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IntegraFin Holdings

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FY2017 Annual Report · IntegraFin Holdings
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ANNUAL REPORT 
AND FINANCIAL 
STATEMENTS

YEAR ENDED 
30 SEPTEMBER 2017

IntegraFin Holdings Limited

Company registration
number: 08860879

CONTENTS

Strategic Report

Financial Statements

Chairman’s Statement  . . . . . . . . . . . . . . . . . . 2

Independent Auditor’s Report  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Chief Executive Officer’s Review  . . . . 4

Consolidated Profit and Loss and Other Comprehensive Income  . . . . . . . . . . . . . . . . 46

Transact at a Glance  . . . . . . . . . . . . . . . . . . . . . 6

Company Profit and Loss and Other Comprehensive Income  . . . . . . . . . . . . . . . . . . . . . 47

About Transact  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Consolidated Statement of Financial Position  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

Our Marketplace  . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Company Statement of Financial Position  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Our Business Model  . . . . . . . . . . . . . . . . . . . . . . 9

Consolidated Statement of Cash Flows  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

Strategic Priorities and Progress  . . . . 9

Company Statement of Cash Flows  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Operating and Financial Review  . . . 10

Consolidated Statement of Changes in Equity  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Risk and Risk Management . . . . . . . . . . 19

Company Statement of Changes in Equity  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Principal Risks and Uncertainties  . . 24

Notes to the Financial Statements  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Corporate Social Responsibility  . . . . 27

Other Information

Governance

Directors, Company Details, Advisers  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

Board of Directors  . . . . . . . . . . . . . . . . . . . . . . 28

Glossary of Terms  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

Corporate Governance Report  . . . . . . 31

Audit Committee Report  . . . . . . . . . . . . . . 33

Directors’ Remuneration Report  . . . 36

Risk Committee Report  . . . . . . . . . . . . . . . 37

Directors’ Report  . . . . . . . . . . . . . . . . . . . . . . . . 41

Statement of Directors’  

Responsibilities  . . . . . . . . . . . . . . . . . . . . . . . . . . 42

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    1

STRATEGIC REPORT

Michael Howard
Chairman

CHAIRMAN’S 
STATEMENT

Dear Shareholders,

Welcome to the annual report of 
your company for 2017, another 
financial year that has been kind to us. 
My friend and colleague, Ian Taylor, 
provides further information on the 
year elsewhere in his report but, 
suffice for me to say, your company 
has had an excellent profit outcome.

Since 2000, wrap services, or platforms 
as they are often called, like ours, 
have transformed the financial 
services landscape because they 
represent, quite simply, a better 
proposition than the “old way”. 
Diversified investment together with 
consolidated administration has made 
financial planning easier and more 
effective for advisers and for their 
clients. Financial advisers are thriving 
in this reconfigured environment,  
and we thrive with them.

Current indicators point to continuing 
bright prospects for your company 
due to the accumulation of investors’ 
annual savings, plus the literally 
trillions of pounds still retained in 
“old fashioned” investments that are 
moving onto platforms. This latter 
process looks set to continue for 
many years to come.

As well as our usual business 
operations, this has been another 
year of getting ready to list  
our company on the London  
Stock Exchange. So far, matters  
are progressing as we would  
hope, and we continue to be 
optimistic that conditions remain 
favourable and we plan to list in the  
first half of 2018.

As part of our preparation, and 
in line with corporate governance 
best practice for listed companies, 
changes have been made to 
IntegraFin Holdings Limited 
(IntegraFin), Integrated Financial 
Arrangements Ltd (IFAL), IntegraLife 
UK Limited (ILUK) and IntegraLife 
International Limited (ILInt) 
Board members.

On 1 October 2017, I stood  
down from the chairmanship 
of IntegraFin, as well as the 
chairmanship and Boards of IFAL  
and ILUK and the Board of ILInt.  
I remain as a Director of IntegraFin.

On 1 October 2017, Patrick Snowball 
took up the reins as Non-Executive 
Chairman of IntegraFin and IFAL.  
Patrick has an impeccable 
background in financial services 
having been the CEO of Aviva UK 
from 2005 to 2007 and from 2009 
to 2015, the CEO of the ASX 100, 
financial services giant, Suncorp.

2    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Finally, and most importantly,  
I would like to take this opportunity 
to thank all those involved in 
making our business, and our 
year, successful. This includes our 
customers, our business partners 
and, of course, our staff and 
Directors. Without the support  
of all of these groups, we would  
have no business.

May our 2018 year deliver all that  
we hope for it.

Michael Howard 
Chairman for financial year 2017

12 December 2017

I welcome him as a most valuable 
addition to our merry band and thank 
him for agreeing to join us.

On 1 October 2017, the chairmanship 
of ILUK was taken up by Neil Holden. 
Neil has been a Director of the Group 
since 2011.

I wish them all well in their new roles.

While Jeremy Brettell, Stuart Bazley 
and Judith Davidson each stepped 
down from the IntegraFin Board  
on 1 October 2017, they continue 
to be Directors of IFAL, plying their 
skills on behalf of the Group, where 
most needed.

Finally, on matters directorial, we have 
made the Board of IntegraFin more 
compact. In the past, IntegraFin  
and IFAL have had identical boards. 
We did this to avoid making too many 
changes at once. In fact, the role  
of IntegraFin, the holding company,  
is to direct the strategy and oversee 
the execution of its operating 
subsidiaries. It is the subsidiaries 
that do the actual work involved  
in providing Transact. 

The IntegraFin Board now comprises 
Patrick Snowball, Ian Taylor, 
Alexander Scott, Neil Holden, 
Christopher Munro and myself.  
We believe this representation better 
reflects the particular needs of each 
of the Group companies.

Penultimately, to the matter always 
of interest to shareholders – your 
company’s dividend. Based on 
our 2017 profit and our policy of 
distributing 65% of what we have 
earned, post tax, we will be paying 
an interim dividend to shareholders 
of £19.42 million, according to our 
usual schedule, in January, 2018.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    3

 
STRATEGIC REPORT 
continued

Ian Taylor 
Chief Executive Officer

CEO REVIEW

Headlines

By many measures, the year to  
30 September 2017 was one of our 
most rewarding so far.

Gross inflows of £5.31 billion were 
48.6% higher than last year and  
net inflows were 66% higher.  
We ended the year with 151,000 
clients (+13%) and funds under 
direction of £27.9 billion (+13.5%)1.

This, combined with sensible 
control of expenses, means that 
we are pleased to report that profits 
after tax increased by 43% to 
£29.9 million.

The market background

The year was a busy one for the  
UK investment platform industry. 
Many platforms saw substantial 
uplifts in new business and Platforum 
estimates that funds under 
direction across the advised platform 
sector grew from £405 billion 
(September 2016) to £488 billion 
(September 2017). 

Not all platforms were winners, 
however, and it seems, to this  
observer at least, that advisers  
are concentrating flows of business 
ever more to those platforms  
that are seen to be significant  
players now and, more importantly, 
into the future.

There was also some consolidation  
of platform ownership during the year 
and more evidence of the potential 
for technology costs to become very 
substantial indeed for those platforms 
who outsource this key component. 

Our activity

Alongside the daily provision of 
Transact, a number of developments 
took place during the year. 

Most notably, in July 2016 we bought 
Integrated Application Development 
Pty Ltd from Michael Howard and 
its other owners. This was the 
final step in our longer term plan 
to bring entirely within the Group 
the ownership and control of the 
technology upon which we rely  
so heavily. This continues to 
contribute to profits and will 
stand us in good stead as we 
prepare for listing.

We also continued to support the 
implementation of financial 
planning by developing new 
functionality, enjoyed by advisers 
and by their clients. In particular 
Transact was the only adviser 
platform to introduce a Lifetime ISA 
wrapper when legislation changed.

1  Platform assets experienced a one off drop in April 2017 following the account closure 

of a single private client for which we were charging a nominal fee for custody.

4    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

In April we made further adjustments 
to some of our prices. We have  
an established record of sharing 
some of our profits with our 
customers when circumstances 
permit. We do this when we are 
comfortable that doing so will have 
no negative impact on service levels 
or revenues. We call this ‘responsible 
pricing’ and it means that the best 
service in the platform market 
becomes even better value.

During the course of the year  
we won awards from Moneyfacts 
(Best Wrap/Platform), Professional 
Adviser (Best Platform for Advisers 
– AUA above £15bn), Professional 
Paraplanner (Best Overall Service 
for New Business), Money Marketing 
(Best Platform) and FT Adviser 
(Investment Innovation and  
Five Star Investment). Transact was 
rated the best adviser platform in 
adviser surveys run by CoreData, 
Investment Trends and Platforum.

The outlook

The closing months of 2017 and the 
early months of 2018 will involve 
us in a great deal of work driven by 
changes in regulation and legislation. 
From Europe we have the second 
Markets in Financial Instruments 
Directive (MiFID II) and the General 
Data Protection Regulation (GDPR), 
and from the FCA the investment 
platform market study. 

Nevertheless, there is no reason to 
think that the natural flow of business 
from old world administration and 
custody to new world administration 
and custody should slow down – and 
we will benefit from this.

Our plan is simple – we will continue 
to drive organic growth and to 
provide the best adviser platform  
in the UK. 

Ian Taylor 
Chief Executive Officer

12 December 2017

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    5

STRATEGIC REPORT  continued

Transact is only marketed in the UK 
and is designed specifically to meet 
the needs of UK financial advisers 
and their clients. 

TRANSACT AT A GLANCE

About IntegraFin

IntegraFin Holdings Limited 
(IntegraFin) is the holding company 
for all of the entities involved in the 
provision of the Transact service.  
Our corporate structure as at  
30 September 2017 is shown below:

INTEGRAFIN CORPORATE STRUCTURE

lntegraFin Holdings Limited

Integrated Financial 
Arrangements Ltd

lntegraFin Services  
Limited 

Transact IP Ltd

Integrated Application 
Development Pty Ltd

ObjectMastery (UK) 
Limited

Transact Nominees  
Limited

IntegraLife UK  
Limited

IntegraLife International 
Limited

Transact Trustees  
Limited

6    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

How we operate

Transact provides a market leading 
platform infrastructure for advisers 
and their clients to make the 
implementation and management 
of client portfolios as simple and 
efficient as possible. Our leading 
investment platform functionality 
is supported by a high-touch 
client service team which provides 

extensive day-to-day and technical 
support no matter how simple or 
complex a query may be. 

As an independent platform we 
provide access to a wide range of tax 
wrappers and investment products. 
There are currently over 8,000 funds 
available on Transact and we can 
provide access to any asset listed  
on a major stock market.

INTEGRAFIN PROPOSITION

Advice 
fees

151k Clients

Financial 
planning and 
advice

5k Advisers

3k Adviser Firms

Services and 
platform 
functionality

Platform 
fees

Statements

Instant 
portfolio 
valuations

On-line 
access

Proprietary Platform Functionality

Asset  
custody

Transaction  
processing

Adviser  
fees

Portfolio  
monitoring

Reporting  
tools

Wide Range of Wrappers 

ISAs

GIAs

Pensions

Onshore bonds

Offshore bonds

Open Investment Architecture

~ 8,125  
Funds

~ 350  
ITs

~ 850 
ETFs

~ 3,100  
Stocks

~ 425  
Gilts

~ 100  
VCTs

Cash

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    7

 
STRATEGIC REPORT  continued

The rapid growth of the sector has 
occurred because the platform 
proposition is extremely attractive to 
both clients and advisers. Ultimately, 
platforms provide clients with greater 
control over their investments as they 
offer the visibility and convenience 
of having all tax wrappers and a 
wide range of investments, held and 
managed in one place, and at a lower 
price than the pre-platform era.

Transact has over 151,000 clients 
across the UK managed by over 
5,000 fi nancial advisers.

£488.76bn - Sept 2017

Our marketplace

Transact was the fi rst investment 
platform service to launch in 
the UK back in 2000, providing 
a revolutionary solution for 
fee based fi nancial advisers. 
Since then other providers have 
continued to enter the market and 
the UK platform sector has grown 
rapidly and now totals £488.76 
billion of assets (Platforum, Issue 
32, November 2017).

UK PLATFORM MARKET GROWTH
XXX

£500bn

£400bn

£300bn

£200bn

£100bn

£0

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

Financial year (end)

D
T
Y

7
1
0
2

Award-winning service

TRANSACT ADVISER RATINGS

Category: 
Large Platforms 
(> £12bn FUD)

Category: 
Large Platforms 
(> £10bn FUD)

Category: 
Large Platforms 
(> £10bn FUD)

We have become renowned for 
high quality service. The results of 
independent research studies stand 
testament to this as Transact has 
consistently been rated by advisory 
professionals as the top platform 
year on year in both the Investment 
Trends and CoreData quantitative 
research studies (2010 to 2017 
inclusive), and consistently performs 
strongly in Platforum quarterly and 
annual surveys.

This year we also completed our 
second annual client survey, the 
results of which were extremely 
positive with 98% of respondents 
saying that they would recommend 
Transact to others.

2017

2016

2015

2014

8    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

 
Our business model

A key aspect of our proposition 
is the control we have over every 
aspect of what we do. We do not 
outsource any material component 
of our service or technology and 
this gives us total control over 
the quality and cost of our whole 
operation. We also set our own 
priorities when deciding on the 
service enhancements we make 
and the frequency with which  
we make them. 

The main components of our 
proposition are:

Control of our systems development 
is crucial to our business model as 
it enables our Client Service teams 
to operate effectively. We design our 
systems and processes around the 
needs of financial advisers and their 
clients and regularly consult with them 
to ensure our solutions are appropriate. 

Similarly, our Client Service teams 
receive extensive training through 
our internal training programmes 
and have been instrumental in our 
success and the many accolades  
and awards Transact has received 
over the years. 

Systems 
Technology 

▪ Proprietary software systems technology.

▪ Full control of the client experience.

▪  We set our own priorities and control management  

of associated costs.

▪ We react quickly to client and industry demands.

Operations

▪  High-touch client service team of over 160 of our  

own staff.

▪  The teams cover our entire proposition and are not 

product centric. This means that the adviser and client 
experience is highly efficient.

▪  This also enables us to build strong adviser 

relationships.

Manufacturer 
of Wrappers

▪ We provide a wide range of tax efficient wrappers.

▪ First B2B platform to introduce the Lifetime ISA.

We do not own any financial advice 
firms. We are proud to have  
long-standing relationships with 
many firms across the UK and 
currently work with over 5,000 
advisers who have independently 
selected Transact for their clients. 

We receive all of our income from  
the fees paid by clients via our 
platform. Our Board and Senior 
Management Team are confident  
that the business model we operate 
is truly sustainable as over 85%  
of revenue is of a recurring nature.

Strategic priorities and progress

Our focus for the coming year will be 
to make continuous improvements  
to maintain our reputation as  
a premium service provider and  
a leading platform within the market.

We continue to see a strong uptake  
in advisers choosing our platform, 
with more registering with Transact 
each month. 

This year has presented new legal 
and regulatory challenges for the 
platform industry. These include 
MiFID II and GDPR, both coming 
into effect in 2018. We are on track 
to meet our obligations and have 
been providing support to advisers, 
where appropriate, in helping them 
to meet theirs. 

We continue to monitor government 
announcements regarding the 
savings and investment tax regime 
and are ready to respond accordingly 
to any changes in the provisions of 
pensions and ISAs in particular.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    9

STRATEGIC REPORT  continued

OPERATING AND  
FINANCIAL REVIEW

It has been a year of significant net 
inflow growth which together with 
good market performance has led 
to strong growth in funds under 
direction (FUD).

Year ended 30 September  
Funds under direction (FUD) 

2017 
£m

2016 
£m

Opening fee generating FUD

Inflows

Outflows

Net Inflows
Market and other movements2

Closing fee generating FUD
Other FUD3

Total Closing FUD

Average fee generating FUD

22,686

5,310

(1,647)

3,663

1,578

27,927

1

27,928

25,307

18,027

3,574

(1,378)

2,196

2,463

22,686

1,914

24,600

20,357

Total gross inflows for the financial 
year to 30 September 2017  
increased by £1.74 billion, or 
48.6% to £5.31 billion from £3.57 
billion, averaging £442 million per 
month, whilst a far smaller increase 
in the level of gross outflows saw 
a significant increase in net new 
inflows on the prior year, totalling 
£3.66 billion, an increase of 66.8%. 
The 2017 financial year has seen 
the Group experience its highest 
total gross inflows since inception. 
This growth, coupled with good 
market performance has led to fee 
generating funds under direction 
increasing by 23.1% to £27.9 billion 
at 30 September 2017.

During the year the majority of 
other FUD was removed from the 
platform as the Group continues to 
make preparations towards an IPO.

INTEGRAFIN GROUP – TOTAL FUD

)
£
(
D
U
F

30bn

25bn

20bn

15bn

10bn

5bn

0bn

19.1

17.9

FY15

24.6

22.7

27.9

FY16
Financial year (end)

FY17

Fee generating FUD

Other FUD3

INTEGRAFIN GROUP – NET & GROSS FEE GENERATING INFLOWS

)
£
(

s
w
o
F

l

6.0bn

5.0bn

4.0bn

3.0bn

2.0bn

1.0bn

0.0bn

5.31

3.37

3.57

3.66

2.04

2.20

FY15

FY16
Financial year (end)

FY17

Net Flows

Gross Inflows 

2 Other movements includes dividends, interest, fees and tax charges and rebates.

3  FUD held on behalf of a single private client for which the only charge was a nominal  

fee for custody. Other FUD is being removed from the platform with no material impact 

on revenue. 

10    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

 
 
Maintaining strong relationships with 
both advisers and clients already 
using Transact is as important to the 
continuing growth of the business 
as bringing new advisers to the 
platform. As at 30 September 2017 
over 68% of registered advisers 
recommending Transact had been 
using the platform for over five 
years. At the year end the number 
of registered advisers with funds on 
the platform averaging greater than 
£1,000 had increased to over 5,000. 

Both advisers with long standing 
relationships, and new advisers,  
bring new clients and new money  
to Transact. With our focus on 
premium service delivering strong 
client retention, and attracting 
new clients, this has seen our total 
number of clients increase by 13%  
to 151,000 from 137,000.  
This has led to continuing growth  
in the number of open tax wrappers, 
increasing by 10% over the year.

INTEGRAFIN – TOTAL NUMBER OF CLIENTS

128k

137k

151k

s
t
n
e

i
l

C

f
o

r
e
b
m
u
N

175k

150k

125k

100k

75k

50k

25k
0

FY15

FY16
Financial year (end)

FY17

INTEGRAFIN – TOTAL NUMBER OF WRAPPERS
AT THE END OF THE YEAR

s
r
e
p
p
a
r
w

f
o

r
e
b
m
u
N

300k

290k

280k

270k

260k

250k

240k

230k

220k

247k

FY15

294k

266k

FY16
Financial year (end)

FY17

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    11

 
 
 
 
STRATEGIC REPORT  continued

Financial performance

Income  
for the financial year ended 30 September

Revenue

Cost of Sales

Gross Profit

Operating Expenses

Operating Profit attributable  
to shareholder returns

Interest Income

Profit before tax attributable  
to shareholder returns

Tax on ordinary activities

Profit after tax

2017 
£m

80.2

(0.6)

79.6

(42.8)

36.8

0.2

37.0

(7.1)

29.9

2016 
£m

68.4

(0.5)

67.9

(42.1)

25.8

0.4

26.2

(5.4)

20.8

Total gross profit in the financial year 
to 30 September 2017 increased 
by £11.7 million, or 17.2%, to 
£79.6 million from £67.9 million. 
This growth has been driven by the 
increase in value of funds under 

direction, which has resulted from 
strong new inflow growth and 
good market growth together with 
an increase in the number of tax 
wrappers held on the platform.

Components of Revenue  
for the financial year ended 30 September

Annual Commission Income

Wrapper Fee Income

Other Income

Total Revenue

2017 
£m

69.5

7.3

3.4

80.2

2016 
£m

58.9

6.5

3.0

68.4

Revenue comprises three elements, 
of these annual commission income 
and wrapper fee income constitute 
the recurring revenue. Other income 
includes ‘buy commission’ and 
‘dealing income’.

12    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

These recurring revenue streams 
constituted 95.8% (2016: 95.8%)  
of total fee income.

Other income, including transactional 
revenue, increased by £0.4 million,  
or 13.3%, to £3.4 million in the 
financial year ended 30 September 
2017. This was due to an increase in 
the number of transactions, and the 
average value of those transactions.

Annual commission income increased 
by £10.6 million, or 18.0%,  
to £69.5 million in the financial  
year ended 30 September 2017.  
This growth was due to the increased 
value of FUD arising from strong new 
inflow growth, and market growth. 
This increase in annual commission 
income has been achieved even 
after allowing for the reduction in 
the annual commission rate charge 
effective from 1 April 2017.

Wrapper administration fee income 
increased by £0.8 million, or 12.3%, 
to £7.3 million in the financial year 
ended 30 September 2017. This was 
due to an increase in the number 
of clients on the platform with open 
tax wrappers and new tax wrappers 
opened in the year by clients already 
using Transact at the start of the 
financial year. This has been offset  
by wrappers being closed.

INTEGRAFIN – REVENUE

e
u
n
e
v
e
R

£80m

£70m

£60m

£50m

£40m

£30m

£20m

£10m

£0m

53.9

58.9

69.5

3.8 5.9

FY15

6.5

3.0

FY16
Financial year (end)

7.3

3.4

FY17

Other Income

Wrapper Fee

Annual Commission

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    13

2017 
£m

30.5

3.5

4.5

3.7

42.2

0.6

42.8

2016 
£m

25.5

3.2

4.6

6.9

40.2

1.9

42.1

Depreciation and amortisation costs 
decreased by £1.3 million, or 68.4%, 
to £0.6 million compared to  
£1.9 million in the prior financial year.  
This decrease was due to the 
amortisation of the platform 
intellectual property ceasing in July 
2016, resulting in a cost reduction 
of £1.3 million. Depreciation charges 
increased marginally in the year 
due to the fixed assets brought into 
account on the acquisition of IAD.

Total capitalised expenditure for 
the financial year was £0.4 million 
compared with £1.5 million in 
the prior year. This was mainly 
attributable to our policy of replacing 
information technology hardware on 
a regular cycle with a small amount 
also spent on office refurbishment.

STRATEGIC REPORT  continued

Operating Expenses  
for the financial year ended 30 September

Staff Costs

Occupancy

Regulatory and Professional Fees

Other Costs

Total Expenses

Depreciation and Amortisation

Total Operating Expenses

Total operating expenses increased 
by £0.7 million, or 1.7%, to £42.8 million 
in the financial year ended 30 September 
2017 compared to £42.1 million in 
the financial year ended 30 September 
2016. This increase was due to 
general inflation of staff costs, a small 
increase in staff numbers, in part 
offset by a reduction from the full 
year effect of the acquisition of IAD 
and subsequent Group reorganisation.

Staff costs increased by £5.0 million, 
or 19.6%, to £30.5 million in the 
financial year ended 30 September 
2017 compared to £25.5 million in the 
financial year ended 30 September 
2016. There are several factors 
affecting staff costs in this period. 
This is the first full year following the 
acquisition of IAD, our development 
company, in July 2016, which added 
65 staff to the Group. This acquisition 
reduced other costs by £2.4 million. 
We believe this acquisition will generate 
a long-term benefit for the Group, 
bringing experience and capability in 
house, giving us full control over our 
platform offering and software costs.

The average number of staff employed 
by the Group increased from 442 to 
451 over the financial year, reflective 
of the increase in business volumes 
and our commitment to maintaining 
premium service. There were general 
inflation increases in staff costs as 
well as a budgeted increase in the 
percentage of salary paid by the 
Group to the staff money purchase 
pension arrangement.

14    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Profit before tax attributable to 
shareholder returns

Over the course of the year we have 
continued to invest in our infrastructure 
and people, delivering award-winning 
service to our advisers and clients, 
whilst also implementing charge 
reductions that have lowered the costs 
to our clients. This has been achieved 
whilst also increasing our operating 
margin from 37.8% to 45.9%.

Profit before tax increased  
by £10.8 million, or 41.2%,  
to £37.0 million in the financial year 
ended 30 September 2017 compared 
to £26.2 million in the prior financial 
year. This is reflective of our strong 
operating performance delivering 
significant inflow growth and  
expense control.

As required by IFPRU 9.1.3, 
IntegraFin’s consolidated net return 
on assets, calculated as net profit 
divided by total balance sheet is 29% 
in 2017 (2016: 24%).

Tax

Tax on ordinary activities described 
below comprises solely the Group’s 
‘shareholder corporation tax’ which  
is distinguished from the ‘policyholder 
tax’ that the Group collects and 
remits to HMRC in respect of ILUK, 
which is taxed under the “I minus E” 
tax regime.

Whilst the Group has operations in 
three tax jurisdictions, UK, Australia 
and Isle of Man, Group profits are 
therefore varyingly subject to tax 
at three different rates, the vast 
majority of the Group’s income is 
earned in the UK.

Taxation increased by £1.7 million,  
or 35.6%, to £7.1 million in the 
financial year ended 30 September 
2017 compared to £5.4 million  
in the prior financial year. Due to  
a reduction in the UK standard rate  
of corporation tax, effective from  
1 April 2017, the effective rate  
of tax over the period reduced to 
19.2% from 20.2%. Our tax strategy 
is published on our website at  
www.integrafin.co.uk. 

Earnings continue to show growth, 
increasing by 43% from £18.41 per 
share to £26.39 per share, for the  
A, B and C shares, demonstrating the 
continuing strength of the business 
and reflecting the strong performance 
over the year.

Earnings per share  
for the financial year ended 30 September

Operating Profit attributable  
to shareholder returns

Interest Income

Profit before tax attributable  
to shareholder returns

Tax on ordinary activities

Profit after tax

Ordinary A, B, C shares – earnings per 
share (Pounds per share)

Ordinary D shares – earnings per share 
(Pounds per share)

2017 
£m

36.8

0.2

37.0

(7.1)

29.9

26.39

22.39

2016 
£m

25.7

0.5

26.2

(5.4)

20.8

18.41

14.41

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    15

STRATEGIC REPORT  continued

INTEGRAFIN – PROFIT BEFORE TAX

T
B
P

£40M

£35M

£30M

£25M

£20M

£15M

£10M

£5M

£0M

£36.98m

£20.32m

£26.20m

FY15

FY16
Financial year (end)

FY17

INTEGRAFIN – EARNINGS PER SHARE

S
P
E

£30

£25

£20

£15

£10

£5

£0

£14.50

£10.50

£18.41

£14.41

£26.39

£22.39

FY15

FY16
Financial year (end)

FY17

EPS A,B,C

EPS D

Liquidity and Capital Management

The Group monitors its liquidity 
position on a regular basis, having 
cognisance to cash and cash 
equivalent holdings and levels of 
outgoings. At 30 September 2017 
the Group held £105.8 million cash 
and cash equivalents compared with 
£90.6 million at 30 September 2016.

Cash is used to expand the business 
through: continued organic growth, 
paying the operating expenses of 
the business; further enhancing the 
premium service; further developing 
the resilience of the Group’s systems 
through investment in technology 
and infrastructure; and paying 
shareholder dividends.

There are three regulated entities 
within the Group, a UK investment 
firm and two life insurance companies, 
one in the UK and one in the  
Isle of Man. Each regulated entity is 
required to maintain a minimum level 
of regulatory capital. Cash is chosen 
as the main deployment of regulatory 
capital required by the regulated 
subsidiaries. The regulatory capital 
for insurance companies under the 
Solvency II regime is based on a 
modelled stressed value-in-force 
concept for the business, rather than 
on the accounting concept of capital. 
The solvency requirements for  
Isle of Man insurance companies  
are due to change with effect from  
30 June 2018.

16    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Regulatory Capital  
for the financial year  
ended 30 September 2017

IFAL

ILUK

ILInt (Current requirement)

ILInt (Estimate based on proposed new rules)

Regulatory 
Capital 
Requirement 
£m

Allowable 
Capital 
Resource 
£m

14.2

134.9

4.1

17.5

34.7

154.0

13.5

31.9

The table above details the regulatory capital requirement for each of the 

Regulated Subsidiaries.

Consolidated Capital  
for the financial year ended 30 September 2017

Shareholder funds

Goodwill, intangibles and other deductibles

Available capital pre dividend

Dividend provision

Available capital post dividend

Estimated capital for regulatory capital 
requirements4

Estimated surplus

£m

102.5

(16.8)

85.7

19.4

66.3

38.4

27.9

Note that for the purpose of this estimate, ILUK’s capital has been taken using 
the accounting concept of capital, rather than on a Solvency II basis.

The Board considers the impact of prospective dividends on its regulatory 
capital requirements and risk appetite levels. Our Pillar 3 document contains 
further details and can be found on our website at www.integrafin.co.uk

Dividend  
for the financial year ended 30 September

Total ordinary dividend

Dividend pounds per A, B and  
C class shares

Dividend pounds per D class share

2017 
£

19.4m

17.18

13.18

2016 
£

13.5m

12.00

8.00

4  Estimated capital required to cover regulatory capital requirements  

takes consideration of COREP, Solvency II and Isle of Man life insurance  
capital requirements.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    17

 
STRATEGIC REPORT  continued

The strategy and business plan is 
approved annually by the Board and 
updated as appropriate. It considers 
the Group’s profitability, cash flows, 
capital requirements, dividend 
payments, and other key variables 
such as liquidity and the solvency 
requirements of the regulated 
entities. These are considered under 
stress and scenario tests to ensure 
the business has sufficient flexibility 
to withstand such impacts by 
adjusting its plans within the normal 
course of business.

Viability Statement

The Directors have assessed the 
Company’s prospects by reference 
to the three-year planning period 
to September 2020, and have 
reasonable expectation that the 
Company will continue to operate  
and meet its liabilities as they fall due 
over the period of this assessment.

The Directors’ assessment has been 
made with consideration and reference 
to: the Group’s current position and 
business plan; the Group’s risk appetite; 
the Group’s financial projections;  
and the Group’s principal risks and 
uncertainties, as detailed in the 
Strategic Report. 

It is the Board’s view that a three 
year time horizon is an appropriate 
period over which to assess its viability 
and prospects, and to execute its 
business plan. This assessment 
period is consistent with the Group’s 
current business plan projections and 
the ICAAP and ORSAs of the Group’s 
regulated entities.

18    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

and effectiveness of policies and 
procedures designed to detect any 
risk of failure by any of the 
Regulated Subsidiaries to comply 
with their obligations under the 
regulatory system.

The Group has a prudent capital 
management approach and 
currently invests shareholder  
assets in high quality, highly liquid,  
short-dated investments.

How risks are managed

The Risk Management Policy provides 
general guidelines for the design 
and implementation of the Risk 
Management Framework with the 
Board responsible for establishing the 
risk strategy and Senior Management 
responsible for its implementation. 
The Risk Management Policy is 
overseen by the Chief Financial 
Officer and is reviewed at least on 
an annual basis. All material changes 
to this policy are considered by the 
Risk Committee and approved by 
the Board.

The Board is responsible for,  
and provides oversight of, the 
Group’s Risk Management Framework 
with guidance provided by the 
Risk Committee. The Group has 
established its framework with 
consideration of the Committee 
of Sponsoring Organisation of the 
Treadway Commission (COSO) 
Integrated Framework Principles, 
providing a consistent, pro-active  
approach to identification, assessment, 
mitigation and reporting of risks 
throughout the Group.

RISK AND RISK 
MANAGEMENT 

Overview

Risk management assists the Board 
in understanding its current and 
future risks and provides appropriate 
risk management information that  
is incorporated into its strategic 
decision making and business 
planning processes. Risk management 
activities encompass all financial, 
strategic and operational risks that 
may prevent IntegraFin Holdings 
Limited (the Company) and the 
Group from fulfilling their business 
objectives. Given the nature of the 
activities undertaken by the Group, 
the key risks that the Company faces 
are financial risks (comprising market 
risk, liquidity risk, outflow risk, 
expense risk and credit risk) and 
non-financial risks (comprising 
regulatory risk, operational risk, 
competition risk, geopolitical risk  
andreputational risk).

The Chief Executive Officer, 
supported by the Chief Financial 
Officer, is responsible for executing 
the strategy set by the Board within 
the risk appetite defined by the Risk 
Committee of IFAL (Risk Committee) 
and approved by the Boards of 
Directors of each of IFAL, ILUK and 
ILInt (collectively known as the 
“Regulated Subsidiaries”). The Chief 
Financial Officer reports directly 
to the Chief Executive Officer and 
is additionally accountable to the 
Board and the Group’s regulators 
for the effective management of 
risk across the business. The Chief 
Financial Officer is responsible for 
overall management of risk controls, 
including the monitoring of risk 
exposures, reporting in relation  
to risk management arrangements 
and for assessing the adequacy 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    19

STRATEGIC REPORT  continued

The Group’s Risk Management Framework is shown below:

OVERSIGHT

ENTERPRISE RISK MANAGEMENT

OWNERSHIP

RISKS

Risk and governance framework

Board

Strategy/Business

Market

Credit

Operational

Insurance

Liquidity

Conduct

Group

t
i
d
u
a

l

a
n
r
e
t
n
I

e
c
n
a

i
l

p
m
o
c

d
n
a

t
n
e
m
e
g
a
n
a
m
k
s
i
R

Model 
governance 
and data 
quality

Risk 
management
policies

Board
with Risk
Committee
guidance

Systems and Controls policies
(Group policy, process and procedures
principles and guidance documents)

Procedures, manuals, 
operational limits, methodology, 
specifications, control activities, 
training, reporting

Management,
Corporate and
Client Accounting,
Operations,
Sales and 
Marketing,
Information
Technology,
Human Resources,
Legal, Technical,
Quality Control,
Actuarial

20    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

 
 
 
 
▪  the Group does not actively 
seek to take operational risk 
to generate returns. It accepts 
a level of operational risk that 
means the controls in place 
should prevent material losses, 
but should not excessively restrict 
business activities

▪  the Group has no risk appetite 

for unfair client outcomes arising 
from systematic failures in its 
cultural outlook or in any element 
of the client life cycle; and

▪  the Group has a zero risk appetite 
for material regulatory breaches.

The actual risk exposures of the 
Regulated Subsidiaries are regularly 
assessed by the Group’s Risk 
Management function against risk 
appetite using a comprehensive set 
of key risk indicators and reported 
to the Risk Committee and Senior 
Management. 

Risk appetite

The Group’s risk appetite is the 
degree of risk that the Regulated 
Subsidiaries are prepared to  
accept in pursuit of their strategic 
and operational objectives.  
The Group’s Risk Management 
Policy and Framework provides 
the mechanism to define the 
Group’s risk appetite. The Group 
has generally adopted an overall 
conservative approach which is 
reflected in its risk appetite values 
and preferences and in the overall 
approach to risk management.  
The Group’s risk preferences can 
be articulated as follows:

▪  the Group ensures risks that 
are taken are aligned with its 
strategic aims and provide an 
acceptable level of return

▪  the Group accepts certain risks 

and ensures that these are 
appropriately managed, mitigated 
and monitored

▪  the Group has a preference 
for products with low capital 
requirements and without 
financial guarantees. Additionally, 
the Group has a preference for 
secondary market risk through 
charges determined based on 
clients’ portfolio values. This is 
central to the Group’s proposition 
and it accepts the potential 
impact on financial performance

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    21

STRATEGIC REPORT  continued

Risk governance

The Risk Management Framework 
defines risk governance as the 
combination of processes and 
structures implemented by the Board 
in order to inform, direct, manage 
and monitor the activities of the 
Group towards the achievement  
of its objectives.

The Risk Committee is made up of 
independent Non-Executive Directors 
(NEDs) and is responsible for 
reviewing the manner in which the 
Group and the Regulated Subsidiaries 
implement, and monitor the 
adequacy of, the Risk Management 
Framework. The Risk Committee also 
assists in fostering a culture that 
encourages good stewardship of risk 
and emphasises and demonstrates 
the benefits of a risk-based approach 
to management of the Group.

The Group implements a comprehensive 
“top-down” and “bottom-up” 
approach to managing risks through 
regular assessments, monitoring 
(including horizon scanning) and 
reporting in conjunction with Senior 

Management and risk owners.  
The Risk Management function 
reports to the Risk Committee, on at 
least a quarterly basis, information 
and analysis on the key risks the 
Group faces (including forward-
looking risks), capital requirements 
and comparison against risk appetite. 
The Chairman of the Risk Committee 
then provides a summary to the 
members of the Boards.

The “three lines of defence” risk 
governance model

For risk management to be effective 
it is important that the roles and 
responsibilities of all those involved 
are clearly defined. Accordingly, 
 the Group’s Risk Management 
Framework is designed along the 
“three lines of defence” model 
(illustrated below), which aims 
to ensure at least three stages 
of oversight to ensure that the 
Regulated Subsidiaries operate  
within the risk appetite defined by 
the Risk Committee and approved  
by the Boards of Directors of each of 
the Regulated Subsidiaries.

THE ”THREE LINES OF DEFENCE” RISK GOVERNANCE MODEL OF THE  
REGULATED SUBSIDIARIES:

The Board

Risk  
Committee

Audit  
Committee

Risk Ownership

Risk Oversight

Risk Assurance

Managers 
Business 
Operations

Risk Management 
Compliance

Internal Audit

First Line of 
Defence

Second Line of 
Defence

Third Line of 
Defence

22    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

First line of defence

Second line of defence

The Group’s first line of defence 
is its business departments which 
have responsibility for managing and 
controlling their risks in accordance 
with agreed risk appetites through 
the implementation of a sound set  
of processes and controls.

Responsibility for risk management 
resides at all levels within the Group’s 
business lines, from the Senior 
Management Team to department and 
team managers. All staff members are 
accountable for managing risks within 
the business areas for which they  
are responsible, ensuring compliance  
with prescribed company plans, 
policies and prevailing regulatory  
and legislative requirements.

The business lines are also responsible 
for complying with the policies and 
standards which comprise the Group’s 
Risk Management Framework.  
Current key risks and issues facing 
the Group are considered by the 
Management Team, with each key 
risk owned by the member of the 
Management Team who is responsible 
for the strategic management of that 
risk across the Group.

The Group’s second line of defence 
comprises of two functions:  
the Risk Management function  
and the Compliance function.

The Risk Management function is 
responsible for co-ordinating all 
the risk management activities 
within the business. This includes 
the development, maintenance 
and enhancement of the Risk 
Management Policy and Framework, 
as well as Risk Management 
reporting. The Risk Management 
function provides regular risk reports 
to the Risk Committee, which is 
comprised solely of NEDs.

The Compliance function is primarily 
responsible for supporting the Group 
to ensure that its activities are 
conducted in accordance with all 
applicable regulatory requirements.

Third line of defence

The Group’s third line of defence  
is the Internal Audit department, 
which provides independent assurance 
on the adequacy and effectiveness 
of the Group’s risk management 
and major business process control 
arrangements. The Head of Internal 
Audit reports directly to the Chairman 
of the Audit Committee, which is 
comprised solely of NEDs.

Internal Audit conducts regular 
audits on the implementation and 
effectiveness of the Risk Management 
Policy and Framework across the 
business. The results of these audits 
are reported to the Audit Committee 
and the Board. The Board is satisfied 
that Internal Audit provides 
sufficient assurance about the Risk 
Management Policy and Framework.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    23

STRATEGIC REPORT  continued

PRINCIPAL RISKS AND 
UNCERTAINTIES

The principal risks and uncertainties 
to which the Company is exposed 
relate to the upstream of capital, 
predominantly from its regulated 
subsidiary, IFAL, in order to support 
its dividend-paying capacity to its 
shareholders. The key drivers of 
this upstream of capital are the 
underlying financial performance 
and solvency position of IFAL and its 
regulated subsidiaries, provided in 
the relevant supplementary accounts. 
In summary, due to the nature of 
the business written by IFAL and 
the other regulated subsidiaries, 
profitability arises primarily from 
charges on the assets held in the 
portfolios less the expenses of 
administering those portfolios. 
As a consequence, the predominant 
risks to which the Company is 
exposed are market risk, liquidity 
risk, outflow risk, expense risk and 
operational risk. The Company seeks 
to limit its exposure to these and  
any other applicable financial and 
non-financial risks.

The following tables (split between 
financial and non-financial risks) 
describe the key risks of the 
Company with a summary 
description of how we manage 
and mitigate the risks:

Solvency II

ILUK has fully embedded the 
requirements of the Solvency II 
regime which came into force on  
1 January 2016. The new regulations 
brought in detailed requirements 
covering risk and risk management, 
including stress and scenario 
testing, as well as new valuation and 
reporting requirements. However, 
this has not fundamentally changed 
ILUK’s business or risk profile and 
ILUK continues to safely manage 
its solvency position through the 
economic cycle.

ILUK has adopted the Standard 
Formula approach in calculating  
the Solvency Capital Requirement 
(SCR), and has not adopted any  
of the Transitional Provisions in the 
calculation of the Solvency II balance 
sheet or SCR. As at 30 September 
2017, ILUK has Own Funds of  
£154m and an SCR of £135m which 
gives a solvency coverage ratio  
of 114%.

24    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

FINANCIAL RISKS

KEY RISK DESCRIPTION

MANAGEMENT AND CONTROLS

Market risk – the impact changes  
in equity and property market 
values, currency exchange rates, 
credit spreads, interest rates and 
inflation, may have on the value  
of clients’ portfolios, resulting in  
a reduction in future charges  
or an increase in future expenses.

The upstream of capital to the Company is exposed to second order 
impacts from market movements as future charges are predominantly 
determined based on clients’ portfolio values. The Regulated Subsidiaries 
of the Group do not offer any guarantees on portfolio values and currently 
invest their shareholder assets in high quality, highly liquid, short-dated 
investments.

Expense inflation risk is mitigated through regular stress testing, 
monitoring of expenditure and closely managing expenses in line with the 
business plan.

Liquidity risk – this is the risk of 
the Company not having available 
sufficient financial resources to 
enable it to meet its obligations  
as they fall due, or can secure such 
resources only at excessive cost.

The Company’s principal liquidity risk is limited to paying out dividends 
and operating expenses as they occur. 

There are robust controls in place to mitigate liquidity risk, for example, 
holding corporate cash across a range of banks, in order to mitigate the 
risk of a single point of counterparty default failure.

Outflow risk – loss of future  
profits due to more clients than 
expected terminating policies or 
more outflows (e.g. withdrawals  
or transfers) than expected.

The Group seeks to mitigate outflow risk by focusing on providing the 
highest level of service that it can. Outflow rates are closely monitored 
and unexpected experience is investigated. Despite the current 
challenging and uncertain economic and geopolitical environment, outflow 
rates remain low and stable.

Expense risk – administration costs 
exceed expense allowance, which 
can occur due to costs increasing 
faster than expected or from one-off 
expense “shocks”.

As a significant percentage of the Group’s expenses are staff-related, the 
key inflationary risk arises from salary inflation. Expense risk is mitigated 
through regular stress testing, monitoring of expenditure and closely 
managing expenses in line with the business plan.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    25

STRATEGIC REPORT  continued

NON-FINANCIAL RISKS

KEY RISK DESCRIPTION

MANAGEMENT AND MITIGATION

Regulatory risk – the risk of new 
regulatory requirements having 
adverse impacts on the Group’s 
business model, or the Group failing 
to comply with existing or new 
regulations resulting in a fine or 
regulatory censure.

Regulatory risk is mitigated through regular monitoring of regulatory 
developments and maintaining open and transparent dialogue with the 
regulators to which the different regulated subsidiaries are subject.

On-going compliance with existing rules is monitored by the Compliance 
function with additional assurance provided by the Internal Audit function 
for the key regulatory risks on a regular basis.

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

The Group aims to minimise operational risk at all times through a strong 
and well-resourced control and operational structure. This is supported by 
the strong corporate governance structure that is embedded in the Group 
as a whole.

Competition risk – the risk of 
competitor activity resulting in loss 
of new business, increased outflows 
of existing business or pressure on 
profit margins.

Geopolitical risk – the risk of 
changes in the political landscape 
disrupting the operations of the 
business or resulting in significant 
development costs.

Competitor risk is mitigated by focusing on providing exceptionally high 
levels of service and being responsive to client and financial adviser 
demands through an efficient expense base.

Geopolitical risk cannot be directly mitigated by the Group. However, 
through close monitoring of developments through its risk horizon 
scanning process, potential impacts are taken into consideration as part 
of the business planning process.

Reputational risk – the risk that 
current and potential clients’ desire 
to do business with the Group reduces 
due to perception of the Transact 
service in the market place.

The Risk Management Framework provides the monitoring mechanisms 
to ensure that reputational damage controls operate effectively and 
reputational risk is mitigated, to some extent, by internal operational risk 
controls, error management and complaints handling processes as well as 
root cause analysis investigations.

26    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

CORPORATE SOCIAL 
RESPONSIBILITY

IntegraFin demonstrates its social 
responsibilities primarily through 
its relationship, as ultimate parent 
company, with companies in its 
Group that operate ethically and 
deliver commercial benefits to 
customers, shareholders and staff. 
IntegraFin also acknowledges its 
responsibilities more widely in 
relation to the Company’s effects on 
environmental and social wellbeing.

Culture

Transact was founded on the principle 
of offering adviser firms and clients a 
high quality service with transparent 
charging (for clients in relation 
to payment for platform services 
and adviser firms’ services) and a 
demonstrably agnostic attitude  
to clients’ investment choice.  
This ethical approach informs all of 
the Group’s business principles. 

Environment

IntegraFin has a limited direct  
impact on the environment. However, 
we still take steps to reduce our 
environmental impact by encouraging 
adviser firms and clients to use 
electronic rather than paper based 
instruction delivery, by encouraging 
staff to reduce consumption of 
electricity, other utilities and paper 
and by recycling waste materials.

Community

We organise a variety of events 
each year to raise money for, and 
awareness of, a number of charities 
chosen from staff suggestions.  
We do not make political donations.

The Group also makes tax 
payments. The UK corporation tax 
and employer’s national insurance 
payable in respect of the year ended 
30 September 2017 was £9.2 million. 
In addition other taxes such as VAT 
and business rates were paid.

This Strategic Report (up to page 27) 
was approved by the Board of 
Directors on 12 December 2017  
and signed on its behalf by 

David Johnson 
Company Secretary

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    27

GOVERNANCE

BOARD OF DIRECTORS TO 30 SEPTEMBER 2017

Michael Howard 
Executive Chairman

Appointed:  
24 January 2014

Ian Taylor 
Chief Executive Officer

Appointed:  
24 January 2014

Alexander Scott 
Group Director

Appointed:  
24 January 2014

▪  Executive Chairman of the Group 
from 2001 until stepping down 
in October 2017 and becoming 
Executive Director. Prior to this he 
was the Managing Director from 
April 1999 to December 2001

▪  CEO of the Group since April 
2002, prior to which he was 
Executive Director and General 
Manager from 1999 to 2002

Experience includes:

▪  AIB Govett Asset Management – 
Marketing Director 1992-1999

▪  Royal Life Holdings Group – Marketing 
Development Manager 1990-1992, 
Business Planning Manager 
1988-1990.

▪  Founded ObjectMastery in 

Australia in April 1992 which 
developed the software 
powering Transact

Experience includes:

▪  Norwich Union Life Insurance – 

launched platform Navigator in 1990, 
Managing Director of Norwich Australia 
Asset Management from 1989-1992, 
Marketing Development Manager 
1988-1989 and Accounts & Company 
Secretary 1986-1988

▪  Touche Ross – Audit division in 

Melbourne office 1984-1986, in the UK 
1980-1984.

▪  Group Director since May 2013

▪  CFO and Head of Risk from 

November 2010 to May 2013

▪  Joined the Group as Actuary 
and Head of Group Technical 
Operations in October 2009

Experience includes:

▪  Sterling Insurance Group – Life 

Director and Chief Actuary 2004-2009

▪  Criterion Assurance Group –  

Non-Executive Director 2003-2010, 
Group Director 2002-2003, Director 
1999-2002, Actuary 1997-1999
▪  National Provident Institution – 

Actuarial Division 1991-1997.

28    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Judith Davidson 
Chief Operating Officer

Christopher Munro 
Non-Executive Director

Neil Holden 
Non-Executive Director

Appointed:  
24 January 2014

Appointed:  
29 March 2017

Appointed:  
24 January 2014

▪  COO of the Group since 

Experience includes:

Experience includes:

November 2010

Experience includes:

▪  Symbiotic Consulting – Founder and 
Managing Partner 2009 to present
▪  Sodexo UK – Client Relations and 
Commercial Director 2005-2009, 
Director of Strategy UK & Ireland 
2002-2005, SAP Implementation 
Director 2000-2002, UK & Ireland 
Sales Director 1997-2000, Divisional 
MD, Business and Industry 1996-1997, 
Managing Director Education 
1995-1996

▪  Gardner Merchant – Sales and 
Operational Roles 1986-1995

▪  Trust House Forte Airport Services – 

Operational Roles 1983-1986.

▪  London and Continental Partners LLP  

▪  Saffron Building Society –  

– Founding Partner 2016

▪  Beckwith Asset Management – Director 

1994 to 2016 

▪  Pacific Capital Partners – Director 2004 

to present

▪  Jupiter Enhanced Income Trust – 

Director 1996 and 2009

▪  River & Mercantile Investment 
Management – CEO 1994-1996

▪  Robert Fleming Holdings Limited – 

Director 1988 and 1994 

▪  Jardine Fleming Holdings – Director 

1983-1986.

Committees: 
Remuneration Committee, 
Risk Committee, 
Regulatory Compliance Committee, 
Audit Committee.

Non-Executive Director since 2014
▪  Calmindon Ltd – Director since 2010
▪  Stanbic International Insurance 

Limited – Non-Executive Director 
since 2003

▪  Bank of London and The Middle East Plc 
– Non-Executive Director since 2006

▪  Quadrant Risk Management 

International Limited – Non-Executive 
Director 2006-2009

▪  Standard Bank Group and Standard 
Bank Plc – Consultant 2006-2008, 
Managing Director in Corporate and 
Investment Banking Financial Risk 
1999-2006

▪  WestLB – Director and Head of Risk 

Management Support & Control 
1996-1998.

Committees: 
Remuneration Committee (Chair), 
Risk Committee, 
Regulatory Compliance Committee, 
Audit Committee (Chair).

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    29

GOVERNANCE  continued

Appointment subsequent 
to 30 September 2017

Jeremy Brettell 
Non-Executive Director

Stuart Bazley 
Non-Executive Director 

Patrick Snowball 
Non-Executive Chairman

Appointed:  
24 January 2014

Appointed:  
24 January 2014

Appointed:  
1 October 2017

Experience includes:

Experience includes:

Experience includes:

▪  Chair of Airdrie Savings Bank 

▪  Visiting Professor in Financial 

▪  Dabre Insurance Group plc – 

since 2015

▪  Chair of Guarantee Protection 

Insurance Ltd since 2014

▪  Chair of Anderson Strathern Asset 

Regulation and Compliance at BPP 
2008-present

Non-Executive Chairman 2017 
to present

▪  IFAL – Head of Compliance 2011-2012
▪  IFAL – Consultant 2010-2011 and 

▪  Aviva UK – CEO 2005-2007
▪  Suncorp Group Limited –  

Management since 2014

2012-2013

CEO 2009-2015

▪  Wesleyan Bank – Non-Executive 

▪  Momenta – Head of Regulatory 

▪  Towergate – Deputy Chairman 

Consulting 2004-2008

2007-2008

▪  Edward Jones – UK General Counsel 
and Compliance Director 1999-2004

▪  Irish Life Assurance UK – Legal 

Adviser, Head of Legal and Compliance 
and Money Laundering Reporting 

Officer 1991-1996.

▪  Jardine Lloyd Thompson plc – 

Non-Executive Director 2008-2009

▪  Member of the Financial Services 
Authority (UK) Practitioner Panel, 
representing Life and General 
Insurance, 2006-2008.

Committees: Remuneration 
Committee, Risk Committee, 
Regulatory Compliance Committee 
(Chair), Audit Committee.

Director and Chair of Audit Committee 
since 2013

▪  UnLtd – Audit Committee Member 

2012–2014

▪  NHS Lothian – Non-Executive Board 
Member and Chair of Audit & Risk 
Committee 2012–2015

▪  Accountant in Bankruptcy –  

Non-Executive Board Member and 
Chair of Audit Committee 2012–2014 

▪  Helvetia Wealth Management – 
Strategy Consultant 2011-2012
▪  SL Investment Management Ltd – 

Chief Executive 2006-2012.

Committees: 
Remuneration Committee, 
Risk Committee (Chair), 
Regulatory Compliance Committee, 
Audit Committee.

30    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

CORPORATE GOVERNANCE 
REPORT

Governance Statement

IntegraFin Holdings Limited is not 
required to comply with the UK 
Corporate Governance Code (Code). 
Nevertheless, the Company’s Board 
considers the terms of the Code 
in determining appropriate and 
proportionate corporate governance 
arrangements for the Company and 
its Group of companies by reference 
to the nature, scale and complexity  
of its business. Accordingly, the 
Group’s corporate governance 
arrangements reflect the standards  
of practice required by the Group  
in relation to the management  
of the Group and are designed to:

▪  promote business effectiveness, 

efficiency, responsibility and 
accountability

▪  assist the effective review and 

monitoring of the Group’s activities

▪  help identify and mitigate significant 

risks to the Group; and

▪  provide the disclosures to 

stakeholders necessary to make 
a meaningful analysis of the 
Group’s business activities and its 
financial position.

Board of Directors

The Role of the Board

Michael Howard  
Executive Chairman

Ian Taylor  
Chief Executive Officer

Alexander Scott  
Group Director

Judith Davidson  
Chief Operating Officer

Neil Holden  
Independent Non-Executive Director

Jeremy Brettell  
Independent Non-Executive Director

Stuart Bazley  
Independent Non-Executive Director

Christopher Munro  
Independent Non-Executive Director

A number of resignations and 
appointments have taken place since 
the financial year end in preparation 
for listing IntegraFin on the London 
Stock Exchange in 2018. On 1 October  
2017 Michael Howard stood down 
as Chairman of IntegraFin and the 
Boards of IFAL, ILUK and ILInt. 
On the same date, Patrick Snowball 
was appointed as Non-Executive 
Chairman of IntegraFin and IFAL. 
Jeremy Brettell, Stuart Bazley and 
Judith Davidson stepped down  
from the IntegraFin Board on 
1 October 2017 but continue to be 
Directors of IFAL. 

Board Leadership

The Board is responsible for the 
leadership and management  
of the Group. The Board oversees  
the Company’s business affairs,  
the maintenance of internal controls,  
and compliance with statutory 
obligations. Michael Howard 
has chaired the Board since the 
Company’s incorporation in January 
2014. The Board comprises four 
Executive Directors (including the 
Chairman) and four NEDs. 

Matters reserved to the Board

The Board’s remit is documented  
in its terms of reference which 
includes details of matters reserved 
to the Board and matters delegated 
by the Board. The terms of reference 
including matters reserved to the Board 
are reviewed and updated annually. 

Board Meetings

The Board met each quarter,  
in accordance with its terms  
of reference. All members of the 
Board attended all Board meetings 
throughout the year.

Conflicts of interest

The Company’s articles of association 
permit the Board to consider and 
authorise situations where a Director 
has an actual or potential conflict 
of interest in relation to the Group. 
The Company maintains a conflicts 
of interest register which is reviewed 
annually by the Board. In addition, 
prior to each Board meeting, the 
Directors are asked to declare any 
conflicts they may have with regard 
to the business meeting. Directors 
who declare a conflict of interest 
may be authorised by the rest of 
the Board to participate in decision 
making in accordance with section 
175 of the Companies Act 2006. 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    31

GOVERNANCE  continued

Board effectiveness 

Annual General Meeting

The Board undertakes a review of its 
effectiveness each year. At the next 
Board meeting the Directors discuss 
the findings and agree any action 
points arising.

Re-election of Directors

The Company’s articles of association 
require Directors to retire by 
rotation at each annual general 
meeting (AGM) of the Company. 
Directors required to retire and seek 
reappointment are those who have 
been appointed by the Board since 
the last AGM and who were not 
appointed or reappointed at one  
of the preceding two AGMs. 

Shareholder engagement 

The Board provides a detailed annual 
communication to shareholders  
which includes a business update  
and financial performance results. 

The AGM provides shareholders with 
a further opportunity to communicate 
with the Board both during the AGM 
and informally afterwards. Notice of 
the AGM is sent in accordance with 
the Companies Act 2006 and 
made available on a dedicated 
shareholder website along with any 
other relevant documentation. 

Group Committees

The Board delegates relevant 
matters to the Audit, Strategy and 
Risk Committees for consideration. 
Independently, the Boards of 
Integrated Financial Arrangements 
Ltd, IntegraLife UK Limited and 
IntegraLife International Limited  
(the regulated companies in the Group) 
have delegated relevant matters to 
a Regulatory Compliance Committee 
and a Remuneration Committee. 

32    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

AUDIT COMMITTEE REPORT

Annual Statement by the 
Chairman of the Audit Committee. 

I am pleased to present the Audit 
Committee’s report for 2017. 

The Audit Committee has worked 
closely with the Risk Committee and 
Regulatory Compliance Committee to 
ensure the Group maintains robust 
controls. It has overseen the integrity 
of the financial reporting process and 
reviewed the work of both external 
and internal auditors. 

Role of the Audit Committee

The role and responsibilities of 
the Audit Committee are set out 
in its terms of reference and are 
summarised below:

▪  monitoring the integrity of the 

Group’s financial reporting process 

▪  ensuring the integrity of our Annual 

Report and Financial Statements

▪  reviewing the manner in which the 
Group implements, and monitors 
the adequacy of, internal financial 
and operational controls

▪  monitoring and reviewing the 

effectiveness of the Group’s Internal 
Audit function

▪  reviewing external audit 

arrangements and making 
recommendations to the Board 
regarding any changes to the 
external auditor as well as review 
and approval of their remuneration 
and terms of engagement

▪  reviewing and monitoring the 

independence and objectivity of 
external auditors as well as the 
effectiveness of the audit process, 
taking into consideration relevant 
professional and regulatory 
requirements.

The Committee reports its findings 
to the Board, identifying any matters 
in respect of which it considers that 
action or improvement is needed, 
and makes recommendations as to 
the steps to be taken. However, the 
Board retains ultimate responsibility 
for reviewing and approving financial 
reports and other public statements. 

Composition of the Audit 
Committee

The members of the Audit Committee 
at 30 September 2017 were:

Neil Holden  
– Chairman (Chartered Accountant)  
– appointed 9 February 2011

Jeremy Brettell  
– appointed 16 July 2012

Stuart Bazley  
– appointed 20 May 2015

Christopher Munro  
– appointed 1 February 2017

All members of the Committee, 
including the Chairman, are 
independent Non-Executive Directors. 

On an on-going basis, membership 
of the Committee is reviewed by 
the Chairman of the Committee 
and any recommendations for new 
appointments are made to the 
IFAL Board. 

In adherence with the UK Corporate 
Governance Code requirement to 
include at least one Committee 
member with recent and relevant 
financial experience, the Audit 
Committee Chairman is a fully 
qualified chartered accountant.

The Group also provides initial 
and on-going training for new and 
existing Committee members to 
support them in carrying out their 
duties effectively. This is delivered 
by in-house technical staff, through 
attendance at formal conferences, 
and an online training programme. 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    33

GOVERNANCE  continued

Meetings and attendance

The Audit Committee meets at  
least three times each year but  
more frequently when required.  
The Committee regularly meet in 

private with external and internal 
auditors. The Committee met eight 
times during this financial year. 
Attendance by each member of the 
Committee at 30 September 2017 is 
set out below. 

MEETING ATTENDANCE

Eligible  
to attend

Meetings  
attended

Chairman

Neil Holden

Members

Jeremy Brettell

Stuart Bazley

Christopher Munro

8

8

8

5

8

8

8

3

The Group Chief Executive Officer, 
Group Chief Financial Officer,  
Group Counsel and Group Head of 
Internal Audit are routinely invited 
to, and attend, the majority of 
meetings, although the Committee 
reserves the right to request any  
of these individuals to withdraw.  
The external auditors for the Group 
and Life Companies (BDO and KPMG 
respectively) also attended specific 
Committee meetings for external audit 
planning and reporting purposes.

In between the formal schedule of 
meetings the Committee Chairman 
keeps in regular contact with the Group 
Chief Executive Officer, Group Chief 
Financial Officer, Group Head of Internal 
Audit, and the Senior Engagement 
Partners of the Group’s two external 
audit firms (BDO and KMPG).

Overview of the actions taken by 
the Audit Committee to discharge 
its duties

The Audit Committee has focused  
on four main areas during the year:

▪ Financial Reporting

▪ Internal controls and key risks

▪ Effectiveness of internal audit

▪  Effectiveness and independence  

of the external auditor.

The Audit Committee has also 
conducted a self-assessment of its 
own effectiveness for the year and 
was satisfied with the results achieved 
and has agreed actions where 
improvements were suggested.

Financial reporting

The financial reporting undertaken 
by the Group has been reviewed and 
challenged by the Committee, with 
input and support from the Group’s 
external auditors. It assessed whether 
suitable accounting policies have 
been adopted, whether management 
have made appropriate estimates and 
judgements and whether disclosures 
in published financial statements were 
fair, balanced and understandable. 

As part of its work during the year,  
the Committee, on behalf of the Board, 
has examined the Annual Report 
and Financial Statements, related 
disclosures, consistency of accounting 
policies and the financial reporting 
process. This included the review and 
approval of the Annual Report, and 
consideration of the Income Statement, 
Statement of Comprehensive Income, 
Statement of Financial Position, 
Statement of Changes in Equity,  
Going Concern statement and the 
Statement of Cash Flows, with an 
emphasis on ensuring that these are 
fair, balanced and understandable.

34    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

The Committee did this by 
ensuring there was a thorough 
process of challenge, including 
challenge by the Committee itself. 
The Committee’s own challenge 
process included questioning the 
Group Chief Executive Officer on 
the overall messages and tone of 
his review statement, examining 
and challenging reports from both 
management and the external  
auditor relating to the Annual Report, 
and reviewing consistency with 
internal reports presented to the 
Board by management, the Group 
Chief Financial Officer, Group Head  
of Internal Audit and Group Chief 
Risk Officer during the year. Following 
this assessment the Committee 
recommended to the Board that the 
2017 Annual Report and Financial 
Statements are fair, balanced and 
understandable.

Internal controls and key risks

The Audit Committee receives 
reports at each meeting from the 
Group Internal Audit function. 
The content and accuracy of 
these reports was assessed and 
challenged by the Committee to 
ensure that management takes 
appropriate and prompt action 
to address audit findings and we 
monitor management’s progress in 
implementing the agreed actions.

The Group will be audited for the 
first time this year under the FRC’s 
new standard regarding CASS 
assurance reports. This Committee 
has discussed the impact of the new 
standards and is satisfied that they 
have been dealt with appropriately. 

Effectiveness of Internal Audit

The Audit Committee assists the 
Board in determining the adequacy 
of the resourcing and plans, and the 
ongoing effectiveness, of the Internal 
Audit function. The Internal Audit 
function presents its Annual Audit 
Plan, using a risk based approach,  

to the Committee once a year  
for prioritisation and approval.  
The Annual Audit Plan is then 
reported to the Audit Committee on 
a quarterly basis for review against 
changing risks to the Group and  
for tracking its completion.

There are no contractual or similar 
obligations restricting the Group’s 
choice of external auditors and  
the Group’s external auditors,  
BDO and KPMG, have both  
confirmed to the Committee that  
they remain independent.

In line with the EU audit regulations 
our UK life insurance subsidiary 
(ILUK), as a Public Interest Entity, 
was required to put its external audit 
engagement to formal tender (as the 
engaged auditors had been in place 
for 10 years). Following a competitive 
tender process carried out in 2017 
KPMG were re-appointed as the 
external auditor to ILUK, and also  
to our Isle of Man life insurance 
subsidiary (ILInt). The tender process 
included assessing the auditor’s audit 
approach and delivery, the composition 
of the engagement team, audit 
quality and fees and terms. 

The Audit Committee met with both 
external auditors privately this year 
in order to discuss any matters directly 
in the absence of management.

The Committee is satisfied with the 
performance and effectiveness of 
BDO and KPMG and has concluded 
that they both continue to display the 
necessary attributes of independence 
and objectivity.

On behalf of the Audit Committee

Neil Holden 
Chairman of the Audit Committee

12 December 2017

Having conducted a review of 
the Internal Audit department 
the Committee considers that its 
resources and plans are appropriate 
for both its resources and plans.  
In line with the recommendation 
by the Institute of Internal Auditors 
whereby an external review of the 
Internal Audit function should be 
carried out no less than every five 
years, our Internal Audit function had 
a satisfactory external review carried 
out in February 2017.

The Audit Committee met with the 
Head of Internal Audit privately 
this year in order to discuss any 
matters directly in the absence 
of management.

Effectiveness and independence 
of the external auditor

The Audit Committee has primary 
responsibility for the Group’s 
relationship with the external 
auditors (BDO and KPMG) and for 
monitoring their independence, 
objectivity and compliance with 
ethical and regulatory requirements.

There were non-audit fees during 
2017 paid to BDO of £105,800 
(2016: £153,650). The non-audit 
fees paid to BDO related to quarterly 
reviews, pension reviews, the annual 
CASS audit, and other assurance 
assignments. Non-audit fees paid to 
KPMG during 2017 were £100,300 
(2016: £105,400). The non-audit fees 
paid to KPMG related to quarterly 
reviews, and a Solvency II audit.

Fees paid to BDO for the audit 
for 2017 were £111,800 (2016: 
£109,500), and audit fees paid to 
KPMG were £98,800 (2016: £96,400).

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    35

GOVERNANCE  continued

DIRECTORS’  
REMUNERATION REPORT

Annual Statement  
by the Chairman of the 
Remuneration Committee.

I am pleased to present a report 
relating to the activities of IFAL’s 
Remuneration Committee in 2017. 

During this year, as in previous years, 
the Committee’s primary activities 
have been to review, set or agree  
(as detailed in the Committee’s terms 
of reference), overall remuneration 
and that of senior individual officers 
as required by the Remuneration 
Code. It has done so with  
a view to aligning remuneration  
with the successful achievement  
of the Group’s long-term objectives 
while taking into account relevant 
regulatory requirements, market 
rates and value for money.

The Group provides a simple 
remuneration package for all staff 
consisting of base salary, annual 
bonus and a benefits package 
(including pension contributions). 
There is no long-term incentive plan.

The anticipated total bonus pool 
is accrued during the year as a 
percentage of the Group’s total base 
salary costs based on forecasted 
financial performance and post-tax 
profits for the year. 

After the end of the financial year  
the Group’s financial performance is 
reviewed before bonuses are awarded. 
Individual payments are expressed as 
a percentage of base salary. Individual 
awards may be increased by reference 
to individual performance but the 
majority of the bonus payment is 
determined by reference to the Group’s 
financial performance.

A relatively low proportion of 
remuneration is paid in the form of 
bonus. Payments are generally made 
in three tranches over a period of six 
months after the year end. The Group’s 
business model ensures that profit  
is quickly translated to cash and 
therefore the Committee deems that 
these timescales are appropriate.

As part of the process of listing 
IntegraFin’s shares, it is anticipated 
that IntegraFin will establish its own 
Remuneration Committee. 

On behalf of the  
IFAL Remuneration Committee

Neil Holden 
Chairman of the IFAL 
Remuneration Committee

12 December 2017

36    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

RISK COMMITTEE REPORT

Annual Statement by the 
Chairman of the Risk Committee

I am pleased to present a report of 
the Risk Committee’s activities in 2017.

During another busy financial  
year the Risk Committee has 
reviewed and considered a wide  
range of topics including information 
technology security and cyber risks, 
client money management, risk 
appetite frameworks (including 
conduct risk) and the impact of  
the UK voting to leave the EU. 
Additionally, the Committee 
recommended for approval the  
IFAL Internal Capital Adequacy 
Assessment Process (ICAAP) to the 
IFAL Board, the ILUK Own Risk and 
Solvency Assessment (ORSA) to the 
ILUK Board and the ILInt Individual 
Capital Assessment (ICA) to the 
ILInt Board.

Role of the Risk Committee

The Committee is a committee  
of the Board of IFAL and assesses 
known and foreseeable risks seeking 
to anticipate future issues, enabling 
action to be taken to minimise the 
impact should any of those risks 
materialise. The Committee reviews 
the manner in which the Group 
implements, and monitors the 
adequacy of, the Risk Management 
Framework. It assists the regulated 
companies’ Boards in fostering 
a culture within the Group that 
encourages good stewardship of risk 
and emphasises and demonstrates 
the benefits of a risk-based approach 
to management of the Group. 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    37

GOVERNANCE  continued

▪  review the Group’s top risks and the 
progress of identified management 
actions to manage those risks that 
are outside appetite

▪  review the Departmental Risk 

Registers with the relevant Heads 
of Department with top risks and 
ensure that mitigating actions are 
progressing to completion

▪  review the risk mitigation 

techniques and approaches adopted 
by the companies and ensure that 
those mechanisms are appropriate 
and are in line with the Group’s 
overriding business principles at 
least annually. This includes the 
appropriateness of decisions which 
have resulted in mitigation not 
being put in place

▪  review the effectiveness of the 

performance of the risk function  
and the adequacy of its resources

▪  escalate matters of relevance  
to the appropriate regulated 
companies’ Boards.

The risk appetites of the Groups’ 
businesses are determined by the 
regulated companies within the 
IntegraFin Group. The Committees’ 
report their findings and any 
recommendations to the regulated 
companies’ Boards. 

The role and responsibilities of the 
Committee are set out in its terms of 
reference and are summarised below:

▪  maintain oversight of the Group’s 
risk management activities and 
monitor their effectiveness

▪  review annually the Group’s 

overarching risk appetite and each 
company’s specific risk appetites  
in relation to the Group’s strategy

▪  identify risk trends, exposures or 
concentrations within the Group  
or individual companies within  
the Group that may necessitate 
policy changes

▪  review annually the Group’s Risk 

Management Framework

▪  review annually and recommend to 
the regulated companies’ Boards, 
for approval the Group’s policies in 
relation to risk, including mitigation 
of the risks identified as a result 
of implementation of the Risk 
Management Framework

▪  review and challenge as necessary, 
at least half-yearly, management 
information reporting the status 
of the Group’s risk profile – by 
reference to risk appetite, risk 
trends and risk concentrations – 
against the top risks as recorded  
in the Group Risk Register

▪  review the ICAAP, the ICA and 
the ORSA documents and Wind 
Down Plan for the Group; capital 
adequacy and regulatory capital 
usage; external risk disclosures 
including risk statements in the 
Annual Directors’ Report and 
Financial Statements and Pillar 3 
Disclosures; annual Internal Audit 
reports where they relate to the 
effectiveness of risk management 
operations

▪  review financial crime risk controls 

and remedial action taken regarding 
fraudulent activity

38    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Composition of the  
Risk Committee

The members of the Risk Committee 
at 30 September 2017 were:

Jeremy Brettell  
– Chairman  
– appointed 16 July 2012

Neil Holden  
– appointed 9 February 2011

Stuart Bazley  
– appointed 20 May 2015

Christopher Munro  
– appointed 29 March 2017

On an annual basis, membership 
of the Committee is reviewed by 
the Chairman of the Committee 
and any recommendations for new 
appointments are made to the  
IFAL Board. 

Meetings and attendance

The Committee meets at least four 
times each year, there were five 
scheduled meetings during the 
financial year and additional ad-hoc  
meetings where required.  
The attendance by each Director  
is set out in the table below. 

All members of the Committee, 
including the Chairman, are 
independent Non-Executive Directors. 

The members of the Committee at 
30 September 2017 who attended 
the five scheduled Committees held 
during the twelve month period were:

MEETING ATTENDANCE

Eligible  
to attend

Meetings  
attended

Chairman

Jeremy Brettell

Members

Stuart Bazley

Neil Holden

Christopher Munro*

*appointed to the Risk Committee on 29 March 2017.

5

5

5

2

5

5

5

2

The Chief Executive Officer, Chief 
Financial Officer/Chief Risk Officer, 
Group Counsel, Head of Quality 
Control, Head of Actuarial and Risk 
and Risk Manager are routinely 

invited to attend meetings, although 
the Committee may request any of 
these individuals to withdraw or call 
for additional attendees to provide 
amplification on specific risk matters.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    39

GOVERNANCE  continued

Overview of the actions taken by 
the Risk Committee to discharge 
its duties

Risk reporting and risk profile 
discussions

The Risk Management function 
provides reports to the Committee 
at each meeting. During the 
2016/2017 financial year the main 
topics discussed included: top risks, 
risk horizon scanning, risk appetite 
statements and assessments, bank 
account and custodian dashboard 
review and updates on the external 
environment following the UK’s vote 
to leave the EU. 

The Committee agrees that the 
Group’s approach to risk continues  
to be appropriate. 

ICAAP, ORSA and ICA

The Committee recommended for 
approval the ILUK ORSA to the  
ILUK Board and the ILInt ICA to the 
ILInt Board in November 2016 and 
the IFAL ICAAP to the IFAL Board  
in December 2016. As part of this, 
the Committee provided risk 
management challenge to key 
underlying processes including 
formulation of scenarios, stress  
and scenario testing, reverse stress 
testing and wind down plans.

Risk Management Policy  
and Framework

The Committee received a report 
from the Head of Actuarial and Risk 
regarding the improvements in the 
design and effectiveness of the Risk 
Management Framework. This included 
the expansion of related risk policies 
and further linking the Group’s 
business principles to the regulated 
companies’ risk appetite frameworks.

Risk effectiveness

The Committee has ensured that 
the Risk Framework has been 
implemented successfully and 
adhered to appropriately in the 
2016/2017 financial year. In addition, 
the Internal Audit function issued 
an Annual Report on the overall 
effectiveness of the governance and 
risk and control framework of the 
regulated companies. The Annual 
Report concluded that overall the 
regulated companies’ documented 
risk and control governance 
framework is effective at mitigating 
the major risks to the Group.

On behalf of the Risk Committee

Jeremy Brettell 
Chairman of the Risk Committee

12 December 2017

40    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

DIRECTORS’ REPORT

Indemnity provision

Auditors

The Directors present their report 
and financial statements for the year 
ended 30 September 2017.

The review of the business and 
principal risks and uncertainties are 
disclosed within the Strategic Report.

Directors

The Directors who served during the 
year were as follows:

M Howard

I A Taylor

A Scott

N J Holden

C I C Munro  
(appointed 1 February 2017)

P J R Snowball  
(appointed 1 October 2017)

J M Davidson  
(resigned 1 October 2017)

J Brettell  
(resigned 1 October 2017)

S Bazley  
(resigned 1 October 2017)

According to the Register of 
Directors’ Interests in the Company, 
no rights to subscribe for shares 
or share options were granted or 
exercised by any of the Directors or 
their immediate families during the 
financial year.

Directors’ and officers’ insurance is 
in place to indemnify the Directors 
against liabilities arising from the 
discharge of their duties as Directors 
of the Company.

BDO LLP have indicated their 
willingness to continue in office.  
A resolution to reappoint BDO LLP  
as auditors for the ensuing year will 
be proposed at the next AGM.

Employee information

The Company has no employees 
(2016: nil), but the Group has 467 
employees (2016: 447). The Group 
continues to promote a culture 
whereby employees are encouraged 
to develop and contribute to the 
overall aims of the business.

Policy on disabled employees

The Group’s policy regarding 
employment, training, career 
development and promotion of 
disabled employees, and employees 
who become disabled whilst in 
employment, is to make reasonable 
adjustments as required. 

Political donations

No political contributions were made 
during the year (2016: £nil).

Each of the persons who is a Director 
at the date of approval of this report 
confirms that:

▪  so far as the Director is aware, 

there is no relevant audit 
information of which the Company’s 
auditor is unaware; and 

▪  the Director has taken all the 

steps that he ought to have taken 
as a Director in order to make 
himself aware of any relevant audit 
information and to establish that 
the Company’s auditor is aware of 
that information. This confirmation 
is given and should be interpreted 
in accordance with the provision  
of s418 of the Companies Act 2006.

By Order of the Board

David Johnson 
Company Secretary

Registered Office 
29 Clement’s Lane  
London 
EC4N 7AE

12 December 2017

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    41

GOVERNANCE  continued

The Directors are responsible 
for keeping adequate accounting 
records that show and explain the 
Group’s transactions, disclose with 
reasonable accuracy at any time the 
financial position of the Company 
and enable them to ensure that the 
financial statements comply with the 
Companies Act 2006.

They are also responsible for 
safeguarding the assets of the 
Company and Group and hence 
for taking reasonable steps for the 
prevention and detection of fraud  
and other irregularities.

The current Directors, at the date 
of approval of this report, confirm 
that they have taken all of the 
steps that they ought to have taken 
as Directors to make themselves 
aware of any information needed 
by the Company’s auditors for the 
purposes of their audit, and to 
establish that the auditors are aware 
of that information. The Directors 
are not aware of any relevant audit 
information of which the auditors 
are unaware.

STATEMENT OF DIRECTORS’ 
RESPONSIBILITIES 

The Directors are responsible for 
preparing the Annual Report and the 
financial statements in accordance 
with the Companies Act 2006 and 
for being satisfied that the financial 
statements give a true and fair view. 

The Directors are also responsible 
for preparing the financial statements 
in accordance with International 
Financial Reporting Standards (IFRSs) 
as adopted by the European Union.

Company law requires the Directors 
to prepare financial statements for 
each financial year which give a 
true and fair view of the state of 
affairs of the Company and Group 
and of the profit or loss of the Group 
for that year. 

In preparing those financial 
statements, the Directors are 
required to:

▪  select suitable accounting policies 
and then apply them consistently

▪  make judgements and estimates 
that are reasonable and prudent

▪  state whether applicable accounting 

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

▪  prepare the financial statements on 
the going concern basis unless it is 
inappropriate to presume that the 
Company and Group will continue 
in business.

42    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

FINANCIAL STATEMENTS

INDEPENDENT AUDITOR’S 
REPORT TO MEMBERS OF 
INTEGRAFIN HOLDINGS 
LIMITED

Opinion

We have audited the financial 
statements of IntegraFin Holdings 
Limited (the Parent Company) and  
its subsidiaries (the Group) for the 
year ended 30 September 2017 
which comprise the Consolidated  
and Company Income Statement, 
Consolidated and Company 
Statement of Financial Position, 
Consolidated and Company 
Statement of Cash Flows, 
Consolidated and Company 
Statement of Changes in Equity  
and notes to the financial statements, 
including a summary of significant 
accounting policies. The financial 
reporting framework that has been 
applied in their preparation is 
applicable law and International 
Financial Reporting Standards (IFRSs) 
as adopted by the European Union.

In our opinion, the financial 
statements:

▪  give a true and fair view of the  
state of the Group’s and of the 
Parent Company’s affairs as at  
30 September 2017 and of the 
Group’s profit and the Parent 
Company’s profit for the year  
then ended;

▪  have been properly prepared in 

accordance with IFRSs as adopted 
by the European Union; and

▪  have been prepared in accordance 

with the requirements of the 
Companies Act 2006. 

Basis for opinion

We conducted our audit in accordance 
with International Standards on 
Auditing (UK) (ISAs (UK)) and 
applicable law. Our responsibilities 
under those standards are further  
described in the Auditor’s 
responsibilities for the audit of the 
financial statements section of our 
report. We are independent of the 
Group and the Parent Company 
in accordance with the ethical 
requirements that are relevant to our 
audit of the financial statements in 
the UK, including the FRC’s Ethical 
Standard, and we have fulfilled 
our other ethical responsibilities in 
accordance with these requirements. 
We believe that the audit evidence 
we have obtained is sufficient and 
appropriate to provide a basis for  
our opinion.

Conclusions relating to going 
concern 

We have nothing to report in respect 
of the following matters in relation  
to which the ISAs (UK) require us  
to report to you where:

▪  the Directors’ use of the going 
concern basis of accounting in 
the preparation of the financial 
statements is not appropriate; or

▪  the Directors have not disclosed 
in the financial statements any 
identified material uncertainties that 
may cast significant doubt about 
the Group or the Parent Company’s 
ability to continue to adopt the 
going concern basis of accounting 
for a period of at least twelve 
months from the date when the 
financial statements are authorised 
for issue.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    43

FINANCIAL STATEMENTS  continued

Other information

The Directors are responsible for  
the other information. The other 
information comprises the 
information included in the annual 
report, other than the financial 
statements and our auditor’s report 
thereon. Our opinion on the financial 
statements does not cover the other 
information and, except to the extent 
otherwise explicitly stated in our 
report, we do not express any form 
of assurance conclusion thereon. 

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 such material 
inconsistencies or apparent 
material misstatements, we are 
required to determine whether 
there is a material misstatement 
in 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 in  
this regard.

Opinions on other matters 
prescribed by the  
Companies Act 2006

In our opinion, based on the work 
undertaken in the course of the audit:

▪  the information given in the 

Strategic Report and Directors’ 
report for the financial year for 
which the financial statements  
are prepared is consistent with  
the financial statements; and

▪  the Strategic report and Directors’ 

report have been prepared in 
accordance with applicable legal 
requirements. 

Matters on which we are required 
to report by exception

In the light of the knowledge and 
understanding of the Group and the 
Parent Company and its environment 
obtained in the course of the audit, 
we have not identified material 
misstatements in the Strategic report 
and Director’s report.

We have nothing to report in respect 
of the following matters in relation 
to which the Companies Act 2006 
requires us to report to you if,  
in our opinion;

▪  adequate accounting records 

have not been kept by the Parent 
Company, or returns adequate for 
our audit have not been received 
from branches not visited by us; or

▪  the Parent Company financial 

statements are not in agreement 
with the accounting records and 
returns; or

▪  certain disclosures of Directors’ 

remuneration specified by law are 
not made; or

▪  we have not received all the 

information and explanations we 
require for our audit.

44    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Responsibilities of Directors 

As explained more fully in  
the Statement of Director’s 
Responsibilities, the Directors are 
responsible for the preparation of the 
financial statements and for being 
satisfied that they give a true and fair 
view, and for such internal control as 
the Directors determines is necessary 
to enable the preparation of financial 
statements that are free from 
material misstatement, whether due 
to fraud or error.

In preparing the financial statements, 
the Directors are responsible for 
assessing the Group’s and the 
Parent Company’s ability to continue 
as a going concern, disclosing, as 
applicable, matters related to going 
concern and using the going concern 
basis of accounting unless the 
Directors either intend to liquidate 
the Group or the Parent Company 
or to cease operations, or have no 
realistic alternative but to do so. 

Auditor’s responsibilities for the 
audit of the financial statements 

This report is made solely to the 
Company’s members, as a body,  
in accordance with Chapter 3 of  
Part 16 of the Companies Act 2006. 
Our audit work has been undertaken 
so that we might state to the 
Company’s members those matters 
we are required to state to them 
in an auditor’s report and for no 
other purpose. To the fullest extent 
permitted by law, we do not accept 
or assume responsibility to anyone 
other than the Company and the 
Company’s members as a body,  
for our audit work, for this report,  
or for the opinions we have formed.

Our objectives are to obtain 
reasonable assurance about whether 
the financial statements as a whole 
are free from material misstatement, 
whether due to fraud or error, and to 
issue an auditor’s report that includes 
our opinion. Reasonable assurance 
is a high level of assurance, but 
is not a guarantee that an audit 
conducted in accordance with ISAs 
(UK) will always detect a material 
misstatement when it exists. 
Misstatements can arise from fraud 
or error and are considered material 
if, individually or in the aggregate, 
they could reasonably be expected 
to influence the economic decisions 
of users taken on the basis of these 
financial statements.

A further description of our 
responsibilities for the audit of the 
financial statements is located at the 
Financial Reporting Council’s website 
at: https://www.frc.org.uk/
auditorsresponsibilities.  
This description forms part of our 
auditor’s report. 

Neil Fung-On  
Senior Statutory Auditor 

For and on behalf of BDO LLP, 
statutory auditor

London

15 December 2017

BDO LLP is a limited liability 
partnership registered in England 
and Wales (with registered number 
OC305127).

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    45

FINANCIAL STATEMENTS  continued

CONSOLIDATED PROFIT AND LOSS AND OTHER COMPREHENSIVE INCOME

2017

Note

£’000

2016 
(Restated)
£’000

5

7

8

9

6

6

6

6

80,242

(599)

79,643

68,357

(488)

67,869

(42,837)

(42,122)

7,905

44,711

7,905

36,806

178

44,889

7,905

19,358

45,105

19,358

25,747

451

45,556

19,358

36,984

26,198

(7,819)

(19,445)

(7,181)

29,889

(5,296)

20,816

-

-

29,889

20,816

2639

2239

2639

2239

1841

1441

1841

1441

Revenue

Fee income

Cost of sales

Gross profit

Administrative expenses

Net income attributable to policyholder returns

Operating profit

Operating profit attributable to policyholder returns

Operating profit attributable to shareholder returns

Interest income

Profit on ordinary activities before taxation

Profit on ordinary activities before taxation attributable to 
policyholder returns

Profit on ordinary activities before taxation attributable to 
shareholder returns

Policyholder tax

Tax on profit on ordinary activities

Profit after tax 

Other comprehensive income

Profit for the financial year

Earnings per share

Ordinary A, B and C shares – basic (pence)

Ordinary D shares – basic (pence)

Ordinary A, B and C shares – diluted (pence)

Ordinary D shares – diluted (pence)

All activities of the Group are classed as continuing.

Notes 1 to 33 form part of these financial statements

46    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

COMPANY PROFIT AND LOSS AND OTHER COMPREHENSIVE INCOME

Revenue

Cost of sales

Gross profit

Administrative expenses

Operating profit

Dividend income

Interest income

Profit on ordinary activities before taxation

Tax on profit on ordinary activities

Profit after tax

Other comprehensive income

Profit for the financial year

All activities of the Company are classed as continuing.

Note

7

8

9

2017
£’000

-

(-)

-

(1,015)

(1,015)

19,281

24

18,290

-

18,290

-

2016
£’000

-

(-)

-

(1,010)

(1,010)

39,649

2

38,641

(78)

38,563

-

18,290

38,563

Notes 1 to 33 form part of these financial statements

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    47

FINANCIAL STATEMENTS  continued

CONSOLIDATED STATEMENT OF FINANCIAL POSITION

Non-current assets
Loans and receivables
Intangible assets
Property, plant and equipment
Deferred acquisition costs
Investments and cash held for the benefit of policyholders

Current assets
Financial assets at fair value through profit or loss
Other prepayments and accrued income
Trade and other receivables
Current tax assets
Cash and cash equivalents

Current Liabilities
Trade and other payables
Current tax liabilities

Non-current liabilities
Provisions for liabilities 
Deferred income liability
Liabilities for linked investment contracts
Deferred tax liabilities

Net assets

Capital and reserves
Called up equity share capital
Share premium account
Capital redemption reserve
Share-based payment reserve
Other reserves
Non-distributable reserves
Profit or loss account
Total equity

30 September 
2017
£’000

30 September 
2016
£’000

Note

10
11
13
14

15
16
17

18

22
19
14
20

23
24
25
26
27

1,873
12,986
1,858
38,295
11,947,652
12,002,664

-
13,006
2,072
31,792
11,316,471
11,363,341

8,895
10,252
1,456
-
105,829
126,432

15,208
2,803
18,011

8,976
9,842
 1,597
199
90,571
111,185

14,289
1,685
15,974

11,831
38,295
11,947,652
10,781
12,008,559

15,550
31,792
11,316,471
8,495
11,372,308

102,526

86,244

57
5,722
2
308
42
501
95,894
102,526

57
5,722
2
308
32
501
79,622
86,244

These financial statements were approved by the Board of Directors on 12 December 2017 and are signed on their behalf by:

Ian Taylor, Director 
Company Registration Number: 08860879

Notes 1 to 33 form part of these financial statements

48    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

COMPANY STATEMENT OF FINANCIAL POSITION

Non-current assets

Investment in subsidiaries

Loans and receivables

Deferred tax asset

Current assets

Other receivables

Cash and cash equivalents

Current liabilities

Trade and other payables

Net assets

Capital and reserves

Called up equity share capital

Profit or loss account

Total equity

30 September 
 2017
£’000

30 September 
 2016
£’000

Note

12

20

17

18

23

14,213

1,873

-

16,086

7

20,081

20,088

1,156

1,156

14,213

-

-

14,213

9

16,422

16,431

388

388

35,018

30,256

57

34,961

35,018

57

30,199

30,256

These financial statements were approved by the Board of Directors on 12 December 2017 and are signed on their 

behalf by:

Ian Taylor 
Director

Company Registration Number: 08860879

Notes 1 to 33 form part of these financial statements

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    49

FINANCIAL STATEMENTS  continued

CONSOLIDATED STATEMENT OF CASH FLOWS

Cash flows from operating activities

Profit before tax

Adjustments for:

Amortisation and depreciation

Interest

Decrease/(increase) in loans and receivables

(Decrease)/increase in payables

Decrease/(increase) in current asset investments

Decrease/(increase) in long term investments

Decrease/(increase) in provisions

Cash generated from operations

Income taxes paid

Net cash flows from operating activities

Investing activities

Acquisition of tangible assets

Acquisition of subsidiary

Interest received

Net cash used in investing activities

Financing activities

Equity dividends paid

Net cash used in financing activities

2017
£’000

2016
£’000

44,889

45,556

571

(178)

(2,142)

920

81

-

(1,432)

42,709

(13,684)

29,025

(434)

-

178

(256)

(13,521)

(13,521)

1,932

(451)

4,213

5,579

(2,031)

392

(5,252)

49,938

(24,149)

25,789

(730)

(13,505)

451

(13,784)

(9,652)

(9,652)

Net increase in cash and cash equivalents

15,248

2,353

Cash and cash equivalents at beginning of year

Exchange gains on cash and cash equivalents

Cash and cash equivalents at end of year

90,571

10

105,829

88,186

32

90,571

Notes 1 to 33 form part of these financial statements

50    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

COMPANY STATEMENT OF CASH FLOWS

Cash flows from operating activities

Profit before tax

Adjustments for:

Interest

Decrease/(increase) in long term investments

Decrease/(increase) in loans and receivables

(Decrease)/increase in payables

Cash generated from operations

Investing activities

Interest received

Net cash used in investing activities

Financing activities

Equity dividends paid

Net cash used in financing activities

2017
£’000

2016
£’000

18,290

38,641

(24)

-

(1,872)

769

(2)

(13,764)

(9)

311

17,163

25,177

24

24

2

2

(13,528)

(13,528)

(8,978)

(8,978)

Net increase in cash and cash equivalents

3,659

16,201

Cash and cash equivalents at beginning of year

Cash and cash equivalents at end of year

16,422

20,081

221

16,422

Notes 1 to 33 form part of these financial statements

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    51

FINANCIAL STATEMENTS  continued

CONSOLIDATED STATEMENT OF CHANGES IN EQUITY

Share 
capital

Share 
premium

Other 
reserve

Share 
based 
payment 
reserve

Non-
distrib-
utable 
reserve

Retained 
earnings

Total 
equity

£’000

£’000

£’000

£’000

£’000

£’000

£’000

Balance at 1 October 2015

57

5,722

2

308

501

68,376

74,966

Comprehensive income for 
the year:

Profit for the year

Other comprehensive income

Other movement

Total comprehensive income 
for the year

Distributions to owners:

Dividends

Total distributions to owners

–

–

–

–

–

–

–

–

–

–

–

–

Balance at 1 October 2016

57 

5,722

Comprehensive income for 
the year:

Profit for the year

Other comprehensive income

Other movement

Total comprehensive income 
for the year

Distributions to owners:

Dividends

Total distributions to owners

–

–

–

–

–

–

–

–

–

–

–

–

Balance at 30 September 2017

57

5,722

–

32

–

32

–

–

34

–

10

–

10

–

–

44

–

–

–

–

–

–

–

–

–

–

–

–

20,816

20,816

–

82

32

82

20,898

20,930

(9,652)

(9,652)

(9,652)

(9,652)

308

501

79,622

86,244

–

–

–

–

–

–

–

–

–

–

29,889

29,889

–

(96) 

10

(96)

29,793

29,803

–

(13,521)

(13,521)

– (13,521)

(13,521)

308

501

95,894

102,526

Notes 1 to 33 form part of these financial statements

52    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

COMPANY STATEMENT OF CHANGES IN EQUITY

Share 
capital 
£’000

Share 
premium 
£’000

Capital 
redemption 
reserve 
£’000

Share 
based 
payment 
reserve 
£’000

Balance at 1 October 2015

Comprehensive income for 
the year:

Profit for the year

Total comprehensive income for 
the year

Distributions to owners:

Dividends

Total distributions to owners

Balance at 1 October 2016

Comprehensive income for  
the year:

Profit for the year

Total comprehensive income for 
the year

Distributions to owners:

Dividends

Total distributions to owners

57

-

-

-

-

57

-

-

-

-

Balance at 30 September 2017

57

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Retained 
earnings 
£’000

Total  
equity 
£’000

614

671

38,563

38,563

38,563

38,563

(8,978)

(8,978)

(8,978)

(8,978)

30,199

30,256

18,290

18,290

18,290

18,290

(13,528)

(13,528)

(13,528)

(13,528)

34,961

35,018

Notes 1 to 33 form part of these financial statements

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    53

FINANCIAL STATEMENTS  continued

NOTES TO THE FINANCIAL STATEMENTS

1.  Basis of preparation and significant accounting policies

a) Basis of preparation

The financial statements have been prepared and approved by the Directors in accordance with Part 15 of the 
Companies Act 2006, Schedule 3 of the Large and Medium-sized Companies and Groups (Accounts and Reports) 
Regulations 2008 and International Financial Reporting Standards (IFRSs) as adopted by the EU. 

The financial statements have been prepared on the historical cost basis, except for the revaluation of certain financial 
instruments, which are stated at their fair value, have been prepared in pound sterling, which is the functional 
currency of the Company and are rounded to the nearest thousand. 

There have been a number of presentational changes to the Consolidated Profit and Loss and Other Comprehensive 
Income statement, leading to the restatement of certain prior year figures. The purpose of this is to make the 
accounts more understandable to the user by splitting out policyholder income and expenses in a clear way.  
These changes are all presentational, and there is no change to the profit for the financial year figure.

The financial statements have been prepared on a going concern basis following an assessment by the Directors.  
The Company has a net asset position, strong solvency position, is currently profitable and, based on the latest 
forecasts, expects to remain profitable. As a result, the Board has reasonable expectation that the Company has 
adequate resources to continue in operational existence from at least 12 months from the date of approving these 
financial statements. 

Basis of consolidation

The consolidated financial statements incorporate the financial statements of the Company and its subsidiaries.  
Where the company has control over an investee, it is classified as a subsidiary. The company controls an investee 
if all three of the following elements are present: power over the investee, exposure to variable returns from the 
investee, and the ability of the investor to use its power to affect those variable returns. Control is reassessed whenever 
facts and circumstances indicate that there may be a change in any of these elements of control. Subsidiaries are fully 
consolidated from the date on which control is obtained by the Company and are deconsolidated from the date that 
control ceases. Acquisitions are accounted for under the acquisition method. Intercompany transactions, balances, 
income and expenses, and profits and losses are eliminated. 

The financial statements of all of the wholly owned subsidiary companies are incorporated into the consolidated 
financial statements. Two of these subsidiaries, IntegraLife International Limited (ILInt) and IntegraLife UK Limited 
(ILUK) issue contracts with the legal form of insurance contracts, but which do not transfer significant insurance risk 
from the policyholder to the Company, and which are therefore accounted for as investment contracts. In accordance 
with IAS 39, the contracts concerned are therefore reflected in the consolidated statement of financial position as 
investments held for the benefit of policyholders, and a corresponding liability to policyholders.

b)  Future standards, amendments to standards, and interpretations not early-adopted in the 2017 annual 

financial statements.

At the date of authorisation of these financial statements the following standards, amendments to standards, and 
interpretations, which are relevant to the Group, have been issued by the International Accounting Standards Board.

IFRS 9 Financial Instruments 

The IASB has issued IFRS 9 Financial Instruments to replace lAS 39 ‘Financial Instruments: Recognition and Measurement’ 
in its entirety. The project has three main phases:

▪  Phase I: Classification and measurement of financial instruments;

▪  Phase II: Amortised cost and impairment of financial assets; and

▪  Phase III: Hedge Accounting.

54    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

IFRS 9 includes requirements for the classification and measurement of financial assets and liabilities, liability 
derecognition requirements and additional disclosure requirements. The main changes from IAS 39 include 
the following:

▪  Financial assets are to be classified and measured based on the business model for managing the financial asset  

and the cash flow characteristics of the financial asset, either at fair value or amortised cost; 

▪  A financial asset or liability that would otherwise be at amortised cost may only be designated as at fair value 

through profit or loss if such a designation reduces an accounting mismatch; and

▪  For financial liabilities designated as at fair value through profit or loss a further requirement is that all changes  
in the fair value of financial liabilities attributable to credit risk be transferred to ‘Other Comprehensive Income’  
with no recycling through profit or loss on disposal.

This standard has been endorsed by the EU and is effective for accounting periods beginning on or after 1 January 
2018. An assessment of the impact of IFRS 9 has been conducted and there is no material impact on the Group on 
its adoption.

IFRS 15 Revenue from Contracts with Customers

The standard provides a comprehensive new model for revenue recognition. The Company will be required to disclose 
information about its contracts with customers, disaggregating information about recognised revenue and information 
about its performance obligations at the end of the reporting period.

This standard has been endorsed by the EU and is effective for accounting periods beginning on or after 1 January 2018. 
An assessment of the impact of IFRS 15 has been conducted and there is no material impact on the Group its adoption.

IFRS 16 Leases

The new standard brings most leases on-balance sheet for lessees under a single lessee accounting model, 
eliminating the distinction between operating and finance leases.

This standard is effective for accounting periods beginning on or after 1 January 2019; it is yet to be endorsed by the 
EU. An initial assessment of the impact of this standard has been conducted, which indicates that whilst there will be 
a material adjustment to gross assets and liabilities as a result of bringing leased assets on balance sheet, there is 
unlikely to be a material net impact at Group level.

IFRS 17 Insurance Contracts

IFRS 17 was issued in May 2017 and will replace IFRS 4 Insurance Contracts. IFRS 17 establishes the principles for 
the recognition, measurement, presentation and disclosure of insurance contracts within the scope of the Standard. 
The Company would be required to provide information that faithfully represent those contracts, such that users of 
the financial statements can assess the effect insurance contracts have on the entity’s financial position, financial 
performance and cash flows. The standard is effective for accounting periods beginning on or after 1 January 2021.

The Group has performed preliminary assessment regarding the impact of IFRS 17 on the financial statements and, 
due to all contracts written by the business being insurance contracts, it is deemed such impact will be negligible.

c) Critical accounting estimates and judgements

Critical accounting estimates are those which involve the most complex or subjective judgements or assessments.  
The areas of the Group’s business that typically require such estimates are the determination of the fair value  
for financial assets, impairment charges, deferred acquisition costs, deferred fee income and deferred taxes.  
Each of these is discussed in more detail in the relevant accounting policies and notes to the financial statements.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    55

FINANCIAL STATEMENTS  continued

d) Principal accounting policies

Revenue recognition

Revenue represents the fair value of services supplied by the Group. The main revenue streams comprise: charges 
levied on the acquisition of assets, due when transactions complete; annual commission levied on the value of assets 
and cash held on the platform, due at the end of each month; and an annual wrapper charge levied on certain 
wrapper types, due at the end of each quarter. Charges are levied on Portfolios as stated in the Transact Terms and 
Conditions. Revenue is recognised as follows:

Fee income

Fees charged for managing investment contracts comprise fees taken both on inception and throughout the life of the 
contract. All fee income is recognised as revenue in line with the provision of the investment management services.

Deferred acquisition costs and deferred income liabilities

Incremental costs directly attributable to securing investment contracts are deferred. These costs consist of fees paid 
to policyholder financial advisers. The costs are capitalised as deferred acquisition costs and are amortised as an 
expense over the Directors’ best estimate of the life of the contract which is deemed to be ten years, as the services 
are provided. Equal service provision is assumed over the lifetime of the contract and, as such, the deferred costs are 
amortised on a linear basis over the expected life of the contract, adjusted for expected persistency. 

A corresponding deferred income liability is recognised in respect of charges taken from customers of the Company 
at the contracts’ inception to meet obligations to financial advisers. Deferred income liabilities are also amortised over 
the Director’s best estimate of the life of the contract, which is again deemed to be ten years.

Investment income

Interest on cash and coupon on shareholder gilts are the two sources of investment income received. Interest income 
is accrued on a time basis, by reference to the principal outstanding and at the effective interest rate applicable, 
which is the rate that exactly discounts estimated future cash receipts through the expected life of the financial asset 
to that financial asset’s carrying amount.

Investments

Fixed asset investments in subsidiaries are stated at cost less any provision for impairment.

Other investments comprise UK Government fixed interest securities backing insurance contracts or held as 
shareholder investments. All investments are classified as ‘fair value through profit or loss at initial recognition’ and 
are stated at quoted bid prices which equates to fair value, with any resultant gain or loss recognised in profit or loss. 
Purchases and sales of securities are recognised on the trade date.

Investment contracts – investments and cash held for the benefit of policyholders

Investment contracts are comprised of unit-linked contracts in ILInt and ILUK. Investment contracts result in financial 
liabilities whose fair value is dependent on the fair value of underlying financial assets. They are designated at 
inception as financial liabilities at ‘fair value through profit or loss’. 

Valuation techniques are used to establish the fair value at inception and each reporting date. The Company’s main 
valuation techniques incorporate all factors that market participants would consider and are based on observable 
market data. The financial liability is measured both initially and subsequently at fair value. The fair value of a unit-linked 
financial liability is determined using the fair value of the financial assets contained within the funds linked to the 
financial liability.

56    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Dividends

Equity dividends are recognised when they become legally payable. Interim equity dividends are recognised when paid.

Liquid resources

For the purposes of the statement of cash flows, liquid resources are defined as current asset investments and short 
term deposits.

Intangible non-current assets

Intangible non-current assets, excluding goodwill, are stated at cost less accumulated amortisation and comprise 
intellectual property software rights. Intellectual property rights are amortised over seven years on a straight line 
basis as it is considered that the code is replaced every seven years, and therefore has a finite useful life.  
Goodwill is held at cost and, in accordance with IFRS, is not amortised but is subject to annual impairment reviews. 

Property, plant and equipment

Property, plant and equipment are stated at cost less accumulated depreciation and accumulated impairment losses. 
Cost includes expenditures that are directly attributable to the acquisition of the asset. Subsequent costs are included 
in the asset’s carrying amount or recognised as a separate asset, as appropriate, only when it is probable that future 
economic benefits associated with the item will flow to the Company and the cost can be measured reliably.  
Repairs and maintenance costs are charged to the profit and loss and other comprehensive income statement  
during the period in which they are incurred.

The major categories of property, plant and equipment are depreciated on a straight-line basis as follows:

Short Leasehold Land and Buildings 
Fixtures & Fittings 
Equipment 

Over 10 years/over the life of the lease 
Over 10 years 
Over 3-5 years

Residual values, method of depreciation and useful lives of the assets are reviewed annually and adjusted if appropriate.

Impairment of non-financial assets

Property, plant and equipment and intangible assets are tested for impairment when events or changes in circumstances 
indicate that the carrying amount may not be recoverable. Recoverable amount is the higher of an asset’s fair value 
less costs to sell and value in use (being the present value of the expected future cash flows of the relevant asset).

The Company evaluates impairment losses for potential reversals when events or circumstances warrant such 
consideration.

Goodwill is tested for impairment annually, and once an impairment is recognised this cannot be reversed. For more 
detailed information in relation to this, please see Note 10.

Pensions

The Group makes defined contributions to the personal pension schemes of its employees. These are chargeable  
to profit or loss in the year in which they become payable.

Foreign currencies

Transactions in foreign currencies are translated into the functional currency at the exchange rate in effect at the  
date of the transaction. Foreign currency monetary assets and liabilities are translated to sterling at the year end 
closing rate. Non-monetary assets denominated in a foreign currency that are measured in terms of historical cost  
are translated using the exchange rate in effect at the date when the fair value was determined. Foreign exchange 
rate differences that arise are reported net in profit or loss as foreign exchange gains/losses.

The assets and liabilities of foreign operations are translated to sterling using the year end closing exchange rate.  
The revenues and expenses of foreign operations are translated to sterling at rates approximating the foreign 
exchange rates ruling at the relevant month of the transactions. Foreign exchange differences arising on retranslation 
are recognised directly in the reserves.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    57

 
 
 
 
 
FINANCIAL STATEMENTS  continued

Taxation

The taxation charge is based on the taxable result for the year. The taxable result for the year is determined in accordance 
with enacted legislation and taxation authority practice for calculating the amount of corporation tax payable. 

Deferred tax assets and liabilities are recognised where the carrying amount of an asset or liability in the statement  
of financial position differs from its tax base. Recognition of deferred tax assets is restricted to those instances where 
it is probable that taxable profit will be available against which the difference can be utilised. 

The amount of the asset or liability is determined using tax rates that have been enacted or substantively enacted by 
the reporting date and are expected to apply when the deferred tax assets/liabilities are recovered/settled.

Segmental reporting

Operating segments are reported in a manner consistent with the internal reporting provided to the chief operating 
decision-maker. The chief operating decision-maker is responsible for allocating resources and assessing performance 
of the operating segments and has been identified as the chief executive officer of the Company.

For the year ended 30 September 2017, the business of ILUK and ILInt was the direct insurance of investment linked 
pensions business, written by single premium in the United Kingdom, single premium life assurance linked bonds and 
linked qualifying investment plans written in the United Kingdom. Insurance risk is minimal as all contracts have been 
classed as investment contracts.

ILInt and ILUK policyholder assets and liabilities

Investments held for the benefit of policyholders are stated at fair value and reported on a separate line in the 
statement of financial position. The assets are classified using the ‘fair value through profit or loss’ option with any 
resultant gain or loss recognised through the income statement. Investments held for the benefit of policyholders also 
includes cash and cash equivalents held within policyholders’ portfolios of assets.

Investment inflows received from policyholders are invested in funds selected by the policyholders. The resulting 
liabilities for linked investment contracts are accounted for under the ‘fair value through profit or loss’ option, in line 
with the corresponding assets as permitted by IAS 39.

As all investments held for the benefit of policyholders are matched entirely by corresponding linked liabilities,  
any gain or loss on assets recognised through the income statement are offset entirely by the gains and losses on 
linked liabilities. The net impact on profit is therefore £nil.

Client assets and client monies

IFAL client assets and client monies are not recognised in the parent and consolidated statements of financial position 
(see Note 21) as they are owned by the clients of IFAL.

Operating lease agreements

Rental costs under operating leases are charged to the statement of profit or loss and other comprehensive income on 
a straight line basis over the term of the lease. Where an incentive to sign the lease has been taken, the incentive is 
spread on a straight line basis over the lease term. Details of the operating lease commitments are set out in Note 28.

Cash and cash equivalents

Cash and cash equivalents comprise cash balances, call deposits, money market OEIC funds and other short-term 
deposits with an original maturity of three months or less. The carrying amount of these assets approximates to their 
fair value.

58    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Financial instruments

Financial assets and liabilities are recognised when the Company becomes a party to the contractual provisions  
of the instrument. Financial assets are derecognised when the rights to receive cash flows from the assets have 
expired or have been transferred and the Company has transferred substantially all risks and rewards of ownership. 
Financial liabilities are derecognised when the obligation specified in the contract is discharged, cancelled or expires.

At initial recognition, the Company classifies its financial instruments in the following categories:

(i)	 Financial	assets	and	liabilities	at	fair	value	through	profit	or	loss

 A financial asset or liability is classified in this category if acquired principally for the purpose of selling or 
repurchasing in the short-term.

 Financial instruments in this category are recognised on the trade settlement date, and subsequently at fair 
value. Purchases and sales of securities are recognised on the trade date. Transaction costs are expensed in the 
consolidated profit and loss and other comprehensive income statement. Gains and losses arising from changes 
in fair value are presented in the consolidated profit and loss and other comprehensive income statement 
within “administrative expenses” for corporate assets and “net income attributable to policyholder returns” for 
policyholder assets in the period in which they arise. Financial assets and liabilities at fair value through profit  
or loss are classified as current except for the portion expected to be realised or paid beyond twelve months of 
the balance sheet date, which are classified as long-term. 

(ii)  Loans and receivables 

 Loans and receivables are non-derivative financial assets with fixed or determinable payments that are not 
quoted in an active market. The Company’s loans and receivables comprise accrued fees, trade and other 
receivables, loans and cash and cash equivalents. These are included in current assets due to their short-term 
nature, except for loans which are included in non-current assets. Loans and receivables are initially recognised 
at the amount expected to be received, less, when material, a discount to reduce the loans and receivables 
to fair value. Subsequently, loans and receivables are measured at amortised cost using the effective interest 
method less any provisions for impairment.

(iii) Financial liabilities at amortised cost

 Financial liabilities at amortised cost comprise trade and other payables. These are initially recognised at the 
amount required to be paid, less, when material, a discount to reduce the payables to fair value. Subsequently, 
trade payables are measured at amortised cost using the effective interest method. They are classified as current 
liabilities due to their short-term nature.

Provisions for liabilities

Provisions are recognised when the Company has an obligation, legal or constructive, as a result of a past event, and 
it is probable that the Company will be required to settle that obligation. Provisions are estimated at the Directors’ 
best estimate of the expenditure required to settle the obligation at the reporting date, and are discounted to present 
values where the effect is material.

Trade and other payables

Other payables are short-term, not interest-bearing and are stated at their amortised cost which is not materially 
different to cost and approximates to fair value.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    59

 
 
 
 
FINANCIAL STATEMENTS  continued

2.  Critical accounting estimates and judgements

In preparing these financial statements, management has made judgements, estimates and assumptions about the 
future that affect the application of the Group’s accounting policies and the reported amounts of assets, liabilities, 
income and expenses. Actual results may differ from these estimates.

Estimates and underlying assumptions are reviewed on an ongoing basis. Revisions to estimates are recognised 
prospectively.

Impairment of accrued fees pending

The Group has recognised an impairment of £128,073 (2016: £181,460) for accrued fees owed by customers.  
This comprises accrued fees that have not been received after three months, and also all fees due on portfolios that 
comprise only limited liquidity assets. Management believes, based on past experience, that these fees are unlikely  
to be received, and an impairment has therefore been recorded in the statement of profit or loss. 

In addition to the above, an amount of £192,103 (2016: £155,839) relates to accrued fees that are past due but not 
impaired. Management believes that these fees are likely to be received, and an impairment is therefore not required. 

Impairment	of	financial	assets

At each reporting date, the Company assesses whether there is objective evidence that a financial asset (other than 
a financial asset classified as fair value through profit or loss) is impaired. A financial asset is only impaired if there 
is objective evidence of impairment as a result of one or more events that have occurred after the initial recognition 
of the asset (a ”loss event”) and that loss event (or events) has an impact on the estimated future cash flows of the 
receivable that can be reliably estimated.

The criteria used to determine objective evidence of an impairment loss include:

(i)  significant financial difficulty of the obligor;

(ii)   delinquencies in interest or principal payments; and

(iii)   it becomes probable that the borrower will enter bankruptcy or other financial reorganisation.

For equity securities, a significant or prolonged decline in the fair value of the security below its cost is also evidence 
that the assets are impaired.

If such evidence exists, the Company recognises an impairment loss, as follows:

(i) 

 Financial assets carried at amortised cost: The loss is the difference between the amortised cost of the loan  
or receivable and the present value of the estimated future cash flows, discounted using the instrument’s original 
effective interest rate. The carrying amount of the asset is reduced by this amount and the amount of the loss  
is recognised in the profit or loss for the period.

60    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

3.  Financial instruments

(i)	 Principal	financial	instruments

The principal financial instruments, from which financial instrument risk arises, are as follows:

▪ Trade and other receivables

▪ Accrued fees

▪ Cash and cash equivalents

▪ Investments in quoted debt instruments

▪ Listed shares and securities

▪ Trade and other payables

▪ Loans.

(ii)  Financial instruments by category 

 As explained in Note 1, financial assets and liabilities have been classified into categories that determine their basis 
of measurement and, for items measured at fair value, whether changes in fair value are recognised in the profit and 
loss and other comprehensive income statement. The following tables show the carrying values of assets and liabilities 
for each of these categories.

Financial assets:

Fair value through profit or loss

Amortised cost

30 Sep 
2017 
£’000

30 Sep 
2016 
£’000

30 Sep 
2017 
£’000

30 Sep 
2016 
£’000

Cash and cash equivalents

Listed shares and securities

Loans and receivables

-

83

-

-

51

-

Investments in quoted debt instruments

8,812

8,925

Accrued income

Trade and other receivables

Investments and cash held for the 
policyholders

Current tax asset

-

-

-

-

11,947,652

11,316,471

-

-

105,829

90,571

-

1,873

-

7,951

1,456

-

-

-

-

-

6,806

1,597

-

199

Total financial assets

11,956,547

11,325,447

117,109

99,173

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    61

FINANCIAL STATEMENTS  continued

Financial liabilities:

Trade and other payables

PAYE and other taxation

Corporation tax

Accruals

Fair value through profit or loss

Amortised cost

30 Sep 
2017 
£’000

30 Sep 
2016 
£’000

-

-

-

-

-

-

-

-

30 Sep 
2017 
£’000

7,524

1,229

2,803

6,454

-

30 Sep 
2016 
£’000

5,800

1,621

1,685

6,867

-

Liabilities for linked investments contracts

11,947,652

11,316,471

Total financial liabilities

11,947,652

11,316,471

18,010

15,973

(iii) Financial instruments not measured at fair value

 Financial instruments not measured at fair value include cash and cash equivalents, accrued fees, loans, trade and 
other receivables, and trade and other payables. Due to their short-term nature and/or annual impairment review,  
the carrying value of these financial instruments approximates their fair value.

(iv) Financial instruments measured at fair value – fair value hierarchy

The table opposite classifies financial assets that are recognised on the statement of financial position at fair value  
in a hierarchy that is based on significance of the inputs used in making the measurements. The levels of hierarchy 
are disclosed in Note 1.

Investments held for the benefit of policyholders are stated at fair value and reported on a separate line in the 
statement of financial position. The assets are classified using the ‘fair value through profit or loss’ option with any 
resultant gain or loss recognised through the income statement. 

Assets held at fair value also comprises investments held in gilts, and these are held at fair value through profit and loss.

The following table shows the Company’s assets measured at fair value and split into the three levels described below: 

▪ Level 1: quoted prices (unadjusted) in active markets for identical assets; 

▪  Level 2: inputs other than quoted prices included within Level 1 that are observable for the asset either directly  

(i.e. as prices) or indirectly (i.e. derived from prices); and

▪ Level 3: inputs for the asset that are not based on observable market data (unobservable inputs).

62    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Level 1 
£’000

Level 2 
£’000

Level 3 
£’000

Total 
£’000

1,091,744

351,308

12,378

11,716,405

8,895

-

94,521

399

132,113

227,033

-

-

1,091,744

1,541

5

2,668

4,214

-

447,370

12,782

10,395,756

11,947,652

8,895

11,725,300

227,033

4,214

11,956,547

Level 1 
£’000

Level 2 
£’000

Level 3 
£’000

Total 
£’000

- Holdings in collective investment schemes

10,260,975

At 30 September 2017

Investments and assets held for the 
benefit of policyholders

- Policyholder cash 

- Investments and securities

- Bonds and other fixed-income securities

Other investments

Total

At 30 September 2016 

Investments and assets held for the 
benefit of policyholders

- Policyholder cash

- Investments and securities

- Bonds and other fixed-income securities

802,924

306,461

11,035

-

65,480

12,743

-

1,885

1,606

2,235

802,924

373,826

25,384

10,114,337

- Holdings in collective investment schemes

8,069,840

2,042,262

Other investments

Total

Level 1 valuation methodology

9,190,260

2,120,485

5,726

11,316,471

8,976

-

-

8,976

9,199,236

2,120,485

5,726

11,325,447

Financial assets included in Level 1 are measured at fair value using quoted mid prices that are available at the 
reporting date and are traded in active markets. These financial assets are mainly collective investment schemes  
and listed equity instruments.

Level 2 and Level 3 valuation methodology

The Group regularly reviews whether a market is active, based on available market data and the specific 
circumstances of each market. Where the Group assesses that a market is not active, then it applies one or more 
valuation methodologies to the specific financial asset. These valuation methodologies use quoted market prices 
where available, and may in certain circumstances require the Group to exercise judgement to determine fair value.

Financial assets included in Level 2 are measured at fair value using observable mid prices traded in markets that 
have been assessed as not active enough to be included in Level 1.

Otherwise, financial assets are included in Level 3. These are assets where one or more inputs to the valuation 
methodology are not based on observable market data.

Level 3 sensitivity to changes in unobservable measurements

For financial assets assessed as Level 3, based on its review of the prices used, the Company believes that any 
change to the unobservable inputs used to measure fair value would not result in a significantly higher or lower fair 
value measurement at year end, and therefore would not have a material impact on its reported results. 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    63

 
 
 
 
 
 
 
 
 
FINANCIAL STATEMENTS  continued

Changes to valuation methodology

There have been no changes in valuation methodology during the year under review. 

Transfers between Levels

The Company’s policy is to assess each financial asset it holds at the current financial year-end, based on the last 
known price and market information, and assign it to a Level. 

The Company recognises transfers between Levels of the fair value hierarchy at the end of the reporting period  
in which the changes have occurred. Changes occur due to the availability of (or lack thereof) quoted prices,  
whether a market is now active or not, and whether there are indications of impairment.

Transfers between Levels between 30 September 2016 and 30 September 2017 are presented in the table below  
at their valuation at 30 September 2017:

Transfers from

Transfers to

Level 1

Level 2

Level 2

Level 1

 £’000 

4,073

9,169

The reconciliation between opening and closing balances of Level 3 assets are presented in the table below  
(all balances are in £’000s):

Opening balance

Unrealised gains or losses in the year ended 30 September 2017

Transfers in to Level 3 at 30 September 2017 valuation

Transfers out of Level 3 at 30 September 2016 valuation

Purchases, sales, issues and settlement

Closing balance

£’000

5,726

(1,890)

1,506

(622)

(506)

4,214

Any resultant gains or losses on financial assets held for the benefit of policyholders are offset by a reciprocal 
movement in the linked liability.

64    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

4.  Risk and risk management

This note supplements the details provided in the Risk and Risk Management section of this report on pages 19 to 26.

Risk assessment

Risk assessment is the determination of quantitative values and/or qualitative judgements of risk related to a concrete 
situation and a recognised threat. Quantitative risk assessment requires calculations of two components of risk,  
the magnitude of the potential impact, and the likelihood that the risk materialises. There are also qualitative aspects 
that are more difficult to express quantitatively, but are still taken into account in order to fully evaluate the impact of 
the risk on the organisation.

(1) Market risk

Description of risk

Market risk is the risk of loss arising either directly or indirectly from fluctuations in the level and in the volatility  
of market prices of assets, liabilities and other financial instruments.

Market risk from reduced income

The Company’s dividend income from its regulated subsidiary IFAL is exposed to market risk. IFAL’s main source of 
income is derived from annual management fees and transaction fees which are linked to the value of the clients’ portfolios.

IFAL mitigates the second order market risk by applying fixed per policy charges in addition to the charges determined 
based on clients’ linked portfolio values, offering an element of diversification to its income stream.

Market risk from direct asset holdings

The Company has limited exposure to primary market risk as its capital is invested in high quality, highly liquid,  
short-dated investments.

(a) Interest rate risk

The Company’s balance sheet and capital requirements are relatively insensitive to first order impacts from 
movements in interest rates. 

(b) Currency risk

The Company is not directly exposed to significant currency risk.

(c) Inflation risk

The Company has exposure related to expense inflation risk, where actual inflation deviates from expectations.  
The Company has no exposures to defined benefit staff pension schemes or client related index linked liabilities.

Expense inflation risk is mitigated through monitoring of expenditure and closely managing expenses in line with  
the business plan. 

(2) Credit (counterparty default) risk

Credit risk is the risk that the Company is exposed to a loss if another party fails to meet its financial obligations.  
For the Company, the exposure to counterparty default risk arises primarily from:

▪ Corporate debt assets directly held by the Company; and

▪ exposure to other debtors. 

Counterparty default risk exposure to other debtors

The Company has no prepayments or other debtors arising, due to the nature of its business, and the structure  
of the Group.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    65

FINANCIAL STATEMENTS  continued

Impact of credit risk on fair value

Due to the limited direct exposure that the Company has to credit risk, credit risk does not have a material impact 
on the fair value movement of financial instruments for the year under review. The fair value movements on these 
instruments are predominantly due to changes in market conditions.

(3) Liquidity risk

Liquidity risk is the risk that funds are not accessible such that the Company, although solvent, does not have sufficient 
liquid financial resources to meet obligations as they fall due, or can secure such resources only at excessive cost.

As a holding company, the Company’s direct liquidity risk is limited to paying out dividends and operating expenses it 
may incur. There are robust controls in place to mitigate liquidity risk, for example, through monitoring of expenditure 
and closely managing expenses in line with the business plan.

Maturity schedule

The following table shows an analysis of the financial assets and financial liabilities by remaining expected maturities 
as at 30 September 2016 and 30 September 2017.

Financial assets:

2016

Up to 3 
months 
£’000

3-12 
 months 
£’000

1-5 years 
£’000

Over  
5 years 
£’000

Total 
£’000

Investments and cash held for the 
policyholders

11,316,471

Investments

Accrued income

Trade and other receivables

Current tax asset

Cash

Total

2017

Investments and cash held for the 
policyholders

Investments

Accrued income

Trade and other receivables

Loans

Cash

Total

51

6,806

1,576

-

90,571

-

8,925

-

21

199

-

11,415,475

9,145

-

-

-

-

-

-

- 

-

-

-

-

-

-

11,316,471

8,976

6,806

1,597

199

90,571

-  11,424,620

Up to 3 
months 
£’000

3-12  
months 
£’000

1-5 years 
£’000

Over  
5 years 
£’000

Total 
£’000

11,947,652

-

-

8,812

7,906

1,557

-

105,829

-

20

-

-

-

-

7

-

1,040

-

-

-

-

-

833

-

11,947,652

8,812

7,913

1,577

1,873

105,829

12,062,944

8,832

1,047

833 12,073,656

66    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Trade and other payables

Current tax liabilities

Total

2017

Financial liabilities:

2016

Up to  
3 months 
£’000

3-12  
months 
£’000

1-5 
 years 
£’000

Over  
5 years 
£’000

Total 
£’000

Liabilities for linked investment contracts

11,316,471

14,289

(45)

11,330,715

-

-

1,731

1,731

-

-

-

- 

-

-

-

11,316,471

14,289

1,686

-  11,332,446

Up to 3 
months 
£’000

3-12  
months 
£’000

1-5  
years 
£’000

Over  
5 years 
£’000

Total 
£’000

Liabilities for linked investment contracts

11,947,652

Trade and other payables

Current tax liabilities

Total

15,208

-

11,962,860

-

-

2,803

2,803

-

-

-

-

-

-

-

11,947,652

15,208

2,803

- 11,965,663

Financial assets held in portfolio investments and the corresponding liabilities are deemed to have a maturity of up 
three months since the liabilities are repayable on demand. In practice the contractual maturities of the underlying 
assets may be longer than three months, but the majority of assets held within portfolios are highly liquid.

(4) Outflow risk

Outflows occur when funds are withdrawn from the platform for any reason. Outflows typically occur where clients’ 
circumstances and requirements change. However, these outflows can also be triggered by operational failure, 
competitor actions or external events such as regulatory or economic changes.

Outflow risk is mitigated by focusing on providing exceptionally high levels of service. Outflow rates are closely 
monitored and unexpected experience is investigated. Despite the current challenging and uncertain economic  
and geopolitical environment, outflow rates remain low and stable.

(5) Expense risk

Expense risk arises where costs increase faster than expected or from one-off expense “shocks”. As a significant 
percentage of the Group’s expenses are staff related the key inflationary risk arises from salary inflation.

The Group’s expenses are governed at a high level by the Group’s Expense Policy. The monthly management  
accounts are reviewed against projected future expenses by the Board and by senior management and action  
is taken where appropriate. 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    67

FINANCIAL STATEMENTS  continued

5.  Segmental reporting

The revenue and profit before tax are attributable to activities carried out in the UK. 

The Group has three classes of business as follows:

▪ provision of investment management services 
▪ transaction of ordinary long term insurance and underwriting life assurance 
▪ provision of consultancy services. 

Analysis by class of business is given below:

Revenue

Investment administration services

Insurance and life assurance business

Consultancy services

Profit before tax

Investment administration services

Insurance and life assurance business

Consultancy services

Net assets

Investment administration services

Insurance and life assurance business

Consultancy services

2017 
£’000

44,019

36,223

-

2016 
£’000

37,854

30,403

100

80,242

 68,357

17,224

27,121

544

44,889

51,176

50,397

953

102,526

11,393

34,024

139

45,556

38,100

47,456

688

86,244

The figures above comprise the results of the companies that fall directly into each segment, as well as a proportion 
of the results from the other Group companies that only provide services to the revenue-generating companies. 
This therefore has no effect on revenue, but has an effect on the profit before tax and net assets figures. 

6.  Earnings per share

Year ended 30 September

Profit

2017 
£’000

2016 
£’000

Profit for the year and earnings used in basic and diluted earnings per share

29,889

20,816

Number of shares

1,137,278

1,137,278

Weighted average number of A, B, C shares used in basic and diluted earnings per share

1,107,278

1,107,278

Weighted average number of D shares used in basic and diluted earnings per share

30,000

30,000

Earnings per share is calculated based on the share capital of IntegraFin Holdings Limited and the earnings of the 
consolidated Group. Separate calculations have been performed for A, B and C shares, and for D shares, to reflect 
the different dividend rate attached to D shares.

68    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

7.  Expenses by nature

The following expenses are included within administrative expenses:

Group

Depreciation

Amortisation

Wages and employee benefits expense

Auditor’s remuneration:

- auditing of the financial statements of the Company pursuant to legislation

- auditing of the financial statements of subsidiaries 

- other assurance services

- taxation service

Other Auditor’s remuneration:

- auditing of the financial statements of subsidiaries

- other assurance services

Impairment losses

Operating lease costs:

- Land and buildings

- Equipment

Company

Auditor’s remuneration:

2017 
£’000

551

20

30,036

25

81

73

-

114

115

128

2016 
£’000

494

1,438

25,059

10 

92

99

78

73

83

574

1,812

8

1,783

8

- auditing of the financial statements of the Company pursuant to legislation

- other assurance services

- taxation services

Impairment losses

Wages	and	employee	benefits	expense

25

-

-

-

The average number of staff (including executive directors) employed by the Group during the financial year 
amounted to:

10

10

78

392

2016 
No.

194

54

50

85

35

23

1

2017 
No.

201

54

49

84

37

25

             1 

451

442

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    69

Client Services staff

Finance staff

Technical and support staff

Software development staff

Sales, marketing and product development staff

Legal and compliance staff

CEO

The Company has no employees (2016: nil).

 
 
FINANCIAL STATEMENTS  continued

Staff (including executive Directors) costs during the year, included within administrative expenses, were as follows:

Wages and salaries

Social security costs

Other pension costs

2017 
£’000

25,474

2,268

2,294

2016 
£’000

20,966

2,391

1,702

30,036

25,059

Compensation of key management personnel

Key management personnel are defined as those persons having authority and responsibility for planning, directing 
and controlling the activities of the entity and as such, only Directors are considered to meet this definition. 

Short term employee benefits

Post employment benefits

Highest paid Director:

Short term employee benefits 

Post employment benefits

Number of Directors for whom pension contributions are paid

8.  Interest income

2017 
£’000

1,645

37

1,682

505

8

3 

2016 
£’000

1,417

119

1,536

455

33

3

Interest income on bank deposits

Interest income on loans

Interest income on financial assets  
at fair value through profit or loss

Other interest

Group 
2017 
£’000

Company 
2017 
£’000

Group 
2016 
£’000

Company 
2016 
£’000

64

16

98

-

178

8

16

-

-

24

145

-

306

-

451

2

-

-

-

2

70    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

9.  Tax on profit on ordinary activities

Group

a) Analysis of charge in year

The income tax expense comprises:

Corporation tax

Corporation tax – under-provision in previous year

Movement in deferred tax asset (Note 20) 

Movement in deferred tax liability (Note 20)

Deferred tax charge/(credit)

Total

2017 
£’000

7,234

9

7,243

(50)

(12)

(62)

2016 
£’000

5,197

21

5,218

78

-

78

7,181

5,296

b) Factors affecting tax charge for the year

The tax on the Company’s profit before tax differs from the amount that 
would arise using the weighted average tax rate applicable to profits of the 
consolidated entities as follows:

Profit on ordinary activities before tax

42,590

38,341

Profit on ordinary activities multiplied by effective rate of Corporation Tax 
19.5% (2016: 20%)

Deferred tax charge/(credit) (see Note 20)

Effects of:

Income not taxable and expenses not deductible for tax purposes, multiplied by 
effective rate of Corporation Tax 19.5% (2016: 20%)

Profits not taxable, multiplied by effective rate of Corporation Tax 19.5%  
(2016: 20%)

Corporation tax – under-provision in prior year

Profits charged at different rates to UK Corporation Tax rate

8,305

(62)

7,668

78

(834)

(2,191)

(292)

(285)

7

57

12

14

7,181

5,296

Changes in tax rates

The main rate of UK corporation tax reduced from 20% to 19% with effect from 1 April 2017 and will reduce to 17% 
with effect from 1 April 2020. The reduction in corporation tax rates does not impact on the policyholder rate.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    71

FINANCIAL STATEMENTS  continued

Company

a) Analysis of charge in year

Deferred tax charge/(credit) (see Note 20)

Total

b) Factors affecting tax charge for the year 
Profit on ordinary activities before tax

Profit on ordinary activities multiplied by effective rate of Corporation Tax 
19.5% (2016: 20%)

Deferred tax charge/(credit) (see Note 20)

Effects of:

Income not taxable and expenses not deductible for tax purposes, multiplied 
by effective rate of Corporation Tax 19.5% (2016: 20%)

2017 
£’000

-

-

2017 
£’000

2016 
£’000

78 

78 

2016 
£’000

18,290

38,641

3,567

-

7,728

78

(3,567)

-

(7,728)

78

72    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

 
10.  Intangible assets – Group

Cost

At 1 October 2016

At 30 September 2017

Amortisation

At 1 October 2016

Charge for the year

At 30 September 2017

Net Book Value

At 30 September 2016

At 30 September 2017

Cost

At 1 October 2015

Addition in the year

At 30 September 2016

Amortisation

At 1 October 2015

Charge for the year

Prior year adjustment

At 30 September 2016

Net Book Value

At 30 September 2015

At 30 September 2016

Software 
and IP rights 
£’000

Goodwill 
£’000

12,505

12,505

12,951

12,951

12,450

20

12,470

 - 

- 

-

Total 
£’000

25,456

25,456

12,450

20

12,470

55

35

12,951

12,951

13,006

12,986

12,505

-

12,505

11,105

1,438

(93)

12,450

1,400

55

- 

12,951

12,951

 - 

- 

-

-

- 

12,951

12,505

12,951

25,456

11,105

1,438

(93)

12,450

1,400

13,006

Amortisation of intangibles is recognised within administrative expenses in the profit or loss account.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    73

FINANCIAL STATEMENTS  continued

Goodwill impairment assessment

The Group is required to test, on an annual basis, whether goodwill has suffered any impairment. The recoverable 
amount is determined based on value in use calculations. The use of this method requires the estimation of future 
cash flows and the determination of a discount rate in order to calculate the present value of the cash flows.

This the first year in which an impairment test has been performed. The goodwill was first recognised upon 
acquisition of IAD in July 2016, and must be tested for impairment annually, so a test was not required in the 
previous financial year.

The carrying amount of goodwill is allocated to the two cash generating units that are benefiting from the 
acquisition as follows: 

Investment management services

Insurance and life assurance business 

Total

2017 
£’000

7,449

5,501

12,951  

The recoverable amounts of the above cash generating units have been determined from value in use calculations 
based on cash flow projections from formally approved budgets covering a five year period to 30 September 2022. 
The results of this showed that no impairment has taken place throughout the historical financial period.

No sensitivity analysis has been performed on the basis that there were no reasonable foreseeable changes in the 
assumptions which would result in the recoverable amount falling below the carrying amount.

74    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

 
11.  Property, plant and equipment – Group

Short 
Leasehold 
Land and 
Buildings 
£’000

Equipment 
£’000

Fixtures 
and 
Fittings 
£’000

Motor 
vehicles 
£’000

Cost

At 1 October 2016

Reclassification

Additions

Disposals

Foreign exchange

1,615

1,613

-

95

-

(2)

307

208

(50)

(6)

At 30 September 2017

1,708

2,072

Depreciation

At 1 October 2016

Reclassification

Charge for the year

Disposals

Foreign exchange

At 30 September 2017

Net Book Value

At 30 September 2016

At 30 September 2017

Cost

At 1 October 2015

Additions

Disposals

At 30 September 2016

Depreciation

At 1 October 2015

Additions

Charge for the year

Disposals

At 30 September 2016

Net Book Value

At 30 September 2015

At 30 September 2016

525

-

155

-

-

680

1,090

1,028

1,242

373

-

1,615

362

39

124

-

525

880

1,090

902

214

356

(35)

(4)

1,433

711

639

1,463

739

(589)

1,613

1,045

214

232

(589)

902

418

711

553

(307)

17

-

-

263

356

(214)

23

-

-

165

197

98

226

327

-

553

121

124

111

-

356

105

197

101

-

43

(43)

(1)

100

27

-

17

(37)

-

7

74

93

- 

101

-

101

- 

-

27

-

27

- 

74

Total 
£’000

3,882

-

363

(93)

(9)

4,143

1,810

-

551

(72)

(4)

2,285

2,072

1,858

2,931

1,540

(589)

3,882

1,528

377

494

(589)

1,810

1,403

2,072

The Company holds no property, plant and equipment.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    75

Total 
£’000

14,213

14,213

14,213

14,213

449

14,156

(392)

14,213

449

14,213

FINANCIAL STATEMENTS  continued

12.  Investment in subsidiaries

Company

At 1 October 2016

At 30 September 2017 

Net book value

At 30 September 2016

At 30 September 2017

At 1 October 2015

Additions

Impairment

At 30 September 2016

Net book value

At 30 September 2015

At 30 September 2016

76    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Name of Company

Holding

% Held

Incorporation  
and significant 
place of business

Business

Direct holdings

Integrated Financial Arrangements Ltd

Ordinary Shares

100%

United Kingdom

IntegraFin Services Limited

Ordinary Shares

100%

United Kingdom

Transact IP Limited

Ordinary Shares

100%

United Kingdom

Integrated Application Development Pty Ltd Ordinary Shares

100%

Australia

Investment 
Management

Services 
Company

Software 
provision & 
development

Software 
maintenance

Objective Asset Management Limited

Ordinary Shares

100%

United Kingdom

Dormant

Indirect holdings

IntegraFin Limited

Ordinary Shares

100%

United Kingdom

Non-trading

Transact Nominees Limited

Ordinary Shares

100%

United Kingdom

Non-trading

IntegraLife UK Limited

Ordinary Shares

100%

United Kingdom

Life Insurance

IntegraLife International Limited

Ordinary Shares

100%

Isle of Man

Life Assurance

ObjectMastery (UK) Limited

Ordinary Shares

100%

United Kingdom

Consultancy

Objective Funds Limited

Ordinary Shares

100%

United Kingdom

Dormant

Objective Wealth Management Limited

Ordinary Shares

100%

United Kingdom

Dormant

IntegraFin (Australia) Pty Limited

Ordinary Shares

100%

Australia

Non-trading

Transact Trustees Limited

Ordinary Shares

100%

United Kingdom

Non-trading

The group has 100% voting rights on shares held in each of the subsidiary undertakings.

All the UK subsidiaries have their registered office address at 29 Clement’s Lane, London, EC4N 7AE. 
IntegraLife International Limited’s registered office address is at 18-20 North Quay, Douglas, Isle of Man, IM1 4LE. 
IntegraFin (Australia) Pty’s registered office address is at Level 4, 854 Glenferrie Road, Hawthorn, Victoria, 
Australia 3122. Integrated Application Development Pty Ltd’s registered office address is 19-25 Camberwell Road, 
Melbourne, Australia.

The above subsidiaries have all been included in the consolidated financial statements. The results of IntegraLife 
International Limited and IntegraLife UK Limited are included as described in the basis of consolidation accounting 
policy in Note 1.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    77

FINANCIAL STATEMENTS  continued

Integrated Financial Arrangements Ltd is authorised and regulated by the Financial Conduct Authority.  
The principal activity of the Company and its subsidiaries is the provision of ‘Transact’, a wrap service that 
arranges and executes transactions between clients, their financial advisers and financial product providers 
including investment managers and stockbrokers.

IntegraFin Services Limited (ISL), is the Group services company. All intra-group service contracts are held by  
this services company.

Integrated Application Development Pty Ltd (IAD) provides software maintenance services to the Group.

IntegraFin Limited is the trustee of the IntegraSIP Share Incentive Plan, which was set up to allocate Class C Shares 
in the capital of the Company to staff. IntegraFin Limited undertakes no other activities.

Transact Nominees Limited holds customer assets as a nominee company on behalf of Integrated Financial 
Arrangements Ltd.

IntegraFin (Australia) Pty Limited is currently non-trading.

Transact IP Limited licenses its proprietary software to other members of the IntegraFin Group.

IntegraLife UK Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct 
Authority and the Prudential Regulation Authority. Its principal activity is the transaction of ordinary long term 
insurance business within the United Kingdom.

IntegraLife International Limited is authorised and regulated by the Isle of Man Financial Services Authority and 
its principal activity is the transaction of ordinary long term insurance business within the United Kingdom through 
the Transact Offshore Bond.

78    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

13.  Deferred acquisition costs

Opening balance

Capitalisation of deferred acquisition costs

Amortisation of deferred acquisition costs

Change in deferred acquisition costs

Closing balance

2017 
£’000

31,792

12,950

(6,447)

6,503

38,295

2016 
£’000

29,736

7,964

(5,908)

2,056

31,792

14.  Non-current asset investments – ILInt and ILUK

Investments and cash held for the benefit of policyholders

ILInt

Cash and cash equivalents held for  
the benefit of the policyholder

Investments held for the benefit of  
the policyholder

ILUK

Cash and cash equivalents held for  
the benefit of the policyholder

Investments held for the benefit of  
the policyholder

2017 
Cost 
£’000

2017 
Fair value 
£’000

2016 
Cost 
£’000

2016 
Fair value 
£’000

74,565

74,565

82,931

82,931

985,912

1,175,098

1,637,842

2,928,144

1,060,477

1,249,663

1,720,773

3,011,075

1,014,314

1,014,314

715,881

715,881

8,049,078

9,683,675

6,898,345

7,589,515

9,063,392

10,697,989

7,614,226

8,305,396

Total

11,947,652

11,316,471

All amounts are current. These assets are held to cover the liabilities for unit linked investment contracts.  
All contracts with customers are deemed to be investment contracts and, accordingly, assets are 100% matched  
to corresponding liabilities.

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    79

FINANCIAL STATEMENTS  continued

15.  Financial assets at fair value through profit or loss

Listed shares and securities

Gilts

Investments are all UK and sterling based and held at fair value.

16.  Other prepayments and accrued income

Accrued income

Prepayments

17.  Trade and other receivables

Amounts owed by Group undertakings

Interest receivable

Other receivables

18.  Trade and other payables

Trade payables

PAYE and other taxation

Due to Group undertakings

Other payables

Accruals and deferred income

80    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

Group 
30 Sep 
2017 
£’000

-

5

1,451

1,456

Group 
30 Sep 
2017 
£’000

265

1,229

-

7,259

6,455

15,208

Company 
30 Sep 
2017 
£’000

7

-

-

7

Company 
30 Sep 
2017 
£’000

-

31

11

21

1,093

1,156

Group 
30 Sep 
2017 
£’000

83

8,812

8,895

Group 
30 Sep 
2017 
£’000

7,951

2,301

10,252

Group 
30 Sep 
2016 
£’000

-

8

1,589

1,597

Group 
30 Sep 
2016 
£’000

364

1,621

-

5,437

6,867

14,289

Group 
30 Sep 
2016 
£’000

51

8,925

8,976

Group 
30 Sep 
2016 
£’000

6,806

3,036

9,842

Company 
30 Sep 
2016 
£’000

9

-

-

9

Company 
30 Sep 
2016 
£’000

-

12

8

5

363

388

19.  Deferred income liability

Opening balance

Capitalisation of deferred income

Amortisation of deferred income

Change in deferred acquisition costs

Closing balance

20.  Deferred tax

2017 
£’000

31,792

12,950

(6,447)

6,503

38,295

2016 
£’000

29,736

7,964

(5,908)

2,056

31,792

Deferred tax is calculated in full on temporary differences under the liability method using a tax rate of 19% 
(2016: 19%). This new rate has been applied to deferred tax balances which are expected to reverse after  
1 April 2017, the date on which that new rate becomes effective.

Liabilities – Group

Balance brought forward

 Release in year at 19% (2016: 19%) future corporation tax rate in respect of:

- Accelerated depreciation

Deferred tax (credit)/charge

Movement in policyholder tax

Balance carried forward 

Analysed as:

- Accelerated depreciation

- Policyholder deferred tax

The Company has no deferred tax liabilities.

Assets – Group and Company

Balance brought forward

 Release in year at 19% (2016: 19%) future corporation tax rate in respect of:

- Unused capital losses

Accelerated depreciation

Balance carried forward

30 Sep 
2017 
£’000

30 Sep 
2016 
£’000

8,495

1,279

(12)

(12)

2,298

10,781

-

10,781

10,781

-

-

50

50

-

-

7,216

8,495

12

8,483

8,495

(78)

78

-

-

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    81

FINANCIAL STATEMENTS  continued

21. Client monies and client assets

2017

Client monies

Client assets

2016

Client monies

Client assets

£’000

2,297,792

Amounts due to clients

25,629,954

Corresponding liability

1,836,756

Amounts due to clients

22,763,205

Corresponding liability

£’000

2,297,792

25,629,954

1,836,756

22,763,205

The above client monies are held separately in client bank accounts which are excluded from the Company’s net 
current assets. In addition the above client assets are held on behalf of Integrated Financial Arrangements Ltd by 
Transact Nominees Limited, the holdings are also excluded from the Company’s net current assets.

22. Provisions for liabilities

Balance brought forward

(Decrease)/increase in dilapidations provision

Increase in ILInt non-linked unit provision

Increase in ILUK tax provision

Balance carried forward

Dilapidations provisions

ILInt non-linked unit provision

ILUK tax provision

Rent provision

Group 
30 Sep 
2017 
£’000

15,550

44

4

(3,767)

11,831

323

29

11,377

102

11,831

Group 
30 Sep 
2016 
£’000

20,802

95

13

(5,360)

15,550

279

25

15,144

102

15,550

The dilapidation provisions relate to the former leasehold premises at 5-7 Singer Street, the current leasehold 
premises at 29 Clement’s Lane, and the current ILInt leasehold premises at 18/20 North Quay, on the Isle of Man. 
The Group is committed to restoring the premises to their original state at the end of the lease term. Whilst it is 
probable that payments will be required for dilapidations, uncertainty exists with regard to the amount and timing  
of these payments, and the amounts provided represent management’s best estimate of the Group’s liability. 

The rent provision relates to potential litigation regarding disputed rent. There is potential for a claim to be made 
against the Group until March 2019, though uncertainty exists as to the timing of any potential claim and whether  
the claim will be successful.

ILUK tax provision is made up of tax relief due to policyholders. It comprises claims received from HMRC that are yet 
to be returned to policyholders and charges taken from unit-linked funds and claims received from HMRC to meet 
future policyholder tax obligations.

82    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

23. Called up share capital – Company and Group

Allotted, called up and fully paid:

Ordinary Class A shares of £0.05 each

Ordinary Class B shares of £0.05 each

Ordinary Class C shares of £0.05 each

Ordinary Class D shares of £0.05 each

30 Sep 
2017 
Number

417,868

357,000

332,410

30,000

30 Sep 
2016 
Number

417,868

357,000

332,410

30,000

30 Sep 
2017 
£’000

30 Sep 
2016 
£’000

21

18

17

1

57

21

18

17

1

57

There has been no movement in called up share capital during the year.

Class A and Class B Ordinary Share Capital have full voting and dividends rights.

Class C Ordinary Share Capital has no voting rights, but ranks equally for dividends.

Class D Ordinary Share Capital has no voting rights, and shareholders are only entitled to receive dividends to the extent 
that the amount per Ordinary Share paid to the holders of Class A Shares, Class B Shares and Class C Shares in any 
financial year exceeds the amount per Ordinary Share received by holders of those Ordinary Shares (excluding any 
Special Dividends) in the financial year prior to the financial year in which relevant Class D Shares are issued.

24. Share premium account – Group

Balance brought forward

Premium on shares issued during the year

Balance carried forward

25. Capital redemption reserve – Group

Balance brought forward

Purchase of own shares

Balance carried forward

2017 
£’000

5,722

-

5,722

2016 
£’000

5,722

-

5,722

2017 
£’000

2016 
£’000

2

-

2

2

-

2

On 12 December 2013 IFAL (formerly IFA plc) was granted authority by shareholders to repurchase £4,500,000 worth 
of ordinary shares from shareholders. IFAL purchased 45,917 shares, and they were then cancelled, giving rise to a capital 
redemption reserve of £2,271. 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    83

FINANCIAL STATEMENTS  continued

26. Share-based payment reserve – Group

Balance brought forward

Transfer to profit and loss reserve

Balance carried forward

27. Other reserves – Group

Balance brought forward

Currency Translation reserve

Balance carried forward

28. Operating lease commitments

The total future minimum lease payments of operating leases are due as follows:

Group

Within 1 year

Within 2-5 years

Over 5 years

2017 
£’000

308

-

308

2017 
£’000

32

10

42

2016 
£’000

308

-

308

2016 
£’000

-

32

32

Land and 
Buildings  
2017 
£’000

Land and 
Buildings  
2016 
£’000

2,398

9,304

1,396

2,365

9,468

3,490

The lease commitments relate to the current leasehold premises at 29 Clement’s Lane, the current ILInt leasehold 
premises at 18/20 North Quay on the Isle of Man, and the current IAD Pty leasehold premises at 19-25 Camberwell 
Road, Melbourne, Australia. 

84    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

29. Related parties

During the year the Company did not render nor receive any services with related parties within the Group, and at the 
year end the Company had the following intra-Group receivables:

Company

Integrated Financial Arrangements Ltd

IntegraFin Services Limited

IntegraFin Limited 

IntegraLife UK Limited

Amounts owed by/(to) 
related parties

2017 
£’000

6

-

(11)

1

2016 
£’000

8

(2)

(6)

(1)

The Group has not made any allowance for bad or doubtful debts in respect of related party debtors nor has any 
guarantee been given or received during 2017 or 2016 regarding related party transactions.

All of the above transactions are commercial, arm’s length transactions undertaken in the normal course of business. 

30. Share incentive plan (SIP)

The Company introduced a SIP trust scheme for its staff in October 2005. The SIP is an approved scheme under 
Schedule 2 of the Income Tax (Earnings & Pensions) Act 2003.

This scheme entitles all the staff who were employed in October 2005 to Class C shares in the Company, subject to 
their remaining in employment with the Company until certain future dates.

The trustee for this scheme is IntegraFin Limited, a wholly owned non-trading subsidiary of Integrated Financial 
Arrangements Ltd.

The cost to the Company in the financial year to 30 September 2017 was £nil (2016: £nil).

31. Share-based payments

There are no share options outstanding. All options have been exercised, and there have been no new share  
options granted.

32. Events after the reporting date

There are no events subsequent to the year-end that require disclosure in, or amendment to the financial statements.

33. Dividends

During the year the Company paid an interim dividend of £13,527,336 (2016: £8,978,224) to shareholders. 

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    85

OTHER INFORMATION

DIRECTORS, COMPANY DETAILS, ADVISERS

Executive Directors

Ian Taylor

Michael Howard

Alexander Scott

Judith Davidson (resigned 1 October 2017)

Non-Executive Directors

Christopher Munro (appointed 1 February 2017)

Patrick Snowball (appointed 1 October 2017) 

Jeremy Brettell (resigned 1 October 2017)

Neil Holden

Stuart Bazley (resigned 1 October 2017)

Company Secretary

David Johnson

Independent Auditors

BDO LLP London

Solicitors

Eversheds Sutherland, London

Principal Bankers

NatWest

Registrars

Neville Registrars

Registered Office

29 Clement’s Lane  
London  
EC4N 7AE

Website

www.integrafin.co.uk 

Company number

08860879

86    INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017

GLOSSARY OF TERMS

AGM   Annual General Meeting

IPO   Initial Public Offering

CASS   Client Assets Sourcebook

ISA   Individual Savings Account

CEO   Chief Executive Officer

ISAs (UK)    International Standards on Auditing (UK)

CFO   Chief Financial Officer

IT   Investment Trust

COO  Chief Operating Officer

MiFID II    Second Markets in  

COREP    Common Reporting, as required by the 

Financial Instruments Directive

Capital Requirements Directive IV

NED   Non-Executive Director

COSO    Committee of Sponsoring Organisation  

OEIC   Open Ended Investment Company

of the Treadway Commission

ETF   Exchange-traded Fund

FCA   Financial Conduct Authority

FRC   Financial Reporting Council

FUD   Funds under Direction

ORSA   Own Risk and Solvency Assessment

SCR   Solvency Capital Requirement 

TCF   Treating Customers Fairly

 The Company  IntegraFin Holdings Limited 

The Group    IntegraFin Holdings Limited 

GDPR   General Data Protection Regulation

and its subsidiaries

GIA   General Investment Account

VCT   Venture Capital Trust

HMRC   Her Majesty’s Revenue and Customs

IAD    Integrated Application Development Pty Ltd

ICA   Individual Capital Assessment 

ICAAP    Internal Capital Adequacy  

Assessment Process

IFAL   Integrated Financial Arrangements Ltd

IFPRU    Prudential Sourcebook for 
Investment Firms

IFRS    International Financial 

Reporting Standards

ILInt   IntegraLife International Limited

ILUK   IntegraLife UK Limited

IntegraFin   IntegraFin Holdings Limited

IP   Intellectual Property

INTEGRAFIN ANNUAL REPORT YEAR ENDED 30 SEPTEMBER 2017    87

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
M137 September 2017

IntegraFin Holdings Limited, 29 Clement’s Lane, London, EC4N 7AE
Tel: (020) 7608 4900 Fax: (020) 7608 5300

(Registered offi ce: as above; Registered in England and Wales under number: 08860879)
The holding company of the Integrated Financial Arrangements Ltd group of companies.