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FY2021 Annual Report · Nahl Group
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Creating opportunity,  
ready for the future

NAHL Group Plc Annual Report and Accounts 2021 

Annual
Report
2021

139

NAHL Group Plc
Bevan House, Kettering Parkway, 
Kettering, Northamptonshire, NN15 6XR
Tel: +44 (0) 1536 527 500
Email: investors@nahl.co.uk 
Web: www.nahlgroupplc.co.uk

Contents

Strategic report  
Chair’s report 
CEO report 
CFO report 
Our Business  
KPIs 
Strategic priorities 
Principal risks and uncertainties 
Our sustainable culture 
Section 172 statement  

Leadership and Governance 

Financial Statements 

5
6
8
15
22
27
31
34
43
50

53

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NAHL Group Plc Annual Report and Accounts 2021 

1

Introduction

At a
glance

NAHL Group plc is a leader in 
the consumer legal services 
and catastrophic injury 
markets, delivering products 
and services to consumers 
and businesses through two 
divisions, Consumer Legal 
Services and Critical Care.

Over the last two years our markets have been 
significantly impacted by the COVID-19 pandemic 
as Government restrictions and cautious consumer 
behaviour suppressed accident numbers, resulting 
in lower activity levels for our two divisions. Also, 
regulatory changes that affect lower value road 
traffic accident (RTA) claims in the personal 
injury market were implemented in May 2021, 
after years of delays. These significantly reduced 
compensation tariffs and most RTA claims worth 
£5,000 or less are now settled through the small 
claims track with no award for costs. This has in 
turn resulted in lower claim numbers in the market.

We have made good progress in our strategy to 
respond to these challenges. In Consumer Legal 
Services, we launched our own personal injury law 
firm, National Accident Law, in 2019 and have since 
been processing an increasing volume of work 
ourselves. We have been focusing on generating 
value from non-RTA work, which isn’t affected by 
the reforms and generates higher margins, and we 
have also launched a proposition to monetise low-
value RTA work. Our ability to place a proportion 
of our claims into a panel of third-party law firms 
and with our joint venture1 partners allows us to 
manage our working capital and to grow National 
Accident Law in a controlled manner.

Whilst there is a lot more to do, the early results have 
been encouraging. In 2021, we grew the volume 
of work we processed in National Accident Law 
by 130%, thereby increasing the total number of 
enquiries we processed ourselves from 10% to 26%. 
We reduced the proportion of enquiries we placed 

with our joint venture partners by 73%, started to 
process higher value non-RTA claims ourselves and 
commenced work on 3,529 small claims in the year.

In our Critical Care business, Bush & Co., we have 
been investing in people, systems and marketing 
activity to grow market share in our core offerings 
of case management and expert witness services. 
We have also been developing new services to grow 
in adjacent markets and enhance our proposition. 
We grew revenues by 9% in the year by supporting 
more clients with our core services. Our 
investments in business development resulted in 
increased instructions which will turn into revenues 
in future years. Underpinning these results is the 
strength of our people and culture, which was 
recognised with our Critical Care division featuring 
in the Top 100 Small Companies to Work For in 
2021, replicating a feat achieved by our Personal 
Injury business in 2019. 

We also reduced our net debt in 2021 and extended 
the term of our debt facility by two years to 31 
December 2024, ensuring we have the liquidity to 
execute on our strategy. 

In summary, whilst the Group 
continues to experience 
headwinds and some of our 
investments will take time to 
translate into profits, we are 
making progress with our 
strategy to create a more 
profitable and sustainable 
business for the benefit of all 
our stakeholders. 

James Saralis 
Chief Executive Officer

1.  Throughout this document, references to ‘joint venture’ law firm 

relate to our law firms Your Law LLP and Law Together LLP which 
we operate in partnership with a minority member. The term 
‘joint venture’ does not relate to the IFRS definition. These law 
firms are accounted for as subsidiary undertakings, see note 1 to 
the financial statements for further details. 

2.  Underlying operating profit excludes certain exceptional items 
as detailed in note 1 to the financial statements. Refer to note 1 
of the financial statements for a reconciliation of this measure to 
IFRS operating profit. 

2 

NAHL Group Plc Annual Report and Accounts 2021

Revenue
£38.9m
(2020: £40.9m)

Underlying operating profit2
£4.2m
(2020: £5.7m)

Profit before tax
£0.2m
(2020: a loss of £0.2m)

Net debt
£15.5m
(31 Dec 2020: £16.3m)

4 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

NAHL Group Plc Annual Report and Accounts 2021 

5

Strategic report

Chair’s
Report

Like many other businesses, the COVID-19 
pandemic continued to affect our trading in 2021. 
Notwithstanding this, we completed the year with 
a profit before tax of £0.2m (2020: loss of £0.2m) 
and a reduction in net debt to £15.5m (2020: 
£16.3m) as we focused on investing in the growth 
of National Accident Law (NAL) and the continued 
recovery of our Critical Care division.

2021 results
Our Personal Injury business saw enquiry levels 
decrease compared with the previous year. This 
was a direct consequence of fewer accidents (both 
Road Traffic Accident (RTA) and non-RTA) due 
to a decrease in population mobility as a result 
of COVID-19 restrictions. As planned, in 2021 
we placed more of the enquires we generated 
into NAL, which continues to grow in size. NAL 
processed 26% of our enquiries in 2021 and had 
7,918 cases underway at the end of the year. 
Although a relatively small part of our portfolio, our 
Residential Property business benefitted from a 
hot market and we continue to explore our options 
for this business. 

Critical Care revenues increased by 9%, driven 
in large part, by 21% more Expert Witness 
instructions. These were generated from 
successful business development initiatives but 
this was offset by increased operating costs due to 
our investment in people, systems and marketing. 

Strategic progress
The Group made good progress in implementing 
its strategy. Most notably, NAL is now processing 
all RTA enquiries and an increasing number of 
non-RTA enquiries. Consequently, significantly 
less work is being placed into our joint venture law 
firms. Notwithstanding this, we will continue to 
place enquiries with our panel to generate short 
term cash and profit that will be reinvested, where 
possible, in NAL. NAL is central to the Group’s 
future success and its creation and development 
were essential in anticipation of the regulatory 
changes introduced in May 2021. Having our 
own modern, technologically-enabled law firm is 
expected, in time, to generate higher margins for 
our personal injury work, as well as significantly 
reducing our non-controlling interest payments. 
In the short-term, however, the strategic focus on 
growing NAL will continue to depress profits until 
the level of admissions and settlements increases 
to compensate for the investment in new claims.

During the year, Critical Care enhanced its business 
development capabilities to drive further growth 
in its core markets. It has also invested in new 
services to move into adjacent markets. This has 
enhanced Critical Care’s reputation and created 
a strong pipeline of work for the future, as case 
management projects can last several years.

Good governance
We remain committed to engaging positively with 
our investors and being transparent about the 
challenges and opportunities ahead. In addition 
to regular meetings with our largest shareholders 
during the year we also met with retail shareholders 
using the InvestorMeetCompany platform for the 
first time. This enabled the Group to host a live 
Q&A session and engage with a wider audience. 

In August 2021, James Saralis was appointed 
CEO and Chris Higham replaced him as acting 
CFO. The Board unanimously supported these 
internal appointments and are delighted with their 
contributions to date. We also appointed Allenby 
Capital as our new Nominated Adviser and Sole 
Broker in February 2022 and look forward to 
working with them to increase shareholder value.

6 

NAHL Group Plc Annual Report and Accounts 2021

 
Strategic report

Having our own modern, technologically-enabled law firm is 
expected, in time, to generate higher margins for our personal 
injury work, as well as significantly reducing our non-controlling 
interest payments.

Summary
I would like to thank all our employees for 
their continued commitment and hard work 
over the last year. Our people adapted to 
home working arrangements and then 
hybrid working effectively. We will continue 
to operate a hybrid model as the COVID-19 
pandemic ends. Our people and our culture 
are essential to our future success.

In summary, I believe we are making good 
progress with the development of our 
Personal Injury business and the growth of 
our Critical Care division, but the COVID-19 
pandemic has made it more difficult, reducing 
the number of accidents to well below 2019 
levels. We expect to see accident numbers 
increase gradually in 2022 as mobility 
levels increase and people return to work. 
Pleasingly, early indications are supportive. 
Our Personal Injury business will continue to 
place an increasing number of enquiries into 
NAL in order to maximise future profit, and 
our Critical Care division already has a strong 
pipeline of work as it starts 2022.  In the short-
term our strategy means profits will remain 
depressed, as we continue our investment 
in NAL, but I remain optimistic about the 
future, particularly now that the COVID-19 
restrictions have come to an end. 

Tim Aspinall 
Chair

NAHL Group Plc Annual Report and Accounts 2021 

7

 
Strategic report

CEO
Report

I am pleased to report our results for the year 
ended 31 December 2021.

Overview
2021 saw the Group make progress with the 
implementation of its strategy, but the COVID-19 
pandemic continued to have an impact on our 
markets throughout the year. Government 
restrictions and cautious consumer behaviour 
supressed accident numbers and resulted in less 
work for our Personal Injury and Critical Care 
businesses. Nevertheless, we continued to make 
progress with our strategy, manage our debt and 
secure debt funding to the end of 2024, whilst 
remaining profitable. 

We have repositioned our Consumer Legal Services 
division and created a fully integrated law firm, 
capable of generating its own leads and focused 
on processing higher margin personal injury 
claims, while reducing our reliance on joint venture 
partnerships. In our Critical Care division, we 
have invested in business development initiatives 
to grow instruction volumes and are seeing 
encouraging results. While these investments will 
take time to translate into profits, we expect them 
to produce greater returns for shareholders in the 
medium and long-term. 

Meanwhile, in the short-term, as the UK adjusts to 
living with COVID-19 and mobility levels across the 
UK recover, we expect to see accident numbers 
gradually increase in our markets. This is expected 
to provide the Group with more opportunities to 
support customers with their personal injury claim 
or rehabilitation needs. 

COVID-19
In 2020, the Group, and indeed the whole country, 
had to quickly adapt and respond to the rapidly 
evolving threat of COVID-19. As a Group, we 
prioritised our staff and supporting our customers 
through that initial period and adapted our ways 
of working to enable homeworking and remote 
access to clients. We prioritised liquidity, slowed 
investment and protected jobs.

2021 started with the third of the Government 
lockdowns. In many ways, the third lockdown was 
the most challenging as it was both unanticipated 
and also the longest and therefore stifled our 
ability to recover at the pace we would have liked 
to. However, operational adaptations that we 
implemented in 2020 stood us in good stead 
and we were able to deliver a good service to our 
customers and generate cash flow. This gave us the 
confidence to increase the level of our investment 
in our Personal Injury and Critical Care businesses, 
despite slow growth in these markets. 

We completed the year with the threat of a new 
wave of restrictions in response to the Omicron 
variant. Thankfully, this turned out to be less 
serious than the Government first thought, but 
it did result in another reduction in mobility 
levels across the country in December 2021, and 
consequently fewer accidents. 

Overall, I’m pleased with the Group’s response to 
the COVID-19 crisis and by applying the learnings 
from successive lockdowns we are well placed to 
grow back stronger.

8 

NAHL Group Plc Annual Report and Accounts 2021

16% to £3.5m (2020: £4.1m) and we reduced the 
number of new enquiries placed with joint venture 
partners by 73% in the year. 

Profit before tax increased to £0.2m, from a loss 
before tax of £0.2m in 2020. Basic earnings per 
share (EPS) were 0.3p (2020: loss per share of 
0.5p) and diluted EPS were 0.3p (2020: a loss 
per share of 0.5p). Underlying basic EPS, the 
calculation of which is explained in note 1 to the 
financial statements, were 0.3p (2020: 1.9p). 

The Group has continued to carefully manage its 
cash flows while investing in its two divisions for 
future growth. Free cash flow (FCF) was £0.8m for 
the year. This compares to £6.1m in 2020, but our 
focus then was on increasing liquidity in response 
to the initial wave of the pandemic. Net debt 
reduced in the year to £15.5m at 31 December 
2021, down from £16.3m at the end of 2020.

We extended the term of our Revolving Credit 
Facility with Yorkshire Bank by two years to the end 
of 2024 and felt confident to reduce the size of the 
facility from £25.0m to £20.0m, consistent with 
our objective to reduce net debt. At year-end we 
had headroom in the facility of £2.0m in addition to 
£2.5m of cash in the bank.

The Board does not believe that it is appropriate to 
reinstate dividends at this time and the Directors 
have recommended that no final dividend be paid in 
respect of 2021. 

Strategic report

2021 results and net debt
The Group finished the year with results that were 
in line with the Board’s expectations. 

Revenue fell by 5% to £38.9m (2020: £40.9m), in 
the first full year to be affected by the COVID-19 
pandemic. 

This was primarily due to a 10% reduction in 
revenues in our Consumer Legal Services division, 
caused by a reduction in the number of personal 
injury accidents in the market and our decision 
to place more enquiries into National Accident 
Law (NAL) for higher future profits. Revenues in 
our Critical Care division grew by 9% to £12.3m 
(2020: £11.3m). 

As a consequence, the Group’s underlying 
operating profit1 reduced by 27% in the year to 
£4.2m (2020: £5.7m). As expected, underlying 
operating profit margins decreased from 13.8% to 
10.7%. In the Consumer Legal Services division, 
underlying operating profit reduced by 31% 
to £3.7m (2020: £5.4m) and in Critical Care, 
underlying operating profit reduced by 8% from 
£3.6m in 2020 to £3.3m.

Our decision to grow case processing in NAL 
required investment in the year however this 
is expected to generate higher margins in the 
medium and long-term. In our Critical Care division, 
our investments in people, systems and marketing 
activity, as well as changes to the commercial 
agreements we have with our case management 
and Expert Witness associates intended to secure 
resource, will help us to grow our market share and 
increase future revenues. 

We reduced costs in our Group shared 
services functions by 16% in the year to £1.6m 
(2020: £1.9m) and other items, which comprise 
share-based payment charges and amortisation 
charges on intangible assets recognised as part of 
business combinations, were 12% lower at £1.2m 
(2020: £1.4m).

There were no exceptional costs incurred in the 
year. In 2020 we recognised £1.4m of exceptional 
costs, largely related to the transformation and 
restructure of the Group’s Consumer Legal 
Services division. This work is now complete. 

The profit attributable to members’ non-controlling 
interests in our joint venture LLPs reduced by 

NAHL Group Plc Annual Report and Accounts 2021 

9

Strategic report

Consumer Legal Services
In our Consumer Legal Services division, revenue 
contracted by 10% from £29.6m in 2020 to 
£26.6m in 2021, and underlying operating profit fell 
by 31% to £3.7m (2020: £5.4m). 

Our strategy to succeed in the personal injury 
market is to create a higher margin, integrated law 
firm underpinned by our flexible business model. 
We will achieve this by continuing to generate our 
own work, using our National Accident Helpline 
brand and by processing an increasing number 
of those enquiries through our own consumer-
focused law firm, National Accident Law. Over time, 
we will process an increasing number of higher-
margin, non-RTA claims and our small claims 
proposition will allow us to maximise the return 
from lower value RTA claims. Finally, our agile and 
scalable placement model is designed to balance 
the work we place with our panel, and joint venture 
partners, for in-year profit and cash with the work 
we process ourselves for greater, but deferred 
profit and cash. 

Despite the challenges of operating in the 
pandemic, I’m pleased to report that we made 
progress with this strategy in 2021. 

Claim volumes in the personal injury market 
remained depressed throughout 2021 with 
registered claim numbers in the market running at 
c.60% of pre-COVID levels throughout much of the 
second half of 2021. This was due to two reasons. 

1)  Firstly, the Government restrictions that were 
put in place in response to the COVID-19 
pandemic resulted in reduced mobility levels 
across the UK. This was evidenced in mobility 
data provided by Google, which started 2021 
mobility levels at c.30% of the baseline2 before 
COVID-19 and grew to around 75% of baseline 
by November 2021. December 2021 then saw 
a further significant reduction, falling to around 
40% before partially recovering in the new year. 

2)  The second factor that caused claim 

numbers to be depressed was the impact 
of the regulatory changes to low value RTA 
claims from 31 May 2021. On this date, the 
Government implemented its planned changes 
to reduce compensation tariffs and eliminate 
cost awards for most RTA claims worth 
£5,000 or less. This removed the majority of 

value for firms processing RTA cases. If the 
intention was to encourage the majority of 
claimants to manage their own claim using the 
Government’s online portal, then the reality is 
very different. Since launch, fewer than 10% of 
claimants have processed their own claim and 
the vast majority still chose to rely on a law firm 
to represent them. The significant reduction 
in compensation available to injured claimants 
combined with the complexity of the process 
has resulted in a lower appetite to claim, leading 
to fewer RTA claims since implementation.

The Government continues to pursue reform to the 
personal injury market. In 2021, the Government 
confirmed that the small claim limit for non-RTA 
claims will increase from £1,000 to £1,500 from 6 
April 2022. Then in January 2022, the Department 
of Health launched a consultation on fixing costs 
in clinical negligence claims worth up to £25,000. 
The proposals are designed to reduce claimant’s 
legal costs, saving the NHS an estimated £500m 
over 10 years. We were anticipating both of these 
proposals, and we do not expect them to have a 
significant impact on our business.

The National Accident Helpline brand continues 
to be the most trusted in the industry3 and 
independent research found it to be associated 
with being helpful, experienced and professional. 
Our marketing activity produced 32,132 new 
enquiries in the year, which was fewer than the 
prior year (2020: 36,214) but that reflects a full 
year of COVID-19 impact. Pleasingly, 10% more 
enquiries were delivered in the period April to 
December 2021 then the equivalent COVID-19 
affected period in the prior year. Furthermore, this 
period delivered 18% more enquiries from organic 
channels in 2021 than the previous year, which 
helped us to manage our marketing cost in a highly 
competitive environment. 

We increased our placement of enquiries into NAL 
by 130% in the year, which included 569 non-RTA 
enquiries and 3,529 small claims. Overall, 26% 
of our total enquiries were placed into NAL for 
processing, which was a significant increase on the 
10% placed in 2020. As a result, at the end of the 
year, NAL was processing 7,918 ongoing claims, 
which was an increase of 166% on the previous 
year. These claims represent a store of value 
for the business that will deliver future revenues 

10 

NAHL Group Plc Annual Report and Accounts 2021

CEO report

NAHL Group Plc Annual Report and Accounts 2020 

11

Strategic report

and cash at an enhanced margin over what we 
could achieve through placing the claims into our 
panel. Based on our current assumptions on claim 
success and value, we estimate that these claims 
will generate c.£6.7m (2020: £3.8m) of future 
revenue and future cash receipts of £8.4m (2020: 
£4.7m). We maintained the proportion of enquiries 
placed with our panel of third-party laws firms and 
reduced the proportion of enquiries in our joint 
venture law firms by 73%.

Also within our Consumer Legal Services division 
is our Residential Property business, comprising 
Homeward Legal and Searches UK. This business 
had a strong year, buoyed by the stimulus of the 
Stamp Duty Land Tax holiday and very strong 
levels of business development success in our 
search business. These businesses generated 
revenue and contribution to operating profit 
before shared costs of £5.6m (2020: £6.3m) and 
£0.8m (2020: £0.3m) respectively and were a net 
contributor to the Group’s free cash flow in 2021. 

Critical Care 
Revenues in our Critical Care business, Bush & 
Co, grew by 9% to £12.3m (2020: £11.3m) and 
underlying operating profit reduced by 8% to 
£3.3m (2020: £3.6m). 

Our strategy in Bush & Co is to grow share in our 
market by appealing to a broader customer base, 
extending our competencies and specialisms and 
to be more efficient at what we do through the use 
of technology. I am pleased with the progress we 
made with these objectives in 2021. 

Bush & Co operates in the catastrophic injury 
market, which suffered a similar impact from 
COVID-19 as in Personal Injury, although it is 
unaffected by the small claims’ reforms. The 
majority of work stems from RTA injuries and 
medical negligence, both of which have seen 
reduced volumes over the past couple of years. 
Case management work is required soon after an 
accident and so the impact on our business was 
clear in 2020 and throughout 2021. Expert Witness 
services, conversely, are not required until the legal 
claim is well underway and average times from 
accident to instruction are around three years. 
Therefore, the full effect of the pandemic may not 
be seen for some time.

We invested in marketing and business 
development in the year and our focus on building 
strong, enduring customer relationships was 
rewarded with a 23% increase in instructions 
for Expert Witness work and a 5% increase for 
instructions for case management INAs. 

We continued our innovative “Happy Post” 
marketing campaign, delivering treats and 
wellbeing packs to solicitors and insurers, which 
attracted praise from across the industry and won 
us the accolade of Marketing Campaign of the Year 
at the 2021 PI Awards. 

Since the team relaunched the brand in 2019, 
Bush & Co has enhanced its reputation as an 
award winning, independent market leader, known 
for delivering a premium service with expertise, 
integrity and professionalism. 

The business increased the number of Expert 
Witness reports it issued by 21%, INA reports 
by 26% and ongoing case management clients 
it supported by 1%. This was an excellent result 
delivered by our operations teams and associates. 
We recruited 34 new associates and proudly work 
with 93 case managers and 96 expert witnesses 
across the UK, across a range of specialisms.

We launched Bush Care Solutions in August 2021, 
which is our expanded care proposition to support 
clients who require nurse-led care in their homes. 
This has been accredited by the Care Quality 
Commission and, along with our case management 
service, provides for a fully managed solution. We 
also launched our differentiated case management 
proposition, which is targeted at serious claims 
valued between £100,000 and £500,000. The 
division employed three new case managers in the 
year to deliver this proposition and the team have 
already started securing relationships with insurer 
customers. 

We have continued to invest in technology in 
Bush & Co, which will drive efficiency savings 
and be a growth enabler. In April 2021, we 
launched our proprietary medico-legal report 
writing tool for Expert Witness reports and this 
was utilised on 26% of reports in 2021. We also 
continued to roll out improvements to our case 
management system. 

12 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Our people, culture and 
communities
At NAHL, we aim to build a sustainable business 
for the long-term gain of all our stakeholders. 
While an important part of that is the development 
of our business models in our two divisions, we 
are committed to doing business in a way that is 
beneficial to our people, our communities and the 
environment. 

We employed 258 people as at 31 December 
2021, a decrease of 1% from the end of 2020 
and our team is split in the ratio 30:70 male to 
female staff. We have an experienced and capable 
leadership team that was restructured in the year, 
following my appointment as CEO. Chris Higham 
was appointed to the role of acting CFO and Will 
Herbertson to the role of Managing Director of 
the Consumer Legal Services division. In October 
2021, we were pleased to welcome John Kushnick 
to the Group to take on the role of Legal Operations 
Director, responsible for growing NAL. John is well 
known and respected in the industry, and we are 
already benefiting greatly from his experience. 

My team and I have always believed that for a 
business to be sustainable, it requires an inclusive 
and supportive culture, with clear leadership and 
a strong focus on employee engagement. The 
Group’s values of Driven, Curious, Passionate and 
Unified guide us in our short and long-term decision 
making and our culture has helped to sustain the 
business through the challenges of COVID-19 and 
our business transformation. 

In 2021, we continued our focus on clear and 
regular staff communication, with regular meetings 
and weekly updates. As the conditions evolved, 
so too did our communications, with an increased 
focus on connecting with people working remotely 
and on staff wellbeing. This was enhanced with the 
addition on our Group-wide employee engagement 
platform, called Totem, during the year. This 
mobile app helped our people to connect and 
award each other recognition, post videos and 
share encouragement.

Our annual engagement survey proved once again 
that our people appreciate our focus on culture 
and communication. Our engagement score of 
75% is significantly higher than the UK average of 
11%4. We have also received external validation of 
our culture, with our Personal Injury and Critical 
Care businesses holding the prestigious Gold 
status from Investors In People and our Residential 
Property business being awarded Silver.

Finally, we were thrilled that Bush & Co was placed 
at number 43 on Best Companies’ ‘The UK’s 100 
Best Small Companies to Work for 2021’, building 
on a similar award achieved by National Accident 
Helpline in 2019. 

We were pleased to support a number of 
community initiatives during the year, including 
supporting local food banks through monetary 
donations, collections and donations of Christmas 
lunches. As at 31 December, the Group had also 
funded the planting of 172 trees in Madagascar, one 
for each Consumer Legal Service employee. This 
will be extended to include Critical Care in 2022 
and we will continue adding trees each time we 
recruit someone new. 

Potential sale of 
Homeward Legal
We announced last year that we intended to 
explore a potential sale of our repositioned and 
streamlined Residential Property business, 
Homeward Legal. While this initially attracted 
encouraging levels of interest from the focussed 
group of potential buyers we engaged with, it 
proved very difficult to complete a deal due to 
external factors beyond our control. While we are 
not in negotiations with a buyer at present, we will 
look to explore a sale and consider our strategic 
options for this business in 2022.

NAHL Group Plc Annual Report and Accounts 2021 

13

Strategic report

Conclusion and outlook
In 2021 we increased the number of claims being 
processed in NAL and launched several new 
initiatives across both divisions. We carefully 
managed our investment levels to remain profitable 
and showed a reduction in net debt.

This progress has continued into 2022 as we look 
to grow the number of enquiries we generate, 
increase the number of claims we are processing in 
NAL, and develop our pipeline of work in Bush & Co. 

In our Personal Injury business, enquiry numbers 
for the first two months of 2022 were up 42% 
compared to the same period in 2021 and we have 
experienced an improvement in the average daily 
enquiry run rate each month since December 
2021. We allocated 31% of these enquiries to NAL, 
compared to 23% for the same period in 2021. 
In Critical Care, despite a relatively slow start in 
January caused by concerns around the Omicron 
variant of COVID-19, the number of Expert Witness 
and INA reports issued in the first two months of 
2022 increased by 8% and 7% respectively on the 
same period in 2021. Instruction numbers for the 
same period were also robust, with Expert Witness 
ahead by 7% and INA instructions by 28%.

Now that the last of the COVID-19 restrictions have 
been lifted, we expect to see mobility levels across 
the UK continue to improve and for this to result 
in a gradual increase in the number of accidents in 
our markets. The Board have undertaken an impact 
assessment considering the recent developments 
in the Ukraine crisis and do not consider that 
this will have a significant impact on the Group’s 
operations.

James Saralis,  
Chief Executive Officer

I would like to end by putting 
on record my thanks to our 
employees for their hard work, 
support and commitment. 
They faced many challenges 
during 2021, including having 
to adjust to the changing 
COVID-19 restrictions, and 
demonstrated their resilience 
and dedication to supporting 
our customers and each 
other. Thank you to our 
employees

James Saralis,  
Chief Executive Officer

1.  Underlying operating profit excludes certain exceptional items as 
detailed in note 1 to the financial statements. Refer to note 1 of the 
financial statements for a reconciliation of this measure to IFRS 
operating profit. 

2.  COVID-19 Community Mobility Reports, google.com.

3.  Independent research produced by The Nursery Research & 

Planning Ltd, September 2021.

4.  Gallup state of the global workplace report 2021.

14 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

CFO
Report

Overview
The year began with the UK in its third and most 
protracted lockdown as the Group continued to 
feel the effects of COVID-19 disrupting volumes 
in our markets as consumer behaviour changed 
and accident numbers were supressed. The year 
also saw the long anticipated small claims reforms 
come into effect at the end of May. Despite this, 
the Group remained profitable, generated cash and 
reduced net debt.

In 2020, we focused on generating immediate cash 
and profit through placement of enquiries into our 
panel law firms. Having created our wholly-owned 
law firm, National Accident Law (NAL), this year we 
turned attention to scaling the business to realise 
higher returns and higher profit in the future. 

We also invested in new initiatives and technology 
in the Critical Care division to underpin future 
growth. 

From an operational perspective, revenue fell 5% 
from £40.9m to £38.9m. This was largely due to 
the full year impact of the COVID-19 pandemic 
affecting accident numbers and reducing demand 
for our services along with our strategic decision to 
grow the number of enquiries we placed with our 
law firm, NAL. 

Underlying operating profit decreased by 27% from 
£5.7m to £4.2m at an underlying margin of 10.7% 
(2020: 13.8%), operating profit fell £0.1m to £4.2m 
and profit before tax was £0.2m (2020: loss of 
£0.2m).

NAHL Group Plc Annual Report and Accounts 2021 

15

Strategic report

Review of income statement

Consumer Legal Services 

Critical Care 

Revenue

Consumer Legal Services 

Critical Care 

Shared Services 

Other items 

Underlying Operating Profit 

Exceptional items 

Operating Profit 

Profit attributable to non controlling interest in LLPs 

Financial income 

Financial Expense 

Profit/(Loss) before tax 

Taxation 

Profit/(Loss) and total comprehensive income for 
the year

2021 
£m 

26.6 

12.3 

 38.9

3.7 

3.3 

(1.6)

(1.2) 

4.2 

0.0 

4.2 

(3.5) 

0.1 

(0.6) 

0.2 

0.0 

0.2 

2020 
£m 

29.6

11.3 

 40.9 

5.4 

3.6 

(1.9) 

(1.4) 

5.7 

(1.4) 

4.3 

(4.1) 

0.2 

(0.6) 

(0.2) 

0.0 

Change 
£m 

Change
%

 (3.0) 

(10.0%)

1.0 

(2.0) 

(1.7) 

(0.3) 

0.3 

0.2 

9.1%

(4.7%)

(31.1%)

(8.4%)

16.0%

12.1%

(1.5) 

(26.6%)

1.4 

(100.0%)

(0.1) 

0.6 

(3.5%)

16.1%

(0.1) 

(49.4%)

0.0 

0.4 

0.0 

5.1%

205.0%

(295.0%)

(0.2) 

0.4 

163.9%

Consumer Legal Services
The Consumer Legal Services division generated 
£26.6m of revenue, a decline of 10% from £29.6m 
while underlying operating profit fell by 31% from 
£5.4m to £3.7m. The national lockdown at the 
start of the year once again supressed accident 
numbers with enquiry volumes 18% lower than 
the second half of 2020. Across the full year, the 
National Accident Helpline brand generated 32,132 
enquiries, 11% lower than last year (2020: 36,214) 
albeit 2020 was largely unaffected by COVID-19 in 
the first quarter. Enquiries grew 27% in the second 
half of the year compared to the first half. 

We increased the number of enquiries placed into 
our wholly-owned law firm, NAL and following the 
introduction of the new rules around low value 
Road Traffic Accident (RTA) claims at the end of 
May, all volume from RTA in England and Wales 

has been placed with NAL. This has contributed 
to a 130% year-on-year increase in the number 
of enquiries processed by NAL. At the end of 
2021, NAL was processing 7,918 ongoing claims, 
an increase of 166% on the previous year. These 
ongoing cases are expected to contribute c£6.7m 
(2020: £3.8m) in future revenue and c£8.4m 
of future cash receipts (2020: £4.7m). Enquiry 
volumes placed with joint venture law firms 
decreased by 73% in the year. 

The enquiries processed by NAL have a longer 
revenue cycle that can run to a number of years 
compared to that of our panel arrangements, due 
to NAL recognising income only once an admission 
of liability has been received from the defendant. 
As we anticipated, the reforms have also resulted 
in a material reduction in revenue from a large 
proportion of our RTA claims.

16 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

The Residential Property business generated a 
positive contribution to profit of £0.8m (2020: 
£0.3m) before allocation of shared costs. The 
business benefitted from an extension to the 
market stimulus in the form of the Stamp Duty 
Land Tax holiday on properties valued up to 
£500,000 alongside business development 
successes and a full year impact of cost savings 
delivered in the previous year. 

Critical Care
The Critical Care division grew revenue by 9% from 
£11.3m to £12.3m (2020: a reduction of 16%) with 
Underlying Operating Profit reducing by 8% from 
£3.6m to £3.3m. 

The division has continued to invest in business 
development activity contributing to a 23% 
increase to Expert Witness instructions and a 
6% increase in INA instructions. Expert Witness 
reports delivered grew by 21%. The number 
of ongoing case management cases has also 
marginally increased although revenue from these 
cases is broadly flat as appointments have been 
carried out remotely during COVID-19 as opposed 
to face-to-face. 

Operating costs increased in the year due to 
investments in people, marketing activity and 
systems to grow the business including new 
initiatives, Hubs and Bush Care Solutions (see 
CEO report on page 12) as well as changes to 
commercial agreements to secure associate 
resource which also further strengthened our IR35 
position with associates. 

Shared Services
The costs for the Group’s Shared Services 
functions fell by £0.3m to £1.6m (2020: £1.9m). 

Government Support
The Group made use of £0.01m of Government 
support in the form of the Coronavirus Job 
Retention Scheme (2020: £0.4m). This income 
is shown in the financial statements in underlying 
operating profit as netted off administration 
expenses within the divisional results. We repaid 
£0.4m of VAT deferred from 2020 in the year with 
no further deferral in 2021.

Exceptional and non-
underlying items
The Group did not incur any exceptional costs 
in the year (2020: £1.4m). Costs relating to the 
exploration of disposing of the Residential Property 
business have been expensed within underlying 
operating profit. 

Taxation
The Group’s tax charge of £79,000 (2020: £2,000) 
represents an effective tax charge of 33.6% (2020: 
-0.9%). The tax charge is higher than the standard 
corporation tax rate of 19% for the reasons set out 
in note 9 to the financial statements. The deferred 
tax credit originates from temporary differences 
in intangible assets acquired on business 
combinations.

Earnings per share (EPS) 
and dividend
Underlying EPS for the year were 0.3p (2020: 1.9p). 
Underlying EPS provide a better comparison year 
on year as earnings have been adjusted to exclude 
certain exceptional items (net of the standard rate 
of corporation tax). This is explained in note 1 to the 
financial statements. 

Basic EPS for the year were 0.3p (2020: -0.5p) and 
the diluted EPS were 0.3p (2020: -0.5p), reflecting 
the impact of share options due to vest in future 
years. 

The growth in basic EPS is due to the exceptional 
costs totalling £1.4m (comprising costs for the 
strategic transformation of the Personal Injury 
division, restructure of Residential Property 
and Personal Injury into a new Consumer Legal 
Services division and due diligence costs relating 
to a potential offer for the Group) not repeated 
in 2021, partially offset by a full year impact 
of COVID-19 and continuing investment in the 
Personal Injury and Critical Care businesses. 

The Board does not believe it is appropriate to 
re-instate dividends at this time and the Directors 
have recommended that no final dividend be paid in 
respect of 2021 (2020: nil).

NAHL Group Plc Annual Report and Accounts 2021 

17

Strategic report

Review of the statement of 
financial position
In reviewing the statement of financial position, 
I consider the significant items to be working 
capital, defined as trade and other receivables less 
trade and other payables, and net debt.

Working Capital 
Trade and other receivables less trade and other 
payables totalled £17.2m at year end (2020: 
£16.7m). 

Trade receivables and accrued income balances 
related to the processing of personal injury 
claims decreased to £6.9m (2020: £7.3m). These 
claims are yet to reach the settlement stage 
but have received an admission of liability from 
the defendant. This is in line with the Group’s 
accounting policy for legal services revenue in 
note 1 to the financial statements. Accrued income 
included £1.7m (2020: £0.9m) relating to liability 
admissions received on open cases within National 
Accident Law.

There is a significant element of uncertainty in 
estimating this accrued income, as discussed 
further in note 1 to the financial statements. The 
Directors believe that the assumptions adopted are 
appropriate and based on historical experience of 
claims processed in our law firms and by our panel. 
These assumptions are updated with actual results 
as claims settle. 

Disbursement receivables increased from £6.7m to 
£8.3m as we scaled NAL. 

Receivables not relating to the law firms decreased 
from £20.3m to £18.2m. This is a result of the 

maturity of historic deferred debt from our panel 
debtors including having received £1.5m of the 
settlement relating to the termination of National 
Law Partners, agreed in 2019. The remaining 
amount of £1.4m is due to be settled by the end of 
Q2 2022. 

Payables reduced from £17.5m on 31 December 
2020 to £16.2m at the balance sheet date. This 
was due to the unwinding of product commissions 
settled in advance and a £0.4m payment for 
VAT deferred from 2020, offset by an increase in 
disbursement payables in our law firms. The latter 
increased, as expected, from £6.0m to £7.2m. 

Net debt and bank 
facilities
We carefully managed our cash resources during 
the year to balance an investment in processing 
personal injury cases with a desire to reduce net 
debt. As a result, net debt fell from £16.3m as at 31 
December 2020 to £15.5m at year-end. Net debt is 
defined in note 29 to the financial statements and is 
comprised of £2.5m of cash (2020: £3.6m) offset 
by borrowings of £17.9m (2020: £19.9m).

The borrowings represent a balance on the Group’s 
Revolving Credit Facility with its lender, Yorkshire 
Bank. We successfully renegotiated the facility with 
Yorkshire Bank extending the facility term for a 
further 24 months through to 31 December 2024. 
As part of the agreement with Yorkshire Bank, 
new covenants have been agreed aligning with our 
latest forecasts and the overall facility has reduced 
from £25.0m to £20.0m to appropriately reflect 
our medium-term requirements. 

18 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Review of the cash flow statement

Net cash generated from operating activities 

2021 
£m 

5.1 

2020 
£m 

11.0 

Change 
£m 

Change
%

(5.9) 

(53.4%)

Net cash used in investing activities 
(excl. disposal of subsidiaries) 

Facility arrangement fees 

Principal element of lease payments 

Drawings paid to LLP members 

Net cash used in financing activities  
(before borrowings)

Free cash flow 

Disposal of subsidiaries 

Repayment of borrowings 

Net (decrease)/increase in cash and cash 
equivalents 

(0.6) 

(1.1) 

0.5 

(42.7%)

(0.1)

(0.2)

(3.4) 

 (0.1) 

 (0.5) 

(3.2) 

0.0 

0.3 

(25.6%)

(70.3%)

(0.2) 

(6.8%)

(3.7) 

(3.8) 

0.1 

5.3%

0.8 

0.0 

(2.0)

6.1 

(1.3) 

 (3.8) 

(5.3) 

(86.0%)

1.3 

1.8

(100.0%)

(46.7%)

(1.2) 

1.0 

(2.2) 

(210.1%)

NAHL Group Plc Annual Report and Accounts 2021 

19

In conclusion, despite the 
continued disruption caused 
by the COVID-19 pandemic, 
we have made progress with 
our strategy, investing in both 
the Consumer Legal Services 
and Critical Care divisions, 
positioning them well to 
maximise future returns whilst 
continuing to manage debt. 

Chris Higham 
Acting Chief Financial Officer

Strategic report

The Group’s cash and cash equivalents reduced 
by £1.2m in the year (2020: increase of £1.0m). 
This was primarily due to repaying borrowings and 
increased investment. The significant items in the 
consolidated cash flow statement are net cash 
from operating activities, drawings paid to LLP 
members and the repayment of borrowings.

Net cash from operating activities reduced from 
£11.0m to £5.1m as we switched focus back 
to growing the number of cases processed in 
NAL in line with our strategy. We temporarily 
changed focus to increase liquidity in 2020, in the 
immediate aftermath of the onset of the COVID-19 
pandemic. Net cash generated from operating 
activities included £2.1m in relation to claims 
settlements received by National Accident Law 
(2020: £1.3m).

The Group paid £3.4m (2020: £3.2m) of drawings 
to its partners in the joint venture law firms during 
the year, under the terms of our agreements. This 
reflects the growth in claims won and settled during 
the year. The Group also acquired £0.3m (2020: 
£0.8m) of intangible assets in the year as it sought 
to improve its technological offering in Critical Care. 

The Group repaid £2.0m (2020: £3.8m) of 
borrowings in the year on its Revolving Credit 
Facility. 

Free Cash Flow (FCF) is the Group’s KPI 
with regards to cash flow. FCF in 2021 was 
£0.8m compared to £6.1m in 2020. The primary 
reason for this decrease is the change of focus to 
processing more cases in NAL as outlined above. 

The Group also monitors underlying cash 
conversion. This fell to 150.2% in the year (2020: 
228.9%), a direct result of the fall in operating cash 
as explained above. 

Chris Higham 
Acting Chief Financial Officer    

20 

NAHL Group Plc Annual Report and Accounts 2021

Section

Our Business

NAHL Group Plc Annual Report and Accounts 2020 

21

Strategic report

Our
group
NAHL Group plc is a leader in the consumer legal services and 
catastrophic injury markets, delivering products and services to 
consumers and businesses through its two divisions.

Consumer Legal Services
WHAT WE DO
Consumer Legal Services provides outsourced 
marketing services to law firms through 
the National Accident Helpline brand and 
Homeward Legal, and claims processing to 
individuals through National Accident Law and 
its joint venture partnerships, Law Together and 
Your Law.  It also provides property searches 
through Searches UK.

Critical Care

WHAT WE DO
Critical Care provides a range of specialist 
services in the catastrophic and serious 
injury market to both claimants and 
defendants through Bush & Co.

PROFILE
• Revenues of £26.6m

PROFILE
• Revenues of £12.4m

• Underlying operating profit of £3.7m

• Underlying operating profit of £3.3m

• 169 employees

• 69 employees and 189 associates

STRATEGY
Our strategy is to create a higher margin, 
integrated law firm, underpinned by our flexible 
business model. We will do this by continuing 
to generate our own work, using our National 
Accident Helpline brand, by processing an 
increasing number of claims through our own 
consumer-focused law firm, National Accident 
Law, and by leveraging our agile and scalable 
placement model to manage our growth.

STRATEGY
Our strategy is to grow share in the 
catastrophic and serious injury markets 
by appealing to a broader customer 
base, extending our competencies and 
specialisms and to be more efficient 
at what we do through the use of 
technology.

Core Competencies

Marketing 
capability

Technologically 
enabled

Trusted  
brands

Highly skilled, 
empathic 
people

Customer 
centric 
approach

Strong 
employee 
culture

Shared Services

WHAT WE DO
Operating as a centralised function, Shared 
Services provides strategic leadership, funding 
and governance to support the divisions.

• £1.6m cost base 
• 20 employees
•  Provides Board, finance, legal and 

people services

value to be realised in the future. The proportion of 
work placed into our joint venture partnerships was 
reduced, in line with our long-term plans.

2021 also saw the small claims’ reforms around 
whiplash RTA claims come into effect on 31st May. 

NAL had already prepared its systems and 
embedded efficient ways of working in preparation 
for the implementation of the small claims reforms 
and from the day the reforms came into effect, NAL 
has taken on all RTA claims generated through the 
National Accident Helpline brand. Technological 
innovation was embedded throughout our 
operations in 2020. This included upgrades to our 
call centre technology, implementation of our ‘One-
Call’ process and a new digital tool enabling RTA 
claims to be made online. These changes enabled 
us to handle cases efficiently, while retaining the 
customer-focused friendly approach which we 
pride ourselves on. We aim to grow the number of 
customers using our digital sign-up tool in 2022.

Our thorough preparation meant that when the 
legislative changes went live, everything was in 
place to ensure effective handling of cases; our 
team and systems were ready and able to utilise 
the new Government portal. 

Strategic report

Consumer Legal Services
The Consumer Legal Services division serves 
the personal injury and residential conveyancing 
sectors of the legal services market. The division 
provides outsourced marketing services to law 
firms through the National Accident Helpline brand 
and Homeward Legal, and claims processing to 
individuals through National Accident Law (NAL), 
and its joint venture LLPs, Law Together and Your 
Law. In addition, it also provides property searches 
through Searches UK.

The first half of 2021 was largely dominated by 
the third COVID-19 lockdown, with measures only 
beginning to ease during Q2. This caused a further 
reduction in volumes within the personal injury 
market, which contracted by 16% compared to the 
previous year. 

While Q1 2020 was only impacted by the pandemic 
for a brief period, 2021 was impacted in its entirety 
by the ongoing situation, and as a result market 
volumes fell for employers liability, road traffic 
accident (RTA) and public liability claims, with only 
the clinical negligence market showing year-on-
year growth. Market volume began to return in H2 
but the rate of recovery was slower than the market 
had experienced following the first 2020 lockdown. 
As restrictions were eased this time, volumes rose 
at a steady pace.

Over the course of the year and in support 
of our strategy to grow the volume of 
enquiries processed by NAL, 26% 
of all claims triaged by the NAL 
legal support teams went on to 
be handled by NAL, up from 
10% the year before. Market 
data shows slower growth 
in the RTA market than the 
volumes we see in our data, 
indicating that our strategy 
has resulted in growth of 
market share.

Following our strategy, we 
began to place more non-
RTA claims into NAL from 
Q4. In total, our law firm has 
around 8,000 cases currently 
in progress, representing a 
significant body of work and 

NAHL Group Plc Annual Report and Accounts 2021 

23

Consolidation of our marketing teams throughout 
our Consumer Legal Services businesses was 
completed, enabling us to work more efficiently 
across the division. Significant projects completed 
in the Residential Property business included 
the introduction of a new CRM system for 
Homeward Legal which saw conversion increase by 
approximately 40%.

Searches UK followed a similar trading pattern 
to Homeward Legal, with the year ending with 
volumes surpassing expectations.

Strategic report

Marketing within the personal injury sector remains 
highly competitive, though advertising spend 
dropped significantly during the pandemic and 
has not returned to pre-COVID levels. Our focus 
remains on generating volume through digital 
marketing channels. 

Internally, we focused on upskilling our team to 
ensure we had the personnel and skills in place to 
deliver our growth plans. The appointment of John 
Kushnick to the role of Legal Operations Director 
brought a wealth of experience to our leadership. 
John’s expertise has helped us to further refine 
our ways of working. Our legal capabilities and 
capacity continue to grow with the addition of 10 
new team members whilst four team members also 
completed their apprenticeships in 2021. 

By embracing hybrid working, we have been able 
to recruit from a wider geographical area, providing 
us with greater access to the best candidates to 
help us realise our goals. Team members working 
in the office are now able to work in comfortable, 
modern surroundings following the completion of 
the refurbishment at our head office, Bevan House 
in Kettering.

Externally, relationships with our key partners 
remain strong, including our joint venture partners, 
panel law firms, insurance and medical agencies.

Our Residential Property businesses continued 
to trade profitably throughout 2021. While 
discussions continued with third parties regarding 
the sale of this area of the business, our teams 
working within Homeward Legal and Searches UK 
remained focused on delivery. 

Market volumes in our Residential Property 
business were heavily influenced by the 
Government’s timetable for the end of the Stamp 
Duty holiday, which was originally due to take place 
at the end of March 2021 and was subsequently 
extended to the end of June. Following the end 
of the Stamp Duty holiday, after an initial dip in 
activity, volumes began to recover towards the end 
of the year as the market normalised.

24 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Critical Care 
Our Critical Care business, Bush & Co, holds a 
leading position providing support services in the 
catastrophic injury market, itself a subset of the 
medical reporting and rehabilitation market. The 
catastrophic injury market is defined as those 
cases involving the most severe and life-changing 
injuries, with settlement values of £500,000 and 
above. 

The complexity of catastrophic injuries results 
in long case life cycles. Most clients require the 
services of an expert witness and around half will 
use a case management service to support their 
rehabilitation.

Case management services usually begin when a 
client’s solicitor instruct Bush & Co to conduct an 
Initial Needs Assessment. These assessments are 
typically conducted three to four months after an 
injury occurs and the outcomes are documented 
in a report. This may result in ongoing case 
management support for the client’s rehabilitation, 
which has an average life cycle of over two years, 
meaning that in any given year, more than half of 
the cases under management relate to accidents 
suffered in previous years. 

COVID-19 resulted in a contraction in accident 
volumes, as lockdowns and Government guidance 
resulted in fewer people being out on the roads, 
in workplaces or receiving non-urgent medical 
treatment. Consequently, there have been fewer 
case management instructions in the market since 
the start of the pandemic and levels remained 
depressed throughout 2021. The clinical negligence 
market, however, remained buoyant. Pleasingly, 
Bush & Co benefitted from the strength of its 
established, strong customer relationships 
and grew its market share through the year. 
As restrictions are lifted and accident volumes 
increase, we expect the volume of instructions for 
case management to return to pre-pandemic levels 
during H2 2022. 

Expert witness instructions are typically received 
once a case is well underway, on average around 
three years from the date of the accident. 
Instruction volumes exceeded our expectations 
in 2021, growing by more than 21% year on year. 
Due to the extended delay between accident 
and instruction, we believe the full impact of the 

pandemic on market volumes in the expert witness 
market is still to be realised. However, our analysis 
shows that Bush & Co has also grown market share 
in expert witness services and this, along with our 
strong customer relationships, should help us to 
minimise any impact of this. Overall, we expect that 
volumes in 2022 will continue to grow.

Our investment in technology included the 
successful launch of our proprietary report writing 
tool for expert witness reports, in April 2021. This 
tool helps to streamline the production of reports 
and enhances quality, whilst delivering savings as 
demand grows. This tool is now fully embedded 
and operating successfully, with more than 70% of 
our most popular care and occupational therapy 
reports being completed using this model.

We launched our differentiated case management 
proposition for serious injury claims valued at 
between £100,000 and £500,000. This service 
utilises employed case managers and technology 
solutions to deliver outcome-driven solutions for 
our larger customers.

We also entered the adjacent care market with 
the launch of Bush Care Solutions in September 
2021. Having achieved accreditation for TDDI 
(Treatment of Disease, Disorder or Injury) from the 
Care Quality Commission, Bush Care Solutions is 
able to offer nurse-led care management services 
to support rehabilitation in a client’s home. The 
introduction of this service complements Bush 
& Co’s existing case management offering and 
enables us to offer clients a fully managed solution.

Bush & Co’s reputation as an industry leader 
and employer of choice was reaffirmed with two 
accolades during 2021. It was named at position 
43 on Best Companies “Best Small Companies 
to Work for in the UK” list in May, and went on to 
receive an award for Marketing Campaign of the 
Year at the PI Awards in November.

NAHL Group Plc Annual Report and Accounts 2021 

25

Our group

NAHL Group Plc Annual Report and Accounts 2021 
26 

26
NAHL Group Plc Annual Report and Accounts 2021

Section

KPIs

NAHL Group Plc Annual Report and Accounts 2021 

27

Strategic report

Key
Performance
Indicators 2021

The Board monitors a number of Key Performance Indicators 
(KPIs) to assess the Group’s performance against its strategic 
objectives. These KPIs include alternative performance 
measures where they provide additional insight into 
performance from the perspective of shareholders and other 
stakeholders. 

In addition to the Group’s financial KPIs, the Board 
has identified several non-financial KPIs that help it 
track progress in areas that are critical for the long-
term success of the Group. These are not directly 
reflected in the Group’s financial statements but 
are assessed on a regular basis and managed by 
divisional management. 

1. Revenue
Revenue comprises amounts receivable from 
customers for the provision of the Group’s 
services. The Group’s key revenue streams are 
detailed in note 1 to the financial statements on 
page 100. As mentioned in the CEO report, the 
Group’s transition to a self-processing law firm has 
meant that an increasing proportion of revenue 
is deferred until liability admission, and therefore 
monitoring and generating growth in revenues is 
key to the Group building a sustainable business 
model. Revenue over the past three years has been 
adversely impacted by the COVID 19 pandemic 
which has reduced demand for our services and 
products from both our panel of B2B customers 
and B2C consumers. 

2. Cash generation – 
free cash flow 
Free cash flow comprises the cash that the Group 
has generated from operations, less amounts 
invested in capital items, lease payments and 
payments to and from members’ non-controlling 
interests in our LLPs. 

The lockdown measures associated with the 
COVID-19 pandemic have continued to impact 
the number of accidents taking place which again 
resulted in fewer enquiries being generated in our 
Personal Injury business (KPI 4). We have balanced 
our liquidity with our desire to grow the number 
of claims processed by National Accident Law 
to realise higher returns, by flexing placement of 
our enquiries in the year (KPI 5). These decisions 
contributed to the Group generating £0.8m of 
free cash flow (please see CFO’s report on Page 
20 for more details and note 2 to the financial 
statements for a reconciliation of this figure to 
statutory measures).

 Cash generation – free cash flow (£’000)

 Revenue (£’000)

2021 

2020 

2019 

38,947

40,875

51,314

2021  849

2020  

(1,702) 2019

6,068

28 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

3. Profitability – Operating 
Profit 
Operating profit reflects the overall performance 
of the business. Operating Profit has decreased 
in 2021 due to the continued impact of COVID-19 
on enquiry volumes in Consumer Legal Services, 
increased investment in processing cases in 
National Accident Law and the enactment of new 
legislation relating to small claims road traffic 
accidents in May 2021, which have had a material 
effect on the value of these claims (please see 
CEO’s report on page 10 for more details).

 Operating profit (£’000)

2021 

2020 

2019 

2,563

4,156

4,309

4. Marketing services – 
personal injury enquiries 
generated 
Our ability to generate personal injury enquiries 
and balance these against market demand and 
available working capital, are a core element 
of our business model and a leading indicator 
of revenue. COVID-19 has continued to restrict 
accident numbers in the market which have, in 
turn, impacted enquiry volumes generated through 
the National Accident Helpline brand. (Please see 
CEO’s report on page 10 for more details).

 No. of enquiries (’000)

2021 

2020 

2019 

32,132

36,214

56,256

5. Personal injury enquiry 
placement – percentage 
of enquiries placed in each 
processing channel
Our placement decisions influence profit and cash 
flow in the current year, as well as in future years. 
Enquiries processed by National Accident Law 
generate higher levels of profit compared to those 
processed by our joint venture law firms or the 
panel, but cash is delayed until the claim is settled. 
Also, the volume of new claims placed in National 
Accident Law is limited by levels of operational 
capacity and available working capital. 

Monthly placement levels are planned as part 
of our annual budgetary process, but these can 
be flexed throughout the year depending on the 
volume of enquiries generated, capacity within 
National Accident Law or levels of capital available. 

Since the new small claims rules relating to road 
traffic accidents were introduced in May 2021, all 
enquiries from road traffic accidents in England 
and Wales have been processed by National 
Accident Law. This contributed to a 130% increase 
in the number of enquiries placed with National 
Accident Law in the year, as well as an increase in 
the number of open cases at 31st December 2021 
(KPI 6)

 Panel and other

 Joint Venture Law Firms

 National Accident Law

2021 

2020 

2019 

68%

6%

26%

69%

21%

10%

67%

29%

4%

NAHL Group Plc Annual Report and Accounts 2021 

29

7 Expert reports – critical 
care reports issued 
We charge fees for issuing expert witness reports 
and initial needs assessments in Critical Care. 
Volume exceeded our expectation this year with 
volume ahead of pre-pandemic levels. (Please see 
CEO’s report on page 12 for more details).

 No. of ongoing claims

2021 

2020 

2019 

1,389

1,148

1,325

Strategic report

6 Service provision – 
ongoing claims/open case 
management cases 
On average, personal injury claims take a number 
of years to conclude. Our ongoing claims represent 
a store of value that will convert to revenue and 
cash in future years as the claims progress through 
the legal process and, ultimately, settle. We have 
materially increased the number of enquiries placed 
with National Accident Law during 2021 and this 
has contributed to open case volumes closing 166% 
higher than 2020. 

In Critical Care, we invoice monthly for ongoing case 
management support provided to clients. COVID-19 
continued to impact volumes due to fewer people 
being out on the roads, in workplaces or receiving 
non-urgent medical treatment. As a result, the 
number of ongoing cases is only marginally ahead of 
2020. (Please see CEO’s report on page 12 for more 
details).

National Accident Law

 No. of ongoing claims

2021 

2020 

2,975

2019

1,641

Critical Care

 No. of ongoing cases

2021 

2020 

2019 

7,918

1,222

1,208

1,294

30 

NAHL Group Plc Annual Report and Accounts 2021

Strategic priorities

NAHL Group Plc Annual Report and Accounts 2021 

31

Strategic report

Consumer
Legal
Services

Strategic Priority

Progress made in 2021

Our focus in 2022

Generate our own work to fuel 
the business model
Cost-efficiently generate the 
enquiries needed to fuel the 
business model and deliver 
growth

•  Generated 32,132 enquiries in 
the year, with a 27% growth in 
the second half compared to 
the first half 

•  Delivered improved organic 
search performance on the 
National Accident Helpline 
website following Google’s Core 
Web Vitals algorithm change in 
June 2021

•  Built brand awareness through 

thought leadership and 
consumer campaigns, including 
Rights on Site and road safety

•  Maintain a high level of brand 
awareness to support cost-
effective enquiry acquisition

•  Continue to develop our SEO 
performance, to optimise the 
cost of acquisition 

•  Work towards a return to TV 
advertising in the second half 
of 2022, providing the market 
conditions are supportive to 
warrant this investment.

Grow the number of personal 
injury enquiries we process 
through National Accident Law
Scale NAL in order to deliver a 
sustainable business, with more 
profit per enquiry

•  NAL has processed 100% of 
RTA enquiries since 31 May

•  Recruit the right people to 

enable our growth

•  569 non-RTA claims were 

allocated to NAL for processing 
from 1 July, which should result 
in a higher margin business

•  Optimise the processes to 
achieve the admission and 
settlement timescales in our 
planning assumptions

•  RTA small claims proposition 

•  Manage the cost of processing 

launched on 31 May, 
allowing NAL to continue to 
monetise low value RTA. NAL 
commenced work on 3,529 
small claims in 2021

claims to our plan

•  Developed our digital sign-

•  Grow the proportion of RTA 

Build a technologically enabled 
law firm to maximise our 
processing efficiency 
Ensure our technology and 
marketing supports digital sign-
up and processing of cases, to 
delight customers and maximise 
efficiency

up and My Account tools to 
facilitate RTA small claims 
processing

•  Successfully introduced 

Peppermint CRM software into 
Homeward Legal to improve 
lead conversion rates

Deliver a great customer 
experience
Ensure customer care is at the 
forefront of our service offering

•  Maintained “Excellent” score 
on Trustpilot for National 
Accident Helpline

small claims using digital sign-
up and processing

•  Continue to maximise 

customers’ usage of our My 
Account portal

•  Continue to develop our 

Peppermint case management 
system to drive efficiency gains

•  Deliver leading customer 

satisfaction levels at sign-up 
resulting in strong Trustpilot 
scores for National Accident 
Helpline

•  Deliver leading customer 

satisfaction levels through to 
settlement resulting in strong 
advocacy scores for NAL

32 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Critical
Care

Strategic Priority

Progress made in 2021

Our focus in 2022

Grow and Strengthen 
Customer Base
Increase the breadth and depth 
of our customer base to drive 
an increase in new instructions 
year-on-year

Extend Team Competencies 
and Specialisms
Extend the range of 
competencies and specialisms 
within the associate group to 
realise revenue at more stages 
in the case lifecycle

Invest in Technology to 
Facilitate Growth
Ensure Bush & Co is supported 
with the right technology to 
enable and underpin growth

Expand into Adjacent Market 
Segments
Develop the HUBS proposition 
to grow lower value, serious 
injury case management work

•  Built on our “Happy Post” 
marketing initiative and 
engaged with both existing and 
potential customers

•  Grow case management and 
expert witness instruction 
numbers

•  Develop relationship with new 

•  Increased instruction numbers 

customers

for expert witness by 21% 
YoY and for initial needs 
assessments by 5% YoY

•  Launched Care Quality 

•  Grow number of nurse-led care 

Commission (CQC) accredited 
nurse-led care service to 
support clients

•  Launched our new proprietary 
medico-legal report writing 
tool for Expert Witness in April 
2021, which has increased 
associate capacity to facilitate 
growth within existing 
resources

•  Implemented improvements 
to core case management 
systems to develop resilience 

•  Recruited six employed case 
managers to help grow the 
HUBS proposition

packages

•  Recruit the right blend of 

associates to ensure coverage 
of all geographies and case 
types

•  Develop our specialisms in child 

and young person cases

•  Deliver further improvements 

to core systems to drive 
operational and reporting 
efficiencies

•  Produce more expert witness 
reports using new digital tool 

•  Develop a portal for use by 
customers and clients to 
improve outcomes

•  Upgrade the finance system 

to drive efficiencies and better 
reporting

•  Grow the number of customers 

signed up to the HUBS 
proposition

•  Launched the HUBS brand in 

•  Grow the number of serious 

October 2021

•  Successfully signed up two 
customers and developed 
relationships with several 
others

injury instructions supported 
through the HUBS brand

NAHL Group Plc Annual Report and Accounts 2021 

33

Section

Principal risks and uncertainties

34 

NAHL Group Plc Annual Report and Accounts 2021

Principal risks and uncertainties

Strategic report

Principal risks 
and uncertainties

The Board is mindful of the detrimental impact that the Group’s 
principal risks and uncertainties could have on its ability to 
deliver on its strategic priorities. It seeks to identify, assess and 
manage these risks through its risk management framework 
and regular reporting and review, combined with additional 
assurance work. Whilst the Board has ultimate responsibility for 
risk, it is supported by the Audit and Risk Committee, Executive 
Director and management.

Our risk management 
framework
The Board maintains a risk management 
framework (figure 1, page 37) that combines a top- 
down strategic assessment of risk with a bottom-
up operational identification and reporting process.

The regular review of existing risks and 
identification of emerging risks is managed 
through quarterly risk reviews between divisional 
management and the Executive Director. Once 
risks are identified and the Group’s appetite for 
each risk determined, risks are prioritised and 
mitigating actions implemented.

Risk appetite
Every year, the Board reviews and sets the Group’s 
appetite for risk. This is done by attributing a score 
to each one of six separate risk categories that the 
Board has identified. The categories are as follows.

1  Strategic & transformation

Risk identification and 
reporting
Divisional management conducts an ongoing 
process of identification and assessment of key 
risks (both financial and non-financial) faced by 
their division. This includes the identification of 
emerging risks, whether from structural changes 
in their markets or transformation activity within 
the business.

Risks are collated on a risk register along with 
mitigating actions that reduce the residual risk to 
an acceptable level, with reference to the Board’s 
appetite. Residual risks are assessed according to 
their likelihood of occurrence and potential impact 
on the profitability and cash flow of the Group.

Divisional risk registers are reviewed quarterly by 
the Executive Director and risks are prioritised 
across the Group. The highest rated risks are 
denoted principal risks and are reported by the 
Executive Director to the Audit and Risk Committee 
and the Board.

2  Operational

3  Financial

4  People and culture

5  Regulatory

6 

IT, systems and data security

These are scored on a scale of 1 (lowest risk) to 12 
(highest risk) and a score of 1–3 is described as an 
averse appetite, 4–6 is a cautious appetite, 7–9 is 
balanced appetite, and 10–12 is an entrepreneurial 
appetite. Individual risks are allocated a category 
and the associated risk appetite then informs 
management’s approach to mitigating that risk.

NAHL Group Plc Annual Report and Accounts 2021 

35

36 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Figure 1 – Risk management framework

i

S
t
r
a
t
e
g
c
a
s
s
e
s
s
m
e
n
t
o
f

r
i
s
k
a
n
d
p
r
i
o
r
i
t
i
s
a
t
i
o
n

Board

Ultimate responsibility for 
risk management

•  Sets strategic priorities

•  Agrees the Group’s appetite for each risk category

•  Top-down risk identification

•  Delegates authority

Audit & Risk
Committee

Executive  
Director

Monitors effectiveness of risk 
management through reporting  
and assurance

•  Sets scope of external audit

•  Monitors internal controls through internal reviews

•  Reviews critical accounting judgements and 

estimates

Monitor performance and  
changes in key risk

•  Provides regular reports and updates to the Board

•  Reports to the Board and Audit & Risk Committee 

on key risks

•  Provides guidance and advice to divisional 

management through quarterly risk reviews

R
i
s
k

i

d
e
n
t
i
f
i
c
a
t
i
o
n
a
n
d
r
e
p
o
r
t
i
n
g

Divisional
management

Identifies, manages and 
reports local risks

•  Maintains local risk registers and mitigation plans

•  Regular assessments of emerging risks

•  Implements mitigation plans

•  Reports quarterly to Executive Director on risk

NAHL Group Plc Annual Report and Accounts 2021 

37

 
 
 
 
 
 
 
 
Strategic report

The principal risks identified are detailed below:

Category

Financial

Risk
Appetite

Balanced
(7/12)

Description

Credit exposure
The Group has a number 
of historic and ongoing 
arrangements with law firm 
customers, some
of which involve deferred 
payments which create a 
credit risk in the event of their 
insolvency or a dispute.

Financial

Balanced
(7/12)

Accuracy of business model 
assumptions (including impact 
of COVID-19)
The Group’s business 
model relies on several 
key assumptions which, 
if not delivered, have a 
material impact on financial 
performance and strategy. 
Some of these assumptions 
could be impacted by an 
elongation of the
COVID-19 pandemic. These 
include assumptions relating to:
•  Enquiry generation costs and 

volumes

•  Case processing performance

•  Small claims processing 

efficiency

•  Volume of critical care 

instructions

Mitigation

The Group has processes 
to approve credit limits and 
monitor exposures, and has 
adopted a more cautious 
approach when considering 
deferred terms for panel law 
firms. No new material deferred 
deals have been entered 
into since 2020. Contractual 
provisions such as set-off 
clauses are in place to mitigate 
the risk for material debts. 
Credit exposure is not material 
in the Critical Care division due 
to the dilution of risk between 
multiple customers.

Model assumptions are 
determined by management 
with oversight from the 
Executive Director and the 
Board.
Sensitivities are performed 
on the key assumptions. 
The model assumptions are 
scrutinised and compared to 
actual results on a regular basis. 
The 2022 budget factored in 
assumptions relating to an 
ongoing COVID-19 impact on 
instruction volumes and other 
key metrics across the Group. 
Adverse insurer behaviour has 
not emerged as an issue.
Additional measures have been 
taken to de-risk assumptions by 
securing additional contractual 
guarantees from key partners.

38 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Description

Category

Transformation

Delivery of key strategic 
projects
The Group has several key 
strategic projects ongoing and 
a delay or failure to deliver any 
of these could have a material 
impact on its financial plan.

Risk
Appetite

Balanced
(9/12)

Regulatory

Cautious
(4/12)

Regulatory Breaches
The Consumer Legal Services 
division operates in a highly 
regulated environment 
and handles high volumes 
of sensitive customer 
data including credit card 
information and medical data. 
The division also handles client 
money. The Group’s law firms 
are regulated by the Solicitors 
Regulation Authority. Breaches 
of regulations could result in 
regulatory action against those 
businesses, directors and 
compliance officers.
Critical care is audited by the 
CQC and any failings could 
create reputational damage and 
loss of customers.

Mitigation

The Group delivered its new 
small claims proposition in May 
2021 and is building its capacity 
to service higher value claims. 
Oversight of strategic projects 
is provided by the Executive 
Director and the Board. 
Dedicated project management 
resource is in place to support 
delivery with a strong focus 
from the management teams. 
Progress is in line with plan on 
all of the Group’s key strategic 
projects.

Both divisions employ 
dedicated compliance 
resources responsible for 
managing compliance issues 
and reporting directly to the 
Board.
External legal advice is taken, 
including from leading counsel 
where appropriate. Advice is 
taken where new regulatory 
risks arise from changes to 
internal processes/structure or 
new legalisation/regulation.

NAHL Group Plc Annual Report and Accounts 2021 

39

Strategic report

Description

Critical Care self-employed 
associate model
New IR35 legislation requires 
careful interpretation to ensure 
arrangements do not breach tax 
laws, resulting in unexpected 
tax charges and fines. Loss of 
key self-employed associates 
and caseloads could create a 
revenue impact if associates are 
not replaced. A consequence 
of this could be disruption to 
the self-employed model, a 
lack of associates willing to 
provide specialist services 
and potentially lost revenues if 
services provided by associates 
cannot be replaced.

Key Person Dependency and 
Recruitment
Unavailability or loss of 
key individuals could have 
a detrimental impact on 
business performance. 
Significant intellectual property, 
relationships and experience 
is held by certain members of 
management. If they became 
unavailable there could 
be a short-term impact on 
operational performance and 
the progress of key projects. To 
support its growth agenda, the 
Group is required to develop its 
remote working model.

Category

Financial

Risk
Appetite

Balanced
(7/12)

People and 
Culture

Balanced
(8/12)

Mitigation

The Critical Care division has 
appointed a Chief Medical 
Officer to sit on its clinical 
governance board and provide 
oversight.
To comply with IR35 rules, 
the Board has taken external 
advice from a leading 
accountancy and tax firm 
and made the necessary 
status determinations 
for each associate. These 
determinations are supported 
by contractual terms, 
operational processes and 
working practices currently 
in place. Bush & Co regularly 
monitors compliance with these 
processes and has controls in 
place to ensure the risk of a 
breach of the legislation is low.

There is a succession plan 
in place covering all key 
individuals and no one person 
is responsible for any key 
relationship. Bonus schemes 
and share options are put in 
place to support retention 
of key employees and are 
regularly reviewed by the 
Remuneration Committee.

40 

NAHL Group Plc Annual Report and Accounts 2021

Category

Financial

Risk
Appetite

Balanced
(7/12)

Mitigation

The Board closely monitors the 
use of capital and uses short 
and medium-term forecasts to 
plan future requirements.
Compliance with the debt 
covenants is reviewed on a 
monthly basis by the Executive 
Director and reported to the 
Board. 
The Board have suspended 
dividend payments in order to 
reduce debt and thereby reduce 
this risk. Decisions around 
future dividends will be made 
with consideration of future 
capital requirements.

Strategic report

Description

Working capital management 
and funding
The Group is investing in 
working capital as it builds its 
book of personal injury claims 
in National Accident Law. These 
claims can take up to two – 
three years to process and it is 
at the settlement point of each 
successful claim that cash is 
received.
This is against the backdrop of 
reduced revenues and ongoing 
uncertainty (particularly case 
volumes), resulting from the 
COVID-19 pandemic.
 The Group has successfully 
extended its banking facility to 
the end of 2024. The agreement 
includes a range of covenants 
which must be complied with. 
These have been re-set and 
are aligned with our strategy 
to grow NAL as set out in our 
medium-term forecasts. If 
performance falls outside of 
expectations the Group could 
be required to depart from its 
growth strategy in order to 
meet covenant requirements 
(e.g. by increasing placement to 
the panel).

NAHL Group Plc Annual Report and Accounts 2021 

41

Strategic report

Description

IT Infrastructure and Security
Many of the Group’s 
interactions with its customers 
are online and systems are 
increasingly automated 
creating an increased exposure 
to systems error. We are reliant 
on our IT systems to capture 
and protect valuable customer 
data obtained in the normal 
course of business. Theft, loss 
and misappropriation of digital 
assets and data could result 
in reputational damage and/
or regulatory fines. The Group 
relies on a number of key IT 
suppliers and its systems 
are increasingly automated, 
creating an increased exposure 
to systems error.

Category

Regulatory

Risk
Appetite

Cautious 
(5/12)

Mitigation

The Group takes data security 
very seriously. The Board 
has undertaken a review of 
processes and controls relating 
to cyber security during 
2021 – including testing by 
independent IT specialists.
The Group has robust policies 
and procedures to ensure it 
is compliant with the Data 
Protection Act 2018 and 
the General Data Protection 
Regulations (GDPR).
Business Continuity plans are 
in place, the Group’s employees 
are provided with regular 
training and the cyber security 
controls are regularly stress 
tested.

42 

NAHL Group Plc Annual Report and Accounts 2021

Our sustainable culture

NAHL Group Plc Annual Report and Accounts 2021 

43

Strategic report

Our
sustainable
culture

Our Culture is underpinned by our Values:

Passionate
about the business, what we do and why 
we do it and each employee’s own role 
within this

Driven
to deliver operational and financial 
performance and provide outstanding 
levels of service for our customers

Unified
to work together to do the best job 
possible and engage with our partners 
and suppliers

?

Curious
about how we can work effectively, make 
improvements and do things differently 
to create the best environment for our 
people and the best experience for our 
customers

The Group is aware of its responsibilities towards 
its stakeholders and its values underpin its 
approach towards stakeholder relationships. 
The Group has identified its key stakeholders as:

•  Our People

•  Our Customers

•  Our Suppliers

•  Our Investors

•  Our Communities

•  The Environment

44 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Our People 
Collaboration 
With the UK entering its third lockdown in January 
2021, the significant adjustments made to our 
ways of working at the beginning of the COVID-19 
pandemic and throughout 2020 remained in place 
throughout much of 2021. 

As restrictions continued to be lifted, we talked to 
our teams about their preferences around hybrid 
working, and cautiously planned a managed return 
to the office. No blanket rule was imposed, with a 
preference instead for collaboration. 

Presence in the office was decided on a team-by-
team basis, based on colleagues’ preferences and 
the business’ needs. Our continued priorities were 
the health, safety and wellbeing of our people, 
and our service and support for our customers 
and business partners, ensuring we adhered to 
Government guidance at the time around face 
coverings and social distancing.

Communication and 
Wellbeing
During the third national lockdown, there was a 
recognition that our people had been remote from 
their line managers and colleagues for some time. 
We focused our communications and engagement 
on connection, encouraging colleagues to replicate 
the spirit of our physical workplace virtually.

Colleagues were encouraged to engage with one 
another and the business to combat isolation and 
loneliness. Teams connected daily to ‘check in’ on 
both a personal and professional level and open 
screen working was encouraged as a substitute for 
the physical office environment. Meeting structures 
were revised to a 50 minute on/10 minute off 
model, to prevent burnout from back-to-back calls.

Mindfulness sessions also equipped our people 
with techniques for coping with loneliness and 
focusing on the positive throughout challenging 
times.

Engagement
The Group is committed to open and transparent 
communication with its staff with engagement 
remaining a primary focus for the Leadership 
teams. The Board engages with employees 
through:

•  Virtual business updates through the delivery 
of quarterly all-staff meetings where strategic 
and performance updates are delivered 
by the Executive Director and the senior 
management team, and two-way communication 
is encouraged. As physical gatherings were 
permitted, our Divisional “Communicake” 
sessions were launched in the office to 
encourage interaction between team members. 
As the name suggests, these sessions combined 
an opportunity for management to communicate 
its plans for the business and for teams to share 
updates with a chance to spend time together 
over tea and cake.

•  In addition to gathering feedback throughout 
the year through regular meetings, the Group 
also encourages employees to share their views 
via its annual staff survey. The People Director 
feeds back the results of this survey to the Board 
and the employee group are encouraged to take 
ownership of these results through identifying 
three actions to be taken by the management 
body and three actions to be taken by the 
employee body in order to encourage positive 
change.

Despite the challenges of the continuing pandemic 
we were very pleased with the results of our staff 
survey, which showed that engagement levels 
remained high at 75% for the year against a UK 
Gallup average of 11%. 

Training and development
Following the move to remote working in early 
2020, managers received support on how 
to manage their teams in a home working 
environment with our “Pokerface” for managers 
training. This was extended in 2021, with managers 
receiving support on how to reconnect their teams 
with one another while still working remotely. This 
was achieved through training around checking in 
with one another, running better team meetings 
and giving recognition to team members.

NAHL Group Plc Annual Report and Accounts 2021 

45

Case study

Our Totem engagement app
Working from home reduced the opportunity 
for informal interaction between colleagues and 
our communications needed to be adapted to 
bridge this gap. To address this, we launched 
a new mobile-first communications platform 
called Totem, in May 2021.  The app places equal 
emphasis on celebrating both the personal and 
professional news and achievements of our people. 

Colleagues can celebrate the achievements of 
others by offering Kudos to them publicly and 
are encouraged to share posts about their work 
or home life on separate streams. Employee 
engagement with the platform has surpassed 
expectations and Totem has successfully 
harnessed the sense of community across the 
Group in a digital form.

46 
46 

NAHL Group Plc Annual Report and Accounts 2021 
NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Following the success of “Pokerface” for managers, 
a similar course for all employees was rolled out 
across the Group within just two months to help 
our people to work through the continuing impact 
of the pandemic. Course content focused on 
understanding how the situation had impacted 
peoples’ mental health and emphasising the 
importance of connection with others.

The Group also extended its on-the-job training by 
enrolling four employees on new apprenticeship 
schemes during the year. At the end of 2021, 
the Group had ten apprentices throughout the 
organisation in a range of roles.

Equal Opportunities and 
Diversity
Diversity and inclusion were a focus across the 
business in 2021, with managers undertaking a 
specially tailored diversity and inclusion training 
programme. As part of this, all colleagues were 
invited to share and discuss their views on this 
area in forums and through a feedback survey. Our 
people told us that they believe our culture is one 
of acceptance, with 91% agreeing in our annual 
staff survey that everyone within the Group is 
treated fairly, regardless of race, gender, ethnicity, 
disability, sexual orientation or other differences.

As a result of this training the following actions 
were implemented:

•  An increased focus on gender pay gap with 

reporting being undertaken annually and shared 
with a group of senior colleagues to review and 
challenge the results. 

•  Raising awareness with senior leaders of the 
actions they can take in order to promote 
diversity and inclusion. 

•  Ensuring the annual staff survey included 

questions around diversity, so that this remains 
an area of focus and allows our people to share 
their thoughts on this important area. 

Our customers
The Group’s customers fall into two distinct 
categories covering both business-to-business and 
business-to-consumer sectors and the Group is 
committed to servicing them both effectively. 

Our business-to-business customers are 
supported by dedicated partnership and business 
development teams who work to ensure that all 
parties are satisfied with the management of the 
relationship and its results. 

Our business-to-consumer customers benefit 
from the empathic expertise of our teams of highly 
trained employees. National Accident Helpline 
remains one of the most trusted brands in our 
market reflecting the ethos of our customer-
first approach. The Group further invests in its 
technologies with a view to ensuring that this 
customer base has a market-leading consumer 
experience. Customers can start a claim using our 
online sign-up tools and manage an ongoing claim 
through our dedicated web-based ‘My Account’ 
portal, allowing claimants to access and provide 
information at their convenience.

Our suppliers
The Group works with a number of key suppliers, 
primarily providers of marketing support services, 
technology providers, self-employed associates 
and search agents and surveyors. Again, each 
division has dedicated marketing and operations 
teams who work closely with these suppliers to 
ensure the successful delivery of these services for 
both parties. Throughout 2020 and 2021 the Group 
has ensured that its payment terms with suppliers 
have been adhered to in order to support our 
supply chain with its cash flow needs throughout 
the pandemic. It has also put in place measures to 
support the health and safety of its self-employed 
associates by supporting them with remote 
working requirements. 

47 

NAHL Group Plc Annual Report and Accounts 2021

Strategic report

Our investors
The Group aims to maintain an ongoing dialogue 
with shareholders throughout the year, to manage 
their expectations and understand the motivation 
behind shareholder voting decisions. Our Investors 
section of our website (www.nahlgroupplc.co.uk/
investors) explains how we have sought to do 
this, including:

•  Engaging with investors through our Annual 

General Meeting.

•  Meeting larger shareholders during twice-yearly 
roadshows following the announcement of the 
full year and interim results. 

•  Meeting with retail shareholders using the 

InvestorMeetCompany platform for the first time 
in 2021, enabling us to host a live Q&A session 
and engage with a wider audience. 

•  The Chair is available to meet investors as required. 

The Board seeks to manage investor expectations 
whilst striving to make the right decisions as it 
navigates the ever-changing markets in which 
it operates; aiming to strike a balance between 
long-term shareholder value and short-term 
business needs.

I believe the company cares 
about me and supports me 
both professionally and 
personally. I am trusted which 
means a lot to me and I am 
empowered to do my job, 
come up with ideas and to 
make things happen.

The Environment
NAHL Group plc is conscious of its environmental 
impact and the need for all businesses to play their 
part in minimising their impact on the environment 
and creating sustainable business practices. 
With this in mind, the following directives were 
undertaken during the year:

•  As of February 2021, the Group’s head office at 
Bevan House in Kettering made the switch to 
100% renewable green energy. 

•  The Group continues to make use of remote 
working and endeavours to strike a balance 
between our people’s wellbeing and the need for 
face-to-face meetings/interactions, whilst also 
considering how we can limit the environmental 
impact of our people travelling long distances. 
A hybrid working arrangement was put in place 
during the year which continues to utilise online 
meeting spaces and minimises our people’s 
commute, and so limits the impact of car and 
train travel on the environment.

•  Customers of National Accident Law are given 

the choice as to whether communications 
are sent by paper or they can choose to go 
completely paperless and help us to reduce our 
impact on the environment.

•  As part of the Consumer Legal Services Division’s 

‘Grow 25’ strategy, the Group partnered with 
a company to plant trees in Madagascar. 
For every employee and new starter, the Group is 
funding the planting of one new tree and as at 31 
December we had funded the planting of  
172 trees. 

NAHL are conscious that environmental and social 
reporting is an area that is drawing increased focus. 
Management are currently undertaking a review of 
its approach to ESG reporting with reference to the 
Taskforce for Climate-related Financial Disclosures 
(TCFD) framework. Management are preparing 
an action plan to be presented to the Board for 
approval in H1 2022 and will report on the progress 
of this in the 2022 Annual Report. 

48 

NAHL Group Plc Annual Report and Accounts 2021 

I am so thankful I work for 
such a supportive company 
with managers who really 
care. 

Strategic report

Our Communities
The Group is committed to engaging and 
supporting its communities:

•  Since 2018, Bush & Co has partnered with 

Paradance UK as its corporate charity partner. 
Not only does this give us the opportunity to 
fundraise and help spread the word about 
Paradance but the ethos of the Charity (everyone 
can dance) aligns to the way Bush works with its 
clients and how we encourage them to achieve 
their goals, regain independence and have hope 
for the future. 

•  We believe it’s crucial for the legal sector to 
evolve and in a way that inspires the next 
generation to build their careers in law. We 
have been running Future Legal Mind, our 
annual search to find the shining legal stars of 
tomorrow, since 2015 and prizes include £1,500 
towards our winner’s studies, the chance to 
take part in mentoring with experienced lawyers 
and complete a work experience placement at 
National Accident Law.

•  Our employees also engage in community 

projects such as supporting their local food 
banks and each employee is entitled to one 
paid day each year where they can take the 
day to volunteer for a cause that is special and 
meaningful to them. 

The culture that has been 
built and even maintained 
throughout lockdown is 
second to none. 

49 

NAHL Group Plc Annual Report and Accounts 2021

Section 172 Statement

50 

NAHL Group Plc Annual Report and Accounts 2021

Section 172 Statement

Strategic report

Section 172 Statement 
and stakeholder engagement

Section 172 of the Companies Act 2006 requires 
a director of a company to act in the way he or 
she considers, in good faith, would be most likely 
to promote the success of the company for the 
benefit of its members as a whole. In doing this, 
Section 172 requires a Director to have regard, 
among other matters, to:

•  the likely consequences of any decision in the 

long-term;

•  the interests of the company’s employees;

•  the need to foster the company’s business 
relationships with suppliers, customers and 
others;

•  the impact of the company’s operations on the 

community and the environment;

•  the desirability of the company maintaining 
a reputation for high standards of business 
conduct; and

•  the need to act fairly with members of the 

company.

The likely consequences 
of any decision in the long-
term
The key decisions made by the Board during the 
year were:

•  Focussing the placement of enquiries in personal 
injury to align to our strategic goals and drive 
longer-term growth. We increased our placement 
of enquiries into our wholly owned law firm, 
National Accident Law (NAL) by 130%. From 
May 2021 all RTA claims were processed through 
NAL, allowing us to process these efficiently 
and effectively. The volume of NRTA claims was 
increased later in the year allowing us to generate 
greater returns from each of these claims in 
future years (see page 10 for further details). 

•  In May 2021, after significant strides to reposition 
and streamline the operations of the Residential 
Property business were implemented, the 
decision was made to look into a potential 
disposal of the business. This supported the 
Group’s long-term strategic plans to turn its 
focus to building value in its PersonaI Injury 
business, and was considered the best course 

of action to realise immediate value from the 
Residential Property business. Whilst this initially 
attracted encouraging levels of interest, it proved 
very difficult to complete a deal due to external 
factors beyond our control. Whilst we are not 
in negotiations with a buyer at present, we will 
continue to explore our options for this business 
in 2022.

•  The Board re-financed its Revolving Credit 

Facility in December 2021, extending the term 
from December 2022 to December 2024 and 
in doing so giving the Group greater stability 
and providing our business with the liquidity to 
continue to grow NAL. As part of this, the limit 
on the facility has been reduced from £25.0m 
to £20.0m to appropriately reflect the Group’s 
medium-term plans.

The Directors give careful consideration to the 
factors set out above in discharging their duties 
under Section 172. Further detail on the long-
term strategy and the Board’s decision-making 
driving this can be found in the CEO’s Report on 
page 8. Our trusted brands (CEO’s report page 
10), Industry awards (CEO’s report page 12) and 
Investors in People (CEO’s report page 13) are all 
testament to how the business strives to maintain 
its reputation for high standards of business 
conduct. The Board sees the value of building 
and maintaining strong relationships with its key 
stakeholders, who are identified on page 44. 

The interests of the 
Company’s employees
As a service provider, the Group recognises the 
importance of its people and the business is 
committed to open and transparent communication 
with its staff, with engagement remaining a primary 
focus for the leadership teams. The Board engages 
with employees through a dedicated People 
Director who is supported in this role by the CEO 
and acting CFO, and who provides regular updates 
on people matters to the Board. Details on how 
management have engaged with employees during 
the year is given on Page 45. 

The Group undertakes an annual pay review taking 
into account market benchmarks. A 2% increase in 
pay was awarded to our employees in June 2021. 
Pay increases above this 2% are considered on 

NAHL Group Plc Annual Report and Accounts 2021 

51

Strategic report

an individual basis and take into account personal 
performance, training and responsibility advances 
and skill/knowledge. The Group also undertakes a 
gender pay gap analysis annually. 

The Group adopts a collaborative approach to 
working conditions and this is led by the People 
Director through staff surveys that touch on areas 
such as relationships with management, work 
life balance and progression opportunities. The 
Group works to take into account these comments 
by adopting actions from the views coming out 
of these surveys. Significant actions taken in the 
current year include the implementation of a 
flexible work from home policy and more activities 
to encourage wellbeing and face to face interaction 
through the introduction of its ‘Communicake’ staff 
meetings. 

The need to foster the 
Company’s business 
relationships with 
suppliers, customers and 
others
The Board appreciates that in order to deliver 
on its strategy, it needs to ensure effective 
collaboration with its key stakeholders. These 
include its suppliers, customers, bankers and 
investors. Details on how the Board seeks to 
foster relationships with suppliers, customers 
and investors is given on page 47–48. The Board 
ensures it keeps in regular contact with its 
bankers and the CEO and acting CFO have regular 
communication with Yorkshire Bank’s relationship 
manager. 

The impact of the 
Company’s operations on 
the community and the 
environment
The Board are aware that the activities of the 
Group and the impact of these activities has a far-
reaching impact and are mindful to take actions to 
limit the Group’s impact on the environment and to 
make a positive impact on its communities. Details 
on how it does this can be found on page 48. 

The desirability of the 
Company maintaining 
a reputation for high 
standards of business 
conduct
The Board believes that its success lies with its 
people and ensuring we have a strong leadership 
team that provides exceptional oversight and 
governance that aligns to our values is key to 
this. Details of the Board and Senior Leadership 
team can be found on pages 54–57 and details 
of how the Board has complied with the QCA 
Corporate Governance Code (its chosen corporate 
governance framework) can be found on pages 62.

The Group is subject to regulation from a 
number of sources and has a dedicated legal 
and compliance team that ensures business is 
conducted in line with these regulations. Further 
details can be found in the principal risks and 
uncertainties report on page 35–42. 

The need to act fairly with 
members of the Company
The Board seeks to balance its long-term strategy 
with shareholder needs. An example of this 
during the year was the decision to look into the 
disposal of the Residential Property business, as 
it was felt that increased value would be created 
for shareholders through disposal rather than 
retention. The Board seeks to maintain regular 
dialogue with shareholders throughout the year as 
detailed on page 58. 

The strategic report on pages 6–52 was approved 
by the Board on 28 March 2022 and signed on its 
behalf by:

Tim Aspinall
Chair

52 

NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

NAHL Group Plc Annual Report and Accounts 2021 

53

Leadership and Governance

Board 
of Directors

Tim Aspinall
Non-Executive Chair

Tim Aspinall became Chair in 
October 2020, having been a 
Non-Executive Director since 
June 2016. He sits on the Group’s 

Remuneration and Nomination Committees and 
attends the Audit and Risk Committee by invitation. 

Tim runs Aspinall Consultants Limited, a 
management consultancy business advising 
professional services firms on strategy, 
performance management and mergers and 
acquisitions. 

Tim is also a Non-Executive Director of Kuro Health 
Limited which is one of the leading providers 
of medical reports in the UK. Tim is a qualified 
solicitor and his senior leadership career in the 
legal sector includes Managing Partner of DMH 
Stallard LLP where he led its transformation into 
an award winning and highly respected mid-market 
law firm.

Gillian Kent
Non-Executive Director

Gillian Kent became Non-
Executive Director in November 
2014 and is Chair of the Group’s 
Remuneration Committee and 

Nomination Committee. She also sits on the Audit 
and Risk Committee.

Gillian is also an independent Non-Executive 
Director at Ascential plc, Mothercare plc, SIG plc 
and Marlowe plc. Her executive career in the digital 
and online sectors includes Managing Director 
of Microsoft’s largest online business in the UK. 
Gillian has also served as Chief Executive Officer 
and Digital Consultant at GK Associates, Chief 
Executive Officer at Propertyfinder.com, Marketing 
Director and Director of Strategy and Business 
Development at Microsoft (MSN).

James Saralis
Chief Executive Officer

James Saralis is Chief Executive 
Officer of the Group, which he 
joined in January 2018.

As Chief Executive Officer, James’ responsibilities 
include managing the day-to-day operations of 
the business, developing and implementing the 
Group’s strategy, ensuring delivery of budgeted 
financial performance and promoting the values of 
the Group.

Between 1 January 2018 and 16 August 2021, 
James served in the role of Group Chief Financial 
Officer and was instrumental in the strategic and 
operational development of NAHL, playing a key 
role in navigating the challenges presented by 
the coronavirus pandemic and in transforming 
the Personal Injury business into a modern, 
technologically-enabled law firm.

James has a wealth of experience both 
operationally and of the AIM market. Previously, 
he spent over 10 years in the general insurance 
industry, including as CFO of the Direct & 
Partnerships and Employee Benefits divisions of 
Jelf, part of Marsh & McLennan Companies. James 
has also held various finance roles in Clearspeed 
Technology plc, HBOS plc and RAC plc. He is a 
Chartered Accountant and fellow of the ICAEW, 
having been a member since 2003. He holds a 
Bachelor of Science from the University of Bristol.

54 

NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Sally Tilleray
Non-Executive Director

Sally joined the board on 19 July 
2019 and is Chair of the Group’s 
Audit and Risk Committee, as well 
as sitting on the Remuneration 

and Nominations Committees.

Sally founded her own consulting business and is 
currently Chair of Cognito Media, an integrated 
communications consulting firm and Chair of 
UNRVLD, a digital experience agency. She is Senior 
Independent Director of Mind Gym plc, the AIM 
quoted behavioural science training and business 
improvement group and Non-Executive Director 
of AIM quoted Skillcast plc, the leading provider of 
corporate compliance e-learning in the UK.

In her executive career, Sally was previously 
Group Chief Operating Officer and Group Chief 
Financial Officer at Huntsworth plc, the fully listed 
international healthcare and communications 
firm, where she was responsible for the Group’s 
worldwide financial functions and day to day 
operations. Prior to this, she served as CFO 
Europe for Predictive Inc., a technology consulting 
business which listed on Nasdaq in 2000. She is a 
member of the Chartered Institute of Management 
Accountants.

Brian Phillips
Non-Executive Director

Brian joined the Board on 25 June 
2020 as a Non-Executive Director.

He has had a long and 

distinguished career in private equity and in 2014 
stepped back from full time employment to build a 
portfolio of investments using his own capital. He 
later used this experience and extensive contacts in 
the field to start Ethos Partners LLP in 2017, which 
is a private investment office operating in the UK 
small cap and private equity market.

During his executive career, Brian was previously 
the Chief Investment Officer for Greenhill Capital 
Partners in London where he was recruited to set 
up a new private equity business for Greenhill & 
Co., a listed US investment bank. Previous to this 
he was Managing Director for L&G Ventures and a 
Director at various firms including Bridgepoint and 
Gartmore Private Capital.

Brian is a Chartered Accountant and member of 
the Institute of Chartered Accountants of Scotland.

NAHL Group Plc Annual Report and Accounts 2021 

55

Leadership and Governance

Executive 
management team

Chris Higham
Acting Chief Financial Officer

Chris Higham is Acting Chief 
Financial Officer of the Group, 
which he joined in 2006.

As acting Group Chief Financial Officer, Chris’ 
responsibilities include management of the finance 
function and liaising with the Group’s investors and 
the banks. Chris has an in-depth understanding of 
the Group’s operations, having helped implement 
the Personal Injury business’ transformation and 
developed the finance function during a period 
of significant change. Chris is a member of the 
Group’s Executive Leadership Team.

Chris joined the Group in 2006 as the Financial 
Controller of National Accident Helpline Limited. 
He has worked in numerous roles at NAHL, 
including CFO of the Personal Injury business, 
Commercial Director at Homeward Legal Limited 
and most recently Group Finance Director.

Chris is a fellow of the Association of Chartered 
Certified Accountants (ACCA) and prior to joining 
NAHL he spent 5 years at Thomson Reuters.

Will Herbertson
Managing Director, Consumer 
Legal Services

Will was appointed to the role of 
Managing Director of the Group’s 
Consumer Legal Services division 

in September 2021, having joined the Group in 
2018. He previously held the roles of Director of 
Marketing and Strategy and Managing Director of 
the Residential Property businesses, both also in 
Consumer Legal Services. 

In his current role, Will is responsible for the 
strategy, leadership and operations of the division 
which includes National Accident Law, the National 
Accident Helpline brand, Searches UK and 
Homeward Legal.

Will brings extensive commercial, marketing and 
digital experience to the Group. Prior to joining 
the Group, Will was a Commercial Director at 
MoneySupermarket and held UK and International 
sales and marketing positions with Proctor & 
Gamble, where he started his career.

Helen Jackson
Managing Director, Critical Care

Helen was appointed as Managing 
Director of the Group’s Critical 
Care division in July 2016 having 
spent four years as Group  
HR Director.

Responsible for the strategy and leadership within 
the division as well as business development, 
quality and clinical independence, Helen has 
driven a number of business improvements. 
Helen led Bush in launching two industry leading 
partnerships with the Spinal Injuries Association 
and Child Brain Injury Trust. These are both 
prominent charities in the sector, reinforcing 
the company’s market positioning as the leader 
in catastrophic injury in case management and 
building on Bush’s 30 years of success within the 
critical care sector.

Previously, Helen held HR leadership roles at 
Everest, BUPA and Tesco.

56 

NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Marcus Lamont
Group People Director

Marcus joined as Group People 
Director in July 2016.

During his time with the Group, 

Marcus has delivered improvements to talent 
development, embedded the Group’s culture and 
Values and enhanced recruitment processes, with 
significant focus on an aligned approach across 
all divisions. Passionate about staff engagement 
and recognition, Marcus was instrumental in the 
Group achieving the Gold Standard from Investors 
in People for the Personal Injury business and 
Critical Care, as well as ensuring its inclusion in The 
Sunday Times Top 100 Best Small Companies to 
Work For.

Marcus joined from Everest where he was HR 
Director and prior to that he held senior positions 
at UPS plc, across the globe.

Jonathan White
Group Legal & Compliance 
Director

Jonathan was appointed 
Group Legal & Compliance 
Director in 2020, 

having joined the Group in 2010. 

During this time he has supported NAHL in 
navigating through a decade of regulatory 
change and was heavily involved in the successful 
floatation on AIM, and the subsequent creation 
of National Accident Law in 2019. Jonathan was 
appointed to support the Government’s insurance 
fraud task force and the FCA’s claims management 
consultive group and has worked extensively with 
Government departments and regulators to tackle 
cold calling and unethical marketing. More recently, 
he has supported ACSO on a range of initiatives 
including cross sector COVID-19 protocols and 
fraud prevention. 

Jonathan is an experienced solicitor with over 20 
years’ experience in personal injury, commercial 
and regulatory law.

NAHL Group Plc Annual Report and Accounts 2021 

57

Leadership and Governance

Chair’s 
Introduction to 
Governance

Dear Shareholder,

On behalf of the Board, I am pleased to introduce 
our Corporate Governance Statement for the 
year ended 31 December 2021. The purpose of 
this section of the Annual Report is to set out our 
commitment to good corporate governance, which 
should be read in conjunction with our website 
which provides further detail.

The Board is ultimately responsible for corporate 
governance, which is the way in which companies 
are directed and controlled. We believe that good 
corporate governance is vital to support long- 
term growth in shareholder value. To achieve 
this, companies require an efficient, effective 
and dynamic management framework that is 
accompanied by clear communication, promoting 
confidence and trust.

Compliance with the  
QCA Corporate 
Governance Code
Companies listed on AIM are required to adopt 
a recognised corporate governance code. The 
Board has adopted the Quoted Companies Alliance 
(QCA) Corporate Governance Code. We believe 
that the QCA code is a pragmatic, principles-
based tool that enhances the Group’s ability to 
explain its approach to corporate governance. It 
is appropriate for the needs and circumstances of 
small and mid-sized quoted companies on a public 
market.

It is based around a set of ten principles to which 
the Group must either comply or explain why it has 
chosen not to. The ten principles of the code are 
set out in the table on page 62 and I can confirm 
that we are in compliance with the requirements 
of the code and the table provides signposts to the 
relevant disclosures and explanations.

Shareholder engagement
An important part of the QCA code concerns 
engagement and communication with our 
shareholders. We welcome open and regular 
dialogue with our shareholders and the Our 
Investors section of our website explains how we 
have sought to do this.

In 2021, due to the ongoing restrictions put in 
place by the UK Government to limit the spread 
of COVID-19, we were forced to hold our Annual 
General Meeting as a closed meeting with the 
minimum number of shareholders present to form 
a quorum. Despite this, we sought to maintain 
engagement by encouraging shareholders to listen 
to the meeting via conference call and submit 
questions, which were answered by the Directors 
during the meeting.

It is our intention that this year we will be able to 
return to a face-to-face AGM and I would like to 
extend an invitation to all shareholders to attend 
our AGM, and to engage with the Board and other 
members of our senior leadership team who will be 
in attendance.

Tim Aspinall
Chair

58 

NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Governance 
Statement

The Board
Board composition
The Board comprises the Non-Executive Chair, 
three independent Non-Executive Directors and 
one Executive Director. Their biographies can be 
found on pages 54–55.

There is a clear separation of the roles of Non- 
Executive Chair and Executive Director. The Chair, 
Tim Aspinall, is responsible for the running of the 
Board and for ensuring that all Directors are fully 
informed of matters sufficient to make informed 
judgements. As Executive Director and CEO, 
James Saralis has responsibility for implementing 
the strategy agreed by the Board and managing 
the day-to-day operations of the Group. He is 
supported in this role by other senior leaders in the 
Group including the acting Chief Financial Officer.

James Saralis stepped down as Company 
Secretary during the year and was replaced in this 
role by Kirstie Cove, a senior member of the finance 
team. The Secretary supports the Board with 
compliance and governance matters and reports 
directly to the Chair on governance matters.

The Board has determined that the Non-Executive 
Directors are independent, experienced and 
influential individuals with complementary skill 
sets. There is currently no Senior Independent 
Non-Executive Director. The Board believes this 
is appropriate given the size of the Board and will 
continue to review this practice as part of its Board 
effectiveness reviews.

Members of the Board maintain membership of 
a number of professional bodies and ensure their 
skill sets are constantly developed. As part of 
our ongoing commitment to staff development, 
Executive Directors and senior leaders have 
personal development programmes which include 

mentoring and attendance at high level leadership 
programmes. In addition, they receive individual 
support for specific and identified development 
needs to ensure they are kept up to date on 
relevant legal developments or changes in best 
practice.

The Nomination Committee is responsible 
for considering the make-up of the Board and 
identifies any succession planning requirements.

No individual or group dominates the Board’s 
decision-making processes.

The Role of the Board
The Board sets the strategic aims of the Group 
and its values, provides the leadership required to 
put them into effect, supervises and constructively 
challenges management who are responsible for 
the day-to-day running of the Group, and reports 
to shareholders on their stewardship. The Board is 
also responsible for risk management, and we have 
set out our approach to this in the Principal Risks 
and Uncertainties section of the Annual Report on 
page 35–42.

Meetings were attended virtually in the first half 
of the year and in person once the COVID-19 
restrictions began to ease from July 2021. 

The Board met six times during 2021 and the 
meetings last for approximately half a day. In 
addition to this, all Directors attend the Group’s 
Annual General Meeting. Additional meetings 
or conference calls are convened as required. 
Members of the Board also chair and sit on the 
Board committees and these each have their own 
time commitments.

The following table shows the Directors’ 
attendance at Board and Committee meetings 
during the year:

Tim Aspinall

James Saralis

Gillian Kent

Sally Tilleray

Brian Phillips

Board

Audit Remuneration

Nomination

6/6

6/6

6/6

6/6

6/6

N/A

N/A

4/4

4/4

4/4

4/4

N/A

4/4

4/4

4/4

2/2

N/A

2/2

2/2

2/2

NAHL Group Plc Annual Report and Accounts 2021 

59

Leadership and Governance

Board effectiveness
The Chair annually reviews the contributions 
of Board members, with a focus on ensuring 
effectiveness and relevance. The Board periodically 
reviews its effectiveness and performance as a 
unit to ensure that it is operating collectively in an 
efficient, informed, productive and open manner.

The Board undertook an evaluation of its 
effectiveness in 2021 which was supervised by the 
Company Secretary. The approach taken was to 
issue a questionnaire, covering topics including 
Board composition and governance, Board 
operations, strategy, stakeholder relations and 
the performance of individual Directors and Board 
Committees. This was followed by a discussion 
with the Board and individual conversations 
with the Chair. The Chair concluded that the 
Board operates effectively and its structures 
and procedures are appropriate for the current 
situation of the Group. 

The Board plans to conduct the next review into 
its effectiveness in the second half of 2023. The 
results of this review will be presented in the 
Group’s financial statements for the financial year 
to 31 December 2023.

Internal control
The Group has implemented policies on internal 
control and corporate governance. These have 
been prepared in order to ensure that:

•  proper business records are maintained and 

reported on, which might reasonably affect the 
conduct of the business;

•  monitoring procedures for the performance of 

the Group are presented to the Board at regular 
intervals;

•  budget proposals are submitted to the Board 

no later than one month before the start of each 
financial year;

•  accounting policies and practices suitable for the 
Group’s activities are followed in preparing the 
financial statements;

•  the Group is provided with general accounting, 
administrative and secretarial services as may 
reasonably be required; and

•  interim and annual accounts are prepared and 
submitted in time to enable the Group to meet 
statutory filing deadlines.

The Group continues to review its system of 
internal control to ensure compliance with best 
practice, whilst also having regard to its size and 
the resources available. The Board considers that 
the introduction of an internal audit function is not 
appropriate at this juncture, although the Group 
finance team has implemented a series of internal 
control reviews and reports the outcomes of these 
to the Audit and Risk Committee.

60 

NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Board committees
To assist in carrying out its duties the Board has 
set up a number of committees, including the Audit 
and Risk Committee, the Remuneration Committee 
and the Nomination Committee. Each committee 
has formally delegated duties and responsibilities 
with written terms of reference. From time-to-time 
separate committees may be set up by the Board 
to consider specific issues when the need arises. An 
explanation of the responsibilities and composition 
of the committees is set out below and the terms of 
reference can be downloaded from our website.

Audit and Risk Committee
The Audit and Risk Committee consists of: 

Sally Tilleray (Chair)

Gillian Kent 

Brian Phillips

The Audit and Risk Committee is expected to meet 
formally at least three times a year and otherwise 
as required. It has responsibility for ensuring that 
the financial performance of the Group is properly 
reported on and reviewed, and its role includes 
monitoring the integrity of the financial statements 
of the Group (including annual and interim 
accounts and results announcements), reviewing 
internal control and risk management systems, 
reviewing any changes to accounting policies, 
reviewing and monitoring the extent of the non-
audit services undertaken by external auditors and 
advising on the appointment of external auditors.

Remuneration Committee
The Remuneration Committee consists of: 

Gillian Kent (Chair)

Tim Aspinall 

Sally Tilleray 

Brian Phillips

The Remuneration Committee is expected to 
meet not less than twice a year and at such other 
times as required. The Remuneration Committee 
has responsibility for determining, within the 
agreed terms of reference, the Group’s policy on 
the remuneration packages of the Company’s 
Chair, the Executive and Non-Executive Directors, 

the Company Secretary and other senior 
executives. The Remuneration Committee also has 
responsibility for:

•  determining the total individual remuneration 

package of the Chair and each Executive Director 
(including bonuses, incentive payments and 
share options or other share awards); and

•  determining the total individual remuneration 

package of the Company Secretary and all other 
senior executives (including bonuses, incentive 
payments and share options or other share 
awards), in each case within the terms of the 
Group’s policy and in consultation with the Chair 
of the Board and/or the Executive Director.

No director or manager may be involved in any 
discussions as to their own remuneration.

Nomination Committee
The Nomination Committee consists of: 

Gillian Kent (Chair)

Tim Aspinall 

Sally Tilleray 

Brian Phillips

The Nomination Committee is expected to meet 
not less than once a year and at such other times 
as required. It has responsibility for reviewing the 
structure, size and composition (including the 
skills, knowledge and experience) of the Board, and 
giving full consideration to succession planning. 
It also has responsibility for recommending new 
appointments to the Board.

Accountability and 
stakeholders
The Board considers that the 2021 Annual Report 
and Accounts, taken as a whole, is fair, balanced 
and understandable and provides the information 
necessary for shareholders to assess the Company’s 
position and performance, business model and 
strategy. Details of how we do this are also explained 
in the Audit and Risk Committee report.

NAHL Group Plc Annual Report and Accounts 2021 

61

Leadership and Governance

How we have complied with the QCA Corporate 
Governance Code
Deliver Growth

Governance principles

Reference

1.  Establish a strategy and business model which 

promote long-term value for shareholders

See Consumer Legal Services overview (page 
23–24), Critical Care overview (page 25) and 
CEO’s report (page 8–14)

2.  Seek to understand and meet shareholder 

See Chair’s Introduction to Governance (page 58) 

needs and expectations

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

4.  Embed effective risk management, considering 
both opportunities and threats, throughout the 
organisation

Maintain a dynamic management framework

See Our sustainable culture (page 44–49) and 
Section 172 Statement (page 51–52)

See Principal Risks and Uncertainties (page 
35–42)

Governance principles

Reference

5.  Maintain the Board as a well-functioning, 

See Governance Statement (page 59–61)

balanced team led by the Chair

6.  Ensure that between them the directors have 

See Governance Statement (page 59–61)

the necessary up-to-date experience, skills and 
capabilities

7.  Evaluate board performance based on clear 
and relevant objectives, seeking continuous 
improvement

See Governance Statement (page 59–61)

8.  Promote a corporate culture that is based on 

See Our sustainable culture (page 44–49)

ethical values and behaviours

9.  Maintain governance structures and processes 

See Governance Statement (page 59–61)

that are fit for purpose and support good 
decision-making by the Board

Build Trust

Governance principles

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

Reference

See Governance Statement (page 59–61) and 
Section 172 Statement (page 51–52)

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NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Audit 
and Risk 
Committee Report

Dear Shareholder,

I am pleased to present my report of the Audit and 
Risk Committee for the year ended 31 December 
2021.

The composition and responsibilities of the 
Committee are set out on page 61. The Chair, Chief 
Executive Officer, acting Chief Financial Officer, 
Group Financial Controller and external auditors 
attend the Committee by invitation, if required.

The main items of business considered by the 
Committee during the year included:

Re-appointment of 
external auditor
The Committee considers a number of areas when 
reviewing the external auditor appointment, namely 
their performance in discharging the audit, the 
scope of the audit and terms of engagement, their 
independence and objectivity, and remuneration. 
Mazars LLP (Mazars) were first appointed as the 
Group’s external auditor in 2020 and conducted 
the audit of the Group’s financial statements for 
the financial year to 31 December 2020. At the 
Annual General Meeting in June 2021 Mazars were 
re-appointed for 2021. The Committee monitors 
the provision of non-audit services by the external 
auditor. The breakdown of fees between audit 
and non-audit services is provided in note 3 to the 
financial statements. The non-audit fees relate to 
a regulatory audit of compliance with the Solicitors 
Accounting Rules in National Accident Law. 

Following the completion of this year’s audit, the 
Committee has confirmed it is satisfied with the 
independence, objectivity and effectiveness of 
Mazars and has recommended to the Board that 
the auditors be reappointed, and there will be a 
resolution to this effect at the forthcoming Annual 
General Meeting.

External audit process
The external auditor prepared a plan for its audit of 
the full year financial statements, which, this year, 
was presented to the Committee in January 2022.

The audit plan set out the scope of the audit, areas 
of significant risk for the external auditor to focus 
their work on and audit timetable. This plan was 
reviewed and agreed in advance by the Audit and 
Risk Committee.

Following its review, the external auditor presented 
its findings to the Audit and Risk Committee 
for discussion. No major areas of concern were 
highlighted by the external auditor during the year 
however areas of significant risk and other matters 
of audit relevance were discussed.

Presentation of 
Homeward Legal 
As part of the interim results announcement, the 
decision was made to classify the operations of 
Homeward Legal as discontinued/held for sale 
under IFRS 5. This decision was based on the fact 
that the Group had located a potential buyer and 
were in the advanced stages of a due diligence 
process at this point. Subsequently, due to external 
factors beyond the Group’s control, the sale with 
this buyer did not proceed. 

The Committee has considered whether the 
operations of Homeward Legal continue to meet 
the definition as classified as held for sale under 
IFRS 5, in particular whether the sale is highly 
probable. 

The Committee note that it is still the preference of 
the Board to dispose of Homeward Legal and the 
Board will continue to explore its options for this 
division in 2022. However, as the Group has not 
identified a suitable acquirer at present and is not 
in any formal due diligence discussions, then whilst 
possible, it is not considered to be highly probable 
that a sale will take place within the next 12 months. 

The Committee has therefore concluded that 
Homeward Legal should not be classified as 
held for sale as at 31 December 2021 and the 
results should be presented within the continuing 
operations of the Group.

NAHL Group Plc Annual Report and Accounts 2021 

63

Leadership and Governance

Critical accounting 
judgements and key 
sources of estimation 
uncertainty
The critical accounting judgements considered 
by the Committee during the year are set out in 
note 1 to the financial statements on page 95. In 
consideration of these judgements, the Committee 
reviewed the recommendations of the finance 
function and received reports from the external 
auditors on their findings. These judgements 
comprised the following:

•  The decision to consolidate the results and 

net assets of two Limited Liability Partnership 
(LLP) law firms in the financial statements. 
The Committee has exercised judgement by 
considering the criteria for consolidation in IFRS 
10, and has determined that each LLP meets 
the definition of a subsidiary and is therefore 
required to be included within the Group’s 
results. Key to this determination is that the 
Committee considers that Your Law LLP and Law 
Together LLP are controlled through the Group’s 
100% subsidiary, Project Jupiter Limited, who is 
entitled to appoint the majority of members to 
the management boards. Therefore, the Group is 
correct in consolidating these entities within the 
financial statements with a corresponding liability 
recognised for our partner firms’ share of profit.

•  The classification and disclosure of exceptional 

items. In order to provide additional useful 
information for shareholders on underlying 
business trends and core trading performance, 
the Board uses alternative performance 
measures and classifies certain items of 
expenditure as exceptional items. The 
classification of such items involves judgement 
as to what is meant by exceptional and the Board 
has therefore developed an accounting policy for 
such items (see note 1 on page 104). Given that 
this is a presentational judgement which does not 
affect the reported amounts of assets, liabilities, 
income and expenses, the Committee has 
determined that this does not warrant disclosure 
in note 1 as a critical accounting judgement. 
There were no exceptional items incurred in 2021. 

The Committee has also considered the key 
sources of estimation uncertainty set out in note 
1 to the financial statements on page 95, which 
comprises the following:

•  The revenue recognition on provision of legal 
services. The Group recognises revenue in its 
ABS law firms using the expected value method 
provided by IFRS 15 Revenue from Contracts with 
Customers. There is uncertainty in determining 
the transaction price, which is dependent on the 
stage at which a claim settles and the quantum 
of final damages, but management use historical 
experience and average fee history in order to 
calculate an estimated price. The estimate is 
revised as the claim progresses and assumptions 
are updated to reflect actual experience. The 
Committee considers that management adopt 
a conservative approach to recognition as no 
revenue is recognised until liability is admitted 
on a claim and, as a result, there is less risk of 
significant revenue write-offs in future.

•  Recoverability of trade receivables. The Group 

recognises trade receivables and accrued 
income in the financial statements net of an 
estimated provision for impairment losses. This 
has been calculated using an expected credit loss 
methodology, in line with the guidance in IFRS 
9 Financial Instruments, along with individual 
provisions for balances where management has 
specific concerns. The Committee has reviewed 
the basis for the calculation of the provision and 
the underlying assumptions (explained in note 1 
on page 95), and is satisfied that the provision is 
appropriately valued.

•  Impairment of goodwill and parent company 

investment. Management conducted a review of 
the carrying value of goodwill in the consolidated 
financial statements to determine whether there 
was any requirement for an impairment charge, 
in accordance with IAS 36 Impairment of Assets. 
This was an area of focus for the Committee 
given the size of the balance and the results 
in the year. Having reviewed the assumptions 
used in the calculation of carrying value, and the 
sensitivity analysis performed, the Committee 
was satisfied that sufficient headroom to the 
carrying value of goodwill existed. The headroom 
arising on the review of the parent company 
investment was much narrower and as such, 

64 

NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

it was deemed appropriate to give further 
information in the significant estimates note. 

In summary, the Committee is satisfied that the 
judgements and estimates made by management 
are appropriate.

Going Concern
The Audit and Risk Committee has reviewed 
the Going Concern assessment prepared by 
management. The assessment includes detailed 
financial forecasts covering the Group’s adopted 
strategy and considers a range of sensitivities. The 
period considered by the forecasts is to the end of 
June 2023, being approximately 12 months from 
the date of signing of the 2021 Annual Report and 
financial statements. The key assumptions in the 
forecasts are a) number of PI enquiries generated 
and b) placement of these enquiries (into our 
panel, our joint venture law firms or NAL). The 
going concern assessment focuses on two key 
areas, being the ability of the Group to meet its 
debts as they fall due and being able to operate 
within its banking facility.

The Group refinanced its banking facilities in 
December 2021 and has access to a £20.0m 
revolving credit facility (RCF) with its bankers 
(reduced from £25.0m). In all of the scenarios 
the Group has modelled it would have sufficient 
liquidity within its current RCF to meet its liabilities 
as they fall due and would not need to access 
additional funding.

The Group’s RCF is subject to quarterly covenant 
testing and all of the scenarios modelled suggest 
that the Group will continue to operate within its 
covenants for the foreseeable future.

The Group has modelled a worst case scenario, 
assuming that volumes remain at 2021 levels. 
Under this scenario, the Group would be able to 
implement sufficient mitigating actions in order to 
operate within its covenants. The likelihood of this 
scenario occurring is considered to be remote and 
therefore the Directors consider the Going Concern 
basis of accounting to be appropriate.

Further details of the going concern review are 
given on page 94. Based on this review, the 
Committee has a reasonable expectation that the 
Company and Group has adequate resources to 
continue in existence for the foreseeable future and 

has concluded it is appropriate to adopt the going 
concern basis of accounting in the preparation of 
the financial statements.

New and forthcoming 
accounting standards
There were no new accounting standards during 
the year.

Risk Management 
Framework and controls
The Audit and Risk Committee provides support 
to the Board in its oversight of the Group’s risk 
management framework, as set out on page 37 and 
monitors the effectiveness of risk management 
through reporting and assurance.

During the year, following on from the review 
performed in 2020, the Committee commissioned 
a further review into cyber-security risks across 
the Group in response to increased levels of fraud 
in the legal industry, and the ongoing risks arising 
from the Group’s decision to ask its employees to 
work from home. The review was conducted by 
the Group Legal & Compliance Director and the IT 
Director and no red flags were identified as part of 
this process. The Committee reviewed the output 
of the cyber-security review along with the wider 
risk management framework and is satisfied that 
appropriate mitigating controls are in place.

At present the Group does not have an internal 
audit function, but the finance function conducts 
a programme of review of the financial controls 
operating within each of the businesses, identifying 
areas to be improved and reporting the outcomes 
to the Committee. The Committee believes that in 
view of the current size and nature of the Group’s 
businesses, this approach is sufficient to enable 
the Committee to derive sufficient assurance as to 
the adequacy and effectiveness of internal controls 
and risk management procedures without a formal 
internal audit function. This will be kept under 
review as the business evolves.

NAHL Group Plc Annual Report and Accounts 2021 

65

Leadership and Governance

Review of law firm accrued 
income
The Committee is conscious that as an increasing 
number of enquiries are placed into NAL, the 
balance of accrued income is becoming more 
material to the Group’s results. It therefore 
requested that a review of the processes and 
controls around monitoring of accrued income 
be undertaken during the year. This review was 
undertaken by the Group finance team with the 
support of the NAL divisional finance team. This 
review identified that the balance of accrued 
income was considered to be fairly stated and 
recommended some minor improvements to 
processes which were subsequently implemented. 

Sally Tilleray
Chair of the Audit and Risk Committee

66 

NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Directors 
Remuneration 
Report 2021

Dear Shareholder, 

On behalf of my colleagues on the Remuneration 
Committee and the Board, I am pleased to present 
the Directors’ Remuneration Report for the 
financial year ended 31 December 2021. 

The composition and responsibilities of the 
Committee are set out on page 61. 

We presented the 2020 Directors’ Remuneration 
Report which was subject to an advisory vote 
by shareholders at the Annual General Meeting 
(AGM) on 29th June 2021. The 2021 Directors’ 
Remuneration Policy was approved at the AGM and 
is available in our 2020 Directors’ Remuneration 
Report on our website.

The Annual Report on Remuneration provides 
details of the amounts earned in respect of the year 
ended 31 December 2021 and how the Directors’ 
Remuneration Policy will be operated for the year 
commencing 1 January 2022. 

Review of the 2021 
financial year
2021 results reflect a full year of COVID-19 impact 
with Government restrictions and cautious 
consumer behaviour supressing accident numbers. 
This coupled with the strategic decision to grow 
the number of enquiries placed into National 
Accident Law, to create a higher margin Personal 
Injury business in the medium term, and continued 
investment to grow the Critical Care division 
resulted in revenue of £38.9m and underlying 
operating profit of £4.2m.

The above context informed and shaped the 
decisions of the Committee during the year.

Remuneration decisions  
in respect of 2021
Board changes
James Saralis was appointed as CEO on 17 August 
2021 and his salary was set at £215,000. This 
represented a circa 3.5% increase on his salary 
prior to his appointment as CEO (£208,000). For 
reference Russell Atkinson’s salary, the previous 
CEO, was set at £227,800 prior to his resignation 
in 2020.

Chris Higham was appointed as acting CFO on 17 
August 2021, but not in a director capacity.

Fees
It was proposed that the Non-Executive Directors 
would receive a 2% increase to base salary and 
fees in line with the percentage increase awarded 
to the wider workforce. Due to the uncertainty 
created in the market as a result of COVID-19, the 
decision to apply this was deferred from 1st March 
2021 to 1st June 2021. The Non-Executive Directors 
declined the increase.

Annual bonus outcomes 
The 2021 annual bonus was assessed against 
underlying operating profit (post minority interest) 
targets. The threshold operating profit target was 
not achieved and therefore James Saralis did not 
receive a bonus payment.

NAHL Group Plc Annual Report and Accounts 2021 

67

Leadership and Governance

Long-term incentives
On 18th April 2019, James Saralis was granted a 
nominal cost share option over 110,568 shares 
(equivalent to 80% of salary) which would vest 
subject to EPS performance (75% of the award) 
and free cash flow performance (25% of award) 
for the year ended 31 December 2021. The option 
has now lapsed in full as the threshold performance 
targets were not achieved.

On 23 April 2021 a restricted share award over 
428,243 shares was granted to James Saralis 
which comprised of two tranches:

•  An award over 194,656 shares (with a value at 

grant equivalent to 50% of his April 2020 salary) 
which will vest on the second anniversary of the 
grant date subject to continued employment and 
a business performance underpin.

•  An award over 233,587 shares (with a value at 

grant equivalent to 50% of his April 2021 salary) 
which will vest on the third anniversary of the 
grant date subject to continued employment and 
a business performance underpin. 

This one-off award structure reflects that no long-
term incentive award was granted in 2020.

Implementation of 
Directors’ Remuneration 
Policy for 2022
Salary/Fees
The CEO was awarded a 2% increase in salary with 
effect from 1st March 2022. 

A 2% increase in Non-Executive Directors’ basic 
fee and the Chair’s fee was awarded with effect 
from 1st March 2022. This is in line with the 
average salary increase awarded to the wider 
workforce.

Annual bonus plan
The CEO’s annual bonus opportunity is in line with 
the 2021 Remuneration Policy at a maximum of 
100% salary which is subject to a stretch operating 
profit (post minority interest) target for 2022. 
The maximum opportunity is decreased in line 
with certain decreasing thresholds on the stretch 
target. The performance targets are considered 
commercially sensitive and will be disclosed in next 
years’ Directors’ Remuneration Report. 

Long-term incentives
It is proposed that the CEO will be granted a 
restricted share award equal to 50% of salary at 
grant. The award will vest on the third anniversary 
of the grant date subject to continued employment 
and a business performance underpin.

Conclusion
We are committed to a responsible and transparent 
approach in respect of executive pay. The 
Committee believes that the advisory vote provides 
accountability and gives shareholders a say on 
this important area of corporate governance. 
We continue to welcome any feedback from 
shareholders and hope to receive your support at 
the 2022 AGM. 

Gillian Kent
Chair of the Remuneration Committee

28 March 2022

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NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Single figure of remuneration (audited)
The table below details the elements of remuneration receivable by each Director for the financial year 
ended 31 December 2021 and the total remuneration receivable by each Director for that financial year and 
for the financial year ended 31 December 2020.

J D Saralis1

Non-Executive 
Directors

T J M Aspinall2

G D C Kent

B Phillips3

S A Tilleray

Salary and 
fees
£000

200

Benefits
£000

17

80

50

45

50

–

–

–

–

Annual 
Bonus
£000

Total
 Remuneration
2021
£000

Total
 Remuneration
20204
£000

Pension
£000

–

–

–

–

–

2

–

–

–

–

219

180

80

50

45

50

58

47

23

48

1.  J D Saralis was appointed as CEO on 17 August 2021. The salary figure in the table above is based on a combination of the salary he received 

during 2021 prior to and following appointment as CEO.

2.  T J M Aspinall was appointed Senior Independent Director on 30th January 2020 with an additional fee of £5,000 per annum and was 

appointed Non-Executive Chair on 8th October 2020 with a fee of £80,000 per annum.

3.  B Phillips was appointed as a Non-Executive Director on 25th June 2020.

4.  The Board agreed to a 20% reduction in base salaries and fees for three months (1 April to 30 June 2020) as part of the cost-saving measures 

implemented in light of COVID-19. The total remuneration for 2020 is shown after the reduction. 

The taxable benefits received during the financial year ended 31 December 2021 are principally car 
allowance and private medical insurance.

Individual elements of remuneration (audited)
Base salary and fees
The base salaries for 2021 and 2022 are as set out below:

J D Saralis1

2021
base salary
£000

2022
base salary1
£000

215

219

% increase

2%

1.  The 2021 figure represents J D Saralis’ salary on appointment as CEO.

Details of Non-Executive Directors’ fees for 2021 and 2022 are as set out below:

Chair’s fee

Non-Executive Director’s fee

Chair of the Audit and Risk Committee

Chair of the Remuneration Committee

2021
fee
£000

80

45

5

5

2022
fee
£000

82

46

5

5

% increase

2%

2%

0%

0%

NAHL Group Plc Annual Report and Accounts 2021 

69

Leadership and Governance

Annual bonus plan (audited)
The maximum annual bonus opportunity for James Saralis was capped at 45% of salary in respect of the 
year ended 31 December 2021. 100% of the annual bonus was assessed against underlying operating profit 
performance (after minority interest).

The threshold operating profit target was not achieved and therefore James Saralis did not receive a bonus 
payment.

The following table sets out the bonus criteria for the CEO.

Performance measure

Operating profit1

Proportion of bonus 
determined by 
measure

Performance

100%

Operating profit 
threshold of £3.3m was 
not achieved.

Bonus earned
£000

0

1. Operating profit is defined as underlying operating profit less profit attributable to non-controlling interests.

Long-term incentives (audited)
On 18 April 2019, J D Saralis was granted a nominal cost share option over 110,568 shares (equivalent to 
80% of salary) in the form of nominal cost share options which would vest subject to EPS performance 
(75% of the award) and free cash flow (25% of award) for the year ended 31 December 2021. 

The options lapsed in full as the threshold performance targets were not achieved as illustrated below.

EPS for the year 
ending 31 December 
2021

Less than 16.5p

16.5p

17.2p

18.1p

Actual

Vesting

Vesting1
(% maximum)

Free Cash Flow

Vesting1
(% maximum)

0%

Less than £6.3m

25%

50%

100%

0.3p

0%

£6.3m

£7.7m

£8.1m

Actual

Vesting

0%

25%

50%

100%

£0.8m

0%

1.  Vesting percentages accrue on a straight-line basis between 25%–50% and 50%–100%.

No long-term incentive awards were granted during the year ended 31 December 2020.

Awards granted during the year
On 23 April 2021 a restricted share award over 428,243 shares was granted to James Saralis which 
comprised of two tranches:

•  An award over 194,656 shares (with a value at grant equivalent to 50% of his April 2020 salary), which 
will vest on the second anniversary of the grant date subject to continued employment and a business 
performance underpin.

•  An award over 233,587 shares (with a value at grant equivalent to 50% of his April 2021 salary), which 
will vest on the third anniversary of the grant date subject to continued employment and a business 
performance underpin.

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NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Tranche 1

Tranche 2

Number 
of shares

Face value at
 grant

(% salary) 

Face value at 
grant
 (£000)1

194,656

233,587

50% of April 
2020 salary

50% of April 
2021 salary

85

102

Vesting 
period

2 years

3 years

1.  The three day average mid-market closing share price prior to grant (£0.4367) was used to determine the face value of the awards.

This one-off award structure reflects that no long-term incentive award was granted in 2020.

Statement of Directors’ shareholding and share 
interests
The interests of the Directors and their immediate families in the Company’s Ordinary Shares as at  
31 December 2021 and as at 31 December 2020 were as follows:

Executive Director
J D Saralis

Non-Executive Directors
T J M Aspinall

G D C Kent

B Phillips 

S A Tilleray

31 December
2021

31 December
2020

0.10%

0.10%

0.02%

0.00%

0.00%

0.00%

0.02%

0.00%

0.00%

0.00%

The interests of the CEO as at 31 December 2021 in the Company’s share schemes were as follows:

Director

Plan

J D Saralis

Restricted share 
award

EMI (nominal 
cost option)

SAYE

Exercised
 during the
year

Vested but 
unexercised 
during the
 year

Unvested and 
subject to 
performance
measures

Unvested and 
not subject to 
performance
measures

Total as at 
31 December
2021

–

–

–

–

–

10,514

428,243

110,5681

–

–

–

–

428,243

110,568

10,514

1.  Figures relate to the long-term incentive award granted on 18 April 2019. The award lapsed in full following the year ended 31 December 2021 

(see page 70).

NAHL Group Plc Annual Report and Accounts 2021 

71

Leadership and Governance

Consideration by the 
Directors of matters 
relating to Directors’ 
remuneration
During the year ended 31 December 2021, the 
Committee was composed of the Company’s 
independent Non-Executive Directors, Gillian 
Kent (Chair), Tim Aspinall, Brian Phillips and Sally 
Tilleray. 

Executive Directors only attend meetings by 
invitation.

The Committee’s key responsibilities are:

•  reviewing the ongoing appropriateness and 
relevance of remuneration policy and its 
application to the business

•  reviewing and approving the remuneration 

packages of the Executive Directors;

•  the grant of 2022 restricted share awards for 

Executive Directors and senior management and 
the outturn of prior long-term incentive awards;

•  monitoring the level and structure of 

remuneration of the senior management; and

•  production of the Annual Report on the Directors’ 

remuneration.

Advisors
During the year ended 31 December 2021, the 
Committee received independent advice from 
Deloitte LLP. Deloitte is a founder member of the 
Remuneration Consultants Group and voluntarily 
operates under its code of conduct in its dealings 
with the Committee. Fees for this service were 
£10,000. 

Director Remuneration 
Report voting at the 2021 
AGM
The table below sets out the voting outcome at 
the Group’s AGM held on 29 June 2021 in respect 
of the resolution to approve the 2020 Directors’ 
Remuneration Report (which comprised the future 
Directors’ Remuneration Policy and Annual Report 
on Remuneration).

Votes for

% for

Votes 
against

% against

Total 
votes cast

Votes 
withheld 
(abstentions)

Approval of 
Directors’ 
Remuneration 
Report

22,471,970

99.5

113,308

0.5

22,585,278

8,289

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NAHL Group Plc Annual Report and Accounts 2021

Leadership and Governance

Directors’
Report

The Directors of NAHL Group plc present their Annual Report 
and audited consolidated financial statements for the year 
ended 31 December 2021. 

Results and dividend
The Group’s profit after tax for the year was £0.2m 
(2020: loss of £0.2m).

The Directors do not propose a final dividend 
(2020: 0.0p per share).

A review of the business, including future 
developments, is included in the Strategic Report 
on pages 6–52.

Post balance sheet events
The Board have undertaken an impact assessment 
considering the recent developments in the Ukraine 
crisis and do not consider that this will have a 
significant impact on the Group’s operations. 
There are no other significant events affecting the 
Company and the Group since the statement of 
financial position date.

Substantial shareholdings
The Group was notified of the following interests 
amounting to 10% or more of its issued share 
capital at the financial year end:

Harwood Capital 19.82%

Lombard Odier Asset Management 18.39%

Schroder Investment Management 16.65%

Directors’ third-party 
indemnity provisions
The Company maintained during the year and to 
the date of approval of the financial statements, 
indemnity insurance for its Directors and 
Officers against liability in respect of proceedings 
brought by third parties, subject to the terms and 
conditions of the Companies Act 2006.

Capital structure
Details of the capital structure can be found in note 
21 of the consolidated financial statements. The 
Group has employee share option plans in place, 
full details of which can be found in note 22 to the 
financial statements.

Financial instruments
The Group’s principal financial instruments 
comprise cash and cash equivalents, trade and 
other receivables, interest-bearing loans and trade 
and other payables. Further details on financial 
instruments are given in note 24 to the financial 
statements.

Directors
The Directors of the Company who were in office 
during the year and up to the date of signing the 
financial statements were:

T J M Aspinall (Chair)

J D Saralis (Chief Executive Officer)

G D C Kent (Independent Non-Executive) 

S P Tilleray (Independent Non-Executive)

B Phillips (Independent Non-Executive)

Biographies of the present Directors of the 
Company are listed on pages 54–55.

Details of the remuneration of the Directors is 
disclosed in the Remuneration Report on pages 69.

Political donations
No political donations were made during the year 
or the previous year.

Statement on engagement 
with employees
For information on how the Group has engaged 
with employees during the year, see Our 
Sustainable Culture on pages 44–49.

NAHL Group Plc Annual Report and Accounts 2021 

73

Leadership and Governance

Statement of relationships 
with suppliers, customers 
and others
For information on how the Group has maintained 
relationships with suppliers, customers and others, 
see Section 172 statement on pages 51–52.

Group’s policy concerning 
employment of disabled 
persons
NAHL Group plc is committed to providing 
equal opportunities for all and taking action on 
unlawful discrimination. We seek to recruit, train 
and promote based on experience, skills and 
performance and provide our employees with the 
necessary tools and equipment to allow them to 
perform their duties to the best of their abilities.

Auditor
Mazars LLP was appointed as Auditor during 
the year and have expressed their willingness to 
continue in office as Auditor and a resolution to 
reappoint them will be proposed at the forthcoming 
Annual General Meeting.

Other information
An indication of likely future developments in the 
business and particulars of significant events 
which have occurred since the end of the year have 
been included in the Strategic Report on pages 
6–52 along with information regarding employee 
matters. Information regarding the Group’s 
financial risk management objectives and policies 
is included in note 24 to the financial statements on 
page 122.

Going concern
In determining the appropriate basis of preparation 
of the financial statements, the Directors are 
required to consider whether the Company and 
Group can continue in operational existence for the 
foreseeable future.

The Board have considered detailed financial 
forecasts of future trading, profits and cash 
flows covering the Group’s adopted strategy and 
considers a range of sensitivities. The going concern 
assessment focuses on two key areas, being the 
ability of the Group to meet its debts as they fall due 
and being able to operate within its banking facility.

The Group refinanced its banking facilities in 
December 2021 and has access to a £20.0m 
revolving credit facility (RCF) with its bankers 
(reduced from £25.0m). In all of the scenarios the 
Group has modelled, it would have sufficient liquidity 
within its current RCF to meet its liabilities as they fall 
due and would not need to access additional funding.

The Group’s RCF is subject to quarterly covenant 
testing and all of the scenarios modelled suggest 
that the Group will continue to operate within its 
covenants for the foreseeable future.

The Group has modelled a worst case scenario, 
assuming that volumes remain at 2021 levels, and 
has then considered the options it would have 
available to mitigate against any shortfall in profits 
and cash. Under this scenario, the Group would be 
able to implement sufficient mitigating actions in 
order to operate within its covenants. The likelihood 
of this scenario occurring is considered to be remote 
and therefore the directors consider the Going 
Concern basis of accounting to be appropriate.

Further details of the going concern review are given 
on page 94. Based on this review, the Committee 
has a reasonable expectation that the Company 
and Group has adequate resources to continue 
in existence for the foreseeable future and has 
concluded it is appropriate to adopt the going 
concern basis of accounting in the preparation of the 
financial statements.

Energy and Carbon 
Reporting
This is the second year the Group has been required 
to comply with the Streamline Energy and Carbon 
Reporting (SECR) legislation.

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Leadership and Governance

Methodology
The report follows the SECR guidance and the GHG 
Reporting Protocol – Corporate Standard as the 
accepted methodology to meet the mandatory 
requirements. No additional optional elements 
have been included. The UK Government’s 
greenhouse gas conversion factors have been 
used to calculate the carbon emissions. The 
below table demonstrates the GHG Emissions and 
Energy Usage Data for the financial year ended 
31 December 2021. For offices where electricity 
is part of a service charge, usage has been 
estimated based on adjusting the bills received 
for other offices around the Group. No data has 
been included for business mileage as this was 
immaterial for 2021 and 2020 (<1% of the overall 
total).

Energy consumption used to calculate emissions 
(electricity/mWh) 85.50 (2020: 260.84)

Energy consumption used to calculate emissions 
(gas/mWh) 0 (2020: 214.42)

Emissions from purchased gas tCO2e (scope 1) 0 
(2020: 39.4)

Emissions from purchased electricity tCO2e (scope 
2) 19.76 (2020: 66.0)

Intensity measurement (tonnes CO2e per 
employee) 0.08 (2020: 0.42)

All energy use is in the UK.

Intensity measurement
The Group has chosen tonnes of gross CO2e per 
employee as the reported SECR intensity metric. 
This is considered to be the most appropriate basis 
for an office-based operation that relies heavily on 
its workforce to provide services to its customers. 
This is a relevant and common business metric and 
will serve as a consistent comparative for reporting 
purposes going forwards.

Energy efficiency actions 
taken
The Group operates from three locations around 
the UK and its workforce is largely office and home-
based. 

As an office-based operation, the Group considers 
its largest carbon footprint to come from the use of 
energy used in an office environment e.g. light, heat 
and computer usage and therefore it has continued 
to focus its efficiency actions around this area. The 
main action taken in 2021 was to switch the supply 
of the Kettering office to 100% green energy. 

The reduction in energy usage year on year is a 
direct result of:

a)  the exiting of the Chancery Lane offices in June 
2020 and consolidation of the Kettering offices 
in November 2020. 2021 is therefore the first 
full year of the impact of these changes with 
no energy consumption at these sites at all for 
2021. 

b)  The move to Green energy suppliers. In 

February 2021, the Kettering office made the 
switch to a 100% green energy supplier and 
therefore from February 2021, the Group’s 
largest offices were not generating greenhouse 
gas emissions.

Further details on how the Group has sought to 
limit its impact on the environment are given in Our 
sustainable culture on page 44–49. 

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75

Leadership and Governance

Group response to 
Modern Slavery Act 2015
1.  Organisational structure 

and recruitment processes

The Group’s organisational structures include 
the Board, Senior Management teams across 
two divisions, a contact centre at one of the 
three locations and standard support functions 
across all sites. Recruitment processes include 
the monitoring of passport documentation, with 
all new recruits expected to show their passport 
as a proof of identity. The Group also reviews 
shared addresses. In addition, the Group monitors 
the ongoing wellbeing of its employees through 
line management relationships and operates an 
Employee Assistance Programme. 

Where recruitment agencies are used to employ 
staff, the Group ensures these agencies also have 
an approved statement in support of the Modern 
Slavery Act 2015. 

As these structures and recruitment processes 
apply to UK-based operations, the Group considers 
these to be very low risk.

2. Services
The services NAHL Group plc provides to its 
customers and consumers are UK office-based, 
with UK field based service providers in regular 
contact with their operational management teams. 
The Group’s supply chain in relation to services 
consists on the whole of marketing and legal 
services in Personal Injury and specialist associates 
in Critical Care and Residential Property. The 
Group considers these to be very low risk in relation 
to slavery and human trafficking so takes no 
specific action in relation to these relationships.

3. Goods
In terms of goods supplied to the Group, the 
majority of goods will be goods for use in an 
office environment such as stationery and office 
equipment. The Group considers these to be very 
low risk in relation to slavery and human trafficking 
so takes no specific action in relation to these 
relationships.

Statement of Directors’ 
Responsibilities
The Directors are responsible for preparing the 
Annual Report and the financial statements in 
accordance with applicable law and regulation. 
Company law requires the Directors to prepare 
financial statements for each financial year. 
Under that law the directors have prepared the 
Group financial statements in accordance with 
International Accounting Standards in conformity 
with the requirements of the Companies Act 
2006 and Company financial statements in 
accordance with International Accounting 
Standards in conformity with the requirements 
of the Companies Act 2006. 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 Company and of the profit or loss 
of the Group and Company for that period. In 
preparing the financial statements, the Directors 
are required to:

•  select suitable accounting policies and then apply 

them consistently;

•  state whether applicable international accounting 

standards have been followed for the Group 
financial statements and whether applicable 
international accounting standards have been 
followed for the Company financial statements, 
subject to any material departures disclosed and 
explained in the financial statements;

•  make judgements and accounting estimates that 

are reasonable and prudent; and

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

The Directors are also responsible for safeguarding 
the assets of the Group and Company and hence 
for taking reasonable steps for the prevention and 
detection of fraud and other irregularities. The 
Directors are responsible for keeping adequate 
accounting records that are sufficient to show and 
explain the Group and Company’s transactions 
and disclose with reasonable accuracy at any time 
the financial position of the Group and Company 

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Leadership and Governance

and enable them to ensure that the financial 
statements comply with the Companies Act 2006.  

The Directors of the ultimate parent Company are 
responsible for the maintenance and integrity of 
the ultimate parent Company’s website. Legislation 
in the United Kingdom governing the preparation 
and dissemination of financial statements may 
differ from legislation in other jurisdictions.

In the case of each director in office at the date the 
Directors’ Report is approved:

•  so far as the Director is aware, there is no 

relevant audit information of which the Group 
and Parent Company auditors are aware; and

•  they have taken all the steps that they ought 
to have taken as a Director in order to make 
themselves aware of any relevant audit 
information and to establish that the Group and 
Parent Company auditors are aware of that 
information.

This confirmation is given and should be 
interpreted in accordance with the provisions of 
s418 of the Companies Act 2006.

On behalf of the Board

James Saralis
Chief Executive Officer 

28 March 2022

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77

  
Financial Statements

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NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

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

Financial Statements

Independent auditor’s 
report to the members
of NAHL Group Plc

Opinion
We have audited the financial statements of 
NAHL Group Plc (the ‘parent company’) and its 
subsidiaries (the ‘group’) for the year ended 31 
December 2021 which comprise the Consolidated 
Statement of Comprehensive Income, the 
Consolidated Statement of Financial Position, the 
Consolidated Statement of Changes in Equity, the 
Consolidated Cash Flow Statement, the Company 
Statement of Financial Position, the Company 
Statement of Changes in Equity, the Company 
Cash Flow Statement, and notes to the financial 
statements, including a summary of significant 
accounting policies. 

The financial reporting framework that has been 
applied in their preparation is applicable law and 
UK-adopted international accounting standards 
and, as regards the parent company financial 
statements, as applied in accordance with the 
provisions of the Companies Act 2006.

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 2021 and of the group’s profit for 
the year then ended;

•  have been properly prepared in accordance with 
UK-adopted international accounting standards 
and, as regards the parent company financial 
statements, as applied in accordance with the 
provisions of the Companies Act 2006; and

•  have been prepared in accordance with the 
requirements of the Companies Act 2006.

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79

Financial Statements

Conclusions relating to 
going concern 
In auditing the financial statements, we have 
concluded that the directors’ use of the going 
concern basis of accounting in the preparation of 
the financial statements is appropriate. 

Our audit procedures to evaluate the directors’ 
assessment of the group’s and the parent 
company’s ability to continue to adopt the going 
concern basis of accounting included but were not 
limited to:

•  Undertaking an initial assessment at the planning 
stage of the audit to identify events or conditions 
that may cast significant doubt on the group’s 
and parent company’s ability to continue as a 
going concern;

•  Obtaining and reviewing management’s going 

concern assessment;

•  Evaluating the directors’ method to assess the 

group’s and parent company’s ability to continue 
as a going concern;

•  Reviewing management’s severe yet plausible 

scenarios and assessing management’s ability to 
take mitigating actions;

•  Reviewing the terms of financing agreements 
and assessing the forecasted results against 
covenants in place;

•  Evaluating the key assumptions used and 

judgements applied by the directors in forming 
their conclusions on going concern; 

•  Assessing the impact of Russia’s invasion of 

Ukraine on the business and its ability to continue 
as a going concern; and

•  Evaluating the appropriateness of the directors’ 

disclosures in the financial statements.

Based on the work we have performed, we 
have not identified any material uncertainties 
relating to events or conditions that, individually 
or collectively, may cast significant doubt on 
the group’s and the parent company’s ability to 
continue as a going concern for a period of at least 
twelve months from when the financial statements 
are authorised for issue.

Our responsibilities and the responsibilities of 
the directors with respect to going concern are 
described in the relevant sections of this report.

Key audit matters
Key audit matters are those matters that, in our 
professional judgement, were of most significance 
in our audit of the financial statements of the 
current period and include the most significant 
assessed risks of material misstatement (whether 
or not due to fraud) we identified, including those 
which had the greatest effect on: the overall audit 
strategy; the allocation of resources in the audit; 
and directing the efforts of the engagement team. 
These matters were addressed in the context of 
our audit of the financial statements as a whole, 
and in forming our opinion thereon, and we do not 
provide a separate opinion on these matters.

We summarise below the key audit matters 
in forming our opinion above, together with 
an overview of the principal audit procedures 
performed to address each matter and our key 
observations arising from those procedures.

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Financial Statements

These matters, together with our findings, were communicated to those charged with governance through 
our Audit Completion Report.

Key Audit Matter

How our scope addressed this matter

Valuation of trade receivables and accrued 
income (Group)

The group’s accounting policy for financial assets 
and liabilities, which include trade receivables and 
accrued income, is set out in the accounting policy 
notes on page 103 of the Annual Report.

The group enters into contracts with customers on 
varied terms. The nature of the industry in which 
the group operates in can sometimes result in long 
lead times between revenue recognition and cash 
generation, due to the time taken to settle cases. 

Following a review of the year-end trade 
receivables and accrued income balance of 
£24.5m (2020: £26.7m), we identified specific 
aged balances totaling £19.5m (2020: £22.3m) 
where there is a risk these balances might not be 
recoverable.

We identified the valuation of these specific 
balances as a significant risk and key audit matter, 
given the subjectivity involved in assessing 
recoverability.

Depending on the facts and circumstances of 
the respective balances, our audit procedures 
included, but were not limited to:

•  Assessing the aging of the receivables balances, 
and performing a retrospective review against 
prior year balances to understand aging profiling 
to identify any potential issues related to 
recoverability;

•  Assessing the level of cash receipts during the 
year and post year end against our expectation 
based on signed payment agreements;

•  Recalculating accrued income balances based on 
contractual fees and the number of enquiries with 
customers;

•  Obtaining third party confirmation from 
customers of the number of outstanding 
enquiries passed to them;

•  Assessing the adequacy of the work of one 

component auditor in respect of £4m of trade 
receivables and accrued income balances;

•  Re-calculating a sample of accrued income 

balances at year end and assessing the level of 
post year end cash receipt against that which 
would be expected, based on the progress of the 
case; and

•  Reviewing management’s methodology for 

Expected Credit Losses with reference to the level 
of debt write-offs during the year and challenging 
their forward looking assessments.

Our observations

Based on the procedures performed, we are 
satisfied with the carrying value of the trade 
receivables and accrued income in the financial 
statements is reasonable.

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81

Financial Statements

Key Audit Matter

How our scope addressed this matter

Carrying Value of Goodwill (Group)

The group’s accounting policies in respect 
of goodwill and impairment are set out in the 
accounting policy notes on page 104 of the annual 
report.

The carrying value of goodwill is £55.5m (2020: 
£55.5m). In assessing the recoverability of 
goodwill, management prepare value in use 
calculations across their two cash generating 
units, Critical Care and Consumer Legal Services, 
which involves assumptions, such as future cash 
flows and the discount rate to apply to those.

Due to the subjectivity involved in estimating 
future performance and the significance of the 
carrying value of goodwill, we identified this as a 
significant risk and key audit matter.

Our audit procedures included, but were not 
limited to:

•  Obtaining and reviewing management’s goodwill 

impairment assessment;

•  Assessing the reasonableness of key 

assumptions in the value in use calculation 
with reference to externally available data, and 
applying our own sensitivity analysis to assess 
the impact of potential changes in assumptions;

•  Reviewing management’s sensitivity analysis to 

further assess the potential for impairment;

•  Engaging our internal valuation expert to assess 
the reasonableness of the Weighted Average 
Cost of Capital (WACC) rate and the model 
methodology used; 

•  Ensuring consistency between value in use 

calculations used for impairment assessment and 
forecasts used for assessment of going concern; 
and

•  Reviewing the reasonableness of the disclosures 
made in the financial statements in relation to the 
carrying value of goodwill.

Our observations

Based on the procedures performed, we are 
satisfied that the carrying value of the goodwill in 
the financial statements is reasonable.

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Financial Statements

Key Audit Matter

How our scope addressed this matter

Valuation of investments (Parent company)

The group’s accounting policies in respect of 
impairment of investments is set out in the 
accounting policy notes on page 131 of the Annual 
Report.

The carrying value of NAHL Group Plc’s 
investments in subsidiaries is £52.7m (2020: 
£52.7m) and is the most significant balance in the 
parent company statement of financial position. 
Given this, we identified it as a significant risk and 
key audit matter.

Our audit procedures included, but were not 
limited to:

•  Obtaining and reviewing management’s 
impairment review and future forecasts;

•  Assessing and challenging the underlying 

assumptions to ensure these are reasonable;

•  Engaging with our internal valuation experts to 
assess the reasonableness of the WACC rate 
used;

•  Reviewing the carrying value with specific 

reference to the year end market capitalisation of 
the Group;

•  Testing individual investments for indicators of 

impairment; and

•  Reviewing the disclosures made in the 

financial statements to ensure they cover the 
requirements of IAS 36.

Our observations

Based on the procedures performed, we are 
satisfied that the carrying value of the investments 
in the financial statements is reasonable.

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83

Financial Statements

Our application of materiality and an overview of the 
scope of our audit
The scope of our audit was influenced by our application of materiality. We set certain quantitative 
thresholds for materiality. These, together with qualitative considerations, helped us to determine the 
scope of our audit and the nature, timing and extent of our audit procedures on the individual financial 
statement line items and disclosures and in evaluating the effect of misstatements, both individually and on 
the financial statements as a whole. Based on our professional judgement, we determined materiality for 
the financial statements as a whole as follows:

Overall materiality

Group financial statements 

Parent financial statement  

£383k

£846k

Where items in the parent company financial statements were 
included in the group financial statements, materiality was restricted 
to that applied to the group.

How we determined it

Group materiality has been calculated by reference to adjusted profit 
before tax, of which it represents 7%. 

Rationale for benchmark 
applied

Performance materiality

Reporting threshold

Parent company materiality has been calculated by reference to 
total assets, of which it represents 1%.

Profit before tax (adjusted for net financing costs, share based 
payments, amortization and other exceptional items) has been 
identified as the principal benchmark within the group financial 
statements due this being the primary focus of shareholders.

Total assets has been identified as the principal benchmark within 
the parent company financial statements as it is considered to be the 
focus of shareholders due to being a holding company with no trade.

Performance materiality is set to reduce to an appropriately low level 
the probability that the aggregate of uncorrected and undetected 
misstatements in the financial statements exceeds materiality for 
the financial statements as a whole.

We set performance materiality applied in our audit was:

Group financial statements  

Parent financial statement  

£287k

£634k

We agreed with the directors that we would report to them 
misstatements identified during our audit above £11k for the group 
financial statements and £25k for the parent company financial 
statements, as well as misstatements below that amount that, in our 
view, warranted reporting for qualitative reasons.

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Financial Statements

As part of designing our audit, we assessed the 
risk of material misstatement in the financial 
statements, whether due to fraud or error, and 
then designed and performed audit procedures 
responsive to those risks. In particular, we 
looked at where the directors made subjective 
judgements, such as assumptions on significant 
accounting estimates.

We tailored the scope of our audit to ensure that 
we performed sufficient work to be able to give 
an opinion on the financial statements as a whole. 
We used the outputs of our risk assessment, 
our understanding of the group and the parent 
company, their environment, controls, and critical 
business processes, to consider qualitative factors 
to ensure that we obtained sufficient coverage 
across all financial statement line items.

Our group audit scope included an audit of 
the group and the parent company financial 
statements of NAHL Group Plc. Based on our 
risk assessment, the parent company and four 
components of the group were subject to full 
scope audit and three components were subject to 
specific audit procedures on certain key balances. 
For the remaining components, in addition to 
desktop analytical review, 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 parent company and those components of 
the group which were subject to full scope audit 
or specific audit procedures accounted for the 
following percentages of the group’s results for the 
year ended 31 December 2021.

Number of 
components

Total group 
revenue

Total group 
assets

Total profits 
and losses that 
make up group 
profit before 
tax

Full scope audits

Specific scope audits

Total

5

3

8

75%

19%

94%

83%

8%

91%

97%

1%

98%

One full scope audit was performed by a component auditor. This component accounted for the following 
percentages of the group’s results for the year ended 31 December 2021:

Number of 
components

Total group 
revenue

Total profits and 
losses that make 
up group profit 
before tax

Total group 
assets

1

12%

12%

16%

Performed by 
component 
auditor

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85

Financial Statements

For that entity, the group engagement team issued 
group instructions to the component auditor to 
direct their work. Group reporting appendices 
were returned by the component auditor and we 
reviewed their working papers to assess whether 
sufficient and appropriate audit procedures had 
been performed. Meetings were held with the 
component auditor at the planning and completion 
stage, to ensure the work was sufficiently directed 
by the group engagement team and the group 
engagement team attended the clearance 
meeting between the component auditor and 
component management. The audit work for all 
other components was completed by the group 
engagement team.

At the parent company level, the group audit 
team also tested the consolidation process and 
carried out analytical procedures to confirm our 
conclusion that there were no significant risks of 
material misstatement of the aggregated financial 
information.

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

Our responsibility is to read the other information 
and, in doing so, consider whether the other 
information is materially inconsistent with the 
financial statements or our knowledge obtained 
in the course of audit or otherwise appears 
to be materially misstated. If we identify such 
material inconsistencies or apparent material 
misstatements, we are required to determine 
whether this gives rise to a material misstatement 
in the financial statements themselves. If, based 
on the work we have performed, we conclude 
that there is a material misstatement of this other 
information, we are required to report that fact.

We have nothing to report in this regard.

Opinions on other 
matters prescribed by the 
Companies Act 2006
In our opinion, the part of the directors’ 
remuneration report to be audited has been 
properly prepared in accordance with the 
Companies Act 2006.

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

•  the information given in the strategic report 

and the directors’ report for the financial year 
for which the financial statements are prepared 
is consistent with the financial statements and 
those reports have been prepared in accordance 
with applicable legal requirements.

Matters on which we are 
required to report by 
exception
In light of the knowledge and understanding of 
the group and the parent company and their 
environment obtained in the course of the audit, we 
have not identified material misstatements in the:

•  strategic report or the directors’ report; or 

•  information about internal control and risk 

management systems in relation to financial 
reporting processes and about share capital 
structures, given in compliance with rules 7.2.5 
and 7.2.6 of the FCA Rules.

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Financial Statements

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

•  adequate accounting records have not been kept 
by the parent company, or returns adequate for 
our audit have not been received from branches 
not visited by us; or

•  the parent company financial statements 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.

Responsibilities of 
Directors
As explained more fully in the directors’ 
responsibilities statement set out on page 76, the 
directors are responsible for the preparation of the 
financial statements and for being satisfied that 
they give a true and fair view, and for such internal 
control as the directors determine is necessary to 
enable the preparation of financial statements that 
are free from material misstatement, whether due 
to fraud or error.

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

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

The extent to which our procedures are capable 
of detecting irregularities, including fraud is 
detailed below.

Irregularities, including fraud, are instances of non-
compliance with laws and regulations. We design 
procedures in line with our responsibilities, outlined 
above, to detect material misstatements in respect 
of irregularities, including fraud.

Based on our understanding of the group and 
its industry, we considered that non-compliance 
with the following laws and regulations might 
have a material effect on the financial statements: 
Anti-Bribery, Living Wage, AIM listing rules, QCA 
Corporate Governance Code, Employment laws, 
Regulation by the Claims Management Regulation 
Unit or Solicitors Regulation Authority, Enterprise 
Act 2002, Competition Act 1998, Modern Slavery 
Act, GDPR, Gender-pay gap and Environmental 
regulations.

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87

Our procedures in relation to fraud included but 
were not limited to:

•  Making enquiries of the directors and 

management on whether they had knowledge of 
any actual, suspected or alleged fraud;

•  Gaining an understanding of the internal controls 

established to mitigate risks related to fraud;

•  Discussing amongst the engagement team the 

risks of fraud; 

•  Addressing the risks of fraud through 

management override of controls by performing 
journal entry testing;

There are inherent limitations in the audit 
procedures described above and the primary 
responsibility for the prevention and detection 
of irregularities including fraud rests with 
management. As with any audit, there remained a 
risk of non-detection of irregularities, as these may 
involve collusion, forgery, intentional omissions, 
misrepresentations or the override of internal 
controls.

The risks of material misstatement that had the 
greatest effect on our audit are discussed in the 
“Key audit matters” section of this report. 

A further description of our responsibilities is 
available on the Financial Reporting Council’s 
website at www.frc.org.uk/auditorsresponsibilities. 
This description forms part of our auditor’s report.

Financial Statements

To help us identify instances of non-compliance 
with these laws and regulations, and in identifying 
and assessing the risks of material misstatement 
in respect to non-compliance, our procedures 
included, but were not limited to:

•  Gaining an understanding of the legal and 

regulatory framework applicable to the group 
and the parent company, the industry in which 
they operate, and the structure of the group, 
and considering the risk of acts by the group and 
the parent company which were contrary to the 
applicable laws and regulations, including fraud; 

•  Inquiring of the directors, management 

and, where appropriate, those charged with 
governance, as to whether the group and the 
parent company is in compliance with laws and 
regulations, and discussing their policies and 
procedures regarding compliance with laws and 
regulations;

•  Inspecting correspondence with relevant 

licensing or regulatory authorities including the 
SRA; 

•  Reviewing minutes of directors’ meetings in the 

year; and

•  Discussing amongst the engagement team the 

laws and regulations listed above, and remaining 
alert to any indications of non-compliance.

We also considered those laws and regulations 
that have a direct effect on the preparation of the 
financial statements, such as the Companies Act 
2006 and UK tax legislation.

In addition, we evaluated the directors’ and 
management’s incentives and opportunities 
for fraudulent manipulation of the financial 
statements, including the risk of management 
override of controls, and determined that the 
principal risks related to posting manual journal 
entries to manipulate financial performance, 
management bias through judgements and 
assumptions in significant accounting estimates 
including goodwill impairment, investment 
valuation and recoverability of trade receivables 
and accrued income, significant one-off or unusual 
transactions, and revenue recognition (which we 
pinpointed to the cut-off assertion), and significant 
one-off or unusual transactions.

88 

NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

Use of the audit report
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.

Stephen Brown (Senior Statutory Auditor) for 
and on behalf of Mazars LLP
Chartered Accountants and Statutory Auditor 

The Pinnacle
160 Midsummer Boulevard
Milton Keynes
MK9 1FF

28 March 2022

NAHL Group Plc Annual Report and Accounts 2021 

89

Financial Statements

CONSOLIDATED STATEMENT 
OF COMPREHENSIVE INCOME
FOR THE YEAR ENDED 31 DECEMBER 2021

Revenue 
Cost of sales 

Gross profit 
Administrative expenses 

Underlying operating profit 
Exceptional items 

Operating profit 
Profit attributable to members’ non-controlling interests in LLPs 
Financial income 
Financial expense 

Profit/(Loss) before tax 
Taxation 

Profit/(Loss) and total comprehensive income for the year 

Earnings per share (p)
Basic earnings per share 
Diluted earnings per share 

Note 

1,2 

3 

1 
4 

2 

7 
8 

9 

Note 

23 
23 

2021 
£000 

38,947 
(21,352) 

17,595 
(13,439) 

4,156 
– 

4,156 
(3,451) 
85 
(555) 

235 
(79) 

156 

2021 
p 

0.3 
0.3 

2020
£000

40,875
(21,602)

19,273
(14,964)

5,659
(1,350)

4,309
(4,115)
168
(585)

(223)
(2)

(225)

2020
p

(0.5)
(0.5)

All profits and losses and total comprehensive income are attributable to the owners of the Company. 

All profits and losses relate to continuing operations.

The notes on pages 94–127 form part of these financial statements.

90 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
Financial Statements

CONSOLIDATED STATEMENT 
OF FINANCIAL POSITION
AT 31 DECEMBER 2021

Non-current assets
Goodwill 
Other intangible assets 
Property, plant and equipment 
Right of use assets 
Deferred tax asset 

Current assets
Trade and other receivables (including £3,718,000 (2020:
£7,828,000) due in more than one year) 
Cash and cash equivalents 

Total assets 

Current liabilities 
Trade and other payables 
Lease liabilities 
Member capital and current accounts 
Current tax liability 

Non-current liabilities 
Lease liabilities 
Other interest-bearing loans and borrowings 
Deferred tax liability 

Total liabilities 

Net assets 

Equity 
Share capital 
Share option reserve 
Share premium 
Merger reserve 
Retained earnings 

Note 

2021 
£000 

2020
£000

13 
15 
16 
17 
10 

18 

20 
17 
14 

17 
19 
11 

21 

55,489 
3,701 
477 
2,315 
23 

62,005 

33,404 
2,458 

35,862 

97,867 

(16,211) 
(242) 
(4,210) 
(97) 

55,489
4,557
367
2,761
14

63,188

34,285
3,609

37,894

101,082

(17,547)
(248)
(4,177)
(126)

(20,760) 

(22,098)

(1,953) 
(17,910) 
(625) 

(20,488) 

(41,248) 

(2,195)
(19,901)
(826)

(22,922)

(45,020)

56,619 

56,062

116 
4,312 
14,595 
(66,928) 
104,524 

115
3,912
14,595
(66,928)
104,368

Capital and reserves attributable to the owners of NAHL Group plc 

56,619 

56,062

The notes on pages 94–127 form part of these financial statements.

These financial statements on pages 90–127 were approved by the Board of Directors on 28 March 2022 
and were signed on its behalf by:

J D Saralis 
Director

Company registered number: 08996352

NAHL Group Plc Annual Report and Accounts 2021 

91

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

CONSOLIDATED STATEMENT OF CHANGES IN EQUITY
FOR THE YEAR ENDED 31 DECEMBER 2021

Share 
capital 
£000 

Share 
option 
reserve 
£000 

Share 
premium 
£000 

Merger 
reserve 
£000 

Note 

Capital and
reserves
attributable to
the owners of
Retained 
earnings  NAHL Group plc
£000

£000 

Balance at  
1 January  
2020 

115 

3,389 

14,595  (66,928) 104,593 

55,764

Total comprehensive income for the year
Loss for the year 

Total comprehensive 
income 

– 

– 

Transactions with owners, recorded directly in equity
Issue of share capital  
Share-based payments 

21 
22 

– 
– 

– 

– 

– 
523 

Total transactions with owners, recorded 
directly in equity 

– 

523 

– 

– 

– 
– 

– 

– 

– 

– 
– 

– 

(225) 

(225)

(225) 

(225)

– 
– 

– 

–
523

523

Balance at
31 December 2020 

Total comprehensive income  
for the year
Profit for the year 

Total comprehensive 
income 

Transactions with owners, recorded  
directly in equity
Issue of share capital  
Share-based payments 

21 
22 

Total transactions with owners,  
recorded
directly in equity 

Balance at
31 December 2021 

115 

3,912 

14,595  (66,928) 104,368 

56,062

– 

– 

1 
– 

– 

– 

– 
400 

1 

400 

– 

– 

– 
– 

– 

– 

– 

– 
– 

– 

156 

156 

– 
– 

– 

156

156

1
400

401

 116 

4,312 

14,595   (66,928) 104,524 

56,619

The notes on pages 94–127 form part of these financial statements.

92 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

CONSOLIDATED CASH FLOW STATEMENT
FOR THE YEAR ENDED 31 DECEMBER 2021

Cash flows from operating activities 
Profit for the year 
Adjustments for: 
Profit attributable to members’ non-controlling interests in LLPs 
Property, plant and equipment depreciation 
Right of use asset depreciation 
Amortisation of intangible assets 
Financial income 
Financial expense 
Share-based payments 
Taxation 

Decrease in trade and other receivables 
(Decrease)/Increase in trade and other payables 

Interest paid 
Tax paid 

Net cash generated from operating activities 

Cash flows from investing activities 
Acquisition of property, plant and equipment 
Acquisition of intangible assets 
Interest received 
Disposal of subsidiary net of cash disposed of1 

Net cash used in investing activities 

Cash flows from financing activities 
Repayment of borrowings 
Issue of share capital 
Facility arrangement fees 
Principal element of lease payments 
Drawings paid to LLP members 

Net cash used in financing activities 

Net (decrease)/increase in cash and cash equivalents 
Cash and cash equivalents at 1 January 

Cash and cash equivalents at 31 December 

Note 

2021 
£000 

2020
£000

  156 

 (225)

16 
17 
15 
7 
8 

21 

3,451 
171 
306 
1,195 
(85) 
555 
400 
79 

6,228 
1,012 
(1,337) 

5,903 
(398) 
(365) 

5,140 

(281) 
(339) 
2 
– 

(618) 

(2,000) 

1 
(90) 
(166) 
(3,418) 

(5,673) 

(1,151) 
3,609 

2,458 

4,115
169
430
1,345
(168)
585
523
2

6,776
2,223
2,945

11,944
(469)
(450)

11,025

(269)
(820)
10

(1,273)1

(2,352)

(3,750)
–
(121)
(558)
(3,199)

(7,628)

1,045
2,564

3,609

1.  The Group disposed of its interest in National Law Associates LLP on 2 January 2020 and de-consolidated its results from this point. 

The above consolidated cash flow statement should be read in conjunction with the accompanying notes.

NAHL Group Plc Annual Report and Accounts 2021 

93

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

NOTES TO THE FINANCIAL STATEMENTS

1 Accounting policies
Basis of preparation
Consolidated Financial Statements
NAHL Group plc (the “Company”) is a public 
company limited by shares registered, incorporated 
and domiciled in England and Wales. The registered 
number is 08996352 and the registered address 
is Bevan House, Kettering Parkway, Kettering, 
Northants, England, NN15 6XR.

The Consolidated Financial Statements for the 
year ended 31 December 2021 have been prepared 
in accordance with International Accounting 
Standards in conformity with the requirements of 
the Companies Act 2006.

The consolidated financial information has been 
prepared on a going concern basis and under the 
historical cost convention.

The following accounting policies have been applied 
consistently year on year except where new policies 
have been adopted as stated below.

Going concern
In determining the appropriate basis of preparation 
of the financial statements, the Directors are 
required to consider whether the Company and 
Group can continue in operational existence for the 
foreseeable future.

The Audit & Risk Committee has reviewed 
the Going Concern assessment prepared by 
management. The assessment includes detailed 
financial forecasts covering the Group’s adopted 
strategy and considers a range of sensitivities. The 
period considered by the forecasts is to the end of 
June 2023, being approximately 12 months from 
the date of signing of the 2021 Annual Report and 
financial statements. The key assumptions in the 
forecasts are a) number of PI enquiries generated 
and b) placement of these enquiries (into our panel, 
our joint venture law firms or NAL). The going 
concern assessment focuses on two key areas, 
being the ability of the Group to meet its debts as 
they fall due and being able to operate within its 
banking facility.

The Group has access to a £20.0m revolving credit 
facility (RCF) with its bankers and at the time of 
writing, it has drawn £18.0m of this facility and has 
cash of £1.9m. In all of the sensitivities the Group 
has modelled it would have sufficient liquidity within 
its current RCF to meet its liabilities as they fall due 
and would not need to access additional funding.

The Group’s RCF is subject to quarterly covenant 
testing. The Group has modelled a worst-case 
scenario, assuming that volumes remain at 2021 
levels, and has then considered the options it would 
have available to mitigate against any shortfall in 
profits and cash. Under this scenario, the Group 
would be able to implement sufficient mitigating 
actions in order to operate within its covenants. The 
likelihood of this scenario occurring is considered 
to be remote and therefore the directors consider 
the Going Concern basis of accounting to be 
appropriate.

Considering the above, the Directors have a 
reasonable expectation that the Company and 
Group have adequate resources to continue in 
existence for the foreseeable future and have 
concluded it is appropriate to adopt the going 
concern basis of accounting in the preparation of 
the financial statements.

Basis of consolidation
The financial statements represent a consolidation 
of the Company and its subsidiary undertakings as 
at the Statement of Financial Position date and for 
the year then ended. In accordance with IFRS 10 
the definition of control is such that an investor 
has control over an investee when: a) it has power 
over the investee, b) it is exposed, or has the rights, 
to variable returns from its involvement with the 
investee and c) has the ability to use its power 
to affect its returns. All three of these criteria 
must be met for an investor to have control over an 
investee. All subsidiary undertakings for which the 
Group meets these three criteria for control have 
been consolidated in the Group’s results.

The consolidated financial information incorporates 
the results of business combinations using the 
purchase method. In the Group statement of 
financial position, the acquiree’s identifiable assets, 
liabilities and contingent liabilities are initially 
recognised at their fair values at the acquisition 
date. The results of acquired operations are 
included in the Group statement of comprehensive 
income from the date on which control is obtained. 
They are deconsolidated from the date on which 
control ceases. Acquisition costs are expensed as 
incurred. This policy does not apply on the 
acquisition of Consumer Champion Group Limited 
for which reverse acquisition accounting has been 
applied. 

94 

NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

1 Accounting policies continued

Key sources of estimation uncertainty
Revenue recognition – provision of legal 
services 
There is a significant element of estimation in 
determining the transaction price for revenue 
in relation to the provision of legal services for 
personal injury claims. Due to the nature of 
personal injury claims, the revenue the Group earns 
from a case is variable and dependent upon a) the 
stage at which a claim settles as this will determine 
the fixed fee and b) the final damages awarded 
to the client, of which the Group recognises 
a percentage as revenue. The Group must 
therefore estimate the revenue it expects to earn 
from a case once the first milestone is achieved 
(admission of liability). This estimation is based 
on an expected value method and assumes that 
cases can be grouped into categories of a similar 
nature (i.e. RTA vs. Non-RTA) that have similar 
characteristics. This assumption is considered 
appropriate as ultimately all cases follow one 
of a number of routes in the claims process. 
Management uses historical experience of the 
likelihood of claims settling at each stage and 
the average fee earned when a claim settles at 
each stage to estimate the transaction price. This 
estimate is revised as a claim moves through 
the process. No revenue is recognised until the 
first milestone is reached, being admission of 
liability, as it is at this point that it becomes highly 
probable that a case will succeed and therefore 
there is less risk of significant revenue write-offs 
in the future. Profits and losses arising from the 
differences in the estimated fee and the final fee 
are recognised on settlement of a case.

At the year-end, the Group has contract asset 
balances of £5,242,000 (2020: £5,046,000) 
calculated using this estimation technique.

Critical accounting judgements and key 
sources of estimation uncertainty
The preparation of financial statements in 
conformity with IFRS requires management 
to make judgements and estimates that affect 
the application of accounting policies and the 
reported amounts of assets, liabilities, income and 
expenses. Estimates are based on past experience 
and other reasonable assessment criteria. Actual 
results may differ from these estimates. Estimates 
and underlying assumptions are reviewed on 
an ongoing basis and revisions to accounting 
estimates are recognised in the year in which 
the estimates are revised and in any future years 
affected.

In accordance with IAS 1 the Group is required to 
disclose critical accounting judgements and key 
sources of estimation uncertainty.

Critical accounting judgements
Within its Consumer Legal Services division, 
the Group has interests in two Limited Liability 
Partnerships (LLPs) in conjunction with third party 
law firms. The LLPs are called Your Law LLP and 
Law Together LLP. 

The Group has exercised judgement by considering 
the criteria for consolidation in IFRS 10 and has 
determined that each LLP meets the definition of a 
subsidiary and is therefore required to be included 
within the Group’s results. 

Key to this determination is that each LLP is run 
by a management board, which is responsible 
for the day-to-day operations, decision-making 
and strategic development of the LLPs. Through 
its 100% subsidiary, Project Jupiter Limited, the 
Group has determined that it exercises control over 
these LLPs as it is entitled to appoint the majority of 
members to each of the management Boards, with 
the remainder being appointed by the respective 
third-party law firm.

In accordance with IFRS 10 Consolidated Financial 
Statements and given that the Group has overall 
control, the results and net assets of the LLPs have 
been consolidated within these financial statements 
with a corresponding liability recognised for the 
other member firms’ share of profit.

NAHL Group Plc Annual Report and Accounts 2021 

95

Financial Statements

1 Accounting policies continued

Statutory and non-statutory measures 
The financial statements contain all the statutory 
measures and disclosures required under IFRS, 
which is the financial reporting framework adopted 
by the Group. In addition to these measures, 
management monitors a number of non-statutory, 
alternative performance measures (APMs) as part 
of its internal performance monitoring and when 
assessing the future impact of operating decisions. 

The APMs allow a year-on-year comparison of 
the underlying performance of the business by 
removing the impact of items occurring either 
outside the normal course of operations or as a 
result of intermittent activities, such as acquisitions 
or strategic projects.

The Directors have presented these APMs in the 
Strategic Report because they believe they provide 
additional useful information for shareholders on 
underlying business trends and performance. As 
these APMs are not defined by IFRS, they may not 
be directly comparable to other companies’ APMs. 
They are not intended to be a substitute for, or 
superior to, IFRS measurements and the Directors 
recommend that the IFRS measures should also 
be used when users of this document assess the 
performance of the Group.

The APMs used in the Strategic Report are 
defined in the table on page 97. There have been 
no changes to the principles for identify adjusting 
items from 2020. The key adjusting items in 
arriving at the APMs are as follows:

  Exceptional items are non-recurring items that 
are material by nature and separately identified 
to allow for greater comparability of underlying 
Group operating results year-on-year. Examples of 
exceptional items in the current and/or previous 
years include reorganisation and restructuring 
costs; revaluation of liability associated with 
legacy ATE products; and acquisition related 
costs. Exceptional costs are separately identified 
to allow for greater comparability of underlying 
Group operating results year-on-year.

Recoverability of trade receivables 
Trade receivables are reflected net of an estimated 
provision for impairment losses. In line with IFRS 
9, the Group uses an expected credit loss model 
to determine the provision for doubtful debts and 
also specific provisions for balances for which it has 
specific concerns over recoverability. The expected 
credit loss model involves segmenting debtors 
into groups and applying specific percentages to 
each of these debtor groupings. The Group has 
considered the profile of its debtor balance and has 
determined that a grouping based on credit terms 
is considered to be appropriate given the significant 
level of debt on extended credit terms.

These groupings are based on those debtors 
due on standard terms, 6–12 month terms, 12– 
18 month terms and 18–24 month terms with 
higher percentages being applied the longer the 
term with the view that there is a greater risk of 
unforeseen circumstances arising the further away 
the settlement date. Standard debtors are also 
then reviewed for those past due and a percentage 
applied to those that are current, between 30–60 
days, 60–90 days and 90+ days overdue. See note 
24 for further information. At the year end, the 
Group had provisions for receivables of £740,000 
(2020: £673,000) calculated using this method. 
The percentages applied to each grouping of 
debtors ranged from 0.5% to 35% with the final 
provision equating to 3.0% of the total gross trade 
receivables and accrued income balances.

New standards and amendments adopted by 
the Group 
There are no new or amended standards applicable 
for the current reporting period.

New standards, interpretations and amendments 
not yet effective 
There are no new standards, interpretations and 
amendments that are not yet effective and that 
would be expected to have a material impact on the 
Group in the current or future reporting periods and 
on foreseeable future transactions.

Profit attributable to members’ non-controlling 
interests in LLPs

Profit attributable to member’s non-controlling 
interests in LLPs represents the operating profit 
for the year which is attributable to minority 
members in our LLP subsidiaries under the terms 
of the partnership agreements. It is presented as a 
separate expense outside of the operating profit of 
the Group for the year.

96 

NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

1 Accounting policies continued

Nature of 
measure

Underlying 
operating 
profit

Related 
IFRS 
measure

Operating 
profit

Related 
IFRS source

Definition

Use/relevance

Consolidated 
income 
statement

Based on the related IFRS 
measure but excluding 
exceptional items.

Underlying 
operating 
cash flow

Cash 
flow from 
operating 
activities

Consolidated 
cash flow 
statement

Underlying 
cash 
conversion

Not defined 
by IFRS

n/a

Free Cash 
Flow

Not defined 
by IFRS

n/a

Based on the related IFRS 
measure but excluding 
cash flows in respect of 
the items excluded from 
underlying operating 
profit as described above.

Calculated as underlying 
operating cash flow 
divided by underlying 
operating profit.

Calculated as net cash 
generated from operating 
activities less net 
cash used in investing 
activities (excluding any 
disposals of subsidiaries) 
less payments made to 
partner LLP members 
and less principal element 
of lease payments. 

Allows management and users 
of the financial statements to 
assess the underlying trading 
results after removing material, 
non-recurring items that are 
not reflective of the core 
trading activities and allows 
comparability of core trading 
performance year-on-year.

Provides management with an 
indication of the amount of cash 
available for discretionary 
investing or financing after 
removing material non-recurring 
expenditure that does not reflect 
the underlying trading operations 
and allows management to 
monitor the conversion of 
underlying profit into cash.

NAHL Group Plc Annual Report and Accounts 2021 

97

Financial Statements

1 Accounting policies continued

Nature of 
measure

Underlying 
Basic EPS 

Related 
IFRS 
measure

Basic EPS

Related 
IFRS source

Definition

Use/relevance

Consolidated 
income 
statement

Based on the related IFRS 
measure but calculated 
using underlying profit 
after tax. 

Working 
capital

Consolidated 
statement of 
cash flows

Movement in 
receivables 
and 
movement 
in payables

Net cash/
(debt)

Not defined 
by IFRS

Consolidated 
cash flow 
statement

Working capital is not 
defined by IFRS. This is 
defined by management 
as being the movement 
in trade and other 
receivables less the 
movement in trade and 
other payables.

Net debt is defined 
as cash and cash 
equivalents less interest 
bearing borrowings net of 
loan arrangement fees.

Allows management and users 
of the financial statements to 
assess the underlying trading 
results after removing material, 
non-recurring items that 
are not reflective of the core 
trading activities and allows 
comparability of core trading 
performance year-on-year.

Allows management to  
assess the short-term cash  
flows from movements in the 
more liquid assets.

Allows management to monitor 
the overall level of debt in the 
business. As stated in the 
strategic report, loan funding 
is key to the Group’s future 
strategy as an increasing 
proportion of profits and cash 
flows are deferred until case 
settlement.

A reconciliation of each measure is provided as follows:

Underlying operating profit

IFRS measure – operating profit 
Exceptional items 

Underlying operating profit 

2021 
£000 

4,156 
– 

4,156 

2020
£000

4,309
1,350

5,659

98 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
Financial Statements

Underlying operating cash flow and underlying cash conversion:

2021 

2021 
Underlying  Exceptional 
items 
operations 
£000 
£000 

2020 
2020 
2021  Underlying  Exceptional 
items 
Total 
£000 
£000 

operations 
£000 

Operating profit 
Share-based payments 
Depreciation and amortisation  
Decrease in trade/other receivables 
(Increase)/decrease in trade/other payables 
Underlying operating cash flow 

4,156 
400 
1,672 
1,012 
(999) 
6,241 

4,156 
– 
400 
– 
1,672 
– 
1,012 
– 
(338) 
(1,337) 
(338)  5,903 

5,659 
523 
1,944 
2,223 
2,607 
12,956 

(1,350) 
– 
– 
– 
338 
(1,012) 

150.2% 

  228.9% 

Operating cash conversion 
Interest paid 
Tax paid 
Net cash generated from operating activities 
Net cash used in investing activities 
(excluding disposals of subsidiaries) 
Lease payments 
Issue of share capital 
Facility arrangement fees 
Payments to non-controlling interests 
Free cash flow 

Underlying basic EPS: 

2020
Total
£000

4,309

523
1,944
2,223
2,945

11,944

  (469)
(450)
11,025

(1,079)
(558)

(121)
(3,199)

6,068

2020
£000

(225)
1,350
(257)

868

(398) 
(365) 
5,140 

(618) 
(166) 
1 
(90) 
(3,418) 
849 

–

2021 
£000 

156 
– 
– 
156 

IFRS measure – Profit/(loss) for the year attributable to shareholders 
Exceptional items 
Tax effect of the above 
Underlying profit for the year attributable to shareholders 

Weighted average number of shares (note 23) 
Underlying basic EPS (pence) 

46,245,345 
0.3p 

46,238,878

1.9p

Working capital: 
Working capital movements for 2020 take into account the disposal of National Law Partners on 1 January 
2020

Movement in trade and other receivables 
Movement in trade and other payables 
Working capital 
Movement in interest accruals 
Movement in corporation tax debtor 
Movement in financing accruals 
IFRS measure – movement in trade and other receivables  
less movement in trade and other payables 

Net debt is defined in note 29.

2021 
£000 

1,012 
(1,337) 
(325) 
(84) 
(47) 
– 

(456) 

2020
£000

2,223
2,945

5,168
(158)
15
110

5,135

NAHL Group Plc Annual Report and Accounts 2021 

99

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

1 Accounting policies continued

Revenue
Marketing services
Consumer Legal Services – Solicitor income 
(personal injury) 
Marketing services resulting in the provision of 
enquiries to Panel Law Firms. Management have 
determined that there is a single performance 
obligation being the provision of marketing 
services. These services include generating 
enquiries through web-based channels, triaging 
of enquiries and provision of call centre support 
staff on a daily basis. As the Group undertakes 
this service on behalf of its customers, the service 
is considered to be simultaneously delivered and 
consumed by the customer and so it is considered 
to be satisfied over time. The transaction price 
is set for each customer based on a cost plus 
margin model, and is allocated to the performance 
obligation using the input method based on the 
costs incurred of providing the service. Invoices 
are raised monthly for the services provided in 
that month and the revenue for that month is 
recognised at this point.

Consumer Legal Services – Conveyancing and 
surveyor instructions (residential property) 
Homeward Legal utilises online marketing to target 
homebuyers and sellers in England and Wales 
to generate leads and instructions which it then 
passes to Panel Law Firms and surveyors in the 
conveyancing sector for a fixed cost.

Management consider there to be one performance 
obligation being the delivery of the instruction to 
the Panel Law Firms and surveyors. Revenue is 
recognised at a point in time being the transfer of 
instruction to the Panel Law Firm or surveyor as it 
is at this point at which the Group has no further 
obligations in respect of the instruction and so 
control of the instruction passes to the customer. 
The full transaction price being the contractually 
agreed upon fixed fee per instruction is recognised 
as revenue at this point.

Service provision
Consumer Legal services – provision of 
resource (residential property) 
Income from the outsourcing of employees 
who provide services to process conveyancing 
transactions for homebuyers and sellers in 
England and Wales. Management consider 
there to be one performance obligation being 
the completion of the transaction as until 
this point there is no entitlement to revenue. 
The full transaction price being the agreed 
upon fee is recognised at this point.

Consumer Legal Services – Provision of legal 
services  
Income from the provision of legal services for 
personal injury claims on a ‘no win – no fee’ 
arrangement. Management consider that this 
service comprises a single distinct performance 
obligation, being the provision of legal services to 
the customer and the transaction price is allocated 
to this single performance obligation. Revenue is 
recognised once control of the service is passed to 
the customer which is considered to be over time 
as the customer simultaneously receives and 
consumes the service provided.

The transaction price is variable in nature as on 
settlement of a successful case the Group will be 
entitled to a fee consisting of a) fixed recoverable 
costs recouped from the liable third party. These 
fees are set by the MoJ and the value of fees 
claimed are determined based on the stage 
at which the claim settles and the value of the 
claim damages; and b) a percentage of awarded 
damages. As these amounts are unknown at 
the outset of a case, management estimate the 
transaction price based on an expected value 
method. The expected value is based on prior 
and historical knowledge and experience of case 
settlement and is considered appropriate as all 
cases follow the same process.

Management consider that it is appropriate 
to recognise revenue on an output basis using 
milestones. Due to the nature of personal injury 
claims, the revenue receivable from progressing a 
case is not directly attributable to the hours worked 
as a case can still fail despite hours being worked 
on it. Due to the no-win, no-fee arrangement, 
no revenue would be receivable if the case fails 
despite the hours worked. An input method is 
therefore considered to be inappropriate. An output 
approach based on key milestones to progress 
a case is therefore considered to be appropriate 
as it best reflects the value of the service to the 
customer. These milestones are 1. Admission of 
liability and 2. Settlement of the case. No revenue 
is recognised up until the first milestone, admission 
of liability, has been achieved as it is at this point 
that it becomes highly probable that recognising 
revenue would not lead to a reversal in the future. 
A proportion of the total transaction price is 
recognised once the first milestone has been 
achieved. This proportion is determined based on 
the average percentage of time worked to bring the 
claim to that point based on historic performance 
across all cases of a similar nature.

100 

NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

1 Accounting policies continued

Critical Care – Case management services  
Case management support within the medico-legal 
framework for multi-track cases. Management 
consider that the performance obligation is the 
provision of case management support and as the 
service is simultaneously delivered and consumed 
by the customer then revenue is measured over 
time based on an input approach being the hours 
worked by each consultant. The transaction 
price, being the contractually agreed upon hourly 
fee rate, is allocated on a per hour basis. Revenue is 
invoiced monthly based on the hours worked in that 
month and recognised at this point.

Expert Reports
Critical Care – Expert witness revenue  
Provision of expert witness reports. In line with 
IFRS 15, revenue is measured on satisfaction of the 
performance obligation when control of the report 
is passed to the customer. Management consider 
there to be one performance obligation which is 
the provision of the expert witness report. Where 
the terms of the contract allow for an enforceable 
right to payment for work performed to date an 
adjustment is made at each month end to accrue 
for revenue on any such reports in progress. This 
is subsequently reversed and the full transaction 
price recognised on provision of the final report.

Consumer Legal Services – Search reports 
Provision of search reports. Management consider 
there to be one performance obligation being the 
delivery of the search report. Revenue is recognised 
at a point in time being the transfer of the report to 
the customer. The full transaction price being the 
contractually agreed upon fixed fee per report is 
recognised as revenue at this point.

Product provision
Consumer Legal services – Product income 
Commissions received from product providers for 
the sale of additional products to the Panel Law 
Firms. Revenue is recognised at a point in time on 
satisfaction of the performance obligation being 
the sale of the product to a Panel Law Firm with 
provisions in place for clawbacks. 

Pre-LASPO ATE – Revenue from commissions 
received from the insurance provider for the use of 
after the event policies by Panel Law Firms. From 1 
April 2013, this product was no longer available as a 
result of LASPO regulatory changes. Consequently, 
there is a remaining liability which is being unwound 
through revenue as historic cases are settled.

All revenue is stated net of Value Added Tax. The 
entire revenue arose in the United Kingdom.

Government grants
As a result of the economic impact of the 
COVID-19 pandemic, the Group made use of the 
Government’s Coronavirus Job Retention Scheme.

Income from this scheme has been accounted 
for under IAS 20: Government Grants and is 
included within the consolidated statement of 
comprehensive income as a deduction from the 
corresponding expense.

Goodwill
Goodwill represents the excess of the fair value 
of the consideration given over the fair value of 
the Group’s share of the net identifiable assets of 
the acquired subsidiary at the date of acquisition. 
Goodwill is not amortised but is tested for 
impairment annually and again whenever indicators 
of impairment are detected and is carried at cost 
less any provision for impairment. Any impairment 
is recognised in the statement of comprehensive 
income.

Other intangible assets
Other intangible assets that are acquired by the 
Group and have finite useful lives are measured 
at cost less accumulated amortisation and 
any accumulated impairment losses. Software 
assets are measured at the cost of bringing 
the asset into use. This may include externally 
incurred consultant costs or a proportion of 
internal time and salary where internal resources 
have been used to build the asset. Internally 
allocated time is based on hours spent bringing 
the asset into use multiplied by hourly salary 
rates. Technology related intangibles, contract 
related intangibles and brand names were 
acquired through business combinations. These 
were independently valued and determined 
to be separately identifiable from goodwill.

Amortisation
Intangible assets are amortised on a straight-line 
basis over their estimated useful lives as follows:

Technology related 
intangibles

Contract related 
intangibles

Brand names

Software

–

–

–

–

5 to 10 years

3 to 10 years

3 to 10 years

3 to 5 years

No amortisation is charged on assets under 
construction until the point they are brought  
into use.

NAHL Group Plc Annual Report and Accounts 2021 

101

Financial Statements

1 Accounting policies continued

Property, Plant and Equipment
Property, plant and equipment are measured at 
cost less accumulated depreciation.

Depreciation
Depreciation is calculated to write off the cost, 
less estimated residual value, of property, plant 
and equipment by equal instalments over their 
estimated useful economic lives as follows:

Fixtures and fittings – 3 to 10 years

Lease assets
The Group as a lessee 
For any new contracts entered into, on or after 
1 January 2020, the Group considers whether a 
contract is, or contains a lease. A lease is defined 
as ‘a contract, or part of a contract, that conveys 
the right to use an asset (the underlying asset) for 
a period of time in exchange for consideration’. To 
apply this definition the Group assesses whether 
the contract meets three key evaluations which are 
whether:

  the contract contains an identified asset, which 
is either explicitly identified in the contract or 
implicitly specified by being identified at the time 
the asset is made available to the Group

  the Group has the right to obtain substantially all 
of the economic benefits from use of the identified 
asset throughout the period of use, considering its 
rights within the defined scope of the contract

  the Group has the right to direct the use of the 
identified asset throughout the period of use. The 
Group assesses whether it has the right to direct 
‘how and for what purpose’ the asset is used 
throughout the period of use.

Measurement and recognition of leases as a 
lessee 
At lease commencement date, the Group 
recognises a right-of-use asset and a lease liability 
on the balance sheet. The right-of-use asset is 
measured at cost, which is made up of the initial 
measurement of the lease liability, any initial direct 
costs incurred by the Group, an estimate of any 
costs to dismantle and remove the asset at the 
end of the lease, and any lease payments made in 
advance of the lease commencement date (net of 
any incentives received).

The Group depreciates the right-of-use assets on a 
straight-line basis from the lease commencement 
date to the earlier of the end of the useful life of 
the right-of-use asset or the end of the lease term. 
The Group also assesses the right-of-use asset for 
impairment when such indicators exist.

At the commencement date, the Group measures 
the lease liability at the present value of the lease 
payments unpaid at that date, discounted using 
the interest rate implicit in the lease if that rate 
is readily available or the Group’s incremental 
borrowing rate. Lease payments included in the 
measurement of the lease liability are made up 
of fixed payments (including in substance fixed), 
variable payments based on an index or rate, 
amounts expected to be payable under a residual 
value guarantee and payments arising from options 
reasonably certain to be exercised.

Subsequent to initial measurement, the liability 
will be reduced for payments made and increased 
for interest. It is remeasured to reflect any 
reassessment or modification, or if there are 
changes in in-substance fixed payments. When the 
lease liability is remeasured, the corresponding 
adjustment is reflected in the right-of-use asset, or 
profit and loss if the right-of-use asset is already 
reduced to zero.

The Group has elected to account for short-term 
leases and leases of low-value assets using the 
practical expedients. Instead of recognising a 
right-of-use asset and lease liability, the payments 
in relation to these are recognised as an expense in 
profit or loss on a straight-line basis over the lease 
term.

Taxation
Tax in the statement of comprehensive income for 
the year comprises current and deferred tax. Tax 
is recognised in the 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 or receivable on the taxable income 
or loss for the year, using tax rates enacted or 
substantively enacted at the balance sheet date, 
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 

102 

NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

1 Accounting policies continued

of the carrying amount of assets and liabilities, 
using tax rates enacted or substantively enacted 
at the balance sheet date. A deferred tax asset is 
recognised only to the extent that it is probable that 
future taxable profits will be available against which 
the temporary difference can be utilised.

Trade and other receivables
Trade and other receivables are recognised initially 
at fair value. Subsequent to initial recognition, 
trade and other receivables are stated at amortised 
cost using the effective interest method, less any 
impairment losses calculated in line with IFRS 9.

Classification of financial instruments 
issued by the Group
Financial instruments issued by the Group are 
treated as equity (i.e. forming part of equity) only 
to the extent that they meet the following two 
conditions:

a)  they include no contractual obligations upon 
the Company (or Group as the case may be) 
to deliver cash or other financial assets or to 
exchange financial assets or financial liabilities 
with another party under conditions that are 
potentially unfavourable to the Company (or 
Group); and

b)  where the instrument will or may be settled in the 
Company’s own equity instruments, it is either 
a non-derivative that includes no obligation to 
deliver a variable number of the Company’s own 
equity instruments or is a derivative that will be 
settled by the Company’s exchanging a fixed 
amount of cash or other financial assets for a 
fixed number of its own equity instruments.

To the extent that this definition is not met, the 
proceeds of issue are classified as a financial 
liability. Where the instrument so classified 
takes the legal form of the Company’s own 
shares, the amounts presented in these 
financial statements for called up share 
capital and share premium account exclude 
amounts in relation to those shares.

Finance payments associated with financial 
liabilities are dealt with as part of interest 
payable and similar charges. Finance payments 
associated with financial instruments that 
are classified as part of shareholders’ funds 
are dealt with as appropriations in the 
reconciliation of movements in equity.

Financial assets and liabilities
The Group’s principal financial instruments 
comprise cash and cash equivalents, trade and 
other receivables, trade and other payables and 
interest bearing borrowings.

Trade and other payables
Trade and other payables are recognised initially at 
fair value. Subsequent to initial recognition, trade 
and other payables are stated at amortised cost 
using the effective interest method.

Cash and cash equivalents
Cash and cash equivalents comprise cash 
balances. Cash and cash equivalents are repayable 
on demand and are recognised at their carrying 
amount.

Interest-bearing borrowings
Interest-bearing borrowings are recognised 
initially at fair value less attributable transaction 
costs. Subsequent to initial recognition, 
interest-bearing borrowings are stated at 
amortised cost using the effective interest 
method, less any impairment losses.

Recoverable disbursements and Disbursements 
payable
Disbursement payables represent the balance 
of disbursements incurred in the processing of 
personal injury claims. These disbursements will 
ultimately be billed on settlement of a case or 
recovered from insurance if a case should fail and 
so the recoverable disbursements represents 
the value of disbursements still to be billed. 
Disbursement payables and receivables are 
recognised initially at fair value and subsequent 
to initial recognition, are stated at amortised cost 
using the effective interest method.

Member capital and current accounts
Member capital and current accounts represent 
the balances owed to non-controlling members’ 
in the LLPs. These consist of any capital advances 
and unpaid allocated profits as at the year end. 
Members capital and current accounts are 
classified as financial liabilities and are recognised 
initially at fair value. Subsequent to initial 
recognition, members capital and current accounts 
are stated at amortised cost using the effective 
interest method.

NAHL Group Plc Annual Report and Accounts 2021 

103

Financial Statements

1 Accounting policies continued

Employee share schemes
The share option plans allow employees of the 
Group to acquire shares of the Company. The 
fair value of options granted is recognised as an 
employee expense with a corresponding increase in 
equity. The fair value is measured at grant date and 
spread over the period during which the employees 
become unconditionally entitled to the options. The 
fair value of the options granted is measured using 
an option pricing model, taking into account the 
terms and conditions upon which the options were 
granted. The amount recognised as an expense 
is adjusted to reflect the actual number of share 
options that are expected to vest except where 
forfeiture is only due to share prices not achieving 
the threshold for vesting. 

Exceptional items
Exceptional items are non-recurring items that 
are material by nature and separately identified 
to allow for greater comparability of underlying 
Group operating results year-on-year. Examples of 
exceptional items in the current and/or previous 
years include reorganisation and restructuring 
costs; revaluation of liability associated with legacy 
ATE products; and acquisition related costs.

Exceptional costs are separately identified to allow 
for greater comparability of underlying Group 
operating results year on year.

Impairment
The carrying amounts of the Group’s non- financial 
assets, other than deferred tax assets, are reviewed 
at each reporting date to determine whether there 
is any indication of impairment.

If any such indication exists, then the asset’s 
recoverable amount is estimated. For goodwill, and 
intangible assets that have indefinite useful lives or 
that are not yet available for use, the recoverable 
amount is estimated each year at the same time.

The recoverable amount of an asset or CGU is 
the greater of its value in use and its fair value 
less costs to sell. In assessing value in use, the 
estimated future cash flows are discounted to their 
present value using a pre-tax discount rate that 
reflects current market assessments of the time 
value of money and the risks specific to the asset. 

For the purpose of impairment testing, assets 
that cannot be tested individually are grouped 
together into the smallest group of assets that 
generates cash inflows from continuing use that 
are largely independent of the cash inflows of other 
assets or groups of assets (the Cash Generating 
Unit or CGU). The goodwill acquired in a business 
combination, for the purpose of impairment testing, 
is allocated to CGUs. For the purposes of goodwill 
impairment testing, CGUs to which goodwill has 
been allocated are aggregated so that the level 
at which impairment is tested reflects the lowest 
level at which goodwill is monitored for internal 
reporting purposes. Goodwill acquired in a business 
combination is allocated to groups of CGUs that 
are expected to benefit from the synergies of the 
combination.

An impairment loss is recognised if the carrying 
amount of an asset or its CGU exceeds its 
estimated recoverable amount. Impairment losses 
are recognised in the statement of comprehensive 
income. Impairment losses recognised in respect 
of CGUs are allocated first to reduce the carrying 
amount of any goodwill allocated to the units, and 
then to reduce the carrying amounts of the other 
assets in the unit (group of units) on a pro-rata 
basis.

An impairment loss in respect of goodwill is not 
reversed. In respect of other assets, impairment 
losses recognised in prior periods are assessed at 
each reporting date for any indications that the loss 
has decreased or no longer exists. An impairment 
loss is reversed if there has been a change in the 
estimates used to determine the recoverable 
amount. An impairment loss is reversed only to the 
extent that the asset’s carrying amount does not 
exceed the carrying amount that would have been 
determined, net of depreciation or amortisation, if 
no impairment loss had been recognised. 

Pensions
The Group operates a stakeholder defined 
contribution pension scheme for employees. The 
assets of the scheme are held separately from 
those of the Company. The annual contributions 
payable are charged to the statement of 
comprehensive income.

104 

NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

1 Accounting policies continued

Retained earnings
Retained earnings represents the cumulative 
historical profits of the Group less historical losses. 

Financial income and expenses
Interest income and interest payable is recognised 
in the consolidated statement of comprehensive 
income as it accrues, using the effective interest 
method. Issue costs of borrowings are initially held 
on balance sheet within the fair value of interest-
bearing borrowings and are subsequently expensed 
to the statement of comprehensive income over 
the contractual life of the associated borrowings.

Dividends
Dividend distribution to the Company’s 
shareholders is recognised in the Group’s financial 
statements in the period in which the dividends are 
approved by the Company’s shareholders or, in the 
case of interim dividends, when paid.

Member drawings
Drawings are made to members in line with the 
provisions as stated in the partnership agreements. 
Members may draw an amount not in excess of 
their profit share for the relevant accounting period 
and drawings may be limited depending on the cash 
requirements of the LLP. Drawings are recognised 
once paid.

Share premium account 
The share premium account represents the excess 
of amounts paid per share above the nominal cost 
of each share. 

Share option reserve
The share option reserve is the corresponding 
charge to equity in respect of the IFRS 2 share base 
payment charge.

The share option reserve forms part of distributable 
reserves and should the Group need to make 
a distribution, the share option reserve will be 
transferred to retained earnings. 

Merger reserve
The merger reserve represents the excess of 
the fair value of shares acquired through share 
for share exchange. In 2014 NAHL Group plc 
declared a bonus issue of a single deferred share 
of £0.0001 (a Deferred Share) with a share 
premium of £50,000,000. This transaction 
resulted in £50,000,000 of the merger reserve 
being transferred to the share premium account. 
In 2015 a further amount standing to the credit 
of the Company’s merger reserve in the sum of 
£16,928,000 was capitalised by way of a bonus 
issue of newly created Capital Reduction Shares.

NAHL Group Plc Annual Report and Accounts 2021 

105

Financial Statements

2 Operating segments

Year ended 
31 December 2021  

Consumer 
Legal Services 
£000 

Critical 
Care 
£000 

Shared 
Services 
£000 

Other 
items 
£000 

Underlying  Exeptional 
operations  
£000 

items  Eliminations2 
£000 
£000 

Revenue 
Depreciation and 
amortisation 
Operating profit/ 
(loss) 
Profit attributable to 
non-controlling 
interest members 
in LLPs 
Financial income 
Financial expenses 
Profit/(Loss) 
before tax 
Trade receivables 
Total assets1 
Segment liabilities1 
Capital expenditure 
(including intangibles) 

Year ended
31 December 2020 

Revenue 
Depreciation and 
amortisation 
Operating profit/ 
(loss) 
Profit attributable to 
non-controlling 
interest members 
in LLPs 
Financial income 
Financial expenses 
Profit/(Loss) 
before tax 
Trade receivables 
Total assets1 
Segment liabilities1 
Capital expenditure 
(including intangibles) 

26,583 

12,364 

– 

– 

38,947 

(272) 

(166) 

(363) 

(871) 

(1,672) 

3,726 

3,293 

(1,592) 

(1,271) 

4,156 

(3,451) 
85 
– 

– 
– 
(10) 

– 
– 
(545) 

– 
– 
– 

(3,451) 
85 
(555) 

3,283 
(2,137) 
360 
– 
4,896 
2,999 
29,625 
6,335  79,413 
(17,754)  (1,306)  (3,556) 

(1,271) 
– 
– 
– 

235 
7,895 
115,373 
(22,616) 

60 

326 

234 

– 

620 

29,537 

11,338 

– 

– 

40,875 

(636) 

(137) 

(247) 

(924) 

(1,944) 

– 

– 

– 

– 
– 
– 

– 
– 
– 
– 

– 

– 

– 

Total
£0000

38,947

(1,672)

4,156

(3,451)
85
(555)

– 

– 

– 

– 
– 
– 

– 
– 
(17,506) 
– 

235
7,895
97,867
(22,616)

– 

620

– 

– 

40,875

(1,944)

5,407 

3,594 

(1,895) 

(1,447) 

5,659 

(1,350) 

–  

4,309

(4,115) 
161 
(1) 

– 
6 
(8) 

– 
1 
(576) 

– 
– 
– 

(4,115) 
168 
(585) 

– 
– 
– 

– 
– 
– 

(4,115)
168
(585)

1,452 
3,422 
32,859 
(19,001) 

(2,470) 
3,592 
4,870 
– 
5,990  79,739 
(1,232)  (3,934) 

(1,447) 
– 
– 
– 

1,127 
8,292 
118,588 
(24,167) 

(1,350) 
– 
– 
– 

– 
– 
(17,506) 
– 

(223)
8,292
101,082
(24,167)

540 

244 

305 

– 

1,089 

– 

– 

1,089

1.  Total assets and segment liabilities exclude intercompany loan balances as these are not included in the segment results reviewed by the chief 

operating decision maker.

2.  Eliminations represents the difference between the cost of subsidiary investments included in the total assets figure for each segment and the 

value of goodwill arising on consolidation.

106 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

2 Operating segments continued

Significant customers
No customers account for greater than 10% of the 
total Group revenue (2020: no customers).

Geographic information
All revenue and assets of the Group are based in 
the UK.

Operating segments
The activities of the Group are managed by the 
Board, which is deemed to be the chief operating 
decision maker (CODM). The CODM has identified 
the following segments for the purpose of 
performance assessment and resource allocation 
decisions. These segments are split along product 
lines and are consistent with those reported  
last year. 

Consumer Legal services – Revenue is split 
along three separate streams being: a) Panel 
– revenue from the provision of personal injury 
and conveyancing enquiries to the Panel Law 
Firms, based on a cost plus margin model, b) 
Products – consisting of commissions received 
from providers for the sale of additional products 
by them to the Panel Law Firms, surveys and 
the provision of conveyancing searches and 
c) Processing – in the case of our ABSs and 
self- processing operations, revenue receivable 
from clients for the provision of legal services.

Critical Care – Revenue from the provision of 
expert witness reports and case management 
support within the medico-legal framework for 
multi-track cases.

Shared services – Costs that are incurred in 
managing Group activities or not specifically 
related to a product.

Other items – Other items represent share-based 
payment charges and amortisation charges on 
intangible assets recognised as part of business 
combinations.

Exceptional items – items that are non-recurring 
and that are material by nature and separately 
identified to allow for greater comparability of 
underlying Group operating results year-on-year. 
Examples of exceptional items in the current 
and/or previous years include reorganisation 
and restructuring costs; revaluation of liability 
associated with legacy ATE products; and 
acquisition related costs. Exceptional costs 
are separately identified to allow for greater 
comparability of underlying Group operating results 
year-on-year.

NAHL Group Plc Annual Report and Accounts 2021 

107

Financial Statements

3 Administrative expenses and auditor’s remuneration

Included in the consolidated statement of comprehensive income are the following:

Depreciation of property, plant and equipment 
Depreciation of right of use assets 
Amortisation of intangible assets (not relating to business combinations) 
Amortisation of intangible assets relating to business combinations 
IFRS 9 provision charge 
Government Grants 
Auditor’s remuneration 

The analysis of the auditor’s remuneration is as follows:

Fees payable to the Company’s auditors for the audit of
parent company and consolidated financial statements 

Fees payable to the Company’s auditors for other services:
SAR audit 

4 Exceptional items

Exceptional items included in the income statement are summarised below:

Group strategic and reorganisation costs1 
Group restructure2 
Due diligence costs3 

2021 
  £000 

171 
  306 
  324 
  871 
67 
  (13) 
130 

2020
£000

169
430
421
924
119
(410)
125

2021 
  £000 

2020
£000

125 

120

5 

5

2021 
  £000 

– 
– 
– 

– 

2020
£000

613
399
338

1,350

1. Group strategic and reorganisation costs relate to project costs to implement fundamental strategic plans that fall outside of the core trading 
operations of the business.

2. Group restructure costs largely relate to redundancy costs and other one-off costs associated with the closure of the Chancery Lane office and 
merger of the Residential Property and Personal Injury businesses into a new Consumer Legal Services division. 

3. Due diligence costs consisting of legal and advisory costs in respect of a potential offer made for the Group during the year. 

108 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

5 Staff numbers and costs

The average number of persons employed by the Group (including Directors) during the year,  
analysed by category, was as follows:

Directors 
Others 

Number of Employees

2021 

2 
257 

259 

2020

2
253

255

The Group also has an average of 4 Non-executive directors (2020: 4) who provided services to the Group 
under service contracts. 

The aggregate payroll costs of these persons were as follows: 

Wages and salaries 
Share based payments (see note 22) 
Social security costs 
Other pension costs 

6 Directors’ emoluments

Statutory Directors’ emoluments 

Statutory Directors’ emoluments

Year ended 31 December 2021
Executive Directors
J D Saralis 
Non-Executive
T J M Aspinall 
G D C Kent 
S P Tilleray 
B Phillips 

2021 
£000 

9,298 
400 
859 
223 

10,780 

2020
£000

9,364
523
909
307

11,103

  2021 
  £000 

 444 

2020
£000

771

Salary 
and fees 
£000 

Benefits 
£000 

Annual 
bonus 
£000  

Pension 
£000 

Total
£000

200 

80 
50 
50 
45 

425 

17 

– 
– 
– 
– 

17 

– 

– 
– 
– 
– 

– 

2 

– 
– 
– 
– 

2 

219

80
50
50 
45

444

NAHL Group Plc Annual Report and Accounts 2021 

109

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

6 Directors’ emoluments continued

Year ended 31 December 2020 
Executive Directors 
J R Atkinson1 
J D Saralis 
Non-Executive 
C Brown2 
T J M Aspinall 
G D C Kent 
S P Tilleray 
B Phillips3 

Salary 
and fees 
£000 

Benefits 
£000 

Annual 
bonus 
£000 

Pension 
£000 

Total
£000

159 
162 

62 
58 
47 
48 
23 

13 
16 

– 
– 
– 
– 
– 

559 

29 

– 
– 

– 
– 
– 
– 
– 

– 

2 
2 

– 
– 
– 
– 
– 

4 

174
180

62
58
47
48 
23

592

1. J R Atkinson resigned from the Board on 7 September 2020. Termination payments of £179,000 were made. 

2. C Brown resigned from the Board on 8 October 2020.

3. Brian Phillips was appointed to the Board on 25 June 2020. 

The Group contributed £2,000 to pension schemes in respect of Directors during the year (2020: £4,000). 
The emoluments of the highest paid Director were £219,000 (2020: £353,000).

Key management personnel are those persons having authority and responsibility for planning, directing 
and controlling the activities of the Group. Key management personnel include members of the leadership 
team who are not statutory directors in addition to the main Board. Disclosure of transactions with key 
management is detailed in note 28.

7 Financial income

Bank interest income 
Other income1 

2021 
£000 

2 
83 

85 

2020
£000

10
158

168

1  Other income relates to financing income in respect of the time value of money adjustments required by IFRS 15 on receivables and accrued 

income expected to be settled within greater than 12 months.

8 Financial expense

Interest on bank loans 
Amortisation of facility arrangement fees 
Interest on lease liabilities 

2021 
£000 

398 
99 
58 

555 

2020
£000

469
88
28

585

110 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

9 Taxation

Recognised in the consolidated statement of comprehensive income

Current tax expense
Current tax on income for the year 
Adjustments in respect of prior years 

Total current tax 

Deferred tax credit 
Origination and reversal of timing differences 

Total deferred tax 

Tax expense in statement of comprehensive income 

Total tax charge 

Reconciliation of effective tax rate

Profit/(Loss) for the year  
Total tax expense 
(Profit)/Loss before taxation 

Tax using the UK corporation tax rate of 19.00% (2020: 19.00%) 

Non-deductible expenses 
Adjustments in respect of prior years 
Share scheme deductions 
Short-term timing differences  

Total tax charge 

2021 
£000 

276 
13 

289 

(210) 

(210) 

79 

79 

2021 
£000 

156 
79 
235 

45 

97 
13 
(8) 
(68) 

79 

2020
£000

202
26

228

(226)

(226)

2

2

2020
£000

(225)
2
(223)

(42)

100
26
(11)
(71)

2

Changes in tax rates and factors affecting the future tax charge
The UK Government announced in the 2021 budget that from 1 April 2023, the rate of corporation tax in the 
United Kingdom will increase from 19% to 25%. This was substantively enacted at the reporting date and 
the effects are included within these financial statements.

NAHL Group Plc Annual Report and Accounts 2021 

111

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

10 Deferred tax asset

At beginning of year 
Recognised in statement of comprehensive income (see note 9)   
Reclassified to liability (see note 11) 

Deferred tax asset at end of year 

2021 
£000 

14 
(27) 
36 

23 

2020
£000

30
(16)
–

14

The asset for deferred taxation consists of the tax effect of temporary differences in respect of:

At 1 January 2020 
Reclassified to deferred tax liability 
Recognised in statement of comprehensive income (see note 9) 

At 31 December 2020 
Recognised in statement of comprehensive income (see note 9) 
Reclassified from deferred tax liability (see note 11) 

At 31 December 2021 

11 Deferred tax liability

At beginning of year 
Reclassified from deferred tax assets (see note 10) 
Recognised in statement of comprehensive income (see note 9) 

Deferred tax liability at end of year 

Property, 
plant & 
equipment 
£000 

Bad debt 
provision 
£000 

Total
£000

17 
– 
(3) 

14 
(27) 
36 

23 

13 
– 
(13) 

– 
– 
– 

– 

30
–
(16)

14
(27)
36

23

2021 
  £000 

  826 
36 
  (237) 

  625 

2020
£000

1,068
–
(242)

826

The liability for deferred taxation consists of the tax effect of temporary differences in respect of:

At 1 January 2020 
Recognised in statement of comprehensive income 

At 31 December 2020 
Reclassified from deferred tax asset 
Recognised in statement of comprehensive income 

At 31 December 2021 

Intangible  
assets 
acquired on 
 business  
combinations 
£000 

Total
£000

Property, 
plant & equipment 
£000 

30 
8 

38 
36 
4 

78 

1,038 
(250) 

1,068
(242)

788 
– 
(241) 

547 

826
36
(237)

625

112 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
Financial Statements

12 Acquisitions and disposals

On 2 January 2020 the Group terminated its partnership in respect of National Law Associates LLP and 
relinquished its interest for nil consideration, recognising neither a profit or loss on disposal. 

13 Goodwill

Cost
At 1 January 2020 
At 31 December 2020 
At 31 December 2021 

Impairment 
At 1 January 2020 
At 31 December 2020 
At 31 December 2021 

Net book value 
At 31 December 2020 
At 31 December 2021 

Personal 
Injury 
£000 

39,897 
39,897 
39,897 

Critical 
Care 
£000 

Residential 
Property 
£000 

15,592 
15,592 
15,592 

4,873 
4,873 
4,873 

Total
£000

60,362
60,362

60,362

– 
– 
                     – 

(4,873) 
– 
(4,873) 
– 
–                (4,873) 

(4,873)
(4,873)

(4,873)

39,897 
39,897 

15,592 
15,592 

– 
– 

55,489

55,489

In 2020 the Group undertook a review of its operations and merged the Personal Injury and Residential 
Property cash generating units (CGUs) into one segment, Consumer Legal Services (see note 2). For 
the purposes of allocating goodwill, the goodwill relating to personal injury and residential property was 
allocated prior to this merger when the two businesses operated as separate CGUs. The impairment of the 
residential property CGU took place in 2019, prior to the restructure. 

In 2019, in light of the losses incurred by the Residential Property CGU and the continued uncertainty in the 
market, the directors undertook an impairment review by considering the CGU’s value in use compared to 
its recoverable amount and concluded that there were insufficient cash flows to support the recoverable 
value of goodwill attributable to the Residential Property CGU. As such, an impairment loss of £4,873,000 
was recognised in the statement of comprehensive income in 2019.

Where goodwill arose as part of a business acquisition, it forms part of the CGU’s asset carrying value which 
is tested for impairment annually. The Group has determined that for the purposes of impairment testing, 
each segment being Personal Injury, Critical Care and Residential Property, is the appropriate level at which 
to test, as this represents the lowest level at which the goodwill is monitored for internal management 
reporting.

The recoverable amounts for the CGUs are based on value in use which is calculated on the operating 
cash flows expected to be generated by the division using the latest budget data for the coming year and 
forecasts for the next five years. These cash flows are discounted at a WACC of 7.8% for Critical Care 
(2020: 8.4%) and 8.4% (2020: 9.3%) for Personal Injury. The range of WACCs represents the different risk 
profiles of each CGU.

We include a terminal value within each forecast which represents the cash flows of the CGU into perpetuity 
with 0% growth assumed, as permitted under IAS36 Impairment of Assets.

Management has determined that the recoverable amount calculations are most sensitive to changes in 
the assumptions of the discount rates, growth rates used to extrapolate the cash flows beyond the budget 
period and operating cash flows.

NAHL Group Plc Annual Report and Accounts 2021 

113

 
 
 
 
 
 
 
 
 
 
Financial Statements

13 Goodwill continued

The operating profit compound annual growth rate assumptions for years one to five are as follows: 

Personal Injury 
Critical Care 

The key factor influencing the Personal Injury 
growth assumptions is the long business cycle 
of National Accident Law. A high proportion of 
profits generated from 2021 onwards relate to the 
settlement of claims first converted by National 
Accident Law in previous years. These forecasts 
are based on detailed financial models using 
assumptions such as lead to enquiry conversion, 
claim underway rate, claims win rate and average 
settlement values. These assumptions are based 
on the company’s knowledge and experience on 
how cases settle gained from prior experience.

A growth rate that is higher than the long-term UK 
average growth rate of c. 2% has been applied to 
the Critical Care CGU. This is based on the recent, 
pre-COVID trading performance of the division over 
the past three years, the anticipated recovery from 
COVID and takes into account the strategic plans 
for the division over the coming years.

The operating profits have been adjusted for 
working capital movements to arrive at the 
operating cashflows. These working capital 
movements have been based on historic trends 
and adjusted for changes in the business model in 
Personal Injury.

2021 

86.4% 
15.8% 

2020

49.8%
14.5%

The amount by which each CGUs recoverable 
amount exceeds its carrying amount is as follows:

PI – £26.4m

CC – £61.0m

Management have performed sensitivity analysis 
on the key assumptions (WACC, growth rate, 
operating cash flows) and have determined that 
there is ample headroom under the value in use 
calculation to determine that no significant changes 
to key assumptions would affect the overall 
judgement as to whether the CGU is impaired.

The impairment calculations are most sensitive to 
changes in assumptions regarding the cash flow 
forecasts and WACC. If the WACC were to increase 
by 25% the following decreases in cash flows 
would be needed in order to reduce the available 
headroom to nil:

Personal Injury – 12.7% 

Critical Care – 55.9%

14 Members’ Non-controlling interests in LLPs

The Group has the following investments in non-wholly owned subsidiaries:

Name of subsidiary 

Your Law LLP 
Law Together LLP 

Country of incorporation 
and principal place 
of business 

Nature of interest 

Principal activity 

2021 

2020

United Kingdom 
United Kingdom 

LLP member 
LLP member 

Personal injury lawyers 
Personal injury lawyers 

75% 
50% 

75%
50%

Ownership

The ownership percentage is based on the proportion of capital contribution advanced by each of the 
corporate members. Profit share allocations and control are not determined by reference to this ownership 
percentage. The Group, through its 100% owned subsidiary Project Jupiter Limited, is entitled to appoint 
60% of the members to the Management Board of each LLP. Profit and net assets are shared between 
members based on the provisions of the partnership agreements.

114 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

14 Members’ Non-controlling interests in LLPs continued

The balances owed to the non-controlling members’ of these LLPs at the end of the year and movements 
during the year are as follows:

Balance at start of the year 
Profit allocation for the year 
Disposal of interest in LLP 
Drawings paid  

Balance at the end of the year 

15 Other Intangible assets

2021 
  £000 

  4,177 
 3,451 
– 

 (3,418) 

 4,210 

2020
£000

3,315
4,115
(54)
(3,199)

4,177

Cost 
At 1 January 2021 
Additions 
Reclassifications 

Technology  Contract 
related 
£000 

related 
£000 

Brand 
names  Software 
£000 

£000 

Assets 
under 
construction 
£000 

Total
£000

167 
– 
– 

8,466 
– 
– 

885 
– 
– 

2,455 
99 
180 

217 
240 
(180) 

12,190
339
–

At 31 December 2021 

167  8,466 

885 

2,734 

277 

12,529

Amortisation and impairment 
At 1 January 2021 
Amortisation charge for the year 

At 31 December 2021 

Net book value 
At 31 December 2020 

At 31 December 2021 

167 
– 

167 

5,206 
825 

6,031 

839 
46 

885 

1,421 
324 

1,745 

– 
– 

– 

7,633
1,195

8,828

– 

– 

3,260 

2,435 

46 

1,034 

– 

989 

217 

277 

4,557

3,701

NAHL Group Plc Annual Report and Accounts 2021 

115

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

15 Other Intangible assets continued

Cost 
At 1 January 2020 
Additions 
Reclassifications 

At 31 December 2020 

Amortisation and impairment 
At 1 January 2020 
Amortisation charge for the year 

At 31 December 2020 

Net book value 
At 31 December 2019 

At 31 December 2020 

Technology  Contract 
related 
£000 

related 
£000 

Brand 
names  Software 
£000 

£000 

Assets 
under 
construction 
£000 

Total
£000

167 
– 
– 

8,466 
– 
– 

885 
– 
– 

1,815 
633 
7 

167  8,466 

885  2,455 

37 
187 
(7) 

217 

11,370
820
–

12,190

167 
– 

167 

4,381 
825 

5,206 

740 
99 

839 

1,000 
421 

1,421 

– 
– 

– 

6,288
1,345

7,633

– 

4,085 

145 

815 

–  3,260 

46 

1,034 

37 

217 

5,082

4,557

In the statement of comprehensive income, the amortisation charge on business combinations and the 
amortisation charge for the year (on other assets) is included within ‘operating expenses’.

16 Property, plant and equipment

Cost 
At 1 January 2021  
Additions 
Disposals 

At 31 December 2021 

Depreciation and impairment 
At 1 January 2021 
Depreciation charge for the year 
Disposals 

At 31 December 2021 

Net book value 
At 31 December 2020 

At 31 December 2021 

Fixtures & fittings
& total
£000

2,205
281
(69)

2,417

1,838
171
(69)

1,940

367

477

116 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

16 Property, plant and equipment continued

Cost 
At 1 January 2020  
Additions 

At 31 December 2020 

Depreciation and impairment 
At 1 January 2020 
Depreciation charge for the year 

At 31 December 2020 

Net book value 
At 31 December 2019 

At 31 December 2020 

17 Leases

This note provides information for leases where the Group is a lessee. 

Amounts recognised in the balance sheet

Right of use assets 
Buildings 
Office equipment 

Lease liabilities 
Current 
Non-current 

Fixtures &
fittings &
total
£000

1,936
269

2,205

1,669
169

1,838

267

367

2020
£000

2,699
62

2,761

2020
£000

248
2,195

2021 
£000 

2,278 
37 

2,315 

2021 
£000 

242 
1,953 

Right of use assets relate to the two head offices at Kettering and Daventry and printer leases. Additions to 
right of use assets of £nil (2020: £2,801,000) were made during the year.

The statement of comprehensive income includes the following amounts relating to leases:

Depreciation charge of right of use assets 
Buildings 
Office equipment 

Interest expense 
Expenses relating to leases of low value assets 

The total cash outflow for leases in 2021 was £166,000 (2020: £558,000). 

NAHL Group Plc Annual Report and Accounts 2021 

2021 
£000 

280 
26 

306 

58 
– 

2020
£000

404
26

430

28
–

117

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

18 Trade and other receivables

Trade receivables: receivable in less than one year 
Trade receivables: receivable in more than one year 
Accrued income: receivable in less than one year 
Accrued income: receivable in more than one year 
Other receivables 
Prepayments 
Corporation tax 
Recoverable disbursements 

2021 
£000 

7,056 
839 
12,414 
3,718 
21 
913 
136 
8,307 

2020
£000

7,493
799
11,398
7,029
14
703
88
6,761

33,404 

34,285

A provision against trade receivables and accrued income of £740,000 (2020: £673,000) is included in the 
figures above.

Trade receivables and accrued income receivable in greater than one year are classified as current assets as 
the Group’s working capital cycle is considered to be up to 36 months as extended credit terms are offered 
as part of commercial agreements.

19 Other interest-bearing loans and borrowings

This note provides information about the contractual terms of the Group’s other interest-bearing loans and 
borrowings, which are measured at amortised cost. For more information about the Group’s exposure to 
interest rate risk, see note 24.

Non-current liabilities 
Revolving credit facility 
Less facility arrangement fees 

Total other interest-bearing loans and borrowings 

2021 
£000 

2020
£000

18,000 
(90) 

17,901 

20,000
(99)

19,901

The revolving credit facility is secured by a fixed and floating charge over the assets of the Group.

Terms and debt repayment schedule

Currency 

Year of 
Nominal interest rate  maturity 

Fair 
value 
2021 
£000 

Carrying 
amount 
2021 
£000 

Fair 
value 
2020 
£000 

Bank loan1 

GBP 

2.25% above SONIA  2024 

17,901 

17,901 

19,901 

17,901 

17,901 

19,901 

Carrying
amount
2020
£000

19,901

19,901

1. The company renewed its banking facilities in September 2017 by taking out a revolving credit facility of £25,000,000 and repaying the 
outstanding term loan at that date of £9,375,000. The facility was reduced to £20,000,000 in December 2021 and was extended with the facility 
now due to terminate on 31 December 2024. Interest is payable at 2.25% above SONIA per annum.

118 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

20 Trade and other payables

Amounts due within one year: 

Trade payables 
Disbursements payable 
Other taxation and social security 
Other payables, accruals and deferred revenue 
Customer deposits 

Total trade and other payables 

21 Share capital 

Number of shares 
Opening: ‘A’ Ordinary Shares of £0.0025 each 
Issued during the year 

Closing: ‘A’ Ordinary Shares of £0.0025 each 

Allotted, called up and fully paid 
Opening: 46,240,222 (2020: 46,178,716) ‘A’ 
Ordinary Shares of £0.0025 each 
Issued during the year: 85,000 ‘A’ Ordinary shares of £0.0025 each 

Closing: ‘A’ Ordinary Shares of £0.0025 each 

Shares classified in equity 
Opening shares classified in equity 
Issued during the year 

Closing balance 

2021 
£000 

1,452 
7,222 
1,216 
5,864 
457 

16,211 

2020
£000

3,201
6,001
1,791
5,849
705

17,547

2021 

2020

46,240,222 
85,000 

46,178,716
61,506

46,325,222 

46,240,222

£000 

£000

115 
1 

116 

115 
1 

116 

115
–

115

115
–

115

The holders of ’A’ Ordinary shares are entitled to one vote per share at the meetings of the Company and to 
dividends as declared in proportion to the amounts paid up on the ordinary shares.

22 Share based payments

The Group operates three employee share plans as follows:

SAYE plan
Options may be satisfied by newly issued Ordinary Shares, or by the transfer of Ordinary Shares held in 
treasury. The SAYE scheme is open to all employees of the Group. The scheme runs over three years with 
employees choosing to save between £0 – £500 per month, the proceeds of which can then be used to 
purchase the shares under option.

EMI Scheme
Options may be granted as tax-favoured enterprise management incentive options (EMI Options) or non- 
tax favoured Options. The EMI Plan provides for the grant, to selected employees of the Group, of rights to 
acquire (whether by subscription or market purchase) Ordinary Shares in the Company (Options).

NAHL Group Plc Annual Report and Accounts 2021 

119

 
 
 
 
 
 
 
 
 
 
Financial Statements

22 Share based payments continued

Nominal Cost LTIP
The nominal cost LTIP will enable selected employees (including Executive Directors) to be granted awards 
in respect of Ordinary Shares. Awards may be granted in the form of nil or nominal cost options to acquire 
Ordinary Shares; or contingent rights to receive Ordinary Shares. Awards may be satisfied by newly issued 
Ordinary Shares, or by the transfer of Ordinary Shares held in treasury.

The terms and conditions of grants of share options to employees of the Group, in the shares of NAHL 
Group plc are as follows:

Grant date/employees entitled/
nature of scheme

Number of 
instruments

Vesting conditions

583,331 ordinary 
shares

Performance-
based

Vesting period and 
maximum life of 
options

Third anniversary of 
Date of Grant

EMI Equity-settled award to 
6 employees granted by the parent 
company on 11 December 2014

SAYE Equity-settled award to 
13 employees granted by the parent 
company on 23 October 2018

Restricted equity-settled award to 
9 employees granted by the parent 
company on 23 April 2021

97,143 ordinary 
shares

Performance-
based

1 December 2021

615,475 ordinary 
shares

Performance-
based

Second anniversary 
of grant date 

Restricted equity-settled award to 
9 employees granted by the parent 
company on 23 April 2021

700,406 ordinary

shares

Performance-
based

Third anniversary of 
Date of Grant

The number and weighted average exercise prices of share options are as follows

Outstanding at the beginning of the year 
Granted during the year 
Cancelled during the year 
Lapsed during the year 
Vested during the year 
Forfeited during the year 

Outstanding at the end of the year 
Exercisable at the end of the year  
Exercised during the year 

2021 

2020

Weighted 
average 
exercise price 
£ 

0.20 
0.0025 
(0.86) 
(0.0025) 
(0.46) 
(0.15) 

0.0025 
1.84 
0.0025 

Number of 
options 
No. 

1,039,791 
1,686,327 
(79,016) 
(530,868) 
(182,143) 
(511,632) 

1,315,881 
680,474 
85,000 

Weighted 
average 
exercise price 
£ 

0.23 
– 
(0.86) 
(0.0025) 
(1.21) 
(0.22) 

0.20 
1.92 
0.0025 

Number of
options
No.

2,040,920
–
(143,830)
(368,112)
(65,160)
(261,271)

1,039,791
648,491 
61,506

120 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

22 Share based payments continued

A charge of £400,000 (2020: £523,000 ) has been made through the statement of comprehensive income 
in the current year in relation to the IFRS 2 share option charge. The weighted average share price of those 
shares exercised during the year was £0.0025 (2020: £0.0025). For shares outstanding at the year end, 
these are exercisable at an exercise price of £0.0025 and have a weighted average remaining life of 673 
days.

There were 1,686,327 share options issued in 2021 (2020: none). The fair value of each employee share 
option has been measured using the Black-Scholes formula where an expected volatility of 65.0% has been 
used as well as a risk-free interest rate (based on government bonds) of 0.04% – 0.85%. The weighted 
average share price used in the model is £0.73 and a dividend yield of between 0.0% –7.2% has been 
assumed. Service and non- market performance conditions attached to the arrangements were not taken 
into account in measuring fair value.

Expected volatility has been based on evaluation of historical volatility of the Company’s share price, 
particularly over the historical period commensurate with the expected term. The expected term of the 
instruments has been based on historical experience and general option holder behaviour.

23 Earnings per share

The calculation of basic earnings per share at 31 December 2021 is based on profit attributable to ordinary 
shareholders of the parent company of £156,000 (2020: loss of £225,000) and a weighted average number 
of Ordinary Shares outstanding of 46,245,345 (2020: 46,238,878).

Profit/(Loss) attributable to ordinary shareholders

£000 

Profit/(Loss) for the year attributable to the shareholders 

Weighted average number of ordinary shares 

Number 

Issued Ordinary Shares at 1 January 

Weighted average number of Ordinary Shares at 31 December 

Basic Earnings per share (p)

Group 

2021 

156 

2020

(225)

Note 

21 

2021 

2020

46,240,222 

46,178,716

46,245,345 

46,238,878

2021 

0.3 

2020

(0.5)

The Group has in place share-based payment schemes to reward employees. At 31 December 2021, there 
were potentially dilutive share options under the Group’s share option schemes. The total number of options 
available for these schemes included in the diluted earnings per share calculation is 1,315,881 (2020: in 
line with IAS 33, as the group has a negative earnings per share, it is assumed there are no dilutive shares). 
There are no other diluting items.

Diluted Earnings per share (p)

Group 

2021 

(0.3) 

2020

(0.5)

NAHL Group Plc Annual Report and Accounts 2021 

121

 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

24 Financial instruments

(a) Fair values of financial instruments
The Group’s principal financial instruments comprise interest-bearing borrowings, cash and short-term 
deposits. The main purpose of these financial instruments is to raise finance for the Group’s operations. 
The Group has various other financial instruments such as trade and other receivables and trade and other 
payables that arise directly from its operations.

The main risks arising from the Group’s financial instruments are credit risk, liquidity risk and market risk 
(specifically interest rate risk). The Board reviews and agrees policies for managing each of these risks and 
they are summarised below. There have been no substantive changes in the Group’s exposure to financial 
instrument risks or its objectives, policies and processes for managing and measuring those risks during the 
periods in this report unless otherwise stated.

The fair values of all financial assets and financial liabilities by class, which approximate to their carrying 
values, shown in the balance sheet are as follows:

Financial assets measured at amortised cost 
Cash and cash equivalents 
Trade and other receivables 
Disbursements (note 18) 

Total financial assets 

Financial liabilities measured at amortised cost 
Other interest-bearing loans and borrowings (note 19) 
Lease liabilities (note 17) 
Trade payables (note 20) 
Disbursements payable (note 20) 
Other payables and accruals (note 20) 

Carrying 
amount 
2021 
£000 

2,458 
18,863 
8,307 

29,628 

17,910 
2,195 
1,452 
7,222 
5,864 

Fair 
value 
2021 
£000 

2,458 
18,863 
8,307 

29,628 

17,910 
2,195 
1,452 
7,222 
5,864 

Carrying 
amount 
2020 
£000 

3,609 
21,288 
6,761 

31,658 

19,901 
2,443 
3,201 
6,001 
5,849 

Total financial liabilities measured at amortised cost 

34,643 

34,643 

37,395 

Fair
value
2020
£000

3,609
21,288
6,761

31,658

19,901 
2,443
3,201
6,001
5,849

37,395

(b) Credit risk
Financial risk management
Credit risk is the risk of financial loss to the Group if a customer or counterparty to a financial instrument 
fails to meet its contractual obligations, and arises principally from the Group’s receivables from customers.

 A customer is considered to have defaulted on their debt if payment is not made within the agreed terms. 
Debts are written-off only when there are indicators that there is no reasonable expectation of recovery. 
Debts subject to enforcement activity are considered for impairment and the appropriate provisions are 
applied against them until there is no reasonable expectation of recovery at which point they are written off. 

Exposure to credit risk
The maximum exposure to credit risk at the balance sheet date by class of financial instrument was:

Trade receivables 
Accrued income 

2021 
£000 

7,895 
10,946 

18,841 

2020
£000

8,292
12,981

21,273

Management consider the credit risk to be mitigated as a result of a) the holding of deposits for all 
significant panel law firm customers and b) only offering significant deferred terms to those panel law firms 
with whom we hold strategic partnerships and after satisfactory credit checks have been obtained. As at 
31 December 2021 these deposits reflect 5.8% (2020: 8.5%) of the balance of trade receivables. At each 
balance sheet date, the amount of deposit held was:

Customer deposits 

2021 
£000 

457 

2020
£000

705

122 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

24 Financial instruments continued

Credit quality of financial assets and impairment losses 
The aging of trade receivables at the balance sheet date was: 

Gross: 

Gross: 
Standard  Deferred 

Not past due 
Past due (1 – 30 days) 
Past due (30 – 120 days) 
Past due (Over 120 days) 

Terms 
2021 
£000 

2,273 
945 
1,025 
2,183 

Terms  Impairment 
2021 
£000 

2021 
£000 

Gross: 
  Standard 
Terms 
2020 
£000 

Total 
2021 
£000 

Gross: 
Deferred 
Terms 
2020 
£000 

Impairment 
2020 
£000  

Total
2020
£000

1,752 
32 
62 
223 

(120)  3,905 
939 
(38) 
1,047 
(40) 
(402)  2,004 

2,441 
986 
926 
2,431 

1,683 
43 
45 
222 

(100)  4,024
1,003
945
(333)  2,320

(26) 
(26) 

6,426  2,069 

(600) 

7,895 

6,784 

1,993 

(485)  8,292

The Group offers standard credit terms of between 30–60 days to the majority of its customers. Deferred 
terms of between 12–24 months are offered to those panel law firms or customers with whom we hold strategic 
partnerships. The impairment for trade receivables is calculated based on a lifetime expected credit loss.

34.0% of standard terms trade receivables are 120 days or more past due (2020: 36.2%). These receivables 
arise primarily in Critical Care and Your Law where our standard credit terms are 30 days. Increasing cost 
pressures on solicitors mean they often do not settle these balances until interim funds are available or a 
case has settled. This is often within 12 months and, therefore, formal deferred terms are not utilised. We 
monitor these debts closely through regular contact with these solicitors and do not consider there to be any 
significant risks regarding recoverability.

Accrued income balances of £10,946,000 (2020: £12,981,000) represent amounts contractually due from 
customers that have not yet been invoiced but where there is a contractual obligation to settle funds once 
they become due. All accrued income of this nature is granted on extended credit terms of up to 36 months 
and none is yet due for payment.

The movement in the allowance for impairment in respect of trade receivables and accrued income during 
the year was as follows:

Balance at 1 January 
Allowance released 
Allowance utilised 

Balance at 31 December 

2021 
£000 

673 
67 
– 

740 

2020
£000

554
119
–

673

The allowance account for trade receivables is used to record impairment losses unless the Group 
is satisfied that no recovery of the amount owing is possible; at that point the amounts considered 
irrecoverable are written off against the trade receivables directly.

The determination of the expected credit losses is detailed in the accounting policies under Critical 
accounting judgements and key sources of estimation uncertainty.

The Group determines whether its assets have a high level of credit risk or low level of credit risk on initial 
recognition by considering the past history of that customer (if known) or where assets relate to a new 
customer, credit checks are performed and the risk assessed based on the outcome of these reports. The 
Group determines whether the credit risk of its financial assets has increased since initial recognition by 
considering a) historical factors such as adherence to payment terms and length of time to settle payments 
and b) forward looking factors such as the anticipated condition of the market in which its customers 
operate. The Group has not identified any significant increases to the credit risk of any of its financial assets 
in 2021. This assessment applies to both trade receivables and accrued income. 

NAHL Group Plc Annual Report and Accounts 2021 

123

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

24 Financial instruments continued

(c) Liquidity risk
Financial risk management
Liquidity risk arises from the Group’s management of working capital and the finance charges on its debt 
instruments and repayments of principal. It is the risk that the Group will encounter difficulty in meeting 
its financial obligations as they fall due. The Group’s objective is to maintain a balance between continuity 
of funding and flexibility through the use of its revolving credit facility to ensure that it will always have 
sufficient cash to allow it to meet its liabilities when they become due.

The following are the contractual maturities of financial liabilities, including estimated interest payments and 
excluding the effects of netting agreements:

2021 

Carrying amount 
Contractual cash flows: 
1 year or less 
1 to 2 years 
2 to 5 years 
5 years or more 

2020 

Carrying amount 
Contractual cash flows: 
1 year or less 
1 to 2 years 
2 to 5 years 
5 years or more 

Secured 
bank loans 
£000 

Lease 
liabilities  
£000 

Trade and 
other 
payables 
£000 

Total
£000

(18,000) 

(2,195) 

(15,754) 

(35,949)

(468) 
(468) 
(18,468) 
– 

(295) 
(277) 
(858) 
(1,015) 

(8,532) 
(7,222) 
– 
– 

(9,295)
(7,967)
(19,326)
(1,015)

(19,404) 

(2,445) 

(15,754) 

(37,603)

Secured 
bank loans 
£000 

Lease 
liabilities  
£000 

Trade and 
other 
payables 
£000 

Total
£000

(20,000) 

(2,443) 

(16,843) 

(39,286)

(400) 
(20,400) 
– 
– 

(20,800) 

(287) 
(295) 
(853) 
(1,306) 

(2,741) 

(10,842) 
(6,001) 
– 
– 

(11,529)
(26,696)
(853)
(1,306)

(16,843) 

(40,384)

(d) Market risk
Financial risk management
Market risk is the risk that changes in market prices, such as foreign exchange rates, interest rates and 
equity prices will affect the Group’s income or the value of its holdings of financial instruments.

Market risk – foreign currency risk

The Group has no foreign currency risk as all transactions are in Sterling. 

Market risk – interest rate risk

Profile
The Group is exposed to interest rate risk from its use of interest-bearing financial instruments. This is a 
market risk that the future cash flows of a financial instrument will fluctuate because of changes in interest 
rates.

124 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

24 Financial instruments continued

At the balance sheet dates, the only interest-bearing financial asset is cash. Cash is held to meet liabilities as 
they fall due and is not held for investment purposes, therefore there is not considered to be an interest rate 
risk associated with cash.

Variable rate instruments 
Financial liabilities 

Total interest-bearing financial instruments 

2021 
£000 

2020
£000

18,000 

18,000 

20,000

20,000

The Group manages the interest rate risk arising from its financial liabilities by monitoring its interest rates 
and the general market and consulting with its bankers to find the best way to mitigate any movements if it 
anticipates any significant changes to interest rates.

Sensitivity analysis
A change of 0.5% in interest rates at the balance sheet date would increase/(decrease) profit or loss in 
the following year by the amounts shown below. This calculation assumes that the change occurred at the 
balance sheet date and had been applied to risk exposures existing at that date.

This analysis assumes that all other variables remain constant and considers the effect of financial 
instruments with variable interest rates. The analysis is performed on the same basis for the comparative 
periods.

Profit for the year 
Increase 
Decrease 

2021 
£000 

90 
(90) 

2020
£000

100
(100)

Market risk – equity price risk 
The Group does not have an exposure to equity price risk as it holds no investment in equity securities which 
are classified as fair value through profit or loss or other comprehensive income.

(e) Capital management
Group
The Group’s objectives when maintaining capital are to safeguard the entity’s ability to continue as a going 
concern and to provide an adequate return to shareholders. Capital comprises the Group’s equity, i.e. share 
capital including preference shares, share premium, own shares and retained earnings, as well as bank 
loans. The Group’s debt/equity ratio as at 31 December 2021 is 0.3:1.0 (2020: 0.3:1.0). The balance of the 
Group’s capital as at 31 December 2021 was £74,619,000 comprising equity of £56,619,000 and bank loans 
of £18,000,000. The Group is subject to quarterly covenant testing against its bank loans. These covenants 
include minimum EBITDA and minimum free cash flow. The Group adhered to both these covenants in 2021 
and is forecasting compliance for the foreseeable future.

25 Commitments 

Capital commitments
At 31 December 2021 the Group had capital commitments of £nil (2020: £nil).

NAHL Group Plc Annual Report and Accounts 2021 

125

 
 
 
 
 
 
 
 
Financial Statements

26 Transactions with owners, recorded directly in equity

Exercise of share options

During the year 85,000 (2020: 61,506) share options were exercised which resulted in the issue of 85,000 
(2020: 61,506) new Ordinary Shares with a par value of £0.0025. The exercising of these options raised 
funds of £213 (2020: £154) for the Group.

27 Dividends

No dividends were paid in 2021 or 2020. 

28 Related parties

Transactions with key management personnel

Key management personnel in situ at the 31 December 2021 and their immediate relatives control 0.3% 
(2020: 0.3%) of the voting shares of the Company.

Key management personnel are considered to be the Directors of the Company as well as those of National 
Accident Law Limited, Homeward Legal Limited, Bush & Company Rehabilitation Limited and any other 
management serving as part of the executive team. Detailed below is the total value of transactions with 
these individuals

Short-term employment benefits 
Termination benefits 

29 Net debt

2021 
£000 

1,918 
129 

2,047 

2020
£000

1,897
179

2,076

Net debt includes cash and cash equivalents and other interest-bearing loans and borrowings.

Cash and cash equivalents 
Other interest-bearing loans and borrowings 

Net debt 

Lease liabilities 

2021 
£000 

2,458 
(17,910) 

(15,452) 

2020
£000

3,609
(19,901)

(16,292)

(2,195) 

(2,443)

126 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
Financial Statements

29 Net debt continued

Set out below is a reconciliation of movements in net debt during the period.

Net (decrease)/increase in cash and cash equivalents 
Net inflow from decrease in debt and debt financing 

Movement in net borrowings resulting from cash flows 
Non-cash movements – net release of prepaid loan arrangement fees 
Net debt at beginning of period 

Net debt at end of period 

2021 
£000 

(1,151) 
2,000 

849 
(9) 
(16,292) 

(15,452) 

Set out below is a reconciliation of movements in lease liabilities arising from financing activities:

Net outflow from decrease in lease liabilities 

Movement in lease liabilities resulting from cash flows 
Non-cash movements arising from initial recognition of new 
lease liabilities, revisions and interest charges 
Lease liabilities at beginning of period 

Lease liabilities at end of period 

2021 
£000 

166 

166 

82 
(2,443) 

(2,195) 

2020
£000

1,045
3,750

4,795
(57)
(21,030)

(16,292)

2020
£000

558

558

(2,754)
(247)

(2,443)

NAHL Group Plc Annual Report and Accounts 2021 

127

 
 
 
 
Financial Statements

COMPANY STATEMENT OF FINANCIAL POSITION
at 31 December 2021

Non-current assets 
Investments 

Current assets 
Trade and other receivables 

Net assets 

Equity 
Share capital 
Share option reserve 
Share premium 
Retained earnings at end of year 

Shareholders’ funds 

Note 

2021 
£000 

2020
£000

2 

3 

5 

52,700 

52,700

32,334 

31,933

85,034 

84,633

116 
4,312 
14,595 
66,011 

115
3,912
14,595
66,011

85,034 

84,633

The Company profit for the year was £nil (2020: £nil). 

The notes on pages 130–135 form part of these financial statements.

These financial statements were approved by the Board of Directors on 28 March 2022 and were signed on 
its behalf by:

J D Saralis 
Director

Company registered number: 08996352

128 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

COMPANY STATEMENT OF CHANGES IN EQUITY
for the year ended 31 December 2021

Share 
capital 
£000 

Note 

Share 
option 
reserve 
£000 

Share 
premium 
£000 

Merger 
reserve 
£000 

Retained 
earnings 
£000 

Total
equity
£000

Balance at 1 January 2020 

115 

3,389 

14,595 

– 

66,011  84,110

Total comprehensive income for the year 
Profit for the year 

Total comprehensive income 

– 

– 

– 

– 

Transactions with owners, recorded 
directly in equity 
Share based payments 

6 

– 

523 

– 

– 

– 

Balance at 31 December 2020 

115 

3,912 

14,595 

Total comprehensive income for the year 

Profit for the year 

Total comprehensive income 

Transactions with owners, recorded 
directly in equity 
Share based payments 
Issue of share capital 

6 
5 

– 

– 

– 

– 
1 

– 

– 

– 

400 
– 

– 

– 

– 

– 
– 

Balance at 31 December 2021 

116 

4,312 

14,595 

– 

– 

– 

– 

– 

– 

– 

– 
– 

– 

– 

– 

–

–

– 

523

66,011  84,633

– 

– 

– 

– 
– 

–

–

–

400
1

66,011  85,034

COMPANY CASH FLOW STATEMENT
for the year ended 31 December 2021

Cash flows from operating activities 
Profit for the year 
Adjustments for: 
Share based payments 

Increase in trade and other receivables 

Net cash generated from operating activities 

Cash flows from financing activities 
New share issue 
Dividends paid 

Net cash used in financing activities 

Net increase in cash and cash equivalents 
Cash and cash equivalents at 1 January 

Cash and cash equivalents at 31 December 

2021 
£000 

– 

400 

400 
(401) 

(1) 

1 
– 

1 

– 
– 

– 

2020
£000

–

523

523
(523)

–

–
–

–

–
–

–

NAHL Group Plc Annual Report and Accounts 2021 

129

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

NOTES TO THE COMPANY FINANCIAL STATEMENTS

1 Accounting policies
Basis of preparation 
Financial Statements

The Financial Statements for the year ended 
31 December 2021 have been prepared in 
accordance with International Accounting 
Standards in conformity with the requirements of 
the Companies Act 2006.

The financial information has been prepared on a 
going concern basis and under the historical cost 
convention. The company has taken advantage 
of the exemption allowed under Section 408 of 
the Companies Act 2006 and has not presented 
its own income statement in these financial 
statements. The Group profit includes a profit after 
tax for the parent company of £nil (2020: £nil).

Critical accounting judgements and key 
sources of estimation 
The preparation of financial statements in 
conformity with IFRSs requires management to 
make judgements and estimates that affect the 
application of accounting policies and the reported 
amounts of assets, liabilities, income and expenses. 
Estimates are based on past experience and other 
reasonable assessment criteria. Actual results 
may differ from these estimates. Estimates and 
underlying assumptions are reviewed on an ongoing 
basis and revisions to accounting estimates are 
recognised in the year in which the estimates are 
revised and in any future years affected.

In accordance with IAS 1 the Group is required to 
disclose critical accounting judgements and key 
sources of estimation uncertainty.

Judgements
In applying the Company’s accounting policies, 
management have not made any judgements 
that have a significant impact on the amounts 
recognised in the financial statements.

Estimates
Calculation of value in use to support recoverable 
amount of investment in subsidiary undertaking

The Board has reviewed its 5-year forecasts based on 
current market trends and has factored in a slower 
market recovery than that used in previous years. 
Because of the inherent unknown speed of market 
recovery as the country recovers from COVID-19 in 
the coming years, the estimation of value in use may 
differ should the market recover at a differing speed 
than expected. This could lead to either a higher 
value in use if the market recovers quicker than 

anticipated or lower if there is a prolonged period of 
cautious consumer behaviour. A lower value in use 
may result in a potential impairment. 

The Board considers that the assumptions adopted 
in the calculation of valuation in use are supportable, 
reasonable and based on the best evidence 
available at present. The key determination for the 
calculation is the number of enquiries generated 
by the Personal Injury business and growth in 
Critical Care. The Board has adopted a conservative 
approach to both of these assumptions and has 
assumed a cautious and gradual recovery to pre-
COVID levels over the short-term.

New standards and amendments adopted by 
the Company 
The Company has not adopted any new standards 
or amendments. 

New standards, interpretations and 
amendments not yet effective 
There are no new standards, interpretations and 
amendments that are not yet effective and that 
would be expected to have a material impact on the 
Company in the current or future reporting periods 
and on foreseeable future transactions.

Going concern 
The Company had net assets of 
£85,034,000 (2020: £84,633,000) and 
net current assets of £32,334,000 (2020: 
£31,933,000) as at each year end.

Details of the Directors’ going concern 
assessment for the Group and Company can 
be found under ‘Going Concern’ in note 1 to 
the Group financial statements on page 94.

Employee share schemes 
The share option plans allow employees of the Group 
to acquire shares of the Company. The fair value 
of options granted is recognised as an employee 
expense with a corresponding increase in equity. 
The fair value is measured at grant date and spread 
over the period during which the employees become 
unconditionally entitled to the options. The fair value 
of the options granted is measured using an option 
pricing model, taking into account the terms and 
conditions upon which the options were granted. 
The amount recognised as an expense is adjusted to 
reflect the actual number of share options that vest 
except where forfeiture is only due to share prices 
not achieving the threshold for vesting. The share-
based payment charge represents the charge in 
respect of the employees of the Group.

130 

NAHL Group Plc Annual Report and Accounts 2021

Financial Statements

1 Accounting policies  continued

Impairment 
The carrying amounts of the Company’s non- 
financial assets are reviewed at each reporting date 
to determine whether there is any indication of 
impairment. If any such indication exists then the 
asset’s recoverable amount is estimated.

An impairment loss is recognised if the carrying 
amount of an asset exceeds its estimated re-
coverable amount. Impairment losses are recognised 
in the income statement. Impairment losses 
recognised in prior periods are assessed at each 
reporting date for any indications that the loss has 
decreased or no longer exists. An impairment loss is 
reversed if there has been a change in the estimates 
used to de-termine the recoverable amount. An 
impairment loss is reversed only to the extent that 
the asset’s carrying amount does not exceed the 
carrying amount that would have been determined, 
net of depreciation or amortisation, if no impairment 
loss had been recognised.

NAHL Group Plc Annual Report and Accounts 2021 

131

Financial Statements

2 Investments

The Company has the following investments in subsidiaries:

Country of 
incorporation 
and principal place 
of business 

Class of 
shares held 

Principal activity 

Ownership

2021 

2020

United Kingdom Ordinary  Holding company 

100% 

100%

United Kingdom Ordinary 
United Kingdom Ordinary 
United Kingdom Ordinary  Holding company 
United Kingdom Ordinary  Holding company 

Critical care services 
Agency services for solicitors 

100% 
100% 
100% 
100% 

100%
100%
100%
100%

Name of subsidiary 

Consumer Champion 
Group Limited2 
Bush & Company 
Rehabilitation Limited2 
Homeward Legal Limited2  
NAH Holdings Limited2 
NAH Group Ltd2 
NAHL Support Services 
Limited2 

United Kingdom Ordinary 

Provision of shared services  
to the Group 

Dormant 
Dormant 

Dormant 
Dormant 

United Kingdom Ordinary 
United Kingdom Ordinary 

United Kingdom Ordinary 
United Kingdom Ordinary 

Lawyers Agency Services 
Limited 
Accident Helpline Limited 
NAH Support Services 
Limited 
Tiger Claims Limited 
National Accident Helpline  
United Kingdom Ordinary 
Limited 
NAH Legal Services Limited  United Kingdom Ordinary 
Searches UK Limited2 
United Kingdom Ordinary 
United Kingdom Ordinary 
Inside Eye Limited 
Project Jupiter Limited2 
United Kingdom Ordinary  Holding company 
Your Law LLP1 
United Kingdom n/a 
National Accident 
Law Limited2 
Law Together LLP1 
National Conveyancing 
Partners Ltd2 

United Kingdom Ordinary 
United Kingdom n/a 

United Kingdom Ordinary  Outsourcing of staff  

Personal Injury lawyers 
Personal Injury lawyers 

Personal Injury lawyers 

Dormant 
Dormant 
Agency services for solicitors 
Dormant 

100% 

100%

100% 
100% 

100%
100%

100% 
100% 

100%
100%

100% 
100% 
100% 
100% 
100% 
75% 

100%
100%
100%
100%
100%
75%

100% 
50% 

100%
50%

100% 

100%

1. Your Law LLP and Law Together LLP are Limited Liability Partnerships. The Group, through its 100% owned subsidiary Project Jupiter Limited, 
is entitled to appoint 60% of the members to the Management Board of each LLP. Profit and net assets are shared between members based on 
the provisions of the partnership agreements.

2. The above 100% subsidiaries have taken the exemption from audit under section 479a of the Companies Act 2006.

The registered office of all of the above 100% subsidiaries is Bevan House, Kettering Parkway, Kettering, 
Northamptonshire, NN15 6XR.

The registered office of Your Law LLP is Helmont House, Churchill Way, Cardiff, CF10 2HE.

The registered office of Law Together LLP is Castlefield House, Liverpool Road, Manchester, M3 4SB.

132 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

2 Investments continued

At 31 December 2021 the value of the investment in Consumer Champion Group Limited, its only directly 
owned subsidiary, was as follows:

Valuation 

At 1 January 2021 and 31 December 2021 

Total
£000

52,700

The Directors have determined that due to the net assets of NAHL Group plc being in excess of the market 
capitalisation of the Group headed by NAHL Group plc as at 31 December 2021 then an indication of 
impairment exists.

The recoverable amount of the investment has been assessed on a value in use basis using the below 
assumptions behind each valuation technique. A value in use valuation is considered to be appropriate as 
the investment is being held for its long-term profit potential.

Value in use  
On a value in use basis the future cash flows from the investment have been assessed. The future cash flows 
are considered to be the future dividends that could be generated by each CGU (i.e. future retained earnings 
generated by each of the trading subsidiaries) using the latest budget data for the coming year extrapolated 
at an annual growth rate for four years and no growth in perpetuity, discounted at a pre-tax WACC of 8.4%. 
The key assumptions under this basis are the WACC and operating profits of each subsidiary. More details 
on how these have been calculated are given in note 13, Goodwill, to the consolidated financial statements.

Under this basis the carrying value of assets is below the recoverable amount valued on a value in use basis 
and therefore there would be no impairment required.

Sensitivity analysis has been performed that indicates the value in use is most sensitive to changes in 
assumptions concerning the forecasts. See Critical accounting judgements and key sources of estimation 
uncertainty in note 1 for further details. 

3 Trade and other receivables

Amounts due from Group undertakings 

2021 
£000 

32,334 

2020
£000

31,933

Amounts due from Group undertakings are interest free and repayable upon demand.

NAHL Group Plc Annual Report and Accounts 2021 

133

 
 
 
 
Financial Statements

4 Financial instruments

a) Amounts due from Group undertakings
The fair value of amounts owed by Group undertakings are estimated as the present value of future cash 
flows, discounted at the market rate of interest at the balance sheet date if the effect is material.

Management believes there are no risks arising from these financial instruments on the grounds that 
management have undertaken a review of recoverability as part of their annual impairment assessment 
and have concluded that the subsidiaries are expected to be able to generate sufficient future cash flows to 
repay the balances in full. There have been no substantive changes in the Company’s exposure to financial 
instrument risks or its objectives, policies and processes for managing and measuring those risks during the 
periods in this report unless otherwise stated.

Carrying 
amount 
2021 
£000 

Fair 
value 
2021 
£000 

Carrying 
amount 
2020 
£000 

Fair
value
2020
£000

Amounts due from Group undertakings 

32,334 

32,334 

31,933 

31,933

Total financial assets 

32,334 

32,334 

31,933 

31,933

b) Capital management
The Company’s objectives when maintaining capital are to safeguard the entity’s ability to continue as a 
going concern and to provide an adequate return to shareholders. Capital comprises the Company’s equity, 
i.e. share capital including preference shares, share premium, own shares and retained earnings. The 
balance of the Company’s capital as at 31 December 2021 was £85,034,000.

5 Share capital

Number of shares 
Opening: ‘A’ Ordinary Shares of £0.0025 each 
Issued during the year 

Closing: ‘A’ Ordinary Shares of £0.0025 each 

2021 

2020

46,240,222 
85,000 

46,178,716
61,506

46,325,222 

46,240,222

£000 

£000

Allotted, called up and fully paid 
Opening: 46,240,222 (2020: 46,178,716) ‘A’
Ordinary Shares of £0.0025 each 
Issued during the year: 85,000 (2020: 61,506) ‘A’ Ordinary shares of £0.0025 each 

Closing: 46,325,222 (2020: 46,240,222) ‘A’ Ordinary Shares of £0.0025 each 

Shares classified in equity 
Opening shares classified in equity 
Issued during the year 

Closing balance 

115 
1 

116 

115 
1 

116 

115
–

115

115
–

115

The holders of ’A’ Ordinary shares are entitled to one vote per share at the meetings of the Company and to 
dividends as declared in proportion to the amounts paid up on the ordinary shares.

134 

NAHL Group Plc Annual Report and Accounts 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements

6  Share based payments
The Company operates three employee share plans. 
Details of these can be found in note 22 to the Group 
accounts.

7  Staff costs and numbers
During the year the Company employed no members 
of staff and incurred no staff costs.

8  Related parties
Details of transactions with key management 
personnel can be found in note 28 to the Group 
accounts.

NAHL Group Plc Annual Report and Accounts 2021 

135

Advisors

Company registration number
08996352

Auditors
Mazars
The Pinnacle
160 Midsummer Boulevard
Milton Keynes
MK9 1FF

Solicitors to the Company
Addleshaw Goddard LLP
Milton Gate 
60 Chiswell Street 
London 
EC1Y 4AG 

Bankers
Yorkshire Bank plc
Birmingham Financial Solutions Centre
Temple Point
No.1 Temple Row
Birmingham
B2 5YB

Nominated advisor and broker
Allenby Capital Limited
5 St. Helen’s Place 
London
EC3A 6AB

Company Registrars 
Link Asset Services 
34 Beckenham Road 
Beckenham 
Kent 
BR3 4TU 

Financial PR 
FTI Consulting 
200 Aldersgate
Aldersgate Street 
London 
EC1A 4HD

Design and production:
Navig8 
www.navig8.co.uk

136 

NAHL Group Plc Annual Report and Accounts 2021

NAHL Group Plc
Bevan House, Kettering Parkway, 
Kettering, Northamptonshire, NN15 6XR
Tel: +44 (0) 1536 527 500
Email: investors@nahl.co.uk 
Web: www.nahlgroupplc.co.uk

Annual
Report
2021