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Manx Financial Group

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FY2018 Annual Report · Manx Financial Group
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_________________________________ 

ANNUAL REPORT 2018 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Welcome to Manx Financial Group PLC
Welcome to Manx Financial Group PLC    
Welcome to Manx Financial Group PLC
Welcome to Manx Financial Group PLC
Integrity through independence and service  

An independent banking group founded in 1935, domiciled in the 
Isle of Man 

Manx Financial  Group PLC (“MFG”)  is 
an  AIM-listed  company  (LSE:  MFX.L) 
which  has  subsidiaries  engaged  in  a 
suite of financial services based in the 
Isle  of  Man  and 
the  UK.  These 
companies  offer  financial  services  to 
both retail and commercial customers. 
MFG's  strategy  is  to  grow  organically 
and  through  strategic  acquisition  to 
further augment the range of services it 
offers.  
Principal wholly owned subsidiaries: -  
• Conister Bank Limited 
• Edgewater Associates Limited 
• Manx FX Limited 

Conister  Bank  Limited  (“the  Bank”)  is  a 
licensed independent bank, regulated by 
the Financial Services Authority in the Isle 
of Man, the Financial Conduct Authority in 
the  UK  and  is  a  full  member  of  the 
MasterCard®  network  and  the  Isle  of 
Man’s Association of Licensed Banks.  
The  Bank  provides  a  variety  of  financial 
products and services, including savings 
accounts,  asset 
financing,  personal 
loans,  loans  to  small  and  medium  sized 
enterprises,  block  discounting  and  other 
specialist  secured  credit  facilities  to  the 
Isle  of  Man  and  the  UK  consumer  and 
business sectors.  

Edgewater  Associates  Limited       
(“EWA”) is the largest independent 
financial adviser in the Isle of Man.  
EWA  provides  a  bespoke  and 
personal  service  to  Isle  of  Man 
residents  and 
the  Group’s 
to 
business  and  personal  customers 
and advises on assets in excess of 
£310 million.  
EWA  specialises  in  the  areas  of 
wealth  management,  mortgages, 
general  insurance,  and  retirement 
planning.  

Manx  FX  Limited  was  formed  in  2014 
and  provides  specialist  solutions  and 
access to competitive foreign exchange 
and  international  payment  processing 
facilities. 

 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
CONTENTS     

Chairman’s Statement 

Business Model and Strategy 

Risk Management 

Corporate Governance Report 

Directors, Officers and Advisers 

Audit, Risk and Compliance Committee 

Directors’ Remuneration Report 

Directors’ Report 

Annual Financial Statements’ Contents 

Statement of Directors’ Responsibilities 

Independent Auditor’s Report 

Consolidated Statement of Profit or Loss and Other Comprehensive Income 

Company Statement of Profit or Loss and Other Comprehensive Income 

Consolidated Statement of Financial Position 

Company Statement of Financial Position 

Consolidated and Company Statements of Changes in Equity 

Consolidated Statement of Cash Flows 

Company Statement of Cash Flows 

Notes to the Consolidated Financial Statements 

01 

04 

06 

12 

16 

18 

21 

23 

24 

25 

26 

30 

31 

32 

33 

34 

35 

36 

37 

  
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STRATEGIC REPORT 

CHAIRMAN’S STATEMENT     

Shareholderssss    
Dear Shareholder
Dear 
Shareholder
Shareholder
Dear Dear 

When  I  wrote  to  you  in  the  Interim  Results  for  2018,  I  was 
confident  that  the  full  year  would  continue  our  growth  in 
profitability. This has proved to be the case, but the effect of 
the two positive initiatives undertaken during the second half 
of  the  year  has  had  a  temporary  impact  on  the  Income 
Statement. The first being the investment in the UK by opening 
a  new  full-service  UK  Headquarters  in  Newbury,  with  a 
satellite branch in Manchester. These offices will source new 
business  and  manage  our  UK  lending  portfolio  through  our 
subsidiary  Conister  Finance  and  Leasing  Limited,  thus 
demonstrating our commitment to this increasingly important 
segment of our business. Secondly, the increasing economic 
uncertainty surrounding both the Isle of Man and the United 
Kingdom  has  reinforced  your  Board’s  decision  to  adopt  an 
the 
to  provisioning  under 
ultra-conservative  approach 
requirements  of 
International  Financial  Reporting 
Standard  9  (“IFRS  9”)  by  recognising  an additional  buffer to 
strengthen  the  Balance  Sheet.  I  must  emphasise  that  this 
action does not represent a realized cash outlay and is there, 
if ever required, solely to protect our future profitability. Indeed, 
the quality of our underwriting is such that our actual ratio of 
bad debts written off stands at an enviable 0.6% (2017: 0.5%). 

the 

As a consequence, our profit before tax is broadly similar to 
2017  at  £2.7  million  (2017:  £2.7  million).  However,  our  total 
assets  have  increased  by  13.8%  to  £196.9  million  (2017: 
£173.0 million) and our total shareholder equity has increased 
by  a  corresponding  14.3%  to  £19.7  million  (2017:  £17.3 
million). Whilst the latter figure is gratifying, I am deeply aware 
that as I write, our market capitalisation stands at only £11.5 
million, being a discount of 42%. This discount is regrettable, 
especially when ranked against our peer group. 

Of our core businesses, Conister Bank has enjoyed excellent 
new  business  generation,  offset  by  the  run-off  by  mutual 
agreement  of  two  discontinued  lending  streams,  both  nearly 
complete, but representing a decrease of £14.8 million during 
the year (2017: £12.7 million). Thus, the fall in interest income 
to £19.1 million (2017: 19.9 million) belies a total new lending 
of £102.1 million for 2018 (2017: £73.7 million). I discuss this 
further below, but suffice to say, this bodes well for the future 
by diversifying our risk profile. Manx FX Limited produced an 
encouraging  profit  before  tax  of  £0.5  million  (2017:  £0.3 
million)  and  Edgewater  Associates  Limited,  although 
experiencing a market downturn during the last two months of 
2018, produced a profit before tax of £0.3 million (2017: £0.7 
million). 

overnance    
Corporate governance
Corporate g
overnance
overnance
Corporate g
Corporate g
It  is  important  for  shareholders  to  understand  the  emphasis 
both I and the Board place upon corporate governance. In May 
2018, we adopted the Quoted Companies Alliance corporate 
governance  code  (“QCA”)  with  which  we  expect  to  be  fully 
compliant in our reporting for the year-end statutory accounts. 
In essence, the code has ten principles to aid investors in their 
understanding of our Group and to help build and develop long 
term trust and maximise our relationship with shareholders. As 
Chairman, it is my responsibility to make a clear statement on 
corporate governance and the value we place upon this. Our 
full  year  accounts  will provide  a  detailed  explanation  of  how 
we observe the QCA, but meanwhile, I am keen for investors 
to  understand  our  strategic  objectives  both  in  the  near  and 
longer term. 

Our key objectives for 2019    
Our key objectives for 2019
Our key objectives for 2019
Our key objectives for 2019
Your Board’s fundamental objective remains that of increasing 
shareholder value, both in a prudent yet progressive manner. 
Thus, our strategic concentration continues to be: - 

  Providing the highest quality service throughout our 
operations  to  all  customers,  ensuring  that  their 
treatment is both fair and appropriate; 

  Adopting  a  pro-active  strategy  of  managing  risk, 
especially following the implementation of IFRS 9 in 
full. In doing so, we are committed to regularly review 
our  loan  book  to  allow  for  any  credit  impairment 
resulting from observing strict Expected Credit Loss 
criteria;  

  Concentrating on developing our core businesses by 
increased  prudential 
considered  acquisitions, 
lending  and  augmenting  the  range  of  financial 
services we offer; 
Implementing  an  enhanced  and  scalable 
infrastructure 
to  better  service 
requirements  of  a  growing  Group  without 
requirement 
headcount; 

IT 
the  operational 
the 
in 

for  a  disproportionate 

increase 

  Focusing on the liabilities side of our balance sheet 
by introducing a new treasury management function 
and structure; and 

  Managing  our  balance  sheet  to  exceed,  as  far  as 
possible,  the  regulatory  requirements  for  capital 
adequacy. 

 

We implemented the General Data Protection Regulation on 
25  May  2018.  Doing  this  required  changes  in  policy, 
procedures and technology across the Group to manage how 
we  process  and  secure  data  and  protect  the  rights  of 
individuals.  Both  our  Internal  Audit  and  Compliance  teams 
have reviewed the process and will continue to be involved in 
making  sure  that  the  post  implementation  requirements 
continue to be met. 

We  have  also  instituted  an  important  new  position,  that  of 
Head  of  Risk  and  Compliance,  to  enhance  and  monitor  our 
control  functions,  ensuring  that  these  meet  the  highest 
banking standards and are commensurate with the growth in 
our operations. 

Financial performance review    
Financial performance review
Financial performance review
Financial performance review

Conister Bank Limited (the “Bank”)
Conister Bank Limited (the “Bank”)    
Conister Bank Limited (the “Bank”)
Conister Bank Limited (the “Bank”)
Despite the shadow of economic uncertainty, all our lending 
targets  for  the  year  were  exceeded.  We  have  been  able  to 
make significant inroads into the UK commercial sector, while 
increasing our lending in the Isle of Man. As I reported above, 
net new lending increased by 38.4% to £102.1 million (2017: 
£73.7 million), driven by a 41.9% uplift in lending on the Isle of 
Man and a substantial increase in demand for our structured 
product  range  in  the  UK.  Thus,  the  net  loan  book  growth  of 
21.0%  to  £148.3  million  (2017:  £122.5  million)  has  been 
achieved  with  no  deterioration  in  loan  book  quality  as 
performing  loans  remained  at  97.2%.  In  anticipation  of  this 
increase in UK demand, we have opened fully equipped new 
offices in Newbury and in Manchester. We are confident that 
we have invested in the most experienced teams available to 
develop this important market segment.  

Page | 1  

 
 
 
 
 
  
 
 
 
 
 
 
 
 
STRATEGIC REPORT 

CHAIRMAN’S STATEMENT     

I have previously explained that improving our technology is 
of primary importance as we increase in scale. During 2018, 
we successfully installed a new deposit system, representing 
an investment of £1.0 million spread over five years. This has 
helped  manage  the  growth of  our deposit base  by  11.4%  to 
£158.5 million (2017: £142.3 million). One of our key efficiency 
measures,  our  Loan  to  Deposit  Ratio,  improved  by  7.5%  to 
93.6% (2017: 86.1%) which reflects the improved use of our 
cash balances. We also continue to almost exactly match our 
loan terms to our deposit maturities. We note, however, that 
the  average  term  of  our  loan  book  has  marginally  reduced, 
reflecting  the  uncertainty  in  the  market  in  response  to  the 
current economic outlook.  

initiative  has  continued 

As I mentioned in my 2017 Chairman’s Report, we instituted a 
policy to eliminate any reliance upon UK introducers where we 
suffer a disproportionately adverse commission-sharing cost. 
This 
throughout  2018.  Thus, 
commission  expense  decreased  by  27.4%  to  £6.1  million 
(2017:  £8.4  million).  This  movement  resulted  in  net  interest 
income  increasing  by  13.1%  to  £12.8  million  (2017:  £11.3 
million)  despite  interest expense  increasing  by 8.9%  to  £3.5 
million following the increase in deposit balances. As a result 
of  these  factors,  trading  income  improved  by  15.9%  to  £9.5 
million  (2017:  £8.2  million)  leading  to  a  16.3%  increase  in 
operating income £9.8 million (2017: £8.4 million).  

Although  operating  expenses  decreased  by  £0.2  million  to 
£6.0 million (2017: £6.2 million), this masks the investment we 
have  made 
in  new  personnel,  systems  and  controls, 
enhancing our skill set throughout the business. The increase 
in  impairment  provision,  to  which  I have  already  referred, to 
£0.9  million  (2017:  £0.6  million)  reflects  a  prudent  buffer 
against  a  potentially  adverse  outcome 
following  any 
conclusion of the current economic uncertainty. It is important 
to note that, despite our conservative approach to approving 
advances, this figure still only represents 2.0% of the enlarged 
gross  loan  book,  with  the  total  impairment  provision  in  the 
Balance  Sheet  standing  at  £3.4  million  (2017:  £2.7  million). 
Other costs net to £0.2 million (2017: £0.0 million) as the gain 
last year from the write-off an intercompany payable has not 
been repeated. Thus, profit before tax improved by 26.0% to 
£2.2 million (2017: £1.7 million) leading to a 24.0% increase in 
post-tax profit contribution by the Bank to £2.0 million (2017: 
£1.6 million).  

Total  assets,  benefitting  by  a  loan  book  growth  of  £25.6 
million,  part  financed  by  the  conversion  of  cash  and  debt 
securities of £5.7 million, showed a 13.0% increase to £190.1 
million (2017: £168.7 million). As a consequence, shareholder 
equity  improved  by  25.0%  to  £21.1  million  (2017:  £16.9 
million).   

Included in the Balance Sheet is a VAT debtor amounting to 
£1.1 million. This figure represents the VAT recovery relating 
to  a  claim  under  the  revised  Partial  Exemption  Special 
Method. Since the publication of our last financial statements, 
the  Court  of  the  European  Union  determined  in  favour  of 
Volkswagen  Financial  Services  Limited  in  a  parallel  dispute 
against  HM  Revenue  &  Customs.  This  is  an  extremely 
encouraging  development  and  sets  a  precedent.  Thus, 
discussions  with  the  Isle  of  Man  Government  Customs  and 
Excise Division have commenced regarding a full recovery of 
this debtor.  

During  the  year,  as  part  of  our  drive  to  maximise  new 
business, the Group financed the issue of £2.4 million of new 
ordinary shares by the Bank which, together with the increase 
in retained earnings, improved total Tier 1 capital by 23.0% to 
£19.8 million (2017: £16.1 million). This in turn improved total 
regulatory  capital  expressed  as  a  percentage  of  total  risk-
weighted assets by 0.6% to 18.1% (2017: 17.5%), well above 
our notification threshold of 15.0%.    

Edgewater Associ
ates Limited (“EWA”)    
Edgewater Associates Limited (“EWA”)
ates Limited (“EWA”)
ates Limited (“EWA”)
Edgewater Associ
Edgewater Associ
Although fee income appears to have remained steady at £2.6 
million  (2017:  £2.6  million),  an  unexpected  change  in  UK 
legislation  meant  a  temporary  halt  to  our  ability  to  service 
pension transfers to the Isle of Man during the second half of 
the  year.  Notwithstanding,  all  other  fee-based  services 
showed encouraging growth. As a result, we were required to 
make a final top-up payment of £0.1 million to the vendor of 
our recent acquisitions. This, coupled with the effect of a full 
year increase in administration costs, including investment in 
improved systems, to £2.3 million (2017: £1.8 million) caused 
the  profit  contribution  to  decline  to  £0.3  million  (2017:  £0.7 
million). 

Total  assets  reduced  by  2.0%  to  £3.1  million  (2017:  £3.2 
million), reflecting a decrease in debtors. However, creditors 
also reduced, resulting in an improvement in net assets to £2.3 
million (2017: £2.0 million). Shareholder equity increased by 
12% to £2.3 million (2017: £2.0 million). 

continues 

The  underlying  business 
to  experience 
considerable excess demand, but is limited by the difficulty of 
recruiting  suitably  qualified  advisors.  Notwithstanding,  EWA 
remains the Isle of Man’s largest IFA. We remain encouraged 
by  the  opportunities  available  for  this  important  part  of  the 
Group’s  business  and  I  am  pleased  to  note  that  we  have 
already  seen  a  meaningful  improvement  in  profitability  from 
the beginning of 2019. 

Manx FX Limited (“MFX”)
Manx FX Limited (“MFX”)    
Manx FX Limited (“MFX”)
Manx FX Limited (“MFX”)
This business is still very much in its infancy. Because of the 
low-cost  structure,  relatively  small  increases  in  income  can 
generate unusually positive consequences. For example, the 
introduction of a hedging strategy for clients during the year 
doubled turnover to £0.8 million (2017: £0.4 million). While this 
level of income is not necessarily expected to be repeated in 
2019, MFX continues to attract new clients, and now services 
an  active  Isle  of  Man  customer  base  of  87  (2017:  58).  This 
rapid growth means that we continue to develop and invest in 
an  enhanced  operational 
the 
necessary 
functions.  As  a 
consequence, our administration expenses have increased to 
£0.3 million (2017: £0.2 million), leading to a significant profit 
contribution from MFX of £0.5 million (2017: £0.3 million). 

in  our  control 

infrastructure 

to  provide 

resilience 

Turning to  the  balance  sheet,  total  assets  increased  to £0.6 
million (2017: £0.2 million) and shareholder equity stands at 
£0.6 million (2017: £0.1 million).  

Page | 2  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
STRATEGIC REPORT 

CHAIRMAN’S STATEMENT     

Outlook
Outlook    
Outlook
Outlook
The  widely  reported  current  economic  uncertainties  and 
potential changes in interest rates will have an impact on credit 
markets both in the Isle of Man and the UK. Notwithstanding, 
I believe that the Bank’s strategy of asset-backed lending to 
carefully selected sectors will allow us to continue to grow. We 
continue to develop new loan products to those entities with 
significant  balance  sheets  which  demonstrate  both 
affordability  and  credit  resilience.  Thus 
far,  we  have 
experienced no downturn in demand in both the commercial 
and consumer marketplace in both jurisdictions and are more 
than  able  to  maintain  rigorous  credit  and  risk  control  in  our 
underwriting. 

In  conjunction  with  this,  the  Bank  continues  to  seek  out 
suitable  acquisitions 
for  our  strategy  of  consolidation, 
particularly in the UK. So far this year, we have acquired 20% 
of the issued share capital of Beer Swaps Limited, trading as 
Ninkasi Brewkit Rentals, a relatively new company financing 
brewery  equipment,  together  with  an  option  to  acquire  the 
remaining shares by April 2021. We have also acquired 30% 
of  the  issued  share  capital  of  PayItMonthly  Limited  which 
provides web-based finance solutions to retailers without the 
need for them to maintain an onerous compliance resource, 
allowing their customers the ability to spread repayments over 
one  year,  together  with  an  option  to  acquire  the  remaining 
shares  after  August  2021.  Although  these  initiatives  are 
individually small in scale, they will be integrated to form our 
own  specialist 
the  synergies 
introducer  network  using 
available from central funding, systems, risk management and 
controls,  augmented  with  dedicated  staff  capable  of 
developing this important aspect of our portfolio. 

Now that the businesses have fully integrated, EWA has the 
real potential to grow financial advisory services, not only on 
the Isle of Man but also within the UK, especially as the need 
to  finance  a  longer  retirement  becomes  a  necessity.  We 
continue to review suitable acquisitions capable of increasing 
profitability. EWA not only has a strong new business pipeline, 
but  approximately  half  of  its  income  derives  from  renewals. 
Our only limitation to this growth is the recruitment of suitably 
qualified advisors. To counter this, we are concentrating on an 
internal program of staff development which is proving to be 
extremely successful. 

Jim MellonMellonMellonMellon    
Jim 
Jim 
Jim 
Executive Chairman 
27 March 2019    

MFX also has the potential for further growth and, conversely, 
has the capability of benefitting from any uncertainties in the 
financial environment as its clients seek the optimum solutions 
to manage foreign currency exposures. Only a relatively few 
Isle  of  Man  businesses  maintain  in-house  foreign  exchange 
expertise and the MFX proposition has limited competition. 

In short, I believe that the Group as a whole is well placed to 
achieve continued expansion. Each of our principal operations 
are  profitable  and  each  has  identified  opportunities,  yet 
unrealised.  It  is  this  which  will  allow  us  to  meet  our  2019 
strategic priorities. Whilst our organic growth continues to be 
excellent,  any  significant  growth  will 
further 
acquisitions,  strategic  partnerships  and  the  development  of 
specialist products to meet the ever-changing market needs. 
Each solution we offer will be assessed in terms of risk profile 
and  subsequent  reward.  Clearly,  those  opportunities  that 
utilise  technology  to  the  full  and  fit  well  within  our  current 
operations are of the greatest interest. Meanwhile, we remain 
in an excellent position to report further success, both at the 
Interims and the year-end. 

require 

I, and the Board, recognise the need to address the question 
of  shareholder  return.  As  ever,  the  conflicting  demands  of 
utilizing  shareholder  equity  as  the  regulatory  platform  to 
support  growth  versus  the  compounded  cost  of  a  dividend 
payment are difficult to reconcile. As an example, currently for 
every  £1,000  paid  as  a  dividend,  the  Group  would  forgo 
£6,000 worth of new business with its attendant yield. Added 
to  which,  as  the  Group  utilises  relatively  expensive  non-
dilutive  term  loans  to  augment  regulatory  capital,  we  would 
effectively  be  undertaking  additional  borrowing  to  make 
payment.  Notwithstanding,  we  are  considering  potential 
arrangements  which  will,  we  believe,  be  of  benefit  to 
shareholders but  without  reducing our potential  to  reach  the 
scale whereby the Group becomes capable of self-generating 
regulatory  capital.  It  is  unlikely  that  we  will  be  able  to 
implement any scheme during 2019, but depending upon this 
year’s outcome, we may be in a better position to implement a 
scheme thereafter. 

Finally, and as always, I would like to thank our shareholders 
for your continued support, our customers and clients for their 
loyalty, and also our excellent staff for their outstanding efforts 
in continuing to develop the Group. 

Page | 3  

 
 
 
 
 
 
 
 
 
 
 
    
STRATEGIC REPORT 

BUSINESS MODEL AND STRATEGY    

Conister Bank 
imited (the “Bank”)    
Conister Bank LLLLimited (the “Bank”)
imited (the “Bank”)
imited (the “Bank”)
Conister Bank 
Conister Bank 
The Bank’s Board of Directors (the “Board”) has set strategic 
objectives,  aligned  to  its  strategic  plan.  These  objectives 
provide the framework for setting risk appetite statements and 
tolerances  for  all  material  risks.  The  strategic  objectives  set 
are:- 

•  Maintain capital adequacy; 
•  Deliver stable earnings growth; 
•  Secure  stable  and  efficient  access  to  funding  and 

liquidity, and 

•  Maintain stakeholder confidence. 

These strategic objectives provide the link between the Bank’s 
strategic planning and its risk management framework, using 
risk appetite statements, measures and tolerances to manage 
risk  on  a  day-to-day  basis  and  are  reviewed  annually  and 
approved  by  the  Board.  Key  in  considering  the  Bank’s 
judgement  of  appetites  is  its  assessment  of  its  regulatory 
environment (both in the Isle of Man (“IOM”) and the United 
Kingdom (“UK”); the IOM deposit market; access to regulatory 
capital;  the  IOM  and  UK  credit  markets;  the  suitability  of  its 
product  range;  concentrations  of  advances  and  historic 
arrears. The aim is to deliver controlled growth, by providing 
adequate  returns  with  strong  credit  profiles.  In  addition,  the 
Bank  has  specifically  assessed  the  impact  of  the  Brexit  on 
both sides of its Balance Sheet.  

Having  considered  the  above,  drawing  on  both  internal  and 
external  resources,  the  Bank  continues  to  believe  the  credit 
markets it operates within remains conducive to growth with 
liquidity  sourced  from  both  its  balance  sheet  the  IOM’s 
substantial deposit base. This growth will be achieved through 
the  expansion  of  existing  products  organically  and  through 
acquisition.  The Bank continues to explore opportunities with 
both  new  products  and  new  markets.  This  strategy  can  be 
analysed  by  the  two  geographical  areas  the  Bank  operates 
within, namely the IOM and the UK. 

The  Bank’s  strategy  for  stable  growth  is  underpinned  by  its 
existing  mix  of  products,  both  for  the  IOM  and  UK  markets.  
The Bank is proud of its heritage and remains heavily centric 
in the IOM but recognises that as its UK loan book grows it will 
need to create a UK presence to manage and grow this aspect 
of its business.  As such, in 2018, the Bank opened offices in 
both Manchester and Newbury.  The former is a base for the 
Bank’s small but growing UK direct sales team and the latter 
deals with all aspects of the Bank’s UK credit broker market. 
These are two markets in which the Bank wishes to increase 
its presence. Furthermore, growth is forecast from the Bank’s 
Structured  Products  and  a  team,  led  by  an  experienced 
banker,  has  been  recruited  to  manage  this  product  range 
based in the Newbury office. 

Sourcing  reliable  funding  underpins  the  Bank’s  growth 
objectives.  Through  the  Bank’s  Class  1  Isle  of  Man  Deposit 
Taking licence it has access to £40.0 billion of deposits. The 
Bank  currently  restricts  itself  to  the  retail  market,  of  which  it 
has circa 1.0% market share, but the Bank recognises it has 
an  opportunity  to  increase  its  market  share  through  the 
reduction in competition experienced in this market and or by 
increasing  interest  rates.  Also,  the  Bank  is  considering 
accessing  other  IOM  deposit  markets,  for  example,  the 
corporate  deposit  market  where  its  systems,  processes  and 

reputation may provide a competitive advantage over others. 
As  such,  the  Bank  believes  that  it  is  armed  with  sufficient 
reliable  alternatives  to  be  confident  that  it  can  raise  the 
necessary deposits when required.  

The  Bank’s  acquisition  strategy  is  to  gain  market  share  in 
markets  it  already  operates  within  or  to  gain  access  to  a 
desirable  market  through  an  existing  reputable,  profitable 
operator.  

Regarding the former, the Bank continues to enjoy a positive 
lending  experience  within  the  UK  credit  broker  market  and 
currently has circa £20.0 million of net loans outstanding.  The 
strategy  for  growth  is  both  organic  (through  improving 
customer service and increasing the number of brokers on its 
roster)  and  acquisitive.    The Bank  is currently  in  negotiation 
with an established credit broker with the view of acquiring its 
non-regulated business during 2019.  

Edgewater Associates
Limited (“EAL”)    
Edgewater Associates    Limited (“EAL”)
Limited (“EAL”)
Limited (“EAL”)
Edgewater Associates
Edgewater Associates
Edgewater  Associates  Limited  is  the  largest  Independent 
Financial Advice firm in the Isle of Man and is regulated by the 
Isle  of  Man  Financial  Services  Authority.  Our  strategic 
objective is to: 

  Grow and service our client base; 
 
Increase assets under advice; and 
  Grow and develop our staff complement. 

EAL is a generalist IFA practice with a diverse mix of clients 
requiring a broad range of products and services covering: 

  First time buyers   ---   mortgages; 
  Newly  qualified  professionals      ---      protection, 

savings, school fees; 

  Established  clients      ---      wealth  management, 

retirement planning; and 

  General  insurance  clients      ---      home,  car,  travel, 

commercial, specialist. 

In  2016  EAL  embarked  on  an  aggressive  and  successful 
acquisition  programme  covering  a  two  year  period;  at  the 
outset  we  had  a  client  base  of  approximately  4,600  clients. 
After four acquisitions and an active data cleansing review, we 
now have an active client base of approximately 11,800, with 
associated assets under advice of £310 million ( up from £273 
million in 2017 ). 

Whilst  we  will  continue  to  grow  and  develop  our  standard 
business model, we will always be open to new opportunities. 
We  remain  nimble  and  ready  to  move  with  economic  and 
regulatory changes as they arise; our team remains up to date 
against industry standards and trends. We retain an appetite 
for  growth  either  through  additional  acquisition  opportunities 
that may arise, or via organic growth from our existing client 
bank and business partners with whom we have built strong 
relationships. 

Diversification  opportunities  are  also  encouraged  and 
pursued,  as  per  our  successful  programme  to  grow  /  build 
Employee  Benefit  Group  Schemes.  This  incorporates  staff 
pensions  (including  pension  freedom),  protection,  private 
medical cover, and death in service. 

Page | 4  

 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
STRATEGIC REPORT 

BUSINESS MODEL AND STRATEGY    

To  keep  pace  with  our  development  we  continue  to  train 
talented  young  people  to  progress  to  rounded,  professional 
advisers  who  are  able  to  fit  into  succession  planning.  To 
supplement this, we also take the opportunity to recruit quality 
experienced  advisers  and  para-planners  who  can  further 
enhance our team. 

Manx Manx Manx Manx FX Limited (“MFX”)
FX Limited (“MFX”)    
FX Limited (“MFX”)
FX Limited (“MFX”)
Established  in  2014,  MFX  has  specialist  knowledge  of 
currency operational requirements and has carefully selected 
the best UK partners to provide market foreign exchange and 
leading  payment  services.    The  strategic  objectives  of  MFX 
are: 

  To maintain and develop existing client relationship; 
  To  increase  the  number  of  referrals  to  our  foreign 
exchange  business  partners  with  a  view  of  on-
boarding new clients; and 

  To  raise  MFX’s  profile  and  build  a  professional 

reputation on the Isle of Man (“IOM”). 

We  believe  the  foreign  exchange  and  international  payment 
offering  via  our  UK  partners  is  second  to  none.    With  our 
upfront  agreed  foreign  exchange  margins  the  customer  has 
complete  pricing  transparency.    Our  business  partners  have 
been carefully selected to ensure they are able to obtain the 
best possible pricing from the market.  

The  international  payments  fees  offer  outstanding  value,  at 
hugely reduced fees compared to any local high street bank.  
At MFX, we realise that often our clients just need a facility to 
send  urgent  payments  quickly  and  efficiently  so  we  provide 
access  to  a  FX  and  payments  online  system  with  straight 
through  processing  to  make  these  tasks  as  effortless  as 
possible. 

For the next 12 months, MFX will concentrate its efforts in the 
IOM.  The IOM offers large potential having a diverse range of 
industries.  

A  small  but  dedicated  team  know  and  understand  the 
importance  of  offering  excellent  service  and  has  pride  and 
integrity  when  dealing  with  both  existing  clients  and  new 
prospects.    Our  professional  reputation  is  important  to  our 
business  and  our  colleagues  attend  local  industry  events 
which serves two purposes; to enforce and raise the profile of 
MFX and support IOM businesses.  

Maintaining a close working relationship with our UK partners 
is  core  to  our  business.    Regular  conference  calls  and 
quarterly  face-to-face  meetings  are  held  to  discuss  new 
opportunities,  changes  to  product  offering,  industry  updates 
and  just  as  importantly  a  chance  to  develop  the  personal 
working relationship. 

Page | 5  

 
 
 
    
 
 
 
 
 
 
RISK AND GOVERNANCE 

RISK MANAGEMENT    

Risk Risk Risk Risk mmmmanagement 
verview    
anagement ooooverview
verview
verview
anagement 
anagement 
Effective risk management is crucial to MFG’s sustainability. 
The  Board 
the  effective 
governance  of  risk  management.  The  Board  maintains  its 
oversight  and  responsibilities  in  terms  of  the  three  lines  of 
defence risk governance model set out below.  

is  ultimately  accountable 

for 

Determining the Group’s risk tolerance and appetite through 
enterprise  risk  management  is  a  key  element  of  MFG’s 
corporate  governance  framework.  This  framework  has  been 
enhanced during 2018 and sets out the governance principles, 
practices  and  guidance  to  facilitate  effective  and  efficient 
management of the Group’s business.  It is primarily designed 
to  assist  the  Group  in  enhancing  its  corporate  governance 
framework  and  intended  to  reinforce  the  key  elements  of 
widely  accepted  and  long  established  Quoted  Companies 
Alliance (“QCA”) corporate governance principles.   

its 

through 

(“ICAAP”)) 

A fundamental principle contained in the code, is for effective 
risk  management:  MFG  has  in  place  a  Risk  Management 
Framework  and  a  Capital  Management  Framework 
Internal  Capital  Adequacy 
(undertaken 
Assessment  Process 
the 
implementation  of  some  of  the  principles  of  the  MFG 
Governance  Framework  at  subsidiary 
level.  The  Risk 
Management  Framework  was  also  significantly  enhanced  in 
2018  and  ensures  that  MFG  conducts  its  business  in  the 
correct way and manages its financial resources responsibly 
to  safeguard  the  interests  of  all  its  stakeholders.  It  further 
supports the Board and senior management in fulfilling their 
respective duties in relation to the sustainable operation of the 
business.  The  risk  management  system  is  supported  by 

support 

to 

policies,  processes  and  activities  relating  to  the  taking, 
management and reporting of risk. 

Management and accountability
Management and accountability    
Management and accountability
Management and accountability
The  Audit,  Risk  and  Compliance  Committee  (“ARCC”)  is 
operated  at  a  group  level  and  currently  comprises  of  two 
experienced  non-executive  directors  who  are  both  qualified 
accountants.  Only  members  of  the  ARCC  have  the  right  to 
attend ARCC meetings to allow for independence. However, 
other individuals representing Risk, Compliance and Internal 
Audit are always invited by the Chairman of the Committee to 
attend all or part of any meeting as and when appropriate. 

The main objectives of the ARCC are to review operations and 
ensure  that  they  are  conducted  to  the  highest  possible 
standards. This is accomplished by providing an independent 
objective assurance function specifically for, but not limited to: 
Internal  Controls  and  Risk  Management  Systems; 
Whistleblowing  and  Fraud;  Risk  and  Compliance;  Internal 
Audit; and External Audit. 

It  provides  oversight  of  compliance  with  all  legislation, 
regulation and applicable codes of practice in the jurisdictions 
that  MFG  conducts  business;  and 
reviews  policies, 
procedures and processes to effectively identify, quantify and 
manage all material risks and to advise on best practice. 

GovGovGovGovernance framework
ernance framework    
ernance framework
ernance framework
The  following  overview  of  the  key  governance  components 
that  make  up  the  MFG  system  of  governance  illustrates  the 
crucial role of risk management: 

Page | 6  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RISK AND GOVERNANCE 

RISK MANAGEMENT    

Culture    
Culture
Culture
Culture
The  risk  culture,  which  forms  part  of  MFG’s  overall  culture, 
encompasses the tone at the top and a set of shared attitudes, 
values,  behaviours  and  practices  that  characterise  how 
individuals at MFG consider risk in their day-to-day business 
activities.  Learnings  are  taken  from  previous  incidents  and 
ongoing assessment to ensure continuous improvement in the 
management of risk.  

All  individuals  understand  the  importance  of  effective  risk 
management and ensure that risks associated with their role 
are  appropriately  understood,  managed  and 
reported. 
Individuals at all levels communicate risk related insights in a 
timely, transparent and honest manner. 

This culture is driven from the top by the Board and Executive 
Management through how they communicate, make decisions 
and motivate the business. Managers and leaders ensure that 
in  all  their  actions  and  behaviours  they  continually  reinforce 
the culture that the effective management of risk is critical to 
MFG’s  success  and  that  every  individual  plays  a  role  in  the 
management of risk. 

Appetite
Appetite    
Appetite
Appetite
Risk appetites are currently only set at subsidiary level and set 
out the maximum amount of risk that it is prepared to accept 
in  the  pursuit  of  delivering  on  business  objectives.  The  risk 
appetite covers all the risk types (e.g. strategic and business 
risk,  market  risk,  credit  risk,  liquidity  risk,  operational  risk, 
conduct  risk  and  compliance  &  legal  risk)  and  is  reviewed 
annually  and  as  the  operating  environment  changes  it  is 
constantly  measured  against  stated  appetite 
take 
appropriate action.   

to 

Risk identification, measurement & control    
Risk identification, measurement & control
Risk identification, measurement & control
Risk identification, measurement & control
Improving  a  robust  understanding  of  the  risks  to  which  the 
business is exposed is crucial to ensure that all material risks 
are appropriately monitored, managed and reported on. Each 
individual within the Group in conjunction with their manager 
is responsible for understanding the risks associated with their 
role.  An  understanding  of  risk  is  developed  through  the 
identification, 
appropriate, 
measurement of risks to which the business is exposed.  

and  where 

assessment 

These  processes  are  performed  as  part  of  strategy  setting, 
strategy execution and day-to-day operations and are referred 
to as risk and control assessments. The Risk team provides 
tools  to  aid  managers  and  individuals  in  developing  an 
understanding  of  risk  within 
their  respective  business 
responsibilities. 

The  risk  and  control  assessment  process  of  understanding 
risk and reviewing the adequacy and effectiveness of related 
controls and risk mitigation approaches is generally performed 
on a regular basis, at least annually, as part of a continuous 
risk management cycle. 

Three lines of 
efence and key assurance functions     
Three lines of ddddefence and key assurance functions 
efence and key assurance functions 
efence and key assurance functions 
Three lines of 
Three lines of 
As part of its overall governance framework, MFG has adopted 
best  practice  monitoring  and  control  mechanisms  by 
implementing  the  three  lines  of  defence  governance  and 
combined assurance model. This means that responsibility for 
the 
governance  and  oversight 

is  allocated 

throughout 

organisation  according 
principles.   

to 

the 

‘three 

lines  of  defence’ 

The three lines of defence governance model is regarded as 
international  best  practice  for  ensuring  good  governance 
(including  governance  within  risk  and  capital  management) 
across an organisation. The emphasis is placed on ownership, 
responsibility, 
independence,  assurance,  communication, 
oversight and transparency across MFG governance.  

The  term  ‘key  assurance  function’  refers  to  a  properly 
authorised  function,  whether  in  the  form of  a  person,  unit  or 
department,  serving  as  a  control  or  ‘checks  and  balances’ 
function from a governance perspective, and which carries out 
such activities.  These functions typically are second and third 
line of defence functions.  

First 
efence     
ine of ddddefence 
First lllline of 
efence 
efence 
ine of 
ine of 
First 
First 
The first line of defence e.g. business management is primarily 
risk  origination  and 
accountable 
management in accordance with risk policy and strategy. This 
includes 
implementing 
responses.    

identifying,  assessing  risks  and 

the  day-to-day 

for 

efence     
ine of ddddefence 
Second lllline of 
Second 
efence 
efence 
ine of 
ine of 
Second 
Second 
The second line of defence is responsible for the development 
and maintenance of the frameworks and policies. The second 
line  provides  oversight  of,  and  challenge  to,  the  first  line  of 
defence and drives the implementation of the frameworks and 
policies. 

Third 
efence     
ine of ddddefence 
Third lllline of 
efence 
efence 
ine of 
ine of 
Third 
Third 
The  third  line  of  defence  is  the  independent  assurance 
function  providing  overall  assurance 
the  Board  on 
governance, risk management, and internal controls. The third 
line of defence comprises of internal audit, external audit and 
other  independent  assurance  providers.    The  third  line  of 
defence is completely independent from the management of 
the day-to-day business activities 

to 

MFG MFG MFG MFG aaaassurance 
unctions     
ssurance ffffunctions 
unctions 
unctions 
ssurance 
ssurance 
MFG has effective systems of risk management and internal 
control.  The  tasks,  processes  and  obligations  of  the  key 
assurance functions are transparent and clearly defined, with 
regular exchange of information between the functions. Each 
of the functions is structured to ensure that the function has 
the necessary authority, independence, resources, expertise 
and  access  to  the  Board  and  all  relevant  employees  and 
information to exercise its authority.  The minimum assurance 
functions within MFG include:  

  Risk management function;   
  Compliance function; and 
 
Internal Audit function.  

The  head  of  each  of  these  key  functions  possesses  the 
necessary skills, experience and knowledge required for the 
specific positions they exercise, and meet all suitability or ‘fit 
and  proper’  requirements.  Written  guidelines  for  these 
functions are in place, and compliance with them is assured 
on a regular basis.   All of the key functions within MFG have 
a direct reporting line to the Board.  

Page | 7  

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
RISK AND GOVERNANCE 

RISK MANAGEMENT    

MFG is developing a combined assurance model to effectively 
manage  the  organisation’s  significant  risks  and  material 
matters  through  a  combination  of  the  assurance  service 
providers and functions described above. 

Risk st
verview    
rategy & ooooverview
Risk strategy & 
verview
verview
rategy & 
rategy & 
Risk st
Risk st
Risk Risk Risk Risk pppplanlanlanlan    
The Board has set strategic objectives, aligned to its strategic 
plan. These objectives provide the framework for setting risk 
appetite statements and tolerances for all material risks. The 
strategic objectives set are:- 

  Maintain capital adequacy; 
  Deliver stable earnings growth; 
  Secure  stable  and  efficient  access  to  funding  and 

liquidity, and 

  Maintain stakeholder confidence. 

its 

These  strategic  objectives  provide  the  link  between  the 
Group’s  strategic  planning  and 
risk  management 
framework,  using  risk  appetite  statements,  measures  and 
tolerances  to  manage  risk  on  a  day-to-day  basis  and  are 
reviewed  annually  and  approved  by  the  Board.  Key  to 
considering 
its 
assessment of its regulatory environment (both in the IOM and 
the UK); the IOM deposit market; access to regulatory capital; 
the  IOM  and  UK  credit  markets;  the  suitability  of  its  product 
range;  concentrations  of  advances  and  historic  arrears.    In 
addition, the Group has specifically considered the impact of 
a ‘hard’ Brexit on both sides of its Balance Sheet.  

judgement  of  appetites 

the  Group’s 

is 

Strategic risk plans are developed at subsidiary level with the 
intent of improving the risk frameworks and embedding these 
into a developing risk culture for the Group. 

Key deliveries of the Risk Management Framework are split 
between  ‘Risk  infrastructure’  and  ‘Risk  management  cycle’: 
The  risk  infrastructure  is  the  establishment  of  a  consistent 
foundation  and  approach  to  enterprise  requirements  and 
supporting  components  in  managing  risks.  The  cycle  of  risk 
management is adaptable and continuously progressing and 
responding to the changing internal and external environment. 

This work has resulted in: 

  The 

redesign 

of  Management  Committee 
frameworks,  including  roles  and  responsibilities  to 
ensure  that  all  material  risks  are  captured  and 
formally  considered  prior  to  presentation  to  the 
ARCC and the Board; 

  A  reclassification  of  the  policies  within  the  policy 
framework to ensure that the relevant Management 
Committee  is  accountable  for  the  policies  that 
support their risk, and to reduce the workload for the 
ARCC  and  Board,  enabling  them  to  focus  on 
overseeing  and  challenging  the  risk  management 
framework; 

  The development of more detailed Board approved 
risk  appetite  statements,  and  the  design  of  an 
underlying risk appetite measures framework, to be 
owned and monitored by the relevant Management 
Committee; 

  The design of a risk management framework which 
looks  to  adopt  a  common  language  across  the 
lines  of 
combined  assurance  model  (and  all 

defence),  with  a  supporting  risk  catalogue  and 
classification matrix; and 

  A high level risk assessment to identify the top risks 
enabling work to progress in a risk focused manner 
on completing risk and control assessments, in order 
to build a key controls monitoring programme. 

Principal r
isks    
Principal risks
isksisks
Principal r
Principal r
The Group has exposure to the following key risks: 

  Strategic risk; 
  Credit risk (including counterparty credit risk);  
  Liquidity risk; 
  Operational risk (including regulatory risk); 
  Market risk (including interest rate risk); 
  Concentration risk; and 
  Reputation risk. 

The  Group  has  considered  the  above  key  risks  that  it  faces 
and the mitigating controls against those risks: 

Strategic rrrriskiskiskisk    
Strategic 
Strategic 
Strategic 
Strategic risk is the risk to the Group’s revenue as set within 
the  budget  and  the  medium  term  plans  arising  through  sub 
optimal  implementation  of  the  strategic  plan  due  to  either 
internal or external factors faced by its subsidiaries. 

Controls and 
itigation    
Controls and mmmmitigation
itigation
itigation
Controls and 
Controls and 
The  Group  controls  and  mitigates  this  risk  via  a  number  of 
measures: 

  Subsidiaries  generally  commence 

formal 
planning  process  in  September  for  the  forthcoming 
year,  to  inform  the  budget  submitted  to  the  Group 
Boards for approval. In reality, the planning process 
is  continuous  and  responsive  to  change  in  the 
internal and external environment. 

their 

  Barriers to delivering the strategic plan, and changes 
to  planned  activity  are  captured  in  the  various 
subsidiary  ‘Managing  Director’s  Reports’  which  are 
submitted  to  their  respective  Boards  and  then 
ultimately reported to the Group Board at each Board 
meeting. The reports will take account of input from 
the Group Executive Directors and current financial 
performance  versus  budget  and  seek  to  highlight 
strategic responses for the related subsidiary. 
  Key  strategic  projects  are  managed  under  formal 
project  governance  with  progress  of  key  projects 
tracked, and communicated and discussed at regular 
project meetings. 

  The  impact  of  limited  capital,  liquidity,  operational 
capacity and regulator restriction on the achievement 
of strategy is captured by the planning process, with 
exceptional  items  dealt  with under  the  relevant  risk 
category,  where  the  impact  on  risk  appetite  and 
mitigating actions will be formally recorded.  

Page | 8  

 
 
 
 
 
 
 
    
    
 
    
    
RISK AND GOVERNANCE 

RISK MANAGEMENT    

risk 
risk 
risk 
risk 

(including 
(including 
(including 
(including 

counterparty, 
counterparty, 
counterparty, 
counterparty, 

concentration, 
concentration, 
concentration, 
concentration, 

Credit 
Credit 
Credit 
Credit 
underwriting and credit migration risks)    
underwriting and credit migration risks)
underwriting and credit migration risks)
underwriting and credit migration risks)
Credit risk is defined as the risk that counterparties fail to fulfil 
their  contractual  obligations.  A  material  decline  in  credit 
quality, or the failure of a counterparty could result in higher 
levels  of  arrears  and  ultimately  in  increased  provisions  and 
write-offs, which impacts upon profitability, potentially eroding 
the capital position for the Group’s subsidiaries.  

itigation    
Controls and mmmmitigation
Controls and 
itigation
itigation
Controls and 
Controls and 

individual 

  Delegated  authorities:  The  Group  operates  to  a 
schedule  of  delegated  authorisation  limits  linked  to 
an 
and 
experience.  This  is  bolstered  by  validations  of  all 
significant  credit  exposures  over  set  limits  and 
ongoing  monitoring  of  credit  positions  of  key 
suppliers and intermediary networks. 

underwriter’s 

knowledge 

  Distribution  strategy:  The  Group  actively  monitors 
and controls the credit risk of all business written to 
ensure  that  it  is  treating  customers  fairly  and  as  a 
safeguard  against  the  failure  of  any  business 
relationship.  Mitigation  of  counterparty  credit  risk  is 
undertaken 
the  maintenance,  where 
appropriate, of cash reserves and loss pools to fund 
any  buy-back 
indemnity.  Comprehensive  due 
diligence processes are also undertaken.  

through 

  Monitoring  of  credit  quality  exposure:  The  Group 
monitors  its  credit  risk  exposures  via  an  internal 
credit  risk  grading  methodology  that  assigns  each 
individual  exposure  with  one  of  three  credit  grades 
based upon the probability of default at product and 
distribution  channel  level.  This  allows  for  better 
monitoring  of  credit  quality  and  impairment  of  its 
current book as well as forecast and stress test on a 
more accurate basis.  

  Concentration 
the 
risk:  To  protect  against 
exposures  where 
build-up 
unintentional 
deterioration 
the 
impact 
could  materially 
sustainability  and  profitability,  the  Group  seeks  to 
maintain  a  diverse  portfolio  of  products  across  a 
variety  of  geographical  regions,  customers,  sectors 
and asset classes. This diversity protects the Group 
against any deterioration in a particular geographical 
region, 
the  economic  environment,  commercial 
sector etc.  

  Accounting  standards:  Finally,  the  introduction  of 
IFRS 9, effective from 2018, necessitated the move 
to an expected loss provisioning methodology rather 
than an incurred loss. This will provide an additional 
credit risk buffer.  

of 

Operational risk (including conduct)
Operational risk (including conduct)    
Operational risk (including conduct)
Operational risk (including conduct)
Operational risk is the risk of loss resulting from human error, 
inadequate  or  failed  internal  processes  or  controls,  system 
failure, improper conduct, fraud or external events. 

The  principal  operational  risks  for  the  Group  arise  from  the 
following areas: 

  Resilience of the IT environment: The IT environment 
is  under  constant  review  to  identify  and  implement 
efficiencies  to  enable  increased  customer  service 
through  the  provision  of  additional  services  and 
products  and  to  automate  manual  tasks  wherever 
possible  to  minimise  the  potential  for  human  error. 
The  Group  implemented  an  IT  Steering  Committee 

during  2017  to  review  and  monitor  current  service 
standards,  highlight  any  deficiencies  and  mitigate 
accordingly. There are a number of exception reports 
and scheduled tasks on a daily basis to ensure that 
any  controls  within  systems  are  being  reported  on 
adequately. 

  Third  Party  administration  services:  The  key 
operational controls ensure that partners are fulfilling 
their legal, regulatory obligations in accordance with 
their  service-level  agreement  with  the  Group.    The 
Group  has  an  outsourcing  policy 
to  ensure 
obligations are monitored and met. Internal reviews 
and  audits  are  conducted  on  counterparties  to 
ensure terms agreed are being adhered to.  

itigation    
Controls and mmmmitigation
Controls and 
itigation
itigation
Controls and 
Controls and 

  Adherence to internal limits and approval processes 

through:  

o  Delegated authorities: The Group operates 
to  a  schedule  of  delegated  credit 
authorisation  limits  and  payment  approval 
limits,  linked  to  an  individual’s  knowledge 
and experience.  

o  Segregation of Duties: There is appropriate 
segregation  between 
those  authorising 
transactions and those executing them, with 
four  eyes  principals 
in  place  where 
required. 
o  Exception 

reporting 
reporting:  Daily 
ensures  that  any  regulatory  and  internal 
the 
limits  are 
appropriate Management team. 

regularly  by 

reviewed 

o  New Business approval policy: All material 
new  business  is  approved  in  line  with  a 
formally  approved  policy,  with  ultimate 
decision making resting with the applicable 
EXCO. 

  Change  control:  The  Group  ensures  that  both 
changes to existing products and services and new 
products  and  services  are  delivered  in  a  controlled 
manner with the appropriate checks and controls in 
place.   

  A  comprehensive  on-boarding  process  in  place  for 

new outsourced partners in the UK. 

  Due diligence checks: The operational risk from the 
Group’s  third  party  administrators  is  mitigated  by  a 
comprehensive  due  diligence  process  which 
includes a take-on due diligence and a full review of 
the  partner’s  policies,  procedures  and  financial 
stability.  

  Key  Operational  Controls:  Key  controls  are 
monitored  through  a  combination  of  management 
oversight,  Risk  and  Compliance  monitoring  and 
Internal Audit reviews.  

  New  Business  Policy  and  Process  –  new  business 
and material business change is outlined in a formal 
policy,  which 
that  a  sequence  of 
assessment  and  approval  is  followed.  This  will 
ensure that all relevant input is included and material 
risks considered.  

requires 

  Exception  reports:  Exception  reporting  allows  the 
Group  to  identify  weaknesses  in  processes  and 
controls  which  in  turn  allows  for  adequate  training 
and the bolstering of systems and processes. 

Page | 9  

 
 
 
    
 
 
    
 
RISK AND GOVERNANCE 

RISK MANAGEMENT    

Conduct risk
Conduct risk    
Conduct risk
Conduct risk
The Group is exposed to conduct risk through its operations 
and  interactions  with  consumers,  either  directly  or  through 
third parties (brokers, or counter-parties).   The risk exposure 
is  regulatory  in  nature  for  the  Group’s  UK  based  operations 
and consideration of any local jurisdiction guidance on good 
practice. 

Controls and m
itigation    
Controls and mitigation
itigation
itigation
Controls and m
Controls and m
The Group has an outsourcing policy to ensure that adherence 
to  conduct  and  regulatory  standards  is  contracted,  and 
compliance with standards is appropriately monitored through 
the  collection  and  assessment  of  relevant  data,  partner 
attestation, and onsite audits where appropriate.  

General  conduct  and  particularly  Treating  Customers  Fairly 
(“TCF”) principles are applied across the Group’s activities.  

Liquidity risk
Liquidity risk    
Liquidity risk
Liquidity risk
Financial institutions are subject to liquidity risk as an inherent 
part of their business. Liquidity risk is the risk that the Group 
may not hold sufficient liquid funds meaning it would be unable 
to meet its contractual liabilities as they fall due.  

Liquidity risk arises where the Group, through its subsidiaries, 
has  contractual  credit  obligations  that  can  be  placed  under 
stress  during 
illiquidity.  The  Group  generally 
accesses wholesale funding markets or builds a core portfolio 
of liquid assets or buffers as additional sources of liquidity that 
can be utilised during such times.  

times  of 

Controls and 
itigation    
Controls and mmmmitigation
itigation
itigation
Controls and 
Controls and 
Overall the Group’s liquidity profile is resistant to stress as the 
Group: 

  Has no contractual credit obligation. The Group has 
no  absolute  credit  line  obligations  to  its  customers 
meaning that in times of liquidity stress, it is able to 
reduce its lending appetite accordingly;  

  Has a matched funding profile and does not engage 
in  maturity  transformation  which  means  that  on  a 
cumulative mismatch position the Group is forecast 
to be able to meet all liabilities as they fall due;  

  Maintains an adequate liquidity buffer; and 
  Has no exposure to the interbank lending market.  

The  Group’s  liquidity  position  is  monitored  on  a  daily  basis 
against  internal  and  external  agreed  limits.  The  Group  also 
has a Liquidity Contingency Policy and Liquidity Contingency 
Committee  should  a  liquidity  crisis  or  potential  liquidity 
disruption event occur.  

Reputation risk
Reputation risk    
Reputation risk
Reputation risk
Reputational Risk is the risk of loss resulting from damages to 
the Group’s reputation, in lost revenue or increased costs; or 
destruction of shareholder value. 

Controls and 
itigation    
Controls and mmmmitigation
itigation
itigation
Controls and 
Controls and 
The Group mitigates this risk by ensuring that its key risks are 
identified  and  managed,  with  an  impact  assessment  of  any 
potential  or  actual  issues  considering  the  impact  to  the 
Group’s reputation. The Group actively seeks to minimise the 
occurrence of events or issues which could give rise to loss or 
negative  feedback,  and actively  manages  the  impact should 
issues occur.  

Interest rate risk    
Interest rate risk
Interest rate risk
Interest rate risk
The  principal  potential  interest  rate  risk  that  the  Group  is 
exposed  to  is  the  risk  that  the  fixed  interest  rate  and  term 
profile  of  its  deposit  base  differs  materially  from  the  fixed 
interest  rate  and  term  profile of  its  asset  base,  or  basis  and 
term structure risk.  

itigation    
Controls and mitigation
Controls and m
itigation
itigation
Controls and m
Controls and m

  Funding profile: Interest rate risk for the Group is not 
deemed to be material currently due to the Group’s 
matched  funding  profile.  In  a  rising  interest  rate 
environment  due  to  the  nature  of  the  Group’s 
products  and  its  matched  funded  profile,  it  should 
theoretically  be  able  to  increase  its  lending  rate  to 
match any corresponding rise in its cost of funds.  
  The  Group  attempts  to  efficiently  match  its  deposit 

taking to its funding requirements.  

  The decay of the Group’s loan book through staged 
repayments  means  interest  risk  is  difficult  to hedge 
effectively  so  the  Group  does  not  currently  hedge 
against this risk, and is therefore not exposed to any 
additional market interest rate risk in this respect. 
  Funding  cost:  The  Group  would  be  exposed  to 
potential risk if its cost of funds, which is linked to the 
cost  of  retail  deposits,  and  ultimately  the  UK  base 
rate,  was  to  increase  and  it  was  unable,  due  to  a 
competitive lending environment, to raise its lending 
rate  correspondingly.  The  Group’s  three  year  plan 
allows  for  an  increase  in  its  cost  of  funds,  but  the 
Group  accepts  that  these  assumptions  may  not 
reflect  the  timing  of  any  interest  rate  rise  or  the 
quantum of the increase(s).  

Regulatory risk
Regulatory risk    
Regulatory risk
Regulatory risk
Regulatory risk is the risk of material breach of regulation.  

The  Group  holds  a  Class  1  (1)  Banking  Licence  and  is 
accordingly  regulated  by  the  FSA.  The  Group  also  holds 
permissions  with  the  FCA  pertaining  to  regulated  credit 
activities, and other specified regulated products and services 
in the UK. 

The  risk  of  regulatory  breach  arises  through  a  failure  to 
identify, assess and apply applicable regulation; or a failure to 
adhere to the applicable regulation as applied. 

Monitoring  and  complying  with  the  requirements  of  existing 
regulation across numerous regulatory bodies, along with the 
rapid pace and volume of regulatory change is a key risk. The 
risk is compounded due to the size of the Group, and the need 
to maintain a manageable cost of compliance.  

Controls and 
itigation    
Controls and mmmmitigation
itigation
itigation
Controls and 
Controls and 
The  Group  remains  well  placed  to  meet  the  regulatory 
challenges  that  bring  change  to  the  macro  environment.  In 
order to strengthen the Risk and Compliance department, the 
ARCC and Board have increased the headcount in 2018 and 
have  appointed  an  experienced  Head  of  Risk  and 
Compliance.  

Page | 10  

 
 
 
    
 
 
 
    
 
 
    
    
    
 
 
 
 
 
 
 
 
RISK AND GOVERNANCE 

RISK MANAGEMENT    

Regulatory risks continue to be mitigated by themed and ad-
hoc compliance monitoring reviews which are driven using a 
risk based approach to ensure resource is directed to areas of 
potential  material  risk.  The  monitoring  plan  is  approve 
annually by ARCC. Monitoring reviews are supplemented by 
ongoing staff training and guidance. 

Wherever  possible,  legislative  and  regulatory  requirements 
are built into relevant administration systems, with appropriate 
monitoring  and  exception  reporting  processes  in  place  to 
monitor compliance. 

The  Group  maintains  a  watching  brief  on  the  regulatory 
environment and, as active members of a number of IOM and 
UK trade bodies, it receives additional regulatory updates and 
guidance  on  proposed  legislative  and  regulatory  issues. 
Upstream  regulatory  changes  are  tracked  and  assessed  for 
impact  by  the  Compliance  Department  and  material  items 
reported to ARCC. 

Internal Capital Adequacy Assessment Process     
Internal Capital Adequacy Assessment Process 
Internal Capital Adequacy Assessment Process 
Internal Capital Adequacy Assessment Process 

Overview
Overview    
Overview
Overview
ICAAP  is  a  key  strategic  and  risk  management  tool  for  the 
Bank.  It  is  a  key component of  the  Bank’s  planning  process 
during the short and medium term. The Bank’s lead regulator, 
the  FSA,  requires  the  Bank  to  establish  and  maintain  an 
internal  adequacy  assessment  process  which  is  appropriate 
to the nature and scale of its business and review that process 
annually and evidence that review. 

Methodology
Methodology    
Methodology
Methodology
The Bank’s ICAAP process is as follows: 

Formulation of the Bank’s strategy and budget 
Formulation of the Bank’s strategy and budget     
Formulation of the Bank’s strategy and budget 
Formulation of the Bank’s strategy and budget 
Strategic  plans  are  prepared  annually  for  the  forthcoming 
year, which will consider the Bank’s risk appetite, key market 
sectors to target, products to leverage/introduce, headcount, 
operational and capital investment required. 

Risk assessment    
Risk assessment
Risk assessment
Risk assessment
The Executive Team will liaise with the Risk and Compliance 
department to determine the material risks in the Bank based 
on  incidents  and  breaches,  Internal  Audit  reports,  Risk  and 
Compliance report findings and issues raised at the Board and 
Committee meetings. 

Stress testing and reverse stress testing
Stress testing and reverse stress testing    
Stress testing and reverse stress testing
Stress testing and reverse stress testing
The  Finance  department  use  Bank  of  England  market 
assumptions  for  stress  testing  and  stress  the  five-year 
forecasts  to  identify  any  capital  deficiencies.  Reverse  stress 
testing  is  also  used based  on  the  assumption  that  the  Bank 
ceases to trade, coupled with a run-off scenario to determine 
the capital distribution.  

Reverse stress testing is used to explore the vulnerabilities of 
the Bank’s strategy and plans to extreme adverse events that 
would  cause  the  business  to  fail  in  order  to  facilitate 
contingency planning. 

Calculation of capital requirement and buffers
Calculation of capital requirement and buffers    
Calculation of capital requirement and buffers
Calculation of capital requirement and buffers
Following the setting of strategy, risk assessment and stress 
tests, the Bank will then calculate its capital requirements by 
considering the following areas: 

  Pillar  I  –  The  calculation  is  based  on  the  minimum 
regulatory requirement under Pillar I of 10.0% of risk 
weighted assets for material risks; 

  Pillar II – Assessment of any additional business risks 
not covered by the minimum Pillar I requirement, plus 
an  assessment  of  Pillar  II  risks  based  upon  the 
current material risk assessment and stress tests, to 
determine whether any additional capital buffers are 
deemed appropriate. An assessment of Pillar II and 
applicable  capital  add-ons  have  been  assessed  in 
Appendix 1; and 

  Pillar  III  –  Pillar  III  establishes  measures  to  make 
better use of market discipline. Pillar III applies only 
at the top consolidated level of a banking group and 
is therefore generally not considered to be applicable 
to  IOM  incorporated  banks  as  per  FSA  ICAAP 
guidance.  

  Buffers – The Bank assesses its position to industry 
standard  for  regulatory  buffers  and  calculates  its 
position  based  on  its  overall  exposures  to  different 
jurisdictions. 

Review, challenge and adoption of the ICAAP
Review, challenge and adoption of the ICAAP    
Review, challenge and adoption of the ICAAP
Review, challenge and adoption of the ICAAP
The  ICAAP  is  prepared  by  the  Finance  department  in 
conjunction  with  the  Risk  and  Compliance  department,  and 
reviewed  by  the  Bank’s  Executive  Team,  Risk  Management 
Committee,  ARCC,  Internal  Audit  and  the  External  Auditor 
prior  to  approval  by  the  Board.  It  is  used  to  measure  and 
benchmark  the  Bank’s  risk  appetite  and  to  forecast  capital 
usage under both stressed and normal conditions. The ICAAP 
is challenged at all stages of the review process and presented 
to the Board by ARCC for approval prior to being submitted to 
the  FSA.  The  ICAAP  is  regularly  reviewed  and  updated 
throughout the year by management and referred to the ARCC 
and Board. 

ICAAP Results
ICAAP Results    
ICAAP Results
ICAAP Results
The  Bank  has  completed  its  ICAAP  testing  for  2018  in 
compliance with regulatory requirements. Despite the severity 
of the risk scenarios modelled, the Bank satisfied the capital 
and leverage requirements for the purpose of the stress test. 
The Bank did not require taking of any capital action as a result 
of the test. 

Page | 11  

 
 
 
 
 
 
 
 
    
RISK AND GOVERNANCE 

CORPORATE GOVERNANCE REPORT    

to  comply  with 

Corporate 
eport     
overnance rrrreport 
Corporate ggggovernance 
eport 
eport 
overnance 
overnance 
Corporate 
Corporate 
The Manx Financial Group Board (the “Board”) is committed 
to  best  practice  in  corporate  governance.  Directors  have 
agreed 
the  Quoted 
Companies Alliance (“QCA”) Corporate Governance Code for 
Small and Mid-Size Quoted Companies to the extent which is 
appropriate to its nature and scale of operations. This report 
illustrates  how  Manx  Financial  Group  PLC  (the  “Group”) 
complies with those principles. 

the  provisions  of 

QCA  Principle  1:  Establish  a  strategy  and  business  model 
QCA  Principle  1:  Establish  a  strategy  and  business  model 
QCA  Principle  1:  Establish  a  strategy  and  business  model 
QCA  Principle  1:  Establish  a  strategy  and  business  model 
value for shareholders    
which promote long----termtermtermterm    value for shareholders
which promote long
value for shareholders
value for shareholders
which promote long
which promote long

The immediate strategy and business operations of the Group 
are set out in the Strategic Report on pages 4 and 5. 

The Group’s strategy and business model and amendments 
thereto, are developed by the Chief Executive Officer and his 
senior  management  team,  and  approved  by  the  Board.  The 
management  team,  led  by  the  Chief  Executive  Officer,  is 
responsible for implementing the strategy and managing the 
business at an operational level.  

The  Group’s  overall strategic objective  is  to capitalise on  its 
unique position as owning the only independent Bank within 
the  British  Crown  Dependencies  by  developing  core 
financial  services  sector,  both 
businesses  within 
organically and by considered acquisitions. 

the 

The  Group  has  a  balanced  portfolio  of  regulated  and 
unregulated operations, all of which are managed on a risk-
based  and  prudential  approach.  The  principal  activities 
include: deposit taking; lending to consumer and commercial 
markets  in  the  IOM  and  the  UK;  the  provision  of  dedicated 
financial  advice,  especially  in  the  areas  of  pensions  and 
general insurance; and foreign currency advisory. Ultimately, 
the Directors believe that this approach will deliver significant 
long-term value for Shareholders. 

The  Group  has  adopted  a  portfolio  approach  to  its  strategic 
assets  and  is  not  dependent  on  one  particular  platform 
technology. The Directors believe that this approach helps to 
mitigate any concentration risk. 

The Group largely operates in an inherently heavily regulated 
sector and this is reflected in the emphasis on compliance and 
the provision of excellent customer service. 

In  executing  the  Group’s  strategy  and  operational  plans, 
management  will  typically  confront  a  range  of  day-to-day 
challenges  associated  with  risks  and  uncertainties,  and  will 
seek to deploy the identified mitigation steps to manage these 
risks as they manifest themselves.  

QCA  Principle  2:  Seek  to  understand  and  meet 
shareholder 
QCA  Principle  2:  Seek  to  understand  and  meet  shareholder 
shareholder 
shareholder 
QCA  Principle  2:  Seek  to  understand  and  meet 
QCA  Principle  2:  Seek  to  understand  and  meet 
needs and expectations    
needs and expectations
needs and expectations
needs and expectations

The Group, via the Chief Executive Officer, seeks to maintain 
a  regular  dialogue  with  both  existing  and  potential  new 
Shareholders in order to communicate the Group’s strategy 
and progress and to understand the needs and expectations 
of Shareholders. 

Beyond  the  Annual  General  Meeting,  the  Chief  Executive 
Officer and, where appropriate, other members of the senior 

management  team  will  meet  with  investors  and  analysts  to 
provide  them  with  updates  on  the  Group’s  business  and  to 
obtain  feedback  regarding  the  market’s  expectations  of  the 
Group. 

The Group’s investor relations activities encompass dialogue 
with both institutional and private investors. From time to time, 
the  Company  attends  private  investor  events,  providing  an 
opportunity  for  those  investors  to  meet  with  representatives 
from the Group in a more informal setting. 

QCA  Principal  3:  Take  into  account  wider  stakeholder  and 
QCA  Principal  3:  Take  into  account  wider  stakeholder  and 
QCA  Principal  3:  Take  into  account  wider  stakeholder  and 
QCA  Principal  3:  Take  into  account  wider  stakeholder  and 
social  responsibilities  and  their  implications  for  long
term 
social  responsibilities  and  their  implications  for  long----term 
term 
term 
social  responsibilities  and  their  implications  for  long
social  responsibilities  and  their  implications  for  long
success    
success
success
success

suppliers, 

employees, 

The Group is aware of its corporate social responsibilities and 
the need to maintain effective working relationships across a 
range  of  stakeholder  groups.  These  include  not  only  the 
Group’s 
regulatory 
partners, 
authorities, but also customers, be they depositors, borrowers 
or  seeking  financial  advice.  The  Group’s  operations  and 
working  methodologies  take  account of  the  need  to balance 
the needs of all of these stakeholder groups while maintaining 
focus  on  the  Board’s  primary  responsibility  to  promote  the 
success of the Group for the benefit of its members as a whole. 
The Group endeavours to take account of feedback received 
to  working 
from  stakeholders,  making  amendments 
arrangements  and  operational  plans  where  appropriate  and 
where  such  amendments  are  consistent  with  the  Group’s 
longer-term strategy. 

The Group takes due account of any impact that its activities 
may  have  on  the  environment  and  seeks  to  minimise  this 
impact  wherever  possible.  Through  the  various  procedures 
and  systems  it  operates,  the Group  ensures  full  compliance 
with  regulatory,  health  and  safety,  and  environmental 
legislation relevant to its activities. 

QCA  Principal  4:  Embed  effective 
risk  management, 
risk  management, 
QCA  Principal  4:  Embed  effective 
risk  management, 
QCA  Principal  4:  Embed  effective 
risk  management, 
QCA  Principal  4:  Embed  effective 
considering  both  opportunities  and  threats,  throughout  the 
considering  both  opportunities  and  threats,  throughout  the 
considering  both  opportunities  and  threats,  throughout  the 
considering  both  opportunities  and  threats,  throughout  the 
organisation    
organisation
organisation
organisation

The Board is responsible for the systems of risk management 
and internal control and for reviewing their effectiveness by a 
series  of  committees,  overseen  by  the  Audit,  Risk  and 
Compliance  Committee  (“ARCC”),  and  reviewed  by  Internal 
Auditors. The internal controls are designed to manage rather 
than  eliminate  risk  and  provide  reasonable  but  not  absolute 
assurance against material misstatement or loss. Through the 
activities of the ARCC, which meets at least six times per year, 
is  formally 
the  effectiveness  of  these 
reviewed four times per year. 

internal  controls 

A comprehensive budgeting process is completed once a year 
and  is  reviewed  and  approved  by  the  Board.  The  Group’s 
results, compared with the budget, are reported to the Board 
on a monthly basis. 

The Group maintains appropriate insurance cover in respect 
of actions taken against the Directors because of their roles, 
as well as against material loss or claims against the Group. 
The  insured  values  and  type  of  cover  are  comprehensively 
reviewed on at least an annual basis. 

Page | 12  

 
 
 
RISK AND GOVERNANCE 

CORPORATE GOVERNANCE REPORT    

The senior management team (“Executive Committee”) meets 
weekly to consider new risks and opportunities presented to 
the  Group,  making  recommendations  to  the  Board  and/or 
ARCC as appropriate. 

QCA  Principal  5:  Maintain  the  board  as  a  well
functioning, 
QCA  Principal  5:  Maintain  the  board  as  a  well----     functioning, 
functioning, 
functioning, 
QCA  Principal  5:  Maintain  the  board  as  a  well
QCA  Principal  5:  Maintain  the  board  as  a  well
team led by the chair    
balanced team led by the chair
balanced 
team led by the chair
team led by the chair
balanced 
balanced 

various  external  advisers  on  a  number  of  corporate 
governance matters. 

Directors’  service  contracts  or  appointment  letters  make 
provision for a Director to seek personal advice in furtherance 
of  his  or  her  duties  and  responsibilities,  normally  via  the 
Company Secretary. 

The  Group’s  Board  currently  comprises  four  Non-executive 
Directors and three Executive Directors. 

QCA Principal 7
Evaluate board performance based on clear 
QCA Principal 7::::    Evaluate board performance based on clear 
Evaluate board performance based on clear 
Evaluate board performance based on clear 
QCA Principal 7
QCA Principal 7
and relevant objectives, seeking continuous improvement    
and relevant objectives, seeking continuous improvement
and relevant objectives, seeking continuous improvement
and relevant objectives, seeking continuous improvement

All of the Directors are subject to election by Shareholders at 
the first Annual General Meeting after their appointment to the 
Board and will continue to seek re-election at least once every 
three years. 

Directors’ biographies are set out on pages 16 and 17. 

The Board is responsible to the Shareholders for the proper 
management of the Group and meets at least four times a year 
to set the overall direction and strategy of the Group, to review 
operational  and  financial  performance,  and  to  advise  on 
management  appointments.  All  key  operational  and 
investment decisions are subject to Board approval. 

The Board considers itself to be sufficiently independent. The 
QCA  Code  suggests  that  a  board  should  have  at  least  two 
independent  non-executive  directors.  The  Board  considers 
that 
two  Non-executive  Directors,  namely  Alan  Clark 
(Chairman  of  ARCC)  and  David  Gibson,  are  regarded  as 
independent under the QCA Code’s guidance for determining 
such independence. 

Non-executive  Directors  receive  their  fees  in  the  form  of  a 
basic cash emolument. Only the Chief Financial Officer holds 
options over the Group’s shares. The number and terms are 
found on page 23. 

The option grant concerned is not deemed to be significant, 
either for the individual executive Director or in aggregate. The 
current remuneration structure for the Board’s Non-executive 
Directors is deemed to be proportionate. 

QCA Principal 6
re that between them the directors have 
QCA Principal 6::::    EnsuEnsuEnsuEnsure that between them the directors have 
re that between them the directors have 
re that between them the directors have 
QCA Principal 6
QCA Principal 6
date experience, skills and capabilities    
the necessary up----totototo----date experience, skills and capabilities
the necessary up
date experience, skills and capabilities
date experience, skills and capabilities
the necessary up
the necessary up

The  Board  considers  that  all  of  the  Non-executive  Directors 
are of sufficient competence and calibre to add strength and 
objectivity to its activities, and bring considerable experience 
in regulatory, financial and operational development within the 
financial service sector in both the IOM and the UK. 

The Directors’ biographies are set out on pages 16 and 17. 

The Board regularly reviews the composition of the Board to 
ensure that it has the necessary breadth and depth of skills to 
support the ongoing development of the Group. 

The  Chairman,  in  conjunction  with  the  Company  Secretary, 
ensures that the Directors’ knowledge is kept up to date on key 
its 
issues  and  developments  pertaining  to  the  Group, 
operational environment and to the Directors’ responsibilities 
as  members  of  the  Board.  During  the  course  of  the  year, 
Directors  receive  updates  from  the  Company  Secretary  and 

The  Board  has  an  internal  process  for  evaluation  of  its  own 
performance, that of its committees and individual Directors, 
including  the  Chairman.  This  process  is  conducted  annually 
and last took place in March 2018, with no substantive issues 
arising. Going forward, the Board intends to utilise the services 
of  an  independent  third-party  organisation  to  manage  the 
future evaluation process, analyse the results and report back 
to  the  Board  for  subsequent  follow-up.  Evaluation  criteria 
include  Controls  and  Procedures,  Strategic  Aims, 
Entrepreneurial  Leadership  and  Communications  and 
Relationships. 

The  Board  may  utilise  the  results  of  the  evaluation  process 
when  considering  the  adequacy  of  the  composition  of  the 
Board and for succession planning. 

QCA Principal 8
ote a corporate culture that is based on 
QCA Principal 8::::    PromPromPromPromote a corporate culture that is based on 
ote a corporate culture that is based on 
ote a corporate culture that is based on 
QCA Principal 8
QCA Principal 8
ethical values and behaviours    
ethical values and behaviours
ethical values and behaviours
ethical values and behaviours

The Board seeks to maintain the highest standards of integrity 
and probity  in  the conduct of the  Group’s  operations.  These 
values  are  enshrined  in  the  written  policies  and  working 
practices  adopted  by  all  employees  in  the  Group.  An  open 
culture 
the  Group,  with  regular 
communications to staff regarding progress and staff feedback 
regularly sought. The Executive Committee regularly monitors 
the  Group’s  cultural  environment  and  seeks  to  address  any 
concerns  that  may  arise,  escalating  these  to  Board  level  as 
necessary. 

is  encouraged  within 

The Group is committed to providing a safe environment for its 
staff and all other parties for which the Group has a legal or 
moral  responsibility  in  this  area.  This  is  enshrined  in  the 
Group’s health and safety policy. 

QCA  Principal  9
Maintain  governance  structures  and 
QCA  Principal  9::::     Maintain  governance  structures  and 
Maintain  governance  structures  and 
Maintain  governance  structures  and 
QCA  Principal  9
QCA  Principal  9
processes that are fit for purpose and support good decision
processes that are fit for purpose and support good decision----    
processes that are fit for purpose and support good decision
processes that are fit for purpose and support good decision
making by the board    
making by the board
making by the board
making by the board

ole of the Board     
The The The The rrrrole of the Board 
ole of the Board 
ole of the Board 
The Board is collectively responsible for the long-term success 
of  the  organisation.  Its  principal  function  is  to  determine  the 
strategy and policies of the Group within an effective control 
framework which enables risk to be assessed and managed. 

The  Board  ensures  that  the  necessary  financial  and  human 
resources are in place for the Group to meet its objectives and 
that  business  and  management  performances  are  reviewed. 
Furthermore, the Board ensures that the Group operates within 
its  constitution,  relevant  legislation  and  regulation  and  that 
proper accounting records and effective systems of business 
control are established, maintained, documented and audited.  

Page | 13  

 
 
 
RISK AND GOVERNANCE 

CORPORATE GOVERNANCE REPORT    

There are at least four formal Board meetings each year. All 
Board members have the benefit, at the Group’s expense, of 
liability  insurance  in  respect  of  their  responsibilities  as 
Directors  and  have  access  to  independent  legal  or  other 
professional  advice  if  required.  The  Board  has  a  formal 
schedule  of  matters  which  are  reserved  for  its  consideration 
and  it  has  established  three  committees  to  consider  specific 
issues  in  greater  detail,  being  the  ARCC  and  Nomination 
Committee.  The  Terms  of  Reference  for  each  of  these 
Committees are published on the Group’s website.  

There  is  a  clear  separation  of  the  roles  of  Chief  Executive 
Officer and Executive Chairman.  

Chairman 
Chairman     
Chairman 
Chairman 
The Chairman is responsible for leading the Board, ensuring 
its effectiveness in all aspects of its role, promoting a culture of 
openness  of  debate  and  communicating  with  the  Group’s 
members  on  behalf  of  the  Board.  The  Chairman  sets  the 
direction of the Board and promotes a culture of openness and 
debate  by  facilitating  the  effective  contribution  of  Non-
executive  Directors  and  ensuring  constructive  relations 
between  Executive  and  Non-executive  Directors.  The 
Chairman also ensures that Directors receive accurate, timely 
and  clear  information.  In  doing  so,  this  fosters  a  positive 
corporate governance culture throughout the Group.  

Chief Executive Officer 
Chief Executive Officer     
Chief Executive Officer 
Chief Executive Officer 
The  Chief  Executive  Officer  is  responsible  for  managing  the 
Group’s business and operations within the parameters set by 
the Board.  

NonNonNonNon----executive Directors 
executive Directors     
executive Directors 
executive Directors 
The  Non-executive  Directors  are  responsible  for  bringing 
independent judgement to the discussions held by the Board, 
using  their  breadth  of  experience  and  understanding  of  the 
business.  Their  key  responsibilities  are  to  constructively 
challenge and contribute to strategic proposals, and to monitor 
performance, 
resources,  and  standards  of  conduct, 
compliance and control, whilst providing support to executive 
management in developing the Group. 

The  Board  has  established  an  ARCC,  a  Remuneration 
Committee  and  a  Nominations  Committee  with  formally 
delegated duties and responsibilities. Alan Clarke chairs both 
ARCC and the Remuneration Committee. 

information  disclosed 

ARCC
ARCC    
ARCCARCC
ARCC meets at least six times each year and comprises two 
Nonexecutive Directors, currently Alan Clarke (Chairman) and 
David  Gibson,  Executive  Directors.  Representatives  from 
Compliance  and  Risk  along  with  the  internal  and  external 
Auditor  attend  by  invitation.  Its  role  is  to  be  responsible  for 
reviewing  the  integrity  of  the  financial  statements  and  the 
the  accompanying 
balance  of 
Directors’  Report,  to  review  the  effectiveness  of  internal 
controls and risk management systems, to monitor and review 
the effectiveness of the internal audit function and to consider 
and recommend to the Board (for approval by the members) 
the appointment or re-appointment of the external auditor. The 
ARCC reviews and monitors the external auditor’s objectivity, 
competence, effectiveness and independence, ensuring that 
if it or its associates are invited to undertake non-audit work it 
will not compromise auditor objectivity and independence.  

in 

Remuneration Committee 
Remuneration Committee     
Remuneration Committee 
Remuneration Committee 
The Remuneration Committee meets at least twice a year and 
comprises of two Non-executive Directors, with the Executive 
Directors,  Head  of  Human  Resources  and  external  advisers 
attending by invitation when appropriate. It is chaired by Alan 
Clarke, and is responsible for determining the remuneration of 
the  Executive  Directors,  the  Company  Secretary  and  other 
members  of  the  management.  Committee  members  do  not 
take part in discussions concerning their own remuneration.  

The  Directors  believe  that  the  above  disclosures  constitute 
sufficient disclosure to meet the QCA Code’s requirement for 
a  Remuneration  Committee  Report.  However,  a  separate 
Remuneration  Committee  Report  will  be  presented  in  the 
Group’s next audited Financial Statements. 

Nomination Committee     
Nomination Committee 
Nomination Committee 
Nomination Committee 
The Nomination Committee is comprised of the whole Board. 
It is chaired by the Chairman of the Board and is responsible 
for making recommendations to the Board on matters relating 
to the composition of the Board, including Executive and Non-
executive  Director  succession  planning,  the  appointment  of 
new Directors throughout the Group and re-election of existing 
Directors.  

Appointments to the Board 
Appointments to the Board     
Appointments to the Board 
Appointments to the Board 
The  principal  purpose  of  the  Nomination  Committee  is  to 
undertake the assessment of the balance of skills, experience, 
independence  and  knowledge  on  the  Board  and  subsidiary 
boards against the requirements of the business, with a view 
to determining whether any shortages exist. Having completed 
the  assessment,  the  Committee  makes  recommendations  to 
the board accordingly. Appointments to the Board are made on 
merit, with due regard to the benefits of diversity. Within this 
context,  the  paramount  objective  is  the  selection  of  the  best 
candidate, irrespective of background, and it is the view of the 
Board that establishing quotas or targets for the diversity of the 
Board is not appropriate.  

All  Group  Director  appointments  must  be  approved  by  the 
Company’s  Nominated  Adviser,  as  required  under  the  AIM 
Rules, before they are appointed to the Group Board.  

Prior to appointment, Non-executive Directors are required to 
demonstrate  that  they  are  able  to  allocate  sufficient  time  to 
undertake their duties.  

ReReReRe----election 
election     
election 
election 
The Group’s Rules require that all Directors are submitted for 
election  at  the  AGM  following  their  first  appointment  to  the 
Board and one third of the Directors are subject to retirement 
by  rotation  on  an  annual  basis  to  refresh  the  Board, 
irrespective of performance. 

The  Group  will  establish  a  separate  Corporate  Governance 
Committee.  

The  Corporate  Governance  Memorandum  also  contains  a 
schedule of matters specifically reserved for Board decision or 
approval and sets out the Company’s share dealing code and 
its  public  interest  disclosure  (“whistle-blowing”)  policy  and 
procedures. 

Page | 14  

 
 
 
 
RISK AND GOVERNANCE 

CORPORATE GOVERNANCE REPORT    

Board and committee attendance
Board and committee attendance    
Board and committee attendance
Board and committee attendance
The  number  of  formal  scheduled  Board  and  committee 
meetings held and attended by Directors during the year was 
as follows: - 

Jim Mellon 
John Banks 
Denham Eke 
Alan Clarke 
David Gibson 
Douglas Grant 
Gregory Bailey* 

Board 
3/6 
3/6 
6/6 
6/6 
6/6 
6/6 
3/6 

ARCC 
- 
- 
- 
8/8 
8/8 
- 
- 

REMCO 
- 
- 
- 
4/4 
4/4 
- 
- 

* Gregory Bailey appointed to the Board on 7 February 2018 

QCA  Principal  10:  Communicate  how  the  company  is 
QCA  Principal  10:  Communicate  how  the  company  is 
QCA  Principal  10:  Communicate  how  the  company  is 
QCA  Principal  10:  Communicate  how  the  company  is 
governed  and  is  performing  by  maintaining  a  dialogue  with 
governed  and  is  performing  by  maintaining  a  dialogue  with 
governed  and  is  performing  by  maintaining  a  dialogue  with 
governed  and  is  performing  by  maintaining  a  dialogue  with 
shareholders and other relevant stakeholders    
shareholders and other relevant stakeholders
shareholders and other relevant stakeholders
shareholders and other relevant stakeholders

The Group places a high priority on regular communications 
with its various stakeholder groups and aims to ensure that all 
communications  concerning  the  Group’s  activities  are  clear, 
fair  and  accurate.  The  Group’s  website  is  regularly  updated 
and users can register to be alerted when announcements or 
details  of  presentations  and  events  are  posted  onto  the 
website. 

Notices of General Meetings of the Company can be found on: 

https://www.mfg.im/investor-centre/regulatory-news 

The  results  of  voting  on  all  resolutions  in  future  general 
meetings will be posted to the Group’s website, including any 
actions to be taken as a result of resolutions for which votes 
against  have  been  received  from  at  least  20  per  cent  of 
independent Shareholders. 

Approval 
Approval     
Approval 
Approval 
This  report  was  approved  by  the  Board  of  Directors  on  27 
March 2019 and signed on its behalf by: - 

Jim Mellon  
Executive Chairman  
27 March 2019 

Page | 15  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RISK AND GOVERNANCE 

DIRECTORS, OFFICERS AND ADVISERS    

Executive Directors 

Jim Mellon (62)‡ 
Executive Chairman 
Jim  Mellon 
is  a  well-known  and  successful 
entrepreneur,  author  and  economic  commentator, 
starting  his  career  in  fund  management  and  now 
including  biopharma,  property,  mining  and 
information 
technology  amongst  his  many 
investments. He holds directorships in a number of 
publicly  quoted  companies,  many  of  which  are  in 
the  financial  services  sector.  He  is  the  beneficial 
owner  of  Burnbrae  Group  Limited  which,  in  turn, 
indirectly  holds  approximately  16%  of  Manx 
Financial  Group  PLC.  He  is  the  founder,  principal 
shareholder  and  chairman  of  the  Regent  Pacific 
Group, quoted on the Hong Kong Stock Exchange.  

Appointment
Appointment    
Appointment
Appointment
Appointed to  the Board on  2  November 2007  and 
appointed as Executive Chairman on 12 February 
2009. 

Non-executive Directors 

Denham Eke (67) ‡ 
Chief Executive Officer 
Denham Eke is the Managing Director of Burnbrae 
Group  Limited,  a  private 
international  asset 
management  company.  He  began  his  career  in 
stockbroking  with  Sheppards  &  Chase  before 
moving into corporate planning for Hogg Robinson 
plc, a major multinational insurance broker. He is a 
director of many years standing of both public and 
private  companies 
financial 
involved 
services,  property,  mining,  and  manufacturing 
sectors.  

the 

in 

Appointment
Appointment    
Appointment
Appointment
Appointed to the Board on 2 November 2007 and 
appointed as Chief Executive on 12 February 2009.  

Douglas Grant (54) ‡ 
Group Finance Director 
Douglas  Grant  has  over  30  years’  experience 
working in finance, initially with Scottish Power, 
before  moving  to  the  industrial  sector  to  work 
with  ICI  and  then  Allenwest.  Prior  to  joining 
Manx Financial Group PLC, he was the group 
financial controller and later financial director of 
various  UK  and  Isle  of  Man  private  sector 
companies  and  has  extensive  capital  markets 
experience.  

Appointment
Appointment    
Appointment
Appointment
Appointed to the Board on 14 January 2010.  He 
is Managing Director of Conister Bank Limited. 

 Alan Clarke (68)‡†* ≠  
Non-executive Director 

David Gibson (71) ‡†* ≠ 
Non-executive Director 

John Banks (50) ‡ 
Non-executive Director 

Alan  Clarke  is  a chartered accountant  and former 
senior partner of Ernst & Young during which time 
he worked closely with HSBC offshore operations in 
both  the  Channel  Islands  and  the  Isle  of  Man. 
Currently,  he  specialises  in corporate  finance  and 
strategic    consultancy,  advising  a  variety  of  both 
listed and private companies. He holds several non-
executive  directorships  and  is  a  past  President  of 
ICAEW Manchester. He is also a registered auditor, 
being the senior partner of Downham Mayer Clarke.  

Appointment
Appointment    
Appointment
Appointment
Appointed  to  the  Board  on  2  November  2007. 
Chairman  of  the  Audit,  Risk  and  Compliance 
Committee  and  Chairman  of  the  Remuneration 
Committee.  

David  Gibson  qualified  as  a  certified  accountant 
whilst  holding  posts  with  Shell-Mex  and  BP  and 
CIBA-Geigy throughout the UK and abroad, before 
transferring  into  treasury  management  in  senior 
positions  with  Turner  and  Newall  and  Westland 
Helicopters  where  he  qualified  as  a  corporate 
treasurer.  He  joined  the  Trustee  Savings  Bank  of 
the  Channel  Islands  as  finance  director,  prior  to 
becoming general manager finance at TSB Retail 
Bank where he gained his formal qualifications as 
a  banker.  Prior  to  retiring  from  executive  life  for 
family  reasons,  he  was  group  finance  director  of 
Portman  Building  Society  for  9  years.  He  is 
currently deputy chairman of commercial property 
investment  companies  Chellbrook  Properties  plc 
and Mountstephen Investments Limited. 

Appointment
Appointment    
Appointment
Appointment
Appointed to the Board on 12 February 2009. He is 
Chairman of Conister Bank Limited. 

John  Banks  is  a  solicitor  qualified  in  both 
England  and  Wales  and  Hong  Kong.  He  has 
worked in private practice with Lovells, in both 
England  and  Hong  Kong  and  as  an  in  house 
counsel for Standard Chartered Bank in Hong 
Kong. He joined Group Direct Limited, later part 
of Brightside Group PLC as group legal counsel 
in  2006,  where  he  worked  on  the  group’s 
joined 
admission 
Southern  Rock  Insurance  Company  Limited 
and Eldon Insurance Services Limited in 2013 
and is a director of both companies.  

trading  on  AIM.  He 

to 

Appointment
Appointment 
Appointment
Appointment
Appointed to the Board on 5 August 2014. 

Page | 16  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
RISK AND GOVERNANCE 

DIRECTORS, OFFICERS AND ADVISERS    

Non-executive Directors 

Company Secretary    

*   Member of the Audit, Risk and 

Compliance Committee 

† Member of the Remuneration Committee 
‡ Member of the Nominations Committee 
≠  Independent Non-executive Director 

Gregory Bailey (63) ‡ 
Non-executive Director 

Rachel Bradley (33) 
Company Secretary 

Gregory Bailey, founded Palantir Group Inc which made 
successful  investments  in  bio-tech  company  start-ups 
and  financings,  and  is  currently  chairman  of  Portage 
Biotech Inc, a CSE-traded drug development company, 
and non-executive director of AIM-traded SalvaRx Group 
Plc.   Along  with  comprehensive  experience  in  finance 
and healthcare, he has served on many public company 
boards and brings to the Group an extensive involvement 
in corporate governance.  

Rachel Bradley qualified to the Bar of the Isle of Man 
in  February  2012  and  has  a  broad  range  of 
the 
regulatory  and  compliance  experience 
financial services industry, both in the UK and Isle 
of Man. Prior to joining Manx Financial Group PLC, 
she worked in the United States of America for two 
years in the legal profession and prior to that, she 
worked  with  several 
local  corporate  services 
providers on the Isle of Man. 

in 

Appointment
Appointment    
Appointment
Appointment
Appointed to the Board on 7 February 2018. 

Appointment
Appointment    
Appointment
Appointment
Appointed as Company Secretary on 15 June 2018. 

Advisers    
Advisers
Advisers
Advisers

Registered Office
Registered Office    
Registered Office
Registered Office
Clarendon House 
Victoria Street 
Douglas 
Isle of Man IM1 2LN 

Registered Agent
Registered Agent    
Registered Agent
Registered Agent
CW Corporate Services Limited 
Bank Chambers 
15-19 Athol Street  
Douglas 
Isle of Man IM1 1LB 

Legal Advisers
Legal Advisers    
Legal Advisers
Legal Advisers
As to Isle of Man law 
Long & Humphrey 
The Old Courthouse 
Athol Street 
Douglas 
Isle of Man IM1 1LD 

As to English law 
Hill Dickinson LLP 
The Broadgate Tower 
20 Primrose Street 
London EC21 2EW 

Independent Auditor
Independent Auditor    
Independent Auditor
Independent Auditor
KPMG Audit LLC 
Heritage Court 
41 Athol Street 
Douglas 
Isle of Man IM99 1HN 

Principal Bank
Principal Bankersersersers    
Principal Bank
Principal Bank
Royal Bank of Scotland 
135 Bishopsgate 
London EC2M 3UR 

Consulting Actuaries
Consulting Actuaries    
Consulting Actuaries
Consulting Actuaries
Boal & Co Ltd 
Marquis House 
Isle of Man Business Park 
Douglas 
Isle of Man IM2 2QZ 

Pension Fund 
Pension Fund     
Pension Fund 
Pension Fund 
Investment Manager
Investment Manager    
Investment Manager
Investment Manager
Thomas Miller Investment 
(Isle of Man) Limited 
Level 2 
Samuel Harris House 
5-11 St George’s Street 
Douglas 
Isle of Man IM1 1AJ 

Nominated Advisor 
Nominated Advisor     
Nominated Advisor 
Nominated Advisor 
and Broker
and Broker    
and Broker
and Broker
Beaumont Cornish 
Limited 
10th Floor 
30 Crown Place 
London EC2A 4EB 

Registrar
Registrar    
Registrar
Registrar
Computershare Investor  
Services (Jersey) Limited 
Queensway House 
Hilgrove Street 
St Helier 
Jersey JE1 1ES 

Presentation of Annual 
Presentation of Annual 
Presentation of Annual 
Presentation of Annual 
Report and Accounts
Report and Accounts    
Report and Accounts
Report and Accounts
Presented  here  are  the 
and 
Annual 
Accounts 
Manx 
Financial Group PLC. 

Report 
of 

Company Information
Company Information    
Company Information
Company Information
The  Annual  and  Interim 
Reports,  along  with  other 
supplementary 
information  of  interest  to 
Shareholders, 
are 
included  on  our  website. 
The  address  of 
the 
website 
is  www.mfg.im
investor 
includes 
which 
relations  information  and 
contact details. 

Page | 17  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
    
 
 
 
 
RISK AND GOVERNANCE 

AUDIT, RISK AND COMPLIANCE COMMITEE     

Dear 
Shareholderssss    
Dear Shareholder
Shareholder
Shareholder
Dear Dear 
I am pleased to set out below an account of the ARCC’s role 
and activities during 2018 and up to the date of publication of 
this Annual Report.  

the  Nomination  Committee, 

Membership
Membership    
Membership
Membership
Members  of  the  ARCC  are  appointed  by  the  Board,  on  the 
recommendation  of 
in 
consultation  with  the  Chairman  of  the  Committee.  The 
Committee is made up of at least 2 members. All members of 
the Committee shall be Non-executive Directors and at least 
one  of  whom  shall  have  recent  and  relevant  financial 
experience  with  a  professional  qualification  from  one  of  the 
professional accountancy bodies. The Chairman of the Board 
shall not be a member of the Committee.  

Appointments to the Committee shall be for a period of up to 
3 years, which may be extended by the Board for a further 3-
year  period  (or,  in  exceptional  circumstances,  two  further  3 
year  periods),  provided  the  Director  remains  independent.  
The  Board  may  approve  annual  extensions  to  any  Director 
who has served 3 consecutive terms. 

The Board shall appoint the Chairman of the Committee who 
shall  be  a  Non-executive  Director.    In  the  absence  of  the 
Chairman of the Committee and/or an appointed deputy, the 
remaining members present shall elect one of themselves to 
chair the meeting. 

The Committee shall meet at least six times a year.  Of these, 
two  will  be  held  to  review  the  annual  and  interim  financial 
statements.  Outside  of  the  formal  meeting  programme,  the 
Chairman of the Committee will maintain a dialogue with key 
individuals involved in the Company’s governance. 

Members    
Members
Members
Members

Appointed     
Appointed 
Appointed 
Appointed 

Alan Clarke (Chairman)  2 February 2007 
David Gibson 

13 February 2009 

Number of 
Number of 
Number of 
Number of 
meetings 
meetings 
meetings 
meetings 
attended
attended    
attended
attended
8/8 
8/8 

Only  members  of  the  Committee  have  the  right  to  attend 
Committee  meetings.    However  other  individuals  may  be 
invited by the Chairman of the Committee to attend all or part 
of any meeting as and when appropriate.  

The ARCC holds separate meetings with the Head of Internal 
Audit, Head of Risk and Compliance and our external auditor, 
KPMG Audit LLC. 

The  Chairman  of  the  Board,  the  executive  directors  and 
executive management are invitees to meetings of ARCC but 
are  excluded  from  the  separate  meetings  held  between  the 
ARCC and the external auditor. 

Execution of functions    
Execution of functions
Execution of functions
Execution of functions
The ARCC has executed its duties and responsibilities during 
the year in accordance with its terms of reference as it relates 
to auditor independence, assisting the Board in its evaluation 
of  our  control  environment  and  internal  controls  including 
information systems and accounting practices. 

Due  to  its  adoption  of  the  QCA  Corporate  Governance 
standard, the committee reassessed the adequacy of its terms 

of reference and its function bearing in mind the requirements 
of this standard. 

During  the  year  under  review,  the  Committee  considered 
among other matters, the following: 

Financial reporting and annual financial statements:    
Financial reporting and annual financial statements:
Financial reporting and annual financial statements:
Financial reporting and annual financial statements:

  Considered the annual financial statements with the 
external 
and 
management  and  reviewed  the  appropriateness  of 
significant  judgements,  estimates  and  accounting 
policies; 

auditor,  Executive  Directors 

  Reviewed  and  recommended  to  the  Board  for 

approval: 

o  Unaudited condensed interim results for the 

period ended 30 June 2018; 

o  Audited  MFG  plc  Group  and  subsidiary 
annual  financial  statements  for  the  year-
ended 31 December 2018; and 
  Reviewed  changes  to  impairment  model  due  to 
adoption of IFRS 9 effective 1 January 2018;  
  Discussed  any  significant  and  unusual  accounting 
matters including key audit matters identified by the 
external auditor. 

External audit:    
External audit:
External audit:
External audit:

  Monitored  and  assessed  the  independence  of  the 
external auditors based on reports received, inquiries 
made into work performed; 

  Determined  the  nature  and  extent  of  non-audit 

services performed by the external auditors; 

  Reviewed  and  assessed  the  significance  of  non-

audit fees compared to audit fees; 

  Reviewed  and  agreed  the  external  audit  plan  in 
advance  for  the  year-end  audit  which  set  out  the 
scope of audit, significant risks, areas of audit focus 
and audit timetable. 

  Received  a  presentation  of  the  external  auditor 
for 

from  execution  of  audit  plan 

findings  on 
discussion; and 

  Satisfied  itself  as  to  the  expertise  experience  and 

independence of the engagement partner. 

Internal audit    
Internal audit
Internal audit
Internal audit

  Reviewed and approved the internal audit plan; 
  Reviewed  Internal  Audit’s  findings  including  the 
design  and  operating  effectiveness  of  the  internal 
control environment and control activities; and  
  Reviewed Internal Audit’s findings on the adequacy 

and reliability of management information. 

pliance    
Risk and compliance
Risk and com
pliance
pliance
Risk and com
Risk and com

  Assessed  the  effectiveness  of  the  Group  Risk  and 

Compliance function; 

  Reviewed 

the  Group  Risk  and  Compliance 
department  findings  on  the  effectiveness  of  the 
Group’s regulatory controls; 

  Recommend a revision of the Risk and Compliance 

policies for Board approval; and 

  Recommend  a  revision  of  the  Internal  Capital 
Adequacy Assessment Process for Board approval. 

Page | 18  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
RISK AND GOVERNANCE 

AUDIT, RISK AND COMPLIANCE COMMITEE     

External auditor
s independence     
External auditor’’’’s independence 
s independence 
s independence 
External auditor
External auditor
The external auditor, KPMG Audit LLC, has been the Group’s 
auditor since 2007. 

Consideration was given to the non-audit work performed by 
the external auditor. The ratio of non-audit fees to audit fees 
for the year was 0.08 to 1 (2017: 0.03 to 1). Non audit services 
related to tax adversary services. Services were performed by 
a  separate  team  to  the  audit  team  to  safeguard  against  the 
self-review threat to independence. 

The ARCC obtained assurance from the external auditor that 
internal  governance  processes  within  KPMG  Audit  LLC 
support  and  demonstrate  its  claim  of  independence.  This 

assurance  was  provided  through  the  receipt  of  an  ISA  260 
letter. 

The ARCC is satisfied with the independence of KPMG Audit 
LLC  and  is  recommending  that  KPMG  Audit  LLCS  be 
reappointed  as  the  Group’s  auditor  at  the  2018  Annual 
General Meeting. 

Key accounting matters
Key accounting matters    
Key accounting matters
Key accounting matters
The  ARCC  considered key  accounting  matters  in  relation  to 
the Group’s financial statements and disclosures. The primary 
areas  in  relation  to  2018  and  how  they  were  addressed  are 
detailed below: 

Key accounting matter
Key accounting matter    
Key accounting matter
Key accounting matter
impairment    
Loan impairment
Loan 
impairment
impairment
Loan 
Loan 
Impairments cover loans specifically identified as impaired and 
a collective impairment of all other loans for those impairments 
incurred but not yet specifically identified.  

ARCC response
ARCC response    
ARCC response
ARCC response
The ARCC satisfied itself that the internal control environment 
and  control  activities  are  appropriately  designed  and 
implemented.  This  was  supported  by  review  of  Internal  and 
External audit reports and findings. 

Loan impairment provisions reflect estimates of the amount and 
timing  of  future  recoveries  which  require  an  assessment  of 
matters  such  as  future  economic  conditions  and  the  value of 
collateral. Estimates, by their nature, give rise to a higher risk 
of material misstatement due to error or fraud.  

The  effect  of  these  matters  is  that,  as  part  of  our  risk 
assessment, we determined that the impairment provision has 
a high degree of estimation uncertainty, with a potential range 
of  reasonable  outcomes  greater  than  our  materiality  for  the 
financial statements as a whole, and possibly many times that 
amount. 
Impairment of goodwill and intangible assets
Impairment of goodwill and intangible assets    
Impairment of goodwill and intangible assets
Impairment of goodwill and intangible assets
Goodwill  and 
the 
estimated recoverable amount of these balances is subjective 
due  to  the  inherent  uncertainty  involved  in  forecasting  and 
discounting future cash flows. 

intangible  assets  are  significant  and 

is  significant  and 

receivable  exposure 

VAT receivable
VAT receivable    
VAT receivable
VAT receivable
The  VAT 
its  
recoverability  rests on the outcome of  discussions  with the 
Isle  of  Man  Government  Customs  and  Excise  Division  (“IOM 
C&E”), which in turn will take into account the final assessment 
by UK Customs and Excise of the impact of the recent ruling by 
the  Court  of  Justice  of  the  European  Union  regarding  the 
dispute between Volkswagen Financial Services (UK) Limited 
vs HM Revenue & Customs.  

The  effect  of  these  matters  is  that,  as  part  of  our  risk 
assessment,  we  determined  that  the  impact  of  the  final 
assessment of the amount of VAT to be recovered has a high 
degree  of  estimation  uncertainty,  with  a  potential  range  of 
reasonable  outcomes  greater  than  our  materiality  for  the 
financial statements as a whole, and possibly many times that 
amount. 

The  ARCC  reviewed  reports  from  executive  management  on 
the  implementation  of  IFRS  9  and  key  changes  to  internal 
processes  and  controls.  The  ARCC  reviewed 
the  key 
assumptions used by management such as Loss given default, 
Loss rates, Probability of default on initial implementation at 30 
June 2018 and at year ended 31 December 2018. 

The ARCC satisfied itself that the internal control environment 
and  control  activities  are  appropriately  designed  and 
implemented.  This  was  supported  by  review  of  Internal  and 
External audit reports and findings. 

The  ARCC  reviewed  management’s  assessment  of  Goodwill 
and  intangible  asset  impairment  and  concluded  that  the 
recoverable amount is appropriate. 
The ARCC satisfied itself that the internal control environment 
and  control  activities  are  appropriately  designed  and 
implemented.  This  was  supported  by  review  of  Internal  and 
External audit reports and findings. 

The  ARCC  reviewed  management’s  assessment  of  VAT 
receivable  impairment  and  concluded  that  the  recoverable 
amount is appropriate.. 

Page | 19  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
RISK AND GOVERNANCE 

AUDIT, RISK AND COMPLIANCE COMMITEE     

Key accounting matter
Key accounting matter    
Key accounting matter
Key accounting matter
Carrying  value  of  Parent  Company’s  subordinated  loans  and 
Carrying  value  of  Parent  Company’s  subordinated  loans  and 
Carrying  value  of  Parent  Company’s  subordinated  loans  and 
Carrying  value  of  Parent  Company’s  subordinated  loans  and 
investment in subsidiaries
investment in subsidiaries    
investment in subsidiaries
investment in subsidiaries
The  carrying  value  of  the  Parent  Company’s  subordinated 
loans to and investment in subsidiaries represents 93% (2017: 
98%) of the Parent Company’s total assets. The assessment of 
carrying value is not at a high risk of significant misstatement 
or  subject  to  significant  judgement  as  the  carrying  value  is 
supported  by  the  audited  net asset  value  of  the  subsidiaries. 
However,  due  to  its  materiality  in  the  context  of  the  Parent 
Company financial statements, this is considered to be the area 
that  had  the  greatest  effect  on  our  overall  Parent  Company 
audit. 

ARCC response
ARCC response    
ARCC response
ARCC response
The ARCC is satisfied that the going concern assessment over 
the Group provides sufficient assurance over the recoverability 
of the Parent Company’s subordinated loans and investment in 
subsidiaries. 

The ARCC has complied with and discharged its responsibilities as set out in its Terms of reference. 

Alan Clarke 
Chairman 
27 March 2019 

Page | 20  

 
 
 
 
 
 
 
RISK AND GOVERNANCE 

DIRECTORS’ REMUNERATION REPORT    

Dear Shareholderssss    
Dear Shareholder
Dear Shareholder
Dear Shareholder

  it reflects our culture and values; and  
  there  is  full  transparency  of  the  Group’s  Remuneration 

On behalf of the Board, I am pleased to report the Directors’ 
Remuneration Report for the year ended 31 December 2018. 

Policy. 

Membership
Membership    
Membership
Membership
Members  of  the  Remuneration  Committee  are  appointed  by 
the  Board,  on  the  recommendation  of  the  Nomination 
Committee 
the 
Committee. The Committee is made up of at least 2 members. 
All  members  of  the  Committee  shall  be  Non-executive 
Directors. The Chairman of the Board shall not be a member 
of the Committee. 

in  consultation  with 

the  Chairman  of 

Appointments to the Committee shall be for a period of up to 
3 years, which may be extended by the Board for a further 3-
year  period  (or,  in  exceptional  circumstances,  two  further  3 
year  periods),  provided  the  Director  remains  independent.  
The  Board  may  approve  annual  extensions  to  any  Director 
who has served 3 consecutive terms. 

The Board shall appoint the Chairman of the Committee who 
shall  be  a  Non-executive  Director.  In  the  absence  of  the 
Chairman of the Committee and/or an appointed deputy, the 
remaining members present shall elect one of themselves to 
chair the meeting. 

The Committee shall meet at least twice a year and at such 
other times as the Chairman of the Committee shall require. 

Membership    
Membership
Membership
Membership

Appointed    
Appointed
Appointed
Appointed

Alan Clarke (Chairman)  13 February 2009 
David Gibson 

12 December 2010 

Number of 
Number of 
Number of 
Number of 
meetings 
meetings 
meetings 
meetings 
attended
attended    
attended
attended
4/4 
4/4 

Only  members  of  the  Committee  have  the  right  to  attend 
Committee  meetings.  However,  other  individuals  may  be 
invited by the Chairman of the Committee to attend all or part 
of any meeting as and when appropriate. 

Areas of focus for 2018
Areas of focus for 2018    
Areas of focus for 2018
Areas of focus for 2018
During the year, the Committee considered the following: 

•  Reviewed  the  overall  pay  increase  of  Executive 

Directors; 
•  Reviewed 

the  overall  non-discretionary  annual 
performance related pay scheme for Group staff; and 
•  Reviewed and approved all new staff appointments 

with packages over £50,000. 

Remuneration policy    
Remuneration policy
Remuneration policy
Remuneration policy
The  Group’s  Remuneration  Policy  reflects  the  Group’s 
business  strategy  and  objectives  as  well  as  sustained  and 
long-term  value  creation  for  shareholders.    In  addition,  the 
policy  aims  to  be  fair  and  provide  equality  of  opportunity, 
ensuring that:  

  the  Group  is  able  to  attract,  develop  and  retain  high-
performing  and  motivated  employees  in  the  competitive 
local IOM and wider UK markets; 

  employees  are  offered  a  competitive  remuneration 
package to encourage enhanced performance and are, in 
a fair and responsible manner, rewarded for their individual 
contribution to the success of the Group; 

In line with the Board’s approach, which reflects that adopted 
within  other  comparable  organisations, 
the  Group’s 
Remuneration  Policy  provides  for  the  reward  of  Executive 
Directors through salaries and other benefits.  

Executive Directors’ Emoluments
Executive Directors’ Emoluments    
Executive Directors’ Emoluments
Executive Directors’ Emoluments
The  remuneration  for  Executive  Directors  reflects  their 
It  comprises  basic  salary,  performance 
responsibilities. 
related variable pay when this is considered appropriate, and 
various benefits detailed below.  

Performance  related  payments  are  not  pensionable  and  are 
not contracted.  

As with staff generally, whose salaries are subject to annual 
reviews,  basic  salaries  payable  to  Executive  Directors  are 
reviewed  each  year  with  reference  to  jobs  carrying  similar 
responsibilities in comparable financial organisations, market 
conditions generally and local employment competition in view 
of the Group’s geographical position.  

The  Group  operates  a  non-contractual  discretionary  annual 
performance  related  pay  scheme  based  on  the  trading 
performance  of  the  Group  and  the  individual  employee’s 
performance  assessed  for  the  period  under  review  in  a 
manner which promotes sound risk management and does not 
promote excessive risk taking.   

The non-contractual discretionary annual performance related 
pay scheme may be paid in one year but that does not confer 
any entitlement in future years.  

to 
Performance  assessments  are  conducted  annually 
determine 
the  performance  rating  of  each  employee’s 
achievements against a mix of targets set and agreed at the 
beginning  of  each  year  between  the  employee  and  their 
manager.  No incentives are paid to employees or executives 
where  the  performance  rating  reflects  below  an  agreed 
expected level for the role employed. 

The non-contractual discretionary annual performance related 
pay  scheme  may  be  disbursed  as  a  cash  payment  through 
payroll, share based instruments (including share options) or 
a  mixture  of  both.    An  element  of  deferment  to  align  the 
interests  of  the  employee  to  the  longer  term  performance  of 
the Group may also be included. 

the  Advisor’s  client  base  and 

EWA’s  Financial  Advisors  are  salaried  and  commission  is 
calculated on a pre-agreed percentage over target which is set 
at between 2 to 3 times annual gross salary depending on the 
size  of 
their  historical 
performance.  Each Financial Advisor is set objectives at the 
beginning of the year including a 100% pass in all compliance 
requirements.  Where indemnified commission is paid and the 
underlying client policy lapses and the commission is clawed 
back then this is reviewed by an Executive Director in order to 
monitor  trends  and  is  then  clawed  back  from  the  relevant 
Financial Advisor. 

Page | 21  

 
 
 
    
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
RISK AND GOVERNANCE 

DIRECTORS’ REMUNERATION REPORT    

Where 
the  Group  operates  contractually  guaranteed 
performance related pay, the contractual conditions must be 
considered by the Remuneration Committee.  

Executive Directors’ Contractual Terms
Executive Directors’ Contractual Terms    
Executive Directors’ Contractual Terms
Executive Directors’ Contractual Terms
In keeping with current recommended practice, the standard 
term  for  Executive  Director  appointments,  which  have  a 
contractual notice period, is 6 months.  

NonNonNonNon----executive Directors’ Remuneration
executive Directors’ Remuneration    
executive Directors’ Remuneration
executive Directors’ Remuneration
Non-executive Directors do not receive any benefits other than 
their  fees  and  travelling  expenses  for  which  they  are 
reimbursed.  The  level  of  fees  payable  to  Non-executive 
Directors  is  assessed  using  benchmarks  from  a  group  of 
comparable financial organisations.  
The Procedure for Determining Remuneration 

emoluments    
Directors’ emoluments
Directors’ 
emoluments
emoluments
Directors’ 
Directors’ 

Remuneration/  
Fees 
£ 

Performance 
Related Pay 
£ 

Executives
Executives    
Executives
Executives
Jim Mellon 
Denham Eke 
Douglas Grant 
Juan Kelly1 

NonNonNonNon----executives
executives    
executives
executives
Alan Clarke 
Gregory Bailey 
John Banks 
Neil Duggan2 
David Gibson 

Aggregate 
emoluments 

25,000 
25,000 
191,458 
- 
241,458 

42,917 
22,400 
25,000 
- 
55,000 
145,317 

- 
- 
50,000 
- 
50,000 

- 
- 
- 
- 
- 
- 

The Remuneration Committee, comprising two Non-executive 
Directors,  is  responsible  for  setting  the  remuneration  of  the 
Executive Directors and is chaired by Alan Clarke. Committee 
members do not take part in discussions concerning their own 
remuneration. The basic Non-executive Director fee is set by 
the Group Chairman. The Chairman of the Committee reports 
at the Board meeting following a Committee meeting. 

Implementation report
Implementation report    
Implementation report
Implementation report
It  is  the  view  of  the  Committee  that  Directors’  remuneration 
awarded  across  the  Group  for  the  year  has  been  in 
accordance with the Group’s stated Remuneration Policy and, 
on behalf of the Committee I recommend that you endorse this 
Group  report.    An  analysis  of  Directors’  emoluments  is  as 
follows: - 

Pension 
£ 

- 
- 
19,146 
- 
19,146 

- 
- 
- 
- 
- 
- 

2018
2018    
20182018
Total
Total    
Total
Total
££££    

25,000
25,000    
25,000
25,000
25,000
25,000    
25,000
25,000
260,604    
260,604
260,604
260,604
----    
310,604    
310,604
310,604
310,604

42,917    
42,917
42,917
42,917
22,400
22,400    
22,400
22,400
25,000
25,000    
25,000
25,000
----    
55,000
55,000    
55,000
55,000
145,317    
145,317
145,317
145,317

2017 
Total 
£ 

25,000 
25,000 
222,986 
47,718 
320,704 

43,000 
- 
25,000 
20,000 
47,500 
135,500 

374,375 

50,000 

19,146 

443,521    
443,521
443,521
443,521

456,204 

1Juan Kelly resigned on 28 March 2017. 
2 Neil Duggan retired on 30 June 2017.    

Approval    
Approval
Approval
Approval
This report was approved by the Board of Directors on 27 March 2019 and signed on its behalf by: -   

Alan Clarke
Alan Clarke    
Alan Clarke
Alan Clarke
Chairman of the Remuneration Committee 
27 March 2019 

Page | 22  

 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
    
    
 
 
 
 
 
 
RISK AND GOVERNANCE 

DIRECTORS’ REPORT    

The  Directors  present  their  annual  report  and  the  audited 
financial statements for the year ended 31 December 2018. 

Directors and Directors’ share interests
Directors and Directors’ share interests    
Directors and Directors’ share interests
Directors and Directors’ share interests
Details of current Directors are set out on pages 16 and 17. 

Principal regulated activities
Principal regulated activities    
Principal regulated activities
Principal regulated activities
The  principal  activities  of  Manx  Financial  Group  PLC  (the 
“Company” or “MFG”) and its subsidiaries (together referred to 
as the “Group”) are the provision of asset and personal finance, 
investing activities, Foreign Exchange brokerage services and 
wealth management. 

The Bank, a wholly owned subsidiary of the Company, holds a 
Class 1(1) deposit taking licence issued under Part 2 of the Isle 
of  Man  Financial  Services  Act  2008.  Deposits  made  with  the 
Bank are covered by the Isle of Man Depositors’ Compensation 
Scheme contained in the Banking Business (Compensation of 
Depositors) Regulations 1991. 

EWA  is  authorised  by  the  Isle  of  Man  Financial  Services 
Authority under section 7 of the Financial Services Act 2008 to 
conduct investment business as a Class 2, sub-classes (3), (6) 
and (7) licence holder.  

Results and dividends
Results and dividends    
Results and dividends
Results and dividends
The proposed transfers to and from reserves are as set out in 
the Statement of Changes in Equity on page 34. The Directors 
do not recommend the payment of a dividend (2017: nil). 

Share capital
Share capital    
Share capital
Share capital
Particulars  of  the  authorised  and  issued  share  capital  of  the 
Company are set out in note 31 to the financial statements.  

Significant shareholdings
Significant shareholdings    
Significant shareholdings
Significant shareholdings
The number of shares held and the percentage of the issued 
shares which that number represented as at 26 March 2019 are: 
% of % of % of % of 
issued capital    
issued capital
issued capital
issued capital
29.10 
16.39 
13.60 
7.44 
3.22 
3.02 

Rene Nominees (IOM) Limited1 
Jim Mellon2 
Gregory Bailey3 
Lynchwood Nominees Limited 
Island Farms Limited 
Rock (Nominees) Limited 

Number    
Number
Number
Number
38,153,158 
21,492,232 
17,835,750 
9,752,879 
4,222,319 
3,955,663 

1  Arron  Banks,  a  former  Director  of  the  Group  is  beneficially 
interested in 38,153,158 Ordinary Shares. This holding includes 
26,288,992  Ordinary  Shares  held  by  Rene  Nominees  (IOM) 
limited (“Rene”) in trust for Southern Rock Insurance Company 
Ltd (“SR”), 9,777,166 for ICS Risk Solutions Limited (“ICS”) and 
2,087,000 for MW SIPP Trustees Ltd. John Banks, a Director of 
MFG is also a director of SR and ICS.   

2  Burnbrae Limited holds 19,164,250 Ordinary Shares. Burnbrae 
Limited is beneficially owned by Jim Mellon. Denham Eke, CEO 
of  MFG  is  also  a  director  of  Burnbrae  Limited.  Pershing 
Nominees  Limited  holds  968,666  Ordinary  Shares,  Vidacos 
Nominees holds 666,666 Ordinary Shares in trust for Jim Mellon 
and 692,650 Ordinary Shares are held in his own name. 

3  Vidacos  Nominees  Limited  holds  17,835,750  Ordinary  Shares 

in trust for Gregory Bailey. 

The number of shares held by the current Directors is as follows:  

Jim Mellon4 
Gregory Bailey5 
John Banks6 
David Gibson7 
Douglas Grant 
Alan Clarke 

Number
Number    
Number
Number
26262626/0/0/0/03333/19/19/19/19    
21,492,232
21,492,232    
21,492,232
21,492,232
17,835,750
17,835,750    
17,835,750
17,835,750
----    
1,721,433
1,721,433    
1,721,433
1,721,433
505,821    
505,821
505,821
505,821
52,149    
52,149
52,149
52,149

Number
Number    
Number
Number
31/12/18    
31/12/18
31/12/18
31/12/18
21,492,232
21,492,232    
21,492,232
21,492,232
17,835,750
17,835,750    
17,835,750
17,835,750
----    
1,721,433
1,721,433    
1,721,433
1,721,433
505,821    
505,821
505,821
505,821
52,149    
52,149
52,149
52,149

Number 
31/12/17 
21,492,232 
17,835,750 
1,433,833 
1,721,433 
505,821 
52,149 

4  Burnbrae  Limited  holds  19,164,250  Ordinary  Shares.  Jim 
Mellon, Executive Chairman of Manx Financial Group PLC, is a 
Director  of  Burnbrae  Limited.  Burnbrae  Limited  is  beneficially 
owned  by  Jim  Mellon.  Denham  Eke,  CEO  of  MFG,  is  also  a 
director of Burnbrae Limited. Pershing Nominees Limited holds 
968,666 Ordinary Shares and Vidacos Nominees holds 666,666 
Ordinary Shares for the benefit of Jim Mellon.  

5  Vidacos  Nominees  Limited  holds  17,835,750  Ordinary  Shares 

in trust for Gregory Bailey. 

6  On  the  19  June  2018,  1,443,833  of  the  Company’s  ordinary 
shares were transferred and are now held by Rene in trust for 
ICS.  Following  the  transfer,  John  Banks  no  longer  has  an 
interest in the issued ordinary share capital of the Company 

7  Comprises  1,721,433  Ordinary  Shares  held  by  Interactive 

Investor Services Limited for the benefit of David Gibson. 

The number of share options held by the current Directors is as 
follows:  

Douglas Grant 

Number
Number    
Number
Number
26262626/0/0/0/03333/19/19/19/19    
1,042,466    
1,042,466
1,042,466
1,042,466

Number
Number    
Number
Number
31/12/18
31/12/18    
31/12/18
31/12/18
1,042,466    
1,042,466
1,042,466
1,042,466

Number 
31/12/17 
1,042,466 

Directors’ liability insurance
Directors’ liability insurance    
Directors’ liability insurance
Directors’ liability insurance
The  Group  maintains  insurance  cover  for  Directors’  potential 
liability. 

Fixed and intangible assets
Fixed and intangible assets    
Fixed and intangible assets
Fixed and intangible assets
The movement in fixed and intangible assets during the year are 
set  out  in  notes  24  and  25  respectively  to  the  financial 
statements.  

StaffStaffStaffStaff    
At 31 December 2018, there were 113 members of staff (2017: 
91), of whom 11 were part-time (2017: 13). 

in subsidiaries    
Investment in subsidiaries
Investment 
in subsidiaries
in subsidiaries
Investment 
Investment 
Investments  in  the  Company’s  subsidiaries  are  disclosed  in 
note 32 to the financial statements.  

Auditor    
Auditor
Auditor
Auditor
KPMG Audit LLC, being eligible, has expressed its willingness 
to continue in office.  

Page | 23  

 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
    
    
 
 
 
 
    
    
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

CONTENTS 

Assurance    
Assurance
Assurance
Assurance

Statement of Directors’ Responsibilities 
Independent Auditor’s Report 

Consolidated and company financial statements 
Consolidated and company financial statements
Consolidated and company financial statements
Consolidated and company financial statements

Consolidated statement of profit or loss and other 
comprehensive income 
Company statement of profit or loss and other 
comprehensive income 
Consolidated statement of financial position 
Company statement of financial position 
Consolidated and company statement of changes in equity 
Consolidated statement of cash flows 
Company statement of cash flows 

Notes to the consolidated and company financial statements 
Notes to the consolidated and company financial statements
Notes to the consolidated and company financial statements
Notes to the consolidated and company financial statements

Basis of preparation
Basis of preparation    
Basis of preparation
Basis of preparation
1. Reporting entity 
2. Basis of accounting 
3. Functional and presentation currency 
4. Use of judgements and estimates 
5. Change in accounting policies 

Financial risk review and fair value
Financial risk review and fair value    
Financial risk review and fair value
Financial risk review and fair value
6. Classification of financial assets and liabilities 
7. Fair value of financial instruments 
8. Financial risk review 

Performance for the year
Performance for the year    
Performance for the year
Performance for the year
9. Operating segments 
10. Net interest income 
11. Net fee and commission income 
12. Terminal funding 
13. Personnel expenses 
14. Other expenses 
15. Impairment on loans and advances to customers 
16. Profit before tax payable 
17. Income tax expense 
18. Earnings per share 

Assets
Assets    
Assets
Assets
19. Cash and cash equivalents 
20. Debt securities 
21. Trading assets 
22. Loans and advances to customers 
23. Trade and other receivables 
24. Property, plant and equipment 
25. Intangible assets 

24 
25 

29 

30 

31 
32 
33 
34 
35 

36 
36 
36 
36 
36 

38 
39 
40 

47 
48 
48 
49 
49 
49 
49 
50 
50 
51 

52 
52 
52 
52 
53 
54 
55 

Liabilities and equity
Liabilities and equity    
Liabilities and equity
Liabilities and equity
26. Deposits from customers 
27. Creditors and accrued charges 
28. Block creditors 
29. Loan notes 
30. Pension liability 
31. Called up share capital 

Group composition    
  Group composition
Group composition
Group composition
32. Investment in Group undertakings 

Other information    
  Other information
Other information
Other information
33. Related parties transactions 
34. Operating leases 
35. Subsequent events 
36. Financial risk management 

Accounting policies
Accounting policies    
Accounting policies
Accounting policies
37. Basis of measurement 
38. Significant accounting policies 
39. Standards issued but not yet adopted 

56 
56 
56 
56 
57 
59 

60 

62 
63 
63 
63 

67 
67 
77 

Page | 24  

 
 
 
    
    
 
 
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
    
    
 
 
 
 
 
    
    
    
 
 
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

STATEMENT OF DIRECTORS’ RESPONSIBILITIES    

responsible 

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

They  are  responsible  for  such  internal  control  as  they 
determine is necessary to enable the preparation of financial 
statements that are free from material misstatement, whether 
due to fraud or error, and have general responsibility for taking 
such steps as are reasonably open to them to safeguard the 
assets of the Group and to prevent and detect fraud and other 
irregularities.   

The  Directors  are  responsible  for  the  maintenance  and 
integrity of the corporate and financial information included on 
the  Company’s  website.    Legislation  in  the  Isle  of  Man 
governing  the  preparation  and  dissemination  of  financial 
statements may differ from legislation in other jurisdictions. 

The Directors are responsible for preparing the Annual Report 
and  the  Group  and  Parent  Company  financial  statements  in 
accordance with applicable law and regulations.   

The  Directors  are  required  to  prepare  Group  and  Parent 
Company  financial  statements  for  each  financial  year.    As 
required by the AIM Rules of the London Stock Exchange they 
are  required  to  prepare  the  Group  financial  statements  in 
accordance with International Financial Reporting Standards 
as  adopted  by  the  EU  (IFRSs  as  adopted  by  the  EU),  as 
applicable to an Isle of Man Company and applicable law and 
have  elected  to  prepare  the  Parent  Company  financial 
statements on the same basis. 

The  Directors  must  not  approve  the  financial  statements 
unless they are satisfied that they give a true and fair view of 
the state of affairs of the Group and Parent Company and of 
their  profit  or  loss  for  that  period.    In  preparing  each  of  the 
Group  and  Parent  Company 
the 
Directors are required to: -   
  select  suitable  accounting policies and  then apply  them 

financial  statements, 

consistently;   

  make  judgements  and  estimates  that  are  reasonable, 

relevant and reliable;   

  state  whether  they  have  been  prepared  in  accordance 

with IFRSs as adopted by the EU;   

  assess  the  Group  and  Parent  Company’s  ability  to 
continue  as  a  going  concern,  disclosing,  as  applicable, 
matters related to going concern; and   

  use  the  going  concern  basis  of  accounting  unless  they 
either  intend  to  liquidate  the  Group  or  the  Parent 
Company  or  to  cease  operations  or  have  no  realistic 
alternative but to do so.   

Page | 25  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

INDEPENDENT AUDITOR’S REPORT, TO THE MEMBERS OF MANX FINANCIAL 
GROUP PLC    

1 Our opinion is unmodified   
1 Our opinion is unmodified       
1 Our opinion is unmodified   
1 Our opinion is unmodified   
We  have  audited  the  financial  statements  of  Manx  Financial  Group 
PLC  (“the  Company”)  for  the  year  ended  31  December  2018  which 
comprise the Consolidated and Parent Company Statements of Profit 
or  Loss  and  Other  Comprehensive  Income,  the  Consolidated  and 
Parent  Company  Statements  of  Financial  Position,  the  Consolidated 
and Parent Company Statements of Cash Flows and the Consolidated 
and Parent Company Statements of Changes in Equity, and the related 
notes, including the accounting policies in note 3.    

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 31 December 2018 and 
of the Group’s and Parent Company’s profit for the year then 
ended;    

  have  been  properly  prepared 

in  accordance  with 
International  Financial  Reporting  Standards  as  adopted  by 
the  European  Union  (IFRSs  as  adopted  by  the  EU),  as 
applicable to an Isle of Man Company;  and   

  have been prepared in accordance with the  requirements of 

the Isle of Man 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 
are  described  below.  We  have  fulfilled  our  ethical  responsibilities 
under,  and  are  independent  of  the  Group  in  accordance  with,  UK 
ethical requirements including the FRC Ethical Standard. We believe 
that  the  audit  evidence  we  have  obtained  is  a  sufficient  and 
appropriate basis for our opinion.    

2 Key audit matters: our assessment of risks of material misstatement   
2 Key audit matters:
2 Key audit matters:
2 Key audit matters:
Key audit matters are those matters that, in our professional judgment, 
were of most significance in the audit of the financial statements and 
include the most significant assessed risks of material misstatement 
(whether  or  not  due  to  fraud)  identified  by  us, including  those  which 
had the greatest effect on: the overall audit strategy; the allocation of 
resources  in  the  audit;  and  directing  the  efforts  of  the  engagement 
team. These matters were addressed in the context of our audit of the 
financial statements as a whole, and in forming our opinion thereon, 
and we do not provide a separate opinion on these matters. In arriving 
at our audit opinion above, the key audit matters, in decreasing order 
of  audit  significance,  are  set  out  below.  These  are  unchanged  from 
2017, with the exception of the inclusion this year of a key audit matter 
with  respect  to  the  carrying  value  of  the  Parent  Company’s 
subordinated loans to and investment in subsidiaries.  

Key audit matter
Key audit matter    
Key audit matter
Key audit matter
Loan impairment     
Loan impairment 
Loan impairment 
Loan impairment 
Loans 
to 
customers £148,278,000 (2017: 
£122,546,000) 

advances 

and 

Impairment 
£3,394,000 (2017:  
£2,687,000).  

Provision 

Refer  to  the  Audit,  Risk  and 
Compliance  Report  (“ARCC”), 
note 4 (Use of Judgements and 
Estimates  -  Assumptions  and 
Estimation  Uncertainties),  note 
8(A)  (Credit  Risk),  note  15 
(Impairment  on  Loans  and 
Advances  to  Customers),  note 
22  (Loans  and  Advances  to 
Customers), 
(B) 
(Financial  Risk  Management  – 
Credit  risk)  and  note  38(I)(vii) 
for 
(Accounting 
Impairment 
Financial 
Instruments). 

Policy 

note 

36 

of 

The risk 
The risk          
The risk 
The risk 
Subjective estimate    
Subjective estimate
Subjective estimate
Subjective estimate
Impairments  cover  loans  specifically  identified  as 
impaired  and  a  collective  impairment  of  all  other 
loans  for  those  impairments  incurred  but  not  yet 
specifically identified.  

Loan impairment provisions reflect estimates of the 
amount and timing of future recoveries which require 
an assessment of matters such as future economic 
conditions and the value of collateral. Estimates, by 
their  nature,  give  rise  to  a  higher  risk  of  material 
misstatement due to error or fraud.  

The effect of these matters is that, as part of our risk 
assessment,  we  determined  that  the  impairment 
provision  has  a  high  degree  of  estimation 
uncertainty,  with  a  potential  range  of  reasonable 
outcomes  greater 
the 
financial statements as a whole, and possibly many 
times that amount.  

than  our  materiality 

for 

Auditor’s
response    
Auditor’s    response
response
response
Auditor’s
Auditor’s
Our procedures included: 

----     Control  design  and  operating  effectiveness: 
Control  design  and  operating  effectiveness: 
Control  design  and  operating  effectiveness: 
Control  design  and  operating  effectiveness: 
Understanding and testing the controls in respect of 
the  Group’s  loan  impairment  process  such  as  the 
timely  recognition  of  impairment  provisions,  the 
completeness  and  accuracy  of  reports  used  in  the 
loan  impairment  process  and  management  review 
processes  over  the  calculation  of  collective  and 
specific provisions.  

in 

the 

Test  of  details:  We  agreed  the  specific  provisions 
----     Test  of  details:
Test  of  details:
Test  of  details:
included 
to 
financial 
management’s  provisioning  schedule  and  vouched 
that  this  schedule  was  correctly  extracted  from  the 
loans  and  advances  system,  including  the  arrears 
information.  

statements 

towards 

Test  of  details:  We  tested  a  sample  of  specific 
----     Test  of  details: 
Test  of  details: 
Test  of  details: 
provisions,  weighted 
those  against 
individually significant impaired loans. This included 
the 
challenging  management’s  assessment  of 
specific  provision,  taking  into  account  such  factors 
as: the number of repayments in arrears; the known 
whereabouts  of  the  hirer/lessor  and  of  the  assets 
under  finance;  and  the  amounts  received  under 
scheduled 
agreed 
repayments  under  the  original  agreement  are  no 
longer being met.  

repayment  plans,  where 

in  collective 

Historical  comparison:  We  challenged  the  inputs 
----     Historical  comparison: 
Historical  comparison: 
Historical  comparison: 
impairment  models  and 
used 
considered  whether  those  inputs  reflected  default 
and  recovery  experience  across  each  of  the  loan 
finance categories.  

Assessing transparency: Assessing the adequacy 
----     Assessing transparency:
Assessing transparency:
Assessing transparency:
of  the  Group’s  disclosures  about  the  degree  of 
estimation  uncertainty  involved  at  arriving  at  the 
provisions. 

Page | 26  

 
 
 
  
 
 
 
 
 
   
 
 
  
 
  
  
  
ANNUAL FINANCIAL STATEMENTS 

INDEPENDENT AUDITOR’S REPORT, TO THE MEMBERS OF MANX FINANCIAL 
GROUP PLC (CONTINUED)    

2 Key audit matters: our assessment of risks of material misstatement (continued) 
2 Key audit matters: our assessment of risks of material misstatement (continued)
2 Key audit matters: our assessment of risks of material misstatement (continued)
2 Key audit matters: our assessment of risks of material misstatement (continued)

Key audit matter
Key audit matter    
Key audit matter
Key audit matter
Impairment  of  goodwill  and 
Impairment  of  goodwill  and 
Impairment  of  goodwill  and 
Impairment  of  goodwill  and 
intangible assets      
intangible assets  
intangible assets  
intangible assets  

The risk 
The risk          
The risk 
The risk 
based valuation     
Forecast----based valuation 
Forecast
based valuation 
based valuation 
Forecast
Forecast

Goodwill  
£2,344,000 (2017: £2,344,000)  
and Intangibles Assets  
£1,952,000 (2017: £1,719,000).  

Goodwill  and  intangible  assets  are  significant  and 
the estimated recoverable amount of these balances 
is subjective due to the inherent uncertainty involved 
in forecasting and discounting future cash flows. 

in 

Refer to the  ARCC report, note 
4  (Use  of  Judgements  and 
Estimates 
-Assumptions  and 
Estimation  Uncertainties),  note 
25  (Intangible  Assets),  note  32 
(Investment 
Group 
Undertakings),  38(A)  (Basis  for 
Consolidation  of  Subsidiaries 
Financial 
and 
the  Parent 
Statements  of 
Company), 
38(M) 
(Goodwill  and  Intangibles)  and 
note 38(N) (Impairment of Non-
Financial Assets) 

Separate 

note 

Auditor’s
response    
Auditor’s    response
response
response
Auditor’s
Auditor’s
Our procedures included:  

----     Control  design  and  operating  effecti
veness: 
Control  design  and  operating  effectiveness: 
veness: 
veness: 
Control  design  and  operating  effecti
Control  design  and  operating  effecti
Understanding and testing the controls in respect of 
the  Group’s  goodwill  and 
intangibles  assets 
impairment  review  process  such  as  the  timely 
recognition  of 
the 
completeness  and  accuracy  of  reports  used  in  the 
impairment review process.  

impairment  provisions  and 

the 
Benchmarking  assumptions:  Comparing 
----     Benchmarking  assumptions: 
Benchmarking  assumptions: 
Benchmarking  assumptions: 
forecasts  and  assumptions 
the 
in 
calculations  of  net  present  value  used  by  the  client 
for impairment testing to historical data, including the 
profit  history  of  the  businesses/groups  of  assets 
concerned.  

included 

the 

Sensitivity analysis: Assessing the reasonableness 
----    Sensitivity analysis: 
Sensitivity analysis: 
Sensitivity analysis: 
of 
by 
sensitivity 
management,  using  higher  discount  rates,  by 
considering  whether 
the  higher  discount  rates 
factored in sufficient downside risk.   

performed 

analysis 

VAT receivable     
VAT receivable 
VAT receivable 
VAT receivable 

Uncertainty over recoverability     
Uncertainty over recoverability 
Uncertainty over recoverability 
Uncertainty over recoverability 

VAT 
£1,049,000 (2017: £930,000).  

receivable 

exposure 

Refer to the  ARCC report, note 
4  (Use  of  Judgements  and 
Estimates  -  Assumptions  and 
Estimation  Uncertainties)  and 
note  23 
(Trade  and  Other 
Receivables).   

The  VAT  receivable  exposure  is  significant  and  its  
recoverability  rests on the outcome of  discussions  
with  the  Isle  of  Man  Government  Customs  and 
Excise Division (“IOM C&E”), which in turn will take 
into  account  the  final  assessment  by  UK  Customs 
and Excise of the impact of the recent CJEU ruling 
regarding 
the  dispute  between  Volkswagen 
Financial Services (UK) Limited (“VWFS”) v  
HM Revenue & Customs.  

The effect of these matters is that, as part of our risk 
assessment,  we  determined  that  the  impact  of  the 
final  assessment  of  the  amount  of  VAT  to  be 
recovered  has  a  high  degree  of  estimation 
uncertainty,  with  a  potential  range  of  reasonable 
outcomes  greater 
the 
financial statements as a whole, and possibly many 
times that amount. 

than  our  materiality  for 

----     Assessing  transparency:
Assessing  transparency:  Assessing  the  adequacy 
Assessing  transparency:
Assessing  transparency:
of  the  Group’s  disclosures  about  the  degree  of 
estimation  uncertainty  involved  in  performing  the 
impairment assessments. 
Our procedures included:  

----    Our tax expertise: 
Our tax expertise: Use of our own tax specialists to 
Our tax expertise: 
Our tax expertise: 
assist  in  our  assessment  of  the  latest  position 
regarding  both  the  VWFS  case  and  discussions 
between the Group and IOM C&E and our knowledge 
and  experience  of  the  application  of  relevant  tax 
legislation. 

----     Test  of  details: 
Test  of  details:  Use  of  our  own  tax  specialist  to 
Test  of  details: 
Test  of  details: 
assist in our testing of the calculations prepared by 
the  Group  based  on  the  revised  VAT  recoverable 
calculation. 

----     Assessing  transparency: 
Assessing  transparency:  Assessing  the  adequacy 
Assessing  transparency: 
Assessing  transparency: 
of  the  Group’s  disclosures  about  the  degree  of 
estimation  uncertainty  involved  in  assessing  the 
recoverability of this balance. 

Page | 27  

 
 
 
 
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
ANNUAL FINANCIAL STATEMENTS 

INDEPENDENT AUDITOR’S REPORT, TO THE MEMBERS OF MANX FINANCIAL 
GROUP PLC (CONTINUED)    

2 Key audit matters: our assessment of risks of material misstatement (continued) 
2 Key audit matters: our assessment of risks of material misstatement (continued)
2 Key audit matters: our assessment of risks of material misstatement (continued)
2 Key audit matters: our assessment of risks of material misstatement (continued)

Key audit matter    
Key audit matter
Key audit matter
Key audit matter
Carrying 
of  Parent 
of  Parent 
value 
Carrying 
value 
of  Parent 
value 
Carrying 
of  Parent 
value 
Carrying 
Company’s  subordinated  loans 
Company’s  subordinated  loans 
Company’s  subordinated  loans 
Company’s  subordinated  loans 
to 
in 
in 
to 
in 
to 
in 
to 
subsidiaries    
subsidiaries
subsidiaries
subsidiaries

investment 
investment 
investment 
investment 

and 
and 
and 
and 

loans 

Subordinated 
to 
subsidiaries  £7,778,000  (2017: 
£5,778,000)  and  investment  in 
subsidiaries £16,172,000 (2017: 
£13,772,000) 

(Investment 

Refer  to  the  ARCC  report,  note 
in  Group 
32 
Undertakings) and note 38(A)(v) 
(Separate Financial Statements 
of the Company). 

The risk 
The risk          
The risk 
The risk 
High value    
High value
High value
High value

Auditor’s
response    
Auditor’s    response
response
response
Auditor’s
Auditor’s
Our procedures included:  

The  carrying  value  of 
the  Parent  Company’s 
subordinated loans to and investment in subsidiaries 
represents  93.0%  (2017:  98.0%)  of  the  Parent 
Company’s total assets. The assessment of carrying 
value is not at a high risk of significant misstatement 
or  subject  to  significant  judgement  as  the  carrying 
value is supported by the audited net asset value of 
the  subsidiaries.  However,  due  to  its  materiality  in 
the  context  of 
financial 
statements, this is considered to be the area that had 
the  greatest  effect  on  our  overall  Parent  Company 
audit. 

the  Parent  Company 

the 

loans 

Tests  of  detail: 
to  and 
Tests  of  detail:  Assessing 
Tests  of  detail: 
Tests  of  detail: 
investment in subsidiaries to identify, with reference 
to 
the  subsidiaries’  accounts,  whether  each 
subsidiary  has  sufficient  assets  to  repay  the  debt 
owed  and  support 
the 
investment. 

the  carrying  value  of 

Assessing subsidiary audits: 
Assessing subsidiary audits: A full scope audit of the 
Assessing subsidiary audits: 
Assessing subsidiary audits: 
accounts  of  the  subsidiaries  by  the  group  audit 
engagement team. 

3  Our  application  of  materiality and  an  overview  of  the  scope  of  our 
3  Our  application  of  materiality and  an  overview  of  the  scope  of  our 
3  Our  application  of  materiality and  an  overview  of  the  scope  of  our 
3  Our  application  of  materiality and  an  overview  of  the  scope  of  our 
audit   
audit       
audit   
audit   
Materiality for the Group and Parent Company financial statements as 
a  whole  was  set  at  £130,000  (2017:  £140,000),  determined  with 
reference  to  a  benchmark  of  Group  profit  before  tax,  of  which  it 
represents approximately 5.0%.    

We agreed to report to the Audit, Risk and Compliance Committee any 
corrected  or  uncorrected  identified  misstatements  exceeding  £7,000 
(2017:  £7,000)  for  both  the  Group  and  Parent  Company  financial 
statements, in addition to other identified misstatements that warranted 
reporting on qualitative grounds.   

The Group’s subsidiaries were subjected to full scope statutory audit 
by  the  Group  audit  team  and  subject  to  a  lower  level  of  materiality 
based on their individual financial statements.  

4 We have nothing to report on going concern 
4 We have nothing to report on going concern     
4 We have nothing to report on going concern 
4 We have nothing to report on going concern 
The  Directors  have  prepared  the  financial  statements  on  the  going 
concern basis as they do not intend to liquidate the Company or the 
Group or to cease their operations, and as they have concluded that 
the  Company’s  and  the  Group’s  financial  position  means  that  this is 
realistic.  They  have  also  concluded  that  there  are  no  material 
uncertainties that could have cast significant doubt over their ability to 
continue  as  a  going  concern  for  at  least  a  year  from  the  date  of 
approval of the financial statements (“the going concern period”).   

Our  responsibility  is  to  conclude  on  the  appropriateness  of  the 
Directors’  conclusions  and,  had  there  been  a  material  uncertainty 
related to going concern, to make reference to that in this audit report. 
However, as we cannot predict all future events or conditions and as 
subsequent events may result in outcomes that are inconsistent with 
judgements  that  were  reasonable  at  the  time  they  were  made,  the 
absence of reference to a material uncertainty in this auditor's report is 
not  a  guarantee  that  the  group  or  the  company  will  continue  in 
operation.  

4 We have nothing to report on going concern (continued)
4 We have nothing to report on going concern (continued)    
4 We have nothing to report on going concern (continued)
4 We have nothing to report on going concern (continued)
In  our  evaluation  of  the  Directors’  conclusions,  we  considered  the 
inherent  risks  to  the  Group’s  and  Company’s  business  model,  and 
analysed  how  those  risks  might  affect  the  Group’s  and  Parent 
Company’s  financial  resources or  ability to  continue  operations  over 
the  going  concern  period.    We  evaluated  those  risks  and  concluded 
that they were not significant enough to require us to perform additional 
audit procedures.   

Based  on  this  work,  we  are  required  to  report  to  you  if  we  have 
concluded  that  the  use  of  the  going  concern  basis  of  accounting  is 
inappropriate or there is an undisclosed material uncertainty that may 
cast significant doubt over the use of that basis for a period of at least 
a year from the date of approval of the financial statements.   
We have nothing to report in these respects, and we did not identify 
going concern as a key audit matter. 

5  We  have  nothing  to  report  on  the  other  information  in  the  Annual 
5  We  have  nothing  to  report  on  the  other  information  in  the  Annual 
5  We  have  nothing  to  report  on  the  other  information  in  the  Annual 
5  We  have  nothing  to  report  on  the  other  information  in  the  Annual 
Report 
Report     
Report 
Report 
The  Directors  are  responsible  for  the  other  information  presented  in 
the Annual Report together with the financial statements.  Our opinion 
on the financial statements does not cover the other information and, 
accordingly, we do not express an audit opinion or, except as explicitly 
stated below, any form of assurance conclusion thereon.   

Our  responsibility  is  to  read  the  other  information  and,  in  doing  so, 
consider  whether,  based  on  our  financial  statements  audit  work,  the 
information  therein  is  materially  misstated  or  inconsistent  with  the 
financial statements or our audit knowledge.  Based solely on that work 
we have not identified material misstatements in the other information.   

Page | 28  

 
 
 
 
  
 
 
 
 
 
    
    
  
  
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

INDEPENDENT AUDITOR’S REPORT, TO THE MEMBERS OF MANX FINANCIAL 
GROUP PLC (CONTINUED)    

6 Respective responsibilities   
6 Respective responsibilities       
6 Respective responsibilities   
6 Respective responsibilities   
Directors’ responsibilities
Directors’ responsibilities                
Directors’ responsibilities
Directors’ responsibilities
As explained more fully in their statement set out on page 25, the 
Directors  are  responsible  for:  the  preparation  of  the  financial 
statements including being satisfied that they give a true and fair 
view;  such  internal  control  as  they  determine  is  necessary  to 
enable  the  preparation  of  financial  statements  that  are  free  from 
material misstatement, whether due to fraud or error; assessing the 
Group  and  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 
they 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
Auditor’s responsibilities                
Auditor’s responsibilities
Auditor’s responsibilities
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  our 
opinion in an auditor’s report. Reasonable assurance is a high level 
of  assurance,  but  does  not  guarantee  that  an  audit  conducted  in 
ISAs  (UK)  will  always  detect  a  material 
accordance  with 
misstatement when it exists. Misstatements can arise from fraud or 
error  and  are  considered  material  if, individually  or in  aggregate, 
they  could  reasonably  be  expected  to  influence  the  economic 
decisions of users taken on the basis of the financial statements.    

A fuller description of our responsibilities is provided on the FRC’s 
website at www.frc.org.uk/auditorsresponsibilities. 

7  The  purpose  of  our  audit  work  and  to  whom  we  owe  our 
7  The  purpose  of  our  audit  work  and  to  whom  we  owe  our 
7  The  purpose  of  our  audit  work  and  to  whom  we  owe  our 
7  The  purpose  of  our  audit  work  and  to  whom  we  owe  our 
responsibilities   
responsibilities       
responsibilities   
responsibilities   
This report is made solely to the Company’s members, as a body, in 
accordance  with  Section  80(c)  of  the  Isle  of  Man  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.   

KPMG Audit LLC  
Chartered Accountants  
Heritage Court  
41 Athol Street 
Douglas  
Isle of Man IM99 1HN  

28 March 2019 

Page | 29  

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

CONSOLIDATED STATEMENT OF PROFIT OR LOSS AND OTHER 
COMPREHENSIVE INCOME 

For the year ended 31 December     

Notes 

Interest income  
Interest expense 

Net interest income    
Net interest income
Net interest income
Net interest income

Fee and commission income    
Fee and commission expense    

Net trading income    
Net trading income
Net trading income
Net trading income

Other operating income 
Loss on trading assets 
Realised gains on debt securities 
Terminal funding 

Operating income    
Operating income
Operating income
Operating income

Personnel expenses  
Other expenses 
Impairment on loans and advances to customers 
Depreciation 
Amortisation and impairment of intangibles 
Share of profit of equity accounted investees, net of tax 
VAT recovery 

Profit before tax payable    
Profit before tax payable
Profit before tax payable
Profit before tax payable

Income tax expense 

Profit for the year     
Profit for the year 
Profit for the year 
Profit for the year 

Other comprehensive income:    ---- 
Other comprehensive income:
Other comprehensive income:
Other comprehensive income:

Items that will be reclassified to profit or loss        
Items that will be reclassified to profit or loss
Items that will be reclassified to profit or loss
Items that will be reclassified to profit or loss
Unrealised gain/(losses) on debt securities 

Items that will never be 
reclassified to profit or loss    
Items that will never be reclassified to profit or loss
reclassified to profit or loss
reclassified to profit or loss
Items that will never be 
Items that will never be 
Actuarial (losses)/gains on defined benefit pension scheme taken to equity 

Total comprehensive income for the period attributable to owners     
Total comprehensive income for the period attributable to owners 
Total comprehensive income for the period attributable to owners 
Total comprehensive income for the period attributable to owners 

Basic earnings per share (pence) 
Diluted earnings per share (pence) 

The notes on pages 37 to 78 form part of these financial statements.  

The Directors believe that all results derive from continuing activities. 

10 

11 
11 

21 
20 
12 

13 
14 
15  
24 
25 
32 
23 

16 

17 

20 

30 

18 
18 

2018
2018    
20182018
£000    
£000
£000£000

19,115    
19,115
19,115
19,115
(3,547)    
(3,547)
(3,547)
(3,547)

Restated 
(Note 5) 

2017                              
£000   

19,893 
(3,256) 

15,568    
15,568
15,568
15,568

16,637 

3,371    
3,371
3,371
3,371
(6,109)    
(6,109)
(6,109)
(6,109)

3,115 
(8,413) 

12,830    
12,830
12,830
12,830

11,339 

131131131131    
(4)(4)(4)(4)    
135135135135    
74747474    

91 
(21) 
36 
90 

13,166    
13,166
13,166
13,166

11,535 

(5,703)
(5,703)    
(5,703)
(5,703)
(3,4(3,4(3,4(3,465656565))))    
(857
(857))))    
(857(857
(184)
(184)    
(184)
(184)
(396)
(396)    
(396)
(396)
30303030    
119119119119    

2,2,2,2,710710710710    

(2(2(2(243434343))))    

2,467    
2,467
2,467
2,467

44444444    

(50)    
(50)
(50)
(50)

2,2,2,2,461461461461    

1.881.881.881.88    
1.541.541.541.54    

(4,783) 
(3,152) 
(585) 
(134) 
(286) 
38 
65 

2,698 

(240) 

2,458 

(93) 

30 

2,395 

2.17 
1.70 

Page | 30  

 
 
 
  
  
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
    
 
 
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
    
    
 
 
    
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
    
    
 
 
    
    
 
 
    
  
    
    
 
 
    
    
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

COMPANY STATEMENT OF PROFIT OR LOSS AND OTHER 
COMPREHENSIVE INCOME 

For the year ended 31 December     

Notes 

Interest income 

Operating income    
Operating income
Operating income
Operating income

Personnel expenses    
Administration expenses 
Depreciation expense    

Profit before tax payable    
Profit before tax payable
Profit before tax payable
Profit before tax payable

Tax payable 

Profit for the year     
Profit for the year 
Profit for the year 
Profit for the year 

Total comprehensive income for the year    
Total comprehensive income for the year
Total comprehensive income for the year
Total comprehensive income for the year

The notes on pages 37 to 78 form part of these financial statements.  

The Directors believe that all results derive from continuing activities. 

16 

2018    
2018
20182018
£000    
£000
£000£000

466466466466    

466466466466    

(177)
(177)    
(177)
(177)
(132)
(132)    
(132)
(132)
(41)    
(41)
(41)
(41)

116116116116    

----    

116116116116    

116116116116    

2017                              
£000   

- 

- 

(22) 
(112) 
(40) 

(174) 

- 

(174) 

(174) 

Page | 31  

 
 
 
  
  
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
    
    
 
 
    
    
 
 
 
    
    
 
 
    
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

CONSOLIDATED STATEMENT OF FINANCIAL POSITION 

As at 31 December     

Notes 

Assets
Assets    
Assets
Assets
Cash and cash equivalents 
Debt securities 
Trading asset 
Loans and advances to customers 
Trade and other receivables 
Property, plant and equipment 
Intangible assets 
Goodwill 
Investment in associate 

Total assets    
Total assets
Total assets
Total assets

Liabilities
Liabilities    
Liabilities
Liabilities
Deposits from customers 
Creditors and accrued charges 
Block creditors 
Loan notes 
Pension liability 
Deferred tax liability 

liabilities    
Total liabilities
Total 
liabilities
liabilities
Total 
Total 

Equity
Equity    
Equity
Equity
Called up share capital 
Profit and loss account 

Total equity    
Total equity
Total equity
Total equity

Total liabilities and equity    
Total liabilities and equity
Total liabilities and equity
Total liabilities and equity

19 
20 
21  
22 
23 
24 
25 
32 
32 

26 
27 
28 
29 
30 
17 

31 

  Restated 
(Note 5) 
2017 
£000 

Restated 
(Note 5) 
2016 
£000 

9,745    
34,272    
24    
122,546    
1,908    
450    
1,719    
2,344    
38    

173,046    

142,272    
3,164    
751    
8,995    
560    
42    

155,784    

6,129 
23,991 
70 
115,929 
2,064 
719 
1,316 
2,344 
- 

152,562 

125,952 
2,975 
1,390 
8,545 
614 
40 

139,516 

2018    
2018
20182018
££££000000000000 

9,753 
9,753
9,753
9,753
30,534 
30,534
30,534
30,534
20202020 
148,278787878 
148,2
148,2
148,2
2,491
2,491 
2,491
2,491
1,384
1,384 
1,384
1,384
1,952 
1,952
1,952
1,952
2,344
2,344 
2,344
2,344
158158158158 

196,914914914914 
196,
196,196,

158,500
158,500 
158,500
158,500
2,012,012,012,010000 
138138138138 
15,871 
15,871
15,871
15,871
584584584584 
88888888 

177,191191191191 
177,
177,177,

20,732
20,732 
20,732
20,732
(1,0(1,0(1,0(1,009090909)))) 

19,19,19,19,723723723723 

20,732    
(3,470)    

17,262    

18,933 
(5,887) 

13,046 

196,914 
196,914
196,914
196,914

173,046    

152,562 

The financial statements were approved by the Board of Directors on 27 March 2019 and signed on its behalf by: - 

Jim Mellon
Jim Mellon    
Jim Mellon
Jim Mellon
Executive Chairman 

Denham Eke
Denham Eke    
Denham Eke
Denham Eke
Chief Executive Officer 

Douglas Grant
Douglas Grant    
Douglas Grant
Douglas Grant
Group Finance Director 

The notes on pages 37 to 78 form part of these financial statements. 

Page | 32  

 
 
 
 
    
    
 
 
 
 
 
 
    
    
 
    
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
    
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
    
    
 
 
 
ANNUAL FINANCIAL STATEMENTS 

COMPANY STATEMENT OF FINANCIAL POSITION 

As at 31 December     

Notes 

Assets
Assets    
Assets
Assets
Cash and cash equivalents 
Trade and other receivables 
Amounts due from Group undertakings 
Property, plant and equipment 
Investment in Group undertakings 
Subordinated loans 

Total assets    
Total assets
Total assets
Total assets

Liabilities
Liabilities    
Liabilities
Liabilities
Creditors and accrued charges 
Amounts due to Group undertakings 
Loan notes 

Total liabilities    
Total liabilities
Total liabilities
Total liabilities

Equity
Equity    
Equity
Equity
Called up share capital 
Profit and loss account 

Total equity    
Total equity
Total equity
Total equity

Total liabilities and equity    
Total liabilities and equity
Total liabilities and equity
Total liabilities and equity

19 
23 
32 
24 
32 
32 

27 
32 
29 

31 

The notes on pages 37 to 78 form part of these financial statements.  

2018
2018    
20182018
££££000000000000 

1,646
1,646    
1,646
1,646
32323232    
----    
126126126126    
16,172
16,172    
16,172
16,172
7,778    
7,778
7,778
7,778

25,754    
25,754
25,754
25,754

94949494    
1,370
1,370    
1,370
1,370
15,871    
15,871
15,871
15,871

17,335    
17,335
17,335
17,335

2017 
£000 

200 
22 
16 
166 
13,772 
5,778 

19,954 

139 
2,517 
8,995 

11,651 

20,732
20,732    
20,732
20,732
(12,313)    
(12,313)
(12,313)
(12,313)

8,419    
8,419
8,419
8,419

25,754    
25,754
25,754
25,754

20,732 
(12,429) 

8,303 

19,954 

Page | 33  

 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
ANNUAL FINANCIAL STATEMENTS 

CONSOLIDATED AND COMPANY STATEMENTS OF CHANGES IN EQUITY 

GroupGroupGroupGroup    

Balance as at 1 
January 2017 (as originally stated)    
Balance as at 1 January 2017 (as originally stated)
January 2017 (as originally stated)
January 2017 (as originally stated)
Balance as at 1 
Balance as at 1 
Retrospective impact on initial application of IFRS 9 (see note 5) 
Restated balance at 1 January 2017 

Profit for the year (See note 8.A.(iv)) 
Other comprehensive income 

Transactions with owners: - 
Share-based payment expense (see notes 16 and 31) 
Shares issued  

Restated Balance as at 31 December 2017 

Profit for the year 

Other comprehensive income 

Transactions with owners: - 
Share-based payment expense (see notes 16 and 31) 

Share 
Share 
Share 
Share 
capital
capital    
capital
capital
££££000000000000    

18,933 
- 
18,933 

- 
- 

- 
1,799 

20,732 

- 

- 

- 

Profit and 
Profit and 
Profit and 
Profit and 
loss account
loss account    
loss account
loss account
££££000000000000    

(5,763) 
(124) 
(5,887) 

2,458 
(63) 

22 
- 

(3,470) 

2,467 

(6) 

- 

Total 
Total     
Total 
Total 
equity    
equity
equity
equity
£000 
£000
£000£000

13,170 
(124) 
13,046 

2,458 
(63) 

22 
1,799 

17,262 

2,467 

(6) 

- 

Balance as at 31 December 2018    
Balance as at 31 December 2018
Balance as at 31 December 2018
Balance as at 31 December 2018

20,732    
20,732
20,732
20,732

(1,0(1,0(1,0(1,009090909))))    

19,19,19,19,723723723723    

Company    
Company
Company
Company

Balance as at 1 January 2017 

Loss for the year 

Transactions with owners: - 
Share-based payment expense (see notes 16 and 31) 
Shares issued  

Balance as at 31 December 2017 

Profit for the year 

Transactions with owners: 
Transactions with owners: ----    
Transactions with owners: 
Transactions with owners: 
Share-based payment expense (see notes 16 and 31) 

Share 
Share 
Share 
Share 
Capital    
Capital
Capital
Capital
££££000000000000    

Profit and 
Profit and 
Profit and 
Profit and 
loss account    
loss account
loss account
loss account
££££000000000000    

18,933 

(12,277) 

- 

(174) 

- 
1,799 

20,732 

- 

----    

22 
- 

(12,429) 

116 

----    

Total     
Total 
Total 
Total 
equity    
equity
equity
equity
££££000000000000 

6,656 

(174) 

22 
1,799 

8,303 

116 

---- 

Balance as at 31 December 2018    
Balance as at 31 December 2018
Balance as at 31 December 2018
Balance as at 31 December 2018

20,732    
20,732
20,732
20,732

(12,313)    
(12,313)
(12,313)
(12,313)

8,419 
8,419
8,419
8,419

The notes on pages 37 to 78 form part of these financial statements. 

Page | 34  

 
 
 
 
 
    
    
    
 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
    
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
 
 
    
    
 
 
 
    
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
 
 
 
 
 
 
 
 
 
 
    
 
    
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
    
 
    
 
    
 
 
    
 
 
 
 
    
 
    
 
    
 
    
 
    
 
    
 
    
 
 
 
    
 
    
 
    
 
 
    
 
 
 
 
 
 
    
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

CONSOLIDATED STATEMENT OF CASH FLOWS 

For the year ended 31 December 

RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS    
RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS
RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS
RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS

Notes 

2018
2018    
20182018
£000 
£000
£000£000

2017 
£000 

Profit before tax 

Adjustments for: 
Depreciation 
Amortisation and impairment of intangibles 
Realised gains on debt securities 
Share in net assets of associate 
Equity settled share-based payment transactions 

Changes in: 
Trading asset 
Trade and other receivables 
Creditors and accrued charges 

Net cash flow from trading activities 
Changes in: 
Loans and advances to customers 
Deposits from customers 
Pension contribution 

Cash (outflow)/inflow from operating activities 
Cash (outflow)/inflow from operating activities
Cash (outflow)/inflow from operating activities
Cash (outflow)/inflow from operating activities

CASH FLOW STATEMENT    
CASH FLOW STATEMENT
CASH FLOW STATEMENT
CASH FLOW STATEMENT

Cash from operating activities
Cash from operating activities    
Cash from operating activities
Cash from operating activities
Cash (outflow)/inflow from operating activities    
Income taxes paid    

Net cash (outflow)/inflow from operating activities 
Net cash (outflow)/inflow from operating activities
Net cash (outflow)/inflow from operating activities
Net cash (outflow)/inflow from operating activities

Cash flows from investing activities
Cash flows from investing activities    
Cash flows from investing activities
Cash flows from investing activities
Purchase of property, plant and equipment 
Purchase of intangible assets 
Sale of tangible fixed assets 
Acquisition of associate 
Sales/(Purchase) of debt securities at FVOCI 
Purchase of debt securities at amortised cost 

Net cash inflow/(outflow) from investing activities    
Net cash inflow/(outflow) from investing activities
Net cash inflow/(outflow) from investing activities
Net cash inflow/(outflow) from investing activities

Cash flows from financing activities
Cash flows from financing activities    
Cash flows from financing activities
Cash flows from financing activities
Receipt of loan notes 
Increase in share capital 
(Decrease) in borrowings from block creditors 

Net cash inflow from financing activities    
Net cash inflow from financing activities
Net cash inflow from financing activities
Net cash inflow from financing activities

Net increase in cash and cash equivalents    
Net increase in cash and cash equivalents
Net increase in cash and cash equivalents
Net increase in cash and cash equivalents

Cash and cash equivalents at 1 January  

Cash and cash equivalents at 31 December    
Cash and cash equivalents at 31 December
Cash and cash equivalents at 31 December
Cash and cash equivalents at 31 December

Included in cash flows are: ----        
Included in cash flows are: 
Included in cash flows are: 
Included in cash flows are: 
Interest received – cash amounts 
Interest paid – cash amounts 

The notes on pages 37 to 78 form part of these financial statements.  

24 
25 
20 
32 
16, 31 

21 

30 

24 
25 

32 
20 
20 

29 

28 

2,2,2,2,710710710710    

2,698 

184184184184    
396396396396    
(135)
(135)    
(135)
(135)
(30)    
(30)
(30)
(30)
----    

134 
286 
(36) 
(38) 
22 

3,3,3,3,125125125125    

3,066 

4444    
(583)    
(583)
(583)
(583)
(1,1(1,1(1,1(1,169696969))))    

1,31,31,31,377777777    

(25,732323232))))    
(25,7
(25,7
(25,7
16,228    
16,228
16,228
16,228
(26)    
(26)
(26)
(26)

(8,153)    
(8,153)
(8,153)
(8,153)

(8,153)    
(8,153)
(8,153)
(8,153)
(182)    
(182)
(182)
(182)

(8,335)    
(8,335)
(8,335)
(8,335)

(1,118)    
(1,118)
(1,118)
(1,118)
(629)
(629)    
(629)
(629)
----    
(90)
(90)    
(90)
(90)
3,917
3,917    
3,917
3,917
----    

2,080    
2,080
2,080
2,080

6,876    
6,876
6,876
6,876
----    
(613)    
(613)
(613)
(613)

6,263    
6,263
6,263
6,263

8888    

9,745    
9,745
9,745
9,745

9,753    
9,753
9,753
9,753

46 
156 
(21) 

3,247 

(6,617) 
16,320 
(24) 

12,926 

12,926 
(28) 

12,898 

(122) 
(452) 
20 
- 
(4,806) 
(5,532) 

(10,892) 

450 
1,799 
(639) 

1,610 

3,616 

6,129 

9,745 

18,362
18,362    
18,362
18,362
(3,434)    
(3,434)
(3,434)
(3,434)

19,109 
(3,152) 

Page | 35  

 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
    
 
 
 
 
 
    
 
 
    
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
 
 
 
    
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
 
    
 
 
    
 
 
    
    
    
 
 
 
    
 
 
 
 
 
    
    
    
    
    
 
    
    
    
    
    
 
    
    
    
    
    
 
    
    
    
    
 
 
    
 
 
    
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
    
 
 
ANNUAL FINANCIAL STATEMENTS 

COMPANY STATEMENT OF CASH FLOWS  

For the year ended 31 December 

RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS    
RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS
RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS
RECONCILIATION OF PROFIT BEFORE TAXATION TO OPERATING CASH FLOWS

Notes 

2018
2018    
20182018
£000 
£000
£000£000

2017 
£000 

Profit before tax 

Adjustments for: 
- Depreciation 
- Share-based payment expense 

Changes in: 
Amounts due from group undertakings 
Trade and other receivables 
Creditors and accrued charges 
Amounts due to group undertakings 

Cash (outflow)/inflow from operating activities  

CASH FLOW STATEMENT    
CASH FLOW STATEMENT
CASH FLOW STATEMENT
CASH FLOW STATEMENT

Cash from operating activities
Cash from operating activities    
Cash from operating activities
Cash from operating activities
Cash (outflow)/inflow from operating activities 
Income taxes paid    

Net cash (outflow)/inflow from operating activities    
Net cash (outflow)/inflow from operating activities
Net cash (outflow)/inflow from operating activities
Net cash (outflow)/inflow from operating activities

Cash flows from investing activities
Cash flows from investing activities    
Cash flows from investing activities
Cash flows from investing activities
Increase in investment in group undertakings 
Issue of subordinated loans 

Net cash outflow from investing activities    
Net cash outflow from investing activities
Net cash outflow from investing activities
Net cash outflow from investing activities

Cash flows from financing activities
Cash flows from financing activities    
Cash flows from financing activities
Cash flows from financing activities
Receipt of loan notes 
Increase in share capital 

activities    
Net cash inflow from financing activities
Net cash inflow from financing 
activities
activities
Net cash inflow from financing 
Net cash inflow from financing 

Net increase in cash and cash equivalents    
Net increase in cash and cash equivalents
Net increase in cash and cash equivalents
Net increase in cash and cash equivalents

Cash and cash equivalents at 1 January  

Cash and cash equivalents at 31 December    
Cash and cash equivalents at 31 December
Cash and cash equivalents at 31 December
Cash and cash equivalents at 31 December

The notes on pages 37 to 78 form part of these financial statements.  

24 
32 

32 
32 

29 

116116116116    

41414141    
----    

157157157157    

16161616    
(10)
(10)    
(10)
(10)
(45)
(45)    
(45)
(45)
(1,147)    
(1,147)
(1,147)
(1,147)

(1,029)    
(1,029)
(1,029)
(1,029)

(1,029)
(1,029)    
(1,029)
(1,029)
----    

(1,029)    
(1,029)
(1,029)
(1,029)

(2,400)
(2,400)    
(2,400)
(2,400)
(2,000)    
(2,000)
(2,000)
(2,000)

(4,400)    
(4,400)
(4,400)
(4,400)

6,875
6,875    
6,875
6,875
----    

6,875    
6,875
6,875
6,875

1,446    
1,446
1,446
1,446

200200200200    

1,646    
1,646
1,646
1,646

(174) 

41 
22 

(111) 

280 
7 
57 
18 

251 

251 
- 

251 

(1,700) 
(600) 

(2,300) 

450 
1,799 

2,249 

200 

- 

200 

Page | 36  

 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
    
 
 
    
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
    
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
 
 
 
 
 
    
 
 
    
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
    
    
    
    
    
    
    
    
 
    
    
    
    
    
 
    
 
 
    
 
 
 
 
 
    
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

1.1.1.1.  Reporting entity
Reporting entity    
Reporting entity
Reporting entity
Manx Financial Group PLC is a company incorporated in the Isle of Man. The consolidated financial statements of Manx Financial 
Group PLC (the “Company”) for the year ended 31 December 2018 comprise the Company and its subsidiaries (the “Group”).  

2.2.2.2.  Basis of
accounting    
Basis of    accounting
accounting
accounting
Basis of
Basis of
The  consolidated  and  the  separate  financial  statements  of  the  Company  have  been  prepared  in  accordance  with  International 
Financial  Reporting  Standards  (“IFRS”)  as  adopted  by  the  European  Union  (“EU”)  and  International  Financial  Reporting 
Interpretations Committee (“IFRIC”) interpretations applicable to companies reporting under IFRS, including International Accounting 
Standards (“IAS”).  

This is the first set of the Group’s annual financial statements in which IFRS 9 Financial Instruments and IFRS 15 Revenue from 
Contracts with Customers have been applied. Changes to significant accounting policies are described in Note 5. 

3.3.3.3.  Functional and presentation currency
Functional and presentation currency    
Functional and presentation currency
Functional and presentation currency
These financial statements are presented in pounds sterling, which is the Group’s functional currency. All amounts have been rounded 
to the nearest thousand, unless otherwise indicated. All subsidiaries of the Group have pounds sterling as their functional currency.  

4.4.4.4.  Use of judgements and estimates
Use of judgements and estimates    
Use of judgements and estimates
Use of judgements and estimates
The  preparation  of  financial  statements  requires  management  to  make  judgements,  estimates  and  assumptions  that  affect  the 
application of 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 accounting estimates are recognised in the 
period in which the estimate is revised and in any future periods affected.  

Assumptions and estimation uncertainties
Assumptions and estimation uncertainties    
Assumptions and estimation uncertainties
Assumptions and estimation uncertainties
Information  about  assumptions  and  estimation  uncertainties  at  year-end  that  have  a  significant  risk  of  resulting  in  a  material 
adjustment to the carrying amounts of assets and liabilities in the next financial year is included in the following notes:- 

  Note 23 – measurement of VAT receivable: key assumptions underlying carrying amount; 
  Note 30 – measurement of defined benefit obligations: key actuarial assumptions; 
  Note 25 and 32 – impairment test of intangible assets and goodwill: key assumptions underlying recoverable amounts; and 
  Note 38(I)(vii) – measurement of ECL allowance for loans and advances to customers and assessment of specific impairment 

allowances where loans are in default or arrears: key assumptions in determining the weighted-average loss rate. 

5.5.5.5.  Changes in accounting policies
Changes in accounting policies    
Changes in accounting policies
Changes in accounting policies
A number of other new standards are also effective from 1 January 2018 but they do not have a material effect on the Group’s financial 
statements.  

Except for the changes below, the Group has consistently applied the accounting policies as set out in Note 38 to all periods presented 
in these financial statements. 

IFRS 9 Financial Instruments    
IFRS 9 Financial Instruments
IFRS 9 Financial Instruments
IFRS 9 Financial Instruments

IFRS 9 sets out requirements for recognising and measuring financial assets, financial liabilities and some contracts to buy or sell 
non-financial items. This standard replaces IAS 39 Financial Instruments: Recognition and Measurement. The requirements of IFRS 
9 represent a significant change from IAS 39. The new standard brings fundamental changes to the accounting for financial assets 
and to certain aspects of the accounting for financial liabilities. 

The key changes to the Group’s accounting policies resulting from the Group’s adoption of IFRS 9 are summarised below. The full 
impact of adopting the standard is set out in Note 6 and 8. 

Classification of financial assets and financial liabilities    
Classification of financial assets and financial liabilities
Classification of financial assets and financial liabilities
Classification of financial assets and financial liabilities

IFRS 9 contains three principal classification categories for financial assets: measured at amortised cost, fair value through other 
comprehensive income (FVOCI) and fair value through profit or loss (FVTPL). IFRS 9 classification is generally based on the business 
model in which a financial asset is manged and its contractual cash flows. The standard eliminates the previous IAS 39 categories of 
held-to-maturity, loans and receivables and available-for-sale.  

Page | 37  

 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

accounting policies (continued)    
Changes in accounting policies (continued)
5.5.5.5.     Changes in 
accounting policies (continued)
accounting policies (continued)
Changes in 
Changes in 

Classification of financial assets and financial liabilities (continued)    
Classification of financial assets and financial liabilities (continued)
Classification of financial assets and financial liabilities (continued)
Classification of financial assets and financial liabilities (continued)

IFRS 9 largely retains the existing requirements in IAS 39 for classification of financial liabilities. However, although under IAS 39 all 
fair value changes of liabilities designated under the fair value option were recognised in profit or loss, under IFRS 9 fair value changes 
are generally presented as follows: 

 

 

the  amount  of  change  in  fair  value  that  is  attributable  to  changes  in  the  credit  risk  of  the  liability  is  presented  in  Other 
Comprehensive Income (“OCI”); and  
the remaining amount of change in the fair value is presented in profit or loss. 

For an explanation of how the Group classifies financial assets and liabilities under IFRS 9, See Note 38(I)(ii). 

Impairment of financial assets    
Impairment of financial assets
Impairment of financial assets
Impairment of financial assets

IFRS 9 replaces the ‘incurred loss’ model in IAS 39 with an ‘expected credit loss’ model.  

Under IFRS 9, credit losses are recognised earlier than under IAS 39. For an explanation of how the Group applies the impairment 
requirements of IFRS 9, see Note 38(I)(vii). 

Transition    
Transition
Transition
Transition

Changes in accounting policies resulting from the adoption of IFRS 9 have been applied retrospectively,  

For more information and details on the changes and implications resulting from the adoption of IFRS 9, see note 6 and 8(A)(iv). 

B. IFRS 15 Revenue from Contracts with Customers    
B. IFRS 15 Revenue from Contracts with Customers
B. IFRS 15 Revenue from Contracts with Customers
B. IFRS 15 Revenue from Contracts with Customers

IFRS 15 establishes a comprehensive framework for determining whether, how much and when revenue is recognised. It replaced 
IAS 18 Revenue, IAS 11 Construction Contracts and related interpretations. 

The Group initially applied IFRS 15 on 1 January 2018 retrospectively in accordance with IAS 8 without any practical expedients. The 
timing or amount of the Group’s fee income from contracts with customers was not impacted by the adoption of IFRS 15.  

Page | 38  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

6. Classification of financial assets and financial liabilities    
6. Classification of financial assets and financial liabilities
6. Classification of financial assets and financial liabilities
6. Classification of financial assets and financial liabilities

For description of how the Group classifies financial assets and liabilities, see Note 38(I)(ii) 

The  following  table  provides  reconciliation  between  line  items  in  the  statement  of  financial  position  and  categories  of  financial 
instruments. 

     Mandatorily 
Mandatorily 
Mandatorily 
Mandatorily 
at FVTPL    
at FVTPL
at FVTPL
at FVTPL

Designated 
Designated 
Designated 
Designated 
as at FVTPL    
as at FVTPL
as at FVTPL
as at FVTPL

FVOCI ––––    
FVOCI 
FVOCI 
FVOCI 
ddddebt ebt ebt ebt 
instruments    
instruments
instruments
instruments

FVOCI ––––    
FVOCI 
FVOCI 
FVOCI 
equity 
equity 
equity 
equity 
instruments    
instruments
instruments
instruments

Amortised 
Amortised 
Amortised 
Amortised 
cost    
cost
cost
cost

31 December 2018
31 December 2018    
31 December 2018
31 December 2018
Cash and cash equivalents 
Debt securities 
Trading assets 
Loans and advances to customers 
Trade and other receivables 
financial assets    
Total financial assets
Total 
financial assets
financial assets
Total 
Total 

Deposits from customers 
Creditor and accrued charges 
Block creditors 
Loan notes 

liabilities    
Total financial liabilities
Total financial 
liabilities
liabilities
Total financial 
Total financial 

31 December 2017 
Cash and cash equivalents 
Debt securities 
Trading assets 
Loans and advances to customers 
Trade and other receivables 
Total financial assets 

Deposits from customers 
Creditor and accrued charges 
Block creditors 
Loan notes 

Total financial liabilities 

- 
20 
- 
----    
20202020    

----    
- 
- 
- 

----    

- 
- 
- 
----    
----    

----    
- 
- 
- 

----    

30,534 
- 
- 
----    
30,534    
30,534
30,534
30,534

----    
- 
- 
- 

----    

- 
- 
- 
- 
----    

- 
- 
- 
- 

----    

  Mandatorily 
at FVTPL 

Designated 
as at FVTPL 

- 
- 
24 
- 
- 
24 

- 
- 
- 
- 

- 

- 
- 
- 
- 
- 
- 

- 
- 
- 
- 

- 

FVOCI – 
debt 
instruments 
- 
28,740 
- 
- 
- 
28,740 

FVOCI – 
equity 
instruments 
- 
- 
- 
- 
- 
- 

- 
- 
- 
- 

- 

- 
- 
- 
- 

- 

Total 
Total 
Total 
Total 
carrying 
carrying 
carrying 
carrying 
amount
amount    
amount
amount
9,753 
30,534 
20 
148,278 
2,491 
191,076767676    
191,0
191,0
191,0

158,500 
2,010 
138 
15,871 

9,753 
- 
- 
148,278 
2,491 
160,522222222    
160,5
160,5
160,5

158,500 
2,010 
138 
15,871 

176,519191919    
176,5
176,5
176,5

176,519191919    
176,5
176,5
176,5

Amortised 
cost 

9,745 
5,532 
- 
122,546 
1,908 
139,731 

142,272 
3,164 
751 
8,995 

Total 
carrying 
amount 
9,745 
34,272 
24 
122,546 
1,908 
168,495 

142,272 
3,164 
751 
8,995 

155,182 

155,182 

The following table shows the original measurement categories in accordance with IAS 39 and the new measurement categories 
under IFRS 9 for the Group’s financial assets and liabilities at 1 January 2017. 

1 January 2017 
Cash and cash equivalents 

Trading assets 

Debt securities 
Debt securities – Certificates of 
Deposit 
Loans and advances to customers 
Trade and other receivables 

Original 
classification under 
IAS 39 
Loans and 
receivables 
FVTPL 

Available-for-sale 
Amortised cost 

Amortised cost 
Loans and 
receivables 

New classification 
under IFRS 9 

Amortised cost 

FVTPL 
(Mandatory) 
FVOCI 
Amortised cost 

Amortised cost 
Amortised cost 

Original carrying 
amount under IAS 
39 
6,129 

New carrying 
amount under 
IFRS 9 
6,129 

70 

23,991 
- 

116,053 
2,064 

70 

23,991 
- 

115,929 
2,064 

Total financial assets 

148,307 

148,183 

Page | 39  

 
 
 
 
    
    
    
 
 
 
 
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

6. Classification of financial assets and financial liabilities (continued)    
6. Classification of financial assets and financial liabilities (continued)
6. Classification of financial assets and financial liabilities (continued)
6. Classification of financial assets and financial liabilities (continued)

1 January 2017 
Deposits from customers 
Creditor and accrued charges 
Block creditors 
Loan notes 

Total financial liabilities 

Original 
classification under 
IAS 39 
Amortised cost 
Amortised cost 
Amortised cost 
Amortised cost 

New classification 
under IFRS 9 

Amortised cost 
Amortised cost 
Amortised cost 
Amortised cost 

Original carrying 
amount under IAS 
39 
125,952 
2,975 
1,390 
8,545 

New carrying 
amount under 
IFRS 9 
125,952 
2,975 
1,390 
8,545 

138,862 

138,862 

In  applying  IFRS  9  both  in  the  current  period  and  retrospectively  in  previous  periods,  there  were  no  reclassifications  in  the 
measurement category.  As a result, there has been no financial adjustment in transitioning to IFRS 9 with respect to adopting the 
revised measurement categories. 

7. Fair value of financial instruments
7. Fair value of financial instruments    
7. Fair value of financial instruments
7. Fair value of financial instruments
For description of the Group’s fair value measurement accounting policy, see Note 38(I)(vi). 
The following table analyses financial instruments measured at fair value at the reporting date, by the level in the fair value hierarchy 
into which the fair value measurement is categorised. The amounts are based on the values recognised in the statement of financial 
position. 

31 December 2018    
31 December 2018
31 December 2018
31 December 2018

Debt securities 
Trading assets 

31 December 2017 

Investment securities 
Debt securities 
Trading assets 

Level 1
Level 1    
Level 1
Level 1
££££000000000000    

Level 2
Level 2    
Level 2
Level 2
££££000000000000    

Level 3
Level 3    
Level 3
Level 3
££££000000000000    

Total
Total    
Total
Total
££££000000000000    

30,534
30,534    
30,534
30,534
20202020    
30,554    
30,554
30,554
30,554

----    
----    
----    

----    
----    
----    

Level 1 
£000 

Level 2 
£000 

Level 3 
£000 

28,740 
24 
28,764 

- 
- 
- 

5,532 
- 
5,532 

30,534
30,534    
30,534
30,534
20202020    
30,554    
30,554
30,554
30,554

Total 
£000 

34,272 
24 
34,296 

Financial instruments not measured at 
fair value    
Financial instruments not measured at fair value
fair value
fair value
Financial instruments not measured at 
Financial instruments not measured at 
The following table sets out the fair values of financial instruments not measured at fair value and analyses them by the level in the 
fair value hierarchy into which each fair value measurement is categorised: -  

31 December 2018    
31 December 2018
31 December 2018
31 December 2018

Assets    
Assets
Assets
Assets
Cash and cash equivalents 
Loans and advances to customers 
Investment in associate 
Trade and other receivables 

Liabilities
Liabilities    
Liabilities
Liabilities
Deposits from customers 
Creditors and accrued charges 
Block creditors 
Loan notes 

Level 1
Level 1    
Level 1
Level 1
££££000000000000    

Level 2
Level 2    
Level 2
Level 2
££££000000000000    

Level 3
Level 3    
Level 3
Level 3
££££000000000000    

----    
----    
----    
----    
----    

----    
----    
----    
----    
----    

9,753
9,753    
9,753
9,753
----    
----    
----    
9,753    
9,753
9,753
9,753

158,500
158,500    
158,500
158,500
----    
----    
----    
158,500    
158,500
158,500
158,500

----    
148,278787878    
148,2
148,2
148,2
158158158158    
2,491    
2,491
2,491
2,491
150,927272727    
150,9
150,9
150,9

----    
2,012,012,012,010000    
138138138138    
15,871
15,871    
15,871
15,871
18,018,018,018,019191919    

Total fair 
Total fair 
Total fair 
Total fair 
values
values    
values
values
££££000000000000    

9,753
9,753    
9,753
9,753
148,278787878    
148,2
148,2
148,2
158158158158    
2,491    
2,491
2,491
2,491
160,680808080    
160,6
160,6
160,6

158,500
158,500    
158,500
158,500
2,012,012,012,010000    
138138138138    
15,871
15,871    
15,871
15,871
176,519191919    
176,5
176,5
176,5

Total 
Total 
Total 
Total 
carrying 
carrying 
carrying 
carrying 
amount
amount    
amount
amount
££££000000000000    

9,753
9,753    
9,753
9,753
148,278787878    
148,2
148,2
148,2
158158158158    
2,491    
2,491
2,491
2,491
160,680808080    
160,6
160,6
160,6

158,500
158,500    
158,500
158,500
2,012,012,012,010000    
138138138138    
15,871
15,871    
15,871
15,871
176,519191919    
176,5
176,5
176,5

Page | 40  

 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
 
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

7. Fair value of financial instruments (continued)    
7. Fair value of financial instruments (continued)
7. Fair value of financial instruments (continued)
7. Fair value of financial instruments (continued)
Financial instruments not measured at fair value (continued)    
Financial instruments not measured at fair value (continued)
Financial instruments not measured at fair value (continued)
Financial instruments not measured at fair value (continued)

31 December 2017 

Assets 
Cash and cash equivalents 
Debt securities – certificates of deposit 
Loans and advances to customers 
Investment in associate 
Trade and other receivables 

Liabilities 
Deposits from customers 
Creditors and accrued charges 
Block creditors 
Loan notes 

Level 1 
£000 

Level 2 
£000 

Level 3 
£000 

- 
- 
- 
- 
- 
- 

- 
- 
- 
- 
- 

9,745 
- 
- 
- 
- 
9,745 

142,272 
- 
- 
- 
142,272 

- 
5,532 
122,546 
24 
1,908 
130,010 

- 
3,164 
751 
8,995 
12,910 

Total fair 
values 
£000 

9,745 
5,532 
122,546 
24 
1,908 
139,755 

142,272 
3,164 
751 
8,995 
155,182 

Total 
carrying 
amount 
£000 

9,745 
5,532 
122,546 
24 
1,908 
139,755 

142,272 
3,164 
751 
8,995 
155,182 

The fair value of loans and advances is estimated using valuation models, such as discounted cash flow techniques. Input into the 
valuation  techniques  includes expected  lifetime credit  losses,  interest  rates,  prepayment  rates.  For  collateral-dependent  impaired 
loans, the fair value is measured based on the value of the underlying collateral. Input into the models may include data from third 
party  brokers based on  over  the counter  trading activity,  and  information obtained  from other  market  participants,  which  includes 
observed primary and secondary transactions.  

8. Financial risk review
8. Financial risk review    
8. Financial risk review
8. Financial risk review
Risk management
Risk management    
Risk management
Risk management
This note presents information about the Group’s exposure to financial risks and the Group’s management of capital. For information 
on the Group’s financial risk management framework, see Note 36.  

A. Credit risk
A. Credit risk    
A. Credit risk
A. Credit risk
For definition of credit risk and information on how credit risk is mitigated by the Group, see Note 36. 

i. Credit quality analysis    
i. Credit quality analysis
i. Credit quality analysis
i. Credit quality analysis

Loans and advances to customers    
Loans and advances to customers
Loans and advances to customers
Loans and advances to customers

Explanation of the terms ‘Stage 1’, ‘Stage 2’ and ‘Stage 3’ is included in Note 38 (I)(vii). 

An analysis of the credit risk on loans and advances to customers is as follows: - 

Grade A1 
Grade B 
Grade C 

Gross value 

Allowance for impairment 
Carrying value 

Stage 1 
£000 

139,695 
760 
- 

140,455 

(125) 
140,330 

Stage 2 
£000 

Stage 3 
£000 

2018
2018    
20182018
£000    
£000
£000£000

139,695
139,695    
139,695
139,695
6,153
6,153    
6,153
6,153
5,824    
5,824
5,824
5,824

2017 
£000 

118,373 
3,090 
3,770 

- 
85 
4,078 

4,163 

151,672    
151,672
151,672
151,672

125,233 

(3,126) 
1,037 

(3,(3,(3,(3,394394394394))))    
148,278787878    
148,2
148,2
148,2

(2,687) 
122,546 

- 
5,308 
1,746 

7,054 

(143) 
6,911 

1 Loans  are graded A to C  depending  on the level  of risk. Grade C  relates to  agreements with the highest  of risk,  Grade B with medium  risk  and  Grade  A relates to 
agreements with the lowest risk.  

Page | 41  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

8. Financial risk review (continued)    
8. Financial risk review (continued)
8. Financial risk review (continued)
8. Financial risk review (continued)
Risk management (continued)
Risk management (continued)    
Risk management (continued)
Risk management (continued)
A. Credit risk (continued)
A. Credit risk (continued)    
A. Credit risk (continued)
A. Credit risk (continued)
i. Credit quality analysis (continued)
i. Credit quality analysis (continued)    
i. Credit quality analysis (continued)
i. Credit quality analysis (continued)
(continued)    
Loans and advances to customers (continued)
Loans and advances to customers 
(continued)
(continued)
Loans and advances to customers 
Loans and advances to customers 

The following table sets out information about the overdue status of loans and advances to customers in Stage 1, 2 and 3. 

31 December  

Current 
Overdue < 30 days 
Overdue > 30 days 

Stage 1 
£000 

137,196 
2,499 
760 

140,455 

Debt securities, Cash and cash equivalents
Debt securities, Cash and cash equivalents    
Debt securities, Cash and cash equivalents
Debt securities, Cash and cash equivalents
The following table sets out the credit quality of liquid assets:  

31 December 

Government bonds and treasury bills    
Government bonds and treasury bills
Government bonds and treasury bills
Government bonds and treasury bills
Rated A to A+ 

Corporate bonds
Corporate bonds    
Corporate bonds
Corporate bonds
Rated A to A+ 

Cash and cash 
equivalents    
Cash and cash equivalents
equivalents
equivalents
Cash and cash 
Cash and cash 
Rated A to A+ 

Stage 2 
£000 

Stage 3 
£000 

- 
- 
7,054 

7,054 

- 
- 
4,163 

2018
2018    
20182018
£000    
£000
£000£000

137,196
137,196    
137,196
137,196
2,499
2,499    
2,499
2,499
11,977777    
11,97
11,97
11,97

2017 
£000 

115,267 
3,106 
6,860 

4,163 

151,672222    
151,67
151,67
151,67

125,233 

2018
2018    
20182018
£000    
£000
£000£000

2017 
£000 

30,534    
30,534
30,534
30,534

28,740 

----    

5,532 

9,754    
9,754
9,754
9,754

9,745 

40,288    
40,288
40,288
40,288

44,017 

The analysis has been based on Standard & Poor’s ratings. 

ii. Collateral and other credit enhancements
ii. Collateral and other credit enhancements    
ii. Collateral and other credit enhancements
ii. Collateral and other credit enhancements
The Group holds collateral in the form of the underlying assets (typically private and commercial vehicles, plant and machinery) to 
loan arrangements as security for HP, finances leases, vehicle stocking plans, block discounting, wholesale funding arrangements, 
integrated wholesale funding arrangements and secured commercial loan balances, which are sub-categories of loans and advances 
to customers. In addition, the commission share schemes have an element of capital indemnified.  During 2018, 37.9% of loans and 
advances fell into this category (2017: 41.7%).   

Estimates of fair value are based on the value of collateral assessed at the time of borrowing, and generally are not updated except 
when  a  loan  is  individually  assessed  as  impaired.  At  the  time  of  granting  credit  within  the  sub-categories  listed  above,  the  loan 
balances due are secured over the underlying assets held as collateral.  

iii. Amounts arising from ECL
iii. Amounts arising from ECL    
iii. Amounts arising from ECL
iii. Amounts arising from ECL
See accounting policy in Note 38(I)(vii) 

IFRS 9 significantly overhauled the requirements and methodology used to assess credit impairments by transitioning to a forward-
looking  approach  based  on  an  expected  credit  loss  model.    The  new  impairment  model  applies  to  financial  assets  measured  at 
amortised cost, contract assets and debt investments at FVOCI, but not to investments in equity instruments.  Under IFRS 9, credit 
losses are recognised earlier than under IAS 39. 

After a detailed review, the Group devised and implemented an impairment methodology in light of the IFRS 9 requirements outlined 
above noting the following: 

  A SICR is always deemed to occur when the borrower is 30 days past due on its contractual payments.  If the Group becomes 
aware ahead of this time of non-compliance or financial difficulties of the borrower, such as loss of employment, avoiding 
contact with the Group then a SICR has also deemed to occur.  

Page | 42  

 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
    
 
 
    
 
 
 
 
    
 
 
    
 
 
 
 
    
 
 
    
 
 
 
 
 
    
 
    
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

8. Financial risk review (continued)    
8. Financial risk review (continued)
8. Financial risk review (continued)
8. Financial risk review (continued)
Risk management (continued)
Risk management (continued)    
Risk management (continued)
Risk management (continued)
A. Credit risk (continued)
A. Credit risk (continued)    
A. Credit risk (continued)
A. Credit risk (continued)
iii. Amounts arising from ECL (continued)    
iii. Amounts arising from ECL (continued)
iii. Amounts arising from ECL (continued)
iii. Amounts arising from ECL (continued)

  A receivable is always deemed to be in default and credit-impaired when the borrower is 90 days past due on its contractual 
payments  or  earlier  if  the  Group  becomes  aware  of  severe  financial  difficulties  such  as  bankruptcy,  IVA,  abscond  or 
disappearance, fraudulent activity and other similar events.  

  The  ECL  was  derived  by  reviewing  the  Group’s  loss  rate  and  loss  given  default  over  the  past  8  years  by  product  and 

geographical segment. 

  The Group has assumed that the future economic conditions will broadly mirror the current environment and therefore the 

forecasted loss levels in the next 3 years will match the Group’s experience in recent years. 

  For  portfolios  where  the  Group  has  never  had  a  default  in  its  history  or  has  robust  credit  enhancements  such  as  credit 

insurance or default indemnities for the entire portfolio, then no IFRS 9 provision is made.   

  If the Group holds objective evidence through specifically assessing a credit-impaired receivable and believes it will go on 
to completely recover the debt due to the collateral held and cooperation with the borrower, then no IFRS 9 provision is 
made. 

iv. Reconciliation of the primary statements from IAS 39 to IFRS 9     
iv. Reconciliation of the primary statements from IAS 39 to IFRS 9 
iv. Reconciliation of the primary statements from IAS 39 to IFRS 9 
iv. Reconciliation of the primary statements from IAS 39 to IFRS 9 

As a result of the change to the Group’s accounting policy in regards to credit-impairments, it has restated the previous periods in 
accordance with IFRS 9.  A reconciliation of the primary statements is as follows: 

Consolidated Income Statement    
Consolidated Income Statement
Consolidated Income Statement
Consolidated Income Statement

31 December 2017 

Profit for the year 
Increase to provision for impairment on loan assets 

Restated profit for the year  

Reduction in basic earnings per share (pence)    
Reduction in diluted earnings per share (pence) 

Consolidated Statement of Other Comprehensive Income    
Consolidated Statement of Other Comprehensive Income
Consolidated Statement of Other Comprehensive Income
Consolidated Statement of Other Comprehensive Income

31 December 2017 

Total comprehensive income for the year attributable to owners 
Increase to provision for impairment on loan assets 

Restated Total comprehensive income for the year attributable to owners  

Reduction in basic earnings per share (pence)    
Reduction in diluted earnings per share (pence) 

Impact of 
adopting IFRS 9 
at 31 December 

£000           

2,508 
(50) 

2,458 

(0.04) 
(0.03) 

Impact of  
adopting IFRS 9  
at 31 December 

£000          

2,445 
(50) 

2,395 

(0.04) 
(0.03) 

Page | 43  

 
 
 
    
  
    
  
 
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
    
 
 
    
 
    
 
 
 
    
 
    
 
 
 
 
    
 
    
 
 
 
    
 
    
 
 
    
    
 
    
 
 
 
    
    
 
    
 
 
 
 
    
 
    
 
 
    
 
    
 
 
    
 
 
    
    
 
    
 
  
 
  
 
 
 
 
 
    
 
 
 
 
 
 
    
 
 
 
    
 
 
    
 
    
 
 
 
    
 
    
 
 
 
 
    
 
    
 
 
 
    
 
    
 
 
    
    
 
    
 
 
 
    
    
 
    
 
 
 
 
    
 
    
 
 
    
 
    
 
 
    
 
 
    
    
 
    
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

8. Financial risk review (continued)    
8. Financial risk review (continued)
8. Financial risk review (continued)
8. Financial risk review (continued)
Risk management (continued)
Risk management (continued)    
Risk management (continued)
Risk management (continued)
A. Credit risk (continued)
A. Credit risk (continued)    
A. Credit risk (continued)
A. Credit risk (continued)
iv. Reconciliation of the primary statements from IAS 39 to IFRS 9 (continued)    
iv. Reconciliation of the primary statements from IAS 39 to IFRS 9 (continued)
iv. Reconciliation of the primary statements from IAS 39 to IFRS 9 (continued)
iv. Reconciliation of the primary statements from IAS 39 to IFRS 9 (continued)

Statement of Financial Position    
Consolidated Statement of Financial Position
Consolidated 
Statement of Financial Position
Statement of Financial Position
Consolidated 
Consolidated 

Assets 
Loans and advances to customers 
Increase to provision for impairment on loan assets 

Restated loans and advances to customers  

Equity 
Profit and loss account 
Increase to provision for impairment on loan assets 

Restated profit and loss account 

Consolidated Statement of Cash Flows    
Consolidated Statement of Cash Flows
Consolidated Statement of Cash Flows
Consolidated Statement of Cash Flows

Impact of 
adopting IFRS 9 
at 31 December 
2017 
£000 

Impact of 
adopting IFRS 9 
at 31 December 
2016 
£000 

122,720 
(174) 

122,546 

(3,296) 
(174) 

(3,470) 

116,053 
(124) 

115,929 

(5,763) 
(124) 

(5,887) 

Total cash flows from operating, investing and financing activities remains unchanged due to the increase in impairments on loan 
assets being a non-cash item. 

Consolidated Statement of Changes in Equity    
Consolidated Statement of Changes in Equity
Consolidated Statement of Changes in Equity
Consolidated Statement of Changes in Equity

For an analysis of the retrospective impact of IFRS 9, see the Consolidated Statement of Changes in Equity which analyses in each 
year the effect of adopting IFRS 9 for that year. 

v. Concentration of credit risk    
v. Concentration of credit risk
v. Concentration of credit risk
v. Concentration of credit risk
Geographical 
Lending is restricted to individuals and entities with Isle of Man, UK or Channel Islands addresses.  

Segmental 
The Bank is exposed to credit risk with regard to customer loan accounts, comprising HP and finance lease balances, unsecured 
personal loans, secured commercial loans, block discounting, vehicle stocking plan loans and wholesale funding agreements.  In 
addition, the Bank lends via significant introducers into the UK.  There was one introducer that accounted for more than 20% of the 
Bank’s total lending portfolio at the end of 31 December 2018 (2017: one introducer). 

B. Liquidity risk
B. Liquidity risk    
B. Liquidity risk
B. Liquidity risk
For the definition of liquidity risk and information on how liquidity risk is manged by the Group see Note 36. 

i. Exposure to liquidity risk    
i. Exposure to liquidity risk
i. Exposure to liquidity risk
i. Exposure to liquidity risk
The key measure used by the Group for managing liquidity risk is the ratio of net liquid assets to deposits from customers and short-
term funding. For this purpose, ‘net liquid assets’ includes cash and cash equivalents and investment-grade debt securities for which 
there is an active and liquid market. 

Details of the reported Group ratio of net liquid assets to deposits from customers at the reporting date and during the reporting period 
were as follows: 

At 31 December  
Average for the period 
Maximum for the period 
Minimum for the period 

2018
2018    
20182018
25%25%25%25%    
32%32%32%32%    
40%40%40%40%    
25%25%25%25%    

2017 
27% 
26% 
30% 
23% 

Page | 44  

 
 
 
    
    
    
    
  
    
  
 
 
 
 
 
    
 
 
 
 
    
 
 
 
 
    
 
 
    
 
    
 
 
 
    
 
    
 
 
 
 
 
    
 
    
 
 
 
 
    
 
    
 
 
    
    
 
    
 
 
 
 
    
    
 
    
 
 
 
 
 
    
 
 
 
 
    
 
 
    
 
    
 
 
 
    
 
    
 
 
 
 
 
    
 
    
 
 
 
 
    
 
    
 
 
    
    
 
    
 
 
 
 
    
 
 
    
 
 
 
    
    
    
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

8. Financial risk review (continued)    
8. Financial risk review (continued)
8. Financial risk review (continued)
8. Financial risk review (continued)
Risk management (continued)
Risk management (continued)    
Risk management (continued)
Risk management (continued)
B. Liquidity risk (continued)    
B. Liquidity risk (continued)
B. Liquidity risk (continued)
B. Liquidity risk (continued)

financial assets    
ii. Maturity analysis for financial liabilities and financial assets
ii. Maturity analysis for financial liabilities and 
financial assets
financial assets
ii. Maturity analysis for financial liabilities and 
ii. Maturity analysis for financial liabilities and 

The table below shows the Group’s financial liabilities classified by their earliest possible contractual maturity, on an undiscounted 
basis including interest due at the end of the deposit term. Based on historical data, the Group’s expected actual cash flow from these 
items vary from this analysis due to the expected re-investment of maturing customer deposits.  

Residual contractual maturities of financial liabilities as at the reporting date (undiscounted)    
Residual contractual maturities of financial liabilities as at the reporting date (undiscounted)
Residual contractual maturities of financial liabilities as at the reporting date (undiscounted)
Residual contractual maturities of financial liabilities as at the reporting date (undiscounted)

31 December 2018    
31 December 2018
31 December 2018
31 December 2018

££££000000000000     

Sight
Sight----
SightSight
8 days
8 days
8 days
8 days

>8 days
>8 days    
>8 days
>8 days
----    1 month
1 month    
1 month
1 month
££££000000000000    

>1 month 
>1 month     
>1 month 
>1 month 
----    3 months
3 months    
3 months
3 months
££££000000000000    

>3 months
>3 months    
>3 months
>3 months
----    6 months
6 months    
6 months
6 months
££££000000000000    

>6 months
>6 months    
>6 months
>6 months
----    1 year
1 year    
1 year
1 year
££££000000000000    

>1 year
>1 year
>1 year
>1 year
----    3 years
3 years
3 years
3 years
££££000000000000

>3 years
>3 years    
>3 years
>3 years
----    5 years
5 years    
5 years
5 years
££££000000000000    

>5 years
>5 years    
>5 years
>5 years
££££000000000000    

Total
Total    
Total
Total
££££000000000000    

Deposits from 
customers 
Other liabilities 

Total liabilities    
Total liabilities
Total liabilities
Total liabilities

31 December 2017 

Deposits from 
customers 
Other liabilities 

Total liabilities 

1,754
1,754    
1,754
1,754
2,061    
2,061
2,061
2,061

3,815    
3,815
3,815
3,815

5,012
5,012    
5,012
5,012
200200200200    

5,212    
5,212
5,212
5,212

14,397
14,397    
14,397
14,397
230230230230    

14,627    
14,627
14,627
14,627

34,028
34,028    
34,028
34,028
216216216216    

34,244    
34,244
34,244
34,244

35,032
35,032    
35,032
35,032
928928928928    

35,960    
35,960
35,960
35,960

56,643
56,643    
56,643
56,643
8,705    
8,705
8,705
8,705

65,348    
65,348
65,348
65,348

11,634
11,634    
11,634
11,634
8,063    
8,063
8,063
8,063

19,697    
19,697
19,697
19,697

----    
584584584584    

584584584584    

158,500
158,500    
158,500
158,500
20,987    
20,987
20,987
20,987

179,487    
179,487
179,487
179,487

Sight- 
8 days 
£000 

>8 days 
- 1 month 
£000 

>1 month  
- 3 months 
£000 

>3 months 
- 6 months 
£000 

>6 months 
- 1 year 
£000 

>1 year 
- 3 years 
£000 

>3 years 
- 5 years 
£000 

>5 years 
£000 

Total 
£000 

2,579
3,094

5,673

3,136
89

3,225

12,710 
318 

13,028 

24,241 
1,540 

25,781 

30,207 
1,754 

31,961 

60,820 
3,326 

12,567
3,322

64,146 

15,889 

- 
560 

560 

146,260 
14,003 

160,263 

Maturity of assets and liabilities at the reporting date    
Maturity of assets and liabilities at the reporting date
Maturity of assets and liabilities at the reporting date
Maturity of assets and liabilities at the reporting date

Sight
Sight----    
SightSight
8 days
8 days    
8 days
8 days
££££000000000000    

>8 days
>8 days    
>8 days
>8 days
----    1 month
1 month    
1 month
1 month
££££000000000000    

>1 month 
>1 month 
>1 month 
>1 month 
----    3 months
3 months    
3 months
3 months
££££000000000000    

>3 months 
>3 months 
>3 months 
>3 months 
----    6 months
6 months    
6 months
6 months
££££000000000000    

>6 months
>6 months
>6 months
>6 months
----    1 year
1 year    
1 year
1 year
££££000000000000    

>1 year
>1 year    
>1 year
>1 year
----    3 years
3 years    
3 years
3 years
££££000000000000    

>3 >3 >3 >3 years
years    
years
years
----    5 years
5 years    
5 years
5 years
££££000000000000    

>5 years
>5 years    
>5 years
>5 years
££££000000000000    

Total
Total    
Total
Total
££££000000000000    

31 December 2018    
31 December 2018
31 December 2018
31 December 2018

Assets
Assets    
Assets
Assets
Cash & cash 
equivalents 
Debt securities 
Loans and advances to 
customers 
Other assets 

9,753
9,753    
9,753
9,753
----    

5,273
5,273    
5,273
5,273
20202020    

----    
17,995    
17,995
17,995
17,995

1,047
1,047    
1,047
1,047
225225225225    

----    
5,989    
5,989
5,989
5,989

9,724
9,724    
9,724
9,724
145145145145    

----    
----    

15,977
15,977    
15,977
15,977
----    

15,977    
15,977
15,977
15,977

----    
----    

35,246
35,246    
35,246
35,246
----    

35,246    
35,246
35,246
35,246

----    
----    

64,099
64,099    
64,099
64,099
----    

64,099    
64,099
64,099
64,099

----    
6,550    
6,550
6,550
6,550

16,16,16,16,910910910910    
----    

23,423,423,423,460606060    

----    
----    

2222    
7,959    
7,959
7,959
7,959

7,961    
7,961
7,961
7,961

9,753
9,753    
9,753
9,753
30,534    
30,534
30,534
30,534

148,278787878    
148,2
148,2
148,2
8,349    
8,349
8,349
8,349

196,914914914914    
196,
196,196,

Total assets    
Total assets
Total assets
Total assets

15,046    
15,046
15,046
15,046

19,267    
19,267
19,267
19,267

15,858    
15,858
15,858
15,858

Liabilities    
Liabilities
Liabilities
Liabilities
Deposits from 
customers 
Other liabilities 

Total liabilities    
Total liabilities
Total liabilities
Total liabilities

1,754
1,754    
1,754
1,754
2,098    
2,098
2,098
2,098

3,852    
3,852
3,852
3,852

5,012
5,012    
5,012
5,012
146146146146    

5,158    
5,158
5,158
5,158

14,397
14,397    
14,397
14,397
92929292    

14,489    
14,489
14,489
14,489

34,028
34,028    
34,028
34,028
----    

34,028    
34,028
34,028
34,028

35,032
35,032    
35,032
35,032
500500500500    

35,532    
35,532
35,532
35,532

56,643
56,643    
56,643
56,643
7,690    
7,690
7,690
7,690

11,634
11,634    
11,634
11,634
7,581    
7,581
7,581
7,581

64,333    
64,333
64,333
64,333

19,215    
19,215
19,215
19,215

----    
584584584584    

583583583583    

158,500
158,500    
158,500
158,500
18,18,18,18,691691691691    

177,191191191191    
177,
177,177,

Page | 45  

 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

8. Financial risk review (continued)    
8. Financial risk review (continued)
8. Financial risk review (continued)
8. Financial risk review (continued)
Risk management (continued)
Risk management (continued)    
Risk management (continued)
Risk management (continued)
B. Liquidity risk (continued)
B. Liquidity risk (continued)    
B. Liquidity risk (continued)
B. Liquidity risk (continued)
ii. Maturity analysis for financial liabilities and financial assets (continued)
ii. Maturity analysis for financial liabilities and financial assets (continued)    
ii. Maturity analysis for financial liabilities and financial assets (continued)
ii. Maturity analysis for financial liabilities and financial assets (continued)
ilities at the reporting date (continued)    
Maturity of assets and liabilities at the reporting date (continued)
Maturity of assets and liab
ilities at the reporting date (continued)
ilities at the reporting date (continued)
Maturity of assets and liab
Maturity of assets and liab

31 December 2017 

Assets 
Cash & cash 
equivalents 
Debt securities 
Loans and advances to 
customers 
Other assets 
Total assets 

Liabilities 
Deposits from 
customers 
Other liabilities 
Total liabilities 

Sight- 
8 days 
£000 

>8 days 
- 1 month 
£000 

>1 month 
- 3 months 
£000 

>3 months-
6 months
£000 

>6 months
- 1 year 
£000 

>1 year
- 3 years

£000  

>3 years 
- 5 years 
£000 

>5 years 
£000 

Total 
£000 

9,745 
- 

3,708 
103 

- 
1,998 

3,649 
194 

- 
16,983 

7,945 
192 

- 
8,524 

10,808 
- 

- 
- 

-
-

- 
6,767 

- 
- 

9,745 
34,272 

25,849 
- 

54,872  

-

15,695 
- 

21 
5,994 

122,546 
6,483 

13,556 

5,841 

25,120 

19,332 

25,849 

54,872  

22,462 

6,015 

173,046 

2,570 
3,086 
5,656 

3,105 
55 
3,160 

12,654 
234 
12,888 

24,112 
169 
24,281 

29,716 
3,333 
33,049 

57,711  
2,945  
60,656  

12,404 
3,130 
15,534 

- 
560 
560 

142,272 
13,512 
155,784 

iii. Liquidity reserves
iii. Liquidity reserves    
iii. Liquidity reserves
iii. Liquidity reserves
The following table sets out the components of the Group’s liquidity reserves. 

Balances with other banks 
Unencumbered debt securities issued by sovereigns 

Total liquidity reserves 

2018
2018    
20182018
Carrying 
Carrying 
Carrying 
Carrying 
amount
amount    
amount
amount
£000    
£000
£000£000

9,753
9,753    
9,753
9,753
30,534    
30,534
30,534
30,534

40,287    
40,287
40,287
40,287

2018 
2018     
2018 
2018 
Fair Fair Fair Fair     
value
value    
value
value
£000    
£000
£000£000

9,753
9,753    
9,753
9,753
30,534    
30,534
30,534
30,534

40,287    
40,287
40,287
40,287

2017 
Carrying 
amount 
£000 

9,745 
34,272 

44,017 

2017  

Fair value 
£000 

9,745 
34,272 

44,017 

C. Market risk
C. Market risk    
C. Market risk
C. Market risk
For the definition of market risk and information on how the Group manages the market risks of trading and non-trading portfolios, 
see Note 36.  

The following table sets out the allocation of assets and liabilities subject to market risk between trading and non-trading portfolios. 

31 December 2018    
31 December 2018
31 December 2018
31 December 2018

Assets subject to market risk 
Assets subject to market risk
Assets subject to market risk
Assets subject to market risk
Trading assets 
Debt securities 
Total    
Total
Total
Total

31 December 2017 

Assets subject to market risk
Assets subject to market risk 
Assets subject to market risk
Assets subject to market risk
Trading assets 
Debt securities 
Total 

Carrying 
Carrying 
Carrying 
Carrying 
amount
amount    
amount
amount
£000    
£000
£000£000

20202020    
30,534
30,534    
30,534
30,534
30,554    
30,554
30,554
30,554

Carrying 
amount 
£000 

24 
34,272 
34,296 

Market risk measure    
Market risk measure
Market risk measure
Market risk measure
Trading 
Trading 
Trading 
Trading 
portfolios
portfolios    
portfolios
portfolios
£000    
£000
£000£000

NonNonNonNon----trading 
trading 
trading 
trading 
portfolios
portfolios    
portfolios
portfolios
£000    
£000
£000£000

20202020    
----    
20202020    

----    
30,534
30,534    
30,534
30,534
30,534    
30,534
30,534
30,534

Market risk measure 

Trading 
portfolios 
£000 

Non-trading 
portfolios 
£000 

24 
- 
24 

- 
34,272 
34,272 

Page | 46  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

8. Financial risk review (continued)    
8. Financial risk review (continued)
8. Financial risk review (continued)
8. Financial risk review (continued)
Risk management (continued)
Risk management (continued)    
Risk management (continued)
Risk management (continued)
C. Market risk (continued)
C. Market risk (continued) 
C. Market risk (continued)
C. Market risk (continued)
trading portfolio    
i. Exposure to interest rate risk ––––    NonNonNonNon----trading portfolio
i. Exposure to interest rate risk 
trading portfolio
trading portfolio
i. Exposure to interest rate risk 
i. Exposure to interest rate risk 

The following tables present the interest rate mismatch position between assets and liabilities over the respective maturity dates. The 
maturity dates are presented on a worst-case basis, with assets being recorded at their latest maturity and deposits from customers 
at their earliest. 

31 December 2018    
31 December 2018
31 December 2018
31 December 2018

Sight----    
     Sight
SightSight
     1 month
1 month    
1 month
1 month
££££000000000000    

>1month    
>1month
>1month
>1month
----    3months
3months    
3months
3months
££££000000000000    

>3months    
>3months
>3months
>3months
----    6months
6months    
6months
6months
        ££££000000000000    

>6months
    >6months
>6months
>6months
----    1 year
1 year    
1 year
1 year
     ££££000000000000    

>1 year     
     >1 year 
>1 year 
>1 year 
----    3 years
3 years    
3 years
3 years
      ££££000000000000    

>3 years    
    >3 years
>3 years
>3 years
----    5 years
5 years    
5 years
5 years
      ££££000000000000    

    >5 years
>5 years    
>5 years
>5 years
      ££££000000000000    

Int. 
     NonNonNonNon----Int. 
Int. 
Int. 
     Bearing
Bearing    
Bearing
Bearing
     ££££000000000000    

Total
Total    
Total
Total
££££000000000000    

Assets
Assets    
Assets
Assets
Cash & cash equivalents 
Debt securities 
Loans and advances to customers 
Other assets 

9,753    
9,753
9,753
9,753
17,995
17,995    
17,995
17,995
6,319
6,319    
6,319
6,319
245245245245    

----    
5,989
5,989    
5,989
5,989
9,724
9,724    
9,724
9,724
145145145145    

----    
----    
     15,977
15,977    
15,977
15,977
----    

----    
----    
     35,247
35,247    
35,247
35,247
----    

----    
----    
     64,099
64,099    
64,099
64,099
----    

----    
6,550    
6,550
6,550
6,550
     16,16,16,16,910910910910    
----    

Total assets    
Total assets
Total assets
Total assets

34,312    
34,312
34,312
34,312

15,858    
     15,858
15,858
15,858

15,977    
     15,977
15,977
15,977

35,247    
     35,247
35,247
35,247

64,099    
     64,099
64,099
64,099

     23,423,423,423,460606060    

Liabilities and equity    
Liabilities and equity
Liabilities and equity
Liabilities and equity
Deposits from customers 
Other liabilities 
Total equity 

Total liabilities and equity    
Total liabilities and equity
Total liabilities and equity
Total liabilities and equity

Interest rate sensitivity gap 

Cumulative    
Cumulative
Cumulative
Cumulative

6,766
6,766    
6,766
6,766
2,22,22,22,244444444    
----    

9,09,09,09,010101010    

25,25,25,25,302302302302    

25,25,25,25,302302302302    

14,397
14,397    
14,397
14,397
92929292    
----    

14,489    
14,489
14,489
14,489

1,369    
1,369
1,369
1,369

26,626,626,626,671717171    

     34,028
34,028    
34,028
34,028
----    
----    

34,028    
     34,028
34,028
34,028
(18,051
(18,051
(18,051
(18,051
))))    

     35,032
35,032    
35,032
35,032
500500500500    
----    

     56,643
56,643    
56,643
56,643
7,690
7,690    
7,690
7,690
----    

     11,634
11,634    
11,634
11,634
7,581
7,581    
7,581
7,581
----    

35,532    
     35,532
35,532
35,532

64,333    
     64,333
64,333
64,333

19,215    
     19,215
19,215
19,215

----    
----    
2222    
----    

2222    

----    
584584584584    
----    

584584584584    

----    
----    
----    
7,959    
7,959
7,959
7,959

9,753    
9,753
9,753
9,753
30,534
30,534    
30,534
30,534
148,278787878    
148,2
148,2
148,2
8,349    
8,349
8,349
8,349

7,959    
7,959
7,959
7,959

196,914914914914    
     196,
196,196,

----    
----    
19,19,19,19,723723723723    

19,656    
19,656
19,656
19,656

158,500
158,500    
158,500
158,500
18,691
18,691    
18,691
18,691
19,19,19,19,723723723723    

196,914914914914    
196,
196,196,

(285)    
(285)
(285)
(285)

(234)    
(234)
(234)
(234)

4,24,24,24,245454545    

(582)    
(582)
(582)
(582)

(11,764764764764))))    
(11,
(11,
(11,

8,8,8,8,620620620620    

8,8,8,8,335335335335    

8,8,8,8,101101101101    

     12,12,12,12,346346346346    

     11,711,711,711,764646464    

----    

  Sight- 
  1 month 
£000 

>1month 
-3months 
       £000 

>3months 
- 6months 
        £000 

 >6months 
  - 1 year 
  £000 

  >1 year  
- 3 years 
£000 

 >3 years 
 - 5 years 
£000 

 >5 years 
£000 

  Non-Int. 
  Bearing 
  £000 

----    

----    

Total 
£000 

31 December 2017 

Assets 
Cash & cash equivalents 
Debt securities 
Loans and advances to customers 
Other assets 
Total assets 

Liabilities and equity 
Deposits from customers 
Other liabilities 
Total equity 
Total liabilities and equity 

Interest rate sensitivity gap 

Cumulative 

5,675 
3,141 
- 
8,816 

10,580 

10,580 

9,745 
1,998 
7,356 
297 

- 
 16,983 
7,945 
      192 

- 
8,524 
  10,808 
- 

- 
- 
  25,849 
- 

- 
- 
  54,872 
- 

- 
6,766 
  15,695 
- 

19,396 

25,120 

19,332 

25,849 

54,872 

22,461 

12,654 
234 
- 
12,888 

  24,112 
169 
- 
24,281 

  29,716 
3,333 
- 
33,049 

  57,711 
2,945 
- 
60,656 

  12,404 
3,130 
- 
15,534 

- 
- 
22 
- 

22 

- 
560 
- 
560 

- 
- 
- 
5,994 

9,745 
34,427 
122,547 
6,483 

5,994 

173,046 

- 
- 
17,262 
17,262 

142,272 
13,512 
17,262 
173,046 

12,232 

(4,949) 

(7,200) 

(5,784) 

6,927 

(538) 

(11,268) 

22,812 

  17,863 

  10,663 

4,879 

  11,806 

  11,268 

- 

- 

- 

The Bank monitors the impact of changes in interest rates on interest rate mismatch positions using a method consistent with the 
FSA required reporting standard. The methodology applies weightings to the net interest rate sensitivity gap in order to quantify the 
impact of an adverse change in interest rates of 2.0% per annum (2017: 2.0%). The following tables set out the estimated total impact 
of such a change based on the mismatch at the reporting date: - 

31 December 2018181818 
31 December 20
31 December 20
31 December 20

Interest rate sensitivity gap 

Weighting 

£000 

Sight
Sight----    
SightSight
     1 month
1 month    
1 month
1 month
     ££££000000000000 

>1month
>1month    
>1month
>1month
----3months
3months    
3months
3months
££££000000000000 

>3months
>3months    
>3months
>3months
----    6months
6months    
6months
6months
     ££££000000000000 

>6months
>6months    
>6months
>6months
     ----    1 year
1 year    
1 year
1 year
     ££££000000000000 

>1 year 
>1 year     
>1 year 
>1 year 
----    3 years
3 years    
3 years
3 years
     ££££000000000000 

>3 years
>3 years    
>3 years
>3 years
     ----    5 years
5 years    
5 years
5 years
££££000000000000 

>5 years
>5 years    
>5 years
>5 years
     ££££000000000000 

NonNonNonNon----Int. 
Int. 
Int. 
Int. 
     Bearing
Bearing    
Bearing
Bearing
     ££££000000000000 

25,25,25,25,302302302302    

0.000    
0.000
0.000
0.000

----    

1,369    
1,369
1,369
1,369

(18,051)    
     (18,051)
(18,051)
(18,051)

0.003    
0.003
0.003
0.003

4444    

0.007    
0.007
0.007
0.007

(126)    
(126)
(126)
(126)

(285)    
(285)
(285)
(285)

0.014    
0.014
0.014
0.014

(4)(4)(4)(4)    

(234)    
(234)
(234)
(234)

0.027    
0.027
0.027
0.027

(6)(6)(6)(6)    

4,24,24,24,245454545    

0.054    
0.054
0.054
0.054

222222229999    

(582)    
(582)
(582)
(582)

(11,764764764764))))    
(11,
(11,
(11,

0.115    
0.115
0.115
0.115

(67)    
(67)
(67)
(67)

0.000    
0.000
0.000
0.000

----    

Total
Total    
Total
Total
££££000000000000 

----    

----    

30303030    

Page | 47  

 
 
 
 
 
    
    
    
    
    
        
        
        
    
    
          
      
      
    
          
      
      
    
          
      
      
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

8. Financial risk review (continued)    
8. Financial risk review (continued)
8. Financial risk review (continued)
8. Financial risk review (continued)
Risk management (continued)
Risk management (continued)    
Risk management (continued)
Risk management (continued)
C. Market risk (continued)
C. Market risk (continued) 
C. Market risk (continued)
C. Market risk (continued)
trading portfolio (continued)    
i. Exposure to interest rate risk ––––    NonNonNonNon----trading portfolio (continued)
i. Exposure to interest rate risk 
trading portfolio (continued)
trading portfolio (continued)
i. Exposure to interest rate risk 
i. Exposure to interest rate risk 

31 December 2017 

Sight- 
  1 month 
  £000 

>1month 
-3months 
£000 

>3months 
-6months 
  £000 

>6months 
  - 1 year 
  £000 

>1 year 
- 3 years 
£000 

>3 years 
 - 5 years 
  £000 

>5 years 
  £000 

Non-Int. 
  Bearing 
 £000 

Interest rate sensitivity gap 

10,580 

Weighting 

£000 

0.000 

- 

12,232 

0.003 

37 

(4,949) 

(7,200)

(5,784) 

0.007 

(35) 

0.014 

(101) 

0.027 

(156) 

6,927 

0.054 

374 

(538) 

(11,268) 

0.115 

(62) 

0.000 

- 

Total 
£000 

- 

- 

57 

D. Capital Management 
D. Capital Management
D. Capital Management
D. Capital Management
i. Regulatory capital
i. Regulatory capital    
i. Regulatory capital
i. Regulatory capital
The lead regulatory of the Group’s wholly owned subsidiary, Conister Bank Limited (‘Bank’), is the Isle of Man Financial Services 
Authority (‘FSA’). The FSA sets and monitors capital requirements for the Bank. 

The Bank’s regulatory capital consists of the following elements. 

  Common Equity Tier 1 (CET1) capital, which includes ordinary share capital, retained earnings and reserves after adjustment 

for deductions for goodwill, intangible assets, intercompany receivable. 

  Tier 2 capital, which includes qualifying subordinated liabilities and any excess of impairment over expected losses. 

The lead FSA’s approach to the measurement of capital adequacy is primarily based on monitoring the relationship of the capital 
resources requirement to available capital resources. The FSA sets individual capital guidance (ICG) for the Bank in excess of the 
minimum capital resources requirement. A key input to the ICG setting process is the Bank’s internal capital adequacy assessment 
process (ICAAP). 

The Bank is also regulated by the Financial Conduct Authority in the United Kingdom for credit and brokerage related activities. 

ii. Capital allocation    
ii. Capital allocation
ii. Capital allocation
ii. Capital allocation

Management  uses  regulatory  capital  ratios  to  monitor  its  capital  base.  The  allocation  of  capital  between  specific  operations  and 
activities is, to a large extent, driven by optimisation of the return achieved on the capital allocated. The amount of capital allocated 
to each operation or activity is based primarily on regulatory capital requirements. 

9. Operating segments    
9. Operating segments
9. Operating segments
9. Operating segments

Segmental information is presented in respect of the Group’s business segments. The Directors consider that the Group currently 
operates in one geographic segment comprising of the Isle of Man, UK and Channel Islands. The primary format, business segments, 
is based on the Group’s management and internal reporting structure. The Directors consider that the Group operates in five (2017: 
five)  product  orientated  segments  in  addition  to  its  investing  activities:  Asset  and  Personal  Finance  (including  provision  of  HP 
contracts,  finance  leases,  personal  loans,  commercial  loans,  block  discounting,  vehicle  stocking  plans  and  wholesale  funding 
agreements); Manx Incahoot; Conister Card Services; Edgewater Associates; and Manx FX.  

For the year ended 31 
For the year ended 31 
For the year ended 31 
For the year ended 31 
December 2018    
December 2018
December 2018
December 2018

Net interest income 
Operating income /(loss) 

Profit / (loss) before tax 
Profit / (loss) before tax 
Profit / (loss) before tax 
Profit / (loss) before tax 
payable    
payable
payable
payable

Capital expenditure 

Total assets    
Total assets
Total assets
Total assets

Asset and
Asset and    
Asset and
Asset and
Personal    
Personal
Personal
Personal
Finance
Finance    
Finance
Finance
££££000000000000    

15,568 
9,306 

2,22,22,22,267676767    

1,589 

190,923232323    
190,9
190,9
190,9

Manx Manx Manx Manx 
Incahoot
Incahoot    
Incahoot
Incahoot
££££000000000000    

Conister
Conister    
Conister
Conister
CardCardCardCard    
Services
Services    
Services
Services
££££000000000000    

Edgewater 
Edgewater 
Edgewater 
Edgewater 
Associates
Associates    
Associates
Associates
££££000000000000    

Manx FX
Manx FX    
Manx FX
Manx FX
££££000000000000    

Investing    
Investing
Investing
Investing
Activities
Activities    
Activities
Activities
££££000000000000    

- 
12 

(189)    
(189)
(189)
(189)

1 

78787878    

- 
- 

(3)(3)(3)(3)    

- 

----    

- 
2,562 

245245245245    

150 

3,153    
3,153
3,153
3,153

- 
493 

490490490490    

6 

608608608608    

Total
Total    
Total
Total
£000    
£000
£000£000

15,568 
13,166 

- 
- 

(100)    
(100)
(100)
(100)

2,2,2,2,710710710710    

1 

1,747 

2,152    
2,152
2,152
2,152

196,914914914914    
196,
196,196,

Page | 48  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
 
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

9. Operating segments (continued)    
9. Operating segments (continued)
9. Operating segments (continued)
9. Operating segments (continued)

For the year ended 31 
December 2017 

Asset and 
Personal 
Finance 
£000 

Manx 
Incahoot 
£000 

Conister 
Card 
Services 
£000 

Edgewater 
Associates 
£000 

Net interest income 
Operating income /(loss) 

Profit / (loss) before tax 
payable 

Capital expenditure 

Total assets 

10. Net interest income    
10. Net interest income
10. Net interest income
10. Net interest income

16,637 
8,298 

1,910 

254 

168,052 

- 
44 

(293) 

1 

307 

- 
(104) 

(104) 

- 

18 

- 
2,625 

742 

319 

2,252 

Interest income
Interest income    
Interest income
Interest income
Loans and advances to customers 
Total interest income calculated using the 
effective interest method    
Total interest income calculated using the effective interest method
effective interest method
effective interest method
Total interest income calculated using the 
Total interest income calculated using the 
Other interest income  
Total interest income    
Total interest income
Total interest income
Total interest income

Interest expense    
Interest expense
Interest expense
Interest expense
Deposits from customers 
Subordinated liabilities 
Block funders 
interest expense    
Total interest expense
Total 
interest expense
interest expense
Total 
Total 

Net interest income    
Net interest income
Net interest income
Net interest income

11. Net fee and commission income    
11. Net fee and commission income
11. Net fee and commission income
11. Net fee and commission income

Manx 
FX 
£000 

- 
447 

249 

- 

181 

Investin
g 
Activitie
s 
£000 

Total 
£000 

- 
- 

16,637 
11,310 

(186) 

2,318 

- 

574 

2,236 

173,046 

2018
2018    
20182018
£000    
£000
£000£000

2017 
£000 

19,037    
19,037
19,037
19,037
19,037
19,037    
19,037
19,037
78787878    
19,115    
19,115
19,115
19,115

(2,744)
(2,744)    
(2,744)
(2,744)
(773)
(773)    
(773)
(773)
(30)
(30)    
(30)
(30)
(3,547)    
(3,547)
(3,547)
(3,547)

19,839 
19,839 
54 
19,893 

(2,690) 
(495) 
(71) 
(3,256) 

15,568    
15,568
15,568
15,568

16,637 

A. Disaggregation of fee and commission income    
A. Disaggregation of fee and commission income
A. Disaggregation of fee and commission income
A. Disaggregation of fee and commission income
In the following table, fee and commission income from contracts with customers in the scope of IFRS 15 is disaggregated by major 
type of services. The table includes a reconciliation of the disaggregated fee and commission income with the Group’s reportable 
segments. 

Major service lines
Major service lines    
Major service lines
Major service lines
Independent financial advice income 
FX trading income 
Fee and commission income    
Fee and commission income
Fee and commission income
Fee and commission income

Fee and commission expense 

Net fee and commission expense    
Net fee and commission expense
Net fee and commission expense
Net fee and commission expense

2018    
2018
20182018
£000    
£000
£000£000

2,547
2,547    
2,547
2,547
824824824824    
3,371    
3,371
3,371
3,371

2017 
£000 

2,625 
490 
3,115 

(6,109)    
(6,109)
(6,109)
(6,109)

(8,413) 

(2,738)    
(2,738)
(2,738)
(2,738)

(5,298) 

Page | 49  

 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
    
 
 
    
 
    
 
 
    
 
 
    
 
 
    
    
 
 
    
 
    
    
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

12. Terminal funding    
12. Terminal funding
12. Terminal funding
12. Terminal funding

In September 2014, the Bank discontinued funding handheld payment devices (referred to as Terminal Funding) due to the volume 
of write offs.  Ever since, the book is being run off whilst the Bank vigorously pursues historical write off.  A decision was made by the 
Board during 2016 to cease funding and run-off the book upon the final repayment date of August 2019. 

Interest income 
Fee and commission expense 
Provision for impairment on loan assets 

13. Personnel expenses    
13. Personnel expenses
13. Personnel expenses
13. Personnel expenses

Gross salaries  
Executive Directors’ remuneration 
Non-executive Directors’ fees 
Executive Directors’ pensions 
Executive Directors’ performance related pay 
Pension costs 
National insurance and payroll taxes 
Training and recruitment costs 

expenses    
14. Other expenses
14. Other 
expenses
expenses
14. Other 
14. Other 

Professional and legal fees 
Marketing costs 
IT costs 
Establishment costs 
Communication costs 
Travel costs 
Bank charges 
Insurance 
Irrecoverable VAT 
Other costs 

15. Impairment on loans and advances to customers    
15. Impairment on loans and advances to customers
15. Impairment on loans and advances to customers
15. Impairment on loans and advances to customers

The charge in respect of specific allowances for impairment comprises: - 

Specific impairment allowances made 
Reversal of allowances previously made 

Total charge for specific provision for impairment    
Total charge for specific provision for impairment
Total charge for specific provision for impairment
Total charge for specific provision for impairment

2018
2018    
20182018
££££000000000000    

181181181181    
(5)(5)(5)(5)    
(102)    
(102)
(102)
(102)

74747474    

2018
2018    
20182018
££££000000000000    

(4,233)
(4,233)    
(4,233)
(4,233)
(241)    
(241)
(241)
(241)
(145)
(145)    
(145)
(145)
(19)
(19)    
(19)
(19)
(50)
(50)    
(50)
(50)
(259)
(259)    
(259)
(259)
(527)    
(527)
(527)
(527)
(229)    
(229)
(229)
(229)

(5,703)    
(5,703)
(5,703)
(5,703)

2018
2018    
20182018
££££000000000000    

(1,(1,(1,(1,067067067067))))    
(237
(237))))    
(237(237
(567)
(567)    
(567)
(567)
(434)
(434)    
(434)
(434)
(146
(146))))    
(146(146
(174)    
(174)
(174)
(174)
(119)
(119)    
(119)
(119)
(141)
(141)    
(141)
(141)
(303)
(303)    
(303)
(303)
(277)    
(277)
(277)
(277)

(3,465))))    
(3,465
(3,465
(3,465

2018
2018    
20182018
££££000000000000    

(1,2(1,2(1,2(1,246464646))))    
410410410410    

(8(8(8(836363636))))    

2017 
£000 

377 
(92) 
(195) 

90 

2017 
£000 

(3,479) 
(214) 
(185) 
(21) 
(36) 
(226) 
(432) 
(190) 

(4,783) 

2017 
£000 

(848) 
(211) 
(528) 
(376) 
(137) 
(149) 
(142) 
(133) 
(180) 
(448) 

(3,152) 

2017 
£000 

(1,295) 
776 

(519) 

Page | 50  

 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
15. Impairment on loans and advances to customers    (continued)
15. Impairment on loans and advances to customers
(continued)
(continued)
15. Impairment on loans and advances to customers
15. Impairment on loans and advances to customers

The charge in respect of collective allowances for impairment comprises: - 

Collective impairment allowances made 
Release of allowances previously made 

Total charge for collective allowances for impairment    
Total charge for collective allowances for impairment
Total charge for collective allowances for impairment
Total charge for collective allowances for impairment

Total charge for allowances for impairment    
Total charge for allowances for impairment
Total charge for allowances for impairment
Total charge for allowances for impairment

16. Profit before tax payable    
16. Profit before tax payable
16. Profit before tax payable
16. Profit before tax payable

The profit before tax payable for the year is stated after charging: - 

2018
2018    
20182018
££££000000000000    

(49)
(49)    
(49)
(49)
28282828    

(21)    
(21)
(21)
(21)

(8(8(8(857575757))))    

Share options expense 
Auditor’s remuneration: -  

as Auditor current year 
 non-audit services 

Pension cost defined benefit scheme 
Operating lease rentals for property 

17. Income tax expense    
17. Income tax expense
17. Income tax expense
17. Income tax expense

Current tax expense
Current tax expense    
Current tax expense
Current tax expense
Current year 
Changes to estimates for prior years 

Deferred tax expense
Deferred tax expense    
Deferred tax expense
Deferred tax expense
Origination and reversal of temporary differences 
Utilisation of previously recognised tax losses 
Changes to estimates for prior years 

GroupGroupGroupGroup    

Company    
Company
Company
Company

2018
2018    
20182018
££££000000000000    
----    
(108)    
(108)
(108)
(108)
(7)(7)(7)(7)    
(17)
(17)    
(17)
(17)
(251)    
(251)
(251)
(251)

2017 
£000 
(22) 
(90) 
(37) 
(17) 
(220) 

2018
2018    
20182018
££££000000000000 
----    
----    
----    
----    
----    

2018
2018    
20182018
££££000000000000    

(1(1(1(197979797))))    
----    
(1(1(1(197979797))))    

(46)
(46)    
(46)
(46)
----    
----    
(46)    
(46)
(46)
(46)

2017 
£000 

(78) 
12 

(66) 

(585) 

2017 
£000 
(22) 
- 
- 
- 
- 

2017 
£000 

(226) 
(12) 
(238) 

(2) 
- 
- 
(2) 

Tax expense     
Tax expense 
Tax expense 
Tax expense 

(2(2(2(243434343))))    

(240) 

Reconciliation of effective tax rate
Reconciliation of effective tax rate    
Reconciliation of effective tax rate
Reconciliation of effective tax rate
Profit before tax  
Tax using the Bank’s domestic tax rate 
Effect of tax rates in foreign jurisdictions 
Non-deductible expenses 
Tax exempt income 
Timing difference in current year 
Origination and reversal of temporary differences in deferred tax 
Changes to estimates for prior years 
Tax expense    
Tax expense
Tax expense
Tax expense

2018
2018    
20182018
££££000000000000    

2,2,2,2,710710710710    
(2(2(2(271717171))))    
----    
(33)
(33)    
(33)
(33)
8888    
7777    
46464646    
----    
(2(2(2(243434343))))    

(10.0)% 
(1.6)% 
(1.0)% 
 2.4% 
1.8% 
(0.1)% 
(0.4)% 
(8.9)% 

2017 
£000 

2,698 
(270) 
(44) 
(28) 
67 
49 
(2) 
(12) 
(240) 

(10.0)%
(10.0)%    
(10.0)%
(10.0)%
0.0 %0.0 %0.0 %0.0 %    
(1.(1.(1.(1.2222)%)%)%)%    
0.3 %0.3 %0.3 %0.3 %    
0.3 %0.3 %0.3 %0.3 %    
1.7 %1.7 %1.7 %1.7 %    
0.0 %0.0 %0.0 %0.0 %    
(9.0)%(9.0)%(9.0)%(9.0)%    

Page | 51  

 
 
 
 
    
    
 
 
 
 
 
    
 
 
 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
    
    
    
    
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
 
 
 
    
    
    
    
 
 
 
    
    
    
 
 
 
    
    
    
 
 
 
 
    
    
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
17. Income tax expense    (continued)
17. Income tax expense
(continued)
(continued)
17. Income tax expense
17. Income tax expense

The main rate of corporation tax in the Isle of Man is 0.0% (2017: 0.0%).  However the profits of the Group’s Isle of Man banking 
activities are taxed at 10.0% (2017: 10.0%). The profits of the Group’s subsidiaries that are subject to UK corporation tax are taxed 
at a rate of 19.0% (2017: 19.0%).  

The value of tax losses carried forward reduced to nil and there is now a timing difference related to accelerated capital allowances 
resulting in a £88,000 liability (2017: £42,000 liability). This resulted in an expense of £50,000 (2017: £2,000) to the consolidated 
income statement. 

18. Earnings per share    
18. Earnings per share
18. Earnings per share
18. Earnings per share

A. Basic and diluted earnings per share    
A. Basic and diluted earnings per share
A. Basic and diluted earnings per share
A. Basic and diluted earnings per share

The calculation of basic earnings per share has been based on the profit for the year and the weighted average number of ordinary 
shares outstanding.  
The calculation of diluted earnings per share has been based on the profit for the year and the weighted average number of ordinary 
shares outstanding after adjustment for the effects of all dilutive potential ordinary shares. 

Total comprehensive income for the year    
Total comprehensive income for the year
Total comprehensive income for the year
Total comprehensive income for the year

Weighted average number of ordinary shares in issue 
Basic earnings per share (pence) 
Diluted earnings per share (pence) 

B. Reconciliation of earnings between basic and diluted earnings    
B. Reconciliation of earnings between basic and diluted earnings
B. Reconciliation of earnings between basic and diluted earnings
B. Reconciliation of earnings between basic and diluted earnings

Total comprehensive income for the year 
Total comprehensive income for the year
Total comprehensive income for the year
Total comprehensive income for the year
As per basic earnings per share – total comprehensive income 
Interest expense saved if all convertible loan notes were exchanged for equity (note 29) 

As per dilutive earnings per share 

2018    
2018
20182018

2017 

,000    
£2,£2,£2,£2,461461461461,000
,000,000

£2,395,000 

131,096,235
131,096,235    
131,096,235
131,096,235
1.81.81.81.88888    
1.541.541.541.54    

110,880,711 
2.17 
1.70 

2018    
2018
20182018

2017 

£2,£2,£2,£2,461461461461,000
,000    
,000,000
£196,150    
£196,150
£196,150
£196,150

,150    
£2,£2,£2,£2,657657657657,150
,150,150

£2,395,000 
£196,150 

£2,591,150 

outstanding between basic and diluted    
C. Reconciliation of weighted average number of ordinary shares outstanding between basic and diluted
C. Reconciliation of weighted average number of ordinary shares 
outstanding between basic and diluted
outstanding between basic and diluted
C. Reconciliation of weighted average number of ordinary shares 
C. Reconciliation of weighted average number of ordinary shares 

Reconciliation of weighted average number of ordinary shares in issue between basic and 
Reconciliation of weighted average number of ordinary shares in issue between basic and 
Reconciliation of weighted average number of ordinary shares in issue between basic and 
Reconciliation of weighted average number of ordinary shares in issue between basic and 
diluted earnings per share
diluted earnings per share    
diluted earnings per share
diluted earnings per share
As per basic earnings per share 
Number of shares issued if all convertible loan notes were exchanged for equity (note 29) 
Dilutive element of share options if exercised (note 31) 

As per dilutive earnings per share 

2018    
2018
20182018

2017 

131,096,235
131,096,235    
131,096,235
131,096,235
41,666,667
41,666,667    
41,666,667
41,666,667
10,366    
10,366
10,366
10,366

110,880,711 
41,666,667 
- 

172,773,268    
172,773,268
172,773,268
172,773,268

152,547,378 

Page | 52  

 
 
 
 
    
 
 
    
    
 
    
    
 
 
 
 
 
 
    
    
 
    
    
 
    
    
 
    
    
 
 
    
    
    
 
 
 
 
    
 
 
 
    
    
    
 
 
 
 
 
 
 
 
    
    
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

19. Cash and cash equivalents    
19. Cash and cash equivalents
19. Cash and cash equivalents
19. Cash and cash equivalents

Cash at bank and in hand 

Group 

Company 

2018
2018    
20182018
££££000000000000    

9,753    
9,753
9,753
9,753

9,753    
9,753
9,753
9,753

2017 
£000 

9,745 

9,745 

2018
2018    
20182018
££££000000000000    

1,646    
1,646
1,646
1,646

1,646    
1,646
1,646
1,646

2017 
£000 

200 

200 

Cash at bank includes an amount of £561,000 (2017: £63,000) representing receipts which are in the course of transmission.  

20. Debt securities    
20. Debt securities
20. Debt securities
20. Debt securities

Financial assets at 
FVOCI:    
Financial assets at FVOCI:
FVOCI:
FVOCI:
Financial assets at 
Financial assets at 
UK Government Treasury Bills 

Financial assets at amortised cost:
Financial assets at amortised cost:    
Financial assets at amortised cost:
Financial assets at amortised cost:
UK Certificates of Deposit 

Group 

2018
2018    
20182018
££££000000000000    

2017 
£000 

Company 

2018
2018    
20182018
££££000000000000    

2017 
£000 

30,534    
30,534
30,534
30,534

28,740    
28,740
28,740
28,740

----    

30,534    
30,534
30,534
30,534

5,532    
5,532
5,532
5,532

34,272    
34,272
34,272
34,272

----    

----    

----    

- 

- 

- 

UK Government Treasury Bills are stated at fair value and unrealised changes in the fair value are reflected in other comprehensive 
income. There were £135,000 (2017: £36,000) realised gains and £44,000 unrealised gains (2017: unrealised losses £93,000) during 
the year. 

21. Trading asset    
21. Trading asset
21. Trading asset
21. Trading asset

The investment represents shares in a UK quoted company, elected to be classified as a financial asset at fair value through profit or 
loss. The investment is stated at market value and is classified as a level 1 investment in the IFRS 13 fair value hierarchy. The cost 
of the shares was £471,000. The unrealised difference between cost and market value has been taken to the income statement. 
Dividend  income  of  £355,000  (2017:  £350,000)  and  £24,000  (2017:  £24,000)  of  sale  proceeds  have  been  received  from  this 
investment since it was made. The investment made a net loss of £4,000 (2017: £21,000) during the year. 

22. Loans and advances to customers    
22. Loans and advances to customers
22. Loans and advances to customers
22. Loans and advances to customers

GroupGroupGroupGroup    

HP balances 
Finance lease balances 
Unsecured personal loans 
Vehicle stocking plans 
Wholesale funding arrangements 
Block discounting 
Secured commercial loans 
Secured personal loans 

GrossGrossGrossGross    
Amount
Amount    
Amount
Amount
££££000000000000    

59,038
59,038    
59,038
59,038
27,238
27,238    
27,238
27,238
14,806
14,806    
14,806
14,806
1,486
1,486    
1,486
1,486
22,944
22,944    
22,944
22,944
17,316    
17,316
17,316
17,316
1,967
1,967    
1,967
1,967
6,877
6,877    
6,877
6,877
151,672    
151,672
151,672
151,672

2018
2018    
20182018
Impairment
Impairment    
Impairment
Impairment
Allowance
Allowance    
Allowance
Allowance
££££000000000000    

(1,416)
(1,416)    
(1,416)
(1,416)
(1,5(1,5(1,5(1,551515151))))    
(382)
(382)    
(382)
(382)
----    
----    
----    
(45)
(45)    
(45)
(45)
----    
(3,(3,(3,(3,394394394394))))    

Carrying
Carrying    
Carrying
Carrying
Value
Value    
ValueValue
££££000000000000    

57,622
57,622    
57,622
57,622
25,625,625,625,687878787    
14,424
14,424    
14,424
14,424
1,486    
1,486
1,486
1,486
22,944
22,944    
22,944
22,944
17,316    
17,316
17,316
17,316
1,922
1,922    
1,922
1,922
6,877    
6,877
6,877
6,877
148,278787878    
148,2
148,2
148,2

Gross 
Amount 
£000 

59,909 
20,088 
10,521 
1,613 
5,830 
13,523 
659 
13,090 
125,233 

2017 
Impairment 
Allowance 
£000 

(1,327) 
(1,101) 
(255) 
- 
- 
- 
(4) 
- 
(2,687) 

Carrying 
Value 
£000 

58,582 
18,987 
10,266 
1,613 
5,830 
13,523 
655 
13,090 
122,546 

Collateral  is  held  in  the  form  of  underlying  assets  for  HP,  finance  leases,  vehicles  stocking  plans,  block  discounting,  secured 
commercial  and  personal  loans  and  wholesale  funding  arrangements.  An  estimate  of  the  fair  value  of  collateral  on  past  due  or 
impaired loans and advances is not disclosed as it would be impractical to do so.  

Specific allowance for impairment    
Specific allowance for impairment
Specific allowance for impairment
Specific allowance for impairment

Balance at 1 January 
Specific allowance for impairment made 
Release of allowances previously made 
Write-offs 
Balance at 31 December    
Balance at 31 December
Balance at 31 December
Balance at 31 December

2018    
2018
20182018
££££000000000000    

2,440
2,440    
2,440
2,440
1,1,1,1,291291291291    
(410)
(410)    
(410)
(410)
(195)    
(195)
(195)
(195)
3,13,13,13,126262626    

2017 
£000 

2,099 
1,295 
(776) 
(178) 
2,440 

Page | 53  

 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
    
 
 
    
 
    
 
    
 
 
 
 
 
 
    
 
    
 
    
 
 
    
 
    
 
    
 
 
 
 
 
 
    
 
    
 
    
 
 
 
    
 
    
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
    
 
 
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
 
    
    
    
    
    
    
 
 
 
 
 
    
    
    
    
 
 
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
    
    
 
    
    
 
 
    
    
    
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
22. Loans and advances to customers    (continued)
22. Loans and advances to customers
(continued)
(continued)
22. Loans and advances to customers
22. Loans and advances to customers

Collective allowance for impairment    
Collective allowance for impairment
Collective allowance for impairment
Collective allowance for impairment

Balance at 1 January 
Collective allowance for impairment made 
Release of allowances previously made 

Balance at 31 December    
Balance at 31 December
Balance at 31 December
Balance at 31 December

impairment    
Total allowances for impairment
Total allowances for 
impairment
impairment
Total allowances for 
Total allowances for 

2018
2018    
20182018
££££000000000000    

247247247247    
49494949    
(28)    
(28)
(28)
(28)

268268268268    

3,3,3,3,394394394394    

2017 
£000 

57 
202 
(12) 

247 

2,687 

Advances  on  preferential  terms  are  available  to  all  Directors,  management  and  staff.  As  at  31  December  2018  £389,005  (2017: 
£347,328) had been lent on this basis. In the Group’s ordinary course of business, advances may be made to Shareholders but all 
such advances are made on normal commercial terms.  

As detailed below, at the end of the current financial year 15 loan exposures (2017: 3) exceeded 10.0% of the capital base of the 
Bank: -  

Exposure    
Exposure
Exposure
Exposure

Block discounting facility 
Wholesale funding agreement 

Outstanding 
Outstanding 
Outstanding 
Outstanding 
Balance
Balance    
Balance
Balance
2018    
2018
20182018
£000 
£000
£000£000

14,211
14,211    
14,211
14,211
21,423    
21,423
21,423
21,423

Outstanding 
Balance 
2017 
£000 

9,487 
- 

HP and finance lease receivables
HP and finance lease receivables    
HP and finance lease receivables
HP and finance lease receivables
Loans and advances to customers include the following HP and finance lease receivables: - 

Less than one year 
Between one and five years 

Gross investment in HP and finance lease receivables    
Gross investment in HP and finance lease receivables
Gross investment in HP and finance lease receivables
Gross investment in HP and finance lease receivables

The investment in HP and finance lease receivables net of unearned income comprises: - 

Facility
Facility    
Facility
Facility
limit    
limit
limit
limit
£000    
£000
£000£000

23,500
23,500    
23,500
23,500
24,500    
24,500
24,500
24,500

2017 
£000 

36,227 
60,576 

96,803 

2017 
£000 

29,317 
50,680 

79,997 

2018
2018    
20182018
££££000000000000    
42,532
42,532    
42,532
42,532
60,184    
60,184
60,184
60,184

102,716    
102,716
102,716
102,716

2018
2018    
20182018
££££000000000000    
37,508
37,508    
37,508
37,508
49,289    
49,289
49,289
49,289

86,797    
86,797
86,797
86,797

Less than one year 
Between one and five years 

Net investment in HP and finance lease receivables 

23. Trade and other receivables    
23. Trade and other receivables
23. Trade and other receivables
23. Trade and other receivables

Prepayments 
VAT recoverable 
Other debtors 

Group 

Company 

2018
2018    
20182018
££££000000000000    

382382382382    
936936936936    
1,173
1,173    
1,173
1,173
2,491    
2,491
2,491
2,491

2017 
£000 

285 
817 
806 
1,908 

2018
2018    
20182018
££££000000000000    

32323232    
----    
----    
32323232    

2017 
£000 

22 
- 
- 
22 

Included in trade and other receivables is an amount of £936,000 (2017: £817,000) relating to a reclaim of VAT.  The Bank, as the 
Group VAT registered entity, has for some time considered the VAT recovery rate being obtained by the business was neither fair nor 
reasonable, specifically regarding the attribution of part of the residual input tax relating to the HP business not being considered as 
a taxable supply. Queries have been raised with the Isle of Man Government Customs & Excise Division (“C&E”), and several reviews 
of the mechanics of the recovery process were undertaken by the Company’s professional advisors.  

Page | 54  

 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
    
    
 
 
    
    
    
 
 
 
    
    
    
 
 
    
    
 
    
    
    
    
 
 
    
    
    
    
 
 
    
    
 
 
    
    
    
 
 
 
    
 
    
    
    
    
    
    
 
 
 
 
 
    
    
 
    
 
 
    
    
    
 
 
 
 
    
    
 
    
    
 
 
 
    
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
 
 
    
    
    
 
 
 
 
    
    
 
    
    
 
 
 
    
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
 
 
    
    
    
 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

23. Trade and other receivables (continued)    
23. Trade and other receivables (continued)
23. Trade and other receivables (continued)
23. Trade and other receivables (continued)

The  decision  of  the  First-Tier  Tax  Tribunal  released  18  August  2011  in  respect  of  Volkswagen  Financial  Services  (UK)  Limited 
(“VWFS”)  v  HM  Revenue  &  Customs  (TC01401)  (“VWFS  Decision”)  added  significant  weight  to  the  case  put  by  the  Bank  and  a 
request for a revised Partial Exemption Special Method was submitted in December 2011. The proposal put forward by the Bank was 
that the revised method would allocate 50.0% of costs in respect of HP transactions to a taxable supply and 50.0% to an exempt 
supply. In addition, a Voluntary Disclosure was made as a retrospective claim for input VAT under-claimed in the last 4 years. A 
secondary claim was also made to cover periods Q4 2012 to Q1 2016 for the value of £230,000 and an amount of £249,000 has been 
accrued to cover periods Q2 2016 to Q4 2018. 

In November 2012, it was announced that the HMRC Upper Tribunal had overturned the First-Tier Tribunal in relation to the VWFS 
Decision. VWFS has subsequently been given leave to appeal and this was scheduled to be heard in October 2013. However, this 
was delayed and the case was heard by the Court of Appeal on 17 April 2015 who overturned the Upper Tribunal’s decision ruling in 
favour of VWFS. HMRC have appealed this decision to the Supreme Court, which has referred the issue to the European Court of 
Justice. 

The Court of Justice of the European Union (“CJEU”) has published its determination concerning the Volkswagen Financial Services 
(UK) Limited (“VWFS”) vs HMRC case. The judgement addressed all specific questions referred and agreed with VWFS on all material 
points. Specifically, the judgment clarifies that a partial exemption method must reflect the taxable sale of the goods, even where 
general costs are commercially passed on as part of the exempt supplies of credit. We have approached Customs and Excise with a 
view  of commencing conversations to  finalise  our  historic claims,  rolling  up  the claim  to date  and  agreeing  a  new  partial  exempt 
method going forward. 

The Bank’s total exposure in relation to this matter increased to £1,049,000, comprising the debtor balance referred to above plus an 
additional £113,000 VAT reclaimed under the partial Exemption Special Method, in the period from Q4 2011 to Q3 2012 (from Q4 
2012 the Bank reverted back to the previous method). On the basis of the discussions and correspondence which have taken place 
between the Bank and C&E, in addition to the VWFS case, the Directors are confident that the VAT claim referred to above will be 
secured. 

24. Property, plant and equipment    
24. Property, plant and equipment
24. Property, plant and equipment
24. Property, plant and equipment

GroupGroupGroupGroup    

CostCostCostCost    
As at 1 January 2018 

Additions 
Disposals 
As at 31 December 2018    
As at 31 December 2018
As at 31 December 2018
As at 31 December 2018

Accumulated 
depreciation    
Accumulated depreciation
depreciation
depreciation
Accumulated 
Accumulated 
As at 1 January 2018 

Charge for year 
Disposals 

As at 31 December 2018    
As at 31 December 2018
As at 31 December 2018
As at 31 December 2018

Carrying value at 31 December 2018    
Carrying value at 31 December 2018
Carrying value at 31 December 2018
Carrying value at 31 December 2018

Carrying value at 31 December 2017 

Leasehold
Leasehold    
Leasehold
Leasehold
Improvements
Improvements    
Improvements
Improvements
££££000000000000    

ITITITIT    
Equipment
Equipment    
Equipment
Equipment
££££000000000000    

Furniture &
Furniture &    
Furniture &
Furniture &
Equipment
Equipment    
Equipment
Equipment
££££000000000000    

MotorMotorMotorMotor    
Vehicles1    
Vehicles
Vehicles
Vehicles
££££000000000000    

443 

66 
----    
509509509509    

189 

60 
- 

249249249249    

260260260260    

254 

294 

41 
----    
335335335335    

152 

61 
- 

213213213213    

122122122122    

142 

646 

18 
----    
664664664664    

599 

13 
- 

612612612612    

52525252    

47 

10 

993 
----    
1,003    
1,003
1,003
1,003

3 

50 
- 

53535353    

950950950950    

7 

Total
Total    
Total
Total
££££000000000000    

1,393 

1,118 
----    
2,511    
2,511
2,511
2,511

943 

184 
- 

1,127    
1,127
1,127
1,127

1,384    
1,384
1,384
1,384

450 

1Motor vehicles relate to operating leases with the Group as lessor. 

Page | 55  

 
 
 
 
 
 
 
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
 
 
 
 
 
    
    
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
    
    
 
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
 
 
 
 
 
 
    
    
    
    
    
    
 
 
 
 
 
    
    
 
 
 
 
    
    
    
    
    
    
    
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
24. Property, plant and equipment    (continued)
24. Property, plant and equipment
(continued)
(continued)
24. Property, plant and equipment
24. Property, plant and equipment

Company    
Company
Company
Company

CostCostCostCost    
As at 1 January 2018 
Additions 
Disposals 

As at 31 December 2018    
As at 31 December 2018
As at 31 December 2018
As at 31 December 2018

Accumulated depreciation
Accumulated depreciation    
Accumulated depreciation
Accumulated depreciation
As at 1 January 2018 
Charge for year 
Disposals 

As at 31 December 2018    
As at 31 December 2018
As at 31 December 2018
As at 31 December 2018

Carrying value at 31 December 2018    
Carrying value at 31 December 2018
Carrying value at 31 December 2018
Carrying value at 31 December 2018

Carrying value at 31 December 2017 

25. Intangible assets    
25. Intangible assets
25. Intangible assets
25. Intangible assets

GroupGroupGroupGroup    

CostCostCostCost    
As at 1 January 2018 
Additions 
Acquisition of MBL 
Disposals 
As at 31 December 2018    
As at 31 December 2018
As at 31 December 2018
As at 31 December 2018

Accumulated amortisation
Accumulated amortisation    
Accumulated amortisation
Accumulated amortisation
As at 1 January 2018 
Charge for year / impairment (note 32) 
Disposals 

As at 31 December 2018    
As at 31 December 2018
As at 31 December 2018
As at 31 December 2018

Carrying value at 31 December 2018    
Carrying value at 31 December 2018
Carrying value at 31 December 2018
Carrying value at 31 December 2018

Carrying value at 31 December 2017 

Leasehold
Leasehold    
Leasehold
Leasehold
Improvements
Improvements    
Improvements
Improvements
££££000000000000    

ITITITIT    
Equipment
Equipment    
Equipment
Equipment
££££000000000000    

Furniture &
Furniture &    
Furniture &
Furniture &
Equipment
Equipment    
Equipment
Equipment
££££000000000000    

234 
- 
- 

234234234234    

92 
39 
- 

131131131131    

103103103103    

142 

13 
- 
- 

13131313    

2 
1 
- 

3333    

10101010    

11 

15 
1 
- 

16161616    

2 
1 
- 

3333    

13131313    

13 

Customer 
Customer 
Customer 
Customer 
Contracts & Lists
Contracts & Lists    
Contracts & Lists
Contracts & Lists
££££000000000000    

Intellectual     
Intellectual 
Intellectual 
Intellectual 
Property Rights
Property Rights    
Property Rights
Property Rights
££££000000000000    

IT Software and 
IT Software and 
IT Software and 
IT Software and 
Website 
Website 
Website 
Website 
Development
Development    
Development
Development
££££000000000000    

1,284 
- 
133 
- 
1,417    
1,417
1,417
1,417

130 
65 
- 

195195195195    

1,222    
1,222
1,222
1,222

1,154 

388 
- 
- 
- 
388388388388    

162 
150 
- 

312312312312    

76767676    

226 

1,550 
496 
- 
- 
2,046    
2,046
2,046
2,046

1,211 
181 
- 

1,392    
1,392
1,392
1,392

654654654654    

339 

Total
Total    
Total
Total
££££000000000000    

262 
1 
- 

263263263263    

96 
41 
- 

137137137137    

126126126126    

166 

Total
Total    
Total
Total
££££000000000000    

3,222 
496 
133 
- 
3,851    
3,851
3,851
3,851

1,503 
396 
- 

1,899    
1,899
1,899
1,899

1,952    
1,952
1,952
1,952

1,719 

On 23 December 2016, the Company acquired the majority of the Isle of Man’s IFA business held by Knox Financial Services Limited 
("KFSL"). The initial acquisition included approximately 4,000 clients together with 6 members of staff. The basis of consideration was 
contingent, as it is determined by 4 times renewal income received in the first 12 months of ownership, reduced by any clawbacks in 
the same period.  The final value could not fall below £800,000.  The Company entered into a loan agreement with Conister Bank 
Limited (see note 32 for terms) and paid the non-refundable minimum of £800,000 and a further £200,000 into an escrow account 
until the final valuation was determined.  When the value was finalised, any surplus or shortfall was settled. 

At acquisition, by reference to the renewal income received by KFSL in the 12 months prior to disposal, an estimate of £236,906 was 
assumed for income over the preceding 12 months, which would have generated a consideration sum of £947,624. Therefore, EWA 
accounted  for  this  transaction  by  recognising  an  intangible asset  of  £947,624  and  a  receivable  of  £52,376  of  the  monies  held  in 
escrow.  Subsequent to acquisition this estimate was updated to an estimated purchase price of £989,400 as at 31 December 2017. 
Consequently, the receivable from escrow was reduced to £10,600. The final consideration for the purchase was determined to be 
£1,101,000.  As  acquisition  accounting  was  finalised  prior  to  final  settlement,  the  £111,600  additional  cost  was  recognised  as  an 
expense in the profit and loss during 2018. The fair value of the assets acquired was considered to be of the same amount as the 
sum estimated to be paid and principally relates to customer contracts. The period over which these contracts are to be amortised is 
estimated to be 18.75 years given the average duration of EWA’s existing portfolio for renewal income.

Page | 56  

 
 
 
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
 
 
 
    
    
 
 
 
    
    
 
 
 
    
    
 
 
 
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
    
    
 
 
 
    
    
 
 
 
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
 
 
 
 
    
    
    
    
    
    
 
 
 
    
    
 
 
 
    
    
    
    
    
    
    
 
 
 
 
    
    
    
    
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
    
    
    
 
 
 
    
    
 
 
 
    
    
 
 
 
    
    
 
 
 
    
    
 
 
 
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
 
 
    
    
 
 
 
    
    
 
 
 
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
    
    
    
    
    
    
    
    
 
    
    
    
    
    
    
 
 
 
 
    
    
    
    
    
    
 
 
 
    
    
 
 
 
    
    
    
    
    
    
    
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
25. Intangible assets    (continued)
25. Intangible assets
(continued)
(continued)
25. Intangible assets
25. Intangible assets

In tandem, both parties entered into an option agreement, exercisable within three months from the transaction date, for EWA to 
acquire  the  remainder  of  the  vendor's  IFA  business  which  included  approximately  150  clients.    This  option  was  exercised  on  18 
January  2017.  The  price  of  the  acquisition  was  calculated  by  four  times  the  renewal  income  received  over  the  12-month  period 
subsequent to completion.  The purchase price was estimated to be £198,300 with £75,000 paid upon exercise of the option. During 
the year, the final purchase consideration was determined to be £231,759. The Company made a final settlement of £156,760 during 
the year in addition to the £75,000 option price paid during the prior year. This has resulted in a valuation adjustment of £33,403. 

On 7 September 2018, the Company acquired a book of insurance and financial services clients from Westwinds Financial Services 
Limited for a final consideration of £100,000. 

26. Deposits from customers    
26. Deposits from customers
26. Deposits from customers
26. Deposits from customers

Retail customers: term deposits 
Corporate customers: term deposits 

27. Creditors and accrued charges    
27. Creditors and accrued charges
27. Creditors and accrued charges
27. Creditors and accrued charges

Commission creditors 
Other creditors and accruals 
Taxation creditors 

28. Block creditors    
28. Block creditors
28. Block creditors
28. Block creditors

2018
2018    
20182018
££££000000000000    

153,735
153,735    
153,735
153,735
4,765    
4,765
4,765
4,765

158,500    
158,500
158,500
158,500

2017 
£000 

137,399 
4,873 

142,272 

Group 

Company 

2018
2018    
20182018
££££000000000000    

758758758758    
897897897897    
355355355355    

2,012,012,012,010000    

2017 
£000 

2,042 
774 
348 

3,164 

2018
2018    
20182018
££££000000000000    

----    
94949494    
----    

94949494    

2018
2018    
20182018
££££000000000000    

----    
138138138138    

138138138138    

2017 
£000 

- 
139 
- 

139 

2017 
£000 

95 
656 

751 

2017 
£000 

1,750 
1,200 
460 
250 

3,660 
5,335 
8,995 

Drawdown 2 – repayable 25/07/2018, interest payable at 5.8%, secured on assets of MFL 
Drawdown 3 – repayable 08/03/2019, interest payable at 6.5%, secured on assets of MFL 

29. Loan notes    
29. Loan notes
29. Loan notes
29. Loan notes

Related parties
Related parties    
Related parties
Related parties
J Mellon 
Burnbrae Limited 
Southern Rock Insurance Company Limited 
Life Science Developments Limited 

Unrelated parties    
Unrelated parties
Unrelated parties
Unrelated parties

Group 

Company 

NotesNotesNotesNotes    

JMJMJMJM    
BLBLBLBL    
SRSRSRSR    
LSLSLSLS    

UPUPUPUP    

2018
2018    
20182018
££££000000000000    

1,750
1,750    
1,750
1,750
1,200
1,200    
1,200
1,200
460460460460    
----    

3,410
3,410    
3,410
3,410
12,461
12,461    
12,461
12,461
15,871    
15,871
15,871
15,871

2017 
£000 

1,750 
1,200 
460 
250 

3,660 
5,335 
8,995 

2018
2018    
20182018
££££000000000000    

1,750
1,750    
1,750
1,750
1,200
1,200    
1,200
1,200
460460460460    
----    

3,410
3,410    
3,410
3,410
12,461
12,461    
12,461
12,461
15,871    
15,871
15,871
15,871

JMJMJMJM – Two loans, one of £500,000 maturing on 31 July 2022 with interest payable of 5.0% per annum, and one of £1,250,000 maturing 
on 26 February 2020, paying interest of 6.5% per annum. Both loans are convertible at the rate of 7.5 pence and 9 pence respectively.    

Page | 57  

 
 
 
 
 
    
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
    
 
 
 
 
 
 
 
    
 
 
 
    
 
 
 
    
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
    
 
 
 
 
    
 
 
 
 
    
    
 
 
 
    
 
 
 
    
    
 
 
 
    
 
 
    
    
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
    
 
 
 
    
    
 
 
 
    
 
 
 
    
 
 
 
 
    
    
 
 
 
    
 
 
 
 
 
 
    
    
 
 
 
    
 
 
 
    
 
 
 
 
    
    
 
 
 
    
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
29. Loan notes    (continued)
29. Loan notes
(continued)
(continued)
29. Loan notes
29. Loan notes

BLBLBLBL – One loan consisting of £1,200,000 maturing on 31 July 2022 with interest payable of 5.0% per annum.  Jim Mellon is the beneficial 
owner of BL and Denham Eke is also a director.  The loan is convertible at a rate of 7.5 pence.   

SRSRSRSR – One loan consisting of £460,000 maturing on 26 February 2020 with interest payable of 6.5% per annum.  The loan is convertible 
at a rate of 9 pence.   John Banks, a Non-executive Director, is also a director of SR and Arron Banks is a major shareholder of SR.   

LSLSLSLS – One loan of £nil (2017: £250,000) which matured on 3 January 2018 with interest payable of 5.0% per annum. Denham Eke is 
a director of LS. The loan was repaid on maturity. 

UPUPUPUP – Thirty-three loans consisting of an average £377,606 with a weighted average interest payable of 5.4% per annum.  The earliest 
maturity date is 20 January 2019 and the latest maturity is 10 October 2023.  

With respect to the convertible loans, the interest rate applied was deemed by the Directors to be equivalent to the market rate at 
the time with no conversion option.  
30. Pension liability     
30. Pension liability 
30. Pension liability 
30. Pension liability 

The  Conister  Trust  Pension  and  Life  Assurance  Scheme  (“Scheme”)  operated  by  the  Company  is  a  funded  defined  benefit 
arrangement which provides retirement benefits based on final pensionable salary. The Scheme is closed to new entrants and the 
last active member of the Scheme left pensionable service in 2011. 

The Scheme is approved in the Isle of Man by the Assessor of Income Tax under the Income Tax (Retirement Benefit Schemes) Act 
1978 and must comply with the relevant legislation. In addition, it is registered as an authorised scheme with the FSA in the Isle of 
Man under the Retirement Benefits Scheme Act 2000. The Scheme is subject to regulation by the FSA but there is no minimum 
funding regime in the Isle of Man.  

The  Scheme  is  governed  by  two  corporate  trustees,  Conister  Bank  Limited  and  Boal  &  Co  (Pensions)  Limited.  The  trustees  are 
responsible for the Scheme’s investment policy and for the exercise of discretionary powers in respect of the Scheme’s benefits. 

The rules of the Scheme state: - “Each Employer shall pay such sums in each Scheme Year as are estimated to be required to provide 
the benefits of the Scheme in respect of the Members in its employ”. 

Exposure to risk
Exposure to risk    
Exposure to risk
Exposure to risk
The Company is exposed to the risk that additional contributions will be required in order to fund the Scheme as a result of poor 
experience. Some of the key factors that could lead to shortfalls are: - 

investment performance – the return achieved on the Scheme’s assets may be lower than expected; and 

 
  mortality – members could live longer than foreseen. This would mean that benefits are paid for longer than expected, increasing 

the value of the related liabilities. 

In order to assess the sensitivity of the Scheme’s pension liability to these risks, sensitivity analyses have been carried out. Each 
sensitivity analysis is based on changing one of the assumptions used in the calculations, with no change in the other assumptions. 
The same method has been applied as was used to calculate the original pension liability and the results are presented in comparison 
to  that  liability.  It  should  be  noted  that  in  practice  it  is  unlikely  that  one  assumption  will  change  without  a  movement  in  the  other 
assumptions; there may also be some correlation between some of these assumptions. It should also be noted that the value placed 
on the liabilities does not change on a straight line basis when one of the assumptions is changed. For example, a 2.0% change in 
an assumption will not necessarily produce twice the effect on the liabilities of a 1.0% change. 

No  changes  have  been  made  to  the  method  or  to  the  assumptions  stress-tested  for  these  sensitivity  analyses  compared  to  the 
previous period. The investment strategy of the Scheme has been set with regard to the liability profile of the Scheme. However, there 
are no explicit asset-liability matching strategies in place.  

Restriction of assets
Restriction of assets    
Restriction of assets
Restriction of assets
No adjustments have been made to the statement of financial position items as a result of the requirements of IFRIC 14 issued by 
IASB’s International Financial Reporting Interpretations Committee. 

Scheme amendments
Scheme amendments    
Scheme amendments
Scheme amendments
There have not been any past service costs or settlements in the financial year ending 31 December 2018 (2017: none). 

Page | 58  

 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

30. Pension liability (continued)    
30. Pension liability (continued)
30. Pension liability (continued)
30. Pension liability (continued)

Funding policy
Funding policy    
Funding policy
Funding policy
The  funding  method  employed  to  calculate  the  value  of  previously  accrued  benefits  is  the  Projected  Unit  Method.  Following  the 
cessation of accrual of benefits when the last active member left service in 2011, regular future service contributions to the Scheme 
are no longer required. However, additional contributions will still be required to cover any shortfalls that might arise following each 
funding valuation. 

The most recent triennial full actuarial valuation was carried out at 1 April 2016, which showed that the market value of the Scheme’s 
assets was £1,379,000 representing 80.7% of the benefits that had accrued to members, after allowing for expected future increases 
in earnings. As required by IAS 19 this valuation has been updated by the actuary as at 31 December 2018. 

The amounts recognised in the Consolidated Statement of Financial Position are as follows: - 

Total underfunding in funded plans recognised as a liability    
Total underfunding in funded plans recognised as a liability
Total underfunding in funded plans recognised as a liability
Total underfunding in funded plans recognised as a liability

Fair value of plan assets 
Present value of funded obligations 

Movement in the liability for defined benefit obligations    
Movement in the liability for defined benefit obligations
Movement in the liability for defined benefit obligations
Movement in the liability for defined benefit obligations

Opening defined benefit obligations at 1 January  
Benefits paid by the plan 
Interest on obligations 
Actuarial (gain)/loss 

Liability for defined benefit obligations at 31 December    
Liability for defined benefit obligations at 31 December
Liability for defined benefit obligations at 31 December
Liability for defined benefit obligations at 31 December

Movement in plan assets    
Movement in plan assets
Movement in plan assets
Movement in plan assets

Opening fair value of plan assets at 1 January 
Expected return on assets 
Contribution by employer 
Actuarial (loss)/gain 
Benefits paid 

Closing fair value of plan assets at 31 December    
Closing fair value of plan assets at 31 December
Closing fair value of plan assets at 31 December
Closing fair value of plan assets at 31 December

Expense recognised in income statement    
Expense recognised in income statement
Expense recognised in income statement
Expense recognised in income statement

Interest on obligation 
Expected return on plan assets 

Total included in personnel costs    
Total included in personnel costs
Total included in personnel costs
Total included in personnel costs

Actual return on plan assets    
Actual return on plan assets
Actual return on plan assets
Actual return on plan assets

Actuarial gain recognised in other comprehensive income     
Actuarial gain recognised in other comprehensive income 
Actuarial gain recognised in other comprehensive income 
Actuarial gain recognised in other comprehensive income 

Actuarial (loss)/gain on plan assets 
Actuarial gain/(loss)  on defined benefit obligations 

2018
2018    
20182018
££££000000000000    

1,361
1,361    
1,361
1,361
(1,945)    
(1,945)
(1,945)
(1,945)

(584)    
(584)
(584)
(584)

2018
2018    
20182018
££££000000000000    

2,029    
2,029
2,029
2,029
(65)
(65)    
(65)
(65)
52525252    
(71)    
(71)
(71)
(71)

1,945    
1,945
1,945
1,945

2018
2018    
20182018
££££000000000000    

1,469
1,469    
1,469
1,469
37373737    
41414141    
(121)
(121)    
(121)
(121)
(65)    
(65)
(65)
(65)

1,361    
1,361
1,361
1,361

2018
2018    
20182018
££££000000000000    

52525252    
(37)    
(37)
(37)
(37)

15151515    

(53)    
(53)
(53)
(53)

2018
2018    
20182018
££££000000000000    

(121)
(121)    
(121)
(121)
71717171    

50505050    

2017 
£000 

1,469 
(2,029) 

(560) 

2017 
£000 

2,034 
(68) 
54 
9 

2,029 

2017 
£000    

1,420 
37 
41 
39 
(68) 

1,469 

2017 
£000    

54 
(37) 

17 

76 

2017 
£000    

39 
(9) 

30 

Page | 59  

 
 
 
 
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
 
 
    
    
    
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
 
 
    
    
    
 
 
    
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
    
    
    
 
 
    
    
 
    
    
    
    
 
 
    
    
    
    
    
 
 
    
    
 
 
    
    
    
 
 
 
    
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
 
 
    
    
    
 
 
    
    
    
 
 
    
    
    
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

30. Pension liability (continued)    
30. Pension liability (continued)
30. Pension liability (continued)
30. Pension liability (continued)

Plan assets consist of the following 
Plan assets consist of the following
Plan assets consist of the following
Plan assets consist of the following

Equity securities 
Corporate bonds 
Government bonds 
Cash 
Other 

The  actuarial  assumptions  used  to  calculate  Scheme  liabilities  under 
The  actuarial  assumptions  used  to  calculate  Scheme  liabilities  under 
The  actuarial  assumptions  used  to  calculate  Scheme  liabilities  under 
The  actuarial  assumptions  used  to  calculate  Scheme  liabilities  under 
IAS19 are as follows: ----    
IAS19 are as follows: 
IAS19 are as follows: 
IAS19 are as follows: 

Rate of increase in pension in payment: -  
Service up to 5 April 1997 
Service from 6 April 1997 to 13 September 2005 
Service from 14 September 2005 
Rate of increase in deferred pensions 
Discount rate applied to scheme liabilities 
Inflation 

2018
2018    
20182018
%%%%    

45454545    
19191919    
28282828    
4444    
4444    
100100100100    

      2017            
% 

48 
18 
25 
5 
4 

100 

2018
2018    
20182018
%%%%    

2017 
% 

2016 
% 

----    
3.03.03.03.0    
2.12.12.12.1    
5.05.05.05.0    
2.62.62.62.6    
3.13.13.13.1    

- 
3.0 
2.1 
5.0 
2.6 
3.1 

- 
3.1 
2.1 
5.0 
2.7 
3.2 

The assumptions used by the actuary are best estimates chosen from a range of possible assumptions, which due to the timescale 
covered, may not necessarily be borne out in practice.  

31. Called up share capital     
31. Called up share capital 
31. Called up share capital 
31. Called up share capital 

available for issue    
Ordinary shares of no par value available for issue
Ordinary shares of no par value 
available for issue
available for issue
Ordinary shares of no par value 
Ordinary shares of no par value 

At 31 December 2018    
At 31 December 2018
At 31 December 2018
At 31 December 2018

At 31 December 2017 

Ordinary shares of no par value    
Issued and fully paid: ----    Ordinary shares of no par value
Issued and fully paid: 
Ordinary shares of no par value
Ordinary shares of no par value
Issued and fully paid: 
Issued and fully paid: 

At 31 December 2018    
At 31 December 2018
At 31 December 2018
At 31 December 2018

At 31 December 2017 

Number    
       Number
Number
Number

200,200,000    
200,200,000
200,200,000
200,200,000

200,200,000    

££££000000000000    

20,732    
20,732
20,732
20,732

20,732 

Number    
       Number
Number
Number

131,096,235    
131,096,235
131,096,235
131,096,235

131,096,235 

There are four  convertible  loans  of  £3,410,000  (2017:  £3,410,000)  with  no  remaining  warrants  to exercise  at  31  December  2018 
(2017: £nil).  

On  23  June  2014,  1,750,000  share  options  were  issued  to  Executive  Directors  and  senior  management  within  the  Group  at  an 
exercise price of 14 pence. The options vest over three years with a charge based on the fair value of 8 pence per option at the date 
of  grant.  The  period  of  grant  is  for  10  years  less  1  day  ending  22  June  2024.  Of  the  1,750,000  share  options  issued,  1,050,000 
(2017:1,050,000) remain outstanding; the balance lapsed during 2017. 

Performance and service conditions attached to share options that have not fully vested are as follows: -  

(a)  The options granted on 25 June 2010 (1,056,000 options) will vest if the mid-market share price of £0.30 is achieved during the 

period of grant (10 years ending 25 June 2020); and  

(b)  The options granted on 25 June 2010 and 23 June 2014 require a minimum of three years’ continuous employment service in 

order to exercise upon the vesting date. 

Page | 60  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
    
 
 
    
 
    
 
 
    
 
    
 
    
 
    
 
    
 
    
 
 
 
 
 
 
 
 
 
    
       
       
       
    
 
 
       
       
       
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

ued)    
(continued)
31. Called up share capital (contin
31. Called up share capital 
ued)ued)
(contin
(contin
31. Called up share capital 
31. Called up share capital 

The fair value of services received in return for share options granted is based on the fair value of share options granted, measured 
using a binomial probability model with the following inputs for each award: - 

Fair value at date of grant 
Share price 
Exercise price 
Expected volatility 
Option life 
Risk-free interest rate (based on government bonds) 
Forfeiture rate 

The charge for the year for share options granted was £nil (2017: £22,000). 

Analysis of changes in financing during the year    
Analysis of changes in financing during the year
Analysis of changes in financing during the year
Analysis of changes in financing during the year

Analysis of changes in financing during the year    
Analysis of changes in financing during the year
Analysis of changes in financing during the year
Analysis of changes in financing during the year

Balance at 1 January 
Issue of loan notes 
Issue of shares 

23 June 
2014 

£0.08 
£0.14 
£0.14 
55.0% 
3 
0.5% 
33.3% 

2018
2018    
20182018
££££000000000000    

29,727
29,727    
29,727
29,727
6,876
6,876    
6,876
6,876
----    

36,603    
36,603
36,603
36,603

25 June 
2010 

£0.03 
£0.11 
£0.11 
47.0% 
3 
2.2% 
0.0% 

2017 
£000 

27,478 
450 
1,799 

29,727 

The 2018 closing balance is represented by £20,732,000 share capital (2017: £20,732,000) and £15,871,000 of loan notes (2017: 
£8,995,000).  

Investment in Group undertakings    
32. 32. 32. 32. Investment in Group undertakings
Investment in Group undertakings
Investment in Group undertakings

The Company has the following investments in subsidiaries incorporated in the Isle of Man: - 

Carrying value of investments    
Carrying value of investments
Carrying value of investments
Carrying value of investments

Nature of 
Business    

31 December
31 December    
31 December
31 December
2017    
2017
20172017
% Holding    
% Holding
% Holding
% Holding

Date of 
Incorporation    

Conister Bank Limited 
Edgewater Associates Limited 
TransSend Holdings Limited 
Bradburn Limited  

Asset and Personal Finance 
Wealth Management 
 Holding Company for Prepaid Card Division 
Holding Company 

100100100100    
100100100100    
100100100100    
100100100100    

05/12/1935 
24/12/1996 
05/11/2007 
15/05/2009 

Amounts owed to and from Group undertakings are unsecured, interest-free and repayable on demand. 

Total
Total    
Total
Total
2018    
2018
20182018
££££000000000000    

14,167
14,167    
14,167
14,167
2,005
2,005    
2,005
2,005
----    
----    
16,172    
16,172
16,172
16,172

Total 
2017 
£000    

11,767 
2,005 
- 
- 
13,772 

Page | 61  

 
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
    
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
    
 
 
 
 
 
 
    
 
    
    
    
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
32. Investment in Group undertakings    (continued)
32. Investment in Group undertakings
(continued)
(continued)
32. Investment in Group undertakings
32. Investment in Group undertakings

Subordinated loans
Subordinated loans    
Subordinated loans
Subordinated loans
MFG has issued several subordinated loans as part of its equity funding into the Bank and EWA. 

Company    
Company
Company
Company
Creation 

Conister Bank Limited
Conister Bank Limited    
Conister Bank Limited
Conister Bank Limited
11 February 2014 
27 May 2014 
9 July 2014 
17 September 2014 
22 July 2013 
25 October 2013 
23 September 2016 
14 June 2017 
12 June 2018 

Associates Limited    
Edgewater Associates Limited
Edgewater 
Associates Limited
Associates Limited
Edgewater 
Edgewater 
14 May 2012 
28 February 2013 
21 February 2017 
14 May 2017 

Goodwill        
Goodwill
Goodwill
Goodwill

Maturity 

Interest rate 

11 February 2024 
27 May 2024 
9 July 2024 
17 September 2026 
22 July 2033 
22 October 2033 
23 September 2036 
14 June 2037 
12 June 2038 

14 May 2017 
28 February 2018 
21 February 2027 
14 May 2027 

7.0% 
7.0% 
7.0% 
7.0% 
7.0% 
7.0% 
7.0% 
7.0% 
7.0% 

7.0% 
7.0% 
7.0% 
7.0% 

Edgewater Associates Limited (“EWA”) 
ECF Asset Finance PLC (“ECF”) 
Three Spires Insurance Services Limited (“Three Spires”) 

2018    
2018
20182018

££££000000000000    

500500500500    
500500500500    
500500500500    
400400400400    
1,000
1,000    
1,000
1,000
1,000    
1,000
1,000
1,000
1,100
1,100    
1,100
1,100
450450450450    
2,000    
2,000
2,000
2,000

----    
50505050    
150150150150    
128128128128    
7,778    
7,778
7,778
7,778

GroupGroupGroupGroup    
2018
2018    
20182018
££££000000000000    

1,849
1,849    
1,849
1,849
454454454454    
41414141    
2,344    
2,344
2,344
2,344

2017 

£000 

500 
500 
500 
400 
1,000 
1,000 
1,100 
450 
- 

- 
50 
150 
128 
5,778 

Group 
2017 
£000 

1,849 
454 
41 
2,344 

Goodwill impairment
Goodwill impairment    
Goodwill impairment
Goodwill impairment
The  goodwill  is  considered  to  have an  indefinite  life  and  is reviewed on  an  annual  basis by  comparing  its  estimated  recoverable 
amount with its carrying value.  

The estimated recoverable amount in relation to the goodwill generated on the purchase of EWA is based on the forecasted 3 year 
cash flow projections, extrapolated to 10 years using a 2.0% annual increment, and then discounted using a 12.0% discount factor. 
The sensitivity of the analysis was tested using additional discount factors of 15.0% and 20.0% on stable profit levels. 

The estimated recoverable amount in relation to the goodwill generated on the purchase of ECF is based on forecasted 3 year sales 
interest income calculated at 5.0% margin, extrapolated to 10 years using a 2.0% annual increment, and then discounted using a 
12.0% discount factor. The sensitivity of the analysis was tested using additional discount factors of 15.0% and 20.0% on varying 
sales volumes.  

There  has  been  no  change  in  the  detailed  method  of  measurement  for  EWA  and  ECF  when  compared  to  2017.    The  goodwill 
generated on the purchase of Three Spires has been reviewed at the current year end and is considered adequate given its income 
streams referred to EWA.  Based on the above reviews no impairment to goodwill has been made in the current year. 

Page | 62  

 
 
 
    
 
 
 
    
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
    
    
 
 
 
 
 
    
 
 
 
    
    
 
    
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
    
    
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

32. Investment in Group undertakings (continued)    
32. Investment in Group undertakings (continued)
32. Investment in Group undertakings (continued)
32. Investment in Group undertakings (continued)

Acquisition of Incahoot Limited
Acquisition of Incahoot Limited    
Acquisition of Incahoot Limited
Acquisition of Incahoot Limited
On 6 March 2015, the business of Incahoot Limited was acquired by Manx Incahoot Limited, a subsidiary of the Group.  

On 9 December 2016, a valuation was conducted by an independent firm of professional advisers on the intellectual property rights 
acquired for the purpose of including within these financial statements. The independent firm addressed the three levels of the IFRS 
fair value hierarchy and concluded that level 3 was most appropriate as the intellectual property rights acquired had no active markets 
(Level 1), or comparable assets against which to index prices (Level 2).  Therefore, the report valued the intellectual property rights 
acquired based on internally generated data (Level 3) being: costs incurred to date and cash flow projections. The report averaged 
two valuation approaches, the replacement cost approach and the income approach using a discount factor of 42.5%, to arrive at a 
final valuation of £262,474. This created an impairment of £48,026. On 2 February 2018, the valuation was again updated which lead 
to a reduced valuation of £154,427. This created an additional impairment of £108,047.  

The Directors performed an internal impairment assessment and consider the recoverable amount of the intellectual property rights 
to be £76,000 at 31 December 2018. The recoverable amount at 31 December 2017 was considered to be £154,427 based on an 
external valuation. 

Investment in associates    
Investment in associates
Investment in associates
Investment in associates

The Business Lending Exchange (“BLX”) 
Beer Swaps Limited (“BSL”) 
Pay It Monthly Ltd (“PIML”) 

GroupGroupGroupGroup    
2018
2018    
20182018
££££000000000000    

56565656    
10101010    
92929292    
158158158158    

Group 
2017 
£000 

38 
- 
- 
38 

On December 2017, 40.0% of the share capital of BLX was acquired for nil consideration. The Group’s share of the associate’s total 
comprehensive income during the year was £18,000. 

On  April  2018,  20%  of  the  share  capital  of  BSL  was  acquired  for  nil  consideration.  The  Group’s  share  of  the  associates  total 
comprehensive income post acquisition and up to year-end was £10,000. 

On  August  2018,  30%  of  the  share  capital  of  PIML  was  acquired  for  £90,000  consideration.  The  Group’s  resulting  share  of  the 
associates total comprehensive income post acquisition and up to year-end was £2,000. 

33. Related party transactions    
33. Related party transactions
33. Related party transactions
33. Related party transactions

Cash deposits
Cash deposits    
Cash deposits
Cash deposits
During the year, the Bank held cash on deposit on behalf of Jim Mellon (Executive Chairman of MFG) and companies related to Jim 
Mellon  and  Denham  Eke  (Chief  Executive  Officer  of  MFG).    Total  deposits  amounted  to  £173,157  (2017:  £40,000),  at  normal 
commercial interest rates in accordance with the standard rates offered by the Bank.  

Staff and commercial loans
Staff and commercial loans    
Staff and commercial loans
Staff and commercial loans
Details of staff loans are given in note 22. 

Normal commercial loans have been made to various companies connected to Jim Mellon and Denham Eke. As at 31 December 
2018, £113,000 of capital and interest was outstanding (2017: £299,000). 

Intercompany recharges
Intercompany recharges    
Intercompany recharges
Intercompany recharges
Various  intercompany  recharges  are  made  during  the  course  of  the  year  as  a  result  of  the  Bank  settling  debts  in  other  Group 
companies. EWA provides services to the Group in arranging its insurance and defined contribution pension arrangements. 

Loan advance to EWA
Loan advance to EWA    
Loan advance to EWA
Loan advance to EWA
On 14 December 2016, a loan advance was made to EWA by the Bank in order to provide the finance required to acquire MBL (see 
note 25).  The advance was for £700,000 at an interest rate of 8% repayable over 6 years.  A negative pledge was given by EWA to 
not encumber any property or assets or enter into an arrangement to borrow any further monies. The balance as at 31 December 
2018 was £508,000 (2017: £700,000). 

Page | 63  

 
 
 
 
 
 
 
    
    
 
    
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
    
    
    
 
 
    
 
    
 
 
    
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
33. Related party transactions    (continued)
33. Related party transactions
(continued)
(continued)
33. Related party transactions
33. Related party transactions

Loan advance to BLX
Loan advance to BLX    
Loan advance to BLX
Loan advance to BLX
On 11 October 2017, a £4,000,000 loan facility was made available to BLX by the Bank in order to provide the finance required to 
expand its operations. The facility is for 12 months, followed by a 3 year amortisation period. Interest is charged at commercial rates. 
At 31 December 2018, £2,520,000 (2017: £550,000) had been advanced to BLX. 

Loan advance to BSL
Loan advance to BSL    
Loan advance to BSL
Loan advance to BSL
On 27 April 2018, a £1,000,000 loan facility was made available to BSL by the Bank in order to provide the finance required to expand 
its operations. On 10 October 2018, this facility was increased to £1,500,000. The facility is for 12 months. Interest is charged at 
commercial rates. At 31 December 2018, £1,099,000 (2017: £nil) had been advanced to BSL. 

Loan advance to PIML
Loan advance to PIML    
Loan advance to PIML
Loan advance to PIML
On 24 May 2018, a £500,000 loan facility was made available to PIML by the Bank in order to provide the finance required to expand 
its operations. The facility is for 12 months. Interest is charged at commercial rates. At 31 December 2018, £322,000 (2017: £nil) had 
been advanced to PIML. Post-year-end on 6 February 2019, the facility was increased to £1,000,000. 

Investments
Investments    
Investments
Investments
The Bank holds less than 1% equity in the share capital of an investment of which Jim Mellon is a shareholder (note 21).  Denham 
Eke acts as co-chairman. 

Subordinated loans
Subordinated loans    
Subordinated loans
Subordinated loans
The Company has advanced £7,450,000 (2017: £5,450,000) of subordinated loans to the Bank and £328,000 (2017: £328,000) to 
EWA at 31 December 2018. 

Loan notes
Loan notes    
Loan notes
Loan notes
See note 29 for a list of related party loan notes as at 31 December 2018 and 2017. 

Key management remuneration including Executive Directors    
Key management remuneration including Executive Directors
Key management remuneration including Executive Directors
Key management remuneration including Executive Directors

Short-term employee benefits 

Operating leases    
34. 34. 34. 34. Operating leases
Operating leases
Operating leases

Non-cancellable lease rentals are payable in respect of property and motor vehicles as follows: - 

2018    
2018
20182018
££££000000000000    

297297297297    

Less than one year 
Between one and five years 
Over five years 

35. Subsequent events    
35. Subsequent events
35. Subsequent events
35. Subsequent events

2018    
2018
20182018

2017 

Leasehold
Leasehold    
Leasehold
Leasehold
Property    
Property
Property
Property
££££000000000000    

214214214214    
790790790790    
162162162162    

1,166    
1,166
1,166
1,166

OtherOtherOtherOther    
££££000000000000    

----    
----    
----    

----    

Leasehold 
Property 
£000 

178 
738 
276 

1,192 

2017 
£000 

300 

Other 
£000 

- 
- 
- 

- 

There were no significant subsequent events identified after 31 December 2018. 

management    
Financial risk management
36. 36. 36. 36. Financial risk 
management
management
Financial risk 
Financial risk 

A. Introduction and overview
A. Introduction and overview    
A. Introduction and overview
A. Introduction and overview
The Group has exposure to the following risks from financial instruments: 

  credit risk; 
 
liquidity risk; 
  market risks; and 
  operational risks. 

Page | 64  

 
 
 
 
 
 
    
    
 
 
 
    
    
    
 
 
 
 
 
 
 
 
 
    
 
 
 
 
    
    
 
 
 
 
 
    
    
 
 
 
 
 
 
    
    
 
 
 
 
    
 
 
    
 
 
    
 
 
 
    
    
    
 
 
 
 
 
 
    
    
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
    
    
    
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

(continued)    
Financial risk management    (continued)
36. 36. 36. 36. Financial risk management
(continued)
(continued)
Financial risk management
Financial risk management
(continued)    
A. Introduction and overview    (continued)
A. Introduction and overview
(continued)
(continued)
A. Introduction and overview
A. Introduction and overview

i. Risk management framework
i. Risk management framework    
i. Risk management framework
i. Risk management framework
The  Company’s  Board  have  overall  responsibility  for  the  establishment  and  oversight  of  the  Group’s  risk  management 
framework. The Board of Directors have established the  Group Audit, Risk and Compliance Committee  (‘ARCC’), which  is 
responsible for approving and monitoring Group risk management policies. ARCC is assisted in its oversight role by Internal 
Audit. Internal Audit undertakes both regular and ad hoc reviews of risk management controls and procedures, the results of 
which are reported to the ARCC. 

The Group’s risk management policies are established to identify and analyse the risks faced by the Group, to set appropriate 
risk limits and controls, and to monitor risks and adherence to limits. The risk management policies and systems are reviewed 
regularly to reflect changes in market conditions and the Group’s activities. The Group, though its training and management 
standards  and  procedures,  aims  to  develop  a  disciplined  and  constructive  control  environment  in  which  all  employees 
understand their roles and obligations. 

B. Credit risk
B. Credit risk    
B. Credit risk
B. Credit risk
‘Credit  risk’ is the risk of financial  loss to the Group  if a customer or counterparty to a financial  instrument fails to meet its 
contractual  obligations,  and  arises  principally  from  the  Group’s  loans  and  advances  to  customers  and  investment  debt 
securities. Credit risk includes counterparty, concentration, underwriting and credit mitigation risks.  

Management of credit risk    
Management of credit risk
Management of credit risk
Management of credit risk

The  Bank’s  Board  of  Directors  created  the  Credit  Committee  which  is  responsible  for  managing  credit  risk,  including  the 
following: 

  Formulating credit policies in consultation with business units, covering collateral requirements, credit assessments, 
risk  grading  and  reporting,  documentary  and  legal  procedures,  and  compliance  with  regulatory  and  statutory 
requirements. 

  Establishing  the  authorisation  structure  for  the  approval  and  renewal  of  credit  facilities.  Authorisation  limits  are 

allocated to in line with credit policy. 

  Reviewing and assessing credit risk: The Credit Committee assesses all credit exposures in excess of designated 
limits, before facilities are committed to customers. Renewals and reviews of facilities are subject to the same review 
process. 

  Limiting  concentrations  of  exposures  to  counterparties,  geographies  and  industries,  by  issuer,  credit  rating  band, 

market liquidity and country (for debt securities). 

  Developing  and  maintaining  risk  grading’s  to  categorise  exposures  according  to  the  degree  of  risk  of  default.  The 

current risk grading consists of 3 grades reflecting varying degrees of risk of default.  

  Developing and maintaining the Group’s process for measuring ECL: This includes processes for: 

initial approval, regular validation and back-testing of the models used;  

o 
o  determining and monitoring significant increase in credit risk; and  
o 

incorporation of forward-looking information. 

  Reviewing compliance with agreed exposure limits. Regular reports on the credit quality of portfolios are provided to 

the Credit Committee which may require corrective action to be taken.  

C. Liquidity risk
C. Liquidity risk    
C. Liquidity risk
C. Liquidity risk
‘Liquidity risk’ is the risk that the Group will encounter difficulty in meeting obligations associated with its financial liabilities that 
are settled by delivering cash or another financial asset. Liquidity risk arises from mismatches in the timing and amounts of 
cash flows, which is inherent to the Group’s operations and investments. 

Management of liquidity risk
Management of liquidity risk    
Management of liquidity risk
Management of liquidity risk
The Group’s approach to managing liquidity is to ensure, as far as possible, that it will always have enough liquidity to meet 
its liabilities when they are due, under both normal and stressed conditions, without incurring unacceptable losses or risking 
damage to the Group’s reputation. The key elements of the Group’s liquidity strategy are as follows: 

  Funding  base:  offering  six-months  to  five-year  fixed  term  deposit  structure  with  no  early  redemption  option.  This 
means the Bank is not subject to optionality risk where customers redeem fixed rate products where there may be a 
better rate available within the market;  

  Funding profile: the Bank has a matched funding profile and does not engage in maturity transformation which means 

that on a cumulative mismatch position the Bank is forecast to be able to meet all liabilities as they fall due; 

Page | 65  

 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

Financial risk management    
36. 36. 36. 36. Financial risk management
Financial risk management
Financial risk management
C. Liquidity risk (continued)
C. Liquidity risk (continued)    
C. Liquidity risk (continued)
C. Liquidity risk (continued)
Management of liquidity risk (continued)    
Management of liquidity risk (continued)
Management of liquidity risk (continued)
Management of liquidity risk (continued)

  Monitoring maturity mismatches, behavioural characteristics of the Group’s financial assets and financial liabilities, 
and the extent to which the Group’s assets are encumbered and so not available as potential collateral for obtaining 
funding.  

  Liquidity buffer: the Bank maintains a liquidity buffer of 10.0% of its deposit liabilities, with strict short-term mismatch 
limits  of  0.0%  for  sight  to  three  months  and  -5.0%  for  sight  to  six  months.  This  ensures  that  the  Bank  is  able  to 
withstand any short-term liquidity shock; and 
Interbank market: the Bank has no exposure to the interbank lending market. The Bank has no reliance on liquidity 
via the wholesale markets. In turn, if market conditions meant access to the wholesale funding was constrained as 
per the 2008 credit crisis, this would have no foreseeable effect on the Bank.  

  The Bank’s liquidity position is monitored daily against internal and external limits agreed with the FSA and according 
to the Bank’s Liquidity Policy. The Bank also has a Liquidity Contingency Policy and Liquidity Contingency Committee 
in the event of a liquidity crisis or potential liquidity disruption event occur. 

 

The Treasury department receives information from other business units regarding the liquidity profile of their financial assets 
and financial liabilities and details of other projected cash flows arising from projected future business. Treasury then maintains 
a portfolio of short-term liquid assets, largely made up of short-term liquid investment securities, loans and advances to banks 
and other inter-bank facilities, to ensure that sufficient liquidity is maintained within the Group as a whole.  

Regular  liquidity  stress  testing  is  conducted  under  a  variety  of  scenarios  covering  both  normal  and  more  severe  market 
conditions. The scenarios are developed considering both Group-specific events and market-related events (e.g. prolonged 
market illiquidity). 

D. Market risk
D. Market risk    
D. Market risk
D. Market risk
‘Market  risk’  is  the  risk  that  changes  in  market  prices  –  e.g.  interest  rates,  equity  prices,  foreign  exchange  rates and  credit 
spreads (not relating to changes in the obligor’s/issuer’s credit standing) will affect the Group’s income or value of its holdings 
of financial instruments. The objective of the Group’s market risk management is to manage and control market risk exposures 
within acceptable parameters to ensure the Group’s solvency while optimising the return on risk. 

Management of market risks    
Management of market risks
Management of market risks
Management of market risks
Overall authority for market risk is vested in Assets and Liabilities Committee (“ALCO”) who sets up limits for each type of risk. 
Group finance is responsible for the development of risk management policies (subject to review and approval by ALCO) and 
for the day-to-day review of their implementation. 

Foreign exchange risk    
Foreign exchange risk
Foreign exchange risk
Foreign exchange risk
The Bank is not subject to foreign exchange risks and its business is conducted in pounds sterling. 

Equity risk
Equity risk 
Equity risk
Equity risk
The Group has investment in associates of £158,000 (2017: £38,000) which are carried at cost adjusted for the Group’s share 
of net asset value. The investment is audited annually and the Bank has access to these accounts. The Bank’s exposure to 
market risk is not considered significant given the low carrying amount of the investment. 

The Group’s investment in listed equities is not considered significant.  

Interest rate risk
Interest rate risk    
Interest rate risk
Interest rate risk
The principal potential interest rate risk that the Bank is exposed to is the risk that the fixed interest rate and term profile of its 
deposit base differs materially from the fixed interest rate and term profile of its asset base, or basis and term structure risk.  
Additional interest rate risk may arise for banks where (a) customers are able to react to market sensitivity and redeem fixed 
rate products and (b) where a bank has taken out interest rate derivate hedges especially against longer term interest rate risk, 
where the hedge moves against the bank.  

Interest rate risk for the Bank is not deemed to be currently material due to the Bank’s matched funding profile. Any interest 
rate risk assumed by the Bank will arise from a reduction in interest rates, in a rising environment due to the nature of the 
Bank’s  products  and  its  matched  funded  profile.  The  Bank  should  be  able  to  increase  its  lending  rate  to  match  any 
corresponding rise in its cost of funds, notwithstanding its inability to vary rates on its existing loan book. The Bank attempts 
to efficiently match its deposit taking to its funding requirements. 

Page | 66  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

Financial risk management    
36. 36. 36. 36. Financial risk management
Financial risk management
Financial risk management
E. Operational risk    
E. Operational risk
E. Operational risk
E. Operational risk

‘Operational risk’ is the risk of direct or indirect loss arising from a wide variety of causes associated with the Group’s processes, 
personnel, technology and  infrastructure, and from external factors other than credit, market and liquidity risks – e.g. those 
arising from  legal and regulatory requirements and generally accepted standards of corporate behaviour. Operational risks 
arise from all of the Group’s operations. 

Management of operational risk    
Management of operational risk
Management of operational risk
Management of operational risk

The Group’s objective is to manage operational risk so as to balance the avoidance of financial losses and damage to the 
Group’s  reputation  with  overall  cost  effectiveness  and  innovation.  In  all  cases,  Group  policy  requires  compliance  with  all 
applicable legal and regulatory requirements. 

The Group has developed standards for the management of operational risk in the following areas: 

requirements for appropriate segregation of duties, including the independent authorisation of transactions; 
requirements for the reconciliation and monitoring of transactions; 

  business continuity planning; 
 
 
  compliance with regulatory and other legal requirements; 
  documentation of controls and procedures; 
  periodic assessment of operational risks faced, and the adequacy of controls and procedures to address the risks 

identified; 
requirements for the reporting of operational losses and proposed remedial action; 

training and professional development; 

 
  development of contingency plans; 
 
  ethical and business standards; 
 
 

information technology and cyber risks; and  
risk mitigation, including insurance where this is cost-effective. 

Compliance with Group standards is supported by a programme of periodic reviews undertaken by Internal Audit. The results 
of Internal Audit reviews are discussed with ARCC.

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ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS  
For the year ended 31 December 2018    

37. Basis of measurement    
37. Basis of measurement
37. Basis of measurement
37. Basis of measurement

The financial statements are prepared on a historical cost basis, except for the following material items. 

Items    
Items
Items
Items

Measurement basis    
Measurement basis
Measurement basis
Measurement basis

Financial instruments at FVPL 
Financial assets at FVOCI 
Net defined benefit asset/liability 

38. Significant accounting policies    
38. Significant accounting policies
38. Significant accounting policies
38. Significant accounting policies

Fair value 
Fair value 
Fair  value  of  plan  assets  less  the  present  value  of  the 
defined benefit obligation 

Except for the changes explained in Note 5, the Group has consistently applied the following accounting policies to all periods 
presented in these financial statements.  

Set out below is an index of the significant accounting policies, the details of which are available on the pages that follow. 

Ref.Ref.Ref.Ref.    

Note description    
Note description
Note description
Note description

A. 
B.  
C. 
D. 
E.  
F. 
G. 
H. 
I. 

J. 
K. 
L. 
M. 
N. 
O. 
P. 

Q. 
R. 
S. 

Basis of consolidation of subsidiaries and separate financial statements of the Company 
Interest in equity accounted investees 
Foreign currency 
Interest 
Fee and commission income 
Programme costs 
Leases 
Income tax 
Financial assets and financial liabilities 
i. Recognition and initial measurement 
ii. Classification 
iii. Derecognition 
iv. Modifications of financial assets and financial liabilities 
v. Offsetting 
vi. Fair value measurement 
vii. Impairment 
Cash and cash equivalents 
Loans and advances 
Property, plant and equipment 
Intangibles assets and goodwill 
Impairment of non-financial assets 
Deposits, debt securities issued and subordinated liabilities 
Employee benefits 
i. Long-term employee benefits 
ii. Share-based compensation 
Share capital and reserves 
Earnings per share 
Segment reporting 

No.No.No.No.    

69 
69 
69 
69 
70 
70 
70 
70 

70 
71 
71 
72 
72 
72 
73 
75 
75 
75 
75 
76 
76 
77 
77 
77 
77 
77 
77 

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ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

(continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies 
(continued)
(continued)
38. Significant accounting policies 
38. Significant accounting policies 
A. Basis of consolidation of subsidiaries and separate financial statements of the Company
A. Basis of consolidation of subsidiaries and separate financial statements of the Company    
A. Basis of consolidation of subsidiaries and separate financial statements of the Company
A. Basis of consolidation of subsidiaries and separate financial statements of the Company
i. Business combinations    
i. Business combinations
i. Business combinations
i. Business combinations

The  Group  accounts  for  business  combinations  using  the  acquisition  method  when  control  is  transferred  to  the  Group.  The 
consideration transferred in the acquisition is generally measured at fair value, as are the identifiable net assets acquired. Any goodwill 
that arises is tested annually for impairment. Any gain on a bargain purchase is recognised in profit or loss immediately. Transaction 
costs are expensed as incurred, except if they are related to issue of debt or equity securities. 

ii. Subsidiaries    
ii. Subsidiaries
ii. Subsidiaries
ii. Subsidiaries

Subsidiaries are entities controlled by the Group. The Group ‘controls’ an entity if it is exposed to or has rights to, variable returns 
from its involvement with the entity and has the ability to affect those returns through its power over the entity. The Group reassesses 
whether it has control if there are changes to one or more of the elements of control. This includes circumstances in which protective 
rights held (e.g. those resulting from a lending relationship) become substantive and lead to the Group having power over an investee. 
The  financial  statements  of  subsidiaries  are  included  in  the  consolidated  financial  statements  from  the  date  on  which  control 
commences until the date on which control ceases. 

iii. Loss of control    
iii. Loss of control
iii. Loss of control
iii. Loss of control

When the Group loses control over a subsidiary, it derecognises the assets and liabilities of the subsidiary, and any related Non-
Controlling Interest (“NCI”) and other components of equity. Any resulting gain or loss is recognised in profit or loss. Any interest 
retained in the former subsidiary is measured at fair value when control is lost.  

consolidation    
iv. Transactions eliminated on consolidation
iv. Transactions eliminated on 
consolidation
consolidation
iv. Transactions eliminated on 
iv. Transactions eliminated on 

Intra-group balances and transactions, and any unrealised income and expenses arising from intra-group transactions, are eliminated 
in preparing the consolidated financial statements. Unrealised losses are eliminated in the same way as unrealised gains, but only to 
the extent that there is no evidence of impairment. 

v. Separate financial statements of the Company    
v. Separate financial statements of the Company
v. Separate financial statements of the Company
v. Separate financial statements of the Company

In the separate financial statements of the Company, interests in subsidiaries, associates and joint ventures are accounted for at cost. 

B. Interests in equity accounted investees    
B. Interests in equity accounted investees
B. Interests in equity accounted investees
B. Interests in equity accounted investees
The Group’s interests in equity accounted investees may comprise interests in associates and joint ventures. 

Associates  are  those  entities  in  which  the  Group  has  significant  influence,  but  not  control  or  joint  control,  over  the  financial  and 
operating policies. A joint venture is an arrangement in which the Group has joint control, whereby the Group has rights to the net 
assets of the arrangement, rather than rights to its assets and obligations for its liabilities.  

Interests  in  associates and  joint  ventures  are  accounted  for  using  the  equity  method. They  are  initially  recognised  at cost,  which 
includes transaction costs. Subsequent to initial recognition, the consolidated financial statements include the Group’s share of the 
profit or loss and OCI of equity accounted investees, until the date on which significant influence or joint control ceases. 

C. Foreign currency
C. Foreign currency    
C. Foreign currency
C. Foreign currency
Foreign currency assets and liabilities (applicable to the Conister Card Services division only) are translated at the rates of exchange 
ruling at the reporting date. Transactions during the year are recorded at rates of exchange in effect when the transaction occurs. The 
exchange movements are dealt with in the income statement.  

D. Interest 
D. Interest     
D. Interest 
D. Interest 
Interest income and expense are recognised in profit or loss using the effective interest rate method.  

Effective interest rate 
The effective interest rate is the rate that exactly discounts estimated future cash payments or receipts of the financial instrument to 
the net carrying amount of the financial asset or financial liability. The discount period is the expected life or, where appropriate, a 
shorter period. The calculation includes all amounts receivable or payable by the Group that are an integral part of the overall return, 
including origination fees, loan incentives, broker fees payable, estimated early repayment charges, balloon payments and all other 
premiums  and  discounts.  It  also  includes  direct  incremental  transaction  costs  related  to  the  acquisition  or  issue  of  the  financial 
instrument. The calculation does not consider future credit losses.    

Page | 69  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

38. Significant accounting policies (continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
D. Interest (continued)
D. Interest (continued)    
D. Interest (continued)
D. Interest (continued)
Effective interest rate (continued) 
Once a financial asset or a group of similar financial assets has been written down as a result of impairment, subsequent interest 
income  continues to  be  recognised using  the original effective  interest  rate applied  to  the  reduced carrying  value of  the  financial 
instrument. 

E. Fees and
commission income    
E. Fees and    commission income
commission income
commission income
E. Fees and
E. Fees and
Fees and commission income other than that directly related to the loans is recognised over the period for which service has been 
provided or on completion of an act to which the fees relate.  

Income in respect of fiduciary deposit taking is recognised on an accruals basis. 

F. Programme costs    
F. Programme costs
F. Programme costs
F. Programme costs
Programme costs are direct expenditure incurred in relation to prepaid card programmes. The costs are recognised over the period 
in which income is derived from operating the programmes.  

G. G. G. G. Leases
Leases    
Leases
Leases
Leases in which the Group is a lessor    
Leases in which the Group is a lessor
Leases in which the Group is a lessor
Leases in which the Group is a lessor
Finance leases and HP contracts
Finance leases and HP contracts    
Finance leases and HP contracts
Finance leases and HP contracts
When assets are subject to a finance lease or HP contract, the present fair value of the lease payments is recognised as a receivable. 
The difference between the gross receivable and the present value of the receivable is recognised as unearned finance income. HP 
and lease income is recognised over the term of the contract or lease reflecting a constant periodic rate of return on the net investment 
in the contract or lease. Initial direct costs, which may include commissions and legal fees directly attributable to negotiating and 
arranging the contract or lease, are included in the measurement of the net investment of the contract or lease at inception. 

Operating leases
Operating leases    
Operating leases
Operating leases
Assets held for operating leases are presented on the Statement of Financial Position according to the nature of the asset. Lease 
income is recognised over the lease term on a straight-line basis. 

Leases in which the Group is a lessee
Leases in which the Group is a lessee    
Leases in which the Group is a lessee
Leases in which the Group is a lessee
Operating leases
Operating leases    
Operating leases
Operating leases
Leases in which a significant portion of the risks and rewards of ownership are retained by the lessor are classified as operating 
leases. Payments made under operating leases (net of any incentives received from the lessor) are charged to the income statement 
on a straight-line basis over the period of the lease.  

H. Income tax    
H. Income tax
H. Income tax
H. Income tax
Current and deferred taxation 
Current taxation relates to the estimated corporation tax payable in the current financial year.  Deferred taxation is provided in full, 
using the liability method, on timing differences arising between the tax bases of assets and liabilities and their carrying amounts in 
the  consolidated  financial  statements.  Deferred  taxation  is  determined  using  tax  rates  (and  laws)  that  have  been  enacted  or 
substantially enacted by the reporting date and are expected to apply when the related deferred tax is realised. Deferred taxation 
assets are recognised to the extent that it is probable that future taxable profit will be available against which the temporary differences 
can be utilised.  

financial liabilities    
assets and    financial liabilities
I. Financial assets and
I. Financial 
financial liabilities
financial liabilities
assets and
assets and
I. Financial 
I. Financial 
i. Recognition and initial measurement
i. Recognition and initial measurement    
i. Recognition and initial measurement
i. Recognition and initial measurement
The Group initially recognises loans and advances, deposits, debt securities issued and subordinated liabilities on the date on which 
they are originated. All other financial instruments including regular-way purchases and sales of financial assets) are recognised on 
the trade date, which is the date on which the Group becomes party to the contractual provisions of the instrument. 

A financial asset or financial liability is measured initially at fair value plus, for an item not at FVTPL, transaction costs that are directly 
attributable to its acquisition or issue. 

Page | 70  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

38. Significant accounting policies (continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
I. Financial 
financial liabilities (continued)    
assets and    financial liabilities (continued)
I. Financial assets and
financial liabilities (continued)
financial liabilities (continued)
assets and
assets and
I. Financial 
I. Financial 
ii. Classification
ii. Classification    
ii. Classification
ii. Classification
Financial assets
Financial assets    
Financial assets
Financial assets
On initial recognition, a financial asset is classified as measured at: amortised cost, FVOCI or FVTPL. 

 
 

 

 

A financial asset is measured at amortised cost if it meets both of the following conditions and is not designated as at FVTPL: 

the asset is held within a business model whose objective is to hold assets to collect contractual cash flows; and 
the contractual terms of the financial asset give rise on specified dates to cash flows that are SPPI. 

A debt instrument is measured at FVOCI only if it meets both of the following conditions and is not designated as FVTPL: 

the asset is held within a business model whose objective is achieved by both collecting contractual cash flows and selling 
financial assets; and 
the contractual terms of the financial asset give rise on specified dates to cash flows that are SPPI. 

On  initial  recognition  of  an  equity  investment  that  is  not  held  for  trading,  the  Group  may  irrevocably  elect  to  present  subsequent 
changes in fair value in OCI. This election is made on an investment-by-investment basis. 

All other financial assets are classified as measured at FVTPL. 

In addition, on initial recognition, the Group may irrevocably designate a financial asset that otherwise meets the requirements to be 
measured at amortised cost or at FVOCI as at FVTPL if doing so eliminates or significantly reduces an accounting mismatch that 
would otherwise arise. 

Business model assessment    
Business model assessment
Business model assessment
Business model assessment
The group makes an assessment of the objective of a business model in which an asset is held at a portfolio level because this best 
reflects the way the business is managed and information provided to management. 

Assessment of whether contractual cash flows are solely payments of principal and 
interest    
Assessment of whether contractual cash flows are solely payments of principal and interest
interest
interest
Assessment of whether contractual cash flows are solely payments of principal and 
Assessment of whether contractual cash flows are solely payments of principal and 
For the purposes of this assessment, ‘principal’ is defined as the fair value of the financial asset on initial recognition. ‘Interest’ is 
defined as consideration for the time value of money and for the credit risk associated with the principal amount outstanding during a 
particular period of time and for other basic lending risks and costs (e.g. liquidity risk and administrative costs), as well as profit margin. 
In assessing whether the contractual cash flows are SPPI, the Group considers the contractual terms of the instrument. This includes 
assessing whether the financial asset contains a contractual term that could change the timing or amount of contractual cash flows 
such that it would not meet this condition. 

Reclassifications
Reclassifications    
Reclassifications
Reclassifications
Financial assets are not reclassified subsequent to their initial recognition, except in the period after the Group changes its business 
model for managing financial assets. 

Financial liabilities 
Financial liabilities     
Financial liabilities 
Financial liabilities 
The Group classifies its financial liabilities, other than financial guarantees and loan commitments, as measured at amortised cost. 

iii. Derecognition    
iii. Derecognition
iii. Derecognition
iii. Derecognition
Financial assets
Financial assets    
Financial assets
Financial assets
The Group derecognises a financial asset when the contractual rights to the cash flows from the financial asset expire, or when it 
transfers the rights to receive the contractual cash flows in a transaction in which substantially all of the risks and rewards of ownership 
of the financial asset are transferred or in which the Group neither transfers nor retains substantially all of the risks and rewards of 
ownership and it does not retain control of the financial asset. 

On derecognition of a financial asset, the difference between the carrying amount of the asset (or the carrying amount allocated to 
the portion of the asset derecognised) and the sum of (i) the consideration received (including any new asset obtained less any new 
liability assumed) and (ii) any cumulative gain or loss that had been recognised in OCI is recognised in profit or loss. 

Page | 71  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

38. Significant accounting policies (continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
I. Financial 
financial liabilities (continued)    
assets and    financial liabilities (continued)
I. Financial assets and
financial liabilities (continued)
financial liabilities (continued)
assets and
assets and
I. Financial 
I. Financial 
iii. Derecognition (continued)    
iii. Derecognition (continued)
iii. Derecognition (continued)
iii. Derecognition (continued)

Financial liabilities
Financial liabilities    
Financial liabilities
Financial liabilities
The Group derecognises a financial liability when its contractual obligations are discharged or cancelled, or expire. 

iv. Modifications    
iv. Modifications
iv. Modifications
iv. Modifications
Financi
al assets     
Financial assets 
al assets 
al assets 
Financi
Financi
If the terms of a financial asset are modified, then the Group evaluates whether the cash flows of the modified asset are substantially 
different.  

If the cash flows are substantially different, the contractual rights to cash flows from the original financial asset are deemed to have 
expired. In this case, the original financial asset is derecognised and a new financial asset is recognised at fair value plus any eligible 
transaction costs. 

If the cash flows are modified when the borrower is in financial difficulties, then the objective of the modification is usually to maximise 
recovery of the original contractual terms rather than to originate a new asset with substantially different terms. If the Group plans to 
modify a financial asset in a way that would result in forgiveness of cash flows, then it first considers whether a portion of the asset 
should be written off before the modification takes place. This approach impacts the result of the quantitative evaluation and means 
that the derecognition criteria are not usually met in such cases. 

If the modification of a financial asset measured at amortised cost or FVOCI does not result in derecognition of the financial asset, 
then the Group first recalculates the gross carrying amount of the financial asset using the original effective interest rate of the asset 
and recognises the resulting adjustment as a modification gain or loss in profit or loss. Any costs or fees incurred and fees received 
as part of the modification adjust the gross carrying amount of the modified financial asset and are amortised over the remaining term 
of the modified financial asset. If such modification is carried out because of financial difficulties of the borrower, then the gain or loss 
is presented together with impairment losses. In other cases, it is presented as interest income calculated using the effective interest 
rate method. 

Financial liabilities
Financial liabilities    
Financial liabilities
Financial liabilities
The Group derecognises a financial liability when its terms are modified and the cash flows of the modified liability are substantially 
different. In this case, a new financial liability based on the modified terms is recognised at fair value. The difference between the 
carrying  amount  of  the  financial  liability  derecognised  and  consideration  paid  is  recognised  in  profit  or  loss.  Consideration  paid 
includes non-financial assets transferred, if any, and the assumption of liabilities, including the new modified financial liability. 

If the modification of a financial liability is not accounted for as derecognition, then the amortised cost of the liability is recalculated by 
discounting the modified cash flows at the original effective interest rate and the resulting gain or loss I s recognised in profit or loss. 
Any costs and fee incurred are recognised as an adjustment of the carrying amount of the liability and amortised over the remaining 
term of the modified financial liability by re-computing the effective interest rate on the instrument. 

v. Offsetting
v. Offsetting    
v. Offsetting
v. Offsetting
Financial assets and financial liabilities are offset and the net amount presented in the statement of financial position when, and only 
when, the Group currently has a legally enforceable right to set off the amounts and it intends either to settle them on a net basis or 
to realise the asset and settle the liability simultaneously. 

Income and expenses are presented on a net basis only when permitted under IFRS, or for gains and losses arising from a group of 
similar transactions such as in the Group’s trading activity. 

vi. Fair value measurement    
vi. Fair value measurement
vi. Fair value measurement
vi. Fair value measurement
‘Fair value’ is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market 
participants at the measurement date in the principal or, in its absence, the most advantageous market to which the Group has access 
at the date. The fair value of a liability reflects its non-performance risk. 

The  Group  recognises  transfers  between  levels  of  the  fair value  hierarchy as of  the  end of  the  reporting period  during which  the 
change has occurred. 

The Group measures fair values using the following fair value hierarchy, which reflects the significance of the inputs used in making 
the measurements: - 

  Level 1: inputs that are quoted market prices (unadjusted) in active markets for identical instruments; 

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ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

Significant accounting policies (continued)    
38. 38. 38. 38. Significant accounting policies (continued)
Significant accounting policies (continued)
Significant accounting policies (continued)
I. Financial 
financial liabilities (continued)    
assets and    financial liabilities (continued)
I. Financial assets and
financial liabilities (continued)
financial liabilities (continued)
assets and
assets and
I. Financial 
I. Financial 
vi. Fair value measurement (continued)    
vi. Fair value measurement (continued)
vi. Fair value measurement (continued)
vi. Fair value measurement (continued)

  Level 2: inputs other than quoted prices included within Level 1 that are observable either directly (i.e. as prices) or indirectly (i.e. 
derived  from  prices).  This  category  includes  instruments  valued  using:  quoted  market  prices  in  active  markets  for  similar 
instruments; quoted prices for identical or similar instruments in markets that are considered less than active; or other valuation 
techniques in which all significant inputs are directly or indirectly observable from market data; and 

  Level 3: inputs that are unobservable. This category includes all instruments for which the valuation technique includes inputs not 
based  on  observable  data  and  the  unobservable  inputs  have  a  significant  effect  on  the  instrument’s  valuation.  This  category 
includes instruments that are valued based on quoted prices for similar instruments for which significant unobservable adjustments 
or assumptions are required to reflect differences between the instruments. 

The fair values of financial assets and financial liabilities that are traded in active markets are based on quoted market prices or dealer 
price quotations. For all other financial instruments, the Group determines fair values using other valuation techniques. 

For financial instruments that trade infrequently and have little price transparency, fair value is less objective, and requires varying 
degrees  of  judgement  depending  on  liquidity,  concentration,  uncertainty  of  market  factors,  pricing  assumptions  and  other  risks 
affecting the specific instrument.  

vii. Impairment
vii. Impairment    
vii. Impairment
vii. Impairment
A financial instrument that is not credit-impaired on initial recognition is classified in ‘Stage 1’ and has its credit risk continuously monitored by 
the Group.   

If a significant increase in credit risk (“SICR”) since initial recognition is identified, the financial instrument is moved to ‘Stage 2’ but is not yet 
deemed to be credit-impaired.  

  An SICR is always deemed to occur when the borrower is 30 days past due on its contractual payments.  If the Group becomes 
aware ahead of this time of non-compliance or financial difficulties of the borrower, such as loss of employment, avoiding contact 
with the Group then an SICR has also deemed to occur.  

  A  receivable  is  always  deemed  to  be  in default and credit-impaired  when the  borrower  is  90 days  past  due  on  its  contractual 
payments or earlier if the Group becomes aware of severe financial difficulties such as bankruptcy, IVA, abscond or disappearance, 
fraudulent activity and other similar events.  

If the financial instrument is credit-impaired, the financial instrument is then moved to ‘Stage 3’. Financial instruments in Stage 3 have their 
ECL measured based on expected credit losses on an undiscounted lifetime basis. 

The Group measures loss allowances at an amount equal to lifetime ECL, except for debt investment securities that are determined to have 
low credit risk at the reporting date for which they are measured as a 12-month ECL. Loss allowances for lease receivables are always 
measured at an amount equal to lifetime ECL. 

12-month ECL are the portion of ECL that result from default events on a financial instrument that are possible within the 12 months after the 
reporting date. Financial instruments for which a 12-month ECL is recognised are referred to as ‘Stage 1 financial instruments’. 

Life-time ECL are the ECL that result from all possible default events over the expected life of a financial instrument. Financial instruments for 
which a lifetime ECL is recognised but which are not credit-impaired are referred to as ‘Stage 2 financial instruments’. 

Measurement of ECL
Measurement of ECL    
Measurement of ECL
Measurement of ECL
After a detailed review, the Group devised and implemented an impairment methodology in light of the IFRS 9 requirements outlined 
above noting the following: 

  The ECL was derived by reviewing the Group’s loss rate and loss given default over the past 8 years by product and geographical 

segment. 

  The Group has assumed that the future economic conditions will broadly mirror the current environment and therefore the forecasted 

loss levels in the next 3 years will match the Group’s experience in recent years. 

  For portfolios where the Group has never had a default in its history or has robust credit enhancements such as credit insurance or 
default indemnities for the entire portfolio, then no IFRS 9 provision is made.  At year-end, 37.9% had such credit enhancements 
(2017: 41.7%). 
If  the  Group  holds  objective  evidence  through  specifically  assessing  a  credit-impaired  receivable  and  believes  it  will  go  on  to 
completely recover the debt due to the collateral held and cooperation with the borrower, then no IFRS 9 provision is made 

 

Page | 73  

 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

(continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies 
(continued)
(continued)
38. Significant accounting policies 
38. Significant accounting policies 
I. Financial 
financial liabilities (continued)    
assets and    financial liabilities (continued)
I. Financial assets and
financial liabilities (continued)
financial liabilities (continued)
assets and
assets and
I. Financial 
I. Financial 
vii. Impairment (continued)
vii. Impairment (continued)    
vii. Impairment (continued)
vii. Impairment (continued)
Measurement of ECL (continued)    
Measurement of ECL (continued)
Measurement of ECL (continued)
Measurement of ECL (continued)

ECL are probability-weighted estimate of credit losses. They are measured as follows: 

 

 

financial assets that are not credit-impaired at the reporting date: as the present value of all cash shortfalls (i.e. the difference between 
the cash flows due to the entity in accordance with the contract and the cash flows that the Group expects to receive); 
financial assets that are credit-impaired at the reporting date: as the difference between the gross carrying amount and the present 
value of estimated future cash flows; and 

undrawn  loan  commitments:  as  the  present  value  of  the  difference  between  the  contractual  cash  flows  that  are  due  to  the  Group  if  the 
commitment is drawn down and the cash flows that the Group expects to receive. 

Credit
impaired financial assets    
Credit----impaired financial assets
impaired financial assets
impaired financial assets
Credit
Credit
At each reporting date, the Group assesses whether financial assets carried at amortised cost and debt financial assets carried at 
FVOCI,  and  finance  lease  receivables  are  credit-impaired  (referred  to  as  ‘Stage  3  financial  assets’).  A  financial  asset  is  ‘credit-
impaired’ when one or more events that have a detrimental impact on the estimated future cash flows of the financial asset have 
occurred. 

Evidence that a financial asset is credit-impaired includes the following observable date: 

  significant financial difficulty of the borrower or issuer; 
  a breach of contract such as a default or past due event; 
 
 
 

the restructuring of a loan or advance by the Group on terms that the Group would not consider otherwise; 
it is becoming probable that the borrower will enter bankruptcy or other financial reorganisation; or 
the disappearance of an active market for a security because of financial difficulties. 

A loan that has been renegotiated due to a deterioration in the borrower’s condition is usually considered to be credit-impaired unless 
there is evidence that the risk of not receiving contractual cash flows has reduced significantly and there are no other indicators of 
impairment.  In  addition,  a  retail  loan  that  is overdue  for  90 days  or  more  is considered  credit-impaired even  when  the  regulatory 
definition of default is different. 

In making an assessment of whether an investment in sovereign debt is credit impaired, the Group considers the following factors: 

 
 
 
 

the market’s assessment of creditworthiness as reflected in the bond yields; 
the rating agencies’ assessments of creditworthiness; 
the country’s ability to access the capital markets for new debt issuance; 
the  probability  of  debt  being  restructured,  resulting  in  holders  suffering  losses  through  voluntary  or  mandatory  debt 
forgiveness; 

  The international support mechanisms in place to provide the necessary support as ‘lender of last resort’ to that country, as 
well as the intention, reflected in public statements, of governments and agencies to use those mechanisms. This includes 
an assessment of the depth of those mechanisms and, irrespective of the political intent, whether there is the capacity to 
fulfil the required criteria. 

Presentation of allowance for ECL in the statement of financial position
Presentation of allowance for ECL in the statement of financial position    
Presentation of allowance for ECL in the statement of financial position
Presentation of allowance for ECL in the statement of financial position
Loss allowances for ECL are presented in the statement of financial position as follows: 

financial assets measured at amortised cost: as a deduction from the gross carrying amount of the assets 
loan commitments: generally, as a provision; 

 
 
  debt instruments measured at FVOCI: no loss allowance is recognised in the statement of financial position because the 
carrying amount of these assets is their fair value. However, the loss allowance is disclosed and is recognised in the fair 
value reserve. 

WriteWriteWriteWrite----offoffoffoff    
Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of recovering a financial 
asset in its entirety or a portion thereof. This is generally the case when the Group determines that the borrower does not have assets 
or sources of income that could generate sufficient cash flows to repay the amounts subject to the write-off. This assessment is carried 
out at the individual asset level. 

Recoveries of amounts previously written off are included in ‘impairment losses on financial instruments’ in the statement of profit or 
loss and OCI. 

Financial assets that are written off could still be subject to enforcement activities in order to comply with the Group’s procedures for 
recovery of amounts due. 

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ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

38. Significant accounting policies (continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
J. Cash and cash equivalents
J. Cash and cash equivalents    
J. Cash and cash equivalents
J. Cash and cash equivalents
For  the purpose  of  the  statement of cash  flows,  cash  and cash  equivalents  comprise  cash  and  deposit balances  with  an  original 
maturity date of three months or less.  

K. Loans and advances
K. Loans and advances    
K. Loans and advances
K. Loans and advances
Loans and advances’ captions in the statement of financial position include: 

 

 

loans and advances measured at amortised cost (see 38 (I)). They are initially measured at fair value plus incremental direct 
transaction costs, and subsequently at their amortised cost using the effective interest method; and 
finance lease receivable (see 38 (G)). 

L. Property, plant and equipment 
L. Property, plant and equipment     
L. Property, plant and equipment 
L. Property, plant and equipment 
Items of property, plant and equipment are stated at historical cost less accumulated depreciation (see below). Historical cost includes 
expenditure that is directly attributable to the acquisition of the items.  

The assets’ residual values and useful economic lives are reviewed, and adjusted if appropriate, at each reporting date. An asset’s 
carrying amount is written down immediately to its recoverable amount if the asset’s carrying amount is greater than its estimated 
recoverable amount.  

When parts of an item of property, plant and equipment have different useful lives, those components are accounted for as separate 
items of property, plant and equipment.  

Depreciation and amortisation
Depreciation and amortisation    
Depreciation and amortisation
Depreciation and amortisation
Assets are depreciated or amortised on a straight-line basis, so as to write off the book value over their estimated useful lives.  The 
useful lives of property, plant and equipment and intangibles are as follows: -  

Property, plant and equipment 
Leasehold improvements 
IT equipment 
Motor vehicles 
Furniture and equipment 

M. Intangible assets and goodwill
M. Intangible assets and goodwill    
M. Intangible assets and goodwill
M. Intangible assets and goodwill
i. Goodwill     
i. Goodwill 
i. Goodwill 
i. Goodwill 

to expiration of the lease 
4-5 years 
2.5 years 
4 -10 years 

Goodwill that arises on the acquisition of subsidiaries is measured at cost less accumulated impairment losses. 

ii. Software
ii. Software    
ii. Software
ii. Software
Software acquired by the Group is measured at cost less accumulated amortisation and any accumulated impairment losses.  

Expenditure on internally developed software is recognised as an asset when the Group is able to demonstrate: that the product is 
technically feasible, its intention and ability to complete the development and use the software in a manner that will generate future 
economic  benefits,  and  that  it  can  reliably  measure  the  costs  to  complete  the  development.  The  capitalised  costs  of  internally 
developed  software  include  all  costs  directly  attributable  to  developing  the  software  and  capitalised  borrowing  costs,  and  are 
amortised  over  its  useful  life.  Internally  developed  software  is  stated  at  capitalised  cost  less  accumulated  amortisation  and  any 
accumulated impairment losses. 

Software is amortised on a straight-line basis in profit or loss over its estimated useful life, from the date on which it is available for 
use.  Amortisation methods, useful lives and residual values are reviewed at each reporting date and adjusted if appropriate. 

iii. Other
iii. Other    
iii. Other
iii. Other
Intangible assets that are acquired by an entity and having finite useful lives are measured at cost less accumulated amortisation and 
any accumulated impairment losses.  

Intangible  assets  acquired  as part  of  a business combination,  with an  indefinite  useful  live  are  measured at  fair  value. Intangible 
assets with indefinite useful lives are not amortised but instead are subject to impairment testing at least annually.  

Page | 75  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

olicies (continued)    
38. Significant accounting policies (continued)
38. Significant accounting p
olicies (continued)
olicies (continued)
38. Significant accounting p
38. Significant accounting p
M. Intangible assets and goodwill (continued)
M. Intangible assets and goodwill (continued)    
M. Intangible assets and goodwill (continued)
M. Intangible assets and goodwill (continued)
iii. Other (continued)    
iii. Other (continued)
iii. Other (continued)
iii. Other (continued)

The useful lives of intangibles are as follows: - 

Customer contracts and lists 
Business intellectual property rights 
Website development costs 
Software 

financial assets    
N. Impairment of non----financial assets
N. Impairment of non
financial assets
financial assets
N. Impairment of non
N. Impairment of non

to expiration of the agreement 
4 years - indefinite 
indefinite 
5 years 

At  each  reporting  date,  the  Group  reviews  the  carrying  amounts  of  its  non-financial  assets  (other  than  deferred  tax  assets)  to 
determine whether there is any indication of impairment. If any such indication exists, the asset’s recoverable amount is estimated. 
Goodwill is tested annually for impairment. 

For impairment testing, assets are group together into the smallest group of assets that generates cash inflows from continuing use 
that is largely independent of the cash inflows of other assets or Cash Generating Units (“CGUs”). Goodwill arising from a business 
combination is allocated to CGUs or groups of CGUs that are expected to benefit from the synergies of the combination. 

The ‘recoverable amount’ of an asset or CGU is the greater of its value in use and its fair value less cost to sell. ‘Value in use’ is based 
on  the  estimated  future  cash  flows,  discounted  to  their  present  value  using  a  pre=tax  discount  rate  that  reflects  current  market 
assessments of the time value of money and the risks specific to the asset or CGU. 

An impairment loss is recognised if the carrying amount of an asset or CGU exceeds its recoverable amount. 

The Group’s corporate assets do not generate separate cash inflows and are used by more than one CGU. Corporate assets are 
allocated to CGUs on a reasonable and consistent basis and tested for impairment as part of the testing of the CGUs to which the 
corporate assets are located. 

Impairment losses are recognised in profit or loss. They are allocated first to reduce the carrying amount of any goodwill allocated to 
the CGU, and then to reduce the carrying amounts of the other assets in the CGU on a pro rata basis. 

An impairment loss in respect of goodwill is not reversed. For other assets, an impairment loss is reversed only to the extent that the 
asset’s carrying amount does not exceed the carrying amount that would have been determined, net of depreciation or amortisation, 
if no impairment loss had been recognised. 

O. Deposits, debt securities issued and subordinated liabilities    
O. Deposits, debt securities issued and subordinated liabilities
O. Deposits, debt securities issued and subordinated liabilities
O. Deposits, debt securities issued and subordinated liabilities

Deposits, debt securities issued and subordinated liabilities are the Group’s sources of debt funding. 

The Group classifies capital instruments as financial liabilities or equity instruments in accordance with the substance of the 
contractual terms of the instruments.  

Deposits, debt securities issued and subordinated liabilities are initially measured at fair value minus incremental direct transaction 
costs, and subsequently measured at their amortised cost using the effective interest method. 

Fiduciary deposits received on behalf of clients by way of a fiduciary agreement are placed with external parties and are not 
recognised in the statement of financial position.  

The Group could receive funds for its prepaid card activities. These funds would be held in a fiduciary capacity for the sole purpose 
of making payments as and when card-holders utilise the credit on their cards and therefore would not be recognised in the statement 
of financial position.  

Page | 76  

 
 
 
    
 
    
    
 
 
 
 
 
 
    
    
 
 
 
    
 
 
    
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

38. Significant accounting policies (continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
P. Employee benefits    
P. Employee benefits
P. Employee benefits
P. Employee benefits

i. Long term employee benefits    
i. Long term employee benefits
i. Long term employee benefits
i. Long term employee benefits

Pension obligations    
Pension obligations
Pension obligations
Pension obligations
The Group has pension obligations arising from both defined benefit and defined contribution pension plans.  

A defined contribution pension plan is one under which the Group pays fixed contributions into a separate fund and has no legal or 
constructive  obligations  to  pay  further  contributions.  Defined  benefit  pension  plans  define  an  amount  of  pension  benefit  that  an 
employee will receive on retirement, usually dependent on one or more factors such as age, years of service and remuneration.  

Under the defined benefit pension plan, in accordance with IAS 19 Employee benefits, the full service cost for the period, adjusted for 
any changes to the plan, is charged to the income statement. A charge equal to the expected increase in the present value of the 
plan liabilities, as a result of the plan liabilities being one year closer to settlement, and a credit reflecting the long-term expected 
return on assets based on the market value of the scheme assets at the beginning of the period, is included in the income statement. 

The statement of financial position records as an asset or liability as appropriate, the difference between the market value of the plan 
assets and the present value of the accrued plan liabilities. The difference between the expected return on assets and that achieved 
in the period, is recognised in the income statement in the year in which they arise. The defined benefit pension plan obligation is 
calculated by independent actuaries using the projected unit credit method and a discount rate based on the yield on high quality 
rated corporate bonds.   

The Group’s defined contribution pension obligations arise from contributions paid to a Group personal pension plan, an ex gratia 
pension plan, employee personal pension plans and employee co-operative insurance plans. For these pension plans, the amounts 
charged to the income statement represent the contributions payable during the year.  

ii. Share
based compensation    
ii. Share----based compensation
based compensation
based compensation
ii. Share
ii. Share
The Group maintains a share option programme which allows certain Group employees to acquire shares of the Group. The change 
in the fair value of options granted is recognised as an employee expense with a corresponding change in equity. The fair value of 
the options is measured at grant date and spread over the period during which the employees become unconditionally entitled to the 
options.  

At each reporting date, the Group revises its estimate of the number of options that are expected to vest and recognises the impact 
of the revision to original estimates, if any, in the income statement, with a corresponding adjustment to equity.  

The  share  option  programme  was  originally  set  up  for  Group  employees  to  subscribe  for  shares  in  Conister  Trust  Limited  (now 
Conister Bank Limited). Since the Scheme of Arrangement, the shareholders of the Bank became shareholders of the Company. The 
share option programme is now operated by the Company. The fair value is estimated using a proprietary binomial probability model. 
The  proceeds  received,  net  of  any  directly  attributable  transaction costs,  are  credited  to share  capital  (nominal value)  and  share 
premium when the options are exercised.  

Q. Share capital and reserves    
Q. Share capital and reserves
Q. Share capital and reserves
Q. Share capital and reserves

Share issue costs    
Share issue costs
Share issue costs
Share issue costs
Incremental costs that are directly attributable to the issue of an equity instrument are deducted from the initial measurement of the 
equity instruments. 

R. Earnings per share    
R. Earnings per share
R. Earnings per share
R. Earnings per share

The Group presents basic and diluted EPS data for its ordinary shares. Basic EPS is calculated by dividing the profit or loss that is 
attributable to ordinary shareholders of the Bank by the weighted-average number of ordinary shares outstanding during the period. 
Diluted EPS is determined by adjusting profit or loss that is attributable to ordinary shareholders and the weighted-average number 
of  ordinary  shares  outstanding  for  the  effects  of  all  dilutive  potential  ordinary  shares,  which  comprise  share  options  granted 
employees. 

S. Segmental reporting    
S. Segmental reporting
S. Segmental reporting
S. Segmental reporting

A segment is a distinguishable component of the Group that is engaged either in providing products or services (business segment), 
or in providing products or services within a particular economic environment (geographical segment), which is subject to risks and 
rewards that are different from those of other segments. The Group’s primary format for segmental reporting is based on business 
segments. 

Page | 77  

 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
    
ANNUAL FINANCIAL STATEMENTS 

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS 
For the year ended 31 December 2018    

38. Significant accounting policies (continued)    
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
38. Significant accounting policies (continued)
S. Segmental reporting (continued)    
S. Segmental reporting (continued)
S. Segmental reporting (continued)
S. Segmental reporting (continued)

An operating segment is a component of the Group that engages in business activities from which it may earn revenues and incur 
expenses, including revenues and expenses relating to transactions with any of the Group’s other components, whose operating 
results  are  regularly  reviewed  by  the  Group’s  chief  operating  decision  maker  (CODM)  to  make  decisions  about  resources  to  be 
allocated to the segment and assess its performance, and for which discrete financial information is available. 

Segment results are reported to the Group’s CEO (being the CODM) include items that are directly attributable to a segment as well 
as those that can be allocated on a reasonable basis. 

39. Standards issued but not yet effective
39. Standards issued but not yet effective    
39. Standards issued but not yet effective
39. Standards issued but not yet effective
A  number  of  new  standards  are  effective  for  annual  periods  beginning  after  1  January  2018  and  earlier  application  is  permitted; 
however, the Group has not early adopted the new or amended standards in preparing these consolidated financial statements. 

Standards    
Standards
Standards
Standards

IFRIC 23 Uncertainty over Income Tax Treatments (issued on 7 June 2017) 

Amendments to IFRS 9: Prepayment Features with Negative Compensation (issued on 12 October 2017) 

IFRS 16 Leases (issued on 13 January 2016) 

Effective date
Effective date
Effective date
Effective date
(accounting periods
commencing on or after)

1 January 2019 

1 January 2019 

1 January 2019 

Of those standards that are not yet effective, IFRS 16 is expected to have a material impact on the Group’s financial statements in 
the period of initial application. 

IFRS 16 Leases
IFRS 16 Leases    
IFRS 16 Leases
IFRS 16 Leases
The  Group  is  required  to adopt  IFRS  16  Leases  from  1  January  2019.  The  Group has  assessed the  estimated  impact  that  initial 
application of IFRS 16 will have on its consolidated financial statements, as described below. The actual impacts of adopting the 
standard on 1 January 2019 may change because: 

 
 

the Group has not finalised the testing and assessment of controls over its new IT systems; and 
the new accounting policies are subject to change until the Group presents its first financial statements that include the date 
of initial application. 

IFRS  16  introduces  a  single,  on-balance  sheet  lease  accounting  model  for  lessees.  A  lessee  recognises  a  right-of  use  asset 
representing its right to use the underlying asset and a lease liability representing its obligation to make lease payments. These are 
recognition exemptions for short-term leases and leases of low-value items. Lessor accounting remains similar to the current standard 
– i.e. lessors continue to classify leases as finance or operating leases. 

IFRS 16 replaces existing leases guidance, including IAS 17 Leases, IFRIC 4 Determining whether an Arrangement contains a Lease, 
SIC-15 Operating Leases – Incentives and SIC-27 Evaluating the Substance of Transactions Involving the Legal Form of a Lease. 

Leases in which the Group is a lessor 
No significant impact is expected for leases in which the Group is a lessor. 

Leases in which the Group is a lessee 
The group will recognise new assets and liabilities for its office premises and car parking sub-leases. As at 31 December 2018, the 
Group’s future minimum lease payments under non-cancellable operating leases amounted to £1,166,000 (2017: 1,192,000) on an 
undiscounted basis. (see note 34) 

Transition
Transition    
Transition
Transition
The Group plans to apply IFRS 16 initially on 1 January 2019, using the modified retrospective approach. Therefore, the cumulative 
effect of adopting IFRS 16 will be recognised as an adjustment to the opening balance of retained earnings at 1 January 2019, with 
no restatement of comparative information. 

The Group plans to apply the practical expedient to grandfather the definition of a lease on transition. This means that it will apply 
IFRS 16 to all contracts entered into before 1 January 2019 and identified as leases in accordance with IAS 17 and IFRIC 4. 

Page | 78  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL FINANCIAL STATEMENTS 

SHAREHOLDER NOTES 

Page | 79  

 
 
 
Clarendon House 
Victoria Street 
Douglas 
Isle of Man 
IM1 2LN 

Tel: (01624) 694694 
Fax: (01624) 624278 

www.mfg.im    
www.mfg.im
www.mfg.im
www.mfg.im

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