Legal Officer in January 2021. He was 
previously Group General Counsel at 
Barclays from 2013 to 2020. Prior to 
that, he was General Counsel and 
Chief Regulatory Affairs Officer for 
PNC Financial Services Group. Bob 
has served as General Counsel and 
Senior Policy Adviser to the US 
Department of the Treasury under 
Secretary Henry M. Paulson Jr, and  
as Special Assistant and Associate 
Counsel to the White House under 
President George W. Bush.

Steve John (49) 
Group Chief Communications and 
Brand Officer

Pam Kaur (59) 
Group Chief Risk and  
Compliance Officer

Steve joined HSBC in December  
2019 and was 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. Steve was 
previously 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 Corporate Affairs 
and PepsiCo as Director of Corporate 
Affairs for their UK and Ireland 
franchises.

Pam was appointed Group Chief Risk 
and Compliance Officer in 2021, 
having held the position of Group 
Chief Risk Officer since 2020. Since 
joining HSBC in 2013, her roles 
included Group Head of Internal Audit 
and Head of Wholesale Market and 
Credit Risk. Pam has also held a 
variety of audit, compliance, finance 
and operations 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 abrdn 
plc, and was previously a non-
executive Director of Centrica plc.

David Liao (50) 
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 2021. He is a Director of the 
Hongkong and Shanghai Banking 
Corporation Limited, Bank of 
Communications Co., Limited, and 
Hang Seng Bank Limited. David joined 
HSBC in 1997, with previous roles 
including: Head of Global Banking 
Coverage for Asia-Pacific; President 
and Chief Executive of HSBC China; 
Head of Global Banking and Markets, 
HSBC China; and Treasurer and Head 
of Global Markets, HSBC China.

HSBC Holdings plc Annual Report and Accounts 2022

245

Corporate governanceAdditional members of the  
Group Executive Committee

Noel Quinn

Georges Elhedery

Aileen Taylor

Biographies are provided on pages 
240 and 243.

Report of the Directors | Corporate governance report

Nuno Matos (55) 
Chief Executive Officer, Wealth  
and Personal Banking 

Nuno was appointed Chief Executive 
Officer of Wealth and Personal 
Banking in 2021. Since joining HSBC  
in 2015 from Santander Group, he has 
held various roles, most recently as 
Chief Executive Officer of HSBC Bank 
plc and HSBC Europe. He has also 
held the positions of Chief Executive 
Officer of HSBC Mexico and Regional 
Head of Retail Banking and Wealth 
Management for Latin America. He is 
currently a Director of HSBC Global 
Asset Management Limited.

Stephen Moss (56) 
Regional Chief Executive Officer – 
Middle East, North Africa and 
Türkiye

Barry O’Byrne (47) 
Chief Executive Officer,  
Global Commercial Banking 

Barry was appointed Chief Executive 
of Global Commercial Banking in 
2020, having served in the role on  
an interim basis since August 2019. 
He joined HSBC in 2017 as Chief 
Operating Officer for Commercial 
Banking. Before joining HSBC, Barry 
worked at GE Capital for 19 years 
where he held a number of senior 
leadership roles, including Chief 
Executive Officer and Chief Operating 
Officer for GE Capital International.

Stephen was appointed Regional Chief 
Executive Officer for the Middle East, 
North Africa and Türkiye in 2021. He 
has held a series of roles in Asia, the 
UK and the Middle East 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 HSBC Bank Middle East 
Limited, HSBC Middle East Holdings 
B.V, HSBC Bank Egypt S.A.E.,  
HSBC Saudi Arabia and The Saudi 
British Bank.

Michael Roberts (62) 
Chief Executive Officer,  
HSBC USA and Americas

Michael was appointed Chief 
Executive Officer of HSBC USA  
when he joined HSBC in 2019. He 
became Chief Executive Officer of the 
Americas with oversight responsibility 
for Canada and Latin America in 2021. 
He is a Director of HSBC Bank Canada; 
Director, President and Chief Executive 
Officer of HSBC North America 
Holdings Inc.; and Chairman of HSBC 
Bank USA, N.A., HSBC USA Inc and 
HSBC Latin America Holdings (UK) 
Limited. Previously, Michael spent 
over 30 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 (54) 
Co-Chief Executive Officer, 
Asia-Pacific – The Hongkong  
and Shanghai Banking  
Corporation Limited

John David Stuart  
(known as Ian Stuart) (59) 
Chief Executive Officer,  
HSBC UK Bank plc

Surendra was appointed co-Chief 
Executive Officer of the Asia-Pacific 
region in 2021. He is a Director of The 
Hongkong and Shanghai Banking 
Corporation Limited, HSBC Global 
Asset Management Limited and HSBC 
Bank Malaysia Berhad. Surendra 
joined HSBC in 1991 and has held 
several senior positions within Global 
Banking and Markets, including Head 
of Global Markets in Indonesia and 
Head of Institutional Sales, Asia-
Pacific. He previously held the position 
of 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 2017 and has 
worked in financial services for over 
four decades. He joined HSBC as 
Head of Commercial Banking in  
the UK and Europe in 2014, having 
previously led the corporate and 
business banking businesses at 
Barclays. He has also held various 
roles at the Royal Bank of Scotland 
Group, and started his career at  
Bank of Scotland. Ian is a business 
ambassador for Meningitis Now,  
and a member of the Economic Crime 
Strategic Board and UK Finance Board.

246

HSBC Holdings plc Annual Report and Accounts 2022

 
Board and senior management diversity  
We value difference

Diversity and inclusion are embedded within the culture of HSBC. The Board remains 
committed to having an inclusive culture that recognises the importance of  
gender, social and ethnic diversity, and the benefits gained from different perspectives.

This section outlines the key diversity and inclusion metrics for Board members and executive management as at 31 December 2022.  
This includes tenure, age, skills and experience, gender and ethnic representation.

Gender and ethnic diversity

Board

Board

The Financial Conduct Authority, in its capacity as the UK Listing Authority, introduced new rules 
during 2022 that require listed companies to publish information on female and ethnic heritage 
representation on the Board and in senior management within the Annual Report and Accounts 
2023. The tables below outline the current gender and ethnic diversity of the HSBC Holdings 
Board and executive management in advance of these requirements becoming applicable.

Male
Female

Board composition, 
tenure and age 
10 
2 

White British or other 
White (including 
minority-White groups)
Asian/Asian British
Executive 
Other ethnic groups, 
Directors 
including Arab

Non-executive 
Directors

Age

Gender
Board

Board

Male
Female

Executive management Executive management

Tenure

Balance of executive Directors 
and non executive Directors
Male
White British or other 
Female
White (including 
minority-White groups)
Asian/Asian British
Other ethnic groups, 
including Arab

Non executive 
Directors 10
Executive 
Directors 2

White British or other White 
(including minority-White groups)
Mixed/multiple ethnic groups
Asian/Asian British
Other ethnic group, including Arab
Not specified/prefer not to say

0–2 years
2–4 years
5–7 years

45–49

50–54

55–59

60–64

Over 65

Executive management Executive management
Tenure
%

Balance of executive Directors 
and non executive Directors

Board

Board

Number

Number of  
senior positions1

Number

Board members

Executive management2

Male

Female

Other

Not specified/prefer not to say

Male
Female

8
Male
Non executive 
Female
4
Directors 10
Executive 
Directors 2

–

–

4

67

33

White British or other White 
(including minority-White groups)
Mixed/multiple ethnic groups
Asian/Asian British
Other ethnic group, including Arab
Not specified/prefer not to say

0–2 years
17
White British or other 
2–4 years
White (including 
4
5–7 years
minority-White groups)
–
Asian/Asian British
Other ethnic groups, 
including Arab

0

–

–

–

–

–

Age

%

81

19

–

–

45–49
50–54
55–59
60–64
Over 65

Board

Ethnic diversity
Board

Executive management Executive management

Male
Female

Male
White British or other 
Female
White (including 
minority-White groups)
Asian/Asian British
Other ethnic groups, 
including Arab

White British or other White 
(including minority-White groups)
Mixed/multiple ethnic groups
Asian/Asian British
Other ethnic group, including Arab
Not specified/prefer not to say

Executive management Executive management

Board members

Male
Female

White British or other White 
(including minority-White groups)

Mixed/multiple ethnic groups

Number

White British or other White 
(including minority-White groups)
Mixed/multiple ethnic groups
Asian/Asian British
Other ethnic group, including Arab
Not specified/prefer not to say

9

–

2

Asian/Asian British

Black/African/Caribbean/ 
Black British

Other ethnic group,  
including Arab

Not specified/prefer not to say

–

1

–

%

75

–

17

8

Executive management2

Number of  
senior positions1

Number

14

1

4

–

1

1

%

66

5

19

–

5

5

4

–

–

–

–

–

Skills and experience

The Board, through its Nomination & 
Corporate Governance Committee, regularly 
reviews the skills and experience it requires 
to effectively discharge its responsibilities.  
A skills matrix, which is a key tool used by 
the Board to inform its succession planning 
discussions, is reviewed at least annually  
by the Board. An extract of the skills matrix, 
showing a selection of the current skills and 
experience of the non-executive Directors,  
is shown below. 

Banking

Finance

Risk

Customer

Technology/digital

Corporate social responsibility/ESG

Direct Asia market experience

1  Senior positions on the Board comprise the Group Chairman, Group Chief Executive, Group Chief Financial 

Officer and Senior Independent non-executive Director.

Male
Global business experience

2  Executive management comprises the Group Chief Executive, his direct reports, and the Group Company 

Secretary and Chief Governance Officer. 

HSBC Holdings plc Annual Report and Accounts 2022

247

9

7

8

5

4

3

4

7

Corporate governanceReport of the Directors | Corporate governance report

Operation of the Board 

The Board is ordinarily scheduled to meet at least seven times a year. 
In 2022, the Board held 15 meetings. For further details on 
attendance at those meetings, see page 250. 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 further information, see ’Board activities during 2022’ on 
page 255.

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 
Board meetings. Other senior executives attend Board meetings for 
specific items as required. 

In addition to formal Board meetings, the Board Oversight Sub-Group 
met in advance of each Board meeting during 2022. Such meetings 
were established following the appointment of Noel Quinn as Group 
Chief Executive and changes to the senior management team as 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 Chair of the 
Group Remuneration 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 senior management are 
invited on an ad hoc basis, depending on the subject matter 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. Following a review by the Group 
Chairman and Group Chief Executive of the role of the Board 
Oversight Sub-Group, it was agreed that it would only be used on an 
ad hoc basis where necessary going forward.
Relationship between the Board and senior 
management 

The Board delegates day-to-day management of the business and 
implementation of strategy to the Group Chief Executive. The Group 
Chief Executive is supported in his 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. For 
further details of the senior management team, see page 244. 

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 Board meetings in different 
locations, and when travelling for other reasons. Board and senior 
management travel resumed in 2022, which allowed for more 
opportunities for Board members to meet together in person and with 
key stakeholders. As Covid-19 restrictions remained in place for some 
markets, and with the safety of colleagues and customers a priority, 
several virtual meetings with senior executives continued to take 
place, which included business meetings, induction meetings and 
subject matter ’deep dives’.

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 financial resource plans for 
achieving strategic objectives, including material transactions; 

• considering and approving the Group’s technology and 

environmental, social and governance strategies; 

• approving the appointment and remuneration of Directors, 

including Board roles; and

• reviewing the Group’s overall corporate governance arrangements.

The Board’s responsibilities are set out in a schedule of matters 
reserved within its terms of reference, which are available on our 
website at www.hsbc.com/who-we-are/leadership-and-governance/
board-responsibilities. The Board’s powers are subject to relevant 
laws, regulations and HSBC’s articles of association.

The role of the independent non-executive Directors is to support the 
development of strategy, oversee risk, 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 can be found in the Nomination & Corporate Governance 
Committee report on page 259. 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 2022, the Board comprised the Group 
Chairman, nine non-executive Directors, and two executive Directors 
who are the Group Chief Executive and the Group Chief Financial 
Officer. One non-executive Director will not stand for re-election at 
the AGM in May 2023.

For further details of Board members' career backgrounds, skills, 
experience and external appointments, see their biographies on 
page 240, and for a breakdown of the diversity and skills of the Board 
and senior management, see page 247.

248

HSBC Holdings plc Annual Report and Accounts 2022

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 has the following three pillars:

• The GEC normally meets every week to discuss current and

emerging issues.

• On a monthly basis, the GEC reviews the performance of each of
the global businesses in 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 respective global businesses, regions and principal
subsidiaries. The Group Chief Risk and Compliance Officer usually
attends these meetings.

• The GEC holds a strategy and governance meeting two weeks in

advance of each Board meeting.

In addition, during the year, the Group Chief Executive independently 
conducts several business reviews on focus areas such as costs and 
the financial reporting plan.

Separate committees have been established to provide specialist 
oversight for matters delegated to the Group Chief Executive and 
senior management. For further details of these committees, see 
page 251.

To further support our senior management, we have dedicated 
corporate governance officers supporting our global businesses and 
global functions to assist in effective end-to-end governance, 
consistency and connectivity.

Subsidiary governance

We are committed to maintaining high standards of corporate 
governance throughout the Group. All subsidiary boards and their 
respective businesses are required to have in place effective 
governance arrangements with regard to the businesses’ nature, size, 
locations and the sectors in which they operate.

Certain subsidiaries are designated formally as principal subsidiaries 
by approval of the Board. In addition to their obligations under their 
respective local laws and regulation, principal subsidiaries, supported 
by regional company secretaries, perform an important role in 
supporting effective and high standards of governance across the 
Group.

The designated principal subsidiaries are:

Principal subsidiary

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 Canada1

Oversight responsibility

Asia-Pacific

Europe, Bermuda (excluding 
Switzerland and UK ring-fenced 
activities)

UK ring-fenced bank and its 
subsidiaries

Middle East, North Africa and 
Türkiye

US

Mexico and Latin America

Canada

1   On 29 November 2022 HSBC announced it had entered into an 
agreement to sell HSBC Bank Canada, subject to regulatory and 
governmental approvals. The sale is expected to complete in late 2023. 

Principal subsidiaries play a critical role in overseeing the 
implementation of the subsidiary accountability framework in the 
regions for which they are responsible. The subsidiary accountability 

framework, refreshed by the Board in 2021, aims to provide 
subsidiaries with a shared understanding and a consistent approach 
towards the Group’s strategic objectives, culture and values, and 
ensure that corporate governance best practice is applied throughout. 
The framework sets clear overarching principles for subsidiaries to 
follow to improve communications and connectivity within the Group. 

It also focuses on ensuring that each subsidiary is led by an effective 
board with an appropriate balance of skills, diversity, experience and 
knowledge, having regard to the nature of the subsidiary's business 
and any local legal and regulatory requirements. Board composition of 
the Group's subsidiaries is kept under review as part of succession 
planning.

The framework is subject to periodic review by the Board and/or its 
Nomination & Corporate Governance Committee and is updated to 
ensure that there is clarity for the directors and officers of their 
respective roles and responsibilities.

Since the revised framework was implemented in 2021, there has 
been a notable improvement in the diversity of subsidiary board 
composition.

To continue this progress, HSBC in 2022 launched a Bank Director 
Programme to develop and equip internal talent to undertake non-
executive employee director roles on subsidiary boards. This 
programme is delivered in partnership with an external business 
school, and provides certified qualifications to its participants in 
becoming highly skilled and knowledgeable subsidiary director 
candidates.

The Group Chairman interacts regularly with the chairs of the principal 
subsidiaries, including through the Chairman’s Forum, which brings 
together the chairs of the principal subsidiaries and the chairs of the 
Group’s audit, risk and remuneration committees, and depending on 
the topic for discussion, also the Group Chief Executive, non-
executive Directors and relevant executive management, advisers 
and/or external experts. In 2022, the Chairman’s Forum covered 
strategic business considerations, geopolitics, global public health, 
liability pricing, shareholder engagements, ESG insights, delegations 
of authority, employee engagement and financial performance. The 
Non-Executive Director Summits, hosted by the Group Chairman, are 
also effective subsidiary directors’ engagement events. 

During 2022, the Group Chairman hosted two virtual Non-Executive 
Director Summits in March and September, where approximately 180 
independent non-executive directors from the Group’s subsidiaries 
attended along with HSBC Holdings Board Directors. The summits 
provide a platform for sharing key messages across subsidiaries, as 
well as facilitating greater connectivity and helping to build a sense of 
community among our subsidiaries’ non-executive directors. In 2022, 
the non-executive directors received updates on Group-wide matters 
including strategy, ESG issues, technology and governance.

The annual Remuneration Committee Chairs’ Forum took place in 
November, and provided the principal subsidiary chairs with an 
opportunity to discuss the Group’s performance and the Group 
Remuneration Committee’s priorities. A follow-up forum was held in 
late November 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. The chairs 
of the principal subsidiary risk committees are regular attendees at 
the Group Risk Committee. Similarly, the Group Audit Committee 
Chair meets regularly with the principal subsidiary audit committee 
chairs to promote the sharing of information and best practices. 
These Group Board committees received escalated reports and 
certifications from the principal subsidiary risk and audit committees 
through the year.

HSBC Holdings plc Annual Report and Accounts 2022

249

Corporate governanceReport of the Directors | Corporate governance report

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 2022. For a 
full description of key Board members’ responsibilities, see www.hsbc.com/who-we-are/leadership-and-governance/board-responsibilities.

Roles

Group Chairman
Mark E Tucker1,2

Executive Director
Group Chief Executive
Noel Quinn2

Executive Director
Group Chief Financial Officer
Ewen Stevenson2,4,6

Non-executive Director
Senior Independent Director
David Nish2,3

15/15

9/9
15/15
15/15
14/15
14/15
6/6
15/15

14/15
15/15
4/6

Non-executive Directors
Geraldine Buckingham3,5
Rachel Duan2,3
Dame Carolyn Fairbairn2,3
James Forese2,3,6
Steven Guggenheimer2,3
Irene Lee2,4
Dr José Antonio Meade 
Kuribreña2,3
Eileen Murray2,3,6
Jackson Tai2,3
Pauline van der Meer 
Mohr2,3,4,6
Group Company Secretary 
and Chief Governance 
Officer
Aileen Taylor

Board 
attendance in 
2022

Responsibilities

15/15

• 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 internal and 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.

• Leads on succession planning for the Board and its committees, ensuring appointments reflect diverse 

cultures, skills and experiences.

15/15

• 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, 

customers, regulators, governments and investors.

• Maintains responsibility and accountability for the Group’s and its employees’ compliance with applicable 

laws, codes, rules and regulations, good market practice and HSBC’s own standards.

14/15

• Supports the Group Chief Executive in developing and implementing the Group strategy and recommends the 

annual budget and long-term strategic and financial resource 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.

• Supports the Group Chairman, acting as intermediary for non-executive Directors when necessary.
• Leads the non-executive Directors in the oversight of the Group Chairman, supporting the clear division of 

responsibility between the Group Chairman and the Group Chief Executive.

• Listens to shareholders’ views if they have concerns that cannot be resolved through the normal channels.

• Develop and approve the Group strategy.
• Challenge and oversee the performance of management.
• Approve the Group’s risk appetite and review risk profile and performance.
• Contribute to the assessment and monitoring of culture.
• Maintain internal and external relationships with the Group’s key stakeholders.

• 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 29 April 2022.
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. 
Irene Lee and Pauline van der Meer Mohr retired from the Board on 29 April 2022. Ewen Stevenson retired from the Board on 31 December 2022.

4 
5  Geraldine Buckingham joined the Board effective 1 May 2022.
6  Due to prior commitments Eileen Murray and Pauline van der Meer Mohr were not able to attend on 28 March 2022 and Steven Guggenheimer on 

2 November 2022. Meetings held on 10 February 2022 and 25 November 2022 were ad hoc meetings called at short notice, and due to prior 
commitments, James Forese and Pauline van der Meer Mohr were unable to attend on 10 February 2022 and Ewen Stevenson was unable to attend 
on 25 November 2022. 

250

HSBC Holdings plc Annual Report and Accounts 2022

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 the Group Chairman and the 
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 259.

The Chairman’s Committee provides the Board with the opportunity 
to consider ad hoc and routine matters between scheduled Board 
meetings. All Board members are invited to attend Chairman’s 
Committee meetings.

In addition to Board committees, working groups have been 
established to enhance Board governance, when appropriate, 
including the Board Oversight Sub-Group and the Technology 
Governance Working Group, which were first convened in 2019 and 
2021, respectively. For further details of these committees, see 
page 248 and the box below. 

The Group Executive Committee has established a number of 
committees to provide specialist oversight for matters delegated to 
the Group Chief Executive and senior management, which help fulfil 
their responsibilities under the Senior Managers and Certification 
Regime.

These committees support the Group Chief Executive and senior 
management in areas such as capital and liquidity, risk management, 
disclosure and financial reporting, restructuring and investment 
considerations, transformation oversight, ESG matters and talent and 
development.

Board

Chair: Mark Tucker

Group Audit 
Committee

Group Risk 
Committee

Chairman’s 
Committee 

Nomination & 
Corporate 
Governance 
Committee

Chair: Mark Tucker

Chair: Mark Tucker

Chair: David Nish

Chair: Jackson Tai

Group 
Remuneration 
Committee

Informal governance

Board Oversight Sub- 
Group

Chair: Dame Carolyn 
Fairbairn

Chair: Mark Tucker

See page 259

See page 262

See page 271

See page 276

Technology 
Governance Working 
Group

Co-Chairs: 
Eileen Murray and 
Steven Guggenheimer

Group Executive Committee
Chair: Noel Quinn

Acquisitions and 
Disposals 
Committee

Disclosure and 
Controls 
Committee

     Chair: Noel 
Quinn

Chair: Ewen 
Stevenson1

Environmental, 
Social and 
Governance 
Committee

Co-Chairs:
Celine Herweijer 
and Aileen Taylor

1   Georges Elhedery took over as chair from 1 January 2023.

Group People 
Committee

Group Risk 
Management 
Meeting

Holdings Asset 
and Liability 
Committee

Transformation 
Oversight 
Executive 
Committee

Chair: Elaine Arden Chair: Pam Kaur

Chair: Ewen 
Stevenson1

Chair: Ewen 
Stevenson1

ESG governance

Technology governance

With ESG issues rising up the global agenda, including with the 
transition to a sustainable economy, we understood the need to 
embed ESG considerations more deeply into our governance 
processes. In February 2021, the Board approved the establishment 
of an executive level ESG committee to support senior management 
in the delivery of the Group’s ESG strategy and development of key 
policies. The ESG Committee also aims to track the Group's 
progress against material commitments by providing holistic 
oversight, coordination and management of ESG activities. The ESG 
Committee is jointly chaired by the Group Chief Sustainability Officer 
and the Group Company Secretary and Chief Governance Officer. 
The committee oversees all areas of environmental, social and 
governance issues, with support from accountable senior 
management in relation to their particular areas of responsibilities. 
Key representatives from the functions and global businesses 
attend to provide insights on the implementation of the ESG 
strategy across the Group, allowing the ESG Committee to make 
recommendations to the Board in respect of ESG matters.

The Technology Governance Working Group was established by the 
Board in early 2021 to enhance its oversight of technology strategy, 
governance and emerging risks, as well as to strengthen 
connectivity with the principal subsidiaries. The role of the working 
group is regularly reviewed by the Board. It was agreed in January 
2022 that it should continue as an informal committee of the Board 
for the duration of 2022, and it was extended for a further 12 
months in January 2023. The working group continues to be jointly 
chaired by two of the Board’s non-executive Directors, Eileen 
Murray and Steven Guggenheimer, and members include the Group 
Risk Committee chair and other non-executive Directors 
representing our US, UK, European and Asian principal subsidiaries. 
The working group met formally six times in 2022. These meetings 
included deep dives on key strategic business initiatives, as well as 
updates on technology strategy implementation and cybersecurity 
matters, with attendance from key technology and business 
stakeholders. There were a number of joint sessions between the 
working group, the Group Audit Committee and the Group Risk 
Committee. For further details of these sessions, see pages 262 
and 271.

HSBC Holdings plc Annual Report and Accounts 2022

251

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Report of the Directors | Corporate governance report

Board induction and training

The Group Company Secretary and Chief Governance Officer works 
with the Group Chairman to ensure that all Board members receive 
appropriate training, both individually and collectively, throughout their 
time on the Board. On appointment, new Directors are provided with 
tailored and comprehensive induction programmes to fit with their 
individual experiences and needs, including the process for managing 
conflicts.  

During 2022, we welcomed one new non-executive Director, 
Geraldine Buckingham, to our Board. In October, we also announced 
that Ewen Stevenson would be stepping down as Group Chief 
Financial Officer on 31 December 2022 and be replaced by Georges 
Elhedery. Georges Elhedery’s induction programme commenced 
upon announcement of his proposed appointment, which included a 
detailed handover prepared by the Group Chief Financial Officer prior 
to Georges commencing the role from 1 January 2023.

The induction programme is delivered through formal briefings and 
introductory sessions with other Board members, senior 
management, legal counsel, auditors, tax advisers and regulators, as 
appropriate. Topics covered in the induction programme include, but 
are not limited to: purpose and values; culture and leadership; 
governance and stakeholder management; Directors’ legal and 
regulatory duties; recovery and resolution planning; anti-money 
laundering and anti-bribery; technical and business briefings; and 
strategy.

Where possible, the induction process is initiated before appointment 
to allow each 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. 

Directors’ induction and ongoing development in 2022

For illustrations of typical induction modules, see the ’Directors’ 
induction and ongoing development in 2022’ table below.

Directors undertook routine training during 2022 in subject matters 
that included: the risk management framework; financial crime; and 
health, safety and well-being. They were provided training by external 
counsel on their obligations when handling confidential and sensitive 
information. The Directors also participated in ’deep dive’ sessions 
into specific areas of the Group’s strategic priorities, risk appetite, 
approach to managing certain risks, climate-aligned finance and 
market abuse regulations. 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 receive 
training that is pertinent to circumstances and context relevant to 
those boards. Opportunities exist for the principal subsidiary 
committee chairs to share their understanding in specific areas with 
the Board Directors as part of the Chairman’s Forum. 

Director

Geraldine Buckingham
Rachel Duan
Dame Carolyn Fairbairn
James Forese
Steven Guggenheimer
José Antonio Meade Kuribreña
Eileen Murray
David Nish
Noel Quinn
Ewen Stevenson
Jackson Tai
Mark Tucker

Induction1
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

Risk and
control3
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

Board global 
mandatory 
training5
l
l
l
l
l
l
l
l
l
l
l
l

Chair and 
subsidiary non-
executive 
Director 
forums6
l
l
l
l
l
l
l
l
l
l
l
l

l Matter considered

ô Matter not considered

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 2022 included: ’Sustainability operating model’, ’Implications from the Russia-Ukraine conflict’ and ’Strategy execution of Asia 
wealth’.

3  Directors received risk and control training and briefings. Examples of specific sessions held in 2022 included: ’Interest rate risk of the banking book 

strategy’ and ’ICAAP/ILAAP’.

4  All Directors received training on topics such as: ’Resolvability assessment framework’, ’Climate-aligned finance’, ’Data literacy’ and ’Cyber 

ransomware’.

5  Global mandatory training, issued to all Directors, mirrored training undertaken by all employees, including senior management. This included: 

management of risk under the risk management framework; cybersecurity risk; health, safety and well-being; sustainability; financial crime, including 
understanding money laundering, terrorist financing, tax, sanctions, fraud and bribery and corruption risks; our values, including workplace harassment; 
and data privacy and the protection of data of our customers and colleagues.

6  These included the Chairman’s Forum, Remuneration Committee Chairs’ Forum and the Non-Executive Director Summits.

252

HSBC Holdings plc Annual Report and Accounts 2022

Board stakeholder engagement 
during 2022 
The Board is committed to engaging with key stakeholders, including 
colleagues, and welcomed the increased focus on bringing the 
employee voice into the boardroom, as envisaged by the revisions 
made to the UK Corporate Governance Code in 2018. 

The Board had previously decided that, given HSBC’s size, scale and 
geographical spread, the ’alternative arrangements’ approach for 
workforce engagement under the UK Corporate Governance Code 
was the suitable option. The Board reviews this annually, and in light 
of the challenges facing the organisation and colleagues from factors 
outside of HSBC’s control, including the Covid-19 pandemic, decided 
to strengthen its practices through the introduction of a non-executive 
Director with designated responsibility for workforce engagement. It 
was agreed by the Board’s Nomination & Corporate Governance 
Committee in May 2022 to appoint José Meade to the new role of 
dedicated workforce engagement non-executive Director. This 
approach assists with the employee voice being heard in Board 
discussions and helps inform decision making.  

The appointment of a designated workforce engagement non-
executive Director does not restrict other Board members from 
engaging with the workforce, particularly as it is not possible for one 
person to represent the diversity of views across the entirety of the 
Group. It remains the responsibility of all Directors to consider 
stakeholder views, including employees.

The programme of workforce engagement for 2022 continued to be 
delivered through a variety of interaction styles, both in person and 
virtually, to accommodate the breadth of experience, geographical 
spread and range of seniority of our employees. Such activities 
included bespoke sessions with smaller groups, formal presentations 
and Q&A opportunities. These engagements were designed to 
promote and deliver open dialogue and two-way discussions between 
Directors and colleagues, allowing the Board to gain valuable insight 
on employee perspectives. This in turn informed Directors’ 
deliberations and decision making in Board and committee meetings.

To help inform the Board of employee initiatives and sentiment and 
allow the Board to plan for future engagement activities, Directors 
received regular workforce engagement papers at Board meetings. 
The Board’s agenda also regularly included non-executive Director 
workforce and other stakeholder engagement updates. These 
updates were addressed in the Group Chief Executive’s Board report 
and the Group Chief Human Resources Officer's report on employee 
views and sentiment, particularly around employee Snapshot surveys. 
The Chairman’s Forum meetings also discussed employee feedback 
from the Group's subsidiaries and received workforce engagement 
updates from each of the principal subsidiary chairs.

Engagement activity between the Board and the wider workforce 
included meetings and events between representatives of the eight 
employee resource groups and the non-executive Directors who have 
been designated to support them. These included:

• a virtual Nurture event with working parents and carers, which 

reflected on the HSBC colleague survey and how more relevant 
data could be captured and actioned;

• two Pride events with our LGBTQ+ colleagues, during which 
participants shared their thoughts, explored what Pride had 
achieved, discussed future opportunities and considered how 
Directors could advocate and support the work of Pride; and

• an in-person event with employee resource group leaders based in 

Hong Kong to discuss what motivates them to be employee 
resource group leaders, share achievements and discuss 
opportunities to align outcomes across the Group.

For more examples of how the Board has engaged with the 
workforce and other stakeholders see ‘Board decision making and 
engagement with stakeholders’ on page 20.

Workforce engagement non-executive 
Director

“I was pleased when the Board took the decision to create 
this role and asked me to assume the position of workforce 
engagement non-executive Director. Our colleagues, and the 
culture we promote, are key to our success in achieving our 
purpose of opening up a world of opportunity.

My role and responsibilities, summarised in the chart below, 
are clear, but I appreciate that given the scale of our 
organisation, and the newness of this responsibility, it is 
critical that I execute this role with focus and intent to 
understand the employee voice, and communicate this to the 
Board. Notwithstanding the challenges, I am dedicated to do 
what I can to meet and speak with a broad spectrum of our 
people, across global businesses, regions and functions.

With the easing of Covid-19 restrictions in 2022, and as the 
Board resumed travel for meetings, I used these opportunities 
to connect with employees on a number of topics. Each 
experience has been enlightening and I am encouraged to see 
how common themes and reflections are being addressed.

While I cannot represent and hear every employee voice, I will 
endeavour to listen to what our colleagues are saying around 
the world. With a dedicated plan of action for 2023, I see this 
role evolving such that I will be able to add value to – and help 
drive more in-depth Board discussions on – topics that affect 
our people.

I look forward to reporting in the future on the progress 
made.”

Dr José Antonio Meade Kuribreña

Workforce engagement non-executive Director

Lunch with graduates 

Mexico City, HSBC Tower

July 2022

HSBC Holdings plc Annual Report and Accounts 2022

253

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Report of the Directors | Corporate governance report

Role of the workforce engagement non-executive Director at a glance

Headline responsibilities:

• Engages, understands, represents colleagues globally.

• Receives employee perspectives through formal and informal engagement.

• Represents the employee voice at Board meetings for consideration during decision making.

Feedback given 
and considered

Holdings Board

↑

Workforce engagement
non-executive Director

↑

Means of 
engagement

Surveys/
Snapshot

Employee 
jams

Audits

Data

Chairs of 
principal 
subsidiaries

Direct engagement

Virtual 'field' trips

Geographical 
visits

Direct 
engagement

↑

Reach

Global

↑

↑

Likely issues/
topics

Purpose, 
culture values

Strategy and 
growth

↑

Pay

Global

Sample

Regional

Specific interest groups

↑

↑

↑

↑

Performance 
management

Working 
conditions/ 
future of work

Diversity and 
inclusion

Change and 
transformation

Climate/ESG

Activities during 2022

José Meade’s appointment was announced to the workforce jointly 
by the Group Chairman and Group Chief Executive on 1 June 2022. 
This was positively received by colleagues, several of whom reached 
out directly to José with engagement ideas.

Since his appointment, José has undertaken a variety of 
engagements in his role including:

Employee views – Mexico, US, India, UK, Hong Kong,
Argentina, Brazil, Chile and Uruguay

In the weeks immediately following his appointment, José had 25 
meetings with colleagues in nine countries, in person and virtually, 
across most areas of the Group. Topics discussed included: the 
need for continued focus on areas such as well-being, and diversity 
and inclusion; and enhancement of technology. Following such 
discussions, several suggestions were made, including 
strengthening employee retention strategies, increasing career 
ownership within teams and improving information gathering 
analysis and dissemination following exit interviews to relevant 
colleagues in the Group.

Graduates – Mexico, US
During the year, José met with Mexican graduates in person and US 
graduates virtually to share experiences of HSBC’s graduate 
programme.

GBM – UK
José participated in an in-person meeting with a diverse group of 
Global Banking colleagues in London to share experiences and 
views on people matters, women in finance, diversity and inclusion, 
and career development. 

Visit to Global Service Centre, Mexico City, Tecnoparque

October 2022
Engagement highlights 
65

1,500+

Sessions attended by executive 
and/or non-executive Directors

Number of employees engaged

38

600+

Sessions attended by workforce 
engagement non-executive 
Director

Number of employees engaged 
by workforce engagement non-
executive Director

Global Service Centre – Mexico
José joined colleagues for a meeting with Global Service Centre 
employees to understand their perspective on working life.

12+

Employee resource groups – Global

Countries of engagement

73%

Highest employee engagement 
survey response

José participated in the virtual annual employee resource group 
summit and heard about the groups' leaders' successes and 
challenges. He connected with representatives in the UK, Mexico, 
India, Dubai, Hong Kong, Singapore and the US.

Employee resource groups – Dubai

José joined an in-person meeting with the chapter leads of the five 
employee resource groups active in MENA (Ability, Balance, 
Embrace, Generations and Nurture).

254

HSBC Holdings plc Annual Report and Accounts 2022

Priorities for 2023

• Review opportunities with Human Resources to ensure the right 
insight is being gained from employees to support and better 
inform the Board when taking decisions. 

• Attend six larger-scale employee engagement events aligned to 
Board meeting agenda items to foster debate and discussion.

• Plan further international employee engagement opportunities in 

addition to the Board travel plans.

 
 
 
 
 
 
 
Board activities during 2022

During 2022, the Board remained focused on HSBC’s strategic 
direction, 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 2022 are set out by theme below.
Strategy and business performance
The Group’s strategy remains focused on increasing returns for 
investors, creating capacity for future investment and building a 
sustainable platform for growth. In 2022, each Board meeting 
featured the Group's strategic performance on its agenda, facilitating 
opportunities to track its delivery throughout the year, and providing 
opportunity to shape how it was developed. The Board reviewed 
progress within the Group’s global businesses and regions, as well as 
against its four strategic pillars of: focus on our strengths, digitise at 
scale, energise for growth and transition to net zero.

The Group’s strategic transformation programme came to a formal 
conclusion in December 2022, having delivered against its objectives 
to reshape underperforming businesses, simplify the organisation, 
reduce costs and reallocate risk-weighted assets. Transformation 
remains a key business focus as it is embedded throughout the 
organisation and its operations.
Environmental, social and governance
In 2020, the Group announced a climate ambition to align its financed 
emissions to net zero by 2050, and to become net zero in its own 
operations and supply chain by 2030. The Group aims to achieve this 
by supporting clients’ transition to a net zero carbon economy and 
focusing on sustainable finance opportunities, as well as by reducing 
the carbon emissions in its own operations.

The Board takes overall responsibility for ESG strategy, overseeing 
executive management in developing the approach, execution and 
associated reporting. The Board considered whether to establish a 
Board committee dedicated to ESG issues, but instead decided that 
the best way to support the oversight and delivery of the Group’s 
climate ambition and ESG strategy was to retain governance at Board 
level. The Group Executive Committee enhanced its governance 
model of ESG matters with the introduction of a dedicated ESG 
Committee and supporting forums. These support senior 
management in the delivery of the Group’s ESG strategy, key policies 
and material commitments by providing oversight over – and 
management and coordination of – ESG commitments and initiatives. 

In 2022, the Board oversaw the implementation of ESG strategy 
through regular dashboard reports and detailed updates including: 
reviews of net zero policies, financed emissions target setting and 
climate-aligned financing initiatives.
Financial decisions
The Board and its dedicated committees approved key financial 
decisions throughout the year, including the Annual Report and 
Accounts 2021, the Interim Report 2022 and the first quarter and the 
third quarter Earnings Releases.

At the end of 2021, the Board approved the 2022 financial resourcing 
plan. The Board monitored the Group’s performance against the 
approved plan, as well as the plans of each of the global businesses. 
The Board also approved the renewal of the debt issuance 
programme. In December 2022, the Board approved the financial 
resourcing plan for 2023. 

The Board adopted a dividend policy designed to provide sustainable 
cash dividends, while retaining the flexibility to invest and grow the 
business in the future, supplemented by additional shareholder 
distributions, if appropriate. For the financial year 2022, we achieved a 

dividend payout ratio within our 2022 target range of between 40% 
and 55% of reported earnings per ordinary share (’EPS’). As 
previously communicated, given our current returns trajectory, we are 
establishing a dividend payout ratio of 50% of reported earnings per 
share for 2023 and 2024, excluding material significant items 
(including the planned sale of our retail banking operations in France 
and the planned sale of our banking business in Canada). 

On 22 February 2022, we announced an interim dividend of $0.18 per 
share for the 2021 full-year, and on 1 August 2022 we announced an 
interim dividend of $0.09 per share for the 2022 half-year. For further 
details of dividend payments, see page 418.
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 by the Board and/or its relevant 
committees. 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

• the Group's revised delegation of authority policy.

The Board also reviewed and monitored the implications of 
geopolitical and macroeconomic developments during the year.
Technology
Throughout the year, the Board received regular updates on 
technology from the Group Chief Operating Officer, including on the 
implementation of the technology strategy and key strategic business 
initiatives. As technology is crucial to help deliver the Group’s 
strategic objectives, including the strategic pillar ’Digitise at scale’, 
strategy papers covered technology issues throughout the year. In 
December, the Board discussed a digital technology map, a new tool 
that could help simplify, prioritise and drive change in the Group’s 
technology estate. For further details, see ’Principal decisions’ on 
page 22.

The Technology Governance Working Group continued to oversee 
and enhance the Group's governance of technology. For further 
details of this working group, see page 251.
People and culture

The Board continued to dedicate time in its meetings to discuss 
people-related and culture-related topics, to help raise its awareness 
of employee and other stakeholder perspectives. The Board is 
committed to setting the right cultural tone, with each Board meeting 
beginning with a ’culture moment’, which includes observations of 
behaviours within the Group aligned to its purpose and values. 

Group subsidiary directors’ approaches to workforce engagement 
were presented by each of the chairs from the principal subsidiaries 
to the Chairman's Forum, where they discussed their respective 
board engagement activities with the workforce, as well as what they 
learned as part of such engagements and other cultural insights. The 

HSBC Holdings plc Annual Report and Accounts 2022

255

Corporate governanceReport of the Directors | Corporate governance report

Board also receives insights from the all-employee Snapshot survey, 
which measures employee sentiment. A culture insights report, 
developed in 2021, provides the Board with key data indicators, such 
as behaviours, sentiment, business outcomes and people to allow it 
to monitor culture across the Group.

Board engagement with management and the wider workforce 
continued to remain a strong area of attention, particularly with the 
appointment of a dedicated workforce engagement non-executive 
Director. For further details of the work of the workforce engagement 
non-executive Director, see page 253.
Governance
The Board continued to oversee the governance, smooth operation 
and oversight of the Group and its principal and material subsidiaries. 

The Board and senior management supported improvements to 
governance initiatives to encourage simplification and promote 
effective decision making in the business. Such improvements 
included making refinements to Board and committee paper 
templates, and reducing unnecessary committee meetings to free 
management time and encourage individual accountability and 
decision taking.

During the year, Pauline van der Meer Mohr and Irene Lee retired as 
independent non-executive Directors, and Ewen Stevenson resigned 
as Group Chief Financial Officer. The Board appointed Geraldine 
Buckingham as an independent non-executive Director in May 2022, 
and Georges Elhedery as Group Chief Financial Officer from 1 January 
2023. The Board, supported by the Nomination & Corporate 
Governance Committee, reviews the skills and experience of the 
Board on an ongoing basis. This ensures that the Board and its 
committees comprise the necessary skills, diversity, experience and 

competencies to discharge their responsibilities effectively. For 
further details of the review and changes to the Board, see the 
Nomination & Corporate Governance report on page 259. For further 
details of diversity of the Board, see page 247.

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.
Board engagements with 
shareholders
In 2022, Board members remained responsive to shareholder 
requests to engage, and certain of the Board met with key investors 
including Ping An Asset Management Co. Ltd. The Group Chairman 
and the Senior Independent Director, often with the Group Company 
Secretary and Chief Governance Officer, engaged with a number of 
our large institutional investors in 19 meetings. The Group Chief 
Executive and the Group Chief Financial Officer, together and 
separately, attended over 100 meetings with investors. Key topics 
included our financial performance, updates on strategy and market 
presence, geopolitical risks and the macroeconomic outlook in key 
geographies. 

The Group Remuneration Committee Chair also met with key 
investors and proxy advisory firms during the fourth quarter of 2022. 
These sessions provided useful insight into investor views on key 
areas of decision making for the Group Remuneration Committee, 
including our approach to the 2022 pay review for executive Directors 
and the wider workforce. For further details of the Group 
Remuneration Committee report, see page 276.

Board activities in 2022

Main topic

Sub-topic

Strategy

Group strategy

Regional strategy/global business strategy

Environmental, social, governance

Business and 
financial 
performance

Region/global business

Financial performance

Financial

Results and accounts

Dividends

Group financial resource planning

Risk

Risk function

Risk appetite

Regulatory

External

Technology

People and 
culture
Governance

Capital and liquidity adequacy
Regulatory and legal matters2 
Regulatory matters with regulators in attendance3

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

l Matter considered

ô Matter not considered

Jan

ô
l
l
l

l
l
l
l
l
ô

ô
l
ô

ô
l

ô

ô
l
l
ô
l

Feb Mar
l
l
ô

Meetings at which topics were discussed1

Apr May
l
l
l
l

ô
l
l
l

l

ô

ô
l
l
ô
l
l
ô
l
l

ô

ô
l
ô

ô
l

l

ô

ô
l
l
ô

ô
l
ô

ô
l

ô

ô
l
ô

ô

ô

Jun
l
ô

ô

ô

ô

ô

ô

ô

ô

ô

ô
l
l
ô
l

ô

ô

ô

ô

ô

ô

Jul
l
l
l
l

l
l
l
l
l
l
ô
l
ô

ô
l

ô

ô
l
l
l
ô

Sep Nov
l
l
l
l

ô
l
ô

ô

l

ô

ô
l
l
ô
l
l
ô
l
l

l

ô
l
ô
l
ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

ô

Dec
l
l
l
l

l

ô

ô
l
l
l
ô
l
ô

ô
l

ô

ô
l
ô
l
ô

ô

ô

ô

ô

ô

ô
l
l
l
ô

ô

ô

ô

ô

ô

ô

ô

ô

ô
l
l
l

l
l
l
l
l
ô

ô
l
ô

ô
l

l

l
ô
l
l
l

1  No Board meetings were held during August and October 2022.
2 

Includes resolvability assessment framework, modern slavery and human trafficking, statement of business principles and code of conduct, regional 
updates and listing renewals.

3  Meeting attended by members of the Prudential Regulation Authority.

256

HSBC Holdings plc Annual Report and Accounts 2022

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. The 
Board intends to conduct an independent evaluation in 2023.

For 2022, the Nomination & Corporate Governance Committee 
agreed that the evaluation of the Board and its committees would 
again be conducted internally. The process included the completion of 
a questionnaire, issued 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, some based on themes from the 2021 evaluation 
findings. A summary of the effectiveness reviews of the Board and 
the Board committees can be found on page 258 and in the 
respective committee reports from page 259.

To gather qualitative feedback, the Group Company Secretary and 
Chief Governance Officer, together with the Deputy Group Secretary, 
conducted interviews with each questionnaire respondent, including 
all the Board Directors, regular attendees of the relevant meetings 
and key advisers. The Group Chairman and committee chairs also 
participated in additional discussions following the consolidation of 
feedback in respect of the individual committees. 

Overall, the work of the Board was rated highly and it was viewed as 
operating effectively. In general, there were consistent findings 
across the Board and committee reviews. These included: 

• a positive view of the effectiveness of the Chairs of the Board and

committees and the participation of its members;

• a greater desire to be even more forward looking;

Board and Committee evaluation process

• a need for continued focus on the quality of meeting materials to
ensure that content remains focused, clear and precise; and

• continued collaboration between the Board committees.

At its January 2023 meeting, the Group Chairman led a discussion 
with the Board and considered the findings. The following areas of 
focus were discussed and actions agreed: a revised approach to 
tracking strategy execution; continued development of the timeline of 
sustainability and technology deliverables; simplification and 
prioritisation of deliverables and interdependencies; and enhanced 
focus on customer stakeholder engagement.

Actions will be monitored and addressed on an ongoing basis. Similar 
discussions were led by each of the committee chairs in their 
respective January meetings. Progress against these actions will be 
included in the Annual Report and Accounts 2023.

During 2022, 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 their pay outcomes each year, is contained in the 
Directors’ remuneration report on page 276.

Agree 
approach

Complete
questionnaires

Conduct
interviews

Evaluate
findings

Agree action plan for 
2023 and disclosures
in the ARA

Report 
findings to the 
Board

Share findings
with 
Committee
Chairs

The Board made good progress against all of the action points 
identified during the 2021 evaluation. In particular, the Board:

• devoted time to the consideration of key areas of focus, including

digital opportunities and threats, ESG and strategic risk;

• enhanced its composition with the appointment of Geraldine

• continued to monitor compliance with the subsidiary accountability

Buckingham, which brought significant Asia leadership experience;

framework; and

• maintained a focus on succession planning, with a view to
strengthening its expertise in banking and improving its
representation from Asia;

• strengthened workforce engagement, with the appointment of
José Antonio Meade Kuribreña as designated non-executive
Director for workforce engagement;

• enhanced coordination and collaboration between its committees,
with combined meetings of the Group Audit Committee, Group
Risk Committee and Technology Governance Working Group held
during the year.

HSBC Holdings plc Annual Report and Accounts 2022

257

Corporate governanceReport of the Directors | Corporate governance report | Board committees

Summary of 2022 Board effectiveness findings and recommendations for action:

Findings from the evaluation

Recommendations for action

Strategy, 
execution and 
deliverables

• The Board’s strategic oversight was rated positively 
overall, although the consistency of management’s 
articulation, tracking and execution of progress against 
the Group’s strategy could be strengthened. It was 
recommended to increase the use of metrics to show 
comparable progress against key deliverables.

• The Board’s approach to the oversight of the Group’s 

sustainability strategy was rated positively, although the 
monitoring of sustainability-related key targets required 
greater clarity. 

• The Board’s oversight of technology strategy was 

considered strong and it was suggested that the Board 
required a more detailed plan of digital deliverables to 
enable continuous monitoring and performance tracking.

• The Group Chief Executive should develop a revised set of 

metrics related to performance, execution and risk management, 
as well as other key value drivers, as appropriate. 

• The Group Chief Executive and relevant accountable executives 

should develop a timeline of ESG and technology deliverables and 
milestones.

Simplification and 
prioritisation

• The importance of devoting sufficient time to 

• A Board session should be held annually on organisational 

challenging management’s progress on simplification 
and prioritisation was highlighted. It was suggested that 
the Board provide greater oversight of management 
prioritisation of key projects and strategic deliverables.

simplification and prioritisation of deliverables and 
interdependencies.

Stakeholder 
engagement

• Engagement with stakeholders was strong, including 
the focus on the employees, in the year. The Board 
asked that further enhancements be considered, in 
particular customers given the current macroeconomic 
headwinds. 

• The Board’s stakeholder engagement plan should be reviewed to 
ensure that all members of the Board have sufficient opportunity 
to engage with, and understand the views, of the Group’s key 
stakeholders. 

Meeting materials •

It was recognised that meeting materials had improved 
considerably over recent years, but it was emphasised 
there was opportunity for further improvement around 
consistency, comparability and ownership. Stakeholder 
considerations could be better incorporated in Board 
papers to support decision making.

• Training and/or guidance should be provided to all paper authors in 

2023.

258

HSBC Holdings plc Annual Report and Accounts 2022

 
Nomination & Corporate Governance Committee

Membership

Mark Tucker (Chair)
Geraldine Buckingham1
Rachel Duan2
Dame Carolyn Fairbairn
James Forese
Steven Guggenheimer
Irene Lee3
José Antonio Meade 
Kuribreña
Eileen Murray2
David Nish
Jackson Tai
Pauline van der Meer Mohr3

Member since

Meeting 
attendance in 2022

Oct 2017
May 2022
Sep 2021
Sep 2021
May 2020
May 2020
Apr 2018
Apr 2019

Jul 2020
Apr 2018
Apr 2018
Apr 2016

7/7
4/4
6/7
7/7
7/7
7/7
3/3
7/7

5/7
7/7
7/7
3/3

1  Geraldine Buckingham was appointed to the Board and joined the 

Committee on 1 May 2022.

2  Rachel Duan was unable to attend the July committee meeting due to 
a pre-existing engagement. Eileen Murray was unable to attend the 
April and September meetings for personal health reasons.
Irene Lee and Pauline van der Meer Mohr stepped down from the 
Board and the Committee following the conclusion of the AGM on 
29 April 2022.

3 

The Committee’s role in overseeing these changes is outlined on the 
following pages.

As we look ahead to 2023, the Committee will consider the changes 
to the UK audit, governance and regulatory regimes, including 
updates to the UK Corporate Governance Code, and the steps needed 
to ensure the Group continues to operate in line with best practice. 

Mark E Tucker

Chair

Nomination & Corporate Governance Committee

21 February 2023

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, the Group Chief Human Resources 
Officer, and the Group Head of Talent routinely and selectively 
attended Committee meetings. The Group Company Secretary and 
Chief Governance Officer attends all Committee meetings and 
supports the Group Chairman in ensuring that the Committee has 
fulfilled its governance responsibilities. 

Russell Reynolds Associates, which supported the Committee and 
the management team in relation to Board and senior management 
succession planning, regularly and selectively attended meetings 
during the year. It has no other connection with the Group or 
members of the Board.

HSBC Holdings plc Annual Report and Accounts 2022

259

"Developing our skills and experience, and diversity 
and inclusion ambitions remains a priority and the 
Committee will continue to oversee and enhance the 
succession pipeline at Board and senior leadership 
level.”

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. 

During 2022, the Committee continued to review the Board’s 
composition, succession planning, skills, experience and diversity, to 
ensure that the Group operated in line with its ambition of world class 
governance.

On behalf of the Board, the Committee oversaw a number of changes 
to Board composition, including the retirements of Pauline van der 
Meer Mohr and Irene Lee, and the appointment of Geraldine 
Buckingham. The Committee also closely monitored executive 
succession planning, in particular the transition of the Group Chief 
Financial Officer, with Georges Elhedery succeeding Ewen Stevenson 
from 1 January 2023. Ewen leaves with our sincere thanks for the 
significant contribution that he has made to the Board and to the 
broader Group over the past four years.

Jackson Tai will retire from the Board at the conclusion of our 2023 
AGM in May and will be succeeded as Chair of the Group Risk 
Committee by James Forese. On behalf of the Board, I wish to thank 
Jackson for his outstanding dedication and the significant contribution 
he has made to the success of the Group, in particular the 
improvement in our oversight and governance of risk and conduct. 
James' significant banking and risk experience will be invaluable in 
the leadership of the Group Risk Committee as the Group continues 
to deliver on its transformation and growth strategy, in a safe and 
sustainable manner.

On 1 March 2023, Kalpana Morparia will join the Board, strengthening 
both its collective Asia business and banking knowledge and 
experience, and diversity.

Developing our skills and experience, and diversity and inclusion 
ambitions of the Board and senior management, remains a priority 
and the Committee will continue to oversee and enhance the 
succession pipeline at Board and senior leadership level through 
2023. This will build on the revised gender and ethnic representation 
targets introduced within the diversity and inclusion policy, and the 
work led by management on developing successors for senior 
leadership roles and under the Asia Talent programme. Our Board 
diversity and inclusion policy, which contains our revised targets, can 
be found on hsbc.com.

During 2022, we also took the decision to establish a new Board role 
designated with responsibility for ensuring that the employee voice is 
strengthened within the Board’s deliberations. The creation of the role 
was a natural evolution of the work already undertaken to enhance 
stakeholder engagement within Board decision making. In this role, 
José Meade will lead our workforce engagement on behalf of the 
Board, supported by the Corporate Governance and Secretariat and 
Human Resource functions. Further details on the role and initial 
areas of focus can be found on page 253.

Corporate governance 
Report of the Directors | Corporate governance report | Board committees

Board composition and succession

The Committee continued its focus on ensuring that the Board and its 
members, both collectively and individually, possess the skills, 
knowledge and experience necessary to oversee, challenge and 
support management in the achievement of the Group’s strategic and 
business objectives.

In addition to the retirements of Irene Lee and Pauline van der Meer 
Mohr, the Board welcomed Geraldine Buckingham, who most 
recently held the position of Head of Asia-Pacific at BlackRock. She 
was appointed to the Board with effect from 1 May 2022. 

In October, the Group announced the appointment of Georges 
Elhedery as an executive Director and Group Chief Financial Officer 
with effect from 1 January 2023. This decision followed a review by 
the Committee of the composition of the Group Executive Committee 
with a particular focus on long-term succession planning. It was 
concluded, based on the recommendation of the Group Chief 
Executive, that Georges, who was previously co-Chief Executive 
Officer of Global Banking and Markets, should replace Ewen, who 
stepped down from the Board at the end of 2022. Georges, who has 
a track record of driving growth and managing change and who brings 
a strong focus on execution, will help the Group to accelerate delivery 
of improved financial performance and shareholder returns. 

In advance of taking up the role, Georges spent significant time with 
Ewen to ensure an orderly handover of responsibilities. The Board has 
put in place a tailored development and support plan for Georges as 
he transitions to his new role, which will be overseen by the 
Committee. 

The Committee expects that non-executive Directors serve two three-
year terms, with any appointments beyond this to be determined on 
an annual basis with reference to the needs of the Board and the 
performance and contribution of the individual. In view of the 
importance of continuity for key roles on the Board, particularly given 
the current economic and geopolitical environment, the Committee 
agreed that David Nish’s appointment should be extended for a 
further year to the 2024 AGM, subject to his re-election by 
shareholders. In taking this decision, the Committee considered the 
need for an effective transition in relation to the Senior Independent 
Director and Chair of the Group Audit Committee roles, both of which 
David currently holds. It is the Board’s strong belief that this 
extension of David’s appointment, given his performance and 
contribution to the Board during 2022, is in the best interests of the 
Group and all of its stakeholders.

As referenced in our 2021 report, the Committee agreed to prioritise 
in future appointments significant previous executive experience in 
banking, as well as with deep business and cultural expertise across 
Hong Kong and mainland China, and south-east Asia. A number of 
potential candidates meeting the desired skills and experiences were 
identified, a shortlist of which were considered and discussed by the 
Committee. Following meetings between various members of the 
Committee and priority candidates to understand their respective 
interests and capacities, the Board accepted the Committee’s 
recommendations and approved the appointments of Geraldine 
Buckingham with effect from 1 May 2022 and Kalpana Morparia with 
effect from 1 March 2023.

Strengthening the Board’s collective experience in these areas 
remains a priority, and the Committee will continue to discuss broader 
succession planning for key roles on the Board and committees 
through 2023, and beyond. In addition, succession planning will have 
regard to diversity and inclusion targets and expectations. The 
Committee is focused on identifying candidates with the following 
skills and experience for future appointments to the Board: 

• significant executive experience in banking;  

• deep business and cultural expertise across Asia, in particular 

Hong Kong and mainland China, and the Middle East, given the 
geographical mix of the Group’s business and the importance of 
these regions to the strategy and future growth; and

• previous public company leadership experience. 

260

HSBC Holdings plc Annual Report and Accounts 2022

The Committee will continue to monitor the market for potential 
candidates for appointment to the Board in both the short and 
medium term, to ensure that the Board has a pipeline of credible 
successors and continues to be equipped to effectively discharge its 
responsibilities. 
Board diversity

The Board recognises the importance of gender, social and ethnic 
diversity, and the strengths diversity brings to Board effectiveness. 
Diversity is taken into account in its broadest sense when considering 
succession plans and appointments at both Board and senior 
management level, as well as more broadly across the Group. 

Over the past 12 months, there has been significant focus on 
diversity at Board level, including as a result of the updated guidance 
and targets issued by the FTSE Women Leaders Review (formerly the 
Hampton-Alexander review) and the UK Listing Authority. The Board 
is supportive of the proposals and, in line with the Board diversity and 
inclusion policy, remains committed to increasing diversity at Board 
and senior levels to ensure we reflect the markets and societies we 
serve. This policy, which was updated in 2022 to incorporate new 
targets on female representation, details our approach to achieving 
our diversity ambitions, and ensures that diversity and inclusion 
factors are considered 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 2022, the Board had 33% female representation, with 
four female Board members out of 12. Following our recent 
announcement in relation to Kalpana Morparia and Jackson Tai, this 
leaves us on track to meet our aspirational target of at least 40% 
female representation on the Board by the end of 2023, ahead of the 
end of 2025 expectations set by the FTSE Women Leaders Review 
for gender representation on Boards.

The FTSE Women Leaders Review also published revised gender 
representation targets, specifically the expectation that a woman 
holds at least one of the senior Board positions of Chair, Chief 
Executive Officer, Senior Independent Director or Chief Financial 
Officer by the end of 2025. The Committee considers succession for 
these key Board roles on an ongoing basis and will take into account 
the need for greater diversity when considering candidates for 
appointment to these roles in future. At the end of 2022, all those 
holding these senior Board positions at the Group were male. The 
Board is committed to achieving this target by the review’s end of 
2025 deadline. 

The Board continued to exceed the Parker Review target of having at 
least one Director of diverse ethnic heritage, with three members of 
our Board self-identifying in line with the ethnicity/ethnic definition set 
by the Parker Review. Given the global and international nature of our 
business, including our strong presence and heritage in Asia, the 
Committee considers that the Board should comprise a greater 
proportion of diverse ethnic heritage Directors than anticipated by the 
Parker Review. The Board’s targets were revised to reflect this 
commitment and therefore to maintain or improve the current 
representation of directors from a diverse ethnic heritage. 

Further details on activities to improve diversity across senior 
management and the wider workforce, together with representation 
statistics, can be found on page 308.

Diversity of our principal subsidiary boards has also improved as a 
result of the Committee’s focus on succession planning and regular 
refreshment of subsidiary boards, with gender representation 
improving across all seven of our principal subsidiaries. The HSBC 
Bank Director Programme, delivered in partnership with IMD 
Business School during the first half of 2022, has also helped to 
prepare senior talent for roles on our subsidiary boards. A number of 
the graduates who participated in the programme have been provided 
with opportunities on subsidiary boards, enhancing the skills, 
experience and diversity of our subsidiary boards.  This programme 
will operate regularly with the next cohort scheduled to take place in 
2024. 

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 after consideration of 
all relevant circumstances that are likely to impair, or could appear to 
impair, independence.

In line with the requirements of the Hong Kong Corporate 
Governance Code, the Committee also reviewed and considered the 
mechanisms in place to ensure independent views and input are 
available to the Board. These mechanisms include: 

• having the appropriate Board and Committee structure in place, 
including rules on the appointment and tenure of non-executive 
Directors;

• facilitating the option of having brokers and external industry 

experts in attendance at Board meetings during 2022, as well as 
having representatives from the Group’s key regulators attend 
Board meetings in relation to specific regulatory items;

• ensuring non-executive Directors are entitled to obtain 

independent professional advice relating to their personal 
responsibilities as a Director at the Group’s expense;

• having terms of reference for each Committee and the Board 

provide authority to engage independent professional advisers; 
and

• holding annual Board and Committee effectiveness reviews, with 
feedback sought from members on the quality of, and access to, 
independent external advice.

Senior executive succession and 
development

The outputs from the annual capability review, including updated 
succession plans for the Group Executive Committee members, were 
considered and approved by the Committee in December 2022. 
These reflected continued efforts to support the development and 
progression of diverse talent and promote the long-term success of 
the Group, with the gender diversity and proportion of Asian heritage 
successors improving year on year. This included future internal and 
external succession options for the Group Chief Executive, to ensure 
that the Committee has a robust and actionable succession plan 
when required. 

The Committee also continued to receive updates on the 
development of our talent programme within the Asia-Pacific region. 

Matters considered during 2022

Since its launch in 2020, significant progress has been made towards 
ensuring that we have a deeper and more diverse leadership bench-
strength. Succession plans are more robust, with greater diversity and 
good succession fulfilment outcomes. 
Committee evaluation

The annual review of the effectiveness of the Committee was 
internally facilitated in 2022. The review concluded that, overall, the 
Committee continued to operate effectively and in line with regulatory 
requirements. However, a number of areas for enhancement were 
identified, including the need for a continued focus on succession 
planning for the Group Chief Executive, the Committee Chair, the 
Senior Independent Director and future non-executive Directors, 
ensuring plans supporting the Board’s objectives in relation to 
diversity and stakeholder needs. Other areas of focus included the 
continued identification of both internal and external talent, training 
requirements and the retention strategy for high performing 
individuals. Certain priority areas of focus for the Committee across 
2023 were suggested, including the continued monitoring of progress 
of governance within material and principal subsidiaries (as defined in 
the subsidiary accountability framework), and the need to review the 
external advisers supporting the Committee. The outcomes of the 
evaluation have been reported to the Board, and the Committee will 
track the progress in implementing recommendations during 2023. In 
line with the UK Corporate Governance Code, the 2023 Board and 
Committee performance review will be externally facilitated. 

The Committee has initiated the process for the selection of the 
independent board evaluator, with a decision on the evaluator to be 
taken within the first half of the year to allow the review to 
commence in the second half of 2023. A report on the process, 
findings and recommendations will be disclosed in the Annual Report 
and Accounts 2023. 

The Committee was kept updated on progress on actions agreed 
following its 2021 evaluation, which were all completed.
Subsidiary governance

In line with the subsidiary accountability framework introduced in 
2021, the Committee continued to oversee the corporate governance 
and succession arrangements across the principal and material 
subsidiary portfolio.  Where appropriate and subject to strong 
rationale, the Committee approved exceptions from strict compliance 
with the framework, including to reflect local law and regulation, as 
well as market practice. The Committee has reinforced its 
expectations that subsidiaries take steps to achieve full compliance 
with the framework, with any exception requests subject to thorough 
review and consideration by the Group Company Secretary and Chief 
Governance Officer in advance of consideration by the Committee.

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 

l Matter considered

ô Matter not considered

Jan

Feb

Apr 

May

Jul

Sep

Dec

l

ô

ô
ô
ô

l
l
l

l

ô

l
ô
l

ô
ô
ô

l

ô

l
ô
ô

ô
ô
l

l

ô

l
ô
ô

ô
ô
ô

ô

l

l
ô
ô

l
l
l

l

ô

l
ô
ô

ô
l
l

ô

ô

l
l
l

ô
l
l

HSBC Holdings plc Annual Report and Accounts 2022

261

Corporate governance 
Report of the Directors | Corporate governance report | Board committees

Group Audit Committee

Membership

David Nish (Chair)
Rachel Duan2
James Forese3
Eileen Murray4
Jackson Tai
Pauline van der Meer Mohr5

Member since

May 2016
Apr 2022
May 2020
Jun 2022
Dec 2018
Apr 2020

Meeting 
attendance
 in 20221
13/13
6/8
5/5
6/8
13/13
5/5

1  These included four joint meetings with the Group Risk Committee 

(‘GRC’) and the Technology Governance Working Group.
2  Rachel Duan was unable to join two meetings due to prior 
commitments made before becoming a GAC member. 
3  James Forese stepped down from the GAC on 1 June 2022.
4  Eileen Murray rejoined the GAC on 1 June 2022, and was unable to 

attend two meetings due to personal circumstances.

5  Pauline van der Meer Mohr retired from the Board on 29 April 2022. 

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 management’s arrangements for compliance with 

prudential regulatory 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. The Board also 
receives copies of the Committee agendas 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.  

"The Committee reviewed management's 
arrangements for compliance and assurance over 
regulatory reporting processes, and progress of 
HSBC-specific reviews of regulatory reporting."

Dear Shareholder

I am pleased to introduce the Group Audit Committee (‘GAC’) report 
setting out the key matters and issues considered in 2022. 

We welcomed Eileen Murray, who rejoined the GAC in 2022, and 
Rachel Duan, who was appointed to the Committee in April 2022. 
Pauline van der Meer Mohr stepped down from the Board and James 
Forese stepped down from the GAC to assume new Board 
responsibilities. I would like to thank them both for their support and 
insightful contributions to the work of the GAC.

The GAC continued to provide oversight of change and transformation 
programmes to enhance the Group’s internal controls over financial 
reporting. We challenged management on its forecasts and 
confidence in the delivery of externally communicated targets in an 
uncertain external environment. The Committee also reviewed 
management's arrangements for compliance and assurance over 
regulatory reporting processes, and progress of HSBC-specific 
reviews of regulatory reporting.

We continued to strengthen our relationships and understanding of 
issues at the local level through regular information sharing with the 
principal subsidiary audit committee chairs. This was supplemented 
with regular meetings with the principal subsidiary audit committee 
chairs to discuss key issues, and through their attendance at GAC 
meetings. I also joined a number of principal subsidiary audit 
committee meetings throughout the Group. 

The Group’s whistleblowing arrangements continue to satisfy 
regulatory obligations and I regularly met the whistleblowing team to 
discuss material whistleblowing cases. Efforts were made in 2022 to 
drive continuous operational improvements and to provide deeper 
insights to support our purpose, values and conduct approach. 
Actions were also taken to make use of best practices across 
investigative functions and to enhance the experiences of colleagues 
when they report concerns at HSBC.

The Committee oversaw the retendering for statutory audit services 
for the 2025 year-end. This process included detailed qualification 
activities, thorough evaluation of firms, consideration of evolving UK 
legislation and guidelines, and engagement with regulators. The GAC 
recommended to the Board that PwC be reappointed for a further 
term of 10 years commencing 1 January 2025.

The Committee implemented all the actions from the 2022 evaluation 
and the 2023 review determined that the GAC continued to operate 
effectively.  

David Nish

Chair

Group Audit Committee

21 February 2023

262

HSBC Holdings plc Annual Report and Accounts 2022

Matters considered during 2022

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
Audit plan updates, independence and effectiveness
External audit 
Reports from external audit, including external audit plan
Appointment, remuneration, non-audit services and effectiveness
Audit tender
Compliance
Accounting standards and critical accounting policies
Corporate governance codes and listing rules
Whistleblowing 
Whistleblowing arrangements and effectiveness

l Matter considered

ô Matter not considered

Jan

Feb

Apr

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Compliance with regulatory requirements

The Board has confirmed that each member of the Committee is 
independent according to the criteria from the US Securities and 
Exchange Commission, and the Committee continues to have 
competence relevant to the sector in which the Group operates. The 
Board has determined that David Nish, Jackson Tai and Eileen Murray 
are ‘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 continued to engage with regulators, including the 
UK’s PRA and the Financial Reporting Council. These included 
trilateral meetings involving the Group’s external auditor, PwC.

The Committee assessed the adequacy of resources of the 
accounting, internal audit, financial reporting and ESG performance 
and reporting functions. 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 GAC strengthened its working relationship with the principal 
subsidiary audit committees through formal and informal channels. 
The GAC Chair regularly met the chairs of the principal subsidiary 
audit committees to enable close links and deeper understanding on 
judgements around key issues. The GAC Chair attended a number of 
the principal subsidiary audit committee meetings and certain chairs 
of the principal subsidiary audit committees also joined meetings of 
the GAC during the year. 

This continuous engagement supported effective information sharing 
and targeted collaboration between audit committee chairs and 
management to ensure there was appropriate focus on the local 
implementation of programmes. Subsidiary audit committee chairs 
were also able to directly share local challenges, including regulatory 
expectations with Group management and the GAC Chair. 

On a half-year basis, principal subsidiary audit committees provided 
certifications to the GAC that regarded the preparation of their 
financial statements, adherence to Group policies and escalation of 
any issues that required the attention of the GAC. These certifications 
also included information regarding the governance, review and 

assurance activities undertaken by principal subsidiary audit 
committees in relation to prudential regulatory reporting. 

Internal controls 

The Committee devoted significant time in understanding the effect 
on financial reporting risk from high-impact programmes aimed at 
enhancing and enabling the transformation of the control environment 
to support financial, prudential regulatory and other regulatory 
reporting. The GAC provided detailed feedback and challenge to 
management on a number of aspects, including requesting external 
assurance, replanning and mobilisation of programme workstreams, 
resourcing and engagement throughout the Group and with 
regulators. Common themes from these discussions included the 
need to improve understanding and accountability for data capture, 
improve data quality from the implementation and embedding of data 
policies while ensuring there was a stronger appreciation throughout 
the Group of the downstream impact on financial and regulatory 
reporting. The oversight and implementation of these programmes 
and their component parts will remain a key focus for the Committee 
in 2023. 

The GAC 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 internal financial controls. These updates 
included the Group’s work on compliance with section 404 of the 
Sarbanes-Oxley Act. Based on this work, the GAC recommended that 
the Board support its assessment of the internal controls over 
financial reporting.  

For further details on how the Board reviewed the effectiveness of 
key aspects of internal control, see page 306.  

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 and Controls 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 2022

263

Corporate governance 
Report of the Directors | Corporate governance report | Board committees

• gave particular regard to the analysis and measurement of IFRS 9 
expected credit losses (‘ECL’), including the key judgements and 
management adjustments made in relation to the forward 
economic guidance, underlying economic scenarios and 
reasonableness of the weightings; 

• focused on compliance with disclosure requirements to ensure 
these were consistent, appropriate and acceptable under the 
relevant financial and governance reporting requirements; 

• provided advice to the Board on the form and basis underlying 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. 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 42.

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 2022 
and results announcements to enable input and comment. It was 
supported by the work of the Group Disclosure and Controls 
Committee, which also reviewed and assessed the Annual Report 
and Accounts 2022 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 UK and Hong Kong Corporate Governance Codes.

Key financial metrics and strategic priorities

The Committee assessed management’s assurance and preparation 
over external financial reporting disclosures, in particular the 
monitoring and tracking of key financial metrics and strategic 
priorities. In the second quarter of 2022, the Committee was involved 
at all stages in overseeing and challenging management on the 
revised financial targets. 

The GAC challenged management on the forecasting, analysis and 
additional assurance work undertaken to support the revised financial 
targets in light of geopolitical risks, deteriorating outlook, ongoing 
impact of the Covid-19 pandemic in certain jurisdictions and a rising 
interest rate environment. 

Further details can be found in the ‘Principal activities and significant 
issues considered during 2022‘ table on page 266.

ESG and climate reporting

The GAC, supported by the executive-level ESG Committee and 
Group Disclosure and Controls Committee, provided close oversight 
of the disclosure risks in relation to ESG and climate reporting, amid 
rising stakeholder expectations.  

The GAC tracked and monitored developments from a number of 
prominent consultations and considered them when reviewing the 
strategy and scope of ESG and climate disclosures in 2022. In 
particular, the Committee asked management to provide further 

details on the pipeline of mandatory regulatory and externally 
committed ESG and climate-related disclosures over the next 12 to 24 
months, including the delivery status. This allowed the Committee to 
consider management’s development of methodologies, tools and 
data solutions holistically to fulfil external disclosure requirements and 
commitments. 

ESG reporting is fast evolving with few globally consistent reporting 
standards and a high reliance on external data. The Committee 
focused on internal and external assurance in this area in line with 
wider market developments. 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, discussed the nature and root 
cause of issues identified through the increased assurance work, as 
well as proposals for further limited third-party assurance to be 
performed over specific ESG-related metrics.

Regulatory reporting

The Committee continued to focus heavily on the quality and reliability 
of regulatory reporting and oversight of key programmes to 
strengthen the end-to-end processes to meet regulatory expectations. 

Management provided updates on the status of ongoing HSBC-
specific external reviews, and discussed the issues and themes 
identified from the increased assurance work and focus on regulatory 
reporting. They also discussed root cause themes, remediation of 
known issues and new issues identified through the increased 
assurance work and focus on regulatory reporting. The GAC was 
instrumental in the initiation of a global programme designed to 
deliver consistent control frameworks for our regulatory reporting 
globally over the next few years. The Committee challenged 
management on remediation plans, to ensure there was a sustainable 
reduction in issues and that dependencies with other key 
programmes were well understood. The Committee Chair invited 
certain principal subsidiary audit committee chairs to GAC meetings 
to participate in discussions to ensure alignment and understanding of 
key issues and ongoing regulatory engagement.

UK audit reform

In May 2022, the UK government published its response to the 
consultation paper, ‘Restoring Trust in Audit and Corporate 
Governance’, on strengthening the UK’s audit, corporate reporting 
and corporate governance systems. This summarised the responses 
received to the consultation and set out the next steps towards 
implementation.

One of the key changes proposed is for large public interest entities, 
such as HSBC, to develop and publish an audit and assurance policy 
every three years, setting out the approach to assurance of 
information beyond the financial statements. The government will 
also introduce a new statutory resilience statement.

The Committee received updates on the outcome of the consultation 
and reviewed management’s proposed actions to support the future 
requirement for disclosure of an audit and assurance policy. This 
includes the work towards designing an integrated internal assurance 
approach across the three lines of defence, with the development 
during the year of an integrated assurance framework in support of 
the Group’s risk management framework.

While the legislation and expected guidance around the form and 
content of an audit and assurance policy is still being drafted, it is 
expected that the areas below will be covered by any future 
disclosures. Current disclosures exist in respect of certain of these 
areas, although these will need to be enhanced and expanded as 
guidance develops. The areas highlighted below are in addition to 
disclosures on the statutory audit and assurance work required by 
regulators.

264

HSBC Holdings plc Annual Report and Accounts 2022

Area

Overview of risk and internal control 
framework
Assurance over internal controls

Relevant current disclosure

Risk review, pages 131 to 238 

Risk review, pages 131 to 238, 
’Global Internal Audit’, page 266, and 
‘Internal controls’ page 306.

Specific information subject to 
assurance

Environmental, social and governance 
review, page 14 

Resilience statement
(currently viability statement)
External auditor engagement
Stakeholder engagement on audit 
and assurance policy

Long-term viability and going concern 
statement, page 42 
’External auditor’, page 265 
No existing disclosure.

The Committee continues to focus on ESG and regulatory reporting 
as areas for expanded assurance, in line with the risk assessment 
framework established in 2021. The specific external assurance over 
ESG disclosures is set out in the ESG review section of the Annual 
Report and Accounts. The Committee continued to respond to various 
regulatory engagement requests and surveys, including the Financial 
Reporting Council’s Draft Minimum Standards for Audit Committees. 
The Committee will continue to monitor developments as legislation 
is drafted to enact the requirements and the associated guidance is 
developed.

External auditor 

The GAC has the primary responsibility for overseeing the relationship 
with the Group’s external auditor, PwC.

PwC completed its eighth 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. Critical 
audit matters discussed with PwC are set out in its report on 
page 313.

External audit plan

The GAC reviewed the PwC external audit approach, including the 
materiality, risk assessment and scope of the audit. PwC highlighted 
the changes being made to their approach to enhance the quality and 
effectiveness of the audit. Changes for the 2023 audit included more 
auditing being performed centrally across legal entities. The 
Committee also focused on PwC's increased use of technology 
solutions, and received detailed briefings on its approach to data and 
analytics.

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. 

In addition, the GAC Chair, certain principal subsidiary audit chairs and 
members of the Group Executive Committee met with the Head of 
Audit, PwC UK to discuss findings from the questionnaire and provide 
in-depth feedback on the interaction with the PwC audit team. 

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 audit quality indicators focused on the 
following areas:

• findings from inspections across the Group and regulators 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. 

There were no breaches of the policy on hiring employees or former 
employees of the external auditor 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 2022. 

The Committee confirms it has complied with the provisions of 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, the GAC oversaw the 
retendering of statutory audit services for the 2025 year-end, 
including considering the tendering and shared audit proposals from 
the UK government’s consultation. More details on the audit tender 
can be found on page 267.

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 2023 will be proposed to shareholders at the 
2023 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 a conflict of interest. All 
non-audit services are either approved by the GAC, or by Group 
Finance when acting within delegated limits and criteria set by the 
GAC.

The non-audit services carried out by PwC included 73 engagements 
approved during the year where the fees were over $100,000 but less 
than $1m. Global Finance, as a delegate of the 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.

Eleven 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.

Auditors‘ remuneration
Total fees payable
Of which fees for non-audit services

2022
$m
148.1   
50.5   

2021
$m
129.4 
41.3 

HSBC Holdings plc Annual Report and Accounts 2022

265

Corporate governance 
 
Report of the Directors | Corporate governance report | Board committees

Global Internal Audit

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. The 
Group Head of Internal Audit reports to, and meets frequently with, 
the Chair of the GAC. In addition, in 2022, there was more interaction 
between Global Internal Audit senior management and the members 
of the GAC, aimed at increasing knowledge and awareness of the 
audit universe and existing and emerging risks identified by Global 
Internal Audit. Global Internal Audit adheres to The Institute of Internal 
Auditors’ mandatory guidance.

Consistent with previous years, the 2023 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. 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 2023 audit coverage remain as: strategy, 
governance and culture; financial crime, conduct and compliance; 
financial resilience; and operational resilience. A quarterly assessment 
of key risk themes will form the basis of thematic reporting and plan 
updates and will ultimately drive the 2024 planning process. 

In 2023, Global Internal Audit will maintain significant focus on the 
Group transformation portfolio, increase coverage of treasury risks, 
financial forecasting processes and regulatory reporting, and include 
coverage of ESG risk, with focus on climate commitments, 
operationalisation and reporting. In addition, Global Internal Audit will 
continue its programme of culture audits to assess the extent that 
behaviours reflect HSBC’s purpose, ambition, values and strategy, 
and expand its coverage of franchise audits for locally significant 
countries, following the development of the approach in 2022. 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.

The results of audit work, together with an assessment of the 
Group’s overall governance, risk management and control framework 
and processes are reported regularly to the GAC, GRC and local audit 
and risk committees, as appropriate. This reporting highlights key 
themes identified through audit activity, 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. 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.  

Executive management is responsible for ensuring that issues raised 
by Global Internal Audit 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.

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.

266

HSBC Holdings plc Annual Report and Accounts 2022

Principal activities and significant 
issues considered during 2022
Collaborative oversight by GAC, GRC and 
Technology Governance Working Group

The GAC and GRC worked closely to ensure there were procedures 
to manage risk and oversee the internal control framework. 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. 

A further development, based on 2022 evaluation findings, was to 
have joint meetings of the GAC, GRC and Technology Governance 
Working Group. These meetings would ensure there was coordinated 
oversight and consistent joint feedback to management on areas of 
significant overlap. 

Areas of joint focus for the GAC, GRC and the Technology 
Governance Working Group during 2022 were:

Finance on the Cloud

Finance on the Cloud is a key multi-year data and reporting 
transformation programme using Cloud technology to enable the 
transformation of the Global Finance operating model and re-
engineering of core reporting processes. 

The committees conducted a deep dive review of Finance on the 
Cloud and held multiple meetings throughout 2022 to challenge 
management on the programme’s overall objectives, scope and target 
end-state. As part of these discussions, the committees considered 
organisational realignment and programme leadership, and asked 
management to seek external assurance and validation of the Finance 
on the Cloud investment case and technology architecture. The 
committees also ensured that there was a greater understanding of 
the complexities and dependencies between Finance on the Cloud 
and other key programmes to ensure that deadlines for financial and 
regulatory reporting deliverables were met. 

Digital Business Services

The committees held a joint meeting to develop a deeper 
understanding of the risk and internal controls issues across key 
components of Digital Business Services. The joint meeting 
discussed: 

• the regulatory purpose of the service company structure, and 
management providing an update on initiatives to streamline, 
simplify and automate the services; 

• actions taken by the Identity and Access Management sub-

function to tackle access risks through automation and a new 
toolset;

• monitoring and governance activities carried out by the Global 
Operations and Payments teams, and its shift towards an 
automated control environment; and

• actions carried out within Global Procurement to enhance the risk 
management and control culture, in particular with regard to the 
oversight of critical third parties and its upgrade to a Cloud-based 
procurement platform. 

Embedding data into our culture

The committees reviewed and challenged the Group’s data strategy 
and the work required for the Group to embed its data policies, define 
the data technology landscape, and build a data-led culture. The 
committees also reviewed the Group's approach to harnessing and 
using data to better unlock value for our customers. 
Whistleblowing and speak-up culture

An important part of HSBC’s values is speaking up when something 
does not feel right. HSBC remains committed to ensuring colleagues 
have confidence to speak up and acting when they do. A wide variety 
of channels are provided for colleagues to raise concerns, including 
the Group’s whistleblowing channel, HSBC Confidential (see page 92 
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 arising from whistleblowing cases and the associated 
management actions. 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 continued to meet regularly throughout 2022 with the 
Group Head of Conduct, Policy and Whistleblowing, receiving 
briefings on material whistleblowing cases and the ongoing 
effectiveness of the whistleblowing arrangements. The Committee 
also received reports on actions being taken to further align our 
whistleblowing arrangements to actively support our purpose and 
values, and conduct approach. During 2023, the Committee will 
continue to be briefed on these actions, as well as the ongoing 
effectiveness of the HSBC Confidential channel.
Audit tender 

Following the conclusion of a formal competitive audit tender 
process, the Board has approved the re-appointment of PwC as 
external auditor of the statutory audits of HSBC Holdings for 2025 to 
2034, at which point we are required to rotate auditors in accordance 
with UK requirements. The audit tender process considered both 
large and challenger audit firms and was led by the GAC.

Scope

Process and assessment 

The shortlisted firms were invited to submit capability proposals 
(including written and data modelling exercises) to demonstrate their 
understanding of HSBC, audit quality, capabilities and their future 
vision of audit. Group and principal subsidiaries’ audit committee chair 
and management meetings took place during October 2022, enabling 
both the audit firms and HSBC management to articulate and discuss 
critical success factors for the audit. Lead audit partner referrals and 
audit quality reports from regulators supplemented these 
assessments and contributed to the final evaluation of the audit firms. 
The capability proposals were submitted on a fee blind basis, with the 
fee proposal submitted directly to the GAC Chair.

The Committee considered the following during the evaluation of 
audit firms:

• a tender proposal, a formal document in response to the tender 

requirements;

• management meetings between the firms and HSBC (major legal 

entity audit committee chairs and senior management);

• data exercises covering audit planning and risk assessment, ECL 
modelling, firms’ broader assurance offering and a shared audit 
exercise;

• public regulator audit reports for independent assessment on audit 

quality;

• external referees to provide a third-party opinion on the audit lead 

partner to support the evaluation process; and

• final presentations to the GAC.

As a UK public interest entity, we are required to tender our audit 
every 10 years and rotate our auditor every 20 years. We disclosed in 
our Annual Report and Accounts 2021 the intention to commence an 
audit tender, given PwC were initially appointed for the audit of the 
Annual Report and Accounts 2015.

As part of the tender process, the GAC Chair also met with Chief 
Executive and Head of Standards of the Financial Reporting Council to 
explain our audit tender process, understand views on shared audits 
and seek input into our evaluation of individual firm’s audit quality 
track record.

Pursuant to the tender, interested and qualified parties were invited to 
submit proposals for the right to provide statutory audit services to 
HSBC Holdings and its subsidiaries for a period of 10 years 
commencing from the financial year ending 31 December 2025.

HSBC’s primary objective was to ensure a fair and transparent tender 
process and appoint the audit firm that will provide the highest quality 
in the most effective and efficient manner. Firms were assessed 
against detailed criteria which considered audit quality, capacity and 
capability, understanding of HSBC and future audit vision. Input was 
sought from principal subsidiaries’ audit committee chairs as part of 
the GAC evaluation. Management views were advisory only to the 
GAC.

In accordance with best practice corporate governance requirements, 
the audit tender process described below was designed and led by 
the GAC, with direct involvement of the GAC Chair at every stage.

Pre-qualification

HSBC undertook a series of pre-qualification activities to identify 
vendors that satisfy our minimum requirements relating to credibility, 
capacity and independence. These activities were overseen by the 
GAC. The pre-qualification phase considered both large and challenger 
audit firms and explored the possibility of adopting a managed, shared 
audit using challenger firms.

During the pre-qualification phase, we were informed by two of the 
large audit firms that they were not able to participate in the tender as 
they believed they had insufficient capacity to perform a quality audit. 

Three shortlisted audit firms were invited to respond to the formal 
tender, including PwC and one challenger audit firm.

Evaluation 

The key evaluation criteria and their respective weightings used to 
assess the successful audit firm were proposed by management and 
reviewed by the Group Audit Committee. The criteria were assessed 
through formal capability proposals, presentations and certain 
supplementary evidence:

• Audit quality (30%) – regulatory evaluation, methodology, risk 

assessment, technology.

• Capacity and capability (30%) – footprint, partner quality and 

rotation, diversity, independence.

• Future audit vision (20%) – future audit developments, audit 

reform and innovation.

• Understanding of HSBC (20%) – knowledge of HSBC, shareholder 

concerns and the financial services landscape.

Final decision

The GAC considered various data points from the assessments 
outlined above, adopting a scorecard approach to supplement the final 
presentations made by the audit firms at the end of the tender 
process. The Committee considered the merits of appointing a 
challenger audit firm in a managed shared audit capacity, in line with 
recent UK government proposals. However, it did not have sufficient 
confidence that the desired audit quality outcomes could be assured 
in a such a large, complex, integrated and global organisation to 
pursue such an arrangement.

The GAC presented two audit firms to the Board for consideration of 
awarding the tender, recommending the re-appointment of PwC 
given their strong performance against our evaluation criteria and the 
benefits of continuity in this period of strategic change and 
uncertainty in the external environment.

The Board made a final decision to award the audit tender to PwC on 
19 January 2023. PwC will continue to be subject to annual 
performance reviews (including annual effectiveness surveys and 
analysis of relevant audit regulator findings) in the period up to 2025 
to support the annual AGM auditor re-appointment requirement.

HSBC Holdings plc Annual Report and Accounts 2022

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Principal activities and significant issues considered during 2022

Areas of focus Key issues

Financial and 
regulatory 
reporting

Significant 
accounting 
judgements

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 2022 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 
2022, there remains an elevated degree of 
uncertainty over ECL estimation under current 
conditions, due to macroeconomic and political 
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. 

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.

Investments in subsidiaries
Management has reviewed investments in 
subsidiaries for indicators of impairment and 
conducted impairment reviews where relevant. 
These involve exercising significant judgement 
to assess the recoverable amounts of 
subsidiaries, by reference to projected future 
cash flows, discount rates and regulatory 
capital assumptions. 

Conclusions and actions
In exercising its oversight, the Committee assessed management’s assurance and 
preparation of external financial reporting 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 and facilitated emissions, and thermal coal exposures. The 
Committee considered the key limitations and challenges relating to governance, 
processes, controls and data underpinning climate reporting. The Committee also 
discussed the nature and root cause of issues identified through the increased 
assurance work and ongoing enhancements to the governance, processes, controls 
and data underpinning climate reporting, which resulted in the deferral of disclosures 
on facilitated emissions and thermal coal. 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 further independent external reviews of various aspects of 
regulatory reporting. The Committee discussed and provided feedback on 
management’s engagement plans with the Group’s regulators, including any potential 
impacts on some of our regulatory ratios. We continue to keep the PRA and other 
relevant regulators informed of our progress.

The measurement of expected credit losses involves significant judgements, 
particularly under current economic conditions. There remains an elevated degree of 
uncertainty over ECL estimation under current conditions, due to macroeconomic, 
and political uncertainties.
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 the 
Russia-Ukraine war, inflation, supply chain disruption risks, China commercial real 
estate and Covid-19, 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 cash flows 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.

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. 

The GAC reviewed the judgements in relation to the impairment review of HSBC 
Overseas Holdings (UK) Limited, and the key inputs underpinning the recoverable 
amounts of its subsidiaries.

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HSBC Holdings plc Annual Report and Accounts 2022

Principal activities and significant issues considered during 2022 (continued)

Areas of focus Key issues

Significant 
accounting 
judgements

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. 

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 2022, 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 implications of the Russia-Ukraine 
war, disrupted supply chains globally and 
slower Chinese economic activity, 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 
expected outcomes relating to uncertain tax 
treatments.

Impact of acquisitions and disposals
In 2022, HSBC engaged in a number of 
business acquisition and disposal activities, 
notably in Canada, 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.

Conclusions and actions
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.

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 also considered the impact of changes in key assumptions 
on other schemes.

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 Canadian and French 
retail businesses, management's judgements in relation to classification as held for 
sale, and the timing of the accounting recognition of these transactions. The GAC 
also considered the financial and accounting impacts of other acquisitions and 
disposals.

HSBC Holdings plc Annual Report and Accounts 2022

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Principal activities and significant issues considered during 2022 (continued)

Areas of focus Key issues

Transformation and sustainable control 
environment
The GAC will oversee the impact on the risk 
and control environment from the Group 
transformation programme.

Group 
transformation

Global Finance transformation
The Committee reviewed the proposals for the 
Global Finance organisational design, the 
migration to Cloud and the impact on financial 
controls. 

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.

Conclusions and actions
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, to oversee progress of the transformation programme and the 
continued embedding of the broader change framework.  

In these updates the Committee monitored the progress of the programme, focused 
on the continued implementation of the change framework and the progress in the 
management of the entire change portfolio. This oversight helped the Committee to 
understand the progress being made in the management of the change portfolio, 
through the implementation of the change framework. The committee noted the 
progress on simplifying our change inventory, greater rigour on tracking progress 
against committed business cases, and strengthening of the lessons learnt process.
Management’s updates were supplemented by further focus and assurance work 
from Global Internal Audit where a dedicated team continuously monitored and 
reviewed the Group transformation programme. This included carrying out targeted 
audit reviews, in addition to audits of significant programmes.
The Committee has oversight for the adequacy of resources and expertise, as well as 
succession planning for the Global Finance function. During 2022, the Committee 
dedicated significant time to the review and progress of the multi-year Global Finance 
transformation programme, particularly Finance on the Cloud, with the overall 
objectives being to improve the control environment and customer outcomes and to 
make use of technology to increase overall efficiency. 

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.

During 2022 management provided updates to the Committee on preparations for the 
implementation of IFRS 17, which is effective from 1 January 2023 with one year of 
comparative restatements required. The Committee was updated on the production 
of the transition balance sheet and considered the financial impacts (for which a 
summary is provided within the Future Accounting Developments section of the 
Basis of Preparation on page 335), as well as the generation of comparative income 
statement estimated impacts (for which a high level summary based on estimated 
1H22 results is provided on page 99). The Committee also received updates with 
respect to progress on implementing the supporting operational infrastructure, 
internal controls over financial reporting, key judgements considered including 
transition approaches selected, as well as plans for disclosure of related non-GAAP 
measures and key performance metrics. 

The first publication of results on an IFRS 17 basis will be at the 1Q23 Earnings 
Release, and the Committee noted that management intends to publish an IFRS 17 
Transition statement together with that announcement. 

The Committee received an update on the progress and impact of the Basel III 
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 and also on a 
staggered basis across each jurisdiction. The discussion highlighted the 
dependencies of the Basel III programme with other Group transformation 
programmes, in particular the dependency on adoption of the Finance on the Cloud 
solution, risk model development and the impact on data delivery and storage. 

The Committee noted the completion of the programme restructure, reviewed the 
ongoing management of risks, issues and dependencies and challenged 
management to prioritise deliverables across each jurisdiction in line with regulatory 
timelines, in each case, to ensure that solutions delivered to the minimum required 
standards. The Committee noted the overall improved status of the programme and 
requested an update post the Office of the Superintendent of Financial Institutions 
Canada implementation date of 1 April 2023.

Committee evaluation and effectiveness 
The annual review of the effectiveness of the Board committees, 
including the GAC, was conducted internally in 2022, led by the Group 
Company Secretary and Chief Governance Officer. Overall, the review 
concluded that the GAC continued to operate effectively. The Chair’s 
management of meetings and leadership of the audit tender process, 
in particular, were rated highly. The review also made certain 
recommendations for continuous improvement. These included a 
need for continued focus on the quality of reporting, oversight of 
prioritisation of key programmes, and continued coordination between 
the GAC and other Board committees on topics of mutual interest. It 
was also suggested that the Committee should dedicate more time to 
the oversight of capacity and succession planning in the Finance and 
Internal Audit functions. 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 2023.

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HSBC Holdings plc Annual Report and Accounts 2022

Focus of future activities 
In 2023, the Committee will prioritise control remediation and 
enhancements, particularly of controls supporting regulatory 
reporting. This will include developing a deeper understanding of the 
prioritisation and interdependencies in the delivery of key 
transformation and regulatory programmes to strengthen the risk and 
control environment. It will also monitor domestic and worldwide tax 
policy developments and examine the potential impact on accounting 
judgements. 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. Along with other committees of the Board, 
the Committee will continue to ensure root cause themes related to 
understanding and accountability for data capture, data quality and the 
implementation and embedding of data policies are addressed by 
management.

Group Risk Committee 

"The GRC closely monitored heightened geopolitical 
and macroeconomic headwinds throughout the year 
to anticipate potential impacts to the Group‘s 
revenue, capital base and continuing ability to support 
customers."

Dear Shareholder

I am pleased to present the Group Risk Committee (‘GRC’) report.  

Geopolitical risks and the macroeconomic outlook deteriorated rapidly 
at the start of the year due to the Russia-Ukraine war. The GRC 
closely monitored heightened geopolitical and macroeconomic 
headwinds throughout the year to anticipate potential impacts to the 
Group’s revenue, capital base and continuing ability to support its 
customers. Measures included monitoring the Group’s preparedness 
for an expected recession in key markets from rising inflation and 
interest rates. The Committee embraced management’s development 
of forward-looking sensitivity analysis to assess the potential impacts 
on HSBC’s prudential position, franchise resilience and ability to 
support customers.

The GRC worked closely with the Group Chief Risk and Compliance 
Officer to strengthen the Group’s risk management framework, and 
to promote the development of more dynamic and granular risk 
appetite statements to manage HSBC’s risk profile.

Throughout the year, the GRC reviewed and challenged management 
on the Group’s regulatory submissions, including the Bank of 
England’s requirements for the Resolvability Assessment Framework, 
internal capital adequacy assessment process (‘ICAAP’) and internal 
liquidity adequacy assessment process (‘ILAAP’). The GRC had 
primary non-executive responsibility for reviewing the outcomes of 
regulatory stress tests, including the Bank of England’s climate 
biennial exploratory scenario, and the 2022 annual cyclical scenario 
exercise.

The GRC carefully considered the Group’s regulatory remediation and 
change programmes, and helped direct management to better 
prioritise and understand where there are interdependencies. In 
particular, the GRC reviewed and challenged the Group’s data 
management plans and interest rate risk in the banking book strategy. 
The GRC also provided oversight and support to risk transformation 
activities to develop stronger risk management capabilities and 
outcomes across the Group.

The GRC continued to review its committee composition, skills and 
experience. In June, we welcomed Geraldine Buckingham and James 
Forese as new members, and we expressed sincere gratitude to José 
Antonio Meade Kuribreña and Eileen Murray, who stepped down to 
assume new Board governance responsibilities.

Jackson Tai

Chair

Group Risk Committee

21 February 2023

Membership

Jackson Tai (Chair)
Geraldine Buckingham2
Dame Carolyn Fairbairn3
James Forese4
Steven Guggenheimer5
José Antonio Meade Kuribreña6
Eileen Murray7
David Nish8

Member since

Sep 2016
June 2022
Sep 2021
June 2022
May 2020
May 2019
Jul 2020
Feb 2020

Meeting attendance 
in 20221
18/18
11/11
17/18
12/13
16/18
10/10
7/9
16/18

1  These included seven scheduled meetings, five ad hoc meetings, four 
joint meetings with the Group Audit Committee and the Technology 
Governance Working Group, and two joint meetings with the Group 
Remuneration Committee. 

2   Geraldine Buckingham joined the GRC on 1 June 2022.
3  Dame Carolyn Fairbairn was unable to attend one meeting due to a 

prior commitment.

4  James Forese joined the GRC on 1 June 2022. He was unable to 

attend one meeting due to a prior commitment. 

5  Steven Guggenheimer was unable to attend two meetings due to 

personal circumstances. 

6  José Antonio Meade Kuribreña stepped down from the GRC on 1 June 

2022.

7  Eileen Murray stepped down from the GRC on 1 June 2022. She was 

unable to attend two meetings due to personal circumstances. 

8  David Nish was unable to attend two meetings due to a prior 

commitment. 

Key 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 include:

• overseeing and advising the Board on all risk-related matters, 

including financial and non-financial risks;

• advising the Board on risk appetite-related matters, and key 

regulatory submissions;

• reviewing the effectiveness of the Group’s risk management 
framework and internal controls systems (other than internal 
financial controls overseen by the GAC); 

• reviewing and challenging the Group’s stress testing exercises; 

and

• overseeing the Group’s approach to conduct, fairness and 

preventing financial crime.

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 Human Resources Officer, 
Group Chief Legal Officer, Group Head of Internal Audit, Group Head 
of Finance and Group Head of Risk Strategy and Macroeconomic Risk 
are standing attendees at GRC meetings. 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 six scheduled GRC meetings in 2022, 
reaffirmed the ownership and accountability of risks in the first line of 
defence.

The Chair meets regularly with the Group Chief Risk and Compliance 
Officer to discuss priorities and track progress on key actions. The 
Chair also has regular meetings with members of senior management 
to discuss specific risk matters that arise outside formal meetings. 
The Chair also meets regularly with the GRC Secretary to ensure the 
GRC addresses its governance responsibilities. A summary of 
coverage is set out in the ’Matters considered during 2022’ table on 
page 272.

HSBC Holdings plc Annual Report and Accounts 2022

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Matters considered during 2022

Jan

Feb

Mar

Apr

May

Jun

Jul

Sep

Oct

Dec

Holistic enterprise risk monitoring including 
Group risk profile1
Risk framework and/or policies 
Treasury risk
Wholesale/retail credit risk
Financial reporting risk
Resilience risk (including IT and operational risk)
Financial crime risk
People and conduct risk
Regulatory compliance risk
Legal risk
Model risk
ESG risk

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l Matter considered

ô Matter not considered

1   The GRC receives updates on all risk types through the Group risk profile, which is presented to the majority of meetings. The Committee also met 
with the Group Chief Risk and Compliance Officer and Risk and Compliance Executive Committee members in November 2022 to review the GRC 
agenda, particularly matters relating to risk transformation, financial crime and conduct. 

How the Committee discharged its 
responsibilities

Activities outside formal meetings

The GRC held a number of meetings outside its regular schedule to 
facilitate deeper and 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 risk transformation, interest rate risk in the banking book, 
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 2022’ 
table starting on page 273.  

Connectivity with principal subsidiary risk committees 

During 2022, 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 a connectivity meeting 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 principal 
subsidiaries at its regular meetings and continued to review escalated 
reports and 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 risk management and 
internal control systems had been operating effectively. 

These interactions furthered the GRC’s understanding of the risk 
profile of the principal subsidiaries, leading to more comprehensive 
review and challenge by the GRC.  

Engagement with the Risk and Compliance Executive 
Committee 

During 2022, the GRC met with the Risk and Compliance Executive 
Committee to promote information sharing and encourage active 
engagement with executive management.

During the engagement meeting, the GRC developed a better 
understanding of the efforts to strengthen our capabilities across the 
Group Risk and Compliance function. There were also in-depth 
discussions on the efforts to embed the right risk culture into our 
global operations to support our transformation activities. The 
engagement also promoted a healthy working relationship between 
GRC members and executive management.

Collaborative oversight by the GRC, GAC and Technology 
Governance Working Group

The GRC worked closely with the GAC and the Technology 
Governance Working Group to address any areas of significant 
overlap, and to oversee risk more comprehensively through inter-
committee communications and joint meetings. 

The GRC, GAC and the Technology Governance Working Group 
convened on four occasions to consider the Group's data strategy and  
ambitions, the Finance on the Cloud transformation programme, and 
internal control issues across key components of  Digital Business 
Services. 

Further details on each of these sessions can be found under the 
’Collaborative oversight by the GAC, GRC and Technology 
Governance Working Group’ section of the GAC report on page 266.

The committees worked closely to ensure appropriate alignment in 
the review, discussion, challenge and conclusions on topics including 
risk and control issues relating to Digital Business Services, and the 
transition of core capabilities to the Cloud. This ensured that the 
committees benefited from each other’s expertise and challenge. The 
GRC Chair also included the GAC Chair for pre-meetings on technical 
matters such as interest rate risk in the banking book and stress 
testing. 

Coordination between the GRC, GAC and the Technology Governance 
Working Group is supported by cross-membership. The GRC and GAC 
Chairs are members of both committees in order to strengthen 
connectivity and the flow of information between the committees. 
The GRC Chair is also a member of the Technology Governance 
Working Group, and each of the co-Chairs of the Technology 
Governance Working Group are members of the GRC and GAC, 
respectively. 

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Principal activities and significant issues considered during 2022

Risk areas

Holistic 
enterprise risk 
monitoring, 
including 
Group risk 
profile

Risk 
framework/
policies

Key issues
Geopolitical and macroeconomic risks continue 
to present significant challenges to revenue 
growth, operational resilience, and our 
commitment to serve customers and local 
markets. 

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 achievement of strategic goals.

The Group takes active steps to safeguard its 
capital and liquidity positions. 
It also performs internal and regulatory stress 
tests to measure its resilience and performance 
against stress, and to consider strategic 
management actions that could be applied 
against anticipated stress events and headwinds.
The Group is also required to show how its 
resolution strategy could be carried out in an 
orderly way, and identify any risks to successful 
resolution.

Treasury risk,  
including 
stress testing 
and recovery 
and resolution

HSBC faces risk from the possibility of losses 
resulting from the failure of a counterparty to 
meet its agreed obligations to pay the Group. 

Wholesale/
retail credit risk

Conclusions and actions

The GRC closely monitored global geopolitical and macroeconomic risks that could 
impact the Group’s strategy, business performance or operations. These risks 
were exacerbated by the Russia-Ukraine conflict and by related regulatory and 
reputational risks impacting our operations globally.  
The GRC continued to track top and emerging risks, our risk appetite and other 
management information metrics, as well as other early warning measures to 
understand sensitivities and the likelihood of the potential impact to our 
operations, customers and stakeholders. The GRC encouraged management to 
examine and maintain a timely and up-to-date book of strategic management 
actions. 

The GRC maintained oversight of the Group’s risk management framework and 
changes to the Group’s risk appetite statements, which provided the basis for the 
Committee’s interactive review of financial and non-financial risk management 
information at each scheduled GRC meeting. The GRC continued to promote the 
development of more dynamic and granular risk appetite statements that were 
forward looking and risk-responsive. The GRC provided oversight for the linkage 
between risk appetite statements with the Group’s corporate strategy, stress 
testing, financial resource plan, as well as the Group’s move towards stronger, 
sustainably higher returns for shareholders. The GRC recommended changes to 
the Group’s risk appetite statement, including in the areas of interest rate risk in 
the banking book, insurance risk, climate risk, resilience risk, financial crime risk, 
regulatory compliance and liquidity risk.    

The GRC reviewed the Group’s ongoing treasury, capital and liquidity risk 
management activities, including early warning indicators, scenario stress testing, 
interest rate risk in the banking book (’IRRBB’) strategy and remediation activity, 
capital and liquidity reporting, and capital and liquidity adequacy. 
The GRC conducted its annual review, challenge and recommendation of the 
Group’s ICAAP and ILAAP to the Board for approval. GRC members previewed the 
ICAAP and ILAAP submissions in depth, with input from principal subsidiary risk 
committee chairs as appropriate. The GRC evaluated the Group’s IRRBB strategy 
and progress on the multi-year liquidity improvement programme. The GRC will 
continue to monitor the Group’s IRRBB strategy closely through regular updates in 
2023. In relation to stress testing exercises, the GRC reviewed the Bank of 
England’s 2022 annual cyclical scenarios, and following a detailed review of 
principal subsidiary and global businesses inputs, approved the results of the 2022 
annual cyclical scenario exercise in December 2022. The GRC also reviewed the 
implications of the results of the severely adverse scenario stress test from the 
Federal Reserve’s Comprehensive Capital Analysis and Review in relation to HSBC 
North America Holdings, and considered actions being progressed by management 
in response.
The GRC continued its oversight of the Group’s progress in developing its 
capabilities against the Bank of England’s requirements for recovery and 
resolvability. In 2022, the GRC reviewed and challenged the Group recovery plan, 
including with an assessment of the financial resources and recovery capacity 
needed to stabilise the Group. The GRC considered views of all lines of defence to 
determine credibility and ability to execute the plan. In advance of the review by 
the GRC, the GRC and GAC Chairs met with management to consider the principal 
subsidiary risk committee components.
The GRC was heavily involved in the governance of the resolvability assessment 
framework (‘RAF’). This included oversight of the addendum to the Group’s RAF 
self-assessment that set out HSBC’s progress since submission of the original 
self-assessment in October 2021. The GRC also reviewed the RAF public 
disclosure prior to its submission, and considered remedial actions to address the 
feedback provided by the Bank of England.  
In addition, the GRC assessed the adequacy of the recovery and resolution 
planning programme that is expected to deliver improvements, in line with 
management expectation and the PRA’s feedback.

The GRC reviewed updates on the strategy and approach to managing credit risk 
and credit risk capabilities. The GRC 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 of a likely recession in our key markets due to rising inflation 
and interest rates to assess management’s readiness and approach to drive 
stronger credit risk management practices. The GRC continued its emphasis on 
building even stronger credit capabilities for specialty sectors, the development of 
stronger portfolio management capabilities and further improving the Group’s 
credit risk culture. 

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Principal activities and significant issues considered during 2022 (continued)

Risk areas

Financial 
reporting risk

Key issues
HSBC is exposed to the risk where controls 
supporting the reporting of its financial 
statements are not effective, resulting in material 
error or misstatement.

Resilience risk 
(technology 
and operational 
risk)

Resilience risk is where we may be unable to 
provide our customers with critical business 
services due to significant disruption.  
Technology risk is where there may be 
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 operational resilience programme defines 
the Group’s policies and practices to strengthen 
its ability and readiness to serve customers in the 
event of unforeseen disruptions in key markets.

Conclusions and actions
The GRC receives regular reports on entity level control assessments to enable the 
oversight of the effectiveness of such controls in support of the Group's financial 
reporting. The GRC also receives notable audit reports that provide an assessment 
of control effectiveness, where applicable. While the GAC assumes primary 
responsibility for the oversight of financial reporting capabilities, the GAC 
collaborated with the GRC and the Technology Governance Working Group to 
assess the progress in developing these capabilities.  Further details on the joint 
meeting are included in the ’Collaborative oversight by the GAC, GRC and 
Technology Governance Working Group’ section on page 272.

The GRC continued its oversight of the Group’s implementation of operational 
resilience capabilities in line with PRA and FCA policies. The GRC reviewed and 
challenged the operational resilience self-assessment against regulatory 
expectations, and worked with management to ensure that ownership and the 
delivery of resilience outcomes were embedded within the business and with 
function leaders. The GRC advocated for the early adoption of operational 
resilience requirements across key markets and businesses. The GRC will oversee 
the progress in extending the programme of operational resilience globally 
throughout 2023. 

The GRC regularly reviewed reports on the Group’s technology risk profile, as well 
as reports on cybersecurity risks. The GRC also maintained a strong focus on 
understanding the Group’s data risk landscape, its data strategy and data 
management programme.

Financial crime 
risk

The Group is committed to closely monitoring 
and managing the risk that HSBC’s products and 
services will be exploited for criminal activity, 
including fraud, bribery and corruption, tax 
evasion, sanctions and export control violations, 
money laundering, terrorist financing and 
proliferation financing.  

The GRC continued to review the Group’s approach to managing its financial crime 
risk across geographies and businesses. This included reviewing the Group’s 
progress in enhancing its transaction monitoring framework, as well as monitoring 
the fraud landscape and the strategies for managing such risk.

In light of the Russia-Ukraine war, 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 multiple and differing sanctions regimes globally.

People and 
conduct risk

Regulatory 
compliance 
risk

Legal risk

Model risk

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 GRC monitored people risk and employee conduct, with support from the 
Group Chief Human Resources Officer and Group Chief Risk and Compliance 
Officer. The GRC considered people risk issues with a focus on capacity, 
capability, culture and conduct. It also considered remuneration risks, and 
strategies to retain talent and acquire new capabilities and skills in key areas. 

The GRC also placed strong emphasis on policies and practices relating to conduct 
and fairness to customers, especially on vulnerable customers given heightened 
macroeconomic pressures and stress on customers across markets.  
The GRC and Group Remuneration Committee met jointly in September and 
December, and reviewed the Group’s risk and reward alignment framework to 
promote sound and effective risk management in meeting PRA and FCA 
remuneration rules and expectations.

The Group operates in multiple jurisdictions, and 
is exposed to risks associated with inappropriate 
market conduct or breaching related financial 
services regulatory standards or expectations. 

The GRC receives feedback from regulators, and monitors the progress of any 
regulatory remediation activities, with the support from the Group Chief Risk and 
Compliance Officer as well as principal subsidiary risk committee chairs. During 
the year, the GRC had oversight over reports providing feedback from regulators, 
including a summary of regulatory deliverables to ensure HSBC remains in line 
with regulatory standards and expectations.

HSBC is exposed to the risk of financial loss, 
legal or regulatory action resulting from 
contractual risk, dispute management risk, 
breach of competition law or intellectual property 
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.

The GRC oversees and receives regular updates on key legal developments and 
material legal issues from the Group Chief Legal Officer. The updates also cover 
material litigation and regulatory enforcement matters and an overview of the legal 
risk profile of HSBC.

The GRC continued to oversee the Group’s progress in managing model risk 
through the Group Chief Risk and Compliance Officer’s Group risk profile report. 
The GRC oversaw the progress in achieving our model risk vision and the 
strengthening of our model risk management capabilities. In particular, the GRC 
reviewed model risk deliverables against external review findings, improvements 
made to enhance first line of defence engagement in the model lifecycle, progress 
made to transform the Model Risk Management function and the implementation 
of new global model risk policy and standards.

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Principal activities and significant issues considered during 2022 (continued)

Risk areas

ESG risk

Key issues
Successful delivery of our climate ambition will 
be determined by our ability to measure and 
manage all components of environmental, social 
and governance (’ESG’) risk, including climate 
risk.

Conclusions and actions
The GRC remained focused on ESG risk, including climate risk, and has reviewed 
quarterly reports on climate risk management, while maintaining oversight of 
delivery plans to ensure that the Group develops robust climate risk management 
capabilities.  The GRC also has oversight over ESG-related initiatives and reviews 
these to assess the risk profile.

The GRC approved the Group’s climate biennial exploratory scenario stress test 
submission to the PRA in March 2022. In preparation, the GRC reviewed the 
scenario and considered planned engagement with clients, strategic 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.

Committee evaluation 

Focus of future activities

During 2022, the GRC implemented the recommendations of the 
external committee evaluation conducted by Lintstock in consultation 
with the Group Company Secretary and Chief Compliance Officer in 
December 2021. This included strengthening the focus of meeting 
agendas, and continuing the GRC’s engagement with the Risk and 
Compliance Executive Committee 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 2022. 
The evaluation concluded that the GRC continued to operate 
effectively and in line with regulatory requirements, and identified 
enhancements. The outcomes of the evaluation have been reported 
to the Board, and the GRC will track the progress in implementing 
recommendations during 2023.

The GRC’s focus for 2023 will include the following activities. It will:

• oversee risk transformation activities to develop even stronger risk 

management capabilities;

• oversee the continued enhancement of the Group's risk appetite 
and risk management framework, especially in light of continued 
geopolitical and macroeconomic headwinds;

• continue to oversee treasury risk to strengthen our capital and 

liquidity management capabilities, including proactive management 
of interest rate risk in the banking book;

• continue to review and challenge the consistency of our risk 

appetite statements, our financial resource plan, and the outcomes 
from our stress testing exercise;

• monitor our ESG progress, including the delivery against the 

climate commitments and the development of appropriate data 
and model management tools and capabilities;

• continue the oversight of recovery and resolution planning 

activities to assess our resolvability capabilities if such situation 
arises;

• 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; 

• continue to oversee financial crime risk and the strengthening of 

the financial crime control framework, including proactive 
management by the business; and

• assess our strategic opportunities and risks including exposures to 

digital currencies or assets and use of timely application of 
technology such as machine learning or artificial intelligence.

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Report of the Directors | Corporate governance report | Directors’ remuneration report

Directors’ remuneration report
Contents

Membership

276

279

282

298

Committee Chair’s statement

Executive remuneration at a glance

Annual report on Directors’ remuneration

Additional regulatory remuneration disclosures

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.

"This year we have refreshed our reward strategy to 
inspire a dynamic culture as we focus on energising 
for growth and delivering sustainable value to our 
shareholders, customers and colleagues."

Dear Shareholder

I am pleased to present our 2022 Directors’ remuneration report on 
behalf of the members of the Group Remuneration Committee, and 
my first as Chair of the Committee. I would like to thank our previous 
Chair, Pauline van der Meer Mohr, for her excellent stewardship of 
the Committee. 

I also thank you for your support of our remuneration resolutions at 
the 2022 Annual General Meeting (‘AGM’). Our current policy and its 
implementation received 96% of votes in favour.

In addition to our usual agenda, the Committee has been focused on 
aligning performance measures and remuneration more closely with 
our strategy. We have been engaging with our major shareholders 
and other investor groups, who have shared valuable feedback.  

We have refreshed our wider reward strategy and proposition for the 
workforce in response to the new or elevated challenges we are 
facing as we move beyond the Covid-19 pandemic, including the cost 
of living pressures many of our colleagues are experiencing. The 
commitments we make to colleagues are critical to support us in 
energising for growth and delivering sustainable performance.

Performance in 2022

Financial performance

Financial performance in 2022 was supported by a rise in global 
interest rates, which materially improved our net interest income, and 
we maintained our strong focus on cost discipline, despite inflationary 
pressures and continued investment in technology. While our revenue 
outlook remains positive, there are continued risks around inflation 
and increasing macroeconomic uncertainty in many of the markets in 
which we operate.

Adjusted profit before tax increased by $3.4bn to $24.0bn, as a rise in 
adjusted revenue of 18% to $55.3bn was partly offset by an adjusted 
expected credit losses charge of $3.6bn, compared with a net release 
in 2021 of $0.8bn, and growth in adjusted operating expenses of 1%. 
Our return on average tangible equity (‘RoTE‘) was 9.9%, an increase 
of 1.6% on 2021, and we have now exceeded our ambition of $120bn 
of risk-weighted asset (‘RWA‘) gross saves since the start of our 
programme in 2020. 

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HSBC Holdings plc Annual Report and Accounts 2022

Member since

Meeting 
attendance in 2022

Dame Carolyn Fairbairn (Chair)
Geraldine Buckingham
Rachel Duan
James Forese
José Antonio Meade Kuribreña
Pauline van der Meer Mohr1

Sept 2021
May 2022
Sept 2021
May 2020
May 2021
Jan 2016

6/6
4/4
6/6
6/6
6/6
2/2

1  Pauline van der Meer Mohr stepped down from the Committee and 

Board at the conclusion of the AGM on 29 April 2022. 

In 2022, we approved dividends of $0.32 per share, equivalent to a 
payout ratio of 44% of reported earnings per share. We are 
establishing a dividend payout ratio of 50% of reported earnings per 
share for 2023 and 2024, excluding material significant items, and we 
intend to revert to paying quarterly dividends from the first quarter of 
2023.

Non-financial performance

In our employee Snapshot survey, our Employee engagement and 
Inclusion indices both increased by 1% year on year to 73% and 76%, 
respectively, which are both above the financial services benchmarks. 
The percentage of Black heritage colleagues in senior leadership 
globally increased by 0.3% to 2.5%, meeting our stretch goal. The 
percentage of women in senior leadership also increased by 1.6% to 
33.3% since 2021, and we are on track to meet our commitment of 
35% by 2025. 

For customer satisfaction, net promoter score (’NPS’) performance 
has been positive relative to our competitors in some areas of our 
business, with work to do in others. In WPB, our NPS increased in the 
UK and Hong Kong, and we were ranked in first place in Hong Kong. 
In CMB, our NPS increased in Hong Kong but declined in the UK, and 
we were ranked in second place in Hong Kong. In GBM, our global 
NPS improved and our global rank remained in fifth place. In WPB and 
CMB digital businesses in Hong Kong, we were ranked in first and 
third places, respectively. In GBM globally, our digital trade finance 
platforms maintained first place for the quality of platforms. Our 
PayMe payments app was also ranked in second place for digital 
wallets. In WPB, our NPS increased in mainland China and Singapore, 
remained unchanged in Mexico, and in India saw a small decline. In 
CMB, our NPS increased in mainland China, Singapore and Mexico, 
and our rank positions in those markets either improved compared 
with 2021 or were in the top three against competitors. 

Workforce reward

Group variable pay pool 

The Committee determined an overall variable pay pool of $3,359m 
(2021: $3,495m) following a review of our performance against 
financial and non-financial metrics set out in the Group risk 
framework. The Committee considered our strong 2022 financial 
performance, with a 17% increase in adjusted profit before tax, a 
RoTE of 9.9% and adjusted cost growth of 1% year on year. The 
Committee also considered the external environment, the challenging 
economic outlook and projected outcomes across the market to 
ensure we remain competitive to attract and retain talent.

The distribution of the pool was differentiated by business 
performance. Overall year-on-year variable pay outcomes were 
strongest in CMB, followed by WPB but down in GBM to reflect 
relative performance. There was robust differentiation for individual 
performance so that our highest performers received meaningful 
variable pay increases on the previous year. We have protected 
variable pay for junior colleagues, which was up on average, 
recognising the inflationary and cost of living challenges experienced 
across most of our markets.

In determining 2023 fixed pay increases, we considered the impact of 
inflation in each country where we operate. Increases were targeted 
towards more junior and middle management colleagues as fixed pay 
is a larger proportion of their overall pay. Across the Group, there was 

 
an overall increase of 5.5% in fixed pay, compared with 3.6% for 
2022. The level of increases varied by country, depending on the 
economic situation and individual roles. There were no fixed pay 
increases for most of our senior leaders, including our executive 
Directors.

Supporting colleagues in 2022  

We monitored the global economic situation carefully and took action 
to support our colleagues according to the market, given local inflation 
and cost of living pressures. We continued to support our colleagues 
in those markets still significantly impacted by the pandemic. In 
mainland China and Hong Kong, we provided care packages and 
increased well-being sessions. In mainland China, we also delivered 
food essentials and provided inconvenience allowances. In Argentina 
and Türkiye, we made regular adjustments to fixed pay given the 
continuing inflationary pressures. In Sri Lanka, we made one-off 
payments and fixed pay increases during the year to address high 
inflation. In the UK, we provided almost 17,000 junior colleagues with 
a one-off payment of £1,500 to help with energy cost pressures.

We continued to focus on well-being, benefits, financial guidance, 
employee assistance programmes and access to hardship funds, as 
well as pay.

£2,164,000 for Noel Quinn (2021: £1,590,000) and £1,091,000 for 
Ewen Stevenson (2021: £978,000). 

The year-on-year increase in annual incentive for the Group Chief 
Executive is based on a formulaic assessment of performance against 
financial and non-financial targets set by the Board at the start of last 
year, taking into account the Group’s 2022 financial plan and strategic 
priorities and commitments. 

While the variable pay pool is determined by the Group’s overall 
performance, it is not set in a formulaic manner. Our approach is to 
smooth the variable pay pool outcomes over time to protect overall 
pay for colleagues from material volatility in performance caused by 
market conditions. In years of lower Group performance, we protect 
colleagues from significant downside in pay outcomes, including in 
2020 when adjusted profit before tax fell 45% year on year, but the 
variable pay pool decreased just 20%. In years of stronger 
performance, such as in 2022, a similar approach is taken on the 
upside. 

The Committee carefully considered the executive Directors’ pay 
outcomes in the context of pay decisions made for the wider 
workforce and determined that these are an appropriate reflection of 
Group, business and individual performance delivered in 2022. 

Key remuneration decisions for Directors

Long-term incentive (‘LTI‘) for executive Directors

Executive Director changes

Georges Elhedery was appointed Group Chief Financial Officer from 
1 January 2023. Ewen Stevenson is leaving the Group on 30 April 
2023 and will receive a payment in lieu of notice until 25 October 
2023. All remuneration decisions in respect of this change were made 
in accordance with our shareholder-approved policy, and are detailed 
in the annual report on remuneration.

Georges Elhedery’s remuneration was set on appointment with a 
base salary of £780,000 per annum, a fixed pay allowance of 
£1,085,000 per annum, a pension allowance of 10% of his base salary 
(in line with most UK employees) and variable remuneration and 
benefits in accordance with our policy.

In recognition of the services that Ewen Stevenson provided to HSBC 
during his tenure and the circumstances of his departure, he has been 
treated as a good leaver for the purpose of unvested incentive 
awards. He remained eligible for a 2022 annual incentive but will not 
receive a long-term incentive award for the 2023 to 2025 performance 
period.

Executive Directors‘ annual incentive 

The Group's financial performance was reflected in the performance 
against the measures in the executive Directors’ annual scorecards. In 
particular, the Committee recognised: adjusted profit before tax was 
$24.0bn, which represented an increase of 17% compared with 2021; 
strong cost controls were demonstrated, despite inflationary 
pressures and continued investment in technology, with adjusted 
costs at $30.5bn; and RoTE was 9.9%, an improvement on the 8.3% 
achieved in 2021. 

Overall, combined with non-financial measures, this level of 
performance resulted in a formulaic scorecard outcome of 79.32% of 
the maximum opportunity for Noel Quinn (2021: 57.30%) and 76.65% 
for Ewen Stevenson (2021: 60.43%). The increase relative to 2021 
reflected performance against targets and is largely a result of 
stronger financial performance in 2022. 

The annual incentive scorecard is also subject to a risk and 
compliance modifier, which provides the Committee with the 
discretion to adjust down the overall scorecard outcome. Taking into 
account the Group’s performance against risk metrics, inputs from 
the Group Risk Committee and the overall accountability of the 
executive Directors with regards to specific matters around capital 
management in the year, the Committee used its judgement and 
applied a downward adjustment of 5% and 15% to Noel Quinn’s and 
Ewen Stevenson’s annual incentive outcomes, respectively. The 
difference in adjustments reflected the degree of accountability and 
relative proximity for capital management. This resulted in an adjusted 
incentive outcome of 75.35% of maximum opportunity for Noel Quinn 
and 65.15% for Ewen Stevenson. This represented amounts of 

For LTI awards for the 2023 to 2025 performance period, we will 
continue to use measures and targets relating to: RoTE; capital 
reallocation to Asia; relative total shareholder return (‘TSR’); and 
environmental impact.

Following feedback from some of our shareholders, the Committee 
reviewed the TSR performance peer group, with the objective of 
including more Asian peers to better reflect the balance of markets 
and businesses of the Group. The new peer group will be used for the 
relative TSR measure for LTI awards with a 2023 to 2025 
performance period, and now includes Bank of China (Hong Kong), 
China Merchants Bank and OCBC Bank. No change will be made to 
the performance peer group for any LTI awards granted prior to the 
2023 to 2025 LTI award.

For the 2023 to 2025 performance period: Noel Quinn will receive an 
LTI award of £4,275,000 (320% of salary) in respect of his 
performance for 2022; Georges Elhedery will receive an LTI award of 
£1,248,000 (160% of salary) in respect of his performance for 2022 
when he was not an executive Director; and Ewen Stevenson will not 
receive an LTI award.

Ewen Stevenson participated in the LTI for the 2020 to 2022 
performance period that will vest in March 2023. The TSR and RoTE 
performance targets were not met and therefore these elements of 
the award lapsed in full. The customers measure was determined to 
be 57% met and therefore 19% of the overall award will vest on a 
pro-rata basis over the next five years.

Executive Directors‘ fixed pay for 2023 

The Committee decided that there will be no increase to the base 
salary or fixed pay allowances for Noel Quinn for 2023. The fixed pay 
for Georges Elhedery for 2023 was set on appointment.   

Ordinarily, an increase would have been considered for Noel Quinn to 
ensure that his total remuneration opportunity is competitive in the 
market. However, given the broader economic context and 
inflationary and cost of living pressures for colleagues across many of 
our markets, we targeted increases to our more junior and lower paid 
colleagues this year.

Looking ahead

We note the UK government’s consultation around the variable to 
fixed pay ratio, and anticipate that this will eventually allow us to place 
more emphasis on variable pay in the overall package. We will keep 
our approach under review and consult with shareholders on any 
potential changes to our overall remuneration framework for 
executive Directors. In the meantime, our approach for 2023 will be 
consistent with the current approved policy and regulatory 
requirements.

We are committed to opening up a world of opportunity for all our 
people in 2023 and beyond. Our refreshed reward proposition 
articulates how we are building a dynamic culture where the best 

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want to work, where we reward colleagues responsibly and reward 
their successes. We will continue to do the right thing for our 
colleagues, rewarding them fairly and supporting them to grow. 

We continue to protect value for our shareholders and customers, and 
manage our costs. We will also continue to engage with all our 
stakeholders on executive pay matters. 

We believe that our decisions on executive pay for 2022 have struck 
the right balance for all stakeholders and are also fair relative to 
performance. As Chair of the Committee, I hope you will support the

Remuneration decisions in context

2022 Directors’ remuneration report, which will be subject to an 
advisory vote at our 2023 AGM. 

Dame Carolyn Fairbairn

Chair

Group Remuneration Committee

21 February 2023

We have given serious consideration to how we manage competing variables when deciding pay outcomes this year. We feel the decisions 
that have been made strike a balance between prioritising fixed pay increases for those who need it the most, and variable pay increases for 
our most exceptional performers. We will continue to listen carefully to all stakeholders – colleagues, customers and shareholders, as well as 
our regulators – in making these important judgements.

What are we doing to support colleagues? 

A key aspect of the Committee’s activities this year has been ensuring 
that we support our colleagues through the challenges that many are 
facing. In recognition of the broader environment, we are spending 
more on fixed pay than we have in recent years, and we have 
increased the total funding by 5.5% globally. We want to make sure 
that colleagues can avoid facing financial hardship, and we support the 
senior leadership’s decision to focus fixed pay increases on our more 
junior and middle management employees, where this is a larger 
proportion of their overall pay. 

We have taken a number of targeted actions to support our colleagues 
during 2022, taking the local context into consideration, as detailed in 
the Chair’s letter. This includes support for those particularly impacted 
by inflationary pressures in Argentina, Türkiye and Sri Lanka. It also 
includes support in mainland China and Hong Kong where colleagues 
are still significantly impacted by the pandemic. In the UK, we 
supported colleagues facing energy cost pressures.

We have continued to provide a wide range of resources to all our 
colleagues globally, including wider support on financial guidance, 
employee assistance programmes and access to hardship funds. 

How was fixed and variable pay determined for executive 
Directors?

The Committee makes decisions on executive Director pay based on a 
policy that is agreed with our shareholders. The performance against 
targets in the executive Directors’ annual scorecards reflects their 
individual contribution to the Group's strong financial performance in 
2022.  

We set clear targets at the start of the year, and then the Committee 
assesses if they have been met or not. The annual incentive scorecard 
is also subject to a risk and compliance modifier. 

Overall, this has resulted in a higher annual incentive outcome for our 
executive Directors for 2022. Details of these outcomes are set out in 
our annual report on remuneration below.

There have been no fixed pay increases for our executive Directors.

How was fixed and variable pay funding determined for all 
employees? 

What are the key areas of focus for the Committee over the 
coming year?

The Group has increased fixed pay funding by 5.5% for 2023, 
compared with 3.6% for 2022. 

We have allocated fixed pay by market, with outcomes differentiated 
based on the economic circumstances, and particularly wage inflation, 
in each market. We have taken into account the impact of the current 
economic environment and targeted fixed pay increases towards 
more junior and middle management colleagues where fixed pay is a 
larger part of their total compensation and who may be most impacted 
by inflation and cost of living pressures. 

There have been no fixed pay increases for most of our senior leaders 
for 2023, including our executive Directors.

The Group variable pay pool is determined by reviewing Group 
performance against key financial and non-financial metrics. Although 
we have improved our financial performance this year, we have kept 
the pool broadly flat when compared with 2021. Our approach is to 
smooth the variable pay pool outcomes over time to protect overall 
pay for colleagues from material volatility in performance caused by 
market conditions. Within the overall variable pay pool, there has been 
significant differentiation to reward our best performing businesses 
and recognise excellent individual performance.

Outcomes for colleagues vary significantly depending on their role, 
business area and performance.

The Committee notes the UK government’s consultation around the 
bonus cap, and we anticipate that this will eventually lead to a 
remuneration structure with a greater focus on variable pay for 
performance. We intend to review the remuneration arrangements for 
our executive Directors in due course in light of the UK government’s 
proposals, and will consult with shareholders on any potential changes 
to our overall remuneration framework.

The Committee continues to keep the performance metrics used for 
our executive scorecards under review to ensure that they continue to 
support the successful execution of our strategy, while also taking 
into account views of our major shareholders, and investor and 
regulatory guidance in this area. As the Group continues to progress 
on our environmental, social and governance (’ESG’) journey, the 
Committee has discussed how we ensure our environmental and 
social commitments continue to be appropriately reflected in the 
performance scorecards for members of the Group Executive 
Committee. This is an area the Committee intends to consider further 
over the coming year.

278

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
Executive remuneration at a glance
This section sets out an overview of our performance, our 2022 remuneration outcomes for executive Directors and a summary of the policy 
approved by shareholders at our 2022 AGM, including how we will implement the policy in 2023.  
Our performance

Adjusted profit before tax

$24.0bn 

(2021: $20.6bn)

Net new invested assets
$80bn
(2021: $64bn)

Adjusted costs
$30.5bn 
(2021: $30.1bn)

Employee engagement 
index
73% 
(2021: 72%)

Inclusion index
76% 
(2021: 75%)

Colleagues reporting 
HSBC cares about their 
well-being
70% 
(up from 50% in 2016 
when we first ran the 
survey)

Return on average 
tangible equity
9.9% 
(2021: 8.3%)

Percentage of women in 
senior leadership roles
33.3% 
(2021: 31.7%)

Remuneration outcomes for executive Directors

Summary remuneration outcomes for 2022 are set out below. Further details are set out in our annual report on remuneration. 

Noel Quinn

Total remuneration (£000)

Ewen Stevenson
Total remuneration (£000)

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.

HSBC Holdings plc Annual Report and Accounts 2022

279

£10,522     £5,562     Salary and fixed pay allowancePension and benefitsAnnual incentiveLong-term incentiveNotional returns on deferred cashawarded in respect of prior roleMaximum opportunity2022 total remuneration£6,167£4,701Salary and fixed pay allowancePension and benefitsAnnual incentiveLong-term incentiveReplacement awardMaximum opportunity2022 total remuneration75.35%24.65%AchievedLapsed65.15%34.85%AchievedLapsed400%513%Shareholding requirementCurrent shareholding300%658%Shareholding requirementCurrent shareholdingCorporate governance 
 
 
Report of the Directors | Corporate governance report | Directors’ remuneration report

Remuneration policy summary – executive Directors 

This section summarises our remuneration policy for executive Directors. The policy was approved at the AGM on 29 April 2022. The full 
remuneration policy can be found on pages 257 to 265 of our Annual Report and Accounts 2021 and in the Directors’ Remuneration Policy 
Supplement, which is available under Group results and reporting in the 'Investors' section of www.hsbc.com.  

Elements and objectives

Operation

Base salary

• Base salary is paid in cash on a monthly basis.
• Other than in exceptional circumstances, the base salary for the current executive 

Directors will not increase by more than 15% above the level at the start of the policy 
period in total for the duration of the policy. 

Fixed pay allowance (‘FPA’)

Cash in lieu of pension

Annual incentive

Long-term incentive (‘LTI’)

Benefits

Shareholding guidelines

• The FPA is granted in instalments of immediately vested shares.
• On vesting, shares equivalent to the net number of shares delivered (after those sold to 
cover any income tax and social security) are subject to a retention period and released 
annually on pro-rata basis over five years, starting from the March immediately following 
the end of the financial year for which the shares are granted.

• Dividends are paid on the vested shares held during the vesting period.

• Cash in lieu of pension is paid on a monthly basis as 10% of base salary.
• This allowance, as a percentage of salary, is aligned 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.

• The maximum opportunity for the annual incentive is up to 215% of base salary.
• Annual incentive performance is measured against an individual scorecard.
• At least 50% of any award is delivered in shares, which are normally immediately vested.
• On vesting, shares equivalent to the net number of shares that have vested (after those 

sold to cover any income tax and social security payable) will be held for a retention period 
of up to one year, or such period as required by regulators.

• Awards will be subject to clawback (i.e. repayment or recoupment of paid vested awards) 
for a period of seven years from the date of award, extending to 10 years in the event of 
an ongoing internal/regulatory investigation at the end of the seven-year period. Any 
unvested awards will be subject to malus (i.e. reduction and/or cancellation) during any 
applicable deferral period.

• The maximum opportunity for LTI awards is up to 320% of base salary.
• The LTI award is granted if the Committee considers that there has been satisfactory 

performance over the prior year and subject to a forward-looking three-year performance 
period from the start of the financial year in which the awards are granted.

• At the end of the performance period, awards will vest in five equal instalments, with the 
first vesting on or around the third anniversary of the grant date and the last instalment 
vesting on or around the seventh anniversary of the grant date.

• On vesting, shares equivalent to the net number of shares that have vested (after those 

sold to cover any income tax and social security payable) will be held for a retention period 
of up to one year, or such period as required by regulators.

• Awards are subject to malus provisions prior to vesting. Vested shares are subject to 

clawback for a period of seven years from the date of award, extending to 10 years in the 
event of an ongoing internal/regulatory investigation at the end of the seven-year period.
• Awards may be entitled to dividend equivalents during the vesting period, paid on vesting. 
Where awards do not receive dividend equivalents, the number of shares awarded can be 
determined using the share price discounted for the expected dividend yield.

• Benefits include the provision of medical insurance, accommodation, car, club 
membership, independent legal advice in relation to a matter arising out of the 
performance of employment duties for HSBC, tax return assistance or preparation, and 
travel assistance (including any associated tax due, where applicable).

• Additional benefits may also be provided when an executive is relocated or spends a 
substantial proportion of his/her time in more than one jurisdiction for business needs.

Executive Directors are expected to satisfy the following shareholding requirement as a 
percentage of base salary within five years from the date of their appointment:
• Group Chief Executive: 400%
• Group Chief Financial Officer: 300%

All-employee share plans

Executive Directors are eligible to participate in all-employee share plans, such as HSBC 
Sharesave, on the same basis as all other employees.

Implementation in 2023

Base salary will not be 
increased for 2023 and will 
remain as follows:
• Noel Quinn: £1,336,000
• Georges Elhedery: 

£780,000

FPA for 2023 will not be 
increased for 2023 and will 
remain as follows:
• Noel Quinn: £1,700,000
• Georges Elhedery: 

£1,085,000

• No change to percentage of 

base salary.

• No change to quantum.
• See page 286 for details of 

2023 annual incentive 
measures.

• No change to quantum.
• See page 285 for details of 
performance measures for 
the LTI awards with a 2023 
to 2025 performance 
period.

• Benefits to be provided as 
per policy. Details will be 
disclosed in the Annual 
Report and Accounts 2023 
single figure of 
remuneration table.

• No change to percentage of 

base salary.

• Participation in any such 
plans will be disclosed in 
the Annual Report and 
Accounts 2023, as required.

280

HSBC Holdings plc Annual Report and Accounts 2022

Our approach to workforce reward
Our refreshed reward proposition 

During 2022, the Committee refreshed our reward strategy, to 
strengthen our focus on inspiring a dynamic culture where the best 
want to work. This work was underpinned by comprehensive internal 
and external research, including reviewing two years of feedback and 
data from our Snapshot and pay surveys, and exit interviews about 
what makes colleagues join, leave and engaged at HSBC.

Our workforce proposition is rooted in our purpose and values. Our 
commitment to reward colleagues fairly, along with the opportunity to 
do inspiring work and contribute within our international network, 
creates a unique proposition for colleagues. Our refreshed principles 
and supporting commitments articulate the experience for 
employees, and provide a clear framework to creating a dynamic 
culture where the best talent are motivated to deliver high 
performance. These principles are: 

• We will reward you responsibly through fixed pay security and 

protection through core benefits, a competitive total compensation 
opportunity, and pay equity with a more inclusive and sustainable 
benefits proposition over time.

• We will recognise your success through our performance culture 

and routines, including feedback and recognition, pay for 
performance, and all employee share ownership opportunities.

• We will support you to grow through our proposition beyond pay, 

with a focus on future skills and development, your mental, 
physical, social and financial well-being, and flexibility in working 
practices. 

We live up to many of these commitments today. We will also set 
new goals to continue to improve over time, with plans to focus on 
improving colleague sentiment through more transparency and 
structure in pay design, and better communications on how we make 
reward decisions. 

Aligned with these commitments, we have developed a roadmap to 
build on our strong benefits and well-being programme, including 
flexible working, and more inclusive and sustainable benefits. 

We have set clear measures and key performance indicators to track 
our progress, including by listening to colleague feedback. 
Supporting colleagues in 2022 

In 2022, our colleagues faced a backdrop of increasing economic 
instability, with rising energy prices and inflation, which increased 
their cost of living. While we continued to focus on making 
responsible reward decisions for our colleagues through our annual 
pay review, we also took a number of actions throughout 2022.

Given this context and our focus on pay security, we allocated more 
to fixed pay increases than in prior years, and this was based on 
consistent principles to help address the impact of rising inflation in 
many of our locations. 

In determining 2023 fixed pay increases, we considered the impact of 
inflation in each market where we operate. Increases were targeted 
towards more junior and middle management colleagues as fixed pay 
is a larger proportion of their overall pay. Across the Group, there was 
an overall increase of 5.5% in fixed pay, compared with 3.6% for 
2022. The level of increases varied by market, depending on the 
economic situation and individual roles.

The distribution of the variable pay pool was differentiated by 
business performance. There was robust differentiation for individual 
performance so that our highest performers received meaningful 
variable pay increases on the previous year. We have protected 
variable pay for junior colleagues, which is up on average, recognising 
the inflationary and cost of living challenges experienced across most 
of our markets.

Considering the macroeconomic environment and cost of living 
challenges impacting colleagues, we provided specific support to 
those most affected. For example, in the UK and the Channel Islands 
we paid our more junior colleagues a one-off payment of £1,500 to 
help with the cost of living pressures, driven primarily by rising energy 
costs. In Argentina, Sri Lanka and Türkiye, where colleagues were 
impacted by inflationary challenges, we gave our colleagues fixed pay 
increases throughout the year. In other areas we provided our 
colleagues support in the form of meal vouchers to help with rising 
food costs, and we increased flexibility around how and where our 
colleagues work. Some of our colleagues are still significantly 
impacted by the pandemic and we have ensured support in these 
specific markets. In mainland China and Hong Kong, we provided care 
packages and increased well-being sessions. In mainland China, we 
also delivered food essentials and provided inconvenience 
allowances. Where colleagues have been impacted by the Russia-
Ukraine war we offered free independent and professional 
counselling, alongside hosting regular public webinars to manage 
topics such as stress and dealing with anxiety. Our colleagues in 
Poland have been providing direct assistance to people crossing the 
border and we quickly made available financial resources for them to 
continue to directly support refugees.

The well-being of our people remained a critical focus in 2022, and in 
particular, the financial well-being of our colleagues and their families. 
Guided by data and colleague feedback, the pillars of our well-being 
programme are mental, physical, financial and social well-being. 
Despite the immense challenges, sentiment remained high. A total of 
70% of colleagues believe HSBC genuinely cares about their well-
being. In a September survey, 84% of colleagues rated their mental 
well-being as positive, 71% rated their overall physical well-being 
positively and 60% of colleagues reported their financial well-being as 
positive.

We measure our colleagues’ sentiment on performance and pay 
through our annual pay review surveys. Considering the challenges 
colleagues faced, it was encouraging to see that check-ins happened 
regularly, with 66% of colleagues having frequent conversations with 
their managers (2021: 60%). 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.

Throughout the year we 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 purpose and values. We also run annual 
spotlight campaigns, with the campaign in 2022 focusing on ESG 
issues to recognise colleagues for exceptional actions in supporting 
our need to work responsibly. Our colleagues made over 1.2 million 
recognitions during 2022, a record high and an 11% increase on the 
previous year.

HSBC Holdings plc Annual Report and Accounts 2022

281

Corporate governanceReport of the Directors | Corporate governance report | Directors’ remuneration report

Annual report on Directors’ 
remuneration
This section sets out how our approved Directors’ remuneration 
policy was implemented during 2022.

Determining executive Directors’ incentive 
outcomes

(Audited)  

For any annual incentive award to be made, each executive Director 
must achieve a minimum standard of conduct and values-aligned 
behaviour. For 2022, both executive Directors met this requirement.

The award is determined by applying the outcome of their annual 
incentive scorecard to the maximum opportunity, which was set at 
215% of salary. The scorecard measures, weightings and targets 
were determined at the start of the financial year taking into account 
the Group’s plan for 2022 and the Group’s strategic priorities and 
commitments. For strategic measures, the assessment was against 
targets set for employee diversity, survey results for employee 
experience and customer satisfaction measures, as well as progress 
made and momentum generated to achieve our strategic priorities.

The Group’s financial performance was reflected in the achievement 
against the measures in the executive Directors’ annual scorecards. In 
particular, the Committee recognised:

•

•

adjusted profit before tax was $24.0bn, which represented an 
increase of 17% compared with $20.6bn in 2021; 

strong cost controls were demonstrated, despite inflationary 
pressures and continued investment in technology, with adjusted 
costs at $30.5bn; and

• RoTE was 9.9%, an improvement on 8.3% in 2021.

Annual incentive scorecard assessment 

(Audited)

Summary assessment 

Our Employee engagement and Inclusion indices in the Snapshot 
survey both increased and were above the financial services 
benchmarks. The percentage of Black heritage colleagues in senior 
leadership globally increased, as did the percentage of women in 
senior leadership. For customer satisfaction, NPS performance is 
assessed with reference to rank movements against our competitors 
and underlying NPS scores. Performance details for employees and 
customers measures are set out in the table in the section below.  

Overall, this level of performance resulted in a formulaic scorecard 
outcome of 79.32% of the maximum for Noel Quinn and 76.65% for 
Ewen Stevenson. 

The annual incentive scorecard is also subject to a risk and 
compliance modifier, which provides the Committee with the 
discretion to adjust down the overall scorecard outcome. Taking into 
account the Group’s performance against risk metrics, inputs from 
the Group Risk Committee and the overall accountability of the 
executive Directors with regards to specific matters around capital 
management in the year, the Committee used its judgement and 
applied a downward adjustment of 5% to Noel Quinn’s annual 
incentive outcome and 15% to Ewen Stevenson’s. The difference in 
adjustments reflected the degree of accountability and relative 
proximity for capital management. This resulted in an adjusted 
incentive outcome of 75.35% of maximum opportunity for Noel Quinn 
and 65.15% for Ewen Stevenson. This represented amounts of 
£2,164,000 for Noel Quinn (2021: £1,590,000) and £1,091,000 for 
Ewen Stevenson (2021: £978,000).

As detailed in the Chair’s letter, the Committee considered carefully 
the executive Directors’ pay outcomes in the context of pay decisions 
made for the wider workforce and determined that these were an 
appropriate reflection of Group, business and individual performance 
delivered in 2022.

Group adjusted profit before tax 
($bn)

Group lending growth – 
customer loans and advances 
(third party)

Growth in net new invested 
assets ($bn)

Reported RoTE
Group adjusted cost total ($bn)
Customer satisfaction
Employee experience
Personal objectives
Total
Annual incentive formulaic 
outcome (000)
Risk adjustments as a result of 
Committee judgement (000)
Annual incentive (000)

Minimum 
(25% 
payout)

Maximum 
(100% 
payout)

Noel Quinn

Ewen Stevenson

Performance

Weighting 
(%)

Assessment 
(%)

Outcome 
(%)

Weighting 
(%)

Assessment 
(%)

Outcome 
(%)

16.66

19.51

24.01

 20.00 

 100.00 

 20.00 

 15.00 

 100.00 

 15.00 

 2.96% 

 5.93% 

 1.45% 

 7.50 

 — 

 — 

 5.00 

 — 

 — 

52.36

 3.00% 
30.87

76.17

 5.00% 
29.47

79.83

 9.90% 
30.47

See following tables for commentary

 7.50 

 15.00 
 10.00 
 15.00 
 15.00 
 10.00 
 100.00 

 100.00 

 100.00 
 46.43 
 60.33 
 87.50 
 100.00 

 5.00 

 15.00 
 10.00 
 15.00 
 15.00 
 20.00 
 100.00 

 100.00 

 100.00 
 46.43 
 60.33 
 87.50 
 74.15 

 7.50 

 15.00 
 4.64 
 9.05 
 13.13 
 10.00 
 79.32 

£2,278

£(114)
5%
£2,164

 5.00 

 15.00 
 4.64 
 9.05 
 13.13 
 14.83 
 76.65 

£1,284

£(193)
15%
£1,091

282

HSBC Holdings plc Annual Report and Accounts 2022

 
Strategic measures for Noel Quinn and Ewen Stevenson

Customer 
satisfaction

15.00%

Measures Weighting (%) Assessment considerations by the Committee
Maintain and 
improve NPS 
in the UK 
and Hong 
Kong, in 
digital 
markets, and 
in key 
growth 
markets

• UK and Hong Kong (assessed at 59%). In WPB, our NPS improved in the 
UK and Hong Kong, and we were ranked in first place in Hong Kong. In 
CMB, our NPS improved in Hong Kong but fell in the UK, and we were 
ranked in second place in Hong Kong. In GBM, our global NPS improved 
and our global rank remained in fifth.

• Digital markets (assessed at 68%). In WPB and CMB digital businesses in 
Hong Kong, we were ranked in first and third. In GBM globally, our digital 
trade finance platforms maintained first place for the quality of platforms. 
Our PayMe payments app was ranked in second place for digital wallets.

• Key growth markets (assessed at 54%). In WPB, our NPS improved in 

Assessment (%) Outcome (%)

60.33%

9.05%

Employee 
experience

Improve 
engagement, 
and diversity 
and inclusion

15.00%

mainland China and Singapore, remained unchanged in Mexico, and in India 
saw a small decrease. In CMB, our NPS increased in mainland China, 
Singapore and Mexico, and our rank positions in those markets either 
improved compared with 2021 or were in the top three against 
competitors.

• Our Snapshot Employee engagement and Inclusion indices both increased 
one percentage point year on year to 73% and 76%, respectively, above 
maximum targets and the financial services benchmarks. 

• The percentage of Black heritage colleagues in senior leadership increased 

by 0.3% to 2.5%, meeting our maximum target.

• The percentage of women in senior leadership increased by 1.6% to 33.3% 

since 2021, within the target range of 33.2% to 33.7%.

87.50%

13.13%

Personal objectives for Noel Quinn and Ewen Stevenson 

For each executive Director, personal objectives were set at the start of the year and measured by the Committee with respect to key performance indicators under 
our strategy levers.

Noel Quinn

Weighting Assessment Performance achievement

Technology 
transformation

2.5%

100%

• The Committee's assessment reflects strong progress automating our organisation at scale against targets 
set. Our Cloud adoption rate, which is the percentage of our technology services on the private or public 
Cloud, increased to 35% (2021: 27%). At the end of 2022, approximately 49% of our WPB customers were 
'mobile active' users (2021: 43%).

2.5%

100%

• The targets for inorganic initiatives were delivered in 2022. We completed the acquisition of L&T 

Execution of 
inorganic initiatives 
in Asia

Progress on exits 
identified
Progress on 
innovation 
programmes

2.5%

2.5%

Investment Management Limited, making us the 12th largest mutual fund management company in India, 
bringing in $10.8bn assets under management and 2.4 million active portfolios. We raised our stake in 
HSBC Qianhai in China to 90%, completed our acquisition of the remaining 50% shares in HSBC Life 
Insurance in China. We renewed our exclusive life distribution partnership with Allianz in Asia, resulting in 
the combined group being the fourth largest health insurer and seventh largest life insurer in Singapore.

100%

• The planned sales of our banking business in Canada, branch operations in Greece and business in Russia 

were announced, reflecting strong progress in reshaping our portfolio. 

100%

• In CMB, we launched an industry-leading native bank account service with Oracle Netsuite Enterprise 

Resource Planning. We also launched Business Go, a platform that brings together international SMEs with 
providers of expert advice and business optimisation tools. In GBM, we launched HSBC Orion, our new 
proprietary tokenisation platform used for digital bond issuance. In WPB, we launched our international 
credit offering, allowing customers to gain access to credit in a new country based on credit history in their 
home country.

Total 

10% out of 10%

Ewen Stevenson Weighting Assessment Performance achievement

Finance for the 
future

12%

67%

• The financial implications of financed emissions targets for the oil and gas, and power and utilities sectors 
and for the $750bn to $1tn target were included in our financial resource plan, meeting the objectives set.
• The second round of the climate biennial exploratory scenario and stress tests for the Monetary Authority 

of Singapore and European Central Bank were completed, with no material issues.

• Plans have been delivered for IFRS 17 compliant reporting, in line with external reporting and disclosure 

requirements.

• The Bank of England Resolvability Assessment Framework and regulatory reporting enhancement 

objectives were delivered in line with the targets set.

• Resolved 100% of market risk RWA-related issues and over 80% of liquidity-related issues, which were 

previously identified and managed under the regulatory reporting enhancement programme.

• The programme to deliver timely, accurate and complete customer-centric management information using 

a single data Cloud platform, with enhanced controls and reduced operational risks, is on track to the 
agreed scope, costs and timeline.  

• Targets were met with increased Employee engagement index at 75% favourable (2021: 68%).
• Female representation in senior management roles across Finance increased to 32.1% (2021: 30.2%).
• Finance costs overall were within 2022 targets. The number of FTEs at the end of 2022 was slightly higher 

than the maximum target, mainly due to growth in key areas where new capabilities are required.  

4%

96%

Global Finance 
employee 
experience and 
function efficiency

Creating strong 
corporate 
development and 
Group 
transformation 
functions

4%

75%

• The Group Transformation function has made strong progress in aligning our change portfolio to the 

Group's strategy and systematically documenting a full change inventory. Achievements include clear 
reporting with associated costs on how the change portfolio is enabling the delivery of Group strategy, and 
stronger governance of the change portfolio, with an expanded remit of the Transformation Oversight 
Executive Committee to cover the entire change portfolio with improved accountability via targeted 
reviews of high impact programmes.

• Major transactions included planned sales of our banking business in Canada, branch operations in Greece 
and business in Russia were announced; the planned merger of Oman operations with Sohar International 
Bank; the completion of the Axa Singapore acquisition; the sale of US domestic mass market retail 
banking; and the acquisition of L&T Investment Management Limited in India.

Total

14.83% out of 20%

HSBC Holdings plc Annual Report and Accounts 2022

283

Corporate governance 
Report of the Directors | Corporate governance report | Directors’ remuneration report

Single figure of remuneration

(Audited)

The following table shows the single figure of total remuneration of each executive Director for 2022, 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 incentive
Notional returns3
Replacement award4
Long term incentive5
Total variable
Total fixed and variable

Noel Quinn

Ewen Stevenson

2022
1,329
1,700
133
119
86
3,367
2,164
31
—
—
2,195
5,562

2021
1,288
1,700
129
95
71
3,283
1,590
22
—
—
1,612
4,895

2022
775
1,085
77
7
50
1,994
1,091
—
1,180
436
2,707
4,701

2021
751
1,062
75
3
42
1,933
978
—
754
—
1,732
3,665

1 Executive Directors made the personal decision to donate 100% of their base salary increases for 2021 to charity. Ewen Stevenson also donated his 

FPA increase for 2021 to charity. Figures 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  The deferred cash awards granted in prior years include a right to receive notional returns for the period between the grant and vesting date. This is 

4 

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 2022 
relate to his 2018 replacement award granted by the Royal Bank of Scotland Group plc, now renamed as NatWest Group plc ('NatWest') for 
performance year 2018 and was subject to a pre-vest performance test assessed and disclosed by NatWest in its Annual Report and Accounts 2021 
(page 158). As no adjustment was proposed for Ewen Stevenson by NatWest, a total of 241,988 shares granted in respect of his 2018 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 £4.8772 
when the first tranche of these awards vested and all tranches were no longer subject to performance conditions, with no value attributable to share 
price appreciation. The values included in the table for 2021 are explained in the Annual Report and Accounts 2021.

5  An LTI award over 476,757 shares was made in February 2020 (in respect of 2019) at a share price of £5.6220 for which the performance period 

ended on 31 December 2022. The value has been computed based on a share price of £4.816, the average share price during the three-month period 
to 31 December 2022. There is no value attributable to share price appreciation. See the following section for details of the assessment outcomes, 
which resulted in 19% vesting due to performance.

Benefits
The values of the significant benefits in the single figure table are set out in the following table1. The insurance benefit for Noel Quinn has 
increased year on year because of the increase in premium at annual renewal.

(£000)
Insurance benefit (non-taxable)
Car and driver (UK and Hong Kong)

Noel Quinn

2022
82
69

2021
67
87

1  The insurance and car benefits for Ewen Stevenson are not included in the above table as they were not deemed significant.

284

HSBC Holdings plc Annual Report and Accounts 2022

Long-term incentive (’LTI’) awards

(Audited)

LTI awards over 2020 to 2022 performance period 

The 2019 LTI award was granted to Ewen Stevenson in February 
2020. Noel Quinn did not receive a 2019 LTI award. Based on the 
performance outcome, 90,584 shares will vest for Ewen Stevenson. 
The awards will vest in five equal annual instalments commencing in 
February 2023.

The Committee is mindful of executives not experiencing ’windfall 

gains’ through the granting of LTI awards when a share price is 
particularly low. We introduced an upfront windfall gains check for 
2020 LTI awards. The Committee agreed that if the LTI grant share 
price experienced a greater than 30% decline since the previous 
grant, that an adjustment percentage equal to half the share price 
percentage decline would be applied to the awards to mitigate the 
potential for windfall gains. Although this was not in place for the 
2019 LTI award, no pre-grant adjustment would have been applied if it 
had been. The value of awards at vesting is less than at grant and the 
Committee determined that there are no windfall gains to consider for 
this award.

Assessment of the 2019 LTI award (performance period 1 January 2020 to 31 December 2022)

Measures (weighting)1

Average RoTE with CET1 
underpin2 (33.3%)

Relative TSR3 (33.3%)

Minimum
(25% payout)

Target
(50% payout)

Maximum
(100% payout)

Actual

Assessment Outcome

10.0%

11.0%

12.0%

9.9%

0.0%

0.00%

At median of the peer 
group

Straight-line vesting 
between minimum 
and maximum

At upper quartile of 
peer group

Below 
median

0.0%

0.00%

Customers (33.3%)

Performance was assessed by the Committee based on:  
• customer satisfaction scores at the start and end of the three-year performance 
period for our global businesses in home and scale markets, which resulted in a 
formulaic 64% outcome. This comprised:
– UK and Hong Kong (assessed at 58%) – in WPB and CMB, we were ranked 
in first and second place in Hong Kong, with improved NPS scores. In GBM, 
our global NPS improved and our global rank remained in fifth;

– Digital markets (assessed at 77%) – in WPB and CMB digital markets, we 
were ranked in top three positions in Hong Kong, and in GBM globally, our 
digital trade finance platforms were ranked in first place; and 

– Key growth markets (assessed at 56%) – in WPB, our NPS increased in 

mainland China, Singapore and Mexico, and in India saw a small decline, and 
in CMB, our NPS increased in Mexico, with slight decreases in the other 
markets, but our rank positions in all four markets were in the top three 
against competitors.

• progress against customer objectives linked to our strategy over 2020 to 2022. It 
was determined that it broadly represented target performance and therefore 
50% of this element was achieved. The main items driving this assessment are 
our growth in international and Premier customers and in specific growth 
markets, where our overall performance has been broadly in line with plan and 
expectations.

These two percentages (64% and 50%) averaged to 57%.

57.0%

19.00%

Total

19.00%

1   Awards vest on a straight-line basis for performance between the minimum, target and maximum levels of performance set in this table.
2   Assessed based on RoTE in the 2022 financial year, which was not met. The CET1 underpin was met. 
3   The peer group was: 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.

LTI awards over 2023 to 2025 performance period 

After taking into account performance for 2022, the Committee 
decided to grant Noel Quinn an LTI award of £4,275,000. 

The 2022 LTI awards will have a three-year performance period 
starting 1 January 2023. 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 relative total shareholder 
return (’TSR’). This is consistent with the measures used for our last 
LTI awards.  

The Committee regularly reviews the TSR peer group to ensure it 
remains an appropriate performance comparison, taking into account 
strategic shifts in our geographical and business mix, notably future 
growth investment in Asia and wealth business. Following feedback 
from some of our shareholders, the Committee reviewed the TSR 
performance peer group, with the objective of including more Asian 
peers to better reflect the balance of markets and businesses of the 
Group. The new peer group will be used for the relative TSR measure 
for LTI awards for the 2023 to 2025 performance period and now 
includes Bank of China (Hong Kong), China Merchants Bank and 
OCBC Bank. No change will be made to the performance peer group 
for subsisting LTI awards.

The LTI continues to be subject to a risk and compliance modifier, 
which gives the Committee the discretion to adjust down the 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.

HSBC Holdings plc Annual Report and Accounts 2022

285

Corporate governanceReport of the Directors | Corporate governance report | Directors’ remuneration report

Performance conditions for LTI awards in respect of 2022 (performance period 1 January 2023 to 31 December 2025)

Measures1
RoTE with CET1 underpin2
Capital reallocation to Asia with CET1 
underpin3

Carbon reduction 
(own emissions)

Sustainable finance 
and investment

Transition to net 
zero4

Relative TSR5

Subject to risk and compliance modifier

Minimum
(25% payout)
13.0%

49.0%

64.0%

Target
(50% payout)
14.3%

50.5%

68.0%

Maximum
(100% payout)
15.5%

Weighting
%
25.0

52.0%

72.0%

$588.0bn

$700.0bn

$756.0bn

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

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. 
3  To be assessed based on share of Group tangible equity (on a reported basis and excluding associates) allocated to Asia by 31 December 2025. This 

metric will be subject to the CET1 underpin.

4  Carbon reduction will be measured based on percentage reduction in total energy and travel emissions achieved by 31 December 2025 using 2019 as 
the baseline. The sustainable finance and investment metric will assess the cumulative amount provided and facilitated over the period ending 31 
December 2025.

5  The peer group for the 2022 award is: Bank of China (Hong Kong), Barclays, BNP Paribas, China Merchants Bank, Citigroup, DBS Group Holdings, JP 

Morgan Chase & Co., Lloyds Banking Group, OCBC Bank, Standard Chartered and UBS Group. 

Annual incentive measures for 2023

2023 annual incentive performance measures

Weighting

The 2023 annual incentive scorecard measures for our executive 
Directors have been set to deliver growth and business 
transformation. They were selected by the Committee after taking 
into account the Group’s strategic pivot to Asia and feedback received 
from our major shareholders during engagement in the year. The 
targets have been set to reflect the Group’s 2023 plan, while 
considering macroeconomic uncertainty, including the interest-rate 
environment and rising 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 2023 annual 
incentive award for executive Directors are disclosed below. In 
previous years, the weightings were different for the Group Chief 
Executive and Group Chief Financial Officer. For 2023, these have 
been aligned, reflecting feedback from shareholders and to simplify 
our approach. The performance targets are commercially sensitive 
and it would be detrimental to the Group’s interests to disclose them 
at the start of the financial year. Subject to commercial sensitivity, we 
will disclose the targets for a given year in the Directors’ 
remuneration report for that year. 

Financial (subject to CET1 underpin)
Reported profit before tax

Reported operating expenses

Reported Group RoTE

Reported Asia RoTE

Fee income growth

Net new invested assets growth

Stakeholders
Customer satisfaction 
(improvement in NPS scores/rank)
Employee experience 
(gender and ethnicity representation and Inclusion index 
score)

Personal objectives 
Group Chief Executive: technology transformation, 
innovation, and simplification of processes and organisation 
Group Chief Financial Officer: regulatory priorities (regulatory 
reporting enhancement programme, resolution recovery 
planning, and ESG and climate), Finance change 
transformation and digitisation, energised Finance 
workforce, and liquidity usage and capital management 

Subject to risk and compliance modifier

60%
15%

15%

15%

5%

5%

5%

30%

15%

15%

10%

286

HSBC Holdings plc Annual Report and Accounts 2022

Scheme interests awarded during 2022

(Audited)

The table below sets out the scheme interests granted to executive Directors during 2022 in respect of performance year 2021, as disclosed in 
the 2021 Directors’ remuneration report. No non-executive Directors received scheme interests during the financial year.

Scheme awards in 2022

(Audited)

Noel Quinn
Ewen Stevenson

Basis on which 
Type of interest 
awarded
award made
LTI deferred shares2 % of salary2
LTI deferred shares2 % of salary2

Face 
value
awarded1
£000

Percentage
 receivable for 
minimum
performance

Number of
shares
awarded

End of
performance 
period

Date of award

28 February 2022  
28 February 2022  

5,290 
3,086 

 25 
 25 

983,339
573,674

31 December 2024
31 December 2024

1 The face value of the award has been computed using HSBC’s closing share price of £5.380 taken on 25 February 2022. LTI awards are conditional 
share awards subject to 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 2022 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 320% of salary for Noel Quinn and 320% of salary 
for Ewen Stevenson. The number of shares to be granted was determined by taking HSBC’s closing share price of £5.380 taken on 25 February 2022, 
and applying a discount based on HSBC’s expected dividend yield of 5% per annum for the vesting period (£4.201). 

2 

The above table does not include details of shares issued as part of the fixed pay allowance and shares issued as part of the 2021 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 2021 LTI award are below:

 Performance conditions for LTI awards in respect of 2021 (performance period 1 January 2022 to 31 December 2024)
(Audited)

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%

46.0%

52.0%

9.5%

48.0%

56.0%

11.0%

50.0%

60.0%

$285.0bn

$340.0bn

$370.0bn

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 

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.

Executive Directors’ interests in shares
(Audited)

The shareholdings of executive Directors in 2022, including the 
shareholdings of their connected persons, at 31 December 2022 (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 2022 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 that are not subject to 
forward-looking performance conditions (on a net of tax basis) will 
count towards their shareholding requirement under the shareholder-
approved policy.

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 fixed pay 
allowance 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 a 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 2022

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Corporate governanceReport of the Directors | Corporate governance report | Directors’ remuneration report

Shares

(Audited)

Executive Directors
Noel Quinn6
Ewen Stevenson6

Shareholding 
guidelines
(% of salary)

Shareholding at 
31 Dec 20222 
(% of salary)

Share 
interests
(number
of shares)

At 31 Dec 2022

Scheme interests

Shares awarded 
subject to deferral1

Share 
options3

without
 performance 
conditions4

with
performance
conditions5

400%
300%

513%  
658%  

1,422,650   
1,064,626   

—   
—   

415,771   
383,587   

2,101,893 
1,687,628 

1 The gross number of shares is disclosed. A portion 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 2022 (£4.816).
3  At 31 December 2022, 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 2021 and 2022 are subject to the performance conditions as set out in the preceding sections above. 
6  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). 

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

Total pension entitlements 

(Audited)

No employees who served as executive Directors during the year 
have a right to amounts under any HSBC final salary pension scheme 
for their services as executive Directors or are entitled to additional 
benefits in the event of early retirement. There is no retirement age 
set for Directors, but the normal retirement age for colleagues is 65.
Payments to past Directors

(Audited)

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)

Departure terms for Ewen Stevenson

Ewen Stevenson is leaving the Group on 30 April 2023. He will 
receive payments totalling £703,519 from the Group in lieu of his 
base salary and pension allowance from 1 January until 25 October 
2023. He will also receive his fixed pay allowance in respect of the 

same period, which totals £885,836, and will be awarded in 
immediately vested shares. The fixed pay allowance will be subject to 
a retention period and released on a pro-rata basis over five years.

Ewen Stevenson will not be eligible for an LTI award in respect of the 
2022 performance year, or any annual incentive award in respect of 
the 2023 performance year.

In accordance with the contractual terms agreed and our approved 
Directors’ remuneration policy, Ewen Stevenson was granted good 
leaver status in respect of his outstanding unvested share awards. 
Good leaver status is conditional upon him not taking up a role with a 
defined list of competitor financial services firms for a year from his 
departure date. As a good leaver, his deferred share awards will 
continue to vest and be released on their scheduled vesting dates, 
subject to the relevant terms (including post-vesting retention periods, 
malus and, where applicable, clawback). Any vesting of his LTI 
awards will be pro-rated for the period up to the departure date and 
will be subject to the relevant terms (including post-vesting retention 
periods, malus and clawback) and the achievement of the required 
performance conditions. For this purpose, his 2020 and 2021 LTI 
awards have been pro-rated for time with the maximum number of 
shares, being 495,597 and 254,966 respectively, still subject to 
performance. 

The Group will make a contribution towards Ewen Stevenson's legal 
fees incurred in connection with his departure arrangements. In line 
with the Directors' remuneration policy, Ewen Stevenson will be 
eligible to receive certain post-departure benefits for a period of up to 
seven years after the departure date.

Ewen Stevenson will receive no other compensation or payment for 
the termination of his service agreement or his ceasing to be a 
Director of the Group.

No other payments for loss of office were made to, or in respect of, 
former or current Directors in the year.

External appointments

During 2022, executive Directors did not receive any fees from 
external appointments.

288

HSBC Holdings plc Annual Report and Accounts 2022

Summary of shareholder return and Group 
Chief Executive remuneration

The 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 2022.

HSBC TSR and FTSE 100 Total Return Index

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.

Group Chief Executive

2013
Stuart 
Gulliver

2014
Stuart 
Gulliver

2015
Stuart 
Gulliver

2016
Stuart 
Gulliver

2017
Stuart 
Gulliver

Total single figure £000
Annual incentive1 (% of maximum)
Long-term incentive1,2,3 (% of maximum)

8,033
49%
49%

7,619
54%
44%

7,340
45%
41%

5,675
64%
–%

6,086
80%
–%

2018

2019

Stuart 
Gulliver

2,387
76%
100%

John 
Flint

4,582
76%
–%

John 
Flint

Noel 
Quinn

2,922
61%
–%

1,977
66%
–%

2020
Noel 
Quinn

4,154
32%
–%

2021
Noel 
Quinn

4,895
57%
–%

2022
Noel 
Quinn

5,562
75%
–%

1  The 2012 annual incentive figure for Stuart Gulliver 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 2013 to 
2015 are therefore related to awards granted in 2014 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 2019 LTI award that had a 
performance period ended on 31 December 2022.

Voting results from Annual General Meeting

2022 Annual General Meeting voting results

Remuneration report (votes cast)

Remuneration policy (votes cast)

For
95.83%

7,675,588,519

95.73%

7,666,488,029

Against
4.17%

334,152,471
4.27%
342,320,697

Withheld
––

6,830,718

––

7,773,468

HSBC Holdings plc Annual Report and Accounts 2022

289

HSBC TSRFTSE 100 Total Return IndexDec 2012Dec 2013Dec 2014Dec 2015Dec 2016Dec 2017Dec 2018Dec 2019Dec 2020Dec 2021Dec 2022100%200%Corporate governanceReport of the Directors | Corporate governance report | Directors’ remuneration report

Group Remuneration Committee
The Group Remuneration Committee is responsible for setting the 
overarching principles, parameters and governance of the Group’s 
remuneration framework for 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 plc. 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/who-we-
are/leadership-and-governance/board-committees.

The Committee met six times during 2022. Pauline van der Meer 
Mohr stepped down from the Committee and the Board after the 
2022 AGM, and was succeeded as Group Remuneration Committee 
Chair by Dame Carolyn Fairbairn. Geraldine Buckingham was 
appointed as a member of the Committee in June 2022. The 
following is a summary of the Committee’s key activities during 2022.

Matters considered during 2022

Jan

Feb May

Jul

Sep

Dec

Remuneration framework and governance
Group variable pay pool, workforce performance and pay matters, pay gap report, and employee insights
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
Governance matters
Principal subsidiaries
Matters from subsidiary committees

l
l
l
l
l

l
l
l

l

l
ô
l
l
l

l
l
l

ô

l
ô
l
l
ô

l
l
l

l

l
ô
l
l
ô

l
l
l

l

l
ô
l
l
ô

l
l
l

l

l
ô
l
l
l

l
l
l

l

l Matter considered

ô Matter not considered

Advisers

The Committee received input and advice from different advisers on 
specific topics during 2022. Deloitte provided independent advice to 
the Committee. Deloitte also provided tax compliance and other 
advisory services to the Group in 2022. 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 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 2022.

For 2022, total fees of £203,800 and £79,803 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.

During the year, the Committee conducted a tender process for its 
independent remuneration adviser. This involved participating firms 
submitting proposals and meeting with the Committee Chair and 
management. Following this process, Deloitte was reappointed as the 
Committee’s independent advisers.
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;

• Ewen Stevenson, who was Group Chief Financial Officer until 

31 December 2022;

• Jenny Craik, Group Head of Performance, Reward and Employee 

Relations;

• Pam Kaur, Group Chief Risk and Compliance Officer;

• Bob Hoyt, Group Chief Legal Officer; 

• Shawn Chen, former Global General Counsel for Litigation and 

Regulatory Enforcement;

• Maureen Lewis, Interim Global General Counsel for Litigation and 

Investigation; 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. 

No Director is present at Group Remuneration Committee meetings 
when their own remuneration is discussed.

In addition to the meetings above, the Group Risk Committee 
convened two joint meetings with the Group Remuneration 
Committee in September 2022 and December 2022. They reviewed 
the Group’s risk and reward alignment framework, which is designed 
to promote sound and effective risk management in meeting PRA and 
FCA remuneration rules and expectations.  
Committee effectiveness

The annual review of the effectiveness of the Board committees, 
including the Group Remuneration Committee, was conducted 
internally in 2022, led by the Group Company Secretary and Chief 
Governance Officer. Overall, the review concluded that the 
Committee continued to operate effectively and in line with regulatory 
requirements. 

Areas for continued enhancement were identified, including the need 
to focus on: a differentiated, fair and transparent reward framework; 
ESG performance metrics; and in particular, sustainability; the 
development of climate performance measures aligned to strategic 
net zero goals; and greater coordination with the Group Risk 
Committee. Given the anticipated changes to remuneration 
regulations and evolving shareholder views on remuneration, a 
structured training programme will be developed and delivered by the 
Committee’s independent remuneration advisers. The outcomes of 
the 2022 annual review have been reported to the Board, and the 
Group Remuneration Committee will track the progress in 
implementing recommendations during 2023.

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HSBC Holdings plc Annual Report and Accounts 2022

 
Non-executive Directors

(Audited)

The following table shows the total fees and benefits of non-executive Directors for 2022, together with comparative figures for 2021.

Fees and benefits

(Audited)
(£000)
Geraldine Buckingham3
Rachel Duan4
Dame Carolyn Fairbairn5
James Forese6
Steven Guggenheimer
Irene Lee7
José Antonio Meade Kuribreña8
Pauline van der Meer Mohr9
Eileen Murray10
David Nish
Jackson Tai
Mark Tucker
Total (£000)
Total ($000)

Fees1

2022

155   
225   
265   
689   
262   
488   
242   
92   
262   
477   
377   
1,500   
5,034   
6,199

2021

—   
67   
80   
572   
250   
556   
223   
291   
266   
482   
350   
1,500   
4,637   
5,710

Benefits2
2022

2021

—   
5   
1   
—   
10   
—   
14   
18   
—   
22   
25   
113   
208   
256

—   
—   
—   
—   
—   
—   
—   
—   
—   
10   
—   
33   
43   
53

Total

2022

155   
230   
266   
689   
272   
488   
256   
110   
262   
499   
402   
1,613   
5,242   
6,455

2021
— 
67 
80 
572 
250 
556 
223 
291 
266 
492 
350 
1,533 
4,680 
5,763

1 Fees are in line with the Directors’ remuneration policy that was approved at the 2022 AGM. No travel allowance was paid to non-executive Directors 
during 2021 due to travel restrictions. The payment of the travel allowance of £4,000 per annum (pro-rata) was paid following the resumption of travel 
by the Board in 2022. 

2 Benefits include taxable expenses such as accommodation, travel and subsistence relating to attendance at Board and other meetings at HSBC 

Holdings' registered offices. Amounts disclosed have been grossed up using a tax rate of 45%, where relevant. 

3 Appointed to the Board and the Group Nomination & Corporate Governance Committee on 1 May 2022, and appointed as a member of the Group 

Remuneration Committee and Group Risk Committee on 1 June 2022.
4 Appointed as a member of the Group Audit Committee on 1 June 2022.
5 Appointed as Chair of the Group Remuneration Committee effective 29 April 2022.
6 Stepped down as a member of the Group Audit Committee on 1 June 2022 and joined the Group Risk Committee on 1 June 2022. Includes fees of 

£447,000 (2021: £332,000) in relation to his role as Chair of HSBC North America Holdings, Inc. This fee was deferred for 2022.

7 Retired from the Board effective 29 April 2022. Includes fees of £434,000 (2021: £380,000) in relation to her roles as non-executive Director and 

Remuneration Committee Chair, Audit Committee member and Risk Committee member of The Hongkong and Shanghai Banking Corporation Limited 
and non-executive Chair, Nomination Committee Chair and member of the Audit, Risk and Remuneration Committees of Hang Seng Bank Limited.
8 Retired from the Group Risk Committee on 1 June 2022. Appointed as the designated workforce engagement non-executive Director on 1 June 2022.
9 Retired from the Board effective 29 April 2022.
10  Retired from the Group Risk Committee on 1 June 2022, and appointed as a member of Group Audit Committee on 1 June 2022.

Non-executive Directors’ interests in shares

(Audited)

The shareholdings of persons who were non-executive Directors in 
2022, including the shareholdings of their connected persons, at 
31 December 2022, or date of cessation as a Director if earlier, are 
set out below. 

Shares

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 2022 met the guidelines.

Geraldine Buckingham (appointed to the Board on 1 May 2022)
Rachel Duan
Dame Carolyn Fairbairn
James Forese
Steven Guggenheimer
Irene Lee (retired on 29 Apr 2022)
José Antonio Meade Kuribreña
Eileen Murray
David Nish 
Jackson Tai 
Mark Tucker
Pauline van der Meer Mohr (retired on 29 Apr 2022)

Shareholding 
guidelines (number 
of shares)

Share interests 
(number of shares)

15,000  
15,000  
15,000  
15,000  
15,000  
15,000  
15,000  
15,000  
15,000  
15,000  
15,000  
15,000  

15,000 
15,000 
15,000 
115,000 
15,000 
15,000 
15,000 
75,000 
50,000 
66,515 
307,352 
15,000 

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2023 fees for non-executive Directors

The table below sets out the 2023 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 
Designated workforce engagement non-executive Director

2023 fees
£
1,500,000
127,000
200,000
150,000
40,000
75,000
40,000
––
33,000
60,000
40,000

Chair
Member
Chair
Member
Chair
Member
Co-Chair

1  The Group Chairman does not receive a base fee or any other fee in respect of chairing of the Nomination & Corporate Governance Committee.
Service contracts

contracts, but are bound by letters of appointment issued for and on 
behalf of HSBC Holdings, which are available for inspection at HSBC 
Holdings’ registered office. There are no obligations in the non-
executive Directors’ letters of appointment that could give rise to 
remuneration payments or payments for loss of office.

Non-executive Directors 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 

2023 AGM
Geraldine Buckingham1
Kalpana Morparia1
David Nish

2024 AGM
James Forese

Steven Guggenheimer

Eileen Murray

Mark Tucker

2025 AGM
Rachel Duan

Dame Carolyn Fairbairn

José Antonio Meade Kuribreña

1  Geraldine Buckingham and Kalpana Morparia were appointed following the 2022 AGM and therefore their initial three-year appointment terms are subject 
to approval of their election by shareholders at the 2023 AGM. Their initial three-year term of appointment will end at the conclusion of the 2026 AGM, 
subject to annual re-election by shareholders’ at the relevant AGMs.

Our approach to workforce remuneration
Remuneration alignment with executive Directors

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 value-aligned behaviours. We set out below the key features and design characteristics of our remuneration 
framework, which will apply on a Group-wide basis, subject to compliance with local laws:

Overview of remuneration structure for employees

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.

Application for Group employees

• Fixed pay may include salary, fixed pay allowance, cash in lieu of pension and other cash

allowances in accordance with local market practice.

• It is based on predetermined criteria, non-discretionary, transparent and not reduced

based on performance.

• It represents a higher proportion of total compensation for more junior employees.
• Fixed pay 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.

Approach for executive 
Directors

• Consistent with approach 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,

• Provision of medical

life insurance, health assessment and relocation support.

insurance, life insurance, car
and tax return assistance.
Group Chief Executive is
eligible to receive
accommodation and a car
benefit in Hong Kong.

• All employees are eligible to be considered for a discretionary variable pay award.

• Annual incentive is

Individual awards are determined against objectives for performance set at the start of the
year.

• Annual incentives represent a higher proportion of total compensation for more senior
employees and will be more closely aligned to Group and business performance as
seniority increases.

• Variable pay 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.

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.

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Overview of remuneration structure for employees (continued)

Remuneration 
components and 
objectives

Buy-out awards
Support recruitment of 
key individuals.

Application for Group employees

Approach for executive 
Directors

• Buy-out awards may be offered if an individual holds any outstanding unvested awards 

• For new hires, the approach 

that are forfeited on resignation from the previous employer.

• The terms of the buy-out awards will not be more generous than the terms attached to 

the awards forfeited on cessation of employment with the previous employer.

is consistent with the 
approach taken for 
employees and policy 
approved by shareholders.

Target variable 
remuneration
Support recruitment of 
key individuals.

• Target variable pay is an indicative value, which is awarded in exceptional circumstances 

• For new hires, the approach 

for new hires, and is limited to the individual's first year of employment only, and is 
subject to a number of factors (such as the respective performance of the Group, 
business unit and individual), and the final value paid remains at the full discretion of 
HSBC. 

is consistent with the 
approach taken for 
employees and policy 
approved by shareholders.

Deferral
Align employee 
interests with the 
medium- to long-term 
strategy, stakeholder 
interests and values-
aligned behaviours.

• 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.

• The exceptional circumstances would typically involve a critical new hire and would also 

depend on the factors such as the seniority of the individual, where the new hire 
candidate is forfeiting any awards and the timing of the hire during the performance year. 

• 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 (33% vesting on the first and second anniversaries of grant and 34% on 
the third).

• 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 in 

specified roles with managerial responsibilities as prescribed under the PRA and FCA 
remuneration rules and seven years for individuals in PRA-designated senior management 
functions.

• In line with the PRA and FCA remuneration rules, and in 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 and awards granted to non-
MRTs on or after 1 January 2022 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 all Group MRTs and the majority of local MRTs, excluding executive Directors, a 

minimum 50% of the deferred awards is in HSBC shares and the rest into deferred cash. 
Local regulatory requirements would also apply where necessary.

• For some employees in our asset management business, where required by the relevant 
regulations, at least 50% of the deferred award is linked to fund units reflective of funds 
managed by those entities, with the remaining portion in 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.

Severance payments
Adhere to contractual 
agreements with 
involuntary leavers.

• 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. 

• Any payments will be in line 
with the policy on loss of 
office

• 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.

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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. 

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

Application

The Group variable pay pool is expected to reflect Group performance, based on a range of financial, non-financial and contextual 
factors. We 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, taking into account contextual factors driving performance, and 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.

Individual 
performance 
scorecard

Control 
function staff

• 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.

Variable pay 
adjustments 
and conduct 
recognition

Malus

Clawback

Sales 
incentives

Identification 
of MRTs

• 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 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 

variable pay awards.

Malus can be applied to unvested deferred awards (up to 100% of 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 (and awards granted to non-MRTs on 
or after 1 January 2022) 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, unless aligned with local market practice and with appropriate 

safeguards to avoid incentivising inappropriate sales behaviours. 

• 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.

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HSBC Holdings plc Annual Report and Accounts 2022

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

Method

A
A
A
A

Lower 
quartile

167:1
154:1
139:1
169:1

Median

95:1
90:1
85:1
105:1

Upper 
quartile

49:1
46:1
43:1
52:1

2022
2021
2020
2019

nearly 35,000 UK employees, other than the individual performing the 
role of Group Chief Executive. We calculated our pay quartiles and 
benefits information for our UK employees using:

• full-time equivalent annualised fixed pay, which includes salary and 

allowances, at 31 December 2022;

• variable pay awards for 2022;

• 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; 

Total pay and benefits amounts used to calculate the ratio

• gains realised from exercising awards from taxable employee 

Lower quartile

Median

Upper quartile

share plans; and

Total 
pay and 
benefits

33,284
31,727
29,833
28,920

Total 
salary

24,615
27,666
23,264
24,235

Total 
pay and 
benefits

58,257
54,678
48,703
46,593

Total 
pay and 
benefits

Total 
salary

113,778 95,000
106,951 84,000
75,000
96,386
72,840
93,365

Total 
salary

41,000
41,500
36,972
41,905

(£) Method

2022
2021
2020
2019

A
A
A
A

The increase in median ratio is primarily driven by a higher annual 
incentive payout than in 2021 to the Group Chief Executive, reflecting 
the improvement in the financial performance of the Group. This is 
described further in the Committee Chair‘s letter. 

The total pay and benefits for the median employee for 2022 was 
£58,257, a 6.5% increase compared with 2021.

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.

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 2022. 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 

• full-time equivalent value of taxable benefits and pension 

contributions. 

Full-time equivalent fixed pay and benefits for each employee have 
been calculated by using each employee’s data as at 31 December 
2022. Where an employee works part-time, fixed pay and benefits are 
grossed up, where appropriate, to full-time equivalent. One-off 
benefits 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 is the single 
figure of remuneration table for Noel Quinn. Total remuneration does 
not include an LTI as he has not received an LTI award with a 
performance period that ended during 2022. 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 differences in business mix and size; employment and 
compensation practices; methodologies for computing pay ratios; and 
assumptions used by companies, the reported ratios may not be 
comparable to our international and listed peers on the FTSE 100.
Relative importance of spend on pay

The following chart shows the change in:

• total staff pay between 2021 and 2022; and

• dividends and share buy-backs in respect of 2021 and 2022.

In 2022, total spend on pay was slightly lower than in 2021, while the 
distribution to shareholders increased by 29% compared with 2021, 
reflecting a higher dividend and the capital return to shareholders 
through the $1bn share buy-back announced in February 2022, which 
concluded in 2022. Dividends include an approximation of the amount 
payable in April 2023 in relation to the second interim dividend of 
$0.23 per ordinary share.
Relative importance of spend on pay

2022  —

$8,144m

$1,000m $9,144m

Total return to 
shareholder

2021  —

$5,070m

$2,000m

$7,070m

Employee pay

2022  —

2021  —

$18,366m

$18,742m

↑
29%

↓
-2%

Employee pay

Dividends

Share buy-back

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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 2022 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 2022 and 2020. The year-on-year percentage 

Annual percentage change in remuneration

change in fees noted in the table below is primarily driven by any pro-
rated fees received by the non-executive Director for 2022 and/or 
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 2022 are not included, which 
includes Geraldine Buckingham who joined on 1 May 2022.

Director/employees

Executive Directors
Noel Quinn2
Ewen Stevenson (retired on 31 
December 2022)

Non-executive Directors3
Kathleen Casey (retired on 24 
April 2020)
Laura Cha (retired on 28 May 
2021)4
Henri de Castries (retired on 28 
May 2021)4,5
Rachel Duan6
Dame Carolyn Fairbairn7
James Forese8
Steven Guggenheimer9
Irene Lee (retired on 29 April 
2022)
José Antonio Meade Kuribreña10
Pauline van der Meer Mohr 
(retired on 29 April 2022)10
Heidi Miller (retired on 28 May 
2021)4,5
Eileen Murray7
David Nish
Sir Jonathan Symonds (retired 
on 18 February 2020)
Jackson Tai10
Mark Tucker
Employee group11

Base 
salary/fees

2020

Benefits

Annual 
incentive

Base 
salary/fees

2021

Benefits

Annual 
incentive1

Base 
salary/fees

2022

Benefits

Annual 
incentive

151.7%

353.7%

20.2%

1.7%

-48.9%

99.0%

3.2%

25.3%

36.1%

2.6%

-25.0%

-58.4%

1.8%

-75.0%

117.3%

3.2%

133.3%

11.6%

-65.0%

200.0%

97.0%

—

4.1%

-75.0%

—

—

—

—

—

—

—

—

20.3%

28.7%

-100.0%

100.0%

17.7%

-75.0%

1.1%

-100.0%

—

—

108.7%

-50.0%

-86.5%

-10.8%

—

2.0%

-4.8%

-78.9%
-77.5%
2.3%

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

-20.0%

—

-58.8%

—

—

-59.4%

2,100.0%

—

—

257.5%
86.6%

1.8%

10.4%

—

—

—

—

—

-100.0%

-6.7%

-100.0%

-60.3%

121.7%
0.4%

171.4%

—

25.0%

—

—

-1.4%

—

1.0%

-100.0%
-36.5%
1.3%

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

25.2%

—

—

—

235.8%
231.1%
20.5%
4.8%

-12.2%

8.5%

-68.4%

—

-1.5%
-1.0%

—

7.7%

—

3.1%

—

—

—

—

—

—

—

—

—

—

—

—

120.0%

—

—

242.4%
7.0%

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

3.7%

1  Noel Quinn and Ewen Stevenson both voluntarily waived the cash portion of their 2020 annual incentive. The year-on-year percentage change 

between 2020 and 2021 would be -1% for Noel Quinn and 9% for Ewen Stevenson without this cash waiver.

2  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.
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 291 provides the underlying single figure of remuneration for non-executive Directors used to calculate the figures above.

3 

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 for 

attending Board and other meetings at HSBC Holdings’ registered offices. 

6  Appointed as member of the Group Audit Committee on 1 June 2022.
7   Appointed as Chair of the Group Remuneration Committee effective 29 April 2022.
8  Appointed as non-executive Chair of HSBC North America Holdings, Inc in 2021. Fees for 2021 included fees in relation to this role. 
9  Joined the Board during 2020 and therefore received fees for only part of 2020.
10  Received no taxable benefits in 2021, resulting in a 100% reduction from 2021. 
11  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.

296

HSBC Holdings plc Annual Report and Accounts 2022

Policy alignment with UK Corporate Governance Code

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.

• 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.

• 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 in our shareholder approved policy report (available in our Annual Report and 

Accounts 2021) 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.

Alignment with culture

Incentive schemes should drive behaviours 
consistent with the Group's purpose, values and 
strategy.

• In order for any annual incentive award to be made, each executive Director must achieve a 

required behaviour rating, which is assessed by reference to the HSBC Values.

• Annual incentive and LTI scorecards contain non-financial measures linked to our wider social 
obligations. 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.

HSBC Holdings plc Annual Report and Accounts 2022

297

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 
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 2022 variable pay information included in the following tables is 
based on the market value of awards. For share awards, the market 
value is based on HSBC Holdings’ share price at the date of grant 
(unless indicated otherwise). For cash awards, it is the value of 
awards expected to be paid to the individual over the deferral period.

Remuneration awarded for the financial year (REM1)

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)

Total remuneration ($m)

Supervisory 
function

Management 
function

Other senior 
management

Other 
identified 
staff

12.0
6.4
6.4
—
—
—
—
12.0
—
—
—
—
—
—
—
—
—
—
—
6.4

2.0
6.3
2.9
3.4
—
—
—
2.0
11.0
1.6
—
9.4
7.8
—
—
—
—
—
—
17.3

18.9
43.6
43.6
—
—
—
—
18.9
65.4
30.0
17.9
35.4
23.3
—
—
—
—
—
—
109.0

1,203.1
656.8
656.8
—
—
—
—
1,203.1
641.0
321.0
151.9
305.9
170.0
8.7
4.7
—
—
5.4
3.3
1,297.8

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 2022. 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 7 individuals for the purpose of calculating the ratio between fixed and 

variable components of 2022 total remuneration. 

5  27 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 $6.2m, of which $5.1m is fixed pay and $1.1m 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)

—
—

—

—
—

—
—
—
—

—

—

—
—

—

—
—

—
—
—
—

—

—

—
—

—

—
—

—
—
—
—

—

—

—
—

—

—
—

59.8
26.9
21.1
—

26.9

2.2

1  No guaranteed variable remuneration was awarded in 2022. 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 

298

HSBC Holdings plc Annual Report and Accounts 2022

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 amount 
of  deferred 
remuneration 
awarded for 
previous 
performance 
period that 
has vested 
but is subject 
to retention 
periods

—
—
—
—
—
—
31.1
2.9
28.2
—
—
—
114.3
43.3
70.0
1.0
—
—
853.1
359.1
474.2
13.9
—
5.9
998.5

—
—
—
—
—
—
2.6
0.5
2.1
—
—
—
15.7
6.4
8.5
0.8
—
—
232.5
85.2
139.0
5.4
—
2.9
250.8

—
—
—
—
—
—
28.5
2.4
26.1
—
—
—
98.6
36.9
61.5
0.2
—
—
620.6
273.9
335.2
8.5
—
3.0
747.7

—
—
—
—
—
—
-2.4
—
-2.4
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
-2.4

—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
—
—
—
—
—
1.9
—
1.9
—
—
—
3.0
—
2.9
0.1
—
—
21.6
—
21.6
0.7
—
-0.7
26.5

—
—
—
—
—
—
2.7
0.5
2.2
—
—
—
16.0
6.5
8.7
0.8
—
—
235.4
86.0
142.1
5.5
—
1.8
254.1

—
—
—
—
—
—
1.0
—
1.0
—
—
—
3.0
—
2.7
0.3
—
—
38.1
—
34.9
2.4
—
0.8
42.1

$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 2022. For details of variable pay awards granted for 2022, 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)

€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

Identified staff that are high 
earners as set out in Article 
450(i) CRR
246 
107 
48 
26 
12 
8 
7 
5 
6 
2 
3 
1 
1 
— 
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 2022

299

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

Supervisory 
function

Management 

function Total

Investment 
banking

Retail 
banking

Asset 
management

Corporate 
function

Independent 
internal 
control 
function

All 
other

Total

1,236.0

12.0

2.0

14.0

2.0

2.0

548.5

228.0

—

32.0

6.9

2.0

6.0

151.0

172.0

71.6

6.4   

—   

6.4   

17.3    23.7   

704.8   

225.2   

40.5   

189.0   

123.8    123.5 

11.0    11.0   

368.6   

107.6   

21.0   

92.4   

53.9    62.9 

6.3    12.7   

336.2   

117.6   

19.5   

96.6   

69.9    60.6 

Total number of 
identified staff
–  of which members of 

the Board

–  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)

1  Variable pay awarded in respect of 2022. 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 2022 are set out below: 

Emoluments

Directors' base salary, allowances and benefits in kind
Non-executive Directors' fees and benefits in kind
Pension contributions
Performance-related pay paid or receivable2
Inducements to join paid or receivable
Compensation for loss of office
Notional return on deferred cash
Total
Total ($000)

Noel Quinn
2022
£000
3,367   

—   
6,439   
—   
—   
31   
9,837   
12,113   

2021
£000
3,283   

—   
5,721   
—   
—   
22   
9,026   
12,414   

Ewen Stevenson

Non-executive Directors1

2022
£000
1,994   

—   
1,091   
1,180   
—   
—   
4,265   
5,252   

2021
£000
1,933 

—   
3,388   
754   
—   
—   
6,075   
8,356   

2022
£000

5,242   
—   
—   
—   
—   
—   
5,242   
6,455 

2021
£000

4,680 
— 
— 
— 
— 
— 
4,680 
5,763

1 Fees and benefits in kind for 2021 reflects the population as per the single figure table for non-executive Directors, which excludes individuals who 

have stepped down from the Board during 2021. 

2 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 2022 was $23,820,419. 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 £6,706 ($8,258), 
Stuart Gulliver valued at £6,706 ($8,258), John Flint valued at £9,996 
($12,309), and Marc Moses valued at £15,851 ($19,519). Tax return 
support was also provided to John Flint valued at £5,441 ($6,700), and 
Marc Moses valued at £2,500 ($3,079). The total aggregate value of 
benefits provided to former executive Directors was £47,200 
($58,123). 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.

300

HSBC Holdings plc Annual Report and Accounts 2022

There were payments under retirement benefit arrangements with 
two former Directors of $405,660. The provision at 31 December 
2022 in respect of unfunded pension obligations to former Directors 
amounted to $5,387,659. 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 2022, or for the period of appointment in 2022 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

13,404   
99   
23,237   
—   
—   
36,740   
45,242   

Senior management
41,639 
611 
56,616 
— 
— 
98,866 
121,745 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Emoluments by bands

Hong Kong dollars

$10,500,001 – $11,000,000
$19,500,001 – $20,000,000
$24,000,001 – $24,500,000
$25,500,001 – $26,000,000
$29,500,001 – $30,000,000
$39,500,001 – $40,000,000
$41,000,001 – $41,500,000
$44,000,001 – $44,500,000
$44,500,001 – $45,000,000
$45,500,001 – $46,000,000
$52,500,001 – $53,000,000
$53,000,001 – $53,500,000
$55,500,001 – $56,000,000
$56,500,001 – $57,000,000
$60,500,001 – $61,000,000
$61,000,001 – $61,500,000
$64,000,001 – $64,500,000
$69,000,001 – $69,500,000
$76,000,001 – $76,500,000
$82,500,001 – $83,000,000
$135,000,001 – $135,500,000

US dollars

$1,340,909 – $1,404,762
$2,490,259 – $2,554,112
$3,064,935 – $3,128,787
$3,256,493 – $3,320,346
$3,767,315 – $3,831,168
$5,044,371 – $5,108,224
$5,235,930 – $5,299,782
$5,619,047 – $5,682,899
$5,682,899 – $5,746,752
$5,810,605 – $5,874,458
$6,704,544 – $6,768,397
$6,768,397 – $6,832,250
$7,087,661 – $7,151,514
$7,215,367 – $7,279,219
$7,726,189 – $7,790,042
$7,790,042 – $7,853,894
$8,173,158 – $8,237,011
$8,811,686 – $8,875,539
$9,705,626 – $9,769,478
$10,535,712 – $10,599,565
$17,240,256 – $17,304,109

Number of highest paid 
employees

Number of senior 
management

—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
1   
1   
1   
1   
1   

1 
1 
1 
1 
1 
1 
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 20 April 2022, HSBC Holdings concluded a share buy-back 
programme of its ordinary shares of $0.50 each that had been 
announced in October 2021. Under this buy-back programme in 2022, 
a total of 191,466,093 ordinary shares were repurchased for 
cancellation on UK trading venues, including the London Stock 
Exchange, BATS, Chi-X, Turquoise and/or Aquis Exchange. 

On 3 May 2022, HSBC Holdings commenced a further share buy-back 
programme of its ordinary shares of $0.50 each up to a maximum 
consideration of $1.0bn. This programme concluded on 28 July 2022, 

with 86,606,357 ordinary shares repurchased for cancellation on the 
UK trading venues and 70,066,800 ordinary shares repurchased for 
cancellation on The Stock Exchange of Hong Kong Limited (’HKEx’). 

The purpose of both buy-back programmes was to reduce HSBC’s 
number of outstanding ordinary shares. 

As at 31 December 2022, the total number of ordinary shares 
purchased and cancelled during the year was 348,139,250, 
representing a nominal value of $174,069,625 and an aggregate 
consideration paid by HSBC of £1,426,598,865 on the UK trading 
venues and HK$3,514,580,618 on the HKEx. The shares cancelled 
represent 1.72% of the shares in issue and 1.74% 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 2022.

First share buy-back on UK trading venues in 2022
Month shares cancelled
Jan-22
Feb-22
Mar-22
Apr-22
Total

Second share buy-back on UK trading venues in 2022
Month shares cancelled
May-22
Jun-22
Jul-22
Aug-22
Total

Number
of shares 
purchased and 
cancelled

25,382,519 
19,064,151 
72,125,062 
74,894,361 
191,466,093 

Number
of shares 
purchased and 
cancelled

21,447,447 
31,082,904 
33,126,211 
949,795 
86,606,357 

Highest price
paid per share 

Lowest price
paid per share

Average price 
paid per share

Aggregate
price paid

£

5.2700
5.5510
5.4040
5.4100

£

4.4555
5.1530
4.4935
5.1460

£

4.9784
5.3395
4.9129
5.2608

£

126,363,981
101,793,492
354,343,000
394,002,122
976,502,595

Highest price
paid per share

Lowest price
paid per share

Average price 
paid per share

Aggregate
price paid

£

5.2700
5.4960
5.5530
5.2170

£

4.7800
4.9780
5.0840
5.1230

£

4.9911
5.2729
5.2598
5.1755

£

107,047,291
163,897,398
174,235,941
4,915,640
450,096,270

HSBC Holdings plc Annual Report and Accounts 2022

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Report of the Directors | Corporate governance report

Number of 
shares 
purchased and 
cancelled

5,244,800 
31,582,400 
33,239,600 
70,066,800 

Highest price 
paid per share

Lowest price 
paid per share

Average price  
paid per share

Aggregate 
price paid

(HK$)

(HK$)

(HK$)

(HK$)

52.8500
52.7000
52.3000

46.5000
48.2500
47.4000

50.8537
50.8657
49.3809

266,717,438
1,606,461,400
1,641,401,780
3,514,580,618

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 2022 was $10.7m.

Preference shares

The preference shares, which have preferential rights to income and 
capital, do not, in general, confer a right to attend and vote at general 
meetings.

There are three classes of preference shares in the share capital of 
HSBC Holdings: non-cumulative US dollar preference shares of $0.01 
each (‘dollar preference shares’); non-cumulative preference shares of 
£0.01 each (‘sterling preference shares’); and non-cumulative 
preference shares of €0.01 (‘euro preference shares’).

The sterling preference share in issue is a Series A sterling preference 
share. There are no dollar preference shares or euro preference 
shares in issue.

Information on dividends approved for 2021 and 2022 may be found 
in Note 8 on the financial statements on page 359.

Further details of the rights and obligations attaching to the HSBC 
Holdings’ issued share capital may be found in Note 32 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 2022

In addition to the share buy-back programme, 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.

Second share buy-back on HKEx in 2022
Month shares purchased
May-22
Jun-22
Jul-22
Total

Dividends

Dividends for 2022

An interim dividend of $0.09 for the 2022 half-year was paid on 
29 September 2022. For further details of the dividends approved in 
2022, see Note 8 on the financial statements.

On 21 February 2023, the Directors approved a second interim 
dividend for 2022 of $0.23 per ordinary share, making a total of $0.32 
for the 2022 full-year. The second interim dividend for 2022 will be 
payable on 27 April 2023 in cash in US dollars, or in sterling or Hong 
Kong dollars at exchange rates to be determined on 17 April 2023. As 
the second interim dividend for 2022 was approved after 
31 December 2022, it has not been included in the balance sheet of 
HSBC as a liability. The distributable reserves of HSBC Holdings at 
31 December 2022 were $35.2bn.

A quarterly dividend of £0.01 per Series A sterling preference share 
was paid on 15 March, 15 June, 15 September and 15 December 
2022. 

Dividends for 2023

The Group intends to pay quarterly dividends during 2023.  

A dividend of £0.01 per Series A sterling preference share was 
approved on 21 February 2023 for payment on 15 March 2023.
Share capital

Issued share capital

The nominal value of HSBC Holdings’ issued share capital paid up at 
31 December 2022 was $10,146,803,705 divided into 20,293,607,410 
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 2022.

Rights, obligations and restrictions attaching to shares

The rights and obligations attaching to each class of ordinary and non-
cumulative preference shares in our share capital are set out in full in 
our Articles of Association. The Articles of Association may be 
amended by special resolution of the shareholders and can be found 
on our website at www.hsbc.com/who-we-are/leadership-and-
governance/board-responsibilities.

Ordinary shares

HSBC Holdings has one class of ordinary share, which carries no right 
to fixed income. There are no voting restrictions on the issued 
ordinary shares, all of which are fully paid. On a show of hands, each 
member present has the right to one vote at general meetings. On a 
poll, each member present or voting by proxy is entitled to one vote 
for every $0.50 nominal value of share capital held. 

There are no specific restrictions on transfers of ordinary shares, 
which are governed by the general provisions of the Articles of 
Association and prevailing legislation.

Information on the policy adopted by the Board for paying interim 
dividends on the ordinary shares may be found in the ’Shareholder 
information’ section on page 418.

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Market value per share

from
£

to
£
5.1 

All-employee share plans1

HSBC Holdings
ordinary shares issued

Aggregate
nominal value

$

HSBC International Employee Share Purchase Plan

234,830   

117,415   

4.9385   

1   In respect of the HSBC Holdings Savings Related Share Option Plan (UK), no new shares were issued under this plan. All exercises were satisfied by 

market purchased shares. See page 309 for details of options granted, exercised and lapsed.

HSBC share plans

Vesting of awards under the HSBC Share Plan 2011

9,991,391   

4,995,696   

4.789   

5.498 

HSBC Holdings
ordinary shares issued

Aggregate
nominal value
$

Market value per share

from
£

to
£

Authorities to allot and to purchase shares and 
pre-emption rights

At the AGM in 2022, shareholders renewed the general authority for 
the Directors to allot new shares up to 13,475,996,328 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 2,021,399,449 ordinary shares. The 
Directors exercised their market purchase authority from both the 
2021 and 2022 AGMs and purchased 348,139,250 ordinary shares 
during the year.

In addition, shareholders gave authority for the Directors to grant 
rights to subscribe for, or to convert any security into, no more than 
4,042,798,898 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 32 on the financial statements. 

Other than as disclosed in the tables above headed ‘Share capital 
changes in 2022’, the Directors did not allot any shares during 2022.

Debt securities

In 2022, HSBC Holdings issued the equivalent of $25.4bn of debt 
securities in the public capital markets in a range of currencies and 
maturities in the form of senior and subordinated 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 29 and 32 on pages 393 and 402.

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 2022, pursuant to Chapter 6 of the UK Companies Act 
2006, 325,273,407 ordinary shares were held in treasury. This was 
the maximum number of shares held at any time during 2022, 
representing 1.60% of the shares in issue as at 31 December 2022. 
The nominal value of shares held in treasury was $162,636,704. 

Notifiable interests in share capital

During 2022, 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 (’Rule 5 of the DTRs’). 

On 13 February 2023, pursuant to Rule 5 of the DTRs, Norges Bank 
gave notice that on 10 February 2023 it had the following: a direct 
interest in HSBC Holdings ordinary shares of 598,657,162; and 

qualifying financial instruments with 9,249,895 voting rights that may 
be acquired if the instruments are exercised or converted, 
representing 2.998% and 0.046% respectively, of the total voting 
rights at that date. 

No further notifications had been received between 31 December 
2022 and 15 February 2023. 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 2022, 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 9 March 2022 that on 4 March 
2022 it had the following interests in HSBC Holdings ordinary 
shares: a long position of 1,701,656,169 shares and a short 
position of 19,262,061 shares, representing 8.27% and 0.09%, 
respectively, of the ordinary shares in issue at that date. 

• Ping An Asset Management Co., Ltd. gave notice on 

25 September 2020 that on 23 September 2020 it had a long 
position of 1,655,479,531 in HSBC Holdings ordinary shares, 
representing 8.00% of the ordinary shares in issue at that date.

Sufficiency of float

In compliance with the Rules Governing the Listing of Securities on 
The Stock Exchange of Hong Kong Limited, at least 25% of the total 
issued share capital has been held by the public at all times during 
2022 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, and purchases by HSBC Holdings under the share 
buy-back programme, 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 2022.

HSBC Holdings plc Annual Report and Accounts 2022

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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 2022 
had certain interests, all beneficial unless otherwise stated, in the 
shares or debentures of HSBC Holdings and its associated 
corporations. 

Directors’ interests – shares and debentures

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.

At 31 Dec 2022 or date of cessation, if earlier

At 1 Jan 2022, or
date of 
appointment,
if later

Beneficial
owner

Child
under 18
or spouse

Jointly 
with
another
person

Trustee

Total
interests

HSBC Holdings ordinary shares
Geraldine Buckingham1 (appointed to the Board on 1 May 2022)
Rachel Duan1
Dame Carolyn Fairbairn
James Forese1
Steven Guggenheimer1
Irene Lee (retired on 29 Apr 2022)
José Antonio Meade Kuribreña1
Eileen Murray1
David Nish 
Noel Quinn2
Ewen Stevenson2
Jackson Tai1,3
Mark Tucker
Pauline van der Meer Mohr (retired on 29 Apr 2022)

—   
—   
—   
115,000   
15,000   
15,000   
15,000   
75,000   
50,000   

15,000   
15,000   
15,000   
115,000   
—   
15,000   
15,000   
75,000   
—   
1,131,278    1,422,650   
838,154    1,064,626   
32,800   
307,352   
15,000   

66,515   
307,352   
15,000   

—   
—   
—   
—   
—   
—   
—   
—   
50,000   
—   
—   
11,965   
—   
—   

—   
—   
—   
—   
15,000   
—   
—   
—   
—   
—   
—   
21,750   
—   
—   

15,000 
—   
15,000 
—   
15,000 
—   
115,000 
—   
15,000 
—   
15,000 
—   
15,000 
—   
75,000 
—   
50,000 
—   
—    1,422,650 
—    1,064,626 
66,515 
—   
307,352 
—   
15,000 
—   

1 Geraldine Buckingham has an interest in 3,000, Rachel Duan has an interest in 3,000, 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, 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 276. At 31 December 2022, 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 –  3,940,314; and Ewen Stevenson – 3,135,841. Each Director’s total interests represents 
approximately 0.02% of the shares in issue and 0.02% 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.

There have been no changes in the shares or debentures of the 
current Directors from 31 December 2022 to the date of this report.

Board governance

Listing Rule 9.8.4 and other disclosures 

This section of the Annual Report and Accounts 2022 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
Emoluments waivers
Emissions
Energy efficiency
Principal activities of HSBC
Business review and future developments

Page references

285
302
302
301
291
47
49, 57, 59
12, 31, 108, 382
11–42, 44, 133, 142, 409

Appointment and re-election of Directors

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 Board may at any time appoint any person as a Director or 
secretary, either to fill a vacancy or as an additional officer. The Board 
may appoint any Director or secretary 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, with any 
individual's appointment beyond six years to be for a rolling one-year 
term and subject to thorough review and challenge with reference to 
the needs of the Board. Where Directors are appointed beyond six 
years, an explanation is 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 2022 AGM were elected and re-elected by 
shareholders.

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None of the Directors who retired during the year or who are not 
offering themselves for re-election at the 2023 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 a non-executive Director serving on 
the Board and as a member of any committee is no more than 75 
days per annum. Directors who also chair a large committee are 
expected to commit up to 100 days per annum with the Senior 
Independent Director expected to serve an additional 30 days per 
annum. The time commitment of the Group Risk Committee chair is 
up to 150 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 their total time 
commitments and potential conflicts of interest.
Conflicts of interest

The Board has an established policy and set of procedures, reviewed 
and amended in 2022, to ensure that the Board’s management of 
Directors’ conflicts of interest is effective. 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. As part of its 2022 review, the Board agreed that 
responsibility for the ongoing review of the conflicts register be 
conducted by the Board, having previously been overseen 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 each 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 its 
conflicts policy and procedures. All non-executive Directors are re-
vetted by the compliance team every three years following 
appointment and as part of such process all conflicts checks are 
refreshed.

Joint Company Secretary

Aileen Taylor is the Group Company Secretary and Chief Governance 
Officer.

In addition to being appointed as Deputy Group Secretary in 
December 2021, for administrative purposes, Hannah Ashdown (46) 
was also appointed in October 2022 as Joint Company Secretary. She 
is a Fellow of the Chartered Governance Institute UK and Ireland. 
Hannah has over 20 years’ governance and regulatory experience 
across multiple sectors including financial services, asset 
management, energy, leisure and retail.

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 2022, from the date of their appointment). 
The deed poll is available for inspection at the registered office of 
HSBC Holdings.

Additionally, Directors and pension trustees have the benefit of both 
Directors’ and officers’, and pension trustees’, liability insurances. 

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 2022, 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 and communication

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.

As set out in the Section 172(1) statement on page 20, the Board 
seeks to understand investor needs through ongoing dialogue 
between members of the Board and institutional investors throughout 
the year. For examples of such engagement, see ’Board decision 
making and engagement with stakeholders’ on page 20, the Board’s 
engagement with shareholders on page 256 and the Group 
Remuneration Committee Chair's letter on page 276. During 2022, 
approximately 570 meetings were held with institutional investors and 
analysts globally.

Our shareholder communications policy summarises how we 
communicate with our shareholders, including through financial 
reporting, general shareholder meetings, investor and analyst 
meetings and our website. The policy is reviewed annually by the 
Board, and in 2022 the Board confirmed that it was satisfied with its 
implementation and effectiveness. The policy can be found at 
www.hsbc.com/who-we-are/leadership-and-governance/board-
responsibilities.

We also publish our current and past financial results, investor 
presentations and shareholder information such as dividend payments 
and shareholder meeting details. Stock exchange announcements are 
also accessible on our website along with information for fixed 
income investors. For further details, see www.hsbc.com/investors.

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 2023 is planned to be held in Birmingham, UK at 
11:00am on Friday, 5 May 2023. Information on how to vote and 
participate, both in advance and on the day, can be found in the 
Notice of the 2023 AGM, which will be sent to shareholders on 24 
March 2023 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. Shareholders should monitor our website and announcements 
for any changes to these arrangements. 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.

HSBC Holdings plc Annual Report and Accounts 2022

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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 HSBC Holdings 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. 

Articles of Association

New Articles of Association were approved at the 2022 AGM. The 
principal changes included updates and changes to articles on hybrid 
meetings, general meetings, untraceable shareholders, Director share 
qualification, Directors’ reappointment, Directors’ written resolutions, 
distribution in specie and dividend forfeiture. The Articles of 
Association can be found at www.hsbc.com/who-we-are/leadership-
and-governance/board-responsibilities. For further details of the 2022 
Notice of AGM, see www.hsbc.com/agm.
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. 

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HSBC Holdings plc Annual Report and Accounts 2022

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 a voluntary Board Finance Committee, which consists of 
contributing eligible employees. The PACs recorded combined 
political donations of $100,250 during 2022 (2021: $15,500).
Charitable contributions

For details of charitable contributions, see page 84.
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 21 February 2023, the date of approval of the Annual 
Report and Accounts 2022.

The key risk management and internal control procedures include the 
following:

Global Principles

The Group’s Global Principles set an overarching standard for all 
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 
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 process to provide 
forward-looking views of issues with the potential to threaten the 
execution of our strategy or operations over the medium to long term. 

We remain committed to investing in the reliability and resilience of 
our IT systems and critical services, including those provided by third 
parties, 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. In our approach to defend 
against these threats, we invest in business and technical controls to 
help us detect, manage and recover from issues, including data loss, 
in a timely manner.

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 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 2022, the GRC continued to focus on the oversight of risk 
transformation activities to strengthen our risk management 
capabilities and to develop a best-in-class Risk function. In 2023, the 
GRC will continue to focus on overseeing emerging risks and 
potential risks arising from new products and offerings. 

The GRC and the GAC received assurance from executive 
management that a thorough risk assessment had been undertaken 
and controls were in place to mitigate the risks arising from the 
Group’s key activities. Necessary actions will be taken to remedy any 
failings or weaknesses identified from these activities.  
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 2022. In 2014, the GAC endorsed 
the adoption of the principles of the Committee of Sponsoring 
Organizations of the Treadway Commission (’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 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 of HSBC’s approach to 
risk management can be found on page 132. 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.

Group Disclosure and Controls Committee

Chaired by the Group Chief Financial Officer, the Group Disclosure 
and Controls 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 Group 
Disclosure and Controls 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 Group Disclosure and Controls Committee consists of senior 
management, including the Group Chief Financial Officer, Group Chief 
Risk and Compliance 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 Group 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 2022.

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 2022, 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. 

HSBC Holdings plc Annual Report and Accounts 2022

307

Corporate governanceReport of the Directors | Corporate governance report

Other information included in the Annual 
Report and Accounts 2022 

We include other non-statutory information in the Annual Report and 
Accounts to enable a broader perspective of our performance for the 
period, including ESG and regulatory capital and liquidity information. 
We highlight on pages 14 and 264 that we are seeking to enhance our 
governance, process, systems and controls in both areas, although 
the scale and nature of the challenges differ between reporting areas. 
Our improvements in regulatory reporting are to ensure this reporting 
is produced to a comparable standard of control as our financial 
reporting. ESG reporting is fast evolving, with few globally consistent 
reporting standards and a high reliance on external data. The GAC 
provides oversight to our reporting improvements in both areas, and 
is also focused on increasing the level of internal and external 
assurance in these areas, in line with wider market developments (set 
out on page 264). 
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 42.
Employees
At 31 December 2022, HSBC had a total workforce equivalent to 
219,000 full-time employees compared with 220,000 at the end of 
2021. Our main centres of employment were India with 
approximately 39,000 employees, the UK with 33,000, mainland 
China with 32,000, Hong Kong with 27,000, Mexico with 17,000 and 
France with 6,000.
Our business spans many cultures, communities and continents. We 
aspire to provide a high-performing 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 employee surveys to assess progress and 
make changes. We want to provide an open culture, where our 
colleagues feel connected and supported to speak up, and where our 
leaders encourage and use feedback. Where we make organisational 
changes, we support our colleagues, 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 laws 
and regulations in the jurisdictions in which we operate, including in 
relation to working hours and rest periods. 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 
stronger. We are dedicated to building a diverse and connected 
workforce where everyone feels a sense of belonging. In 2022, we 
introduced a social well-being index that measures the 
connectedness of our colleagues as we embrace hybrid working 
practices.
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 
their best selves to work. 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. 

308

HSBC Holdings plc Annual Report and Accounts 2022

We expect all colleagues at HSBC to 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, including those included in the Group executive scorecards, 
which enable us to pinpoint inclusion barriers and enable us to take 
action where required. Our approach to diversity and inclusion is set 
out on page 74 alongside our goals and progress. 
Further details of our diversity and inclusion activity, alongside our 
Gender and Ethnicity Pay Gap Reports 2022, 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.

Everyone at HSBC annually completes 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 
groups of colleagues 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 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.  
Our 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. In 2022, we rolled the platform out to an 
additional 83,000 colleagues and we will continue the global roll-out in 
2023. 
Effective people management and impactful leadership remain critical 
to our ability to energise for growth. Following the success of our 
refreshed executive development curriculum in 2021, we launched a 
new programme for our Managing Director colleagues in 2022. This 
combines internal programmes and business school activities with 
targeted technical programmes on key topics and skills. 
Health and safety
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 to 
ensure we are compliant with relevant laws and regulations.

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 2022 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, as well as 
reviewing and adjusting our risk control measures as government 
restrictions were lifted.

• We reinforced our advice and risk assessment and control 

methodology on working from home for employees adopting a 
hybrid work style, providing more awareness and best practices on 
good ergonomics and well-being.

• We delivered health and safety training and awareness to 240,000 
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 2022 
safety climate survey results showed that we continue to maintain 
a positive safety culture that is significantly above the industry 
average. A particular strength that the survey identified is our 
encouragement of colleagues to make suggestions on how to 
improve health and safety.

• We expanded our guidance and training programme for our 

construction partners, focusing on our key markets globally, to 
reduce the likelihood of accidents occurring by helping them 
understand and deliver industry-leading health and safety 
performance. More than 3,400 construction workers received 
safety passporting training across 20 countries.

• Our Eat Well Live Well programme continued educating and 

informing our colleagues on how to make healthy food and drink 
choices. Launched in 2019, and now live in 12 markets across all 
regions, the programme has helped to shift HSBC employee diets 
towards more sustainable choices, with a more than 50% rise in 
healthy food options being selected in our workplace catering 
outlets since launch. Furthermore, with digital health tools and 
over 50 healthy and plant-forward recipes created by chefs 
available online, employees are supported to continue to make 
healthy choices when away from the workplace.

• Protection of our colleagues and operations is of critical 

importance and we have effective controls in place to protect our 
people from natural disasters (such as storms and earthquakes). In 
2022, there were 38 named storms that passed over 1,667 of our 
buildings, resulting in no 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
Lost days due to work injury

2022 2021 2020
—
  — 
15
88
449

—
14 
64 
  485    358 

7   
70   

Remuneration 
HSBC’s pay and performance strategy is designed to reward 
competitively the achievement of long-term sustainable performance 
and attract and motivate the very best people, regardless of gender, 
ethnicity, age, disability or any other factor 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 292. 

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 2022 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 287.

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 
2022, 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 26 September 2022, the day before 
the options were granted and as derived from the Daily Official List, 
was £5.0160.

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 
31 jurisdictions, although no options are granted under this plan.

During 2022, approximately 189,000 employees were offered 
participation in these plans.

1  Fractures, dislocation, concussion, loss of consciousness, overnight 

admission to hospital.

HSBC Holdings Savings-Related Share Option Plan (UK)

Dates of awards

Exercise price

Usually exercisable

from

to

from
(£)

to
(£)

from

to

HSBC Holdings ordinary shares

At
1 Jan 2022

Granted

Exercised
during year1 during year2

Lapsed

At
during year 31 Dec 2022

22 Sep 2015 27 Sep 2022   2.6270    5.9640  1 Nov 2020 28 Apr 2028  

123,196,850   

8,928,527   

3,483,332    12,991,322    115,650,723 

1  Options over HSBC ordinary shares granted in response to approximately 9,564 applications from HSBC employees in the UK on 27 September 2022.
2  The weighted average closing price of the shares immediately before the dates on which options were exercised was £5.0534.

HSBC Holdings plc Annual Report and Accounts 2022

309

Corporate governance 
 
 
Report of the Directors | Corporate governance report

Statement of compliance 

The statement of corporate governance practices set out on pages 
239 to 311 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

UK Corporate Governance Code www.frc.org.uk

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 
('HKEx'))

Descriptions of the roles and 
responsibilities of the:

– Group Chairman

– Group Chief Executive

– Senior Independent Director

– Board

Board and senior management

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

www.hkex.com.hk

www.hsbc.com/who-we-are/
leadership-and-governance/board-
responsibilities

www.hsbc.com/who-we-are/
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 2022, save to the extent referred to in the 
next paragraph, HSBC complied with the provisions and requirements 
of both the UK and Hong Kong Corporate Governance Codes.

Dame Carolyn Fairbairn was appointed as Chair to the Group 
Remuneration Committee on 29 April 2022 and has been a member 
of such committee since September 2021. In approving Dame 
Carolyn Fairbairn's appointment, the Board considered the UK 
Corporate Governance Code expectation that the Chair has served at 
least 12 months as a member on the committee before assuming the 
position of Chair. Before her appointment she had served on the 
Group Remuneration Committee for eight months. However, given 
her previous experience as both a member and chair of the 
remuneration committees of other UK listed companies, the Board 
approved the appointment of Dame Carolyn Fairbairn as Chair. 

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 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

21 February 2023

310

HSBC Holdings plc Annual Report and Accounts 2022

Directors’ responsibility statement

The Directors are responsible for preparing the Annual Report and 
Accounts 2022, 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 2022 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 2022, 
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 240 
to 243 of the Annual Report and Accounts 2022, 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

• 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 262 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

21 February 2023

HSBC Holdings plc Annual Report and Accounts 2022

311

Corporate governance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.

313 

 Report of Independent Registered Public  
Accounting Firm to the Board of Directors  
and Shareholders of HSBC Holdings plc

324   Financial statements

335   Notes on the financial statements

Building on our international 
connections 

We aim to collaborate internationally to make a difference  
for our customers. In May 2022, we supported a Hong 
Kong-based client with its investment in one of London’s  
tallest skyscrapers. We helped C C Land Holdings Limited  
with a £605m refinancing of The Leadenhall Building in the  
City of London financial district. The international property 
development and investment company bought the 225-metre 
tall tower in 2017 for £1.15bn, in what was the second biggest 
sale of a UK building at the time. The refinancing was co-
ordinated by colleagues from our UK and Hong Kong  
teams, and incorporated support from three other banks.

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HSBC Holdings plc Annual Report and Accounts 2022

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 statements 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 2022 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.

We have audited the financial statements, included within the Annual Report and Accounts 2022 (the “Annual Report”), which comprise: the 
consolidated and company balance sheets as at 31 December 2022; 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 description of the 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 131 to 238 and 
the Directors remuneration report disclosures on pages 276 to 301.

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

We remained independent of the group in accordance with the ethical requirements that are relevant to our audit of the financial statements in 
the UK, which includes the FRC’s Ethical Standard, as applicable to listed public interest entities, and the International Code of Ethics for 
Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants 
(IESBA Code), and we have fulfilled our other ethical responsibilities in accordance with these requirements.

To the best of our knowledge and belief, we declare that non-audit services prohibited by either the FRC’s Ethical Standard or Article 5(1) of 
Regulation (EU) No 537/2014 were not provided to the company or its controlled undertakings.

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.

HSBC Holdings plc Annual Report and Accounts 2022

313

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

Our audit approach

Overview

Audit scope

•

This was the fourth year that it has been my responsibility to form this opinion on behalf of PricewaterhouseCoopers LLP, 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.

Key audit matters

•
•
•
•
•

Expected credit losses - Impairment of loans and advances (group)
Impairment of investment in associate - Bank of Communications Co., Ltd ('BoCom') (group)
Investments in subsidiaries (company)
Valuation of defined benefit pension obligations (group)
Held for sale accounting (group)

Materiality

•
•

Overall group materiality: US$1bn (2021: US$970m) based on 5% of adjusted profit before tax.
Overall company materiality: US$950m (2021: US$920m) 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$750m (2021: US$725m) (group) and US$712m (2021: US$690m) (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.

Held for sale accounting (group) is a new key audit matter this year. Otherwise, the key audit matters below are consistent with last year.

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HSBC Holdings plc Annual Report and Accounts 2022

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 (specifically the central and downside scenarios given these have the 
most material impact on ECL) and estimating management judgemental adjustments and significant discounted cash flows for material credit impaired 
exposures in relation to the China offshore unsecured commercial real estate portfolio. 
The level of estimation uncertainty and judgement has remained high during 2022 as a result of the uncertain macroeconomic and geopolitical 
environment, high levels of inflation and a rising global interest rate environment, as well as developments in China’s commercial real estate sector. 
Macroeconomic conditions vary between territories and industries, leading to uncertainty around judgements made in determining the severity and 
probability weighting of macroeconomic variable 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 prevailing macroeconomic 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 and 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, in particular in relation to the China commercial 
real estate offshore portfolio. 
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 corporate exposures, other than in relation to the China commercial real 

estate offshore portfolio;

• model methodologies themselves; and
• quantitative and qualitative criteria used to assess significant increases in credit risk.

Matters discussed with the Group Audit Committee

the severity of macroeconomic scenarios, and their related probability weightings, across territories;

We held discussions with the GAC covering governance and controls over ECL, with a significant focus on the uncertain prevailing macroeconomic 
conditions and developments in China’s commercial real estate sector. We discussed a number of areas, including:
•
• management judgemental adjustments and the nature and extent of analysis used to support those adjustments;
•

significant assumptions used to estimate the discounted cash inflow projections for defaulted exposures in relation to unsecured offshore China 
commercial real estate;

• 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.

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 macroeconomic scenarios and their probability weightings, 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 triggers;
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;
the calculation and approval of management judgemental adjustments to modelled outcomes; and
approval of significant individual impairments.

•
•
We involved our economic experts in assessing the significant assumptions made in determining the severity and probability weighting of 
macroeconomic variables (“MEV”) forecasts. These assessments considered the sensitivity of ECL to variations in the severity and probability 
weighting of MEV forecasts. We involved our modelling experts in assessing the appropriateness of the significant assumptions and methodologies 
used for models and certain management judgemental adjustments. We independently re-performed the calculations for a sample of those models 
and certain management judgemental adjustments. In respect of unsecured offshore China commercial real estate, we involved our business recovery 
experts in assessing certain significant management judgemental adjustments and discounted cash flows for a sample of credit impaired exposures. 
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;
• assumptions and critical data for a sample of credit impaired wholesale exposures; and 
• a sample of CRRs applied to the wholesale exposures.
We evaluated and tested the Credit Risk disclosures made in the Annual Report.

Relevant references in the Annual Report and Accounts 2022

• Credit risk disclosures, page 145.
• Group Audit Committee Report, page 262.
• Note 1.2(d):Financial instruments measured at amortised cost, page 340.
• Note 1.2(i): Impairment of amortised cost and FVOCI financial assets, page 341.

HSBC Holdings plc Annual Report and Accounts 2022

315

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

Impairment of investment in associate – Bank of Communications Co., Ltd (‘BoCom’) (group)

Nature of the key audit matter

At 31 December 2022, the fair value of the investment in BoCom, based on the share price, was US$15.2bn lower than the carrying value (‘CV’) of 
US$23.3bn.
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 $0.2bn 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, and expected credit losses;
• long term assumptions for profit and asset growth rates, expected credit losses, and effective tax rates; and
• capital related assumptions (risk-weighted assets as a percentage of total 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 11 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 the 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:
•
• obtaining evidence for data supporting significant assumptions including historic experience, external market information, third-party sources 

challenging the appropriateness of the significant assumptions and, where relevant, their interrelationships;

including analysts reports, information from BoCom management and historically available BoCom public information;
assessing the impact on the VIU of 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 meetings 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 2022

• Group Audit Committee Report, page 262.
• Note 1.2(a): Critical accounting estimates and judgements, page 338.
• Note 18: Interests in associates and joint ventures, page 379.

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HSBC Holdings plc Annual Report and Accounts 2022

 
Investments in subsidiaries (company)

Nature of the key audit matter

Management reviewed investments in subsidiaries for indicators of impairment and indicators that impairment charges recognised in prior periods may 
no longer exist or may have decreased in accordance with IAS 36 as at 31 December 2022. Where indicators have been identified management 
estimated the recoverable amount using the higher of value in use (‘VIU’) or fair value less cost to sell. Management’s assessment resulted in a partial 
reversal of an impairment charge of US$2.5bn in relation to the investment in HSBC Overseas Holdings (UK) Limited (‘HOHU’), which is an immediate 
holding company of certain businesses in North America. This resulted in investment in subsidiaries of $US167.5bn at 31 December 2022.
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 business plan for 2023 to 2027 focusing on revenue, cost and ECL forecasts including the impact of climate change risk;
• 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 reasonable 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 business plan and the prospects for HSBC’s businesses, as well as considering the achievement of 
historic forecasts;

• obtaining and evaluating evidence relating to significant assumptions, from a combination of historical 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 2022

• Note 19: Investments in subsidiaries, page 382.

Valuation of defined benefit pensions obligations (group)

Nature of the key audit matter

The group has a defined benefit obligation of US$25.7bn, of which US$18.8bn 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 obligations. 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 tested the accuracy of the calculation, 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 2022

• Group Audit Committee Report, page 262.
• Note 1.2(k): Critical accounting estimates and judgements, page 345.
• Note 5: Employee compensation and benefits, page 351.

HSBC Holdings plc Annual Report and Accounts 2022

317

Financial statements 
Report of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

Held for sale accounting (group)

Nature of the key audit matter

The group has agreements to sell a number of businesses as part of executing its strategy. This has resulted in US$115.9bn of assets and US$114.6bn 
of liabilities being classified as held for sale as at 31 December 2022, in relation to businesses in France, Canada, Russia and Greece. In addition to the 
assets and liabilities classified as held for sale, a loss of US$2.4bn has also been recognised in 2022 in relation to the sale of the business in France. 
For the assets and liabilities to be classified as held for sale, the sale needs to be considered highly probable and expected to complete within 12 
months of the date of classification. We focused our audit on the areas with greater levels of management judgement relating to the highly probable 
threshold being met including the expected timing of completion, the appropriateness of disclosures relating to the highly probable assessment and 
the loss recognised in relation to the sale of the business in France. 

Matters discussed with the Group Audit Committee

We discussed with the GAC the judgements made by management in determining if the highly probable thresholds were met as at 31 December 
2022. We also discussed the appropriateness of the disclosure made in the Annual Report which explained how management had concluded that 
transactions met the highly probable threshold as at 31 December 2022. 

How our audit addressed the Key Audit Matter

We tested governance and controls in place over the management process to determine if the highly probable threshold had been met on assets and 
liabilities classified as held for sale. 
We assessed the key judgments made by management to determine whether the highly probable thresholds were met as at 31 December 2022, 
including their assessment of remaining actions to complete the transactions, any regulatory requirements that need to be met, and the likelihood and 
expected timing of the transactions being approved by relevant regulators and shareholders.
We also tested the completeness and accuracy of the assets and liabilities that were classified as held for sale and the loss on sale recognised in 
relation to the French business. We evaluated and tested the disclosures made in the Annual Report in relation to assets and liabilities classified as 
held for sale.

Relevant references in the Annual Report and Accounts 2022

• Group Audit Committee Report, page 262.
• Note 1.2(o): Critical accounting estimates and judgements, page 347.
• Note 23: Assets held for sale and liabilities of disposal groups held for sale, page 389.

How we tailored the audit scope

We tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on the financial statements as a 
whole, taking into account the structure of the group and the company, the accounting processes and controls, and the industry in which they 
operate.

The risks that HSBC faces are diverse, with the interdependencies between them being numerous and complex. In performing our risk 
assessment we engaged with a number of stakeholders to ensure we appropriately understood and considered these risks and their 
interrelationships. This includes stakeholders within HSBC and our own experts within PwC. This engagement covered external factors across 
the geopolitical, macroeconomic and regulatory and accounting landscape, the impact of climate change risk as well as the internal environment 
at HSBC, driven by strategy and transformation.

We evaluated and challenged management's assessment of the impact of climate change risk, which is set out on page 46, including their 
conclusion that there is no material impact on the financial statements. In making this evaluation we considered management’s use of stress 
testing and scenario analysis to arrive at the conclusion that there is no material impact on the financial statements. We considered 
management's assessment on the areas in the financial statements most likely to be impacted by climate risk, including:

• the impact on ECL on loans and advances to customers, for both physical and transition risk;
• the forecast cashflows from management’s five year business plan and long term growth rates used in estimating recoverable amounts as 

part of impairment assessments of investments in subsidiaries, goodwill and intangible assets;

• the impact of climate related terms on the solely payments of principal and interest test for classification and measurement of loans and 

advances to customers; and

• climate risks relating to contingent liabilities as HSBC faces increased reputational, legal and regulatory risk as it progresses towards its 

climate ambition.

HSBC’s progress on their ESG targets is not included within the scope of this audit. We were engaged separately to provide independent limited 
assurance to the Directors over the following ESG data: 

• the 2019 and 2020 on-balance sheet financed emissions for 6 sectors in total (page 50);
• the cumulative progress made by HSBC on providing and facilitating sustainable financing and investments (page  57); and
• HSBC’s own operations’ scope 1, 2 and 3 (limited to business travel) greenhouse gas emissions data for 2022 (page 62); and supply chain 

greenhouse gas emissions for purchased goods and services, and capital goods for 2021 and 2022 (page 64).

The independent limited assurance reports, which explain the scope of our work and the procedures undertaken can be found on: 
www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre. The work performed for a limited assurance report is 
substantially less than the work performed for our financial audit, which provides reasonable assurance.

Through our risk assessment, we tailored our determination as to which entities and balances we needed to perform testing over to support our 
Group opinion, taking into consideration the complex and disaggregated group structure, the accounting processes and controls as well as the 
industry in which they operate. The risks of material misstatement can be reduced to an acceptable level by testing the most financially 
significant entities within the Group and those that drive particular significant risks identified as part of our risk assessment. This ensures that 
sufficient coverage has been obtained for each financial statement line item (FSLI). 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 The Hongkong and Shanghai Banking Corporation 
Limited, HSBC Bank plc, and HSBC North America Holdings Inc. 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. Banco. We obtained audit opinions over specific balances for 

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HSBC Holdings plc Annual Report and Accounts 2022

 
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 to incorporate elements of unpredictability into our audit scoping, extending the scope of work performed for both The Hongkong 
and Shanghai Banking Corporation India Branch, and HSBC Bank (China) Limited. These entities are also in scope for The Hongkong and 
Shanghai Banking Corporation Limited. This was undertaken with consideration of both the relative profitability of these entities in the region and 
the Group’s strategy.

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'). 
Whilst these operations centres are not separate components,  the IT and operational processes and controls are relevant to the financial 
information of the Significant Subsidiaries. Financial reporting processes and controls are also performed centrally in HSBC's Group Finance 
function and finance operation centres (‘Finance Operations’), including the impairment assessment of goodwill and intangible assets, the 
consolidation of the group's results, the preparation of financial statements, and management's oversight controls relevant to the group's 
financial reporting.

Group-wide processes or processes in DBS and Finance Operations are subject to specified audit procedures or an audit over specific FSLIs. 
These procedures primarily relate to testing of IT general controls, forward looking economic scenarios for ECL, operating expenses, intangible 
assets, valuation of financial instruments, intercompany eliminations, reconciliations and consolidation as well as payroll. 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, Mexico and the Philippines. 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

In March 2022, we held a meeting in Dubai with the partners and senior staff from the Group audit team and the PwC teams who undertake 
audits of the Significant Subsidiaries and the Operations Centres. The meeting focused primarily on reconnecting as a team after virtual 
interactions throughout the Covid-19 pandemic, reassessing our approach to auditing HSBC’s businesses, changes at HSBC and in our PwC 
teams, and how we continue to innovate and improve the quality of the audit. We also discussed our significant audit risks.

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$712m to US$50m. Certain Significant Subsidiaries were audited to a 
local statutory audit materiality that was a lower level than our allocated 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. Senior members of our team undertook at least one in-person site visit prior to the 
year end where a full scope audit was requested. We attended Audit Committee meetings for some of the Significant Subsidiaries. We also 
attended meetings with management for each of these Significant Subsidiaries at the year-end.

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 
84% of total assets and 69% of total operating income.

Using the work of others

We have increased our use of evidence provided by others through our reliance on management assurance testing of controls across the group. 
This included testing of controls performed by management themselves in certain low risk areas including reconciliations, footnote disclosure 
controls and certain automated controls. We re-performed a portion of the testing to ensure appropriate quality of testing, as well as assessing 
the competence and objectivity of those performing the testing.

We also used the work of PwC experts, for example economic experts for our work around the severity and probability weighting of 
macroeconomics variables 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.

HSBC Holdings plc Annual Report and Accounts 2022

319

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

Materiality

The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for materiality. These, together 
with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and extent of our audit procedures on the 
individual financial statement line items and disclosures and in evaluating the effect of misstatements, both individually and in aggregate on the 
financial statements as a whole.

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

Financial statements – group

Overall materiality

US$1bn (2021: US$970m).

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 qualitative 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 29, 
management believes it best reflects the performance of 
HSBC and how the group is run. We excluded the 
adjustments made by management on page 29 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$950m (2021: US$920m).

0.75% of total assets. This would result in an overall 
materiality of US$2bn and was therefore reduced below the 
group materiality.

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% (2021: 75%) of overall materiality, amounting to US$750m (2021: US$725m) for the group financial statements and 
US$712m (2021: US$690m) for the company financial statements.

In determining the performance materiality, we considered a number of factors - the history of misstatements, risk assessment and aggregation 
risk and the effectiveness of controls - and concluded that an amount at the upper end of our normal range was appropriate.

We agreed with the GAC that we would report to them misstatements identified during our audit above US$50m (group audit) (2021: US$48m) 
and US$50m (company audit) (2021: US$48m) 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 both internal risks (i.e.

strategy execution) and external risks (i.e. macroeconomic conditions);

• 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; and
• 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.

Our opinion on the financial statements does not cover the other information and, accordingly, we do not express an audit opinion or, except to 
the extent otherwise explicitly stated in this report, any form of assurance thereon. In connection with our audit of the financial statements, our 
responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial 
statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated. If we identify an apparent material 
inconsistency or material misstatement, we are required to perform procedures to conclude whether there is a material misstatement of the 
financial statements or a material misstatement of the other information. If, based on the work we have performed, we conclude that there is a 
material misstatement of this other information, we are required to report that fact. We have nothing to report based on these responsibilities.

320

HSBC Holdings plc Annual Report and Accounts 2022

With respect to the Strategic Report and Report of the Directors, we also considered whether the disclosures required by the UK Companies Act 
2006 have been included.

Based on our work undertaken in the course of the audit, the Companies Act 2006 requires us also to report certain opinions and matters as 
described below.
Strategic report and Report of the Directors

In our opinion, based on the work undertaken in the course of the audit, the information given in the Strategic Report and Report of the Directors 
for the year ended 31 December 2022 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 appropriate 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 and company 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.

HSBC Holdings plc Annual Report and Accounts 2022

321

Financial statementsReport of Independent Registered Public Accounting Firm to the Board of Directors and
Shareholders of HSBC Holdings plc

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

Based on our understanding of the group and industry, we identified that the principal risks of non-compliance with laws and regulations related 
to breaches of 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 in relation to cost targets, and management bias in accounting 
estimates. The group engagement team shared this risk assessment with the component auditors so that they could include appropriate audit 
procedures in response to such risks in their work. Audit procedures performed by the group engagement team and/or component auditors 
included:

• review of correspondence with and reports from 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;
• 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 assessment of the investment in BoCom, valuation of defined benefit pensions 
obligations, investment in subsidiaries and valuation of financial instruments;

• 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 controls 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 controls;

• 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; and
• 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 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 

322

HSBC Holdings plc Annual Report and Accounts 2022

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 Group Audit Committee ('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 
eight years, covering the years ended 31 December 2015 to 31 December 2022.
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

21 February 2023

HSBC Holdings plc Annual Report and Accounts 2022

323

Financial statementsFinancial statements

Financial statements

Contents
324

Consolidated income statement

325

326

327

328

331

331

332

333

334

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
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
Impairment loss relating to the planned sale of our retail banking operations in France5 
Other operating income/(loss)6
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 assets7
Amortisation and impairment of intangible assets
Goodwill impairment
Total operating expenses
Operating profit
Share of profit in associates and joint ventures
Profit before tax
Tax expense
Profit for the year
Attributable to:
–  ordinary shareholders of the parent company
–  preference shareholders of the parent company
–  other equity holders
–  non-controlling interests
Profit for the year

Basic earnings per ordinary share
Diluted earnings per ordinary share

Notes*

2

3

3

3

3

4

4

5

21

18

7

9

9

2022
$m
32,610   
55,059   
(22,449)   
11,451   
15,213   
(3,762)   
10,469   

(3,394)   

(77)   
226   
(3)   
12,825   
(2,378)   
(133)   
61,596   
(9,869)   
51,727   
(3,592)   
48,135   
(18,366)   
(11,091)   
(2,157)   
(1,716)   
—   
(33,330)   
14,805   
2,723   
17,528   
(858)   
16,670   

14,822   
—   
1,213   
635   
16,670   

$
0.75   
0.74   

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 

4,053   

2,081 

(182)   
798   
569   
10,870   
—   
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   

231 
455 
653 
10,093 
— 
527 
63,074 
(12,645) 
50,429 
(8,817) 
41,612 
(18,076) 
(11,115) 
(2,681) 
(2,519) 
(41) 
(34,432) 
7,180 
1,597 
8,777 
(2,678) 
6,099 

3,898 
90 
1,241 
870 
6,099 
$
0.19 
0.19 

*  For Notes on the financial statements, see page 335.
1 

Interest income includes $48,134m (2021: $30,916m; 2020: $35,293m) of interest recognised on financial assets measured at amortised cost and 
$6,386m (2021: $4,337m; 2020: $5,614m) of interest recognised on financial assets measured at fair value through other comprehensive income. 
Interest income is calculated using the effective interest method and comprises interest recognised on financial assets measured at either amortised 
cost or fair value through other comprehensive income. 
Interest expense includes $20,798m (2021: $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 impairment of goodwill of $425m.
6   Other operating income includes a loss on net monetary positions of $678m (2021: $224m, 2020: $128m) as a result of applying IAS 29 ‘Financial 

Reporting in Hyperinflationary Economies’.
Includes depreciation of the right-of-use assets of $723m (2021: $878m; 2020: $1,029m). 

7 

324

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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:
Fair value gains on property revaluation
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 year, net of tax
Total comprehensive income/(expense) 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/(expense) for the year

2022
$m
16,670   

2021
$m
14,693   

(5,468)   
(7,261)   
(20)   
67   
1,746   
(3,655)   
(4,207)   
(758)   
1,310   
(367)   
(367)   
(9,931)   

280   
(1,031)   
(1,723)   
692   

1,922   

2,573   
(651)   
107   
107   
—   
842   
(17,301)   
(631)   

(2,393)   
—   
1,213   
549   
(631)   

(2,139)   
(2,270)   
(464)   
(49)   
644   
(664)   
595   
(1,514)   
255   
103   
103   
(2,393)   

—   
(274)   
(107)   
(167)   

531   

512   
19   
(446)   
(443)   
(3)   
315   
(4,967)   
9,726   

7,765   
7   
1,303   
651   
9,726   

2020
$m
6,099 

1,750 
2,947 
(668) 
48 
(577) 
471 
(157) 
769 
(141) 
(73) 
(73) 
4,855 

— 
834 
1,223 
(389) 

167 

190 
(23) 
212 
212 
— 
193 
8,409 
14,508 

12,146 
90 
1,241 
1,031 
14,508 

HSBC Holdings plc Annual Report and Accounts 2022

325

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
Assets held for sale1
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
Liabilities of disposal groups held for sale1
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

Notes*

11

14

15

16

23

22

18

21

7

24

25

15

26

23

27

4

28

7

29

32

32

19

At

31 Dec
2022
$m

327,002   
7,297   
43,787   
218,093   
45,063   
284,146   
104,882   
924,854   
253,754   
425,564   
115,919   
156,866   
1,230   
29,254   
21,321   
7,498   
2,966,530   

43,787   
66,722   
1,570,303   
127,747   
7,864   
72,353   
127,327   
285,764   
78,149   
114,597   
133,240   
1,135   
114,844   
1,958   
2,422   
22,290   
2,770,502   

10,147   
14,664   
19,746   
(9,141)   
152,068   
187,484   
8,544   
196,028   
2,966,530   

31 Dec
2021
$m

403,018 
4,136 
42,578 
248,842 
49,804 
196,882 
83,136 
1,045,814 
241,648 
446,274 
3,411 
136,571 
970 
29,609 
20,622 
4,624 
2,957,939 

42,578 
101,152 
1,710,574 
126,670 
5,214 
84,904 
145,502 
191,064 
78,557 
9,005 
114,773 
698 
112,745 
2,566 
4,673 
20,487 
2,751,162 

10,316 
14,602 
22,414 
6,460 
144,458 
198,250 
8,527 
206,777 
2,957,939 

1 

‘Assets held for sale’ in 2021, including $2.4bn of loans and advances to customers in relation to our exit of mass market retail banking business in the 
US, were reported within ‘Prepayments, accrued income and other assets’ in the Annual Report and Accounts 2021. Similarly, $8.8bn of customer 
accounts classified as ‘Liabilities of disposal groups’ were previously presented within ‘Accruals, deferred income and other liabilities’.

*  For Notes on the financial statements, see page 335.

The accompanying notes on pages 335 to 417 and the audited sections in the Risk review on pages 131 to 238 (including ‘Measurement 
uncertainty and sensitivity analysis of ECL estimates’ on pages 153 to 162, and ‘Directors’ remuneration report’ on pages 276 to 301 form an 
integral part of these financial statements. 

These financial statements were approved by the Board of Directors on 21 February 2023 and signed on its behalf by:

Mark E Tucker
Group Chairman

Georges Elhedery
Group Chief Financial Officer

326

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of cash flows
for the year ended 31 December

Profit before tax
Adjustments for non-cash items:
Depreciation, amortisation and impairment
Net loss/(gain) from investing activities
Share of profits in associates and joint ventures
Loss 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 purchases of own shares for market-making and investment purposes
Net cash flow from change in stake of subsidiaries
Redemption of preference shares and other equity instruments
Subordinated loan capital issued
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
–  cash and cash equivalents held for sale4
–  less: items in the course of transmission to other banks
Cash and cash equivalents at 31 Dec3

2022
$m
17,528   

3,873   
11   
(2,723)   
2,639   
3,907   
635   
400   
(1,084)   
49,127   

20,181   
31,799   
(23,405)   
8,344   
(10,771)   
(91,194)   
4,344   
12,518   
(13,647)   
15,978   
944   
(194)   
(2,776)   
26,434   
(520,600)   
495,049   
(1,285)   
(3,530)   
(3,125)   
(989)   
(34,480)   
—   
(2,285)   
(91)   
(197)   
(2,266)   
7,300   
(1,777)   
(6,970)   
(6,286)   
(14,332)   
574,032   
(38,029)   
521,671   

327,002   
7,297   
72,295   
68,682   
26,727   
19,445   
8,087   
(7,864)   
521,671   

2021
$m
18,906   

4,286   
(647)   
(3,046)   
—   
(519)   
1,063   
467   
510   
18,937   

(9,226)   
(11,014)   
552   
(4,254)   
19,899   
95,703   
14,769   
(16,936)   
(11,425)   
(10,935)   
808   
(509)   
(3,077)   
104,312   
(493,042)   
521,190   
(1,086)   
3,059   
(2,479)   
(106)   
27,536   
1,996   
(707)   
(1,386)   
—   
(3,450)   
—   
(864)   
(6,383)   
(10,794)   
121,054   
468,323   
(15,345)   
574,032   

403,018   
4,136   
55,705   
76,658   
28,488   
11,241   
—   
(5,214)   
574,032   

2020
$m
8,777 

5,241 
(541) 
(1,597) 
— 
9,096 
1,164 
433 
(906) 
(25,749) 

13,150 
(14,131) 
9,950 
(1,962) 
(19,610) 
226,723 
(28,443) 
(9,075) 
(6,630) 
20,323 
761 
(495) 
(4,259) 
182,220 
(496,669) 
476,990 
(1,446) 
1,362 
(2,064) 
(603) 
(22,430) 
1,497 
— 
(181) 
— 
(398) 
— 
(3,538) 
(2,023) 
(4,643) 
155,147 
293,742 
19,434 
468,323 

304,481 
4,094 
51,788 
65,086 
30,023 
17,194 
— 
(4,343) 
468,323 

Interest received was $55,664m (2021: $40,175m; 2020: $45,578m), interest paid was $22,856m (2021: $12,695m; 2020: $17,440m) and 
dividends received (excluding dividends received from associates, which are presented separately above) were $1,638m (2021: $1,898m; 2020: 
$1,158m).

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 $(1.8)bn (2021: $(0.9)bn; 2020: $(3.5)bn) of securities. Non-cash 

changes during the year included foreign exchange gains/(losses) of $(1.1)bn (2021: $(0.3)bn; 2020: $0.5bn) and fair value gains/(losses) of $(3.1)bn 
(2021: $(1.0)bn; 2020: $1.1bn).

3 At 31 December 2022, $59.3bn (2021: $33.6bn; 2020: $41.9bn) was not available for use by HSBC, due to a range of restrictions, including currency 

exchange and other restrictions, of which $22.1bn (2021: $15.4bn; 2020: $16.9bn) related to mandatory deposits at central banks.

4   Includes $6.5bn of cash and balances at central banks (excluding the expected cash contribution as part of the planned sale of our retail banking 

operations in France. For further details, see Note 23); $1.3bn of reverse repurchase agreements with banks of one month or less and $0.2bn of loans 
and advances to banks of one month or less.

HSBC Holdings plc Annual Report and Accounts 2022

327

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

Consolidated statement of changes in equity
for the year ended 31 December

Called up
share
capital
and
share
premium

Other
equity
instru-
ments

$m

$m

24,918   22,414   
—   

—   

Retained
earnings3,4
$m
144,458   
16,035   

Other reserves

Cash
flow
hedging
reserve

Foreign
exchange
reserve

Financial
assets
at
FVOCI
reserve

$m
(634)   
—   

$m
(197)   
—   

$m
(22,769)   
—   

Merger
and other
reserves4,5
$m

Total
share-
holders’
equity

$m

30,060    198,250   
—    16,035   

Non-
controlling
interests

Total
equity

$m

$m
8,527    206,777 
635    16,670 

—   

—   

1,368   

(5,325)   

(3,613)   

(9,819)   

174    (17,215)   

(86)    (17,301) 

—   

—   

—   

(5,417)   

—   

—   

—   

(5,417)   

(51)   

(5,468) 

—   

—   

—   

—   

—   

—   

92   

—   

—   

(3,613)   

—   
—   

—   
—   

1,922   
—   

—   
—   

—   
—   

—   

—   

(1,029)   

—   

—   

—   

—   

—   
—   

—   

—   

92   

15   

107 

—   

(3,613)   

(42)   

(3,655) 

—   
174   

1,922   
174   

—   
106   

1,922 
280 

—   

(1,029)   

(2)   

(1,031) 

—   

—   
—   

—   

—   
—   

(367)   

842   
—   

—   

—   
—   

—   

—   
—   

—   

—   
(9,819)   

—   

—   
—   

(367)   

842   
(9,819)   

—   

(367) 

—   
(112)   

842 
(9,931) 

—   

—   

17,403   

(5,325)   

(3,613)   

(9,819)   

174   

(1,180)   

549   

(631) 

67   

—   

—   
—   
—    (2,668)   
—   
—   

(67)   

(6,544)   
402   
(2,499)   

—   

—   
—   
—   

—   

—   
—   
—   

—   

—   

400   

—   

—   

—   

—   
—   
—   

—   

—   

—   

—   

— 

—   
—   
2,499   

(6,544)   
(2,266)   
—   

(426)   
—   
—   

(6,970) 
(2,266) 
— 

—   

400   

—   

400 

(174)   
—   

—   
—   
24,811   19,746   

(1,000)   
(485)   
152,068   

—   
3   
(5,956)   

—   
2   
(3,808)   

—   
—   
(32,588)   

174   
304   

(1,000)   
(176)   
33,211    187,484   

(1,000) 
—   
(106)   
(282) 
8,544    196,028 

At 1 Jan 2022
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

–  property revaluation
–  remeasurement of defined benefit 

asset/liability

–  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

Dividends to shareholders
Redemption of securities2
Transfers6
Cost of share-based payment 
arrangements
Cancellation of shares7
Other movements
At 31 Dec 2022

328

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated statement of changes in equity (continued)
for the year ended 31 December

Other reserves

Called up 
share 
capital and 
share 
premium

Other
equity
instru-
ments

$m

$m

Retained
earnings3,4
$m

24,624   22,414   
—   

—   

140,572   
13,917   

Financial 
assets at 
FVOCI 
reserve

Cash 
flow
hedging
reserve

Foreign
exchange
reserve

$m
1,816   
—   

$m
457   
—   

$m
(20,375)   
—   

Merger 
and other 
reserves4,5
$m

Total
share-
holders’
equity

$m

26,935    196,443   
—    13,917   

Non- 
controlling
interests

Total
equity

$m

$m
8,552    204,995 
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)   

(10)   

(446) 

(664) 

—   

—   

531   

—   

—   

—   

—   

531   

—   

531 

—   

—   

(288)   

—   

—   

—   

—   

(288)   

14   

(274) 

—   

—   
—   

—   

—   
—   

103   

315   
—   

—   

—   
—   

—   

—   
—   

—   

—   
(2,394)   

—   

—   
—   

103   

315   
(2,394)   

—   

—   
1   

103 

315 
(2,393) 

—   

—   

14,578   

(2,455)   

(654)   

(2,394)   

—   

9,075   

651   

9,726 

354   

—   

—    2,000   
—   
—   
—    (2,000)   
—   
—   

(336)   

(4)   
(5,790)   
—   
(3,065)   

—   

—   
—   
—   
—   

—   

—   
—   
—   
—   

—   

—   

467   

(60)   
—   

—   
—   
24,918   22,414   

(2,004)   
40   
144,458   

—   

—   
5   
(634)   

—   

—   
—   
(197)   

—   

—   
—   
—   
—   

—   

—   

18   

—   

18 

—   
—   
—   
3,065   

1,996   
(5,790)   
(2,000)   
—   

—   
(593)   
—   
—   

1,996 
(6,383) 
(2,000) 
— 

—   

467   

—   

467 

—   
—   
(22,769)   

60   
—   

(2,004)   
45   
30,060    198,250   

—   
(83)   

(2,004) 
(38) 
8,527    206,777 

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

–  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

HSBC Holdings plc Annual Report and Accounts 2022

329

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

Consolidated statement of changes in equity (continued)
for the year ended 31 December

Other reserves

Called up
share
capital and
share
premium

Other
equity
instru-
ments

$m

$m

Retained
earnings3,4
$m

24,278   20,871   
—   

—   

136,679   
5,229   

Financial
assets at
FVOCI
reserve

Cash
flow
hedging
reserve

Foreign
exchange
reserve

$m
(108)   
—   

$m

(2)   
—   

$m
(25,133)   
—   

Merger
and other
reserves4,5
$m

Total
share-
holders’
equity

$m

27,370    183,955   
5,229   

—   

Non-
controlling
interests

Total
equity

$m

$m
8,713    192,668 
6,099 

870   

—   

—   

1,118   

1,913   

459   

4,758   

—   

8,248   

161   

8,409 

—   

—   

—   

1,746   

—   

—   

—   

1,746   

4   

1,750 

—   
—   

—   
—   

—   
—   

167 

—   

459   

—   

—   

167   

—   

—   

—   

—   

831   

—   

—   

—   
—   

—   

—   

—   
—   

167   
459   

45   
12   

212 
471 

—   

167   

—   

167 

—   

831   

3   

834 

—   
—   
—   

—   
—   
—   

(73)   
193   
—   

—   
—   
—   

—   
—   
—   

—   
—   
4,758   

—   
—   
—   

(73)   
193   
4,758   

—   
—   
97   

(73) 
193 
4,855 

—   

—   

6,347   

1,913   

459   

4,758   

—    13,477   

1,031    14,508 

346   

—   

—    1,500   
—   
—   
—   
—   
—   
—   

(339)   

(3)   
(1,331)   
(1,450)   
435   

—   

—   

434   

—   

—   
—   
—   
—   

—   

—   

43   
24,624   22,414   

(200)   
140,572   

11   
1,816   

—   

—   
—   
—   
—   

—   

—   
457   

—   

—   
—   
—   
—   

—   

—   

—   
—   
—   
(435)   

7   

1,497   
(1,331)   
(1,450)   
—   

—   

—   
(692)   
—   
—   

7 

1,497 
(2,023) 
(1,450) 
— 

—   

434   

—   

434 

—   
(20,375)   

—   

(146)   
26,935    196,443   

(500)   

(646) 
8,552    204,995 

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 due 
to movement in own credit risk
–  remeasurement of defined benefit 

asset/liability

–  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

1 

In 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 additional tier 1 instruments.

2  During 2022, HSBC Holdings redeemed €1,500m 5.250% perpetual subordinated contingent convertible capital securities and SGD1,000m 5.875% 

perpetual subordinated contingent convertible capital securities. For further details, see Note 32. In 2021, HSBC Holdings redeemed $2,000m 6.875% 
perpetual subordinated contingent convertible capital securities. In 2020, HSBC Holdings called and later redeemed $1,450m 6.20% non-cumulative US 
dollar preference shares.

3  At 31 December 2022, retained earnings included 554,452,437 treasury shares (2021: 558,397,704; 2020: 509,825,249). These include treasury shares 
held within HSBC’s insurance business’s 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 Securities 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 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, 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 2020, an impairment of $435m was recognised and a permitted transfer of this amount was made from the merger reserve to 
retained earnings. During 2022 and 2021, part-reversals of these impairments resulted in transfers from retained earnings back to the merger reserve 
of $2,499m and $3,065m respectively.

7 For further details, see Note 32. In October 2021, HSBC announced a share buy-back of up to $2.0bn, which was completed in April 2022. Additionally, 

HSBC announced a share buy-back of up to $1.0bn in February 2022, which concluded on 28 July 2022. 

330

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings income statement 
for the year ended 31 December 

Net interest expense
–  interest income
–  interest expense
Fee (expense)/income
Net income from financial instruments held for trading or managed on a fair value basis
Changes in fair value of designated debt and related derivatives1
Changes in fair value of other financial instruments mandatorily measured at fair value through profit 
or loss

Gains less losses from financial investments
Dividend income from subsidiaries
Other operating income
Total operating income
Employee compensation and benefits
General and administrative expenses
Reversal of impairment/(impairment) of subsidiaries
Total operating expenses
Profit before tax
Tax (charge)/credit2
Profit for the year

Notes*

3

3

3

5

2022
$m
(3,074)   
937   
(4,011)   
(3)   
2,129   
2,144   

(2,409)   

58   
9,478   
91   
8,414   
(41)   
(1,586)   
2,493   
866   
9,280   
3,077   
12,357   

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 

*  For Notes on the financial statements, see page 335.
1  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch.
2  The tax credit includes $2.2bn arising from the recognition of a deferred tax asset from historical tax losses in HSBC Holdings. This was a result of 
improved profit forecasts for the UK tax group, which accelerated the expected utilisation of these losses and reduced uncertainty regarding their 
recoverability. The amounts recorded within profit before tax with respect to dividend income from subsidiaries and reversal of impairment of 
subsidiaries are not subject to tax.

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

2022
$m
12,357   

2021
$m
10,834   

326   

435   
(109)   
326   
12,683   

267   

259   
8   
267   
11,101   

2020
$m
4,085 

176 

176 
— 
176 
4,261 

HSBC Holdings plc Annual Report and Accounts 2022

331

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

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
Deferred tax 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
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 335. 

Notes*

31 Dec 2022
$m

31 Dec 2021
$m

15

25

15

26

29

32

3,210   
52,322   
3,801   
26,765   
19,466   
5,242   
464   
167,542   
189   
2,100   
281,101   

314   
32,123   
6,922   
66,938   
1,969   
19,727   
—   
127,993   

10,147   
14,664   
19,746   
40,555   
67,996   
153,108   
281,101   

2,590 
51,408 
2,811 
25,108 
26,194 
1,513 
122 
163,211 
215 
— 
273,172 

111 
32,418 
1,220 
67,483 
4,240 
17,059 
311 
122,842 

10,316 
14,602 
22,414 
37,882 
65,116 
150,330 
273,172 

The accompanying notes on pages 335 to 417 and the audited sections in the Risk review on pages 131 to 238 (including ‘Measurement 
uncertainty and sensitivity analysis of ECL estimates’ on pages 153 to 162), and ‘Directors’ remuneration report’ on pages 276 to 301 form an 
integral part of these financial statements.

These financial statements were approved by the Board of Directors on 21 February 2023 and signed on its behalf by:

Mark E Tucker
Group Chairman

Georges Elhedery
Group Chief Financial Officer 

332

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 issued
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
–  cash collateral and net settlement accounts
–  treasury and other eligible bills

2022
$m
9,280   
(2,500)   
(2,428)   
1   
(73)   

(1,657)   
(914)   
4,712   
51   
196   
(5,625)   
(4,755)   
(3,394)   
215   
(4,391)   
(21,481)   
17,165   
(5,696)   
3,860   
(39)   
(6,191)   
67   
(2,266)   
(438)   
(2,298)   
7,300   
—   
18,076   
(10,094)   
(5,330)   
(1,214)   
3,803   
(6,779)   
13,535   
6,756   

3,210   
3,544   
2   

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   
(16,966)   
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   

2020
$m
4,250 
442 
87 
1 
354 

(327) 
(3,289) 
(1,657) 
(633) 
449 
3,063 
1,258 
1,366 
270 
5,192 
(11,652) 
9,342 
(2,558) 
1,516 
(33) 
(3,385) 
1,846 
— 
— 
— 
— 
(1,500) 
15,951 
(16,577) 
— 
(1,331) 
(1,611) 
196 
5,980 
6,176 

2,913 
249 
3,014 

Interest received was $2,410m (2021: $1,636m; 2020: $1,952m), interest paid was $3,813m (2021: $2,724m; 2020: $3,166m) and dividends 
received were $9,478m (2021: $11,404m; 2020: $8,156m).

HSBC Holdings plc Annual Report and Accounts 2022

333

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial statements

HSBC Holdings statement of changes in equity 
for the year ended 31 December

At 1 Jan 2022
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 shares2,3
Dividends to shareholders
Redemption of capital securities 
Transfers4
Other movements
At 31 Dec 2022

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
Transfers4
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 
Transfers4
Other movements5
At 31 Dec 2020

Other 
reserves

Called up
share
capital
$m

Share
premium
$m

Other
equity
instruments
$m

Retained
earnings1
$m

Merger 
and other
reserves
$m

Total
shareholders’
equity
$m

10,316   
—   
—   

14,602   
—   
—   

22,414   
—   
—   

—   
—   

5   
—   

(174)   
—   
—   
—   
—   

—   
—   

62   
—   

—   
—   
—   
—   
—   

—   
—   
—   
—   

—   
—   
(2,668)   
—   
—   

10,147   

14,664   

19,746   

65,116   
12,357   
326   

326   

12,683   
(161)   
—   
(1,001)   
(6,544)   
402   
(2,499)   
—   
67,996   

10,347   
—   
—   

14,277   
—   
—   

22,414   
—   
—   

65,005   
10,834   
267   

37,882   
—   
—   

—   

—   
—   
—   
174   
—   
—   
2,499   
—   
40,555   

34,757   
—   
—   

—   

—   

—   

267   

—   

—   
29   
—   
(60)   
—   
—   
—   
—   
10,316   

—   
325   
—   
—   
—   
—   
—   
—   
14,602   

—   
—   
2,000   
—   
—   
(2,000)   
—   
—   
22,414   

11,101   
(103)   
(20)   
(2,004)   
(5,790)   
—   
(3,065)   
(8)   
65,116   

10,319   
—   
—   

13,959   
—   
—   

20,743   
—   
—   

62,484   
4,085   
176   

—   
—   
—   
60   
—   
—   
3,065   
—   
37,882   

37,539   
—   
—   

—   

—   

—   

176   

—   

—   
28   
—   
—   
—   
—   
—   
10,347   

—   
318   
—   
—   
—   
—   
—   
14,277   

—   
—   
1,500   
—   
—   
—   
171   
22,414   

4,261   
2,540   
(15)   
(1,331)   
(1,450)   
435   
(1,919)   
65,005   

—   
(2,347)   
—   
—   
—   
(435)   
—   
34,757   

150,330 
12,357 
326 

326 

12,683 
(94) 
— 
(1,001) 
(6,544) 
(2,266) 
— 
— 
153,108 

146,800 
10,834 
267 

267 

11,101 
251 
1,980 
(2,004) 
(5,790) 
(2,000) 
— 
(8) 
150,330 

145,044 
4,085 
176 

176 

4,261 
539 
1,485 
(1,331) 
(1,450) 
— 
(1,748) 
146,800 

Dividends per ordinary share at 31 December 2022 were $0.27 (2021: $0.22; 2020: nil).

1  At 31 December 2022, retained earnings included 331,874,221 ($2,615m) treasury shares (2021: 329,871,829 ($2,542m); 2020: 326,766,253 

($2,521m)).

2 On 26 October 2021, HSBC announced a share buy-back of up to $2.0bn, which was completed on 20 April 2022.
3  On 3 May 2022, HSBC announced a share buy-back of up to $1.0bn, which was completed on 28 July 2022.
4  Permitted transfers from the merger reserve to retained earnings were made when the investment in HSBC Overseas Holdings (UK) Limited was 

previously impaired. In 2022, a part-reversal of this impairment resulted in a transfer from retained earnings back to the merger reserve of $2,499m 
(2021: $3,065m). At 31 December 2020, an additional impairment of $435m 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.

5 

334

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Contents
335

  1  Basis of preparation and significant accounting

 policies

  2  Net fee income
  3  Net income from financial instruments measured at fair 

value through profit or loss 

  4  Insurance business
  5  Employee compensation and benefits
  6  Auditors’ remuneration 
  7  Tax
  8  Dividends
  9  Earnings per share
  10  Segmental analysis
  11  Trading assets 
  12  Fair values of financial instruments carried at fair value 
  13  Fair values of financial instruments not carried at fair value 
  14  Financial assets designated and otherwise mandatorily 

measured at fair value through profit or loss

  15  Derivatives
  16  Financial investments
  17  Assets pledged, collateral received and assets 

transferred

  18  Interests in associates and joint ventures
  19  Investments in subsidiaries

20 Structured entities

348
349

349
351
356
357
359
360
360
363
363
370
371

372
376
378

379
382
384

386
389
389
391
391
392
392
392
393
396

401
402
404
405
405
408
409
409

  21  Goodwill and intangible assets
  22  Prepayments, accrued income and other assets
  23  Assets held for sale and liabilities of disposal groups held for sale
  24  Trading liabilities

25 Financial liabilities designated at fair value
26 Debt securities in issue
27 Accruals, deferred income and other liabilities
28 Provisions
29 Subordinated liabilities
30 Maturity analysis of assets, liabilities and off-balance sheet 

commitments

31 Offsetting of financial assets and financial liabilities
32 Called up share capital and other equity instruments
33 Contingent liabilities, contractual commitments and guarantees
34 Finance lease receivables
35 Legal proceedings and regulatory matters
36 Related party transactions
37 Events after the balance sheet date
38 HSBC Holdings’ subsidiaries, joint ventures and associates

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 2022 affecting these consolidated 
and separate financial statements. 

Standards adopted during the year ended 31 December 2022

There were no new accounting standards or interpretations that had a significant effect on HSBC in 2022. 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 2022 that are applicable to HSBC. However, the IASB has 
published a number of minor amendments to IFRSs that are effective from 1 January 2023 and 1 January 2024. 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 and December 2021. Following 
the amendments, IFRS 17 is effective for annual reporting periods beginning on or after 1 January 2023 and is applied retrospectively, with 
comparatives restated from 1 January 2022. IFRS 17 has been adopted in its entirety for use in the UK while it has been adopted by the EU 
subject to certain optional exemptions.  

IFRS 17 sets out the requirements that the Group will apply in accounting for insurance contracts it issues, reinsurance contracts it holds, and 
investment contracts with discretionary participation features. 

The Group is at an advanced stage in the implementation of IFRS 17, having put in place accounting policies, data and models, and made 
progress with preparing 2022 comparative data. We set out below our expectations of the impact of IFRS 17 compared with our current 
accounting policy for insurance contracts, which is set out in Note 1.2(j) on page 344.

HSBC Holdings plc Annual Report and Accounts 2022

335

Financial statements 
Notes on the financial statements

Under IFRS 17, no present value of in-force business (‘PVIF’) asset is recognised. Instead, the measurement of the insurance contracts liability is 
based on groups of insurance contracts and will include fulfilment cash flows, as well as the contractual service margin (‘CSM’), which 
represents the unearned profit. 

To identify groups of insurance contracts, individual contracts subject to similar dominant risk and managed together are identified as a portfolio 
of insurance contracts. Each portfolio is further separated by profitability group and issue date into periodic cohorts.

The fulfilment cash flows comprise: 

• the best estimates of future cash flows, including amounts expected to be collected from premiums and payouts for claims, benefits and 

expenses, which are projected using assumptions based on demographic and operating experience; 

• an adjustment for the time value of money and financial risks associated with the future cash flows; and 

• an adjustment for non-financial risk that reflects the uncertainty about the amount and timing of future cash flows.

In contrast to the Group’s IFRS 4 accounting where profits are recognised upfront, the CSM will be systematically recognised in revenue, as 
services are provided over the expected coverage period of the group of contracts without any change to the overall profit of the contracts. 
Losses resulting from the recognition of onerous contracts are recognised in the income statement immediately.

The CSM is adjusted depending on the measurement model of the group of insurance contracts. While the general measurement model 
(‘GMM’) is the default measurement model under IFRS 17, the Group expects that the majority of its contracts will be accounted for under the 
variable fee approach (‘VFA’), which is mandatory to apply for insurance contracts with direct participation features upon meeting the eligibility 
criteria. 

IFRS 17 requires entities to apply the standard retrospectively as if it had always applied, using the full retrospective approach (‘FRA’) unless it is 
impracticable. When the FRA is impracticable such as when there is a lack of sufficient and reliable data, an entity has an accounting policy 
choice to use either the modified retrospective approach (‘MRA’) or the fair value approach (‘FVA’). HSBC will apply the FRA for new business 
from 2018 at the earliest, subject to practicability, and the FVA for the majority of contracts for which the FRA is impracticable. Where the FVA is 
used, the measurement takes into account the cost of capital that a market participant within the jurisdiction would be expected to hold based 
on the asset and liability positions on the transition date.

The Group will make use of the option to re-designate eligible financial assets held to support insurance liabilities, currently measured at 
amortised cost, as financial assets measured at fair value through profit or loss. Following re-designation, interest income earned on these 
financial assets will no longer be shown in ‘net interest income’, and will instead form part of ‘net income/(expense) from assets and liabilities of 
insurance businesses, including related derivatives, measured at fair value through profit or loss’ in accordance with HSBC’s income and 
expense policy set out in Note 1.2(b) on page 339.

The Group will also make use of the risk mitigation option for a number of economic offsets between the VFA contracts and reinsurance 
contracts held that meet the requirements, and the other comprehensive income (‘OCI’) option to a limited extent for some contracts. 

Impact of IFRS 17

Changes to equity on transition are driven by the elimination of the PVIF asset, the re-designation of certain eligible financial assets in the scope 
of IFRS 9, the remeasurement of insurance liabilities and assets under IFRS 17, and the recognition of the CSM.

IFRS 17 requires the use of current market values for the measurement of insurance liabilities. The shareholder’s share of the investment 
experience and assumption changes will be absorbed by the CSM and released over time to profit or loss under the VFA. For contracts 
measured under GMM, the shareholder’s share of the investment volatility is recorded in profit or loss as it arises. Under IFRS 17, operating 
expenses will be lower as directly attributable costs will be incorporated in the CSM and recognised in the insurance service result.

While the profit over the life of an individual contract will be unchanged, its emergence will be later under IFRS 17.

All of these impacts will be subject to deferred tax.

Estimates of the opening balance sheet as at 1 January 2022 have been calculated and are presented below, showing separately the impact on 
the total assets, liabilities and equity of our insurance manufacturing operations and Group equity. These estimates are based on accounting 
policies, assumptions, judgements and estimation techniques that remain subject to change.

Impact of transition to IFRS 17, at 1 January 2022

Insurance manufacturing operations

Balance sheet values at 1 January 2022 under IFRS 4
Removal of PVIF
Replacement of IFRS 4 liabilities with IFRS 17
Removal of IFRS 4 liabilities and recording of IFRS 17 fulfilment cash 
IFRS 17 contractual service margin
Remeasurement effect of IFRS 9 re-designations
Tax effect
Estimated balance sheet values at 1 January 2022 under IFRS 17

Assets
$bn
144.6

(9.5)   
(0.4) 
(0.3)   
(0.1) 
4.9  
0.6  

140.2

Liabilities
$bn
127.6  
—   
7.3  
(2.2) 
9.5  
— 
(1.6) 

133.3

Equity
$bn
17.0   
(9.5)   
(7.7)   
1.9  
(9.6)   
4.9  
2.2  
6.9  

Group

Equity
$bn
206.8 
(9.5) 
(8.1) 
1.9 
(10.0) 
4.9 
2.2 
196.3 

PVIF of $9.5bn less deferred tax of $1.7bn constitute the overall estimated reduction in intangible assets, after tax, of $7.8bn on transition to 
IFRS 17.

The Group’s accounting for insurance contracts considers a broader set of cash flows than those arising within the insurance manufacturing 
entities. This includes the effect of eliminating intra-Group fees associated with distribution of policies through the Group’s banking channels and 
directly attributable costs incurred by other Group entities. These factors lead to an increase to the Group CSM after inclusion of distribution 
activities of approximately $0.4bn, with a consequential reduction to Group’s equity of approximately $0.4bn after the inclusion of deferred tax. 

(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.

336

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
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. Except for 
subsidiaries operating in hyperinflationary economies (see Note 1.2(p)), 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 2022 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 131 to 238.

• The ‘Own funds disclosure’ is included in the ‘Risk review’ on page 206.

• Disclosures relating to HSBC’s securitisation activities and structured products are included in the ‘Risk review’ on pages 131 to238.

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.

Management has considered the impact of climate-related risks on HSBC’s financial position and performance. While the effects of climate 
change are a source of uncertainty, as at 31 December 2022 management do not consider there to be a material impact on our critical 
judgements and estimates from the physical, transition and other climate-related risks in the short to medium term. In particular management 
has considered the known and observable potential impact of climate-related risks of associated judgements and estimates in our value in use 
calculations.

(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 in structural changes from the Covid-19 pandemic, the 
Russia-Ukraine war, disrupted supply chains globally, slower Chinese economic activity, climate change and other top and emerging risks, as 
well as from the related impacts on profitability, capital and liquidity. 

1.2 Summary of significant accounting policies

(a)  Consolidation and related policies

Investments in subsidiaries

Where an entity is governed by voting rights, HSBC consolidates when it holds – directly or indirectly – the necessary voting rights to pass 
resolutions by the governing body. In all other cases, the assessment of control is more complex and requires judgement of other factors, 
including having exposure to variability of returns, power to direct relevant activities, and whether power is held as agent or principal.

Business combinations are accounted for using the acquisition method. The amount of non-controlling interest is measured either at fair value or 
at the non-controlling interest’s proportionate share of the acquiree’s identifiable net assets. This election is made for each business 
combination. HSBC Holdings’ investments in subsidiaries are stated at cost less impairment losses.

Impairment testing is performed where there is an indication of impairment, by comparing the recoverable amount of the relevant investment to 
its carrying amount. 

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Financial statements 
Notes on the financial statements

Critical accounting estimates and judgements 

Investments in subsidiaries are tested for impairment when there is an indication that the investment may be impaired, which involves estimations of 
value in use reflecting management’s best estimate of the future cash flows of the investment and the rates used to discount these cash flows, both of 
which are subject to uncertain factors as follows:
Judgements
• The accuracy of forecast cash flows is subject to a 

Estimates
• The future cash flows of each investment are sensitive to the cash flows projected for the 

high degree of uncertainty in volatile market 
conditions. Where such circumstances are 
determined to exist, management re-tests 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.

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 the investment. The cost of equity 
percentage is generally derived from a capital asset pricing model and the 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 impairment in subsidiaries are described in Note 19.

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

• 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.

Estimates
• 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.

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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

(b)

Income and expense

Operating income

Interest income and expense

Estimates
• Management’s best estimate of BoCom’s earnings is 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.

Interest income and expense for all financial instruments, excluding those classified as held for trading or designated at fair value, are recognised 
in ‘Interest income’ and ‘Interest expense’ in the income statement using the effective interest method. However, as an exception to this, 
interest on debt instruments issued by HSBC for funding purposes that are designated under the fair value option to reduce an accounting 
mismatch and on derivatives managed in conjunction with those debt instruments is included in interest expense.

Interest on credit-impaired financial assets is recognised using the rate of interest used to discount the future cash flows for the purpose of 
measuring the impairment loss.

Non-interest income and expense

HSBC generates fee income from services provided at a fixed price over time, such as account service and card fees, or when HSBC delivers a 
specific transaction at a point in time, such as broking services and import/export services. With the exception of certain fund management and 
performance fees, all other fees are generated at a fixed price. Fund management and performance fees can be variable depending on the size 
of the customer portfolio and HSBC’s performance as fund manager. Variable fees are recognised when all uncertainties are resolved. Fee 
income is generally earned from short-term contracts with payment terms that do not include a significant financing component.

HSBC acts as principal in the majority of contracts with customers, with the exception of broking services. For most brokerage trades, HSBC 
acts as agent in the transaction and recognises broking income net of fees payable to other parties in the arrangement.

HSBC recognises fees earned on transaction-based arrangements at a point in time when it has fully provided the service to the customer. 
Where the contract requires services to be provided over time, income is recognised on a systematic basis over the life of the agreement.

Where HSBC offers a package of services that contains multiple non-distinct performance obligations, such as those included in account service 
packages, the promised services are treated as a single performance obligation. If a package of services contains distinct performance 
obligations, such as those including both account and insurance services, the corresponding transaction price is allocated to each performance 
obligation based on the estimated stand-alone selling prices.

Dividend income is recognised when the right to receive payment is established. This is the ex-dividend date for listed equity securities, and 
usually the date when shareholders approve the dividend for unlisted equity securities.

Net income/(expense) from financial instruments measured at fair value through profit or loss includes the following: 

• ‘Net income from financial instruments held for trading or managed on a fair value basis’: This comprises net trading income, which includes 
all gains and losses from changes in the fair value of financial assets and financial liabilities held for trading and other financial instruments 
managed on a fair value basis, together with the related interest income, expense and dividends, excluding the effect of changes in the credit 
risk of liabilities managed on a fair value basis. It also includes all gains and losses from changes in the fair value of derivatives that are 
managed in conjunction with financial assets and liabilities measured at fair value through profit or loss.

• ‘Net income/(expense) from assets and liabilities of insurance businesses, including related derivatives, measured at fair value through profit 
or loss’: This includes interest income, interest expense and dividend income in respect of financial assets and liabilities measured at fair 
value through profit or loss; and those derivatives managed in conjunction with the above that can be separately identifiable from other 
trading derivatives.

• ‘Changes in fair value of designated debt instruments and related derivatives’: Interest paid on debt instruments and interest cash flows on 

related derivatives is presented in interest expense where doing so reduces an accounting mismatch.

• ‘Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss’: This includes interest on 

instruments that fail the solely payments of principal and interest test, see (d) below.

The accounting policies for insurance premium income are disclosed in Note 1.2(j).

(c)

Valuation of financial instruments 

All financial instruments are initially recognised at fair value. Fair value is the price that would be received to sell an asset or paid to transfer a 
liability in an orderly transaction between market participants at the measurement date. The fair value of a financial instrument on initial 
recognition is generally its transaction price (that is, the fair value of the consideration given or received). However, if there is a difference 
between the transaction price and the fair value of financial instruments whose fair value is based on a quoted price in an active market or a 
valuation technique that uses only data from observable markets, HSBC recognises the difference as a trading gain or loss at inception (a ‘day 1 
gain or loss’). In all other cases, the entire day 1 gain or loss is deferred and recognised in the income statement over the life of the transaction 
until the transaction matures, is closed out, the valuation inputs become observable or HSBC enters into an offsetting transaction. The fair value 
of financial instruments is generally measured on an individual basis. However, 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.

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Financial statements 
Notes on the financial statements

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 
inputs if, in the opinion of management, greater than 5% of the instrument’s 
valuation is driven by unobservable inputs.

• ‘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

• Details on the Group’s level 3 financial instruments and the 

sensitivity of their valuation to the effect of applying reasonably 
possible alternative assumptions in determining their fair value 
are set out in Note 12.

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 sold shortly after origination, the commitment to lend is recorded as a derivative. When HSBC intends to hold the 
loan, the loan commitment is included in the impairment calculations set out below.

Non-trading reverse repurchase, repurchase and similar agreements

When debt securities are sold subject to a commitment to repurchase them at a predetermined price (‘repos’), they remain on the balance sheet 
and a liability is recorded in respect of the consideration received. Securities purchased under commitments to resell (‘reverse repos’) are not 
recognised on the balance sheet and an asset is recorded in respect of the initial consideration paid. Non-trading repos and reverse repos are 
measured at amortised cost. The difference between the sale and repurchase price or between the purchase and resale price is treated as 
interest and recognised in net interest income over the life of the agreement.

Contracts that are economically equivalent to reverse repo or repo agreements (such as sales or purchases of debt securities entered into 
together with total return swaps with the same counterparty) are accounted for similarly to, and presented together with, reverse repo or repo 
agreements.

(e)

Financial assets measured at fair value through other comprehensive income 

Financial assets held for a business model that is achieved by both collecting contractual cash flows and selling and which contain contractual 
terms that give rise on specified dates to cash flows that are solely payments of principal and interest are measured at fair value through other 
comprehensive income (‘FVOCI’). These comprise primarily debt securities. They are recognised on the trade date when HSBC enters into 
contractual arrangements to purchase and are normally derecognised when they are either sold or redeemed. They are subsequently 
remeasured at fair value and changes therein (except for those relating to impairment, interest income and foreign currency exchange gains and 
losses) are recognised in other comprehensive income until the assets are sold. Upon disposal, the cumulative gains or losses in other 
comprehensive income are recognised in the income statement as ‘Gains less losses from financial instruments’. Financial assets measured at 
FVOCI are included in the impairment calculations set out below and impairment is recognised in profit or loss.

(f) 

Equity securities measured at fair value with fair value movements presented in other comprehensive income

The equity securities for which fair value movements are shown in other comprehensive income are business facilitation and other similar 
investments where HSBC holds the investments other than to generate a capital return. Dividends from such investments are recognised in 
profit or loss. 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.

(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’ or ‘Changes in fair value of designated debt and related derivatives’ 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 criteria, 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.

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HSBC Holdings plc Annual Report and Accounts 2022

 
• 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 where doing so reduces an accounting 
mismatch, the contractual interest is shown in ‘Interest expense’ together with the interest payable on the issued debt.

Hedge accounting

When derivatives are not part of fair value designated relationships, if held for risk management purposes they are designated in hedge 
accounting relationships where the required criteria for documentation and hedge effectiveness are met. HSBC uses these derivatives or, where 
allowed, other non-derivative hedging instruments in fair value hedges, cash flow hedges or hedges of net investments in foreign operations as 
appropriate to the risk being hedged.

Fair value hedge

Fair value hedge accounting does not change the recording of gains and losses on derivatives and other hedging instruments, but results in 
recognising changes in the fair value of the hedged assets or liabilities attributable to the hedged risk that would not otherwise be recognised in 
the income statement. If a hedge relationship no longer meets the criteria for hedge accounting, hedge accounting is discontinued and the 
cumulative adjustment to the carrying amount of the hedged item is amortised to the income statement on a recalculated effective interest rate, 
unless the hedged item has been derecognised, in which case it is recognised in the income statement immediately.

Cash flow hedge

The effective portion of gains and losses on hedging instruments is recognised in other comprehensive income and the ineffective portion of the 
change in fair value of derivative hedging instruments that are part of a cash flow hedge relationship is recognised immediately in the income 
statement within ‘Net income from financial instruments held for trading or managed on a fair value basis’. The accumulated gains and losses 
recognised in other comprehensive income are reclassified to the income statement in the same periods in which the hedged item affects profit 
or loss. When a hedge relationship is discontinued, or partially discontinued, any cumulative gain or loss recognised in other comprehensive 
income remains in equity until the forecast transaction is recognised in the income statement. When a forecast transaction is no longer expected 
to occur, the cumulative gain or loss previously recognised in other comprehensive income is immediately reclassified to the income statement.

Net investment hedge

Hedges of net investments in foreign operations are accounted for in a similar way to cash flow hedges. The effective portion of gains and 
losses on the hedging instrument is recognised in other comprehensive income and other gains and losses are recognised immediately in the 
income statement. Gains and losses previously recognised in other comprehensive income are reclassified to the income statement on the 
disposal, or part-disposal, of the foreign operation.

Derivatives that do not qualify for hedge accounting

Non-qualifying hedges are derivatives entered into as economic hedges of assets and liabilities for which hedge accounting was not applied.

(i) 

Impairment of amortised cost and FVOCI financial assets

Expected credit losses (‘ECL’) are recognised for loans and advances to banks and customers, non-trading reverse repurchase agreements, other 
financial assets held at amortised cost, debt instruments measured at fair value through other comprehensive income (‘FVOCI’), and certain loan 
commitments and financial guarantee contracts. At initial recognition, an 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, an 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 which 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 that a concession has been granted to the borrower for economic or legal reasons relating to the borrower’s financial condition, or 
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.

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Financial statementsNotes on the financial statements

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.

Forbearance

Loans are identified as forborne and classified as either performing or non-performing when HSBC modifies the contractual terms due to 
financial difficulty of the borrower. Non-performing forborne loans are stage 3 and classified as non-performing until they meet the cure criteria, 
as specified by applicable credit risk policy (for example, when the loan is no longer in default and no other indicators of default have been 
present for at least 12 months). Any amount written off as a result of any modification of contractual terms upon entering forbearance would not 
be reversed.

In 2022, the Group adopted the EBA Guidelines on the application of definition of default for our retail portfolios, which affect credit risk policies 
and our reporting in respect of the status of loans as credit impaired principally due to forbearance (or curing thereof). Further details are provided 
under ‘Forborne loans and advances’ on page 146.

Performing forborne loans are initially stage 2 and remain classified as forborne until they meet applicable cure criteria (for example, they 
continue to not be in default and no other indicators of default are present for a period of at least 24 months). At this point, the loan is either 
stage 1 or stage 2 as determined by comparing the risk of a default occurring at the reporting date (based on the modified contractual terms) and 
the risk of a default occurring at initial recognition (based on the original, unmodified contractual terms).

A forborne loan 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 forborne loan is a substantially different financial instrument. Any new loans that arise 
following derecognition events in these circumstances would generally be classified as POCI and will continue to be disclosed as forborne.

Loan modifications other than forborne loans

Loan modifications that are not identified as forborne are considered to be commercial restructurings. 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. Modifications of certain higher credit risk wholesale loans are assessed for derecognition, having regard to changes in contractual 
terms that either individually or in combination are judged to result in a substantially different financial instrument. Mandatory and general offer 
loan modifications that are not borrower specific, for example market-wide customer relief programmes generally do not result 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.

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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 146. 

For retail portfolios, default risk is assessed using a reporting date 12-month PD derived from credit scores, which incorporate 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 homogenous 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 therefore identifies loans with a PD higher than 
would be expected from loans that are performing as originally expected and higher than that which would have been acceptable at origination. It 
therefore approximates a comparison of origination to reporting date PDs.

As additional data becomes available, the retail transfer criteria approach continues to be refined to utilise a more relative approach for certain 
portfolios. These enhancements take advantage of the increase in origination-related data in the assessment of significant increases in credit risk 
by comparing remaining lifetime PD to the comparable remaining term lifetime PD at origination based on portfolio-specific origination segments. 
These enhancements resulted in significant migrations of loans to customers gross carrying amounts from stage 1 to stage 2, but did not have a 
significant impact on the overall ECL for these portfolios in 2022 due to low loan-to-value ratios.

Unimpaired and without significant increase in credit risk (stage 1)

ECL resulting from default events that are possible within the next 12 months (‘12-month ECL’) are recognised for financial instruments that 
remain in stage 1.

Purchased or originated credit impaired 

Financial assets that are purchased or originated at a deep discount that reflects the incurred credit losses are considered to be POCI. This 
population includes new financial instruments recognised in most cases following the derecognition of forborne loans. The amount of change in 
lifetime ECL for a POCI loan is recognised in profit or loss until the POCI loan 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. In the case of non-performing forborne loans, such financial instruments are 
transferred out of stage 3 when they no longer exhibit any evidence of credit impairment and meet the curing criteria as described above. 

Measurement of ECL

The assessment of credit risk and the estimation of ECL are unbiased and probability-weighted, and incorporate all available information which 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 and 
considers other factors such as climate-related risks.

In general, HSBC calculates ECL using three main components: a probability of default (‘PD’), 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 Holdings plc Annual Report and Accounts 2022

343

Financial statementsNotes on the financial statements

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 

PD

Regulatory capital
• Through the cycle (represents long-run average PD throughout 

IFRS 9
• Point in time (based on current conditions, adjusted to take into 

a full economic cycle)

• The definition of default includes a backstop of 90+ days past 
due, although this has been modified to 180+ days past due 
for some portfolios, particularly UK and US mortgages

account estimates of future conditions that will impact PD)

• Default backstop of 90+ days past due for all portfolios

EAD

• Cannot be lower than current balance

• Amortisation captured for term products

• Downturn LGD (consistent losses expected to be suffered 

• Expected LGD (based on estimate of loss given default 

LGD

Other

during 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

including 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 of 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 its 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 work-out 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. However, where the financial 
instrument includes both a drawn and undrawn commitment and the contractual ability to demand repayment and cancel the undrawn 
commitment does not serve to limit HSBC’s exposure to credit risk to the contractual notice period, the contractual period does not determine 
the maximum period considered. Instead, ECL is measured over the period HSBC remains exposed to credit risk that is not mitigated by credit 
risk management actions. This applies to retail overdrafts and credit cards, where the period is the average time taken for stage 2 exposures to 
default or close as performing accounts, determined on a portfolio basis and ranging from between two and six years. In addition, for these 
facilities it is not possible to identify the ECL on the loan commitment component separately from the financial asset component. As a result, the 
total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial asset, 
in which case the ECL is recognised as a provision. For wholesale overdraft facilities, credit risk management actions are taken no less frequently 
than on an annual basis.

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 credit losses 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 153. 

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

• 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

• Making management adjustments to account for late-breaking events, model and data 

limitations and deficiencies, and expert credit judgements 

• Selecting applicable recovery strategies for certain wholesale credit-impaired loans

Estimates

• The section ‘Measurement uncertainty and 

sensitivity analysis of ECL estimates’, marked as 
audited from page 153, 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

(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 

344

HSBC Holdings plc Annual Report and Accounts 2022

 
  
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 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 Note 1.2 (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 costs of obligations arising from other post-employment plans are accounted for on the same basis as defined benefit pension plans.

HSBC Holdings plc Annual Report and Accounts 2022

345

Financial statementsNotes on the financial statements

Critical accounting estimates and judgements

The most significant critical accounting estimates relate to the determination of key assumptions applied in calculating the defined benefit pension 
obligation for the principal plan.

Judgements

Estimates

• A range of assumptions could be applied, and different assumptions could 

significantly alter the defined benefit obligation and the amounts recognised in 
profit or loss or OCI.

• The calculation of the defined benefit pension obligation includes assumptions 
with regard to the discount rate, inflation rate, pension payments and deferred 
pensions, pay and mortality. Management determines these assumptions in 
consultation with the plan’s actuaries.

• Key assumptions used in calculating the defined benefit pension obligation for the 
principal plan and the sensitivity of the calculation to different assumptions are 
described in Note 5.

(l)   Tax

Income tax comprises current tax and deferred tax. Income tax is recognised in the income statement except to the extent that it relates to 
items recognised in other comprehensive income or directly in equity, in which case the tax is recognised in the same statement as the related 
item appears.

Current tax is the tax expected to be payable on the taxable profit for the year and on any adjustment to tax payable in respect of previous years. 
HSBC provides for potential current tax liabilities that may arise on the basis of the amounts expected to be paid to the tax authorities. 

Deferred tax is recognised on temporary differences between the carrying amounts of assets and liabilities in the balance sheet, and the 
amounts attributed to such assets and liabilities for tax purposes. Deferred tax is calculated using the tax rates expected to apply in the periods 
in which the assets will be realised or the liabilities settled.

In assessing the probability and sufficiency of future taxable profit, management considers the availability of evidence to support the recognition 
of deferred tax assets, taking into account the inherent risks in long-term forecasting, including climate change-related, and drivers of recent 
history of tax losses where applicable. Management also considers the future reversal of existing taxable temporary differences and tax planning 
strategies, including corporate reorganisations. 

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

• 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. See Note 7 for 
further detail. 

The Group does not consider there to be a significant risk of a material adjustment to the carrying amount of deferred tax assets in the next 
financial year but does consider this to be an area that is inherently judgemental.

(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
• Determining whether a present obligation exists. Professional advice is 

Estimates
• 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.

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.

346

HSBC Holdings plc Annual Report and Accounts 2022

 
 
Contingent liabilities, contractual commitments and guarantees 

Contingent liabilities

Contingent liabilities, which include certain guarantees and letters of credit pledged as collateral security, and contingent liabilities related to legal 
proceedings or regulatory matters, are not recognised in the financial statements but are disclosed unless the probability of settlement is 
remote.

Financial guarantee contracts

Liabilities under financial guarantee contracts that are not classified as insurance contracts are recorded initially at their fair value, which is 
generally the fee received or present value of the fee receivable. 
HSBC Holdings has issued financial guarantees and similar contracts to other Group entities. HSBC elects to account for certain guarantees as 
insurance contracts in HSBC Holdings’ financial statements, in which case they are measured and recognised as insurance liabilities. This 
election is made on a contract-by-contract basis, and is irrevocable.
(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 losses 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). 

(o)  Non-current assets and disposal groups held for sale

HSBC classifies non-current assets or disposal groups (including assets and liabilities) as held for sale when their carrying amounts will be 
recovered principally through sale rather than through continuing use. To be classified as held for sale, the non-current asset or disposal group 
must be available for immediate sale in its present condition subject only to terms that are usual and customary for sales of such assets (or 
disposal groups), and the sale must be highly probable. For a sale to be highly probable, the appropriate level of management must be 
committed to a plan to sell the asset (or disposal group) and an active programme to locate a buyer and complete the plan must have been 
initiated. Further, the asset (or disposal group) must be actively marketed for sale at a price that is reasonable in relation to its current fair value. 
In addition, the sale should be expected to qualify as a completed sale within one year from the date of classification and actions required to 
complete the plan should indicate that it is unlikely that significant changes to the plan will be made or that the plan will be withdrawn.  

Held for sale assets and disposal groups are measured at the lower of their carrying amount and fair value less costs to sell except for those 
assets and liabilities that are not within the scope of the measurement requirements of IFRS 5. If the carrying amount of the non-current asset 
(or disposal group) is greater than the fair value less costs to sell, an impairment loss for any initial or subsequent write down of the asset or 
disposal group to fair value less costs to sell is recognised. Any such impairment loss is first allocated against the non-current assets that are in 
scope of IFRS 5 for measurement. This first reduces the carrying amount of any goodwill allocated to the disposal group, and then to the other 
non-current assets of the disposal group pro rata on the basis of the carrying amount of each asset in the disposal group. Thereafter, any 
impairment loss in excess of the carrying value of the non-current assets in scope of IFRS 5 for measurement is recognised against the total 
assets of the disposal group. 

Critical accounting judgements

The classification as held for sale depends on certain judgements:

Judgements

Management judgement is required in determining whether the IFRS 5 held for sale criteria are met, including whether a sale is highly probable and 
expected to complete within one year of classification. The exercise of judgement will normally consider the likelihood of successfully securing any 
necessary regulatory or political approvals which are almost always required for sales of banking businesses. For large and complex plans judgement 
will also include an assessment of the enforceability of any binding sale agreement, the nature and magnitude of any disincentives for non-
performance, and the ability of the counterparty to undertake necessary pre-completion preparatory work, comply with conditions precedent, and 
otherwise be able to comply with contractual undertakings to achieve completion within the expected timescale. Once classified as held for sale, 
judgement is required to be applied on a continuous basis to ensure that classification remains appropriate in future accounting periods.

(p)  Hyperinflationary accounting

Hyperinflationary accounting is applied to those subsidiary operations in countries where the three-year cumulative inflation rate is approaching or 
exceeding 100%. In 2022, this affected the Group’s operations in Argentina and Türkiye. The Group applies IAS 29 to the underlying financial 
information of relevant subsidiaries to restate their local currency results and financial position so as to be stated in terms of the measuring unit 
current at the end of the reporting period. Those restated results are translated into the Group’s presentation currency of US dollars for 

HSBC Holdings plc Annual Report and Accounts 2022

347

Financial statements 
 
Notes on the financial statements

consolidation at the closing rate at the balance sheet date. Group comparatives are not restated for inflation and consequential adjustments to 
the opening balance sheet in relation to hyperinflationary subsidiaries are presented in other comprehensive income. The hyperinflationary gain 
or loss in respect of the net monetary position of the relevant subsidiary is included in profit or loss.
When applying hyperinflation accounting for the first time, the underlying financial information is restated in terms of the measuring unit current 
at the end of the reporting period as if the relevant economy had always been hyperinflationary. Group comparatives are not restated for such 
historic adjustments.
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

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

348

HSBC Holdings plc Annual Report and Accounts 2022

Wealth and
Personal
Banking

Commercial 
Banking

2022

Global 
Banking and 
Markets

Corporate 
Centre

$m
1,769   
2,146   
100   
575   
337   
682   
1   
140   
72   
—   
283   
1,423   
7,528   
(2,497)   
5,031   

$m
105   
313   
776   
40   
718   
14   
2   
14   
378   
475   
16   
1,082   
3,933   
(240)   
3,693   

$m
503   
32   
598   
634   
356   
—   
443   
767   
348   
159   
1   
2,382   
6,223   
(3,464)   
2,759   

$m

—   
—   
—   
—   
1   
—   
(5)   
—   
1   
—   
—   
(2,468)   
(2,471)   
2,439   
(32)   

Wealth and
Personal 
Banking

Commercial
Banking

2021

Global
Banking and
Markets

Corporate
Centre

$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   

$m
546   
23   
690   
669   
340   
—   
1,009   
787   
343   
145   
—   
2,503   
7,055   
(3,452)   
3,603   

$m

—   
1   
1   
—   
6   
—   
(2)   
—   
—   
—   
—   
(2,465)   
(2,459)   
2,420   
(39)   

Wealth and
Personal 
Banking

Commercial
Banking

2020

Global
Banking and
Markets

Corporate
Centre

$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

—   
—   
—   
—   
—   
—   
(1)   
—   
(1)   
—   
—   
(2,290)   
(2,292)   
2,266   
(26)   

Total

$m
2,377 
2,491 
1,474 
1,249 
1,412 
696 
441 
921 
799 
634 
300 
2,419 
15,213 
(3,762) 
11,451 

Total

$m
2,656 
2,213 
1,627 
1,601 
1,452 
1,088 
1,017 
978 
775 
620 
341 
2,420 
16,788 
(3,691) 
13,097 

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 $6,410m 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 (2021: $6,742m; 2020: $5,858m), $1,613m 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 (2021: $1,520m; 2020: $1,260m), 
$3,506m of fees earned on trust and other fiduciary activities (2021: $3,849m; 2020: $3,426m) and $422m of fees payable relating to trust and 
other fiduciary activities (2021: $305m; 2020: $267m). 

3 Net income from financial instruments measured at fair value through 

profit or loss

Net income/(expense) arising on:
Net trading activities
Other instruments managed on a fair value basis
Net income from financial instruments held for trading or managed on a fair value basis
Financial assets held to meet liabilities under insurance and investment contracts
Liabilities to customers under investment contracts
Net income/(expense) from assets and liabilities of insurance businesses, including related derivatives, 
measured at fair value through profit or loss
Derivatives managed in conjunction with HSBC’s issued debt securities
Other changes in fair value
Changes in fair value of designated debt and related derivatives1
Changes in fair value of other financial instruments mandatorily measured at fair value through profit 
or loss

Year ended 31 Dec

2022
$m

2,576   
7,893   
10,469   
(3,720)   
326   

(3,394)   

(7,086)   
7,009   
(77)   

226   

7,224   

2021
$m

6,668   
1,076   
7,744   
4,134   
(81)   

4,053   

(2,811)   
2,629   
(182)   

798   

12,413   

1  The debt instruments, issued for funding purposes, are designated under the fair value option to reduce an accounting mismatch. 

HSBC Holdings

Net income/(expense) arising on:
–  trading activities
–  other instruments managed on a fair value basis
Net income from financial instruments held for trading or managed on a fair value basis
Derivatives managed in conjunction with HSBC Holdings-issued debt securities
Other changes in fair value
Changes in fair value of designated debt and related derivatives
Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss
Year ended 31 Dec

2022
$m

2,094   
35   
2,129   
(1,529)   
3,673   
2,144   
(2,409)   
1,864   

2021
$m

87   
23   
110   
(625)   
974   
349   
(420)   
39   

4

Insurance business

Net insurance premium income1

Gross insurance premium income
Reinsurers’ share of gross insurance premium income
Year ended 31 Dec 2022

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

Non-linked
insurance

 Linked life
insurance

$m
11,685   
(1,226)   
10,459   

8,529   
(555)   
7,974   

8,321   
(362)   
7,959   

$m
824   
(5)   
819   

1,027   
(4)   
1,023   

579   
(8)   
571   

Investment
contracts 
with DPF2
$m
1,547   
—   
1,547   

1,873   
—   
1,873   

1,563   
—   
1,563   

2020
$m

11,074 
(1,492) 
9,582 
2,481 
(400) 

2,081 

2,619 
(2,388) 
231 

455 

12,349 

2020
$m

(336) 
1,137 
801 
694 
(1,020) 
(326) 
1,141 
1,616 

Total

$m
14,056 
(1,231) 
12,825 

11,429 
(559) 
10,870 

10,463 
(370) 
10,093 

1  This table is presented after elimination of inter-company transactions between our insurance manufacturing operations and other Group entities.
2  Discretionary participation features.

HSBC Holdings plc Annual Report and Accounts 2022

349

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Net insurance claims and benefits paid and movement in liabilities to policyholders1

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 2022

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

Non-linked
insurance

Linked life
insurance

$m
11,008   
4,032   
6,976   
(1,206)   
(1,005)   
(201)   
9,802   

10,474   
2,929   
7,545   
(543)   
(343)   
(200)   
9,931   

10,050   
3,695   
6,355   
(366)   
(430)   
64   
9,684   

$m
(124)   
680   
(804)   
8   
(7)   
15   
(116)   

1,134   
1,023   
111   
(9)   
(7)   
(2)   
1,125   

1,112   
900   
212   
(4)   
(10)   
6   
1,108   

Investment
contracts 
with DPF2
$m
183   
1,845   
(1,662)   
—   
—   
—   
183   

3,332   
2,142   
1,190   
—   
—   
—   
3,332   

1,853   
2,083   
(230)   
—   
—   
—   
1,853   

Total

$m
11,067 
6,557 
4,510 
(1,198) 
(1,012) 
(186) 
9,869 

14,940 
6,094 
8,846 
(552) 
(350) 
(202) 
14,388 

13,015 
6,678 
6,337 
(370) 
(440) 
70 
12,645 

1 This table is presented after elimination of inter-company transactions between our insurance manufacturing operations and other Group entities.
2 Discretionary participation features.

Liabilities under insurance contracts1

Gross liabilities under insurance contracts at 1 Jan 2022
Claims and benefits paid
Increase in liabilities to policyholders
Exchange differences and other movements2
Gross liabilities under insurance contracts at 31 Dec 2022
Reinsurers’ share of liabilities under insurance contracts
Net liabilities under insurance contracts at 31 Dec 2022

Gross liabilities under insurance contracts at 1 Jan 2021
Claims and benefits paid
Increase in liabilities to policyholders
Exchange differences and other movements3
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

 Non-linked
insurance

 Linked life
insurance

$m
79,475   
(4,032)   
11,008   
2,004   
88,455   
(4,247)   
84,208   

72,464   
(2,929)   
10,474   
(534)   
79,475   
(3,638)   
75,837   

$m
6,513   
(680)   
(124)   
(313)   
5,396   
(10)   
5,386   

6,449   
(1,023)   
1,134   
(47)   
6,513   
(30)   
6,483   

Investment
contracts 
with DPF2
$m
26,757   
(1,845)   
183   
(4,102)   
20,993   
—   
20,993   

28,278   
(2,142)   
3,332   
(2,711)   
26,757   
—   
26,757   

Total

$m
112,745 
(6,557) 
11,067 
(2,411) 
114,844 
(4,257) 
110,587 

107,191 
(6,094) 
14,940 
(3,292) 
112,745 
(3,668) 
109,077 

1 This table is presented after elimination of inter-company transactions between our insurance manufacturing operations and other Group entities.
2 Discretionary participation features.
3 ‘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. 

350

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5

Employee compensation and benefits

Employee compensation and benefits1
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

2022
$m
18,366   
922   
19,288   

16,954   
1,413   
921   
19,288   

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 

1   Employee compensation and benefits are presented net of software capitalisation costs in the income statement. 

Average number of persons employed by HSBC during the year by global business1

Wealth and Personal Banking
Commercial Banking
Global Banking and Markets
Corporate Centre
Year ended 31 Dec

2022
135,676   
48,004   
48,597   
365   
232,642   

2021
138,026   
44,992   
48,179   
359   
231,556   

2020
144,615 
45,631 
49,055 
411 
239,712 

1   Average number of persons employed represents the number of persons with contracts of service with the Group.

Average number of persons employed by HSBC during the year by geographical region1

Europe
Asia
Middle East and North Africa
North America
Latin America
Year ended 31 Dec

2022
58,145   
132,257   
9,541   
12,242   
20,457   
232,642   

2021
60,919   
127,673   
9,329   
13,845   
19,790   
231,556   

2020
64,886 
129,923 
9,550 
15,430 
19,923 
239,712 

1   Average number of persons employed represents the number of persons with contracts of service with the Group.

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

2022
$m
3,359   
(343)   
3,016   
239   
(22)   
3,233   

2021

$m
3,495   
(379)   
3,116   
270   
4   
3,390   

‘Wages and salaries’ includes the effect of share-based payments arrangements, of which $400m was equity settled (2021: $467m; 
2020: $434m), as follows:

Conditional share awards
Savings-related and other share award option plans
Year ended 31 Dec

2022
$m
402
22
424

2021
$m
479
27
506

2020

$m
2,659 
(239) 
2,420 
286 
2 
2,708 

2020
$m
411
51
462

HSBC share awards

Award

Deferred share awards 
(including annual 
incentive awards, long-
term incentive (‘LTI’)  
awards delivered in 
shares) and Group 
Performance Share 
Plans (‘GPSP’)

International Employee 
Share Purchase Plan 
(‘ShareMatch’)

Policy
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 LTI awards, which are subject to 
performance conditions.

•  Deferred share awards generally vest over a period of three, four, five or seven years.
•  Vested shares may be subject to a retention requirement post-vesting. 
•  Awards are subject to malus and clawback provisions.
The plan was first introduced in Hong Kong in 2013 and now includes employees based in 31 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.

HSBC Holdings plc Annual Report and Accounts 2022

351

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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 ($)

2022
Number
(000s)
109,364   
90,190   
(67,718)   
(5,590)   
126,246   
5.60   

2021
Number
(000s)
103,473 
75,549 
(63,635) 
(6,023) 
109,364 
6.49 

HSBC share option plans

Main plans

Savings-related share 
option plans (‘Sharesave’)

Policy
•   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% (2021: 20%) discount to the market value immediately preceding the date of 

Calculation of fair values

invitation.

The fair values of share options are calculated using a Black-Scholes model. The fair value of a share award is based on the share price at the 
date of the grant. 

Movement on HSBC share option plans

Outstanding at 1 Jan 2022
Granted during the year2
Exercised during the year3
Expired during the year
Forfeited during the year
Outstanding at 31 Dec 2022
–  of which exercisable
Weighted average remaining contractual life (years)

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)

Savings-related
share option plans

Number
(000s)

WAEP1
£

123,197   
8,928   
(3,483)   
(9,047)   
(3,944)   
115,651   
4,029   
2.26

130,953   
15,410   
(3,878)   
(11,502)   
(7,786)   
123,197   
4,949   
3.02

2.85 
4.24 
3.49 
3.55 
2.79 
2.89 
4.11 

2.97 
3.15 
3.80 
3.53 
3.97 
2.85 
4.05 

1  Weighted average exercise price.
2  The weighted average fair value of options granted during the year was $1.45 (2021: $0.85).
3  The weighted average share price at the date the options were exercised was $6.22 (2021: $5.87).

Post-employment benefit plans

The Group operates pension plans throughout the world for its employees. ‘Pension risk management processes’ on page 205 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. For further details of how the trustee of the HSBC Bank 
(UK) Pension Scheme manages climate risk, see ’Managing risk for our stakeholders’ on page 64.

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.

352

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The principal plan is subject to the statutory funding objective requirements of the UK Pensions Act 2004, which requires that it be funded to at 
least the level of technical provisions (an actuarial estimate of the assets needed to provide for the benefits already built up under the plan). 
Where a funding valuation is carried out and identifies a deficit, the employer and trustee are required to agree to a deficit recovery plan. 

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 that an element of prudence is contained in the 
funding valuation assumptions for discount rate, inflation rate and life expectancy. The funding valuation is used to judge the amount of cash 
contributions the Group needs to put into the pension scheme. It will always be different to the IAS 19 accounting surplus, which is an 
accounting rule concerning employee benefits and shown on the balance sheet of our financial statements. The next funding valuation will be 
performed in 2023, with an effective date of 31 December 2022. The plan is estimated to remain in a comfortable surplus relative to the funding 
liabilities as at the end of 2022, based on assumptions consistent with those used to determine the funding liabilities for the 2019 valuation.

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 assumption which allow for reserves 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.

The trust deed gives the ability for HSBC UK to take a refund of surplus assets after the plan has been run down such that no further 
beneficiaries remain. In assessing whether a surplus is recoverable, HSBC UK has considered its right to obtain a future refund together 
with the rights of third parties such as trustees. On this basis, any net surplus in the HBUK section of the plan is recognised in HSBC UK’s 
financial statements and the Group’s financial statements,

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. In 2022, the trustee and HSBC UK agreed to adopt a simplified approach for all members to implement GMP equalisation. 
This resulted in an increase to the liabilities of £5m ($6m) and has been recognised as a past service cost through profit and loss.

Income statement charge

Defined benefit pension plans
Defined contribution pension plans
Pension plans
Defined benefit and contribution healthcare plans
Year ended 31 Dec

Net assets/(liabilities) recognised on the balance sheet in respect of defined benefit plans

2022
$m
42   
852   
894   
27   
921   

2021
$m
243   
767   
1,010   
27   
1,037   

Fair value of
plan assets

Present value of
defined benefit
obligations

Effect of
limit on plan
surpluses

$m
32,171   
96   
32,267   

$m
(25,693)   
(388)   
(26,081)   

51,431   
103   
51,534   

(42,277)   
(572)   
(42,849)   

$m

—   
—   
—   

(23)   
—   
(23)   

Defined benefit pension plans
Defined benefit healthcare plans
At 31 Dec 2022
Total employee benefit liabilities (within Note 27 ‘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 2021
Total employee benefit liabilities (within Note 27 ‘Accruals, deferred income and other 
liabilities’)
Total employee benefit assets (within Note 22 ‘Prepayments, accrued income and other 
assets’)

HSBC Holdings

2020
$m
146 
775 
921 
25 
946 

Total

$m
6,478 
(292) 
6,186 

(1,096) 

7,282 

9,131 
(469) 
8,662 

(1,607) 

10,269 

Employee compensation and benefit expense in respect of HSBC Holdings’ employees in 2022 amounted to $41m (2021: $30m). The average 
number of persons employed during 2022 was 42 (2021: 54). 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. 

HSBC Holdings plc Annual Report and Accounts 2022

353

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Defined benefit pension plans

Net asset/(liability) under defined benefit pension plans 

At 1 Jan 2022
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 2022

At 1 Jan 2021
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 2021

Fair value of plan 
assets

Present value of 
defined benefit 
obligations

Effect of the asset 
ceiling

Net defined benefit 
asset/(liability)

Principal1
plan

Other
plans

Principal1
plan

Other
plans

Principal1
plan

Other
plans

Principal1
plan

Other
plans

$m
41,384   
—   
—   
—   

$m
10,047   
—   
—   
—   

$m
(32,255)   
(30)   
(12)   
(18)   

$m
(10,022)   
(170)   
(161)   
(9)   

703   

198   

(546)   

(202)   

(11,505)   

(2,181)   

9,532   

2,360   

(11,505)   
—   
—   
—   

—   
(4,288)   
(1,222)   
49   
25,121   

(2,181)   
—   
—   
—   
—   
(180)   
(616)   
(218)   
7,050   

—   
10,543   
(123)   
(888)   
—   
3,325   
1,222   
(35)   
(18,787)   

—   
2,383   
24   
(47)   
—   
35   
686   
407   
(6,906)   

42,505   
—   
—   
—   

10,485   
—   
—   
—   

(33,005)   
(55)   
(14)   
(41)   

(10,990)   
(276)   
(206)   
(70)   

613   

172   

(473)   

(174)   

(377)   

(377)   
—   
—   
—   
—   
(361)   
(1,396)   
400   
41,384   

7   

(271)   

471   

7   
—   
—   
—   
—   
(94)   
(645)   
122   
10,047   

—   
611   
(447)   
(435)   
—   
283   
1,396   
(130)   
(32,255)   

—   
315   
64   
92   
—   
138   
712   
97   
(10,022)   

$m

—   
—   
—   
—   

—   

—   

—   
—   
—   
—   
—   
—   
—   
—   
—   

—   
—   
—   
—   

—   

—   

—   
—   
—   
—   
—   
—   
—   
—   
—   

$m
(23)   
—   
—   
—   

$m
9,129   
(30)   
(12)   
(18)   

$m
2 
(170) 
(161) 
(9) 

(1)   

157   

(5) 

(3)   

—   
—   
—   
—   
(3)   
2   
—   
25   
—   

(44)   
—   
—   
—   

(1,973)   

176 

(11,505)   
10,543   
(123)   
(888)   
—   
(963)   
—   
14   
6,334   

9,500   
(55)   
(14)   
(41)   

(2,181) 
2,383 
24 
(47) 
(3) 
(143) 
70 
214 
144 

(549) 
(276) 
(206) 
(70) 

(1)   

140   

(3) 

22   

—   
—   
—   
—   
22   
—   
—   
—   
(23)   

(648)   

(377)   
611   
(447)   
(435)   
—   
(78)   
—   
270   
9,129   

500 

7 
315 
64 
92 
22 
44 
67 
219 
2 

1  For further details of the principal plan, see page 352.
2  Other movements include contributions by HSBC, contributions by employees, administrative costs and taxes paid by plan.

HSBC expects to make $129m of contributions to defined benefit pension plans during 2023, consisting of $13m for the principal plan and 
$116m for other plans. 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

2023
$m
1,234   
433   

2024
$m
1,275   
439   

2025
$m
1,317   
445   

2026
$m
1,359   
428   

2027
$m
1,403   
452   

2028-2032
$m
7,737 
2,231 

1  The duration of the defined benefit obligation is 13.2 years for the principal plan under the disclosure assumptions adopted (2021: 17.3 years) and 10.2 

years for all other plans combined (2021: 12.7 years).
2  For further details of the principal plan, see page 352.

354

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fair value of plan assets by asset classes

31 Dec 2022

Quoted
market price
in active
market

No quoted
market price
in active
market

$m

$m

Value

$m

Thereof
HSBC1
$m

25,121   
112   
14,764   
1,203   
842   
8,200   

7,050   
639   
4,986   
4   
109   
1,312   

13,915   
—   
14,301   
—   
—   

(386)   

5,848   
486   
4,537   
(1)   
104   
722   

11,206   
112   
463   
1,203   
842   

8,586   

1,202   
153   
449   
5   
5   
590   

510   
—   
—   
510   
—   

—   

37   
2   
4   
—   
—   
31   

31 Dec 2021

Quoted
market price
in active
market

No quoted
market price
in active
market

$m

$m

36,270   
5   
35,612   
—   
—   

653   

8,248   
668   
6,490   
(13)   
119   
984   

5,114   
192   
683   
1,864   
1,094   

1,281   

1,799   
224   
590   
20   
4   
961   

Value

$m

41,384   
197   
36,295   
1,864   
1,094   

1,934   

10,047   
892   
7,080   
7   
123   
1,945   

Thereof
HSBC1
$m

1,037 
— 
— 
1,037 
— 

— 

52 
5 
5 
— 
— 
42 

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 36. 
2  For further details on the principal plan, see page 352.
3 
4  Principal plan bonds includes fixed income bonds of $5,285m (2021: $18,315m) and index-linked bonds of $9,479m (2021: $18,160m).
5   Other assets within the principal plan includes $8,586m (2021: $1,281m) of unquoted pooled investment vehicles, of which the majority of the 

Includes $112m (2021: $192m) in relation to private equities. 

underlying assets are invested in bonds.

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

Discount rate
%

Inflation rate (RPI)
%

Inflation rate (CPI) Rate of increase for pensions Rate of pay increase
%

%

%

UK
At 31 Dec 2022
At 31 Dec 2021

 4.93 
 1.90 

 3.39 
 3.45 

 2.84 
 3.20 

 3.27 
 3.30 

 3.34 
 3.45 

1  For further details on the principal plan, see page 352.

Mortality tables and average life expectancy at age 60  for the principal plan1

UK
At 31 Dec 2022
At 31 Dec 2021

Mortality
table

SAPS S32
SAPS S3

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

27.1
27.3

28.6
28.8

28.4
28.5

29.9
30.1

1  For further details of the principal plan, see page 352.
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 2021 core projection model with an initial addition to improvement of 0.25% per annum, a long-term rate of improvement of 1.25% per annum, 
and a 5% weighting to 2020 and 2021 mortality experience reflecting updated long-term view on mortality improvements post-pandemic.

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

2022
$m
(582)   
466   
551   
10   
470   

2021
$m
(1,337)   
1,211   
1,267   
20   

1,387 

2022
$m
612   
(446)   
(519)   
(10)   
N/A

2021
$m
1,425 
(980) 
(1,177) 
(20) 
N/A

1  For further details of the principal plan, see page 352.
2   Sensitivities allow for HSBC UK’s convention of rounding pension assumptions during 2022 to the nearest 0.01% (2021: 0.05%). The degree of 

rounding has been increased to align with market practice.

HSBC Holdings plc Annual Report and Accounts 2022

355

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

The above sensitivity analyses are based on a change in an assumption while holding all other assumptions constant. In practice, this is 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 276.

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
Year ended 31 Dec

2022
$m
97.6
1.6
99.2

2022
$m
21.9   
126.2   
75.7   
26.4   
24.1   
148.1   

2021
$m
88.1
2.0
90.1

2021
$m
19.5   
109.9   
68.6   
18.7   
22.6   
129.4   

2020
$m
92.9
1.0
93.9

2020
$m
21.9 
108.3 
71.0 
17.2 
20.1 
130.2 

1 Audit fees payable to PwC in 2022 included adjustments made to the prior year audit fee after finalisation of the 2021 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

2022
$000

480   
480   

2021
$000

382   
382   

2020
$000
316 
316 

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 $13.1m (2021: $6.3m; 
2020: $12.3m). 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.

356

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
Tax
7
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

2022
$m
2,991   
3,271   
(280)   
(2,133)   
(2,236)   
(293)   
396   
858   

2021
$m
3,250   
3,182   
68   
963   
874   
132   
(43)   
4,213   

2020
$m
2,700 
2,883 
(183) 
(22) 
(341) 
58 
261 
2,678 

1  Current tax included Hong Kong profits tax of $604m (2021: $813m; 2020: $888m). The Hong Kong tax rate applying to the profits of subsidiaries 

assessable in Hong Kong was 16.5% (2021: 16.5%; 2020: 16.5%). 
In addition to amounts recorded in the income statement, a tax credit of $145m (2021: 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 2022:
–  local taxes and overseas withholding taxes
–  other permanent disallowables
–  impacts of hyperinflation
–  adjustments in respect of prior period liabilities
–  tax impact of planned sale of French retail banking business
–  bank levy
–  movements in provisions for uncertain tax positions
–  non-deductible goodwill write-down
–  impact of differences between French tax basis and IFRSs
Items reducing tax charge in 2022:
–  movements in unrecognised UK deferred tax
–  non-taxable income and gains
–  effect of profits in associates and joint ventures
–  non-UK movements in unrecognised deferred tax
–  impact of changes in tax rates
–  deductions for AT1 coupon payments
Year ended 31 December 2022

2022

$m
17,528 

3,329 
374 
283 

%

2021

$m
18,906 

 19.0   
 2.1   
 1.6   

3,592 
280 
332 

550 
202 
171 
116 
115 
59 
27 
3 
— 

(2,191) 
(825) 
(504) 
(312) 
(293) 
(246) 
858 

 3.1   
 1.2   
 1.0   
 0.7   
 0.7   
 0.3   
 0.2   
 —   
 —   

 (12.5)   
 (4.7)   
 (2.9)   
 (1.8)   
 (1.7)   
 (1.4)   
 4.9   

360 
236 
68 
25 
(434) 
93 
15 
178 
434 

294 
(641) 
(414) 
(67) 
132 
(270) 
4,213 

%

 19.0   
 1.5   
 1.8   

 1.9   
 1.2   
 0.4   
 0.1   
 (2.3)   
 0.5   
 0.1   
 0.9   
 2.3   

 1.6   
 (3.4)   
 (2.2)   
 (0.4)   
 0.7   
 (1.4)   
 22.3   

2020

$m
8,777 

1,668 
178 
(113) 

228 
333 
65 
78 
— 
202 
4 
— 
— 

444 
(515) 
(250) 
608 
58 
(310) 
2,678 

%

 19.0 
 2.0 
 (1.3) 

 2.6 
 3.8 
 0.7 
 0.9 
 — 
 2.3 
 — 
 — 
 — 

 5.1 
 (5.8) 
 (2.8) 
 6.9 
 0.6 
 (3.5) 
 30.5 

The Group’s profits are taxed at different rates depending on the country or territory in which the profits arise. The key applicable tax rates for 
2022 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 22.7% (2021: 22.3%). 

The effective tax rate for the year of 4.9% was lower than in the previous year (2021: 22.3%). The effective tax rate for the year reduced by 
14.3% as a result of the recognition of previously unrecognised losses in the UK of $2.2bn and France of $0.3bn, in light of improved forecast 
profitability.

During 2022, legislation was enacted to reduce the rate of the UK banking surcharge from 8% to 3% from 1 April 2023, decreasing the Group’s 
2022 tax charge by $173m due to the remeasurement of deferred tax balances. The main rate of UK corporation tax will increase from 19% to 
25% from 1 April 2023.   

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. 
Exposures relating to legacy tax cases were reassessed during 2022, resulting in a charge of $27m to the income statement. 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. 

HSBC Holdings plc Annual Report and Accounts 2022

357

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Movement of deferred tax assets and liabilities

Assets
Liabilities
At 1 Jan 2022
Income statement
Other comprehensive income
Foreign exchange and other adjustments
At 31 Dec 2022
Assets1
Liabilities1

Assets
Liabilities
At 1 Jan 2021
Income statement
Other comprehensive income
Foreign exchange and other adjustments
At 31 Dec 2021
Assets1
Liabilities1

Loan
impairment
provisions

Unused tax
losses and
tax credits

Financial 
assets at 
FVOCI

Insurance
business

Cash flow 
hedges

Retirement 
obligations

$m
1,162   
—   
1,162   
6   
—   
7   
1,175   
1,175   
—   

1,242   
—   
1,242   
(89)   
(5)   
14   
1,162   
1,162   
—   

$m
2,001   
—   
2,001   
2,425   
—   
(36)   
4,390   
4,390   
—   

1,821   
—   
1,821   
161   
33   
(14)   
2,001   
2,001   
—   

$m
84   
(254)   
(170)   
—   
1,679   
(79)   
1,430   
1,430   
—   

99   
(896)   
(797)   
—   
634   
(7)   
(170)   
84   
(254)   

$m

—   
(1,640)   
(1,640)   
170   
—   
35   
(1,435)   
—   
(1,435)   

—   
(1,622)   
(1,622)   
(43)   
—   
25   
(1,640)   
—   
(1,640)   

$m
176   
(22)   
154   
—   
1,159   
(42)   
1,271   
1,271   
—   

25   
(70)   
(45)   
—   
212   
(13)   
154   
176   
(22)   

$m
109   
(2,928)   
(2,819)   
217   
692   
237   
(1,673)   
—   
(1,673)   

—   
(2,306)   
(2,306)   
(336)   
(205)   
28   
(2,819)   
109   
(2,928)   

Other

$m
1,690   
(427)   
1,263   
(685)   
(642)   
(18)   
(82)   
1,571   
(1,653)   

2,850   
(973)   
1,877   
(656)   
115   
(73)   
1,263   
1,690   
(427)   

Total

$m
5,222 
(5,271) 
(49) 
2,133 
2,888 
104 
5,076 
9,837 
(4,761) 

6,037 
(5,867) 
170 
(963) 
784 
(40) 
(49) 
5,222 
(5,271) 

1  After netting off balances within countries, the balances as disclosed in the accounts are as follows: deferred tax assets of $7,498m (2021: $4,624m) 

and deferred tax liabilities of $2,422m (2021: $4,673m). 

In applying judgement in recognising deferred tax assets, management has 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. When forecasts are extrapolated beyond five years, a number of different scenarios are considered, reflecting difference 
downward risk adjustments, in order to assess the sensitivity of our recognition and measurement conclusions in the context of such longer-
term forecasts.

The Group’s deferred tax asset of $7.5bn (2021: $4.6bn) included $3.9bn (2021: $0.8bn) of deferred tax assets relating to the UK, $3.3bn (2021: 
$2.6bn) of deferred tax assets relating to the US and a net deferred asset of $0.7bn (2021: $0.0bn) in France. 

The net UK deferred tax asset of $3.9bn excluded a $1.8bn 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. The majority of the deferred tax asset relates to tax attributes 
which do not expire and are forecast to be recovered within five years and as such are less sensitive to changes in long-term profit forecasts. 
The net UK deferred tax asset includes $2.2bn of previously unrecognised losses that were recognised in the UK in the period in light of 
improved forecast profitability in the UK group. Sensitivity regarding the recognition and measurement of that deferred tax asset relates to 
ongoing experience outcome of UK profitability versus forecast, taking into account the non-expiring nature of the underlying attributes.

The net US deferred tax asset of $3.3bn included $1.3bn related to US tax losses, of which $1.1bn expire in 10 to 15 years. Management 
expects the US deferred tax asset to be substantially recovered within 14 years, with the majority recovered in the first eight years.

The net deferred tax asset in France of $0.7bn included $0.7bn related to tax losses, which are expected to be substantially recovered within 
nine to 18 years. Following recognition of $0.3bn of previously unrecognised deferred tax asset on losses, deferred tax is now recognised in full 
in respect of France. 

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 $9.2bn (2021: $16.9bn). This amount included unused UK tax losses of $3.5bn (2021: $10.5bn), which arose prior to 1 April 2017 and can 
only be recovered against future taxable profits of HSBC Holdings. No deferred tax was recognised on these losses due to the absence of 
convincing evidence regarding the availability of sufficient future taxable profits against which to recover them. Deferred tax asset recognition is 
reassessed at each balance sheet date based on the available evidence. Of the total amounts unrecognised, $3.6bn (2021: $10.9bn) had no 
expiry date, $1.2bn (2021: $0.7bn) was scheduled to expire within 10 years and the remaining balance is expected to expire after ten 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 $11.7bn (2021: $12.7bn) and the 
corresponding unrecognised deferred tax liability was $0.7bn (2021: $0.8bn).

358

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8 Dividends

Dividends to shareholders of the parent company

Dividends paid on ordinary shares
In respect of previous year:
–  second interim dividend
In respect of current year:
–  first 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 

2022

Per
share

$

Total

$m

2021

Per
share

$

Total

$m

2020

Per
share

$

Total

$m

0.18   

3,576   

0.15   

3,059   

—   

— 

0.09   
0.27   
—   

1,754   
5,330   
—   

1,214 
6,544 

0.07   
0.22   
4.99   

1,421   
4,480   
7   

1,303 
5,790 

—   
—   
62.00   

— 
— 
90 
1,241 
1,331 

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 securities1
$2,000m issued at 6.875%2
$2,250m issued at 6.375%
$2,450m issued at 6.375%
$3,000m issued at 6.000%
$2,350m issued at 6.250%3
$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%7
€1,000m issued at 6.000%
€1,250m issued at 4.750%
£1,000m issued at 5.875%
SGD1,000m issued at 4.700%8
SGD750m issued at 5.000%
Total

2022

First call date

Per security

Jun 2021  
Sep 2024  
Mar 2025  
May 2027  
Mar 2023  
Mar 2028  
Jun 2031  
Mar 2026  
Mar 2031  
Sep 2022  
Sep 2023  
Jul 2029  
Sep 2026  
Jun 2022  
Sep 2023  

$68.750   
$63.750   
$63.750   
$60.000   
$62.500   
$65.000   
$46.000   
$40.000   
$47.000   
€52.500   
€60.000   
€47.500   
£58.750   
SGD47.000   
SGD50.000   

Total
$m

—   
143   
156   
180   
147   
117   
69   
40   
47   
76   
63   
65   
70   
14   
27   
1,214   

2021
Total
$m

69   
143   
156   
180   
147   
117   
69   
20   
24   
93   
70   
72   
80   
35   
28   
1,303   

2020
Total
$m

138 
143 
156 
180 
147 
117 
— 
— 
— 
90 
67 
67 
74 
35 
27 
1,241 

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 15 April 2021 and was redeemed and cancelled on 1 June 2021.
3 This security was called by HSBC Holdings on 30 January 2023 and is expected to be redeemed and cancelled on 23 March 2023. 
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.

7 This security was called by HSBC Holdings on 9 August 2022 and was redeemed and cancelled on 16 September 2022.
8 This security was called by HSBC Holdings on 4 May 2022 and was redeemed and cancelled on 8 June 2022.

After the end of the year, the Directors approved a second interim dividend in respect of the financial year ended 31 December 2022 of $0.23 
per ordinary share, a distribution of approximately $4,593m. The second interim dividend for 2022 will be payable on 27 April 2023 to holders on 
the Principal Register in the UK, the Hong Kong Overseas Branch Register or the Bermuda Overseas Branch Register on 3 March 2023. No 
liability was recorded in the financial statements in respect of the second interim dividend for 2022.

On 4 January 2023, HSBC paid a coupon on its €1,250m subordinated capital securities, representing a total distribution of €30m ($31m). No 
liability was recorded in the balance sheet at 31 December 2022 in respect of this coupon payment. 

HSBC Holdings plc Annual Report and Accounts 2022

359

Financial statements 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Earnings per share

9
Basic earnings per ordinary share is calculated by dividing the profit attributable to ordinary shareholders of the parent company by the weighted 
average number of ordinary shares outstanding, excluding own shares held. Diluted earnings per ordinary share is calculated by dividing the basic 
earnings, which require no adjustment for the effects of dilutive potential ordinary shares, by the weighted average number of ordinary shares 
outstanding, excluding own shares held, plus the weighted average number of ordinary shares that would be issued on conversion of dilutive 
potential ordinary shares. 

Profit attributable to the ordinary shareholders of the parent company

2020
$m
5,229 
(90) 
(1,241) 
3,898 

Per
share

$
0.19 

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

2022
$m
16,035   
—   
(1,213)   
14,822   

2021
$m
13,917   
(7)   
(1,303)   
12,607   

Basic1
Effect of dilutive potential 
ordinary shares
Diluted1

2022
Number 
of shares

Profit

Per
 share

Profit

2021
Number
of shares

$m (millions)

14,822   

19,849   

$
0.75   

$m
12,607   

(millions)

20,197   

Per
share

$
0.62   

Profit

$m
3,898   

137 

105 

2020
Number
of shares

(millions)

20,169   

73 

14,822   

19,986   

0.74   

12,607   

20,302   

0.62   

3,898   

20,242   

0.19 

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 9.4 
million (2021: 8.6 million; 2020: 14.6 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 2021 and 2020 adjusted performance information is presented on a constant currency 
basis. The 2021 and 2020 income statements are converted at the average rates of exchange for 2022, and the balance sheets at 31 December 
2021 and 31 December 2020 at the prevailing rates of exchange on 31 December 2022. 

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.

360

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
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

2022

Global
Banking and
Markets

Corporate 
Centre

$m

$m

$m

$m

Total

$m

24,367   

16,215   

15,359   

(596)   

55,345 

21,753   
2,614   
18,137   
(1,137)   
23,230   
(14,726)   
8,504   
29   
8,533   
%
 35.5 
 60.4 
$m
423,553   
508   
889,450   
779,310   

16,715   
(500)   
11,867   
(1,858)   
14,357   
(6,642)   
7,715   
1   
7,716   
%
 32.1 
 41.0 
$m
308,094   
15   
606,698   
458,714   

19,598   
(4,239)   
5,303   
(587)   
14,772   
(9,325)   
5,447   
(2)   
5,445   
%
 22.7 
 60.7 
$m
192,852   
108   
1,321,076   
331,844   

2021

(2,721)   
2,125   
(2,706)   
(10)   
(606)   
227   
(379)   
2,695   
2,316   
%
 9.7 
 38.1 
$m
355   
28,623   
149,306   
435   

55,345 
— 
32,601 
(3,592) 
51,753 
(30,466) 
21,287 
2,723 
24,010 
%
 100.0 
 55.0 
$m
924,854 
29,254 
2,966,530 
1,570,303 

20,963   

20,725   
238   
13,458   

12,538   

12,423   
115   
8,308   

13,982   

15,590   
(1,608)   
3,844   

(463)   

(1,718)   
1,255   
(716)   

47,020 

47,020 
— 
24,894 

213   

225   

313   

3   

754 

21,176   
(14,489)   
6,687   
34   
6,721   
%
 32.6 
 69.1 
$m
461,047   
489   
888,028   
819,319   

12,763   
(6,554)   
6,209   
1   
6,210   
%
 30.1 
 52.3 
$m
330,683   
12   
586,392   
480,201   

21,481   

19,521   
1,960   
14,752   

12,889   

13,278   
(389)   
8,997   

14,295   
(9,250)   
5,045   
—   
5,045   
%
 24.5 
 66.2 
$m
198,779   
116   
1,157,327   
322,435   

2020

14,696   

17,635   
(2,939)   
4,314   

(460)   
189   
(271)   
2,898   
2,627   
%
 12.8 
 40.8 
$m
688   
27,469   
174,073   
592   

47,774 
(30,104) 
17,670 
2,933 
20,603 
%
 100.0 
 64.0 
$m
991,197 
28,086 
2,805,820 
1,622,547 

(218)   

(1,586)   
1,368   
(1,324)   

48,848 

48,848 
— 
26,739 

(2,878)   

(4,710)   

(1,227)   

—   

(8,815) 

18,603   
(14,536)   
4,067   
6   
4,073   
%
 34.8 
 67.7 
$m
436,105   
437   
828,309   
788,043   

8,179   
(6,475)   
1,704   
(1)   
1,703   
%
 14.6 
 50.2 
$m
320,084   
15   
530,203   
439,889   

13,469   
(8,895)   
4,574   
—   
4,574   
%
 39.1 
 60.5 
$m
211,510   
128   
1,238,781   
310,757   

(218)   
(539)   
(757)   
2,102   
1,345   
%
 11.5 
 (247.2) 
$m
1,151   
25,142   
184,030   
540   

40,033 
(30,445) 
9,588 
2,107 
11,695 
%
 100.0 
 62.3 
$m
968,850 
25,722 
2,781,323 
1,539,229 

1   Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

HSBC Holdings plc Annual Report and Accounts 2022

361

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Revenue1
ECL
Operating expenses
Share of profit in 
associates and joint 
ventures 
Profit/(loss) before tax  

Notes on the financial statements

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

2022
$m
51,727   
11,767   
15,894   
3,893   
136   
20,037   

2021
$m
49,552   
10,909   
14,245   
3,795   
2,179   
18,424   

2020
$m
50,429 
9,163 
15,783 
4,474 
1,753 
19,256 

1 

 Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

Adjusted results reconciliation

2022
Significant

Adjusted
$m

items Reported Adjusted
$m

$m

$m

2021

2020

Currency
translation
$m

Significant

 items Reported Adjusted
$m

$m

$m

Currency
translation
$m

55,345   
(3,592)   
(30,466)   

(3,618)   
—   
(2,864)   

51,727    47,020   
754   
(3,592)   
(30,104)   
(33,330)   

3,074   
174   
(2,181)   

(542)   
—   
(2,335)   

49,552    48,848   
(8,815)   
(30,445)   

928   
(34,620)   

1,523   
(2)   
(1,170)   

Significant

items Reported
$m

$m

58   
—   
(2,817)   

50,429 
(8,817) 
(34,432) 

2,723   

—   

2,723   

2,933   

113   

—   

3,046   

2,107   

24,010   

(6,482)   

17,528    20,603   

1,180   

(2,877)   

18,906    11,695   

(48)   

303   

(462)   
(3,221)   

1,597 
8,777 

1   Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.

Adjusted balance sheet reconciliation

Loans and advances to customers (net)
Interests in associates and joint ventures
Total external assets
Customer accounts

Adjusted profit reconciliation

2022
Reported and
adjusted
$m

924,854   
29,254   
2,966,530   
1,570,303   

2021
Currency 
translation
$m

54,617   
1,523   
152,119   
88,027   

Adjusted
$m

991,197   
28,086   
2,805,820   
1,622,547   

Reported
$m

1,045,814   
29,609   
2,957,939   
1,710,574   

Adjusted
$m

968,850   
25,722   
2,781,323   
1,539,229   

2020
Currency 
translation
$m

69,137   
962   
202,841   
103,551   

Reported
$m

1,037,987 
26,684 
2,984,164 
1,642,780 

Year ended 31 Dec
Adjusted profit before tax
Significant items
–  customer redress programmes (revenue)
–  disposals, acquisitions and investment in new businesses (revenue)1
–  fair value movements on financial instruments2
–  restructuring and other related costs (revenue)3
–  customer redress programmes (operating expenses)
–  disposals, acquisitions and investment in new businesses (operating expenses)
–  impairment of goodwill and other intangible assets
–  past service costs of guaranteed minimum pension benefits equalisation
–  restructuring and other related costs (operating expenses)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

2022
$m

24,010   
(6,482)   
8   
(2,799)   
(579)   
(248)   
31   
(18)   
4   
—   
(2,881)   
—   
—   

17,528   

2021
$m

20,603   
(2,877)   
11   
—   
(242)   
(307)   
(49)   
—   
(587)   
—   
(1,836)   
—   
—   
133   
1,180   
18,906   

2020
$m

11,695 
(3,221) 
(21) 
(10) 
264 
(170) 
54 
— 
(1,090) 
(17) 
(1,908) 
(12) 
(462) 
151 
303 
8,777 

Includes losses from classifying businesses as held for sale as part of the broader restructuring of our European business, of which $2.4bn relates 

1 
     to the planned sale of the retail banking operations in France in 2022.
2   Includes fair value movements on non-qualifying hedges and debit valuation adjustments on derivatives.  
3  Comprises gains and losses relating to the business update in February 2020, including losses associated with the RWA reduction programme.
4 

Includes impairment of software intangible assets of $128m (2021: $21m, 2020: $189m) of the total software intangible asset impairment of $147m 
(2021: $146m, 2020: $1,347m) and impairment of tangible assets of $332m (2021: $75m, 2020: $197m).

5  During 2020, The Saudi British Bank (’SABB’), an associate of HSBC, impaired the goodwill that arose following the merger with Alawwal bank in 2020. 

HSBC‘s post-tax share of the goodwill impairment was $462m.

362

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

2022
$m
22,897   
78,126   
88,026   
189,049   
8,769   
20,275   
218,093   

2021
$m
23,110 
89,944 
109,614 
222,668 
7,767 
18,407 
248,842 

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 reported as financial liabilities designated 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.

HSBC Holdings plc Annual Report and Accounts 2022

363

Financial statements 
 
 
 
 
 
 
 
Notes on the financial statements

Financial instruments carried at fair value and bases of valuation

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
Financial liabilities designated at fair value
Derivatives

2022

2021

Level 1
$m

Level 2
$m

Level 3
$m

Total
$m

Level 1
$m

Level 2
$m

Level 3
$m

Total
$m

  148,592   

64,684   

4,817    218,093    180,423   

65,757   

2,662    248,842 

15,978   

13,019   

16,066   

45,063   

17,937   

17,629   

14,238   

49,804 

2,917    279,265   
71,621   

  182,231   

1,964    284,146   
2,965    256,817    247,745   

2,783    191,621   
97,838   

2,478    196,882 
3,389    348,972 

44,787   

27,092   
1,130    115,765   
2,400    280,444   

474   

72,353   
10,432    127,327   
2,920    285,764   

63,437   

20,682   
1,379    136,243   
1,686    186,290   

785   

84,904 
7,880    145,502 
3,088    191,064 

The table below provides the fair value levelling of assets held for sale and liabilities of disposal groups that have been classified as held for sale 
in accordance with IFRS 5. For further details, see Note 23.

Financial instruments carried at fair value and bases of valuation – assets and liabilities held for sale

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
Financial liabilities designated at fair value
Derivatives

Transfers between Level 1 and Level 2 fair values

2022

2021

Level 1
$m

Level 2
$m

Level 3
$m

Total
$m

Level 1
$m

Level 2
$m

Level 3
$m

Total
$m

2,932   

244   

—   

3,176   

—   

—   
11,184   

14   

866   
—   

2,572   
—   
—   

182   
3,523   
813   

47   

—   
—   

—   
—   
—   

61   

866   
11,184   

2,754   
3,523   
813   

—   

—   

—   
—   

—   
—   
—   

—   

—   

—   
—   

—   
—   
—   

—   

—   

—   
—   

—   
—   
—   

— 

— 

— 
— 

— 
— 
— 

Financial
investments

Trading
assets

$m

$m

At 31 Dec 2022
Transfers from Level 1 to Level 2
Transfers from Level 2 to Level 1
At 31 Dec 2021
Transfers from Level 1 to Level 2
Transfers from Level 2 to Level 1

4,721   
8,208   

5,284   
5,964   

8,477   
6,007   

6,553   
4,132   

Assets

Designated and otherwise
mandatorily measured 

at fair value Derivatives

Liabilities
Designated
at fair 
value Derivatives

Trading
liabilities

$m

$m

$m

$m

743   
1,214   

1,277   
768   

—   
—   

103   
—   

113   
233   

181   
638   

—   
—   

—   
—   

$m

— 
— 

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.

364

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global Banking and Markets fair value adjustments

Type of adjustment
Risk-related 
–  bid-offer 
–  uncertainty 
–  credit valuation adjustment
–  debit valuation adjustment
–  funding fair value adjustment
Model-related 
–  model limitation 
Inception profit (Day 1 P&L reserves)
At 31 Dec

2022

GBM

$m

Corporate
Centre

$m

650   
426   
86   
245   
(175)   
68   
61   
61   
97   
808   

40   
—   
—   
35   
—   
5   
—   
—   
—   
40   

2021

GBM

$m

868   
412   
66   
228   
(92)   
254   
57   
57   
106   
1,031   

Corporate
Centre

$m

42 
— 
1 
35 
— 
6 
— 
— 
— 
42 

The reduction in fair value adjustments was driven by changes to derivative exposures and the credit environment, including HSBC’s own credit.

Bid-offer

IFRS 13 ‘Fair Value Measurement’ requires the use of the price within the bid-offer spread that is most representative of fair value. Valuation 
models will typically generate mid-market values. The bid-offer adjustment reflects the extent to which bid-offer costs would be incurred if 
substantially all residual net portfolio market risks were closed using available hedging instruments or by disposing of or unwinding the position.

Uncertainty

Certain model inputs may be less readily determinable from market data and/or the choice of model itself may be more subjective. In these 
circumstances, an adjustment may be necessary to reflect the likelihood that market participants would adopt more conservative values for 
uncertain parameters and/or model assumptions than those used in HSBC’s valuation model.

Credit and debit 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 debit 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.

HSBC Holdings plc Annual Report and Accounts 2022

365

Financial statements 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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

Financial 
investments

Trading 
assets

$m

$m

$m

$m

Total

$m

647   

438   
—   
—   
1,880   
2,965   

544   

1,008   
—   
—   
1,837   
3,389   

19   

208   
—   
—   
4,590   
4,817   

2   

132   
—   
—   
2,528   
2,662   

15,652   

95   
—   
—   
319   
16,066   

13,732   

1   
—   
—   
505   
14,238   

—    16,318   

—   
—   
1,964   
—   

741   
—   
1,964   
6,789   
1,964    25,812   

—    14,278   

—   
—   
2,478   
—   

1,141   
—   
2,478   
4,870   
2,478    22,767   

Private equity including strategic 
investments 

Asset-backed securities 
Structured notes 
Other derivatives 
Other portfolios 
At 31 Dec 2022

Private equity including strategic 
investments 
Asset-backed securities 
Structured notes 
Other derivatives 
Other portfolios 
At 31 Dec 2021

Liabilities

Trading 
liabilities

Designated 
at fair 
value Derivatives

$m

92   

—   
—   
—   
382   
474   

9   

—   
—   
—   
776   
785   

$m

$m

Total

$m

—   

—   
10,432   
—   
—   
10,432   

—   

—   
7,879   
—   
1   
7,880   

—   

92 

— 
—   
—    10,432 
2,920 
382 
2,920    13,826 

2,920   
—   

—   

9 

—   
—   
3,088   
—   

— 
7,879 
3,088 
777 
3,088    11,753 

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.

366

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
Reconciliation of fair value measurements in Level 3 of the fair value hierarchy

Movement in Level 3 financial instruments

Assets

Designated and 
otherwise 
mandatorily 
measured at fair 
value through 

profit or loss Derivatives

Financial 
investments

Trading 
assets

Liabilities

Trading 
liabilities

Designated 
at fair 
value Derivatives

$m
3,389   
(4)   

$m
2,662   
(245)   

$m
14,238   
159   

$m
2,478   
390   

$m
785   
(52)   

$m
7,880   
(1,334)   

$m
3,088 
1,014 

—   

(245)   

—   

390   

(52)   

—   

1,014 

—   

(4)   

—   

—   

(325)   

(137)   

(203)   
(122)   
1,048   
1   
(245)   
(463)   
(523)   
87   
2,965   

—   
(137)   
3,436   
—   
(1,102)   
(1,273)   
(442)   
1,918   
4,817   

159   

—   

(217)   

—   
(217)   
4,330   
—   
(783)   
(1,729)   
(39)   
107   
16,066   

—   

—   

(219)   

—   
(219)   
—   
—   
—   
(918)   
(409)   
642   
1,964   

—   

(100)   

(148)   

707   

—   

(100)   

—   

707   

—   

(1,334)   

—   

—   

(345)   

82   
(427)   
—   
4,183   
(94)   
182   
(1,296)   
1,256   
10,432   

(11)   

—   
(11)   
178   
8   
(152)   
(644)   
(18)   
380   
474   

2   

2   

— 

— 

(226) 

— 
(226) 
— 
— 
— 
(993) 
(632) 
669 
2,920 

100   

2,779 

—   

2,779 

—   

—   

(148)   

—   

—   

100   

— 

3,654   
(10)   

2,499   
(378)   

11,477   
1,753   

2,670   
2,237   

162   
16   

5,306   
(836)   

4,188 
2,583 

—   

(378)   

—   

2,237   

16   

—   

2,583 

—   

(10)   

(521)   

(428)   
(93)   
1,025   
—   
(580)   
(336)   
(383)   
540   
3,389   

—   

—   

—   

—   

(18)   

—   
(18)   
1,988   
—   
(473)   
(747)   
(1,027)   
818   
2,662   

(309)   

(309)   

1,753   

—   

(285)   

—   
(285)   
3,692   
—   
(1,216)   
(1,049)   
(184)   
50   
14,238   

—   

—   

(27)   

—   
(27)   
—   
—   
—   
(2,347)   
(418)   
363   
2,478   

1,509   

1,298   

—   

1,298   

—   

—   

(8)   

—   
(8)   
1,014   
35   
(4)   
(681)   
(7)   
258   
785   

—   

—   

(836)   

—   

(61)   

—   
(61)   
1   
5,969   
(27)   
(2,922)   
(704)   
1,154   
7,880   

— 

— 

(26) 

— 
(26) 
— 
— 
— 
(3,962) 
(734) 
1,039 
3,088 

166   

(969) 

—   

(969) 

—   

—   

1,509   

—   

—   

166   

— 

At 1 Jan 2022
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/ (losses)
–  exchange differences 
Purchases 
New issuances 
Sales 
Settlements 
Transfers out 
Transfers in 
At 31 Dec 2022
Unrealised gains/(losses) recognised in profit or loss 
relating to assets and liabilities held at 31 Dec 2021
–  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

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

–  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/ (losses)
–  exchange differences 
Purchases 
New issuances 
Sales 
Settlements 
Transfers out 
Transfers in 
At 31 Dec 2021
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

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. 

HSBC Holdings plc Annual Report and Accounts 2022

367

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Effect of changes in significant unobservable assumptions to reasonably possible 
alternatives

Sensitivity of fair values to reasonably possible alternative assumptions

2022

2021

Reflected in profit or loss
Un-
favourable
changes

Favourable
changes

Reflected in OCI

Favourable
changes

Un-
favourable
changes

Reflected in profit or loss
Un-
favourable
changes

Favourable
changes

Reflected in OCI

Favourable
changes

Un-
favourable
changes

$m

$m

$m

$m

$m

$m

$m

264   

(291)   

—   

—   

143   

(146)   

—   

914   

11   
1,189   

(911)   

(11)   
(1,213)   

—   

65   
65   

—   

(55)   
(55)   

849   

20   
1,012   

(868)   

(20)   
(1,034)   

—   

113   
113   

$m

— 

— 

(112) 
(112) 

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.
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 2022.

Quantitative information about significant unobservable inputs in Level 3 valuations 

Fair value

Private equity including strategic 
investments 
Asset-backed securities 
–  collateralised loan/debt obligation
–  other ABSs 
Structured notes 

–  equity-linked notes 

–  Foreign exchange-linked notes 
–  other 
Derivatives 
–  interest rate derivatives
   securitisation swaps 

   long-dated swaptions 
   other 
–  Foreign exchange derivatives

   Foreign exchange options 
   other 
–  equity derivatives
   long-dated single stock options 
   other 
–  credit derivatives
Other portfolios 
–  repurchase agreements
–  other1
At 31 Dec 2022

2022
Full range
of inputs
Lower Higher

2021
Full range
of inputs
Lower Higher

Assets Liabilities Valuation

$m

$m

techniques

Key unobservable
inputs

  16,318   

92  See below

See below

741   
188  
553   

— 
—  Market proxy 
—  Market proxy

—   

10,432 

—   

6,833 

Model – Option model 
Model – Option model 

2,694  Model – Option model 

905 

Bid quotes 
Bid quotes

— 
— 

92  
99  

— 
— 

100
100

Equity volatility 
Equity correlation 
Foreign exchange 
volatility 

6% 142%
99%

32%

6% 124%
99%

22%

3%

37%

1%

99%

—   
—   

1,964   
560   
259   

53   

248   
445   

2,920   
710   
209  Model – Discounted cash flow Prepayment rate 

67  Model – Option model 

Interest rate 
volatility 

5%

8%

10%

5%

10%

53%

15%

35%

434 
304 

404   

274  Model – Option model 

Foreign exchange 
volatility

1%

46%

1%

99%

41   
850   
415   
435   
109   
6,789   
750   
6,039   
  25,812   

30 
1,658 

502  Model – Option model 

Equity volatility

7% 153%

4% 138%

1,156 
248 
382 
328  Model – Discounted cash flow Interest rate curve

54 
13,826 

1%

9%

1%

5%

1 

‘Other’ includes a range of smaller asset holdings.

368

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.

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 

2022
$m

2021
$m

3,801   
52,322   

32,123   
6,922   

2,811 
51,408 

32,418 
1,220 

HSBC Holdings plc Annual Report and Accounts 2022

369

Financial statements 
 
 
 
 
Notes on the financial statements

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

At 31 Dec 2022
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 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

Fair value

Carrying
amount

Quoted market
price Level 1

Observable
inputs Level 2

Significant
unobservable
inputs Level 3

$m

$m

$m

$m

104,882   
924,854   
253,754   
168,746   

66,722   
1,570,303   
127,747   
78,149   
22,290   

83,136   
1,045,814   
241,648   
97,302   

101,152   
1,710,574   
126,670   
78,557   
20,487   

—   
—   
—   
90,629   

—   
—   
—   
—   
—   

—   
—   
—   
38,722   

—   
—   
—   
—   
—   

104,074   
8,768   
253,668   
67,419   

66,831   
1,570,209   
127,500   
76,640   
22,723   

82,220   
10,287   
241,531   
63,022   

101,149   
1,710,733   
126,670   
78,754   
26,206   

814   
904,288   
—   
626   

—   
—   
—   
381   
—   

1,073   
1,034,288   
121   
523   

—   
—   
—   
489   
—   

Fair values of financial instruments not carried at fair value and bases of valuation – assets and disposal groups held for sale

At 31 Dec 2022
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 2021
Assets
Loans and advances to banks
Loans and advances to customers
Liabilities
Deposits by banks
Customer accounts

Fair value

Carrying 
amount

Quoted market 
price Level 1

Observable 
inputs Level 2

Significant 
unobservable 
inputs Level 3

$m

$m

$m

$m

253   
80,687   
4,646   
6,165   

64   
85,274   
3,266   
12,928   
8   

3   
3,056   

87   
8,750   

—   
—   
—   
6,042   

—   
—   
—   
—   
—   

—   
—   

—   
—   

257   
111   
4,646   
—   

64   
85,303   
3,266   
12,575   
7   

3   
363   

87   
8,750   

—   
78,048   
—   
—   

—   
—   
—   
—   
—   

—   
2,808   

—   
—   

Total

$m

104,888 
913,056 
253,668 
158,674 

66,831 
1,570,209 
127,500 
77,021 
22,723 

83,293 
1,044,575 
241,652 
102,267 

101,149 
1,710,733 
126,670 
79,243 
26,206 

Total

$m

257 
78,159 
4,646 
6,042 

64 
85,303 
3,266 
12,575 
7 

3 
3,171 

87 
8,750 

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.

370

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Valuation

Fair value is an estimate of the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market 
participants at the measurement date. It does not reflect the economic benefits and costs that HSBC expects to flow from an instrument’s cash 
flow over its expected future life. Our valuation methodologies and assumptions in determining fair values for which no observable market prices 
are available may differ from those of other companies.

Loans and advances to banks and customers

To determine the fair value of loans and advances to banks and customers, loans are segregated, as far as possible, into portfolios of similar 
characteristics. Fair values are based on observable market transactions, when available. When they are unavailable, fair values are estimated 
using valuation models incorporating a range of input assumptions. These assumptions may include: value estimates from third-party brokers 
reflecting over-the-counter trading activity; forward-looking discounted cash flow models, taking account of expected customer prepayment 
rates, using assumptions that HSBC believes are consistent with those that would be used by market participants in valuing such loans; new 
business rates estimates for similar loans; and trading inputs from other market participants including observed primary and secondary trades. 
From time to time, we may engage a third-party valuation specialist to measure the fair value of a pool of loans.

The fair value of loans reflects expected credit losses at the balance sheet date and estimates of market participants’ expectations of credit 
losses over the life of the loans, and the fair value effect of repricing between origination and the balance sheet date. For credit-impaired loans, 
fair value is estimated by discounting the future cash flows over the time period they are expected to be recovered.

Financial investments

The fair values of listed financial investments are determined using bid market prices. The fair values of unlisted financial investments are 
determined using valuation techniques that incorporate the prices and future earnings streams of equivalent quoted securities.

Deposits by banks and customer accounts

The fair values of on-demand deposits are approximated by their carrying value. For deposits with longer-term maturities, fair values are 
estimated using discounted cash flows, applying current rates offered for deposits of similar remaining maturities.

Debt securities in issue and subordinated liabilities

Fair values in debt securities in issue and subordinated liabilities are determined using quoted market prices at the balance sheet date where 
available, or by reference to quoted market prices for similar instruments.

Repurchase and reverse repurchase agreements – non-trading

Fair values of repurchase and reverse repurchase agreements that are held on a non-trading basis provide approximate carrying amounts. This is 
due to the fact that balances are generally short dated.
HSBC Holdings

The methods used by HSBC Holdings to determine fair values of financial instruments for the purposes of measurement and disclosure are 
described above.

Fair values of HSBC Holdings’ financial instruments not carried at fair value on the balance sheet

Assets at 31 Dec
Loans and advances to HSBC undertakings 
Financial investments – at amortised cost
Liabilities at 31 Dec
Debt securities in issue 
Subordinated liabilities 

2022

2021

Carrying amount
$m

Fair value1
$m

Carrying amount
$m

Fair value1
$m

26,765   
19,466   

66,938   
19,727   

26,962   
19,314   

65,364   
20,644   

25,108   
26,194   

67,483   
17,059   

25,671 
26,176 

69,719 
21,066 

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

Designated at 
fair value

2022

Mandatorily 
measured at 
fair value

$m
3,079   
649   
2,430   
—   
—   
—   
3,079   

$m
38,529   
95   
3,969   
34,465   
1,841   
1,614   
41,984   

Total

$m
41,608   
744   
6,399   
34,465   
1,841   
1,614   
45,063   

Designated at 
fair value

$m
2,251   
599   
1,652   
—   
—   
—   
2,251   

2021
Mandatorily 
measured at 
fair value

$m
42,062   
31   
5,177   
36,854   
4,307   
1,184   
47,553   

Total

$m
44,313 
630 
6,829 
36,854 
4,307 
1,184 
49,804 

HSBC Holdings plc Annual Report and Accounts 2022

371

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 
Gross total fair values
Offset (Note 31)
At 31 Dec 2022

Foreign exchange 
Interest rate 
Equities 
Credit 
Commodity and other 
Gross total fair values
Offset (Note 31)
At 31 Dec 2021

Fair value – Assets

Fair value – Liabilities

Trading
$m

Notional contract amount
Hedging
$m
38,924   
276,589   
—   
—   
—   
315,513   

8,434,453   
  15,213,232   
570,410   
183,995   
78,413   
  24,480,503   

Trading
$m
122,203   
285,438   
9,325   
1,091   
1,485   
419,542   

Hedging
$m
525   
5,066   
—   
—   
—   
5,591   

  24,480,503   

315,513   

419,542   

5,591   

7,723,034   
  14,470,539   
659,142   
190,724   
74,159   
  23,117,598   

43,839   
162,921   
—   
—   
—   
206,760   

79,801   
151,631   
12,637   
2,175   
1,205   
247,449   

1,062   
1,749   
—   
—   
—   
2,811   

  23,117,598   

206,760   

247,449   

2,811   

Total
$m
122,728   
290,504   
9,325   
1,091   
1,485   
425,133   
(140,987) 
284,146   

80,863   
153,380   
12,637   
2,175   
1,205   
250,260   
(53,378) 
196,882   

Trading
$m
123,088   
287,877   
9,176   
1,264   
1,679   
423,084   

Hedging
$m
166   
3,501   
—   
—   
—   
3,667   

423,084   

3,667   

77,670   
146,808   
14,379   
3,151   
1,261   
243,269   

207   
966   
—   
—   
—   
1,173   

243,269   

1,173   

Total
$m
123,254 
291,378 
9,176 
1,264 
1,679 
426,751 
(140,987) 
285,764 

77,877 
147,774 
14,379 
3,151 
1,261 
244,442 
(53,378) 
191,064 

The notional contract amounts of derivatives held for trading purposes and derivatives designated in hedge accounting relationships indicate the 
nominal value of transactions outstanding at the balance sheet date. They do not represent amounts at risk.

Derivative assets and liabilities increased during 2022, 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

Foreign exchange 
Interest rate 
At 31 Dec 2022

Foreign exchange 
Interest rate 
At 31 Dec 2021

Notional contract amount
Hedging
$m

Trading
$m
60,630   
34,322   
94,952   

36,703   
35,970   
72,673   

Trading
$m
502   
2,386   
2,888   

384   
712   
1,096   

Assets

Hedging
$m

—   
913   
913   

—   
1,715   
1,715   

Total
$m
502   
3,299   
3,801   

384   
2,427   
2,811   

Trading
$m
1,683   
826   
2,509   

377   
769   
1,146   

Liabilities

Hedging
$m

—   
4,413   
4,413   

—   
74   
74   

Total
$m
1,683 
5,239 
6,922 

377 
843 
1,220 

—   
81,873   
81,873   

—   
45,358   
45,358   

Use of derivatives

For details regarding the use of derivatives, see page 220 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 
Unamortised balance at 31 Dec1

1 This amount is yet to be recognised in the consolidated income statement. 

372

HSBC Holdings plc Annual Report and Accounts 2022

2022
$m
106   
191   
(192)   
(112)   
(3)   
(77)   
(8)   
97   

2021
$m
104 
311 
(308) 
(177) 
(4) 
(127) 
(1) 
106 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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’.

Hedged risk components 

HSBC designates a portion of cash flows of a financial instrument or a group of financial instruments for a specific interest rate or foreign 
currency risk component in a fair value or cash flow hedge. The designated risks and portions are either contractually specified or otherwise 
separately identifiable components of the financial instrument that are reliably measurable. Risk-free or benchmark interest rates generally are 
regarded as being both separately identifiable and reliably measurable, except for the Interest Rate Benchmark Reform Phase 2 transition where 
HSBC designates alternative benchmark rates as the hedged risk which may not have been separately identifiable upon initial designation, 
provided HSBC reasonably expects it will meet the requirement within 24 months from the first designation date. The designated risk 
components account for a significant portion of the overall changes in fair value or cash flows of the hedged items.

HSBC uses net investment hedges to hedge the structural foreign exchange risk related to net investments in foreign operations including 
subsidiaries and branches whose functional currencies are different from that of the parent. When hedging with foreign exchange forward 
contracts, the spot rate component of the foreign exchange risk is designated as the hedged risk. 

Fair value hedges

HSBC enters into fixed-for-floating-interest-rate swaps to manage the exposure to changes in fair value caused by movements in market interest 
rates on certain fixed-rate financial instruments that are not measured at fair value through profit or loss, including debt securities held and 
issued.

HSBC hedging instrument by hedged risk

Hedged risk
Interest rate3
At 31 Dec 2022

Interest rate3
At 31 Dec 2021

Notional amount1
$m
162,062   
162,062   

90,556   
90,556   

Hedging instrument

Carrying amount

Assets
$m
4,973   
4,973   

1,637   
1,637   

Liabilities
$m
2,573 
2,573 

1,410 
1,410 

Balance sheet 
presentation

Derivatives  

Change in fair value2
$m
4,064 
4,064 

Derivatives  

1,330 
1,330 

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

Hedged item

Ineffectiveness

Carrying amount

Accumulated fair value hedge adjustments 
included in carrying amount2

Hedged risk

Assets
$m

Liabilities
$m

Assets
$m

Liabilities
$m

Interest rate3

  82,792 

3,415 

519 

(5,100) 

(210) 

(18) 

49,180 

83 

At 31 Dec 2022

  86,726   

49,263   

(5,328)   

Interest rate3

68,059 

2 

3,066 

1,199 

(3) 

9 

14,428 
86 

At 31 Dec 2021

71,127   

14,514   

1,205   

(2,006) 

— 
(2,006) 

992 
1 
993 

Balance sheet 
presentation

Financial investments 
measured at fair value 
through other 
comprehensive income  

Loans and advances to 
customers  

Reverse repos  

Debt securities in issue  
Deposits by banks  

Change in 
fair value1
$m

Recognised 
in profit 
and loss

$m

Profit and loss 
presentation

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

(59) 

(8,005) 

(233) 

(17) 

4,138 
(5) 

(4,122)   

(59) 

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  

(1,932) 

(3) 

(41) 

609 
1 

(36) 

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

(1,366)   

(36) 

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 $252m (2021: $1,061m) for FVOCI assets and liabilities of $916m (2021: $15m) for debt issued.

3 The hedged risk ‘interest rate’ includes inflation risk.

HSBC Holdings plc Annual Report and Accounts 2022

373

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings hedging instrument by hedged risk

Hedging instrument

Carrying amount

Hedged risk
Interest rate3
At 31 Dec 2022

Interest rate3
At 31 Dec 2021

Notional amount1,4
$m
81,873   
81,873   

45,358   
45,358   

Assets
$m
913   
913   

1,715   
1,715   

Liabilities
$m
4,413 
4,413 

74 
74 

Balance sheet 
presentation

Derivatives  

Change in fair value2
$m
(5,599) 
(5,599) 

Derivatives  

(1,515) 
(1,515) 

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 $81,873m (2021: $45,358m), of which the weighted-average maturity date is June 

2028 and the weighted-average swap rate is 2.33% (2021: 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

Carrying amount

Assets
$m

Liabilities
$m

Assets
$m

Liabilities
$m

Balance sheet 
presentation
Debt securities

Change in 
fair value1
$m

68,223 

(3,829) 

in issue  

6,258   

Hedged risk

Interest rate3

Interest rate3

At 31 Dec 2022

6,812   

68,223   

6,812 

(789) 

(789)   

(3,829) 

Loans and 

advances to banks  

(693) 

5,565   

39,154 

1,408 

in issue  

1,599   

(21) 

Debt securities

At 31 Dec 2021

7,863   

39,154   

7,863 

(104) 

(104)   

1,408 

Loans and 

advances to banks  

(104) 

1,495   

(21) 

Ineffectiveness

Recognised 
in
profit and 
loss

$m

(34) 

(34) 

Profit and loss
presentation
Net income from 
financial instruments 
held for trading or 
managed on a fair value 
basis

Net income from financial 
instruments held for 
trading or managed on a 
fair value basis

1 Used in effectiveness testing; comprising amount attributable to the designated hedged risk that can be a risk component.
2 The accumulated amount of fair value adjustments remaining in the statement of financial position for hedged items that have ceased to be adjusted 

for hedging gains and losses were liabilities of $971m (2021: $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.

374

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Hedging instrument by hedged risk

Hedging instrument

Hedged item

Ineffectiveness

Hedged risk

Notional 
amount1
$m

Carrying amount

Assets

Liabilities

$m

$m

Balance 
sheet 
presentation

Change in 
fair value2
$m

Change in fair 
value3
$m

Foreign currency

8,781   

418   

166 

Derivatives  

659   

659   

Interest rate

At 31 Dec 2022

  114,527   

  123,308   

93   

511   

950 

1,116 

Derivatives  

(4,997)   

(4,338)   

(4,973)   

(4,314)   

Foreign currency

17,930   

827   

207 

Derivatives  

987   

Interest rate

At 31 Dec 2021

72,365   

90,295   

112   

939   

217 

424 

Derivatives  

(519)   

468   

987   

(500)   

487   

Recognised 
in profit and 
loss 

$m

— 

(24) 

(24) 

— 

(19) 

(19) 

Profit and loss 
presentation

Net income from
financial instruments
held for trading or
managed on a fair
value basis

Net income from 
financial instruments 
held for trading or 
managed on a fair 
value basis

1 The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions 

outstanding at the balance sheet date. They do not represent amounts at risk.

2 Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3 Used in effectiveness assessment; comprising amount attributable to the designated hedged risk that can be a risk component.

Sources of hedge ineffectiveness may arise from basis risk, including but not limited to timing differences between the hedged items and 
hedging instruments and hedges using instruments with a non-zero fair value.

Reconciliation of equity and analysis of other comprehensive income by risk type

Cash flow hedging reserve at 1 Jan 2022
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 loss1
Income taxes
Others
Cash flow hedging reserve at 31 Dec 2022

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

1   Hedged items that have affected profit or loss are primarily recorded within interest income.

Net investment hedges

Interest rate
$m

8   
(4,973)   

325   
1,123   
130   
(3,387)   

495   
(500)   

(217)   
185   
45   
8   

Foreign currency
$m
(205) 
659 

(926) 
28 
23 
(421) 

(37) 
987 

(1,177) 
25 
(3) 
(205) 

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
2022
Pound sterling-denominated structural foreign exchange
Swiss franc-denominated structural foreign exchange
Hong Kong dollar-denominated structural foreign exchange
Other structural foreign exchange1
Total
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

Carrying value

Derivative
 assets

Derivative 
liabilities

$m

264   
—   
—   
—   
264   

229   
—   
7   
7   
243   

$m

—   
(21)   
(19)   
(117)   
(157)   

—   
(8)   
—   
—   
(8)   

Nominal
 amount

$m

14,000   
727   
4,597   
10,819   
30,143   

15,717   
809   
4,992   
4,387   
25,906   

Amounts 
recognised in 
OCI

Hedge ineffectiveness 
recognised in income 
statement

$m

1,447   
111   
(2)   
375   
1,931   

(126)   
101   
5   
6   
(14)   

$m

— 
— 
— 
— 
— 

— 
— 
— 
— 
— 

1   Other currencies include New Taiwan dollar, Singapore dollar, Canadian dollar, Omani rial, South Korean won, Indian rupee, Indonesian rupiah, euro, 

Mexican peso, Qatari riyal, Kuwaiti dinar, Saudi riyal and United Arab Emirates dirham.

HSBC Holdings plc Annual Report and Accounts 2022

375

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 138 in the section ‘Financial instruments impacted by the Ibor 
reform’. For further details on Ibor transition, see ‘Top and emerging risks‘ on page 137.

During 2022, 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 completed by the second quarter of 2023. 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 2022

Fair value hedges
Cash flow hedges
At 31 Dec 2021

Hedging instrument

Impacted by Ibor reform

£
$m

—   
—   
—   

—   
—   
—   

$
$m
2,015   
—   
2,015   

18,525   
100   
18,625   

Other3
$m
12,643   
27,830   
40,473   

6,615   
8,632   
15,247   

€2
$m
12,756   
8,865   
21,621   

6,178   
7,954   
14,132   

Not impacted 
by Ibor 
reform
$m

134,648   
77,832   
212,480   

59,238   
55,679   
114,917   

Total
$m
27,414   
36,695   
64,109   

31,318   
16,686   
48,004   

Notional
amount1
$m

162,062 
114,527 
276,589 

90,556 
72,365 
162,921 

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 $12,756m (31 December 2021: $6,178m) and ‘Cash flow hedges’ of $8,865m (31 December 2021: $7,954m).

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

Fair value hedges
At 31 Dec 2022

Fair value hedges
At 31 Dec 2021

Hedging instrument

Impacted by Ibor reform

£
$m

—   
—   

—   
—   

$
$m
2,000   
2,000   

20,035   
20,035   

Other
$m
1,336   
1,336   

1,458   
1,458   

€
$m
15,210   
15,210   

9,944   
9,944   

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

376

HSBC Holdings plc Annual Report and Accounts 2022

Not impacted 
by Ibor 
reform
$m

Total
$m
18,546   
18,546   

31,437   
31,437   

63,327   
63,327   

13,921   
13,921   

2022
$m
256,817   
86,749   
168,264   
1,696   
108   
168,747   
35,282   
133,465   
425,564   

Notional 
amount
$m

81,873 
81,873 

45,358 
45,358 

2021
$m
348,972 
100,158 
246,998 
1,770 
46 
97,302 
21,634 
75,668 
446,274 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2022

Investments required by central institutions
Business facilitation
Others
At 31 Dec 2021

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 
UK Government 
Hong Kong Government 
Other governments 
Asset-backed securities 
Corporate debt and other securities 

Fair value

Dividends 
recognised

$m
690   
954   
52   
1,696   

766   
954   
50   
1,770   

$m
24 
28 
2 
54 

17 
24 
3 
44 

Up to 1
 year

Yield
%

1 to 5 
years

Yield
%

5 to 10 
years

Yield
%

Over 10 
years

Yield
%

 1.0 
 4.7 
 1.1 
 0.5 
 1.3 
 2.3 
 6.7 
 3.4 

 10.2 
 — 
 2.9 
 — 
 1.9 
 2.1 
 4.0 
 3.2 

 1.3 
 0.9 
 1.7 
 0.8 
 1.6 
 3.0 
 0.2 
 1.8 

 3.4 
 2.9 
 2.4 
 — 
 3.8 
 4.2 
 4.7 
 3.2 

 1.3 
 3.2 
 2.1 
 0.4 
 1.7 
 2.9 
 2.7 
 2.5 

 3.8 
 7.2 
 3.2 
 0.7 
 2.2 
 3.6 
 — 
 3.3 

 2.3 
 2.5 
 1.7 
 1.3 
 — 
 3.7 
 2.4 
 2.2 

 2.8 
 3.2 
 3.3 
 0.9 
 4.5 
 3.8 
 7.7 
 4.0 

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 2022 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 

2022
$m

12,796   
6,670   
19,466   

2021
$m

19,508 
6,686 
26,194 

Up to 1
 year

Yield
%

1 to 5 
years

Yield
%

5 to 10 
years

Over 10 
years

Yield
%

Yield
%

 0.3 

 2.8 

 — 

 — 

The weighted average yield for each range of maturities is calculated by dividing the annualised interest income for the year ended 31 December 
2022 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 2022

377

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

17 Assets pledged, collateral received and assets transferred

Assets pledged1

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

2022
$m
18,364   
10,198   
27,627   
60,542   
26,902   
67,576   
211,209   

2021
$m
9,613 
412 
55,370 
66,629 
34,472 
45,396 
211,892 

Assets pledged as collateral include all assets categorised as encumbered in the disclosure on page 89 of the Pillar 3 Disclosures at 
31 December 2022, except for assets held for sale.

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

2022
$m
56,894   
27,841   
84,735   

2021
$m
69,719 
12,416 
82,135 

Collateral received1
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 $449,896m (2021: $476,455m). The 
fair value of any such collateral sold or repledged was $228,245m (2021: $271,582m).

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 transferred1
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

Carrying amount of:

Fair value of:

Transferred
assets

Associated
liabilities

Transferred
assets

Associated
liabilities

$m

$m

$m

$m

Net
position

$m

52,604   
39,134   

48,501 
4,613 

51,135   
43,644   
3,826   

48,180 
2,918 
3,826   

3,830   

3,842   

(12) 

At 31 Dec 2022
Repurchase agreements
Securities lending agreements

At 31 Dec 2021
Repurchase agreements
Securities lending agreements
Other sales (recourse to transferred assets only)

1   Excludes assets classified as held for sale.

378

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

2022
$m
29,127   
127   
29,254   

2021

Fair value1
$m
8,141   
6,602   

Carrying amount
$m
23,616   
4,426   

Fair value1
$m
8,537 
5,599 

2022
Carrying amount
$m
23,307   
4,494   

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

Share of profit in associates and joint ventures

Bank of Communications Co., Limited
The Saudi British Bank
Other associates and joint ventures
Share of profit in associates and joint ventures

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
Saudi Arabia

At 31 Dec 2022

Principal activity

Banking services
Banking services

HSBC’s interest
%

 19.03 
 31.00 

2021
$m
2,461 
276 
309 
3,046 

2022
$m
2,377   
342   
4   
2,723   

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 ‘Investments in 
Associates and Joint Ventures', 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 2022, the fair value of the Group’s investment in BoCom had been below the carrying amount for approximately 11 years. As a 
result, the Group performed an impairment test on the carrying amount, which confirmed that there was no impairment at 31 December 2022 as 
the recoverable amount as determined by a value-in-use (‘VIU’) calculation was higher than the carrying value. 

BoCom

At 31 Dec 2022

VIU
$bn
23.5   

Carrying value
$bn
23.3   

Fair value
$bn
8.1   

At 31 Dec 2021
VIU Carrying value
$bn
$bn
23.6   
24.8   

Fair value
$bn
8.5 

The headroom, which is defined as the extent to which the VIU exceeds the carrying value, decreased by $1.0bn compared with 31 December 
2021. The decrease in headroom was principally due to revisions to management’s best estimates of BoCom‘s future earnings in the short to 
medium term, and the impact from BoCom’s actual performance.

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. 

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 ’Impairment of Assets’. 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. Forecast 
earnings growth over the short to medium term are lower than recent (within the last five years) historical actual growth and reflect the 
uncertainty arising from the current economic outlook. Reflecting management‘s intent to continue to retain its investment, earnings beyond the 

HSBC Holdings plc Annual Report and Accounts 2022

379

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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.

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% (2021: 3%) for periods after 2026, which does not exceed forecast GDP growth in mainland China and is 

similar to forecasts by external analysts.

• Long-term asset growth rate: 3% (2021: 3%) for periods after 2026, which is the rate that assets are expected to grow to achieve long-term 

profit growth of 3%.

• Discount rate: 10.04% (2021: 10.03%), which is based on a capital asset pricing model (‘CAPM’), using market data. The discount rate used is 
within the range of 8.4% to 10.4% (2021: 8.7% to 10.1%) indicated by the CAPM. While the CAPM range sits at the lower end of the range 
adopted by selected external analysts of 8.8% to 13.5% (2021: 9.9% to 13.5%), we continue to regard the CAPM range as the most 
appropriate basis for determining this assumption.

• Expected credit losses (‘ECL’) as a percentage of customer advances: ranges from 0.99% to 1.05% (2021: 0.98% to 1.12%) 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 2026, the ratio is 0.97% (2021: 0.97%), which is higher than BoCom’s average ECL as a 
percentage of customer advances in recent years prior to the pandemic.

• Risk-weighted assets as a percentage of total assets: ranges from 61.0% to 64.4% (2021: 61.0% to 62.4%) in the short to medium term, 

reflecting higher risk-weights in the short term followed by an expected reversion to recent historical levels. For periods after 2026, the ratio 
is 61.0% (2021: 61.0%), which is similar to BoCom’s actual results in recent years.

• Operating income growth rate: ranges from 1.9% to 7.7% (2021: 5.1% to 6.2%) in the short to medium term, which is lower than BoCom’s 
actual results in recent years and is similar to the forecasts disclosed by external analysts. This reflects BoCom’s most recent actual results, 
global trade tensions and industry developments in mainland China.

• Cost-income ratio: ranges from 35.5% to 36.3% (2021: 35.5% to 36.1%) 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 4.4% to 15.0% (2021: 6.8% to 15.0%) in the short to medium term, reflecting BoCom’s actual results 
and an expected increase towards the long-term assumption through the forecast period. For periods after 2026, the rate is 15.0% (2021: 
15.0%), 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 of 12.5% (2021: 12.5%) and tier 1 capital adequacy ratio of 9.5% (2021: 9.5%), based on 

BoCom’s capital risk appetite and capital requirements respectively.

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 4 basis points

• Increase by 3 basis points

• Increase by 5 basis points

• Expected credit losses as a percentage of customer advances

• Increase by 1 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

• Increase by 26 basis points

• Decrease by 5 basis points

• Increase by 15 basis points

• Increase by 46 basis points

• Increase by 5 basis points

• Capital requirements – tier 1 capital adequacy ratio

• Increase by 175 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 based on external analysts’ forecasts, statutory requirements and 
other relevant external data sources, which can change period to period.

380

HSBC Holdings plc Annual Report and Accounts 2022

 
Sensitivity of VIU to reasonably possible changes in key assumptions

At 31 Dec 2022
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
At 31 Dec 2021
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

75   
(71)   
(164)   

3.6   
3.1   
6.9   

27.1   
26.6   
30.4   

Decrease in 
VIU

$bn

(2.7)   
(4.1)   
(3.7)   

VIU

$bn

20.8 
19.4 
19.8 

bps

(71)   
75   
136   

2022 to 2026: 95
2027 onwards: 91  
(118)   
44   
(122)   
(426)   
—   
—   

87   
(69)   
(133)   

2021 to 2025: 103
2026 onwards: 91  
(111)   
37   
(152)   
(104)   
—   
—   

1.9   

25.4 

2022 to 2026: 120
2027 onwards: 104  

0.1   
1.3   
1.0   
1.5   
—   
—   

4.2   
2.9   
5.4   

23.6   
24.8   
24.5   
25.0   
23.5   
23.5   

29.0   
27.7   
30.2   

239   
(83)   
174   
1,000   
191   
266   

(69)   
87   
207   

1.5   

26.3 

0.2   
1.0   
1.7   
0.3   
—   
—   

25.0   
25.8   
26.5   
25.1   
24.8   
24.8   

2021 to 2025: 121
2026 onwards: 105  
280   
(58)   
174   
1,000   
325   
364   

(2.9)   

20.6 

(2.3)   
(2.5)   
(2.1)   
(3.6)   
(6.3)   
(3.2)   

(2.7)   
(4.7)   
(5.3)   

21.2 
21.0 
21.4 
19.9 
17.2 
20.3 

22.1 
20.1 
19.5 

(2.7)   

22.1 

(2.1)   
(1.8)   
(1.7)   
(3.6)   
(10.0)   
(6.5)   

22.7 
23.0 
23.1 
21.2 
14.8 
18.3 

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.

Considering the interrelationship of the changes set out in the table above, management estimates that the reasonably possible range of VIU is 
$16.9bn to $28.7bn (2021: $19.0bn to $29.3bn). 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. All other long-term assumptions and the basis of the CMC have been kept unchanged when 
determining the reasonably possible range of the VIU. Impairment, if determined, would be recognised in the income statement. The impact on 
the Group’s CET1 ratio is expected to be minimal in the event of an impairment, as the adverse impact on CET1 capital from the impairment 
would be offset by the favourable impact from a lower carrying value.

Selected financial information of BoCom

The statutory accounting reference date of BoCom is 31 December. For the year ended 31 December 2022, HSBC included the associate’s 
results on the basis of the financial statements for the 12 months ended 30 September 2022, taking into account any known changes in the 
subsequent period from 1 October 2022 to 31 December 2022 that would have materially affected the results.

Selected balance sheet information of BoCom

Cash and balances at central banks 
Due from and placements with banks and other financial institutions 
Loans and advances to customers 
Other financial assets 
Other assets 
Total assets 
Due to and placements from banks and other financial institutions 
Deposits from customers
Other financial liabilities 
Other liabilities 
Total liabilities 
Total equity 

At 30  Sep
2022
$m
114,390   
99,802   
1,022,223   
549,364   
55,884   
1,841,663   
277,185   
1,144,297   
237,521   
35,543   
1,694,546   
147,117   

2021
$m
123,194 
98,932 
993,956 
541,577 
47,679 
1,805,338 
287,057 
1,099,266 
228,135 
40,070 
1,654,528 
150,810 

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
Carrying amount  

At 30 Sep
2022
$m
22,828   
479   
23,307   

2021
$m
23,097 
519 
23,616 

HSBC Holdings plc Annual Report and Accounts 2022

381

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Selected income statement information of BoCom

Net interest income 
Net fee and commission income 
Credit and impairment losses
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 

2022
$m
25,314   
6,854   
(9,712)   
(2,351)   
(598)   
13,582   
(245)   
13,337   
749   

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 2022. The fair value of the Group’s investment in SABB of $6.6bn was above the 
carrying amount of $4.5bn.

19 Investments in subsidiaries

Main subsidiaries of HSBC Holdings1

Place of 
incorporation or 
registration

HSBC’s 
interest 
%

Europe

HSBC Bank plc 

HSBC UK Bank plc
HSBC Continental Europe
HSBC Trinkaus & Burkhardt GmbH
Asia
Hang Seng Bank Limited 

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

England and Wales

England and Wales
France
Germany

Hong Kong
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
HSBC Mexico, S.A., Institución de Banca Múltiple,
Grupo Financiero HSBC 

Canada
US

At 31 Dec 2022

Share class

£1 Ordinary, $0.01 Non-Cumulative Third Dollar 
Preference

£1 Ordinary
€5 Actions
€1 Ordinary

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

 100 

 100 
 99.99 
 99.99 

 62.14 

 100 

 100 
 100 
 100 

 100 

 100 
 100 

Mexico

 99.99 

MXN2 Ordinary

1   Main subsidiaries are either held directly or indirectly via intermediate holding companies.

Details of the debt, subordinated debt and preference shares issued by the main subsidiaries to parties external to the Group are included in 
Note 26 ‘Debt securities in issue’ and Note 29 ‘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. 

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 2022, 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.

382

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
The amount of guarantees by HSBC Holdings in favour of other Group entities is set out in Note 33.

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.

Impairment testing of investments in subsidiaries

At each reporting period end, HSBC Holdings reviews investments in subsidiaries for indicators of impairment. An impairment is recognised 
when the carrying amount exceeds the recoverable amount for that investment. The recoverable amount is the higher of the investment’s fair 
value less costs of disposal and its VIU, in accordance with the requirements of IAS 36. The VIU is calculated by discounting management’s cash 
flow projections for the investment. The cash flows represent the free cash flows based on the subsidiary’s binding capital requirements.

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: The cash flow projections for each investment are based on the latest approved 

plans, which include forecast capital available for distribution based on the capital requirements of the subsidiary, taking into account 
minimum and core capital requirements. For the impairment test at 31 December 2022, cash flow projections until the end of 2027 were 
considered in line with our internal planning horizon.  Our cash flow projections include known and observable climate-related opportunities 
and costs associated with our sustainable products and operating model. 

• Long-term growth rates: A long-term growth rate is used to extrapolate the free cash flows in perpetuity. The growth rate reflects inflation for 

the country or territory within which the investment operates, and is based on the long-term average growth rates. 

• Discount rates: The rate used to discount the cash flows is based on the cost of capital assigned to each investment, which is derived using a 
CAPM. CAPM depends on a number of inputs reflecting financial and economic variables, including the risk-free rate and a premium to reflect 
the inherent risk of the business being evaluated. These variables are based on the market’s assessment of the economic variables and 
management’s judgement. The discount rates for each investment are refined to reflect the rates of inflation for the countries or territories 
within which the investment operates. In addition, for the purposes of testing investments for impairment, management supplements this 
process by comparing the discount rates derived using the internally generated CAPM, with cost of capital rates produced by external sources 
for businesses operating in similar markets. The impacts from climate risk are included to the extent that they are observable in discount rates 
and asset prices.

The net increase in investments in subsidiaries was partly due to the reversal of impairment of HSBC Overseas Holdings (UK) Limited of $2.5bn. 
The recoverable amount of HSBC Overseas Holdings (UK) Limited is supported by the recoverable amounts of its subsidiaries, of which the 
principal subsidiaries are HSBC North America Holdings Limited, HSBC Bank Canada and HSBC Bank Bermuda Limited. As HSBC Overseas 
Holdings (UK) Limited has entered into a sales purchase agreement with Royal Bank of Canada to dispose of HSBC Bank Canada the sales 
purchase agreement has been used to support the recoverable amount of $10.8bn (inclusive of the preferred shares) under a fair value less costs 
of disposal basis. The fair value less costs of disposal of HSBC Bank Canada is at a $3.7bn premium to the book value recorded in HSBC 
Overseas Holdings (UK) Limited. The cumulative impairment for HSBC Overseas Holdings (UK) Limited at 31 December 2022 was $4.7bn (2021: 
$7.2bn). The carrying value was $32.8bn at 31 December 2022 (2021: $33.1bn). In 2022, in addition to the planned sale of our banking business 
in Canada, there has been demonstrable performance of the underlying subsidiaries and an increase in interest rate forecasts. These factors 
provide us with observable indications that HSBC Overseas Holdings (UK) Limited’s value has increased, which has led to the reversal of 
impairment in HSBC Holdings. However, a distribution of the proceeds from the planned sale of HSBC Bank Canada to HSBC Holdings from 
HSBC Overseas Holdings (UK) Limited could lead to a future impairment. 

Impairment test results

Investments
At 31 Dec 2022
HSBC North America Holdings Limited
HSBC Bank Bermuda Limited
At 31 Dec 2021
HSBC North America Holdings Limited
HSBC Bank Bermuda Limited

Recoverable amount
$m
18,363 
2,471 

Discount rate
%
 10.00 
 10.40 

Long-term growth 
%
 2.22 
 1.87 

20,560 
1,643 

 9.20 
 9.50 

 3.50 
 1.71 

Sensitivities of key assumptions in calculating VIU

At 31 December 2022, the recoverable amount of HSBC Overseas Holdings (UK) Limited remained sensitive to reasonably possible changes in 
key assumptions impacting its principal subsidiaries, notably HSBC North America Holdings Limited and HSBC Bank Bermuda Limited.

In making an estimate of reasonably possible changes to assumptions, management considers the available evidence in respect of each input to 
the model. These include the external range of observable discount rates, historical performance against forecast, and risks attaching to the key 
assumptions underlying cash flow.

HSBC Holdings plc Annual Report and Accounts 2022

383

Financial statements 
 
 
 
Notes on the financial statements

The following table presents a summary of the key assumptions underlying the most sensitive inputs to the model for HSBC North America 
Holdings Limited and HSBC Bank Bermuda Limited, the key risks attaching to each, and details of a reasonably possible change to assumptions 
where, in the opinion of management, these could result in an impairment.

Reasonably possible changes in key assumptions

Investment

HSBC North America 
Holdings Limited and HSBC 
Bank Bermuda Limited 
(subsidiaries of HSBC 
Overseas Holdings (UK) 
Limited)

Input

Key assumptions

Associated risks

Reasonably possible 
change

Free cash flows projections

• Level of interest rates and 

yield curves.

• Competitors’ positions 

within the market.

• Strategic actions relating 
to revenue and costs are 
not achieved.

• Free cash flow projections 

decrease by 10%.

Discount rate

• Discount rate used is a 

reasonable estimate of a 
suitable market rate for 
the profile of the 
business.

• External evidence arises 
to suggest that the rate 
used is not appropriate to 
the business.

• Discount rate increases 

by 1%.

Sensitivity of VIU to reasonably possible changes in key assumptions

In $bn (unless otherwise stated)

At 31 December 2022
VIU

Impact on VIU
100bps increase in the discount rate – single variable1  
10% decrease in forecast profitability – single variable1

HSBC North 
America Holdings 
Limited

HSBC Bank 
Bermuda Limited

18.4

(1.7)   
(1.8)   

2.5

(0.2) 
(0.2) 

1   The recoverable amount of HSBC Overseas Holding (UK) Limited represents the aggregate of recoverable amounts of the underlying subsidiaries. 
Single variable sensitivity analysis on a single subsidiary may therefore not be representative of the aggregate impact of the change in the variable.

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

2022

2021

37.86%
Hong Kong
$m
520  
7,683  
361  

240,679  
218,892  
4,325  
1,375  
1,269  

37.86%
Hong Kong
$m
708 
7,597 
568 

230,866 
209,315 
4,280 
1,872 
1,686 

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 2022
At 31 Dec 2021

Conduits

Conduits Securitisations HSBC managed funds

Other

$bn
4.2   
4.4   

$bn
7.2   
10.0   

$bn
4.8   
6.3   

$bn
7.5   
8.4   

Total

$bn
23.7 
29.1 

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 2022, Solitaire, HSBC’s principal SIC, held $1.3bn of ABSs (2021: $1.6bn). It is currently funded entirely by commercial paper 

(‘CP’) issued to HSBC. At 31 December 2022, HSBC held $1.5bn of CP (2021: $1.8bn).

384

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
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 $6.2bn at 31 December 2022 (2021: $6.7bn). 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.

Nature and risks associated with HSBC interests in unconsolidated structured entities

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 2022

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 2022

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 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

Securitisations

HSBC 
managed 
funds

Non-HSBC 
managed 
funds

Other

85   
8   
—   
—   
—   
93   

$bn

2.5   

—   

—   

2.5   
—   
—   

—   

—   
0.2   
2.7   

96   
11   
—   
—   
—   
107   
$bn

4.8   

—   

—   

4.8   
—   
—   

—   

—   
0.1   
4.9   

338   
102   
28   
18   
5   
491   
$bn

10.7   

0.4   

9.7   

—   
0.6   
—   

—   

—   
1.5   
12.2   

294   
116   
33   
14   
4   
461   
$bn

10.8   

0.2   

10.0   

—   
0.6   
—   

—   

—   
0.9   
11.7   

1,321   
929   
388   
206   
24   
2,868   
$bn

19.7   

0.1   

18.7   

0.5   
0.4   
—   

—   

—   
4.6   
24.3   

1,408   
911   
435   
197   
11   
2,962   
$bn

18.6   

2.4   

15.5   

0.1   
0.6   
—   

—   

—   
4.6   
23.2   

41   
4   
—   
—   
—   
45   

$bn

2.6   

—   

—   

1.9   
—   
0.7   

0.4   

0.4   
1.8   
4.0   

37   
3   
—   
—   
—   
40   

$bn

3.8   

0.1   

—   

3.0   
—   
0.7   

0.4   

0.4   
1.2   
4.6   

Total

1,785 
1,043 
416 
224 
29 
3,497 
$bn

35.5 

0.5 

28.4 

4.9 
1.0 
0.7 

0.4 

0.4 
8.1 
43.2 

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 

HSBC Holdings plc Annual Report and Accounts 2022

385

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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 115.

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.

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 2022 and 2021 was not significant.

21 Goodwill and intangible assets

Goodwill
Present value of in-force long-term insurance business
Other intangible assets1
At 31 Dec

2022
$m
4,156   
9,900   
7,265   
21,321   

2021
$m
5,033 
9,453 
6,136 
20,622 

1 Included within other intangible assets is internally generated software with a net carrying value of $6,166m (2021: $5,430m). During the year, 

capitalisation of internally generated software was $2,663m (2021: $2,373m), impairment was $125m (2021: $137m) and amortisation was $1,447m 
(2021: $1,183m).

Movement analysis of goodwill

Gross amount
At 1 Jan 
Exchange differences
Reclassified to held for sale and additions1
Other
At 31 Dec
Accumulated impairment losses
At 1 Jan
Impairment losses2
Exchange differences
Reclassified to held for sale1
At 31 Dec
Net carrying amount at 31 Dec

2022
$m

22,215   
(776)   
(2,485)   
11   
18,965   

(17,182)   
—   
482   
1,891   
(14,809)   
4,156   

2021
$m

23,135 
(905) 
— 
(15) 
22,215 

(17,254) 
(587) 
659 
— 
(17,182) 
5,033 

1 Includes goodwill allocated to disposal groups as a result of the planned sales of our retail banking operations in France, banking business in Canada 
and branch operations in Greece, offset by goodwill arising from the acquisition of L&T Investment Management Limited. For further details, see 
Note 23.

2 Full impairment of goodwill allocated to Latin America – WPB.

386

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Goodwill

Impairment testing

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 2022. No indicators of impairment were 
identified as part of these reviews.

Basis of the recoverable amount

The recoverable amount of all CGUs to which goodwill has been allocated was equal to its value in use (‘VIU’) at each respective testing date. 
The VIU is calculated by discounting management’s cash flow projections for the CGU. 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 2022

Carrying 
amount at 
1 Oct 2022

of which 
goodwill

Value in 
use at 
1 Oct 2022

$m
15,215   

$m
2,643   

$m
46,596 

Discount 
rate

%
 9.9 

Europe – WPB  

Growth 
rate
beyond 
initial
cash flow

Carrying 
amount at 
1 Oct 2021

of which 
goodwill

Value in use 
at 1 Oct 
2021

%
 2.0   

$m
18,780   

$m
3,556   

$m
29,799 

Growth rate 
beyond 
initial cash 
flow 
projections

%
 1.8 

Discount
rate

%
 9.2 

At 1 October 2022, aggregate goodwill of $1,464m (1 October 2021: $2,108m) had been allocated to CGUs that were not considered individually 
significant. The Group’s CGUs do not carry on their balance sheets any significant intangible assets with indefinite useful lives, other than 
goodwill.

Management’s judgement in estimating the cash flows of a CGU

The cash flow projections for each CGU are based on 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. For the 1 October 2022 impairment test, 
cash flow projections until the end of 2027 were considered, in line with our internal planning horizon. Key assumptions underlying cash flow 
projections reflect management’s outlook on interest rates and inflation, as well as business strategy, including the scale of investment in 
technology and automation. Our cash flow projections include known and observable climate-related opportunities and costs associated with our 
sustainable products and operating model. 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. The impacts of climate-risk are included to the extent that they are observable in 
discount rates and asset prices.

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 2022, given the extent by which VIU exceeds carrying amount, the Europe – WPB CGU was not 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. None of the 
remaining CGUs are individually significant.
Other intangible assets

Impairment testing

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.

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 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. Our cash flow projections include known and observable 
climate-related opportunities and costs associated with our sustainable products and operating model.

HSBC Holdings plc Annual Report and Accounts 2022

387

Financial statements 
Notes on the financial statements

• 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. The impacts of climate-risk are included to the extent that they are observable in discount rates and 
asset prices.

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 2022, 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. 

Financial Reporting 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 Financial 
Reporting Committee.

Movements in PVIF

At 1 Jan
Acquisitions
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

2022
$m
9,453   
271   
263   
1,322   
(785)   
(252)   
(22)   
(87)   
9,900   

2021
$m
9,435 
— 
130 
1,090 
(903) 
(105) 
48 
(112) 
9,453 

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:

• $875m decrease (2021: $59m increase) in PVIF due to rising interest rates, which is directly offset within the valuation of liabilities under 

insurance contracts;

• $72m decrease (2021: $324m decrease) 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

• $695m increase (2021: $160m increase) 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

2022

Hong Kong

%
 3.85 
 7.33 
 3.00 

France1
%
 2.80 
 4.44 
 4.26 

2021

Hong Kong

%
 1.40 
 5.20 
 3.00 

France1
%
 0.69 
 1.55 
 1.80 

1 For 2022, the calculation of France’s PVIF assumes a risk discount rate of 4.44% (2021: 1.55%) plus a risk margin of $100m (2021: $215m).

388

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
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 237.

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 238.

22 Prepayments, accrued income and other assets

Prepayments and accrued income
Settlement accounts
Cash collateral and margin receivables
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

2022
$m
10,316   
19,565   
63,421   
15,752   
8,407   
4,257   
7,282   
2,219   
10,365   
15,282   
156,866   

2021
$m
8,233 
17,713 
42,171 
15,283 
11,229 
3,668 
10,269 
2,985 
10,255 
14,765 
136,571 

Prepayments, accrued income and other assets include $113,383m (2021: $91,045m) of financial assets, the majority of which are measured at 
amortised cost.

23 Assets held for sale and liabilities of disposal groups held for sale

Held for sale at 31 December
Disposal groups
Unallocated impairment losses1
Non-current assets held for sale
Assets held for sale
Liabilities of disposal groups held for sale

2022
$m

118,055   
(2,385)   
249   
115,919   
114,597   

2021
$m

2,921 
— 
490 
3,411 
9,005 

1   This represents impairment losses in excess of the carrying value of the non-current assets, excluded from the measurement scope of IFRS 5.  

Disposal groups 
Planned sale of our retail banking operations 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 operations in France. The sale, 
which is subject to regulatory approvals and the satisfaction of other relevant conditions, includes: HSBC Continental Europe’s French retail 
banking operations; 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 framework agreement has a long-stop date of 31 May 2024, if the sale has not closed by that point, the agreement will terminate, although 
that date can be extended by either party to 30 November 2024 in certain circumstances or with the agreement of both parties. We have agreed 
a detailed plan with My Money Group with the aim of completing the sale in the second half of 2023, subject to regulatory approvals, agreement 
and implementation of necessary financing structures, and the completion of the operational transfer, including customer and data migrations. In 
this regard the framework agreement imposes certain obligations on the parties in planning for completion.

Given the scale and complexity of the business being sold, there is risk of delay in the implementation of this plan. The disposal group was 
classified as held for sale for the purposes of IFRS 5 as at 30 September 2022, reflecting the prevailing judgements concerning likelihood of the 
framework agreement’s timetable being achieved. The assets and liabilities classified as held for sale were determined in accordance with the 
framework agreement, and are subject to change as the detailed transition plan is executed. This classification and consequential 
remeasurement resulted in an impairment loss of $2.4bn, which included impairment of goodwill of $0.4bn and related transaction costs. At 31 
December 2022, we reassessed the likelihood of completion, taking account of the most recent correspondence with My Money Group 
concerning the implementation of the plan and related developments. As a result of this reassessment, the likelihood of completion in 2023 is 
judged to be highly probable. As such, and in accordance with IFRS 5, the disposal group continues to be classified as held for sale. 

The disposal group will be remeasured at the lower of the carrying amount and fair value less costs to sell at each reporting period. Any 
remaining gains or losses not previously recognised, including from the recycling of foreign currency translation reserves and the reversal of any 
remaining deferred tax assets and liabilities, will be recognised on completion.

HSBC Holdings plc Annual Report and Accounts 2022

389

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Planned sale of our banking business in Canada

On 29 November 2022, HSBC Holdings plc announced its wholly-owned subsidiary, HSBC Overseas Holdings (UK) Limited, entered into an 
agreement for the planned sale of its banking business in Canada to Royal Bank of Canada. Completion of the transaction is expected in late 
2023, subject to regulatory and governmental approval.

The majority of the estimated gain on sale of $5.7bn (inclusive of the recycling of an estimated $0.6bn of accumulated foreign currency 
translation reserve losses) will be recognised on completion, reduced by earnings recognised by the Group in the period to completion. The 
estimated pre-tax profit on the sale will be recognised through a combination of the consolidation of HSBC Canada’s results into the Group’s 
financial statements (between the 30 June 2022 net asset reference date and until completion), and the remaining gain on sale recognised at 
completion. There would be no tax on the gain recognised at completion. At 31 December 2022, total assets of $90bn and total liabilities of 
$85bn met the criteria to be classified as held for sale in accordance with IFRS 5.

Planned sale of our branch operations in Greece

On 24 May 2022, HSBC Continental Europe signed a sale and purchase agreement for the planned sale of its branch operations in Greece to 
Pancreta Bank SA. Completion of the transaction is subject to regulatory approval, and is currently expected to occur in the first half of 2023. At 
31 December 2022, the disposal group included $0.4bn of loans and advances to customers and $2.3bn of customer accounts, which met the 
criteria to be classified as held for sale. In the second quarter of 2022, we recognised a loss of $0.1bn, including goodwill impairment, upon 
reclassification as held for sale in accordance with IFRS 5. On completion accumulated foreign currency translation reserves will be recycled to 
the income statement. 

Planned sale of our business in Russia

On 30 June 2022, following a strategic review of our business in Russia, HSBC Europe BV (a wholly-owned subsidiary of HSBC Bank plc) 
entered into an agreement for the planned sale of its wholly-owned subsidiary HSBC Bank (RR) (Limited Liability Company). Completion of the 
transaction is subject to regulatory and governmental approval, and is currently expected to occur in the first half of 2023. In 2022, a $0.3bn loss 
on the planned sale was recognised, upon reclassification as held for sale in accordance with IFRS 5. On completion accumulated foreign 
currency translation reserves will be recycled to the income statement. 

At 31 December 2022, the major classes of assets and associated liabilities of disposal groups held for sale, including allocated impairment 
losses, were as follows:

Assets of disposal groups held for sale
Cash and balances at central banks
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 investments1
Goodwill
Prepayments, accrued income and other assets 
Total assets at 31 December 2022

Liabilities of disposal groups held for sale
Trading liabilities
Deposits by banks
Customer accounts  
Repurchase agreements – non-trading
Financial liabilities designated at fair value
Derivatives
Debt securities in issue  
Subordinated liabilities
Accruals, deferred income and other liabilities 
Total liabilities at 31 December 2022

Expected date of completion
Operating segment

Canada

$m

4,664   
3,168   

13   

866   
99   
55,197   
4,396   
17,243   
225   
4,256   
90,127   

2,751   
62   
60,606   
3,266   
—   
806   
11,602   
8   
5,727   
84,828   

Retail banking 
operations in France

$m

71   
—   

47   

—   
—   
25,029   
—   
—   
—   
75   
25,222   

—   
—   
22,348   
—   
3,523   
7   
1,326   
—   
159   
27,363   

Other

$m

1,811   
8   

1   

—   
154   
350   
250   
106   
—   
26   
2,706   

3   
2   
2,320   
—   
—   
—   
—   
—   
81   
2,406   

Total

$m

6,546 
3,176 

61 

866 
253 
80,576 
4,646 
17,349 
225 
4,357 
118,055 

2,754 
64 
85,274 
3,266 
3,523 
813 
12,928 
8 
5,967 
114,597 

Second half of 2023
All global  businesses

Second half of 2023
WPB

1   Includes financial investments measured at fair value through other comprehensive income of $11,184m and debt instruments measured at amortised 

cost of $6,165m 

Net assets/(liabilities) classified as held for sale1
Expected cash contribution 2
Disposal group post-cash contribution 3

Retail banking 
operations in France

$m
(2,063) 
4,094 
2,031 

1   Excludes impairment loss allocated against the non-current assets that are in scope of IFRS 5 measurement of $78m.
2   The contributions are reported within ‘Cash and balances at central banks’ on the Group’s consolidated balance sheet.
3   ‘Disposal group post-cash contribution’ includes the net asset value of the transferring business of €1.6bn ($1.8bn) and $0.2bn of additional items to 

which a nil value is ascribed per the framework agreement. 

390

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Under the financial terms of the planned transaction, HSBC Continental Europe will transfer the business with a net asset value of €1.6bn 
($1.8bn), subject to adjustment (upwards or downwards) in certain circumstances, for a consideration of €1. Any required increase to the net 
asset value of the business to achieve the net asset value of €1.6bn ($1.8bn) will be satisfied by the inclusion of additional cash. The value of 
cash contribution will be determined by the net asset or liability position of the disposal group at the point of completion. Based upon the net 
liabilities of the disposal group at 31 December 2022, HSBC would be expected to include a cash contribution of $4.1bn as part of the planned 
transaction. 
Completed business disposals

Mass market retail banking business in the US

On 26 May 2021, we announced our intention to exit our mass market retail banking business in the US, including our Personal and Advance 
propositions, as well as retail business banking, and rebranding 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 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. As a 
result of entering into these sale agreements, assets and liabilities related to the agreements were transferred to held for sale during the second 
quarter of 2021.

In February 2022, we completed the sale of the branch disposal group and recognised a net gain on sale of $0.2bn (including subsequent closing 
adjustments). Included in the sale were $2.1bn of loans and advances to customers and $6.9bn of customer accounts. Certain assets under 
management associated with our mass market retail banking operations were also transferred. The remaining branches not sold or rebranded 
have been closed.
Business acquisitions

The following acquisitions form part of our strategy to become a market leader in Asian wealth management:

• On 28 January 2022, HSBC Insurance (Asia-Pacific) Holdings Limited, a subsidiary of the Group, notified the shareholders of Canara HSBC 

Life Insurance Company Limited (‘Canara HSBC’) of its intention to increase its shareholding in Canara HSBC 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 
Canara HSBC, as well as internal and regulatory approvals. Established in 2008, Canara HSBC is a life insurance company based in India.

• On 11 February 2022, HSBC Insurance (Asia-Pacific) Holdings Limited completed the acquisition of 100% of AXA Insurance Pte Limited (‘AXA 
Singapore’) for $0.5bn. A gain on acquisition of $0.1bn was recorded, reflecting the excess of the fair value of net assets acquired (gross 
assets of $4.5bn and gross liabilities of $3.9bn) over the acquisition price. The legal integration of AXA Singapore with HSBC’s pre-existing 
insurance operations in the country concluded on 1 February 2023.

• On 6 April 2022, The Hongkong and Shanghai Banking Corporation Limited, a subsidiary of the Group, announced it had increased its 

shareholding in HSBC Qianhai Securities Limited, a partially-owned subsidiary, for $0.2bn from 51% to 90%.

• On 23 June 2022, HSBC Insurance (Asia) Limited, a subsidiary of the Group, acquired the remaining 50% equity interest in HSBC Life 

Insurance Company Limited for $0.2bn. Headquartered in Shanghai, HSBC Life Insurance Company Limited offers a comprehensive range of 
insurance solutions covering annuity, whole life, critical illness and unit-linked insurance products.

• On 25 November 2022, HSBC Asset Management (India) Private Ltd, a subsidiary of the Group, completed the acquisition of L&T Investment 

Management Limited from L&T Finance Holdings Limited for $0.4bn, recognised primarily as intangibles and goodwill. L&T Investment 
Management Limited is the investment manager of the L&T Mutual Fund, with assets under management of $9.4bn on completion.

24 Trading liabilities

Deposits by banks1
Customer accounts1
Other debt securities in issue (Note 26)
Other liabilities – net short positions in securities
At 31 Dec

1 ‘Deposits by banks’ and ‘Customer accounts’ include fair value repos, stock lending and other amounts.

25 Financial liabilities designated at fair value

HSBC

Deposits by banks and customer accounts1
Liabilities to customers under investment contracts
Debt securities in issue (Note 26)
Subordinated liabilities (Note 29)
At 31 Dec

2022
$m
9,332   
10,724   
978   
51,319   
72,353   

2022
$m
19,171   
5,380   
93,140   
9,636   
127,327   

2021
$m
4,243 
9,424 
1,792 
69,445 
84,904 

2021
$m
16,703 
5,938 
112,761 
10,100 
145,502 

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 $8,124m less than the contractual amount at maturity (2021: $827m 
more). The cumulative amount of change in fair value attributable to changes in credit risk was a profit of $234m (2021: loss of $2,084m). 

HSBC Holdings plc Annual Report and Accounts 2022

391

Financial statements 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC Holdings

Debt securities in issue (Note 26)
Subordinated liabilities (Note 29)
At 31 Dec

2022
$m
25,423   
6,700   
32,123   

2021
$m
26,818 
5,600 
32,418 

The carrying amount of financial liabilities designated at fair value was $2,405m less than the contractual amount at maturity 
(2021: $1,766m more). The cumulative amount of change in fair value attributable to changes in credit risk was a loss of $516m (2021: $951m).

26 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 24)
–  financial liabilities designated at fair value (Note 25)
At 31 Dec

HSBC Holdings

Debt securities 
Included within:
–  financial liabilities designated at fair value (Note 25)
At 31 Dec

27 Accruals, deferred income and other liabilities

Accruals and deferred income
Settlement accounts
Cash collateral and margin payables
Endorsements and acceptances
Employee benefit liabilities (Note 5)
Lease liabilities
Other liabilities
At 31 Dec

2022
$m
145,240   
27,027   
172,267   

(978)   
(93,140)   
78,149   

2022
$m
92,361   

(25,423)   
66,938   

2022
$m
12,353   
18,176   
70,292   
8,379   
1,096   
2,767   
20,177   
133,240   

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 
3,586 
22,430 
114,773 

Accruals, deferred income and other liabilities include $125,890m (2021: $111,887m) of financial liabilities, the majority of which are measured at 
amortised cost.

28 Provisions

Restructuring
costs

Legal 
proceedings
and regulatory
matters

Customer
remediation

Other
provisions

$m

383   
434   
(288)   
(87)   
3   
445   

$m

$m

$m

619   
271   
(393)   
(82)   
(6)   
409   

386   
60   
(106)   
(109)   
(36)   
195   

558   
206   
(168)   
(125)   
(74)   
397   

Total

$m

1,946 
971 
(955) 
(403) 
(113) 
1,446 

620 
(108) 
512 

2,566 
1,958 

Provisions (excluding contractual commitments)
At 1 Jan 2022
Additions
Amounts utilised
Unused amounts reversed
Exchange and other movements
At 31 Dec 2022
Contractual commitments1
At 1 Jan 2022
Net change in expected credit loss provision and other movements
At 31 Dec 2022
Total provisions
At 31 Dec 2021
At 31 Dec 2022

392

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

671   
347   
(499)   
(170)   
34   
383   

$m

$m

$m

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 

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 35. 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.

For further details of the impact of IFRS 9 on undrawn loan commitments and financial guarantees, presented in ‘Contractual commitments’, see 
Note 33. 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 163.

29 Subordinated liabilities

HSBC’s subordinated liabilities

At amortised cost
–  subordinated liabilities
–  preferred securities
Designated at fair value (Note 25)
–  subordinated liabilities
–  preferred securities
At 31 Dec
Issued by HSBC subsidiaries
Issued by HSBC Holdings

2022
$m
22,290   
20,547   
1,743   
9,636   
9,636   
—   
31,926   
6,094   
25,832   

2021
$m
20,487 
18,640 
1,847 
10,100 
10,100 
— 
30,587 
9,112 
21,475 

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.

HSBC Holdings plc Annual Report and Accounts 2022

393

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

HSBC’s subsidiaries subordinated liabilities in issue

Additional tier 1 capital securities guaranteed by HSBC Holdings1,2
$900m

10.176% non-cumulative step-up perpetual preferred securities, series 23 

Additional tier 1 capital securities guaranteed by HSBC Bank plc1,2
£700m

5.844% non-cumulative step-up perpetual preferred securities4,5 

Tier 2 securities issued by HSBC Bank plc
$750m
$500m
$300m
$300m

Undated floating rate primary capital notes
Undated floating rate primary capital notes
Undated floating rate primary capital notes, series 3
7.65% subordinated notes6

£300m
£350m
£500m
£225m
£600m

6.50% subordinated notes7 
5.375% callable subordinated step-up notes2,7,8
5.375% subordinated notes7 
6.25% subordinated notes7 
4.75% subordinated notes7 

Tier 2 securities issued by The Hongkong and Shanghai Banking Corporation Limited
$400m

Primary capital undated floating rate notes (third series)

Tier 2 securities issued by HSBC Bank Malaysia Berhad
MYR500m 5.05% subordinated bonds2,9

Tier 2 securities issued by HSBC USA Inc.
$250m

7.20% subordinated debentures2 

Tier 2 securities issued by HSBC Bank USA, N.A.
$1,000m
$750m
$700m

5.875% subordinated notes10
5.625% subordinated notes10
7.00% subordinated notes 

Tier 2 securities issued by HSBC Bank Canada

Other subordinated liabilities each less than $150m2,11

Securities issued by other HSBC subsidiaries
Other subordinated liabilities each less than $200m12
Subordinated liabilities issued by HSBC subsidiaries at 31 Dec

First call date Maturity date

Jun 2030

Nov 2031

Jun 1990
Sep 1990
Jun 1992
— 

— 
Nov 2025
— 
— 
— 

Jul 1991

May 2025  

Jul 2023  
Nov 2030  
Aug 2033  
Jan 2041  
Mar 2046  

Nov 2022

Nov 2027  

— 

Jul 2097  

— 
— 
— 

Nov 2034  
Aug 2035  
Jan 2039  

Oct 1996

Nov 2083  

2022
$m

900   
900   

684   
684   

750   
500   
300   
170   
1,720   

162   
73   
186   
56   
230   
707   
2,427   

400   
400   

—   
—   

223   
223   

339   
366   
700   
1,405   

—   
—   

2021
$m

900 
900 

947 
947 

750 
500 
300 
300 
1,850 

406 
539 
900 
303 
805 
2,953 
4,803 

400 
400 

120 
120 

222 
222 

456 
489 
697 
1,642 

9 
9 

55   
6,094   

69 
9,112 

1 See paragraph below, ‘Guaranteed by HSBC Holdings or HSBC Bank plc’.
2 These securities are ineligible for inclusion in the capital base of HSBC.
3 The interest rate payable after June 2030 is the sum of the three-month Libor plus 4.98%.
4  The interest rate payable after November 2031 is the sum of the compounded daily Sonia rate plus 2.0366%.
5  The value of the security partially decreased as a result of a fair value hedge gain. The instrument was held at amortised cost in 2021.
6  HSBC Bank plc tendered for this security in November 2022. The principal balance is $180m. The original notional value of the security was $300m.
7  HSBC Bank plc tendered for these securities in November 2022. The principal balances are £135m, £61m, £157m, £70m and £237m, respectively. The 

original notional values of these securities were £300m, £350m, £500m, £225m and £600m respectively.

8  These securities qualified as tier 2 capital for HSBC under CRR II until 31 December 2021 by virtue of the application of grandfathering provisions. The 

interest rate payable after November 2025 is the sum of the compounded daily Sonia rate plus 1.6193%.

9  These securities were fully repaid in November 2022.
10  HSBC tendered for these securities in November 2019. The principal balances are $357m and $383m respectively. The original notional values of these 

securities were $1,000m and $750m, respectively.

11  Liability accounts for HSBC Bank Canada have been reclassified to ‘Liabilities of disposal groups held for sale’. 
12  These securities are included in the capital base of HSBC, in accordance with the grandfathering provisions under CRR II. In 2022, securities of $11m 

matured and were redeemed.  

HSBC Holdings’ subordinated liabilities

At amortised cost 
Designated at fair value (Note 25)
At 31 Dec

2022
$m
19,727   
6,700   
26,427   

2021
$m
17,059 
5,600 
22,659 

394

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings’ subordinated liabilities in issue

Tier 2 securities issued by HSBC Holdings
Amounts owed to third parties
$2,000m
$1,500m
$1,500m
$264m
$223m
$125m
$97m
$1,431m
$569m
$1,515m
$985m
$961m
$539m
$1,500m
$2,000m
$2,000m

4.25% subordinated notes2,3
4.25% subordinated notes2
4.375% subordinated notes2
7.625% subordinated notes1,4
7.625% subordinated notes2,6
7.35% subordinated notes1,4
7.35% subordinated notes2,6
6.50% subordinated notes1,5
6.50%subordinated notes2,6
6.50% subordinated notes1,5
6.50% subordinated notes2,6
6.80% subordinated notes1,5
6.80% subordinated notes2,6
5.25% subordinated notes2
4.762% subordinated notes2
8.113% subordinated notes2

£650m
£650m
£750m
£900m
£1,000m

€1,500m
€1,000m
€1,250m

5.75% subordinated notes2
6.75% subordinated notes2
7.00% subordinated notes2
6.00% subordinated notes2
8.201% subordinated notes2

3.0% subordinated notes2
3.125% subordinated notes2
6.364% subordinated notes2

SGD900m 5.25%subordinated notes2

JPY11,900m 2.50% subordinated notes2

First call
date

Maturity
date

2022
$m

— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
— 
Mar 2032
Nov 2032

— 
— 
— 
— 
Aug 2029

— 
— 

Nov 2027

 Mar 2024  
Aug 2025  
 Nov 2026  
May 2032  
May 2032  
Nov 2032  
Nov 2032  
May 2036  
May 2036  
Sep 2037  
Sep 2037  
Jun 2038  
Jun 2038  
Mar 2044  
Mar 2033  
Nov 2033  

Dec 2027  
Sep 2028  
Apr 2038  
Mar 2040  
Nov 2034  

Jun 2025  
Jun 2028  
Nov 2032  

1,941   
1,450   
1,450   
308   
223   
143   
97   
1,461   
568   
1,178   
977   
953   
540   
1,447   
1,766   
2,008   

775   
816   
817   
776   
1,252   

1,492   
991   
1,316   

Jun 2027

Jun 2032  

694   

Sep 2027

Sep 2032  

88   

2021
$m

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 
— 

— 

— 

Amounts owed to HSBC undertakings
$900m

10.176% subordinated step-up cumulative notes

Jun 2030

Jun 2040  

At 31 Dec

25,527   

21,759 

900   
900   
26,427   

900 
900 
22,659 

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.

4  These securities were subjected to a tender and an exchange offer exercise in September 2022. The original principal amounts were $488m and 

$222m, respectively, and are now $264m and $125m.   

5   These securities were subjected to an exchange offer exercise in September 2022. The original principal amounts were $2,000m, $2,500m and 

$1,500m, respectively, and are now $1,431m, $1,515m and $961m.  

6  These subordinated notes were issued under an exchange offer exercise in September 2022.    

HSBC Holdings plc Annual Report and Accounts 2022

395

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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.

30 Maturity analysis of assets, liabilities and off-balance sheet commitments
The table on page 397 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 included in ‘other financial liabilities’, 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 238. 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.

396

HSBC Holdings plc Annual Report and Accounts 2022

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

  327,002   

7,297   

43,787   

—   

—   

—   

—   

—   

—   

  213,234   

1,333   

1,343   

—   

—   

—   

338   

—   

—   

—   

425   

—   

—   

—   

808   

—   

—   

—   

222   

—    327,002 

—   

7,297 

—   

43,787 

390    218,093 

2,778   

101   

370   

658   

(53)   

645   

2,005   

38,559   

45,063 

133   
13,963   
75,487   
9,142   
60,064   
6,281   
51,736   
79,912   
3,755   
6,249   

  281,710   
72,241   
  139,935   
41,835   
84,956   
13,144   
  171,173   
46,997   
33,781   
99,409   

30   
8,364   
58,983   
6,664   
45,719   
6,600   
16,164   
31,629   
3,452   
3,772   
  1,439,344    232,669    124,107   
—   
  1,439,344    232,669    124,107   

—   

—   

21   
880   
35,642   
5,754   
24,427   
5,461   
5,840   
12,301   
3,044   
616   
59,340   
—   
59,340   

64   
2,344   

261   
3,058   

1,052   
3,900   

875    284,146 
132    104,882 
33,738    100,027    173,306    307,736    924,854 
51,104    273,487    412,140 
31,135    446,032 
66,682 
—    253,754 
79,410    119,766    425,564 
14,697    117,378 
40,017   
1,708    113,380 
303   
56,915    166,681    302,281    483,863    2,865,200 
—    101,330    101,330 
56,915    166,681    302,281    585,193    2,966,530 

18,375   
68,514    108,590   
13,612   
13,138   
2,066   
3,999   
41,968   
15,369   
546   

5,779   
22,627   
5,332   
2,776   
13,581   
3,263   
777   

3,114   

—   

—   

27,340   

—   

—   

—   

—   

—   

—   

—   

27,340 

43,787   
46,994   
  1,388,297   
  657,413   
  555,539   
  175,345   
  121,193   

—   
359   
93,108   
55,252   
31,624   
6,232   
3,804   

—   
3,510   
47,712   
35,430   
10,385   
1,897   
685   

—   
205   
14,244   
10,431   
3,080   
733   
170   

—   
136   
17,295   
12,374   
3,824   
1,097   
645   

7,864   

—   

66,027   

5,668   

—   

281   

—   

113   

—   

113   

—   
1,455   
4,719   
2,835   
1,667   
217   
1,250   

—   

116   

—   
13,737   
4,607   
2,351   
2,146   
110   
—   

43,787 
—   
326   
66,722 
321    1,570,303 
2    776,088 
274    608,539 
45    185,676 
—    127,747 

—   

35   

—   

—   

7,864 

72,353 

16,431   

7,399   

6,561   

4,307   

5,326   

19,287   

34,885   

33,131    127,327 

—   
7,057   

—   
3,621   

—   
4,792   

—   
3,156   

—   
4,289   

—   
16,234   

—   
29,940   

—   
23,510   

— 
92,599 

—   

—   

—   

—   

—   

1,971   

3,675   

3,990   

9,636 

9,374   
  284,414   
4,514   
—   
705   
3,809   
76,928   
  104,224   
—   

3,778   
73   
7,400   
—   
28   
7,372   
4,342   
9,384   
—   
  2,160,673    131,537   
—   
  2,160,673    131,537   

—   

  825,781   
  242,953   
  449,843   
  132,985   

184   
2   
176   
6   

1,769   
18   
7,476   
—   
40   
7,436   
5,374   
4,785   
11   
76,413   
—   
76,413   

75   
3   
72   
—   

1,151   
46   
4,745   
—   
38   
4,707   
6,599   
1,022   
160   
31,611   
—   
31,611   

59   
—   
59   
—   

1,037   
57   
3,585   
—   
36   
3,549   
8,606   
1,626   
—   
37,389   
—   
37,389   

210   
110   
84   
16   

1,082   
171   
9,198   
—   
124   
9,074   
2,343   
1,111   
—   
39,650   
—   
39,650   

242   
199   
43   
—   

5,631   

21,991   
—   
1,346   
20,645   

1,270   
849   
19,240   
601   
656   
17,983   
8,653   
2,018   
1,689   
85,713   

25,092 
136    285,764 
78,149 
601 
2,973 
74,575 
1,479    114,324 
1,720    125,890 
20,430   
22,290 
79,534    2,642,520 
—    127,982    127,982 
85,713    207,516    2,770,502 

975   
811   
163   
1   

328    827,854 
300    244,378 
28    450,468 
—    133,008 

Financial 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 or otherwise 
mandatorily measured at fair value

Derivatives
Loans and advances to banks
Loans and advances to customers
–  personal
–  corporate and commercial
–  financial
Reverse repurchase agreements – non-trading
Financial investments
Assets held for sale1
Accrued income and other financial assets
Financial assets at 31 Dec 2022
Non-financial assets
Total assets at 31 Dec 2022
Off-balance sheet commitments received
Loan and other credit-related commitments
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
–  debt securities in issue: unsecured
–  subordinated liabilities and preferred 

securities

–  other
Derivatives
Debt securities in issue
–  covered bonds
–  otherwise secured
–  unsecured
Liabilities of disposal groups held for sale2
Accruals and other financial liabilities
Subordinated liabilities
Total financial liabilities at 31 Dec 2022
Non-financial liabilities
Total liabilities at 31 Dec 2022
Off-balance sheet commitments given
Loan and other credit-related commitments
–  personal
–  corporate and commercial 
–  financial 

1  Unallocated impairment losses in relation to disposal groups of $2.4bn and non-financial assets of $1bn that are both are presented within assets held 

for sale on the balance sheet have been included within non-financial assets in the table above.

2   $0.3bn of non-financial liabilities that are presented within liabilities of disposal groups held for sale on the balance sheet have been included within 

non-financial liabilities in the table above.

HSBC Holdings plc Annual Report and Accounts 2022

397

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

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 not
more 
than
1 month

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

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

Financial assets
Cash and balances at central banks
Items in the course of collection from other 
banks
Hong Kong Government certificates of 
indebtedness 

Trading assets 
Financial assets designated at fair value 
Derivatives 
Loans and advances to banks
Loans and advances to customers
–  personal 
–  corporate and commercial
–  financial 
Reverse repurchase agreements – non-trading
Financial investments 
Assets held for sale1
Accrued income and other financial assets
Financial assets at 31 Dec 2021
Non-financial assets 
Total assets at 31 Dec 2021
Off-balance sheet commitments received
Loan and other credit-related commitments
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 
–  debt securities in issue: unsecured 
–  subordinated liabilities and preferred  

securities

–  other 
Derivatives 
Debt securities in issue 
–  covered bonds 
–  otherwise secured 
–  unsecured 
Liabilities of disposal groups held for sale
Accruals and other financial liabilities
Subordinated liabilities 
Total financial liabilities at 31 Dec 2021
Non-financial liabilities 
Total liabilities at 31 Dec 2021
Off-balance sheet commitments given
Loan and other credit-related commitments
–  personal
–  corporate and commercial
–  financial

  403,018   

4,136   

42,578   

—   

—   

—   

—   

—   

—   

2,403   
89   
164   
10,889   
82,531   
11,373   
64,511   
6,647   
49,392   
68,034   
—   
5,932   

  244,422   
4,968   
  195,701   
55,572   
  160,583   
50,573   
97,554   
12,456   
  155,997   
47,084   
58   
79,019   

440   
585   
85   
5,469   
69,380   
8,934   
52,548   
7,898   
18,697   
33,233   
—   
2,935   
 1,393,136    219,434    130,824   
—   
 1,393,136    219,434    130,824   

—   

—   

—   

—   

—   

194   
515   
110   
1,078   
42,459   
8,022   
29,341   
5,096   
9,386   
20,638   
—   
536   
74,916   
—   
74,916   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—    403,018 

—   

4,136 

—   

42,578 

40,716   

468   
224   
233   
1,512   

294   
1,852   
310   
3,134   

621   
855   
91   
5,321   

—    248,842 
49,804 
188    196,882 
83,136 
161   
42,651    107,393    220,746    320,071    1,045,814 
78,373    284,922    475,234 
32,664    505,335 
65,245 
—    241,648 
80,367    125,236    446,274 
2,831 
90,985 
71,065    167,121    309,358    490,094    2,855,948 
—    101,991    101,991 
71,065    167,121    309,358    592,085    2,957,939 

25,271   
72,441    127,527   
14,846   
1,843   

7,766   
28,749   
6,136   
3,661   
21,779   
180   
357   

9,681   
2,672   
49,903   
11   
254   

2,033   
1,689   

549   
263   

2,485   

—   

—   

49,061   

—   

—   

—   

—   

—   

—   

—   

49,061 

42,578   
63,660   
 1,615,025   
  802,777   
  623,459   
  188,789   
  117,625   

—   
2,695   
51,835   
24,725   
22,980   
4,130   
4,613   

—   
2,419   
19,167   
12,038   
5,654   
1,475   
1,716   

5,214   

79,789   
18,080   
—   
9,916   

—   

—   

3,810   
9,437   
1,137   
5,967   

346   
4,514   
—   
2,823   

—   
238   
8,007   
5,961   
1,762   
284   
292   

—   

218   
3,287   
—   
2,259   

—   
125   
9,710   
5,255   
3,402   
1,053   
142   

—   

223   
4,485   
—   
3,462   

—   
14,653   
3,143   
2,304   
706   
133   
975   

—   
16,734   
3,585   
2,242   
1,167   
176   
377   

—   

42,578 
628    101,152 
102    1,710,574 
26    855,328 
33    659,163 
43    196,083 
930    126,670 

—   

—   

—   

5,214 

445   
17,422   
1,481   
14,758   

73   
42,116   
1,160   
34,515   

—   

84,904 
46,161    145,502 
3,778 
35,282    108,982 

—   

—   

—   

—   

—   

—   

—   

5,371   

4,729   

10,100 

8,164   
  190,233   
7,053   
—   
957   
6,096   
8,753   
82,996   
—   
 2,231,006   
—   
 2,231,006   

  813,491   
  239,207   
  456,498   
  117,786   

2,333   
46   
7,777   
—   
164   
7,613   
6   
10,311   
1   
90,531   
—   
90,531   

121   
34   
76   
11   

1,691   
11   
5,664   
—   
42   
5,622   
9   
5,621   
11   
39,478   
—   
39,478   

133   
34   
91   
8   

1,028   
30   
6,880   
997   
31   
5,852   
9   
1,094   
—   
20,055   
—   
20,055   

228   
54   
168   
6   

1,023   
25   
1,703   
—   
193   
1,510   
8   
1,064   
—   
17,485   
—   
17,485   

254   
108   
143   
3   

1,183   
100   
9,045   
996   
896   
7,153   
31   
1,917   
417   
48,148   
—   
48,148   

6,150   

20,181   
—   
1,207   
18,974   
11   

1,070   
288   
20,254   
860   
1,696   
17,698   
68   
2,339   
2,055   
87,889   

22,642 
331    191,064 
78,557 
2,853 
5,186 
70,518 
8,895 
2,818    108,160 
18,003   
20,487 
89,165    2,623,757 
—    127,405    127,405 
87,889    216,570    2,751,162 

78   
32   
46   
—   

931   
688   
243   
—   

238    815,474 
238    240,395 
—    457,265 
—    117,814 

398

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings

Maturity analysis of assets, liabilities and off-balance sheet commitments (continued)

Due not
more 
than
1 month

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

$m

$m

$m

$m

$m

$m

$m

$m

Total

$m

3,210   
2,889   
—   

—   
—   
2,163   

—   
—   
240   

—   
—   
—   

—   
—   
—   

—   
—   
2,035   

—   
796   

—    3,210 
116    3,801 
4,414    17,913    26,765 

—   

1,517   
68   
7,684   
—   
7,684   

48   
—   
—   

—   

2,540   
—   
722   
—   
3,310   
—   
3,310   

—   

2,712   
4,147   
9,022   
—   
9,022   

266   
—   
—   

—   

—   
—   
450   
—   
716   
—   
716   

2,590   
1,101   
120   

—   
—   
750   

—   

1,759   

8,377   
129   
12,317   
—   
12,317   

7,166   
874   
10,549   
—   
10,549   

—   
397   
397   

—   

1,167   
1,051   
1,778   
—   
4,393   
—   
4,393   

111   
2,484   
2,484   

—   

—   
—   
730   
—   
3,325   
—   
3,325   

—   

8,870   
179   
9,289   
—   
9,289   

—   
—   
—   

—   

35   
1,972   
648   
—   
2,655   
—   
2,655   

—   
—   
341   

250   

3,014   
108   
3,713   
—   
3,713   

—   
—   
—   

—   

—   
—   
1,612   
—   
1,612   
—   
1,612   

—   

1,020   
90   
1,110   
—   
1,110   

—   
—   
—   

—   

—   
448   
61   
—   
509   
—   
509   

—   

9,007   

16,230    27,085    52,322 

2,194   
4   
2,198   
—   
2,198   

—   
—   
—   

—   

102   
714   
35   
—   
851   
—   
851   

3,153   
—   
14,195   
—   
14,195   

—   
1,447   
1,447   

—   
14   

—    19,466 
—    4,502 
21,454    45,114   110,066 
—   171,035   171,035 
21,454   216,149   281,101 

—   

—   

314 
16,459    14,217    32,123 
12,784    11,192    25,423 

—   

3,675   

3,025    6,700 

460   
11,046   
—   
1,941   
14,894   
—   
14,894   

14   

1,638   

2,147    6,922 
25,380    27,378    66,938 
31    1,961 
1,492    16,294    19,727 
44,983    60,067   127,985 
8 
44,983    60,075   127,993 

—   

8   

—   
—   
—   

—   
—   
3,017   

—   
23   
5,608   

—   
585   
13,333   

—   
1,102   
1,939   

2,590 
2,811 
25,108 

1,019   

1,346   
58   
2,423   
—   
2,423   

—   
—   
—   

—   

—   
—   
68   
—   
68   
—   
68   

—   

5,987   

19,455   

22,938   

51,408 

3,026   
4   
6,047   
—   
6,047   

3,265   
—   
14,883   
—   
14,883   

—   
—   

—   
—   
33,373   

26,194 
1,173 
25,979    109,284 
—    163,888    163,888 
33,373    189,867    273,172 

—   
—   
—   

—   

—   
—   
12   
—   
12   
—   
12   

—   
1,364   
1,364   

—   
11,276   
8,020   

—   
16,897   
14,553   

111 
32,418 
26,818 

—   

3,256   

2,344   

5,600 

5   
8,525   
—   
—   
9,894   
—   
9,894   

1   
29,889   
—   
3,809   
44,975   
—   
44,975   

1,220 
47   
67,483 
28,018   
4,240 
40   
13,250   
17,059 
58,252    122,531 
311 
58,563    122,842 

311   

Financial assets
Cash at bank and in hand:
–  balances with HSBC undertakings
Derivatives 
Loans and advances to HSBC undertakings 
Financial assets with HSBC undertakings 
designated and otherwise mandatorily 
measured at fair value

Financial investments
Accrued income and other financial assets
Total financial assets at 31 Dec 2022
Non-financial assets 
Total assets at 31 Dec 2022
Financial liabilities
Amounts owed to HSBC undertakings 
Financial liabilities designated at fair value 
–  debt securities in issue 
–  subordinated liabilities and preferred 

securities 
Derivatives 
Debt securities in issue 
Accruals and other financial liabilities
Subordinated liabilities 
Total financial liabilities 31 Dec 2022
Non-financial liabilities 
Total liabilities at 31 Dec 2022

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 2021
Non-financial assets 
Total assets at 31 Dec 2021
Financial liabilities
Amounts owed to HSBC undertakings 
Financial liabilities designated at fair value 
–  debt securities in issue
–  subordinated liabilities and preferred 

securities
Derivatives 
Debt securities in issue 
Accruals and other financial liabilities
Subordinated liabilities 
Total financial liabilities at 31 Dec 2021
Non-financial liabilities 
Total liabilities at 31 Dec 2021

HSBC Holdings plc Annual Report and Accounts 2022

399

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Contractual maturity of financial liabilities

The following table shows, on an undiscounted basis, all cash flows relating to principal and future coupon payments (except for trading liabilities 
and derivatives not treated as hedging derivatives). For this reason, balances in the following table do not agree directly with those in our 
consolidated balance sheet. Undiscounted cash flows payable in relation to hedging derivative liabilities are classified according to their 
contractual maturities. Trading liabilities and derivatives not treated as hedging derivatives are included in the ‘Due not more than 1 month’ time 
bucket and not by contractual maturity.

In addition, loan and other credit-related commitments and financial guarantees are generally not recognised on our balance sheet. The 
undiscounted cash flows potentially payable under loan and other credit-related commitments and financial guarantees are classified on the basis 
of the earliest date they can be called.

Cash flows payable by HSBC under financial liabilities by remaining contractual maturities

Deposits by banks
Customer accounts
Repurchase agreements – non-trading
Trading liabilities
Financial liabilities designated at fair value
Derivatives
Debt securities in issue
Subordinated liabilities
Other financial liabilities1

Loan and other credit-related commitments
Financial guarantees2
At 31 Dec 2022
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 liabilities1

Loan and other credit-related commitments
Financial guarantees2
At 31 Dec 2021
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

Due over
5 years

$m
47,082   
1,387,125   
121,328   
72,353   
16,687   
283,512   
4,329   
37   
153,597   
2,086,050   
825,781   
18,696   
2,930,527   

85%

63,684   
1,613,065   
117,643   
84,904   
18,335   
190,354   
7,149   
119   
129,706   
2,224,959   
813,471   
27,774   
3,066,204   

88%

$m
406   
96,474   
3,852   
—   
7,859   
171   
8,217   
168   
8,670   
125,817   
184   
25   
126,026   

4%

2,712   
54,092   
4,615   
—   
9,760   
192   
7,958   
168   
9,842   
89,339   
121   
6   
89,466   
3%

$m
4,024   
80,608   
1,535   
—   
18,740   
1,181   
17,522   
1,395   
5,994   
130,999   
344   
62   
131,405   

4%

2,800   
37,219   
2,157   
—   
13,606   
190   
15,142   
848   
7,664   
79,626   
615   
9   
80,250   
2%

$m
16,050   
9,961   
1,268   
—   
63,606   
2,222   
34,283   
7,321   
3,230   
137,941   
1,217   
—   
139,158   

4%

31,294   
7,093   
1,359   
—   
63,834   
1,792   
32,651   
6,741   
4,577   
149,341   
1,029   
6   
150,376   

4%

$m
359   
346   
—   
—   
43,475   
1,059   
26,428   
32,946   
1,704   
106,317   
328   
—   
106,645   

3%

643   
138   
935   
—   
50,953   
1,332   
21,911   
28,347   
2,697   
106,956   
238   
—   
107,194   

3%

Total

$m
67,921 
1,574,514 
127,983 
72,353 
150,367 
288,145 
90,779 
41,867 
173,195 
2,587,124 
827,854 
18,783 
3,433,761 

101,133 
1,711,607 
126,709 
84,904 
156,488 
193,860 
84,811 
36,223 
154,486 
2,650,221 
815,474 
27,795 
3,493,490 

1  Excludes financial liabilities of disposal groups.
2  Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

HSBC Holdings

HSBC Holdings’ primary sources of liquidity are dividends received from subsidiaries, interest on and repayment of intra-Group loans and 
securities, and interest earned on its own liquid funds. HSBC Holdings also raises funds in the debt capital markets to meet the Group’s 
minimum requirement for own funds and eligible liabilities. HSBC Holdings uses this liquidity to meet its obligations, including interest and 
principal repayments on external debt liabilities, operating expenses and collateral on derivative transactions.

HSBC Holdings is also subject to contingent liquidity risk by virtue of credit-related commitments and guarantees and similar contracts issued 
relating to its subsidiaries. Such commitments and guarantees are only issued after due consideration of HSBC Holdings’ ability to finance the 
commitments and guarantees and the likelihood of the need arising.

HSBC Holdings actively manages the cash flows from its subsidiaries to optimise the amount of cash held at the holding company level. During 
2022, 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). 

400

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.

Cash flows payable by HSBC Holdings under financial liabilities by remaining contractual maturities

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 2022

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

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

Due over
5 years

$m
48   
11   
1,182   
—   
46   
721   
2,008   
—   
17,707   
19,715   

—   
473   
1,223   
1,196   
81   
1,778   
4,751   
—   
13,746   
18,497   

$m
266   
72   
177   
544   
161   
458   
1,678   
—   
—   
1,678   

111   
2,611   
9   
276   
155   
730   
3,892   
—   
—   
3,892   

$m

—   
1,139   
1,089   
4,899   
1,068   
745   
8,940   
—   
—   
8,940   

—   
621   
51   
1,286   
722   
1,692   
4,372   
—   
—   
4,372   

$m

—   
22,921   
4,231   
44,608   
8,262   
14   
80,036   
—   
—   
80,036   

—   
15,017   
414   
43,360   
7,222   
—   
66,013   
—   
—   
66,013   

$m

—   
19,196   
1,321   
32,540   
27,045   
31   
80,133   
—   
—   
80,133   

—   
17,557   
585   
30,800   
20,777   
40   
69,759   
—   
—   
69,759   

Total

$m
314 
43,339 
8,000 
82,591 
36,582 
1,969 
172,795 
— 
17,707 
190,502 

111 
36,279 
2,282 
76,918 
28,957 
4,240 
148,787 
— 
13,746 
162,533 

1  Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

31 Offsetting of financial assets and financial liabilities
In the offsetting of financial assets and financial liabilities, the net amount is reported in the balance sheet when the offset criteria are met. This 
is achieved when there is a legally enforceable right to offset the recognised amounts and there is either an intention to settle on a net basis, or 
realise the asset and settle the liability simultaneously.

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 

• cash and non-cash collateral (debt securities and equities) has been received/pledged for derivatives and reverse repurchase/repurchase, 

stock borrowing/lending and similar agreements to cover net exposure in the event of a default or other predetermined events.

The effect of over-collateralisation is excluded. 

‘Amounts not subject to enforceable netting agreements’ include contracts executed in jurisdictions where the rights of offset may not be 
upheld under the local bankruptcy laws, and transactions where a legal opinion evidencing enforceability of the right of offset may not have been 
sought, or may have been unable to obtain.

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.

HSBC Holdings plc Annual Report and Accounts 2022

401

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Offsetting of financial assets and financial liabilities

Amounts subject to enforceable netting arrangements

Amounts not set off in the 
balance sheet

Net
amounts 
in
the 
balance
sheet

Gross
amounts

Amounts
offset

$m

$m

$m

Financial 
instruments, 
including 
non-cash 
collateral1
$m

Amounts not
subject to
enforceable
netting
arrangements2
$m

Total

$m

Cash
collateral

Net
amount

$m

$m

419,006   

(140,987)   

278,019   

(236,373)   

(36,486)   

5,160   

6,127    284,146 

24,372   
335,193   
28,337   
806,908   

(236)   
(102,888)   
(12,384)   
(256,495)   

24,136   
232,305   
15,953   
550,413   

(24,106)   
(231,432)   
(13,166)   
(505,077)   

(29)   
(449)   
—   
(36,964)   

1   
424   
2,787   
8,372   

1,367   

25,503 
21,689    253,994 
16,220 
29,450    579,863 

267   

244,694   

(53,378)   

191,316   

(151,304)   

(36,581)   

3,431   

5,566    196,882 

21,568   
353,066   
27,045   
646,373   

(222)   
(136,932)   
(10,919)   
(201,451)   

21,346   
216,134   
16,126   
444,922   

(21,272)   
(215,769)   
(13,065)   
(401,410)   

(71)   
(165)   
—   
(36,817)   

3   
200   
3,061   
6,695   

1,729   

23,075 
25,731    241,865 
16,453 
33,353    478,275 

327   

419,994   

(140,987)   

279,007   

(239,235)   

(29,276)   

10,496   

6,757    285,764 

20,027   
206,827   
37,164   
684,012   

(236)   
(102,888)   
(12,384)   
(256,495)   

19,791   
103,939   
24,780   
427,517   

(19,790)   
(103,296)   
(13,166)   
(375,487)   

—   
(249)   
—   
(29,525)   

1   
394   
11,614   
22,505   

4   

19,795 
23,808    127,747 
24,794 
30,583    458,100 

14   

239,597   

(53,378)   

186,219   

(163,359)   

(18,225)   

4,635   

4,845    191,064 

13,540   
235,042   
40,875   
529,054   

(222)   
(136,932)   
(10,919)   
(201,451)   

13,318   
98,110   
29,956   
327,603   

(13,318)   
(97,816)   
(13,065)   
(287,558)   

—   
(203)   
—   
(18,428)   

—   
91   
16,891   
21,617   

17   

13,335 
28,560    126,670 
29,973 
33,439    361,042 

17   

Financial assets
Derivatives (Note 15)3
Reverse repos, stock borrowing and similar 
agreements classified as:4
–  trading assets
–  non-trading assets 
Loans and advances to customers5
At 31 Dec 2022

Derivatives (Note 15)3
Reverse repos, stock borrowing and similar 
agreements classified as:4
–  trading assets 
–  non-trading assets
Loans and advances to customers5
At 31 Dec 2021

Financial liabilities
Derivatives (Note 15)3
Repos, stock lending and similar 
agreements classified as:4
–  trading liabilities
–  non-trading liabilities 
Customer accounts6
At 31 Dec 2022

Derivatives (Note 15)3
Repos, stock lending and similar 
agreements classified as:4
–  trading liabilities 
–  non-trading liabilities
Customer accounts6
At 31 Dec 2021

1  The disclosure has been enhanced in 2022 to support consistency across Group entities. All financial instruments (whether recognised on our balance 

sheet or as non-cash collateral received or pledged) are presented within ‘financial instruments, including non-cash collateral‘, as balance sheet 
classification has no effect on the rights of offset associated with financial instruments. Comparative data have been re-presented accordingly.

2   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.

3   At 31 December 2022, the amount of cash margin received that had been offset against the gross derivatives assets was $8,357m (2021: $4,469m). 

The amount of cash margin paid that had been offset against the gross derivatives liabilities was $10,918m (2021: $9,479m).

4  For the amount of repos, reverse repos, stock lending, stock borrowing and similar agreements recognised on the balance sheet within ‘Trading 

assets’ of $25,503m (2021: $23,075m) and ‘Trading liabilities’ of $19,795m (2021: $13,335m), see the ‘Funding sources and uses’ table on page 210.

5  At 31 December 2022, the total amount of ‘Loans and advances to customers’ was $924,854m (2021: $1,045,814m), of which $15,953m (2021: 

$16,126m) was subject to offsetting.

6  At 31 December 2022, the total amount of ‘Customer accounts’ was $1,570,303m (2021: $1,710,574m), of which $24,780m (2021: $29,956m) was 

subject to offsetting.

32 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

2022

Number

20,631,520,439   
10,226,221   
—   
348,139,250   
20,293,607,410   

$m
10,316   
5   
—   
174   
10,147   

2021

Number

20,693,621,100   
58,266,053   
—   
120,366,714   
20,631,520,439   

$m
10,347 
29 
— 
60 
10,316 

402

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HSBC Holdings share premium

At 31 Dec

Total called up share capital and share premium

At 31 Dec

2022
$m
14,664   

2022
$m
24,811   

2021
$m
14,602 

2021
$m
24,918 

1  All HSBC Holdings ordinary shares in issue, excluding 325,273,407 shares held in treasury, confer identical rights, including in respect of capital, 

dividends and voting.

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 called by HSBC Holdings on 10 December 2020 and were 
redeemed and cancelled 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 two types of additional tier 1 capital securities in its tier 1 capital, including 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 29 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.

HSBC’s additional tier 1 capital – contingent convertible securities in issue which are accounted for in equity

6.375% perpetual subordinated contingent convertible securities 
$2,250m
6.375% perpetual subordinated contingent convertible securities
$2,450m
6.000% perpetual subordinated contingent convertible securities 
$3,000m
6.250% perpetual subordinated contingent convertible securities1
$2,350m
6.500% perpetual subordinated contingent convertible securities
$1,800m
4.600% perpetual subordinated contingent convertible securities2
$1,500m
4.000% perpetual subordinated contingent convertible securities3
$1,000m
4.700% perpetual subordinated contingent convertible securities4
$1,000m
5.250% perpetual subordinated contingent convertible securities5
€1,500m
6.000% perpetual subordinated contingent convertible securities
€1,000m
4.750% perpetual subordinated contingent convertible securities
€1,250m
5.875% perpetual subordinated contingent convertible securities
£1,000
SGD1,000m 4.700% perpetual subordinated contingent convertible securities6
SGD750m
5.000% perpetual subordinated contingent convertible securities
At 31 Dec

First call
date

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  

2022
$m
2,250   
2,450   
3,000   
2,350   
1,800   
1,500   
1,000   

1,000   
—   
1,123   
1,422   
1,301   
—   
550   
19,746   

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 
22,414 

1   This security was called by HSBC Holdings on 30 January 2023 and is expected to be redeemed and cancelled on 23 March 2023. 
2   This security was issued by HSBC Holdings on 17 December 2020. The first call date is 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 is 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 is six calendar months prior to the reset date of 9 September 2031.
5  This security was called by HSBC Holdings on 9 August 2022 and was redeemed and cancelled on 16 September 2022. 
6  This security was called by HSBC Holdings on 4 May 2022 and was redeemed and cancelled on 8 June 2022. 

HSBC Holdings plc Annual Report and Accounts 2022

403

Financial statements 
 
 
 
Notes on the financial statements

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

Number of
HSBC Holdings
ordinary shares

31 Dec 2022

Usual period of 
exercise

Exercise price 

Number of
HSBC Holdings
ordinary shares

115,650,723 

2021 to 2028

£2.6270–£5.9640  

123,196,850 

31 Dec 2021

Usual period of 
exercise

2020 to 2027

Exercise price

£2.6270–5.9640

Maximum obligation to deliver HSBC Holdings ordinary shares

At 31 December 2022, 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 240,612,019 (2021: 224,974,433). The total number of shares at 31 December 2022 held by employee benefit trusts 
that may be used to satisfy such obligations to deliver HSBC Holdings ordinary shares was 12,315,711 (2021: 9,297,415).

33 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

2022
$m

18,783   
88,240   
676   
107,699   

8,241   
50,852   
768,761   
827,854   

2021
$m

27,795   
85,534   
858   
114,187   

8,827   
47,184   
759,463   
815,474   

HSBC Holdings1

2022
$m

17,707 
— 

90   

17,797 

—   
—   
—   
—   

2021
$m

13,746
—

133 
13,879

— 
— 
— 
— 

1  Financial guarantees by HSBC Holdings are all in favour of other Group entities.
2 

Includes $618,788m of commitments at 31 December 2022 (31 December 2021: $627,637m), 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 28.

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 28 and 35.
Financial Services Compensation Scheme

The Financial Services Compensation Scheme (‘FSCS’) provides compensation, up to certain limits, to eligible customers of financial services 
firms that are unable, or likely to be unable, to pay claims against them. The FSCS may impose a further levy on the group to the extent the 
industry levies imposed to date are not sufficient to cover the compensation due to customers in any future possible collapse. The ultimate FSCS 
levy to the industry as a result of a collapse cannot 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. In December 2022, the FCA announced that it expects to review various elements of the scheme to ensure consumers 
are appropriately and proportionately protected, with costs distributed across industry levy payers in a fair and sustainable way, with a view to 
deliver the majority of changes by the end of the 2023/24 financial year.

Associates

HSBC’s share of associates’ contingent liabilities, contractual commitments and guarantees amounted to $64.8bn at 31 December 2022 (2021: 
$63.5bn). No matters arose where HSBC was severally liable.

404

HSBC Holdings plc Annual Report and Accounts 2022

 
 
 
 
 
 
 
 
 
 
 
 
34 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. 

The table below excludes finance lease receivables reclassified on the balance sheet to ‘Assets held for sale’ in accordance with IFRS 5. Net 
investment in finance leases of $1,502m was reclassified to ‘Assets held for sale’ as a result of the planned sale of our banking business in 
Canada.

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

2022

Unearned
finance
income

$m

$m

Total future
minimum
payments

2021
Unearned
finance
income

$m

$m

Present
value

$m

2,159   
1,652   
1,391   
906   
613   
4,562   
4,064   
10,785   

(236)   
(201)   
(161)   
(131)   
(112)   
(605)   
(736)   
(1,577)   

1,923   
1,451   
1,230   
775   
501   
3,957   
3,328   
9,208   

3,298   
2,303   
1,645   
1,225   
795   
5,968   
4,044   
13,310   

(303)   
(242)   
(192)   
(146)   
(113)   
(693)   
(528)   
(1,524)   

Present
value

$m

2,995 
2,061 
1,453 
1,079 
682 
5,275 
3,516 
11,786 

35 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 2022 (see Note 28). 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, seeking recovery of transfers 
from Madoff Securities to HSBC in an amount not specified, and these lawsuits remain pending in the US Bankruptcy Court for the Southern 
District of New York (the ‘US Bankruptcy Court’).

Certain Fairfield entities (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 August 2022, the US District Court for the 
Southern District of New York (the ‘New York District Court’) affirmed earlier decisions by the US Bankruptcy Court that dismissed the majority 
of the liquidators’ claims (against most of the HSBC companies). In September 2022, the remaining defendants before the US Bankruptcy Court 
sought leave to appeal and the liquidators filed appeals to the US Court of Appeals for the Second Circuit, which are currently pending. 
Meanwhile, proceedings before the US Bankruptcy Court with respect to the remaining claims 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. The claim has not yet been served and the amount claimed has not been specified.

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 monetary damages. Following dismissal of Primeo’s action by the lower and appellate courts in the Cayman 
Islands, in 2019, Primeo appealed to the UK Privy Council. During 2021, the UK Privy Council held two separate hearings in connection with 
Primeo’s appeal. 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 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. In December 2018, Senator brought additional claims against HSSL and HSBC Bank plc Luxembourg 
branch, seeking restitution of Senator’s securities or money damages. These matters are currently pending before the Luxembourg District 
Court.

HSBC Holdings plc Annual Report and Accounts 2022

405

Financial statements 
 
 
 
 
 
 
 
 
Notes on the financial statements

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. For several years thereafter, HSBC 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 determined that no further Skilled Person 
work is required. Separately, the Independent Consultant’s engagement is now complete and, in August 2022, the FRB terminated its cease-
and-desist order.

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. Nine actions remain pending in federal 
courts and HSBC’s motions to dismiss have been granted in five of these cases. In September 2022 and January 2023, respectively, the 
appellate courts affirmed the dismissals of two of the cases, and the plaintiffs’ requests for review of these decisions by the full appellate courts 
have been denied. The dismissals in the other cases are subject to appeal. The four remaining actions are at an early stage.

Based on the facts currently known, it is not practicable at this time for HSBC to predict the resolution of the pending 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, and the EC imposed a fine on HSBC based 
on a one-month infringement in 2007. The fine was annulled in 2019 and a lower fine was imposed in 2021. In January 2023, the European Court 
of Justice dismissed an appeal by HSBC and upheld the EC’s findings on HSBC’s liability. A separate appeal by HSBC concerning the amount of 
the fine remains pending before the General Court of the European Union.

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 federal and state laws, including antitrust and 
racketeering laws and the Commodity Exchange Act (‘US CEA’). 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.

Singapore interbank offered rate (‘Sibor’) and Singapore swap offer rate (‘SOR’): In 2016, The Hongkong and Shanghai Banking Corporation 
Limited and other panel banks were named as defendants in a putative class action filed in the New York District Court on behalf of persons who 
transacted in products related to the Sibor and SOR benchmark rates. The complaint alleged, among other things, misconduct related to these 
benchmark rates in violation of US antitrust, commodities and racketeering laws, and state law. 

In October 2021, The Hongkong and Shanghai Banking Corporation Limited reached a settlement-in-principle with the plaintiffs to resolve this 
action, the agreement for which was executed in May 2022. The court granted final approval of the settlement in November 2022.

Based on the facts currently known, it is not practicable at this time for HSBC to predict the resolution of the pending matters, including the 
timing or any possible impact on HSBC, which could be significant.
Foreign exchange-related investigations and litigation 

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, which remains ongoing. 

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 
N.A. (‘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 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. In 
December 2022, HSBC reached a settlement-in-principle with the plaintiffs to resolve these matters. The settlement remains subject to the 
negotiation of definitive documentation. Additionally, in January 2023, HSBC reached a settlement-in-principle with plaintiffs in Israel to resolve a 
class action lawsuit filed in the local courts alleging foreign exchange-related misconduct. The settlement remains subject to the negotiation of 
definitive documentation and court approval. Lawsuits alleging foreign exchange-related misconduct remain pending against HSBC and other 
banks in courts in Brazil. 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.

406

HSBC Holdings plc Annual Report and Accounts 2022

Precious metals fix-related litigation

Gold: Beginning in December 2015, numerous putative class actions 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, which were consolidated in the New York District Court, 
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. In February 2022, following the conclusion of pre-class 
certification discovery, the defendants filed a motion seeking to dismiss the plaintiffs’ antitrust claims, which remains pending.

In April 2016, two putative class actions 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 and related 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.
Film finance litigation

In June 2020, two separate investor groups issued claims against HSBC UK Bank plc (as successor to HSBC Private Bank (UK) Limited (‘PBGB‘)) 
in the High Court of England and Wales in connection with PBGB’s role in the development of Eclipse film finance 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. In October 2022, this claim was discontinued.

Based on the facts currently known, it is not practicable at this time for HSBC to predict the resolution of the pending matters, including the 
timing or any possible impact on HSBC, 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 (‘CFTC‘) regarding interest rate swap transactions related to bond 
issuances, among other things. HSBC has reached a settlement-in-principle with the CFTC’s Division of Enforcement to resolve this 
investigation. The settlement is subject to final approval by the CFTC;

investigations by the CFTC and US Securities and Exchange Commission (‘SEC‘) concerning compliance with records preservation 
requirements relating to the use of unapproved electronic messaging platforms for business communications. HSBC has reached 
settlements-in-principle with the CFTC’s and SEC’s Divisions of Enforcement to resolve these investigations. The settlements are subject to 
the negotiation of definitive documentation and final approval by the CFTC and SEC;

• 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 into potentially anti-competitive arrangements involving historical trading 

activities relating to certain UK-based fixed income products and related financial instruments;

• 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.

HSBC Holdings plc Annual Report and Accounts 2022

407

Financial statementsNotes on the financial statements

36 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 240 to 246 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 and Brand 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.
Key Management Personnel

Details of Directors’ remuneration and interests in shares are disclosed in the ‘Directors’ remuneration report’ on pages 276 to 301. 
IAS 24 ‘Related Party Disclosures’ requires the following additional information for key management compensation.

Compensation of Key Management Personnel

Short-term employee benefits 
Post-employment 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 held
At 31 Dec

2022
$m
52   
1   
8   
26   
87   

2021
$m
50   
—   
6   
27   
83   

2022
(000s)

35   
18,185   
228   
18,448   

2020
$m
39 
— 
5 
20 
64 

2021
(000s)
35 
13,529 
228 
13,792 

Advances and credits, guarantees and deposit balances during the year with Key Management Personnel

2022

2021

Key Management Personnel
Advances and credits1
Guarantees
Deposits

16   
—   
53   

Highest amounts
outstanding
during year

Balance at
31 Dec

Highest amounts
outstanding
during year

Balance at
31 Dec

$m

$m

25   
—   
123   

$m

373   
25   
284   

$m

401 
45 
3,190 

1  Advances and credits entered into by subsidiaries of HSBC Holdings plc during 2022 with Directors and former Directors, disclosed pursuant to section 
413 of the Companies Act 2006, totalled $2.5m (2021: $2.8m) and the total value of guarantees entered into on behalf of the Directors and former 
Directors was $nil (2021: $nil). 

Some of the transactions were connected transactions as defined by the Rules Governing The Listing of Securities on The Stock Exchange of 
Hong Kong Limited, but were exempt from any disclosure requirements under the provisions of those rules. The above transactions were made 
in the ordinary course of business and on substantially the same terms, including interest rates and security, as for comparable transactions with 
persons of a similar standing or, where applicable, with other employees. The transactions did not involve more than the normal risk of 
repayment or present other unfavourable features.
Associates and joint ventures

The Group provides certain banking and financial services to associates and joint ventures including loans, overdrafts, interest and non-interest 
bearing deposits and current accounts. Details of the interests in associates and joint ventures are given in Note 18.

Transactions and balances during the year with associates and joint ventures

Unsubordinated amounts due from joint ventures
Unsubordinated amounts due from associates
Amounts due to associates 
Amounts due to joint ventures
Fair value of derivative assets with associates 
Fair value of derivative liabilities with associates
Guarantees and commitments

408

HSBC Holdings plc Annual Report and Accounts 2022

2022

2021

Highest balance 
during the year

Balance at
31 Dec

Highest balance
during the year

Balance at
31 Dec

$m
140   
7,378   
2,548   
57   
1,205   
4,319   
513   

$m
90   
6,594   
1,295   
53   
841   
3,648   
293   

$m
160   
4,527   
3,397   
102   
936   
696   
1,016   

$m
96 
4,188 
1,070 
44 
465 
555 
347 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2022, $2.9bn (2021: $3.4bn) of HSBC post-employment benefit plan assets were under management by HSBC companies, 
earning management fees of $13m in 2022 (2021: $14m). At 31 December 2022, HSBC’s post-employment benefit plans had placed deposits of 
$369m (2021: $476m) with its banking subsidiaries, earning interest payable to the schemes of nil (2021: 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 2022, the gross notional value of the swaps was $6.6bn (2021: $7.4bn). These swaps had a 
positive fair value to the scheme of $0.5bn (2021: $1.0bn); and HSBC had delivered collateral of $0.5bn (2021: $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.
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

2022

2021

Highest balance
during the year

Balance at
31 Dec

Highest balance
during the year

$m

$m

$m

Balance at
31 Dec

$m

7,421   

3,210   

3,397   

2,590 

52,322   

5,380   
26,765   
4,893   
167,542   
264,323   

314   
8,318   
1,375   
900   
10,907   
17,707   

52,322   

3,801   
26,765   
4,803   
167,542   
258,443   

314   
6,922   
429   
900   
8,565   
17,707   

64,686   

4,187   
27,142   
1,555   
163,211   
264,178   

340   
2,872   
2,036   
900   
6,148   
16,477   

51,408 

2,811 
25,108 
1,135 
163,211 
246,263 

111 
1,220 
1,732 
900 
3,963 
13,746 

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.

37 Events after the balance sheet date
A second interim dividend for 2022 of $0.23 per ordinary share (a distribution of approximately $4,593m) was approved by the Directors after 
31 December 2022. HSBC Holdings called $2,350m 6.250% perpetual subordinated contingent convertible securities on 30 January 2023. The 
security is expected to be redeemed and be cancelled on 23 March 2023. HSBC Holdings also exercised the call option on AUD350m and 
AUD650m MREL on 13 January 2023 callable on 16 February 2023. The redemption took place on 16 February 2023. These accounts were 
approved by the Board of Directors on 21 February 2023 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 2022 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.

HSBC Holdings plc Annual Report and Accounts 2022

409

Financial statements 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes on the financial statements

Subsidiaries 

Subsidiaries

452 TALF Plus ABS Opportunities SPV LLC
452 TALF SPV LLC
Almacenadora Banpacifico S.A. (In 
Liquidation)
Assetfinance December (F) Limited

Assetfinance December (H) Limited
Assetfinance December (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
AXA Insurance Pte. Ltd.
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 L.P.
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 & Partners Asset Management Limited
CCF Holding (Liban) S.A.L. (In Liquidation)
Charterhouse Administrators (D.T.) Limited
Charterhouse Management Services Limited
Charterhouse Pensions Limited
Chongqing Dazu HSBC Rural Bank Company 
Limited

Chongqing Fengdu HSBC Rural Bank 
Company Limited
Chongqing Rongchang HSBC Rural Bank 
Company Limited

COIF Nominees Limited

Corsair IV Financial Services Capital Partners - 
B, LP

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.

% 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)

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

N/A

N/A

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

15

15

16

17

18

18

18

18

17

18

19

17

18

18

17

1, 20

18

21

22

22

23

0, 46

12, 24

0, 1, 25

18

18

26

15

15

27

18

28

18

18

18

12, 29

12, 30

12, 31

0, 18

0, 1, 32

12, 33

0, 34

4, 35

4, 35

16

1, 16

22

36

35

35

12, 37

38

11, 16

26

(99.99)

(99.99)
(99.99)

(99.99)

(99.99)
(99.99)

(99.99)
(99.99)

(62.14)
(99.99)

GPIF Co-Investment, LLC
Griffin International Limited
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 (In Liquidation)
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
HLF
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 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 (India) Private 
Limited

HSBC Asset Management (Japan) Limited

HSBC Assurances Vie (France)

HSBC Australia Holdings Pty Limited

HSBC BANK (CHILE)

HSBC Bank (China) Company Limited

N/A
100.00
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

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

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)

(99.99)

(99.99)

Footnotes

0, 15

18

16

12, 39

1, 12, 40

38

41

38

38

38

38

38

38

38

1, 42

38

38

38

38

43

12, 44

38

38

38

1, 38

38

45

38

35

1, 46

47

1, 46

1, 46

45

48

0, 1, 27

18

2, 79

22

49

49

20

50

18

49

15

51

18

2, 46

18

18

18

1, 18

52

53

54

55

56

12, 57

410

HSBC Holdings plc Annual Report and Accounts 2022

Subsidiaries

HSBC Bank (General Partner) Limited
HSBC Bank (Mauritius) Limited
HSBC Bank (RR) (Limited Liability Company)
HSBC Bank (Singapore) Limited
HSBC Bank (Taiwan) Limited
HSBC Bank (Uruguay) S.A.
HSBC Bank (Vietnam) Ltd.
HSBC Bank A.S.
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 
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

% of share class 
held by immediate 
parent company 
(or by the Group 
where this varies)

(99.99)

(99.99)

100.00
100.00
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

Footnotes

79

58

0, 13, 59

20

60

61

62

63

51

64

55

23

65

0, 79

0, 79

66

49

67

68

69

70

18

2, 18

71

17

21

46

46

46

46

46

46

72

0, 72

15

79

15

16

73

73

18

18

74

0, 15

35

49

46

2, 18

18

55

22

75

76

12, 77

78

79

80

Subsidiaries
HSBC Electronic Data Processing Lanka 
(Private) Limited

HSBC Electronic Data Service Delivery 
(Egypt) S.A.E.

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 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 (Malta) 
Limited
HSBC Global Asset Management (México), 
S.A. de C.V., Sociedad Operadora de Fondos 
de Inversión, Grupo Financiero HSBC

HSBC Global Asset Management (Singapore) 
Limited
HSBC Global Asset Management 
(Switzerland) AG

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

% 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
99.65
100.00

100.00

100.00

100.00

100.00

100.00

100.00

(99.99)

(99.99)

(99.99)

100.00

(70.03)

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
99.99

100.00
100.00

100.00
100.00

81

82

54

17

18

18

17

35

2, 18

15

18

83

18

1, 20

84

85

86

3, 23

65

87

54

46

88

16

20

4, 89

46

18

91

51

92

2, 18

18

1, 18

83

18

46

18

2, 18

1, 50

18

2, 18

18

18

HSBC Holdings plc Annual Report and Accounts 2022

411

Financial statementsNotes on the financial statements

% of share class 
held by immediate 
parent company 
(or by the Group 
where this varies)

Footnotes

Subsidiaries

% of share class 
held by immediate 
parent company 
(or by the Group 
where this varies)

Footnotes

Subsidiaries

HSBC Infrastructure Debt GP 1 S.à r.l.
HSBC Infrastructure Debt GP 2 S.à r.l.

HSBC Infrastructure Limited
HSBC Institutional Trust Services (Asia) 
HSBC Institutional Trust Services (Bermuda) 
Limited

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 Brokerage Company Limited

HSBC Insurance Brokers Greater China 
Limited

HSBC Insurance Holdings Limited
HSBC Insurance SAC 1 (Bermuda) Limited

HSBC Insurance SAC 2 (Bermuda) Limited
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 and Insurance Brokerage, 
Philippines Inc.

HSBC Investment Bank Holdings B.V.
HSBC Investment Bank Holdings Limited
HSBC Investment Company Limited
HSBC Investment Funds (Canada) Inc.

N/A
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
100.00

100.00
100.00
100.00

99.99

(99.98)

98.99

(98.98)

99.99

99.99

100.00
100.00
100.00
100.00

HSBC Investment Funds (Hong Kong) Limited

100.00

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 Life (Bermuda) Limited
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 (Workshop) Limited
HSBC Life Assurance (Malta) Limited
HSBC Life Insurance Company Limited

HSBC LU Nominees Limited
HSBC Management (Guernsey) Limited
HSBC Markets (USA) Inc.

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

(70.03)

0, 93

0, 93

18

46

23

94

20

95

46

23

20

91

1, 96

1, 46

2, 18

23

1, 23

18

97

98

20

99

56

52

52

50

52

100

18

18

2, 18

65

46

101

102

18

18

18

2, 18

46

23

95

95

23

95

95

18

1, 95

88

12, 57

18

103

15

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
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. (In Liquidation)
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 Investment Counsel (Canada) 
Inc.
HSBC Private Markets Management SARL

HSBC Private Trustee (Hong Kong) Limited

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 REGIO Fund General Partner S.à r.l.
HSBC REIM (France)
HSBC Retirement Benefits Trustee (UK) 
Limited
HSBC Retirement Services Limited
HSBC Saudi Arabia, Closed Joint Stock 
Company

HSBC Savings Bank (Philippines) Inc.
HSBC Securities (Canada) Inc.
HSBC Securities (Egypt) S.A.E. (In 
Liquidation)

HSBC Securities (Japan) Co., Ltd.

HSBC Securities (Japan) Limited

HSBC Securities (Singapore) Pte Limited

HSBC Securities (South Africa) (Pty) Limited
HSBC Securities (Taiwan) Corporation Limited

HSBC Securities (USA) Inc.

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
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

N/A

100.00

100.00

100.00

100.00
100.00

90.00

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

100.00

18

18

16

104

2, 68

0, 68

105

65

15

49

46

106

49

3, 15

87

2, 18

107

18

51

74

108

109

16

94

63

18

101

108

18

108

74

18

65

0, 110

46

50

18

18

46

12, 111

35

1, 93

54

1, 2, 18

1, 18

112

113

83

66

1, 53

18

20

114

60

15

(99.99)

(99.99)

(94.65)

412

HSBC Holdings plc Annual Report and Accounts 2022

Subsidiaries

HSBC Securities and Capital Markets (India) 
Private Limited

HSBC Securities Brokers (Asia) Limited
HSBC Securities Investments (Asia) Limited
HSBC Securities Services (Bermuda) Limited
HSBC Securities Services (Guernsey) Limited
HSBC Securities Services (Ireland) DAC

HSBC Securities Services (Luxembourg) S.A.
HSBC Securities Services Holdings (Ireland) 
DAC

HSBC Securities Services Nominees Limited
HSBC Seguros de Retiro (Argentina) S.A.
HSBC Seguros de Vida (Argentina) S.A.
HSBC Seguros, S.A de C.V., Grupo Financiero 
HSBC

HSBC Service Company Germany GmbH
HSBC Service Delivery (Polska) Sp. z o.o.

HSBC Services (France)
HSBC Services Japan Limited
HSBC Services USA Inc.
HSBC Servicios Financieros, S.A. de C.V

HSBC Servicios, S.A. DE C.V., Grupo 
Financiero HSBC

HSBC SFH (France)
HSBC SFT (C.I.) Limited
HSBC Software Development (Guangdong) 
Limited

HSBC Software Development (India) Private 
Limited

HSBC Software Development (Malaysia) Sdn 
Bhd

HSBC Specialist Investments Limited

HSBC Technology & Services (China) Limited
HSBC Technology & Services (USA) Inc.
HSBC Titan GmbH & Co. KG

HSBC Transaction Services GmbH

HSBC Trinkaus & Burkhardt (International) 
S.A.

HSBC Trinkaus & Burkhardt Gesellschaft fur 
Bankbeteiligungen mbH

HSBC Trinkhaus & Burkhardt GmbH
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 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 Covered Bonds LLP
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

% of share class 
held by immediate 
parent company 
(or by the Group 
where this varies)

Footnotes

Subsidiaries

99.99

100.00
100.00
100.00
100.00
100.00

100.00
100.00

100.00
100.00
100.00
100.00

100.00
100.00

100.00
100.00
100.00
100.00

100.00

100.00
100.00
100.00

100.00

100.00

100.00

100.00
100.00
100.00

100.00

100.00

50

46

46

23

22

109

101

109

1, 46

51

51

16

(99.99)
(99.99)
(99.99)

(99.99)

1, 87

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

(99.99)

100.00

(99.99)

100.00
100.00

(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
N/A
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00

(99.99)
(99.99)

(62.14)

115

35

92

116

16

16

4, 54

22

117

118

78

18

57

15

1, 87

6, 87

119

87

87

87

6, 87

6, 87

65

97

18

74

120

22

46

20

2, 17

17

0, 17

2, 18

107

15

75

1, 17

63

15

38

18

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 Bisa, S.A. de C.V.

Inmobiliaria Grufin, S.A. de C.V.

Inmobiliaria Guatusi, S.A. de C.V.

James Capel (Nominees) Limited

James Capel (Taiwan) Nominees Limited
John Lewis Financial Services Limited

Keyser Ullmann Limited
L&T Investment Management 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
Marks and Spencer Unit Trust Management 
Limited

Maxima S.A. AFJP (In Liquidation)
Midcorp Limited
Midland Bank (Branch Nominees) Limited
Midland Nominees Limited
MIL (Cayman) Limited
MP Payments Group Limited

MP Payments Operations Limited 

MP Payments UK Limited
MW Gestion SA
Prudential Client HSBC GIS Nominee (UK) 
PT Bank HSBC Indonesia
PT HSBC Sekuritas Indonesia
R/CLIP Corp.
Real Estate Collateral Management Company
Republic Nominees Limited
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 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

% of share class 
held by immediate 
parent company 
(or by the Group 
where this varies)

100.00

100.00

100.00

100.00

100.00
100.00

(62.14)
(99.99)

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
100.00

99.98
100.00
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
99.99
100.00
100.00
100.00
100.00
100.00

100.00
100.00
100.00

100.00
100.00
60.00
100.00

100.00
100.00
100.00

100.00
100.00
100.00
100.00

(99.99)

(99.99)

(99.99)
(99.99)

(98.93)

(99.99)
(99.99)
(99.99)

(99.99)

(59.99)
(99.99)

(99.99)
(99.99)
(99.99)

(99.99)

(99.99)

Footnotes

121

12, 122

123

12, 124

38

87

16

16

16

18

18

18

18

1, 52

46

1, 99

99

1, 46

46

125

125

51

18

17

17

73

1, 18

1, 18

1, 18

51

18

126

126

15

15

22

1, 18

1, 18

35

4, 35

4, 35

54

46

1, 12, 57

35

114

12, 127

1, 12, 128

129

11, 54

35

4, 35

4, 35

35

109

23

35

18

HSBC Holdings plc Annual Report and Accounts 2022

413

Financial statementsAssociates

The undertakings below are associates and equity accounted.

Associates

Bank of Communications Co., Ltd.
Barrowgate Limited
BGF Group PLC
Bud Financial Limited
Canara HSBC Life Insurance Company 
Limited

Contour Pte Ltd

Divido Financial Services Limited
Electronic Payment Services Company (Hong 
Kong) Limited

Episode Six Limited
EPS Company (Hong Kong) Limited
EURO Secured Notes Issuer
GZHS Research Co Ltd
HSBC Jintrust Fund Management Company 
Limited

Liquidity Match LLC
London Precious Metals Clearing Limited
MENA Infrastructure Fund (GP) Ltd
Monese Ltd
Quantexa Ltd
Services Epargne Entreprise
The London Gold Market Fixing Limited
The Saudi British Bank
Threadneedle Software Holdings Limited
Trade Information Network Limited

Trinkaus Europa Immobilien-Fonds Nr. 7 
Frankfurt Mertonviertel KG

Vizolution Limited

We Trade Innovation Designated Activity 
Company

% of share class 
held by 
immediate parent 
company (or by 
the Group where 
this varies)

19.03
15.31
24.61
5.36
26.00

12.65

5.56
38.66

7.02
38.66
16.67
20.50
49.00

N/A
30.00
33.33
5.39
10.10
14.18
25.00
31.00
6.56
16.67

N/A

17.95

9.88

Footnotes

136

137

138

1, 139

140

1, 141

1, 142

46

1, 143

46

144

145

57

0, 1, 146

1, 147

145

1, 149

131

150

134

152

1, 153

1, 154

0, 87

1, 155

1, 156

Notes on the financial statements

% of share class 
held by immediate 
parent company 
(or by the Group 
where this varies)

100.00

100.00

100.00

100.00

100.00
100.00
100.00
100.00

(99.99)

Footnotes

17

12, 57

18

5, 46

18

2, 18

130

87

100.00

(99.99)

6, 87

100.00

(99.99)

87

100.00

(99.99)

6, 87

100.00

(99.99)

6, 87

100.00

100.00
100.00
100.00
100.00

100.00

100.00

N/A

100.00

100.00

(99.99)

(99.99)

87

6, 87

73

17

35

46

46

0, 15

23

38

(99.99)

(62.14)

Subsidiaries

St Cross Trustees Limited

Sun Hung Kai Development (Lujiazui III) 
Limited

Swan National Limited

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

Wayfoong Nominees Limited

Westminster House, LLC

Woodex Limited

Yan Nin Development Company Limited

Joint ventures

The undertakings below are joint ventures and equity accounted.

Joint ventures

Climate Asset Management Limited

Global Payments Technology Mexico S.A. De 
C.V

HCM Holdings Limited (In Liquidation)
Pentagreen Capital Pte. Ltd

ProServe Bermuda Limited
The London Silver Market Fixing Limited
Vaultex UK Limited

% of share class 
held by 
immediate parent 
company (or by 
the Group where 
this varies)

40.00

50.00

50.99
50.00

50.00
N/A
50.00

Footnotes

1, 131

16

45

1, 132

133

0 1, 134

135

414

HSBC Holdings plc Annual Report and Accounts 2022

 
Footnotes for Note 38
Description of Shares
0

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).

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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

Non-Participating Voting Shares

Parts

Registered Capital Shares

Russian Limited Liability Company Shares

Stückaktien

Registered offices
15

c/o The Corporation Trust Company 1209 Orange Street, 
Wilmington, Delaware, United States of America, 19801

Paseo de la Reforma 347 Col. Cuauhtemoc, Mexico, 06500

1 Centenary Square, Birmingham, United Kingdom, B1 1HQ

8 Canada Square, London, United Kingdom, E14 5HQ

5 Donegal Square South, Northern Ireland, Belfast, United 
Kingdom, BT1 5JP

10 Marina Boulevard #48-01 Marina Bay Financial Centre, 
Singapore, 018983

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

First Floor, Xinhua Bookstore Xindong Road (SE of roundabout), 
Miyun District, Beijing, China

Oak House Hirzel Street, St Peter Port, Guernsey, GY1 2NP

2929 Walden Avenue, Depew, New York, United States of 

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

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

160 Mine Lake CT, Ste 200, Raleigh, North Carolina, United 
States Of America, 27615-6417

38 avenue Kléber, Paris, France, 75116

16

17
18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

MMG Tower, 23 floor Ave. Paseo del Mar Urbanizacion Costa del 
Este, Panama

72

Registered offices
37

No. 1 1211 Yanjiang Zhong Road, Yongan, Fujian, China

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

83 Des Voeux Road Central, Hong Kong

No.44 Xin Ping Road Central, Encheng, Enping, Guangdong, 
China, 529400

Room 311, Cheng Hui No. 2, Nan Sha Street, Nan Sha District, 
Guangzhou, Guangdong, China

34/F, 36/F, Unit 031 of 45/F, and 46/F, Hang Seng Bank Tower, 
1000 Lujiazui Ring Road, Pilot Free Trade Zone, Shanghai, China, 
200120

Gustav Mahlerplein 2 1082 MA, Amsterdam, Netherlands

8/F, Prince’s Building, 10 Chater Road, Central, Hong Kong

1001, T2 Office Building, Qianhai Kerry Business Center, Qianhai 
Avenue, Nanshan Street, Qianhai Shenzhen-Hong Kong 
Cooperation Zone, Shenzhen, Guangdong, China

156 Great Charles Street, Queensway, Birmingham, West 
Midlands, United Kingdom, B3 3HN

1 Queen’s Road, Central, Hong Kong

Commerce House, Wickhams Cay 1, P.O. Box 3140, Road Town, 
Tortola, British Virgin Islands, VG1110

The Corporation Trust Company of Nevada 311 S. Division 
Street, Carson City, Nevada, United States of America, 89703

Menara IQ, Lingkaran TRX, Tun Razak Exchange, Kuala Lumpur, 
Malaysia, 55188

52/60 M G Road Fort, Mumbai, India, 400 001

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

HSBC Building 11-1, Nihonbashi 3-chome, Chuo-ku, Tokyo, 
Japan, 103-0027

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

IconEbene, Level 5 Office 1 (West Wing), Rue de L’institut, 
Ebene, Mauritius

2 Paveletskaya Square Building 2, Moscow, Russian Federation, 
115054

54F, 7 Xinyi Road Sec. 5, Xinyi District, Taipei, Taiwan

1266 Dr Luis Bonativa, 1266 Piso 30 (Torre IV WTC), 
Montevideo, Uruguay, CP 11.000

The Metropolitan, 235 Dong Khoi Street, District 1, Ho Chi Minh 
City, Viet Nam

Esentepe mah. Büyükdere Caddesi No.128, Istanbul, Türkiye, 
34394

66 Teryan Street, Yerevan, Armenia, 0009

885 West Georgia Street, 3rd Floor, Vancouver, British Columbia, 
Canada, V6C 3E9

306 Corniche El Nil, Maadi, Egypt, 11728

116 Archbishop Street, Valletta, Malta

401, Level 4 Gate Precinct Building 2, Dubai International 
Financial Centre, P.O. Box 30444, Dubai, United Arab Emirates

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

HSBC Holdings plc Annual Report and Accounts 2022

415

Financial statements 
Notes on the financial statements

Registered offices
73

P.O. Box 1109, Strathvale House, Ground Floor, 90 North Church 
Street , George Town, Grand Cayman, Cayman Islands, 
KY1-1102

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

100

101

102

103

104

105

106

107

108

109

HSBC House Esplanade, St. Helier, Jersey, JE1 1HS

c/o Rogers Capital St. Louis Business Centre, Cnr Desroches & 
St Louis Streets, Port Louis, Mauritius

49 avenue J.F. Kennedy, Luxembourg, 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

Filinvest One Building, Northgate Cyberzone, Filinvest Corporate 
City, Alabang, Muntinlupa City, Philippines

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, Shanghai, 
China

Hansaallee 3, Düsseldorf, Germany, 40549

80 Mill Street, Qormi, Malta, QRM 3101

26 Gartenstrasse, Zurich, Switzerland, 8002

24th Floor, 97-99, Sec.2, Tunhwa S. Road, Taipei, Taiwan

452 Fifth Avenue, New York, United States of America, NY10018

Mareva House, 4 George Street, Nassau, Bahamas

4 rue Peternelchen, Howald, Luxembourg, 2370

6th floor HSBC Centre 18, Cybercity, Ebene, Mauritius, 72201

18th Floor, Tower 1, HSBC Centre, 1 Sham Mong Road, 
Kowloon, Hong Kong

Unit 201 Floor 2, Building 3, No. 12, Anxiang Street, Shunyi 
District, Beijing, China

300 Delaware Avenue, Suite 1401, Wilmington, Delaware, 
United States of America, 19801

Woodbourne Hall, Road Town, Tortola, British Virgin Islands, P.O. 
Box 916

PO Box 71, Craigmuir Chambers, Road Town Tortola, British 
Virgin Islands

5/F HSBC Centre 3058 Fifth Ave West, Bonifacio Global City, 
Taguig City, Philippines

18 Boulevard de Kockelscheuer, Luxembourg, 1821

21 Farncombe Road Worthing, United Kingdom, BN11 2BW

Arnold House, St Julians Avenue, St Peter Port, Guernsey, GY1 
1WA

345-6791, HSBC Tower, Burj Khalifa Community, Dubai, United 
Arab Emirates

Office No.16, Owned by HSBC Bank Middle East Limited, Dubai 
Branch, Bur Dubai, Burj Khalifa, Dubai, United Arab Emirates

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, 
21093

Quai des Bergues 9-17, Geneva, Switzerland, 1201

1 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, 
D02 P820

416

HSBC Holdings plc Annual Report and Accounts 2022

Registered offices
110

5 rue Heienhaff, Senningerberg, Luxembourg, 1736

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

136

137

138

139

140

141

142

143

144

145

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, 1780

1 Mutual Place, 107 Rivonia Road, Sandton, Gauteng, South 
Africa, 2196

Kapelanka 42A , Krakow, Poland, 30-347

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

Business Bay, Wing 2, Tower B, Survey no 103, Hissa no. 2, 
Airport road, Yerwada, Pune, India, 411006

16 Boulevard d’Avranches, Luxembourg, Luxembourg, L-1160

P.O. Box 309 Ugland House, Grand Cayman, Cayman Islands, 
KY1-1104

No. 56 Yu Rong Street, Macheng, China, 438300

No. 205 Lie Shan Road Suizhou, Hubei, China

Building 3, Yin Zuo Di Jing Wan Tianmen New City, Tianmen, 
Hubei Province, China

RM101, 102 & 106 Sunshine Fairview, Sunshine Garden, 
Pedestrian Walkway, Pingjiang, China

Kings Meadow Chester Business Park , Chester, United 
Kingdom, CH99 9FB

World Trade Center 1, Jalan Jenderal Sudirman Kavling 29 - 31, 
Jakarta, Indonesia, 12920

No. 198-2 Chengshan Avenue (E), Rongcheng, China, 264300

Room 1303-13062 Marine Center Main Tower, 59 Linhai Road, 
Nanshan District, Shenzhen, China

Woodbourne Hall, Road Town, Tortola, British Virgin Islands, P.O. 
Box 3162

25 Main St. P.O. Box 694, Grand Cayman KY1 1107, Cayman 
Islands, KY1 1107

Hill House, 1 Little New Street, London , United Kingdom, EC4A 
3TR

60B Orchard Road #06-18, The Atrium @Orchard, Singapore, 
238891

c/o MUFG Fund Services (Bermuda) Limited, Cedar House, 4th 
Floor North, 41 Cedar Avenue, Hamilton, Bermuda, HM 12

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 

50/F, Lee Garden One, 33 Hysan Avenue, Hong Kong

13-15 York Buildings, London, United Kingdom, WC2N 6JU

Linen Court, Floor 3, 10 East Road, London, United Kingdom, N1 
6AD

Unit No. 208, 2nd Floor, Kanchenjunga Building 18, Barakhamba 
Road, New Delhi, India, 110001

50 Raffles Place, #32-01 Singapore Land Tower, Singapore, 
048623

Office 7, 35-37 Ludgate Hill, London, United Kingdom, EC4M 
7JN

100 Town Square Place, Suite 201, Jersey City, New Jersey, 
United States Of America, 07310

7th Floor, 62 Threadneedle Street, London, United Kingdom, 
EC2R 8HP

Precinct Building 4, Level 3, Dubai International Financial Centre, 
Dubai, United Arab Emirates, PO Box 506553

Registered offices
146

9/F Amtel Building, 148 des Voeux Road Central, Central, Hong 
Kong

147

148

149

150

151

152

153

154

155

156

3 Avenue de l’Opera , Paris, France, 75001

Room 1303, 106 Feng Ze Dong Road, Nansha District, 
Guangzhou, Guangdong, China

Eagle House, 163 City Road, London, United Kingdom, EC1V 
1NR

32 rue du Champ de Tir, Nantes, France, 44300

Ernst-Schneider-Platz 1 , Duesseldorf, Germany, 40212

Al Amir Abdulaziz Ibn Mossaad Ibn Jalawi Street, Riyadh, Saudi 
Arabia

2nd Floor, Regis House, 45 King William Street, London, United 
Kingdom, EC4R 9AN

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, DO2 T380

HSBC Holdings plc Annual Report and Accounts 2022

417

Financial statementsAdditional information

Shareholder information

Contents

418

418

418

418

419

419

420

Second Interim dividend for 2022

Interim dividends for 2023

Other equity instruments

2022 Annual General Meeting

Earnings releases and interim results

Shareholder enquiries and communications

Stock symbols

Investor relations

420
420 Where more information about HSBC is available
421

Taxation of shares and dividends

422

424

426

427

Approach to ESG reporting

Cautionary statement regarding forward-looking statements

Certain defined terms

Abbreviations

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 2022
The Directors have approved a second interim dividend for 2022 of $0.23 per ordinary share. Information on the currencies in which 
shareholders may elect to have the cash dividend paid will be sent to shareholders on or about 24 March 2023. 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 2022 and/or Strategic Report 2022
Final date for dividend election changes including 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

21 February 2023
2 March 2023
3 March 2023
24 March 2023

13 April 2023

17 April 2023
27 April 2023

1 Removals to and from the Overseas Branch register of shareholders in Hong Kong will not be permitted on this date.

Interim dividends for 2023
For the financial year 2022, we achieved a dividend payout ratio within our 2022 target range of between 40% and 55% of reported earnings per 
ordinary share (‘EPS’). As previously communicated, given our current returns trajectory, we are establishing a dividend payout ratio of 50% of 
reported earnings per share for 2023 and 2024, excluding material significant items (including the planned sale of our retail banking operations in 
France and the planned sale of our banking business in Canada). The Group intends to revert to paying quarterly dividends from the first quarter 
of 2023. The dividend policy has the flexibility to adjust EPS for material 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 approved 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 32 on the financial statements. 

HSBC issued no new perpetual contingent convertible securities during 2022.  

2022 Annual General Meeting
With the exception of the shareholder requisitioned Resolution 19, which the Board recommended that shareholders vote against, and 
resolution 17(b), which the Board withdrew from the agenda of the 2022 Annual General Meeting (‘AGM‘), all resolutions considered at the 
2022 AGM held at 11:00am on 29 April 2022 at Queen Elizabeth Hall, Southbank Centre, Belvedere Road, London SE1 8XX, UK were passed on 
a poll.

418

HSBC Holdings plc Annual Report and Accounts 2022

 
Earnings releases and interim results
First and third quarter results for 2023 will be released on 2 May 2023 and 30 October 2023, respectively. The interim results for the six months 
to 30 June 2023 will be issued on 1 August 2023.   

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
The Pavilions
Bridgwater Road
Bristol BS99 6ZZ
United Kingdom
Telephone: +44 (0) 370 702 0137
Email via website: 
www.investorcentre.co.uk/contactus

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

Investor Relations Team
HSBC Bank Bermuda Limited
37 Front Street
Hamilton HM 11
Bermuda
Telephone: +1 441 299 6737
Email: hbbm.shareholder.services@hsbc.bm

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
P.O. Box 43006
Providence RI 02940-3078
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 2022 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.

HSBC Holdings plc Annual Report and Accounts 2022

419

Additional information 
 
Additional information

Chinese translation

A Chinese translation of the Annual Report and Accounts 2022 will be available upon request after 24 March 2023 from the Registrars:

Computershare Hong Kong Investor Services Limited
Rooms 1712-1716, 17th Floor 
Hopewell Centre 
183 Queen’s Road East
Hong Kong

Computershare Investor Services PLC
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.

《2022 年報及賬目》備有中譯本,各界人士可於2023年3月24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

HSBA*
5

New York Stock Exchange (ADS)
Bermuda Stock Exchange

HSBC
HSBC.BH

Investor relations
Enquiries relating to HSBC’s strategy or operations may be directed to:

Richard O’Connor, Global Head of Investor Relations
HSBC Holdings plc
8 Canada Square
London E14 5HQ
United Kingdom
Telephone: +44 (0) 20 7991 6590
Email: investorrelations@hsbc.com

Mark Phin, Head of Investor Relations, Asia-Pacific
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
The Annual Report and Accounts 2022 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 2022 by 
31 December 2023. This information will be available on HSBC’s website: www.hsbc.com/tax.

420

HSBC Holdings plc Annual Report and Accounts 2022

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 2022 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 8.75% 
for basic rate taxpayers, 33.75% for higher rate taxpayers and 39.35% 
for additional rate taxpayers. 

UK resident companies 

Shareholders that are within the charge to UK corporation tax should 
generally be entitled to an exemption from UK corporation tax on any 
dividends received from HSBC Holdings. However, the exemptions 
are not comprehensive and are subject to anti-avoidance rules.

If the conditions for exemption are not met or cease to be satisfied, or 
a shareholder within the charge to UK corporation tax elects for an 
otherwise exempt dividend to be taxable, the shareholder will be 
subject to UK corporation tax on dividends received from HSBC 
Holdings at the rate of corporation tax applicable to that shareholder.  

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 have 
been applied to a disposal of those shares in December 2017. If in 
doubt, shareholders are recommended to consult their professional 
advisers.

Stamp duty and stamp duty reserve tax

Transfers of shares by a written instrument of transfer generally will 
be subject to UK stamp duty at the rate of 0.5% of the consideration 
paid for the transfer (rounded up to the next £5), and such stamp duty 
is generally payable by the transferee. An agreement to transfer 
shares, or any interest therein, normally will 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 
2022 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. 

HSBC Holdings plc Annual Report and Accounts 2022

421

Additional informationAdditional information

Based on the company’s audited financial statements and relevant 
market and shareholder data, HSBC Holdings does not believe that it 
was a passive investment company for its 2022 taxable year and does 
not anticipate becoming a passive foreign investment company in 
2023 or the foreseeable future. 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.

422

HSBC Holdings plc Annual Report and Accounts 2022

Approach to ESG reporting
The information set out in the ESG review on pages 43 to 96, taken 
together with other information relating to ESG issues included in this 
Annual Report and Accounts 2022, aims to provide key ESG 
information and data relevant to our operations for the year ended 
31 December 2022. The data is compiled for the financial year 
1 January to 31 December 2022 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 62.

• A2.4 on sourcing water issue and water efficiency target: Taking 

into account the nature of our business, we do not consider this to 
be a material issue for 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, 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 45 
for further information on how we determine what matters are 
material to our stakeholders.

TCFD recommendations and recommended 
disclosures

As noted on page 17, 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 2022 
save for certain items, which we describe below:

Targets setting 

Metrics and targets (c) relating to short-term targets: For financed 
emissions we do not plan to set 2025 targets. We set targets in line 
with the Net-Zero Banking Alliance (‘NZBA‘) guidelines by setting 
2030 targets. While the NZBA define 2030 as intermediate, we use 
different time horizons for climate risk management. We define short 
term as time periods up to 2025; medium term is between 2026 and 
2035; and long term is between 2036 and 2050. These time periods 
align to the Climate Action 100+ disclosure framework. In 2022, we 
disclose interim 2030 targets for on-balance sheet financed emissions 
for eight sectors as we outline on page 18. For the shipping sector, 
we chose to defer setting a baseline and target until there is sufficient 
reliable data to support our work, allowing us to more accurately track 
progress towards net zero. We have chosen to defer setting targets 
for facilitated emissions until the PCAF standard for capital markets is 
published, which is expected in the first half of 2023. We aim to 
update our targets and baselines to include both on- and off-balance 
sheet activities following the publication of the industry standard for 
capital markets methodology by PCAF. We intend to review the 
financed emissions baselines and targets annually, where relevant, to 
help ensure that they are aligned with market practice and current 
climate science. 

Metrics and targets (c) relating to capital deployment target: We do 
not currently disclose a target for capital deployment. In relation to 
capital deployment, since 2015, we have issued more than $2bn of 
our own green bonds and structured green bonds with the capital 
invested into a variety of green projects, including: green buildings, 
renewable energy and clean transportation projects. In 2022, we are 
internally reviewing and enhancing the green bond framework, with 
further refinement to be undertaken in 2023. Our continued 
monitoring of evolving taxonomies and practices over time could 
result in revisions in our reporting going forward and lead to 
differences year-on-year as compared with prior years. See the 
HSBC’s Green Bond Report for further information. 

Metrics and targets (c) relating to internal carbon prices: We do not 
currently disclose internal carbon prices due to transitional challenges 
such as developing the appropriate systems and processes, but we 
considered carbon prices as an input for our climate scenario analysis 
exercise. We expect to further enhance the disclosure in the medium 
term as more data becomes available.

Impacts on financial planning and performance

Strategy (b) relating to financial planning and performance: We have 
used climate scenarios to inform our organisation’s business, strategy 
and financial planning. In 2022, we incorporated certain aspects of 
sustainable finance and financed emissions within our financial 
planning process. We do not currently fully disclose the impacts of 
climate-related issues on financial planning, and particularly the impact 
of climate-related issues on our financial performance (for example, 
revenue and costs) and financial position (for example, assets and 
liabilities), in each case due to lack of data and systems for compiling 
the relevant financial impact. We expect to further enhance the 
disclosure in the medium term as more data becomes available.

Strategy (b) related to transition plan: We do not currently disclose our 
transition plan. We have committed to publish our own Group-wide 
net zero transition plan in 2023. This plan will bring together our 
climate strategy, science-based targets, and how we plan to embed 
this into our processes, policies, governance and capabilities. It will 
outline, in one place, not only our commitments, targets and approach 
to net zero across the sectors and markets we serve, but how we are 
transforming our organisation to embed net zero and finance the 
transition. 

Metrics and targets (a) relating to internal carbon prices and climate-
related opportunities metrics: We do not currently disclose internal 
carbon price targets due to transitional challenges such as data 
challenges. But we considered carbon prices as an input for our 
climate scenario analysis exercise. In addition, we do not currently 
fully disclose the proportion of revenue or proportion of assets, capital 
deployment or other business activities aligned with climate-related 
opportunities, including revenue from products and services designed 
for a low-carbon economy, forward-looking metrics consistent with 
our business or strategic planning time horizons. In relation to 
sustainable finance revenue and assets we are disclosing certain 
elements. We expect the data and system limitations related to 
financial planning and performance, and climate-related opportunities 
metrics to be addressed in the medium term as more reliable data 
becomes available and technology solutions are implemented. We 
expect to further enhance the disclosure in the medium term.

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. In 2022, we have disclosed 
the impairment impacts for our wholesale, retail and commercial real 
estate portfolios in different climate scenarios. In addition, we have 
disclosed losses on our retail mortgage book under three scenarios 
and flood depths for specific markets. For our wholesale book we 
have disclosed potential implications on our expected credit losses for 
11 sectors under three scenarios. We have also disclosed a heat map 
showing how we expect the risks to evolve over time. 

Metrics and targets (a) relating to detailed climate-related risk 
exposure metrics for physical and transition risks: We do not fully 
disclose metrics used to assess the impact of climate-related physical 
(chronic) and transitions (policy and legal, technology, market) 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). We disclose the exposure to 
six high risk wholesale sectors and the flood risk exposure and Energy 
Performance Certificate breakdown for the UK portfolio. We are 
aiming to develop the appropriate systems, data and processes to 
provide these disclosures in future years. 

Metrics and targets (c) on targets related to physical risk: We do not 
currently disclose targets used to measure and manage physical risk. 
This is due to transitional challenges including data limitations of 
physical risk metrics. For retail, this is because we do not use targets 
to measure and manage physical risk. Instead we have developed 
exposure monitoring metrics and risk appetite where appropriate to 
measure and manage physical risk. We also considered physical risk 
as an input for our climate scenario analysis exercise.

We expect to further enhance the disclosure in medium term 
considering the data limitations related to quantitative scenario 
analysis, specific risk metrics and physical risk targets to be 
addressed, more reliable data becoming available, and technology 
solutions 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, supply chain and financed emissions. In relation to 
financed emissions, we published on-balance sheet financed 
emissions for six sectors as detailed on page 18. Future disclosure on 
financed emissions, and related risks is reliant on our customers 
publicly disclosing their carbon emissions and related risks. We aim to 
disclose financed emissions for additional sectors in our Annual 
Report and Accounts 2023 and related disclosures. Our approach to 
disclosure of financed emissions for additional sectors can be found 
at: www.hsbc.com/who-we-are/esg-and-responsible-business/esg-
reporting-centre.

HSBC Holdings plc Annual Report and Accounts 2022

423

Additional informationAdditional information

Other matters

Strategy (b) relating to acquisitions/divestments: We have considered 
the impact of climate-related issues on our businesses, strategy, and 
financial planning, but not specifically in relation to acquisitions/
divestments. 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 in the medium term.

Strategy (b) relating to access to capital: We have considered the 
impact of climate-related issues on our businesses, strategy, and 
financial planning. Our access to capital may be impacted by 
reputational concerns as a result of climate action or inaction. In 
addition, if we are perceived to mislead stakeholders on our business 
activities or if we fail to achieve our stated net zero ambitions, we 
could face reputational damage, impacting our revenue generating 
ability and potentially our access to capital markets. We expect to 
further enhance the disclosure in the medium term as more data 
becomes available.

To manage these risks we have integrated climate risk into our 
existing risk taxonomy, and incorporated it within the risk 
management framework through the policies and controls for the 
existing risks where appropriate. 

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 45 for further information. 
Cautionary statement regarding 
forward-looking statements
The Annual Report and Accounts 2022 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:

424

HSBC Holdings plc Annual Report and Accounts 2022

• changes in general economic conditions in the markets in which 
we operate, such as new, continuing or deepening recessions, 
prolonged inflationary pressures and fluctuations in employment 
and creditworthy customers beyond those factored into 
consensus forecasts (including, without limitation, as a result of 
the Russia-Ukraine war and, to a lesser extent, the Covid-19 
pandemic); the Russia-Ukraine war and the Covid-19 pandemic and 
their impact on global economies and the markets where HSBC 
operates, which could have a material adverse effect on (among 
other things) 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 Russia-Ukraine war, inflationary pressures and 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 the Russia-Ukraine war (including the 
continuation and escalation thereof) and the related imposition of 
sanctions and trade restrictions, supply chain restrictions and 
disruptions, sustained increases in energy prices and key 
commodities, claims of human rights violations, 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 
adversely affect HSBC 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, and in supporting 
the global transition to net zero carbon emissions, 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, including in relation to the 
effectiveness of its Ibor remediation strategy, 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 impact of the Russia-
Ukraine war on inflation and 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, which continues to be characterised by 
uncertainty and political disagreement, particularly with respect to 

the regulation of financial services, despite the signing of the 
Trade and Cooperation Agreement between the UK and the EU; 
changes in UK macroeconomic and fiscal policy as a result of the 
change in UK government leadership, which may result in 
fluctuations in the value of the pound sterling; 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 energy policy 
and our targets to reduce our on-balance sheet financed emissions 
in eight high-emitting 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 high inflationary pressures, rising interest rates and 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; the 
accuracy and effective use of data, including internal management 
information that may not have been independently verified, 
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 high-emitting sectors portfolio and the commitments set forth 
in our thermal coal phase-out policy and our energy 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 135 to 142. 

Additional cautionary statement 
regarding ESG and climate-related 
data, metrics and forward-looking 
statements
The Annual Report and Accounts 2022 contains a number of forward-
looking statements (as defined above) with respect to HSBC’s ESG 
targets, commitments, ambitions, climate-related scenarios or 
pathways and the methodologies we use to assess our progress in 
relation to these (‘ESG-related forward-looking statements’).

In preparing the ESG-related information contained in the Annual 
Report and Accounts 2022, HSBC has made a number of key 
judgements, estimations and assumptions, and the processes and 
issues involved are complex. We have used ESG and climate data, 
models and methodologies that we consider, as of the date on which 
they were used, to be appropriate and suitable to understand and 
assess climate change risk and its impact, to analyse financed 
emissions - and operational and supply chain emissions, to set ESG-
related targets and to evaluate the classification of sustainable finance 
and investments. However, these data, models and methodologies 
are new, are rapidly evolving and are not of the same standard as 
those available in the context of other financial information, nor are 
they subject to the same or equivalent disclosure standards, historical 
reference points, benchmarks or globally accepted accounting 
principles. In particular, it is not possible to rely on historical data as a 
strong indicator of future trajectories, in the case of climate change 
and its evolution. Outputs of models, processed data and 
methodologies are also likely to be affected by underlying data quality, 
which can be hard to assess and we expect industry guidance, 
market practice, and regulations in this field to continue to change.  In 
light of the highly uncertain nature of the evolution of climate change 
and its impact, HSBC may have to re-evaluate its progress towards its 
ESG ambitions, commitments and targets in the future, update the 
methodologies it uses or alter its approach to ESG and climate 
analysis and may be required to amend, update and recalculate its 
ESG disclosures and assessments in the future, as market practice 
and data quality and availability develops rapidly. The ESG-related 
forward-looking statements and metrics discussed in the Annual 
Report and Accounts 2022 therefore carry an additional degree of 
inherent risk and uncertainty.  

No assurance can be given by or on behalf of the Group as to the 
likelihood of the achievement or reasonableness of any projections, 
estimates, forecasts, targets, commitments, ambitions, prospects or 
returns contained herein. Readers are cautioned that a number of 
factors, both external and those specific to HSBC, could cause actual 
achievements, results, performance or other future events or 
conditions to differ, in some cases materially, from those stated, 
implied and/or reflected in any ESG-related forward-looking 
statements or metrics due to a variety of risks, uncertainties and 
other factors (including without limitation those referred to below):

• Climate change projection risk: this includes, for example, the 
evolution of climate change and its impacts, changes in the 
scientific assessment of climate change impacts, transition 
pathways and future risk exposure and limitations of climate 
scenario forecasts; 

• Changes in the ESG regulatory landscape: this involves changes in 
government approach and regulatory treatment in relation to ESG 
disclosures and reporting requirements, and the current lack of a 
single standardised regulatory approach to ESG across all sectors 
and markets;  

• Variation in reporting standards: ESG reporting standards are still 
developing and are not standardised or comparable across all 
sectors and markets, new reporting standards in relation to 
different ESG metrics are still emerging;   

• Data availability, accuracy, verifiability and data gaps: our 

disclosures are limited by the availability of high quality data 
needed to calculate financed emissions. Where data is not 
available for all sectors or consistently year on year, there may be 
an impact to our data quality scores. Whilst we expect our data 
quality scores to improve over time, as companies continue to 

HSBC Holdings plc Annual Report and Accounts 2022

425

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.

Additional information

expand their disclosures to meet growing regulatory and 
stakeholder expectations, there may be unexpected fluctuations 
within sectors year on year, and/or differences between the data 
quality scores between sectors.  Any such changes in the 
availability and quality of data over time could result in revisions to 
reported data going forward, including on financed emissions, 
meaning that such data may not be reconcilable or comparable 
year-on year;

• Developing methodologies: the methodologies HSBC uses to 
assess financed emissions and set ESG-related targets may 
develop over time in line with market practice, regulation and/or 
developments in science, where applicable. Any such 
developments in methodologies could result in revisions to 
reported data going forward, including on financed emissions or 
the classification of sustainable finance and investments, meaning 
that data outputs may not be reconcilable or comparable year-on 
year. In addition, climate scenarios and the models that analyse 
them have limitations that are sensitive to key assumptions and 
parameters, which are themselves subject to some uncertainty, 
and cannot fully capture all of the potential effects of climate, 
policy and technology driven outcomes; and

• Risk management capabilities: governments’, customers’, and 
HSBC’s actions may not be effective in supporting the global 
transition to net zero carbon emissions and in managing and 
mitigating ESG risks, including 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 to 
HBSC. In particular:

– we may not be able to achieve our ESG targets, commitments 
and ambitions (including with respect to the commitments set 
forth in our thermal coal phase-out policy, our energy policy and 
our targets to reduce our on-balance sheet financed emissions 
in our portfolio of selected high-emitting sectors), which may 
result in our failure to achieve any of the expected benefits of 
our strategic priorities; and

– we may not be able 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 may diminish (including as a result of 
data and model limitations and changes in methodologies), 
which may affect our ability to achieve our climate ambition, 
our targets to reduce our on-balance sheet financed emissions 
in our portfolio of selected high-emitting sectors and the 
commitments set forth in our thermal coal phase-out policy and 
energy policy, and increase the risk of greenwashing. 

HSBC makes no commitment to revise or update any ESG forward-
looking statements to reflect events or circumstances occurring or 
existing after the date of any ESG forward-looking statements. 
Written and/or oral ESG-related forward-looking statements may also 
be made in our 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.

Our data dictionaries and methodologies for preparing the above ESG-
related metrics and third-party limited assurance reports can be found 
on: www.hsbc.com/who-we-are/ esg-and-responsible-business/esg-
reportingcentre. 

426

HSBC Holdings plc Annual Report and Accounts 2022

Abbreviations

Currencies

£
CA$
€
HK$
MXN
RMB
SGD
$

A

ABS¹
ADR
ADS
AGM
AI
AIEA
ALCO
AML
AML DPA

AT1

B

Basel 
Committee
Basel II¹
Basel III¹

Basel 3.1

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

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
Five-year deferred prosecution agreement with the US 
Department of Justice, entered into in December 2012

Additional tier 1

Basel Committee on Banking Supervision

2006 Basel Capital Accord
Basel Committee’s reforms to strengthen global capital and 
liquidity rules
Outstanding measures to be implemented from the Basel 
III reforms

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 Sponsoring Organizations 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

Days past due
Discretionary participation feature of insurance and 
investment contracts

Debit valuation adjustment

Exposure at default

DPD
DPF

DVA¹

E

EAD¹

EBA
EC
ECB
ECL

EEA
Eonia
EPC
EPS
ESG
EU
Euribor
EVE

F

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

FAST-Infra

Finance to Accelerate the Sustainable Transition-
Infrastructure

FCA
FFVA

FPA
FRB
FRC
FSCS
FTE
FTSE
FVOCI¹
FX

G

GAAP
GAC
GBM
GDP
GEC
GMP
GPS

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 Services Compensation Scheme
Full-time equivalent staff
Financial Times Stock Exchange index
Fair value through other comprehensive income
Foreign exchange

Generally accepted accounting principles
Group Audit Committee
Global Banking and Markets, a global business
Gross domestic product
Group Executive Committee
Guaranteed minimum pension
Global Payments Solutions, the business formerly known as 
Global Liquidity and Cash Management

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
The Stock Exchange of Hong Kong Limited
HKEx
Hong Kong Monetary Authority
HKMA
HM Revenue and Customs
HMRC
HNAH
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
High-quality liquid assets
HSBC Holdings together with its subsidiary undertakings
HSBC
HSBC Bank plc HSBC Bank plc, also known as the non-ring-fenced bank
HSBC Bank 
Middle East

HSBC Bank Middle East Limited

HSBC Bank 
USA
HSBC Canada

HSBC 
Continental 
Europe
HSBC Finance

HSBC Bank USA, N.A., HSBC’s retail bank in the US

The sub-group, HSBC Bank Canada, HSBC Trust Company 
Canada, HSBC Mortgage Corporation Canada and HSBC 
Securities Canada, consolidated for liquidity purposes
HSBC Continental Europe

HSBC Finance 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 UK

HSBC Private Bank (Suisse) SA, HSBC’s private bank in 
Switzerland

HSBC UK Bank plc, also known as the ring-fenced bank

HSBC Holdings plc Annual Report and Accounts 2022

427

Additional informationAdditional information

HSBC USA

HSI
HSSL
HTIE

I

IAS
IASB
Ibor
ICAAP
ICMA
IEA
IFRSs
ILAAP
IMA
IMM
IRB¹
ISDA

J

JV

K

KMP

L

LCR
LGBTQ+

LGD¹
Libor
Long term

LTI
LTV¹

M

Mainland China

Medium term

MENA
MREL
MRT¹
MSS

N

Net operating 
income

NGO
NII
NIM
NPS
NSFR
NYSE
NZBA

O

OCI
OECD
OTC¹

P

PBT
PCAF

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
Interbank offered rate
Internal capital adequacy assessment process
International Capital Market Association
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, transgender and queer. 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

People’s Republic of China excluding Hong Kong and 
Macau
For our strategic goals, we define medium term as three to 
five years, commencing 1 January 2020
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 before change in expected credit 
losses and other credit impairment charges/Loan 
impairment charges and other credit provisions, also 
referred to as revenue

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

Profit before tax
Partnership for Carbon Accounting Financials

428

HSBC Holdings plc Annual Report and Accounts 2022

PD¹
Performance 
shares¹

Ping An

POCI
PRA
PRC
Principal plan
PVIF

PwC

R

RAS
Repo¹
Reverse repo
RFR
RMM
RNIV
RoE
RoTE
RWA¹

S

SABB
SAPS
SASB
SBTi
SDG
SEC
ServCo group

Sibor
SIC
SICR
SME
SOFR
Solitaire

Sonia
SPE¹

T

TCFD¹
THBFIX
TNFD
TSR¹

U

UAE
UK
UN
US

V

VaR¹
VIU

W

WEF
WPB

Probability of default
Awards of HSBC Holdings ordinary shares under employee 
share plans that are subject to corporate performance 
conditions

Ping An Insurance (Group) Company of China, Ltd, the 
second-largest life insurer in the PRC
Purchased or originated credit-impaired financial assets
Prudential Regulation Authority (UK)
People’s Republic of China
HSBC Bank (UK) Pension Scheme
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
Security purchased under commitments to sell
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)
Separately incorporated group of service companies 
established in response to UK ring-fencing requirements

Singapore interbank offered rate
Securities investment conduit
Significant increase in credit risk
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 2022 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
P.O. Box 43006
Providence RI 02940-3078
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 2023

All rights reserved 

No part of this publication may be reproduced, stored in a retrieval 
system, or transmitted, in any form or by any means, electronic, 
mechanical, photocopying, recording, or otherwise, without the prior 
written permission of HSBC Holdings plc

Published by Global Finance, HSBC Holdings plc, London 

Designed by Superunion, London (Strategic Report and ESG review) 
and by Global Finance with Superunion (rest of Annual Report and 
Accounts)

Printed by Park Communications Limited, London, on Nautilus 
SuperWhite board and paper using vegetable oil-based inks. Made in 
Austria, the stocks comprise 100% de-inked post-consumer waste. 
Pulps used are totally chlorine-free.  

The FSC® recycled logo identifies a paper that contains 100% post-
consumer recycled fibre certified in accordance with the rules of the 
Forest Stewardship Council®. 

HSBC Holdings plc Annual Report and Accounts 2022

429

Additional information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

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