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Moneysupermarket.com Group

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FY2022 Annual Report · Moneysupermarket.com Group
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Helping households 
save money

Annual Report and Accounts 2022

 
 
 
 
 
 
Moneysupermarket Group is a successful 
business driven by a clear purpose of  
helping households save money

It’s never been more important for 
people to save money and we are at 
the forefront of helping households 
across the UK save a total of 
£1.8bn on their costs.

Peter Duffy
Chief Executive Officer

» Read more on pages 10 and 11

What we do

The Group operates a tech-led savings platform 
and leading UK brands including price comparison 
sites, cashback and a consumer finance content 
led brand. 

Our purpose is to help households save money by 
giving them access to free online tools that enable 
them to compare and switch products. We operate 
a marketplace business model, matching consumers 
to providers in an efficient way for both sides. 
Consumers can come to a single site, answer a 
simple question set and let us do the work of 
providing them with a wide choice of relevant 
products. For providers it is a cost-effective and 
flexible way to access millions of customers. 

How we have made a difference this year

Lisa’s story
We strive to deliver to our 
customers products and 
services that we feel can 
have a real benefit...
I find it to be incredibly meaningful knowing that the work I do can be 
intrinsically connected to benefit us all, from our friends, to our family 
and to all of us as customers. 

» More details on page 28.

Kit’s story
Our work has felt 
very rewarding... 
With the onset of the cost of living crisis, MSE can play a very 
important role as a trusted source of advice for consumers... 
it has given the best possible advice to its users – particularly 
those most affected by the cost of living crisis. 

» More details on page 27.

Contents
Strategic Report
02  Highlights
04  At a Glance
06 
08  Chair’s Statement
10 

Investment Case

 Chief Executive Officer’s 
Review 

12  Our Market and Trends
16  Business Model
18  Our Strategy
23 
29 

 Strategy in Action
 Section 172 of the 
Companies Act 2006 – 
Stakeholder Engagement

36  Sustainability
54  Financial Review 
60 

 Viability Statement for 
the 2022 Annual Report

62  Risk Management
 Principal Risks 
66 
and Uncertainties

Governance
68 

 Chair’s Introduction 
to Governance 
70  Board of Directors
72 

 Corporate Governance 
Statement 
 Employee Champion 
Report
 Nomination Committee 
Report

83 

85 

89  Audit Committee Report 
94 

 Risk and Sustainability 
Committee Report
 Remuneration 
Committee Report

97 

118  Directors’ Report
123   Statement of Directors’ 
Responsibilities in 
respect of the Annual 
Report and the 
Financial Statements

172  Glossary
173  Shareholder Information
IBC  2023 Financial Calendar

Financial Statements
124  Independent Auditor’s 

Report

132   Consolidated Statement 
of Comprehensive 
Income

133   Consolidated Statement 
of Financial Position
134   Consolidated Statement 
of Changes in Equity
135   Consolidated Statement 

of Cash Flows

136   Changes in liabilities 

from financing activities

137   Notes to the 

Consolidated Financial 
Statements

166  Company Balance Sheet
167   Company Statement 
of Changes in Equity
168   Notes to the Company 

Financial Statements

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

01

Strategic Report 
Highlights

2022 overview

Consistent strategic execution and strong results. 

Revenue by segment

Insurance

Travel

Money

£172.0m

2021: £158.7m

£14.9m

2021: £4.1m

£103.3m

2021: £75.2m

Cashback

Home Services

£57.6m

2021: £10.6m

£39.8m

2021: £68.1m

Operational highlights 
•  Revenue grew 22% (8% excluding Cashback) with strong 

performance in Money and Travel channels, and despite closed 
energy switching market

•  Gross margin down c.3%pts, driven by expected impact 

of Quidco consolidation

Continued progress on our transition to becoming a flexible, 
tech-led savings platform:

•  Data centralised on Google Cloud Platform, with Quidco 
following in 2023, laying foundations for customer-facing 
innovation 

•  Profit growth: adjusted EBITDA up 15% and profit after tax 

•  More efficient customer acquisition and retention capabilities 

up 33%

with enhanced PPC bidding and marketing tools 

•  Strong cash conversion with operating cashflow of £104.4m 

•  CYTI, Ice Travel Group, Quidco acquisitions on track

in the year. Net debt to adjusted EBITDA fell to 0.3x (0.6x in 2021) 

•  Full-year dividend maintained at 11.71p

•  Helped households save an estimated £1.8bn 

•  Commitment to reach Operational Net Zero by 2030; remained 

‘Beyond Carbon Neutral’, offsetting 150% of our 
carbon footprint 

•  Ranked first on the FTSE Women Leaders Review report; 

Included in the Inclusive Companies Top 50 UK Employer List

02

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Financial highlights

Revenue (£m)

Profit before tax (£m)

Adjusted EBITDA1 (£m)

£387.6m

£85.2m

£115.5m

2022

2021

2020

2019

2018

387.6

316.7

344.9

388.4

355.6

2022

2021

2020

2019

2018

85.2

70.2

87.8

116.0

106.9

2022

2021

2020

2019

2018

115.5

100.5

107.8

141.5

129.4

Basic earnings per share (p)

Adjusted basic earnings per share1 (p)

Total dividend per share (p)

12.7p

14.4p

11.71p

2022

2021

2020

2019

2018

9.8

12.7

12.9

17.7

16.2

2022

2021

2020

2019

2018

14.4

11.9

13.1

18.2

17.4

2022

2021

2020

2019

2018

11.71

11.71

11.71

11.71

11.05

1 

 Use of alternative performance measures (‘APMs’) is detailed in the Financial Review on page 54 and APMs are defined in the Glossary on page 172.

Our key verticals in 2022

Insurance

Money

Home 
Services

Travel

Cashback

Households are able to save money on a number of different insurance products including: car, 
travel, life, home and pet. Following the introduction of the FCA General Insurance Pricing 
regulation in January 2022, market switching volumes for car and home saw double-digit declines in 
H1, although this improved to single-digit declines in H2. Car and home premium inflation gained 
momentum through the year. Travel insurance grew strongly as the market continued to recover 
after the lifting of pandemic-related restrictions. 

Users of MoneySuperMarket and MoneySavingExpert are able to compare a wide range of credit 
cards, loans, savings, current accounts and mortgage products. The sites also provide users with 
access to their credit scores and provide information on topics such as mortgage affordability, the 
different types of lending and household budgeting. Money performed well in 2022. Banking 
benefited from the consistent availability of attractive promotional products, especially savings 
accounts. In borrowing there was strong demand and conversion for most of the year but 
conversion weakened in the final quarter, particularly in loans, as providers repriced their products. 

Adjusted 
EBITDA 
contribution

Revenue

£172.0m
2021: £158.7m

£98.3m
2021: £94.7m

£103.3m
2021: £75.2m

£72.3m
2021: £50.8m

Customers are able to save money on a broad range of products including broadband, energy, 
landline and mobile phones. As well as comparing on MoneySuperMarket and MoneySavingExpert, 
our switching services for energy, broadband and mobile are available on external brands via 
Decision Tech. Home Services revenue was impacted by the closure of the energy market for the 
whole year. Home comms revenue returned to growth in H2 as we annualised the loss of a large B2B 
contract in July 2021. Particularly attractive Black Friday offers drove exceptional growth in mobile.

£39.8m
2021: £68.1m

£25.2m
2021: £33.2m

TravelSupermarket and icelolly.com help people to save money on their holiday. TravelSupermarket 
merged with icelolly.com in 2021. Both brands offer holiday comparison and deals and allow 
customers to compare millions of holidays from the UK’s leading travel companies and access 
attractive deals. Performance in 2022 was strong capitalising on the return of travel after pandemic 
restrictions were lifted.

£14.9m
2021: £4.1m

£4.9m
2021: £(0.9)m

Quidco is one of the UK’s leading cashback services and helps users earn cashback on their online 
spending with thousands of brands. Quidco was acquired and added to the Group in November 2021, 
hence the prior year only represents two months‘ contribution. During the year the resurgence in travel 
offset declines in the retail and services segments. Retail moderated as the high online penetration 
experienced during the pandemic softened, with consumers returning to physical stores. Services was 
affected by the closure of the energy market and lower switching volumes in car and home insurance.

£57.6m
2021: £10.6m

£9.5m
2021: £1.8m

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

03

Strategic ReportAt a Glance

Delivered through 
our leading brands

Who we are
Moneysupermarket 
Group is a successful 
business driven 
by a clear purpose of 
helping households 
save money.

What we do
The Group operates a tech-led savings 
platform and leading UK brands including 
price comparison sites, cashback and a 
consumer finance content led brand. We 
cover a broad range of verticals including 
lnsurance, Money, Home Services and 
Travel amongst others. Our purpose is to 
help households save money on bills by 
giving them access to free online tools that 
enable them to switch and buy products. 

We operate a marketplace business model, 
matching consumers to providers in an 
efficient way for both sides. Consumers 
can come to a single site, answer a simple 
question set and let us do the work of 
providing them with a wide choice of deals 
to compare and switch to. For providers, 
it is a cost-efficient and flexible way to 
access millions of customers. 

“ The MoneySuperSeven. 

“ Cutting your costs, 

More ways to save 
more money”
MoneySuperMarket is a leading UK 
price comparison site which provides 
personalised, painless and free online 
and app-based tools to help people save 
money on their household bills.

MoneySuperMarket covers a range of 
verticals including Insurance, Money and 
Home Services. Consumers can come to 
a single site, answer a single question set 
and get a wide choice of relevant 
products to choose from.

fighting your corner”
MoneySavingExpert is one of the UK’s 
biggest consumer finance websites and 
is dedicated to cutting users’ costs and 
fighting their corner with journalistic 
research, cutting edge tools and a 
massive community all focused on 
finding deals, saving costs and 
campaigning for financial justice.

More than 8.9 million people have signed 
up to receive its weekly email which has 
deals and money-saving advice.

MoneySavingExpert.com topped the 
YouGov Recommended rankings in 
2022 – making it the UK brand most 
recommended by its users.

“One of the UK’s leading 
cashback sites” 
Quidco helps users earn cashback on 
their online spending with nearly 5,000 
popular brands. 

Quidco offers cashback with many 
household brand names across 
categories including Travel, Clothing, 
Home & DIY and Health & Beauty. 
Quidco also provides a compare service 
helping users save on their car, home 
and other insurance needs. 

04

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Our brands help households to save money, 
which is more important than ever before.

Peter Duffy
Chief Executive Officer

»  Read more from Peter on pages 10 and 11.

Estimated customer savings across 
the Moneysupermarket Group

Revenue per active user (MSM) 

£1.8bn

£16.40

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“Looking for a great 
travel deal?”
TravelSupermarket helps people save on 
their holidays. Its goal is to help users 
filter through a big range of travel deals 
and find the one that suits them more 
easily.

It compares prices on a broad range of 
holiday options including thousands of 
individual package holidays and hotels, 
low-cost and charter airlines, and car 
hire providers.

“Compare millions of 
cheap holidays”
icelolly.com is a holiday comparison 
and deals site that allows customers 
to compare holidays from the UK’s 
leading travel companies and access 
attractive deals.

It helps users compare deals on package 
holidays from a wide range of holiday 
providers. There were more than 8 
million visitors in 2022 and more than 1 
million people are subscribed to icelolly’s 
email list to receive the best deals 
straight into their inbox.

“Creating the best possible 
comparison experiences 
for businesses and users”
Decision Tech is a UK price comparison 
platform. It creates digital experiences 
that connect users with the right products 
and services when they need them. 

DecisionTech B2B solution offers 
industry-leading comparison technology 
for third party brands enabling them to 
provide a first class user experience, 
whilst maximising monetisation.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

05

 
Investment Case

Why invest in 
Moneysupermarket Group?

Moneysupermarket Group is a successful digital marketplace business, driven 
by a clear purpose of helping households save money. Our leading brands play 
a vital role for consumers and providers and are underpinned by a tech-led 
savings platform. The business model is highly profitable and asset-light.

Leading and trusted brands 

We have a Group net promoter score 
of 72. Both MoneySuperMarket and  
MoneySavingExpert are well trusted by 
consumers and enjoy high NPS scores.

Data-driven marketplace providing 
value to consumers and providers 

We offer users the tools, services and 
products to save money as they switch and 
spend, with millions of users making savings 
with Group brands in 2022. Our success-based 
fee revenue model gives our providers and 
merchants a cost-efficient way to access 
millions of users. We use data provided by 
our users to send reminders and to offer 
them the most competitive quotes for 
their circumstances.

Growth from core and new markets

Prior to COVID-19, we forecast our core 
markets (car, home, life and travel insurance, 
credit cards and loans, and energy) to grow 
at mid-single digit rates on average, and we 
expect those markets to resume similar 
growth once recovered. The Group has the 
opportunity to gain market share through 
efficient acquisition, better retention and 
cross-sell, and by expanding our offer into 
adjacent markets.

06

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Efficient capital allocation 
and strongly cash generative 

Our financial model is highly profitable, 
strongly cash generative and capital light. 
In 2021 we delivered £104.4m operating 
cash flow and paid a dividend of £62.8m.

Purpose-driven organisation 
driving benefits to society 

Our purpose is to help households save 
money and all our brands enable users to 
make significant savings on their household 
bills and purchases. MoneySavingExpert is a 
consumer champion that provides valuable 
advice to millions of UK users every year.

We are a constituent of the FTSE4Good Index, 
and are accredited as “Beyond 
Carbon Neutral”.

The Group has been included in the Inclusive 
Companies Top 50 UK companies ranking.

Strong differentiated model 

Our business fundamentals remain strong and 
differentiated. In addition to leading brands, 
we combine high margins and strong cash 
flows with an asset-light approach. We benefit 
from an efficient mix of marketing, publishing 
and B2B business models to attract a variety 
of users. Our proprietary comparison 
technologies provide flexibility as well 
as a high barrier to competitive entry.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

07

Strategic ReportChair’s Statement

Delivering with purpose  
in tough times

We have regularly considered and 
monitored the real and potential 
risks, and impacts of macroeconomic 
disruption to our end markets along 
with mitigating actions. 

We have carefully considered the 
impact of inflation, recession and 
future end market volatility, as well 
as regulatory change and data 
security breach scenarios upon the 
Group’s business, financial position 
and liquidity. 

We do not consider there to be a 
threat to the Group’s long-term 
financial resilience. 

Our Group purpose of helping 
households save money 
remains as relevant as ever.
Spiralling energy prices, the cost of living 
crisis and an uncertain economic outlook 
have only heightened the financial strain 
and uncertainty faced by UK consumers. 
I am pleased to report that the Group has 
once more helped out, saving households 
an estimated £1.8bn in 2022.

The year again saw challenging conditions 
in some of our main markets, with 
wholesale energy prices preventing 
providers from offering competitive 
tariffs that consumers could switch to and 
significant regulatory reform from our 
general insurance providers. The diversity 
of our product offering once again proved 
a major strength in the face of such 
disruption. Our Money vertical performed 
robustly, and as COVID-19 travel 
restrictions eased, our sales in travel-
related channels started to recover. Our 
brands are again rising to the challenge, 
providing useful advice and savings tips to 
millions of people; MoneySavingExpert 
has become the foremost authority in the 
energy crisis, campaigning to protect the 
most vulnerable and helping users make 
difficult decisions around their household 
bills. As ever, MoneySuperMarket helped 
millions more find the best insurance 
policies and financial products to suit 
their needs.

We also continued to deliver well against 
our strategy, finalising the rollout of our 
modernised marketing tech stack, further 
simplifying our Group tech platform and 
connecting all brands to the new data 
platform. After significant inorganic 
activity in 2021, we successfully integrated 
the new businesses and made significant 
progress in realising the benefits of these 
acquisitions. Quidco has made a strong 
initial contribution in 2022 and Ice Travel 
Group has already proven its value in 
diversifying the Group within the travel 
sector. We remain confident that both 
will be engines for future growth.

The breadth and diversity of our 
product range continue to underpin the 
performance of the Group. Even after a 
succession of shocks, including COVID-19 
and unprecedented wholesale energy 
prices, the diversified nature of our Group 
and our cash-generative financial model 
has allowed us to maintain the dividend. 
The flexibility and hard work of our 
colleagues and the leadership of the 
Executive Team have again generated 
substantial value for users 
and stakeholders.

The Board has received regular 
updates from the Executive 
Team on our operations, how 
we are supporting employees 
and the community, and the 
risks faced by our business. 

2022 was a year of good strategic progress 
and strong results. We remain confident 
in our strategy and the growth prospects 
of the business, supported by our inclusive 
and innovative culture.

Robin Freestone
Chair

08

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Our role in society
Our Group strategy is underpinned by a 
culture that encourages our people to 
consider the impact we have individually and 
as a company on stakeholders. That includes 
our focus on employee welfare and mental 
wellbeing at work, donating our time and 
efforts to raise funds for The Prince’s Trust, 
and reducing our carbon footprint in an 
effort to ensure a sustainable future for 
all. Board members ensure that they are 
regularly spending time talking directly to 
employees, in order to ensure they remain 
connected to our people. Sarah Warby, 
our Non-Executive Director and Employee 
Champion, regularly updates the Board 
on key topics raised by employees. We 
appointed Rakesh Sharma as our Employee 
Champion on 17 January 2023 and on the 
same date Sarah Warby was appointed our 
Consumer Champion to give us further 
insight into our customer experience. 

Our Board believes that active management 
of environmental, social and governance 
matters plays a key role in supporting the 
Group’s strategy and long-term 
performance and the sustainability of the 
business. This is why I am delighted to 
report that the Group remained Beyond 
Carbon Neutral in 2022 and committed to 
become Operational Net Zero by 2030. 
Whilst the impact of climate change has 
limited direct effects on our business model 
and strategy in the short to medium term, 
the Board recognises that climate change 
may present potential risks and opportunities 
to our business in the longer term. Further 
information on this, and our stakeholder 
engagement more generally, can be found 
on pages 29 to 53.

The Board
Succession planning has continued to 
be an area of focus for the Board in 2022. 
As part of this process, the Nomination 
Committee has reviewed the composition 
and tenure of the Board. For further 
information on our Board changes please 
see page 70.

Diversity continues to be a focus in our 
succession planning. Our Board collectively 
possesses a broad range of experience, 
skills and knowledge from various 
backgrounds which support the strategic 
and operational direction of the Group. 
I am proud that our Board currently 
consists of a majority of female members, 
which exceeds that recommended by the 
Hampton-Alexander Review.

Read more in the Sustainability 
Report on pages 36 to 54

Revenue (£m)

£387.6m 

Profit before tax

£85.2m 

Adjusted EBITDA (£m)

£115.5m 

Total dividend per share

11.71p 

2022 performance
Our business model again proved resilient, 
despite market headwinds, reinforcing 
our confidence for the future. While some 
of our end markets recovered as travel 
returned gradually and there was 
strong demand for financial products, 
unprecedented wholesale energy prices 
meant the energy switching market 
remained closed. In Insurance, new 
regulatory requirements suppressed 
switching during the first half of the year, 
but their influence lessened as the year 
went on and the market adapted. 

Notwithstanding these impacts the Group 
delivered an estimated £1.8bn (2021: £1.6bn) 
in consumer savings in 2022. Group 
revenue increased by 22% from £316.7m 
to £387.6m, adjusted EBITDA increased by 
15% from £100.5m to £115.5m and profit 
before tax increased by 21% to £85.2m. We 
generated good cash flow, with operating 
cash flow of £104.4m, and paid out ordinary 
dividends of £62.8m to shareholders.

Read more about our Strategy 
on pages 18 to 22

Innovating our business
Rollout of our new tech-enabled savings 
platform continued at pace in 2022. At the 
same time, we continued to develop new 
consumer propositions. We launched a 
MoneySavingExpert app that will make 
its valuable content more accessible and 
personal at a time when it is needed the 
most. We launched a new proposition from 
MoneySuperMarket that guarantees the 

cheapest car and home insurance for 
customers: this is a clearly differentiating 
promise in the Price Comparison website 
market. We made significant progress 
upgrading, integrating and unlocking 
synergies in the businesses the Group 
acquired in 2021. We launched a new 
advertising campaign featuring Dame 
Judi Dench, leading the MoneySuperSeven, 
which resonated well with UK consumers, 
emphasising both our purpose and the 
breadth of the MoneySuperMarket offer.

Further detail on how innovation supports 
our strategy can be found in the CEO’s 
Review on pages 10 and 11 and Our 
Strategy on pages 18 to 22.

Capital allocation
Our strong and reliable level of cash 
generation and robust balance sheet was a 
factor in the Board’s decision to recommend 
a final dividend of 8.61p per share 
(2021: 8.61p). Following the acquisition of 
Quidco, the Group finished 2021 with net 
debt of £59.6m. The strong cash generation 
of our model allowed us to finish 2022 with 
net debt of £37.2m, a very manageable 0.3x 
adjusted EBITDA. We remain confident of the 
future prospects of the Group and recognise 
the importance placed on the dividend by our 
shareholders. If approved by shareholders at 
the forthcoming Annual General Meeting, the 
final dividend will bring the total dividend for 
the year to 11.71p (2021: 11.71p) per ordinary 
share. The final dividend will be paid on 
11 May 2023 to all shareholders on the 
register on 31 March 2023. 

The Board will continue to keep under 
review the scope for resumed dividend 
growth and thereafter, when we have 
significant surplus capital and there are no 
material short-term organic or acquisitive 
growth opportunities available, we will again 
consider returning these surplus funds to 
shareholders through a “special distribution”, 
in accordance with our capital allocation policy.

Looking ahead
As we progress into 2023, we will continue 
to execute effectively against our strategy 
and our growth plans, creating innovative 
propositions underpinned by advanced 
data capabilities and an inclusive, open 
culture. With UK households facing cost of 
living pressures we are well placed to grow 
our business and deliver on our purpose 
of helping households save money.

Robin Freestone
Chair
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

09

Strategic ReportChief Executive Officer’s Review

Expanding the capabilities  
of our platform

We made good progress with 
our strategy, extending the 
capabilities of our tech-led 
savings platform. Our trading 
performance shows the 
strength of our business model 
and diversified Group. 
We have now centralised our data and 
made it available to colleagues across the 
Group in real time. We have also adopted 
best-in-class marketing technology and 
more of our brands and comparison 
channels are powered by flexible and 
re-deployable services. This means we 
can attract visitors to our websites more 
efficiently and simplify our operations. 
We have introduced innovations to help 
people save more money and to support 
our providers, whose products and 
services are available on our sites, more 
effectively. We see significant opportunity 
ahead for our Group.

The Group platform supports strong 
brands. MoneySuperMarket’s latest 
advertising campaign underscores its 
purpose to help people save money and is 
resonating with consumers. 
MoneySavingExpert remains the most 
recommended source for people coping 
with financial pressure in these uncertain 
times. And we have exciting plans for 
Quidco and our Travel business after our 
acquisitions in 2021.

Revenue per active user (MSM)

£16.40

The business has delivered strong results 
even though some of our end-markets 
were suffering challenges, in particular 
energy and car and home insurance. The 
energy switching market was closed for 
the whole year and new general insurance 
regulation meant subdued switching in 
car and home, particularly in the first half. 
The return of travel after pandemic 
restrictions were lifted and very strong 
demand for Money products offset this. 
And with the results of our strategy 
starting to come through we have grown 
both revenue and profit for the first time 
since 2019. With new capabilities and our 
platform becoming more mature, we 
are better placed than ever to grow 
our business.

Adjusted EBITDA and profit before tax 
grew 15% and 21% respectively, driven 
mainly by strong performance 
in Money and Travel as well 
as the first full year of 
Quidco ownership. Gross 
margin was down circa 
three percentage points, 
which was expected 
given the consolidation 
of Quidco with its lower 
gross margins than the 
rest of the Group.

We operate market-leading brands, 
supported by a scalable, tech-led savings 
platform. In 2022 we generated strong 
results despite headwinds in several 
of our markets. 

Peter Duffy
Chief Executive Officer

10

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Our platform
At the heart of the Group is our technology 
and data platform. The breadth of comparison 
services we offer has always been a major 
strength. But historically our brands operated 
on distinct technology stacks. Over the last 
two years we have been redeveloping our 
technology so we build things once, at Group 
level. That means a single, common platform 
underpinning our brands apart from Ice 
Travel Group (ITG). Working this way not 
only increases the pace of innovation while 
retaining our ability to apply different user 
experiences for specific comparison areas, 
but also simplifies platform updates. Using 
car insurance comparison as an example, we 
have now launched the MoneySavingExpert 
Compare+ car insurance tool in May; put it 
onto the Quidco site and then opened it up 
for business-to-business (B2B) partners – with 
two new partners going live in the last month. 
The build once at Group level approach 
requires less resource for maintenance and 
development. By the end of 2022 several of 
our large channels had transitioned to the 
new approach. 

Data is the lifeblood of our business. In 2022 
we consolidated our data onto Google Cloud 
Platform (GCP). Quidco will follow. This provides 
us with a market leading infrastructure, greatly 
enhancing our ability to store and use data. We 
now have a complete view of users which 
allows us to improve their experience on our 
sites, make our marketing more relevant and to 
deliver more value for our providers. This 
change has also improved the capture of new 
data, which helps us understand what users 
need. The time needed to add new data has 
reduced from weeks to seconds. Different 
parts of the Group now use the same data, 
presented in broadly the same way, which 
means better decisions, made faster. 

With more agility and better data, we have 
started to innovate and offer new ways for 
users to save more and offer improved 
support for providers. In 2022 we started 
simplifying the user experience for our 
returning customers. Traditionally price 
comparison focused on getting the information 
required for the specific product being 
compared. We have pivoted this so the focus is 
now on our users, by building a user profile 
that becomes more populated as they enquire 
across more channels. For users that means an 
easier journey on the site. For example, 
customers wanting to borrow often like to 
compare a loan with a credit card. Until now, 
they would have to go through the full question 
set for each product. Soon, 12 of the 16 
questions of their second enquiry would be 
completed for them. For providers we have 
created new products from our real-time data 
to help them tailor their quotes more keenly, 
which helps them offer better savings and 
attract new customers. 

In 2023 we will continue to migrate the rest of 
our business onto the Group platform and will 
use this as the foundation to add innovative 
ways for users to save, and support providers 
with their customer acquisition strategies. 

Our brands
We enjoy leading positions in growing markets 
where there is significant room to grow. 
Our brands are firmly trusted by customers.

Our price comparison brand, 
MoneySuperMarket (‘MSM’), had 11.1m active 
users in 2022. We have repositioned the brand 
focusing it more clearly around “saving” and 
supercharged the latest campaign by including 
Dame Judi Dench and the mission to save 
Britain £1bn. Since launch in May, this 
campaign has been very successful, ranking 
in the top quarter of all UK advertising; and 
MSM’s share of branded search has increased 
to its highest level since 2018. 

We have also improved MSM’s ability to attract 
traffic efficiently and engage with users. In 
2022 we deployed leading digital marketing 
tools and integrated them with our centralised 
data infrastructure. This has meant better 
content creation and more effective bidding for 
paid search traffic. MSM now ranks in the top 
2 organic search results for most of our 
channels. Our new customer relationship 
management (CRM) tool improves how MSM 
reaches customers and we can now contact 
users with more relevant and timely offers. 

MoneySavingExpert (‘MSE’), our content-led 
brand, is greatly trusted and provides valuable 
tips and tools to millions of users. MSE has 
been at the forefront of supporting UK 
consumers through the energy and cost of 
living crisis, and it is an authority in personal 
finance. YouGov again rated MSE the most 
recommended brand in the UK. During the 
year we have trialled a new MSE app that 
makes content more accessible. The app uses 
Open Banking technology to identify 
personalised opportunities to save and has 
garnered positive feedback with a 4.8 out 5 
app store rating (both Apple and Android). 
It is the start of a suite of more personalised 
experiences that will help users be in control 
of their finances. 

In 2021 we bought Quidco, the UK’s second 
largest cashback brand. Last year we made 
good progress integrating it into the Group. It 
now operates on the Group’s HR and finance 
systems. We closed the London office with 
colleagues moving into the main Group office 
on Dean Street. We have brought Quidco’s 
website and app data into the Group’s Google 
Cloud Platform and are migrating CRM 
operations to leading customer engagement 
platform Braze. Group technology is now 
powering Quidco compare journeys for Home 
Services, Travel and pet and car insurance. 

Ice Travel Group (‘ITG’), the combination of 
TravelSupermarket (‘TSM’) and icelolly.com, 
has seen the benefits of bringing the two 
businesses together. TSM is using the icelolly.
com proprietary bidding technology that allows 
providers to bid for more prominent placings 
on the website. TSM travel insurance and car 
hire panel are now on icelolly.com. Thanks to 
this improved offer and the combined reach 
of the two brands ITG has capitalised on the 
post-pandemic recovery in Travel. 

People and culture
In the cost-of-living crisis our purpose is more 
relevant than ever and the passion and 
commitment of our employees to saving 
households money is an inspiration. 
Reinforcing our inclusive culture is a priority for 
me. Colleagues are championing that in our 
Employee Resource Groups. I thank them, as 
well as employees throughout the business, for 
continuing to help move our culture forward 
and to deliver to our purpose. 

We are committed to embracing and 
promoting diversity, inclusion and equal 
opportunities. The Group was ranked first on 
the most recent FTSE Women Leaders Review 
report for its 62.5% female representation. In 
2022 we also were recognised on the Inclusive 
Companies Top 50 UK Employer List. Over 20% 
of our hires in 2022 described themselves as 
coming from a multi-ethnic background. 

Social impact 
Helping households save money and 
supporting our wider community is at the 
heart of what we do. In 2022, we undertook 
a review of our Net Zero targets to ensure 
that we remained aligned with the 1.5⁰C 
decarbonisation pathway, and that our targets 
are sufficiently ambitious. As a result, we have 
taken the decision to increase the targets we 
set in 2021 to ensure that we are doing all we 
can to reduce our emissions. In the meantime, 
we continue to be ‘Beyond Carbon Neutral’, 
offsetting 150% of our carbon emissions. 
In the meantime, we continue to disclose 
our environmental impact via the Carbon 
Disclosure Project and have retained our 
C score for 2022. 

The Group donated £100,000 to the Prince’s 
Trust, our charity partner, including the 
proceeds from colleague fundraising activities. 
Through our partnership with the Prince’s Trust 
and the MSE charity we aim to deepen our 
impact and support those most in need. MSE 
donated £100,000 to the MSE Charity, which 
provides grants of up to £7,500 to UK 
not-for-profit groups that provide education, 
information and support to help people 
manage their money better 

Outlook
In the last two and half years, we have built a 
scalable, tech-led savings platform with our 
purpose to help households save money at its 
core. That gives us a strong foundation for an 
efficient Group with market leading brands and 
propositions. This foundation sets us up for 
the next phase of our strategy - delivering 
innovative products for providers and new 
ways for customers to help them save more 
money, making them more loyal and valuable. 

Peter Duffy
Chief Executive Officer
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

11

Strategic ReportOur Market and Trends

Trends in our
chosen markets

Price Comparison (overall market)

Regulatory focus

Link to strategy 

Brands affected 

Trend 

Impact 

Opportunities 

Greater focus from governmental 
and regulatory bodies on 
empowering customers.

Regulation will become an 
increasingly important feature 
of the price comparison sector.

Regulation empowering customers to save money is fully 
aligned with our purpose of helping households save money. 
Such regulation can generate additional demand, as we saw 
when the energy price cap was introduced, and also facilitate 
the switching process, for example with faster energy switching 
or by changing insurance auto-renewal protocols.

Comparison beyond price

Brands affected 

Trend 

Impact 

Opportunities 

Providing greater and better 
information to users beyond 
just price. 

Simultaneous comparison 
across multiple factors can be 
challenging to present clearly 
to the user.

Today price comparison focuses heavily on price. The cheapest 
policy is not always the right one though, and price comparison 
sites can improve the additional information they provide to 
help users assess value. We incorporate independent quality 
scores to our results like defaqto in insurance products. This 
allows customers to include in their decisions factors including, 
but not limited to price.

Advisory propositions

Brands affected 

Trend 

Impact 

Opportunities 

Propositions that recommend 
products or even execute the 
switch for the consumer have 
started to emerge.

“Do it for me” propositions 
could disrupt the status quo 
and rapidly gain scale.

Advisory propositions are generally more heavily regulated 
than our current model, but they also represent a potential 
long-term evolution of the price comparison model to one 
that is more automated, with higher frequency of switching.

Economic downturn 

Brands affected 

Trend 

Impact 

Opportunities 

Rising inflation and interest 
rates have put the UK and 
other major economies at 
risk of entering a recession.

Households could cut back 
on spending. 

Our purpose to save households money becomes even more 
relevant in a tough economic environment. Our broad range 
of comparison services could see increased demand. 

12

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Our brands

Strategic priority

MoneySuperMarket

MoneySavingExpert

  Efficient acquisition

Quidco

TravelSupermarket

Decision Tech

Icelolly.com

  Retain and grow

  Expand our offer

Insurance 

FCA pricing regulations

Link to strategy 

Brands affected 

Trend

Impact

Opportunities

In January 2022 the FCA 
introduced regulations to stop 
‘price walking’ by insurers in car 
and home insurance. This was 
part of a package of measures 
expected to ensure that 
insurance products offer 
fair value to consumers.

Insurance premiums

New business pricing became 
less attractive compared to 
renewal pricing which led to 
higher customer retention 
levels and lower market 
switching volumes in 2022. 

The first year of the regulation has been one of transition. 
Switching volumes were significantly down in the first half 
of the year as insurers focused on compliance. Competition 
for new customers returned and decline in the second half 
of the year was lower and improving.

Brands affected 

Trend

Impact

Opportunities

In 2022 premiums entered an 
inflationary cycle for the first 
time since 2019 as insurers 
reflected the higher cost 
of parts and repairs into 
their pricing. 

Travel insurance

Premium inflation 
generally stimulates 
more enquiry volumes.

An inflationary environment should drive higher enquiries 
across the market. By making our journeys as smooth 
and efficient as possible, we can capitalise on this 
increased demand.

Brands affected 

Trend

Impact

Opportunities

The overall demand for travel 
and therefore the demand for 
travel insurance are recovering 
as pandemic-related travel 
restrictions ease. However, the 
risk of an economic downturn 
could put pressure on 
consumer spending.

We have seen a recovery in the 
travel market as restrictions 
have eased and consumer 
confidence returns. A recession 
could result in a reduction in 
demand for discretionary 
services like travel.

In difficult economic times our broad provider panel means we 
are well placed to help travellers save money finding the most 
suitable policy.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

13

Strategic Report 
 
 
 
 
    
 
 
  
 
Our Market and Trends continued

Money 

Interest rate rises

Link to strategy 

Brands affected 

Trend

Impact

Opportunities

Interest rates in major 
economies are starting to rise 
after years of historic lows.

Higher interest rates make 
credit more costly.

Rising interest rates make credit cards and loans more expensive 
which could soften demand. In addition, we may see heightened 
demand for balance transfer or zero-interest credit cards as 
debt becomes more costly.

Home Services 

Energy wholesale pricing

Link to strategy 

Brands affected 

Trend

Impact

Opportunities

As was the case from late 2021, 
energy wholesale prices 
remained high and volatile in 
2022 reflecting both demand 
and supply issues. 

These conditions, along with 
Government interventions like 
the introduction of the Energy 
Price Guarantee, meant there 
were no switching products 
available on our sites.

There was no switching in 
the market and therefore 
no switching revenue.

We expect the energy switching market to remain closed in 
2023; however, when wholesale prices stabilise, and depending 
on the level of the price cap, we may see a significant opportunity 
for switching. Our broad panel and simple energy journeys 
mean we are well set to benefit from this.

In addition, MSE editorial is uniquely positioned to guide consumers 
as the market reopens, and on the best deals in the market.

14

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

 
    
 
    
Cashback 

Online spending demand 

Link to strategy 

Brands affected 

Trend

Impact

Opportunities

The pandemic accelerated 
the secular growth of online 
purchasing. However, the 
reopening of the high street 
and the weaker consumer 
spending outlook could 
moderate these trends.

UK online spending has 
returned to trends 
seen pre-pandemic. 

Cashback presents a way for consumers to save money on 
everyday purchases amid the rising cost of living. The greater 
penetration of online retail brings the potential for wider, more 
frequent engagement with cashback sites such as Quidco.

Travel 

Package holiday growth

Link to strategy 

Brands affected 

Trend

Impact

Opportunities

Consumer demand for package 
holidays improved as COVID-19 
restrictions relaxed; however, 
economic uncertainty could 
weaken travel demand.

As the largest discretionary 
spend area for many households, 
demand for travel may soften 
under macroeconomic pressures. 
However, almost two years of 
travel disruption created by the 
pandemic could make demand 
more resilient compared to 
previous economic downturns.

Ice Travel Group continues to focus on building leading comparison 
services to help consumers find the best deal for their holiday 
which is especially more relevant during tough economic times.

Our brands

Our strategy

MoneySuperMarket

MoneySavingExpert

Quidco

TravelSupermarket

Decision Tech

Icelolly.com

Efficient 
acquisition

Retain & 
grow

Expand our 
offer

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

15

Strategic Report   
 
Business Model

Helping households 
save money

Our key strengths 
and resources 

Technology
Our offer is underpinned by our scalable 
and flexible technology solutions that 
are increasingly able to support multiple 
in-house and external brands from 
a common platform.

Data
Our strong analytical capabilities and 
upgraded infrastructure allow us to 
personalise the customer experience, 
generate real-time performance 
information, and provide relevant, 
useful data to providers.

Relationships
Our strong relationships with our providers 
allow us to offer exclusive and market-
leading deals.

»  Read more about how we engage 

with our providers on pages 32 and 33.

People
Our talented people ensure we provide 
customers with the best experience. 

»  Read more about how we support 
our employees on pages 44 to 47.

Leading brands
We operate well-known brands which 
are trusted by our customers.

»  Read about our brands on pages 04 and 05.

Marketing platforms
We have leading marketing platforms 
integrated with our centralised data.

»  Read more about the effectiveness 
of our marketing on pages 23 to 26.

16

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Our value cycle 
We provide products and services to help 
users make meaningful savings across their 
household finances. At the same time we 
help providers to acquire new customers 
in an efficient and cost effective way.

1  Our brand strength and marketing attract users 

and providers to our well- established platform

2   

Efficient switching journeys help users easily switch and save

3   

Providers pay us when products are purchased 

4  We remind users when it is time to re- switch; we use data 

to prioritise and market further switching opportunities

5  We generate insights from users and providers to optimise 

our propositions and identify growth opportunities 

6  

  We expand into new markets and additional services

Underpinned by our responsible approach

» Read more on pages 36 to 47

Risk management framework 
The Group operates in a complex business 
environment and there are risks to the 
delivery of our strategic goals and the 
sustainability of our business model. We 
have identified the principal risks through 
our risk management framework, and we 
have considered them as part of our 

viability assessment. Our risk management 
framework also provides the tools to 
manage and continually review our risks. 
It seeks to drive accountability across the 
Group and create the insight required for 
the Board to monitor our risks. Our risk 
management framework also allows 

management and the Board to adapt the 
strategy to ensure that we are not taking 
unnecessary risks and that the underlying 
risks in the strategy are being 
appropriately mitigated.

Transition to a tech-led 
savings platform 

B r a n d - a g n o s tic MSMG platform

H ome Services
c o m p arison services

  d if  erentiated bran

d

s

e l l i n g ,

o m p

C

cy, advertisin g 
ack solutio n s

b
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& c
T

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m

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a

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r

2

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,

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C

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M

3

+ Our B2B Partners

Data infrastru c t u r e  
& analytic s

1  SEM – Search Engine Marketing.

2  SEO – Search Engine Optimisation.

3  CRM – Customer Relationship Management.

Underpinned by our responsible approach

» Read more on pages 36 to 47

•  Minimising our environmental impact 

•  Our social responsibility  

•  Robust governance and ethics

I
n

s

u

r

a

n

c

s

e

e

r

c

v

o

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o
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o

aris
p
services
m
M oney co

How we share value 
with our stakeholders

Our customers
Savings through readily accessible, 
personalised information

In 2022 our customers are 
estimated to have saved

£1.8bn(2021: £1.6bn)

Our providers
Cost-effective customer acquisition via 
access to millions of informed customers

Number of providers and merchants

5,000+(2021: 4,500+)

Our people
An inclusive place to work where 
employees feel that they belong

Employee diversity and inclusion score

77% (2021: 71%)

Our communities
Positive impact through work experience, 
charitable donations and volunteering

Donated to charitable causes in 2022

£0.2m

(2021: £0.2m)

Our shareholders
Full year dividend maintained

Cash return to shareholders in 2022

£62.8m

(2021: 62.8m)

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

17

Strategic Report 
 
 
 
Our Strategy

Helping households
save money

Helping households save money

1.
Efficient acquisition
•  Best-in-class digital efficiency

•  Effective marketing

•  Seamless, shorter journeys

2.
Retain and grow
•  Engaged relationships – helpful 

prompts and reminders

•  Targeted, relevant cross-sell

3.
Expand our offer
•  Further channels

•  Wider audiences

•  More products on more brands

Advanced data capabilities • Common technology • Scalable platforms

Underpinned by

1. Efficient acquisition

We continually optimise our paid search (‘PPC’), 
search engine optimisation (‘SEO’) and brand 
marketing in order to attract consumers to our 
sites in the most cost effective way.

that increase our agility and speed. This has 
allowed us to adapt quickly to changing demands 
and MSM ended the year ranking in the top two 
organic search results for most channels. 

Following migration to the SA360 PPC bidding 
platform in 2021, in 2022 we deployed more 
sophisticated features. Using machine learning 
we can now bid for more search terms, make 
bids more targeted using our first-party data and 
adjust our bids more frequently. This has allowed 
us to reduce cost per click and increase our share 
of clicks.

SEO delivers substantial volumes of free search 
traffic to our sites. In 2022 we established a new 
set of tools and processes for content production 

Above-the-line marketing remains an important 
driver of traffic to MoneySuperMarket. In May we 
launched our latest MoneySuperSeven marketing 
campaign featuring Dame Judi Dench. This 
campaign is resonating better with consumers 
than any campaign we have done before and, 
since launching the new campaign, MSM share 
of branded search traffic has reached the highest 
level since 2018.

2. Retain and grow

We want to retain users and help them 
switch more of their household bills which 
will ultimately increase customer lifetime value. 
To drive higher retention, we focus on timely 
reminders and a simpler experience for 
returning users. 

Cross-sell continues to be a major opportunity. 
In 2022, 21% of our MSM active users enquired 
in more than one of our seven core channels. 
This is up from 19% the year before, mainly 
driven by the recovery in travel insurance. On 
average, active users enquired in 1.2 channels.

Data is critical to deepen our relationship with 
our customers. In 2022 we consolidated our 
data into Google Cloud Platform ‘GCP’. Quidco 
will follow. This improves our ability to store 
and use it. We now have a single source of rich, 
real-time data. This data is available 

operationally to drive growth and increase 
marketing efficiency.

In 2022 we finalised transitioning to Braze, a 
leading customer engagement platform. Braze 
is fully integrated with our centralised data and 
allows us to deliver personalised messages to 
users across our apps, web and via email. 
Campaign creation is more efficient, allowing a 
test and refine approach, which in turn means 
better user retention and engagement.

We also aim to simplify the experience for 
returning users by using data to shorten 
question sets thereby reducing the time and 
effort needed to get to a quote. The core of 
this is a re-build of question sets to use a 
shared user profile that becomes richer as 
users enquire across more channels. This is 
now live on MSM car insurance, credit cards 

MoneySavingExpert continues to offer content 
and tools to guide and support consumers to get 
in control of their finances and enjoys great trust. 
MSE was again named the most recommended 
brand by YouGov and quadrupled its social media 
followers to 1.3m. Quidco, our cashback brand, is 
the latest addition to the Group. In 2022 we 
brought its website and app data into our central 
data platform and started to drive new member 
registrations. In 2023 we will continue to use 
more of the Group’s marketing capabilities to 
grow Quidco. 

and loans. In 2023 we will continue to expand 
the channels that use the shared profile and 
how we use data to improve conversion 
and cross-sell.

Capturing more information on our users 
allows us to offer more opportunities to save 
and helpful reminders to switch. Last year we 
developed the capability to use Open Banking 
technology to identify potential saving 
opportunities in household bills. We did this 
as part of our new MoneySavingExpert app. 
The app is a convenient way for users to access 
MSE content and also the start of a suite of 
more personalised experiences that will help 
users be more in control of their finances.

18

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Our strategy in action

Efficient Acquisition page 23

Retain and Grow page 24

Expand our Offer page 25

3. Expanding our offer 

We will continue to grow our Group further with 
new propositions, new distribution routes and 
new channels. In 2022 we have made progress 
integrating our 2021 acquisitions, released 
new B2B capabilities and expanded our offer 
for providers.

Quidco is our latest acquisition. The Group’s 
comparison services are already powering 
Quidco Compare journeys for Home Services, 
Travel and pet insurance. We are migrating CRM 
operations to Braze and continue to expand the 
channels using our platform capabilities.

We acquired icelolly.com and combined it with 
TravelSupermarket (‘TSM’) to create Ice Travel 
Group (‘ITG’) in 2021. The two brands now share 
products and capabilities improving their offer. 
TSM is using icelolly.com’s proprietary 

technology that allows providers to bid for more 
prominent positions on the site. And 
TravelSupermarket’s travel insurance and 
car hire panel are now on icelolly.com. 

Our tech and data platform allows us to extend 
the services we offer our providers. Last year 
we launched the first propositions that use the 
Group’s data. Our data enrichment tools give 
insurers access to real-time data that enables 
them to offer more competitive pricing. We took 
early steps to offer providers the opportunity to 
use data to personalise quotes and we will 
continue to develop the proposition in 2023.

We have expanded the channels in which we 
can offer tenancy and B2B. Tenancy enables 
providers to promote their brands in 
designated advertising spots on our sites. 

Our B2B proposition allows us to utilise our 
Group platform to provide switching services to 
third-party brands, extending our reach. We 
launched a B2B car insurance journey in early 
2023. In tenancy, we have seen strong demand 
from providers and will continue to extend our 
offering across channels.

The mortgage proposition remains an attractive 
opportunity for the Group. In December we 
gained control of our mortgages joint venture 
partner Podium. In 2023 we will continue to 
innovate to deliver enhanced, digitised 
mortgage comparison services to customers.

Advanced data capabilities, common technology, scalable platforms

The breadth of our offer has always been one 
of the strengths of the Group. We offer the 
ability to compare products across practically 
all household bills. The dataset we now have 
means we can better serve our users with new 
ways to help them save. With our new platform-
led approach we are focused on consolidating 
and simplifying our infrastructure, building our 
technology in a way that maximises efficient 
re-use across the Group and beyond. 

We continue to ‘platformise’ our tech estate 
– building features once and deploying them 
across all our brands. This delivers cost 
efficiencies, making our technology estate 
simpler to manage and reducing maintenance 
cost. A number of our largest channels are now 
fully ‘platformised’ – energy, car insurance and 
home communications.

With this new platform-led approach we can 
bring new propositions to market and to scale 
faster, rolling them out across multiple brands. 
For example, making car insurance comparison 
re-deployable as a service allowed us to launch 
the MSE Compare+ tool in May, to start powering 
the Quidco car insurance comparison service 
early in 2023 and to provide a car insurance 
comparison service to B2B partners.

Culture

Our strategy is underpinned by our strong 
Company culture. We strive to embed and 
maintain a culture of diversity and inclusion, 
promoting an environment where all of our 
employees can grow and develop. In line with 
the changes we are making to our ways of 

working, we are also seeking to build a 
more entrepreneurial, fast-paced and agile 
organisation to deliver greater innovation 
for our users.

We remain deeply committed to investing 
in our employees’ health and wellbeing, 
with several relevant initiatives in 2022. 
For information on these and on people and 
culture more widely, please see pages 44 to 47.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

19

Strategic Report 
Our Strategy continued

Progress against our 
strategic priorities

Strategic 
initiatives

Efficient 
acquisition

What we have done in 2022

Our future

•  Enhancement of our pay-per-click 
bidding capabilities with greater 
use of data and transition to 
SA360 bidding platform

•  Ongoing focus on the use 
of proprietary data to 
optimise the effectiveness 
of PPC

•  Migrated to new content 

management system that enables 
faster and more agile approach 
to content creation

•  Continue to build on 
the success of the 
MoneySuperSeven creative 
with new campaigns

•  Launched MoneySuperMarket 
price promise guaranteeing the 
best price for our customers in 
car and home insurance

•  Launch new components of 
the new MSM proposition 
for customers

Principal risks and 
uncertainties

Brand

•  Competitive environment 
and consumer demands

•  Brand strength 
and reputation

•  Economic conditions

•  Regulation

•  Relevance to partners

Retain and grow

•  Transition to Google Cloud 

Platform complete except Quidco, 
consolidating data and enabling 
greater analytical processing 

•  More effective and efficient 
CRM platform with shorter 
turnaround times and 
targeted campaigns

•  Consolidation of question sets 
to shorten journeys and allow 
wide pre-population 

•  Launched MoneySavingExpert 
(‘MSE’) app with new open 
banking features

•  Extend simpler, pre-
populated enquiries 
to more channels

•  Optimise returning user 
enquiries using shared 
user profile 

•  Complete migration of 

•  Brand strength 
and reputation

•  Data processing 
and protection

•  Data security and cyber risk

•  Business transformation

Quidco onto Google Cloud

•  Relevance to partners

•  Add new personalisation 
features in the MSE app 

•  Economic conditions

•  Regulation

Expand our offer

•  Integrated Quidco website and 
app data into Group Google 
Cloud Platform 

•  Migrate Quidco CRM to 
Group Braze platform 

•  Competitive environment 
and consumer demands

•  Strengthen Ice Travel 

•  Business transformation

Group data capabilities 
and brands

•  Grow tenancy advertising 
and B2B propositions 

•  Relevance to partners

•  Regulation

•  Shared capabilities 

between icelolly.com 
and TravelSupermarket 

•  Launched first provider 
propositions using rich, 
real-time data

•  Developed capability to offer car 
comparison as a B2B proposition

•  Expanded tenancy advertising 
capabilities to new channels 

Our brands

MoneySuperMarket

MoneySavingExpert

Quidco

TravelSupermarket

Decision Tech

Icelolly.com

20

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Our focus 
on customers

Focusing on customers’ needs
Our purpose of helping households save 
money has never been more relevant than 
in 2022; with growing concern over the 
cost of living, we continued to offer the 
best opportunities to save money and 
to innovate for our customers and users 
with helpful services and advice. 

MoneySavingExpert
MSE continued to be the most 
authoritative source of advice on 
household finances, and its traffic grew 
year-on-year. It maintains its position of 
trust according to YouGov brand trust 
index and in an independent survey 
about financial advice 47% of consumers 
mention MSE as their first port of call for 
financial advice. In addition, we have 
launched our MSE app, making it simpler 
for users to access helpful information. 
During the year MSE launched several 
guides to help consumers understand 
and manage their energy bills.

MoneySuperMarket
We extended our MoneySuperSeven 
campaign featuring a squad of seven saving 
specialists that help customers to 
understand the different ways they can 
save: car insurance, home insurance, 
energy, broadband, credit cards, travel 
insurance and pet insurance. In 2022 
MoneySuperMarket has launched “mission 
£1 billion” aiming to save British households 
that amount of money on their bills.

Quidco
We re-launched our cashback reminder 
extension that automatically alerts 
members of opportunities to save as they 
browse or search online and allows them 
to active cashback with just one click. 
This will help them save on more of 
their everyday purchases and benefit 
the most from being a Quidco member.

Energy
Unprecedented energy costs have 
increased energy bills and created 
pressure for numerous households and 
have constrained providers’ ability to offer 
attractive new tariffs. We took the decision 
to maintain availability of our energy 
comparison journeys providing general 
information about why the prices were 
so high, and about which suppliers 
had ceased trading.

Money
Through our eligibility journeys for credit 
cards and loans, we provided greater 
transparency of the products available 
to customers, based on their personal 
circumstances. We have also improved 
our online journeys, reducing friction 
for our customers through question set 
improvements and other optimisations. 

Mortgages

We have significantly enhanced our 
customer experience with a new 
logged-in experience that allows 
customers to retrieve their last results 
and pick up where they left off, and added 
a more intelligent affordability calculator.

The quotations you supplied were excellent 
and enabled me to make a quick decision.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

21

Strategic ReportOur Strategy continued

Cutting your costs,
fighting your corner

Cutting your costs
MoneySavingExpert has continued to 
develop its position as one of the UK’s 
biggest finance websites, editorially 
independent and committed to helping its 
users cut their costs and fighting their 
corner. There were more than 200 million 
sessions on the site in 2022, and around 
70 million on the MSE Forum, our online 
community of money savers. Our social 
media following quadrupled to 1.3 million 
and around 8 million people receive our 
famous weekly email.

Much of our effort remains focused on 
helping people manage the impact of 
energy bills and the cost of living crisis on 
their finances: our detailed analysis of the 
impact of dramatic rises in energy costs 
and guides to reduce energy consumption 
have been very popular in 2022. 

Our journalism continues to make an impact: 
our team chased answers as cost of living 
payments of £150 were delayed for some of 
the 6 million with disabilities that were due. 

Fighting your corner
One thing that underpins that recognition 
is our campaigning on behalf of consumers. 
In 2022 MSE released its report calling 
for a return to ‘typical APRs’, which would 
mean that at least 66% of successful 
card and loan applicants would get the 
advertised rate, as opposed to the 51% 
guaranteed by the ‘Representative’ APRs.

The site also highlighted in its report, the 
Roaming Risk, that consumer protections 
had lapsed for those roaming in Europe as 
EU-based law was allowed to sunset. MSE 
continues to campaign Ofcom to put these 
protections back in place.

The key achievement of the year came 
in the spring when MSE and a coalition 
of campaigners managed to get the 
Government to include scams in the 
Online Safety Bill. This was a real milestone 
in making sure consumers will benefit from 
strengthened expectations of online firms 
when it comes to fraudulent advertising.

Even easier to use
We continue to invest considerable 
resources in our platforms and content 
to respond to the changing needs of our 
users. In 2022 we have launched an MSE 
app with convenient access to all MSE 
content and Open Banking integration 
to find opportunities to save. We have 
also launched a “multi-comparison” car 
insurance proposition and relaunched 
our Quidco cashback reminder to help 
our members save more.

22

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Strategy in Action 

Efficient Acquisition

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On a mission to save Britain £1bn
In 2021 we relaunched the 
MoneySuperMarket brand with the 
”MoneySuperSeven” a new campaign 
featuring a squad of smart, eclectic, cool 
savvy women working together to help 
people make savings on multiple 
household bills. Last year the team grew 
with a new member, “Eight”, played by 
a unique British icon, Dame Judi Dench. 
This new and important member joins the 
team at a time when their purpose is most 
relevant and brings an important new 
mission. Saving Britain £1bn on their bills.

MoneySuperMarket’s brand campaign in 
2022 has been very successful. We test our 
advertising with independent customer 
research. The ad is in the top 5% of UK ads 
for grabbing attention and the top 3% of all 
ads for its positive portrayal of women.

Since launching the campaign our share of 
branded search has grown (and remained) 
at the highest levels since 2018. 

Brilliant service. Really quick and easy and 
I got my insurance sorted in no time! Thanks! 

We plan to continue to build on the success 
of our MSM brand. In 2022 we have 
launched our “MSM price promise” on car 
and home insurance, which is a first step 
towards a re-invigorated proposition to 
make us the first choice for consumers to 
save money. If you find the same product 
cheaper, we offer to pay the difference 
and more.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

23

 
Strategy in Action continued

Retain and Grow

This user-focused approach will improve 
conversion and make our users more loyal 
and valuable. Our new question sets that 
make use of the centralised user profile are 
already live in some of our biggest channels 
for our MoneySuperMarket brand. We will 
continue to expand the channels that use 
the shared user profile and we have a strong 
pipeline of improvements building on this.

Simpler, more personal journeys
The breadth of our offer has always 
been one of the strengths of the 
MoneySuperMarket Group. With us you can 
save in practically all your household bills. 
Simplicity is at the heart of what we do. We 
ask you a few questions and present all your 
options in a simple summary. We are now 
taking that to the next level. As you use our 
services to save, we will make your experience 
easier, simpler and more personalised.

The core of this is a re-build of question sets 
and a centralised user profile that becomes 
richer as they enquire across more channels. 
This means that when you come to us, we 
can offer the easiest journey and we can 
personalise your experience according to 
your specific needs and purpose. For 
example, customers wanting to borrow 
often compare between getting a loan 
and a credit card. With our new approach 
we will be able to use the answers you gave 
when looking for loans and when you go 
to compare credit cards some of your 
information is already there and you 
only need to check that it is still accurate.

To offer attractive deals in any of our 
verticals it is necessary to collect a lot of 
information. Traditionally, this has been done 
with the focus on a channel, collecting the 
information required for the specific product 
being compared. We have pivoted the focus 
to our users, by building a single user profile 
shared across our different channels.

Easy and helpful throughout...I am really grateful...
gave me a feeling of loyalty to MSM. Thank you. 

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Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Expand our Offer

S
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Expanding our offer
Cashback reminders
In 2021 we acquired Quidco, the second 
largest cashback brand in the UK. Cashback 
gives users the opportunity to save on 
purchases across a range of categories 
like travel, clothing, DIY, home and health 
& beauty. We have more than 5,000 
merchants on our panel and our members 
can benefit from cashback when they buy 
from them. 

Given the breadth of the offer and the depth 
of the merchant panel, members can benefit 
from receiving cashback on a large number 
of their everyday purchases. 

Members that have used cashback 
for some time use it for a lot of their 
purchases and save across a range of 
categories. However, some new members 
are not always as aware of the range of 
merchants offered by Quidco, and the 
potential cashback opportunities. 

To support our members and help them save 
more, in 2022 we have re-launched Quidco’s 
“cashback reminder” browser extension. The 
extension works in all major desktop and 
mobile web browsers. It sits silently and 
when members are searching for products 
or browsing online stores it alerts them and 
shows how much they could save with 
Quidco on that product. 

Our new browser extension also allows 
members to activate cashback with one 
click. When browsing a product in their 
retailer website, they don’t need to go to 
Quidco and return to their previous journey. 
Members can activate their offers without 
leaving the retailer website and cashback 
will be automatically added to their account. 

The new extension is great...it reminds 
me when I can sync to get cashback! 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

25

 
Strategy in Action continued 

Our new 
MSE App

In May 2022, MSE launched its mobile 
App on the Apple and Google play 
stores. The App hosts the entire MSE 
website, including all our money-saving 
tools and our famous weekly email, 
accessible to all users without 
needing an account. 
Users with an account gain access to extra, personalised features 
and alerts driven by open banking, building on MSE’s core editorial 
mission by allowing us to offer curated and relevant content to 
help users best manage their personal finances. 

Developing a global MSE account is at the heart of our plans for 
the App and MSE. Users have previously only been able to create 
accounts in the MSE club (Energy and Credit), as well as the MSE 
Forum, and these three accounts are not connected. The global 
account allows users to create their own personalised version of 
MSE for the first time, and for the legacy clubs accounts to be 
unified. The MSE account will soon also be available on the 
MSE website.

Open banking helps to personalise MSE’s App. The App has three 
areas: (1) the MSE website hosted within the App; (2) myMSE, which 
contains editorial content via recommended Hot Topics, and a Bill 
Buster feature with personalised alerts powered by open banking; 
and (3) a Tools area which has links to all the MSE tools including 
three that have been enhanced to allow users to save their 
searches.

The Regular Payments Detective tool finds recurring payments in 
any linked bank accounts, and then offers a set of smart alerts to 
help the users stay on top of their household budgets such as 
identifying an unexpected change to the payment amount or 
a payment that should be cancelled. 

The editorial team produces daily content for myMSE which is 
personalised for users based on transactions in their connected 
bank and credit accounts, plus a set of categories selected by the 
user. Each piece of myMSE content has editorially-driven actions 
associated with it (e.g. check Broadband Unbundled) or links to 
relevant guides and articles which the user can work through 
or save for later. 

We were proud to launch our 
new MSE App in May 2022. 

26

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Bill Buster was released in November 2022. It offers new 
functionality which will form an increasingly powerful part of the 
MyMSE offer to users, combining open banking data and MSE 
expertise to help them stay on top of their bills. Its first, early 
iteration automatically finds your mobile and broadband bill 
in your bank statement and presents this back to you in a 
dashboard. It will automatically generate advice powered by 
simple questions that can be answered without looking up your 
bill. We plan to have most of the important household bills ready 
in 2023, including credit cards, car insurance and more. Bill Buster 
will be a major step forward in personalisation. 

We have been pleased with the strong demand for the App in 
both the Apple and Google play stores and we have received very 
positive feedback from users; as at 30 January 2022, it held a 4.8 
rating out of 5 (4.9 for Apple and 4.7 for Google Play). We have twice 
been featured by Apple as “App of the day”, and Apple has shown 
continued interest in furthering this partnership, primarily due to 
its focus on financial assistance in the current economic climate.

It is our belief that the introduction of personalisation at MSE 
has the potential to transform the experience for MSE users 
and further strengthen our position as the UK’s most successful 
personal finance site. We look forward to seeing how the 
MSE App can help users save even more money!

Kit helps households 

save money

My name is Kit and I’ve worked 
at MoneySavingExpert (‘MSE’) 
for almost four years now. 

Having occupied my current role throughout 
the coronavirus pandemic – which involved 
writing and maintaining MSE’s guide on the 
Government’s furlough scheme – I began 
2022 with a feeling that both my contribution 
to MSE and MSE’s own impact across the UK 
had probably peaked. Surely it was unlikely 
MSE would ever need to step-up and play 
so vital a role again.

Fast forward to the end of 2022 and how 
wrong could I have been? With the onset of 
the cost of living crisis, MSE now finds itself 
more in demand than at any point in its near 
20-year history. Once again, everyone at MSE 
has needed to step up and pull together as a 
team. Each of us has had a role in ensuring 
that MSE has given the best possible advice 
to its users – particularly those most affected 
by the cost of living crisis.

One subject area I’ve looked after for some 
time now is mortgages. For years, our 
messaging has followed a similar pattern – 
“interest rates are at historic lows, so check 
now to see if you can bag a cheaper deal”. 
With the base rate having been slashed to 
0.1% during lockdown, sub-1% mortgage 
rates became increasingly common 
throughout 2021, something we flagged 
as best we could.

Yet all of this started to change in December 
2021, the point at which the cost of living 
crisis really began to bite. 

Around this time, the base rate started to 
rise, and market indications were that it 
would continue to be hiked in a bid to curtail 
inflation. This is when our messaging around 
mortgages started to change – be that in 
news stories I wrote, the mortgage guides 
I look after or the weekly email that MSE 
sends. It was now that we started warning 
that the era of ultra-low mortgage rates was 
coming to an end, a message we tried hard 
in particular to convey to those with expiring 
mortgage deals: get a new deal sorted pronto.

As interest rate rises picked up pace 
throughout the early months of 2022, we 
made people aware that more lenders were 
increasing how far in advance borrowers 
could lock in a new rate of interest – a relief 
for those whose current deals weren’t 
expiring for a while.

When interest rates peaked around October, 
we tweaked our message again, highlighting 
how fixing a new deal at that moment wasn’t 
necessarily the best option – instead, what 
about temporarily moving onto a variable-
rate deal which you could leave, penalty free, 
when you were ready to fix? Now that interest 
rates have started to come down, we’ve been 
explaining what the options are if you did lock 
into a mortgage which hasn’t started yet and 
can now be beaten by a better rate elsewhere.

At each step of the mortgage journey this 
year, users have got in touch to thank us for 
the insight we’ve provided – a great 
reassurance for me that our messaging has 
been getting through. I’m hopeful that the 
advice we provided has helped households 
save £100s – if not £1,000s – on their 
mortgage outgoings. 

Another subject I cover is council tax – a cost 
that invariably increases each April. 

Yet many people are due discounts or 
reductions off their council tax bill, something 
that can help them save £100s or even 
£1,000s a year. Earlier this year, I published a 
new guide on council tax discounts, which 
outlines exactly what support is available. It 
was really satisfying getting this guide into the 
public domain, as since then we’ve had many 
people getting in touch with their council tax 
discount successes.

What’s more, the kinds of successes have 
been so varied: from those who are 
diagnosed as “severely mentally impaired”, 
to those who live alone, from those who are 
full-time students or live-in carers, to those 
with disabilities whose homes have been 

modified for mobility purposes. It’s good to 
see people have been applying for the help 
with council tax that they’re due.

One great success that I read recently 
came from Patricia, who said:

“I recently signed up for the 
weekly advice email and 
am now over £900 better 
off as I have been able to 
claim a council tax rebate 
as a single resident. Hurrah!”

Patricia

With the cost of living crisis starting to bite 
harder than ever, millions more people 
are finding themselves on the border of 
affordability – and therefore at greater risk 
of rejection when applying for credit. This 
means that ensuring you’ve got a healthy 
credit report is more important than ever. Yet 
doing this is easier said than done, especially 
when simply making ends meet is much 
harder at present for some people.

Our “Improve your credit score” guide is the 
closest you’ll come to “chapter and verse” on 
credit scoring. I’ve worked hard this year to 
ensure the guide remains as up-to-date and 
relevant as possible – I’ve even added in 
details of ways users can get paid to check 
their own credit reports and scores.

While lenders are notoriously secret about 
how they score potential borrowers, I know 
that our advice on credit reports and scores 
has been vital for many of our users in getting 
accepted for credit in the first place.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

27

Strategic ReportStrategy in Action continued 

Lisa helps households 

save money

I know how my role helps and supports 
our purpose to help households save 
money, and I feel I am making a 
tangible diference every day.

Working for a company that does not just 
talk about what is right for customers but 
demonstrates it daily is so refreshing. To be 
part of something that feels worthwhile is 
tremendously important to me and 
contributes massively as to why I am so 
happy in MSMG. I find it to be incredibly 
meaningful knowing that the work I do can 
be intrinsically connected to benefit us all, 
from our friends, to our family, and to all of 
us as customers.

My role within the Group is as a Commercial 
Manager within the Money vertical; one of 
my main responsibilities is to build and 
maintain the strong working relationships 
that we enjoy with our partners. It is essential 
to collaborate closely with our partners to 
understand the current climate from an 
economic standpoint, whilst also establishing 
how we can fill potential gaps in our 
propositions through customer behaviour 
insight. Our main priority is to ensure that 
whatever our customers’ needs are, there is 
a potential product through our banking and 
borrowing landscape that could resonate 
and meet their financial needs. Being able to 
build a platform of products that allows the 
customer the insight and knowledge to make 
informed decisions really is the true 
foundation of the role.

The Money Team has had tremendous 
success this year, not only in the amazing 
deals and exclusives we have secured but 
also because of the strong and united team 
that we have been able to build. 

A key part of being in the Commercial Team 
is being able to adapt to an ever-changing 
world. Nothing in our day-to-day role is a 
certainty; from the exclusives we may secure 
to the rates we discuss at the time, these can 
all change in a minute so being able to 
demonstrate flexibility is a key skill which 
needs to be proven daily. Having the tenacity 

to keep momentum and not become 
distracted by potential obstacles is also 
paramount to delivering all our outcomes. 
Our role is all about building relationships, 
establishing strong routines and setting clear 
expectations on both sides. We must also 
understand how we can support our 
partners and help provide insight into 
customers’ behaviour and translate those 
gaps into potential offers or products. We 
always have to be alert in recognising 
conflicting objectives and effectively 
influencing our position to move our 
strategies further. 

During 2022 one of my personal highlights 
was the onboarding of a new key provider, 
one which has the potential to grow even 
further over the coming years. Not only was 
the onboarding of this relationship mutually 
profitable, it helped me grow and develop 
even further whilst displaying all the key 
behaviours needed in Commercial. 

I feel that the work that the team and I do 
has always been important but, in these 
times especially, it has become increasingly 
more significant. Our country and our 
customers have been impacted by several 
changing factors throughout this year and 
this has emphasised ever more so the need 
to make every penny count! We strive to 
deliver to our customers products and 
services that we feel can have a real benefit 
to their overall lives, to help give certainty in 
an uncertain time. As a team we are not 
immune to the difficulties that our customers 
can face; we see it in our own lives through 
friends and family members. Being part of a 
team which is forever keeping the message 
clear as to how we can save money feels 
honourable. I feel proud that the work that 
I do can have a positive impact on people’s 
lives, helping them make better and more 
prudent financial decisions. 

The ethos of the Company from top to 
bottom is geared towards helping us achieve 
these outcomes for our customers and it 
makes our job easier knowing that we have 
this support. I am proud to say who my 
employer is and look forward to building 
on my ongoing relationship.

2022 has been a year of change and 
challenge in the UK, with all of us having to 
adapt in some way to new ways of living; the 
current situation is very real and has become 
a daily consideration. The power of people 
can help to make amazing changes; if we 
continue to focus on the importance of each 
of our contributions, what they mean and 
how it all connects to our ultimate purpose 
of helping households save money, we can 
continue to deliver products and offers that 
can truly help and support all our customers. 

I find it to be incredibly 
meaningful knowing that 
the work I do can be 
intrinsically connected to 
benefit us all...

28

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Moneysupermarket.com Group PLC

 
 
Section 172 of the Companies Act 2006 – Stakeholder Engagement

Who are the Group’s 
key stakeholders?

Engaging regularly with our stakeholders 
is fundamental to the way we do business. 
This ensures we operate in a balanced 
and responsible way, both in the short 
and longer-term. We are committed to 
maintaining good communications and 
building positive relationships with all 
our stakeholders, as this is essential to 
ensuring our business fulfils its purpose 
and remains sustainable. The Group 
considers our key stakeholders to be 

those individuals or groups who have a 
significant interest in, or are affected by, 
the activities of our business. We work 
with a significant number and variety 
of stakeholders including customers, 
suppliers and providers, shareholders and 
the wider communities and environment 
that we operate within. During 2022, our 
Board has striven to balance the different 
priorities and interests of these stakeholder 
groups with due regard to the matters set 

out in section 172 of the Companies Act 
2006 and consider them when taking 
decisions. The information included below 
outlines how the Directors have performed 
this duty, having regard to a range of 
stakeholder feedback, as well as balancing 
the need to maintain a reputation for high 
standards of business conduct and to act 
fairly between the members of the Company.

Customers

Why it is 
important 
to engage

Customers’ 
key interests

Our success is dependent upon our ability to understand and respond to the needs of our customers. 
This allows us to provide relevant products and services where customers can make meaningful savings, 
differentiating us from our competitors.

•  Products and services

•  Range of products and services

•  Competitiveness and value

•  Ease of use and convenience

•  Compliance with data protection regulation

•  Accurate and up-to-date information

How we engage

•  For Moneysupermarket.com we implemented a 

•  Our live chat service across more channels 

continual customer satisfaction survey in October 
to help monitor our performance and customer 
perception across a range of indicators including 
customer satisfaction, functional drivers such as 
ease of use and emotional drivers.

within MoneySuperMarket gives customers the 
opportunity to receive responses to queries in real 
time. We also have a dedicated “Contact Us” page on 
Moneysupermarket.com which provides customers 
with the opportunity to provide feedback directly.

•  In our FAQs on MSE we provide a number 
of difference contact details if consumers 
want to contact us.

•  Quidco undertake testing and surveys with 

customers, and customers can contact Quidco 
via an active social media channel. 

•  We monitor our customer KPIs, including our net 
promoter score (‘NPS’) metric and associated 
feedback, closely.

How the 
Board engages

Significant 

feedback

Indirect engagement:

•  Regular functional update agenda items at Board 

meetings provided the Board with the opportunity 
to discuss the voice of the customer with the 
relevant Executive Team members.

•  The Board received updates on the key insights 

gained from quantitative and qualitative customer 
research used to inform our strategy.

•  Our Board members received reports on our customer 

NPS metric and other customer-related KPIs.

•  For Moneysupermarket.com the customer 

satisfaction survey highlighted that customers were 
satisfied with our user-friendly platform, money-
saving offers, and quantity of products. It also 
identified a number of areas that we can improve, 
such as clearer communication in certain areas. 

•  Customers would also welcome the opportunity 
to utilise a chat function to receive feedback in 
real time.

•  Quidco customers indicated in their survey 

responses that they would like cashback paid faster 
and to have a browser extension. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

29

Strategic ReportSection 172 of the Companies Act 2006 – Stakeholder Engagement continued

Customers continued

Outcomes

•  In response to feedback, in 2022 we changed how 

customer satisfaction is measured to ensure that we 
could capture and report more meaningful data.

•  We extended our live chat service across more 
channels to give customers the opportunity to 
receive responses to queries in real time.

•  We improved the “Contact Us” page on 

Moneysupermarket.com to provide a more user-
friendly and easy to navigate journey for customers, 
which also helps us to provide a more efficient 
response, and in many cases a one-contact resolution.

•  MSE launched its Compare+ car insurance tool to 
provide helpful tips to users looking to compare 
car insurance quotes on Moneysupermarket.com.

•  MoneySuperMarket launched its Super Save Price 

Promise where if customers find a better like-for-like 
deal from the same provider, we not only refund the 
difference but also give customers a choice of a £20 
gift card, with an easy to use claim form.

•  MSE launched its mobile app to improve the user 
journey and enable customers to quickly access 
money-saving news, top deals and in-depth guides, 
as well as vital cost of living help.

•  Quidco has refined its focus on its proposition, 
including initiatives to offer faster cashback 
payments for selected merchants (pilot ongoing) 
and a browser extension that helps customers to 
remember to use Quidco for all their purchases. 

Employees

Why it is 
important 
to engage

Employees’ 
key interests

A highly skilled and motivated workforce is essential to the success of the Group. We work to create a diverse 
and inclusive workplace where employees can reach their full potential. Engaging with our employees ensures 
we can retain and develop the best talent. During 2022, employee engagement continued to be adapted to 
reflect our hybrid way of working, with increased communication and engagement via online mechanisms. 

•  Company purpose and reputation

•  Training and development

•  Reward

•  Career opportunities

•  Employee engagement

•  Wellbeing

•  Health and safety

•  Equality

How we engage

•  Our CEO used a variety of face-to-face, virtual and 

hybrid methods to stay connected with employees, 
including “Ask Peter Anything” sessions across 
our locations.

•  We continued to explore a range of virtual, in-person 

and hybrid communication methods for our 
employee engagement to ensure that all employee 
voices are heard.

•  We have nine active Employee Resource Groups 
(‘ERGs’), including ERGs for mental health and 
inclusion of under-represented groups, which we 
engage with to help ensure our people can thrive. Our 
ERGs have Executive sponsors and regular contact 
with our designated NED Employee Champion.

•  We conduct a biannual employee engagement 

survey, and the results are reported to the Board. 

•  We continued to run a fortnightly all-employee 
“floor brief” to update colleagues on business 
developments and provide an opportunity to ask our 
Executive Team questions, and have incorporated 
the use of a live feedback survey tool to make it 
easier for employees to provide real-time feedback.

•  As part of the Board’s commitment to the Race at 
Work Charter, material or cumulative incidents of 
micro aggressions are raised to the Board via the 
whistleblowing report.

•  We have an independent whistleblowing helpline 
to allow all staff to raise concerns confidentially.

•  We have a designated NED Employee Champion, 
Sarah Warby, who has Board responsibility for 
championing the interests of employees by bringing 
their views to the Boardroom, and an employee-led 
Group Employee Forum to feed back the needs, 
views and concerns of employees to the designated 
NED Employee Champion.

•  Following external announcements, internal 
Group-wide updates were held to gain an 
understanding of the reaction of employees to 
the trading updates, and respond to any queries 
or concerns.

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Employees continued

How the 
Board engages

Direct engagement:

Indirect engagement:

•  Our Non-Executive Directors held quarterly informal 
sessions with employees to understand what it feels 
like to work at Moneysupermarket Group. The Board 
held meetings in Manchester, London and Ewloe 
during 2022, offering employees in each of these 
locations the opportunity to feed back directly. 

•  The Board received updates from the NED Employee 

Champion on employee engagement.

•  The Board reviewed succession planning across the 
Group to ensure that both short-term and long-term 
interests are aligned between all stakeholder groups 
and the Company’s values and culture.

Significant 
feedback

•  Our designated NED Employee Champion, Sarah 

Warby, who has Board responsibility for 
championing the interests of employees by bringing 
their views to the Boardroom, engaged with our 
Employee Resource Groups. 

•  Our Executive Team presented updates to the Board 
on their respective areas, to provide feedback and to 
invite the Board to provide challenge.

•  Overall colleague engagement through our 

engagement surveys remained high; 84% of our 
employees took part in our November 2022 
engagement survey which covered a range of topics 
such as leadership, communication, “My manager’ 
and DEIB ‘Diversity, Equity, Inclusion and Belonging’.

•  Through the “Ask Peter Anything” session, 

employees provided feedback to our CEO on hybrid 
working arrangements, remuneration and benefits 
in the cost of living crisis and the performance of the 
different business areas. 

•  The Board received the results of the biannual 

employee engagement survey.

•  The Board received reports relating to our independent 
whistleblowing helpline which allows all staff to raise 
concerns confidentially.

•  As part of its regular functional updates, the Board 

received regular updates on our diversity and 
inclusion progress.

•  Feedback was obtained during a “Women in Tech” 
event that career development opportunities for 
women could be limited where an inadequate level 
of support was received from line managers. 

•  We undertake exit interviews when our employees 
leave to gain feedback which can be escalated to 
relevant senior leaders, as appropriate.

Outcomes

•  We answered employee questions or concerns 

raised during our regular “floor brief” sessions and 
any agreed actions were followed up by the 
Executive Team. 

•  The Senior Leadership Team supported an initiative 
to enable women in tech to seek support from the 
wider senior leadership population if required, in 
order to enhance career progression.

•  Following feedback from employees on the hybrid 
working structure, individual teams were given the 
flexibility to choose their own in-office working days.

•  Our employee engagement has been reviewed to 
ensure that a there is a programme of employee 
engagement throughout the year to obtain feedback 
on different areas.

•  Following queries from employees on the 

performance of the MSMG pension scheme, we 
worked with our pension provider to offer a series of 
seminars to employees to help them to understand 
how the investments work. 

•  We made a one-off payment of £2,000 to all 

employees earning less than £55k to help with 
the increased cost of living.

Shareholders

Why it is 
important 
to engage

Shareholders’ 
key interests

Access to capital is vital to the long-term performance of our business and the Board aims to understand the 
views of shareholders and to always act in their best interests. We ensure that we provide fair, balanced and 
understandable information to shareholders and investment analysts and work to ensure they have a strong 
understanding of our purpose, strategy, performance, culture, values and ambitions.

•  Financial performance, economic impact and 

•  Dividend growth/return on investment

market competition

•  Governance and transparency

•  Operating and financial information

•  Confidence in the Company’s leadership

•  Sustainability

•  Strategic progress

•  Total shareholder return 

Annual Report and Accounts 2022
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31

Strategic ReportSection 172 of the Companies Act 2006 – Stakeholder Engagement continued

Shareholders continued

How we engage

•  The CEO and CFO, together with our Investor 

Relations team meets with shareholders, potential 
investors and analysts throughout the year to 
discuss any business developments and respond to 
any ad hoc queries.

•  We held an informal dinner for our analysts to meet 
our Executive Team and gain a greater understanding 
of our strategy and the different areas of our 
business operations.

•  We transitioned from virtual meetings to hybrid and 
in-person meetings for our shareholder meetings 
and results presentations to provide a greater level 
of engagement.

How the 
Board engages

Direct engagement:

Indirect engagement:

•  The Board attended our AGM to offer shareholders 

the opportunity to engage and raise questions about 
the Group’s performance.

•  Feedback is gathered from key investors at results 
roadshows and investor conferences and tabled 
to the Board.

•  The Chair of the Remuneration Committee 

•  The Board received updates from the Group’s 

consulted with the Group’s top 15 shareholders 
in November 2022 in relation to our proposed 
Remuneration Policy (see the principal decision 
on page 35 for further information).

Investor Relations Team during specific consultation 
exercises and on publication of trading results 
and updates.

•  Investor associations’ voting recommendations 

and commentary on our general meeting resolutions 
and Annual Report and Accounts are brought to the 
Board’s attention ahead of our Annual General Meeting.

•  Analyst reports are provided to the Board. 

Significant 
feedback

•  Following engagement with shareholders on 

•  The General Counsel and Company Secretary, 

the proposed Remuneration Policy, we received 
feedback in relation to the Restricted Share Plan 
underpins. See page 35 for detail on this 
principal decision. 

together with the Deputy Company Secretary, met 
with two significant shareholders in November 2022 
to discuss the Group’s governance and sustainability 
and provided the Board with an update on 
discussions at its December 2022 meeting. 

Outcomes

•  All resolutions at the 2022 AGM were approved.

•  The Group’s Sustainability Report has clearly 

•  The Remuneration Committee agreed to formally 
document within the Restricted Share Plan Rules 
that only downward discretion would be applied 
in respect of any vesting outcomes. 

articulated the Group’s Sustainability Framework 
and the Group’s governance structures, objectives 
and progress. 

Suppliers and Providers

Why it is 
important 
to engage

Our third parties, such as the providers who provide products through our channels and the suppliers who 
provide goods and services to us, are critical to our performance. We engage with our third parties to build 
trusting relationships from which we can mutually benefit and to ensure that they are performing to our 
standards and conducting business to our expectations.

Suppliers’ 
key interests

•  Cost efficiency and value

•  Long-term relationships

•  Efficient customer acquisitions

•  Value creation

•  Responsible business, trust and ethics

•  Data

How we engage

•  Our Commercial Team provides a crucial link with 
our providers, actively managing the provider 
relationships to ensure best value outcomes.

•  We work collaboratively with our top two tiers of 
provider to agree joint business plans, a highly 
successful initiative that has increased engagement 
and had a positive impact on our trading. 

•  We undertook provider satisfaction surveys to gain 
feedback on our account management processes, 
product changes and onboarding processes to 
identify any areas for improvement, and to inform 
our strategic choices for 2023.

•  We engaged our suppliers in a variety of ways including 
tender processes and more informal meetings and 
dialogue. These interactions cover a broad range of 
topics such as cost efficiencies and ways of working. 
We conducted revenue audits on selected providers 
and third party audits on a sample of our suppliers.

•  Quarterly reviews are held with commercial partners 

of Quidco, where partners are able to feedback 
directly to Quidco. 

•  In 2022 we cemented the use of our governance, risk 
and compliance tool to provide increased visibility 
and reporting on our supply chain, which can then 
be communicated to the Board.

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Suppliers and Providers continued

How the 
Board engages

Indirect engagement:

•  The Board approved key Tier 1 contracts, retaining 
oversight for those contracts which are significant 
either in terms of value or strategic importance to 
the Group.

•  The Board received supplier oversight updates to 
understand the level of supplier engagement and 
any arising risks in the Group’s supply chain or 
supplier management activities.

•  Key supplier and provider updates are brought to the 
Board through our regular functional agenda items 
and in the annual strategy sessions.

Significant 
feedback

survey that additional data propositions to sit 
alongside our current offerings would be welcomed. 

•  We reviewed feedback from our provider satisfaction 

•  We received feedback from suppliers and our 

Outcomes

•  We have invested in the car aggregation platform which 
has dramatically accelerated motor product onboarding.

•  We have significantly improved the data and insights 
provided to providers by transitioning to Tableau for 
our insight packs and providing more granular 
performance data on a more frequent basis.

management teams that the process for onboarding 
suppliers could be enhanced to ensure a smoother 
and more efficient journey.

•  We have improved engagement in our Money 

vertical, where trading was tougher as a result of 
COVID-19, and were able to provide improved 
offerings to customers as a result, especially through 
our banking channels. 

•  We have reviewed our supplier onboarding process 

and contract approval limits to ensure a more 
streamlined process, whilst maintaining appropriate 
oversight and rigour.

Communities and Environment

Why it is 
important 
to engage

Communities’ 
key interests

How we engage

How the 
Board engages

We are committed to building positive relationships with the communities in which we operate. We support 
communities and groups local to our offices and consider the environmental and social impacts of our operations. 
We seek to ensure that we provide a positive contribution to the communities in which we operate and to 
the environment.

•  Local operational impact

•  Climate-related risk, commitments, performance 

•  Health and safety performance

and reporting 

•  We provide support to charities local to our offices 
and beyond through donations and community 
support initiatives (see page 47 for more details).

•  We continued to partner with Nanny Biscuit in an 

initiative to support the local community and reduce 
food waste. 

•  Long-term partnership and strategic alignment

•  We partnered with The Prince’s Trust for a fourth 
year to provide meaningful support to deprived 
young people over the long term, via fundraising 
initiatives including a Future Steps challenge and 
a Three Peaks fundraising challenge.

•  We provided sponsorship for Black Business Week 

in October 2022 and our Chief People Officer 
participated in a panel discussion on allyship.

Direct engagement:

Indirect engagement:

•  The Board approved a Group Sustainability 
Framework, and the formation of a Risk and 
Sustainability Committee, to closer align its 
ESG activities with its clear social purpose.

•  The Board receives an annual update on our 

charities and communities initiatives from the 
Chief People Officer.

•  The Board has overseen the Group’s external 

climate-related commitments, including a revision 
of the Group’s net zero targets.

•  Regular updates were provided to the Board on 
sustainability throughout the year, including on 
our TCFD Report.

Significant 
feedback

•  We received feedback from our investors about 

our sustainability plans. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

33

Strategic ReportSection 172 of the Companies Act 2006 – Stakeholder Engagement continued

Communities and Environment continued

Outcomes

•  The Board approved a new Group Sustainability 

•  We supported local families and our communities 

Framework with underpinning governance. 

•  To encourage our colleagues to help in their 

and helped several groups to restart their 
communities work.

community, a charity, or an initiative that supports 
the Group’s purpose of helping households save 
money, we provide paid time off to volunteer. 

•  We donated £100,000 to the Princes Trust, 

which offer grants of up to £7,500 to support 
any non-profit organisation.

•  We have continued to reduce our greenhouse gas 

•  The Board approved our 2022 Task Force on 

emissions as a result of our carbon reduction strategy.

Climate-Related Financial Disclosures (‘TCFD’) Report 
– see pages 48 to 51 for details.

Regulators/Government

Why it is 
important 
to engage

Regulators’ 
key interests

Open communications and dialogue help to create understanding of our business, strategy and culture 
and ensure regulatory and legislative compliance.

•  Openness and transparency

•  Treating customers fairly

•  Proactive and compliant with new regulations 

•  Impact on the environment

and legislation

•   We have engaged with the FCA on regulatory 
developments to ensure our implementation 
approach meets regulatory expectations.

•   We provide training and support colleagues on the 
importance and implication of the GDPR regime as 
part of our cyber security training and of their 
regulatory responsibilities under the FCA’s 
Conduct Rules.

•   Our MSE team engaged with the Government on 
various campaigns including the future of the 
energy price cap.

•  The Board reviewed the Group’s FCA Consumer 

Duty Plan in October 2022.

•   The Board received updated SM&CR training 

in August 2022.

How we engage

•  Our Risk and Compliance team works across the 

Group to ensure it remains compliant with any new 
and existing regulation.

•  We provide the FCA with quarterly, half-yearly and 

annual reporting that includes information on sales, 
complaints and regulatory capital. This reporting is 
one of the FCA’s supervisory tools.

•   We maintain regular and ongoing dialogue with key 

regulatory bodies, including the FCA, Ofgem and CMA 
and, where appropriate, the ICO, ASA and Ofcom.

•   We have monitored and responded to new and 
emerging regulatory developments, including GI 
pricing, FCA Consumer Duty and the energy 
market crisis.

Indirect engagement:

•   Regular updates are provided to the Board as well 
as specific reports/updates on any significant 
interactions with regulators.

•   The Board received updates on the Government’s 
BEIS proposal on ‘Restoring trust in audit and 
corporate governance’ and considered implications 
for the Group.

How the 
Board engages

Significant 
feedback

•   We received feedback on the Group’s 
implementation of GI pricing rules.

Outcomes

•  The Board approved of the Group’s FCA Consumer 

Duty Plan in October 2022.

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Long-term decision making

The Board delegates day-to-day 
management and decision making to its 
senior management whilst maintaining 
oversight of the Company’s performance, 
and reserves to itself specific matters 
for approval, including the strategic 
direction of the Group, M&A activity 
and entering into material contracts 
above set thresholds. 

In 2022 the Board:

•  received presentations on specific 

business areas and, through ongoing 
discussion with members of senior 
management, determined strategic 
priorities and the development of 
robust supporting operating plans;

•  agreed the Group’s principal risks, 
considered emerging risks and 
received regular risk management 

and internal control reviews 
throughout the year, including specific 
consideration of risks arising from 
regulatory changes and changes to the 
energy and insurance markets; and

•  set annual budgets and capital 

allocation and oversaw business 
performance against targets, enabling 
the Board to confirm the going 
concern statement and the Group’s 
longer-term viability.

Reputation for high standards of business conduct

The Board is responsible for developing 
a corporate culture across the Group 
that promotes integrity and transparency. 
It has established a comprehensive 
corporate governance framework and 
approves policies and procedures which 
promote corporate responsibility and 
ethical behaviour. 

In 2022 the Board:

•  received regular reports from the Chief 
Risk Officer designed to strengthen 
governance and compliance, and the 
identification and management of 
existing and emerging risks;

•  approved the Company’s Modern 

Slavery Act Statement, describing the 
steps it had taken to ensure that 
slavery and human trafficking were 
not taking place; and

•  received regular governance updates 

and training on key areas of law 
and regulation;

•  reviewed the Group’s implementation 
of the 2018 UK Corporate Governance 
Code, ensuring that the Group 
continued to remain compliant with 
the Code.

Principal Decisions

Principal Decision – Remuneration Policy consultation

During November and December 2022 
eight meetings took place between the 
Group’s largest shareholders and the 
Interim Remuneration Committee Chair, 
the Remuneration Committee Chair 
Designate, the Chair and the Group 
General Counsel and Company Secretary. 
15 meetings were offered and several of 
those shareholders who did not request 
a meeting provided written feedback. 

acceptance of a move to Restricted Share 
Awards ‘Scheme’ for the Executives, they 
wished to see further information about 
the Scheme’s proposed underpins, 
understand how these had been applied 
in the context of proposed awards, and 
understand the expected nature and 
extent to which the Remuneration 
Committee would seek to exercise its 
discretion upon vesting. 

The feedback confirmed that whilst a 
number of shareholders indicated their 

The Remuneration Committee considered 
the feedback in detail and agreed that 

should the proposed Scheme be 
approved by shareholders at the AGM 
on 4 May 2023, future Group Directors 
Remuneration Reports will be transparent 
as regards those underpins applied at 
Scheme grant and provide a detailed 
explanation of the Group’s execution of 
the Scheme. The Remuneration Committee 
further agreed to formally document within 
the Scheme rules that only downward 
discretion would be applied in respect 
of any Scheme vesting outcomes. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

35

Strategic ReportSustainability

Sustainability 
for success

I am so proud of the strides we 
have made to clearly articulate our 
Group Sustainability Framework 
and all the great things we’ve 
delivered during 2022. 

Shazadi Stinton
General Counsel and Company Secretary

My role as Group General Counsel and 
Company Secretary includes having 
responsibility for the Group’s sustainability 
strategy, and how we make sure we 
continue to focus on what’s important for 
the resilience of our Company; to continue 
to reduce our impact on the environment, 
to have a positive impact on society, and 
to continue to ensure we run our Company 
ethically and with good governance practices.

In 2022 we have adopted our new MSMG 
Sustainability Framework. We have set 
ourselves ambitions across each area 
under our Sustainability Framework. For 
example, under our Environmental pillar 
we have confirmed our commitment to 
becoming Operational Net Zero by 2030; 
under our Social pillar to ensure we are 
benefiting our communities whilst also 
looking after our employees and under our 
Governance pillar, living our purpose and 
values across the Group. Further information 
can be found on our Sustainability 
Framework on page 37 in this report.

Alongside our Sustainability Framework, 
in 2022 we have also introduced our new 
Sustainability Governance Framework, 
with the aim of providing our stakeholders 
greater clarity of how our sustainability 
strategy is governed. Together with the 
Board, and the Risk and Sustainability 
Board Committee’s oversight, we also have 
an Executive level Risk and Sustainability 
Committee to ensure the Group is on track 
to hit internal and external sustainability 
targets, and to further embed sustainability 
within the business, we have introduced 
a new Sustainability Steering Committee 
with cross-functional representation. 
During 2023 we will introduce a new set 
of measures under each pillar which will 
be tracked via regular reporting to the 
Risk and Sustainability Committee.

We have undertaken a number of projects 
across the year to help our employees 
and our communities. Highlights include 
providing workshops for our employees 
on how to reduce waste and how to have 
a sustainable Christmas, using our carbon 
offset projects to help some of the poorest 
communities across the world, reducing 
our food waste whilst providing meals to 
our local community in Ewloe, and 
supporting the financial fitness of our 
colleagues through a £2,000 one-off cost 
of living payment to all those earning 
below £55,000. 

We know we still have more to do, and 
in 2023 we will continue to reduce our 
environmental impact, focus on our social 
responsibility to our communities and our 
employees and ensure we have robust 
governance and ethics in place; whilst 
always striving to deliver on our purpose 
of helping households save money. 

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sustainability further into account in terms 
of our strategy, decision making, operations 
and behaviours.

Our culture
We are proud of our organisational purpose 
and our culture is built around delivering for 
our customers and users and being a socially 
responsible and thoughtful employer.

“ Great people to work with 
across teams with a focus 
to get things done.”

Engagement survey comment 
(November 2022)

We build our culture through nurturing 
and promoting high performance and 
the wellbeing of our employees and 
communities. Our Company behaviours 
of “Create Belonging”, “Grow and Develop” 
and “Innovate to Deliver” are our common 
language and a clear everyday standard of 
what we believe in, value, and expect of 
each other, irrespective of role. 

Our Chief People Officer is the Executive 
Sponsor for our Social pillar under our 
Sustainability Framework, further details 
of which are contained in this report. 
Our voluntary Employee Resource Groups 
(‘ERGs’) form a vibrant community that 
help build wider learning, awareness and 
engagement. In 2022 they have been 
involved in a wide range of activities 
including awareness talks on ADHD, 
autism, suicide prevention, Pride, and 
Crohn’s and colitis – invisible illnesses, 
as well as a mental health masterclass 
for men.

In 2022 we also established a new ERG 
– Women in Tech (‘WIT’). In this ERG we 
have pioneered and established peer 
mentoring circles with WIT from external 
organisations and have also attended 
conferences as well as understanding 
sessions on pay and career development 
within the Group. Our Green Team ERG 
contributes to the Group’s commitment 
to achieve operational net zero by 2030 
and our Tech Zero industry partnership.

Sustainability overview
With the deepening cost of living crisis, our 
purpose of helping households save money 
has never been more important. As a 
business, we’re committed to limiting our 
impact upon the environment; treating 
everyone with respect; and meeting our 
purpose in an ethical, honest and 
sustainable manner.

In 2022 we have produced our new Group 
Sustainability Framework to provide a 
clearer overview of our approach to 
sustainability. We have also significantly 
evolved our Group’s governance 
of sustainability. 

The framework sets out our overarching 
sustainability ambitions, together with our 
top three priorities under each pillar. The 
new governance structure will ensure 
appropriate oversight of the Group’s 
sustainability strategy and framework and 
risks, as well as the Group’s sustainability 
commitments and performance. 

With greater focus on the Group’s 
Sustainability Framework, it is intended 
that a cultural shift will be created across 
the Group, with the purpose of taking 

MSMG Sustainability Framework

Our purpose

Helping households save money

Environmental: 

Social: 

Governance: 

Minimising our 
environmental impact

Our social responsibility 
to our communities 
and employees

Robust governance 
and ethics

1. Net zero and beyond

1. Benefiting our communities

1.  Living our purpose and values

2. Reporting our progress 

2. Looking after our employees

2. Good business ethics

(Task Force on Climate-Related 
Financial Disclosures, Carbon 
Disclosure Project and Annual 
Report and Accounts)

3. Our environmental initiatives

3. Being a fair and socially 

inclusive employer

3.  Sustainable governance

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

37

Strategic ReportSustainability continued

Sustainability overview continued

Our culture continued
In 2022 we ran two employee engagement 
surveys. 84% of our employees took part 
in our November 2022 engagement survey, 
which asked a variety of questions about 
culture and employee experience. On top 
of the anonymous survey questions, 
employees took the time to leave verbatim 
comments on a range of topics such as 
leadership, communication, “My manager” 
and diversity, equity, inclusion and belonging 
(‘DEIB’) which was hugely encouraging to see 
and helps us take sustained action on pinch 
points across teams.

Each of the survey dimensions trended up 
over the year, with the exception of one 
which formed part of our organisation-
wide action planning to deep dive into 
improvements. 74% of our colleagues 
said that they would recommend us as 
a great place to work.

Some of the highlights we’re proud of are:

•  91% of respondents believed their 
manager created an environment 
where they could be themselves; 

•  89% said their manager valued their 
perspective even if different from 
their own; and

•  85% agreed they knew how their 

work contributed to our objectives.

Minimising our environmental impact
Whilst the Group is not a major energy 
user, we are aware of our impact on the 
environment and we strive to reduce our 
environmental impact by reducing our 
carbon emissions and waste, and sourcing 
responsibly. Our Spinningfields (Manchester) 
office is BREEAM rated Excellent, and we 
utilise a 100% renewable electricity tariff 
across all of our core offices. 

pathway, and that our targets are sufficiently 
ambitious. As a result, we have taken a bold 
step to increase the targets we set in 2021 
to ensure that we are doing all we can to 
reduce our emissions. 

We have significantly increased our 
medium-term target for reducing Scope 1 
and 2 emissions by 2030 from 45% to 67% 
against our base year. In addition, we have 
also increased our target for reducing 
Scope 3 emissions by 2030 to 46% (2021: 
45% by 2030). Our long-term targets are 
more ambitious again: we have increased 
our targets to reduce Scopes 1, 2 and 3 
emissions by 10% and are now committed 
to reducing emissions across these scopes 
by 90% by 2050 (2021: 80% by 2050).

As part of our operational net zero 
commitment, we:

•  measure all of the Group’s carbon 
emissions, including Scope 3, and 
report them publicly each year;

•  publish details on our corporate website 
on how we plan to reach operational 
net zero;

•  continue to be a Beyond Carbon 

Neutral business;

•  continue thinking about how to 

communicate our climate commitments 
in other meaningful ways, including to 
our shareholders, employees, customers, 
users and the wider community in which 
we operate;

We continue to be a constituent of the 
FTSE4Good Index Series and we are firmly 
committed to the Science Based Targets 
initiative (‘SBTi’) to set science-based 
emissions reduction targets across 
all scopes, in line with 1.5°C emissions 
circumstances and the criteria and 
recommendations of the SBTi, and we 
look forward to providing further details 
on this in 2023.

Operational Net Zero by 2030
We are firmly committed to reaching 
operational net zero emissions by 2030. 
Operational net zero is a state where an 
organisation’s activities result in no net 
impact on the climate from greenhouse gas 
emissions. This means limiting the Group’s 
carbon footprint in line with keeping global 
warming to below 1.5ºC – the critical level 
of heating to avoid the worst impacts of the 
climate crisis. 

We are making good progress towards our 
operational net zero target (see our GHG 
Report on page 42 for details) and in 2022 
we undertook a review of our operational 
net zero targets to ensure that we remained 
aligned with the 1.5⁰C decarbonisation 

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We keep our employees actively involved 
and consulted about Group activities and 
business performance through a range of 
internal communication channels. These 
include: small group “Ask Me Anything” 
sessions with the CEO; fortnightly CEO and 
Executive-led virtual and hybrid floor briefs, 
where employees can ask questions or give 
feedback; Scoop – our weekly e-newsletter; 
monthly functional all-hands meetings led 
by the Executive Team; our internal intranet; 
Microsoft Teams posts and corporate 
announcement emails. Following the 
appointment of Sarah Warby as Non-
Executive Director Employee Champion 
in 2018, we introduced a programme 
of listening sessions. In 2022 we have 
continued to run these frequent “NED 
Breakfasts” giving employees at all levels 
of the organisation an opportunity to give 
direct and unfiltered feedback to our 
Board on life at Moneysupermarket Group.

•  report on our progress against our short 
and medium-term targets to the Board 
on a regular basis;

•  provide updates on our progress via 
our Annual Report and our corporate 
website; and

•  commit to having a member of our 
Executive Team responsible for our 
net zero target.

Carbon Disclosure Project
In 2022, Moneysupermarket Group again 
chose to complete a full climate change 
disclosure to the Carbon Disclosure 
Project (‘CDP’) detailing the commitments 
we have in place to manage our impact on 
the environment.

The CDP is a not-for-profit charity which 
for the past 20 years has led the way 
in creating comparable, transparent 
disclosure for companies, cities, states 
and regions around climate change. 
We have retained our ‘C’ rating1 which 
puts Moneysupermarket Group in the 
Awareness bracket, in line with the average 
score for our sector. We are committed to 
improving our climate governance in line 
with feedback received and will continue to 
provide updated CDP disclosures annually 
going forward.

1  On an eight-point A–D scale.

Key initiatives in 2022
To achieve our operational net zero 
ambitions, we have undertaken several 
environmental initiatives this year to both 
actively reduce our carbon emissions and 
to improve our emissions reporting. 

In 2022, we have increased employee 
awareness of our carbon reduction plan 
and, as our hybrid working arrangements 
have continued into 2022, we have 
provided advice to employees on how 
behavioural changes can help them to 
reduce both the Group’s carbon footprint 
and their own carbon footprint whilst 
working from home. 

To do this we have used a variety of 
communication channels including:

•  Group-wide internal “floor-brief” updates 

led by our CEO and Executive Team;

•  our “MoneySuperScoop” newsletter 

and “Hub” intranet; and 

•  in-office communications, including 

a poster campaign.

In conjunction with our proactive and 
passionate Green Team, which devises 
and implements local energy-saving and 
waste reduction initiatives, we have also:

•  undertaken an employee commuting 

survey to maximise our Scope 3 
reporting and understand how we can 
help employees to commute more 
sustainably;

•  worked with Giki to educate employees 
both on their personal environmental 
impact, and on how to have a sustainable 
Christmas (see page 40 for details);

•  improved our reporting on the waste 

we generate in our offices; 

•  provided battery charging points and 

chargeable batteries in our head office; 
and

•  partnered with a local charity to reduce 
our food waste by donating our surplus 
food to the local community. 

Beyond Carbon Neutral
For the emissions that we haven’t yet been 
able to eliminate, we have continued to 
offset 150% of these via verified carbon 
offset projects to ensure that we not only 
reduce our negative impact but also have 
a long-lasting and positive legacy for the 
environment, as a Beyond Carbon 
Neutral company.

This year, we were keen to ensure that 
we selected offset projects that had a 
significant benefit for the environment, 
and were aligned to our purpose of helping 
households save money. We chose to 
invest 50% of our offset in an afforestation 
project and asked our employees to help 
us to choose the projects for the 
remaining offsets. 

Project 1

Project 2

Project 3

Degraded land 
afforestation, 
Uruguay
The main objectives of this project are 
sustainable wood production, land 
restoration and carbon sequestration 
through afforestation. In addition to 
delivering over seven million tonnes 
of emissions removals over the 
project’s lifetime, the project provides 
new income and job opportunities to 
local communities in rural areas of 
Uruguay, while respecting existing 
cattle farmers’ land use.

Bondhu 
Chula stoves, 
Bangladesh
Less than 20% of the 35 million 
Bangladeshi households have access 
to clean cooking. Traditionally, cooking 
is done over an open fire pit, releasing 
smoke and particulate pollutants. 
These pollutants contribute to nearly 
50,000 premature deaths a year and 
cause millions in the country to suffer 
from lung, eye or skin infections. The 
Bondhu Chula stove cuts carbon 
emissions by 50%; saves families 
money on fuel costs; reduces harmful 
indoor air pollution and provides 
decent work and economic growth. 

Gyapa efficient 
stoves, Ghana
This project introduces families 
in Ghana to an efficient stove, the 
Gyapa, that cooks food more quickly, 
requires nearly 50% less fuel and is 
less smoky. The stove not only cuts 
carbon emissions, but also reduces 
exposure to toxic fumes. Reducing 
the amount of wood used for cooking 
saves families as much as $100 
annually, while protecting Ghana’s 
tree cover, which has decreased 19% 
since 2000 according to Global 
Forest Watch.

Emissions removed over 
project’s lifetime

7m tonnes

Stoves installed to date 
through this project

3m

A family can save up to

$100

on their annual fuel bill

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

39

Strategic Report 
Sustainability continued

Case study

Case study

40

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Giki
Giki is an evidence-led B Corp and 
social enterprise with a mission to 
empower people with the knowledge 
and tools to reduce carbon and 
transform our world, step by step. 

We worked with Giki on an initiative 
to increase our employees’ 
understanding of their own carbon 
footprints, and on the steps to take 
to reduce their emissions in their 
everyday lives. This included an 
introduction to Giki’s science-based 
platform, a workshop on how to have 
a more sustainable Christmas, how 
to spot greenwashing and how to 
reduce waste.

Nanny Biscuit 
Nanny Biscuit is a Flintshire-based 
charity with a passion to engage, 
inspire and support local people to 
build a brighter future. Their strong 
purpose is to increase social 
awareness and community spirit, 
promote good mental and physical 
health, reduce loneliness and isolation, 
and reduce their carbon footprint. 

Our long-term partnership with Nanny 
Biscuit has continued into 2022 with 
Bytes, our on-site catering team, 
working with Nanny Biscuit on an 
initiative that has both minimised our 
food waste and provided much needed 
support to the local community during 
the cost of living crisis.

Every day, any food that we have left 
over from the breakfasts and lunches 
provided to employees in our Ewloe 
office is packaged by the Bytes team 
into individual portions and 
appropriately labelled. A representative 
from Nanny Biscuit visits the office to 
collect the food and distributes the 
meals to the local community.

Minimising our environmental impact continued

Helping customers to make 
sustainable choices
In addition to helping our employees 
to have a more positive impact on the 
environment, we also live our purpose 
of helping households to save money 
by providing guidance to our users and 
customers who want to make low-carbon 
and sustainable choices, and save money in 

a sustainable way. On MoneySuperMarket, 
we provide customers with information 
on what green energy is and how it is 
generated. We also provide functionality 
for comparing green energy tariffs which 
we will continue to promote when the 
energy market conditions improve.

Firmly aligned to our purpose of 
helping households save money, 

our MoneySavingExpert team has been at 
the forefront of providing advice to users on 
how to reduce their energy consumption, 
and save money at the same time, with 
articles containing energy-saving tips, 
advice on how to save energy on appliances, 
energy mythbusters, and advice on how to 
“heat the human, not the home”. 

Our aims for 2023
We recognise that we are only partway 
through our sustainability journey. 
Together with our Green Team, we will 
continue to develop and implement 
initiatives in order to have a positive 
impact on our environment. We will:

•  further embed our Sustainability 
Framework within the Group; 

•  remain Beyond Carbon Neutral whilst 
making further progress against our 
carbon reduction plan;

•  continue our climate-related 

disclosures through CDP, TCFD 
and the FTSE4Good Series;

•  alongside our Green Team, further 
engage our employees on climate 
change issues and share how to 
lead more sustainable lives through 
challenges, events and provision 
of resources;

•  finalise and obtain validation for our 
Science-Based Targets Initiative; and

•  continue to provide guidance to 
our customers and users on 
sustainable choices.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

41

Strategic ReportSustainability continued

Minimising our environmental impact continued

Greenhouse gas (‘GHG’) 
emissions
This section includes our mandatory 
reporting of greenhouse gas emissions 
and global energy use pursuant to the 
Companies Act 2006 (‘Strategic Report 
and Directors’ Report’) Regulations 2013 
and the Streamlined Energy and Carbon 
Reporting (‘SECR’) under the Companies 
(Directors’ Report) and Limited Liability 
Partnerships (Energy and Carbon Report) 
Regulations 2018. The methodology used 
to calculate our emissions is based on the 
GHG Protocol Corporate Standard. 
Emissions reported correspond with 
our financial year.

Set out in the paragraphs below is our total 
annual carbon intensity in tCO2e per £m 
revenue. In addition to this, we also 

disclose specifically against Scope 1, Scope 
2 and Scope 3 as required under SECR. 
Emission factors are from UK Government 
GHG conversion factors for 
company reporting. 

We recognise that 2022 has been another 
unusual year and as such our carbon 
reduction plans will continue to be based 
on 2019, the year our baseline GHG 
assessment was carried out. 

We report annually on our carbon intensity 
in tCO2e per £m revenue and are proud to 
report a 9% year-on-year reduction, and a 
reduction of 63% compared to our 
baseline emissions year, 2019. In addition, 
we report on our kWh per square foot of 
floor area, as this is considered to be the 
best indicator of carbon efficiency across 
the estate. The Group has made a number 

of changes to its estate, due to the 
acquisition of Quidco and formation of ITG 
in 2021. As a result, our kWh per square 
foot of floor area has increased by 6% 
since 2021. When compared to our 
baseline year of 2019, this is a 
27% reduction. 

We also measure the metric of intensity 
ratio of kgCO2e per employee. The 
employee carbon intensity ratio includes 
emissions resulting from all scopes, 
whereas the floor area carbon intensity 
ratio only includes Scope 1 and 2 
emissions relating directly to building 
activity. We are pleased to report that our 
carbon intensity ratio has reduced by 3% 
since 2021 and by 57% since 2019. 
This is due to a consistent reduction 
in emissions despite annually steady 
employee numbers.

Streamlined Energy and Carbon Report 

Set out below is our Scope 1, Scope 2 and Scope 3 as required under SECR:

SECR energy use report:

Energy from:

Scope 1: heating fuels
Scope 2: purchased electricity
Scope 3: employee mileage

Total energy

SECR Greenhouse gas (‘GHG’) emissions in tonnes of CO2e:

Emissions from:

Scope 1 (direct)
Scope 2 (indirect)
Scope 3 (indirect)

Total gross emissions

150% carbon removal

Total net emissions

SECR Intensity ratios:

Floor area: kWh/sq.ft/year
Employees: tCO2e/employee/year
Revenue: tCO2e/£m/year

kWh

2022

431,719
605,232
41,702

2021

220,939
785,815
14,622

1,078,653

1,021,376

Tonnes of CO2e
2022

79
9
13

101

(152)

(51)

2022

10.38
0.14
0.26

2021

45 
135
3

183

(274.5)

(91.5)

2021

9.78
0.29
0.58

42

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Social 
Due to the nature of our businesses, we 
have always been mindful of our social 
responsibility to our communities and 
employees. We believe our purpose and 
values are supported and espoused 
through the support we deliver to our 
communities and to the inclusive and 
open environment that we strive to 
create for our employees. 

Priority 1 – Benefiting 
our communities
We actively champion partner charities 
as well as supporting the communities 
in which we operate. Through our 
partnership with The Prince’s Trust, and 
the MSE charity, we strive to broaden 
and deepen our impact and create a 
legacy, targeting our support to those 
most in need. We provide further 
examples of our work in the community 
on pages 46 and 47 and pages 33 and 
34 of this Annual Report.

Governance 
The Group has a strong governance 
culture in place, as detailed below, that 
underpins our governance ambition and 
helps to protect our trusted brands. 

Priority 1 – living our purpose 
and values
We have a clear purpose that our 
employees understand and embrace. 

Our Code of Conduct applies to 
all employees and sets out our 
commitment to:

(1)  behave ethically;

(2)   comply with relevant laws 
and regulations; and

(3)  do the right thing.

Our Code of Conduct also confirms that 
we respect and uphold internationally 
proclaimed human rights principles as 
specified in the International Labour 
Organisation’s Declaration on 
Fundamental Principles and Rights at 
Work (‘ILO Convention’) and the United 
Nations’ Universal Declaration of 
Human Rights.

In 2023, we will continue to build on 
effective communication of our Code 
and values and recognise our employees 
when they actively engage with and 
demonstrate our purpose and 
our values.

Priority 2 – Looking 
after our employees
We are a responsible employer and 
recognise that our success is dependent 
upon the talent and diverse skill sets of 
our employees. We are a Real Living 
Wage employer. We are committed to 
investing in our employees’ wellbeing 
and creating an environment in which all 
our colleagues can thrive. Focus areas 
for 2022 included supporting the 
financial fitness of our employees 
through the provision of a £2,000 one 
off cost of living payment to all those 
earning below £55,000 as a FTE. In 
addition to the Group’s purpose of 
helping households save money, we 
want to do more to maximise the social 
value that we create. We provide further 
examples of working at MSMG on 
pages 44 to 46 of this Annual Report.

Priority 3 – Being a fair and 
socially inclusive employer
We are passionate about being a fair 
and socially inclusive employer and 
creating an environment where 
everyone who works for us can be 
themselves. We have forward thinking 
targets under our diversity goals and 
report on our gender pay gap and 
voluntarily report our ethnicity pay gap. 
We have also rolled out mandatory 
inclusive leadership training for most of 
our line managers. In 2022 we celebrated 
Race Equality, Pride and other Neuro 
Diverse areas of awareness. We provide 
further examples our approach on 
pages 44 and 45 of this Annual Report.

Priority 2 – good 
business ethics
Good business ethics are demonstrated 
through the policies and procedures the 
Group has in place and how we track 
that our employees are aware of and 
adhering to these policies. Relevant 
policies that help to support our Code 
of Conduct include our Anti-Slavery and 
Human Trafficking Policy for suppliers 
and a separate one for employees; our 
Anti-Bribery and Corruption Policy; our 
Competition Law Policy; and our 
Whistleblowing Policy. Our Code of 
Conduct confirms that we respect and 
uphold international human rights 
principles as specified in the International 
Labour Organisation’s Declaration on 
Fundamental Principles and Rights at 
Work (‘ILO Convention’) and the United 
Nations’ Universal Declaration of 
Human Rights.

In 2022, we undertook a review of all our 
Group policies, to ensure they remain 
fit for purpose, and that employees 
understand the application of these 
policies whilst they are working for 
the Group. 

Priority 3 – 
sustainable governance
In 2022, we formed a Board-level 
Risk and Sustainability Committee 

to continue to ensure Board-level 
oversight of our sustainability strategy. 
We have also established an Executive 
Risk and Sustainability Committee, 
which will oversee our performance 
against all the topics in our 
Sustainability Framework. 

Reporting into the Executive Risk and 
Sustainability Committee is our new 
Sustainability Steering Committee, 
chaired by the Group General Counsel 
and Company Secretary and composed 
of Executives and senior management, 
who will have responsibility for delivery 
of the Sustainability Framework across 
the Group. 

In addition to shaping the Sustainability 
Framework and driving our sustainability 
agenda, the Sustainability Steering 
Committee will oversee:

•  communications;

•  Board engagement; and 

•  educating on sustainability.

With greater focus on the Group’s 
Sustainability Framework, we are 
striving to create a cultural shift across 
the Group to ensure that sustainability 
is further embedded into our strategy, 
operations and behaviours. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

43

Strategic ReportSustainability continued

People and culture 
Our colleagues are the heart of our 
business. We are proud to deliver on 
our purpose of helping households save 
money, whilst continuing to support the 
wellbeing of our 733 (including ITG) 
colleagues across the Group.

2022 has been a busy year. As we have 
settled into our hybrid working pattern 
of a minimum of two days in the office, 
we have continued our focus on physical 
and mental wellbeing as well as ensuring 
that our colleagues remain informed 
and connected. We have invested in 
bringing teams together once again for 
collaboration and all colleague events and 
we have held over 30 small group in-
person “Ask Me Anything” sessions directly 
with our colleagues and CEO Peter Duffy 
to connect teams with our strategy. 
The overall commitment dimension in 
our latest engagement survey trended 
up 11 points versus November 2021.

“ I appreciate that Peter is very 
candid and it feels like he 
is genuinely trying to have 
honest communication.”

Engagement survey comment 
(November 2022) 

Diversity, Equity, Inclusion 
and Belonging
Diversity, Equity, Inclusion and 
Belonging (‘DEIB’) remains a key pillar 
for Moneysupermarket Group. 

We are committed to embracing 
and promoting diversity, inclusion and 
equal opportunity and are proud that 
our Company behaviour of “Create 
Belonging” is part of everyday life as 
one of our key behavioural values.

During 2022 we built on our DEIB strategy. 
This included rolling out inclusive language 
workshops which gave 101 managers and 
members of the People team time and space 
to reflect on the language used every day 
and increased awareness and recognition 
of non-inclusive language at work. 

We continue to be extremely proud of 
our gender diversity. In February 2022 we 
were ranked at number five on the FTSE 
250 Women Leaders Review for females 
on the Board, and at number nine for 
female overall leadership. In December, 
we remained above the benchmark of 
40% women in senior leadership roles:

•  62.5% of our Non-Executive Directors 

were female;

•  44% of our Executive were female; and

•  51% of our Executive -1 were female. 

44 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Case study

Diversity, equity 
inclusion, belonging

John Barrett, Lead Product Manager, Manchester.

Living with disabilities can be an isolating experience especially when it comes to 
your career. I currently live with two separate conditions; I became deafened in my 
right ear in 2015 and I have a genetic condition called Charcot-Marie-Tooth disease, 
which is a neuromuscular condition that damages my peripheral nerves. This is a 
progressive condition which currently affects my mobility in small ways such as 
tripping up on the flattest of surfaces and experiencing severe nerve pain in my 
hands and feet. 

Like most disabled people who can “hide” their disability, I only reveal my conditions 
to an employer once I’ve got the offer of employment, and that was the case back in 
the summer of 2021 when I accepted MSMG’s offer. The reaction from the People 
Team, the senior leaders who conducted the interview and my line manager was 
one of the most positive experiences of my career. They were reaching out at 
regular intervals, discussing how they can make the workplace adaptable to my 
needs and how we can access funding such as “Access to Work” to pay for 
any adaptations. 

My new team was extremely accommodating, especially during our office days, as 
even simple things such as the positioning of my desk and the place I stand in for 
the morning stand-up meetings are key to enabling my full potential. 

When you’re dealing with trying to be the best you can be on a day-to-day basis you 
can understandably not keep a focus on your longer-term ambition, as getting to 
the end of the day not having tripped or being in pain is a big win. My manager has 
been a great support and keeps looking at how I can develop here at MSMG. In 
September 2022, they revealed that as part of the skills framework assessment it 
became abundantly clear that I was operating at a Lead Product Manager level and 
the decision had been made to promote me to that role. To receive that recognition 
is something I’ve not seen in other companies and sets MSMG apart as a great place 
to work. 

As I mentioned, my conditions are progressive and whilst that brings an element 
of uncertainty to my future, I know that from a work perspective whatever happens, 
MSMG will be supporting me every step of the way. 

In May we launched our Family Wellbeing 
Support guidelines covering Menopause 
and Perimenopause, Fertility treatment, 
Pregnancy/baby loss and Domestic 
and other violence. They aim to provide 
transparency on the Group’s approach to 
supporting colleagues to ensure consistency 
and fair treatment from both a colleague 
and manager perspective, whilst taking 
a flexible approach to individual needs. 
The guidelines recognise that these life 
events are not isolated to women, cisgender 
people or heterosexual couples. These 
guidelines aim to help colleagues feel 
empowered to ask for adjustments and 
carry out their daily role in a safe working 
environment whether at home or in 
the office. 

We also partnered with Dyslexia Box 
this year to audit our recruitment and 
e-learning from a neurodiversity and 
disability perspective. The purpose is 
to measure and monitor the Group’s 
neuro-inclusive and disability status, 
progress the current strategy, and 
implement best practices. Full 
recommendations are being considered 
with some changes already adopted.

In addition, in 2022 we have also:

•  voluntarily published our ethnicity pay 

gap for a second year;

•  been recognised at number 33 on the 

Inclusive Top 50 UK Employer List 2022 
by Inclusive Companies;

•  built on our Race Equality Action Plan and 
Race at Work Charter commitments 
through a focus on ethnicity representation 
across all levels of our organisation;

•  sponsored Black Business Week’s 

Allyship panel and signed up to the “Mind 
the Gap” initiative on ethnicity pay gaps;

•  celebrated International Women’s Day, 
Pride, Black History Month and Mental 
Health Awareness Week;

•  taken part in London Pride Parade with 

27 colleagues and their partners 
celebrating the day and representing 
the Group;

•  held awareness sessions and invited 
outside speakers on multiple topics 
from suicide prevention to baby loss 
from a father’s perspective;

•  introduced multi-faith leave, allowing 
colleagues to take additional leave for 
a key religious or cultural festival of 
their choice as an alternative to 
Christmas leave;

•  trained 53 colleagues in British Sign 

Language; and

•  welcomed our first support dog, 

Hamble, into our Manchester office.

Gender diversity and gender 
pay gap
We’ve been reporting our gender pay gap 
since 2018. We understand the drivers of 
our gender pay gap and we are working 
hard to address them. The Group has 
a large percentage of male colleagues 
in Tech, Product and Data, and female 
representation in these areas trend 
behind the rest of the Group. 

Whilst we still have work to do, we continue 
to make progress. 

Our long-term aim is to close our gender 
pay gap and we continue to take action to 
reach that aim, as outlined in the report on 
our corporate website at https://corporate.
moneysupermarket.com.

Ethnic diversity and ethnicity 
pay gap
As part of the Race at Work Charter, 
we committed to publishing our Ethnicity 
Pay gap and 2022 is the second time that 
we are voluntarily reporting. 

Our Ethnicity Pay gap reporting is based 
on the ethnicity data from 78% of 
colleagues who voluntarily shared their 
ethnicity as of April 2022. At the time of 
reporting, 15% of those colleagues came 
from multi-ethnic (ME) backgrounds. 
Our ethnicity pay gap mean is 6%. 
When broken down by the specific ethnic 
groups, the ethnicity pay gap is in favour 
of Asian colleagues (-14.2%) who have the 
highest ethnic representation within 
the Group.

Hiring for diversity remains a focus for 
our Talent Acquisition team and 20% of our 
hires in 2022 who disclosed their ethnicity 
were from multi-ethnic backgrounds.

At December 2022, 20% (three out of 15) 
of our Board and Executive are from 
ME backgrounds. 

Learning and development
Our learning philosophy hinges on the 
concept that continuous development 
should be at the heart of our employee 
offering and not just provided by formal 
classroom learning activities.

We focus on encouraging a growth 
mindset and supporting employees 
through career challenges and 
opportunities by providing practical, 
interactive and reflective learning 
resources on demand. Whilst not always 
possible, we seek to promote and give 
opportunity from within and frequently 
see colleagues move internally into roles.

We have invested £358k in training and 
development in 2022, ranging from 
individual coaching and professional 
development programmes to Group-wide 
upskilling initiatives.

In 2022 18 participants took part in 
LEAD, a Chartered Management Institute 
accredited leadership programme. 
Five cohorts of LEAD are currently 
live, with the last of those set to complete 
the programme mid 2023. LEAD is funded 
by the Apprenticeship Levy and provides 
our managers and leaders with holistic 
development through a combination 
of webinars, applied learning stretch 
activities, and one-to-one coaching 
over a 12 to 18-month period. 

Our mentoring scheme continues, bringing 
together senior leaders with colleagues 
from across the Group. We continually 
evolve this initiative and seek participants 
from a diverse pool of employees, with 
many mentoring relationships continuing 
beyond the defined engagement period.

“ I have had brilliant 
opportunities to grow here, 
which I have taken. This is 
one of the areas that this 
Company does very well 
from my point of view.”

Engagement survey comment 
(November 2022) 

This year we trained 101 leaders in 
inclusive language via our partner UNLRN. 
This training builds on inclusive leadership 
skills and takes leaders through the core 
principles of inclusive language to ensure 
leaders are mindful and aware of impact 
versus intent amongst other practical tips 
in this complex and evolving area. 

We also continued our partnership with 
CybSafe to deliver our mandatory annual 
cyber awareness training. This has allowed 
our employees to access a suite of tools 
covering all aspects of online safety in a 
user-friendly e-learning solution. This 
included modules to keep colleagues 
cyber-safe online when working from our 
offices and remotely, and involved email, 
phone, messaging, social media, internet 
and password security, phishing and cyber 
theft prevention.

Employee benefits
In September 2022 we were pleased to be 
able to pay all our full-time colleagues 
earning less than £55,000 FTE per year a 
one-off cost of living allowance of £2,000. 
Part time colleagues on less than £55,000 
as an FTE received £1,000. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

45

Strategic ReportSustainability continued

Case study

Life at MSMG 

Becca Wright, CRM Executive, Quidco

Quidco being acquired by MSMG has led to so many great opportunities for me. 
MSMG has helped me to grow my own personal skills whilst allowing me to 
express my interests outside of work with my fellow colleagues!

I was very lucky to get the opportunity to work closely with the Represent team 
this year when I signed up to be a part of the Pride 2022 committee. Between 
helping organise the socials across all sites, to helping come up with design ideas 
for the Pride Parade, I was able to express my passion for inclusion within a work 
setting and have lots of fun with the team in the parade itself! Later in the year, 
I was then able to join the Represent team and I look forward to organising further 
events promoting inclusion and diversity within our business.

Furthermore, joining the MSMG Group allowed me to sign up to its great mentor 
scheme. The mentor scheme has allowed me to progress my skills and confidence 
so much. I am hugely grateful to my mentor for allowing me to soak up lots of 
knowledge from within his area of the business and for pushing me to try new 
things! The mentor scheme has been unfathomably useful in helping me achieve 
my career goals, feel empowered and further my knowledge in our industry.

Lastly, I feel so lucky to be working in a company where the impact of the cost 
of living crisis has been actively thought about and help has been implemented. 
The cost of living allowance I received as a result of the increased cost of energy, 
groceries and fuel has been unbelievably beneficial.

Thank you, MSMG, for having ethics 
and inclusion at the heart of our business.

46

Annual Report and Accounts 2022
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Community 
Our aim is to be a force for good and an 
active contributor to our chosen charities 
and the communities in which we operate. 
We are proud to have supported 
numerous causes with our fundraising 
and volunteering initiatives throughout 
the year.

“ There is nothing I need 
that is not provided by 
this wonderful company.”

Engagement survey comment 
(November 2022) 

Our charity partnership 
with The Prince’s Trust
At the end of 2021 we took a decision to 
extend our three-year charity partnership 
with The Prince’s Trust by 12 months, 
as the pandemic had impacted our 
fundraising efforts in years two and 
three of the partnership. 

As with each of our previous years, our first 
initiative of 2022 was “Future Steps” – a 
walking challenge run across the business 
which engaged 83 colleagues and raised 
just over £12,000. 

Quidco took an active part in fundraising 
this year with a team entering two football 
tournaments and raising a total of £1060 
for The Trust.

As we became more comfortable 
fundraising in person, we were 
extremely happy to launch our first 
Moneysupermarket Group adventure 
challenge since 2019, which proved to be 
our most successful fundraiser of the year. 
54 colleagues took part in a 12-hour trek, 
the Yorkshire 3 Peaks challenge, covering 
24 miles and raising a phenomenal 
£31,500, including company matching. 

In September, colleagues raised £1,300 
by engaging in The Prince’s Trust’s flagship 
event “Palace to Palace” and cycling 
45 miles between Buckingham Palace 
and Windsor Castle.

Over the year, our employees raised 
a further £52,000 from fundraising 
activities with the Group, including company 
matching. Towards the end of the year, 
we took a decision to donate a further 
£22,000 to the Trust, rounding up our 
total 2022 donations to £100,000. 

Our fundraising efforts this year also 
earned us a nomination at The Prince’s 
Trust Partnership Awards for the second 
time during our four-year partnership. 
We feel proud of the £423,392 we have 
donated since becoming partners at the 
beginning of 2019 and of the volunteer 
work we have been able to complete 
during this time.

 
“ Having been in 
Moneysupermarket Group 
for over 20 years, this still 
remains one of my favourite 
things to do and I am proud 
to be able to chair such an 
awesome group of people, 
helping those who help others.”

Paul Cartwright, .Community Lead

Our .Community efforts
Hot off the back of our Christmas 2021 
drive, (where teams in Belfast visited 
a depot organised by Cash4Kids and spent 
the day helping package, bag and wrap 
presents for the local families, as well as 
toy donations of our own to the “Home 
Start” charity based in Mold and a £500 
donation to a family support shelter 
in Manchester), in 2022 we turned 
our support efforts to the Ukraine.

Several members of staff asked if there 
was anything we could do to help with 
the Ukrainian Refugee crisis in Poland. 
We organised a staff collection in each 
office in collaboration with the local Polish 
support group, PCIS. After collecting items 
all week we headed to the collection centre 
only to be turned away; they had run out of 
room for any further donations to be 
collected and were crying out for more 
storage space. 

This is where we were able to go the extra 
mile, offering spare space in our Ewloe 
office as a temporary storage location.

Van after van arrived at the office with 
donations from the area, filling an entire 
office wing in a matter of hours, and 
members of staff in the Ewloe office 
helped unload and sort through all the 
donations. The next week, an articulated 
truck came to the office, we loaded it to 
the brim, and it went on its way directly 
to the centre in Poland. To help raise 
awareness of the cause, we posted on 
LinkedIn, sharing the amazing work the 

team had done; it was viewed nearly 
10,000 times and helped to keep the 
donations coming.

Beyond our Ukraine initiative, we saw 
many contacts at our local charities 
disappear, COVID-19 having put a stretch 
on their resources. This has resulted in 
lower overall requests for donations from 
the .community fund and we issued 
£6,275 in donations over the year to 
nine charities. 

It was with great sadness that we lost 
a treasured member of our community 
group this year owing to complications 
with cancer treatment. We took comfort 
from being able to donate to the local 
hospital charity that helped both her 
and her family during this time. 

As 2022 drew to a close, increasing costs 
of utilities and food created hardship for 
many families in the UK. In a direct link 
to our purpose, .community helped 
households through support for food 
banks and fuel poverty charities. 

The MSE Charity
Throughout 2022, MoneySavingExpert 
continued to donate funds to the MSE 
Charity, donating £100,000 over the year. 

Rather than engaging in specific projects 
itself, the charity offers grants of up to 
£7,500 to support non-profit organisations, 
such as a social enterprise or a registered 
charity, with specific money education 
projects. Help is given to a range of 
organisations, from small grassroots 
groups to more mainstream charities, 
with the maximum annual income level 
for an organisation set at £500,000. 

The MSE Charity has two themed grant-
giving rounds a year and four themes that 
rotate through a two-year cycle. Its themes 
include building and developing resilience, 
life-changing transitions, and living with 
long-term challenges. Nine groups received 
grants in the February grant round, which 
focused on the theme of “living with 
long-term challenges”.

This year’s summer round, themed on 
“developing resilience”, was launched 
earlier than usual in response to the cost 
of living crisis, and focused on groups 
that provide urgent money guidance and 
emergency debt help. Eight organisations 
benefited from a total of just under 
£50,000, with an average grant of about 
£6,250, allowing them to teach vital 
financial skills to people who are struggling 
with their finances. Full details of the 
recipients can be found at 
www.msecharity.com.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

47

Strategic ReportSustainability continued

Task Force on Climate-Related Financial Disclosures (‘TCFD’)
We recognise that mitigating the impact of 
climate change is a unique challenge and 
acknowledge the growing scientific consensus 
that the window to tackle climate change is 
rapidly diminishing. We are committed to 
helping households save money in a way 
that is mindful of climate change.

regulation. The Group’s oversight of climate 
risk has continued to expand and evolve 
with our expanding commitment to our 
increasingly ambitious climate goals. 

We consider future climate change to 
represent physical risk, including acute 
impacts resulting from weather events and 
chronic impacts stemming from longer-term 
shifts in climate, like higher temperatures, 
prolonged heat waves and drought, and the 
transition risk arising from changes in 
consumer behaviour, technology and 

We are adopting a climate-focused mindset, 
supported by an effective governance 
process which has included widening the 
remit of the Risk Committee in 2022 to the 
Risk and Sustainability Committee (see 
pages 94 to 96 of the Annual Report). 
We operate a low-carbon intensity business, 
we neither mine, manufacture nor transport 
goods and we do not operate in the most 
immediately susceptible areas. Therefore, 
we consider that the Group has relatively 

limited exposure to potential direct physical 
risks, but we are cognisant of some potential 
transitional risk over the longer term.

We consider this report to be consistent 
with the four pillars of Governance, 
Strategy, Risk Management and Targets 
and Metrics, together with the 11 supporting 
recommended disclosures from the 
recommendations of the TCFD (taking 
into account Section C of the TCFD Annex 
entitled “Guidance for All Sectors”), and 
have structured the report in line with 
these pillars and recommended disclosures. 

•  to achieve net zero by 2050 and beyond, 

Board statement on its commitment to becoming operational net zero 
The Moneysupermarket.com Group PLC 
Board recognises the significant risks 
from climate change and the role we must 
play to mitigate the impacts on the wider 
world and our own business. We strive 
to reduce our environmental impact by 
reducing our carbon emissions and 
production of waste, and sourcing 
responsibly. We consider environmental 
and sustainability issues in aspects of 
our operational and business activities.

environmental initiatives in our 
business to reduce our impact 
on the environment. 

and operational net zero by 2030 
through robust plans;

•  to report our progress to our 

•  to seek and implement new 

stakeholders; and 

scopes, in line with 1.5°C emissions 
circumstances and the criteria and 
recommendations of the SBTi. We have 
been working on our targets and expect 
to submit these to SBTi for validation in 
the next financial year (FY23), with further 
communication to stakeholders to follow 
in due course. 

During 2022 we reviewed our approach 
to achieving operational net zero and 
engaged our employees in considering 
which projects we should sponsor as part 
of our carbon offsetting arrangements (see 
further below). In 2022, we also completed 
a full disclosure to the Carbon Disclosure 
Project (‘CDP’) detailing the commitments 
we have in place to manage our impact on 
the environment, and will continue to 
provide updated CDP disclosures annually 
going forward. 

Our net zero plan covers the areas which 
are most material to our business: the 
emissions we create, the waste we make 
and the sustainability of our supply chain. 
We continue to be a Beyond Carbon 
Neutral business (meaning we eliminate 
more carbon dioxide than we emit via our 
carbon offsetting projects) and in 2021, 
we announced our new commitment to 
achieving operational net zero by 2030. 

We are proud to be one of the founding 
members of the Tech Zero taskforce (‘Tech 
Zero’). Announced in March 2021, Tech Zero 
aims to take steps to tackle the climate 
crisis. By working together, we hope to make 
faster progress to net zero and encourage 
other companies to take action to reduce 
their emissions. Companies that join Tech 
Zero agree to a set of commitments, 
including measuring their Scope 1, 2 and 
3 emissions and setting an ambitious net 
zero target within a year of joining. 

Together with this, on 4 November 2021, 
we also committed to the Science Based 
Targets initiative (‘SBTi’) to set science-based 
emissions reduction targets across all 

We are proud of the progress we have made 
to date, but we are aware we have more to 
do. Our plans for 2023 include, considering 
using the journey to achieving operational 
net zero as an opportunity to further engage 
our employees in our carbon reduction 
initiatives and further embedding climate 
change and sustainability as part of the 
culture of the Company. 

We will continue to evolve and enhance our 
reporting against the framework provided 
by the Task Force on Climate-related 
Financial Disclosures, and we welcome 
feedback on our approach.

The information provided in this TCFD 
Report, in conjunction with our wider Annual 
Report and Accounts, helps to: set out our 
oversight of and governance process 
surrounding climate-related risks and 
opportunities; demonstrate how we are 
identifying and dealing with climate-
related risks and opportunities, and how 
they impact our strategic and financial 
planning; and describe the metrics and 
targets we have set ourselves over the 
next few years and the progress we are 
making against these. 

We have been focusing on a clearer and 
more transparent articulation of our Group 
sustainability strategy and this year we 
have adopted our new Sustainability 
Framework (see page 37 of the Annual 
Report) and accompanying Sustainability 
Framework, as detailed below. 

Under the Environmental pillar of our 
Sustainability Framework, our aim is to 
continue to reduce our impact on the 
environment and we have three priority 
areas to help deliver our ambition: 

48

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

1. Governance
Board oversight of climate-related risks 
and opportunities 

The Board takes overall accountability for 
the oversight of the Group’s risks and 
opportunities, which includes climate 
change. The Board receives regular updates 
from management as well as the Risk and 
Sustainability Committee on environmental 
and climate-related matters and considers 
the risks and opportunities arising from 
climate-related change. 

The Board considered and adopted a new 
Group Sustainability Framework in 2022. 
This includes the ambition and priorities set 
out under the Environmental pillar; the 
ambition of the Group is to minimise our 
environmental impact and our three priority 
areas centre around our operational net 
zero plans and beyond, reporting our 
progress to our stakeholders in a clear and 
timely manner and finally, putting in place 
environmental initiatives that will help to 
reduce our carbon emissions and our 
environmental impact. The Board 
considered our Operational Net Zero by 
2030 plans and the environmental initiatives 
we have undertaken in 2022. The Board has 
also considered how we report our 
progress, through our TCFD report, 
submitting our data to the Carbon 
Disclosure Project and agreed that we 
should have our net zero targets verified 
independently by the Science Based Target 
initiative in 2023. 

The Board also considered new reporting 
arrangements for the Group Sustainability 
Framework to the Board and relevant 
Committee. As part of this, the Board 
agreed to new reporting through to the 
Board against the three priority areas under 
the environmental pillar, which included 
plans relating to the Group’s targets of being 
Operational Net Zero by 2030 and Net Zero 
by 2050. These new reporting arrangements 
will be fully reported through to the Board 
in FY23. 

The Board further considered the reach and 
impact of the Committees role in reviewing 
our Sustainability Framework, including our 
environmental ambitions. As part of this, 
the Board approved the update of the Risk 
Committee, to becoming the Risk & 
Sustainability Committee. Therefore, 
in September 2022 the Risk Committee 
renamed itself the Risk and Sustainability 
Committee and updated its terms of 
reference to widen its remit to include 
oversight of the Group’s sustainability 
strategy, framework and risks, as well as 
the Group’s sustainability commitments 
and performance. Reporting to the Risk and 
Sustainability Committee is the Executive Risk 
and Sustainability Committee, which oversees 
the Group’s performance against all the 
topics within the Sustainability Framework. 
Climate-related risks are incorporated into 

our Group risk management framework 
(see section 3 on Risk Management below) 
and we have continued to assess climate 
change as an emerging risk to our business, 
rather than a principal risk. See pages 94 
to 96 for further detail on the Risk and 
Sustainability Committee.

Reporting to the Executive Risk and 
Sustainability Committee is our new 
Sustainability Steering Committee, 
chaired by the Group General Counsel 
and Company Secretary and composed 
of Executives and senior management 
who have responsibility for delivery of 
the Sustainability Framework across 
the Group. This Committee oversees 
communications, Board engagement 
and the education of colleagues across 
the Group. The governance diagram on 
the following page illustrates how our 
sustainability governance is structured. 

Assurance of climate-related 
measurement and reporting 

The Group is committed to continuous 
improvement within our climate-related 
external reporting and to this end undertook 
an internal review of the Group’s sustainability 
plans during the third quarter of 2022, 
including the consideration of the assurance 
that management has over our TCFD Report 
and our externally reported data. 

As part of this review the Group has 
enhanced internal processes to include 
the peer review of data submitted to our 
external partner who helps us to produce 
our carbon footprint to ensure its accuracy, 
traceability and completeness. Internal 
processes have also been updated to 
ensure that it is made clear where data has 
been estimated (and the basis for such 
estimations and assumptions) and where it 
is based upon actual figures. We have for 
the first time included within this report the 
emission data from Ice Travel Group 
following its acquisition. 

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

As stated above, the Group General Counsel 
and Company Secretary has responsibility 
for leading our climate change agenda, for 
embedding our ambition and commitments 
into the Group and for managing our 
policies and practices across a range of 
sustainability and ESG matters, including 
climate change. The Chief Risk Officer is 
responsible for our risk management 
framework and approach, including the 
assessment and management of climate-
related risks. Climate related matters are 
identified through both internal and 
external avenues; these include being 
updated through the Employee 
Representative Group the “Green Team” 
on initiatives, through internal plans and 
updates to reporting on the Group’s 
emissions and targets, through an external 

consultant who assists the Company with its 
GHG reporting and through industry 
updates. Both the General Counsel and 
the Chief Risk Officer attend the Risk and 
Sustainability Committee meetings and 
report to the Committee on sustainability 
and risk matters as appropriate throughout 
the year. The Risk and Sustainability 
Committee formally report to the Board 
at the next Board meeting. 

The operational management of our 
climate-related risks and opportunities 
continues to be embedded within our 
business strategy and operations, as 
detailed in section 2 below. We are 
developing our approach as to how we 
effectively embed climate-related risks and 
opportunities into our financial planning 
and investment decisions.

We have a TCFD Working Group which is 
chaired by the Group General Counsel and 
Company Secretary and has representation 
from the Legal, Governance and 
Procurement team which has responsibility 
for sustainability in the business, and the 
Risk and Compliance team, including the 
Chief Risk Officer, and is responsible for 
reporting the Group’s progress against 
the TCFD requirements.

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

Our employee-led Green Team is 
a proactive and passionate group of 
colleagues who work together to devise and 
implement local energy-saving and carbon 
emission and waste reduction initiatives. 

2. Strategy
Climate-related risks and opportunities 
identified over the short, medium and 
long term

The processes used to identify the material 
climate-related risks and opportunities 
include scenario analysis and detailed risk 
assessment, in consultation with relevant 
stakeholders across our business. Risks are 
classified, assessed and managed 
in accordance with our Group Risk 
Management Framework described on 
pages 62 to 67. In considering this risk 
assessment, we defined the 
following timescales:

•  short term (up to three years) reflecting 

the period over which we prepare 
financial projections which are used to 
manage performance and expectations;

•  medium term (period to 2030) reflecting 
the period over which we committed to 
achieve operational net zero; and 

•  long term (period beyond 2030) reflecting 

the period over which longer term 
climate, consumer and structural trends 
will take place.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

49

Strategic ReportSustainability continued

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

2. Strategy continued
Climate-related risks and opportunities 
identified over the short, medium and 
long term continued

When considering climate-related risks, we 
have categorised risks into three main types:

•  physical risk: acute – event-driven risks such 
as extreme weather events and flooding;

•  physical risk: chronic – longer-term shifts 
in climate patterns such as sea level rise 
or sustained higher temperatures; and

•  transition risk: changes in consumer 
behaviour, technology or regulation. 

As a UK based, low-carbon intensity 
business, we do not operate in the most 
immediately susceptible areas and so we 
consider that the Group has relatively 
limited exposure to potential direct physical 
climate-related risks. We consider that there 
is the potential for transition risk to impact 
the Group over the medium to long term. 
We anticipate that such risks may arise in 
response to consumer behaviour changes 
within our Insurance and Travel sectors, 
in particular changes in insurance 
requirements, car ownership and 
international travel. 

We have assessed the potential impact from 
major climate change that could affect the 
UK; for example, we have reviewed and 
considered the four “key risks” for Europe 
developed by the Intergovernmental Panel 
on Climate Change (‘IPCC’), including heat 
stress, food/water scarcity and rising sea 
levels. Climate-related decisions by 
providers could also impact the Group (for 
example, if insurers were to amend home 

insurance policies to require EPC ratings for 
property, or reduce cover in respect of 
extreme weather events).

Impact of climate-related risks and 
opportunities on our Group, strategy 
and financial planning 

To understand the impact on the Group, we 
look both through the lens of the physical 
impacts and potential socioeconomic 
developments. Under both scenarios, we 
anticipate that our providers would likely 
seek to evolve their products, e.g. insurance 
policies and energy tariffs, in response to 
climate-related risks and opportunities. We 
expect consumers would still seek to engage 
with switching sites and seek to compare 
products across additional criteria, rather 
than purely in relation to price. As a Group 
we are well placed to deliver the tools 
consumers would need to understand 
which products provide good value. Building 
on the work we completed in 2021, we are 
adapting our processes to consider the 
assessment of fair value in some of our key 
channels in line with FCA Consumer Duty 
regulation. Our existing environmental focus 
will help to reduce the impact of these risks 
to our strategy and business model. 

Having undertaken our risk and 
opportunities assessment, we do not 
anticipate any specific opportunities for 
the business in the short term. As green 
products become more available (and 
potentially more desirable, particularly 
if regulatory change leads to an increase 
in demand in certain products) over the 
medium term, we will act to promote and 
guide users to these. We have also 
considered whether to help users of other 

Group sites better understand their carbon 
footprint, for example as it relates to car 
mileage or travel, and have also considered 
specific commercial initiatives relating to 
carbon change. At this point, we do not 
expect that climate-related matters will have 
a material impact on areas of financial 
planning over the short term. We will 
continue to assess consumer demand for 
such products to prioritise such initiatives 
in the future.

Our “Expand Our Offer” strategy to broaden 
the Group’s offering should provide additional 
diversification, enabling us to take advantage 
of emerging climate-related opportunities 
and reduce the impact of climate-related 
changes from any area of the Group.

Resilience of our Group strategy, taking 
into consideration different climate-
related scenarios (including a 2°C or 
lower scenario)

In 2022, we have continued to build and 
enhance our resilience assessment. 
Our climate scenarios were based on the 
representative pathways developed by the 
IPCC, which show how the emission of 
greenhouse gases translates to increases 
in average global temperatures. Whilst the 
climate outlook shows the UK is expected 
to face average temperature increases 
between 0.5°C and 1°C up to 2035, 
we undertook a climate-related scenario 
analysis exercise to understand the 
potential impact that climate changes of 
1.5°C and 3°C could potentially have on the 
Group. To construct our climate scenarios 
and analysis we have modelled based on 
the IPCC RCP 4.5 which shows greenhouse 
gases will peak between 2040/50 which 

MSMG PLC Board
Oversight of Company strategy and ensuring the long-term success of MSMG

Risk and Sustainability Board Committee
Provides guidance and direction to the Group’s sustainability strategy and framework  
Advises the Board on Group Risk Framework and Risk Appetite

Executive Risk and Sustainability Committee
Meetings to discuss how the Group is managing its risks as well as how internal and external sustainability targets are achieved

Sustainability Steering Committee
Group GC responsible for delivery of the Sustainability Framework across the Group, with functional representatives

Group Green Team

Environment
Minimising our impact 
on the environment  
GC & CoSec 

Social
Our social purpose 
Chief People Officer

Governance
Robust governance 
and ethics  
GC & CoSec 

50

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Our long-term targets are more ambitious 
again: we have increased our targets to 
reduce Scopes 1, 2 and 3 emissions by 
10% and are now committed to reducing 
emissions across these scopes by 90% by 
2050 (2021: 80% by 2050) and therefore 
net zero by 2050.

We are actively working to reduce our 
emissions wherever possible. We no longer 
occupy energy-intensive data centres and 
our London, Manchester and Ewloe offices 
now operate on 100% renewable electricity 
tariffs and we will continue to work on 
several initiatives to further reduce our 
emissions; see page 41 for details.

We have committed to the Science Based 
Targets initiative (‘SBTi’) to approve our 
science-based targets for Scopes 1, 2 and 
3 emissions and are on track to submit our 
targets in 2023. The methodology for 
modelling our emissions has been 
developed in line with the accepted 
international standard for GHG value chain 
modelling, the Greenhouse Gas Protocol. 
The baseline year chosen is 1 January to 
31 December 2019, as it is representative 
of our current activities and was the most 
recent year with complete and verifiable 
data. Engaging with our third-party 
suppliers will be key to delivering this 
reduction. Over the next year, we will 
extend our strategy of collecting supplier 
information and reporting on our progress 
in reducing our Scope 3 emissions. 

As the sustainability landscape evolves, 
we will continue to refine and expand our 
disclosures to provide meaningful 
information for our stakeholders.

Greenhouse gas (‘GHG’) emissions 
and the related risks

Our greenhouse gas (GHG) emissions 
are reported on page 42 of this Annual 
Report. Together with reporting our GHG 
emissions for Scope 1 and Scope 3, we 
have also chosen to publicly disclose our 
Scope 3 GHG emissions. We include a 
description of the methodologies used 
to calculate or estimate the metrics. 

For the emissions that we have not yet 
been able to eliminate, we mitigate 150% 
of these emissions through investing in 
verified carbon offset projects; see 
page 42 for details. 

will result in average atmospheric 
temperatures increasing between 2°C to 3°C 
by the end of the century. Whilst the climate 
outlook shows the UK is expected to face 
average temperature increases between 
0.5°C to 1°C up to 2035, our scenarios build 
on our long-term strategy. Based on our 
current analysis scenarios and initiatives, 
we expect the Group strategy to be resilient 
to any physical risks which may materialise. 
We expect to be impacted by transition risk; 
however, this is predominantly an indirect 
risk due to providers modifying their 
products and services.

3. Risk management
Our processes for identifying 
and assessing climate-related risks 
and integrating climate-related 
risks within our overall risk 
management framework

Our approach to the identification and 
assessment of climate-related risks fits 
into our already established risk 
management framework. These risks are 
identified, classified and assessed 
alongside the other risks which the Group 
faces. See pages 62 to 67 on risk 
management in the Group. Climate change 
risks and, where applicable, opportunities 
are reported to the Executive Team and 
the Board (see section 1 on Governance 
above for detail). 

Climate-related risks have been assessed 
in accordance with our Group risk 
framework and we have continued to 
consider climate change as an emerging 
risk to our business, rather than a principal 
risk. To correctly scope out the significance 
of climate-related risks we have developed 
a number of scenarios and reviewed the 
IPCC identified risk impacts on the Group. 
We additionally support the use of the 
IPCC likelihood scenarios. 

We monitor existing and emerging 
regulatory requirements related to climate 
change to understand the potential impact 
and opportunities for our business and 
stakeholders, recognising that climate 
change regulations could require us to 
make changes to our processes or 
operations, but also that changes in 
climate change regulations could present 
opportunities if they result in an increase 
in the demand for energy efficiency 
products or services.

Processes for identifying, assessing, 
and managing climate-related 
risks into the Group’s risk 
management framework

Our approach to assessing and managing 
the climate-related risks is consistent with 
our approach to other risks which the 
Group faces and is described as part of 
our Group Risk Management Framework 
on pages 62 to 67. At this point, 

we consider the potential impact of 
climate change includes strengthening our 
operational resilience to climate-related 
risks by reducing our emissions across our 
activities. We have already implemented 
a number of measures to reduce our 
carbon emissions, such as installing EV 
charging points for employee use, moving 
to a secure pull print system and installing 
LED lighting and motion sensors in our 
offices. Through our net zero plan, we have 
identified additional opportunities such as 
delivering a carbon emissions awareness 
campaign to our employees and moving 
our remaining offices to renewable 
energy tariffs. We are continually working 
on our approach to climate related risks 
and opportunities and as part of our plans 
for 2023, we will identify and assess 
transition risks to the Group as applicable.

4. Metrics and targets 
Group metrics to assess climate-
related risks and opportunities 
in line with our strategy and risk 
management processes

We are committed to our plan for 
operational net zero emissions by 2030 
and have made a commitment to limit our 
Company’s carbon footprint in line with 
keeping global warming to below 1.5ºC.

We report on a range of greenhouse gas 
emissions and intensity metrics to 
understand our impacts and performance. 
Full details of our Scope 1, 2 and 3 GHG 
emissions and our intensity ratio metrics 
can be found on page 42.

Due to the limited risks and opportunities 
we do not use metrics other than GHG 
emissions to measure and manage risks 
and opportunities. We continue to keep 
this under review and will continue to 
update our position in our future 
TCFD reports. 

Group targets to manage climate-
related risks and opportunities and 
performance against targets

As a Group we are keen to ensure we are 
doing all we can to have a positive impact 
on the environment. We will continue with 
our plans to become operational net zero 
by 2030. This means for Scope 1 and 2, 
and to be aligned with the SBTI (1.5⁰C 
pathway), there will be a 90% reduction 
in our Scope 1 and 2 emissions. 

In terms of our longer-term plans, to 
become net zero by 2050, to ensure 
that we remain aligned with the 1.5⁰C 
decarbonisation pathway, and that our 
targets are sufficiently ambitious, we 
undertook a review of our Scope 3 net zero 
targets in 2022. As a result of this review, 
we have also increased our target for 
reducing Scope 3 emissions by 2030 
to 46% (2021: 45% by 2030). 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

51

Strategic ReportSustainability continued

Non-Financial Information Statement
We comply with the non-financial reporting requirements contained 
in sections 414CA and 414CB of the Companies Act 2006. 
The below table outlines our position on non-financial matters and provides signposts to where these issues are addressed in the report. 

Reporting requirement

Policies and standards which  
govern our approach

Additional information  
and risk management

Stakeholders

Group Data Protection Policy Code of Conduct

Section 172 Statement pages 29 to 35

Board activities pages 74 to 76

Sustainability disclosures pages 36 to 53

Employee Champion Report pages 83 and 84

Corporate Governance Statement pages 72 to 82

Audit Committee Report pages 89 to 93

Environmental

Environmental Policy

Sustainability disclosure pages 36 to 53

Sustainability Framework 

Employees

Code of Conduct

Sustainability disclosure pages 36 to 53

Equal Opportunities & Diversity Policy

Employee Champion Report pages 83 and 84

Flexible Working – “Work Your Way” Policy

Whistleblowing Policy and Framework

Health and Safety Policy Statement

Human rights

Anti-Slavery & Human Trafficking Policy

Corporate Governance Statement pages 72 to 82

Code of Conduct

Social matters

Anti-Slavery & Human Trafficking Policy

Sustainability disclosures pages 36 to 53

Volunteering Guide (Time-Off Policy)

Directors’ Report pages 118 to 122

Anti-corruption and bribery

Anti-Bribery & Corruption Policy and Procedure

Directors’ Report pages 118 to 122

Competition Law Policy

Conflicts of Interest Policy and Procedure

Hospitality & Gifts Policy and Procedure 

Fraud Investigation Policy 

Share Dealing Policy and Code 

How to Buy Guidelines

Principal risks and impact  
on the business

Description of 
business model

52

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Risk management pages 62 to 65

Principal risks pages 66 and 67

Business model pages 16 and 17

Risk Committee Report pages 94 to 96

Business model pages 16 and 17

People
At Moneysupermarket Group, 
we understand that our behaviour, 
our operations and how we treat our 
employees all have an impact on the 
environment and society. We recognise the 
importance of health and safety and the 
positive benefits to the Group. The Group 
has a Health and Safety Policy which is 
communicated to all employees through 
a health and safety handbook, which is 
regularly reviewed and updated. Behaving 
ethically is an essential part of working for 
our Group, fundamental to how we do 
business and vitally important to the 
reputation and success of our Group. Our 
Code of Conduct applies to all employees 
and sets out our commitment to:

•  behave ethically;

•  comply with relevant laws 

and regulations; and

•  do the right thing.

Human rights
Our Code of Conduct also confirms that 
we respect and uphold internationally 
proclaimed human rights principles as 
specified in the International Labour 
Organisation’s Declaration on 
Fundamental Principles and Rights at Work 
(‘ILO Convention’) and the United Nations’ 
Universal Declaration of Human Rights. 
In addition, we have an Anti-Slavery and 
Human Trafficking Policy for suppliers and 
a separate one for employees. Training is 
provided to all employees on issues of 
modern slavery in conjunction with the 
Code of Conduct e-learning module. 
We have a zero-tolerance approach to 
modern slavery, and are committed to 
acting ethically and with integrity in all our 
business dealings and relationships, and 
to implementing and enforcing effective 
systems and controls to ensure modern 
slavery is not taking place anywhere in our 
own business or in any of our supply 
chains. We publish our Modern Slavery Act 
Transparency Statement annually and this, 
together with previous statements, can be 
viewed on our website at https://corporate.
moneysupermarket.com.

Anti-corruption and 
anti-bribery
We also have Anti-Bribery and Anti-
Corruption and Competition Law Policies 
that incorporate the Group’s key principles 
and standards, governing business conduct 
towards our key stakeholder groups.

We believe we should treat all of these 
groups with honesty and integrity. 
Our Anti-Bribery Policy is supported by 
clear guidelines and processes for giving 
and accepting gifts and hospitality from 
third parties.

Whistleblowing
Our Whistleblowing Policy is supported by 
an external, confidential reporting hotline 
which enables employees of the Group to 
raise concerns in confidence. Any reported 
issues will be reported to the Audit 
Committee and, where appropriate, 
remedial actions taken.

Tax Policy
Our Group is guided by our purpose to 
help households save money. We believe 
that our business makes a valuable 
contribution to UK society and we are 
proud that MSM has helped 11.1m active 
users to save an estimated £1.8bn on 
their households bills in 2022, by finding 
a better deal on their insurance, energy 
and banking products.

Alongside this, we want to make our 
contributions to the communities that 
our customers live in by paying the right 
amount of tax, at the right time. In 2022, 
we paid £18m in corporation tax and over 
£54.3m in other taxes (including VAT and 
employer’s National Insurance). We are 
committed to acting with integrity and 
transparency in all tax matters. We will not 
support proposals to reduce our tax cost 
through implementing artificial structures, 
but we will seek to structure commercial 
transactions in an efficient and legitimate 
way. A copy of our tax strategy is available 
at https://corporate.moneysupermarket.com.

Dividend Policy
In determining the level of dividend in any 
year in accordance with the policy, the Board 
also considers a number of other factors 
that influence the proposed dividend 
through its annual and strategic planning 
processes and the scenario planning 
described below in our viability review 
section, which includes: the level of available 
distributable reserves in the Parent 
Company; future cash commitments and 
investment needs to sustain the long-term 

growth prospects of the business; potential 
strategic opportunities; a prudent buffer; 
and the level of dividend cover.

Moneysupermarket.com Group PLC, 
the Parent Company of the Group, is a 
non-trading investment holding company, 
which derives its distributable reserves 
from dividends paid by subsidiary 
companies. The Board reviews the level 
of distributable reserves in the Parent 
Company biannually, to align with the 
proposed interim and final dividend 
payments. The distributable reserves of 
the Parent Company approximate to the 
balance on the profit and loss account 
reserve, which at 31 December 2022 
amounted to £117.5m (2021: £120.4m) (as 
disclosed in the Company balance sheet 
on page 166). The total external dividends 
relating to the year ended 31 December 
2022 amount to £62.8m (2021: £62.8m).

The Group is well positioned to continue to 
fund its dividend, which is suitably covered 
by cash generated by the business. The 
distributable reserves are sufficient to pay 
dividends for a number of years as, when 
required, the Parent Company can receive 
dividends from its subsidiaries to increase 
its distributable reserves. Details on the 
Group’s continuing viability and going 
concern can be found on pages 59 and 60.

The ability of the Board to maintain a 
future dividend policy will be influenced by 
a number of the principal risks identified 
on pages 65 to 67 that could adversely 
impact the performance of the Group.

The Strategic Report on pages 02 to 67 
was approved by the Board of Directors 
and signed on its behalf by:

Peter Duffy
Chief Executive Officer
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

53

Strategic ReportFinancial Review

Strong performance and 
strategic momentum

We’ve seen a pleasing return to profit growth and a healthy 
increase in operating cashflow. We’ve continued to balance 
efficiencies with investing for future growth.

Scilla Grimble
Chief Financial Officer

I’m pleased to present the financial review 
in a year that has seen a return to both 
revenue and profit growth. Revenue grew 
22%, or 8% excluding Cashback. Money 
had an exceptional year, our travel 
channels rebounded strongly and the 
trend in switching in the car and home 
insurance markets improved as we moved 
through the year. 

Adjusted EBITDA grew 15% to nearly 
£116m and basic EPS increased by 30%, 
more than EBITDA driven by a decrease in 
our effective tax rate in 2022 and deal fees 
in the previous year.

Operating cashflow increased by 59%, 
reflecting stronger trading performance 
and some one-off working capital outflows 
in 2021. Our net debt to EBITDA ratio fell to 
0.3x from 0.6x in 2021. 

54

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Moneysupermarket.com Group PLC

Financial review

Group revenue increased 22% to £387.6m (2021: £316.7m), with profit after tax increasing 33% to £69.3m (2021: £52.1m). When reviewing 
performance, the Board reviews several adjusted measures, including adjusted EBITDA which increased 15% to £115.5m (2021: £100.5m) 
and adjusted basic EPS which increased 21% to 14.4p (2021: 11.9p), as shown in the table below. 

Extract from the Consolidated Statement of Comprehensive Income
for the year ended 31 December

Revenue
Cost of sales

Gross profit
Operating costs 

Operating profit
Amortisation and depreciation

EBITDA

Profit after tax

Earnings per share:
– basic (p)
– diluted (p)

Reconciliation to adjusted EBITDA:

EBITDA
Deal fees and associated costs

Adjusted EBITDA

Adjusted earnings per share1:
– basic (p)
– diluted (p)

1  A reconciliation to adjusted EPS is included within the adjusting items on page 57.

Revenue
for the year ended 31 December

Insurance
Money
Home Services
Travel2
Cashback

Total

2022
£m 

387.6
(125.1)

262.5
(173.5)

89.0
26.5

115.5

69.3

12.7
12.7

2022
£m 

115.5
0.0

115.5

14.4
14.3

2022
£m 

172.0
103.3
39.8
14.9
57.6

387.6

2021
£m

316.7
(93.8)

222.9
(149.5)

73.4
23.5

96.9

52.1

9.8
9.8

2021
£m

96.9
3.6

100.5

11.9
11.9

2021
£m

158.7
75.2
68.1
4.1
10.6

316.7

Growth
%

22
33

18
16

21
13

19

33

30
30

Growth
%

19
n.m.

15

21
20

Growth
%

8
37
(42)
265
n.m.

22

2 

 Travel includes revenue from Icelolly.com from 1 September 2021. Cashback reflects full year of Quidco revenue and the final two months of revenue in 2021 therefore 
year-on-year growth is not meaningful. 

Revenue grew 22% in 2022 or 8% excluding Cashback. Performance was driven by the strong recovery in travel channels and exceptional 
trading in Money, partly offset by the closure of the energy switching market. 

Insurance

Insurance revenue increased 8% with growth in travel offsetting declines in the other main channels.

Following the introduction of the FCA General Insurance Pricing regulation in January 2022, market switching volumes for car and home 
saw double-digit declines in H1, although this improved to single-digit declines in H2. As expected, providers, especially those with larger 
back books, gradually reassessed their customer acquisition strategies with new products launched as the year progressed. 

Car and home premium inflation gained momentum through the year, rising by double-digits compared to 2021, as premiums increased 
to reflect the rising cost of claims. The acceleration of premium inflation in the year helped drive search traffic.

Travel insurance grew strongly as the market continued to recover after the lifting of pandemic-related restrictions. It is now our second 
largest Insurance channel and revenue was c.20% above 2019 levels.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

55

Strategic Report 
Financial Review continued

Revenue continued 
Money

Money had an exceptional year with revenue growing 37% and all channels seeing double-digit growth. 

Banking benefited from the consistent availability of attractive promotional products, especially savings accounts, throughout the year. 

In borrowing there was strong demand and conversion for most of the year. In the final quarter, conversion weakened following 
September’s mini-budget as providers, particularly in loans, repriced their products making them less attractive to users.

Home Services 

Home Services revenue fell 42%, driven by the continued closure of the energy switching market. Throughout 2022 wholesale energy 
prices were above Ofgem’s price cap therefore providers were unable to offer switchable tariffs with meaningful customer savings. 
Future savings levels could also be impacted by the regulator’s market stabilisation charge. The ongoing uncertainty in the energy 
market means it is unlikely that switching will return in 2023.

Home comms revenue returned to growth in H2 as we annualised the loss of a large B2B contract in July 2021. Particularly attractive 
Black Friday offers drove exceptional growth in mobile. 

Travel

Travel recorded its best performance since 2019 as COVID-19 related restrictions were largely absent from Q1 onwards. Revenue 
was around 50% of 2019 levels.

Cashback

The significant increase in Cashback revenue year on year reflects the full year of ownership compared to only two months in 2021. 
During the year the resurgence in travel offset declines in the retail and services segments. Retail moderated as the high online spending 
penetration experienced during the COVID-19 pandemic of 2021 softened, with consumers returning to physical stores. Services was 
affected by the closure of the energy market and lower switching volumes in car and home insurance.

Gross profit 
Gross margin decreased 2.7%pts year on year from 70.4% to 67.7% with stable margins between H1 and H2. Excluding the impact of 
Cashback, which has structurally lower margins, Group gross margin would have been about 4.5%pts higher. The loss from July 2021 
of a large but low margin B2B contract benefited Group margin c.1.0pts in the year.

The mix into Money, particularly the growth in higher margin banking products, also improved margin by c.0.5%pt.

Other mix impacts were broadly neutral as the closure of the energy switching market offset market dynamics which reduced Insurance gross 
margin year on year (recovery of travel insurance and the FCA General Insurance Pricing regulation impacts on car and home insurance).

We continued to see a shift of traffic to mobile devices, with 63.6% (2021: 61.0%) of MSM visits coming from a mobile device, while 
tablet share again declined. Overall, there was little impact on Group margin from changes in device mix and we expect this to be 
the case going forward. 

Operating costs
for the year ended 31 December

Distribution expenses
Administrative expenses

Operating costs

Within administration expenses
Amortisation of technology related intangible assets
Amortisation of acquisition related intangible assets3
Depreciation

Amortisation and depreciation

2022
£m 

40.1
133.4

173.5

10.4
11.3
4.8

26.5

2021
£m

29.5
120.0

149.5

14.6
4.4
4.5

23.5

Growth
%

36
11

16

(29)
160
7

13

3 

 Amortisation of acquisition related intangibles includes £6.4m relating to acquired technology assets. This is included in the amortisation of technology related assets of £16.8m 
presented in note 13.

As expected, distribution expenses increased year on year to support MSM’s MoneySuperSeven advertising campaign. Costs were c.£4m 
higher than guided due to the early launch of MSM’s latest advert and the decision in H2 to widen marketing initiatives in icelolly.com and 
Quidco. In 2023 we will continue to build awareness across our portfolio of brands and expect distribution expenses to remain broadly 
flat year on year.

Administrative expenses increased by £13m, as a result of a full year of consolidation of Quidco and icelolly.com. Efficiency gains from 
simplifying the organisation and improving our data and tech estate helped offset wider inflationary pressures. 

In 2023 we expect total operating costs (excluding depreciation and amortisation) to increase by mid-single digit per cent with efficiency 
gains more than offset by wage inflation.

56

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Moneysupermarket.com Group PLC

Adjusting items4
for the year ended 31 December

Deal fees and associated costs
Amortisation of acquisition related intangible assets

Adjusting items included in administrative expenses
Change in fair value of financial instrument

Total

2022
£m 

—
11.3

11.3
(0.0)

11.3

2021
£m

3.6
4.4

8.0
0.7

8.7

Growth
%

n.m.
160

42
n.m.

30%

4 

 Amortisation of acquisition related intangible assets and the change in fair value of financial instruments are not included in EBITDA and therefore are only adjusting items in the 
adjusted EPS calculation. Deal fees and associated costs are adjusting items in both the adjusted EBITDA and adjusted EPS calculations.

Amortisation of acquisition related intangible assets relates to technology, brands and customer/member relationships arising on the 
acquisitions of MSE, Decision Tech, CYTI and Quidco, as well as the combination of TravelSupermarket and Icelolly.com, in prior years. 
These assets are being amortised over periods of three to ten years. The charge has increased this year due to a full year of amortisation 
in respect of the assets acquired through the M&A activity in 2021.

In 2021, the Group incurred deal fees and associated costs relating to the Quidco acquisition and combination of TravelSupermarket and 
Icelolly.com. The change in fair value of financial instruments in 2021 related to the reclassification of CYTI from a joint venture to a subsidiary.

Key performance indicators
The Board reviews key performance indicators (KPIs) to assess the performance of the business against the Group’s strategy. This year 
we have added an MSM cross-channel enquiry metric so we now measure six key strategic KPIs: estimated customer savings, net 
promoter score, active users, revenue per active user, marketing margin and cross-channel enquiry.

We will continue to evaluate and broaden the KPIs as needed to ensure they provide visibility of our strategic progress under 
a framework that measures the strength of the Group and our brands. 

Estimated Group customer savings 
Group marketing margin
MSM and MSE net promoter score
MSM active users
Revenue per active user
MSM cross-channel enquiry

Estimated Group customer savings:

31 December
2022 

31 December
2021

£1.8bn
57%
72
11.1m
£16.40
21%

£1.6bn
61%
72
10.0m
£16.90
19%

This is calculated by multiplying sales volume by the market average price per product based 
on external data compared to the cheapest deal in the results table for core channels. Savings 
for non-core channels are estimated by applying the savings for core channels proportionally 
to non-core revenue. From November 2021 we have added the cashback earned by 
Quidco members.

Group marketing margin:

The inverse relationship between Group revenue and total marketing spend represented 
as a percentage. Total marketing spend is the direct cost of sales plus distribution expenses.

MSM and MSE net promoter score:

MSM active users:

The 12 monthly rolling average NPS (1 Jan 2022 – 31 Dec 2022 inclusive) measured by YouGov 
Brand Index service Recommend Score weighted by revenue for MSM and MSE to create 
a combined NPS.

The number of unique accounts running enquiries in our core seven channels for MSM (car 
insurance, home insurance, life insurance, travel insurance, credit cards, loans and energy) 
in the last 12-month period.

MSM revenue per active user:

The revenue for the core seven MSM channels divided by the number of active users for 
the last 12 months.

MSM cross-channel enquiry:

The proportion of MSM active users that enquire in more than one of our core channels 
within a 12 month period.

We estimate that the Group saved customers £1.8bn in 2022. The increase from 2021 is mainly driven by the recovery in travel insurance 
and strong Money volumes, partially offset by a full year of closure of the energy switching market. 

NPS remained strong at 72 demonstrating that trust and satisfaction in both brands remains high. MSE scored extremely well and MSM 
finished the year ahead of the PCW peer group.

MSM active user numbers rose by 1.1m to 11.1m, driven both by travel insurance as the market recovered following the easing of travel 
restrictions and higher volumes in borrowing channels. Energy enquiries remained high despite the absence of switchable tariffs.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

57

Strategic Report 
Financial Review continued

Key performance indicators continued
Revenue per active user fell by 50p to £16.40p reflecting a sharp decline in energy conversion (negligible switching since Q4 2021) 
and market-driven falls in car and home insurance conversion. 

The marketing margin reduction reflects movements in gross margin, driven by consolidation of lower-margin Quidco, as well as the 
increase in brand marketing spend.

During the year cross-channel enquiry improved driven primarily by the recovery in travel insurance. Our ongoing work to simplify 
customer journeys and offer further switching prompts, facilitated by the improvements to our data infrastructure, will help drive this KPI.

Alternative performance measures 
We use a number of alternative (non-Generally Accepted Accounting Practice (“non-GAAP”)) financial measures which are not defined 
within IFRS. The Board reviews adjusted EBITDA and adjusted EPS alongside GAAP measures when reviewing the performance of the 
Group. Executive management bonus targets include an adjusted EBITDA measure and the long-term incentive plans include an adjusted 
basic EPS measure.

The adjustments are separately disclosed and are usually items that are non-underlying to trading activities and that are significant in 
size. Alternative performance measures used within these statements are accompanied with a reference to the relevant GAAP measure 
and the adjustments made. These measures should be considered alongside the IFRS measures.

Dividends
The Board has recommended a final dividend of 8.61 pence per share (2021: 8.61p), making the proposed full year dividend 11.71 pence 
per share (2021: 11.71p). The Board will continue to keep under review the scope for resumed dividend growth and thereafter, when we 
have significant surplus capital and there are no material short-term organic or acquisitive growth opportunities available, we will again 
consider returning surplus funds to shareholders through a “special distribution”, in accordance with our capital allocation policy.

The final dividend will be paid on 11 May 2023 to shareholders on the register on 31 March 2023, subject to approval by shareholders 
at the Annual General Meeting to be held on 4 May 2023.

Tax
The effective tax rate of 18.7% (2021: 25.8%) is in line with the UK standard rate of 19.0% (2021: 19.0%). The higher effective tax rate in 2021 
was mainly due to a deferred tax charge arising from a change in the standard rate of corporation tax which comes into effect in 2023.

Earnings per share
Basic reported earnings per share increased by 30% to 12.7p (2021: 9.8p). Growth was ahead of adjusted EBITDA due to deal fees 
incurred last year and a lower effective tax rate this year.

Adjusted EPS is based on profit before tax after adding back the adjusting items detailed above. A tax rate of 19.0% (2021: 19.0%) is applied 
to calculate adjusted profit after tax. Adjusted basic EPS increased by 21% to 14.4p per share, which is higher than the percentage increase 
in adjusted EBITDA due to a decrease in underlying (non-acquisition related) amortisation, partially offset by a higher net 
finance expense. 

Cash flow and balance sheet
The Group operating cashflow increased to £104.4m (2021: £65.7m) driven by the strong trading performance. The Group’s net debt 
position at year end was £37.2m (2021: £59.6m). Net debt includes borrowings of £44.0m (2021: £57.5m) and £9.8m (2021: £14.6m) 
of deferred consideration following the acquisition of Quidco last year. Net debt to adjusted EBITDA fell to 0.3x from 0.6x in 2021.

The working capital inflow of £4.7m was mainly driven by tighter receivables working capital management but also benefited from 
an increase in payables relating to the higher revenues in our travel insurance channel.

Cash outflows on investing activities of £16.9m reflect £10.6m of cash capital expenditure and £4.8m of deferred consideration relating 
to the acquisition of Quidco.

Capital expenditure
Capital expenditure was £11.4m (2021: £9.8m), including technology spend of £10.6m (2021: £9.2m). In 2023, technology capex is 
expected to be in the region of £13m as we continue to invest in integrating recent acquisitions into the Group. We expect capex 
to return to levels seen in recent years in 2024.

The amortisation charge for technology assets in 2022 (£10.4m) is lower than 2021 (£14.6m) as last year’s charge included accelerated 
amortisation of several data infrastructure assets that were replaced by newer technologies. 

58

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Moneysupermarket.com Group PLC

Going concern
The Directors have prepared the financial statements on a going concern basis for the following reasons. As at 31 December 2022, the 
Group’s external debt comprised an amortising loan (with a balance outstanding of £40m, repayable by October 2024) and a revolving 
credit facility (‘RCF’), (of which £4m of the £90m available was drawn down). No further amounts have been drawn down since the year 
end. The operations of the business have been impacted by regulatory changes in Insurance, COVID-19 recovery in Travel and the 
conditions affecting the energy switching market. However, the Group remains profitable, cash generative and compliant with the 
covenants of the bank loan and RCF.

The Directors have prepared cash flow forecasts for the Group, including its cash position, for a period of at least 12 months from the 
date of approval of the financial statements. The Directors have also considered the effect of potential cost-of-living trading headwinds 
and recession and competition such as new entrants upon the Group’s business, financial position, and liquidity in severe, but plausible, 
downside scenarios. The scenarios modelled take into account the potential downside trading impacts from recession, sustained 
cost-of-living increases, competitive pressures and any one-off cash impacts on top of a base scenario derived from the Group’s latest 
forecasts. The severe, but plausible, downside scenarios modelled, under a detailed exercise at a channel level, included minimal 
recovery over the period of the cash flow forecasts and in the most severe scenarios reflected some of the possible cost mitigations 
that could be taken. The impact these scenarios have on the financial resources, including the extent of utilisation of the available debt 
arrangements and impact on covenant calculations has been modelled. The possible mitigating circumstances and actions in the event 
of  such scenarios occurring that were considered by the Directors included cost mitigations such as a reduction in the ordinary dividend 
payment, a reduction in operating expenses or the slowdown of capital expenditure. A reverse stress test has also been performed, 
which assumes the maximum available drawdown of borrowings, whilst maintaining covenant compliance.

The scenarios modelled and the reverse stress test showed that the Group and the Parent Company will be able to operate at adequate 
levels of liquidity for at least the next 12 months from the date of signing the financial statements. The Directors, therefore, consider that 
the Group and Parent Company have adequate resources to continue in operational existence for at least 12 months from the date of 
approval of the financial statements and have prepared them on a going concern basis.

Consideration of Climate Change
In preparing the financial statements, the Directors have considered the impact of climate change, particularly in the context of the 
risks outlined under TCFD on pages 48 to 51, and there has been no material impact identified in the reporting period on the financial 
reporting judgements and estimates. The Directors considered the risks with respect to going concern and viability, as well as the 
cashflow forecasts used in the impairment assessment, and noted no material risks within the planning period. Whilst there is no 
medium-term impact to the Group expected from climate change, the Directors will assess these risks regularly against the judgements 
and estimates used in preparation of the financial statements. 

Scilla Grimble
Chief Financial Officer
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

59

Strategic ReportViability Statement for the 2022 Annual Report

Viability Statement

As required by Provision 31 of the 2018 UK 
Corporate Governance Code, the Directors 
have assessed the prospects of the Group 
over a three-year period to December 
2025. In making this assessment, the 
Directors took account of the business 
model and principal risks set out on 
pages 16 and 17 and pages 65 to 67 
of the Strategic Report.

Business model
The Group has a simple business model – 
matching customers to the right providers. 
It uses online services to help customers 
to compare a wide range of products in 
one place and make an informed choice 
when taking out the product most suited 
to their needs. With the addition of Quidco 
in 2021, our model has expanded to 
providing users with cashback offerings on 
their online purchases and merchants with 
valuable marketing leads.

For our providers, it offers an efficient and 
cost-effective way to reach a large volume 
of informed customers who are actively 
looking for a product. For the majority of 
our services, we receive a success-based 
marketing fee from the providers. 
This business model operates along 
the following principles:

•  the Group relies on customer 

transactions for its revenues and 
does not have long-term contracted 
revenue streams;

•   the Group makes money when its 

customers find the product they want, 
switch to it and save themselves money;

•   customers will continue to see value in 
shopping around for products and 
services and will aim to save money by 
doing so; and

•   providers will have strategies of new 
customer acquisition and develop 
products and services to fulfil 
that strategy.

The Group’s strategy continues to focus 
on three pillars: improving acquisition 
efficiency, driving greater retention and 
cross-sell from existing users, and finally 
expanding the business into profitable and 
adjacent areas. All of this is underpinned 
by an increasingly common, flexible and 
re-deployable tech and data platform.

The Strategic Report sets out the Group’s 
performance on the main KPIs which the 
Board monitored for the year ended 
31 December 2022. The Board monitors 
and reviews progress against three time 
horizons: quarterly to review and reforecast 
performance against the Annual Plan and 
Budget; annually to establish a clear 
Annual Plan and Budget that will deliver 
against the Strategic Plan; and a three-year 
Strategic Plan reassessed annually, to 
determine the strategy of the Group.

The Board noted the commentaries issued 
by the Financial Reporting Council 
suggesting that Viability Statements should 
be extended beyond a period of three 
years; however, due to the nature of our 
economic, technological and regulatory 
environment, the Board did not consider it 
appropriate to alter its current time frame 
due to the following reasons:

•   The expected life cycle of the Group’s 
technology is three years, and this 
reflects the frequent changes in the 
way that consumers choose to 
use technology.

•   It is difficult to forecast revenues and 

costs beyond three years given that the 
Group’s revenues and costs are not 
materially covered by long-term contracts.

•   Within three years costs could be 

substantially restructured to compensate 
for a major fall in revenues. As such, the 
Board proposes to keep the time frame 
as three years rather than extending 
beyond this.

Risk management
As part of the review of the strategic 
priorities, the Board identified the Group’s 
principal risks around delivering these 
priorities which represent a risk or 
combination of risks in severe but 
reasonable scenarios that can seriously 
affect the future prospects or reputation 
of the Group through threatening its 
business model, future performance, 
solvency or liquidity. These include 
competitive environment and consumer 
demands, brand strength and reputation, 
data processing and protection, 
data security and cyber, business 
transformation and relevance to partners. 
In addition, the Directors believe that the 
Group faces risks around regulation, 
Government policy, market competition 
and economic conditions (including the 
impact of a deep recession, increased cost 
of living impacts and no or limited recovery 
of energy market switching) especially 
as that may influence the availability of 
attractive products for customers. 
Our principal risks and uncertainties 
(including mitigating activities) are on 
pages 66 and 67.

We have prepared cash flow forecasts for 
the Group and have considered the impact 
of the economic conditions mentioned 
above upon the Group’s business, financial 
position and liquidity in severe, but plausible, 
downside scenarios, using stress testing 
and scenario analysis techniques. The 
scenarios use a base scenario derived 
from the Group’s latest forecasts and 
factor in existing borrowings, including 
debt repayments, the deferred consideration 
and covenant compliance as well as member 
creditor commitments. Our revolving 
credit facility runs to October 2024 and we 
will re-finance the RCF within the viability 
period. The plausible, severe scenarios 
modelled, under a detailed exercise at 
a channel level, included minimal revenue 
recovery for the period of the cash 
flow forecasts.

The assessment consisted of scenario 
(stress) testing including one combined 
scenario for those with impacts of medium 
or higher likelihood and moderate or 
higher residual risk. These stress tests 
involved estimating the impact on 
revenues, EBITDA and net cash/debt, 
together with reverse stress testing to 
identify the theoretical sensitivity that 
the Group could absorb. The possible 
mitigating circumstances and actions in 
the event of such scenarios occurring that 
were considered by the Directors included 
cost mitigations such as a reduction in the 
ordinary dividend payment, a reduction 
in operating expenses or the slowdown 
of capital expenditure. 

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The Board manages risks across the Group 
through a formal risk management framework, 
designed to ensure that risks are properly 
identified, prioritised, evaluated and 
mitigated to the extent possible. Key 
aspects of this framework include:

•   a Risk Appetite Statement expressing 
the amount and type of risk the Board 
is willing to accept to achieve its 
strategic objectives;

•   regular assessments of current and 

emerging risks being faced by the Group 
including internal control effectiveness 
and mitigating actions;

•   risk metrics and thresholds which are 

monitored as potential indicators of risk;

•   scenario planning based on the principal 

risks; and

•  oversight from Risk and Compliance 

and Internal Audit functions.

The Board has also considered the risks 
from climate change and concluded that 
there is no material impact with respect to 
viability and going concern over the 
Group’s planning period. 

Viability assessment
In making its assessment of viability, the 
Board has considered the resilience of the 
Group using scenario planning based on 
the principal risks to test the Group’s 
planned earnings, cash flows and viability 
over the three-year period. Using its 
judgement on the likelihood of the principal 
risks and the probability of them being 
inter-related, the Board assessed the risks 
separately and in certain combinations of 
stressed scenarios. In arriving at its 
conclusion, the Board is making the 
assumption that the key aspects of customer 
and provider behaviour set out above 
which underpin the business model will 

continue. It is also assuming that customers 
and providers will continue to want to 
transact online. 

Based on the Company’s current position 
and principal risks, together with the 
results of this robust assessment and the 
Company’s ongoing risk management 
processes, the Directors have a reasonable 
expectation that the Company will be able 
to continue in operation and meet its 
liabilities as they fall due over the three-
year period of their assessment.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

61

Strategic ReportRisk Management

Risk management 
with a customer lens

We continue to manage our risks 
while maintaining our focus on 
helping households save money.

Matt Whittle
Chief Risk Officer

Risk management process

Risk management governance and oversight
•  Framework, policy and procedures

Risk management culture
•  Values, behaviours and communication

•  Three lines of defence

•  Risk appetite 

•  Risk registers and risk assessment

•  Training, education and awareness

•  Embedding in decision-making

•  Continuous improvement

Identify risks

Quantify gross risk

Identify existing risk mitigation

Quantify net risk

Identify if further controls needed

Monitor and control

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Risk management approach
Effective risk management is vital to enabling the Group to achieve 
its strategic objectives, securing the business for the long term 
and ensuring the desired outcomes for consumers. The Group’s 
risk management framework, alongside its governance structure 
and system of internal control, gives the Board assurance that 
risks are being appropriately identified, assessed and managed, 
in line with its risk appetite.

effectively manages risk and takes appropriate and timely action 
where issues are identified. The Risk and Sustainability Committee 
oversees Executive management on behalf of the Board in the 
management of risks. Commencing in 2023, the Chair of the Risk and 
Sustainability Committee will provide assurance to the Remuneration 
Committee on the performance of the business and control functions 
on an annual basis to allow the Remuneration Committee to satisfy 
itself on the appropriateness of its remuneration decisions.

Governance and oversight
A governance and oversight structure is in place, with clearly defined 
lines of responsibility, accountability and delegation of authority.

Horizon scanning is undertaken by the legal, risk and compliance 
teams in order to keep abreast of potential emerging risks. The Risk 
and Sustainability Committee’s agenda retains flexibility in order to 
discuss the mitigation of emerging risks as they are identified.

The Board is ultimately responsible for the overall effectiveness 
of risk management across the business, supported by the Risk 
and Sustainability Committee. The Board delegates day-to-day 
responsibility to Executive management. Executive management 
owns the Group risks, is responsible for ensuring that the business 

The Board has carried out a robust assessment of the emerging and 
principal risks facing the Group, including those that would threaten 
its business model, future performance, solvency or liquidity. Our 
principal risks and uncertainties are outlined on pages 66 and 67 
along with a description of how they are being managed.

Role 

Board 

Responsibilities 

•  Approval of Group Risk Framework and risk appetite. 

•  Carry out an assessment (at least annually) of principal risks and effectiveness of risk management 

and internal control policies, and report to shareholders on such matters.

•  Assessment of the effectiveness of Group Risk Framework and risk appetite and system 

of internal control.

Risk and Sustainability 
Committee

•  Advise the Board on Group Risk Framework and risk appetite. Review and oversight of key risk 

themes and metrics.

•  Oversight of Executive management in management of risks.

•  Review of emerging risks and regulatory change.

Management 

•  Ensure risk management is an integral part of implementing the business strategy.

(1st Line of Defence)

•  Operate the business within set risk appetite and risk metrics.

•  Responsibility for managing risks and implementing effective controls.

•  Implement appropriate processes to identify and evaluate risks.

Risk and Compliance 

•  Implementation of Group Risk Framework and risk appetite and assess internal control effectiveness 

(2nd Line of Defence)

and management actions.

•  Develop and implement risk management policies and tools, and lead communication and training.

•  Monitor progress of the key risk themes.

•  Co-ordinate appropriate and timely delivery of risk management information to Executive 

management and the Risk and Sustainability Committee.

•  Advise and challenge management on risk management and internal control processes.

Internal Audit 

•  Monitor effectiveness of risk management processes.

(3rd Line of Defence)

•  Perform tests of internal controls effectiveness.

•  Identify and agree corrective actions with management.

•  Liaise with Risk and Compliance function, including in relation to mapping of assurance activities to 

the Group’s significant risks.

•  Report to the Audit Committee.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

63

Strategic ReportFuture developments
We will continue to ensure that risk 
management is part of everyday business 
decision making and is understood by all of 
the Group. We will continue to develop our 
management information in light of our 
strategic initiatives and ensure that 
specialist risk knowledge is readily 
available to each of our brands to enable 
them to take and be fully accountable for 
risk-based decisions, whilst providing an 
effective level of risk and compliance 
oversight for the Group.

We will continue to enhance our risk 
management framework in specific 
areas of focus, including cyber risks and 
operational resilience, and consumer 
behaviours, as well as enabling the 
identification and mitigation of 
emerging risks. 

The Group recognises that regulation, in 
particular the activities of the FCA, the ICO, 
Ofgem and the CMA will continue to be 
a feature of both the Price Comparison 
market and the consumer markets in 
which we operate. In 2023, we will embed 
changes necessary to comply with the 
FCA’s Consumer Duty and new Appointed 
Representative requirements and continue 
to assess and respond to the impact of 
energy and insurance regulation in both 
the short and long term.

The management of operational risks 
will continue to be a priority for our risk 
management framework in 2023, in 
particular ongoing embedding of enhanced 
controls in respect of data protection and 
third-party management.

Risk identification 
and assessment
The Group adopts formal risk identification 
and management processes which are 
designed to ensure that risks are properly 
identified and evaluated, in line with risk 
appetite. The identification of significant 
risks is informed using a bottom-up and 
top-down approach with each business 
area identifying new risks as well as 
reassessing those already being monitored. 
To aid in the identification of risks and 
development of associated mitigating 
actions, risks are categorised into strategic, 
financial, operational, regulatory, conduct 
and data risks. Our regular and ongoing 
risk oversight includes a risk and control 
assessment twice a year across all areas 
of the business, in order to understand the 
strength and performance of the controls 
in place, and potential gaps and weaknesses.

Management reporting
Timely and accurate management 
information is provided to the right people 
to support management decisions and 
manage risk effectively within the Group.

Reporting enables management to have 
clear visibility of the most relevant risks; 
to identify areas of concern and/or priority; 
to have access to detailed information to 
enable root cause analysis and identification 
of underlying trends; and to identify, escalate 
and potentially mitigate the impact of new 
operational risk concerns in a timely manner.

Should risk exposures be identified as 
being outside the Group’s risk appetite, 
this is escalated and reported to the Risk 
and Sustainability Committee, alongside 
clear action plans to bring the risk within 
tolerance, with appropriate timescales. 
The type and extent of any mitigating actions 
will be determined by the level and nature 
of the risk and the Group’s risk appetite.

Risk Management continued

The Board performs an annual assessment 
of the risk management and internal 
control framework, covering financial, 
operational and compliance controls 
including the:

•  assessment of the risk management 

framework for identifying and 
monitoring risks, with consideration of 
the integration of strategic and business 
planning processes. This is supported 
by independent reporting on risk 
management and internal controls 
by the Internal Audit function or 
independent third parties, including 
the external auditor;

•  assessment of the extent, frequency and 
quality of risk management and internal 
control reporting;

•  review of the resolution of issues arising 

from internal control failings or 
weaknesses; and

•  review of the effectiveness of the 
financial reporting processes.

Risk management framework
During 2022, we have monitored the risks 
associated with the Group’s current and 
future strategic priorities, overseen the 
Group’s management of risks associated 
with strategic initiatives and strengthened 
the embedding of data security, cyber and 
data protection processes and controls. 
We have also continued to evolve the 
Group’s risk management framework to 
reflect regulatory change such as FCA 
Consumer Duty and FCA General 
Insurance Pricing requirements. 

Risk appetite
“Risk appetite” defines the level and type of 
risk the Group is able and willing to accept 
in order to achieve its strategic objectives. 
The Group’s risk appetite influences the 
Group’s culture and operating decisions, 
and is reflected in the way risk is managed. 
The Group Risk Appetite Statement is 
reviewed at least annually, in line with the 
strategic direction of the Group, recent 
experience and the regulatory environment, 
and is subject to Board approval.

There are certain risk areas where we have 
a very low or no appetite. In such areas, we 
take actions to avoid or eliminate this risk 
as far as possible. In other areas, such as 
strategy, we recognise the importance of 
managed risk taking in order to achieve 
business objectives and goals.

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Our principal risks (as at 31 December 2022)
Outlined here are the Group’s most significant risks that may affect our future. We assess the probability of the risk 
materialising and the impact of the risk on a residual basis (taking into account the benefit of mitigating controls).

1

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6

4

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Probability

Strategic priorities

  Efficient acquisition

  Retain and grow

  Expand our offer

1    Competitive environment  
and consumer demands  

2    Brand strength and reputation 

3    Data processing and protection 

4    Data security and cyber 

5    Relevance to partners 

6    Economic conditions 

7    Regulation

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

65

Strategic Report 
 
Principal Risks and Uncertainties

The table below summarises the Board’s view of the 
material strategic, financial and operational/conduct risks 
to the Group and how the Group seeks to mitigate them.

1

 Competitive environment and consumer demands

Strategic risk

Description
The Group operates in a dynamic 
and highly competitive marketplace 
with new competitors entering the 
market. We must continually 
innovate to keep ahead of 
competitors and changing 
consumer demands.

Mitigating activities
Continuous innovation of new services and ongoing 
evolution of existing propositions.

Regular engagement with consumers to understand 
changes in how they use our services.

Investment in our technology platforms to 
improve customer experience and make comparing 
products easier.

Link to strategy 

Developments in 2022
The Group has invested in a price match offer 
for motor insurance, ensuring that we could offer 
customers cheaper quotes than our competitors 
or they will receive a gift voucher worth £20 and 
we refund the difference.

Quidco has introduced a browser extension, which, 
when installed, allows consumers to browse online, 
and Quidco will remind them to activate cashback.

2

 Brand strength and reputation

Strategic risk

Description
The Group must maintain consumer 
awareness of and engagement with 
its key brands.

Link to strategy 

Mitigating activities
Investment in marketing across a range of media to 
maintain the Group’s brands in consumers’ minds.

Developments in 2022
In May, the MoneySuperSeven featured Dame Judi 
Dench as “Eight” with a mission to save the nation £1bn.

Our strong relationships with our providers allow 
us to offer exclusive and market-leading deals.

MoneySavingExpert has been uniquely positioned 
to guide consumers through changes in the energy 
market and the cost of living crisis. MoneySavingExpert 
introduced an app in May to appeal to a wider audience. 

3

 Data processing and protection

Operational/conduct risk

Description
The Group must appropriately 
process and control the data our 
customers share.

As a leading website operator, the 
Group may experience operational 
issues which result in incorrect or 
incomplete data being transferred 
to or from partners.

Link to strategy 

Mitigating activities
Understanding and assessment of the data we collect 
from our customers and how we use it.

Specialist data protection knowledge within our Risk and 
Compliance, Technology and Legal teams. Annual data 
protection training for all employees.

Controls and monitoring of internal processes. Regular 
ongoing quality assurance procedures.

Developments in 2022
The Group extended its modernisation of the data 
estate into Google Cloud Platform, with Quidco 
following in 2023, to simplify, but strengthen, internal 
processes, and to better share data and insight within 
the Group.

MoneySuperMarket enhanced and delivered its 
mandatory training across the Group. 

4

 Data security and cyber risk

Operational/conduct risk

Description
The Group must protect itself from 
security breaches or successful 
cyber attacks which could impact 
our ability to operate our websites 
and services.

Mitigating activities
Rigorous monitoring and testing of the Group’s 
systems and infrastructure. Enhancing controls to our 
data and systems through the implementation of our 
Information Security Management System (“ISMS”).

Developments in 2022
The Group continues to invest in our cyber 
governance framework and ‘ISMS’ – this includes 
bot management. 

Link to strategy 

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Moneysupermarket.com Group PLC

Risk trend 

Strategic priority

Increasing

  Efficient acquisition

   Decreasing

  Retain and grow

   Stable

  Expand our offer

5  Relevance to partners

Strategic risk

Link to strategy 

Description
The Group relies on its partners to 
access competitive products and 
technological integration to provide 
a seamless customer experience. 

Mitigating activities
Working closely with partners to ensure high-quality 
and appropriate products and to maximise the 
opportunities for partners to acquire customers 
in a cost-effective manner.

Developments in 2022
The Group remains a cost-efficient and flexible way 
for providers to access millions of customers. Strong 
relationships with partners enable us to access 
exclusive deals and offers for our customers.

6

 Economic conditions

Strategic risk

Description
Weaknesses in the UK economy 
including the cost of living crisis and 
unprecedented energy market 
conditions have led to more 
challenging conditions in one or 
more markets in which we operate.

7

 Regulation

Strategic risk

Description
The Group must understand and 
respond to the effects of regulatory 
intervention in the markets in which 
we operate. 

The Group must comply with 
existing and new regulatory 
requirements which directly 
apply to its activities.

Mitigating activities
Maintaining a diversified business across a range 
of products.

Regular monitoring of market conditions and 
environment.

Focusing on maintaining control of our cost base.

The continued diversity of the Group across a 
portfolio of brands and channels offers the Group 
protection from cyclical economic changes.

Link to strategy 

Developments in 2022
The Group has continued to diversify and 
reallocated resources and prioritisation to 
appropriate channels where necessary as a 
result of the energy market conditions. 

Link to strategy 

Mitigating activities
We maintain regular and ongoing dialogue with key 
regulatory bodies.

Our Risk and Compliance team works across the 
Group to ensure it remains compliant with new 
and existing regulations.

Developments in 2022
The Group has monitored and responded to new and 
emerging regulatory developments. We have proactively 
engaged with regulators, such as the FCA and Ofgem, on 
regulatory change, including the energy price cap, the 
FCA GI pricing reform and the FCA’s Consumer Duty.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

67

Strategic Report  
Chair’s Introduction to Governance

Leadership
and governance

We delivered well against our strategy. 
Our work on more efficient acquisition has 
delivered strong gross margin improvements.

Robin Freestone
Chair 

Purpose and culture
The cultural tone of the business begins 
in the Boardroom. Our purpose of helping 
households save money is enabled by the 
behaviours that are embedded into our 
business and is aligned with our strategy. 
Together, these help to create a culture 
which optimises performance and 
delivers long-term results.

The Board endeavours to promote 
integrity and diversity of thought at all 
levels of the Group. We are committed to 
developing a diverse workforce and an 
inclusive working environment. This 
commitment is demonstrated in the 
implementation of our diversity and 
inclusion initiatives, including our 
commitment to the Race at Work Charter.

Further details on our culture, purpose 
and values can be found in our Strategic 
Report on pages 02 to 67.

Dear fellow shareholder 
I am pleased to present the Group’s 
Corporate Governance Statement 
for 2022.

Board focus areas in 2022:
•   appointment and induction of a new 
Independent Non-Executive Director 
and the sourcing of a new Chief 
Financial Officer; 

•   robust assessment of the Group’s 
strategy and strategic initiatives; 

•   monitored and reviewed the Group’s 

emerging and principal risks; 

•   monitored progress against the Group’s 

diversity and inclusion strategy; 

•   assessment of environmental initiatives, 
including progress made against the 
plan to become operational net zero by 
2030 and development of SBTi targets; 

•   approved the acquisition of additional 
share capital in Podium, bringing our 
total interest to 52%; and

•   monitored the embedding of Quidco 

into the Group post acquisition in 2021.

As a Board, we aim to maintain a 
governance structure which provides 
effective control and oversight of the 
Group, while promoting the entrepreneurial 
spirit which has been central to the Group’s 
success in helping households save money. 
In this report, we describe how our purpose, 
values and strategy are aligned with our 
culture and how we consider all our 
stakeholders in key decisions.

Governance improvements 
during 2022
•  dedicated Board session reviewing risk 
management processes, including risk 
tolerances of the Group; 

•  reviewed and enhanced the Board and 
Committee reporting templates, action 
tracking and planning processes; 

•  reviewed and approved all governance 
policies and training, ensuring they 
remained aligned with Group values 
and continue to support long-term 
sustainable success; 

•  the enhancement of governance 

controls in relation to our Sustainability 
Framework including clarity of roles and 
responsibilities and an additional review 
process; and 

•  updated and approved the Matters 

Reserved for the Board and the Board 
Committees’ Terms of Reference. 

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The table below shows where shareholders can evaluate how the Company has 
applied the principles of the Code and where key content can be found in this report. 

Section

Further information

Board leadership and Company purpose 

Business model – pages 16 and 17

The cultural tone of the business begins in 
the Boardroom. The Board has established 
a clear purpose, set of values and strategy, 
taking into account the interests of our wider 
stakeholders. The right resources, structures 
and processes are in place to ensure that 
these are implemented throughout the Group.

Board activities – pages 74 to 76

Risk management – pages 62 to 65

Shareholder engagement – page 73

Section 172 Statement – pages 29 
to 35

Sustainability Report – pages 36 to 53

Workforce engagement – pages 83 to 84

Division and responsibilities

Board of Directors – pages 70 and 71

The respective roles and responsibilities of 
the Executive and Non-Executive Directors 
are clear and consistently applied, providing 
for effective and constructive dialogue and 
clear accountability.

Composition, succession and evaluation

The Group has a strong Board with a balance 
of skills, experience, knowledge and diversity. 
The appointment process is rigorous and 
carefully applied, with annual evaluation 
keeping the effectiveness of the Board and 
its Committees under regular review.

Division of responsibilities – pages 77 
and 78

Nomination Committee Report 
– pages 85 to 88

Nomination Committee Report 
– pages 85 to 88

Board skills and experience – page 86

Board evaluation – pages 81 and 82

Audit, risk and internal control

Risk management – pages 62 to 65

The Board has established clear processes 
and procedures to ensure that risks are 
carefully identified, monitored and mitigated 
against and then reported externally in an 
open and transparent manner. This helps 
ensure that the Company’s financial 
statements are fair, balanced and 
understandable. Effective risk management 
is critical to achieving our strategy.

Audit Committee Report – pages 89 
to 93

Risk and Sustainability Committee 
Report – pages 94 to 96

Board activities – pages 74 to 76

Remuneration

Business model – pages 16 and 17

Remuneration supports the Company’s 
strategy and is appropriate to the size, 
nature, complexity and ambitions of the 
business. The Board aims to report in a 
clear manner, demonstrating that pay, 
performance and wider interests are aligned.

Remuneration Committee Report – 
pages 97 to 117

Compliance with the 2018 UK Corporate Governance Code 
(the ‘Code’)
During the year ended 31 December 2022, we have applied the principles and complied 
with the provisions contained in the Code with the exception of provision 38 (alignment of 
executive director pension contribution rates with those available to the wider workforce), 
for which phased arrangements were in place to ensure that Scilla Grimble’s pension 
was in compliance by 31 December 2022 as detailed in the Remuneration Report on 
page 107. This report explains how we as a Board lead the Group and discharge our 
governance duties and outlines the governance initiatives we have undertaken during 
the year. The Corporate Governance Statement also explains compliance with the FCA’s 
Disclosure and Transparency Sourcebook. In reviewing our Board’s effectiveness, we 
have taken into account the Financial Reporting Council’s 2018 Guidance on Board 
Effectiveness and applied its guidance where appropriate. The Financial Reporting 
Council (‘FRC’) is responsible for the publication and periodic review of the UK 
Corporate Governance Code, and this can be found on the FRC 
website, www.frc.org.uk.

The Board also reviewed its governance framework to ensure it remains fit for 
purpose and continues to be compliant with the SM&CR.

Board changes
The Board spent a significant amount of time 
considering succession planning during the 
year. As previously notified, James Bilefield 
resigned from the Board on 31 May 2022, 
following which Sarah Warby was appointed 
Interim Remuneration Committee Chair. Also, 
as previously notified, Sally James stepped 
down as a Non-Executive Director at the 
conclusion of the AGM on 5 May 2022 and I 
would like to thank Sally for her contribution 
to the Board during her tenure. I am pleased 
to announce that Lesley Jones took over the 
role of Chair of the Risk and Sustainability 
Committee and Caroline Britton was 
appointed Senior Independent Director. 
Supriya Uchil has decided to step down from 
the Board on 30 April 2023 to focus on other 
work commitments and I would like to thank 
her for her support over the past three years.

As described in my Chair's Statement 
on page 08, we were delighted to welcome 
Rakesh Sharma OBE, who joined the Board as 
a Non-Executive Director on 3 October 2022 
and took over the role of Remuneration 
Committee Chair on 1 January 2023. Rakesh 
brings with him a wealth of experience in 
technology, cyber and industry and further 
strengthens the diversity and experience of 
our Board. Niall McBride joined the Group on 
1 February 2023 and will take over as Chief 
Financial Officer on 20 February. Niall brings 
strong digital and consumer experience and I 
am looking forward to working with him as we 
continue to successfully execute our strategy.

For further information regarding the formal, 
rigorous and transparent selection process in 
relation to Rakesh and Niall, please see our 
Nomination Committee Report on pages 85 
to 88. 

Company Secretary change 
Shazadi Stinton was appointed General 
Counsel and Company Secretary with effect 
from 9 May 2022 and Alice Rivers completed 
her appointment as Interim Deputy Company 
Secretary on 29 July 2022. 

Dividend 
I am delighted to report that the Board has 
proposed a final dividend of 8.61p per share 
to shareholders in respect of 2022.

Looking forward
We will continue as a Board to maintain our 
high standards of corporate governance 
across the Group, underpinning the delivery 
of our strategy and our purpose. Over the 
next 12 months we will also continue to focus 
on delivering our social and environmental 
commitments, as well as the continued 
engagement of our employees and 
implementation of our diversity and 
inclusion strategy.

Robin Freestone
Chair
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

69

GovernanceBoard of Directors

Experience

and focus

01

03

05

07

09

02

04

06

08

10

Read more about employee 
engagement on pages 83 and 84

Read more about key Board 
activities on pages 74 to 76

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Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Selection process 
We welcomed Rakesh Sharma to the Board in 
October 2022. The Company has a formal, rigorous 
and transparent selection process for the 
appointment of new Directors. The Nomination 
Committee is responsible for identifying and 
nominating all Board candidates and, before any 
appointment is made, evaluates the mix of skills, 
experience, knowledge and diversity to ensure 
the correct balance is maintained.

Induction and onboarding
On joining the Board, it is the responsibility of 
the Chair and Company Secretary to ensure that 
all newly appointed Directors receive a full and 
formal induction, which is tailored to their 
individual needs. The induction programme 
includes a comprehensive overview of the 
Group and dedicated time with the Directors 
and senior management, as well as guidance 
on the duties, responsibilities and liabilities 
as a Director of a listed company.

01  Robin Freestone
Chair of the Board

Committees  N

Term of office: Appointed as Non-Executive 
August 2015 and as Chair May 2019.

Robin’s contribution to the Board, key 
strengths, skills and reasons for re-election: 
Robin brings to the Board extensive transformation 
and diversification experience from leading 
global and digital businesses. He was Chief 
Financial Officer of Pearson PLC from 2006 to 2015, 
and Deputy Chief Financial Officer prior to that. 
Robin has also held senior financial positions at 
Amersham plc (2000 to 2004), Henkel Ltd (1995 
to 2000) and ICI plc (1984 to 1995). Robin has 
extensive global and digital business leadership 
experience and has an in-depth understanding 
of governance requirements having served as 
both an Executive and Non-Executive Director 
of a number of listed companies. Robin brings 
financial insight as well as an understanding of 
how to attract and retain talent as Chair of the 
Board and Nomination Committee.

External appointments: Robin is Lead Director 
of Capri Holdings (formerly Michael Kors 
Holdings Limited) and Non-Executive Director 
and Chair of the Audit and Risk Committee of 
Aston Martin Lagonda Global Holdings plc. 

02  Peter Duffy
Chief Executive Officer

Term of office: Appointed September 2020.

Peter’s contribution to the Board, key 
strengths, skills and reasons for re-election: 
Peter’s key contributions to the Board are 
extensive experience in digital businesses and a 
dynamic leadership style. He was previously CEO 
of Just Eat and before that was Chief Commercial 
Officer at easyJet and Marketing Director of Audi 
UK. Peter started his career in banking, holding 
positions with Barclays, Yorkshire Bank and TSB. 
Peter has an excellent overall track record, as 
well as very relevant experience in driving digital 
revenues and in all aspects of marketing. He is 

well rounded from a sector perspective having 
worked in financial services, airlines, automotive 
and consumer internet. This mix has given him 
plenty of exposure to operating within 
a regulated environment.

External appointments: Peter is a Non-Executive 
Director of Close Brothers Group plc, where he is a 
member of the Risk Committee and Remuneration 
Committee. He is currently President of ISBA – 
the UK trade body for leading British advertisers.

03  Sarah Warby
Independent Non-Executive Director and 
Non-Executive Director Employee Champion
Committees  A   N   RS   RE
Term of office: Appointed June 2018.

Sarah’s contribution to the Board, key 
strengths, skills and reasons for re-election: 
Sarah has experience of building valuable 
brands across consumer sectors. She was 
previously Chief Executive Officer of Lovehoney 
and, before that, Chief Growth Officer of 
HyperJar Ltd. Prior to that, Sarah was Chief 
Marketing Officer at J Sainsbury plc and 
Marketing Director of Heineken UK. She is a 
fellow of the Marketing Society and Marketing 
Academy and an adviser to the Museum of Brands. 
A proven leader, with strong people and 
communications skills, Sarah brings valuable 
experience to her role as Non-Executive Director 
and Employee Champion.

External appointments: Sarah is 
Chief Customer Officer at Nando’s UK&I.

04  Caroline Britton
Senior Independent Director
Committees  A   N   RS   RE
Term of office: Appointed September 2019.

Caroline’s contribution to the Board, key 
strengths, skills and reasons for re-election: 
Caroline has a strong financial background, 
retiring as Audit Partner at Deloitte LLP after 30 
years of service (2000 to 2018 as Audit Partner). 
Caroline is an FCA of the Institute of Chartered 
Accountants in England and Wales and holds an 
MA in Economics from Cambridge University. 
Caroline’s strong financial background and 
regulatory experience make her ideally skilled to 
Chair the Audit Committee and she brings to the 
Board valuable governance and risk 
management expertise.

External appointments: Caroline is a 
Non-Executive Director of Sirius Real Estate 
Limited where she is Chair of the Audit 
Committee and a member of the Nomination 
Committee. Caroline is also a Non-Executive 
Director of Revolut Limited where she is Chair 
of the Audit Committee and a member of the 
Risk and Remuneration Committees and of 
the Supervisory Council of Revolut Bank UAB; 
a member of the Audit, Finance, Risk and 
Investment Committee of Make-A-Wish 
International; and a Trustee of the Royal Opera House.

05  Supriya Uchil 
Independent Non-Executive Director
Committees  A   N   RS   RE  
Term of office: Appointed March 2020 (Supriya 
resigned from Board on 18 January 2023 and will 
step down from the Board on 30 April 2023).

Supriya’s contribution to the Board, key 
strengths and skills: Supriya is the product-
focused Non-Executive Director of Bloom&Wild.
com, an online European florist. She is the Chair 
of the Ounass Advisory Board, a luxury 
e-commerce start-up in the GCC. Previously she 
was the Chief Product Officer of Booking Go, 
part of Booking Holdings Inc, and prior to that 
held senior roles at Amazon.com.

External appointments: Supriya is a 
Non-Executive Director of Bloom & Wild, 
Non-Executive Director for Ounass, Chair 
of the Advisory Board for Ounass and CEO 
of Accelerate Product Ltd.

06  Rakesh Sharma 
Independent Non-Executive Director
Committees  A   N   RS   RE  
Term of office: Appointed October 2022.

Rakesh’s contribution to the Board, key 
strengths, skills and reasons for election: 
Rakesh is a former Chief Executive Officer and 
brings to the Board over 30 years’ broad 
experience from the tech and cyber industries. 
Having successfully overseen remuneration 
policy updates as Remuneration Committee 
Chair at PayPoint plc, he brings valuable 
experience to the Board as Chair of the 
Remuneration Committee. 

External appointments: Rakesh is currently 
the Senior Independent Director and 
Remuneration Committee Chair at PayPoint plc 
and Chairman of AIM-listed Kromek Group plc. 

07  Scilla Grimble
Chief Financial Officer

Term of office: Appointed February 2019 (as 
announced on 20 June 2022, Scilla will step down 
from the Board on 17 February 2023).

Scilla’s contribution to the Board, key 
strengths and skills: Scilla has a strong 
financial background and extensive consumer 
experience. She was formerly Director of Group 
Finance and Interim Chief Financial Officer at 
Marks and Spencer Group PLC (2016 to 2018). 
Scilla previously held senior finance roles at 
Tesco PLC and was a Managing Director at UBS 
Investment Bank. Scilla is a qualified chartered 
accountant, having trained and qualified with PwC.

External appointments: Scilla is a Non-
Executive Director of Taylor Wimpey plc where 
she is a member of the Audit Committee and the 
Nomination and Governance Committee.

08  Lesley Jones
Independent Non-Executive Director
Committees  A   N   RS  
Term of office: Appointed September 2021.

Lesley’s contribution to the Board, key 
strengths, skills and reasons for re-election: 
Lesley was previously a Non-Executive Director 
of N Brown Group plc, ReAssure Group plc 
(where she chaired the Risk Committee), 
Northern Bank Limited and Close Brothers 
Group plc (where she also chaired the Risk 
Committee). Lesley started her career at 
Citigroup Inc. where she held a number of senior 
roles in relationship and risk management over 
a period of 30 years. She then spent over five 
years at RBS Group plc as Group Chief Credit 
Officer where she rebalanced the Group’s credit 
risk appetite, established a market-leading credit 
function and led its credit quality assurance 
function. Lesley’s extensive experience as a 
global credit risk manager operating at both 
executive and board level means that she is 
well placed to chair the Risk and Sustainability 
Committee and brings her broader financial 
services expertise to the Audit and Nomination 
Committees.

External appointments: Chair of Sainsbury’s 
Bank and Non-Executive Director of Moody’s 
Investors Services Limited.

09  Shazadi Stinton
General Counsel and Company Secretary 

Term of office: Appointed April 2022.

Shazadi’s contribution to the Board, 
key strengths and skills: Shazadi has over 
20 years' legal experience, having been Head 
of Legal Counsel at Severn Trent and a solicitor 
at Eversheds Sutherland. Shazadi’s key 
contribution over and above her legal acumen is 
her extensive understanding of environmental 
and sustainability issues and requirements, 
which she has utilised to enhance the Group’s 
frameworks, governance and external reporting. 

External appointments: None.

10  Niall McBride 
Chief Financial Officer 

Term of office: To be appointed 20 February 2023.

Niall’s contribution to the Board, key 
strengths, skills and reasons for election: 
A chartered accountant, Niall brings strong digital, 
consumer and corporate finance experience to 
the Board. Niall was most recently Chief Financial 
Officer at Ocado Retail Limited and prior to this 
he was a Managing Director at Rothschild & Co, 
having commenced his career at PwC. 

External appointments: None.

A Audit Committee
N Nomination Committee
RS Risk and Sustainability 

Committee

RE Remuneration Committee

Denotes Chair

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

71

GovernanceCorporate Governance Statement

Governance framework

The Board
The Board is responsible for the long-term sustainable success of the Group, with  
the overall aim of delivering shareholder value. Principally, we achieve this through:

•  setting and monitoring strategy and ensuring the necessary resources are in place;

•  providing entrepreneurial leadership within an effective risk management  

Read more about the Board  
on pages 70 and 71

Read more about key Board 
activities on pages 74 to 76

framework and internal control system; and

•  reviewing management’s performance.

Read more about division of 
responsibilities on pages 77 and 78

Remuneration 
Committee
The Remuneration 
Committee’s key 
responsibility is to 
determine and apply 
the shareholder 
approved Remuneration 
Policy to ensure that it 
promotes the delivery 
of our strategy and the 
long-term sustainable 
success of the Group.

Nomination 
Committee
The Nomination 
Committee is 
responsible for 
reviewing the Board’s 
size, structure and 
composition, including 
the recommendation 
of appointments to 
the Board, succession 
planning and 
development plans 
for the Board and 
overseeing the Group’s 
diversity plans.

Audit Committee
The Audit Committee 
is responsible for 
ensuring appropriate 
challenge and 
governance of 
accounting treatment 
and the internal control 
environment and 
ensuring that the 
Annual Report as a 
whole is fair, balanced 
and understandable.

Risk and 
Sustainability 
Committee
The Risk and 
Sustainability 
Committee is 
responsible for 
overseeing the Group’s 
risk management and 
sustainability 
frameworks. The 
Committee ensures 
that risks are 
appropriately 
identified, managed 
and mitigated, and 
advising the Board on 
risk appetite, structure 
and culture. From 
January 2023, it will 
monitor the embedding 
of the sustainability 
framework, monitoring 
related KPIs and 
external reporting. 

Audit 
Committee Report

Pages 88 to 93

Risk and 
Sustainability 
Committee Report

Pages 94 to 96

Remuneration 
Committee Report

Pages 97 to 117

Nomination 
Committee Report

Pages 85 to 88

CEO and Executive Team

Information and reporting 

Responsibility for the development and implementation of the 
Group’s strategy and overall commercial objectives rests with the CEO, 
supported by the Executive Team and Senior Leadership Team. The 
Executive Team is responsible for day-to-day operations, for delivering 
results and for driving growth, ensuring this is done in a sustainable 
and ethical manner.

Each Committee has an annual forward agenda planner based upon 
the duties and responsibilities documented within its Terms of 
Reference and presented at each meeting for consideration. Company 
Secretariat conducted a detailed review of the Terms of Reference 
during the year, with updated versions being approved by the Board in 
December 2022. Papers are circulated to the Board seven days before 
meetings take place to ensure that members have adequate time to 
review and digest.

72

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

a mixture of group and one-to-one 
contexts. They also met with 15 of our top 
investors, some on multiple occasions. 

Formal presentations are given to analysts 
and shareholders covering the full-year 
and half-year results, and briefings are 
also given on quarterly trading. Virtual 
roadshows were attended by the CEO 
and CFO during the year to meet with 
our material and prospective UK, European 
and US investors. The Group also seeks 
to maintain a dialogue with various bodies 
which monitor the Company’s governance 
policies and procedures. The Investor 
Relations Director generally deals with ad 
hoc queries from individual shareholders.

The Chair initiates contact with major 
shareholders after the Annual Report and 
Accounts is published to invite them to 
engage prior to the Annual General 
Meeting. It is also an opportunity to 
discuss important matters such as our 
strategy. The Remuneration Committee 
Chair also engages in discussion with 
shareholders on significant matters 
relating to Executive remuneration, in 
particular any amendments or material 
changes to our remuneration policy. 
During 2022 Sarah Warby, our Interim 
Remuneration Committee Chair, together 
with our Chair and General Counsel and 
Company Secretary, met with eight of our 
top 15 shareholders to discuss our 
proposed Remuneration Policy and further 
details of the outcome of these meetings is 
on page 35.

Our Senior Independent Non-Executive 
Director is available to shareholders if they 
have concerns which contact through the 
normal channels of the Chair, the CEO or 
the CFO, has failed to resolve, or for which 
such contact is inappropriate.

All Directors receive formal reports and 
briefings during the year about the 
Company’s Investor Relations programme. 
Directors also receive detailed feedback 
obtained by the Company’s brokers after 
meetings, allowing them to develop an 
understanding of the views of major 
shareholders. External analysts’ reports 
on the Group are circulated to Directors on 
a regular basis. The Directors also receive 
investor feedback reports on 
quarterly results.

Annual General Meeting (‘AGM’)
Our 2022 AGM was held on 5 May 2022 at 
which shareholders representing c.81% of 
the Company’s issued share capital voted 
and we received in excess of 83% votes in 
favour for all of our resolutions. Our 2022 
AGM was conducted at 1 Dean Street, 
London, and shareholders were given the 
opportunity to submit questions to the 
Board ahead of the AGM and a Q&A 
session was recorded and published 
on our corporate website.

2022 key shareholder events

17 February 2022

2021 full year results

12 April 2022

Q1 2022 trading update

5 May 2022

Annual General Meeting

12 May 2022

Payment of 2021 final dividend

21 July 2022

H1 2022 interim results

October 2022

Q3 2022 trading update

16 February 2023

2022 full year results

Strategy
The Board is responsible for setting and 
monitoring progress against the Group’s 
strategy, ensuring this is aligned with the 
Group’s purpose of helping households 
save money and delivers value for 
shareholders. High standards of corporate 
governance underpin this by ensuring that 
the Board, supported by the Executive 
Team, can execute effective decision 
making and create sustainable long-term 
value for the benefit of all of our 
stakeholders. Further information on the 
delivery of our strategy is on pages 18 to 
28. Responsibility for the development and 
implementation of the strategy and overall 
strategic initiatives sits with the CEO who is 
supported by senior management.

The Board undertook a review of the Group’s 
strategy at a number of meetings during the 
year, attended by senior management, 
where it received presentations on the 
strategies for the business and functional 
areas, as well as a review of the overall 
strategy. These culminated in an annual 
one-day strategy offsite meeting in October 
2022 whereby the future year’s strategy 
was reviewed, with agreed initiatives 
being incorporated within operational 
and budgetary plans to enable tracking 
throughout 2023.

Stakeholder engagement
The success of the Group’s strategy is 
reliant on stakeholder engagement. The 
Board is focused on driving long-term 
sustainable performance for the benefit 
of our customers, shareholders and wider 
stakeholders. The Board does not seek 
to balance the interests of the Company 
and those of its stakeholders. Instead, 
it considers all the relevant factors and 
chooses the course of action which is 
most likely to lead to the Group’s long-term 
success. Further information on how the 
Group engages with its stakeholders and 
the Group’s Section 172 Statement can 
be found on pages 29 to 35.

Shareholder engagement
The Board actively seeks and encourages 
engagement with major institutional 
shareholders and other stakeholders. The 
CEO and CFO regularly meet with analysts 
and institutional shareholders to keep 
them informed of significant developments 
and to develop an understanding of their 
views which are then discussed with the 
Board. During 2022 the Investor Relations 
team conducted over 80 meetings with 
potential and current investors, and 
attended four investor conferences, 
meeting a broad range of investors in 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

73

GovernanceCorporate Governance Statement continued

2022 Board attendance

Board member

Board

Additional

Nomination
 Committee 

Additional

Remuneration
Committee

Additional

Audit
 Committee

Additional

Risk and 
Sustainability
Committee

Additional

Total 
number of 
meetings 

Robin 
Freestone

Scilla 
Grimble 

Caroline 
Britton

Sally James1

Sarah 
Warby

Supriya 
Uchil

James 
Bilefield2

Lesley Jones

Peter Duffy

Rakesh 
Sharma3

8

8/8

8/8

8/8

4/8

7/8

7/8

4/8

8/8

8/8

2/8

1

0/1

0/1

1/1

0/1

1/1

1/1

0/1

0/1

1/1

0/1

3

3/3

—

3/3

2/3

2/3

2/3

2/3

3/3

—

1/3

1

1/1

—

1/1

0/1

1/1

1/1

0/1

0/1

—

0/1

3

—

—

3/3

1/3

2/3

3/3

1/3

—

—

1/3

3

—

—

3/3

1/3

3/3

3/3

1/3

—

—

1/3

4

—

—

4/4

2/4

3/4

4/4

2/4

4/4

—

1/4

—

—

—

—

—

—

—

—

—

—

—

3

—

—

3/3

2/3

2/3

3/3

2/3

3/3

—

0/3

—

—

—

—

—

—

—

—

—

—

—

1  Sally James stood down from the Board in May 2022. Sally attended all meetings until this date.

2 

James Bilefield stood down from the Board in June 2022. James attended all meetings until this date.

3  Rakesh Sharma joined the Board in October 2022.

Ad hoc Committee meetings were convened to deal with specific matters which required attention between scheduled meetings, 
such as the recruitment of a new Independent Non-Executive Director and Chief Financial Officer and for consideration of the 
Group’s Remuneration Policy.

Links

Links to strategy

Links to risks

1   2   5   6

Key Board activities

Key Board activities

Strategy:

•  undertook a review of the Group’s strategy at a number of meetings attended by the Board and 
senior management, including a one-day strategy meeting at which we reviewed and discussed:

 – the strategic landscape in which the Group operates;

 – the Group’s financial outlook;

 – compelling customer propositions; and

 – expanding the Group’s offer;

•  approved acquisition of additional share capital in Podium, taking the Group’s total to a majority 

stake of 52%;

•  reviewed the Group’s plans against the Board’s risk appetite to ensure that our ambitions for 

the business are aligned with our ability to manage risk;

•  considered alternative ownership options and defence strategies;

•  held "deep dives" at our Board meetings into various aspects of the business including our 
data infrastructure, cyber security, third-party risk management and strategic priorities;

•  approved the Group’s net zero strategy and carbon reduction plans; and

•  considered the risks and opportunities faced by the Group in response to climate change.

74

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Links

Links to strategy

Links to risks

2

3

4

7

Key Board activities

Governance, risk management and regulatory: 

•  reviewed and revised our annual programme of business for the Board and each 

of the Committees, tailoring the deep dives to reflect our strategic priorities;

•  progressed the actions from the 2021 Board evaluation and conducted an internal Board 

evaluation process, details of which are on pages 81 to 82;

•  reviewed, within the Remuneration Committee, the Group’s Remuneration Policy 
and undertook consultation with the top 15 shareholders as detailed on page 35; 

•  reviewed our governance framework to ensure it remains fit for purpose and compliant 

with SM&CR;

•  reviewed and approved the Group’s FCA Consumer Duty Plan in October 2022;

•  considered whistleblowing processes throughout the Group and received a whistleblowing update;

•  oversaw the implementation of digital enhancements, including those pertaining to our cyber 

and data security capabilities;

•  reviewed our application and compliance of the Code including receiving a stakeholder 

engagement update and reviewing our wider engagement mechanisms;

•  agreed the Group’s principal risks and uncertainties, and identifying emerging risks which 
could impact the Group, such as those arising from the cost of living crisis and changes to 
the energy market; 

•  reviewed the effectiveness of our internal control and risk management processes; and

•  ensured compliance with the requirements of the TCFD, receiving regular updates throughout 

the year and approving the TCFD Report as detailed on pages 48 to 51.

Leadership, employees and culture:

Links to strategy

•  reappointed Sarah Warby as our Non-Executive Director Employee Champion and approved 

an enhanced programme of engagement activities with employees;

•  appointed Rakesh Sharma as an Independent Non-Executive Director and Chair of the 

Remuneration Committee (subject to regulatory approval) and Niall McBride as Chief Financial 
Officer with effect from 20 February 2023;

Links to risks

1

2

5

6

7

•  received "Employee Voice Updates" as a standing Board agenda item for every meeting; 

•  reviewed and approved the Group’s Modern Slavery Act Statement;

•  received an update on the Group’s Whistleblowing Policy and procedures, enabling employees 

to raise concerns confidentially;

•  assessed progress against the Group’s diversity and inclusion strategy, including the 

implementation of the Group’s commitment to the Race at Work Charter; and

•  received updates on the Group’s people and culture, organisational structure, diversity, talent 
management and employee engagement including reviewing results of employee surveys and 
feedback from the various employee focus groups (diversity and inclusion, mental health 
awareness and environmental matters).

Budget, financing and investor relations:

•  approved the annual budget and long-term plan;

•  approved audited financial statements for the year ended 31 December 2022, confirming 

the Group’s going concern statement and the longer-term viability;

•  received reports and updates at each meeting on investor relations activities;

•  reviewed capital allocation options including approving the interim dividend and recommending 

the final dividend to shareholders; and

•  received updates on the programme to migrate data to the Google Cloud Platform. 

Links to strategy

Links to risks

6

7

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

75

GovernanceCorporate Governance Statement continued

Key Board activities continued

Key Board activities

Business performance:

•  reviewed the strategic and operational performance of each of our businesses;

•  reviewed market and trading updates and considered Group financial performance against 

budget and forecast, including the decision to increase market guidance within the Q3 Trading 
Statement; and

•  agreed Group KPIs for 2022 onwards which are aligned with the Group’s strategic priorities.

Links

Links to strategy

Links to risks

1

2

5

6

Section 172: how we bring the stakeholder voice into the Boardroom:

Links to strategy

•  the Board reporting templates were enhanced during 2022 to include reference to section 172 
which requires paper providers to consider the Group’s stakeholders during proposal drafting 
and the Board to factor this into its decision making; 

•  the Board receives biannual updates from the Chief People Officer on people, culture, diversity, 

talent and engagement;

Links to risks

1

2

5

7

•  "Employee Voice Update" is a standing agenda item and our NED Employee Champion, Sarah 
Warby, provides feedback on engagement sessions for further discussion by the Board. It was 
confirmed on 17 January 2023 that Rakesh Sharma would take on the role of NED Employee 
Champion during 2023;

•  the Board considered the appointment of Sarah Warby as the Group’s FCA Consumer Duty 

Champion, confirming the appointment on 17 January 2023. Sarah advocates for the Group’s 
customers to ensure that they are considered in our decision making; 

•  at the annual strategy meeting between the Board and Executive Team, potential impacts to 

stakeholders are discussed and considered, when deciding and agreeing on strategic initiatives;

•  members of the Board and the Executive Team meet with major shareholders and feedback 

is shared with the wider Board;

•  provider feedback is received through business updates given to the Board during the year;

•  customer and user updates are provided to the Board by the senior management team 

on a regular basis;

•  key advisers attend and contribute to Board and Committee meetings; and

•  regulatory updates are provided to the Risk and Sustainability Committee and, where appropriate, 

to the whole Board, including direct interaction with the FCA and other regulatory bodies.

For further information please see our Section 172 Statement on pages 29 to 35.

Looking forward to 2023:

Links to strategy

•  implementation of the FCA’s Consumer Duty Plan and embedding of the Consumer Duty 

Champion role into Board discussions; 

•  the delivery of the Group’s 2023 strategic initiatives; 

•  recruiting and inducting a new Non-Executive Director following the resignation of Supriya Uchil 

on 17 January 2023;

•  oversight of management's preparedness for the implementation of the BEIS recommendations, 

including internal control enhancements and upcoming changes to the Corporate 
Governance Code;

•  supporting the onboarding and induction of the Chief Financial Officer; and

•  undertaking training in cyber security, sustainability and consumer duty.

Links to risks

1

2

3

4

5

6

7

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Annual Report and Accounts 2022
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Division of responsibilities

Roles and responsibilities
Board members have clearly defined roles 
and responsibilities, as set out in the table 
below. As set out in their biographies on 
pages 70 and 71, each member of the 
Board has a range of skills and experience 
that is relevant to the successful operation 
of the Group.

Independence of Non-
Executive Directors
The Nomination Committee reviews the 
independence of the Non-Executive 
Directors annually and has confirmed to 
the Board that it considers each of the 
Chair and the Non-Executive Directors 
to be independent in accordance with 
the Code.

Time commitment
All Non-Executive Directors are required to 
devote sufficient time to meet their Board 
responsibilities and demonstrate 
commitment to their role. During the year, 
the Nomination Committee considered the 
time commitment of all the Directors and 
agreed that the required time commitment 
from them remained appropriate. See 
page 88 of the Nomination Committee 
Report for further details. 

External appointments
In accordance with the Code, full Board 
approval is sought prior to a Director 
accepting an external appointment. 
Prior to the approval of any external 
appointments, the Board considers 

the time commitment required by Directors 
to perform their duties effectively. As part 
of the selection process for any new 
Board candidates, any significant time 
commitments are considered before 
an appointment is agreed. 

Access to advice
Should any Director judge it necessary to 
seek independent legal advice about the 
performance of their duties with the 
Company, they are entitled to do so at the 
Company’s expense. All Directors have 
access to the advice and services of the 
Company Secretary.

Roles and responsibilities table
Name

Role

Responsibility

Chair

Robin 
Freestone

•  leading the Board with integrity and ensuring its effectiveness in all aspects of its role;

•  promoting the highest standards of corporate governance;

•  promoting diversity and inclusion;

•  facilitating effective contribution of Non-Executive Directors and encouraging active 
engagement by all Directors, with the appropriate level of challenge by all Directors;

•  ensuring the Board receives accurate, timely and clear information and is consulted 

on all matters important to it;

•  ensuring the Board considers the interests of stakeholders and reviews mechanisms 

for engagement with stakeholders; and

•  ensuring the Company maintains effective communication with shareholders and 

communicating their views to the Board.

CEO

Peter Duffy

•  leading the performance and management of the Group;

•  proposing strategies, business plans and policies to the Board;

•  ensuring effective implementation of the Board’s decisions;

•  maintaining an effective framework of internal controls and risk management; and

•  leading, motivating and monitoring performance of the Company’s Executive management, 

and focusing on succession planning for the Executive management.

CFO

Scilla Grimble

•  supporting the CEO in developing and implementing strategy;

•  overseeing the day-to-day financial activities of the Group; 

•  deputising for the CEO as required; and

•  together with the CEO, ensuring that policies and practices set by the Board are adopted 

at all levels of the Group.

Senior 
Independent 
Director

Caroline 
Britton

•  meeting with the Company’s shareholders and representative bodies when requested and, 

if necessary, discussing matters with them where it would be inappropriate for those 
discussions to take place with either the Chair or the CEO;

•  acting as a sounding board for the Chair and as an intermediary for the other Directors 

when necessary; and

•  leading the annual appraisal and review of the Chair’s performance.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

77

GovernanceCorporate Governance Statement continued

Division of responsibilities continued

Roles and responsibilities table continued

Role

Name

Responsibility

Non-
Executive 
Directors

Non-
Executive 
Director 
Employee 
Champion

Caroline 
Britton

•  bringing external perspective, independent judgement and objectivity to the Board’s 

deliberations and decision making; 

Lesley Jones

•  constructively challenging the Executive Directors and senior management team 

Supriya Uchil

Sarah Warby

Rakesh Sharma

Sarah Warby

(Rakesh 
Sharma 
appointed on 
17 January 2023)

and helping develop proposals on strategy; and

•  chairing Committees in their area of expertise as appropriate.

•  helping the Board to establish what channels of engagement are appropriate, in order 
to gather and bring the views and experiences of the workforce into the Boardroom;

•  working with the Board to take appropriate steps to evaluate, and where possible mitigate, 

the impact that the Board’s proposals and decisions may have on the workforce;

•  challenging the Executive Directors, when required, as to the way in which workforce 

engagement is undertaken and the steps to be taken to address workforce concerns arising 
out of business-as-usual activities; and

•  giving feedback to employees, where appropriate, on steps taken to address their concerns 

or explain why particular steps have not been taken.

Non-
Executive 
Consumer 
Champion 

Sarah Warby 
(appointed 
17 January 2023)

•  ensuring that the Consumer Duty is discussed in a meaningful way regularly and raised 

in all relevant discussions;

•  representing the interests of consumers in Board discussions and decision making, 

challenging as appropriate; and

•  working with the Board to take appropriate steps to evaluate, and where possible mitigate, 

the impact that the Board’s proposals and decisions may have on consumers.

General 
Counsel and 
Company 
Secretary

Shazadi Stinton

•  providing comprehensive legal support to the Board and individual Directors;

•  managing the provision of timely, accurate and considered information to the Board;

•  recommending corporate governance policies and practices to the Chair and CEO; and

•  advising the Board and its Committees on corporate governance and compliance within 

the Group and appropriate procedures for the management of their meetings and duties.

78

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Moneysupermarket.com Group PLC

Risk management and 
internal control
The Board has overall responsibility for 
setting the risk appetite of the Group, 
maintaining the Group’s risk management 
and internal control system and reviewing 
the system’s effectiveness. We have an 
ongoing process for identifying, evaluating 
and managing the principal risks faced by 
the Group which has been in place for the 
year under review and up to the date of 
approval of the Annual Report. The Risk 
and Sustainability Committee and the 
Audit Committee assist us in discharging 
these duties.

A description of the process for managing 
risk, together with a description of the 
emerging and principal risks and strategies 
to mitigate those risks, is provided on 
pages 62 to 67.

The main features of the Group’s risk 
management and internal controls in 
respect of financial reporting and the 
preparation of accounts are:

•  a comprehensive annual business 
planning and budgeting process, 
requiring Board approval, through 
which risks are identified and appraised;

•  a comprehensive financial reporting 
system, regularly enhanced, within 
which actual and forecast results are 
compared with approved budgets and 
the previous year’s figures on a monthly 
basis and reviewed by the Board;

•  a review of Group policies relating to 

the maintenance of accounting records, 
transaction reporting and key financial 
control procedures;

•  an investment evaluation procedure to 
ensure an appropriate level of approval 
for all capital expenditure and other 
capitalised costs;

•  monthly finance team meetings which 
include reviews of internal financial 
reporting and financial control 
monitoring; and

•  ongoing training and development 
of financial reporting employees.

Other controls in place to manage our 
business in accordance with our Group 
Risk Framework include:

•  an annual strategy meeting to discuss 
and approve the Group’s strategic 
direction, plans and objectives and 
the challenges to achieving them;

•  a schedule of matters reserved for 
approval by the Board to ensure it 
maintains control over appropriate 
strategic, financial, organisational, 
compliance and capital investment issues;

•  an organisational governance structure 

with clearly defined lines of responsibility 
and delegation of authority;

•  a formal risk management framework 

with supporting policies and 
procedure manuals;

•  regular reviews of the principal risks 
facing the Group to ensure they are 
being identified, evaluated and 
appropriately managed;

•  a process for regular assessment of the 
effectiveness of key internal controls 
across the Group;

•  a Risk and Compliance function 
responsible for overseeing the 
implementation of the Group 
Risk Framework;

•  an Internal Audit function providing 
assurance over key risks, processes 
and controls; and

•  a whistleblowing hotline which 

employees can use to report any 
instances of suspected wrongdoing.

Our internal control effectiveness is 
assessed through the performance of 
regular checks, which in 2022 included 
the following areas:

•  reviewing and testing the Group’s 
financial reporting processes;

•  completion of the Group’s Internal 

Audit plan;

•  performing risk business partnering and 
monitoring activities including financial 
promotion reviews and call listening;

•  assessment of the identification and 

management of risks connected to the 
Group’s capital investment programme;

•  assessment of the Group’s processes 
for identifying and mitigating potential 
conflicts of interest;

•  assessment of the identification and 

management of technology risks across 
the Group, including cyber risk, data 
security and change management; and

•  monitoring the completion of the 

Group’s mandatory "Introduction to 
Regulation", data protection, cyber 
security and Code of Conduct training 
for new starters and refresher training 
for all employees.

Risk review and assessment
The Group’s systems and procedures 
are designed to identify and manage and, 
where practicable, reduce and mitigate 
the risk of failing to achieve the Group’s 
objectives. They are not designed to 
eliminate such risk, but the Group seeks 
to understand its key risks and manage 
them within our risk appetite.

Twice a year the Group’s principal risks and 
the Group Risk Framework and Statement 
are reviewed by the Board. During these 
reviews, the Board takes account of the 
significance of any environmental, social 
and governance matters to the business of 
the Group, ensuring any related risks and 
associated mitigation have been identified.

The risk register is a key element in our 
risk management framework and is used 
in the assessment and reporting of key 
risks being managed by the Group. Senior 
management works alongside the Risk and 
Compliance function to ensure the risk 
register incorporates any new risks and 
movements in risks. The risk register is 
managed by the Risk and Compliance 
function; risks and internal controls are 
owned by a member of the Executive 
Team who is responsible for the ongoing 
effectiveness assessment and the delivery 
of mitigating actions. Robust risk and 
control assessments are regularly carried 
out across all areas of the business, in 
order to understand the strength and 
performance of the controls in place, 
and potential gaps and weaknesses. 
The results of risk register assessments, 
together with risks identified through 
other tools within our risk management 
framework, including findings from Internal 
Audit and Risk and Compliance monitoring, 
are reviewed on a regular basis by the Risk 
and Sustainability Committee.

The Risk and Compliance function provides 
challenge to the Executive Team in its 
assessment and management of risks with 
particular focus on the actions being taken 
to reduce risk. Reporting to the Executive 
Team and Risk and Sustainability 
Committee provides clear visibility of the 
most significant risks, identifies areas of 
concern and/or priority, analyses root 
cause and identifies underlying trends. 
Reporting to the Risk and Sustainability 
Committee enables the Directors to have 
clear visibility of the most significant risks; 
identify areas of concern and/or priority; 
and ensure actions to potentially mitigate 
the impact of new risks are taken in a 
timely manner. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

79

GovernanceCorporate Governance Statement continued

Risk review and assessment 
continued
Process for review of effectiveness

The Risk and Sustainability Committee is 
responsible for reviewing the effectiveness 
of the systems of internal controls. The steps 
it takes in relation to the review are set out 
on page 95. The Risk and Sustainability 
Committee makes a recommendation to the 
Board on effectiveness, which the Board 
considers in forming its own view on the 
effectiveness of the risk management 
and internal control systems. 

During 2022, the Chief Risk Officer was 
promoted to the Executive Team, reflecting 
the importance of internal control and risk 
management processes to the Group. A 
review of the effectiveness of the Group’s 
risk management and internal control 
systems was undertaken in 2022. We 
confirm that the processes outlined on 
page 95 have been in place for the year 
under review and up to the date of 
approval of this Annual Report, and that 
these processes accord with the Code and 
the FRC Guidance on Risk Management, 
Internal Control and Related Financial and 
Business Reporting (September 2016 
version). We have strengthened and 
expect to continue to embed enhanced 
controls in respect of cyber security and 
data privacy. A summary of actions we 
have taken in 2022 is set out in the Risk 
and Sustainability Committee Report on 
pages 94 to 96. The Board has carried out 
a robust assessment of the emerging and 
principal risks facing the Group, including 
those that would threaten its business 
model, future performance, solvency or 
liquidity and these, together with how they 
are managed or mitigated, are set out on 
pages 62 to 67.

Composition, succession 
and evaluation
Board composition and appointments

Our Board comprises the Chair (who 
was independent on appointment), five 
Independent Non-Executive Directors and 
two Executive Directors. The details of 
their career background, relevant skills, 
Committee membership, tenure and 
external appointments are set out on 
pages 70 and 71. Further details on the 
role of the Chair and members of the 
Board can be found on pages 77 and 78. 
The Chair, Senior Independent Director 
and Non-Executive Directors are 
appointed for a three-year term, subject 
to annual re-election by shareholders 
following consideration of the annual 
Board effectiveness evaluation. The 

composition of our Board continued 
to be an area of focus this year for the 
Nomination Committee to ensure that it 
retains the necessary balance of skills, 
experience and independence, in 
accordance with the Board Diversity Policy, 
the statement for which is detailed in the 
Nomination Committee Report. Any new 
appointments to the Board result from 
a formal, rigorous and transparent 
procedure, responsibility for which is 
delegated to the Nomination Committee, 
although decisions on appointment are 
a matter reserved for the Board. Further 
information on the work of the Nomination 
Committee is on pages 85 to 88.

During 2022, the Board and Nomination 
Committee have fully considered Board 
succession to ensure that the Board has 
the right mix of skills and experience, 
as well as the capability to provide 
constructive challenge and promote 
diversity. Additional detail can be found 
within the Nomination Committee Report 
on pages 85 to 88.

Board induction and training 

We develop a detailed, tailored induction 
for each new Non-Executive Director. This 
includes one-to-one meetings with the 
Chair and each of the existing Non-
Executive Directors. They have one-to-one 
meetings with the CEO, the CFO and the 
Company Secretary along with other 
members of senior management. New 
appointees to the Board would meet with 
members of the operational team and visit 
our three offices in London, Manchester 
and Ewloe as part of the annual Board 
meeting cycle. New Directors receive a 
briefing on the key duties of being a 
Director of a listed company as well as the 
requirements of the SM&CR. We regularly 
review the induction programme, building 
in feedback from new appointees and 
the internal and external Board 
effectiveness evaluations. 

Whilst our induction plans can take up to 
a year to fully complete, Rakesh Sharma 
joined the Board in October 2022 and 
executed his tailored plan in good order, 
meeting with senior management 
promptly and attending meetings and 
colleague events at both our London and 
Ewloe offices by the end of December 2022. 

Directors are continually updated on the 
Group’s business, the markets in which we 
operate and changes to the competitive 
and regulatory environments through 
presentations and briefings to the Board 
from Executive Directors and senior 
management. The Company Secretary 

also maintains a record of the Board’s 
collective training plan, the 2023 plan 
having been approved by the Board in 
January 2023. 

Directors received briefings from the 
Company Secretary during 2022 on 
governance and compliance matters 
and relevant legislative changes. The Board 
was also provided with training materials 
on digital markets and regulatory and 
competition law developments for 
UK-based providers and operators. 
Training was also provided on 
environmental regulations and diversity 
and inclusion. In addition, individual 
Directors receive tailored training where 
beneficial or required in order for them 
to adequately discharge their duties. 

To ensure that Directors are able to fully 
acquaint themselves with current trading 
and matters requiring discussions and 
decisions, comprehensive Board papers 
and Committee papers are circulated 
electronically approximately one week 
prior to scheduled meetings.

The Directors also have available to them 
a regularly updated electronic "Resource 
Centre" acting as a Board manual which 
includes extensive information including 
financial and analyst reports, current 
and historical regulatory publications, 
Group codes and policies, organisational 
structure documentation, and 
information on Directors’ duties.

Directors may, in the furtherance of their 
duties, take independent professional 
advice at the Company’s expense.

Directors’ skills and experience

An effective Board requires the right mix 
of skills and experience. Our Board is a 
diverse and effective team focused on 
promoting the long-term success of the 
Group. The Board skills and experience 
matrix below details some of the key skills 
and experience that our Board has 
identified as particularly valuable to the 
effective oversight of the Company and 
execution of our strategy. We plan to 
evolve our Board Skills Matrix criteria and 
assessment process in 2023 to keep pace 
with best practice. For further details on 
our Board Skills Matrix and process, please 
see our Nomination Committee Report on 
pages 85 to 88.

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Moneysupermarket.com Group PLC

Board evaluation

Individual Director evaluations

The annual Board evaluation provides 
the Board and its Committees with an 
opportunity to consider and reflect on 
the quality and effectiveness of its 
decision making, and the range and level 
of discussions, and for each member 
to consider their own contribution and 
performance. For further information 
please see our Nomination Committee 
Report on pages 85 to 88. 

In 2022, each of the Directors was 
appraised individually in the form of 
an interview with the Chair, taking into 
account feedback received as part of the 
Board evaluation process. Following these 
discussions, the Chair has confirmed that 
each Director continues to make a valuable 
contribution to the Board and devotes 
sufficient time to their role. 

The Chair’s evaluation was undertaken 
by the Senior Independent Director, 
taking into account the views of the other 
Directors obtained as part of the Board 
evaluation. The Senior Independent 
Director provided feedback to the Chair 
at a dedicated feedback meeting. 

Board, Committee and Directors’ effectiveness evaluation cycle 

Year 1

Year 2

Year 3

Internal effectiveness 
evaluation conducted 
by the Chair (2021)

Internal effectiveness 
evaluation conducted 
by the Chair (2022)

Externally facilitated 
evaluation process 
conducted by third 
party (2023)

2022 effectiveness evaluation: process

During 2022, the Board conducted an 
internal evaluation of the performance of 
the Board and the Committees, the Chair 
and individual Directors, taking into 
account the principles and provisions of 
the Code. The Chair approved detailed 
questionnaires which were completed 
anonymously by individual Directors and 
Executive members. Members of the wider 
Executive Team were invited to complete 
questionnaires on the performance of the 
Committees which they regularly attended. 
The results were then collated and 

analysed by Company Secretariat and 
presented with proposed actions. The 
results and actions of the Board and 
Committee evaluation were scrutinised 
by the Chair, following which they were 
submitted for discussion at the October 
Board meeting and an action plan approved.

The review of the Chair’s effectiveness was 
conducted by the Senior Independent 
Director, who met individually with Board 
members to garner feedback against 
agreed criteria. The results were discussed 
at the October Board meeting without the 

Chair present and then fed back by the 
Senior Independent Director outside 
of the meeting.

The Chair met with individual Directors 
during December 2022 to discuss their 
performance against agreed criteria, 
following which the Board’s collective 
training plan was approved in January 2023. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

81

GovernanceCorporate Governance Statement continued

Composition, succession 
and evaluation continued
2022 effectiveness evaluation: 
outcome and actions

The Directors’ many positive responses 
indicated their widely held view that the 
Board worked effectively as a team, with 
strong ratings received for the Board’s 
oversight of the Group’s risk framework 
and investments in strategic initiatives. 
Members considered that they understood 
the views and requirements of the Group’s 
customers and were well supported by both 
management and Company Secretariat. 

Overall, the Committees were considered 
to be very well run, with the Audit 
Committee being praised in particular for 
the time the Chair took to ensure members 
fully understood both the content for 
discussion and their responsibilities in 
relation to it. The Remuneration 
Committee members noted that further 
stability would be achieved once the newly 
appointed Independent Non-Executive 
Director, Rakesh Sharma, had received 
regulatory approval and been formally 
appointed as Chair. 

The Chair’s performance was highly 
rated by all Board members, and it was 
concluded that he was effective at chairing 
meetings and steering discussions without 
stifling contributions, and brought both 
pragmatic and thoughtful guidance and 
leadership to the Board and to individual 
Directors. 

Upon completion of the individual Director 
evaluations, it was confirmed that each 
Director continued to be committed to 
their roles and have sufficient time to 
perform their duties effectively and 
therefore, should be proposed for 
re-election at the 2023 AGM with the 
exception of Scilla Grimble, who is stepping 
down on 17 February 2023 and Supriya 
Uchil, who resigned on 17 January 2023 
and is stepping down on 30 April 2023.

Some of the focus areas for enhancement 
in 2023 are:

•  a more proactive approach to the 

Group’s succession planning and talent 
management, including incorporating a 
focus on diversity of experience and the 
consideration of the Chair’s succession 
as he will reach the Code’s nine-year 
tenure limit in August 2024; 

•  the establishment of a Board 

Sponsorship Programme whereby 
members mentor/sponsor individuals 
within the Senior Leadership Team in 
their development; 

•  a more structured and detailed Board 
training plan to be implemented, with 
dedicated sessions at least four times 
during 2023; and

•  the development and implementation 
of a stakeholder engagement strategy 
to ensure the appropriate type, level 
and frequency of engagement with 
each stakeholder.

Progress against the 2021 evaluation action plan

The Board also reviewed its progress against actions identified in the internally facilitated 2021 Board evaluation.

An update on progress against these actions during 2022 is set out below:

Action item

Our progress

Stakeholder engagement 

To increase the Board’s visibility of key 
stakeholder groups and their feedback 
and to develop a more proactive 
approach to engagement. 

Culture

Further articulation of the Group’s culture 
and values to ensure clarity across all levels 
of the organisation.

Talent and succession planning 

To ensure a healthy pipeline of talent 
throughout the Executive and Senior 
Leadership Teams. 

The Board and Committee reporting templates were updated in Q4 2022 to ensure 
that paper writers considered the impact of proposals upon relevant stakeholder 
groups and this information considered within the decision-making processes. A 
stakeholder engagement strategy is being developed and will be approved by the 
Board in Q1 2023. In addition, the Executive Team has presented its vertical provider 
feedback questionnaire results to the Board directly during 2022, increasing its 
accountability for performance. Please see our Section 172 Statement on pages 29 
to 35 for further engagement activity during 2022. 

The Senior Leadership Team developed a set of leadership behaviours underneath the 
key pillars of Leading with Simplicity, Innovation, Inclusion and Accountability and were 
tasked with rolling these out within their respective teams. The Group’s floor briefs 
have been enhanced to encourage participation and knowledge sharing across all 
levels of the business and offer colleagues the opportunity to submit questions 
directly and anonymously to the CEO to increase accountability. The Board is provided 
with feedback on culture via colleague surveys and NED breakfasts as well as via the 
designated NED Employee Champion. 

The Board re-baselined the Group’s succession plans following restructuring within 
the Executive and Senior Leadership Teams. A new Head of Talent Acquisition role 
was incepted to support recruitment practices.

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Employee Champion Report

Employee Voice 
in the Boardroom

2022 has seen the role of the Employee 
Champion inform Board discussions 
in changing times. 

Sarah Warby
NED Employee Champion

G
o
v
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n
a
n
c
e

As Employee Champion, I am pleased to 
report on the progress that we have made 
this year on bringing our employee voice to 
the Boardroom.

As a Group, we have a desire to genuinely 
engage with employee views and recognise 
the benefits that such engagement can 
bring. Our employees are our most 
important asset and we recognise that it’s 
vital for our Board members to hear the 
concerns and ideas of our employees and 
are able to consider these as they relate to 
Company culture and strategy.

Role of the Employee 
Champion
I was appointed the designated NED 
Employee Champion in 2018, with a remit 
to draw on my experience of bringing 
stakeholder voices into the Boardroom 
gained through a career in customer-
focused roles. I am pleased to report that I 
was reappointed to this role by our Board 
in September 2022. Having a designated 
NED appointed as Employee Champion 
ensures that we have a visible and 

approachable conduit between our 
employees and our Directors and provides 
a mechanism for the Board to connect 
directly with employees, and for the 
employee voice to be considered in 
Board discussions. 

Having been in the role now for a number 
of years, I have established strong 
connections with our network of employee 
resource groups, and am a familiar face in 
our offices. This has helped to create a 
culture of openness and ensures that I am 
in a strong position to bring an honest 
employee voice to the Boardroom. I am also 
the NED accountable for whistleblowing. 

To ensure there is space and opportunity 
for employee opinions to be voiced, we 
include a standing agenda item for 
employee engagement at the beginning of 
every Board meeting. Not only does this 
allow us to raise discussion topics which 
come from employees, it also draws focus 
onto the voice of our employees early in the 
agenda, setting the tone for the meeting. 

In the last 12 months, we have 
consolidated our ways of working and 

inducted several new NEDs into a regular 
calendar of activity. My duties include 
discussions with the Employee Resource 
Groups, and members of the People Team, 
while all our NEDs plug-in and connect 
with employees in their relevant disciplines 
and through our employee/NED breakfasts. 
This role will continue to evolve and as a 
Group we continue to see the value that 
this role adds to the Group, most notably 
this year in informing our views on hybrid 
working, understanding employee 
sentiment in our different locations, 
challenging management in a variety of 
diversity and inclusion discussions and 
understanding the capacity and capability 
in the organisation for change.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

83

Employee Champion Report continued

Activities in 2022
It has been great to be able to run some 
face-to-face engagement sessions again this 
year, alongside the virtual sessions that we 
have grown used to. These have included: 

NED breakfasts: Along with my fellow 
NEDs, we have held interactive "NED 
breakfasts" throughout the year. These are 
held in each of our core office locations to 
ensure that the employee voice reflects 
the geography and demographics of our 
employee population. These sessions 
incorporate a mix of specific discussion 
topics and open dialogue to ensure that 
we capture the general sentiment, 
alongside the views on specific issues. 
Participants in these meetings have 
reported that they liked the intimate 
structure and the freedom to explore a 
variety of topics that they feel passionate 
about. Topics discussed during these 
events have included innovation, 
leadership, hybrid working, strategy, 
employee engagement, gender/ethnicity 
pay gap reporting, wellbeing, recruitment 
and pace of implementation.

Employee engagement surveys: These 
provide for regular and structured input 
from our employees, especially during 
periods of change. I discuss the results 
with our Chief People Officer to see how 
we can act on the insights received. 
See pages 44 to 47 for further detail. 

Employee Resource Groups: ERGs are 
voluntary, colleague-led self-managed 
groups that connect those who share 
common challenges, interests and 
experiences. The aim of the ERGs is to act 
as an open forum to meet and support 
one another in creatively addressing our 
internal inclusion challenges and champion 
colleague voice. I meet with representatives 
from our ERGs twice a year to gain an 
understanding of their views and any 
concerns they have. See pages 44 to 47 
for further detail. 

Ad-hoc engagement: Throughout the 
year, NEDs meet with colleagues around 
the business on an ad hoc basis. They have 
joined the monthly floor briefs given by the 
CEO and they have had individual or small 
group meetings to share experience in 
their relevant field (e.g. Supriya Uchil 
meets with members of the Product teams 
frequently; similarly Caroline Britton has 
met with members of the Finance function). 
See pages 29 to 35 for further details on 
how the Board has engaged with our 
stakeholder groups. 

Key outcomes
Much of the insight that our direct 
connection with colleagues gives us serves 
to inform Board discussions, by bringing 
the decisions we make to life. Having a 
clear colleague voice in the room generally 
informs how we approach discussions 
and often influences how we guide 
management to implement activity. 
During 2022, the key issues raised 
by our employees have been:

Embracing hybrid working 

Our employees gave us clear insight about 
the pros and cons of hybrid working, 
helpfully bringing to life the challenges and 
opportunities it presents. This feedback 
allowed the Board to work with 
management to agree the approach and 
expectations as MSMG moved into a new 
definition of normal working practices. 
As a result, the new ways of working have 
landed and are being used to good effect 
across the Group.

Strategy to implementation 

Our employees’ passion and energy has 
been a key theme in our engagement this 
year. The feedback we have received has 
highlighted how much progress has been 
made, making many employees feel 
empowered and able to push the 
innovation agenda further. Feedback over 
the year showed us that capacity for 

implementation clearly varied across 
different functions, with some areas 
concerned about being able to keep up 
while others were keen to forge ahead. This 
feedback informed our Board discussions 
around quarterly milestones, recruitment 
and also strategy development.

Focus areas for 2023
Whilst I have enjoyed my time as Employee 
Champion immensely, it was agreed on 
17 January 2023 that I be appointed as 
the Group's Consumer Champion and that 
I would therefore need to relinquish the 
role. I have handed over the responsibility 
to Rakesh Sharma, who having recently 
joined the Board, will bring a fresh 
perspective and I've no doubt there will 
be synergies between this and his role 
as Remuneration Committee Chair. 

A full programme of meetings has been 
planned for the coming year. Our focus 
areas will include: colleagues’ 
understanding and commitment to 
strategy, leadership impact, colleague 
wellbeing, implementation pace, 
integration of new businesses and 
confidence in management.

As part of a wider review of our Group’s 
stakeholder engagement strategy, we are 
also considering alternative engagement 
methods as a way to keep the energy up 
and the conversation with employees 
fresh and pertinent.

Sarah Warby
NED Employee Champion
15 February 2023

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Nomination Committee Report

Resourcing for 
sustainable success

G
o
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n
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c
e

The Nomination Committee is 
responsible for ensuring the Group’s 
leadership is well constituted, 
inclusive and reflective of 
our strategic requirements.

Robin Freestone
Chair of the Nomination Committee

As Chair of the Nomination Committee, 
I am pleased to present the Nomination 
Committee’s Report for the year ended 
31 December 2022. I have set out below 
our role and activities in reviewing the 
Board’s size, structure and composition, 
including the recommendation of 
appointment of a new Non-Executive 
Director, reviewing succession and 
development plans for the Board and 
Executive management, and overseeing 
the Group’s diversity and inclusion strategy.

The Committee is comprised of all 
Independent Non-Executive Directors, 
with the exception of myself as Chair 
of the Board (I was independent on 
appointment). Only members of the 
Committee have the right to attend 
Committee meetings. Other individuals 
such as the CEO, the Chief People Officer, 
senior management and external advisers 
may be invited to attend meetings as and 
when appropriate. The Committee 
membership was refreshed in 2022, 

following Sally James stepping down post 
our AGM on 5 May 2022, the resignation 
of James Bilefield on 31 May 2022 and 
the appointment of Rakesh Sharma on 
3 October 2022. For full details of the 
Committee’s membership and attendance 
during 2022, please see page 74.

Role and responsibilities
The Nomination Committee plays a key 
role supporting the Board within the 
governance framework in reviewing the 
composition of the Board and its 
Committees. This includes an assessment 
of whether the balance of skills, 
experience, knowledge and independence 
of the Board is appropriate to enable it to 
operate effectively. The Committee also 
assisted the Board in its consideration of 
conflicts of interest and independence 
issues. No conflicts of interest or 
independence issues were identified 
as a result of this activity.

The Board supports the recommendations 
of the Hampton-Alexander Review on 
gender diversity and the Parker Review on 
ethnic diversity. The Board has achieved 
the minimum recommended composition; 
this currently stands at five female 
Directors (62.5%) and includes two 
Non-Executive Directors from ethnic 
minority backgrounds (however this will 
change following the stepping down of 
Supriya Uchil as Non-Executive Director 
on 30 April 2023).

The Committee has an annual schedule 
of work, developed from its Terms of 
Reference (available on our website at 
https://corporate.moneysupermarket.
com), with standing items that it considers 
at each meeting, in addition to any specific 
matters upon which the Committee has 
decided to focus. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

85

Nomination Committee Report continued

Role and responsibilities continued

Committee activities in 2022

Committee priorities for 2023 

Conducted a search for, considered and recommended to the 
Board the appointment of a Chief Financial Officer and Non-
Executive Director.

Oversee the effective handover of the Chief Financial Officer 
position from Scilla Grimble to Niall McBride, including relevant 
induction and training. 

Continued to review talent within the Group, with an increased 
focus on succession planning and development at the level below 
Executive management.

Reviewed the composition of the Board, including the balance 
of skills, knowledge and experience, taking into account the 
experience and understanding of our stakeholder groups.

Develop and progress a plan for the succession of the Chair, 
including job description and the commencement of recruitment.

Recruit and induct a Non-Executive Director following the 
stepping down of Supriya Uchil on 30 April 2023. 

Reviewed progress made against the Board Diversity Policy, 
including a target of 33% female representation and a target of 
one Director from an ethnic minority background by 2024.

Continue to support management in navigating the challenging 
market environment to successfully recruit and retain women 
within the Group’s tech teams. 

Considered the ongoing contribution of each Board Director, 
including their time commitments, and recommended to the Board 
the re-election of all Directors at the 2022 Annual General Meeting.

Oversee the commencement of planning in relation to the 
Group's medium-term ambition of offering a graduate 
programme.

Reviewed the Group’s Conflicts of Interest Policy and process and 
the Register of Directors’ Conflicts of Interest.

Oversee the strengthening of the Group’s succession plans 
in relation to the Executive and Executive -1 populations. 

Reviewed the Group’s diversity and inclusion strategy.

Monitor progress against the newly appointed Non-Executive 
Directors' inductions. 

Reviewed the size, structure and composition of the Board 
and its Committees.

Board composition 
The Board supports the recommendations 
of the FTSE Women Leaders Review and 
Hampton-Alexander Review on gender 
diversity, and the Parker Review on ethnic 
diversity. The Board has achieved the 
recommended composition and is 
committed to maintaining at least 33% 
female Board membership and a minimum 
of one Director from an ethnic minority. At 
the same time, the Nomination Committee 
will keep under review and evaluate, on 
behalf of the Board, its balance to ensure 
that it has the appropriate mix of skills, 
experience, independence and knowledge 
to ensure their continued effectiveness.

As at the review date of this statement, the 
Board had a total of eight Directors. The 
skill set of the Non-Executive Directors 
includes financial, economic, financial 
services, banking, digital, technology, 
communications and consumer expertise.

All appointments to the Board will be made 
on merit and against objective criteria. The 
process will take into account suitability for 
the role, the Board composition, its 
balance and the required mix of skills, 
background and experience, including a 
consideration of all aspects of diversity. 
Other relevant matters will also be taken 
into account, such as independence, 
subject matter knowledge and the ability 

to fulfil required time commitments. 
Combined, this will form part of the role 
specification for all Board recruitment.

Prior to making any recommendations for 
appointment to the Board, the Nomination 
Committee will consider suitably qualified 
candidates for Non-Executive Director 
roles from as wide a pool as appropriate 
and whose skills and experience will add 
value to the Board.

The Nomination Committee will work 
with executive search consultants who 
understand and agree with the Group’s 
approach to diversity and inclusion, 
including this Board Diversity Statement, 
and will consistently apply it when identifying 
and proposing suitable candidates.

Board skills matrix
The below diagram indicates those skills which Board members are both very competent and experienced in. 

Caroline 
Britton

Peter 
Duffy

Robin 
Freestone

Scilla 
Grimble

Rakesh 
Sharma

Lesley 
Jones

Sarah 
Warby

Supriya 
Uchil

Banking/insurance industry experience

Digital/customer experience (front office)

Finance and accounting

International experience

Governance

Risk and regulation

Technology (back office)

Marketing

Strategy

Tenure (MM/YY)

09/19

09/20

08/15

02/19

10/22

09/21

06/18

03/20

86

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Moneysupermarket.com Group PLC

Board effectiveness evaluation
An internal Board, Committee and 
Individual Director evaluation was 
conducted in October 2022, full details 
of which are available on pages 80 to 82.

Succession planning 
The Group’s Succession planning is a 
continual cycle of activity and as part of 
this the Committee reviewed succession 
plans for our Executive and Senior 
Leadership Teams. The Executive 
summarised their performance and 
development areas, identifying whether 
there was internal talent able to fulfil 
the role immediately, within two years, or 
whether alternative resourcing would occur.

This included information pertaining to 
each individual’s current performance and 
future potential. 

The Committee considered the tenure of 
each of the Directors and noted that the 
Chair would be the next member to rotate 
off the Board in summer 2024. Our Senior 
Independent Director will commence the 
process of seeking a new Chair by 
discussing with each Non-Executive 
Director the position and potential 
requirements for the job description in 
spring 2023. The Senior Independent 
Director will then prepare a plan for the 
Committee’s consideration in May 2023. 

The Committee will recruit a new Non-
Executive Director in early 2023 to replace 
Supriya Uchil who will step down following 
the conclusion of the AGM on 4 May 2023.

Talent development
We recognise the importance of 
developing our people and, as such, the 
talent pipeline within our business remains 
a key focus for the Committee. Our senior 
leadership population is a source of future 
Executive talent, with two members of our 
Executive Team, Matt Whittle and Mike 
Philips, progressing through this route. Our 
LEAD Programme, launched in April 2020, 
is one of the key investments we are 
making into developing senior leadership 
over the next two to three years. LEAD is 
a 12–18-month programme, resulting in 
each participant gaining the CMI Level 5 
Qualification in Management and Leadership.

Diversity and inclusion
As described earlier in this report, the 
Board and Committee continue to drive 
the agenda of diversity and inclusion 
across the Group and are proud of the 
progress made, especially in respect of 
female representation on the Board 
and Executive Team of 62.5% and 44% 
respectively. A breakdown by gender of the 
number of persons who were Directors of 
the Company, senior managers (as defined 
in the 2018 Code and Companies Act 
2006), and other employees is set out later 
in this report. To reflect the Group’s 
continued focus on this area, diversity and 
inclusion, including progress against our 
diversity strategy, has been added as a 
standing agenda item for all Nomination 
Committee meetings.

The Board’s Statement on Diversity is 
as follows: “The Board recognises the 
importance of diversity in its broadest 
sense as one of the key drivers of Board 
effectiveness. Diversity encompasses 
diversity of perspective, insight, 
experience, educational and professional 
background, and personal demographics 
such gender identity, race and ethnicity, 
age, disability, neurodiversity, social 
mobility and sexual orientation.

Diverse membership of the Board 
supports better decision making and 
reduces the risk of groupthink by providing 
different viewpoints, ideas and challenges."

The Committee received an update on the 
Group’s partnership with Vessy.com in 
October 2022. Vessy is conducting an audit 
of our approach and offerings and will 
work with us to build our diversity strategy 
for 2023 and beyond. Vessy Tasheva is 
a thought leader in diversity, equity, 
inclusion and belonging, with a networked 
team of experts and resources. We have 
also appointed a talent and inclusion 
partner to further our organisational 
awareness and learning in this area. 
For further information on the Group’s 
Inclusion and Diversity Strategy "Create 
Belonging", please see pages 44 to 47.

The Committee discussed the employee 
survey results in relation to diversity and 
inclusion, noting that they remained 
strong, with a 77% favourable score which 
was in line with benchmarks within the UK 
technology sector and ahead of that within 
the financial services sector. 

The Board's diversity and inclusion 
objective during 2022 was to improve our 
approach to how we attract and source 
talent with a focus on delivering real 
change in our diversity mix. This has 
been achieved by: 

•  broadening our approach to 

Neurodiversity and Family Health within 
the workplace. We achieved this by 
launching guidelines, conducting 
audits by "Dyslexia Box" plus multiple 
other initiatives;

•  designing a Technology Apprenticeship 

Scheme for young and underrepresented 
talent to fill junior tech roles within the 
Group. We have also delivered against a 
Group-wide inclusive language learning 
programme; and

•  making net positive improvements in the 
multi-ethnic representation across the 
Group to better reflect our customers. 
Whilst we did not achieve our metric, 
lots of work was undertaken in this area, 
with an average of 21% of Group hires 
being from multi-ethnic backgrounds 
in 2022.

Supporting racial equity
The Group has been an official signatory 
of the Race at Work Charter since 2020, 
a public commitment to prioritising action 
on race equity, as part of the Group’s Race 
Equity Plan. The Charter requires us to 
have in place five things:

•  an appointed Executive Sponsor for race;

•  the capturing of our ethnicity data 
and publicising of our progress;

•  a Board-level commitment to zero 

tolerance of bullying and harassment;

•  that equity, diversity and inclusion are 

made the responsibility of all our leaders 
and managers; and 

•  actions that support Black, Asian, 

mixed race and other ethnically diverse 
employee career progression.

The Board has committed that all allegations 
of racial bullying or harassment will be taken 
seriously, and managed consistently and 
in line with the Group’s Anti-Bullying and 
Harassment Policy, with formal action taken 
where necessary. Any material grievances 
will be reported to the Audit Committee via 
the whistleblowing report.

We are dedicated to continuing the 
progress we have made under the five 
principles of the 2020 Charter and are 
pleased to reconfirm our commitment 
to these principles.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

87

GovernanceNomination Committee Report continued

Board appointments 
The Nomination Committee has a formal, 
rigorous and transparent procedure for 
the appointment of new Directors to the 
Board. When the need to appoint a 
Director is identified, we prepare a 
candidate profile indicating the skills, 
knowledge and experience required, 
taking into account the Board’s existing 
composition and the relevant experience 
and understanding of our stakeholder 
groups. We engage external executive 
search consultants and consider the 
gender, nationality, educational and 
professional background of candidates, as 
well as individual characteristics which will 
enhance diversity of thinking on the Board. 
Suitable candidates are interviewed by 
Committee members.

We give careful consideration to ensure 
proposed appointees have enough time 
available to devote to the role and that 
the balance of skills, knowledge and 
experience on the Board, with regard to 
experience and understanding of our 
stakeholder groups, is maintained. When 
the Nomination Committee has identified 
a suitable candidate, we then make a 
recommendation to the Board with the 
Board making the final decision.

We followed the procedure outlined above 
for the search for the our new Chief 
Financial Officer and Non-Executive 
Director, engaging Russell Reynolds 
Associates and Audeliss Limited as 
external executive search consultants for 
the respective appointments. Both Russell 
Reynolds Associates and Audeliss Limited 
are signatories to the Voluntary Code of 
Conduct for Executive Search Firms on 
gender diversity and best practice and 
have no other connection with the 
Company or individual Directors. Audeliss 
Limited is a market-leading firm 
specialising in the representation of LGBT+, 
ethnic minority and female candidates. The 
Committee briefed the search consultants 
on our diversity expectations, and we 
considered and interviewed a wide and 
diverse range of candidates for the roles. 
The Board was unanimous in its decision 
to appoint Niall McBride as Chief Financial 
Officer and Rakesh Sharma as a Non-
Executive Director. Following the 
appointment of Rakesh, the Board’s 
gender balance has been updated to 
62% female.

Gender diversity % as 
at 31 December 2022
Group employees

44%

Senior leadership – Group

49%

Board diversity % as 
at 31 December 2022
Gender split

62%

Ethnic minority background split

20%

Director conflicts 
and independence
The Committee conducted its annual review 
of individual Director conflict authorisation 
as recorded in the Conflicts of Interest 
Register in October 2022. Additionally, the 
Board and Committee consider conflicts of 
interest at every meeting.

The Conflicts of Interest Register sets out 
any actual or potential conflict of interest 
situations which a Director has disclosed 
to the Board in line with their statutory 
duties. When reviewing conflict 
authorisations, the Committee considers 
any other appointments held by the 
Director as well as the findings of the 
Board effectiveness review. Following the 
review, the Committee recommended to 
the Board that each conflict authorisation 
remained appropriate.

The independence of the Non-Executive 
Directors is formally reviewed annually 
by the Nomination Committee. The 
Nomination Committee and Board 
consider that there are no business or 
other circumstances that are likely to affect 
the independence of any Non-Executive 
Directors and that all Non-Executive 
Directors continue to demonstrate 
independence. In accordance with the 
2018 UK Corporate Governance Code, all 
of the eligible Directors will retire at this 

year’s AGM and submit themselves 
for appointment or reappointment by 
shareholders. Each of the Non-Executive 
Directors seeking reappointment are 
considered to be independent in 
judgement and character.

Time commitment 
The expected time commitment of the 
Chair and Non-Executive Directors is 
detailed within our letter of appointment, 
and is assessed, together with any existing 
external appointments, during the 
recruitment process. Time commitment is 
reviewed by the Committee on an annual 
basis and both the Committee and Board 
continue to consider that the Directors 
have sufficient time to undertake their 
roles effectively.

Nomination Committee 
effectiveness
In 2022, we carried out an internal 
evaluation of Nomination Committee 
effectiveness which involved the 
completion of a questionnaire, with the 
results being analysed and presented at the 
Board meeting in October. The Committee 
determined it continues to be effective in 
fulfilling its role and remains independent. 
In response to required actions identified in 
the 2022 evaluation, the Committee will 
continue to ensure that succession planning 
remains a key focus area.

Overview of Committee 
activities for 2023
Succession planning has been an area of 
focus for the Committee in 2022 and this 
will continue into 2023. As part of this 
process, the Nomination Committee will 
review the composition and tenure of the 
Board, including plans for me as I approach 
my ninth year of appointment on 1 August 
2024. The Committee will recruit and 
induct a Non-Executive Director following 
the stepping down of Supriya Uchil and 
review the talent pipeline within the 
business as part of its broader review 
of management succession planning.

This report was approved by the Board 
and signed on its behalf by:

Robin Freestone
Chair of the Nomination Committee
15 February 2023

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Audit Committee Report

Maintaining the Group’s 
financial integrity

G
o
v
e
r
n
a
n
c
e

The Committee has ensured the integrity and 
quality of the Group’s disclosures by providing 
objective, constructive challenge of management’s 
assumptions and independent oversight of its 
internal control environment.

Caroline Britton
Chair of the Audit Committee

On behalf of the Board, I am pleased to 
share the Audit Committee’s Report for the 
year ended 31 December 2022. I have set 
out our role and activities in ensuring 
appropriate challenge and governance 
around accounting treatment and the 
internal control environment and ensuring 
that the Annual Report as a whole is fair, 
balanced and understandable. 
Furthermore, I look forward to attending 
the AGM on 4 May 2023 to answer any 
questions on the work of the Committee. 

The Committee membership was 
refreshed in 2022, following Sally James 
stepping down post our AGM on 5 May 
2022, the resignation of James Bilefield 
on 31 May 2022 and the appointment of 
Rakesh Sharma on 3 October 2022. The 
Committee continues to comprise a wide 
range of business and financial experience, 
including competence relevant to the 
sector in which the Company operates in 
compliance with Code Provision 24. Lesley 
Jones, appointed Risk and Sustainability 
Committee Chair on 6 May 2022, remains 
a member to ensure the work of both 
Committees continues to be co-ordinated. 

Role and responsibilities
The primary role of the Audit Committee 
is to monitor the integrity of the financial 
statements of the Group and other 
financial information prior to publication 
and review the significant reporting 

judgements contained therein. The 
Committee achieves this by overseeing the 
financial reporting and audit processes 
and monitoring the effectiveness of the 
Group’s internal control and risk 
management systems. This includes:

•  monitoring the integrity of the financial 

statements of the Company, and 
discussing formal announcements 
relating to the Company’s financial 
performance and any significant issues 
and judgements contained in them;

•  reviewing the Group’s financial 

statements and the material financial 
reporting judgements contained in them;

•  advising the Board on whether the 

Committee believes this Annual Report 
and the financial statements contained 
within it, when taken as a whole, is fair, 
balanced and understandable and 
provides the information necessary 
for shareholders to assess the Group’s 
position and performance, business 
model and strategy (please see pages 
16 and 17 for further information);

•  reviewing and monitoring the external 
auditor’s independence and objectivity 
and the effectiveness of the audit 
process, taking into consideration 
relevant UK professional regulatory 
requirements;

•  developing and implementing a policy 
on the level, amount and pre-approval 
of non-audit services provided by 
the external auditor;

•  advising the Board on the appointment, 

reappointment and removal of the 
external auditor and the remuneration 
and terms of engagement of the 
external auditor;

•  monitoring the effectiveness of the 
Group’s internal control and risk 
management systems, including 
whistleblowing and fraud controls;

•  reviewing the scope, activities and 
results of the Group’s Internal 
Audit function;

•  reviewing the Audit Committee’s Terms 
of Reference, carrying out an annual 
performance evaluation exercise and 
noting the satisfactory operation 
of the Committee; and

•  reporting to the Board how it has 
discharged its responsibilities.

The Committee has an annual schedule 
of work, developed from its Terms of 
Reference (available on our website at 
https://corporate.moneysupermarket.
com), with standing items that it considers 
at each meeting, in addition to any specific 
matters upon which the Committee has 
decided to focus. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

89

Audit Committee Report continued

Role and responsibilities continued

Committee activities in 2022

Reviewed and approved the 31 December 2022 Annual Report and Financial 
Statements and the half-year statement to 30 June 2022, together with reports from 
the external auditor, examining key points of disclosure and presentation to ensure 
adequacy, clarity and completeness.

Committee priorities for 2023 

Oversee management’s preparations and 
responses to the changing control landscape, 
including in response to the BEIS consultation.

Reviewed and challenged management’s assessments, conclusions and disclosures 
in relation to goodwill and impairment.

Continued focus on assurance over the Group’s 
data management and protection controls.

Reviewed and approved the Internal Audit Charter.

Oversaw the work of our Internal Audit function, ensuring it retained the right 
expertise and experience to provide effective challenge throughout the 
organisation and measured the effectiveness and value of the function, including 
co-source arrangements, through questionnaires, metrics and assessments, 
including with reference to the IIA Code of Practice.

Oversee the onboarding of the new Group 
Chief Financial Officer.

Work with the Risk and Sustainability 
Committee to determine the approach to be 
taken to any assurance required in respect of 
ESG metrics.

Considered management’s and Internal Audit’s assessment of the effectiveness of key 
controls (across finance, operational and information security risks), in particular 
ongoing improvements made to the documentation and evidence of controls.

Continued oversight of the integration of 
acquired businesses into Group reporting 
and internal control processes.

Reviewed, considered and approved the scope and methodology of the audit work 
to be undertaken by the external auditor, including the terms of engagement and 
fees to be paid to the external auditor for the audit of the 2022 financial statements.

Make initial preparations ahead of holding 
a formal tender for the provision of external 
audit services in the medium term. 

Considered management’s progress in relation to finance integration of the 2021 
acquisitions in relation to systems, controls and process alignment to Group.

Evaluated the independence, objectivity and effectiveness of the external auditor 
and made a recommendation to the Board on the reappointment of KPMG as the 
external auditor.

Received summary reports on the progress of the Revenue Assurance function.

Reviewed and approved the rolling 12-month Internal Audit plan for appropriate risk 
coverage, including quarterly in-year updates for any changes, and considered the 
different sources of assurance against the Group’s key risks to ensure there is 
comprehensive risk and assurance coverage. Agreed and monitored the balance 
of audit focus across strategic, operational, third-party and core assurance areas.

Received updates in relation to the Group’s Treasury and Tax Policies and strategies. 

Received reports from management in relation to the Group’s anti-bribery and 
corruption processes, including whistleblowing, fraud and gifts and hospitality. 

Reviewed, approved and recommended to the Board the Group’s going concern 
and long-term Viability Statements as contained on pages 59 and 60.

Reviewed and approved the Committee’s updated Terms of Reference to reflect 
best practice. 

Considered Internal Audit reports, including any unsatisfactory audit findings, root 
causes and related actions plans, and satisfied ourselves that management had 
resolved or was in the process of resolving them.

Reviewed reports from the external auditor, KPMG, on the results of its controls 
testing as part of the external audit, including recommendations made by the external 
auditors in management letters and the adequacy of management’s response.

Received updates from management on continuous improvement of the Finance 
function as well as key projects such as finance data migration.

Considered the proposals from the Government on "Restoring Trust in Audit and 
Corporate Governance" and reviewed the Group’s readiness for the new requirements.

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Financial statements 
and reports
The Committee is responsible for reviewing 
the appropriateness of the Group’s 
half-year reporting and annual financial 
statements. We do this by considering, 
among other things: the accounting 
policies and practices adopted by the 
Group; the correct application of 
applicable reporting standards 

and compliance with broader governance 
requirements; the approach taken 
by management to report the key 
judgemental areas of reporting; and 
the comments of the external auditor 
on management’s chosen approach.

Significant financial statement 
reporting matters
We identified the matters below as being 
significant in the context of the 2022 

financial statements. We consider these 
areas to be significant taking into account 
the level of materiality and degree of 
judgement exercised by management. We 
discussed the issues in detail to ensure 
that the approaches taken were 
appropriate. This included reviewing 
presentations and reports from both 
management and the external auditor.

Issue

Committee review

Recoverability of goodwill, 
the Cashback CGU 

We reviewed and challenged management’s impairment modelling approach and outcomes 
in relation to the Cashback CGU including:

As described in our impairment 
review in note 13 to the accounts, 
as expected the estimated 
recoverable amount for the 
Cashback cash generating unit 
(“CGU”) provides relatively low 
headroom compared to the 
Group’s other CGUs as this 
CGU was only acquired by 
the Group in November 2021. 
The value in use calculation, 
which represents the estimated 
recoverable amount, is subjective 
due to the inherent uncertainty 
involved in selecting appropriate 
key assumptions. The model 
is sensitive to changes to the 
key assumptions, such as the 
revenue growth rate and the 
discount rate (which is more 
uncertain due to the macro-
economic environment). The 
Financial Statements (note 13) 
disclose the sensitivities 
estimated by the Group. 

Capitalisation of software 
and development costs

As more fully described on 
page 140 of the Group’s 
financial statements, the Group 
holds intangible asset balances 
arising from the capitalisation 
of certain software and 
development costs principally 
relating to developments in the 
Group’s front-end platforms 
and back-office data platforms.

•  The approach taken for the goodwill impairment assessment including the appropriateness 
of inputs to the model such as the board approved long term plan and the growth rates.

•  The discount rate and the appropriateness of the risk premium applied for the Cashback CGU.

•  The key assumptions to the model, being revenue growth and the discount rate, and the 

sensitivity analysis.

•  The associated disclosures (note 13) to confirm they provide adequate transparency and are fair, 

balanced and understandable.

We also heard from KPMG on the procedures they have performed to test these balances 
(see page 125). 

Our conclusions upon review are aligned with management and the auditors that the Cashback 
CGU goodwill is not impaired. We concluded that the disclosures give relevant information about the 
estimation uncertainty, including the risk of a reduction in the headroom as a result of a reasonably 
possible change in one or more of the key assumptions.

The judgements in relation to software and development assets largely relate to the future economic 
benefits associated with the assets and confirm that capitalisation is in accordance with the relevant 
accounting standards. We assessed the operation of key financial controls relating to investment 
appraisal, capitalisation and ongoing monitoring of intangible assets and we were comfortable with 
their integrity as reported by management. Sample testing was also conducted by the Internal Audit 
team on the related controls as part of the core assurance programme. We are also reassured by the 
fact that business plans in relation to the capitalised assets receive either direct Board approval or 
approval via appropriate delegated authority within pre-agreed limits.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

91

GovernanceAudit Committee Report continued

Significant financial statement reporting matters continued
We also reviewed and considered the following areas due to their materiality and the application of judgement.

Issue

Committee review

Intangible assets 
impairment testing

Revenue recognition

We reviewed the judgements, assumptions and estimates made by management in preparing the 
impairment review to ensure that they were appropriate. We also obtained the external auditor's 
views on the appropriateness of the approach and conclusions. The results of this review were 
that we were satisfied with the conclusions reached.

We reviewed and challenged the judgements, assumptions and estimates made by management 
regarding variable consideration under new and existing contracts. We also obtained the external 
auditor's views on the appropriateness of the approach and conclusions. The results of this review 
were that we were satisfied with the conclusions reached.

Going concern and viability 
statements

In assessing the validity of the statements detailed on pages 59 and 60, we reviewed and challenged 
management’s assessment of the Group’s resilience to the principal risks under various scenarios 
and gained appropriate assurance that sufficient rigour was built into the process. We also obtained 
the external auditor's views on the work undertaken by management. 

Fair, balanced and 
understandable Annual Report 
and Financial Statements
One of the Committee’s key roles is to 
recommend to the Board that the Annual 
Report and Financial Statements, taken 
as a whole, is fair, balanced and 
understandable and provides the 
information necessary for shareholders 
to assess the Group’s position and 
performance, business model and 
strategy. Ensuring this standard is met 
requires continuous assessment of the 
financial reporting issues affecting the 
Group, in addition to the focused exercises 
which take place during the production of 
the Annual Report and Financial 
Statements. These focused exercises 
can be summarised as follows:

•  a qualitative review of disclosures 

and a review of internal consistency 
throughout the Annual Report and 
Financial Statements;

•  a review by the Committee of all material 
matters, as reported elsewhere in this 
Annual Report and Financial Statements;

•  a risk comparison review, which 
assesses the consistency of the 
presentation of risks, and significant 
judgements throughout the main areas 
of risk disclosure in this Annual Report 
and Financial Statements;

•  a review of the balance of good and 

bad news; and

•  ensuring it correctly reflects:

 – the Group’s position and performance 

as described on pages 54 to 59;

 – the Group’s business model, as 

described on pages 16 and 17; and

 – the Group’s strategy, as described 

on pages 18 to 22.

The Directors’ Statement on a fair, 
balanced and understandable Annual 
Report and Financial Statements is set 
out on page 123.

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External auditor
The Committee is responsible for making 
recommendations to the Board in relation 
to the appointment of the external auditor. 
We also approve the terms of engagement 
and fees of the external auditor, ensuring 
they have appropriate audit plans in place 
and that an appropriate relationship is 
maintained between the Group and the 
external auditor.

Independence and 
non‑audit services
The Committee evaluated the 
independence and objectivity of the 
external auditor, having regard to: (a) a 
report from the external auditor 
describing its arrangements to identify, 
report and manage conflicts of interest; (b) 
the extent and nature of non-audit 
services provided by the external auditor; 
and (c) the tenure of the audit partner, who 
is required to rotate every five years in line 
with ethical standards.

There are policies and procedures in place 
in relation to the provision of non-audit 
services by the external auditor which are 
reviewed regularly. These ensure that the 
Group benefits in a cost-effective manner 
from the cumulative knowledge and 
experience of its auditor, whilst also 
ensuring that the auditor maintains the 
necessary degree of independence and 
objectivity. The external auditor is not 
permitted to perform any work which it 
may later be required to audit, or which 
might affect its objectivity and 
independence or create a conflict of 
interest. Key points from our internal 
procedure for approval of work given 
to the external auditor are:

•  no non-audit work may be placed with 

the external auditor without the specific 
approval of the Committee;

•  any approved non-audit services must 

be in line with the cap limits as enforced 
by the Financial Reporting Council ('FRC');

•  the non-audit fees are reported 
regularly to the Committee; and

•  various services are prohibited, 

including the provision of most types 
of tax services, valuation services, 
appraisals or fairness opinions, 
outsourcing of Internal Audit services, 
management functions, recruitment 
services and legal services.

During the year, the value of non-audit 
services provided by the external auditor 
amounted to £0.06m (2021: £0.05m). The 
non-audit services during 2022 and 2021 
related to the review of the Group’s half year 
reporting, which is not part of the audit fee 
cap. No other non-audit services were 
provided by the external auditor, therefore 
the Group was within required cap limits.

The assurance provided by the external 
auditor on this item is considered by the 
Group as strictly necessary in the interests 
of the Group. The non-audit services 
offered reflect the auditor’s knowledge 
and understanding of the Group. The 
Group has also continued with the 
appointment of other accountancy firms 
to provide certain non-audit services to 
the Group in connection with internal 
audit, tax, systems and regulatory advice 
and anticipates that this will continue in 2023.

The external auditor was not engaged 
during the year to provide any services 
which may have given rise to a conflict of 
interest. The Committee is satisfied that 
the overall levels of audit and non-audit 
fees are not material, relative to the 
income of the external auditor as a whole, 
and therefore that the objectivity and 
independence of the external auditor 
were not compromised.

External audit effectiveness
The Committee considered the quality and 
effectiveness of the external audit process. 
We worked with KPMG to understand its 
judgements about materiality and 
considered the way it communicated key 
accounting and audit judgements. This 
approach was supplemented by members 
of the Committee completing a detailed 
questionnaire. The questionnaire evaluated 
the overall effectiveness of the external 

auditor including the audit partner’s and 
his team’s approach, communication, 
independence, objectivity, and reporting. 
We also assessed the value for money of 
the audit process, including KPMG’s 
existing and proposed audit fees. The 
results of the questionnaire were then 
reported to and discussed by the 
Committee and the findings reporting to 
the Board as part of our recommendation.

As in prior years, at the planning meetings 
for the half-year review and year end audit, 
the external auditor was required to 
explain its understanding of significant 
risks to audit quality, by reference to the 
Company’s specific circumstances and 
changes in the risks and reasons for those 
changes. We explored the auditor’s 
understanding of our business and 
industry knowledge which informed its 
approach to identifying risks. We also 
considered the auditor's use of specialists 
in its work to support its core team.

The Committee held private meetings with 
the external auditor as necessary after 
Committee meetings to review key issues 
within its sphere of interest and responsibility.

Reappointment of the 
external auditor
KPMG has acted as the auditor to the 
Group since 2004 and was appointed as 
the auditor to the Company on its flotation 
in 2007. The lead audit partner rotates 
every five years to ensure independence, 
with the last rotation in 2020. Following a 
formal competitive tender exercise during 
2016, in relation to the audit for the Group 
for the year ended 31 December 2017, the 
Board approved the Audit Committee’s 
recommendation to put a resolution to 
shareholders at the 2017 Annual General 
Meeting to reappoint KPMG, which 
shareholders subsequently approved.

We have therefore complied with the 
requirement to ensure the external audit 
contract is tendered within the ten years 
prescribed by EU and UK legislation and 
the Code’s recommendation. We confirm 
we have complied with the provisions of 
The Statutory Audit Services for Large 
Companies Market Investigation 
(Mandatory Use of Competitive Tender 
Processes and Audit Committee 
Responsibilities) Order 2014.

Since KPMG’s reappointment, we have 
considered further the length of KPMG’s 
tenure and have conducted detailed 
stakeholder surveys on its performance 
to assess its continued effectiveness and 
independence. We continue to remain 
satisfied with the work of KPMG and that 
it continues to remain independent and 
objective. In accordance with ISA (UK) 
260 and Ethical Standard 1 issued by 
the Financial Reporting Council, and as 
a matter of best practice, the external 
auditor has confirmed its independence 
as auditor of the Company, in a letter 

addressed to the Directors. It will therefore 
be proposed at the 2023 AGM that KPMG 
be reappointed as the Group’s auditor for 
the financial year ended 31 December 2023. 
The Committee will conduct a formal audit 
tender process during 2024 with a view to 
proposing a resolution to shareholders at 
the 2025 Annual General Meeting.

objectivity and reporting. The results of the 
questionnaire were then reported to and 
discussed by the Committee. Additionally, 
the Head of Internal Audit undertakes an 
annual self-assessment of the Internal 
Audit function against the Chartered 
Institute of Internal Audit Standards and 
reports the results to the Audit Committee. 

Internal control
The Committee is responsible for 
monitoring and reviewing the effectiveness 
of the Group’s internal control and risk 
management systems. The Committee 
delivers on this objective by reviewing 
management’s reports on internal control 
effectiveness via self-assessment and 
first line testing of key financial controls, 
including monitoring of control improvement 
plans and consideration of the mitigating 
controls in operation. The Committee also 
receives assurance reports on key financial 
controls from independent testing by 
Internal Audit, as well as management 
control points from External Audit. Through 
monitoring the effectiveness of its internal 
controls and risk management, the 
Committee is able to maintain a good 
understanding of business performance, 
key judgemental areas and management’s 
decision-making processes. The Committee 
was pleased to receive a report from 
finance on their continuous improvement 
project which had delivered ongoing 
control enhancements and efficiencies 
during 2022. 

We consider the adequacy of 
management’s response to matters raised 
and the implementation of 
recommendations made. The Board’s 
statement on internal control and risk 
management can be found on page 79.

Internal Audit
The Group has an Internal Audit function 
which, together with a PwC co-source 
arrangement, delivers a risk-based Internal 
Audit plan to provide independent 
assurance over the Group’s key risks. In 
2022, the Internal Audit team continued to 
utilise the PwC co-source relationship to 
deliver specialist reviews. These reviews 
were more technical in nature and related 
to the ISMS and Cyber Red Team 
assessments. The Audit Committee meets 
with the Head of Internal Audit without 
management present on an annual basis. 
In addition, the Head of Internal Audit 
meets separately with the Chair of the 
Committee throughout the year to discuss 
internal audit objectives. 

Internal Auditor effectiveness 
The Committee considered the quality and 
effectiveness of the Internal Audit function 
by way of completing a detailed 
questionnaire. In 2022 the questionnaire 
evaluated the overall effectiveness of the 
Internal Audit function including the team’s 
approach, communication, independence, 

The Committee approves the Internal Audit 
Charter on an annual basis and reviews 
and monitors progress against the annual 
Internal Audit plan. The Committee further 
seeks confirmation from the Head of 
Internal Audit that the Internal Audit 
function has the requisite expertise and 
resources to successfully fulfil its role. 

Whistleblowing
The Group has established procedures by 
which all employees may, in confidence, 
report any concerns. Our whistleblowing 
process sets out the ethical standards 
expected of everyone that works for and 
with us and includes the procedures for 
raising concerns in strict confidence. Our 
workforce can raise concerns through their 
manager or senior management and 
through our confidential and independent 
whistleblowing helpline. All investigations 
are carried out independently with findings 
being reported to the Committee.

The Board, as a whole, monitors and 
reviews the effectiveness of the Group’s 
whistleblowing arrangements annually, to 
ensure that it has sufficient oversight of 
whistleblowing to support its work on 
culture, risk and stakeholder engagement. 
The Committee receives reports on 
investigations and all significant 
whistleblowing matters are reported 
directly to the Board. The Board has 
reviewed the whistleblowing arrangements 
and is satisfied that they are effective, 
facilitate the proportionate and 
independent investigation of reported 
matters and allow appropriate follow-up 
action to take place.

Audit Committee effectiveness
In 2022, we carried out an internal evaluation 
of Committee effectiveness which involved 
the completion of a questionnaire, with the 
results being analysed and presented at 
the October Board meeting for discussion. 
The Committee determined it continues 
to be effective in fulfilling its role and 
remains independent.

This report was approved by the Board 
and signed on its behalf by:

Caroline Britton
Chair of the Audit Committee
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

93

GovernanceRisk and Sustainability Committee Report

Balancing Risk 
and Opportunity

The Committee expanded its remit in 2022 to 
incorporate oversight of the Group’s sustainability 
framework, further embedding the achievement 
of our sustainability goals within our risks 
and opportunities.

Lesley Jones
Chair of the Risk and Sustainability Committee

Having been appointed as Risk and 
Sustainability Committee Chair in May 
2022, I am pleased to present the 
Committee’s Report for the year ended 
31 December 2022. I have set out our role 
and activities in overseeing the Group’s 
risk management framework, ensuring 
risks are appropriately identified, managed 
and mitigated, and advising the Board on 
risk appetite, strategy and culture. In 
September 2022 the Committee assumed 
responsibility for the oversight of the 
Group’s Sustainability Framework 
implementation and embedding, with 
the Board approving updated Terms of 
Reference in December 2022. 

The Risk and Sustainability Committee 
maintains close links with the Audit 
Committee, with the Chair of each 
Committee being a member of the other. 
This cross-membership and liaison 
between the Committees, on agenda items 
and reports, facilitate effective linkage 
between both Committees and ensure that 
any matters relating to internal control and 
financial reporting are considered in an 
effective and timely manner. Commencing 
in 2023 I, as Chair of the Risk and 
Sustainability Committee, will provide 
assurance to the Remuneration Committee 
on the performance of the business and 
control functions on an annual basis to 
allow the Remuneration Committee to 
satisfy itself on the appropriateness of its 
remuneration decisions. 

94

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Role and responsibilities 
The primary role of the Risk and 
Sustainability Committee is to assist the 
Board in its oversight of risk management 
and delivery of its sustainability strategy 
within the Group. The Committee achieves 
this by:

•  advising the Board on the overall risk 

appetite, tolerance, strategy and culture;

•  overseeing and advising the Board on 
the current risk exposures and future 
risk strategy;

•  overseeing the application of the risk 

management framework;

•  overseeing the management of key risks, 

including strategic, operational, 
regulatory, conduct and data risks 
across the Group;

•  reviewing reports received from 

management, the Risk and Compliance 
function and, where appropriate, 
Internal Audit or third parties on the 
identification, management and 
mitigation of risks;

•  reviewing reports from the legal team 
in relation to legal matters affecting 
the Group;

•  receiving "deep dive" updates into 
key risk areas including cyber, data 
protection and third-party risks;

•  overseeing compliance with relevant 
legal and regulatory requirements; 

•  overseeing and monitoring the Group’s 

sustainability and environmental 
initiatives; and

•  considering and approving the remit of 
the Risk and Compliance function and 
ensuring it has adequate resources.

The Committee held three meetings in 
2022 and has an annual schedule of work, 
developed from its Terms of Reference 
(available on our website at https://
corporate.moneysupermarket.com), with 
standing items that it considers at each 
meeting, in addition to any specific matters 
upon which the Committee has decided to 
focus. This schedule of work evolved in 
September 2022 to include oversight of 
the Group’s Sustainability Framework, with 
regular reporting commencing in 2023. 
The Risk and Sustainability Committee 
receives regular reports from the 
management team, the Chief Risk Officer 
and the General Counsel and 
Company Secretary.

Committee activities in 2022

Committee priorities for 2023 

Received reports from management on risks associated with the 
strategic initiatives and received ad hoc reports relating to new 
or emerging risks.

Approved the renaming of the Committee to the Risk and 
Sustainability Committee and the updating of its Terms of 
Reference to include oversight of the delivery of the Group’s 
Sustainability Framework and outcomes.

Oversaw compliance with evolving regulating including the 
Group’s FCA Consumer Duty Plan preparation, recommending 
the same to the Board for approval. 

Focus on management of risks associated with the delivery of the 
strategic initiatives.

Oversight of enhanced controls relating to the Group’s financial 
crime and data protection risks. 

Oversight and monitoring of the Group’s sustainability 
and environmental initiatives.

Oversaw the ongoing embedding of enhanced controls in respect 
of cyber security, data privacy and third-party management.

Oversight of regulatory change including FCA, ICO, CMA 
and energy market. 

Received reports on actions and progress against the Group’s risk 
acceptances, including whether these continued to be appropriate.

Approve the Risk and Compliance plan and monitor 
management’s progress against the same.

Received progress updates on management third-party oversight 
through the embedding of the Supplier Management Framework.

Provide assurance to the Remuneration Committee on the 
performance of the business and control functions on an annual 
basis to allow the Remuneration Committee to satisfy itself on 
the appropriateness of its remuneration decisions. 

Oversaw the progress of integration of acquisitions into the 
Group’s risk management framework.

Reviewed and approved the Risk and Compliance plan 
and monitored management’s progress against the same.

Reviewed the resources and considered the effectiveness of the 
Risk and Compliance function.

Reviewed the conduct scorecards and oversaw related actions 
to ensure we are putting customers at the heart of the business.

Risk and Compliance
The Group has a Risk and Compliance function, led by the Chief Risk Officer, which oversees the Group’s risks and controls together with 
the Group’s compliance with the requirements of the various bodies that regulate the Group’s activities. These regulatory bodies include 
the CMA, the FCA and the ICO as well as Ofgem and Ofcom (which operate voluntary price comparison codes in the energy and home 
communications sectors to which brands in the Group subscribe). The Chief Risk Officer is a member of the Executive Team, reflecting 
the importance of the risk management and internal control processes to the Group. The Chief Risk Officer meets with the Risk and 
Sustainability Committee members without members of the executive present at the conclusion of each meeting to discuss 
pertinent matters.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

95

GovernanceRisk and Sustainability Committee Report continued

Risk and Compliance continued
The Group has a Risk and Compliance plan, 
which defines the scope of the work that 
the function will undertake, including 
compliance monitoring and assurance 
activities across the Group. In 2022 this 
focused on extending and embedding the 
Group risk framework to acquisitions and 
enhancing control in respect of data 
protection and business continuity. 

Principal and emerging risks
The Committee undertook an assessment 
of the Group’s principal and emerging 
risks, including those which had the 
potential to impact delivery of our 
strategy, culture and future performance. 
Details of the Group’s principal risks and 
uncertainties, including their type, link 
to the Group’s strategy and trend 
information, are provided on pages 66 
and 67. 

In accordance with the 2018 UK Corporate 
Governance Code Principle O and 
Provision 29, following a detailed review by 
the Committee, the Directors can confirm 
that the Group’s key risks have been 
robustly assessed by management and 
the related key controls are effective. 

The key risks are managed by one or more 
control owner across the Group and are 
recorded in the Operational Risk Log. 
Controls are documented within a Control 
Brief, which summarises how the control 

works, the frequency, who is responsible 
and how effectiveness will be evidenced. 
Quarterly reviews of controls are 
conducted by control owners to confirm 
whether they have been operating 
correctly, they are mitigating the risk as 
expected and they can be appropriately 
evidenced. Where enhancements to 
controls are identified via assurance 
activities, actions are agreed to strengthen 
them to ensure they continue to effectively 
mitigate the risk. Control owners and the 
relevant Executive member attest to the 
effectiveness of their controls biannually 
at the half and full year. The Risk and 
Compliance Team reports changes in the 
effectiveness of controls to the Executive 
and Audit Committees. An independent 
annual review of internal controls is 
undertaken by the Internal Audit function.

Opportunities 
Our risk management framework 
underpins the strategy of the Group, as it is 
only by understanding the level of risk the 
Board is willing to take that we can identify 
and pursue strategic opportunities. The 
Risk and Compliance function’s monitoring 
and assurance of in-flight strategic 
programmes enable the early detection 
of execution risks. For further details 
regarding the principal and emerging 
risk assessment, including details of the 
Board’s appetite in relation to its strategic 
objectives, please see pages 62 to 67.

Risk and Sustainability 
Committee effectiveness
In 2022, we carried out an internal evaluation 
of the Risk and Sustainability Committee's 
effectiveness which involved the completion 
of a questionnaire, with the results being 
analysed and presented at the October 
Board meeting for discussion. The Committee 
determined it continues to be effective in 
fulfilling its role and remains independent. 

Overview of Committee 
activities for 2023
In 2023 the Committee will monitor the 
management of risks associated with the 
delivery of the strategic initiatives, the 
Group’s FCA Consumer Duty Plan and the 
Group’s sustainability and environmental 
initiatives. Further, we will oversee the 
Group’s response to regulatory change 
including the FCA, ICO, CMA and energy 
market and the ongoing enhancement of 
the Group’s cyber security and third-party 
management arrangements.

This report was approved by the Board 
and signed on its behalf by:

Lesley Jones
Chair of the Risk and 
Sustainability Committee
15 February 2023

96

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

G
o
v
e
r
n
a
n
c
e

Remuneration Committee Report

Incentivising our 
most valuable 
asset

The Remuneration Committee’s key 
responsibility is to determine and apply 
the Remuneration Policy to ensure it promotes 
the delivery of our strategy and the 
long‑term success of the Group. 

Rakesh Sharma 
Chair of the Remuneration Committee

As a Committee we ensure that our remuneration framework continues to align with our Group strategy.

How we performed in the year

Group revenue

Group adjusted EBITDA

£387.6m

(2021: £316.7m)

£115.5m

(2021: £100.5m)

Net promoter score 
(MSM and MSE)

72

(2021: 72)

How performance links to Executive Directors’ Annual Bonus
Performance targets are set each year by the Remuneration Committee by reference to factors such as the budget and strategic objectives 
for the year, progress against the prior year and market expectations. Personal targets for 2022 included continued delivery of the Group 
strategy, leadership objectives and our focus on delivery at pace across the Group.

Total remuneration received by our Executive Directors

Board member

Peter Duffy

CEO

Scilla Grimble

CFO

Salary

Taxable Benefits

Pension

Annual Bonus

LTIP/Other

592,300

23,313

29,615

771,431 1

434,800

14,000

76,000

— 2

0

0

1  One-third of annual bonus deferred into shares.

2  Scilla Grimble was not entitled to an annual bonus for 2022 following her resignation.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

97

Remuneration Committee Report continued

Number of meetings of the 
Remuneration Committee

5

Quick facts
All members of the Committee 
in 2022 were independent 
Non-Executive Directors.

•  Only members of the Committee 

have the right to attend Committee 
meetings. Other individuals may be 
invited to attend meetings as and 
when appropriate, including the 
Chair of the Board, the CEO, the 
CFO, the Chief People Officer, the 
Head of Reward, the General Counsel 
and the Company Secretary and the 
external remuneration consultant.

•  The members of the Remuneration 
Committee can, where they judge it 
necessary to discharge their 
responsibilities, obtain independent 
professional advice at the 
Company’s expense.

•  The Committee’s Terms of 
Reference were updated in 
December 2022 and are available 
on the Investor section of the 
Group’s website at http://corporate.
moneysupermarket.com.

Chair’s letter
Attendance for each of the Committee 
meetings can be found on page 74 in 
the Corporate Governance section. 

2022 highlights
•  Undertook a comprehensive review 

of the Directors’ Remuneration 
Policy in order to ensure that it 
continues to operate effectively and 
aligns with the strategic priorities 
and direction of the Group.

•  Developed the proposed 

Remuneration Policy, including the 
replacement of the existing LTIP 
with Restricted Share Awards.

•  Reviewed and approved executive 
bonus outcomes for 2022, which 
reflect the strong financial and 
strategic performance of the Group 
over the year.

98

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

Dear Shareholder
I am pleased to present the Directors’ 
Remuneration Report for the year ended 
31 December 2022, my first Directors’ 
Remuneration Report as Remuneration 
Committee Chair of Moneysupermarket.
com Group. James Bilefield stepped 
down from the Board in May 2022, 
with Sarah Warby assuming the role 
of Interim Chair of the Committee. 
I was appointed to the Board and 
Remuneration Committee as Chair 
Designate in October 2022 and assumed 
the role of Chair of the Committee from 
January 2023. I would like to extend mine 
and the Board’s thanks to both James 
and Sarah for their respective periods 
chairing the Committee.

Whilst I was not Chair of the Committee 
during the entirety of the review of the 
Directors’ Remuneration Policy (as 
discussed below), I have been involved in 
discussions both internally and with our 
shareholders since my appointment to 
the Committee as Chair Designate, and 
am fully supportive of the proposals which 
I believe will support the implementation 
of the Group’s strategy and the creation of 
sustainable shareholder value during the 
Policy life cycle in what continues to be an 
unpredictable external market environment.

Wider workforce context
Throughout 2022 the Committee has 
been mindful of the challenging 
economic environment which has seen 
high inflation levels with lower paid 
employees disproportionately impacted. 
We are acutely aware that this is a 
challenging time for many of our 
colleagues who are experiencing 
significant increases to their cost of living.

The Company has taken a number of 
actions during the year in response to this, 
including a £2,000 cost of living payment to 
any colleagues earning below £55,000 p.a. 
in September 2022 in order to support our 
lowest paid colleagues during this time, as 
well as regularly reviewing our benefits 
packages to ensure that they remain most 
appropriate for employees during this 
period. In addition to an increase in the 
overall budget allocated to salary increases 
in the 2022 annual pay review, for the prior 
year pay review (allocated in March 2022) 
we increased the proportion of the overall 
budget which is allocated to lower paid 
employees such that junior employees 
received a higher percentage increase 
than more senior colleagues. Therefore 
colleagues earning under £40,000 
received a minimum salary increase of 
£1,200. The salary increase budget for 
2023 is 6.5%.

The Group is also a real living wage 
employer and implemented the most 
recent increase immediately (employers 
have 8 months to implement) in order 
to support our lowest paid employees.

Outside of the cost of living crisis, focus 
areas for 2022 included our Diversity, 
Equity, Inclusion and Belonging strategy. 
From a remuneration perspective we 
continued to focus on understanding the 
drivers of gender and multi-ethnic pay gaps 
internally in order to take tangible action. 

Remuneration Policy review
Our existing Remuneration Policy was 
approved by shareholders at the 2020 
AGM. In line with the normal three-year 
renewal cycle, we will be seeking 
shareholder approval for a new Policy, 
set out on pages 101 to 108, at the AGM 
in 2023.

During the year, the Remuneration 
Committee has undertaken a 
comprehensive review of the overall 
remuneration framework to ensure that 
it continues to be aligned with our 
strategy and the interests of all of our 
stakeholders. The outcome of this review 
is that is that two key changes to the 
Policy are proposed and these changes 
are outlined below.

Introduction of Restricted 
Share Awards
As a marketplace business, the Group is 
very reliant on end-market dynamics and 
these have experienced substantial levels 
of dislocation in recent years, including:

1. 

2. 

3. 

 Our Travel-related business channels 
(insurance, car hire, holidays) were all 
closed during the COVID-19 
pandemic and, whilst travel 
insurance has now recovered, other 
Travel channels are still materially 
impacted by continuing disruption. It 
is not currently possible to forecast 
when these will return to their 
pre-pandemic levels.

 Our energy switching business is 
currently significantly depressed 
whilst market prices remain volatile 
and at unprecedented levels. We 
currently have extremely limited 
visibility on when energy providers 
will come back to the market for 
customer acquisition and hence 
when energy switching can resume.

 The general insurance related 
FCA regulations which took effect 
in January 2022 resulted in a 
contraction in the car and home 
insurance switching markets. Whilst 
we believe the impact of these 
regulatory reforms have since 
stabilised, there may be further 
regulatory changes that will 
be introduced and will 
alter end‑markets. 

Whilst we remain confident in our long‑
term business model and in our ability 
to deliver shareholder value, against an 
unpredictable market backdrop, the 
Committee does not believe it is possible to 
set robust, fair and meaningful three-year 
financial targets under the LTIP. The 
Committee has therefore concluded that 
the LTIP is not currently functioning as 
intended and that an alternative incentive 
model would be more appropriate at 
this time.

The Committee therefore believes that a 
restricted share model (i.e. shares which 
are not subject to traditional performance 
conditions) will provide a more appropriate 
mechanism for the Group’s long-term 
share-based reward. 

Restricted Share Awards (RSAs) will provide 
a simple and transparent award which 
can support the creation of significant 
long-term equity ownership. The 
Committee believes that, at this current 
time, a simpler pay structure, with less 
reliance on long-term performance 
conditions, and a greater focus on large 
long-term shareholdings, will have a 
positive impact on investment, innovation, 
long-term decision making and long-term 
sustainable value creation. RSAs will 
encourage management to make the best 
long-term decisions for the business.

The RSAs will sit alongside our annual 
bonus plan, which will continue to drive 
short-term performance against the 
Group’s key financial and strategic 
objectives each year. 

We already use RSAs as a form of long‑term 
reward within the business, and therefore 
adopting RSAs at our Executive Director 
level will deliver alignment across the Group.

The appropriateness of RSAs will be kept 
under review and during the next review of 
the Directors’ Remuneration Policy the 
Committee will assess whether greater 
market visibility is evident and may seek to 
return to a performance-based long-term 
scheme in the future.

The Remuneration Committee undertook an 
extensive consultation with our shareholders 
and proxy voting agencies in respect of the 
proposed framework and overall investors 
were generally supportive of the approach. 
We thank our shareholders for the time they 
took to provide their feedback as part of 
the review, which helped us shape the 
final proposals.

Restricted Share Awards – 
award parameters aligned to 
best practice
The proposed parameters for the RSA 
awards fully align with established best 
practice guidance in the UK-listed market. 
Awards will be: 

•  based on a “haircut” of 50% from current 
LTIP award levels, resulting in awards of 
87.5% of salary for the CEO and 75% of 
salary for the CFO;

•  earned over a vesting period of three 
years, followed by a further two-year 
post-vesting holding period;

•  subject to robust underpins to provide 

an appropriate safeguard for our 
shareholders. Should any of the 
underpins not be met, the Committee 
would consider whether, and to what 
extent, a discretionary reduction in the 
vesting of awards was required 
(Committee discretion can be used only 
to reduce the vesting outcome). The 
underpins for 2023 are as follows:

 – performance against the Group’s key 
strategic priorities (including an ESG 
objective) over the vesting period;

 – whether there is a material 

weakness in the underlying financial 
health or sustainability of the 
business. Factors such as, (but not 
limited to), long-term revenue, 
profitability, cash generation and 
dividend cash cover would be 
considered; and

 – whether there has been a materially 
serious conduct, reputational or 
regulatory event which could have 
been reasonably foreseen.

Further details of the operation of the 
underpins for 2023 are set out on page 108 
and a full explanation of the Committee’s 
decisions regarding the vesting of RSAs, 
including assessment of the underpin 
conditions, will be provided in the relevant 
Directors’ Remuneration Report.

Post-employment 
shareholding guidelines
Under the existing Policy, Executive 
Directors must retain their full 
in-employment shareholding guideline 
(200% of salary) for one year following 
cessation of employment and 50% of 
the guideline (100% of salary) for the 
second year.

We are proposing to strengthen our 
post-employment shareholding guideline 
so that Executive Directors will be required 
to hold their full in-employment guideline 
for two years following cessation of 
employment, in line with the Investment 
Association’s guidance and best practice.

The Committee believes that RSAs in 
combination with the in-employment 
shareholding guideline and our 
strengthened post-shareholding guideline 
strongly aligns management with 
shareholder interests, incentivising our 
Executives to make the best long-term 
decisions for the business.

2022 remuneration outcomes
As described elsewhere in the Annual 
Report and Accounts, 2022 was a year 
of good strategic progress and result 
delivery. Whilst challenging conditions 
remained in some of our main markets, 
particularly energy, the diversity of our 
product offering proved a major strength 
in the face of such disruption. Our Money 
vertical performed robustly, with our 
brands providing useful advice and savings 
tips to millions of people amidst the cost of 
living crisis. We helped households save an 
estimated £1.8bn and MoneySavingExpert 
has become the foremost authority in the 
energy crisis.

We continued to deliver well against 
our strategy, finalising the rollout of our 
modernised marketing tech stack, with 
more of our products migrating to the new 
Group tech platform, all connected to the 
new data infrastructure. We delivered 
improved PPC bidding capabilities and 
introduced our new MoneySuperMarket 
brand campaign. 

Taking into account all of the above, the 
overall bonus outcome for Peter Duffy was 
130.2% of base salary out of a maximum 
opportunity of 150% of salary i.e. 86.8% of 
maximum. The Committee considers that 
this overall outcome is appropriate in the 
context of the strong business 
performance (both financial and strategic) 
and wider stakeholder experience. In line 
with the existing Remuneration Policy, 
one-third of this award will be deferred into 
shares which vest after two years. Further 
details of performance achieved are set out 
on page 114.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

99

GovernanceAnnual bonus opportunity levels are 
unchanged for 2023; Peter Duffy’s 
maximum award is 150% of salary and Niall 
McBride’s maximum award is 135% of 
salary (pro-rated for time in role). 

Restricted Share Awards

RSAs will operate in line with the proposed 
Remuneration Policy as outlined above, 
with award levels of 87.5% of salary for the 
CEO and 75% of salary for the CFO. Awards 
will be subject to underpin conditions (as 
set out above) and should any of the 
underpins not be met, the Committee 
would consider whether, and to what 
extent, a discretionary reduction in the 
vesting of awards was required. Further 
details of the operation of the underpins 
for 2023 are set out on page 108.

2023 AGM
We consulted extensively with our major 
shareholders as part of the review of the 
Remuneration Policy, listening carefully to 
a wide range of views, and incorporating 
feedback where we felt it was in the best 
interests of the business. We will be 
submitting the Policy and Annual Report 
on Remuneration to our shareholders at 
the 2023 AGM where the Policy will be 
subject to a binding shareholder vote and 
the Report subject to an advisory 
shareholder vote. I very much look forward 
to receiving your support and will be 
available to answer any questions.

Rakesh Sharma
Chair of the Remuneration Committee
15 February 2023

Remuneration Committee Report continued

2022 remuneration outcomes 
continued
Scilla Grimble was not eligible for an 
annual bonus in respect of 2022 following 
her resignation. 

The 2020 LTIP award was based on a 
combination of stretching targets of adjusted 
basic EPS, revenue and comparative total 
shareholder return over the three-year 
performance period to 31 December 2022. 
The targets for this award were set before 
the on-set of the COVID-19 pandemic and 
given the disruption in the market during this 
period, these stretching targets have not 
been met. The Committee has not exercised 
discretion in relation to the outcome.

Chief Financial Officer transition
As announced last year, Niall McBride was 
appointed to the role of Chief Financial 
Officer on 20 February 2023, replacing 
Scilla Grimble who stepped down from the 
Board on 17 February. Niall has been 
appointed on a salary of £435,000 (in line 
with that paid to Scilla), his pension is 
aligned with the wider workforce at 5% 
of base salary and other elements of the 
package are in line with the Policy. No 
additional awards were made to buy-out 
forfeited remuneration. Niall will be eligible 
for a pro-rated annual bonus in respect of 
2023 (pro-rated for time in role) and will be 
granted an RSA award subject to the 
approval of the proposed Policy.

Scilla is not eligible for an annual bonus in 
respect of 2023 and will not receive an RSA 
award for 2023. Scilla’s remaining in-flight 
LTIP awards have lapsed and any unvested 
deferred bonus awards will vest in line with 
the original timescales. Scilla will also be 
subject to the post-employment shareholding 
guideline within our 2020 Policy.

Approach to remuneration 
in 2023
Salary, pension and benefits

Peter Duffy received a salary increase of 4% 
to £615,992 effective 1 January 2023. This is 
below the average awarded to the wider 
workforce where a salary increase budget 
pot of 6.5% was distributed. When 
awarding Peter a salary increase for 2023, 
the Committee was conscious of the 
continuing cost of living crisis which has 
disproportionately impacted our lower paid 
employees, therefore the increase awarded 
was below the average level provided to the 
wider workforce in order to reflect this. 
Niall McBride joined the business on 20 
February and was therefore not eligible for 
a salary increase for 2023.

Pension and benefits will operate in line 
with the Remuneration Policy. All Executive 
Directors receive a pension contribution of 
5% of salary, in line with that available to 
the wider workforce.

Annual bonus

During 2022 the Committee reviewed the 
operation of the annual bonus, including 
the performance measures and relative 
weightings. Whilst it was considered that 
the financial measures of EBITDA and 
revenue (and their relative weightings 
of 50% and 20% respectively) remain 
appropriate, it is proposed to simplify the 
approach for non-financial measures in 
order to improve the overall line of sight 
for the senior leadership and the collective 
focus on driving the key strategic 
objectives for the year. 

For 2023, the non-financial measures have 
been simplified as follows: 5% based on 
each of customer and ESG measures, with 
20% based on shared strategic objectives. 
Personal objectives have been replaced 
with collective strategic objectives in order 
to create a collective focus on 
collaboration and delivering the key 
priorities for the Group during the year. 
For 2023 the shared strategic objectives 
have been focused on strategic, 
technology operations and leadership 
objectives. The Committee is conscious 
that the weighting on ESG has been 
reduced relative to previous years, 
however given that progress against our 
ESG objectives is included as part of the 
strategic underpin for the Restricted Share 
Awards, on balance, we believe that 
sufficient focus is placed on ESG.

100 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

 
Directors’ Remuneration Policy
Set out below is the Company’s Directors’ 
Remuneration Policy, which will be put to a 
binding shareholder vote and become 
formally effective from the 2023 Annual 
General Meeting.

The design and implementation of the 
Remuneration Policy is the responsibility of 
the Company’s Remuneration Committee. 
Further information on the composition 
and operation of the Remuneration 
Committee is set out on page 74 and 98.

In developing the proposed Policy, the 
Committee followed a robust process which 
included discussions on the content of the 
Policy at Remuneration Committee 

meetings during the year. Input was 
received from the Company Chair and 
management while ensuring that conflicts of 
interest were suitably mitigated. Input was 
also provided by the Committee’s appointed 
independent advisers throughout the 
process. The Committee also sought 
feedback from shareholders and feedback 
has been reflected in final proposals.

Changes from the 
previous Policy
The key changes to this Remuneration 
Policy, from the previous Policy approved 
by shareholders at the 2020 AGM, and as 
described in the Chair’s introductory 
statement, are as follows:

•  introduction of Restricted Share Awards 
(RSAs) under the Company’s Restricted 
Share Plan in place of the LTIP to better 
support the Company’s strategy.

•  strengthened post-employment 

shareholding guidance, with Executive 
Directors required to hold their full 
in-employment guideline for two years 
following cessation, in line with 
best practice.

Other minor changes have been made to 
the wording of the Policy to aid operation 
and to increase clarity.

Remuneration Policy table

Base salary

Purpose and link 
to strategy

Operation

To provide competitive fixed remuneration to attract and retain Executive Directors of the calibre 
required to deliver the business strategy for shareholders.

The base salary for Executive Directors will normally be reviewed annually by the Committee. Individual 
salary adjustments may take into account each Executive Director’s performance and experience in role, 
changes in role or responsibility, the Group’s financial performance, and external market data.

Maximum

There is no prescribed maximum base salary or maximum salary increase.

Salary increases are ordinarily in line with the broader employee population but increases may be above 
this level in certain circumstances, for example, an increase in the scale, scope or responsibility of the 
role, an increase in the size and complexity of the Company, developments in the wider competitive 
market or significant change in market practice and other exceptional circumstances.

Current base salary levels are set out on page 107.

Performance targets

No specific targets although the Committee will take into account individual performance when 
considering salary increases.

Pension

Purpose and link 
to strategy

Operation

Maximum

To provide an appropriate retirement benefit that is competitive in the relevant market.

Executive Directors may participate in the Company’s defined contribution pension scheme and/or 
receive salary supplements, or such other allowance as the Committee considers appropriate.

Maximum contribution or cash supplement in line with that available to the majority of the wider 
workforce (currently 5% of base salary).

Performance targets

Not applicable.

Benefits

Purpose and link 
to strategy

Operation

To provide market competitive benefits.

Current benefit provision includes a car allowance, life insurance and private medical insurance. Other 
benefits may be provided where appropriate including, for example, one-off or on-going relocation 
benefits, travel expenses and reimbursed business expenses (including any associated tax liability) 
incurred when travelling in performance of duties.

Maximum

There is no prescribed maximum monetary value for benefit provision. Benefits are set at a level which 
the Committee determines is reasonable and appropriate and the value may vary depending on the 
benefit provided and the market cost of the benefit given the individual’s personal circumstances.

Performance targets

Not applicable.

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101

GovernanceRemuneration Committee Report continued

Remuneration Policy table continued

Annual bonus

Purpose and link 
to strategy

Incentivises the delivery of stretching financial, operational and strategic performance. Deferral into 
Moneysupermarket.com Group PLC shares increases long-term alignment with shareholders.

Operation

The annual bonus is based on performance against performance targets set by the Committee.

A proportion of any annual bonus earned (at least one-third) will normally be deferred into an award 
of Moneysupermarket.com Group PLC shares under the terms of the Deferred Bonus Plan (DBP). DBP 
awards will normally vest at least two years after grant. The remainder will be paid in cash following the 
year end.

Malus and clawback provisions apply for a period of two years following the payment of a cash bonus 
and the grant of any DBP award.

Maximum

The maximum annual bonus opportunities in respect of a financial year will be:

Performance targets

•  CEO: 150% of base salary; and

•  CFO: 135% of base salary.

Where considered appropriate in exceptional circumstances, the Committee may determine that the 
maximum annual bonus opportunity in respect of a particular financial year is up to 200% of base salary.

Payment is determined by reference to performance assessed over a financial year. The Committee shall 
determine performance measures for the bonus each year which the Committee considers to be aligned 
to the strategy and the creation of shareholder value. These may include financial measures and other 
metrics linked to the delivery of the business strategy, operations or personal performance targets.

The Committee determines the weightings of the performance measures each year. The overall 
framework will normally be weighted towards financial measures of performance. The performance 
measures and weightings for the 2023 financial year are shown on page 107. The Committee retains 
discretion to use different or additional measures or weightings in future years to ensure that the bonus 
framework appropriately supports the business strategy and objectives for the relevant year.

Performance targets are set each year by the Committee by reference to factors such as the budget and 
strategic objectives for the year and market expectations. Pay-out will be based on a scaled performance 
target schedule, with the level of pay-out in aggregate for threshold performance being no higher than 
15% of the maximum. The target schedule will normally be disclosed retrospectively in the Annual 
Remuneration Report.

The Committee has the discretion to adjust performance targets for any exceptional events that may 
occur during the year.

In addition, the Committee may determine that it is appropriate to adjust the bonus payouts outcome if, 
for example, outcomes are not considered to be reflective of underlying performance of the business or 
the performance of the individual, where performance targets are no longer considered appropriate or 
where the outcome is not considered appropriate in the context of the experience of shareholders or 
other stakeholders.

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Restricted Share Awards (RSAs)

Purpose and link 
to strategy

Operation

To reward our Executive Directors for driving the sustainable long-term growth of the Company 
and shareholder value and to encourage and enable substantial long‑term share ownership.

Awards will normally vest at the end of a three-year period, subject to continued employment 
and assessment of the underpin.

Following vesting, an additional two-year holding period will normally apply, such that vested shares 
are normally released five years from grant.

Malus and clawback provisions apply until 2 years from the date of vesting.

Maximum

Under normal circumstances, the maximum award levels granted in respect of a financial year will be:

Performance targets

•  CEO: 87.5% of base salary; and

•  CFO: 75% of base salary.

Under exceptional circumstances (as determined by the Committee), the maximum award level that 
may be granted in respect of a financial year will be 100% of base salary.

No specific performance conditions are required for the vesting of RSAs, although the awards will 
normally be subject to one or more underpin conditions over the vesting period. Should any of the 
underpins not be met, the Committee would consider whether a discretionary reduction in the vesting of 
awards was required. The underpins applying to each award will be determined by the Committee each 
year but may include measures related to key financial, strategic, governance, ESG or share price metrics.

In addition, the Committee may determine that it is appropriate to reduce the vesting outcome if, for 
example, outcomes are not considered to be reflective of underlying performance of the business or the 
performance of the individual, where underpins are no longer considered appropriate or where the outcome 
is not considered appropriate in the context of the experience of shareholders or other stakeholders.

All employee share plans

Purpose and link 
to strategy

Operation

Maximum

To encourage wider employee share ownership and thereby increase alignment with shareholders.

Executive Directors are eligible to participate in all employee share plans, which are offered on similar 
terms to all employees, such as HMRC-approved Sharesave plans and Share Incentive Plans.

The maximum which applies to all employees, which includes the limits for any HMRC-approved plans, 
are as defined by HMRC from time to time.

Performance targets

Not applicable.

Share ownership guidelines

Purpose and link 
to strategy

To increase long-term alignment between Executives and shareholders, including after they have 
stepped down from the Board.

Operation

In-employment

Executive Directors are normally expected to build up and maintain a substantial holding of 
Moneysupermarket.com Group PLC shares of 200% of base salary.

To achieve this, Executive Directors are normally expected to retain 50% of the net of tax vested legacy 
LTIP shares and RSA shares until the guideline is met. Unvested deferred bonus shares, unvested RSAs 
subject to an underpin and vested RSA shares or legacy LTIP shares subject to a holding period will 
count towards the guideline (on a net of tax basis).

Post-employment

Following stepping down from the Board, Executive Directors will normally be expected to maintain a 
minimum shareholding of 200% of salary (or their actual shareholding on cessation if lower) for 2 years. 
The Committee retains discretion to waive this guideline if it is not considered to be appropriate in the 
specific circumstance.

Maximum

Not applicable.

Performance targets

Not applicable.

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103

GovernanceRemuneration Committee Report continued

Remuneration Policy table continued

Non-Executive Director fees

Purpose and link 
to strategy

Operation

Maximum

To provide market competitive fees which reflect the time commitment and responsibilities of each role.

The fees for the Non-Executive Directors (excluding the Chair) are determined by the Board and 
comprise a base fee with additional fees payable to reflect additional responsibilities or time 
commitment. The fees for the Chair are determined by the Committee and are structured as a 
single fee.

Fees may be reviewed on an annual basis.

The Non-Executive Directors do not participate in any Company pension arrangements, nor do they 
currently receive any benefits.

Non-Executive Directors may be reimbursed for business expenses (and any associated tax liabilities) 
incurred when travelling in performance of duties.

Additional benefits may be introduced if considered appropriate.

There is no prescribed maximum annual increase. The Board is guided by increases for the broader 
employee population but on occasions may need to recognise, for example, an increase in the scale, 
scope or responsibility of the role, as well appropriate market data.

Current fee levels are set out on page 108 and will not exceed the aggregate maximum levels set out 
in the Company’s Articles of Association.

Performance targets

Not applicable.

Non-Executive Directors do not participate in variable pay arrangements.

Notes:

(1) Awards under any of the Company’s share plans referred to in this report may: 

a) 

be granted as conditional share awards or nil-cost options or in such other form that the Committee determines has the same economic effect; 

  b) 

 incorporate the right to receive an amount (in cash or additional shares) equal to the value of dividends which would have been paid on the shares under an award that vest 
up to the time of vesting. Under the DBP this amount may be calculated assuming that the dividends have been reinvested in the Company’s shares on a cumulative basis; 

c) 

be settled in cash at the Committee’s discretion (this provision would only be applied for Executive Directors in exceptional circumstances); and 

  d) 

 be adjusted in the event of any variation of the Company’s share capital or any demerger, delisting, special dividend or other event that may affect the Company’s share price. 

(2)  The choice of the performance measures applicable to the annual bonus reflects the Committee’s belief that any incentive compensation should be appropriately challenging 

and aligned to the Group’s financial and strategic objectives, and the creation of shareholder value. Underpins applying to RSAs have been selected as they are considered to be 
an appropriate measure of the success of the business over the period.

(3)  Malus and clawback provisions exist on all variable components of the package. The Committee has discretion to reduce the vesting of a DBP award or RSA prior to vesting and/
or require the participant to return the value of the cash bonus, DBP award or RSA which has been received (within the timescales shown in the table) in certain circumstances. 
These circumstances include, in summary: a misstatement of financial results; an error in the assessment of a performance underpin; a significant breach of regulatory 
obligations; misconduct justifying summary dismissal; corporate failure; being responsible for a failure of risk management; contributing to a material loss for the Company or 
any member of the Group; or acting in a manner which has (or could have) caused serious reputational damage to the Company or any member of the Group.

(4)  The Committee reserves the right to make any remuneration payments and payments for loss of office (including exercising any discretions available to it in connection with such 
payments) notwithstanding that they are not in line with the Policy set out above where the terms of the payment were agreed (i) before the Policy set out above came into effect 
provided that the terms of the payment were consistent with any shareholder-approved Directors’ Remuneration Policy in force at the time they were agreed or (ii) at a time 
when the relevant individual was not a Director of the Company or other person to whom this policy applies and, in the opinion of the Committee, the payment was not in 
consideration for the individual becoming a Director of the Company or other such person. For these purposes “payments” includes the Committee satisfying awards of variable 
remuneration and, in relation to an award over shares, the terms of the payment are “agreed” at the time the award is granted. 

(5)  The Committee may make minor amendments to the Policy (for regulatory, exchange control, tax or administrative purposes or to take account of a change in legislation) 

without obtaining shareholder approval.

(6) References in this Policy to Executive Directors includes any other individual who is required to be treated as an Executive Director under the applicable regulations.

104 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

 
 
Illustrations of Application of Remuneration Policy
The chart below illustrates how the composition of the Executive Directors’ remuneration packages varies at different levels 
of performance under the annual remuneration framework in the 2023 Policy, both as a percentage of total remuneration 
opportunity and as a total value.

Chief Executive Officer

Chief Financial Officer

£2,500k

£2,000k

£1,500k

£2,403k

£2,500k

£2,133k

34%

25%

£2,000k

43%

38%

£1,500k

£1,671k

32%

£1,000k

28%

£670k

100%

40%

31%

28%

Minimum

Mid

Maximum

Maximum 
(+50% 
increase in 
share 
price)

 Fixed pay 

 Annual Bonus 

 RSAs

£500k

0

Notes:

£1,000k

£500k

0

£1,439k

£1,629k

35%

£1,145k

26%

33%

26%

41%

41%

36%

33%

29%

£471k

100%

Minimum

Mid

Maximum

Maximum 
(+50%  
increase  
in share  
price)

(1) Minimum includes the value of fixed pay components – annual base salary effective in 2023; pension (5% of base salary) and benefits (based on 2022 actual).

(2) Mid includes fixed pay; an annual bonus of 50% of maximum and full vesting of RSAs. 

(3) Maximum includes fixed pay; maximum annual bonus (CEO: 150% of salary, CFO 135% of salary) and full vesting of RSAs (CEO: 87.5% of salary, CFO: 75% of salary).

(4)  Maximum (+50% increase in share price) includes fixed pay; maximum annual bonus (CEO: 150% of salary, CFO 135% of salary) and full vesting of RSAs (CEO: 87.5% of salary, 

CFO: 75% of salary) assuming a 50% increase in the share price over the period.

Service agreements for Executive Directors
The service agreements of the Executive Directors are not fixed term and are terminable by either the Company or the Director on 
12 months’ notice and make provision, at the Board’s discretion, for early termination by way of payment of salary, benefits and pension 
in lieu of 12 months’ notice. Under these service agreements, the Committee has discretion to make such payments on a phased basis, 
subject to mitigation.

Approach to leavers
In calculating the amount payable to a Director on termination of employment, the Committee would consider the circumstances on 
a case‑by‑case basis, taking into account the relevant contractual terms, the circumstances of the termination, any applicable duty 
to mitigate and the commercial interests of the Company. The treatment of any share awards held by an Executive Director under the 
Company’s share plans will be determined based on the relevant plan rules. The following table summarises the leaver provisions under 
each incentive plan. 

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105

GovernanceRemuneration Committee Report continued

Approach to leavers continued
Summary of leaver provisions

Plan

Annual 
bonus

The default treatment is that an annual bonus with respect to performance in the financial year of cessation, or any 
annual bonus in respect of prior financial years which has not yet been paid at the date of cessation of employment, 
will not be paid unless the Committee determines otherwise.

If the Committee determines that it is appropriate, an annual bonus may be payable with respect to performance in the 
financial year of cessation (pro-rated for time, unless the Committee determines otherwise) and in respect of any annual 
bonus for prior financial years which had not yet been paid at the date of cessation of employment. The Committee 
retains discretion to deliver any such bonus solely in cash and to pay it at the normal date.

DBP

Awards will normally continue to vest on the original vesting date, subject to the clawback provisions (unless the 
individual is summarily dismissed in which case DBP awards will lapse).

RSAs

The default treatment is that any unvested awards lapse on cessation of employment.

However, in certain circumstances, such as death, ill health, injury, disability, retirement, the sale of the participant’s 
employing company or business out of the Group, or in any other circumstances at the discretion of the Committee, 
‘good leaver’ status may be applied.

For good leavers, awards will normally vest on their normal vesting date, to the extent the Committee determines taking 
into account the satisfaction of the relevant underpins and, unless the Committee determines otherwise, the proportion 
of the vesting period served.

In the case of death, awards will vest immediately, to the extent the Committee determines, taking into account the 
satisfaction of the relevant underpins.

RSAs granted in the form of nil-cost options may be exercised for six months following vesting, or such other period 
as may be determined by the Committee.

For both DBP awards and RSAs, the Committee retains discretion to vest/release awards before the end of the original vesting period 
where appropriate (e.g. in circumstances of death).

On a change of control of the Company, unvested awards under the DBP would vest. Unvested RSAs would normally vest, taking into 
account the extent to which any underpin conditions have been satisfied at that time and, unless the Committee determines otherwise, 
the proportion of the vesting period which has elapsed.

The Committee reserves the right to make any other payments in connection with a Directors’ cessation of office or employment where 
such payments are made in good faith in discharge of an existing legal obligation (or by way of damages for breach of such an obligation) or 
by way of settlement or compromise of any claim arising in connection with the termination of a Director’s office or employment. Any such 
payments may include but are not limited to paying any fees for outplacement assistance and for the Directors’ legal and/or professional 
advice fees in connection with his cessation of office or employment. Incidental expenses may also be payable where appropriate.

Approach to recruitment and promotions
The remuneration package for a new Executive Director, including the maximum level of variable remuneration, would be set in 
accordance with the terms of the Company’s Remuneration Policy table above. Salaries would be set at an appropriately competitive level 
to reflect the skills and experience of the individual. Where an Executive Director has been appointed to the Board at a lower than typical 
market salary to allow for growth in the role, larger increases may be awarded to move salary positioning closer to typical market level as 
the Executive Director gains experience.

Where an individual forfeits outstanding variable pay opportunities or contractual rights at a previous employer as a result of appointment 
to the Company, the Committee may offer compensatory payments or awards to facilitate recruitment. Any such payments or awards 
would be in such form as the Committee considers appropriate to be in the best interests of the Company and would, where appropriate, 
reflect the nature, time horizons and performance requirements attaching to that remuneration. There is no limit on the value of such 
compensatory awards, but the Committee’s intention is that broadly the value awarded would be no higher than the value forfeited.

For an internal Executive Director appointment, any variable pay element awarded in respect of the prior role may be allowed to pay out 
according to its terms. In addition, any other continuing remuneration obligations existing prior to appointment may continue.

For external and internal appointments, the Committee may agree that the Company will meet certain relocation and/or incidental 
expenses as appropriate.

Other appointments
The Executive Directors may accept outside appointments, with prior Board approval, provided these opportunities do not negatively 
impact on the individual’s ability to perform their duties at the Company. Whether any related fees are retained by the individual or are 
remitted to the Company will be considered on a case by case basis.

Non-Executive Directors
Non-Executive Directors are appointed under arrangements that may generally be terminated by either the Company or the Director on 
up to three months’ notice and their appointment is reviewed annually. The remuneration package for a newly appointed Non-Executive 
Director would normally be in line with the structure set out in the Remuneration Policy table.

Differences from the remuneration policy for other employees 
The remuneration policy framework for other employees is based on broadly consistent principles as described in the Policy table above. 

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All Executives and senior managers are generally eligible to participate in an annual bonus plan, based on consistent performance 
measures and targets. Participation in RSAs, or in other share-based plans, is extended to Executives and certain senior managers which 
may be on different terms to participation by Executive Directors. Individual salary levels and percentage levels of awards in the annual 
bonus and RSAs vary according to employees’ level of responsibility. All UK-based employees are eligible to participate in the Company’s 
HMRC approved Sharesave plan on similar terms. 

Consideration of shareholder views
The Committee undertook an engagement with major shareholders in respect of the changes to the Remuneration Policy and the 
feedback received was taken into account in finalising the proposals. During each year, the Committee considers shareholder feedback 
received in relation to the Annual General Meeting (AGM), plus any additional feedback received during any meetings from time to time. 
The Committee also regularly reviews the policy in the context of published shareholder guidelines.

Consideration of employment conditions elsewhere in the Group
The Committee considers the pay and conditions of employees throughout the Company when determining the remuneration 
arrangements for Executive Directors, and is provided with relevant information and updates by the management. The Company 
regularly carries out engagement surveys which enable employees to share their views with management. To the extent that 
employees are shareholders, they can vote on Directors’ remuneration at the AGM.

Implementation of the Remuneration Policy for the year ending 31 December 2023
A summary of how the proposed Directors’ Remuneration Policy will be applied during the year ending 31 December 2023 is set out below.

Base salary
The Remuneration Committee has determined base salaries for the Executive Directors, with effect from 1 January 2023, as set out below.

Board member

Peter Duffy
Niall McBride (from 20 February 2023)

2023
£

615,992
435,000

2022
£

592,300
—

% increase

4%
—

The Group’s budgeted salary increase pot for employees for 2023 is 6.5%. When awarding Peter Duffy a salary increase for 2023, 
the Committee was conscious of the continuing cost of living crisis which has disproportionately impacted our lower paid employees, 
therefore the increase awarded was below the average level provided to the wider workforce in order to reflect this. Scilla Grimble’s 
salary during 2022 was £434,800 and she did not receive a salary increase for 2023 following her resignation. Niall McBride joined the 
business on 20 February 2023 and was therefore not eligible for a salary increase for 2023.

Pension
All Executive Directors receive a pension contribution of 5% of base salary in line with that available to the wider workforce. Scilla Grimble 
previously received a fixed pension allowance of £76,000 which represented 17.5% of base salary – in line with shareholder guidance, this 
has been reduced for 2023 to align with that available to the wider workforce (5% of base salary).

Annual bonus
For the year ending 31 December 2023, the maximum annual bonus opportunities will be in line with the Policy, as shown in the following table:

Peter Duffy
Niall McBride (pro-rated for time in role)

Scilla Grimble is not eligible for an annual bonus in respect of 2023.

% of salary

150%
135%

Awards will be determined based on a balanced combination of financial and non-financial performance, directly aligned to our KPIs and 
strategic objectives. For 2023, the Board will continue to focus on adjusted EBITDA and revenue growth as key financial metrics for our 
strategic delivery. As set out earlier, we have simplified the weightings of the non-financial performance measures and individual objectives 
have been replaced by shared strategic objectives. For 2023 the shared strategic objectives will focus on delivering against the strategy to 
help households save money; continuous development of advanced data capabilities; common technology solutions; scalable platforms 
and build out of a strong cyber framework and environment; and leadership of an effective and engaged organisation. We have also 
retained our customer and Group-wide ESG (Diversity & Inclusion) metrics – both of these metrics align to the Group’s strategic objectives 
and KPI reporting (see page 57). D&I performance will be assessed by the Committee at the year-end taking into account the Company’s 
overall delivery of key D&I objectives and our progress towards key objectives. The weightings for the various metrics are set out below:

Adjusted EBITDA
Revenue growth
Customer
ESG: Diversity & Inclusion
Shared strategic objectives

Weighting
(% of bonus)

50%
20%
5%
5%
20%

Maximum bonus will only be payable when performance has significantly exceeded expectations. The Committee believes that the 
underlying targets are commercially sensitive and cannot be disclosed at this stage. To the extent that they are no longer commercially 
sensitive, they will be disclosed in next year’s Report.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

107

GovernanceRemuneration Committee Report continued

Annual bonus continued
In line with the Remuneration Policy, one-third of any bonus earned will be deferred into Moneysupermarket.com Group PLC shares 
for a period of two years.

Restricted Share Awards
The Committee intends to make the first awards of RSAs to Executive Directors shortly after the completion of the 2023 AGM (subject 
to shareholder approval of the Policy and plan). For the year ending 31 December 2023, RSAs will be in line with the proposed Policy, 
as shown in the following table:

Peter Duffy CEO
Niall McBride CFO

% of salary

87.5%
75%

Scilla Grimble will not receive an award of RSAs for 2023.

Awards will be subject to a three-year vesting period followed by a two-year holding period.

No specific performance conditions are required for the vesting of RSAs, although the awards will be subject to underpin conditions. 
Should any of the underpins not be met, the Committee would consider whether, and to what extent, a discretionary reduction in the 
vesting of awards was required. The underpins for 2023 are as follows:

•  performance against the Group’s key strategic priorities (including our ESG objectives) over the vesting period;

•  whether there is a material weakness in the underlying financial health or sustainability of the business. Factors such as, (but not 

limited to), long-term revenue, profitability, cash generation and dividend cash cover would be considered; and

•  whether there has been a materially serious conduct, reputational or regulatory event which could have been reasonably foreseen.

In addition, the Committee may determine that it is appropriate to reduce the vesting outcome if, for example, outcomes are not 
considered to be reflective of underlying financial or non-financial performance of the business or the performance of the individual, 
or where the outcome is not considered appropriate in the context of the experience of shareholders or other stakeholders. When 
considering this the Committee will also take into account whether management have been considered to benefit from any ‘windfall 
gains’ during the vesting period which misalign their remuneration outcomes with the experience of the wider shareholder base.

The Committee has selected the three underpins outlined above to reflect a good overall balance and safeguard the financial stability 
of the business whilst providing sufficient focus on our strategic priorities, ESG performance and regulatory compliance.

When assessing whether the strategic underpin has been met the Committee may consider whether appropriate progress has been 
made against a wide range of key strategic priorities and initiatives of the Group over the three-year period (including those which are 
developed during this period) including:

•  efficient acquisition – development of our brands and focus on search engine optimisation;

•  retain and grow – simplification and improvement of the user experience;

•  expand our offer – optimisation, integration and extension of Quidco and further expansion into mortgages;

•  climate – the Group’s commitment to become operational net zero by 2030 and to remain Beyond Carbon Neutral; and

•  diversity and inclusion – initiatives to improve diversity and inclusion in the business, as well as employee engagement, work-life 

balance and employee wellbeing.

Similarly with the financial health underpin, the Committee may consider a range of factors such as (but not limited to), long-term 
revenue, profitability, cash generation and dividend cash cover throughout the vesting period. The Committee has not set specific 
thresholds for these metrics below which RSAs would be scaled back, as it considers that it is important that we continue to retain 
flexibility to assess performance in the round taking into account the market circumstances and all other relevant factors.

The Committee takes the role of the underpin (to act as a safeguard against payment for underperformance) seriously and would actively 
use it to scale back awards where it did not consider that the full vesting of the RSAs was appropriate. A full explanation of the Committee’s 
decisions regarding the vesting of RSAs, including assessment of the underpin conditions will be provided in the relevant Directors’ 
Remuneration Report.

Non-Executive Directors
The fees for the Non-Executive Directors for 2023 will be increased in line with the increase given to the Executive Director as follows:

Board member

Chair
Base fee
Additional fees:
Senior Independent Director
Committee Chair fee
Committee membership fee per Committee
Employee Champion fee

108 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

2023
£

268,871
65,129

16,068
11,783
1,607
8,034

2022
£

258,530
62,624

15,450
11,330
1,545
7,725

% increase

4
4

4
4
4
4

Remuneration received by Directors for the year ended 31 December 2022 (audited)
Directors’ remuneration for the year ended 31 December 2022 was as follows:

Salary/fees
(£)

Taxable
 benefits 1
(£)

Pension 2
(£)

Total fixed
(£)

Annual
 bonus 3
(£)

Vesting 
LTIPs
(£)

Total 
variable
(£)

Total
(£)

Peter Duffy 

2022

2021

Scilla Grimble

2022

2021

Robin Freestone

2022

2021

James Bilefield 
(leaver 31 May 2022)

2022

2021

Sally James  
(leaver 5 May 2022)

2022

2021

Sarah Warby

2022

2021

Caroline Britton

2022

2021

Supriya Uchil 

2022

2021

Lesley Jones  
(appointed 1 September 2021)

2022

2021

Rakesh Sharma  
(appointed 3 October 2022)

2022

2021

Total 

2022

2021

592,300

23,313

29,615

645,228

771,431

575,000

18,690

28,750

622,440

162,202

434,800

399,100

14,000

14,000

76,000

524,800

—

76,000

489,100

130,059

258,530

251,000

32,745

76,300

32,771

91,300

81,792

74,300

88,181

74,800

68,804

66,800

73,671

21,767

19,557

—

—

—

—

—

—

—

—

—

—

—

— 

—

—

—

—

—

— 258,530

—

251,000

—

—

—

—

—

—

—

—

—

—

—

—

—

—

32,745

76,300

32,771

91,300

81,792

74,300

88,181

74,800

68,804

66,800

73,671

21,767

19,557

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

0

0

0

0

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

771,431 1,416,659

162,202

784,642

— 524,800

130,059

619,159

— 258,530

—

251,000

—

—

—

—

—

—

—

—

—

—

—

—

—

—

32,745

76,300

32,771

91,300

81,792

74,300

88,181

74,800

68,804

66,800

73,671

21,767

19,557

—

1,683,151

37,313

105,615 1,826,079

771,431

— 771,431 2,597,510

1,630,367

32,690

104,750

1,767,807

292,261

—

292,261  2,060,068

1 

 Taxable benefits for the Executive Directors incorporate all benefits and expense allowances arising from employment and relate to the provision of a car allowance and 
health insurance.

2 

 Pension payments reflect defined contribution and/or salary supplement arrangements. The Company provided salary supplements for our Executive Directors during 2022.

3 

 Annual bonus – the amounts shown in the table above represent the full value of the annual bonus earned in respect of the year. One-third of any amount shown is deferred 
into shares for three years.

Annual bonus
Maximum bonus entitlement for the year ended 31 December 2022 as a percentage of base salary was 150% for Peter Duffy and 135% 
for Scilla Grimble for the achievement of stretching targets specific to growth in revenue, adjusted EBITDA, Diversity & Inclusion and 
customer satisfaction (YouGov Brand Index) as well as specific personal objectives.

The performance targets, weightings, and actual performance against those targets for Peter Duffy are set out below. Scilla Grimble 
was not eligible for an annual bonus in 2022 following her resignation.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

109

GovernanceRemuneration Committee Report continued

Annual bonus continued

Performance targets

Group 
revenue

Group 
adjusted 
EBITDA

£366.6m

£374.3m
£381.9m
£397.2m
£387.6m

£101.5m

£105.1m
£108m
£114.5m
£115.5m

Customer 
satisfaction

Measured by ranking NPS results (from the YouGov Brand Index survey) 
with MSE and MSM as standalone brands, versus the peer group.
Achievement of stretch as both brands reached 1 and 2 positions 
for NPS against the peer group.

Payout  
(% of 
maximum)

0%

33%
67%
100%
Actual

17%

44%
67%
100%
Actual

Actual

Diversity & 
Inclusion

Increase the multi-ethnic colleague representation average (self-declaring from 
a multi‑ethnic background) across MSM and MSE to align to the Tech Nation 2021 
benchmark of 15.2% (Measured by Threshold: 14.8%; Target: 15.2% Stretch: 15.6%) .

Significant progress on our D&I agenda was made (see below), however staff exits 
meant that the threshold target of 14.8% was not hit. Achievements to improve the 
diversity of talent at all levels, create an inclusive, fair and equitable environment 
and participate in education and awareness activities included:

•  collected data from the Quidco acquisition and when included, our end of year 

multi-ethnic metric is an average of 14.2% for the year and 14.3% in December 2022);

•  at the end of December 2022, we were above the FTSE Women Leaders Review 
2021 benchmark of 40% women in senior leadership roles: 66.7% of our Non-
Executive Directors were female; 44.4% of our Executive were female and; 51.2% 
of our Executive -1 were female;

•  overall commitment dimension in our latest engagement survey +11 points from 

November 2021);

•  80.7% ethnicity disclosure rate (including Quidco) across MSM and MSE at 

December 2022;

•  trained 101 leaders in inclusive language via our partner UNLRN; and

•  recognised at number 33 in the Inclusive Top 50 UK Employer List 2022, as 

measured by Inclusive Companies.

Personal

The personal targets were set individually for each Executive Director based on the 
key objectives for the year in their area of responsibility, and include a shared 
objective related to D&I – see tables below.

Total

Peter 
Duffy

20%

79%

50%

100%

7%

100%

7%

Weighting  
(% of bonus)

Payout  
(% of 
maximum)

Weighting  
(% of bonus)

Payout  
(% of 
maximum)

Weighting  
(% of bonus)
Payout  
(% of 
maximum)

Weighting  
(% of bonus)

Payout  
(% of 
maximum)

Weighting  
(% of bonus)
Payout  
(% of 
maximum)

Payout  
(% of 
maximum)
Payout  
(% of salary)

0%

16%

87.5%

86.8%

130.2%

110 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

In accordance with the Remuneration Policy, to ensure fair and consistent performance measurement, the Group financial performance 
targets may be adjusted to reflect exceptional one-off and unanticipated items. No adjustments were made. 

In line with the Directors’ Remuneration Policy, one-third of Peter Duffy’s bonus award was deferred into shares for two years, with the 
balance paid in cash.

The personal targets set for Peter Duffy were based on key areas of strategic focus for the year. The table below highlights the key 
objectives and achievements against those personal targets.

Peter Duffy

Objective

Leadership delivery, at pace

Maximum
opportunity 
(% of salary)

12%

Execution and Focus

12%

Performance outcome and key achievements

The benefits of Peter’s highly accessible leadership style were demonstrated 
in the annual engagement survey, where significant improvements were 
made across nearly all metrics, but particularly colleagues’ understanding 
of our strategy, which he had personally led. 

The strategy began to deliver, with big progress on re-platforming our 
technology, particularly the areas of data, marketing technology, aggregation 
and question sets. There was an equally large focus on improving our cyber 
posture. This is all change which is hard to deliver, but has broadly been 
delivered on time and within planned budgets; it sets us up well for future 
consumer-facing innovation and delivery. 

As processes improved and became more automated, Peter’s continued 
drive for a leaner more integrated and efficient organisation saw the closure 
of two offices and further reduction in headcount, which like for like is now 
26% less than when he joined the Group in 2020. 

Whilst we made significant progress on our D&I agenda with multi‑ethnic 
hiring hitting over 20%; and the delivery of an exciting colleague-inclusion 
programme, staff exits meant that the overall threshold of 14.8% of the 
population self-declaring from a multi-ethnic background was not hit.

Across the year, last year’s acquisitions (CYTI, ITG and Quidco) were 
integrated into the Group and now sit on finance and people systems. Where 
appropriate, deeper integrations are in train. 

The MSE app was soft-launched, as was the MSE Compare + car insurance 
proposition, the Moneysupermarket Price Guarantee, new tenancy and data 
enrichment propositions for providers as well as ongoing improvements in 
the marketing programmes of all brands. Significant improvements to our 
cyber posture were delivered moving to an overall EY audited score of 3.4 
in 2022, up from 2.9 in 2021, and an improvement in 15 of the 21 
identified areas.

Peter brings a more ‘tech’ type delivery culture which is embedding into 
the Group and evidenced by strong financial delivery in the year as well 
as momentum in our car insurance market share.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

111

GovernanceRemuneration Committee Report continued

Vesting of LTIP awards
The LTIP award granted on 28 March 2020 was based on performance to the year ended 31 December 2022. The performance targets 
for this award, and actual performance against those targets, was as follows:

Weighting

Performance condition

Threshold

Maximum

Actual

Vesting %

Metric

Vesting

Compound annual 
growth in adjusted 
earnings per share

Compound 
annual growth in 
Group revenue

50%

30%

Comparative total 
shareholder return

20%

Compound annual growth in adjusted 
earnings per share from 1 January 2020 to 31 
December 2022.

Compound annual growth in Group revenue 
from 1 January 2020 to 31 December 2022.

Comparative total shareholder return against 
the constituents of the FTSE 250 Index 
(excluding Investment Trusts) from 1 January 
2020 to 31 December 2022. Comparative total 
shareholder return measured with a three-
month average at the start and end of the 
performance period.

20%

5%

100%

15%

(7)%

4%

9%

0%

Median

Upper
quartile

Below
median

0%

0%

0%

Note: Vesting is determined on a straight-line basis between threshold and maximum.

Long-term incentives granted during the year (audited)
During the year, the following share awards were made to the Executive Directors:

Executive Director

Type of award

Basis of award granted

Face value
of award 1
£

% of maximum
that would vest
 at threshold
performance

Peter Duffy

Scilla Grimble

2022 LTIP

2022 LTIP

175% of salary

£1,036,523.32

150% of salary

£652,199.18

20%

20%

Total vesting

0%

Vesting determined
by performance over

Three financial years to
31 December 2024

1 

 Face value for the LTIP awards was determined using the average share price over the preceding five trading days prior to the date of grant. The grant date was 31 March 2022 
with an average share price of £1.9880.

The performance targets for the 2022 LTIP awards are as follows:

Metric

Vesting (% of maximum)

Compound annual growth 
in adjusted earnings 
per share

Compound annual growth 
in Group revenue

Comparative total 
shareholder return

Weighting 
(% of award)

Performance condition

50%

30%

20%

Compound annual growth in adjusted basic EPS over 
the three‑year performance period.

Compound annual growth in Group revenue over the 
three-year performance period.

Comparative total shareholder return against the 
constituents of the FTSE 250 Index (excluding Investment 
Trusts) over the three-year performance period. Three-
month averaging is applied at the start and end of the 
performance period.

Threshold

Maximum

20%

5%

100%

15%

4%

9%

Median

Upper 
quartile

Note: Vesting is determined on a straight-line basis between threshold and maximum.

Payments to past Directors (audited)
There were no payments to past Directors during the year.

112 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Statement of Directors’ shareholdings and share interests (audited)

Director

Peter Duffy
Scilla Grimble
Robin Freestone
Sally James
Caroline Britton
Sarah Warby
James Bilefield
Lesley Jones
Supriya Uchil
Rakesh Sharma

Beneficially 
owned at 
31 December 
2022

48,462
87,016
209,403
20,000
—
—
10,000
—
—
10,689

Outstanding
LTIP
awards

1,136,007
749,908
—
—
—
—
—
—
—
—

Outstanding
share awards
under all
employee
share plans

Unvested 
deferred bonus 
shares 1

8,866
0
—
—
—
—
—
—
—
—

14,367
11,520
—
—
—
—
—
—
—
—

Total
interest
in shares

1,207,777
848,444
209,403
20,000
—
—
10,000
—
—
10,689

Beneficial shares 
(including DBP net
 of tax) owned
as a % of
base salary at
31 December
2022 2

20%3
43%3
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a

1  Estimated number of shares net of tax, NI and fees payable on vesting.

2 

Includes the value of deferred bonus shares on a net of tax basis.

3  Percentage is the beneficially owned plus the unvested deferred bonus shares.

Executive Directors are required to hold shares in the Company worth 200% of base salary and are normally expected to retain 50% 
of the net of tax value of any vested LTIP shares until the guideline is met. 

In the period from 31 December 2022 to the date of this report, there has been no change in the Directors’ interests in shares in 
the Company.

Outstanding share awards
The table below sets out details of outstanding share awards held by the Executive Directors.

Granted
during
the year

Vested
during
the year

Lapsed
during
the year

No. of
shares at
31 December
2022

End of
performance
period

Vesting/
exercise
date

Executive 
Director

Peter Duffy

Scheme

Grant date

Exercise
price

Scilla Grimble

LTIP 01/09/2020
31/03/2021
31/03/2022
DBP 31/03/2022

LTIP1 01/04/2020
LTIP1 31/03/2021
LTIP1 31/03/2022
DBP 31/03/2022

Nil
Nil
Nil
Nil

Nil
Nil
Nil
Nil

No. of
shares at
1 January
2022

236,555
378,062
—
—

—
—
521,390
27,194 

203,400
218,440

—
—
— 328,068
21,805 
—

1  Scilla Grimble’s outstanding shares have lapsed following her resignation.

—
—
—

—
—
—
—

—
—
—

—
—
—
—

31/12/2022 01/09/2023
236,555
378,062 31/12/2023 31/03/2024
31/12/2024 31/03/2025
521,390
27,194  
31/03/2024

31/12/2022 01/04/2023
203,400
218,440 31/12/2023 31/03/2024
31/12/2024 31/03/2025
328,068
31/03/2024
21,805 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

113

GovernanceRemuneration Committee Report continued

Performance graph 
The following graph shows the cumulative total shareholder return of the Company over the last ten financial years relative to the FTSE 
250 Index (excluding Investment Trusts). The Remuneration Committee considers the FTSE 250 Index (excluding Investment Trusts) 
to be an appropriate index for total shareholder return and comparison disclosure as it represents a broad equity market index in 
which the Company is a constituent member.

This graph shows the value, by 31 December 2022, of £100 invested in Moneysupermarket.com Group PLC on 31 December 2012 
compared with the value of £100 invested in the FTSE 250 Index (excluding Investment Trusts) on the same date, assuming the 
reinvestment of dividends. The other points plotted are the values at intervening financial year ends.

350

300

250

200

150

100

50

0

Dec-12

Dec-13

Dec-14

Dec-15

Dec-16

Dec-17

Dec-18

Dec-19

Dec-20

Dec-21

Dec-22

 Moneysupermarket.com Group PLC 

 FTSE 250 Index (excluding Investment Trust)

114 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Total remuneration for Chief Executive Officer
The total remuneration figures for the Chief Executive Officer during each of the last ten financial years are shown in the table below. 
The total remuneration figure includes the annual bonus based on that year’s performance and LTIP awards based on three‑year 
performance periods ending in the relevant year. The annual bonus payout and LTIP vesting level as a percentage of the maximum 
opportunity are also shown for each of these years.

2013

2014

2015

2016

2017

2017

2018

2019

2020

2020

2021 

2022

Year ended 31 December

CEO

Peter
Plumb

Peter
Plumb

Peter
Plumb

Peter
Plumb

Peter
Plumb

Mark
Lewis

Mark
Lewis

Mark
Lewis

Mark
Lewis

Peter
Duffy

Peter
Duffy

Peter
Duffy

Total remuneration (£)

3,059,163 3,365,277 2,715,342 2,391,627 1,064,634 841,030

1,156,842 1,244,266 459,651

206,546

784,642 

1,416,659

Annual bonus (% of maximum)

83%

85%

95%

72%

60%

47%

61%

55.8%

n/a

LTIP vesting (% of maximum)

100%

98%

85%

81%

68%

n/a

n/a

9.6%

n/a

n/a

n/a

18.8%

86.8%

n/a

0%

Pay ratio
The table below discloses the ratio of CEO pay for 2022, using the single total figure of remuneration (‘STFR’) of the CEO (as disclosed on 
page 109) to the comparable earnings of the rest of the employees in the Group, at a number of prescribed data points (25th, 50th and 
75th percentiles).

Year

2022
2021
2020
2019
2018

Notes:

Method

Option A
Option A
Option A
Option A
Option A

25th percentile
(P25) pay ratio

Median (P50)
pay ratio

75th percentile
(P75) pay ratio

37:1
20:1
19:1
35:1
35:1

24:1
14:1
14:1
25:1
24:1

18:1
11:1
10:1
18:1
17:1

The ratios are calculated using option A in the disclosure regulations. The employees at the lower quartile, median and upper quartile (P25, P50, and P75, respectively) were 
determined based on total remuneration for 2022 using a valuation methodology consistent with that used for the CEO in the single figure table. This option was selected on 
the basis that it provided the most accurate means of identifying the median, lower and upper quartile employees. The calculation is undertaken on a full‑time equivalent basis.

The total remuneration in respect of 2022 for the employees identified at P25, P50 and P75 is £38,169, £59,705, and £80,285 respectively. The base salary in respect of 2022 for 
the employees identified at P25, P50 and P75 is £34,835, £55,000, and £74,358 respectively.

The Committee considers pay ratios as one of many reference points when considering remuneration. Throughout the Company, pay is 
positioned to be fair and market competitive in the context of the relevant talent market, fairly reflecting market data and other relevant 
benchmarks for the role. The Committee notes the limited comparability of pay ratios across companies and sectors, given the diverse 
range of business models and employee population profiles which exist across the market. A significant proportion (over 70%) of the 
CEO’s total remuneration is delivered in variable remuneration, and particularly via long-term share awards under the DBP and LTIP. In 
order to drive alignment with investors, the value ultimately received from LTIP awards is linked to stretching Company performance 
targets and long-term share price movement. As a result, the pay ratio is likely to be driven largely by the CEO’s LTIP outcome and may 
therefore fluctuate significantly on a year-to-year basis.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

115

GovernanceRemuneration Committee Report continued

Percentage change in the Directors’ remuneration 
The table below shows the percentage change in the Executive Directors and Non-Executive Directors salary, benefits and annual bonus 
compared to that of the average percentage change for all employees of the Group for each of these elements of pay, in respect of the 
relevant financial year.

2022

Taxable
 benefits
%

Salary
%

Peter Duffy 
Scilla Grimble
Robin Freestone 
Sally James  
(leaver 5 May 2022)
Sarah Warby1
Caroline Britton2
Supriya Uchil 
James Bilefield  
(leaver 31 May 2022)
Lesley Jones3 
(appointed 1 September 2021)
Rakesh Sharma  
(appointed 3 October 2022)
Other employees

3
3
3

—
16
26
3

—

18

—
10

25
0
—

—
—
—
—

—

—

—
22

Annual 
bonus
%

376
(100)
—

—

—
—

—

—

—
70 

All employees have been selected in the comparator pool.

1  Reflects increase in responsibilities as interim Chair of the Remuneration Committee.

2  Reflects increase in responsibilities as Senior Independent Director.

3  Reflects increase in responsibilities as Chair of the Risk and Sustainability Committee.

2021

Taxable
 benefits
%

5
(1)
—

—
—
—
—

—

—

—
3

Salary
%

0
8.9
0

0
0
0
0

0

0

—
3

Annual 
bonus
%

100
100
—

—
—
—
—

—

—

—
100

2020

Taxable
 benefits
%

Salary
%

2
2
2

1
0
1
—

—

—

—
3

0
0
—

—
—
—
—

—

—

—
2

Annual 
bonus
%

(100)
(100)
—

—
—
—
—

—

—

—
(100)

Employee engagement
The Remuneration Committee reviews workforce remuneration and related policies and the alignment of incentives and rewards 
with culture, taking these into account when setting the policy for Executive Director remuneration.

Relative importance of spend on pay 
The following table shows the Company’s actual spend on pay (for all employees) relative to dividends, tax and retained profits:

Staff costs (£m)
Dividends (£m)
Tax (£m)
Profit after tax (£m)1

1  2021 after adjusting for non-controlling interest of (£0.6m) previously referred to as retained profits.

2021

57.6
62.8
18.1
52.1

2022

61.4
62.8
15.9
69.3

Change %

7
0 
(12)
33

116 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Consideration by the Directors of matters relating to Directors’ remuneration
During 2022 the following Independent Non-Executive Directors were members of the Remuneration Committee: Rakesh Sharma 
(appointed to the Committee as Chair Designate on 3 October 2022 and Chair of the Committee on 1 January 2023), Sarah Warby (who 
also served as Interim Chair of the Committee from 17 June to 31 December 2022), Caroline Britton, Supriya Uchil and James Bilefield 
(Chair of the Committee until his resignation on 31 May 2022). Biographies of the current members of the Remuneration Committee 
are set out on pages 70 and 71. 

The Remuneration Committee’s duties include:

•  determining the policy for the remuneration of the Chair, Executive Directors and Executive management;

•  determining the remuneration package of the Chair, Executive Directors and Executive management, including, where appropriate, 

bonuses, incentive payments and pension arrangements within the terms of the agreed framework and policy;

•  ensuring the remuneration practices and policies for the wider workforce are aligned to our strategy and culture; and

•  determining awards under the Company’s long-term incentive schemes.

In 2022, we carried out the annual evaluation of the Remuneration Committee’s effectiveness as part of an internally facilitated Board 
evaluation process. The outcome of the review determined that it continues to be effective in fulfilling its role and that actions 
implemented in response to previous reviews had been successfully implemented.

During 2022, the Remuneration Committee and the Company received advice from Deloitte LLP, who are independent remuneration 
consultants, in connection with remuneration matters including the Group’s performance related remuneration policy. Deloitte LLP is 
a member of the Remuneration Consultants Group and is committed to that group’s voluntary code of practice for remuneration 
consultants in the UK. Deloitte LLP has no other connection or relationship with the Group. During 2022, Deloitte LLP also provided 
services to the Group in respect of corporate tax and VAT advice and risk advisory work. The fees paid to Deloitte LLP for providing advice 
which materially assisted the Committee in relation to Executive remuneration over the financial year under review was £126,050.

Outside appointments
Executive Directors are permitted to accept outside appointments on external boards so long as these are not deemed to interfere with 
the business of the Group. During 2022, Peter Duffy was a Non-Executive Director of Close Brothers Group plc and was President of ISBA 
– the UK trade body for leading British advertisers. Scilla Grimble was a Non‑Executive Director of Taylor Wimpey plc.

Statement of voting at general meeting
The following votes were received from shareholders in respect of the Directors’ Remuneration Report (excluding Policy) at last year’s 
Annual General Meeting:

Remuneration Report
(2022 AGM)

Votes

403,006,046
18,833,099
421,839,145
10,368,000

%

95.52
4.48

Votes cast in favour1
Votes cast against
Total votes cast
Abstentions2

1 

Includes Chair’s discretionary votes.

2  A vote withheld is not a vote in law and is not counted in the calculation of the proportion of votes validly cast.

This report was approved by the Board and signed on its behalf by:

Rakesh Sharma
Chair of the Remuneration Committee
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

117

GovernanceDirectors’ Report

Our responsibilities 
as a listed company

Our additional statutory information. 

Shazadi Stinton
General Counsel and Company Secretary

Annual General Meeting
The Annual General Meeting (‘AGM’) of 
Moneysupermarket.com Group PLC (the 
‘Company’) will be held at Exchange House, 
Primrose Street, London EC2A 2EG on 
Thursday 4 May 2023 at 10.00am. The 
notice convening the meeting, with details 
of the business to be transacted at the 
meeting and explanatory notes, is set out in 
a separate AGM circular which will be issued 
to all shareholders on 23 February 2023. 

Dividend
The Directors recommend a final dividend 
of 8.61p (2021: 8.61p) per ordinary share in 
respect of the year ended 31 December 
2022. If approved by shareholders at the 
forthcoming AGM, this will be paid on 
11 May 2023 to shareholders on the 
register at close of business on 31 March 
2023. The final dividend and the interim 
dividend of 3.10p per ordinary share paid 
on 2 September 2022 give a total dividend 
for the year of 11.71p (2021: 11.71p) per 
ordinary share.

Issued share capital 
and control
As at 31 December 2022, the issued share 
capital of the Company was £107,372 
comprising 536,861,647 ordinary shares of 
0.02p each. Full details of the share capital 
of the Company and changes to share 
capital during the year are set out in 
note 22 to the Group financial statements 
on page 157.

The information in note 10 is incorporated 
by reference and forms part of this 
Directors’ Report.

At the 2022 AGM, shareholders authorised 
the Directors to allot up to 357,545,000 
ordinary shares in the capital of the 
Company. Directors will again seek 
authority from shareholders at the 
forthcoming AGM to allot up to 
357,907,764 ordinary shares.

Holders of ordinary shares are entitled 
to receive dividends when declared, to 
receive the Company’s Annual Report, to 
attend and speak at general meetings of 
the Company, to appoint proxies and to 
exercise voting rights.

On a show of hands at a general meeting 
of the Company, every holder of ordinary 
shares present in person or by proxy, and 
entitled to vote, has one vote and, on a 
poll, every holder of ordinary shares 

present in person or by proxy, and entitled 
to vote, has one vote for every ordinary 
share held. Electronic and paper proxy 
appointments and voting instructions 
must be received not later than 48 hours 
before the meeting. A holder of ordinary 
shares can lose the entitlement to vote 
and the right to receive dividends where 
that holder fails to comply with a disclosure 
notice issued under section 793 of the 
Companies Act 2006. There are no issued 
shares in the Company with special rights 
with regard to control of the Company.

The Company operates a Share Incentive 
Plan which entitles all employees to 
purchase ordinary shares in the Company 
using money deducted from their pre-tax 
salary. Plan shares are held in trust for 
participants by Equiniti Share Plan 
Trustees Limited (‘the Trustee’).

Voting rights are exercised by the 
Trustee in accordance with participants’ 
instructions. If a participant does not 
submit an instruction to the Trustee, no 
vote is registered. In addition, the Trustee 
does not vote on any unawarded or forfeit 
shares held under the Plan as surplus 
assets. As at the date of this report, the 
Trustee held 0.06% of the issued ordinary 
share capital in the Company.

118 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

The Company operates a Long Term 
Incentive Plan (the ‘Plan’) and shares 
are held by the Trustee, Ocorian Limited 
(‘Ocorian’), pending vesting of the shares 
awarded under the Plan. Ocorian does not 
vote on any shares held in trust. As at the 
date of this report, Ocorian held 0.02% 
of the issued ordinary share capital in 
the Company.

Full details of the rights and obligations 
attaching to the Company’s share capital 
are contained in its Articles of Association 
which are published on our website. 

All of the Company’s share schemes 
contain provisions relating to a change of 
control. Outstanding options and awards 
normally vest and become exercisable on 
a change of control subject to satisfaction 
of any performance conditions at that 
time. Save in respect of provisions of the 
Company’s share schemes, there are no 
agreements between the Company and 
its Directors or employees providing 
compensation for loss of office or 
employment (whether through resignation, 
purported redundancy or otherwise) that 
occurs because of a takeover bid.

The Company has entered into two 
significant agreements which would be 
terminable upon a change of control: the 
bank loan to fund the acquisition of Quidco 
and the extension of its credit facility 
agreement to October 2024, both with 
Barclays Bank PLC, the Bank of Ireland 
and Silicon Valley Bank.

Restrictions on the transfer 
of securities
Whilst the Board has the power under the 
Articles of Association to refuse to register 
a transfer of shares, there are no restrictions 
on the transfer of shares other than:

•  certain restrictions may from time to 

time be imposed by laws and regulations 
(for example insider trading laws); and

•  pursuant to the Listing Rules of the 

Financial Conduct Authority whereby 
certain Directors, officers and 
employees of the Group require the 
approval of the Company to deal in 
ordinary shares of the Company.

The Company is not aware of any 
agreements between shareholders that 
may result in restrictions on the transfer 
of securities and/or voting rights.

Authority to purchase 
own shares
The Company was authorised at the 2022 
AGM to purchase up to 53,686,000 of its 
own shares in the market. No shares were 
purchased under this authority in 2022. 
Directors will seek authority from 
shareholders at the forthcoming AGM for 
the Company to purchase, in the market, 
up to 53,686,164 shares. The Directors 
have no present intention of conducting 
purchases of the Company’s shares but 
consider it prudent to obtain the flexibility 
this authority provides. The Directors will 
only use this power after careful 
consideration, taking into account the 
financial resources of the Company, the 
Company’s share price and future funding 
opportunities. The Directors will only 
purchase such shares after taking into 
account the effects on earnings per share 
and the interests of shareholders generally.

Major shareholders 
As at 31 December 2022, the Company had been notified of the following significant holdings of voting rights in its ordinary shares 
in accordance with the Financial Conduct Authority’s Disclosure Guidance and Transparency Rules:

Shareholder

Gruppo MutuiOnline SpA

BlackRock, Inc.

Prudential plc Group of Companies 

Jupiter Fund Management PLC

Allianz Global Investors GmbH

Ameriprise Financial, Inc. and its group

Heronbridge Investment Management LLP

Standard Life Investments Holdings Limited

FIL Limited

State Street Nominees

Massachusetts Financial Services Company

Number of
shares/voting
rights notified

43,050,000

27464174

27,061,089

27,078,002

26,794,299

27,199,089

26,517,435

25,417,919

24,758,460

20,581,165

26,749,045

Percentage of
shares/voting
rights notified

8.02

6.05

5.07

5.04

4.99

4.94

4.94

4.60

4.52

3.76

4.98

All interests disclosed to the Company in accordance with Rule 5 of The Disclosure Guidance and Transparency Rules that have occurred 
since 31 December 2022 can be found of the Group’s website.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

119

GovernanceDirectors’ Report continued

Directors
The Directors who served during the financial year were as follows:

Director

Robin Freestone

James Bilefield

Caroline Britton

Peter Duffy

Scilla Grimble

Sally James

Lesley Jones

Sarah Warby

Supriya Uchil

Rakesh Sharma

Position

Chair

Service in the year ended 
31 December 2022

Served throughout year

Independent Non-Executive Director

Until 31 May 2022

Independent Non-Executive Director1 

Served throughout year

Chief Executive Officer

Served throughout year

Chief Financial Officer

Served throughout year

Senior Independent Non-Executive Director

Until 5 May 2022

Independent Non-Executive Director

Served throughout year

Independent Non-Executive Director

Served throughout year

Independent Non-Executive Director

Served throughout year

Independent Non-Executive Director

Appointed 3 October 2022

1  Was appointed Senior Independent Director in 5 May 2022.

Their biographical details are set out on 
pages 70 and 71. Further details relating 
to Board and Committee composition are 
disclosed in the Corporate Governance 
Report on page 80.

The Articles of Association provide that a 
Director may be appointed by an ordinary 
resolution of shareholders or by the 
existing Directors, either to fill a vacancy 
or as an additional Director. All eligible 
Directors will retire and offer themselves 
for election or re-election at the 2023 AGM 
in accordance with the 2018 UK Corporate 
Governance Code.

The Executive Directors serve under 
rolling contracts that are terminable upon 
12 months’ notice from either party. The 
Non-Executive Directors serve under 
letters of appointment. Copies of service 
contracts and letters of appointment are 
available for inspection at the Company’s 
registered office during normal business 
hours and will be available for inspection 
at the Company’s AGM.

The Directors’ Remuneration Report, 
which includes the Directors’ interests 
in the Company’s shares, is set out on 
page 118. During the year, no Director 
had any material interest in any contract 
of significance to the Group’s business.

Directors’ powers
The Board of Directors may exercise all 
the powers of the Company subject to 
the provisions of relevant legislation, the 
Company’s Articles of Association and 
any directions given by the Company 
in general meeting.

Directors’ indemnities
During the financial year ended 
31 December 2022 and up to the date 
of this Directors’ Report, the Company has 
maintained appropriate liability insurance 
for its Directors and officers.

The Company has granted indemnities to 
each of its Directors and the Company 
Secretary to the extent permitted by law 
and its Articles of Association. These 
indemnities were in force throughout the 
year ended 31 December 2022 and remain 
in force as at the date of this report in 
relation to certain losses and liabilities 
which the Directors or Company Secretary 
may incur in the course of acting as Directors, 
Company Secretary or employees of the 
Company or of any associated company. 
In addition, the Company grants similar 
indemnities to senior managers of the 
Group who are subject to the provisions 
of the Senior Managers and Certification 
Regime (‘SM&CR’). 

Conflicts of interest
As permitted by the Companies Act 2006, 
the Company’s Articles of Association 
enable Directors to authorise potential 
conflicts of interest. The Company has a 
formal procedure for notification and 
authorisation to be sought, prior to the 
appointment of any new Director or prior 
to a new conflict arising. This procedure 
enables non-conflicted Directors to 
impose limits or conditions when giving 
or reviewing authorisation. It also requires 
the Board to review the register of 
Directors’ conflicts annually and on an ad 
hoc basis when necessary. The Board has 
complied with this procedure during 
the year.

120 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Information required by Listing Rules 9.8.4R
Information required to be disclosed by LR 9.8.4R:

Interest capitalised 

Publication of unaudited financial information 

Details of long-term incentive schemes

Waiver of emoluments by a Director

Waiver of future emoluments by a Director

Non-pre-emptive issues of equity for cash

Not applicable 

Not applicable 

112 

Not applicable 

Not applicable 

Not applicable 

Item (7) in relation to major subsidiary undertakings

Not applicable 

Parent participation in a placing by a listed subsidiary

Not applicable

Contracts of significance 

Provision of services by a controlling shareholder

Shareholder waivers of dividends

Shareholder waivers of future dividends

Agreements with controlling shareholders

Not applicable 

Not applicable

Not applicable 

Not applicable 

Not applicable 

Employees
The Group places considerable value on 
the involvement of its employees and 
uses a number of ways to engage with 
employees on matters that impact them 
and the performance of the Group. These 
include formal business performance 
updates by members of Executive 
management for all employees, informal 
fortnightly floor briefs with the CEO, regular 
update briefings for all employees, regular 
team meetings, the Group’s intranet site 
and Teams channels which enable easy 
access to the latest information and 
policies, and the circulation to employees 
of results and other corporate 
announcements. This also helps to achieve 
a common awareness amongst employees 
of the financial and economic factors 
affecting the performance of the Group. 
The Board appointed Sarah Warby, one of 
our Independent Non-Executive Directors, 
as our “Employee Champion” in 2018 and 
has provided the opportunity for 
employees to engage directly with our 
Non-Executive Directors in order to give 
them the opportunity to understand more 
about our employees. Employees were 
also offered breakfasts and coffees with 
members of the Executive management 
and small group sessions with the Chief 
Executive Officer.

A robust employee engagement survey 
process is also in place to ensure that 
employees are given a voice in the 
organisation and that the Group can take 
action based on employee feedback. All 
employees are able to participate in both 

the Company’s Share Incentive Plan and 
Save As You Earn Scheme which provide 
employees with the opportunity to 
purchase ordinary shares in the Company, 
actively encouraging their interest in the 
performance of the Group. Further 
information on employee engagement 
can be found on pages 83 and 84.

Equal opportunities
The Group is committed to providing 
equality of opportunity to all employees 
without discrimination and applies fair and 
equitable employment policies which seek 
to promote entry into and progression 
within the Group. Appointments are 
determined solely by application of job 
criteria, personal ability, behaviour 
and competency.

In 2022 the Group has continued to 
commit to the Race at Work Charter which 
we originally signed up to in 2020. This is 
a public commitment to prioritising action 
on race equity as part of the Group’s Race 
Equity Plan. The plan includes a specific 
commitment at Board level to zero 
tolerance of racial harassment or bullying. 
This means that all allegations of racial 
bullying or harassment will be taken 
seriously, and managed consistently and 
in line with the Group’s Anti‑Bullying and 
Harassment Policy, with formal action 
taken where necessary.

In the opinion of the Directors, all 
employee policies are deemed to be 
effective and in accordance with their 
intended aims.

Disabled persons have equal opportunities 
when applying for vacancies, with due 
regard to their skills and abilities. 
Procedures ensure that disabled 
employees are fairly treated in respect 
of training and career development. For 
those employees that become disabled 
during the course of their employment, 
the Group is supportive so as to provide 
an opportunity for them to remain with the 
Group, wherever reasonably practicable.

Business Relationships with 
Suppliers, Customers 
and Others 
You can read about how our Directors had 
regard to the need to foster the Group’s 
business relationships with suppliers, 
customers and others and the effect 
of that regard on pages 29 to 35.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

121

GovernanceDirectors’ Report continued

Borrowings
In October 2021, the Group entered into a 
new £50m amortising term loan that matures 
in October 2024. We also have a revolving 
credit facility (‘RCF’) of £90m, now extended 
to October 2024, with an accordion option 
to apply for up to £100m of additional funds 
during the term of the RCF. As at 
31 December, the Group owed £40m 
on the term loan and £4.0m on the RCF. 

Political donations
During the financial year ended 
31 December 2022, the Group did not 
make any political donations (2021: £nil).

Post balance sheet events
There have been no events that either 
require adjustment to the financial 
statements or are important in the 
understanding of the Company’s 
current position.

Auditor and disclosure 
of information
The Directors who held office at the date 
of this report confirm that, so far as they 
are each aware, there is no relevant audit 
information of which the Company’s auditor 
is unaware; and each such Director has taken 
all the steps that he or she ought to have 
taken as a Director to make himself or herself 
aware of any relevant audit information, and 
to establish that the Company’s auditor is 
aware of that information.

Auditor
The Board approved the Audit 
Committee’s recommendation to put a 
resolution to shareholders recommending 
the reappointment of KPMG LLP as the 
Company’s auditor, and KPMG LLP has 
indicated its willingness to accept 
reappointment as auditor of the Company. 
The audit partner was rotated in April 2020 
in accordance with the FRC’s Ethical 
Standard 3 (Revised).

The Audit Committee, in its recommendation, 
confirmed that: (1) the recommendation 
was free from influence by a third party; 
and (2) no contractual term of the kind 
mentioned in Article 16(6) of the EU 
Regulation 537/2014 has been imposed 
on the Company.

A resolution proposing the reappointment 
of KPMG is contained in the notice of the 
forthcoming AGM and will be proposed to 
shareholders at that meeting.

Reporting requirements
The following sets out the location of additional information forming part of the Directors’ Report: 

Reporting requirement

Location

Strategic Report – Companies Act 2006 section 414A-D

Strategic Report on pages 02 to 67

DTR4.1.8R – Management Report – the Directors’ Report 
and Strategic Report comprise the “Management Report”

Directors’ Report on pages 118 to 122 and Strategic Report 
on pages 02 to 67

Likely future developments of the business and Group

Strategic Report on pages 02 to 67

Statement on corporate governance

Details of use of financial instruments and specific policies 
for managing financial risk

The Board’s assessment of the Group’s internal 
control systems

Greenhouse gas emissions

Directors’ remuneration including disclosures required 
by Schedule 5 and Schedule 8 of SI2008/410 – Large and 
Medium-sized Companies and Groups (Accounts and 
Reports) Regulations 2008

Corporate Governance Report, Audit Committee Report, Risk and 
Sustainability Committee Report, Nomination Committee Report 
and Directors’ Remuneration Report on pages 72 to 122

Note 21 to the Group financial statements on page 156

Corporate Governance Report on pages 72 to 82, Audit 
Committee Report on pages 89 to 93 and Risk and Sustainability 
Committee Report on pages 94 to 96

Sustainability and Stakeholder Engagement Report on pages 29 
to 53

Directors’ Remuneration Report on pages 97 to 117

Directors’ Responsibility Statement

Directors’ Responsibility Statement on page 123

Directors’ interests

Directors’ Remuneration Report on pages 97 to 117

The Strategic Report comprising the inside cover and pages 02 to 67 and this Directors’ Report comprising pages 118 to 122 have been 
approved by the Board and are signed on its behalf by:

Shazadi Stinton
General Counsel and Company Secretary
15 February 2023

Registered office: Moneysupermarket House, St. David’s Park, Ewloe, Chester CH5 3UZ

122 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Statement of Directors’ Responsibilities in respect of the Annual Report 
and the Financial Statements 

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

•  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. 

Responsibility statement of 
the Directors in respect of 
the annual financial report 
We confirm that to the best of our knowledge: 

Company law requires the Directors to 
prepare Group and Parent Company 
financial statements for each financial year. 
Under that law they are required to 
prepare the Group financial statements in 
accordance with UK-adopted international 
accounting standards and applicable law 
and have elected to prepare the Parent 
Company financial statements in 
accordance with UK accounting standards 
and applicable law, including FRS 102 The 
Financial Reporting Standard applicable in 
the UK and Republic of Ireland.

Under company law the Directors must not 
approve the financial statements unless 
they are satisfied that they give a true and 
fair view of the state of affairs of the Group 
and Parent Company and of the Group’s 
profit for that period. In preparing each of 
the Group and Parent Company financial 
statements, the Directors are required to: 

•  select suitable accounting policies and 

then apply them consistently; 

•  make judgements and estimates that are 

reasonable, relevant, reliable and prudent; 

•  for the Group financial statements, state 
whether they have been prepared in 
accordance with UK-adopted 
international accounting standards; 

•  for the Parent Company financial 

statements, state whether applicable UK 
accounting standards have been followed, 
subject to any material departures 
disclosed and explained in the Parent 
Company financial statements; 

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

The Directors are responsible 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 
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. 

Under applicable law and regulations, the 
directors are also responsible for preparing 
a Strategic Report, Directors’ Report, 
Directors’ Remuneration Report and 
Corporate Governance Statement that 
complies with that law and those regulations. 

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

In accordance with Disclosure Guidance 
and Transparency Rule 4.1.14R, the financial 
statements will form part of the annual 
financial report prepared using the single 
electronic reporting format under the TD 
ESEF Regulation. The Auditor’s Report on 
these financial statements provides no 
assurance over the ESEF format.

•  the financial statements, prepared in 
accordance with the applicable set of 
accounting standards, give a true and fair 
view of the assets, liabilities, financial 
position and profit or loss of the 
Company and the undertakings included 
in the consolidation taken as a whole; and 

•  the Annual Report and Accounts include 
a fair review of the development and 
performance of the business and the 
position of the issuer and the 
undertakings included in the 
consolidation taken as a whole, together 
with a description of the principal risks 
and uncertainties that they face. 

We consider the Annual Report and Accounts, 
taken as a whole, is fair, balanced and 
understandable and provides the information 
necessary for shareholders to assess the 
Group’s position and performance, business 
model and strategy.

Peter Duffy
Chief Executive Officer
15 February 2023

Scilla Grimble
Chief Financial Officer
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

123

GovernanceIndependent Auditor’s Report

to the members of Moneysupermarket.com Group plc 

1. Our opinion is unmodified
We have audited the Financial Statements of Moneysupermarket.com Group plc (“the Company”) for the year ended 31 December 2022 
which comprise the Consolidated Statement of Comprehensive Income, Consolidated Statement of Financial Position Consolidated 
Statement of Changes in Equity, Consolidated Statement of Cash Flows, and the related notes, including the accounting policies in note 2 
to the Group Financial Statements, and the Company Balance Sheet and Company Statement of Changes in Equity, and the related notes 
including the accounting policies in note 1 to the Parent Company Financial Statements.

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 2022 

and of the Group’s profit for the year then ended; 

•  the Group Financial Statements have been properly prepared in accordance with UK-adopted international accounting standards; 

•  the Parent Company Financial Statements have been properly prepared in accordance with UK accounting standards, including FRS 102 

The Financial Reporting Standard applicable in the UK and Republic of Ireland; and 

•  the Financial Statements have been prepared in accordance with the requirements of the Companies Act 2006. 

Basis for opinion 

We conducted our audit in accordance with International Standards on Auditing (UK) (“ISAs (UK)”) and applicable law. Our responsibilities 
are described below. We believe that the audit evidence we have obtained is a sufficient and appropriate basis for our opinion. Our audit 
opinion is consistent with our report to the Audit Committee. 

We were first appointed as auditor by the Company before 9 July 2007. The period of total uninterrupted engagement is for the 16 
financial years ended 31 December 2022. Prior to that we were also auditor to the Group’s previous Parent Company, but which, being 
unlisted, was not a public-interest entity. We have fulfilled our ethical responsibilities under, and we remain independent of the Group in 
accordance with, UK ethical requirements including the FRC Ethical Standard as applied to listed public interest entities. No non-audit 
services prohibited by that standard were provided. 

Overview

Materiality: group Financial Statements as a whole

£3.9m (2021: £4.2m)

Coverage

Key audit matters 

Recurring risks

4.45% (2021: 4.55%) of Group Profit before tax  
(2021: 3 year average Group profit before tax)

88% (2021: 96%) of group profit before tax

New: Recoverability of Goodwill in respect  
of the Cashback CGU

Recoverability of Parent Company investments  
and debt due from group companies

vs 2021

124 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

2. Key audit matters: our assessment of risks of material misstatement
Key audit matters are those matters that, in our professional judgement, 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. We summarise below the key audit matters, in decreasing order of audit significance, in arriving at our 
audit opinion above, together with our key audit procedures to address those matters and, as required for public interest entities, our 
results from those procedures. These matters were addressed, and our results are based on procedures undertaken, in the context of, 
and solely for the purpose of, our audit of the Financial Statements as a whole, and in forming our opinion thereon, and consequently are 
incidental to that opinion, and we do not provide a separate opinion on these matters. 

The risk

Our response

Recoverability of Goodwill: 
Cashback cash 
generating unit

(£68.3 million; 2021:  
£68.8 million)

Refer to pages 89 – 93  
(Audit Committee Report), 
page 140 (accounting policy) 
and pages 150 – 152  
(financial disclosures).

Forecast based assessment:

The Cashback cash generating unit (“CGU”) was 
acquired by the Group in November 2021. The 
estimated recoverable amount provides relatively 
low headroom compared to the Group’s other 
CGUs where there is significant headroom between 
the recoverable amount and the carrying value of 
CGU assets. 

The value in use calculation, which represents the 
estimated recoverable amount, is subjective due 
to the inherent uncertainty involved in selecting 
appropriate key assumptions. Changes to the key 
assumptions, such as the revenue growth rate and 
the discount rate, could have a material impact on 
the recoverable amount of the associated goodwill.

Estimation uncertainty in the UK has increased as 
a result of inflationary pressures from the 
macroeconomic and geo-political environment. 
This has a proportionally more significant effect 
on the Cashback CGU due to the limited headroom 
available following the recent acquisition in 2021. 

The effect of these matters is that, as part of our 
risk assessment, we determined that the 
recoverability of the Cashback CGU goodwill 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.

The Financial Statements (note 13) disclose the 
sensitivities estimated by the Group. These 
disclosures give relevant information about the 
estimation uncertainty, including the risk of 
a reduction in the headroom as a result of a 
reasonably possible change in one or more of 
the key assumptions.

We performed the tests below rather than seeking 
to rely on any of the Group’s controls because the 
nature of the balance is such that we would expect 
to obtain audit evidence primarily through the 
detailed procedures described.

Our procedures included:

•  Benchmarking assumptions: We assessed and 
challenged the operating cash flow assumptions 
used by the Group, such as the revenue growth 
rate, through comparing growth rates to external 
industry forecasts, analysis of analysts’ reports 
and historic trends;

•  Our sector experience: We challenged the 

appropriateness of the discount rate by deriving 
our own independent range with input from our 
corporate finance professionals;

•  Sensitivity analysis: We performed sensitivity 

analysis on the key assumptions (revenue growth 
rate and discount rate) and assessed whether the 
Directors have identified appropriate scenarios in 
their own sensitivity analysis; and

•  Assessing transparency: We assessed whether 

the disclosures about the sensitivity of the 
outcome of the impairment assessment to 
changes in key assumptions reflect the risks 
inherent in the recoverable amount of the 
Cashback CGU goodwill.

Our results

We found the Group’s conclusion that there is no 
impairment of the Cashback CGU goodwill to be 
acceptable (2021: acceptable).

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

125

Financial StatementsIndependent Auditor’s Report continued

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

Recoverability of Parent 
Company’s investment in 
subsidiary and debt due 
from Group companies

Investment in subsidiary

(£181.7 million; 2021:  
£181.7 million)

Amounts due from 
subsidiary undertakings

(£215.0 million; 2021:  
£223.3 million)

The risk

Low risk, high value:

The carrying amount of the Parent Company’s 
investment in subsidiary and debt due from Group 
entities represents 99.7% (2021: 99.8%) of the 
Parent Company’s total assets. Their recoverability 
is not a high risk of significant misstatement or 
subject to significant judgement.

However, due to their 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.

Our response

We performed the tests below rather than seeking 
to rely on any of the Group’s controls because the 
nature of the balance is such that we would expect 
to obtain audit evidence primarily through the 
detailed procedures described.

Our procedures included: 

•  Test of detail: We compared the carrying 

amount of the investment in subsidiary and debt 
due from Group entities with the net assets of 
the relevant subsidiary included within the Group 
consolidation, to identify whether the net asset 
value, being an approximation of its minimum 
recoverable amount, was in excess of its carrying 
amount; 

•  Assessing subsidiary audits: We assessed the 
results of our procedures over the subsidiaries 
that were in scope for the group audit and 
considered the results of that work on those 
subsidiaries’ profits and net assets, including 
assessing the liquidity of the assets, and 
therefore the ability of the subsidiary to fund the 
repayment of the receivable; and 

•  Comparing valuations: We compared the 

carrying amount of the investment and debt due 
from Group entities to the Group’s market 
capitalisation to assess whether there are any 
indicators of impairment. 

Our results 

We found the Company’s conclusion that there is no 
impairment of its investment in subsidiary and debt 
due from Group entities to be acceptable (2021: 
acceptable).

The valuation of intangible assets arising from the purchase of Maple Syrup Media Limited (Quidco) in 2021 was an event driven significant 
risk and consequently, a key audit matter in the prior period.  Therefore as the significant risk and key audit matter relates only to the prior 
year this has not been separately identified in our audit report this year.

3. Our application of materiality and an overview of the scope of our audit
Materiality for the Group Financial Statements as a whole was set at £3.9 million (2021: £4.2 million), determined with reference to a 
benchmark of Group profit before tax of £85.2 million (2021: Group profit before tax of £92.5 million normalised by averaging over the 
last 3 years due to fluctuations in the business cycle), of which it represents 4.6% (2021: 4.5%).

Materiality for the Parent Company Financial Statements as a whole was set at £3.8 million (2021: £3.6 million), determined with reference 
to a benchmark of Parent Company total assets, limited to be less than materiality for the group as a whole. It represents 1.0% (2021: 0.5%) 
of the stated benchmark.

In line with our audit methodology, our procedures on individual account balances and disclosures were performed to a lower threshold, 
performance materiality, so as to reduce to an acceptable level the risk that individually immaterial misstatements in individual account 
balances add up to a material amount across the Financial Statements as a whole.

Performance materiality for the Group and Parent Company was set at 75% (2021: 75%) of materiality for the Financial Statements as a 
whole, which equates to £2.9 million (2021: £3.2 million) for the Group and £2.9 million (2021: £2.7 million) for the Parent Company. We 
applied this percentage in our determination of performance materiality because we did not identify any factors indicating an elevated 
level of risk.

We agreed to report to the Audit Committee any corrected or uncorrected identified misstatements exceeding £0.2 million (2021: £0.2 million), 
in addition to other identified misstatements that warranted reporting on qualitative grounds.

Of the Group’s fifteen (2021: fifteen) reporting components, we subjected five (2021: four) to full scope audits for group purposes and 
one (2021: one) to specified risk-focused audit procedures. The component for which we performed specified risk-focused procedures 
was not financially significant enough to require an audit for group reporting purposes, but did present specific individual risks that 
needed to be addressed. Work on all components, including the audit of the Parent Company, was performed by the Group audit team.

The components within the scope of our work accounted for the percentages illustrated opposite.

126 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

3. Our application of materiality and an overview of the scope of our audit continued
For the residual components, we performed analysis at an aggregated group level to re-examine our assessment that there were no 
significant risks of material misstatement within these.

The scope of our audit work performed was predominantly substantive as we placed limited reliance upon the Group’s internal control 
over financial reporting.

Group profit before tax

£85.2m (2021: £92.5m)

Group materiality

£3.9m (2021: £4.2m)

9595++55++II

£3.9m

Whole financial statements 
materiality (2021: £4.2m)

£2.9m

Whole financial statements 
performance materiality 
(2021: £3.2m)

£3.4m

Range of materiality at 
5 components (£1.5m 
to £3.4m) (2021: £1.5m 
to £3.6m)

 Group PBT

 Group materiality

£0.2m

Misstatements reported to the 
audit committee (2021: £0.2m)

 Full scope for group audit purposes 2022

 Full scope for group audit purposes 2021

Group revenue

5

7

5

11

95

(2021: 95%)

Group PBT

93%

89%

93+93+
939595+
89+89+
899595+
94+94+
949999+

94%

Group total assets

(2021: 99%)

(2021: 95%)

6
1

99

95

 Specified risk-focused audit procedures 2021

 Residual components

4. The impact of climate change on our audit
In planning our audit, we have considered the potential impact of risks arising from climate change on the Group’s business and its 
Financial Statements.

The Group has set out its commitments under the Paris accord to be operational net zero by 2030. Further information is provided in the 
Group’s Task Force for Climate-Related Financial Disclosures (‘TCFD’) recommended disclosures on pages 48 to 51.

As a part of our audit we have performed a risk assessment, including making enquiries of management, reading board meeting minutes 
and applying our knowledge of the Group and sector in which it operates to understand the extent of the potential impact of climate 
change risk on the Group’s Financial Statements. Taking into account the nature of the business and the limited impact of climate change 
on the assumptions in impairment testing, we have not assessed climate related risk to be significant to our audit this year. There was no 
impact on our key audit matters.

We have read the Group’s TCFD in the front half of the annual report and considered consistency with the Financial Statements and our 
audit knowledge.

We have not been engaged to provide assurance over the accuracy of the climate risk disclosures set out on pages 48 to 51 in the 
Annual Report.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

127

Financial Statements7
7
+
+
I
I
+
5
+
5
+
I
I
11
11
+
+
I
I
+
5
+
5
+
I
I
6
6
+
+
I
I
+
1
+
1
+
I
I
Independent Auditor’s Report continued

5. Going concern 
The Directors have prepared the Financial Statements on the going concern basis as they do not intend to liquidate the Group or the Parent 
Company or to cease their operations, and as they have concluded that the Group’s and the Parent Company’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”).

We used our knowledge of the Group, its industry and the general economic environment to identify the inherent risks to its business 
model and analysed how those risks might affect the Group’s and the Parent Company’s financial resources or ability to continue 
operations over the going concern period. The risks that we considered most likely to adversely affect the Group’s and the Parent 
Company’s available financial resources and metrics relevant to debt covenants over this period were:

•  The competitive environment and a reduction in consumer demand; 

•  The impact of increased economic uncertainty and inflation in the wider economy;

•  The potential impact of a significant data breach or cyber-attack, the resulting fines and damage to brand strength and reputation; and

•  The impact of regulatory changes and government policy reducing the availability of attractive products to customers.

We considered whether these risks could plausibly affect the liquidity or covenant compliance in the going concern period by assessing 
the Directors’ sensitivities over the level of available financial resources and covenant thresholds indicated by the Group’s financial 
forecasts taking account of severe, but plausible adverse effects that could arise from these risks individually and collectively.

Our procedures included:

•  Critically assessing assumptions in the base case and severe, but plausible, downside scenarios relevant to liquidity and covenant 

metrics, in particular by comparing to economic forecasts, approved budgets and our knowledge of the Group and the sector in which 
it operates;

•  We also compared past budgets to actual results to assess the Directors’ track record of budgeting accurately; and

•  We evaluated the achievability of the actions the Directors consider they would take to improve the position should the risks 

materialise, which included a reduction in the ordinary dividend payment, a reduction in operating expenses or the slowdown of 
capital expenditure, taking into account the extent to which the Directors can control the timing and outcome of these.

We also assessed the completeness and adequacy of the going concern disclosure.

Our conclusions based on this work:

•  we consider that the Directors’ use of the going concern basis of accounting in the preparation of the Financial Statements is appropriate;

•  we have not identified, and concur with the Directors’ assessment that there is not, a material uncertainty related to events or 

conditions that, individually or collectively, may cast significant doubt on the Group’s or the Parent Company’s ability to continue as a 
going concern for the going concern period;

•  we have nothing material to add or draw attention to in relation to the Directors’ statement in note 2 to the Financial Statements on the 
use of the going concern basis of accounting with no material uncertainties that may cast significant doubt over the Group and Parent 
Company’s use of that basis for the going concern period, and we found the going concern disclosure in note 2 to be acceptable; and

•  the related statement under the Listing Rules set out on page 59 is materially consistent with the Financial Statements and our 

audit knowledge.

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 above conclusions are not a guarantee that the Group or the 
Parent Company will continue in operation. 

128 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

6. Fraud and breaches of laws and regulations – ability to detect
Identifying and responding to risks of material misstatement due to fraud

To identify risks of material misstatement due to fraud (“fraud risks”) we assessed events or conditions that could indicate an incentive or 
pressure to commit fraud or provide an opportunity to commit fraud. Our risk assessment procedures included:

•  Enquiring of Directors, the Audit Committee, the Risk and Sustainability Committee, Internal Audit and inspection of policy 

documentation as to the Group’s high-level policies and procedures to prevent and detect fraud, including the internal audit function, 
and the Group’s channel for “whistleblowing”, as well as whether they have knowledge of any actual, suspected or alleged fraud.

•  Reading Board, Audit Committee, and Risk and Sustainability Committee meeting minutes;

•  Considering remuneration incentive schemes and performance targets for Directors including the revenue growth, Adjusted EBITDA 

and Adjusted EPS growth targets for remuneration.

•  Using analytical procedures to identify any unusual or unexpected relationships.

We communicated identified fraud risks throughout the audit team and remained alert to any indications of fraud throughout the audit. 

As required by auditing standards, and taking into account possible pressures to meet profit targets, we perform procedures to address 
the risk of management override of controls, in particular the risk that Group management may be in a position to make inappropriate 
accounting entries and the risk of bias in accounting estimates and judgements such as the recoverable amount of Goodwill attributed to 
the Cashback cash generating unit. On this audit we do not believe there is a fraud risk related to revenue recognition because the 
degree of estimation subjectivity for the revenue accrual is low and revenue generated throughout the period converts to cash within a 
reasonably short period.

We did not identify any additional fraud risks.

We performed procedures including: 

•  Identifying journal entries and other adjustments to test based on risk criteria and comparing the identified entries to supporting 

documentation. These included those posted to unusual accounts and those posted by senior finance management; and

•  Assessing whether the judgements made in making accounting estimates are indicative of a potential bias.

Identifying and responding to risks of material misstatement due to non-compliance with laws and regulations

We identified areas of laws and regulations that could reasonably be expected to have a material effect on the Financial Statements from 
our general commercial and sector experience, through discussion with the Directors and other management (as required by auditing 
standards), and from inspection of the Group’s regulatory correspondence and discussed with the Directors and other management the 
policies and procedures regarding compliance with laws and regulations. 

As the Group is regulated, our assessment of risks involved gaining an understanding of the control environment including the entity’s 
procedures for complying with regulatory requirements.

We communicated identified laws and regulations throughout our team and remained alert to any indications of non-compliance 
throughout the audit.

The potential effect of these laws and regulations on the Financial Statements varies considerably.

Firstly, the Group is subject to laws and regulations that directly affect the Financial Statements including financial reporting legislation 
(including related companies legislation), distributable profits legislation and taxation legislation and we assessed the extent of 
compliance with these laws and regulations as part of our procedures on the related financial statement items.

Secondly, the Group is subject to many other laws and regulations where the consequences of non-compliance could have a material 
effect on amounts or disclosures in the Financial Statements, for instance through the imposition of fines or litigation. We identified the 
following areas as those most likely to have such an effect: data protection laws and laws and regulations of various bodies that regulate 
the Group’s activities including the Competition and Marketing Authority (CMA), the Financial Conduct Authority (FCA), the Information 
Commissioners Office (ICO), the Office of Gas and Electricity (Ofgem) and the Office of Communications (Ofcom). Auditing standards limit 
the required audit procedures to identify non-compliance with these laws and regulations to enquiry of the Directors and other 
management and inspection of regulatory and legal correspondence, if any. Therefore, if a breach of operational regulations is not 
disclosed to us or evident from relevant correspondence, an audit will not detect that breach.

We assessed the legality of the distribution in the period based on assessing the level of distributable profits.

Context of the ability of the audit to detect fraud or breaches of law or regulation

Owing to the inherent limitations of an audit, there is an unavoidable risk that we may not have detected some material misstatements in 
the Financial Statements, even though we have properly planned and performed our audit in accordance with auditing standards. For 
example, the further removed non-compliance with laws and regulations is from the events and transactions reflected in the Financial 
Statements, the less likely the inherently limited procedures required by auditing standards would identify it. 

In addition, as with any audit, there remained a higher risk of non-detection of fraud, as these may involve collusion, forgery, intentional 
omissions, misrepresentations, or the override of internal controls. Our audit procedures are designed to detect material misstatement. We 
are not responsible for preventing non-compliance or fraud and cannot be expected to detect non-compliance with all laws and regulations.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

129

Financial StatementsIndependent Auditor’s Report continued

7. We have nothing to report on the other information in the Annual 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.

Strategic report and Directors’ report 

Based solely on our work on the other information: 

•  we have not identified material misstatements in the strategic report and the Directors’ report; 

•  in our opinion the information given in those reports for the financial year is consistent with the Financial Statements; and 

•  in our opinion those reports have been prepared in accordance with the Companies Act 2006. 

Directors’ remuneration report

In our opinion the part of the Directors’ Remuneration Report to be audited has been properly prepared in accordance with the Companies 
Act 2006. 

Disclosures of emerging and principal risks and longer-term viability

We are required to perform procedures to identify whether there is a material inconsistency between the Directors’ disclosures in respect of 
emerging and principal risks and the viability statement, and the Financial Statements and our audit knowledge. 

Based on those procedures, we have nothing material to add or draw attention to in relation to: 

•  the Directors’ confirmation within the Risk Management report on pages 60 – 61 that they have carried out a robust assessment of the 
emerging and principal risks facing the Group, including those that would threaten its business model, future performance, solvency 
and liquidity; 

•  the Principal Risks and Uncertainty disclosures describing these risks and how emerging risks are identified, and explaining how they 

are being managed and mitigated; and 

•  the Directors’ explanation in the Viability Statement of how they have assessed the prospects of the Group, over what period they have 
done so and why they considered that period to be appropriate, and their statement as to whether they have a reasonable expectation 
that the Group will be able to continue in operation and meet its liabilities as they fall due over the period of their assessment, 
including any related disclosures drawing attention to any necessary qualifications or assumptions. 

We are also required to review the Viability Statement, set out on pages 60 – 61 under the Listing Rules. Based on the above procedures, we 
have concluded that the above disclosures are materially consistent with the Financial Statements and our audit knowledge.

Our work is limited to assessing these matters in the context of only the knowledge acquired during our Financial Statements audit. 
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 anything to report on these statements is not a guarantee 
as to the Group’s and Parent Company’s longer-term viability.

Corporate governance disclosures 

We are required to perform procedures to identify whether there is a material inconsistency between the Directors’ corporate 
governance disclosures and the Financial Statements and our audit knowledge.

Based on those procedures, we have concluded that each of the following is materially consistent with the Financial Statements and our 
audit knowledge: 

•  the Directors’ statement that they consider that the annual report and Financial Statements taken as a whole is fair, balanced and 

understandable, and provides the information necessary for shareholders to assess the Group’s position and performance, business 
model and strategy; 

•  the section of the annual report describing the work of the Audit Committee, including the significant issues that the audit committee 

considered in relation to the Financial Statements, and how these issues were addressed; and

•  the section of the annual report that describes the review of the effectiveness of the Group’s risk management and internal 

control systems.

We are required to review the part of the Corporate Governance Statement relating to the Group’s compliance with the provisions of the 
UK Corporate Governance Code specified by the Listing Rules for our review. We have nothing to report in this respect.

130 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

8. We have nothing to report on the other matters on which we are required to report by exception 
Under the Companies Act 2006, we are required to report to you if, in our opinion: 

•  adequate accounting records have not been kept by the Parent Company, or returns adequate for our audit have not been received 

from branches not visited by us; or 

•  the Parent Company Financial Statements and the part of the Directors’ Remuneration Report to be audited are not in agreement with 

the accounting records and returns; or 

•  certain disclosures of Directors’ remuneration specified by law are not made; or 

•  we have not received all the information and explanations we require for our audit. 

We have nothing to report in these respects.

9.  Respective responsibilities 
Directors’ responsibilities 

As explained more fully in their statement set out on page 123, 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 

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 accordance with ISAs (UK) will always detect a material misstatement when 
it exists. Misstatements can arise from fraud or error and are considered material if, individually or in 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.

The Company is required to include these financial statements in an annual financial report prepared using the single electronic 
reporting format specified in the TD ESEF Regulation. This auditor’s report provides no assurance over whether the annual financial 
report has been prepared in accordance with that format.

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

Suvro Dutta (Senior Statutory Auditor) 
for and on behalf of KPMG LLP, Statutory Auditor  
Chartered Accountants  
15 Canada Square 
London 
E14 5GL
15 February 2023

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

131

Financial StatementsConsolidated Statement of Comprehensive Income

for the year ended 31 December 2022

Revenue
Cost of sales

Gross profit
Distribution expenses
Administrative expenses

Operating profit
Profit on disposal of property, plant and equipment
Finance income
Finance expense
Share of post-tax loss of equity accounted investees
Change in fair value of financial instruments

Profit before tax
Taxation

Profit for the year

Other comprehensive income – items that will not be reclassified to profit and loss:
Change in fair value of financial instruments

Total comprehensive income for the year

Profit/(loss) attributable to:
Owners of the Company
Non-controlling interest

Profit for the year

Total comprehensive income attributable to:
Owners of the Company
Non-controlling interest

Total comprehensive income for the year

All profit and other comprehensive income relate to continuing operations.

Earnings per share
Basic earnings per ordinary share (p)

Diluted earnings per ordinary share (p)

Year ended
31 December
2022
£m

Year ended
31 December
2021
£m

387.6
(125.1)

262.5
(40.1)
(133.4)

89.0
0.0
 0.3
(3.8)
(0.3)
0.0

85.2
(15.9)

69.3

(2.0)

67.3

68.3
1.0

69.3

66.3
1.0

67.3

12.7

12.7

316.7
(93.8)

222.9
(29.5)
(120.0)

73.4
0.1
0.1
(2.1)
(0.6)
(0.7)

70.2
(18.1)

52.1

1.4

53.5

52.7
(0.6)

52.1

54.1
(0.6)

53.5

9.8

9.8

Note

4

6

8
8
14

9

15

29

29

10

10

132 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Consolidated Statement of Financial Position

at 31 December 2022

Assets
Non-current assets
Property, plant and equipment
Intangible assets and goodwill
Equity accounted investments
Other investments

Total non-current assets

Current assets
Trade and other receivables
Prepayments
Cash and cash equivalents

Total current assets

Total assets

Liabilities
Non-current liabilities
Other payables
Borrowings
Deferred tax liabilities

Total non-current liabilities

Current liabilities
Trade and other payables
Borrowings
Current tax liabilities

Total current liabilities

Total liabilities

Equity
Share capital
Share premium
Reserve for own shares
Retained earnings
Other reserves

Equity attributable to the owners of the Company
Non-controlling interest

Total equity

Total equity and liabilities

31 December
2022
£m

31 December
2021
£m

Note

12
13
14
15

16, 28

21

17
18
19

17, 28
18

20

29

35.4
279.9
 — 
5.5

320.8

63.5
8.3
16.6

88.4

39.8
288.4
0.0
7.5

335.7

65.3
9.3
12.5

87.1

409.2

422.8

27.7
30.0
22.5

80.2

99.5
14.0
0.8

114.3

194.5

0.1
205.4
(2.4)
(58.1)
63.7

208.7
6.0

214.7

409.2

38.3
40.0
25.3

103.6

93.9
17.5
0.2

111.6

215.2

0.1
205.4
(2.6)
(64.7)
65.1

203.3
4.3

207.6

422.8

The Financial Statements were approved by the Board of Directors and authorised for issue on 15 February 2023. They were signed 
on its behalf by:

Peter Duffy
Chief Executive Officer

Scilla Grimble
Chief Financial Officer

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

133

Financial StatementsConsolidated Statement of Changes in Equity

for the year ended 31 December 2022

At 1 January 2021
Profit/(loss) for the year
Other comprehensive income 
for the year

Total comprehensive income 
for the year

Acquisition of subsidiary with 
non-controlling interest
Purchase of shares by 
employee trusts
Exercise of LTIP awards
New shares issued
Equity dividends
Share-based payments
Realisation of fair value gains

At 31 December 2021

Profit for the year
Other comprehensive income 
for the year

Total comprehensive income 
for the year

Acquisition of subsidiary with 
non-controlling interest
Purchase of shares by 
employee trusts
Exercise of LTIP awards
Equity dividends
Share-based payments

Note

15

11
23
15

15

29

11
23

0.1
—

—

—

—

—
—
0.0
—
—
—

0.1

—

—

—

—

—
—
—
—

Share 
capital
£m

Share
premium
£m

Reserve for
own shares
£m

Retained
earnings
£m

205.0
—

(2.8)
—

(57.2)
52.7

Equity
attributable
 to the
owners of
the Company
£m

Non-
controlling
interest
£m

208.5
52.7

—
(0.6)

Other
reserves
£m

63.4
—

Total 
equity
£m

208.5
52.1

—

—

—

—
—
0.4
—
—
—

205.4

—

—

—

—

—
—
—
—

—

—

—

(0.3)
0.5
—
—
—
—

(2.6)

—

—

—

—

(0.3)
0.5
—
—

—

52.7

—

—
(0.5)
—
(62.8)
1.4
1.7

(64.7)

68.3

1.4

1.4

2.0

—
—
—
—
—
(1.7)

65.1

—

(0.3)
—
0.4
(62.8)
1.4
—

203.3

68.3

(0.6)

(1.4)

(2.0)

67.7

(1.4)

66.3

—

—
(0.5)
(62.8)
2.2

—

—
—
—
—

—

(0.3)
—
(62.8)
2.2

1.4

—

1.4

54.1

(0.6)

53.5

2.0

4.9

6.9

—
—
—
—
—
—

4.3

1.0

—

1.0

0.7

—
—
—
—

(0.3)
—
0.4
(62.8)
1.4
—

207.6

69.3

(2.0)

67.3

0.7

(0.3)
—
(62.8)
2.2

At 31 December 2022

0.1

205.4

(2.4)

(58.1)

63.7

208.7

6.0

214.7

Reserve for own shares

The reserve for the Company’s own ordinary shares comprises the cost of the Company’s ordinary shares held by the Group through 
employee trusts. At 31 December 2022, the Group held 339,657 (2021: 343,328) ordinary shares at a cost of 0.02p per share (2021: 0.02p) 
through a Share Incentive Plan trust for the benefit of the Group’s employees.

The Group also held 151,723 (2021: 253,886) shares through an Employee Benefit Trust at an average cost of 204.80p per share 
(2021: 239.19p) for the benefit of employees participating in the various Long Term Incentive Plan schemes.

Other reserves

Fair value reserve
Merger reserve
Revaluation reserve

Total

31 December
2022
£m

31 December
2021
£m

5.0
16.9
41.8 

63.7

6.4
16.9
41.8

65.1

The fair value reserve of £5.0m (2021: £6.4m) represents amounts recognised in other comprehensive income in relation to changes 
in fair value of investments and amounts recognised directly in equity on initial recognition of non-controlling interest.

The merger and revaluation reserve balances relate to the acquisition of Moneysupermarket.com Financial Group Limited by the 
Company. The merger reserve of £16.9m (2021: £16.9m) represents 45% of the book value of assets and liabilities transferred and 
the revaluation reserve of £41.8m (2021: £41.8m) represents 45% of the fair value of the intangible assets transferred, net of amounts 
recycled to retained earnings.

134 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Consolidated Statement of Cash Flows 

for the year ended 31 December 2022

Cash flows from operating activities
Profit for the year
Adjustments to reconcile Group profit to net cash flow from operating activities:
Amortisation of intangible assets
Depreciation of property, plant and equipment
Profit on disposal of property, plant and equipment
Share of post-tax loss of equity accounted investees
Change in fair value of financial instruments
Net finance expense
Equity-settled share-based payment transactions
Income tax expense
Change in trade and other receivables
Change in trade and other payables
Income tax paid

Net cash from operating activities

Cash flows from investing activities
Interest received
Acquisition of property, plant and equipment
Acquisition of intangible assets
Acquisition of subsidiaries, net of cash acquired
Acquisition of investments
Proceeds from disposal of property, plant and equipment
Proceeds from disposal of investments

Net cash used in investing activities

Cash flows from financing activities
Dividends paid
Proceeds from share issue
Purchase of shares by employee trusts
Proceeds from borrowings
Repayment of borrowings
Interest paid
Repayment of lease liabilities

Net cash used in financing activities

Net increase/(decrease) in cash and cash equivalents
Cash and cash equivalents at 1 January

Cash and cash equivalents at 31 December

Year ended
31 December
2022
£m

Year ended
31 December
2021
£m

Note

69.3

21.7
4.8
(0.0)
0.3
(0.0)
3.5
2.2
15.9
3.0
1.7
(18.0)

104.4

0.0
(0.8)
(10.6)
(5.3)
(0.2)
0.0
 —

(16.9)

(62.8)
— 
(0.3)
62.0
(75.5)
(3.7)
(3.1)

(83.4)

4.1
12.5

16.6

52.1

19.0
4.5
(0.1)
0.6
0.7
2.0
1.4
18.1
3.6
(20.6)
(15.6)

65.7

0.1
(0.6)
(9.2)
(59.3)
(0.7)
0.4
2.1

(67.2)

(62.8)
0.4
(0.3)
105.6
(48.1)
(2.1)
(2.3)

(9.6)

(11.1)
23.6

12.5

13
12

14

8
23
9

11

21

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

135

Financial StatementsChanges in liabilities from financing activities 

At 1 January 2021
Changes from financing cash flows
Proceeds from borrowings
Repayment of borrowings
Interest paid
Repayment of lease liabilities

Total changes from financing cash flows
Other changes
Interest expense
Lease liability adjustment
Acquisition of lease liabilities through business combinations

Balance at 31 December 2021

At 1 January 2022
Changes from financing cash flows
Proceeds from borrowings
Repayment of borrowings
Interest paid
Repayment of lease liabilities

Total changes from financing cash flows
Other changes
Interest expense

At 31 December 2022

Borrowings
£m

—

105.6
(48.1)
(1.2)
—

56.3

1.2
—
—

57.5

57.5

62.0
(75.5)
(2.6)
—

(16.1)

2.6

44.0

Lease
liabilities
£m

32.8

—
—
(0.9)
(2.3)

(3.2)

0.9
(0.5)
1.7

31.7

31.7

—
—
(1.1)
(3.1)

(4.2)

1.1

28.6

Total
£m

32.8

105.6
(48.1)
(2.1)
(2.3)

53.1

2.1
(0.5)
1.7

89.2

89.2

62.0
(75.5)
(3.7)
(3.1)

(20.3)

3.7

72.6

136 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Notes to the Consolidated Financial Statements

1. Corporate information
The Consolidated Financial Statements of Moneysupermarket.com Group PLC, a public company incorporated and domiciled in England 
(registered at Moneysupermarket House, St David’s Park, Ewloe, Chester, CH5 3UZ), and its subsidiaries (together referred to as the 
‘Group’) for the year ended 31 December 2022, were authorised for issue in accordance with a resolution of the Directors on 15 February 2023. 
The Consolidated Financial Statements have been prepared in accordance with UK-adopted international accounting standards. The 
presentation currency of these Consolidated Financial Statements is sterling. All amounts in the Consolidated Financial Statements have 
been rounded to the nearest £100,000. The Company has elected to prepare its Company Financial Statements in accordance with FRS 102 
– The Financial Reporting Standard applicable in the UK and Republic of Ireland; these are presented on pages 166 and 167.

The principal activity of the Group is to provide price comparison and lead generation services to customers across a wide range 
of products including Money, Insurance and Home Services through its websites.

2. Summary of significant accounting policies
The Group has consistently applied the following accounting policies to all periods presented in these Consolidated Financial Statements, 
unless mentioned otherwise.

Basis of preparation

The Consolidated Financial Statements are prepared on the historical cost basis, except where otherwise stated. Comparative figures 
presented in the Consolidated Financial Statements represent the year ended 31 December 2021.

In light of new information obtained since the acquisition of Quidco Limited (formerly known as Maple Syrup Media Limited) (‘Quidco’) 
about facts and circumstances that existed at the date of acquisition, and in accordance with IFRS 3 – Business Combinations, an 
adjustment to the previously reported balance sheet at 31 December 2021 has been included in these Consolidated Financial 
Statements. Further information on this is included in note 28.

Going concern

The Directors have prepared the Financial Statements on a going concern basis for the following reasons. As at 31 December 2022, the 
Group’s external debt comprised an amortising loan (with a balance outstanding of £40m, repayable over the period to October 2024) 
and a revolving credit facility (‘RCF’), (of which £4m of the £90m available was drawn down). No further amounts have been drawn down 
since the year end. The operations of the business have been impacted by regulatory changes in general insurance, COVID-19 recovery in 
Travel related channels and the current conditions affecting the energy market. However, the Group remains profitable, cash generative 
and compliant with the covenants of the bank loan and RCF. 

The Directors have prepared cash flow forecasts for the Group, including its cash position, for a period of at least 12 months from the 
date of approval of the Financial Statements. The Directors have also considered the effect of potential cost of living trading headwinds 
and recession and higher competition, including potential new entrants, upon the Group’s business, financial position, and liquidity in 
severe, but plausible, downside scenarios. The scenarios modelled take into account the potential downside trading impacts from 
recession, sustained cost-of-living pressures, competitive pressures and potential one-off cash impacts on top of a base scenario derived 
from the Group’s latest forecasts. The severe, but plausible, downside scenarios modelled, under a detailed exercise at a channel level, 
included minimal recovery over the period of the cash flow forecasts and in the most severe scenarios reflected some of the possible 
cost mitigations that could be taken. The impact these scenarios have on the financial resources, including the extent of utilisation of the 
available debt arrangements and impact on covenant calculations has been modelled. The possible mitigating circumstances and actions 
in the event of such scenarios occurring that were considered by the Directors included cost mitigations such as a reduction in the 
ordinary dividend payment, a reduction in operating expenses or the slowdown of capital expenditure. A reverse stress test has also 
been performed, which assumes the maximum available drawdown of borrowings, whilst maintaining covenant compliance.

The scenarios modelled and the reverse stress test showed that the Group and the Company will be able to operate at adequate levels of 
liquidity for at least the next 12 months from the date of signing the Financial Statements. The Directors, therefore, consider that the 
Group and the Company have adequate resources to continue in operational existence for at least 12 months from the date of approval 
of the Financial Statements and have prepared them on a going concern basis.

Use of estimates and judgements

The preparation of Consolidated 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.

Information about assumptions and estimation uncertainties at 31 December 2022 that may have a 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 note:

•  Note 13 intangible assets and goodwill (impairment assessment of goodwill of the cashback cash generating unit).

Information about judgements made in applying accounting policies that have the most significant effects on the amounts recognised 
in the Consolidated Financial Statements is included in the following notes:

•  Note 13 intangible assets and goodwill (capitalisation of software and development costs).

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

137

Financial StatementsNotes to the Consolidated Financial Statements continued

2. Summary of significant accounting policies continued
Basis of consolidation

These Consolidated Financial Statements incorporate the Financial Statements of the Company and all its subsidiaries.

Subsidiaries are entities controlled by the Group. The Group controls an entity when 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 acquisition date 
is the date on which control is transferred to the acquirer. The Financial Statements of subsidiaries are included in the Consolidated 
Financial Statements from the date that control commences until the date that control ceases.

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 other comprehensive income (OCI) of equity accounted investees, until the date on which significant influence or joint control ceases.

Intra-group balances and transactions, and any unrealised income and expenses arising from intra-group transactions, are eliminated.

Non-controlling interest is measured at the proportionate share of the entity’s net assets. On initial recognition this includes the 
proportionate share of the pre-acquisition net assets of Travelsupermarket Limited and the net assets arising on the acquisitions 
of Icelolly Marketing Limited and Podium Solutions Limited.

Accounting for business combinations

From 1 January 2010 the Group has applied IFRS 3 – Business Combinations (2008) in accounting for business combinations using 
the acquisition method. The change in accounting policy has been applied prospectively.

Acquisitions on or after 1 January 2010

For acquisitions on or after 1 January 2010, the Group measures goodwill at the acquisition date as:

•  the fair value of the consideration transferred; plus

•  the recognised amount of any non-controlling interests in the acquiree; plus

•  if the business combination is achieved in stages, the fair value of the existing equity interest in the acquiree; less

•  the net recognised amount (fair value) of the identifiable assets acquired and liabilities assumed.

When the excess is negative, a bargain purchase gain is recognised immediately in profit or loss.

The consideration transferred does not include amounts related to the settlement of pre-existing relationships. Such amounts are 
generally recognised in profit or loss.

Costs related to the acquisition, other than those associated with the issue of debt or equity securities, that the Group incurs in 
connection with a business combination are expensed as incurred.

Any contingent amount payable is recognised at fair value at the acquisition date. If the contingent amount is classified as equity, it is not 
remeasured and settlement is accounted for within equity. Otherwise, subsequent changes to the fair value of the contingent amount are 
recognised in profit or loss. Where the contingent amount is dependent on future employment, it is treated as a cost of continuing 
employment, and therefore is recognised as an expense over the relevant period.

Deferred consideration comprises obligations to pay specified amounts at future dates, i.e. there is no uncertainty about the amount 
to be paid. It is recognised and measured at fair value at the date of acquisition and it is included in the consideration transferred. 
The unwinding of any interest element or deferred consideration is recognised in the Income Statement.

Acquisitions between establishment of the Group (22 June 2007) and 1 January 2010

For acquisitions between 22 June 2007 and 1 January 2010, goodwill represents the excess of the cost of the acquisition over the Group’s 
interest in the recognised amount (generally fair value) of the identifiable assets, liabilities and contingent liabilities of the acquiree. When 
the excess was negative, a bargain purchase gain was recognised immediately in profit or loss.

Transaction costs, other than those associated with the issue of debt or equity securities, that the Group incurred in connection 
with business combinations were capitalised as part of the cost of the acquisition.

138 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

2. Summary of significant accounting policies continued
Acquisitions between establishment of the Group (22 June 2007) and 1 January 2010 continued

The Group was established via a series of transactions that occurred concurrently on 22 June 2007. These comprised the incorporation 
of the Company with Simon Nixon as sole shareholder, the acquisition by the Company using a share for share exchange of Simon Nixon’s 
45% interest in Moneysupermarket.com Financial Group Limited and the acquisition by the Company of all other shares in 
Moneysupermarket.com Financial Group Limited from third parties. The acquisition of Simon Nixon’s shares was between two parties, 
being Simon Nixon and the Company, who were under common control at the time of the transaction. The acquisition was of an interest 
in a company which gave the investor a significant influence in the Company and it was concluded that this arrangement was a common 
control transaction and not within the scope of IFRS 3 – Business Combinations.

As a result the Company accounted for this 45% interest in Moneysupermarket.com Financial Group Limited at original carrying value rather 
than fair value at the date of the acquisition. The acquisition of the remaining shares in Moneysupermarket.com Financial Group Limited was 
accounted for in accordance with IFRS 3 – Business Combinations applying the accounting guidance for a business combination achieved in 
stages. This resulted in the fair value of the identifiable assets, liabilities and contingent liabilities of Moneysupermarket.com Financial Group 
Limited being recognised in full and the goodwill in respect of the acquisition from third parties being recognised.

Revenue

Revenue is derived from the Group’s principal activity of providing price comparison and lead generation services on the internet. 
The Group generates fees from internet lead generation and commissions from brokerage sales through a variety of contractual 
arrangements.

Revenue is recognised when the Group has satisfied its performance obligations relating to a transaction. IFRS 15 – Revenue from 
Contracts with Customers requires the Group to allocate the transaction price to separate performance obligations within a contract.

The following table provides information about the nature and timing of the satisfaction of performance obligations and the related 
revenue recognition policies.

Type of sales transaction

Nature and timing of satisfaction of performance obligations

Revenue recognition policies

Price comparison services

The performance obligation is the provision of 
an internet lead to a provider’s website.

Revenue is recognised in the period in which the 
lead is provided.

Cashback services

The trigger for the transaction price to become 
receivable is usually a completed sale on the 
provider’s website. However, for some contracts 
the trigger is the point at which the lead is provided.

The transaction price is either a fixed amount per 
completed sale or a variable amount derived from 
the terms of the completed sale.

Revenue is generated from rendering services 
to the merchant. The performance obligation is 
the provision of an internet lead to a 
merchant’s website. 

The trigger for the transaction price to become 
receivable is a completed sale on the 
merchant’s website. 

The transaction price is derived from the terms 
of the completed sale.

At the period end an estimate of accrued revenue 
is made for leads provided that have resulted in 
completed sales. This is based on the volume of 
leads provided in the period, historic conversion 
rates and the expected price per completed sale.

For some contracts, an estimate of accrued revenue 
is also made for leads that will result in completed 
renewals. This is based on expected renewal rates 
and premiums.

Revenue is recognised in the period in which the 
lead is provided.

At the period end an estimate of accrued revenue 
is made for leads provided that will result in 
completed sales. This is based on the volume of 
leads provided in the period, historic conversion 
rates and the expected price per completed sale.

From historical experience and post year end confirmation, the Group does not expect there to be a material difference between the 
revenue accrued at the year end and the amount subsequently billed. Also, given there is a large volume of low value transactions, the 
risk of a significant reversal in the amount of cumulative revenue recognised is unlikely.

Judgement is applied in defining the customer for the cashback services. The customer is the merchant and the service provided is the 
delivery of an internet lead to their website. Accordingly, the cashback provided to members is not consideration payable to a customer 
and is recognised in cost of sales.

Cost of sales

The Group recognises associated costs of internet lead generation in the period that the lead is generated. Costs in respect of cashback 
and incentive payments made by the Group to users and members of our websites and revenue share for B2B partnerships are also 
included in cost of sales.

Unclaimed cashback balances in respect of Cashback members who have had no account activity for a consecutive 12-month period 
are released as a credit to cost of sales. This is in accordance with the terms and conditions agreed with members.

Advertising costs

The Group incurs costs from advertising via several different media. Costs associated with the production of adverts are recognised 
as an expense once the advert is aired or displayed. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

139

Financial StatementsNotes to the Consolidated Financial Statements continued

2. Summary of significant accounting policies continued
Property, plant and equipment

Property, plant and equipment is stated at cost less accumulated depreciation and any accumulated impairment losses. Subsequent 
expenditure is capitalised only if it is probable that the future economic benefits associated with the expenditure will flow to the Group. 
Where parts of an item of property, plant and equipment have different useful lives, they are accounted for as separate items of property, 
plant and equipment.

Depreciation is charged to the Statement of Comprehensive Income on a straight-line basis over the estimated useful life of each part of 
an item of property, plant and equipment. Assets under construction are not depreciated until brought into use. The estimated useful 
lives are as follows:

Land and buildings  

Plant and equipment (including IT equipment) 

Office equipment 

Fixtures and fittings 

10–50 years

3 years

5 years

5 years

The useful lives and depreciation rates are reassessed at each reporting date and adjusted if appropriate.

Intangible assets and goodwill

Goodwill

Goodwill is measured at cost less any accumulated impairment losses, with the carrying value being reviewed for impairment at least 
annually, and whenever there is an indication that the carrying value may be impaired.

Other intangible assets

The cost of other intangible assets acquired in a business combination is fair value as at the date of acquisition. After initial recognition, 
intangible assets are carried at cost less any accumulated amortisation and any accumulated impairment losses. All the Group’s 
intangible assets (other than goodwill) have been identified as having finite useful lives. As such, they are amortised on a straight-line 
basis over their useful economic life and assessed for impairment whenever there is an indication that the intangible asset may be 
impaired. The amortisation period and the amortisation method for an intangible asset with a finite useful life are reviewed at least at 
each reporting date and adjusted if appropriate. The amortisation expense on intangible assets with finite lives is recognised in the 
Statement of Comprehensive Income. The estimated useful lives are as follows:

Market-related 

Customer/member relationships 

Technology 

10 years

10 years

3–5 years

Internally generated and other intangible assets are amortised under the same method as noted above.

Market-related intangible assets are defined as those that are primarily used in the marketing or promotion of products and services, 
for example trademarks, trade names and internet domain names.

Customer-related intangible assets acquired by the Group consist of customer lists, customer contracts and relationships, and non-
contractual customer relationships. For accounting purposes, customer relationships and customer lists have been identified separately. 
Relationships with high-profile customers provide the Group with prominence in the marketplace, create volume and traffic on the 
website, and enhance the reputation of the brand. Customer lists allow the Group to undertake targeted marketing activities.

Member relationships relate to the Cashback vertical and are deemed to have value as they provide direct access to potential leads that 
can be transferred to the merchants’ websites.

Technology-based intangible assets relate to innovations and technical advances such as computer software, patented and unpatented 
technology, databases and trade secrets. Costs that are directly attributable to projects of a capital nature are recognised as technology-
based intangible assets controlled by the Group and are recognised when the following criteria are met:

•  it is technically feasible to complete the project so that it will be available for use;

•  management intends to complete the project and use it;

•  there is an ability to use or sell the project;

•  it can be demonstrated how the project will generate probable future economic benefits;

•  adequate technical, financial and other resources to complete the development and to use output of the project are available; and

•  the expenditure attributable to the project during its development can be reliably measured.

Directly attributable costs that are capitalised as part of the project can include employee and contractor costs. Other development 
expenditures that do not meet these criteria, as well as ongoing maintenance and costs associated with routine upgrades and 
enhancements, are recognised as an expense as incurred.

Subsequent expenditure is capitalised only when it increases the future economic benefits embodied in the specific asset to which it 
relates. All other expenditure, including expenditure on internally generated goodwill and brands, is recognised in profit or loss as incurred.

140 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2. Summary of significant accounting policies continued
Financial instruments

Recognition and initial measurement

Trade receivables and debt securities issued are initially recognised when they are originated. All other financial assets and financial 
liabilities are initially recognised when the Group becomes a party to the contractual provisions of the instrument.

Fixed asset and short-term investments in equity securities held by the Group are classified as fair value through other comprehensive 
income (‘FVOCI’) – equity instruments and are stated at fair value, with any resultant gain or loss being recognised directly in other 
comprehensive income (in the fair value reserve).

Cash and cash equivalents comprise cash balances and call deposits.

A financial asset (unless it is a trade receivable without a significant financing component) or financial liability is initially measured at fair 
value plus, for an item not at fair value through profit or loss (‘FVTPL’), transaction costs that are directly attributable to its acquisition 
or issue. A trade receivable without a significant financing component is initially measured at the transaction price.

Classification and subsequent measurement

Financial assets

Financial assets are not reclassified subsequent to their initial recognition unless the Group changes its business model for managing 
financial assets, in which case all affected financial assets are reclassified on the first day of the first reporting period following the 
change in the business model.

A financial asset is measured at amortised cost if it meets both of the following conditions and is not designated as at FVTPL:

•  it is held within a business model whose objective is to hold assets to collect contractual cash flows; and

•  its contractual terms give rise on specified dates to cash flows that are solely payments of principal and interest on the principal 

amount outstanding.

A debt investment is measured at FVOCI if it meets both of the following conditions and is not designated as at FVTPL:

•  it is held within a business model whose objective is achieved by both collecting contractual cash flows and selling financial assets; and

•  its contractual terms give rise on specified dates to cash flows that are solely payments of principal and interest on the principal 

amount outstanding.

All financial assets not classified as measured at amortised cost or FVOCI as described above are measured at FVTPL. This includes all 
derivative financial assets.

Financial assets – subsequent measurement and gains and losses

Financial assets at FVTPL

These assets are subsequently measured at fair value. Net gains and losses, including any interest 
or dividend income, are recognised in profit or loss.

Financial assets at amortised cost These assets are subsequently measured at amortised cost using the effective interest method. 

Debt investments at FVOCI

Equity investments at FVOCI

The amortised cost is reduced by impairment losses. Interest income, foreign exchange gains 
and losses and impairment are recognised in profit or loss. Any gain or loss on derecognition 
is recognised in profit or loss.

These assets are subsequently measured at fair value. Interest income calculated using the 
effective interest method, foreign exchange gains and losses and impairment are recognised 
in profit or loss. Other net gains and losses are recognised in OCI. On derecognition, gains 
and losses accumulated in OCI are reclassified to profit or loss.

These assets are subsequently measured at fair value. Dividends are recognised as income 
in profit or loss unless the dividend clearly represents a recovery of part of the cost of the 
investment. Other net gains and losses are recognised in OCI and are never reclassified to profit 
or loss.

Financial instruments and contract assets

The Group recognises loss allowances for Expected Credit Losses (‘ECLs’) on financial assets measured at amortised cost. The Group 
measures loss allowances at an amount equal to lifetime ECLs. Loss allowances wholly relate to trade receivables and contract assets 
are always measured at an amount equal to lifetime ECLs.

When determining whether the credit risk of a financial asset has increased significantly since initial recognition and when estimating 
ECLs, the Group considers reasonable and supportable information that is relevant and available without undue cost or effort. This 
includes both quantitative and qualitative information and analysis, based on the Group’s historical experience and informed credit 
assessment and including forward-looking information. The Group uses an allowance matrix to measure the ECLs of trade receivables 
from individual customers and assumes that the credit risk of default on a financial asset has increased significantly if it is more than 
120 days past due.

The maximum period considered when estimating ECLs is the maximum contractual period over which the Group is exposed to credit risk.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

141

Financial StatementsNotes to the Consolidated Financial Statements continued

2. Summary of significant accounting policies continued
Classification and subsequent measurement continued

Financial instruments and contract assets continued

At each reporting date, the Group assesses whether financial assets carried at amortised cost and debt securities at FVOCI are credit-
impaired. 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.

Loss allowances for financial assets measured at amortised cost are deducted from the gross carrying amount of the assets.

The gross carrying amount of a financial asset is written off when the Group has no reasonable expectations of recovering a financial 
asset in its entirety or a portion thereof. For individual customers, the Group has a policy of writing off the gross carrying amount when 
the financial asset is 180 days past due based on historical experience of recoveries of similar assets.

ECLs’ are a probability-weighted estimate of credit losses. Credit losses are measured as the present value of all cash shortfalls (i.e. the 
difference between the cash flows due to the Group in accordance with the contract and the cash flows that the Group expects to 
receive). ECLs are discounted at the effective interest rate of the financial asset.

Financial liabilities – classification, subsequent measurement and gains and losses

Financial liabilities are classified as measured at amortised cost or FVTPL. A financial liability is classified as at FVTPL if it is classified as 
held for trading, it is a derivative or it is designated as such on initial recognition. Financial liabilities at FVTPL are measured at fair value 
and net gains and losses, including any interest expense, are recognised in profit or loss. Other financial liabilities are subsequently 
measured at amortised cost using the effective interest method. Interest expense and foreign exchange gains and losses are recognised 
in profit or loss. Any gain or loss on derecognition is also recognised in profit or loss.

Derecognition

Financial asset

The Group derecognises a financial asset when the contractual rights to the cash flows from the financial asset expire, or 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.

Financial liability

The Group derecognises a financial liability when its contractual obligations are discharged or cancelled or expire. The Group also 
derecognises a financial liability when its terms are modified and the cash flows of the modified liability are substantially different, in 
which case a new financial liability based on the modified terms is recognised at fair value.

On derecognition of a financial liability, the difference between the carrying amount extinguished and the consideration paid (including 
any non-cash assets transferred or liabilities assumed) is recognised in profit or loss.

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. The transaction is assumed to take place in the principal or, in its absence, the most advantageous 
market to which the Group has access at that date.

A number of the Group’s accounting policies and disclosures require the measurement of fair values, for both financial and non-financial 
assets and liabilities. When one is available, the Group measures the fair value of an instrument using the quoted price in an active 
market for that instrument. A market is regarded as “active” if transactions for the asset or liability take place with sufficient frequency 
and volume to provide pricing information on an ongoing basis.

If there is no quoted price in an active market, then the Group uses valuation techniques that maximise the use of relevant observable 
inputs and minimise the use of unobservable inputs. The chosen valuation technique incorporates factors that market participants 
would take into account in pricing a transaction. In doing so, the Group consults with appropriate internal and external specialists to 
determine the fair valuation. Key assumptions are benchmarked against other comparable companies and sensitised to gain assurance 
that they fall within a reasonable range.

Impairment

Impairment of non-financial assets

The carrying amounts of the Group’s assets are reviewed annually to determine whether there is any indication of impairment. If such 
indication exists, the asset’s recoverable amount is estimated.

For the purposes of impairment reviews, the recoverable amount of the Group’s assets is taken to be the higher of their fair value less 
costs to sell and their value in use.

An impairment loss is recognised whenever the carrying amount of an asset or its cash-generating unit (‘CGU’) exceeds its recoverable 
amount. Impairment losses are recognised in the Consolidated Statement of Comprehensive Income.

See note 13 for full disclosure of how goodwill and impairment losses are allocated across the CGUs.

142 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

2. Summary of significant accounting policies continued
Employee benefits

Defined contribution plans

Obligations for contributions to defined contribution pension plans are recognised as an expense in the Consolidated Statement 
of Comprehensive Income as the related service is provided.

Share-based payment transactions

The Group’s share schemes allow certain Group employees to acquire ordinary shares in the Company. The fair value of share awards 
made is recognised as an employee expense with a corresponding increase in equity. The fair value is measured at the award date and 
spread over the period during which the employees become unconditionally entitled to the awards. The fair values of the share awards 
are measured using the Monte Carlo method for options subject to a market-based condition and the Black-Scholes model for all others, 
taking into account the terms and conditions upon which the awards were made. The amount recognised as an expense is adjusted to 
reflect the number of share awards expected to vest.

Short-term employee benefits

Short-term employee benefit obligations are measured on an undiscounted basis and are recognised as an expense in the Consolidated 
Statement of Comprehensive Income as the related service is provided.

A provision is recognised for the amount expected to be paid under short-term cash bonus or deferred bonus plan if the Group has a 
present legal or constructive obligation to pay this amount as a result of past service provided by the employee and the obligation can 
be estimated reliably. The Group’s deferred bonus plans currently do not have any ongoing performance obligations and are therefore 
provided for as described above in the period to which they related.

Finance income

Finance income comprises interest receivable from bank deposits and loan notes.

Finance costs

Finance costs comprise interest charged on borrowings, leases (recognised under IFRS 16 – Leases) and the unwind of discount 
on deferred consideration.

Leases

At inception of a contract, the Group assesses whether a contract is, or contains, a lease. A contract is, or contains, a lease if the contract 
conveys the right to control the use of an identified asset for a period of time in exchange for consideration. To assess whether a contract 
conveys the right to control the use of an identified asset, the Group uses the definition of a lease in IFRS 16 – Leases. 

Leased items are recognised on the balance sheet as an asset valued at its right of use and a corresponding liability that reflects the 
present value of future lease payments.

The asset is initially measured at its right-of-use value which reflects the total cost of lease payments, the direct costs incurred to bring 
the asset into use and an estimate of the cost that will be incurred when dismantling or uninstalling the item. The asset is then 
depreciated through the profit and loss account on a straight-line basis over the contract term of the lease.

The liability is initially recognised at the present value of future lease payments using the discount rate implicit in the lease if it can 
be determined or otherwise using the incremental borrowing rate of the Group.

Leased items with a value of less than £5,000 and items leased over a term of less than 12 months are not recognised on the balance sheet 
as an asset and liability. The cost of lease payments is recognised in the profit and loss account as they fall due on an accrued basis.

Dividends

Dividends payable to the Company’s shareholders are recognised as a liability and deducted from shareholders’ equity in the period 
in which the shareholders’ right to receive payment is established.

Taxation

Income tax expense comprises current and deferred tax. It is recognised in the Consolidated Statement of Comprehensive Income 
except to the extent that it relates to items recognised directly in equity, in which case it is recognised in equity.

Current tax is the expected tax payable on the taxable income for the year, using tax rates in force for the year, and any adjustment to tax 
payable in respect of previous years.

Deferred tax is provided on temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes 
and the amounts used for taxation purposes. The following temporary differences are not provided for: the initial recognition of goodwill; 
the initial recognition of assets or liabilities that affect neither accounting nor taxable profit other than in a business combination; and 
differences relating to investments in subsidiaries to the extent that they will probably not reverse in the foreseeable future. The amount 
of deferred tax provided is based on the expected manner of realisation or settlement of the carrying amount of assets and liabilities, 
using tax rates enacted or substantively enacted at the balance sheet date.

Research and development tax credits are accounted for as a government grant in accordance with IAS 20 – Accounting for Government 
Grants and Disclosure of Government Assistance. The credit is recognised once a reasonable estimate of the amount can be made.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

143

Financial StatementsNotes to the Consolidated Financial Statements continued

2. Summary of significant accounting policies continued
Taxation continued

A deferred tax asset is recognised only to the extent that it is probable that future taxable profits will be available against which the 
asset can be utilised.

Deferred tax liabilities are recognised at the expected future tax rate of the value of the intangible assets with finite lives which are 
acquired through business combinations representing the tax effect of the amortisation of these assets in future periods.

These liabilities will decrease in line with the amortisation of the related intangible assets, with the deferred tax credit recognised in 
the Statement of Comprehensive Income in accordance with IAS 12 – Income Taxes.

Reserve for own shares

The Group has a number of equity-settled, share-based employee incentive plans. In connection with these, shares in the Company are 
held by an Employee Benefit Trust (‘EBT’). The assets and liabilities of the EBT are required to be consolidated within these accounts as it 
is deemed to be under de facto control of the Group. The assets of the EBT mainly comprise Moneysupermarket.com Group PLC shares, 
which are shown as a deduction from total equity at cost.

Standards, amendments and interpretations issued but not yet effective

A number of new standards are effective for annual periods beginning after 1 January 2022 and earlier adoption is permitted; however, 
the Group has not early adopted the new or amended standards in preparing these Consolidated Financial Statements.

The following amended standards and interpretations are not expected to have a significant impact on the Group’s Consolidated 
Financial Statements and are either not yet effective or not yet adopted by the UK Endorsement Board. The below standards are those 
that are relevant to the Group.

Standard

Summary of changes

Amendments to IAS 1

Amendments to IAS 8

Amendments to IAS 1 – Presentation of Financial Statements to update requirements on determining 
the classification of liabilities as current or non-current; and disclosure of material accounting policies 
rather than significant accounting policies. Effective date 1 January 2023.

Amendments to IAS 8 – Accounting Policies, Changes in Accounting Estimates and Errors to introduce 
a new definition of accounting estimates and clarifying the relationship between accounting policies 
and accounting estimates. Effective date 1 January 2023.

Amendments to IAS 12

Amendments to IAS 12 – Income Taxes to provide clarification of accounting treatment in relation 
to deferred tax assets and liabilities arising from a single transaction. Effective date 1 January 2023.

Amendments to IFRS 17

Amendments to IFRS 17 – Insurance Contracts establishes the principles for the recognition, 
measurement, presentation and disclosure of insurance contracts within the scope of the standard. 
Effective date 1 January 2023.

3. Acquisitions and disposals
Podium Solutions Limited (‘Podium’)

On 23 December 2022, the Group gained control of Podium. Prior to this the Group had held a 50% investment in Podium which was 
accounted for as a joint venture. On completion of the transaction, the other shareholders of Podium exercised options which diluted 
the Group’s holding to 42%. The Group then acquired an additional 10% of the share capital bringing its holding up to 52%. Since then, 
the Group has been in control of Podium and has accounted for it as a subsidiary undertaking. For further information see note 28.

4. Revenue
All revenue is derived from the Group’s principal activity and is generated in the UK.

Revenue from price comparison services
Revenue from cashback services1

Total revenue

2022
£m

330.0
57.6

387.6

2021
£m

306.1
10.6

316.7

1 

 Revenue from cashback services in 2021 related to November and December only as we acquired Quidco Limited (formerly known as Maple Syrup Media Limited) on 1 November 2021.

144 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

5. Segmental information
Business segments

Below we report a measure of profitability at segment level that reflects the way performance is assessed internally. The Group has a 
number of teams, capabilities and infrastructure which are used to support all verticals, e.g. data platform and brand marketing. These 
are shared costs of the Group rather than “central costs”. We have concluded there is no direct or accurate basis for allocating these 
costs to the operating segments and therefore they are disclosed separately, which is how they are presented to the Chief Operating 
Decision Maker.

The Group’s reportable segments are Insurance, Money, Home Services, Travel and Cashback. These segments represent individual 
trading verticals which are reported separately for revenue and directly attributable expenses. Net finance expense, share of loss of 
equity accounted investments, tax and net assets are only reviewed by the Chief Operating Decision Maker at a consolidated level and 
therefore have not been allocated between segments. All assets held by the Group are located in the UK.

Travel includes revenue and directly attributable expenses from TravelSupermarket prior to 1 September 2021 and then the combined 
Ice Travel Group thereafter.

Cashback covers revenue and directly attributable expenses from Quidco Limited (formerly known as Maple Syrup Media Limited) 
following its acquisition on 1 November 2021.

The following summary describes the products and services in each segment.

Segment

Insurance

Products and services

Customer completes transaction for insurance policy on any of the following: provider website, our website 
or a telephone call.

Money

Customer completes transaction for money products such as credit cards, loans and mortgages on provider website.

Home Services

Customer completes transaction for home services products such as energy and broadband on provider website.

Travel

Cashback

Customer completes transaction for travel products on provider website or our website.

Customer completes transaction for retail, telecommunications, services and travel products with a cashback 
incentive on merchant website. Customer receives confirmed cashback incentive on our site.

Segment

Year ended 31 December 2022
Revenue
Directly attributable expenses

Adjusted EBITDA contribution
Adjusted EBITDA contribution margin1
Depreciation and amortisation
Profit on disposal of property, plant and equipment
Net finance expense
Share of loss of equity accounted investments
Change in fair value of financial instruments

Profit before tax
Taxation

Profit for the year

Insurance
£m

Money
£m

Home
 Services
£m

Travel
£m

Cashback
£m

172.0
(73.7)

98.3
57%

103.3
(31.0)

72.3
70%

39.8
(14.6)

25.2
63%

14.9
(10.0)

4.9
33%

57.6
(48.1)

9.5
16%

Shared 
costs
£m

—
(94.7)

(94.7)
—

Total
£m

387.6
(272.1)

115.5
30%
(26.5)
0.0
(3.5)
(0.3)
0.0

85.2
(15.9)

69.3

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

145

Financial StatementsNotes to the Consolidated Financial Statements continued

5. Segmental information continued
Business segments continued

Segment

Year ended 31 December 2021
Revenue
Directly attributable expenses

Adjusted EBITDA contribution
Adjusted EBITDA contribution margin1
Depreciation and amortisation
Deal fees and associated costs
Profit on disposal of property, plant and equipment
Net finance expense
Share of loss of equity accounted investments
Change in fair value of financial instruments

Profit before tax
Taxation

Profit for the year

Insurance
£m

Money
£m

158.7
(64.0)

94.7
60%

75.2
(24.4)

50.8
68%

Home
 Services
£m

68.1
(34.9)

33.2
49%

Travel
£m

Cashback
£m

4.1
(5.0)

(0.9)
(21%)

10.6
(8.8)

1.8
17%

Shared 
costs
£m

—
(79.1)

(79.1)
—

Total
£m

316.7
(216.2)

100.5
32%
(23.5)
(3.6)
0.1
(2.0)
(0.6)
(0.7)

70.2
(18.1)

52.1

1  Adjusted EBITDA contribution margin is calculated by dividing adjusted EBITDA contribution by revenue.

Insurance margin decreased from 60% to 57% year on year. This has been driven by the recovery in the lower margin travel insurance 
channel and the impact of FCA GI regulation on car and home, particularly in the first half. 

In Money, margin improved by 2ppt mainly due to the strong performance in banking which benefited from the consistent availability 
of attractive products.

In Home Services, margin improved by 14ppt primarily due to the loss of a large but low margin B2B contract in July 2021 and the decline 
of the lower margin energy business.

Travel trading rebounded driven by market recovery enabling it to return to profit in 2022.

Margin for Cashback is significantly lower than other verticals as a large proportion of commission is paid out to members as cashback; 
margin finished broadly in line year on year. In the first full year as part of the Group, contribution increased significantly compared to 
the two months of ownership in 2021.

Shared costs increased due to investments in the Group’s data platforms and security, as well as media and production spend in support 
of the early delivery of advertising campaigns and from inflationary pressures.

6. Operating profit
Operating profit is stated after charging items detailed in the table below.

Depreciation of property, plant and equipment
Amortisation of intangible assets
Auditor’s remuneration:
Audit of these Consolidated Financial Statements
Audit of subsidiaries’ Financial Statements

2022
£m

4.8
21.7

0.5
0.4

2021
£m

4.5
19.0

0.3
0.3

Non-audit related services provided by KPMG constituted a review opinion on the financial statements for the six-month period ended 
30 June 2022 which amounted to £0.06m (2021: £0.05m).

146 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

7. Staff numbers and cost
The average number of persons employed by the Group (including Directors) during the year, analysed by category, was as follows:

Technology and product operations
Administration

The aggregate payroll costs of these persons were as follows:

Wages and salaries
Compulsory social security contributions
Contributions to defined contribution plans
Share-based payment transactions
Social security contributions related to share awards and options
Capitalised staff costs

8. Net finance expense

Finance income
Loan notes 
Bank deposits

Total finance income

Finance expense
Revolving credit facility
Bank loan
Leases
Deferred consideration 

Total finance expense

Net finance expense

9. Taxation

Current tax
Current tax on income for the year
Adjustment in relation to prior period

Total current tax

Deferred tax
Origination and reversal of temporary differences
Adjustments due to changes in corporation tax rate
Adjustment in relation to prior period

Total deferred tax

Taxation 

2022
No.

265
468

733

2022
£m

50.6
6.2
2.1
2.2
0.3
(3.4)

58.0

2022
£m

0.3
0.0

0.3

(1.2)
(1.4)
(1.1)
(0.1)

(3.8)

(3.5)

2022
£m

18.3
0.4

18.7

(1.9)
(0.2)
(0.7)

(2.8)

15.9

2021
No.

290
461

751

2021
£m

49.4
5.5
1.9
1.4
(0.6)
(4.0)

53.6

2021
£m

0.0
0.1

0.1

(0.7)
(0.2)
(1.1)
(0.1)

(2.1)

(2.0)

2021
£m

15.9
(0.3)

15.6

(1.1)
3.5
0.1

2.5

18.1

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

147

Financial StatementsNotes to the Consolidated Financial Statements continued

9. Taxation continued
Reconciliation of the effective tax rate

The effective tax rate for the year is lower (2021: higher) than the standard rate of corporation tax in the UK of 19% (2021: 19%). 
The differences are explained below.

Profit before tax
Standard rate of tax at 19% (2021: 19%)
Effects of:
Expenses not deductible for tax purposes
Investments chargeable to tax not included in reported profit before tax
Movement related to share-based payments
Change in fair value of financial instruments
Impact of changes in tax rate
Adjustments in relation to prior periods

Taxation

2022
£m

85.2
16.2

0.1
— 
0.1
(0.0)
(0.2)
(0.3)

15.9

2021
£m

70.2
13.3

0.9
0.3
0.2
0.1
3.5
(0.2)

18.1

In March 2021, an increase in the UK corporation tax rate from 19% to 25% (effective 1 April 2023) was substantively enacted. 
The deferred tax liability at the balance sheet date has been calculated based on a rate of 25%.

10. Earnings per share 
Basic earnings per share

Basic earnings per share is calculated by dividing the profit or loss for the year attributable to ordinary equity holders of the Company, 
by the weighted average number of ordinary shares outstanding during the year. The Company’s own shares held by employee trusts 
are excluded when calculating the weighted average number of ordinary shares outstanding.

Diluted earnings per share

Diluted earnings per share is calculated by dividing the profit or loss for the year attributable to ordinary equity holders of the Company, 
by the weighted average number of ordinary shares outstanding during the year plus the weighted average number of ordinary shares 
that would be issued on the conversion of all dilutive potential ordinary shares into ordinary shares.

Earnings per share

Basic and diluted earnings per share have been calculated on the following basis:

Profit after taxation attributable to the owners of the Company (£m)
Basic weighted average shares in issue (millions)
Dilutive effect of share-based instruments (millions)
Diluted weighted average shares in issue (millions)
Basic earnings per share (p)
Diluted earnings per share (p)

Adjusted basic and diluted earnings per share have been calculated as follows:

Profit before tax
Adjusted for (profit)/loss before tax attributable to non-controlling interest

Profit before tax attributable to the owners of the Company
Amortisation of acquisition related intangible assets
Amortisation of acquisition related intangible assets attributable to non-controlling interest
Deal fees and associated costs
Deal fees and associated costs attributable to non-controlling interest
Change in fair value of financial instruments

Estimated taxation at 19% effective rate (2021: 19%)

Profit for adjusted earnings per share purposes

Adjusted basic earnings per share (p)

Adjusted diluted earnings per share (p)

2022

68.3
536.5
2.4
538.9
12.7
12.7

2022
£m

85.2
(1.2)

84.0
11.3
(0.2)
—
— 
(0.0)

95.1 
(18.1)

77.0

14.4

14.3

2021

52.7
536.4
0.1
536.5
9.8
9.8

2021
£m

70.2
0.7

70.9
4.4
(0.1)
3.6
(0.6)
0.7

78.9
(15.0)

63.9

11.9

11.9

148 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

11. Dividends

Declared and paid dividends on ordinary shares:
Prior year final dividend
Interim dividend

Total dividend paid in the year

Proposed for approval (not recognised as a liability at 31 December):
Final dividend

2022

pence per
share

8.61
3.10

11.71

8.61

Total
£m

46.2
16.6

62.8

46.2

2021

pence per
share

8.61
3.10

11.71

8.61

12. Property, plant and equipment

Cost:
At 1 January 2021
Acquisitions through business combinations
Additions
Disposals

At 31 December 2021

At 1 January 2022
Additions
Disposals

At 31 December 2022

Depreciation:
At 1 January 2021
Depreciation for the year
Disposals

At 31 December 2021

At 1 January 2022
Depreciation for the year
Disposals

At 31 December 2022

Carrying value:
At 31 December 2021

At 31 December 2022

Land and
buildings
£m

Plant and
equipment
£m

Office
equipment
£m

Fixtures and
fittings
£m

49.5
1.7
—
(1.6)

49.6

49.6
—
(2.0)

47.6

9.8
3.6
(0.6)

12.8

12.8
4.0
(2.0)

14.8

36.8

32.8

20.2
0.4
0.6
(0.5)

20.7

20.7
0.4
—

21.1

18.4
0.6
(0.5)

18.5

18.5
0.6
—

19.1

2.2

2.0

1.5
—
0.0
—

1.5

1.5
0.0
—

1.5

0.7
0.1
—

0.8

0.8
0.1
—

0.9

0.7

0.6

2.1
—
0.0
—

2.1

2.1
—
(0.0)

2.1

1.8
0.2
—

2.0

2.0
0.1
(0.0)

2.1

0.1

0.0

Total
£m

46.2
16.6

62.8

46.2

Total
£m

73.3
2.1
0.6
(2.1)

73.9

73.9
0.4
(2.0)

72.3

30.7
4.5
(1.1)

34.1

34.1
4.8
(2.0)

36.9

39.8

35.4

Land and buildings includes right-of-use assets of £22.4m (2021: £25.4m) related to leased properties that do not meet the definition 
of investment property (see note 24). 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

149

Financial StatementsNotes to the Consolidated Financial Statements continued

13. Intangible assets and goodwill

Cost:
At 1 January 2021
Acquisitions through business combinations
Additions internally developed
Disposals

At 31 December 2021

At 1 January 2022
Acquisitions through business combinations
Additions internally developed
Transfers

At 31 December 2022

Amortisation:
At 1 January 2021
Amortisation charge for the year
Disposals

At 31 December 2021

At 1 January 2022
Amortisation charge for the year

At 31 December 2022

Carrying value:
At 31 December 2021

At 31 December 2022

Market
related
£m

155.3
14.3
—
—

169.6

169.6
—
—
—

169.6

148.5
2.0
—

150.5

150.5
2.8

153.3

19.1

16.3

Customer/
member
relationship
£m

Technology
related
£m

Goodwill
£m

—
21.2
—
—

21.2

21.2
—
—
—

21.2

—
0.4
—

0.4

0.4
2.1

2.5

20.8

18.7

101.5
15.4
9.2
(2.7)

123.4

123.4
3.2
10.0
0.5

137.1

75.8
16.6
(2.7)

89.7

89.7
16.8

106.5

33.7

30.6

212.6
76.5
—
—

289.1

289.1
—
—
(0.5)

288.6

74.3
—
—

74.3

74.3
— 

74.3

214.8

214.3

Total
£m

469.4
127.4
9.2
(2.7)

603.3

603.3
3.2
10.0
—

616.5

298.6
19.0
(2.7)

314.9

314.9
21.7

336.6

288.4

279.9

Acquisitions through business combinations

Details of acquisitions through business combinations can be found in note 28.

Additions internally developed

Included within the technology related intangible assets are technology related intangible assets under development with a net carrying 
value of £3.7m (2021: £5.6m).

In order to accurately quantify the value of internally generated technology assets the Group undertakes project tracking to record the 
cost of both internal and contract staff wholly assigned to each project. Third party costs incurred are allocated to investment projects and 
recognised at purchase cost. This approach ensures that technology related intangible assets accurately reflect the cost of development. 
As highlighted in note 2, there is a degree of judgement regarding the recognition of costs incurred in developing technology related intangible 
assets. This is due to the asset recognition criteria being predicated on future economic benefit flowing from that asset. The Directors 
are satisfied that any spend capitalised meets the criteria of IAS 38 – Intangible Assets and, where relevant, SIC-32 Intangible Assets – 
Web Site Costs. On an annual basis, or where an indication exists, the Group is required to assess its goodwill and intangible assets for 
impairment. See below for this assessment for goodwill and technology related assets.

Disposals

Disposals in the prior year include assets with a combined gross book value of £2.7m and carrying value of £nil that were no longer in use 
and were therefore retired. There was no impact on profit or loss arising from this.

Intangible assets and goodwill

The Group employs the services of appropriately qualified and experienced experts to value the intangible assets acquired as part of 
any business combinations. For larger acquisitions and more complex intangible assets, the Group employs independent third parties 
to assist our in-house team. At 31 December 2022, the Group had significant balances relating to goodwill as a result of acquisitions of 
businesses in the current and previous years. Goodwill balances are tested annually for impairment or if events or changes in circumstances 
indicate that the carrying amount of these assets may not be recoverable.

150 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

13. Intangible assets and goodwill continued
Intangible assets and goodwill continued

The Group is required to allocate goodwill between its cash generating units (‘CGUs’) that represent the lowest level within the Group at 
which goodwill is monitored for internal management purposes. These CGUs are Insurance, Money, Home Services, Travel and Cashback. 
The Group has performed impairment testing at a CGU level for all CGUs.

Goodwill is allocated to each CGU as follows:

Insurance
Money
Home Services
Travel
Cashback

Goodwill

Impairment review 

31 December
2022
£m

31 December
2021
£m

46.5
33.2
54.8
11.5
68.3

46.5
33.2
54.8
11.5
68.8

214.3

214.8

For all CGUs the present value of the future cash flows has been calculated using management’s best estimate of future cash flows, 
which are based on the Group’s long term plan, approved in January 2023, incorporating cost of sales, advertising and an allocation of 
overhead costs. The forecast assumes continued growth in each CGU; with many change programmes delivered in 2022 we expect to see 
the benefits in future years with market growth in a number of channels. In accordance with IAS 36 – Impairment of Assets, the Group 
is required to test goodwill for impairment annually. We test impairment at a CGU level by comparing the net present value of future cash 
flows, derived from the latest budget and long term plan, to the carrying value of the total assets. The value in use method requires the 
Group to determine appropriate assumptions (which are sources of estimation uncertainty) in relation to the cash flow projections over 
the strategic plan period, the long-term growth rate to be applied beyond this period and the risk-adjusted pre-tax discount rate used 
to discount the assumed cash flows to present value: 

•  Cash flows beyond our strategic planning period have been calculated as a perpetuity inclusive of an annual growth of 2.7% 

(2021: 1.0%). This year, given recent volatility in Gross Domestic Product (GDP) growth rates, our rate is taken over a longer period 
of 7 years per the Office for Budget Responsibility forecast average for growth in the UK’s GDP. 

•  The pre-tax discount rate for the Group has been determined as 13.5% (2021: 13.5%). Management estimate discount rates using 

pre-tax rates that reflect current market assessments of the time value of money and the risks specific to a CGU. In the prior year the 
Group discount rate was at the higher end of our range and reflected uncertainty in key channels, particularly within Insurance due 
to the regulatory changes introduced in early 2022 and in the travel sector due to COVID-19 disruption at the time. Now with reduced 
uncertainty in key channels, maintaining the rate the same this year incorporates the current rising rates environment and increases 
to the risk-free premium. Each CGU faces different market-specific risks, but these are not considered significant enough to justify 
more than a small adjustment to the risk premium applied to each CGU (these are described below). 

Our assessment confirms there is headroom across all CGUs and the Directors have therefore concluded no impairment of goodwill is 
required (after considering sensitivities there is no reasonable change in assumptions to cause an impairment in any CGU). The 
headroom in the Cashback CGU is more sensitive than the other CGUs to assumptions on the discount rate and revenue growth as 
explained below).

Insurance, Money, Home Services and Travel CGUs

The present value of the future cash flows has been calculated with the following key assumptions:

•  A 3 year Board approved cash flow forecast, incorporating past experience, based on market growth, visitor volumes, source 

of visitors, revenue per transaction/visitor and marketing spend. 

•  A pre-tax discount rate of 13.5% (2021: 13.5%) for Insurance and Money in line with the Group rate. 

•  A pre-tax discount rate of 15.5% (2021: 16.5%) for the Travel and Home Services CGUs, which incorporates a risk premium of 2% 

to reflect management’s assessment of specific risks related to this CGU.

The assessment concludes that the recoverable amount of the assets allocated to the Insurance, Money, Home Services and Travel CGUs 
exceeds their carrying value by in excess of 100% (2021: in excess of 100%). No reasonable possible change to a key assumption would 
therefore result in an impairment.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

151

Financial StatementsNotes to the Consolidated Financial Statements continued

13. Intangible assets and goodwill continued
Cashback CGU

The present value of the future cash flows has been calculated with the following key assumptions:

•  A 5 year Board approved cash flow forecast based on market growth, active member transactions, revenue per purchase, gross profit, 
member drawdowns and marketing spend. A longer forecast time frame (5 years) has been used for the Cashback CGU to reflect the 
synergies expected from being part of the Group. 

•  A pre-tax discount rate of 15.5% has been applied to the Cashback CGU, which reflects a 2% risk premium to the Group discount rate 

to reflect management’s assessment of specific risks related to this CGU. 

The recoverable amount of the assets allocated to the Cashback CGU exceeds the carrying value by £13m, or 16%. The value in use 
calculation is sensitive to key assumptions such as the discount rate and revenue growth. As reasonable sensitivities, with all other 
assumptions unchanged, increasing the discount rate to 16.0% would reduce the headroom to £9.4m and decreasing the revenue growth 
forecast by an average of 5% each year would reduce the headroom to £5.1m. An increase in the discount rate to 17.4% or a decrease 
in the revenue growth by an average of 9% each year would reduce the headroom to nil. 

Group impairment testing

As explained in note 5, in our segmental reporting we allocate costs across our operating segments where they can be allocated 
directly or on a reasonable and consistent basis, however a number of the significant costs which the Group incurs cannot be allocated 
either directly or on a reasonable and consistent basis to the CGUs. These shared costs are reviewed at that level by the Group’s Chief 
Operating Decision Maker. Therefore the cash flows estimated for these CGUs include all of the Group’s forecast segmental profit 
contributions and an allocation of the Group’s forecast shared costs.

The Group has therefore also performed a further impairment test for the Group as a whole, in a manner consistent with previous 
years. In these calculations the Group is treated as one group of CGUs, and the test compares the carrying amount, including goodwill 
and other corporate assets, to the recoverable amount.

The recoverable amount has been estimated based on the present value of its future cash flows, which has been calculated with a set 
of assumptions consistent with those set out above in relation to the individual operating segment calculations.

The analysis performed calculates that the recoverable amount of the Group’s assets exceeds their carrying value by in excess of 100% 
(2021: in excess of 100%), and as such, no impairment was identified.

The Group has completed sensitivity analysis as part of its impairment testing procedures by flexing both cash flow and discounting 
assumptions significantly. The headroom on goodwill is such that there are no foreseeable scenarios in which the Group would need 
to consider an impairment.

In conclusion, no reasonably possible change to a key assumption would result in an impairment (2021: same).

Impairment testing of technology and market related intangible assets

Technology and market related intangible assets in use by the Group are tested for impairment if there is an indication that the asset 
may be impaired. In line with IAS 36 – Impairment of Assets, the Group also conducts annual impairment testing of significant technology 
related intangible assets under development and not yet available for use. The impact of travel recovery and the current conditions 
affecting the energy switching market were deemed to be indicators of a potential impairment of the technology assets in the Travel CGU 
and in the Home Services CGU. Impairment testing was therefore performed, which determined that the recoverable amounts of these 
assets exceed their carrying values. 

14. Equity accounted investments
The carrying amounts of equity accounted investments as at 31 December 2022 was £nil (2021: £0.0m). The Group’s share of post-tax 
loss of equity accounted investees for the year was £0.3m (2021: £0.6m). Equity accounted investments in both the current and prior 
years relate solely to Podium Solutions Limited (‘Podium’). 

In March 2018, the Group obtained joint control and a 50% ownership interest in Podium, which it accounted for as a joint venture. 
Podium is a financial technology business, principally engaged in developing digital solutions in the mortgages sector. Podium is not 
publicly listed and is registered at Fourth Floor, Market Square House, St James Street, Nottingham, Nottinghamshire, NG1 6FG. On 
23 December 2022, the Group increased its shareholding to 52% and thereby gained control of Podium. This investment has 
subsequently been accounted for as a subsidiary undertaking (see notes 3 and 28). 

152 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

15. Other investments 
The carrying amounts of other investments as at 31 December 2022 are shown in the table below. The investments are held at fair value 
with gains and losses being recognised through other comprehensive income (see note 21).

Investments in equity securities

At 1 January 2021
Disposals in the year
Change in fair value

At 31 December 2021

At 1 January 2022
Change in fair value

At 31 December 2022

Truelayer
Limited
£m

Flagstone
Group Limited 1
£m

By 
Miles Ltd
£m

Plum Fintech
Limited
£m

1.4
(2.1)
0.7

—

—
—

—

3.6
—
—

3.6

3.6
0.6 

4.2

2.6
—
—

2.6

2.6
(2.6)

0.0

0.6
—
0.7

1.3

1.3
—

1.3

Total
£m

8.2
(2.1)
1.4

7.5

7.5
(2.0)

5.5

1  Name of company changed from Flagstone Investment Management Limited to Flagstone Group Limited on 28 July 2022.

The total charge to other comprehensive income in respect of changes in fair value of other investments was £1.4m (2021: £1.4m credit). 

In December 2022, the fair value of the Group’s investment in By Miles Ltd was deemed to be £0.0m (2021: £2.6m). The original cost of 
the investment was £0.6m and accumulated fair value uplifts of £2.0m had been recognised in the fair value reserve (within other 
reserves) in prior years. £2.0m was therefore deducted from other reserves and £0.6m was charged to retained earnings. 

During the year, a fair value uplift of £0.6m was also recognised in respect of the Group’s investment in Flagstone Group Limited. This has 
been recognised in the fair value reserve within other reserves. 

In May 2021, the Group disposed of its investment in Truelayer, receiving sales proceeds on an arm’s length basis of £2.1m. This resulted 
in a fair value uplift immediately prior to disposal of £0.7m which was recognised as other comprehensive income. On disposal, £1.7m of 
fair value gains were transferred from the fair value reserve (in other reserves) to retained earnings.

During the prior year, the Group also recognised a fair value uplift of £0.7m in respect of Plum Fintech Limited.

Sensitivity analysis

For the fair value of investments, a 5% movement in share price would have an effect of £0.3m (2021: £0.4m) on the total value.

16. Trade and other receivables

Trade and other receivables

All receivables fall due within one year.

31 December
2022
£m

31 December
2021
£m

63.5

65.3

The comparative trade and other receivables balance as at 31 December 2021 has been restated from £61.5m to £65.3m (see note 28).

From historical experience and post year end confirmation, the Group expects any differences between the amounts accrued at year 
end and those amounts subsequently billed to not be materially different. The under and overestimates on accrued revenue are 
typically in a region of -1% to +3%; historically this has been an under estimate of accrued revenue. A -1% to +3% difference on the £53.7m 
(2021 restated: £51.1m) revenue accrual would equate to approximately (£0.5m) to £1.6m (2021: (£0.5m) to £1.5m). 

The assumptions used to calculate the revenue accrual have been disclosed within note 2.

At 31 December 2022, trade receivables are shown net of a provision for credit losses of £1.6m (2021: £1.6m), which represents a judgement made 
by management of which receivables balances are unlikely to be recovered taking into consideration the ageing of the debt, evidence of poor payment 
history or financial position of a particular customer. The balance is largely related to energy providers which ceased trading in the prior year.

Movements in the provision for credit losses were as follows:

At 1 January
Provisions made in the year
Provisions utilised in the year

At 31 December

31 December
2022
£m

31 December
2021
£m

1.6
0.0
(0.0)

1.6

0.2
1.6
(0.2)

1.6

At 31 December, the analysis of trade and other receivables that were past due but not impaired was as follows:

At 31 December 2021

At 31 December 2022

Neither past
due nor
impaired
£m

Past due not impaired

0–30 days
£m

30–60 days
£m

60–90 days
£m

90–120 days
£m

>120 days
£m

57.7

60.1

4.5

2.5

2.2

0.4

0.7

0.3

0.2

0.2

0.0

0.0

Total
£m

65.3

63.5

The Group’s standard payment terms are typically 15 days (2021: 15 days) from the invoice date. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

153

Financial StatementsNotes to the Consolidated Financial Statements continued

17. Trade and other payables
Non-current

Lease liabilities
Deferred consideration
Amounts owed to non-controlling interest

Other payables

31 December
2022
£m

31 December
2021
£m

25.9
— 
1.8

27.7

28.5
9.8
— 

38.3

Deferred consideration relates to amounts payable for the acquisition of Quidco. At 31 December 2022, all amounts outstanding 
are presented within current liabilities.

Amounts owed to non-controlling interest includes balances acquired as part of the acquisition of Podium in December 2022 (see note 28). 

Current

Trade payables
Non-trade payables and accrued expenses
Other payables
Lease liabilities
Deferred income
Deferred consideration 

Trade and other payables

31 December
2022
£m

31 December
2021
£m

36.4 
2.8
47.0 
2.7 
0.8 
9.8 

99.5 

35.9
2.3
47.3
3.2
0.4
4.8

93.9

As a result of click-based revenue being recognised in the period that the lead is generated, an accrual for cost of sales, such as partner 
revenue share agreements, relating to the revenue accrued at the year end is included within trade payables (see note 16).

The comparative other payables balance as at 31 December 2021 has been restated from £43.5m to £47.3m (see note 28).

Other payables relate to amounts due to Cashback members. This balance is net of an estimated cancellation rate (i.e. clicks which do not 
result in completed sales), based on historical data, and therefore reflects the amount that is expected to be payable. A -/+3ppt change in 
this cancellation rate would equate to approximately £0.4m (2021: £0.5m). This balance is payable once the sale has been completed, the 
cash has been received from the merchant and the member has requested payment.

Deferred consideration has been discounted to its present value and the unwind is treated as a finance expense (see note 8). 

18. Borrowings
Non-current

Loan

Current

Revolving credit facility
Loan

Total

31 December
2022
£m

31 December
2021
£m

30.0

40.0

31 December
2022
£m

31 December
2021
£m

4.0
10.0

14.0

7.5
10.0

17.5

The revolving credit facility provides £90m in committed funds with £47m provided by Barclays, £38m by BOI and £5m by SVB. The £50m 
term loan was taken out in October 2021 is repayable in instalments over the period to October 2024. It was funded £28m by Barclays, 
£7m by BOI and £15m by SVB.

Interest is payable on the facilities at a rate of SONIA plus an applicable margin based on the adjusted leverage of the Group. At 
31 December 2022, the Group had £40.0m (2021: £50.0m) outstanding on the term loan and £4.0m (2021: £7.5m) drawn down on the 
revolving credit facility. The remaining balance of the upfront arrangement fees, totalling £0.3m (2021: £0.4m), is held within prepayments.

154 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

19. Deferred tax liabilities
Deferred tax assets and liabilities are attributable to the following:

Goodwill related to MoneySavingExpert.com
Intangible assets and goodwill relating to other acquisitions
Share schemes
Accelerated capital allowances
Losses

Deferred tax liability

The following table illustrates the movement in the deferred tax liabilities during the year:

At 1 January
Temporary differences on:
Goodwill related to MoneySavingExpert.com
Intangible assets and goodwill relating to other acquisitions
Share schemes
Accelerated capital allowances
Losses

At 31 December

31 December
2022
£m

31 December
2021
£m

13.2
11.3
(0.5)
(0.2)
(1.3)

22.5

2022
£m

25.3

(0.1)
(1.3)
(0.3)
(0.2)
(0.9)

22.5

13.3
12.2
(0.2)
0.4
(0.4)

25.3

2021
£m

11.4

3.0
11.2
— 
0.1
(0.4)

25.3

Deferred tax liabilities arose from the recognition of the intangible assets and goodwill upon the acquisition of Moneysupermarket.com 
Financial Group Limited, MoneySavingExpert.com Limited, Decision Technologies Limited, CYTI (Holdings) Limited, Ice Travel Group 
Limited, Quidco Limited (formerly known as Maple Syrup Media Limited) and Podium Solutions Limited.

Deferred tax assets arise on share option schemes based on the expected tax deduction on vesting. Deferred tax assets have also been 
recognised for unused tax losses to the extent that it is probable that future taxable profits will be available against which they can be used.

Deferred tax assets and liabilities have been calculated at the applicable tax rate enacted at the balance sheet date of 25% (2021: 25%).

20. Called up share capital
The nominal value of ordinary shares is 0.02p. The holders of ordinary shares are entitled to returns of capital, receive a dividend 
and vote.

Issued and fully paid

Number of ordinary shares

At the beginning of the year
Issued on exercise of SAYE options

At the end of the year

Nominal value of ordinary shares

At the beginning of the year
Issued on exercise of SAYE options

At the end of the year

2022
No.

2021
No.

536,861,647
— 

536,700,541
161,106

536,861,647

536,861,647

2022
£

107,372
— 

107,372

2021
£

107,340
32

107,372

The Group operates a Long Term Incentive Plan under which conditional nil cost awards of ordinary shares in the Company have been 
made to certain Directors and employees of the Group, and an HMRC approved Save As You Earn scheme (‘Sharesave’) is eligible to all 
employees (see note 23).

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

155

Financial StatementsNotes to the Consolidated Financial Statements continued

21. Financial instruments
Interest rate risk

The Group invests its cash in a range of cash deposit accounts with UK banks. Interest earned therefore closely follows movements in 
the Bank of England base rate. A movement of 1% in this rate would result in a difference in annual pre-tax profit of £0.1m (2021: £0.1m) 
based on Group cash, cash equivalents and financial instruments at 31 December 2022. At the balance sheet date, £6.3m (2021: £5.3m) 
was invested with Barclays Bank, this being the most invested with any one bank in both years.

Fair values

The Group’s financial assets and liabilities are principally short term in nature, and therefore their fair value is not materially different 
from their carrying value. The valuation method for the Group’s financial assets and liabilities can be defined as follows:

Level 1:  Quoted prices (unadjusted) in active markets for identical assets or liabilities.

Level 2:  

 Inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either directly 
(i.e. as prices) or indirectly (i.e. derived from prices).

Level 3: 

 Inputs for the asset or liability that are not based on observable market data (unobservable inputs).

All investments and derivatives fall under Level 3 as the fair value is measured using the latest unquoted share price of recent 
transactions, with updates made as required considering market conditions at year end. A reconciliation is provided in note 15. All other 
financial assets and liabilities are held at amortised cost and other financial liabilities respectively in accordance with IFRS 9 – Financial 
Instruments. There have been no transfers between levels in the year.

The Directors consider that the carrying amounts of financial assets and financial liabilities recorded at amortised cost in the financial 
statements approximate their fair values.

Effective interest rates

In respect of interest-earning financial assets, the following table indicates their effective interest rates at the year end date:

Cash and cash equivalents

Credit risk

31 December 2022

31 December 2021

Effective
interest rate

0.09%

£m

16.6

Effective
interest rate

0.07%

£m

12.5

Credit risk refers to the risk that a counterparty will default on its contractual obligations resulting in a financial loss to the Group. The 
Group has adopted a policy of only dealing with creditworthy counterparties as a means of mitigating risk of financial loss from default. 
The Group’s exposure is regularly monitored by the credit control team and finance management.

Of the top 75% of the Group’s providers by revenue, approximately 28% (2021: 26%) of these are UK quoted companies with the 
remainder being a mixture of larger UK independent companies and overseas owned or quoted companies. At the balance sheet date, 
the five largest trade and other receivables, by provider, accounted for 31% (2021: 18% restated) of the total trade and other receivables 
balance of £63.5m (2021: £65.3m restated) and the largest individual balance was £6.4m (2021: £4.8m). The comparatives have been 
restated to reflect the prior year adjustment to trade and other payables (see note 28).

The Directors do not consider there to be any material contracts with providers in the Group.

Liquidity risk

Liquidity risk refers to the risk that the Group will encounter difficulty in meeting the obligations associated with its financial liabilities. 
The Group manages liquidity risk by maintaining adequate reserves and banking facilities by continuously monitoring forecast and actual 
cash flows. Details of additional undrawn facilities that the Group has at its disposal to further reduce liquidity risks are set out below:

Unsecured borrowings facilities
– amount drawn
– amount undrawn

For details of the Group’s unsecured borrowings facilities see note 18.

The covenants in place in relation to the facilities are outlined below:

31 December
2022
£m

31 December
2021
£m

44.0
86.0

57.5
82.5

Adjusted leverage is calculated by dividing adjusted EBITDA by net debt, which consists of cash less borrowings, lease liabilities 
and deferred consideration. Interest cover is calculated by dividing adjusted EBITDA by net finance charges. The Group continues 
to have significant headroom over the covenants.

156 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

21. Financial instruments continued
Exposure to liquidity risk

The following are the remaining contractual maturities of financial liabilities at the reporting date. The amounts are gross and undiscounted.

At 31 December 2022

120.6

(120.6)

(40.8)

(22.2)

(32.8)

31 December 2022

Non-derivative financial liabilities
Deferred consideration
Trade payables
Borrowings
Lease liabilities
– undiscounted cash flows
– discounting
Amounts owed to non-controlling interest

Carrying
amount
£m

9.8
36.4
44.0

33.7
(5.1)
1.8

31 December 2021

Non-derivative financial liabilities
Deferred consideration
Trade payables
Borrowings
Lease liabilities
–  undiscounted cash flows
– discounting

Carrying
amount
£m

14.6
35.9
57.5

37.8
(6.1)

Total
£m

<2 months
£m

2–12 months
£m

1–2 years
£m

2–5 years
£m

>5 years
£m

Contractual cash flows

(9.8)
(36.4)
(44.0)

(33.7)
5.1
(1.8)

—
(36.4)
(4.0)

(0.6)
0.2
—

(9.8)
—
(10.0)

(3.2)
0.8
—

—
—
(30.0)

(3.7)
0.9
—

—
—
—

(11.0)
2.0
—

(9.0)

—
—
—

(15.2)
1.2
(1.8)

(15.8)

Total
£m

<2 months
£m

2–12 months
£m

1–2 years
£m

2–5 years
£m

>5 years
£m

Contractual cash flows

(14.6)
(35.9)
(57.5)

(37.8)
6.1

(0.9)
(35.9)
(7.5)

(0.7)
0.2

(3.9)
—
(10.0)

(3.5)
0.9

(16.5)

(9.8)
—
(10.0)

(3.8)
0.9

(22.7)

—
—
(30.0)

(11.1)
2.3

(38.8)

—
—
—

(18.7)
1.8

(16.9)

At 31 December 2021

139.7

(139.7)

(44.8)

The lease liability cash flows are spread evenly between 2-5 years.

22. Group management of capital
The Group’s objectives when managing capital are:

•  to safeguard the entity’s ability to continue as a going concern, so that it can continue to provide returns for shareholders and benefits 

for other stakeholders; and

•  to provide an adequate return to shareholders by pricing products and services commensurately with the level of risk.

The Group sets the amount of capital in proportion to risk. The Group manages the capital structure and makes adjustments to it in 
the light of changes in economic conditions and the risk characteristics of the underlying assets. In assessing the level of capital all 
components of equity are taken into account, i.e. share capital, retained earnings and reserves (where applicable). The table below 
summarises the carrying value of each component.

Carrying value

Share capital
Retained earnings and reserves
Non-controlling interest

Total

31 December
2022
£m

31 December
2021
£m

0.1
208.6
6.0 

214.7

0.1
203.2
4.3

207.6

In line with internal capital management requirements, the Group manages its cash balances by, where possible, depositing them with a 
number of financial institutions to reduce credit risk. The table below summarises the credit rating of each financial institution that held 
cash at 31 December 2022.

Credit rating

Barclays Bank PLC
Lloyds Bank Plc
HSBC Bank Plc
Natwest Bank Plc
Silicon Valley Bank

2022

A
A
AA-
A
BBB+

2021

A
A
AA-
A
BBB+

One way in which the Group manages capital is utilising the revolving credit facility, as set out in note 18.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

157

Financial StatementsNotes to the Consolidated Financial Statements continued

22. Group management of capital continued
Management of capital focuses around the Group’s ability to generate cash from its operations. In order to maintain or adjust the capital 
structure, the Group may adjust the amount of dividends paid to shareholders, return capital to shareholders, issue new shares, or sell 
assets to raise funds. The Directors are satisfied that the Group is meeting its objectives for managing capital as funds are available for 
reinvestment where necessary as well as being in a position to make returns to shareholders where this is felt appropriate.

There were no changes to the Group’s approach to capital management during the year.

23. Share-based payments
The share-based payment charge in the Consolidated Statement of Comprehensive Income relates to the following types of share option 
and share award:

Long Term Incentive Plan 
Restricted Share Awards
Sharesave Scheme
Share Incentive Plan 

Share-based payment transactions

Long Term Incentive Plan (‘LTIP’)

31 December
2022
£m

31 December
2021
£m

1.0
0.7
0.5
 — 

2.2

0.6
0.3
0.5
 — 

1.4

Each year conditional awards are made over ordinary shares under the Moneysupermarket.com Group PLC Long Term Incentive Plan 
(‘LTIP’) schemes to senior employees. Under each scheme, the awards vest at the end of a three-year period dependent on certain 
performance criteria being met, as outlined below:

•  achievement of a specified average growth rate in adjusted basic EPS at the end of the vesting period;

•  the total shareholder return (‘TSR’) of the Company relative to a comparator group of defined companies; and/or

•  Group revenue performance.

Restricted Share Award (‘RSA’)

Conditional awards are made over ordinary shares under the Moneysupermarket.com Group PLC Restricted Share Award (`RSA’) Plan 
schemes to senior employees that vest over either one or two years. Under the two year schemes, 50% of the award vests at the end of 
a one-year period and 50% of the award vests at the end of a two-year period. Vesting on all schemes is subject to the participant being 
employed on the relevant vesting date, and not, on or prior to that vesting date, having been issued with or having given notice to 
terminate employment with the Group.

Sharesave Scheme

The Group grants options under the HMRC approved Moneysupermarket.com Group PLC Sharesave Scheme which is available to all 
employees. The scheme allows employees to save an amount of their net pay into a savings account each month and, at the end of the 
three-year period, choose to either receive back their savings or use them to buy ordinary shares in the Company at a discounted 
exercise price.

Share Incentive Plan (‘SIP’)

Upon listing, the Company granted £3,000 of ordinary shares at the price of £1.70 per ordinary share to each eligible employee free of 
charge. If an employee left within one year of listing, all these ordinary shares were forfeited; between one and two years of listing, 50% 
were forfeited; between two and three years of listing, 20% were forfeited; and after three years of listing, none were forfeited. 948,184 
shares were issued under the Share Incentive Plan scheme in 2007. On 31 July 2010 eligible employees became entitled to receive their 
allocation of free shares. There are 55 active participants (2021: 31) in the HMRC approved SIP scheme, who can subscribe for up to 
£150 of shares each month. At 31 December 2022, the total number of shares that remain in trust was 339,657 (2021: 343,328).

158 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

23. Share-based payments continued
LTIP and RSA schemes

The table below summarises the current LTIP and RSA schemes and the performance criteria elements:

Number of ordinary shares
Performance criteria:
–  adjusted basic EPS (%)
– total shareholder return (%)
–  revenue performance (%)

Weighted average share price at the date of exercise (£)

Sharesave Scheme

2022
LTIP

2022
RSA

2021
LTIP

2021
RSA

2020
LTIP

2019
LTIP

2,275,280

224,355 1,880,072

401,243 1,644,847 1,514,690

50
20
30

n/a

—
—
—

n/a

50
20
30

n/a

—
—
—

n/a

50
20
30

n/a

80
20
—

n/a

During 2022, the Group granted options to employees on the same basis as the grants in previous years. The exercise price for the 
options under each active scheme was fixed at the prices below:

Sharesave 2022
Sharesave 2021
Sharesave 2020
Sharesave 2019

Movements in the year

Exercise price

156.0p
203.0p
244.0p
294.0p

The following table illustrates the number and weighted average exercise price (‘WAEP’) of, and movements in, share options during the year.

Outstanding at 1 January 2021
Awards made during the year
Awards vested and exercised during the year
Awards forfeited during the year

Outstanding at 31 December 2021

Awards made during the year
Awards vested and exercised during the year
Awards forfeited during the year

Outstanding at 31 December 2022

Number

2,926,130
2,281,315
(209,589)
(1,412,843)

3,585,013

2,499,635
(282,956)
(972,862)

4,828,830

WAEP

£0.00
£0.00
£0.00
£0.00

£0.00

£0.00
£0.00
£0.00

£0.00

The following table lists the inputs to the Black-Scholes models and Monte Carlo simulations used for the schemes for the year ended 
31 December 2022:

Fair value at grant date (£)
Share price (£)
Exercise price (£)
Expected volatility (%)
Expected life of option/award 
(years)
Weighted average remaining 
contractual life (years)
Expected dividend yield (%)
Risk-free interest rate (%)

2022
Sharesave

2021
Sharesave

2020
Sharesave

0.98
1.95
1.56
90.2

3.0

2.8
6.0
4.4

1.31
2.54
2.03
91.8

3.0

1.8
4.6
0.4

1.61
3.04
2.44
92.2

3.0

0.8
3.9
0.0

2022
LTIP

1.98
1.98
0.0
92.2

3.0

2.3
0.0
1.4

2022
RSA

1.91
1.91
0.0
92.8

1.1

0.5
0.0
1.0

2021
LTIP

2.66
2.66
0.0
93.0

3.0

1.3
0.0
0.2

2021
RSA

2.71
2.71
0.0
102.9

2.0

0.3
0.0
0.0

2020
LTIP I

2.86
2.86
0.0
85.4

3.0

0.3
0.0
0.2

2020
LTIP II

3.04
3.04
0.0
89.3

3.0

0.7
0.0
0.0

Expected volatility has been estimated by considering historical average share price volatility for the Company or similar companies. 
Staff attrition has been assessed based on historical retention rates.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

159

Financial StatementsNotes to the Consolidated Financial Statements continued

24. Leases
Leases as lessee

The Group holds leases over property for its offices. The London office lease was signed on 22 July 2016 for a period of 15 years, with 
a lease start date of 1 June 2017. There was an 18-month rent-free period included in the agreement. The Manchester office lease was 
signed on 7 May 2019 for a period of 15 years, with a lease start date of 7 May 2019. There was a 36-month rent-free period included in 
the agreement. There is a break clause available at 7 May 2029 and the lease liabilities have been recognised up to this date. In 2021, 
the Group also acquired some other smaller leases with the acquisitions of CYTI (Holdings) Limited, Ice Travel Group Limited and Quidco 
Limited (formerly known as Maple Syrup Media Limited).

i. Right-of-use assets

Right-of-use assets related to leased properties that do not meet the definition of investment property are presented as property, 
plant and equipment.

Balance at 1 January 2021
Depreciation charge for the year
Acquisitions through business combinations
Reduction in right-of-use assets

Balance at 31 December 2021

Balance at 1 January 2022
Depreciation charge for the year

Balance at 31 December 2022

ii. Amounts recognised in profit or loss

Depreciation charge for the year
Interest on lease liabilities

iii. Amounts recognised in statement of cash flows

Interest paid
Repayment of lease liabilities

Land and
buildings
£m

27.1
(2.9)
1.7
(0.5)

25.4

25.4
(3.0)

22.4

2021
£m

2.9
1.1

4.0

2021
£m

0.9
2.3

3.2

2022
£m

3.0
 1.1

4.1

2022
£m

1.1
3.1

4.2

During 2019, the Group entered into an agreement to sub-lease a proportion of its London office. The sub-lease is for a period of 4.5 
years and as such does not reflect a transfer of substantially all of the risk and reward of the underlying asset, which in this case is the 
15-year head lease or right-of-use asset. Consequently, the Group has classified the sub-lease as an operating lease under IFRS 16. 
The rental income for the year was £0.6m (2021: £0.6m).

25. Pensions and other post-employment benefit plans
The Group operates a defined contribution pension scheme calculated on base salary. The assets of the scheme are held separately 
from those of the Group in an independently administered fund. The contributions payable to the scheme in respect of the current year 
were £2.1m (2021: £1.9m). In the year ended 31 December 2022, £2.0m (2021: £1.8m) of contributions were charged to the Consolidated 
Statement of Comprehensive Income and £0.1m (2021: £0.1m) were included in amounts capitalised (see note 7). As at 31 December 
2022, pension contributions of £0.4m (2021: £nil) were outstanding and have been settled post year end.

160 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

26. Commitments and contingencies
At 31 December 2022, the Group was committed to incur capital expenditure of £0.3m (2021: £0.9m).

Comparable with most companies of our size, the Group is a defendant in a small number of disputes incidental to its operations and 
from time to time is under regulatory scrutiny. As a leading website operator, the Group occasionally experiences operational issues 
as a result of technological oversights that in some instances can lead to customer detriment, dispute and potentially cash outflows. 
The Group has a professional indemnity insurance policy in order to mitigate liabilities arising out of events such as this.

There is a cross-guarantee held between Moneysupermarket.com Group PLC, MoneySavingExpert.com Limited, Moneysupermarket.com 
Limited, Moneysupermarket.com Financial Group Limited and Moneysupermarket.com Financial Group Holdings Limited in relation to 
balances owed under the revolving credit facility and the term loan. The maximum amount owed during the year was £89.0m (2021: £89.6m) 
and the amount owed at 31 December 2022 was £44.0m (2021: £57.5m).

The contingencies outlined above are not expected to have a material adverse effect on the Group.

27. Related party transactions
The Group has the following investments in all of its subsidiaries which are all included in the Consolidated Financial Statements:

Country of
incorporation

Ownership
interest %

Principal activity

Moneysupermarket.com Financial Group 
Holdings Limited
UK
Moneysupermarket.com Financial Group Limited UK
Moneysupermarket.com Limited
UK
MoneySavingExpert.com Limited
UK
Quidco Limited1 
UK
Decision Technologies Limited
UK
CYTI (Holdings) Limited
UK
CYTI Limited
UK
Mortgage 2000 Limited
UK
Sellmymobile.com Limited
UK
Townside Limited
UK
Ice Travel Group Limited
UK
Travelsupermarket Limited
UK
Icelolly Marketing Limited
UK
Express Rooms Limited
UK
Icelolly Limited
UK
Icelolly.co.uk Limited
UK
Icelolly Investments Limited
UK
Icelolly.com Limited
UK
Sunsave Travel Limited
UK
Podium Solutions Limited
UK

100
100
100
100
100
100
100
100
100
100
100
67
67
67
67
67
67
67
67
67
52

Holding company
Holding company
Internet price comparison through lead generation
Personal finance website
Cashback services through lead generation
Internet price comparison through lead generation
Holding company
Internet price comparison through lead generation
Dormant
Dormant
Dormant
Holding company
Internet price comparison through lead generation
Internet price comparison through lead generation
Dormant
Dormant
Dormant
Dormant
Dormant
Dormant
Technology platform provider

1  Company name changed from Maple Syrup Media Limited to Quidco Limited with effect from 13 January 2023. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

161

Financial StatementsNotes to the Consolidated Financial Statements continued

27. Related party transactions continued

Aggregate
capital
reserves
£m

Profit/
(loss) for
the year

£m Registered office address

Class of
shares
held

Ownership
31 December
2022

Ownership
31 December
2021

267.0

65.0 MoneySuperMarket House, St David’s Park, 

Ordinary

100%

100%

Ewloe, Chester, UK, CH5 3UZ

Moneysupermarket.com 
Financial Group 
Holdings Limited
Moneysupermarket.com 
Financial Group Limited
Moneysupermarket.com 
Limited
MoneySavingExpert.com 
Limited
Quidco Limited1

Decision Technologies Limited
CYTI (Holdings) Limited
CYTI Limited
Mortgage 2000 Limited

Sellmymobile.com Limited
Townside Limited
Ice Travel Group Limited

Travelsupermarket Limited

Icelolly Marketing Limited

18.0

45.6

39.7

11.8

21.4
0.0
3.4
0.0

0.0
0.0
21.8

14.2

1.0

Podium Solutions Limited

(2.7)

59.4 MoneySuperMarket House, St David’s Park, 

Ordinary

100%

100%

Ewloe, Chester, UK, CH5 3UZ

36.3 MoneySuperMarket House, St David’s Park, 

Ordinary

100%

100%

Ewloe, Chester, UK, CH5 3UZ

29.7 One Dean Street, London, UK, W1D 3RB

Ordinary

100%

100%

8.2 MoneySuperMarket House, St David’s Park, 

Ordinary

100%

100%

Ewloe, Chester, UK, CH5 3UZ

14.0 One Dean Street, London, UK, W1D 3RB
0.0 One Dean Street, London, UK, W1D 3RB
2.8 One Dean Street, London, UK, W1D 3RB
(0.5) MoneySuperMarket House, St David’s Park, 

Ewloe, Chester, UK, CH5 3UZ

0.4 One Dean Street, London, UK, W1D 3RB
0.2 One Dean Street, London, UK, W1D 3RB
1.0 Park Row House, 19-20 Park Row, Leeds,  

West Yorkshire, UK, LS1 5JF

Ordinary
Ordinary
Ordinary
Ordinary

Ordinary
Ordinary
Ordinary

1.0 Park Row House, 19-20 Park Row, Leeds,  

Ordinary

West Yorkshire, UK, LS1 5JF

0.3 Park Row House, 19-20 Park Row, Leeds,  

Ordinary

West Yorkshire, UK, LS1 5JF
(0.6) 4th Floor, Market Square House,  
St James Street, Nottingham, 
Nottinghamshire, UK, NG1 6FG

Ordinary

100%
100%
100%
100%

100%
100%
67%

67%

67%

52%

100%
100%
100%
100%

100%
100%
67%

67%

67%

50%

1  Company name change from Maple Syrup Media Limited to Quidco Limited with effect from 13 January 2023.

The Company is the ultimate parent entity of the Group. Intercompany transactions with wholly-owned subsidiaries are eliminated on 
consolidation as per the exemption offered in IAS 24 – Related Party Disclosures. The list above represents all companies within the 
Group. All companies within the Group are registered at the addresses shown above. The Company’s registered office is disclosed 
on page 137. All shareholdings with all subsidiaries are ordinary shares.

The Company has committed to continue to provide support to all of its subsidiaries for any short-term day-to-day cash management, 
if required.

Transactions with key management personnel

In addition to their salaries, the Group also provides non-cash benefits to Directors and Executive Officers. Directors and Executive 
Officers also participate in the Group’s Long Term Incentive Plan.

Peter Duffy, Robin Freestone, Scilla Grimble, James Bilefield and Sally James in total received dividends from the Group totalling £41,649 
(2021: Peter Duffy, Robin Freestone, Scilla Grimble, James Bilefield and Sally James in total received £30,389).

There were no amounts or any future commitments outstanding to the Company as at 31 December 2022 (2021: none).

Key management personnel compensation 

Key management, defined as the Executive management team, received the following compensation during the year:

Short-term employee benefits
Share-based payments
Post-employment benefits

Key management personnel compensation

31 December
2022
£m

31 December
2021
£m

2.7
1.0
0.2

3.9

3.3
0.6
0.2

4.1

In addition to the above, the Executive management team received a bonus of £1.4m (2021: £1.0m) in relation to the reporting period.

162 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

27. Related party transactions continued
Other related party transactions

During the year, Moneysupermarket.com Limited purchased £1.0m (2021: £0.4m) worth of services from Podium Solutions Limited in 
relation to the development of digital solutions for the mortgages channel journey on the Group’s website. No balances were outstanding 
as at 31 December 2022 in relation to these purchases (2021: £nil). Moneysupermarket.com Financial Group Limited acquired £0.3m 
(2021: £0.6m) of loan notes from Podium with a repayment term of ten years and an annual interest rate of 10%. These amounts were 
included in the carrying amount of the Group’s equity accounted investment in Podium until it was reclassified as a subsidiary in 
December 2022. Since then, these amounts have been eliminated on consolidation. During the year, the Group has recognised interest 
income of £0.3m (2021: £nil) in respect of these loan notes. At 31 December 2022, the balance outstanding was £1.8m (2021: £1.3m).

During the year, Travelsupermarket Limited provided internet leads to CYTI Limited, the company that powers its travel insurance 
journey. Travelsupermarket Limited charged net commissions of £0.6m (2021: £nil) to CYTI Limited in respect of the services provided 
by the two companies. No balances were outstanding as at 31 December 2022 in relation to these transactions (2021: £nil).

28. Acquisition of subsidiaries
Quidco Limited (formerly known as Maple Syrup Media Limited) (‘Quidco’)

On 1 November 2021, the Group acquired 100% of the share capital and voting rights of Quidco for total consideration payable of 
£104.6m. On acquisition a new Cashback vertical was created for this business. 

Due to the proximity of the acquisition date to the year end and in accordance with IFRS 3 – Business Combinations, a disclosure was 
included in the Group’s 2021 Annual Report indicating that if new information obtained within one year of the date of acquisition about 
facts and circumstances that existed at the date of acquisition identifies adjustments to the amounts recognised, or any additional 
provisions that existed at the date of acquisition, then the accounting for the acquisition will be revised. Since the year end we have 
identified new information about facts and circumstances that existed at the date of acquisition which has resulted in an increase in both 
accrued income (within trade and other receivables) and other payables (within trade and other payables) of £3.8m. There is no impact 
on total identifiable net assets acquired and therefore no impact on previously reported goodwill. The comparative balance sheet as 
at 31 December 2021 has been restated in these financial statements accordingly.

Podium Solutions Limited (‘Podium’)

On 23 December 2022, the Group gained control of Podium. Prior to this the Group had held a 50% investment in Podium which was 
accounted for as a joint venture. On completion of the transaction, the other shareholders of Podium exercised options which diluted 
the Group’s holding to 42%. The Group then acquired an additional 10% of the share capital bringing its holding up to 52%. Since then, 
the Group has been in control of Podium and has accounted for it as a subsidiary undertaking.

The fair value of total consideration was £1.6m which comprised the following:

Fair value of existing interest
Fair value of additional equity interest
Fair value of non-controlling interest

Fair value of total consideration

The fair value of the total identifiable net assets acquired was £1.6m:

Intangible assets
Trade and other receivables
Cash
Trade and other payables
Amounts due to non-controlling interest
Deferred tax

Fair value of total identifiable net assets acquired

£m

0.7
0.2
0.7

1.6

£m

3.2
1.0
0.1
(0.1)
(1.8)
(0.8)

1.6

Intangible assets relate to technology expenditure that had not been capitalised in Podium prior to acquisition. The fair value of these 
assets has been determined using a rebuild cost valuation method. This was developed in consultation with senior technology professionals 
and using a cost assumption for developers inclusive of a profit margin as would be the case in an external build contracted to develop 
an equivalent platform. When valuing assets of this nature we take into account any obsolescence arising from advancements in 
technology since they have been built. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

163

Financial StatementsNotes to the Consolidated Financial Statements continued

28. Acquisition of subsidiaries continued
Podium Solutions Limited (‘Podium’) continued

There was no goodwill arising from the acquisition as the fair value of total consideration was equal to the fair value of total identifiable 
net assets acquired.

In the period from completion of the deal to the year end, Podium contributed revenue and profit before tax of £0.0m to these 
Consolidated Financial Statements.

As part of the transaction the Group has a call option to acquire the remaining 48% of Podium in three years’ time. The consideration 
payable will equate to the fair value of Podium at that date. No value has therefore been attributed to this call option in these 
financial statements.

29. Non-controlling interest
In December 2022, the Group acquired control of Podium Solutions Limited which had previously been accounted for as a joint venture. 
Podium is now consolidated as a subsidiary undertaking and non-controlling interest is recognised within equity (see note 28).

The Group also recognises non-controlling interest in respect of Ice Travel Group Limited and its two wholly owned subsidiaries 
Travelsupermarket Limited and Icelolly Marketing Limited (together ‘Ice Travel Group’). 

The following table summarises the financial performance and position of these companies at the year end before any intra-group eliminations.

Non-controlling interest

Non-current assets1
Current assets
Non-current liabilities
Current liabilities

Net assets

Net assets attributable to non-controlling interest

Revenue
Profit
Other comprehensive income

Total comprehensive income

Profit attributable to the non-controlling interest
Other comprehensive income attributable to non-controlling interest

Total comprehensive income attributable to non-controlling interest

Cash flows from operating activities
Cash flows from investing activities
Cash flows from financing activities

Net increase in cash and cash equivalents

31 December 2022

Ice Travel 
Group

Podium
Solutions
Limited

48%

£m

3.2
0.3
(1.8)
(0.1)

1.6

0.7

—
—
—

—

—
—

—

—
—
—

—

33%

£m

14.5
8.3
(4.9)
(2.0)

15.9

5.3

14.6
3.1
—

3.1

1.0
—

1.0

4.5
(0.4)
—

4.1

Total

£m

17.7
8.6
(6.7)
(2.1)

17.5

6.0

14.6
3.1
—

3.1

1.0
—

1.0

4.5
(0.4)
—

4.1

1 

 Non-current assets for Ice Travel Group include £7.4m (2021: £7.4m) of goodwill in respect of Travelsupermarket Limited that was recognised on the Group’s balance sheet prior 
to the acquisition of Ice Travel Group.

164 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

 
29. Non-controlling interest continued

Non-controlling interest

Non-current assets1
Current assets
Non-current liabilities
Current liabilities

Net assets

Net assets attributable to non-controlling interest

Revenue
Loss 
Other comprehensive income

Total comprehensive income

Loss attributable to the non-controlling interest
Other comprehensive income attributable to non-controlling interest

Total comprehensive income attributable to non-controlling interest

Cash flows from operating activities
Cash flows from investing activities
Cash flows from financing activities

Net increase in cash and cash equivalents

31 December 2021

Podium 
Solutions
Limited

Ice Travel
Group

—

£m

—
—
—
—

—

—

—
—
—

—

—
—

—

—
—
—

—

33%

£m

14.8
3.8
(3.4)
(2.5)

12.7

4.3

2.2
(1.8)
—

(1.8)

(0.6)
—

(0.6)

(1.9)
—
4.0

2.1

Total

33%

£m

14.8
3.8
(3.4)
(2.5)

12.7

4.3

2.2
(1.8)
—

(1.8)

(0.6)
—

(0.6)

(1.9)
—
4.0

2.1

1 

 Non-current assets for Ice Travel Group include £7.4m of goodwill in respect of Travelsupermarket Limited that was recognised on the Group’s balance sheet prior to the 
acquisition of Ice Travel Group.

Ice Travel Group’s profit (2021: loss) and total comprehensive income for the year of £3.1m (2021: £1.8m) includes £nil (2021: £1.8m) 
of deal fees and associated costs and £0.6m (2021: £0.2m) of amortisation of intangibles relating to the acquisition of Ice Travel Group 
by the Group. Included in the profit (2021: loss) and total comprehensive income attributable to the non-controlling interest of £1.0m 
(2021: £0.6m) are £nil (2021: £0.6m) of deal fees and associated costs and £0.2m (2021: £0.1m) of amortisation of intangibles. 

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

165

Financial StatementsCompany Balance Sheet

at 31 December 2022

Fixed assets
Investments

Total fixed assets

Current assets
Debtors – including amounts falling due in more than one year of £0.3m (2021: £0.3m)
Cash at bank and in hand

Total current assets 

Creditors: amounts falling due within one year 

Net current assets 

Creditors: amounts falling due in more than one year

Net assets

Capital and reserves
Share capital
Share premium
Reserve for own shares
Other reserves
Profit and loss account

Shareholders’ funds

31 December
2022
£m

31 December
2021
£m

Note

4

5

6

7

10

181.7

181.7

215.8
0.2

216.0

(30.2)

185.8

(30.0)

337.5

0.1
205.4
(2.4)
16.9
117.5

337.5

181.7

181.7

224.3
0.0

224.3

(25.8)

198.5

(40.0)

340.2

0.1
205.4
(2.6)
16.9
120.4

340.2

No profit and loss account is presented for the Company as permitted by section 408 of the Companies Act 2006. The profit after tax 
for the Company was £59.9m (2021: £71.4m) which included dividends received of £65.0m (2021: £75.0m).

The Financial Statements were approved by the Board of Directors and authorised for issue on 15 February 2023. They were signed 
on its behalf by:

Peter Duffy
Chief Executive Officer

Scilla Grimble
Chief Financial Officer

Registered number: 6160943

166 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Company Statement of Changes in Equity

for the year ended 31 December 2022

At 1 January 2021

Profit for the year

Total comprehensive income

New shares issued
Purchase of shares by employee trusts
Exercise of LTIP awards
Equity dividends
Share-based payments

At 31 December 2021

Profit for the year

Total comprehensive income

Purchase of shares by employee trusts
Exercise of LTIP awards
Equity dividends
Share-based payments

Share
capital
£m

0.1

—

—

0.0
—
—
—
—

0.1

—

—

—
—
—
—

Share
premium
£m

205.0

—

—

0.4
—
—
—
—

205.4

—

—

—
—
—
—

At 31 December 2022

0.1

205.4

Reserve for own shares

Reserve for
own shares
£m

(2.8)

—

—

—
(0.3)
0.5
—
—

(2.6)

—

—

(0.3)
0.5
—
—

(2.4)

Other
reserves
£m

16.9

—

—

—
—
—
—
—

16.9

—

—

—
—
—
—

16.9

Profit and
loss account
£m

112.1

71.4

71.4

—
—
(0.5)
(62.8)
0.2

120.4

59.9

59.9

—
(0.5)
(62.8)
0.5

117.5

Total
£m

331.3

71.4

71.4

0.4
(0.3)
—
(62.8)
0.2

340.2

59.9

59.9

(0.3)
—
(62.8)
0.5

337.5

The reserve for the Company’s own ordinary shares comprises the cost of the Company’s ordinary shares held by the Group through 
employee trusts. At 31 December 2022, the Group held 343,328 (2021: 343,328) ordinary shares at a cost of 0.02p per share (2021: 0.02p) 
through a Share Incentive Plan trust for the benefit of the Group’s employees.

The Group also held 151,723 (2021: 253,886) shares through an Employee Benefit Trust at an average cost of 204.80p per share 
(2021: 239.19p) for the benefit of employees participating in the various Long Term Incentive Plan schemes.

Other reserves

The other reserves balance represents the merger reserve of £16.9m (2021: £16.9m) generated upon the acquisition of 
Moneysupermarket.com Financial Group Limited by the Company and a capital redemption reserve for £19,000 (2021: £19,000) arising 
from the acquisition of 95,294,118 deferred shares of 0.02p by the Company from Simon Nixon.

Upon the acquisition of Moneysupermarket.com Financial Group Limited, a merger reserve of £16.9m for 45% of the book value 
transferred from a company under common control was recognised.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

167

Financial StatementsNotes to the Company Financial Statements

1. Accounting policies
Basis of preparation

Moneysupermarket.com Group PLC (the ‘Company’) is a public company limited by shares and incorporated and domiciled in England, 
UK. The registered office is disclosed on page 137.

These Financial Statements were prepared in accordance with Financial Reporting Standard 102 – The Financial Reporting Standard 
Applicable in the UK and Republic of Ireland (‘FRS 102’). The presentation currency of these Financial Statements is sterling. All amounts in 
the Financial Statements have been rounded to the nearest £100,000. These Financial Statements are prepared on the historical cost basis.

In these Financial Statements, the Company is considered to be a qualifying entity for the purposes of this FRS and has applied the 
exemptions available under FRS 102 in respect of the following disclosures:

•  Cash Flow Statement and related notes; and

•  key management personnel compensation.

As the Consolidated Financial Statements include the equivalent disclosures, the Company has also taken the exemptions under FRS 102 
available in respect of the following disclosures:

•  certain disclosures required by FRS 102.26 – Share Based Payments;

•  the disclosures required by FRS 102.11 – Basic Financial Instruments and FRS 102.12 – Other Financial Instrument Issues in respect 

of financial instruments not falling within the fair value accounting rules of Paragraph 36(4) of Schedule 1; and

•  the disclosures required by FRS 102.33.1A – Related Party Disclosures.

The accounting policies set out below have, unless otherwise stated, been applied consistently to all periods presented in these 
Financial Statements.

Use of estimates and judgements

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.

There are no significant estimates or judgements made in preparation of these Financial Statements.

Investments

Investments are shown at cost less provision for impairment.

Basic financial instruments

Trade and other debtors are recognised initially at transaction price less attributable transaction costs. Trade and other creditors 
are recognised initially at transaction price plus attributable transaction costs. Subsequent to initial recognition they are measured 
at amortised cost using the effective interest method, less any impairment losses in the case of trade debtors. If the arrangement 
constitutes a financing transaction, for example if payment is deferred beyond normal business terms, then it is measured at the present 
value of future payments discounted at a market rate of interest for a similar debt instrument.

Cash and cash equivalents

Cash and cash equivalents comprise cash balances and call deposits. Bank overdrafts that are repayable on demand and form an integral 
part of the Company’s cash management are included as a component of cash and cash equivalents for the purpose only of the Cash 
Flow Statement.

168 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

1. Accounting policies continued
Bank borrowings

Interest-bearing bank loans and overdrafts are recorded at the proceeds received. Finance charges, including direct issue costs, are 
accounted for on an accruals basis in profit or loss using the effective interest method and are added to the carrying amount of the 
instrument to the extent that they are not settled in the period in which they arise.

Own shares held by Employee Benefit Trust

Transactions of the Company-sponsored Employee Benefit Trust are treated as being those of the Company and are therefore reflected 
in the Company Financial Statements. In particular, the trust’s purchases and sales of shares in the Company are debited and credited 
directly to equity.

Share-based payment transactions

The Company’s share schemes allow employees to acquire ordinary shares in the Company. The fair value of share awards made is 
recognised as an employee expense with a corresponding increase in equity. The fair value is measured at award date and spread over 
the period during which the employees become unconditionally entitled to the awards. The fair value of the awards made is measured 
using an option valuation model, taking into account the terms and conditions upon which the awards were made. The Company’s 
share-based payment expenses relate solely to employees of the Company. Share-based payment expenses in respect of other Group 
employees are recognised in the company that employs them.

Dividends

Dividends receivable are recognised when the Company’s right to receive payment is established. Dividends payable to the Company’s 
shareholders are recognised as a liability and deducted from shareholders’ equity in the period in which the shareholders’ right to 
receive payment is established.

Taxation

Income tax expense comprises current and deferred tax. It is recognised in the profit and loss account except to the extent that it relates 
to items recognised directly in equity, in which case it is recognised in equity.

Current tax is the expected tax payable on the taxable income for the year, using tax rates in force for the year, and any adjustment to tax 
payable in respect of previous years.

Deferred tax is provided on timing differences which arise from the inclusion of income and expenses in tax assessments in periods 
different from those in which they are recognised in the Financial Statements. Deferred tax is not recognised on permanent differences 
arising because certain types of income or expense are non-taxable or are disallowable for tax or because certain tax charges or 
allowances are greater or smaller than the corresponding income or expense.

Deferred tax is measured at the tax rate that is expected to apply to the reversal of the related difference, using tax rates enacted or 
substantively enacted at the balance sheet date. Deferred tax balances are not discounted.

Deferred tax assets are recognised only to the extent that is it probable that they will be recovered against the reversal of deferred tax 
liabilities or other future taxable profits.

2. Share-based payments
The analysis and disclosures in relation to share-based payments are given in the Consolidated Financial Statements in note 23.

3. Staff numbers and cost
The average number of persons employed by the Company (including Directors) during the year, analysed by category, was as follows:

Administration

The aggregate payroll costs of these persons were as follows:

Wages and salaries
Social security costs
Other pension costs
Share-based payments

2022
No.

2

2022
£m

1.1
0.1
0.1
0.5

1.8

2021
No.

2

2021
£m

1.0
0.1
0.1
0.2

1.4

In addition to the above, bonuses of £0.8m (2021: £0.3m) were payable in relation to the reporting period. Neither Director exercised 
share options during the period (2021: one) and the total gain on exercise of these options was £nil (2021: £61,145). Directors’ 
remuneration is disclosed on pages 97 to 117.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

169

Financial StatementsNotes to the Company Financial Statements continued

4. Investments

Cost and net book value:

At 31 December 2021 and 31 December 2022

Shares in
subsidiary
undertakings
£m

181.7

The investment represents the Company’s holding in Moneysupermarket.com Financial Group Holdings Limited, which was obtained via 
a share for share exchange during 2012 in which the Company exchanged its existing shareholding in Moneysupermarket.com Financial 
Group Limited for the entire share capital of Moneysupermarket.com Financial Group Holdings Limited.

5. Debtors

Amount due from subsidiary undertakings
Prepayments
Deferred tax asset (note 8)

6. Creditors: amounts falling due within one year

Borrowings
Amount owed to subsidiary undertakings
Accruals

7. Creditors: amounts falling due after one year

Borrowings

8. Deferred tax asset

Short-term timing differences

9. Dividends

31 December
2022
£m

31 December
2021
£m

215.0
0.5
0.3

215.8

223.3
0.7
0.3

224.3

31 December
2022
£m

31 December
2021
£m

14.0
15.1
1.1

30.2

17.5
7.0
1.3

25.8

31 December
2022
£m

31 December
2021
£m

30.0

40.0

31 December
2022
£m

31 December
2021
£m

0.3

0.3

Declared and paid dividends on ordinary shares:
Prior year final dividend
Interim dividend

Total dividend paid in the year

Proposed for approval (not recognised as a liability at 31 December): final 
dividend

pence per
share

31 December
2022
£m

pence per
share

31 December
2021
£m

8.61
3.10

11.71

8.61

46.2
16.6

62.8

46.2

8.61
3.10

11.71

8.61

46.2
16.6

62.8

46.2

170 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

10. Called up share capital
The following rights attached to the shares in issue during the year:

Ordinary shares

The holders of ordinary shares were entitled to returns of capital, receive a dividend and vote.

Issued and fully paid

Number of ordinary shares

At the beginning of the year
Issued on exercise of SAYE options

At the end of the year

Nominal value of ordinary shares

At the beginning of the year
Issued on exercise of SAYE options

At the end of the year

2022

2021

536,861,647
—

536,700,541
161,106

536,861,647

536,861,647

2022
£

107,372
—

107,372

2021
£

107,340
32

107,372

The Group has a Long Term Incentive Plan under which conditional nil cost awards of ordinary shares in the Company have been made to 
certain Directors and employees of the Group, and an HMRC approved Save As You Earn scheme (‘Sharesave’) is eligible to all employees 
(see note 23 of the Consolidated Financial Statements).

11. Operating lease commitments
Future minimum lease payments under non-cancellable operating leases total £27.2m (2021: £29.9m). All lease payments are settled 
by subsidiary undertakings.

All rental expenses are recharged to subsidiary undertakings and therefore there is no impact on the profit and loss account of the 
Company. During the year, rental expenses of £2.4m (2021: £2.4m) were recharged.

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

171

Financial StatementsGlossary

2018 Code – means the UK Corporate Governance Code 
published by the FRC in July 2018.

ISA (UK and Ireland) – means International Standard(s) on 
Auditing in the UK and Ireland.

Adjusted EBITDA – means earnings before interest, tax, 
depreciation, amortisation and Adjusting Items.

Adjusting items – means items that are considered 
exceptional or non-underlying in nature and are either added back 
or deducted from performance measures such as EBITDA, EPS 
and profit before tax to enable like-for-like comparison between 
reporting periods.

Adjusted EPS – means earnings per share excluding 
Adjusting items. A calculation of this is provided in note 10 
to the Consolidated Financial Statements.

B2B – means business to business.

B2C – means business to consumer.

Beyond Carbon Neutral – means offsetting greater 
than 100% of the Group’s carbon emissions.

CAGR – means compound annual growth rate.

Capital expenditure or Capex – means expenditure 
on property, plant and equipment or intangible assets. These 
amounts are recognised on the Consolidated Statement of 
Financial Position.

Carbon emissions (Scope 1 and 2) – means emissions 
of CO2 and other greenhouse gases from fuel combustion and 
energy used in the Group’s direct operations.

Carbon Neutral – means offsetting 100% of the Group’s 
carbon emissions.

CGU – means cash generating units.

Company – means Moneysupermarket.com Group PLC, a 
company incorporated in England and Wales with registered 
number 6160943 whose registered office is at Moneysupermarket 
House, St David’s Park, Ewloe, Chester CH5 3UZ.

Corporate website – means https://corporate.
moneysupermarket.com/.

CRM – means Customer Relationship Management.

Directors – means the Directors of the Company whose names 
and biographies are set out on pages 66 and 67 or the Directors 
of the Company’s subsidiaries from time to time as the context 
may require.

EBITDA – means earnings before interest, tax, depreciation and 
amortisation. It equates to operating profit before depreciation 
and amortisation.

EPS – means earnings per share.

Executive Team – means senior management responsible 
for managing the day-to-day operations of the business.

GDPR – means General Data Protection Regulation.

GHG – means greenhouse gas(es).

Group – means Moneysupermarket.com Group PLC, its 
subsidiaries, significant undertakings and affiliated companies 
under its control or common control.

IAS – means International Accounting Standard(s).

IBOR – means interbank offered rates.

IFRIC – means International Financial Reporting Standards 
Interpretations Committee.

IFRS – means International Financial Reporting Standard(s).

ITG – means Ice Travel Group.

KPI – means key performance indicator.

LTIP – means the Company’s Long Term Incentive Plan for 
Executive Directors and selected senior managers.

Marketing margin – means total marketing expenditure 
recognised in distribution expenses and cost of sales divided 
by revenue.

MoneySuperMarket.com – means MoneySuperMarket’s 
price comparison site.

MoneySavingExpert.com – means MoneySavingExpert’s 
consumer site.

MSE – means MoneySavingExpert.com.

MSM – means MoneySuperMarket.com.

Net finance costs – means finance income less finance 
costs. Finance income is composed of bank interest. Finance cost 
is composed principally of interest, arrangement and commitment 
fees relating to borrowings and interest on lease liabilities.

Net debt – means cash and cash equivalents less borrowings 
and deferred consideration. It does not include lease liabilities.

Net zero – means the reduction of emissions and using offsets 
to neutralise any residual emissions.

Operating expenditure or Opex – means distribution 
expenses and administrative expenses, both of which are 
recognised in the Consolidated Statement of Comprehensive 
Income.

Operational net zero – a 90% reduction in Scope 1 
and Scope 2 emissions.

PCW – means price comparison website.

PPC – means pay-per-click.

R&D – means research and development.

RCF – means revolving credit facility.

SEM – means Search Engine Marketing.

SEO – means Search Engine Optimisation.

Sharesave Scheme or SAYE Scheme – means the 
Moneysupermarket Group employee savings-related share option 
plan approved by HMRC.

SIP – means the Share Incentive Plan.

SM&CR – means the Financial Conduct Authority’s Senior 
Managers and Certification Regime.

SONIA – means the Sterling Overnight Index Average.

TCFD – means Task Force on Climate-Related Financial 
Disclosures.

TravelSupermarket – means TravelSupermarket’s price 
comparison site.

TSM – means TravelSupermarket.

TSR – means total shareholder return – the growth in value of 
a shareholding over a specified period, assuming that dividends 
are reinvested to purchase additional shares.

Working capital – means current assets minus current 
liabilities excluding financing and investment activities.

172 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

Shareholder Information

Registered office
Moneysupermarket House
St David’s Park
Ewloe
Chester CH5 3UZ
Telephone: +44 (0)1244 665700
Website: http://corporate.moneysupermarket.com

Registered number
No. 6160943

Company Secretary 
Shazadi Stinton

Financial advisers/stockbrokers
Credit Suisse Securities (Europe) Limited

One Cabot Square
London E14 4QJ

Barclays Bank PLC

1 Churchill Place, Canary Wharf
London E14 5HP

Auditor
KPMG LLP

15 Canada Square
London E14 5GL

Solicitors
Herbert Smith Freehills LLP

Exchange House
Primrose Street
London EC2A 2EG

Principal bankers
Barclays Bank PLC

1 Churchill Place, Canary Wharf
London E14 5HP

Bank of Ireland

Floor 3A, Baggot Plaza
27–33 Upper Baggot Street
Ballsbridge
Dublin 4

Silicon Valley Bank

Alphabeta
14–18 Finsbury Square
London
EC2A 1BR

Financial PR
The Maitland Consultancy Limited

3 Pancras Square
London N1C 4AG

Registrar
Equiniti Group

Aspect House
Spencer Road
Lancing
West Sussex BN99 6DA

Annual Report and Accounts 2022
Moneysupermarket.com Group PLC

173

Financial StatementsShareholder Information continued

Enquiring about your shareholding
If you want to ask, or need any information, about your 
shareholding, please contact our registrar, Equiniti Group, by:

Telephone: 0371 384 2564 (UK) (calls are charged at the standard 
geographic rate and will vary by provider. Lines are open 8.30am–
5.30pm Monday–Friday).

Electronic communications
You can elect to receive shareholder communications electronically 
by contacting our registrar (see contact details opposite). This will 
save on printing and distribution costs, creating environmental 
benefits. When you register, you will be sent a notification to say 
when shareholder communications are available on our website 
and you will be provided with a link to that information.

Cautionary note regarding forward-looking 
statements
This Annual Report includes statements that are forward looking in 
nature. Forward-looking statements involve known and unknown 
risks, assumptions, uncertainties and other factors which may 
cause the actual results, performance or achievements of the 
Group to be materially different from any future results, 
performance or achievements expressed or implied by such 
forward-looking statements. Except as required by the Listing 
Rules, Disclosure Guidance and Transparency Rules and applicable 
law, the Company undertakes no obligation to update, revise or 
change any forward-looking statements to reflect events or 
developments occurring on or after the date of this Annual Report.

+44 (0) 371 384 2564 (overseas).

Email: customer@equiniti.com.

Alternatively, if you have internet access, you can access the 
Group’s shareholder portal at www.shareview.co.uk where you can 
view and manage all aspects of your shareholding securely.

Investor relations website and share price 
information
The investor relations section of our website, http://corporate. 
moneysupermarket.com, provides further information for anyone 
interested in the Group. In addition to the Annual Report and 
share price, Company announcements including the half-year and 
full-year results announcements and associated presentations are 
also published there.

Dividend mandates
If you wish to have dividends paid directly into a bank or building 
society account, you should contact our registrar (see contact details 
above) or visit the Group’s shareholder portal at www.shareview.com 
where you can set up or amend a dividend mandate. This method of 
payment removes the risk of delay or loss of dividend cheques in the 
post and ensures that your account is credited on the due date.

Dividend reinvestment plan (‘DRIP’)
You can choose to reinvest dividends received to purchase further 
shares in the Company through a DRIP. A DRIP application form is 
available from our registrar (see contact details above).

Share dealing service
You can buy or sell the Company’s shares in a simple and 
convenient way via the Equiniti share dealing service either online 
(www.shareview.co.uk) or by telephone (0371 384 2564). Calls are 
charged at the standard geographic rate and will vary by provider. 
Lines are open 8.00am–4.30pm Monday–Friday.

Please note that the Directors of the Company are not seeking to 
encourage shareholders to either buy or sell shares in the Company. 
Shareholders in any doubt about what action to take are 
recommended to seek financial advice from an independent financial 
adviser authorised by the Financial Services and Markets Act 2000.

174 Annual Report and Accounts 2022

Moneysupermarket.com Group PLC

2023 Financial Calendar

Declaration date of 2022 final dividend

Announcement of 2022 full-year results

Ex-dividend date of 2022 final dividend

Record date of 2022 final dividend

Trading update

Annual General Meeting

Payment date of 2022 final dividend

Half year end

Announcement of 2023 half-year results

Trading update

Financial year end

Announcement of 2023 full-year results

16 February 2023

16 February 2023

30 March 2023

31 March 2023

18 April 2023 

4 May 2023

11 May 2023

30 June 2023

20 July 2023

October 2023

31 December 2023

February 2024

Moneysupermarket.com Group PLC’s commitment to 
environmental issues is reflected in this Annual Report, 
which has been printed on Amadeus Silk, an FSC® certified 
material. This document was printed by Pureprint Group 
using its environmental print technology, with 99% of dry 
waste diverted from landfill, minimising the impact of 
printing on the environment. The printer is a CarbonNeutral® 
company. Both the printer and the paper mill are registered 
to ISO 14001.

CBP017255

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Moneysupermarket.com Group PLC
Telephone: 01244 665700

Web: http://corporate.moneysupermarket.com

Registered in England No. 6160943

Registered Office: Moneysupermarket House, 
St David’s Park, Ewloe, Chester CH5 3UZ